U.S. ENVIRONMENTAL PROTECTION AGENCY 

EPA NEW ENGLAND 

 RECORD OF DECISION 

AMENDEMNT 

EASTLAND WOOLEN MILL 

OPERABLE UNIT I

 SEPTEMBER 2006 
Record of Decision Amendment 

Table of Contents 

PART 1: THE DECLARATION 

A. SITE NAME AND LOCATION 

B. STATEMENT OF BASIS AND PURPOSE 

C. ASSESSMENT OF SITE 

D. DESCRIPTION OF SELECTED REMEDY 

E. STATUTORY DETERMINATIONS 

F. SPECIAL FINDINGS 

G. ROD DATA CERTIFICATION CHECKLIST 

H. AUTHORIZING SIGNATURES 

PART 2: THE DECISION SUMMARY 

A. SITE NAME, LOCATION AND BRIEF DESCRIPTION 

B. SITE HISTORY AND ENFORCEMENT ACTIVITIES 

1. History of Site Activities 

2. History of Federal and State Investigations and Removal and Remedial Actions 

3. History of CERCLA Enforcement Activities 

C. COMMUNITY PARTICIPATION 

D. SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION 

E. SITE CHARACTERISTICS 

F. CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES 

G. SUMMARY OF SITE RISKS 

1. Human Health Risk Assessment 

2. Ecological Risk Assessment 

3. Basis for Response Action 

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Corinna, Maine 
Record of Decision 

Table of Contents 

H. REMEDIATION OBJECTIVES 

I. DEVELOPMENT AND SCREENING OF ALTERNATIVES 

J. DESCRIPTION OF ALTERNATIVES 

K. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES 

L. THE SELECTED REMEDY 

M. STATUTORY DETERMINATIONS 

N. DOCUMENTATION OF NO SIGNIFICANT CHANGES 

O. STATE ROLE 

APPENDICES 

Appendix A: Tables and Figures not included in the text of the ROD 

Appendix B: State of Maine DEP Letter of Concurrence 

Appendix C: Responsiveness Summary 

Appendix D: Administrative Record Index 

Record of Decision Amendment - Operable Unit I Version: Final 

Eastland Woolen Mill Superfund Site Date: September 28, 2006 

Corinna, Maine 
Record of Decision Amendment 

Part 1 – The Declaration 

DECLARATION FOR THE RECORD OF DECISION AMENDMENT 

A. SITE NAME AND LOCATION 

Eastland Woolen Mill Superfund Site 

Corinna, Penobscot County, Maine 

MED980915474 

Site ID No: 0101043 

EPA Lead 

Operable Unit I 

B. STATEMENT OF BASIS AND PURPOSE 

This decision document presents an amendment to the September 19, 2002 Record of 

Decision (ROD) that identified the selected remedial action for Operable Unit I (OU I) at the 

Eastland Woolen Mill Superfund Site in Corinna, Maine (the Site), which was chosen in 

accordance with the Comprehensive Environmental Response, Compensation and Liability Act 

of 1980, as amended (CERCLA), 42 USC § 9601 et seq., and, to the extent practicable, the 

National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40 CFR Part 300, as 

amended. The Director of the Office of Site Remediation and Restoration (OSRR) of the United 

States Environmental Protection Agency (EPA), Region 1 has been delegated the authority to 

approve this Record of Decision Amendment (ROD Amendment). 

This decision is based on the Administrative Record, which has been developed in 

accordance with Section 113(k) of CERCLA, and which is available for review at the Stewart 

Public Library, Corinna, Maine and at the EPA Region 1, OSRR Records Center at One 

Congress Street, Boston, Massachusetts during normal business hours. The Administrative 

Record Index (Appendix D to the ROD) identifies each of the items comprising the 

Administrative Record upon which the selection of the remedial action is based. In accordance 

with 40 C.F.R. §300.825(a)(2), this ROD Amendment will become part of the Administrative 

Record file. 

The State of Maine concurs with the selected remedy. 

C. ASSESSMENT OF THE SITE 

The response action selected in this ROD Amendment is necessary to protect the public 

health or welfare or the environment from actual or threatened releases of hazardous substances 

into the environment. 

D. DESCRIPTION OF THE SELECTED REMEDY 

This ROD Amendment changes the original remedy set forth in the ROD for OU I (2002 

OU I ROD) for the Site. Both the original 2002 remedy and amended remedy target the 

restoration of contaminated groundwater through treatment using the application of in-situ 

reagents. The amended remedy, however, eliminates the long-term groundwater extraction and 

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Corinna, Maine 
Record of Decision Amendment 

Part 1 - The Declaration 

treatment system and the enhanced flushing with surfactants or solvents components of the 

original remedy. 

Specifically, the OU I amended remedial action will include the following major components: 

• In-situ chemical oxidation of the source material in the deep overburden soil and the shallow 

and deep bedrock; 

• Application of biostimulants after the in-situ chemical oxidation program; 

• Connection of residences to the public water supply; 

• Implementation of institutional controls to restrict future groundwater use; 

• Long-term monitoring of site groundwater; and 

• Five-Year Reviews to ensure that the remedy remains protective of human health and the 

environment. 

The selected remedy addresses principal and low-level threat wastes at the Site by 

reducing the mass of contamination, including Dense Non-Aqueous Phase Liquid (DNAPL), in 

the soil and bedrock fractures to achieve groundwater restoration. 

E. STATUTORY DETERMINATIONS 

The selected remedy is protective of human health and the environment, complies with 

federal and state requirements that are applicable or relevant and appropriate to the remedial 

action (unless justified by a waiver), is cost-effective, and utilizes permanent solutions and 

alternative treatment (or resource recovery) technologies to the maximum extent practicable. 

The remedy also satisfies the statutory preference for treatment as a principal element of 

the remedy by reducing the toxicity, mobility, and volume of source materials comprising 

principal threats through in-situ chemical oxidation treatment. 

Because this remedy will result in hazardous substances remaining on-site above levels 

that allow for unlimited use and unrestricted exposure (and groundwater use restrictions are 

necessary), a review will be conducted within five years after initiation of remedial action to 

ensure that the remedy continues to provide adequate protection of human health and the 

environment. 

F. SPECIAL FINDINGS

 None. 

Record of Decision Amendment - Operable Unit I 2 Version: Final 

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Record of Decision Amendment

Part 1 - The Declaration

G. ROD DATA CERTIFICATION CHECKLIST

The following information is included in the Decision Summary section of this ROD

Amendment or is referenced to the 2002 OU I ROD when the language from the original 2002

OU I ROD did not require revision. Additional information can be found in the Administrative

Record file for this Site.

1. Chemicals of concern (COCs) and their respective concentrations.

2. Baseline risk represented by the COCs.

3. Cleanup levels established for COCs and the basis for the levels.

4. How source materials constituting principal threats are addressed.

5. Current and reasonably anticipated future land assumptions and current and

potential future beneficial uses of groundwater used in the baseline risk

assessment and ROD Amendment.

6. Potential land and groundwater use that will be available at the Site as a result of

the selected remedy.

7. Estimated capital, operation and maintenance (O&M), and total present worth

costs; discount rate; and the number of years over which the remedy cost

estimates are projected.

8. Key factor(s) that led to selecting the remedy, including a description of how the

selected remedy provides the best balance of tradeoffs with respect to the

balancing and modifying criteria and highlighting criteria key to the decision.

H. AUTHORIZING SIGNATURES

This ROD Amendment documents the selected remedy for OU I at the Eastland Woolen

Mill Superfund Site. The State of Maine Department of Environmental Protection (ME DEP)

concurs with the selected remedy.

Concur and recommend for immediate implementation:

U.S. Environmental Protection Agency

By: &LQCUI 5\vd\\0\ Date:

Susan Studlien, Director

Office of Site Remediation and Restoration

EPA New England

Record of Decision Amendment - Operable Unit I 3 Version: Final

Eastland Woolen Mill Superfund Site Date: September 28, 2006

Corinna, Maine
Record of Decision 

Part 2 – The Decision Summary 

RECORD OF DECISION AMENDMENT SUMMARY 

A. SITE NAME, LOCATION AND BRIEF DESCRIPTION 

Eastland Woolen Mill Superfund Site 

Corinna, Penobscot County, Maine 

MED980915474 

Site ID No: 0101043 

EPA Lead 

Operable Unit I 

The Eastland Woolen Mill Superfund Site is located in the Town of Corinna, Penobscot 

County, Maine, approximately 6 miles north of Newport and 25 miles northwest of Bangor, 

Maine (Figure 1). Approximately 800 people live within one mile of the Site and 2,500 live 

within four miles. The Town of Corinna is located within the East Branch of the Sebasticook 

River (EBSR) watershed, which drains to Sebasticook Lake approximately three miles south of 

the Town. Topography within the watershed is typified by gently rolling hills to steeply sloping 

ridges, varying from narrow valleys to fairly expansive low-lying floodplains. Elevations within 

the immediate vicinity of Corinna range from 200 to 320 feet above mean sea level (msl). The 

former Eastland Woolen Mill straddled the EBSR and the southern portion of the former Mill 

Pond. 

The future land use assumptions for the 25 acre Site and surrounding areas are based on 

the Reuse Plan that was developed by the Town of Corinna. The large land area in the center of 

town, currently occupied by the Site, has been targeted for a mix of commercial, residential and 

mixed-use development. An expansion of the water supply has been implemented by the local 

water district to support future growth. The majority of the Site is available for re-use since the 

current cleanup program only occupies about three of the 25 acres covered by the Site. The 

available 22 acres are currently being marketed by the Town of Corinna. The back portion of the 

Site has already been brought into productive re-use. A 20 unit senior housing facility, Corundel 

Commons, opened on this portion of the Site in February 2006. 

A more complete description of the Site can be found in Section 1 of the Focused 

Feasibility Study (FFS) Report released in May 2006. 

B. RATIONALE FOR ROD AMENDMENT 

On September 19, 2002 EPA, with the concurrence of the ME DEP, in accordance with 

the Comprehensive Environmental Response, Compensation and Liability Act of 1980, as 

amended (CERCLA), 42 USC § 9601 et seq., issued the ROD for OU I at the Eastland Woolen 

Mill Site. The 2002 OU I ROD included in-situ chemical oxidation (ISCO) and groundwater 

extraction and treatment as the approach to achieve restoration of the contaminated aquifer. The 

2002 OU I ROD also included the potential for the use of enhanced flushing solvents/surfactants) 

in addition to the ISCO program. A long-term groundwater extraction and treatment system was 

included in the 2002 OU I ROD to limit migration of the contaminated groundwater, prevent 

contaminated groundwater from having an adverse impact on the benthic community in the 

EBSR, and facilitate the restoration of the aquifer after the completion of the ISCO program. 

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Part 2- The Decision Summary 

The 2002 OU I ROD was written prior to the completion of the non-time-critical removal action 

(NTCRA) that commenced in 1999. Therefore, the impact of the NTCRA-related excavation 

and treatment of the contaminated overburden source areas was uncertain at the time of the 

ROD. Subsequent to the signing of the 2002 OU I ROD and the completion of the NTCRA 

excavation and treatment program, EPA performed assessment monitoring of the groundwater. 

EPA also developed an improved conceptual site model through additional hydro-geologic 

investigations and groundwater modeling. The primary results of the investigations and 

monitoring from 2002 – 2005 are presented below: 

• The groundwater plume was found to be receding as a result of the NTCRA cleanup 

activities and the connection of certain water supply wells to the Corinna Water District 

water line. This eliminated the major pumping stresses that were influencing the expansion 

of the groundwater contamination. Since the groundwater was no longer expanding, 

containment of the groundwater to prevent expansion was no longer necessary. The 

institutional controls that are being developed as part of the OU I Remedial Action will 

prevent the re-use of the water supply wells that could cause the area of groundwater 

contamination to expand. 

• Monitoring of the groundwater and surface water indicates that the EBSR is not being 

impacted by the groundwater contamination; therefore the benthic community in the EBSR is 

no longer threatened by the Site contamination. An assumption of the 2002 OU I ROD was 

that the EBSR may be impacted by the discharge of contaminated overburden groundwater. 

Prior to the NTCRA, contaminated groundwater contributed to severe ecological impacts in 

the EBSR. The EBSR was relocated as part of the NTCRA and the combined benefit of the 

relocation of the EBSR and elimination of the majority of the source contamination was not 

known at the time of the 2002 OU I ROD. To assess the potential for impacts to the EBSR 

after completion of the soil excavation and ex-situ treatment phase of the NTCRA, 

groundwater samples were collected from a series of piezometers installed within the EBSR 

channel. One sample collected from a piezometer located adjacent to Area 1 contained 

chlorinated benzene compounds at concentrations less than the federal and state drinking 

water standards. In addition, samples collected from piezometers installed within the base of 

the river did not contain detectable concentrations of chlorinated benzene compounds. 

• Groundwater modeling based on the most updated Site information revealed that the time 

frame to achieve aquifer restoration without a groundwater extraction and treatment system 

was only slightly longer than the time frame with the groundwater extraction and treatment 

system. The time frame to achieve aquifer restoration has two components. The first 

component is the removal of the principal threat source material through the ISCO and 

biological enhancements. This first component is identical in both the original 2002 OU I 

ROD remedy, identified as GW-4 in the FFS, and the amended OU I remedy, identified as 

GW-4a in the FFS. The second component of the restoration is the aquifer recovery through 

long-term natural attenuation processes, either facilitated by groundwater extraction, as 

included in Alternative GW-4, or through non-active processes, as included in Alternative 

GW-4a. The time frame for the source removal under both Alternative GW-4 and GW-4a is 

estimated at 15 years. Subsequent to the 15 year period required for source removal, an 

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Corinna, Maine 
Record of Decision 

Part 2 – The Decision Summary 

additional 15 to 60 years is estimated to be necessary to achieve full aquifer restoration for 

Alternative GW-4 with the use of long-term groundwater extraction and treatment. This 

results in an estimated range for the cleanup of 30 to 75 years, with 60 years being selected in 

the FFS as a reasonable estimate for the basis of alternative comparison and cost evaluation. 

For Alternative GW-4a, without the use of long-term groundwater extraction and treatment, 

the estimated time period to achieve aquifer restoration is 30 to 74 years, resulting in a 

cleanup range of 45 to 89 years and with 80 years being selected as a reasonable estimate for 

the basis of alternative comparison and cost evaluation. 

• The 20 year time difference between GW-4 and GW-4a is not considered significant for the 

following reasons: 

o The groundwater plume that will remain after the NTCRA and ISCO programs is 

located under roadways and greenspace within an area where groundwater use is 

prohibited and a water line is available. There is therefore minimal potential for 

human consumption of the groundwater during the additional 20 years. 

o The time frame estimates were developed using the information available and are 

considered reasonable for alternative comparison; however, there is substantial 

uncertainty associated with these estimates. The actual difference in time frame for 

aquifer restoration could therefore be much smaller than estimated. 

• The pilot testing and initial applications of the oxidizing reagent, persulfate, supports the 

conclusion that this technology would be appropriate for use in the deep bedrock. Therefore, 

EPA does not expect to use the enhanced flushing with surfactants or co-solvents as a 

cleanup technology for OU I. 

Based on the above information, EPA decided to amend the 2002 OU I ROD to eliminate 

the groundwater extraction and treatment system as well as the enhanced flushing component 

with surfactants or co-solvents in order to achieve the remedial action objectives and cleanup 

goals in a more cost effective manner. An updated cost estimate for original OU I remedy, GW4, and a cost estimate for the amended remedy, GW-4a, was developed as part of the FFS. 

Alternative GW-4 has an estimated present worth of $10.5 million as compared with the 

estimated present worth of GW-4a of $4.5 million. Further, the projected total cost (not adjusted 

for present value) for GW-4 is $20.8 million as compared with $6.5 million for GW-4a. 

Therefore, GW-4a with a $6 million lower present value and $14.3 million lower total cost is the 

most cost effective alternative, given that GW-4a provides a similar level of protection of human 

health and the environmental and compliance with ARARs. 

The amended OU I Remedial Action will achieve the original OU I remedial action 

objectives and cleanup goals and will be equally protective of human health and the 

environment. In addition, the elimination of the long-term groundwater extraction and treatment 

system substantially reduces the financial burden to the State of Maine and provides additional 

area for re-use at the Site. 

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Record of Decision Amendment 

Part 2- The Decision Summary 

 Table 1 listed a comparison of the original 2002 OU IROD components and the ROD 

amendment. 

Table 1 

2002 OU I ROD ROD Amendment 

Extraction and treatment of the contaminated overburden Long-term extraction and treatment is not included in the 

and bedrock groundwater. The extraction system will be amended Remedial Action. 

designed to prevent off-site migration of contaminated 

groundwater and restore the aquifer to federal and state 

MCLs, federal non-zero MCLGs and more stringent state 

MEGs. 

In-situ treatment of the contaminated overburden and In-situ treatment of the contaminated overburden and 

bedrock groundwater and remaining areas of bedrock groundwater and remaining areas of 

contaminated soil/DNAPL. A chemical reagent (e.g., contaminated soil/DNAPL. A chemical reagent (e.g., 

Fenton=s Reagent or another oxidizing agent) will be Fenton=s Reagent or another oxidizing agent) will be 

added to the overburden and bedrock aquifer to reduce added to the overburden and bedrock aquifer to reduce 

the mass of contaminants in the system. If the mass the mass of contaminants in the system. If the mass 

reduction is not sufficient to achieve cleanup levels, then reduction is not sufficient to achieve cleanup levels, then 

enhanced flushing (using surfactants/solvents) and biological degradation (using bio-stimulants) will be 

biological degradation (using bio-stimulants) will be attempted to further reduce the mass of contamination. 

attempted to further reduce the mass of contamination. Enhanced flushing with surfactants/solvents is not 

included in the amended Remedial Action. 

Connection of certain residences to the water supply Connection of certain residences to the water supply 

lines to prevent their wells from becoming contaminated lines to prevent their wells from becoming contaminated 

and to prevent expansion of the contamination in the and to prevent expansion of the contamination in the 

groundwater. groundwater. 

Implementation, monitoring and maintenance of Implementation, monitoring and maintenance of 

institutional controls (i.e., deed restrictions) in the form institutional controls (i.e., deed restrictions) in the form 

of groundwater use restrictions (e.g., easements or of groundwater use restrictions (e.g., easements or 

restrictive covenants) to prevent ingestion of restrictive covenants) to prevent ingestion of 

groundwater and disturbance of the groundwater groundwater and disturbance of the remedy. 

extraction and treatment system. 

Long-term monitoring of groundwater, surface water and Long-term monitoring of groundwater, surface water and 

sediments to evaluate the success of the remedial action. sediments to evaluate the success of the remedial action. 

Implementation of five-year reviews to assess the Implementation of five-year reviews to assess the 

protectiveness of the remedy until cleanup goals have protectiveness of the remedy until cleanup goals have 

been met. been met. 

This ROD Amendment and the documents that form the basis for the Amendment are 

available at the following information repositories: 

EPA Records Center 

One Congress Street, Suite 1100 

Boston, MA 02114-2023 

(617) 918-1459 

Hours: 10 a.m. to noon and 2 p.m. to 5 p.m. 

Stewart Public Library 

8 Levi Stewart Drive 

Corinna, ME 04928 

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OU I Record of Decision Amendment 

Part 2: The Decision Summary 

C. SITE HISTORY AND ENFORCEMENT ACTIVITIES 

1. History of Site Activities 

The Eastland Woolen Mill operated a textile mill in Corinna, Maine from about 1909 to 

1996. Liquid wastes were discharged directly into the EBSR until 1972, when the liquid wastes 

were sent to the local sewage treatment plant. In 1983, local water supplies were found to be 

contaminated with chlorinated benzene compounds released by the Eastland Woolen Mill. As a 

result of this contamination, five locations were fitted with carbon filters in 1983. This number 

increased to ten locations by 1988. In 1995, a water line was installed to serve the properties with 

contaminated water supplies. From 1984 to 1995, the Eastland Woolen Mill performed a series of 

environmental assessments. The Eastland Woolen Mill ceased to operate in 1996. All of the 

equipment and land were either sold at a creditor auction or taken by the Town of Corinna to 

address tax liability. Please refer to the 2002 OU I ROD and the associated OU I remedial 

investigation and feasibility study (RI/FS) for a more detailed history of Site activities prior to the 

2002 OU I ROD. A detailed description of the Site operating history can also be found in Section 

1 of the OU I RI Report and Section 1.3 of the FFS Report. 

2. History of Federal and State Investigations and Removal and Remedial 

Actions 

After the closure of the Eastland Woolen Mill, the State of Maine performed a response 

action in 1997 to remove hazardous materials from the former mill buildings. The State of Maine 

also provided technical and financial support to maintain the Corinna Water District after closure 

of the mill. In 1998, EPA began investigation activities at the Eastland Woolen Mill. In July 

1999, EPA placed the Eastland Woolen Mill site on the National Priorities List and signed an 

Action Memorandum to begin a Non-Time-Critical Removal Action (NTCRA) to address the 

primary source of the contamination in groundwater, surface water, and sediment. From 1999 to 

2002, EPA performed the RI/FS for the Eastland Woolen Mill. In September 2002, EPA signed a 

ROD for OU I of the Eastland Woolen Mill Superfund Site to address contaminant source 

material remaining after the NTCRA, as well as the associated groundwater contamination. The 

OU I RI/FS also identified and designated sediment and associated floodplain areas of the EBSR 

as well as the old dump as a second operable unit (OU II) for the Site. Please refer to the 2002 

OU I ROD and the associated OU I RI/FS for more detail regarding the history of federal and 

state Investigations and Removal and Remedial Actions prior to the 2002 OU I ROD. Subsequent 

investigations and response actions are described in Section 1 of the FFS. A brief summary of the 

federal and state response actions since the OU I ROD was issued is presented below. 

During the period from September 2002 through September 2006 there were three major 

categories of activity at the Site. These are: 

• Completion of the Operable Unit II (OU II) RI/FS and the associated ROD; 

• Completion of the NTCRA; and 

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Part 2- The Decision Summary 

• Completion of the pre-design and design activities for the OU I Remedial Action, 

initiation of the Remedial Action, and construction completion of the Remedial 

Action. 

Each of these activities will be summarized below. See Figure 2 for the general location of 

the NTCRA, OU I, and OU II areas of the Site. 

(a) Operable Unit II Remedial Investigation/Feasibility Study and Operable Unit II Record of 

Decision 

In September 2002, EPA created OU II to address the sediment and associated floodplain 

areas of the EBSR downstream of NTCRA excavation, as well as an area of solid and liquid 

waste disposal known as the old dump. The OU I RI included the entire Site (both the OU I and 

OU II area) in the Human Health Risk Assessment. The Human Health Risk Assessment for OU 

I/OU II did not identify any unacceptable threats to human health from current or future use of the 

OU II areas. The current and future use assumptions in the Human Health Risk Assessment were 

based on non-residential recreational activities (swimming, hunting, fishing). The OU I RI did 

identify the potential for impacts to ecological receptors in the OU II area. During 2002 and 

2003, EPA performed a series of studies to better define the potential for ecological impacts in the 

OU II area. Surface water, sediment, floodplain soil, and crayfish tissue samples were collected, 

and biological assessments of the benthic macro-invertebrate community were performed. The 

information from these studies was presented in a Supplemental RI Report. The information was 

also combined with the initial RI data to prepare a revised Baseline Ecological Risk Assessment 

Report that found there was no unacceptable risk to ecological receptors in the OU II area. Both 

reports were released in 2004 as part of the Administrative Record and were available for review 

during the public comment period for the OU II Proposed Plan. On September 30, 2004, EPA 

signed a ROD selecting No Further Action for OU II of the Site. EPA activities in the OU II 

Study Area are complete, and no further activities are anticipated. 

(b) Non-Time Critical Remedial Action 

In July 1999, EPA signed an Action Memorandum to initiate the NTCRA at the Site. 

Beginning in 1999, EPA retained the United States Army Corps of Engineers (USACE) to 

implement the NTCRA. The USACE retained Weston Solutions, Inc. (Weston) as the prime 

contractor to perform the NTCRA cleanup activities. The NTCRA has included the removal of 

the mill buildings (performed during the winter of 1999-2000) and contaminated soils from four 

areas (performed from 2000-2001). NTCRA work areas are described below and shown in Figure 

2: 

• Area 1: Region underlying former Eastland Woolen Mill Buildings 1, 1A, and 3 extending 

across the former location of Main Street (Route 7), and including the segment of the EBSR 

beneath the former Eastland Woolen Mill and extending across the former Main Street. The 

contaminated soil in this area was removed in 2001. 

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OU I Record of Decision Amendment 

Part 2: The Decision Summary 

• Area 2: Segment of ESBR down river from the former Eastland Woolen Mill to the 

abandoned railroad trestle. The contaminated soil and sediment in this area was removed in 

2000. 

• Area 2a: Segment of EBSR under the abandoned railroad trestle between Area 2 and Area 3. 

The contaminated soil and sediment in this area was removed in 2000. 

• Area 3: Segment of EBSR for a distance of several hundred feet beyond the railroad trestle. 

The contaminated soil and sediment in this area was removed in 2000. 

• Area 4: Lot 88, Building 9, UST Area, Building 14 Area, and other miscellaneous areas. 

The initial contaminated soil removal for these areas occurred in 2000 and 2001. 

Additional contaminated soil removal for the Building 14 Area was performed in 2005. During 

2000 and 2001 approximately 75,000 yd3

 of chlorinated-benzene contaminated soils were 

excavated and stockpiled at the Site in lined containment structures. 

In 2001, pilot testing of an on-site thermal soil treatment system was performed. The 

results of this pilot test indicated that the treatment system could meet the treatment goals 

established for the NTCRA. Full-scale treatment of contaminated soil using an on-site ex-situ 

low temperature thermal system began in October 2002 and was completed in October 2003. 

Quality control testing of the soil after treatment documented that all of the soil that was used for 

on-site backfill contained residual levels of contamination below residential cleanup standards 

and met the NTCRA groundwater leaching criteria that were developed during the NTCRA. 

Table 2 contains a summary of the data collected as part of the ex-situ treatment program. 

Table 2 

NTCRA Soil Cleanup Summary 

Summary Statistics for Soil Excavated and Subject to Treatment 

Contaminant 95% Upper 

Confidence Level 

Concentration of soil 

prior to treatment 

(ug/kg) – based on 

100 soil samples 

95% Upper 

Confidence Level 

Concentration of soil 

used as backfill after 

treatment 

(ug/kg) based on 

4,200 soil samples 

Soil concentration 

that allows for 

residential use -

direct contact with 

of soil (ug/kg) 

Soil concentration 

that was determined 

to be protective of 

groundwater 

(ug/kg) (dependent 

upon soil organic 

carbon content) 

1,2,4 

Trichlorobenzene 

92,070 4,451 540,000 3,900 – 8,000 

1,2,3 

Trichlorobenzene 

25,955 1,408 

1,2 Dichlorobenzene 17,091 610 370,000 4,700 – 4,900 

1,3 Dichlorobenzene 1,427 285 16,000 4,300 – 4,800 

1,4 Dichlorobenzene 12,279 563 3,400 3,400 – 3,800 

Chlorobenzene 3,938 169 150,000 3,300 – 3,600 

To support the NTCRA excavation and thermal treatment activities, a temporary 

groundwater extraction and treatment system was constructed to aid in control of groundwater 

infiltration during excavation activities. One bedrock well and four overburden wells were 

connected to the temporary groundwater extraction and treatment system. The system remained 

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Part 2- The Decision Summary 

operational until November 2004 to provide hydraulic control over the groundwater plume during 

the initial phase of the NTCRA. Since 2004, the temporary groundwater extraction and treatment 

system has been operated as necessary to support the NTCRA in-situ oxidation program. 

Details concerning the NTCRA excavation and thermal treatment program are presented 

in the Final Completion Report, Areas 2, 3, 4-Lot 88, and 4-Building 4 Soil Remediation NTCRA, 

Eastland Woolen Mill Superfund Site, Corinna, Maine, Weston Solutions, Final Completion 

Report Areas 2,3,4-Lot 88 and 4-Building 4 Soil Remediation Non-time Critical Removal Action, 

Eastland Woolen Mill Superfund Site, Corinna, Maine, June 2001; Weston Solutions, Final 

Completion Report Areas 1 and 4 Soil Remediation Non-time Critical Removal Action, Eastland 

Woolen Mill Superfund Site, Corinna, Maine, June 2001. 

NTCRA In-Situ Treatment Program 

Three areas of contaminated soil were not accessible to the NTCRA excavations. One 

area was located within Area 1 and the other two were within the Area 4 UST Area and Building 

14 Area. These areas are shown in Figure 3. These remaining soils are located in the saturated 

zone between depths of 6 to 40 ft below ground surface (bgs). The final phase of the NTCRA 

targeted the reduction of contamination in these source areas using in-situ chemical oxidation 

(ISCO). EPA also retained the USACE to implement this component of the NTCRA. USACE 

retained Nobis Engineering, Inc. as the lead contractor for the remaining NTCRA activities. 

An ISCO Pilot Study was performed to identify the optimal oxidant technology for use in 

the NTCRA ISCO program. In the Spring and Summer of 2004, Nobis installed 23 ISCO injector 

wells in Area 1 to depths ranging from 35 to 40 ft bgs. Following injector installations, a fieldscale pilot study was performed by a subcontractor to Nobis, Xpert Design and Diagnostics 

(XDD), and Nobis in November 2004. The pilot study was designed to evaluate effectiveness of 

two potential oxidant technologies, Fenton’s reagent and iron-catalyzed sodium persulfate (ICP). 

The Fenton’s Study Area consisted of injecting 10,000 gallons of sulfuric acid and 11,534 gallons 

of hydrogen peroxide into two injection wells. The Persulfate Study Area consisted of injecting 

5,580 gallons of persulfate and chelated Fe+2 catalyst into two injection wells. 

The results of this pilot study indicated that ICP achieved superior subsurface distribution 

relative to Fenton’s reagent due to its longer reaction half-life. Based on post-pilot study soil 

sampling, a 48% total mass reduction was estimated over the pilot study area. Based on these 

results, ICP was selected as the oxidant for full-scale treatment application for the NTCRA ISCO 

program. The NTCRA ISCO Pilot Study was also incorporated in the Remedial Design for the 

OU I ISCO program that was occurring simultaneously with the final phase of the NTCRA, and 

resulted in the selection of ICP as the oxidant technology for the OU I Remedial Action ISCO 

programs. 

The NTCRA ISCO Program consisted of two work areas: Phase I, which included the 

contaminated soil associated with the former UST Area and Building 14 Area; and Phase II, 

which included the contaminated soil associated with Area 1. These work areas are shown in 

Figure 3. 

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Phase I Activities 

Following demolition of Building 14 by the Town of Corinna in 2004, a limited 

excavation was undertaken by Weston adjacent to the former loading dock to remove a small 

quantity of contaminated soil that was present in the vadose zone adjacent to the loading dock. 

The excavation did not extend below the water table. Analytical results for confirmation soil 

samples collected from base of the excavation indicated contaminated soil remained in-place at 

depths below the water table (approximately 6 ft bgs). 

In Spring 2005, Nobis installed 20 injector wells in the UST Area and the former Building 

14 Area to depths ranging from 15 to 30 ft bgs. ISCO treatment consisted of two full-scale 

injections of ICP, followed by confirmatory soil borings and groundwater sampling. These 

injections were performed in July and October/November 2005. A total of 13,319 gallons of 

persulfate solution (22,120 lbs of oxidant) and 13,514 gallons of chelated iron solution were 

delivered to the UST Area and Building 14 Area. Confirmatory soil borings and groundwater 

sampling indicated an approximate 90% reduction of dissolved phase contamination and an 

approximate 71% reduction in sorbed phase soil contamination following the Phase I ICP 

applications. The Phase I Task Plan and the Chemical Oxidation Phase I ISCO Work Plan 

describe in detail the activities that were performed to complete the NTCRA source reduction in 

this area. The 2005 Phase I and Phase II ISCO Remedial Performance Assessment documents 

that the ISCO has been successful in reducing the mass of contamination in the Phase 1 Area. 

The NTCRA for the Phase 1 Area is complete. The OU I Remedial Action will include long-term 

monitoring of the Phase I Area to confirm whether groundwater restoration is achieved. 

Phase II Activities 

In August 2005, Nobis and XDD performed one full-scale round of Phase II ISCO treatment 

for Area 1. ICP was delivered to the subsurface via 11 ISCO injector wells. Approximately 

19,256 gallons of persulfate (31,947 lbs of oxidant) and 19,423 gallons of chelated iron solution 

(2,429 lbs) were delivered to the Phase II treatment area. Confirmatory groundwater sampling 

performed following full-scale ISCO application indicated a reduction of dissolved phase 

contamination by approximately 63%. Soil sampling performed following the ISCO Pilot study 

indicated a 38% reduction in residual DNAPL contamination. The Phase II Task Plan and Phase 

II Full Scale ISCO Injection Plan - Application #1 describe the activities that were performed to 

further the completion of NTCRA source reduction in this area. The “2005 Phase I and Phase II 

ISCO Remedial Performance Assessment Eastland Woolen Mill Superfund Site, Non-Time 

Critical Removal Acion, Corinna, Maine, May 2006” documents that the ISCO has been 

successful in reducing the mass of contamination in the Phase II Area. The Phase II program will 

continue as part of the OU I Remedial Action. 

(c) OU I Remedial Design, and Remedial Action 

The 2002 OU I ROD was issued to address overburden and bedrock groundwater and 

remaining areas of contaminated soil/DNAPL and restore the aquifer to federal and state MCLs, 

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federal non-zero MCLs and more stringent state MEGs. The OU I remedy targeted the 

restoration of contaminated groundwater through treatment using both extraction and ex-situ 

treatment and the application of in-situ reagents. Treatment of the groundwater will be 

accomplished in two ways: (1) groundwater will be extracted from the ground and treated to 

reduce the concentration of contaminants to levels that are protective of human health and the 

environment and achieve the applicable criteria for discharge into either the EBSR or the 

groundwater; and (2) in-situ reagents will be used to facilitate the removal of contamination (via 

in-situ oxidation and in-situ surfactant addition, in combination with the addition of biostimulants as a polishing step). Institutional controls will restrict the future use of the Site to 

prevent ingestion of groundwater and disruption of the groundwater extraction and treatment 

system. This cleanup approach is expected to control the off-site migration of contaminated 

groundwater and restore the aquifer to drinking water standards. 

OU I also targets the soil contamination remaining after the NTCRA ex-situ and in-situ 

soil treatment programs. The soil excavation and ex-situ soil treatment program conducted under 

the NTCRA removed all soil contamination above the water table and most soil contamination, 

including the DNAPL below the water table, except in a few areas under the former Eastland 

Woolen Mill complex, the UST Area and Building 14 Area that were not accessible during the 

NTCRA. The in-situ ISCO program performed as part of the NTCRA completed the source 

reduction in the UST Area and Building 14 Area and reduced the source material in Area 1 of the 

Site. The OU I ISCO program will target the remaining contaminated soils and DNAPL located 

in Area 1 of the Site that acts as a continuing source of groundwater contamination. The OU I 

program will also include long-term assessment of the Building 14 Area and UST Area to confirm 

that the NTCRA source reduction was successful. Figure 4 shows the area that will be the focus 

of OU I Remedial Action. 

Specifically, the 2002 OU I ROD includes the following major components: 

$ Extraction and treatment of the contaminated overburden and bedrock groundwater. The 

extraction system will be designed to prevent off-site migration of contaminated 

groundwater, prevent contaminated groundwater from having an adverse impact on the 

benthic community in the EBSR, and restore the aquifer to federal and state MCLs, 

federal non-zero MCLGs and more stringent state MEGs. 

$ In-situ treatment of the contaminated overburden and bedrock groundwater and remaining 

areas of contaminated soil and DNAPL. A chemical reagent (e.g., Fenton=s Reagent or 

another oxidizing agent) will be added to the overburden and bedrock aquifer to reduce 

the mass of contaminants in the system. If the mass reduction is not sufficient to achieve 

cleanup levels, then enhanced flushing (using surfactants/solvents) and biological 

degradation (using bio-stimulants) will be attempted to further reduce the mass of 

contamination. 

$ Connection of certain residences to the water supply lines to prevent their wells from 

becoming contaminated, and to prevent expansion of the contamination in the 

groundwater. 

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$ Implementation, monitoring and maintenance of institutional controls (i.e., deed 

restrictions) in the form of groundwater use restrictions (e.g., easements or restrictive 

covenants) to prevent ingestion of groundwater and disturbance of the groundwater 

extraction and treatment system. 

$ Long-term monitoring of groundwater, surface water and sediments to evaluate the 

success of the remedial action. 

$ Implementation of five-year reviews to assess the protectiveness of the remedy until 

cleanup goals have been met. 

The selected remedy addresses principal and low-level threat wastes at the Site by both 

reducing the mass of contamination, including DNAPL, in the soil and bedrock fractures and 

containing and treating the contaminated groundwater to achieve groundwater restoration. 

The Remedial Design for the OU I Remedial Action was initiated in 2003 and completed 

in August 2005. Two components of the OU I Remedial Action were not included in the design: 

design of a long-term groundwater extraction and treatment system and the enhanced flushing 

(using surfactants or solvents) of the deep bedrock aquifer. Remedial Design was implemented in 

close coordination with the final phase of the NTCRA ISCO program since both programs relied 

on ISCO to reduce the mass of contamination in the overburden soil and bedrock. As such, the 

NTCRA design support activities and the Remedial Design support activities are complementary. 

As referred to in the previous NTCRA description, a series of additional studies and 

investigations were performed between 2003 and 2005 to develop the design for the NTCRA 

ISCO program and the in-situ treatment portion of the OU I Remedial Action. The results and 

conclusions of these investigations are summarized in the FFS and are reported in greater detail in 

the Conservative Interwell Tracer Test (CITT) Design, Conceptual Model Update Report, and the 

OU I Remedial Design Report. The studies and investigations performed to support the design 

activities included: 

• ISCO Pilot Study: The ISCO Pilot Study performed for the NTCRA ISCO program was 

incorporated in the Remedial Design for the OU I ISCO program and resulted in the selection 

of ICP as the oxidant technology for the OU I Remedial Action ISCO programs. 

• Bedrock Well Installations: Fifteen bedrock boreholes were drilled in Area 1. Bedrock 

fractures were characterized by borehole geophysics, and water samples were collected by 

packer methods. Shallow fracture DNAPL distribution and rock matrix properties were 

assessed by methanol extracted rock samples (MERC). These well locations provide 

characterization data for the Area 1 bedrock groundwater and contribute to the overall 

understanding of the bedrock fracture system and its behavior under pumping conditions. 

• Hydraulic Control Pump Test: In September 2004, a multi-well pump test was initiated 

utilizing six pumping wells (EW-2, EW-3, EW-4, EW-5, EW-6, and EW-7). During the test, 

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individual well flow rates were gradually increased or decreased depending on individual well 

responses. The pumping test was completed by October 2004, when the CITT/Electrical 

Resistivity Tomography (ERT) baseline was initiated. 

• Conservative Interwell Tracer Test (CITT): A CITT was designed and performed during 

October 2004 under forced gradient conditions to demonstrate that measurable flow paths 

exist within the aquifer. Data was used to evaluate dilution factors to verify the scale at which 

adequate minimum oxidant and surfactant concentrations could be maintained and to 

demonstrate sufficient aquifer connection at a scale suitable for treatment. 

• Partitioning Tracer Test (PITT): An initial PITT was designed and performed in conjunction 

with the CITT. This pilot-scale PITT was performed within the DNAPL source zone to assess 

the volume of DNAPL contacted within the swept aquifer volume. 

• Electrical Resistivity Tomography (ERT)/Induced Polarization (IP): ERT was completed prior 

to and in conjunction with the CITT to identify preferential pathways of saline solutions in the 

fracture system between individual boreholes. Selected IP profile panels were also 

completed. The selected IP profiles were completed to provide potential evidence for the 

presence or absence of DNAPL in weathered bedrock and potentially contaminated fractures. 

• Assessment Monitoring: Area-wide groundwater and drinking water sampling was 

implemented to evaluate and quantify the nature and extent of the overburden and bedrock 

contaminant plumes that remained after NTCRA activities. The results from the 2004 areawide sampling event are presented in the 2005 Area-Wide Groundwater Sampling Technical 

Memorandum. The results from the 2005 area-wide sampling results are presented in the 

spring 2006 Area-Wide Groundwater Sampling Technical Memorandum. 

• Bedrock wells to assess aquifer characteristics: Off-site bedrock borehole installations and 

groundwater pumping tests provided refined estimates of aquifer transmissivity and 

anisotropy at locations east of the EBSR. Results are presented in the Conceptual Model 

Update Technical Memorandum. 

• Groundwater Modeling: Groundwater flow and contaminant transport numerical model 

simulations assessed the long-term impacts of the bedrock contaminant plume under various 

potential future site conditions based on varying degrees of contaminant mass reduction. The 

modeling is described in the Institutional Control Zones Groundwater Modeling Report. 

• Long-Term Monitoring: A Long-Term Monitoring Plan (LTMP) was developed for future 

area-wide sampling to be performed for the evaluation of plume migration and impacts. 

• Institutional Controls and Water Line Connections: The results of the area-wide sampling and 

groundwater modeling were used to identify the properties that should be connected to the 

public water supply. The results were also used to finalize the extent of the institutional 

control zones (ICZ). 

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The information from the studies described above was used to develop the Remedial 

Design that was approved in August 2005 and to develop the implementation work plans for 

the OU I Remedial Action. 

The OU I Remedial Action was initiated in September 2005 with the installation of the 

first of the three water line connections. All of the water line connections have now been 

completed. The construction phase of the OU I Remedial Action also included the installation 

of the injection system for the OU I ISCO program as well as the long-term monitoring wells. 

Restrictive environmental covenants for the use of groundwater at the Site are being 

developed. All construction activities for the OU I Remedial Action were completed in 

September 2006 as documented in the Preliminary Close Out Report for the Eastland Woolen 

Mill Site. 

3. History of CERCLA Enforcement Activities 

Enforcement activities have been limited by the lack of viable potentially responsible 

parties (PRPs) at the Site. Eastland Woolen Mill ceased to operate in 1996. The family-owned 

company is now defunct (it ceased operations shortly after proposing a reorganization plan 

pursuant to Chapter 7 of the Bankruptcy Code), and most of its officers are deceased. 

The Site is currently owned by numerous entities, including the Town of Corinna and the 

State of Maine. The State acquired its title through eminent domain and abandonment, and the 

Town of Corinna acquired its title through tax foreclosure and an eminent domain taking. There 

is currently one private owner of a portion of the mill complex who acquired title at a creditor’s 

auction. 

EPA is continuing to investigate its enforcement options at the Eastland Woolen Site. 

D. COMMUNITY PARTICIPATION 

This ROD Amendment meets the criteria for community involvement specified in 

CERCLA Section 117 and in Sections 300.435(c)(2)(ii)(A) through (H) of the NCP. 

Throughout the EPA cleanup of the Site, community concern and involvement have been 

high. The local Selectboard actively sought EPA’s involvement at the Site to address the 

contamination left behind by the closure of the mill in 1996. EPA has kept the community and 

other interested parties informed of Site activities through informational meetings, fact sheets, 

press releases and public meetings. Information about the Site is posted on EPA’s website at 

http://www.epa.gov/ne/superfund/index2.htm. EPA has met regularly with the community and 

Selectboard to keep them informed and to seek their input regarding Site activities. The 

community has also benefited from a website (www.cattailpress.com), which was developed and 

is maintained by a local resident. The website contained daily photographs of Site activities 

during the NTCRA demolition and excavation activities and has provided a forum for community 

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dialogue regarding the Site. EPA’s public notices and fact sheets have been posted on this 

website as well. 

Below is a brief chronology of public outreach efforts subsequent to the 2002 OU I ROD: 

• In April 2003, March 2004, and February 2006, EPA released public information updates to 

keep the public informed of Site activities. 

• On April 30, 2003, EPA met with the community to provide an update of the NTCRA, OU I, 

and OU II activities. 

• In support of the cleanup decision for the OU II ROD, EPA implemented the following public 

involvement activities. Updates regarding the NTCRA and OU I cleanup were provided as 

part of these efforts: 

o On June 7, 2004, EPA met with the local organization, Sebasticook Committee for a 

Clean Environment (SCCE) to present the findings of the Ecological Risk Assessment 

and Supplemental RI for OU II. The SCCE is a recipient of a Technical Assistance 

Grant from EPA. EPA presented a description of the Supplemental RI and the results 

of the revised Baseline Ecological Risk Assessment to the SSCE, its Technical 

Advisors, and members of the public and news media at the meeting. 

o On June 30, 2004 EPA held an informational meeting to discuss the results of the RI 

Report, particularly the Supplemental RI and revised Baseline Ecological Risk 

Assessment, and to present the Agency=s Proposed Plan to a broader community 

audience than those that had already been involved at the Site. At this meeting, 

representatives from EPA answered questions from the public. 

o From July 13, 2004 to August 12, 2004, EPA held a 30 day comment period for the no 

further action proposal. 

o On August 10, 2004, EPA held a public hearing to receive oral comments regarding 

the no further action proposal. 

o In September 2004, EPA signed the ROD for OU II documenting that no further action 

was necessary in the OU II area. 

• On February 28, 2006, EPA participated in an open house for the Corundel Commons housing 

development where EPA provided an update of Site activities as part of the poster 

presentation at the open house. 

• In May 2006, EPA published a Proposed Plan to amend the 2002 OU I ROD. The Proposed 

Plan for the ROD Amendment asked for public comment on the proposal to eliminate 

groundwater extraction and treatment of deep bedrock groundwater and to eliminate enhanced 

flushing with surfactants or solvents of the aquifer. 

• On May 25, 2006, EPA held a public information meeting which was followed by a public 

hearing to accept comment on the Proposed Plan to amend the 2002 OU I ROD. 

• From May 25 to June 25, 2006 EPA held a thirty day public comment period for the proposal 

to amend the 2002 OU I ROD. 

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All formal comments are summarized and responded to in the Responsiveness Summary, 

which is included as Appendix C to this ROD Amendment. 

Pursuant to Section 300.825(c) of the NCP, EPA updated the Administrative Record in 

May 2006 to add the documents which EPA relied on to form the basis for the decision to amend 

the response action for 2002 OU I at the Eastland Woolen site. See Appendix D for the 

Administrative Record Index. 

E. SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION 

There are three cleanup actions at the Eastland Woolen Mill Site. The first cleanup action 

is the NTCRA that was authorized by an Action Memorandum signed in July 1999. The second 

is the remedy described in the 2002 OU I ROD and is the subject for this ROD Amendment. The 

third is the RI/FS and associated No Further Action decision for the OU II Study Area. The 

location of the areas affected by these actions is shown on Figures 1 and 2. The NTCRA is 

complete and the OU II ROD terminated EPA involvement in the OU II Study Area. The OU I 

ROD targets the groundwater contamination and the associated DNAPL and source 

contamination remaining after the NTCRA in the downtown area of Corinna. The OU I ROD 

includes treatment of the principle threat wastes and restoration of the overburden and bedrock 

aquifers. The ROD Amendment only adjusts the 2002 OU I Remedial Action to eliminate a 

component of the remedy that was determined not to be necessary and does not change the overall 

scope, role, or expected outcome in that restoration of groundwater will occur within a similar 

timeframe as the original ROD remedy without the need for long-term extraction and treatment of 

groundwater. Please refer to the 2002 OU I ROD for more details regarding the scope and role of 

the OU I Remedial Action. 

F. SITE CHARACTERISTICS 

Chapter 1 of the FS Report contains an overview of the RI Report and the general 

characteristics of the Site. The significant findings of the pre-design, design, and NTCRA 

activities performed after the 2002 OU I ROD are summarized below and are further presented in 

the FFS. Refer to the 2002 OU I ROD for a summary of the RI/FS for OU I. 

1. Soil and Bedrock Source Contamination 

Overburden materials in Area 1 consist of anthropogenic fill materials (treated and 

reworked site soil) overlying glacial till up to 26 feet thick. Underlying the glacial till is 

weathered bedrock (Waterville formation) which slopes generally to the east, towards the EBSR, 

and ranges in thickness from less than one foot to approximately ten feet. Underlying highly 

weathered bedrock is moderately competent to competent fractured bedrock. In the overburden 

system, a pocket of residual DNAPL resides in an area just outside the deepest portion of the 

NTCRA soil excavation (down to and including some of the weathered bedrock surface) adjacent 

to the relocated Main Street. Significant lateral and vertical variability exists in soil contaminant 

concentrations due to heterogeneity in the overburden. Within the bedrock system, residual 

DNAPL resides in weathered bedrock and competent rock (upper 100 feet) immediately below 

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the DNAPL entry area and the bottom of the NTCRA excavation. Under static (non-pumping) 

groundwater conditions, overburden groundwater flow is to the southeast where the groundwater 

discharges to the EBSR. Bedrock groundwater flow is upward to overburden and to the drainage 

divide created by the EBSR. 

There are two source areas that are the focus of the OU I Remedial Action. 

Area 1 Deep Overburden Soil 

The release of chlorinated benzenes at the Eastland Woolen Mill resulted in extensive 

contamination of saturated overburden soils and bedrock underlying DNAPL source areas. Two 

zones of DNAPL entry are presumed to exist in Area 1, based on the distribution of residual 

DNAPL saturations above bedrock and bedrock sample data collected during investigations 

performed in 2004. The more significant of the two areas is present within deep overburden till 

located along the southeastern edge of the former NTCRA Area 1 Excavation, and it is presumed 

to contain both residual and sorbed-contamination (contamination either adsorbed or absorbed 

onto soil particles). The residual- and sorbed-soil contamination in Area 1 soil exists at depths of 

approximately 31 to 41 feet bgs along the southeastern portion of the former Area 1 NTCRA 

excavation. Figure 4 shows the areas of remaining contamination in this area after the NTCRA 

excavation and ex-situ treatment program and Figure 5 shows a cross-section of the soil 

contamination remaining after the NTCRA. 

Bedrock DNAPL and Residual Contamination 

Chlorinated benzene compounds in pure form are DNAPLs and have the potential to 

migrate vertically downward through the water table regardless of the direction of groundwater 

flow. To account for the deep penetration of contamination in bedrock directly under the mill, the 

contamination had to migrate counter to the overall direction of bedrock groundwater flow. It is 

believed that deep penetration of DNAPL along fracture planes in bedrock underlying the Site 

accounts for the observed distribution of contamination. 

The results of MERC sampling indicate that diffusion of contaminant mass into the 

weathered bedrock matrix and oxidized bedrock adjacent to fractures is an important feature of 

the mass distribution within the bedrock system. The presence of high concentrations of 

chlorinated benzene compounds in the MERC data support the conclusion that DNAPL migration 

did occur down deep along specific bedding planes and vertical fractures, opposite of the upward 

flow direction of discharging bedrock groundwater. The MERC data also indicates that 

contaminant mass has diffused up to several feet from contaminated fractures into the fresh rock 

matrix. Compared to the mass in the oxidized rock matrix, this fresh matrix contaminant mass is 

a small component of residual mass. 

Diffusion coefficients of chlorinated benzene compounds are similar but vary an order of 

magnitude in solubility from 1,2,4-trichlorobenzene to monochlorobenzene. Extremely high 

groundwater concentrations for 1,2,4-trichlorobenzene approaching 30 to 50 percent of compound 

solubility were measured in a number of bedrock boreholes. This data, in addition to the MERC 

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data, suggests that limited amounts of DNAPL may still be present in specific fractures in the two 

regions of the fractured bedrock aquifer. 

In general, many of the high contaminant concentrations observed in groundwater and 

MERC data within the competent fractured bedrock may result from the backward diffusion of 

contamination from weathered rock matrix near fractures. Although rock porosity was not 

measured during this investigation, the weathered porosity adjacent to fractures has been 

measured at similar sites and may range from 1 to 5 percent. The total porosity in the rock matrix 

is assumed to be a combination of the weathered porosity along fractures, primary rock porosity 

(generally less than one-half to one percent) and open micro-fracture networks. 

Bedrock contaminant mass estimates were revised in 2005 as part of the Conceptual 

Model Update Report. The total estimated mass for the shallow bedrock (0-10 feet in depth) 

includes 5.4 kg of DNAPL and 120 kg of mass diffused in oxidized rock matrix adjacent to 

fractures. The total estimated mass for the deep fractured bedrock includes 14.5 kg of DNAPL, 

182 kg of mass diffused in oxidized rock matrix adjacent to fractures, and 16 kg of mass diffused 

into fresh rock matrix. Figure 6 shows the approximate extent of the bedrock contamination that 

will be targeted by the OU I cleanup. 

2. Groundwater Contamination 

Two regions of overburden groundwater containing Site-related dissolved-phase 

contamination at concentrations above federal and state drinking water criteria are present at the 

groundwater source area. One region is associated with shallow soil at the UST/Building 14 area 

(NTCRA Area 4), and the other with deep overburden soil at the former location of Buildings 1, 

1A, and 3 (NTCRA Area 1). Additionally, bedrock groundwater located directly under the 

former mill location is contaminated at concentrations in excess of MCLs/MEGs. These 

groundwater systems are described separately while recognizing that they are related because of 

interactions between bedrock, overburden and surface water systems. Figure 7 depicts the 

boundaries of the bedrock and overburden contaminant plumes in 2002 and 2006, as well as the 

regions of groundwater that contain site related contaminants in excess of federal and state 

drinking water criteria. 

Overburden Groundwater Plumes 

Area 1 Overburden 

Based upon data collected between 2004 and 2005, it appears that the groundwater flow 

direction (potentiometric surface) in Area 1 is heavily influenced by the operation of the 

temporary groundwater extraction and treatment system installed during the NTCRA. Under 

pumping conditions, the overburden groundwater in this area flows generally toward the NTCRA 

excavation and the temporary extraction wells. Under non-pumping/static conditions, the 

overburden groundwater flow in this area is toward the south/southeast and discharges to the 

EBSR approximately 135 feet from the eastern edge of soil excavation to bedrock. 

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Both a pilot-study and a full-scale application of ICP were completed in Area 1 between 

2004 and 2005. Samples of groundwater were collected prior to the full-scale application in order 

to evaluate the potential for contaminant “rebound” resulting from the mass reduction during the 

pilot test, as well as after the full-scale application in order to evaluate remedial success. Table 3 

provides a summary of the analytical results from the most recent Area 1 overburden groundwater 

sampling round that was conducted in November 2005 after the first full-scale ICP application. A 

select number of wells along with the major contaminants of concern area shown in Table 3 

below. 

Table 3 

Area 1 Overburden 

Groundwater Contamination 

OU I 

Compound 

Cleanup 

Levels IM-04-01 IM-04-09 P2-04-07 P2-04-09 P2-04-12R P2-04-27 

ug/L μg/L μg/L μg/L μg/L μg/L μg/L 

Benzene 5 6.6J 

CB 47 4,100 13,000 640 84 16J 2,300 

1,2-DCB 85 3,900 8,500 350 110 25 1,900 

1,3-DCB 85 150 260 12J 110 

1,4-DCB 27 2,600 7,000 270 100 21 2,000 

1,2,4-TCB 70 7,400 10,000 160 54 83 3,200 

An assumption of the 2002 OU I ROD was that the EBSR may be impacted by the 

discharge of contaminated overburden groundwater. Prior to the NTCRA, contaminated 

groundwater contributed to severe ecological impacts in the EBSR. The EBSR was relocated as 

part of the NTCRA, and the combined benefit of the relocation of the EBSR and elimination of 

the majority of the source contamination was not known at the time of the 2002 OU I ROD. To 

assess the potential for impacts to the EBSR after completion of the NTCRA soil excavation and 

ex-situ treatment program, groundwater samples were collected from a series of piezometers 

installed within the EBSR channel. One sample collected from a piezometer located adjacent to 

Area 1 contained chlorinated benzene compounds at concentrations less than their respective 

MCLs. In addition, samples collected from piezometers installed within the base of the river did 

not contain detectable concentrations of chlorinated benzene compounds. As a result of this data, 

EPA has concluded that the groundwater is not a threat to the EBSR. See Figure 7 for the extent 

of Area 1 groundwater contamination. 

UST Area and Building 14 Area 

Based upon data collected during 2004 and 2005, overburden groundwater within the 

Building 14 Area and UST Area is inferred to migrate toward and ultimately discharge to the 

EBSR, located approximately 270 to 340 feet to the west/southwest of the UST Area dissolved 

plume. 

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The OU I RI identified an area approximately 200 long and 50 feet wide of overburden 

groundwater containing contaminants above MCLs and MEGs. This dissolved contaminant 

plume is interpreted to be continuous between Building 14 Area and the UST Area based upon 

the direction of overburden groundwater flow. Groundwater sampling conducted in 2005 

following two full-scale ISCO applications to soil indicated that the groundwater contamination 

plume in the Building 14 Area and UST Area had retracted from the southwest towards the 

northeast to an area approximately 100 feet long and 40 feet wide. The groundwater 

contamination is primarily observed in shallow overburden groundwater and will be included in 

the long-term monitoring program. See Figure 7 for the location of the Building 14 Area and UST 

Area groundwater contamination. 

Bedrock Groundwater Plume 

An assumption of the 2002 OU I ROD was that containment was necessary for the 

bedrock groundwater contamination. Contamination has spread from the former Eastland 

Woolen Mill to water supply wells serving the Sunshine Village housing project. The 2002 OU I 

ROD included a groundwater extraction and treatment system to contain the bedrock plume. The 

bedrock groundwater system at the Site responds in a strongly anisotropic (non uniform) manner 

to groundwater pumping stresses because of the dominance of the bedding plane fracture network 

on groundwater movement. This high degree of anisotropy has allowed distant pumping stresses 

to pull deep and shallow bedrock groundwater outward from the source area if the pumping 

sources are aligned parallel to the source area along the direction of bedding plane fractures. 

A groundwater plume with high concentrations of chlorinated benzene compounds exists 

in bedrock groundwater to depths in excess of 300 feet bgs. In 2000, the bedrock plume was 

estimated to extend approximately 1,200 feet laterally along a southwest-northeast axis, and 

approximately 400 feet downgradient from the source area as described in the OU I FS. Based on 

area-wide sampling performed in 2004 and 2005, the bedrock plume is believed to have receded 

and is now estimated to extend 240 feet laterally (reduced from 1,200 feet in 2000) along a 

southwest-northeast axis and approximately 230 feet downgradient (reduced from 400 feet in 

2000) from the source area. Figure 7 depicts the former and current extents of the bedrock plume 

contamination and residual DNAPL. Based on the data collected since the 2002 OU I ROD, the 

bedrock plume discharges to overburden and surface waters and rapidly diminishes downgradient. 

The plume appears to be in a stable configuration with respect to downgradient migration and has 

receded when compared with results prior to 2004. The stability and reduction of the plume is 

enhanced by the removal of downgradient pumping stresses, such as the Sunshine Village well, 

and the removal of over 90% of the contaminant source material as part of the NTCRA. The 

groundwater monitoring data documents that the groundwater plume is contracting as a result of 

the combined impacts of the NTCRA and Remedial Action activities. 

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Maximum concentration of VOCs detected in bedrock groundwater above MCLs and 

MEGs are summarized in Table 4 below. 

Table 4 

Maximum Bedrock Groundwater COC Concentrations in Area 1 

Compound 

Benzene 

CB 

1,2-DCB 

1,3-DCB 

1,4-DCB 

1,2,4-TCB 

OU I Cleanup 

Levels 

(ug/L) 

5 

47 

85 

85 

27 

70 

BM-99-04F 

(ug/L) 

11 

13,000 

6,000 

380 

6,100 

3,700 

BM-04-37 

(ug/L) 

12 

18,000 

7,400 

240 

6,100 

3,500 

R-2 

(ug/L) 

1.7 

1,200 

770 

81 

890 

880 

3. Conceptual Site Model 

Refer to the 2002 OU I ROD for the full description of the Conceptual Site Model (CSM). 

The Amended ROD retains the focus on treating the principle threat wastes in the soil and 

bedrock, including DNAPLs. The pre-design, design, and preliminary implementation phases of 

OU I along with the activities performed to complete the NTCRA have further validated that the 

CSM for the Site presented in the 2002 OU I ROD was accurate. The only changes in the CSM 

since 2002 are: 

• The groundwater plume is not expanding, it is contracting. This is due to the source 

removal activities to date and the removal of the major pumping stresses in the area. 

• The contamination is no longer impacting the surface water of the East Branch of the 

Sebasticook River. The removal of the contaminated material and the hydrological 

changes resulting from relocating the river have eliminated the ecological impacts from 

contaminated overburden groundwater. 

F. CURRENT AND POTENTIAL FUTURE LAND AND RESOURCE USES 

Refer to the 2002 OU I ROD for the summary of current and potential future land uses. 

Since the 2002 OU I ROD was issued, Site soils have been excavated, treated to residential use 

levels and backfilled. The Reuse Plan for Corinna has been implemented, three residences have 

been connected to the public water line, and institutional controls prohibiting the use of 

groundwater have been developed but not yet implemented. One area of the Site has been 

redeveloped into a senior housing project, and a historic structure that was relocated has been 

renovated into a General Store and restaurant. The Town of Corinna is currently marketing 

several lots within the Site for reuse. Currently, 22 acres of the 25 acre Site that have been part of 

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the cleanup action are available for reuse. Figure 8 shows the areas that are currently available for 

re-use. 

G. SUMMARY OF SITE RISKS 

The 2002 OU I ROD included an assessment of the potential threats to human health in 

the OU I study area. Based on the Human Health Risk Assessment prepared as part of the RI and 

the 2002 OU I ROD, the only pathways that exceed EPA’s acceptable cancer risk range and/or a 

hazard quotient of concern are ingestion of groundwater in the overburden and bedrock plumes by 

a future resident. The lifetime cancer risk estimate for a combined child and adult exposure to the 

bedrock plume groundwater is 6 x 10-3. Seventy-five percent of this risk is due to arsenic, with 

twenty-five percent attributable to the 1,4-DCB. EPA’s hazard index of concern for noncarcinogenic risk is exceeded for children and adults for several target organs. The major 

contributors to these exceedances are chlorobenzene, 1,2-DCB, 1,3-DCB, 1,4-DCB, 1,2,4-TCB 

and arsenic. These COCs also were detected at concentrations above federal and state maximum 

contaminant levels (MCLs) and more stringent state maximum exposure guidelines (MEGs). 

The lifetime cancer risk estimates for the overburden plume groundwater is 2 x 10-3. 

Sixty-seven percent of this risk is attributable to 1,4-DCB, with arsenic contributing to the 

remainder of the cancer risk. EPA’s hazard index of concern for non-carcinogenic risk is 

exceeded for children and adults for several target organs. The major contributors to these 

exceedances are chlorobenzene, 1,2-DCB, 1,3-DCB, 1,4-DCB, 1,2,4-TCB and arsenic. These 

COCs also were detected at concentrations above federal and state MCLs and more stringent state 

MEGs. The Baseline Human Health Risk Assessment concluded that the estimated risk for the 

soils, surface water, or sediments within the OU I area do not represent an unacceptable threat to 

human health. Only groundwater represents a threat to human health. Soil contamination that is 

causing groundwater contamination is also relevant to the cleanup action. 

The groundwater beneath and surrounding the Site still remains a drinking water aquifer. 

Although data gathered since the 2002 OU I ROD was issued demonstrates that the groundwater 

plume has receded and contaminant mass is reduced, contaminant levels still exceed drinking 

water standards and ingestion of groundwater continues to pose a risk to human health consistent 

with the risks summarized above. 

The OU I ROD concluded that contaminant levels in surface waters, surface soils and 

sediments within the OU I area of the EBSR are not sufficiently elevated to pose a substantial risk 

to invertebrates, fish and wildlife through direct contact and dietary exposure to the Site-related 

COCs. Exposure to the contaminated water at the groundwater/surface water interface, however, 

was identified as an unacceptable risk to those organisms dwelling in this zone. Data gathered 

since the 2002 OU I ROD, however, demonstrate that the concentration of contaminants in the 

groundwater do not exceed the levels that have the potential for an unacceptable risk to organisms 

dwelling in the groundwater/surface water interface. Therefore, the successful implementation of 

the NTCRA and OU I remedy has eliminated this risk. 

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Refer to the 2002 OU I ROD for the complete presentation of the human health and 

ecological risks. 

Actual or threatened releases of hazardous substances from this Site, if not addressed by 

implementing the response action selected in this ROD, may present an imminent and substantial 

endangerment to public health, welfare, or the environment. 

H. REMEDIATION OBJECTIVES 

Based on preliminary information relating to the types of contaminants, environmental 

media of concern and potential exposure pathways, response action objectives (RAOs) were 

developed to aid in the development and screening of alternatives. These RAOs were developed 

to mitigate, restore and/or prevent existing and future potential threats to human health and the 

environment. The RAOs for the selected OU I Remedial Action remain the same and are 

repeated below: 

- Prevent the ingestion of groundwater containing contaminants that exceed federal or 

state MCLs, federal non-zero MCL Goals (MCLGs) and more stringent state MEGs, or in 

their absence, an excess cancer risk of 1 x 10-6 or a hazard quotient of 1; 

- Prevent, to the extent practicable, the off-site migration of groundwater containing 

contaminants at a concentration above Site cleanup levels; 

- Prevent, to the extent practicable, the discharge of groundwater containing contaminants 

at a concentration above levels that could impact ecological receptors to the East Branch 

of the Sebasticook River; 

- Restore groundwater to meet federal or state MCLs, federal non-zero MCLGs or state 

MEGs (whichever is most stringent), or in their absence, an excess cancer risk of 1 x 10-6 

or a hazard quotient of 1; and 

- Perform long-term monitoring of surface water, sediments and groundwater to verify that 

the cleanup actions at the Site are protective of human health and the environment. 

I. DEVELOPMENT AND SCREENING OF ALTERNATIVES 

1. Statutory Requirements/Response Objectives 

Under its legal authorities, EPA’s primary responsibility at Superfund sites is to undertake 

remedial actions that are protective of human health and the environment. In addition, Section 

121 of CERCLA establishes several other statutory requirements and preferences, including a 

requirement that EPA’s remedial action, when complete, must comply with all federal and more 

stringent state environmental and facility siting standards, requirements, criteria or limitations, 

unless a waiver is invoked; a requirement that EPA select a remedial action that is cost-effective 

and that utilizes permanent solutions and alternative treatment technologies or resource recovery 

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technologies to the maximum extent practicable; and a preference for remedies in which treatment 

that permanently and significantly reduces the volume, toxicity or mobility of the hazardous 

substances is a principal element over remedies not involving such treatment. Response 

alternatives were developed to be consistent with these Congressional mandates. 

2. Technology and Alternative Development and Screening 

CERCLA and the National Contingency Plan (NCP) set forth the process by which 

remedial actions are evaluated and selected. In accordance with these requirements, a range of 

alternatives were developed for the Site. 

With respect to the groundwater response action, the OU I RI/FS developed a limited 

number of remedial alternatives that attain Site cleanup levels within different time frames using 

different technologies, as well as a no-action alternative. The FFS incorporated the alternative 

development and screening step completed as part of the OU I RI/FS by reference. 

J. DESCRIPTION OF ALTERNATIVES 

This Section provides a narrative summary of the alternatives considered as part of the 

ROD Amendment Focused Feasibility Study (FFS). The FFS was prepared to evaluate the 

original OU I Remedial Action against the revised OU I Remedial Action. 

Alternative GW-1: No Further Action 

Alternative GW-1, the No Further Action alternative, was retained as a baseline with which to 

compare the other alternatives, as required by the NCP. This alternative would not include 

remedial action components beyond those already performed in the NTCRA to contain or reduce 

contaminant concentrations in groundwater. Nor would GW-1 control potential risks from 

exposure to contaminated groundwater by implementing institutional controls, extending the 

public water supply, or environmental monitoring. Site reviews would not be performed as part of 

this alternative. The NTCRA groundwater management system would be turned off and 

decommissioned upon completion of the NTCRA in 2006, and no further groundwater cleanup 

activities would occur at the Site. 

Capital Costs: none 

Present Worth of Long Term Monitoring:

None 

Alternative GW-4: Hydraulic Containment plus Mass Reduction (2002 OU I ROD 

Remedial Action)

Alternative GW-4 includes actions to hydraulically contain groundwater in the source area of the 

mill footprint, reduce contaminant mass contributing to the contamination of groundwater through 

chemical oxidation, extend the public water supply system to prevent ingestion of contaminated 

groundwater and plume expansion and migration, implement institutional controls to prevent 

exposure to contaminated groundwater, and perform environmental monitoring to assess 

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migration of contamination and potential human health risks from exposure to contaminated 

groundwater. Hydraulic containment of the Area 1 bedrock and overburden groundwater plumes 

would occur by extraction and treatment of bedrock and overburden groundwater from beneath 

the Site. These actions would accelerate clean up of groundwater to some degree, control plume 

migration and prevent discharge of contaminated groundwater to the EBSR in excess of 

concentrations that would pose potential ecological risk. 

Capital Costs: $6.9 million 

Total Present Value of Alternative GW-4: $10.5 million 

Estimated time to achieve groundwater restoration: 60 years. 

Alternative GW-4a: Mass Reduction without Active Hydraulic Containment 

Alternative GW-4a includes actions to reduce contaminant mass contributing to the contamination 

of groundwater through chemical oxidation and extends the public water supply system to prevent 

ingestion of contaminated groundwater and to prevent plume migration and/or address potential 

threats to human health. It also relies upon institutional controls and environmental monitoring to 

control potential human health risks from exposure to contaminated groundwater. These actions 

would accelerate clean up of groundwater, further control plume migration, and prevent discharge 

to the EBSR of groundwater with contaminant concentrations that would pose potential 

ecological risk. 

Capital costs: $3.54 million 

Present Value of Alternative GW-4a: $4.5 million 

Estimated time to achieve aquifer restoration: 80 years. 

K. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES 

Section l2l(b)(1) of CERCLA presents several factors that, at a minimum, EPA is 

required to consider in its assessment of alternatives. Building upon these specific statutory 

mandates, the NCP articulates nine evaluation criteria to be used in assessing the individual 

remedial alternatives. These criteria are summarized as follows: 

Threshold Criteria 

The two threshold criteria described below must be met in order for the alternatives to be 

eligible for selection in accordance with the NCP: 

1. Overall protection of human health and the environment addresses whether or not 

a remedy provides adequate protection and describes how risks posed through each 

pathway are eliminated, reduced or controlled through treatment, engineering 

controls, or institutional controls. 

2. Compliance with applicable or relevant and appropriate requirements (ARARs) 

addresses whether or not a remedy will meet all federal environmental and more 

stringent state environmental and facility siting standards, requirements, criteria or 

limitations, unless a waiver is invoked. 

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Primary Balancing Criteria 

The following five criteria are utilized to compare and evaluate the elements of one 

alternative to another that meet the threshold criteria: 

3. Long-term effectiveness and permanence addresses the criteria that are utilized to 

assess alternatives for the long-term effectiveness and permanence they afford, 

along with the degree of certainty that they will prove successful. 

4. Reduction of toxicity, mobility, or volume through treatment addresses the degree 

to which alternatives employ recycling or treatment that reduces toxicity, mobility, 

or volume, including how treatment is used to address the principal threats posed 

by the Site. 

5. Short-term effectiveness addresses the period of time needed to achieve protection 

and any adverse impacts on human health and the environment that may be posed 

during the construction and implementation period, until cleanup goals are 

achieved. 

6. Implementability addresses the technical and administrative feasibility of a 

remedy, including the availability of materials and services needed to implement a 

particular option. 

7. Cost includes estimated capital and Operation and Maintenance (O&M) costs, as 

well as present-worth costs. 

Modifying Criteria 

The modifying criteria are used as the final evaluation of remedial alternatives, generally 

after EPA has received public comment on the RI/FS and Proposed Plan: 

8. State acceptance addresses the State’s position and key concerns related to the 

preferred alternative and other alternatives, and the State’s comments on ARARs 

or the proposed use of waivers. 

9. Community acceptance addresses the public’s general response to the alternatives 

described in the Proposed Plan and RI/FS. 

The following is a comparison of the 2002 OU I ROD remedy and the alternatives 

evaluated for this ROD Amendment, contrasting each remedy’s components with respect to the 

nine evaluation criteria. Only those alternatives that satisfied the first two threshold criteria were 

balanced and modified using the remaining seven criteria. 

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Summary for the Comparative Analysis of Alternatives 

Overall Protection of Human Health and the Environment 

Overall protection of human health and the environment addresses whether each 

alternative provides adequate protection of human health and the environment and describes how 

risks posed through each exposure pathway are eliminated, reduced, or controlled, through 

treatment, engineering controls, and/or institutional controls. 

Results of Baseline Human-health Risk Assessment for overburden and bedrock 

groundwater indicate that cancer risks due to chlorinated benzene compounds exceed the EPA 

target cancer risk range of 1x10-4 to 1x10-6 and a non-cancer risk target of an HI=1, (for inorganic 

and chlorinated benzene compounds). As identified in the OU I FS and 2002 OU I ROD, 

Alternative GW-1 would not take any actions to prevent potential human receptor exposure to 

contaminated groundwater. The No Further Action alternative would not reduce these risks and 

would not be protective of human health or the environment. 

Alternatives GW-4 and GW-4a are considered protective of potential risks to human 

health and the environment. They utilize active remedial actions that either destroy or remove 

COCs from the aquifer in combination with using a public water supply and institutional controls 

that prohibit groundwater use, which are to be implemented until such time that MCLs/MEGs are 

achieved or it can be shown that risk levels posed by the COCs in groundwater are within target 

risk ranges. Alternative GW-4, the original 2002 OU I ROD remedy, included a groundwater 

extraction and treatment component to aid in achieving aquifer restoration. The reduction of the 

contaminant mass through NTRCA activities and the elimination of local pumping stresses that 

could cause the expansion of the groundwater plume have eliminated the primary need for the 

long-term groundwater extraction and treatment system, which was to prevent plume migration 

and protect the EBSR from contaminated water discharge until cleanup levels are met. As a 

result, the only remaining reason for long-term groundwater extraction and treatment would be to 

facilitate aquifer restoration. However, given that the groundwater contamination is limited to an 

un-developable area consisting of either roadway or designated greenspace, the anticipated 

placement of institutional controls to prevent future groundwater use, the availability of a water 

line, and the fact that the groundwater contamination is receding rather than expanding, EPA 

considers the less aggressive approach defined in Alternative GW-4a to provide an equivalent 

level of protection of human health and the environment to that of Alternative GW-4. 

Alternatives GW-4 and GW-4a both include groundwater monitoring as a component to provide 

information on the ability of the alternative to destroy/remove contaminants within the aquifer 

and to confirm that COCs are eventually reduced to concentrations that protect against potential 

risks to human health and the environment. 

Compliance with Applicable or Relevant and Appropriate Requirements 

Section 121(d) of CERCLA requires that remedial actions at CERCLA sites attain legally 

applicable or relevant and appropriate federal and state requirements, standards, criteria, and 

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limitations which are collectively referred to as “ARARs,” unless such ARARs are waived 

pursuant to CERCLA section 121(d)(4). This criterion must be met for a remedial alternative to 

be chosen as a final site remedy in accordance with CERCLA. 

Chemical-specific ARARs. Chemical-specific ARARs for groundwater (MCLs, non-zero 

MCLGs, and MEGs) would not be met by Alternative GW-1 for an estimated 600 years. 

Alternatives GW-4 and GW-4a are expected to attain chemical-specific ARARs within 60 and 80 

years, respectively. 

Location-specific ARARs. Alternatives GW-4 and GW-4a can be designed and implemented to 

comply with location-specific ARARs, with Alternative GW-4a having slightly fewer impacts to 

wetlands and floodplains since construction or expansion of the groundwater treatment system is 

eliminated. There are no location-specific ARARs for Alternative GW-1. 

Action-specific ARARs. Alternative GW-1 entails no action and therefore triggers no actionspecific ARARs. Alternatives GW-4 and GW-4a produce investigation-derived waste from 

groundwater sampling that would be required to be managed in accordance with EPA OSWER 

Publication 9345.3-03FS, which is a “to be considered” (TBC) guidance. Alternatives GW-4 and 

GW-4a will also meet applicable groundwater injection program standards during subsurface 

application of remedial solutions. Alternative GW-4’s long-term groundwater extraction and 

treatment system produces waste streams from water treatment that requires potential handling, 

storage, transportation, and disposal/treatment of hazardous waste. For Alternative GW-4, 

groundwater discharged to the EBSR would need to be treated to prevent exceedance of AWQC 

in the river at low-flow and to protect surface water quality. 

Long-Term Effectiveness and Permanence 

Long-term effectiveness and permanence refers to expected residual risk and the ability of 

a remedy to maintain reliable protection of human health and the environment over time, once 

cleanup levels have been met. Alternative GW-4 uses chemical oxidation, possibly surfactant or 

cosolvent flushing, and bioremediation to remove or destroy contaminants within the aquifer. 

Hydraulic capture and treatment performed during these processes will result in contaminants 

being isolated ex-situ for further treatment and disposal off-site. Alternative GW-4a uses 

chemical oxidation and bioremediation to remove or destroy contaminants within the aquifer. 

There is no long-term hydraulic capture and treatment performed as part of GW-4a because the 

plume is no longer expanding and the EBSR is not threatened by the remaining groundwater 

contamination. Alternatives GW-4 and GW-4a both rely on an aggressive treatment approach. 

Although GW-4a is presumed to require a longer period of time for aquifer restoration (80 years 

as opposed to 60 years), they offer essentially equivalent long-term effectiveness. 

For long-term protectiveness, Alternatives (GW-4 and GW-4a) both rely on restrictive 

environmental covenants to prevent the use of groundwater until cleanup goals are met. Because 

waste remains in place, EPA will review the remedy every five years to ensure the effectiveness 

and protectiveness of this control and to implement further controls if necessary. Long-term 

monitoring will continue under both alternatives. 

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Reduction of Toxicity, Mobility, or Volume Through Treatment 

Reduction of toxicity, mobility, or volume through treatment refers to the anticipated 

performance of the treatment technologies that may be included as part of a remedy. Alternatives 

GW-4 and GW-4a use aggressive treatment approaches to destroy contaminants in-situ. The 

hydraulic containment portion of Alternative GW-4 would actively control contaminant mobility 

in the subsurface during in-situ treatment implementation. The ex-situ treatment portion would 

reduce contaminant mobility in extracted groundwater. Alternative GW-4a does not include longterm active hydraulic containment. The RAO for groundwater restoration can be met without 

long-term hydraulic containment based upon the result of the groundwater modeling performed 

for the OU I design. A decrease has been observed in the volume of the groundwater 

contamination plume and the COC concentrations with the absence of hydraulic control. It is 

anticipated that a continued decrease in plume volume and COC concentrations will occur with 

continued ISCO applications. Alternatives GW-4 and GW-4a provide the same reduction in 

toxicity, mobility, and volume of contaminants through treatment, although GW-4a is presumed 

to require a longer period of time for aquifer restoration (80 years as opposed to 60 years). 

Short-Term Effectiveness 

Short-term effectiveness addresses the period of time needed to implement the remedy and 

any adverse impacts that may be posed to workers and the community during construction and 

operation of the remedy until cleanup goals are achieved. Because there is no current exposure to 

groundwater, there will be no short-term adverse effects to the community from exposure to 

groundwater during implementation of any of the groundwater remedies. Site workers will 

experience the same short-term impacts during ICP ISCO in-situ remediation with both 

alternatives. Alternatives GW4 and GW-4a both include connection to a public water line to offer 

immediate protection to nearby residences and businesses from ingestion of contaminated 

drinking water. Alternative GW4a has a slight advantage over alternative GW-4 in that 

elimination of the long-term groundwater extraction and treatment systems and surfactant/cosolvent flushing results in less onsite construction, less truck traffic, and fewer impacts on 

wetlands and floodplains. 

Implementability 

Implementability addresses the technical and administrative feasibility of a remedy from 

design through construction and operation. Factors such as availability of services and materials, 

administrative feasibility, and coordination with other governmental entities are also considered. 

Although both alternatives rely on innovative technologies, ICP ISCO has been successfully 

implemented at the Site during 2004 and 2005 NTCRA activities. Surfactant/cosolvent flushing 

in Alternative GW-4 has yet to be successfully implemented in a fractured bedrock setting 

comparable in scale to the Site and must be considered unproven. Based on this general 

comparison, the alternative GW-4a is considered more implementable than GW-4. 

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Cost 

The estimated present worth costs for the alternatives, not including Alternative GW-1, 

range from $4.5 million for Alternative GW-4a to $10.5 million for Alternative GW-4. When 

evaluating the alternatives based upon an annual outlay as opposed to present value, the cost 

benefit of Alternative GW-4a is more apparent. The cumulative expenditures to achieve aquifer 

restoration using Alternative GW-4a will be approximately $6.5 million by the end of 80 years 

whereas the cumulative expenditure for Alternative GW-4 is estimated at $20.8 million at the end 

of 60 years. Although the revised OU I remedial action, GW-4a, would require 20 additional 

years to achieve the restoration of the aquifer, the cost to achieve restoration is significantly lower 

than GW-4, which relies on a long-term groundwater extraction and treatment system to facilitate 

the groundwater restoration in a shorter period. However, given the reduced size of the 

groundwater plume and the implementation of institutional controls, there is no consequence to 

public health as a result of the additional 20 years to achieve restoration. Capital, present worth, 

and total long-term costs for each alternative are shown in the following Table 5 below. 

Table 5 

Comparison of Costs 

Cost Category Alternative 

GW-1 

Alternative 

GW-4 

Alternative 

GW-4a 

Capital Costs $0 $6,891,283 $3,541,980 

Present Worth of Annual and Periodic Costs $0 $3,614,296 $926,674 

Present Worth $0 $10,505,579 $4,468,653 

Total (Long-term) Costs – non-discounted $0 $20,777,431 $6,508,976 

costs (60 years) (80 years) 

Capital costs are greater for GW-4 due to the installation of the groundwater extraction 

and treatment system and injection system for enhanced flushing. Long-term operation and 

maintenance costs are also greater for GW-4 due to the cost associated with the operation and 

maintenance of the treatment system. 

State/Support Agency Acceptance 

This criterion addresses whether, based on its review of the data derived from the Site and 

the Proposed Plan, the State concurs with, opposes, or has no comment on the Amendment that 

EPA has selected for the Site. 

ME DEP has reviewed the May 2006 Proposed Plan to amend the 2002 OU I ROD and a 

draft of this ROD Amendment. The State of Maine supports the proposed changes to the OU I 

remedy as described in Alternative GW-4a. 

Community Acceptance: 

This criterion addresses whether the public concurs with EPA’s proposed Amendment. 

Compliance with this criterion is based on the comments received at the public meeting and 

public hearing. 

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The community is supportive of the proposed changes to the OU I remedy as described in 

Alternative GW-4a. 

L. THE SELECTED REMEDY 

1. Summary of the Rationale for the Selected Remedy 

The selected remedy is the proposed preferred alternative, Alternative GW-4a, that was 

identified in the Proposed Plan and presented in more detail in the FFS. The amended OU I 

remedy remains a comprehensive remedy for the OU I portion of the Site that utilizes the 

application of in-situ reagents, incorporates groundwater use restrictions and long-term 

monitoring and will require five-year reviews as long as waste remains in place. 

For the amended remedy for OU1, EPA has selected a remedy which ensures 

protectiveness of human health and the environment, attains all federal and state regulations, 

provides long-term and short-term effectiveness, is implementable, and reduces toxicity, volume, 

and mobility through treatment. 

2. Description of Remedial Components 

The major components of the remedy are: 

Alternative GW-4a includes actions to 1) reduce the contaminant mass contributing to the 

contamination of groundwater through chemical oxidation; 2) extend the public water supply 

system to prevent ingestion of contaminated groundwater; and 3) prevent plume migration to 

address potential threats to human health and the environment. It also relies upon institutional 

controls and environmental monitoring to control potential human health risks from exposure to 

contaminated groundwater. Alternative GW-4a is presented in Figure 9 and consists of the 

following key components: 

• Groundwater source mass reduction 

o ISCO treatment of Area 1 deep saturated soil and shallow weathered bedrock 

o ISCO treatment of Area 1 deep fractured bedrock including installation of 

additional bedrock injection wells 

o Bio-stimulation of Area 1 deep fractured bedrock 

• Environmental monitoring 

o Groundwater monitoring to assess remedy effectiveness and progress toward 

attaining cleanup goals 

• Institutional Controls to prevent future use of the contaminated groundwater and prevent 

disturbance of the remedy 

• Connecting currently occupied properties within the institutional controls zone to the 

existing public water supply system 

• Five-year reviews to ensure that the remedy remains protective of human health and the 

environment. 

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Corinna, Maine 
OU I Record of Decision Amendment 

Part 2: The Decision Summary 

Groundwater Source Mass Reduction 

This alternative focuses mass reduction technologies on three specific areas of contamination that 

represent residual sources below the water table. These areas include: 

• Area 1 deep saturated soil 

• Area 1 shallow weathered bedrock surface 

• Area 1 deep fractured bedrock 

Area 1 Deep Saturated Soil ISCO 

An estimated 1,289 kg of contaminant mass exists as residual DNAPL within 

approximately 809 yd3

 of dense glacial till approximately two to four feet thick immediately 

above the bedrock surface in Area 1. An additional contaminant mass of approximately five kg of 

contaminants is estimated to be present as sorbed contamination in approximately 543 yd3

 of soil, 

forming a wedge shape overlying and adjacent to the DNAPL saturated soils. 

The ISCO application will be performed in the Area 1 overburden during 2006 to reduce 

soil concentration to allow groundwater to achieve MCLs/MEGS. Post-injection soil and 

groundwater sampling will be performed to evaluate the success of these future treatments. 

Additional ISCO applications will occur as necessary to achieve a level of source reduction that 

will support the restoration of the aquifer. 

Area 1 Shallow Weathered Bedrock Surface ISCO 

This area is estimated to contain approximately 5.4 kg of DNAPL mass and 120 kg of 

mass diffused in oxidized rock matrix adjacent to fractures. To treat residual DNAPL dispersed 

along the top of weathered bedrock, an ISCO program will be performed. During the ISCO 

injections, groundwater will be extracted from the fractured bedrock underlying Area 1 from the 

existing extraction well (former Lot 120 Recovery Well 2 (R2), re-converted as EW-1). The 

extracted groundwater will be treated onsite by carbon absorbtion and discharged to the EBSR. 

Best management practices will be used during extraction, treatment and discharge activities. 

Area 1 Deep Fractured Bedrock ISCO and Bio-stimulation 

The total estimated contaminant mass for this area includes 14.5 kg of DNAPL, 182 kg of 

mass diffused in oxidized rock matrix adjacent to fractures, and 16 kg of mass diffused into fresh 

rock matrix. An ISCO program would be performed to target the deep bedrock contamination 

and to stimulate biological degradation processes that would provide the long-term reduction in 

contaminant levels necessary to achieve cleanup levels. 

An option included in the 2002 OU I ROD was possibility of using bio-stimulants as a 

polishing step to remove any contamination that remained after the ISCO. This ROD Amendment 

incorporates the use of bio-stimulants into the remedy. The bio-stimulant composition will likely 

be designed or formulated from commercially available products such as HRCTM, specialized 

Record of Decision Amendment - Operable Unit I 31 Version: Final 

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Record of Decision Amendment 

Part 2- The Decision Summary 

sugars and nutrients, or injection of air with gaseous phase nutrients (nitrogen and phosphorous) 

with methane as a carbon source. The full-scale application of bio-stimulant would be 

accomplished through approximately eight vertical bedrock wells. The bio-stimulant injection 

would be repeated on an as-needed frequency to maintain productive levels of biological activity. 

The level of biological activity would be assessed using phospho-lipid fatty acid analysis or other 

specialized analytical procedures, in addition to monitoring methane, chloride and nutrient levels 

within the aquifer treatment zone. 

As with the shallow bedrock, hydraulic control would be established and maintained 

during active treatment of the bedrock groundwater system by operation of the temporary 

groundwater extraction and treatment system installed during the NTCRA. Once the active 

treatment phase is completed and treatment fluids have been recovered from the subsurface, the 

temporary groundwater extraction and treatment system will be removed. 

Environmental Monitoring 

The monitoring program will be initiated after completion of the mass reduction phase. 

Environmental monitoring will consist of collection and analysis of groundwater samples for 

VOCs, inorganics, and field parameters from approximately 24 overburden and 16 bedrock 

monitoring wells. This includes four new overburden and six new bedrock groundwater 

monitoring wells. The monitoring locations include wells within and outside the limits of the 

bedrock and overburden groundwater plumes. The monitoring will occur annually for five years 

and then may be reduced to support each five year review. 

Details of the monitoring program, including quality assurance/quality control (QA/QC) 

protocols and institutional control compliance, will be specified in a long-term monitoring plan to 

be submitted to ME DEP for review and concurrence prior to implementation. 

Institutional Control Components 

Based on the groundwater modeling that was performed as part of the OU I Remedial 

Design, the Institutional Control Zone (ICZ) was modified to reflect additions or changes to the 

ICZ components. The final proposed ICZ is shown in Figure 10. 

The ICZ contains three property categories, IC Zone A (ICZ-A), IC Zone B (ICZ-B), and 

IC Zone C (ICZ-C). These properties that are classified as ICZ would have environmental 

covenants that either prohibit (ICZ-A and ICZ-B) or restrict (ICZ-C) groundwater use. 

ICZ-A identified those properties that will be subject to environmental covenants 

prohibiting use of groundwater over the entire property. All of the ICZ-A properties are currently 

served by the water line. Within the ICZ-A boundary, all existing bedrock and overburden water 

supply wells will be formally decommissioned, unless the wells are converted to monitoring wells 

for use in the long-term remedial action. ICZ-A properties are depicted on Figure 10. 

ICZ-B identified those properties where connection to the water line and implementation 

of an environmental covenant prohibiting use of groundwater over the entire property was 

Record of Decision Amendment - Operable Unit I 32 Version: Final 

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OU I Record of Decision Amendment 

Part 2: The Decision Summary 

determined to be necessary. All of the properties have now been connected to the water line, 

moving these properties to ICZ-A; there is therefore no longer a functional application for ICZ-B. 

ICZ-C identified those properties where the current well is not contaminated and does not 

appear to be impacting the groundwater contamination, however, the groundwater modeling 

suggested that a modification to the existing well to increase yield or the installation of a new well 

at locations on the property closer to the Site could have an adverse impact on the groundwater 

contamination by inducing migration of the groundwater contamination. The restrictions on these 

properties will prohibit installation of future groundwater wells in locations or at depths that differ 

from existing water supply wells located on these properties. ICZ-C properties may continue to 

use their private water wells within this zone for domestic or other uses. There are two properties 

included in ICZ-C. The ICZ-C properties are shown on Figure 10. 

In addition to ICZ-A, ICZ-B, and ICZ-C, the Town Cemetery will also be included in the 

institutional controls pertaining to property where treated soil was placed. The Town of Corinna, 

EPA, and ME DEP agreed that any backfilled, treated soil that was subject to EPA’s removal or 

remedial activities that is excavated during future Town redevelopment may be moved to and 

backfilled at the Village Cemetery located on Stetson Road. The Town of Corinna has agreed to 

implement this environment restriction. 

Once the institutional controls have been implemented, compliance with the restrictions 

will be monitored and enforced to ensure that the institutional controls are effective. Over time, 

EPA will also evaluate whether the land use restrictions can be removed or modified because 

acceptable levels have been met at the Site. 

Five-Year Reviews. 

As long as contamination that prevents unrestricted use of the Site remains, EPA will 

review the Site at least once every five years after the initiation of remedial action to ensure that 

the remedial action continues to protect human health and the environment. 

Record of Decision Amendment - Operable Unit I 33 Version: Final 

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Record of Decision Amendment 

Part 2- The Decision Summary 

3. Summary of the Estimated Remedy Costs 

The estimated capital cost for the remedial action is $3.54 million. The capital costs are 

detailed in Table 6 below. 

Table 6 

CAPITAL COST SUMMARY FOR ALTERNATIVE GW-4a: 

Description Cost 

Site Management, Equipment, and Facilities (2006-2008) $512,151 

Connection of residences to public water supplies $54,761 

Long-term monitoring well installation $239,273 

Institutional Control Support $33,607 

ISCO – Area 1 Shallow Bedrock $796,648 

ISCO – Area 1 Deep Bedrock $741,118 

ISCO – Area 1 Polishing Injections $374,571 

Biological Enhancement Treatment – Area 1 $309,345 

Performance Monitoring (2006/2007) $160,000 

Site restoration (removal of temporary treatment plant and well decommissioning) $120,016 

Direct Cost Subtotal $3,341,490 

Indirect Capital Costs 

Construction Management $100,245 

Project Management $100,245 

Indirect Cost Subtotal $200,489 

TOTAL CAPITAL COSTS $3,541.980 

The estimated monitoring and periodic injection costs are summarized in Table 7 below. 

Table 7 

COST SUMMARY FOR ALTERNATIVE GW-4a: 

Annual Operation and Maintenance Costs 

Description Quantity Unit Unit Cost Cost 

Annual Costs 

Annual Groundwater monitoring (years 1-5) – including 

10% contingency, 5 percent project management, and 

10% technical support 

45 wells annual LS $75,000 

 Periodic Costs 

Periodic monitoring to support 5 year reviews (every 

fourth year, for years 5-80) – including 10% contingency, 

5 percent project management, and 10% technical support 

45 wells Event LS $75,000 

Five-Year Reviews (every 5 years beginning in 2011) – 

including 10% contingency, 5 percent project 

management, and 10% technical support

 Event LS $31,250 

Bio-stimulant Injections (years, 2,4,6, and 8) – including 

10% contingency, 5 percent project management, and 

10% technical support 

LS $120,454 

Record of Decision Amendment - Operable Unit I 34 Version: Final 

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Corinna, Maine 
OU I Record of Decision Amendment 

Part 2: The Decision Summary 

The present value of the long-term costs for Alternative GW-4a is $926,674. The total 

cost, including capital and present value of long-term costs, for Alternative GW-4a is $4,468,653. 

The detailed breakout of long-term costs and the present value is presented in Table 8, which is 

attached to this ROD Amendment. 

The information in this cost estimate summary table is based on the best available 

information regarding the anticipated scope of the remedial alternative. Changes in the cost 

elements are likely to occur as a result of new information and data collected during the 

engineering design of the remedial alternative. A discount rate of 7% was used to develop the 

present value. Major changes may be documented in the form of a memorandum in the 

Administrative Record file, an Explanation of Significant Difference (ESD), or a ROD 

amendment. This is an order-of-magnitude engineering cost estimate that is expected to be within 

+50 to -30 percent of the actual project cost. 

4. Expected Outcomes of the Selected Remedy 

The primary expected outcome of the selected OU I amended remedy is that the OU I Site 

area will no longer present an unacceptable risk to future users of the groundwater through 

ingestion and inhalation of groundwater and will be suitable for unrestricted use. Approximately 

80 years is the estimated time necessary to achieve the goals consistent with aquifer restoration. 

The NTCRA and selected remedy have also reduced the flux of contaminants into the EBSR 

allowing for a full recovery of the benthic community. The previous removal actions, including 

the NTCRA, have eliminated any threat from exposure to soils within the Site. It is anticipated 

that the selected remedy will also provide significant socio-economic and community 

revitalization impacts since the area addressed by the NTCRA and this OU I cleanup are the 

center of the community. The completion of the NTCRA and the construction phase of the OU I 

cleanup, have allowed the community to implement the redevelopment plan. Of the 25 acres that 

were part of the Site cleanup activities, 22 acres are currently available for productive re-use. A 

senior housing facility, Corundel Commons, was installed on one portion of the Site. A historic 

structure, relocated from the center of the Site to just outside the Site, has been rehabilitated and 

serves the community as a general store and restaurant. The Town of Corinna has approved a 

subdivision plan and is actively marketing most of the remaining areas of the Site that are 

available for re-use. 

Record of Decision Amendment - Operable Unit I 35 Version: Final 

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Record of Decision Amendment 

Part 2- The Decision Summary 

a. Cleanup Levels -- Groundwater 

The provisional cleanup levels established in the 2002 OU I ROD remain protective of 

human health and the environment. Refer to the 2002 OU I ROD for discussion about cleanup 

levels. The numerical cleanup levels from the 2002 OU I ROD are listed in Table 9 below. 

Table 9 Provisional Groundwater Cleanup Levels 

Carcinogenic Chemicals of 

Concern 

Cancer 

Classification 

Provisional 

Cleanup Level 

(ug/l) 

Basis RME Risk 

arsenic A 10 MCL 2 x 10 -04 

1,4 dichlorobenzene C 27 1992 MEG 1 x10 -05 

benzene A 5 MCL 2 x 10-06

 Sum of Carcinogenic Risk 2 x 10 -04 

Non-Carcinogenic Chemicals 

of Concern 

Target Endpoint Provisional 

Cleanup Level 

(ug/l) 

Basis RME Hazard 

Quotient 

arsenic skin 10 MCL 2.1 

manganese central nervous 

system 

200 MEG 0.57 

benzene hematological system 5 MCL 0.12 

chlorobenzene liver 47 1992 MEG 0.018 

1,2 dichlorobenzene liver 85 1992 MEG 0.085 

1,3 dichlorobenzene liver 85 1992 MEG 9.4 

1,4 dichlorobenzene liver/kidney 27 1992 MEG 0.080 

1,2,4 trichlorobenzene Endocrine system 70 MCL 0.78 

HI (liver): 9.7 HI (central nervous system): 0.57 HI (skin): 2.1 HI (endocrine system): 0.78 

Key 

MCL: Federal Safe Drinking Water Act Maximum Contaminant Level 

MCLG: Federal Safe Drinking Water Act Maximum Contaminant Level Goal 

MEG: State of Maine Maximum Exposure Guidelines 

HI: Hazard Index 

RME: Reasonable Maximum Exposure 

Record of Decision Amendment - Operable Unit I 36 Version: Final 

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OU I Record of Decision Amendment 

Part 2: The Decision Summary 

All groundwater cleanup levels identified in the ROD and any newly promulgated ARARs 

and modified ARARs that call into question the protectiveness of the remedy and the protective 

levels determined as a consequence of the risk assessment of residual contamination must be met 

at the completion of the remedial action at the points of compliance. At this Site, cleanup levels 

must be met throughout the contaminated groundwater plume. The values represent 

concentration levels that cannot be exceeded in any given well location at the Site. EPA has 

estimated that the groundwater cleanup levels will be obtained within 80 years after the initiation 

of the in-situ oxidation program. 

EPA’s new Cancer Guidelines and Supplemental Guidance (March 2005) will be used as 

the basis for EPA’s analysis of all new carcinogenic risk assessments. If updated carcinogenic 

risk assessments become available, EPA will determine whether an evaluation should be 

conducted as part of the remedial design to assess whether adjustments to the target cleanup levels 

for this remedial action are needed in order for this remedy to remain protective of human health. 

M. STATUTORY DETERMINATIONS 

The amended OU I remedial action selected for implementation at the Site is consistent 

with CERCLA and, to the extent practicable, the NCP. The selected remedy is protective of 

human health and the environment, will comply with ARARs and is cost-effective. In addition, 

the selected remedy utilizes permanent solutions and alternate treatment technologies or resource 

recovery technologies to the maximum extent practicable and satisfies the statutory preference for 

treatment that permanently and significantly reduces the mobility, toxicity or volume of 

hazardous substances as a principal element. 

1. The Selected Remedy is Protective of Human Health and the Environment 

The remedy at this Site will adequately protect human health and the environment by 

eliminating, reducing or controlling exposures to human and environmental receptors through 

treatment, engineering controls and institutional controls (i.e., deed restrictions). More 

specifically, the selected remedy’s in-situ oxidation will reduce the mass of contamination and 

protect the ecological resources by reducing the loading of contaminated water into the EBSR. 

Institutional controls will limit future Site use to prevent ingestion of groundwater during the 

period required for restoration. Institutional controls will also prevent the extraction of 

groundwater from locations that could cause the contamination to migrate. Long-term monitoring 

will allow for the evaluation of the cleanup and the identification of any future threats. 

The selected remedy will reduce potential human health risk levels such that they do not 

exceed EPA’s acceptable risk range of 10-4 to 10-6 for incremental carcinogenic risk, and such that 

the non-carcinogenic hazard is below a level of concern. It will reduce potential human health 

risk levels to protective ARARs levels, i.e., the remedy will comply with ARARs and TBC 

criteria. Implementation of the selected remedy will not pose any unacceptable short-term risks 

or cause any cross-media impacts. 

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Part 2- The Decision Summary 

At the time that the ARAR-based Ground Water Cleanup Levels identified in the ROD 

and ROD Amendment and newly promulgated ARARs and modified ARARs that call into 

question the protectiveness of the remedy have been achieved and have not been exceeded for a 

period of three consecutive years, a risk assessment shall be performed on the residual ground 

water contamination to determine whether the remedy is protective. This risk assessment of the 

residual ground water contamination will follow EPA procedures and will assess the cumulative 

carcinogenic and non-carcinogenic risks posed by ingestion of ground water and inhalation of 

VOCs from domestic water usage. If, after review of the risk assessment, the remedy is not 

determined to be protective by EPA, the remedial action will continue until protective levels are 

achieved and have not been exceeded for a period of three consecutive years, or until the remedy 

is otherwise deemed protective. These protective residual levels shall constitute the final cleanup 

levels for this ROD and shall be considered performance standards for any remedial action. 

2. The Selected Remedy Complies With ARARs 

ARARs were identified during the development of the 2002 OU I ROD and were 

reviewed as part of this ROD Amendment process. Several Maine statutes were updated to 

reflect their current citations and are noted in Tables 10 - 12. In addition, a 2005 risk assessment 

guidance was added as a TBC to be used when future risk assessments are conducted. No other 

changes were made. 

The most significant ARARs reflect the groundwater cleanup levels. The federal MCLs 

and non-zero MCLGs govern the quality of drinking water provided by public water supply and 

are relevant and appropriate requirements for groundwater remediation at the Site. The state 

MEGs are also relevant and appropriate chemical-specific ARARs. The Maine Standards for 

Hazardous Waste Facilities, which include the state MEGs, require that a miscellaneous unit be 

closed in a manner that ensures hazardous waste shall not appear in ground or surface waters 

above MEGs. The Site is considered analogous to a miscellaneous hazardous waste unit. The 

selected amended remedy will comply with these and all other federal and any more stringent 

state ARARs listed in Tables 10-12 for the remedial action. 

Further discussion about ARARs may be found in Section 3 of the FS Report. 

3. The Selected Remedy is Cost-Effective 

In EPA’s judgment, the selected remedy is cost-effective because the remedy’s costs are 

proportional to its overall effectiveness (see 40 CFR 300.430(f)(1)(ii)(D)). This determination 

was made by evaluating the overall effectiveness of those alternatives that satisfied the threshold 

criteria (i.e., that are protective of human health and the environment and comply with all federal 

and any more stringent state ARARs, unless appropriately waived). Overall effectiveness was 

evaluated by assessing, in combination, three of the five balancing criteria: long-term 

effectiveness and permanence; reduction in toxicity, mobility, and volume through treatment; and 

short-term effectiveness. The overall effectiveness of each alternative then was compared to the 

alternative’s costs to determine cost-effectiveness. 

Record of Decision Amendment - Operable Unit I 38 Version: Final 

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OU I Record of Decision Amendment 

Part 2: The Decision Summary 

The relationship of the overall effectiveness of this remedial alternative was determined to 

be proportional to its costs and hence represents a reasonable value for the money to be spent. 

Alternatives GW-4 and GW-4a would be equally ARAR-compliant in that each alternative would 

achieve the groundwater cleanup levels in a reasonable time period. The cost effectiveness of 

both Alternatives GW-4 and GW-4a is predicated upon the ability of the in-situ reagents and biostimulants to eliminate the source of the contamination in order for the aquifer to achieve full 

restoration. The time frame for the source removal under both Alternatives GW-4 and GW-4a is 

15 years. Subsequent to the 15 year period required for source removal, an additional 15 to 60 

years was estimated to achieve full aquifer restoration for Alternative GW-4 with the use of longterm groundwater extraction and treatment. This results in an estimated range for the cleanup of 

30 to 75 years, with 60 years being selected as a reasonable estimate for the basis of alternative 

comparison and cost evaluation. For Alternative GW-4a, without the use of long-term 

groundwater extraction and treatment, the estimated time period to achieve aquifer restoration is 

30 to 74 years, resulting in a cleanup range of 45 to 89 years, with 80 years being selected as a 

reasonable estimate for the basis of alternative comparison and cost evaluation. Given that the 

groundwater plume is located under roadways and greenspace within an area where groundwater 

use is prohibited and a water line is available, there is no consequence to waiting the additional 20 

years. GW-4 has an estimated present worth of $10.5 million as compared to the estimated 

present worth of GW-4a of $4.5 million. Further, the projected total cost (not adjusted for present 

value) for GW-4 is $20.8 million, as compared to $6.5 million for GW-4a. Therefore, GW-4a, 

with a $6 million lower present value and $14.3 million lower total cost, is the most cost effective 

alternative given that GW-4 provides an equivalent level of protection of human health and the 

environmental and compliance with ARARs. 

4. The Selected Remedy Utilizes Permanent Solutions and Alternative 

Treatment or Resource Recovery Technologies to the Maximum Extent 

Practicable 

Once the Agency identified those alternatives that attain or, as appropriate, waive ARARs, 

and that are protective of human health and the environment, EPA identified which alternative 

utilizes permanent solutions and alternative treatment technologies or resource recovery 

technologies to the maximum extent practicable. This determination was made by deciding 

which one of the identified alternatives provides the best balance of trade-offs among alternatives 

in terms of: (1) long-term effectiveness and permanence; (2) reduction of toxicity, mobility or 

volume through treatment; (3) short-term effectiveness; (4) implementability; and (5) cost. The 

balancing test emphasized the long-term effectiveness and permanence and the reduction of 

toxicity, mobility and volume through treatment, and considered the preference for treatment as a 

principal element, the bias against off-site land disposal of untreated waste, and community and 

state acceptance. The selected remedy provides the best balance of trade-offs among the 

alternatives. 

The selected remedy provides long-term effectiveness and permanence while using 

treatment to reduce the toxicity, mobility, and volume of the contaminant mass material. 

Chemical oxidation treatment is a principal element of the selected remedy in achieving 

permanent aquifer restoration. The addition of bio-stimulants will enhance the restoration 

Record of Decision Amendment - Operable Unit I 39 Version: Final 

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Part 2- The Decision Summary 

process. The State of Maine and the community were very supportive of the selected remedy. 

The potential to more cost effectively achieve cleanup goals in a similar time frame supports the 

selection of Alternative GW-4a over Alternative GW-4, which would achieve essentially the same 

outcome at a substantially greater cost. 

5. The Selected Remedy Satisfies the Preference for Treatment Which 

Permanently and Significantly Reduces the Toxicity, Mobility or Volume of the 

Hazardous Substances as a Principal Element 

The principal element of the selected remedy is the in-situ treatment of groundwater and 

DNAPL. This element addresses the primary threats at the Site – highly contaminated 

groundwater, DNAPL, and the remaining soil contamination – as defined by the risk to local 

water supplies and the exceedance of MCLs/MEGs. The selected remedy satisfies the statutory 

preference for treatment as a principal element by reducing the contamination in the aquifer 

through in-situ treatment of the mass of contamination in the overburden soil and bedrock and in 

the overburden and bedrock groundwater. 

6. Five-Year Reviews of the Selected Remedy are Required 

Because this remedy will result in hazardous substances remaining on-site above levels 

that will not allow for unlimited use and unrestricted exposure, a review will be conducted within 

five years after initiation of the remedial action to ensure that the remedy continues to provide 

adequate protection of human health and the environment. This review will continue every five 

years as long as waste remains in place above cleanup levels. 

N. DOCUMENTATION OF NO SIGNIFICANT CHANGES 

On May 25, 2006, EPA presented a proposed plan that described eliminating the longterm extraction and treatment of the groundwater component of the original 2002 OU I ROD 

remedy. The Plan also noted a minor change that eliminated the enhanced flushing with 

surfactants/co-solvents. EPA reviewed all written and verbal comments submitted during the 

public comment period, which was open from May 26 to June 25, 2006. None of the comments 

opposed the proposed amendment to the 2002 OU I ROD, and it was determined that no 

significant changes to the remedy, as originally identified in the Proposed Plan, were necessary. 

EPA has prepared a responsiveness summary to address the comments received during the public 

comment period. The responsiveness summary is attached as Appendix C. 

One minor change in the cost of Alternatives GW-4 and GW-4a has occurred since the 

public comment period. The FFS reported the present value as a net rate of 3.9%. EPA guidance 

recommends a discount rate of 7%. The costs reported in the ROD are based on the discount rate 

of 7%. The revision does not impact capital costs for either alternative. The present value of 

long-term costs for Alternative GW-4 in the Proposed Plan and FFS was reported as $5,651,353. 

The revised present value for these long-term costs for GW-4 is $3,614,296. The revised total 

present value (capital and long-term costs) for GW-4 is $10.5 million. The present value of longterm costs for Alternative GW-4a in the Proposed Plan and FFS was reported as $1,263,640. The 

Record of Decision Amendment - Operable Unit I 40 Version: Final 

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OU I Record of Decision Amendment 

Part 2: The Decision Summary 

revised present value for GW-4a is $926,674. The revised total present value (capital and longterm costs) for GW-4a is $4.5 million. There is no significant impact to the comparative analysis 

or other aspects of the alternative evaluation since the cost differential remains substantial and 

GW-4a is more cost effective than GW-4. 

O. STATE ROLE 

ME DEP has reviewed the various alternatives and has indicated its support for the 

selected remedy. The State has also reviewed the FFS with respect to amendment to determine 

whether the selected remedy is in compliance with applicable or relevant and appropriate state 

environmental and facility siting laws and regulations. The State of Maine concurs with the 

amendment to the selected remedy for the Eastland Woolen Mill Superfund Site. A copy of the 

declaration of concurrence is attached as Appendix B. 

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Record of Decision Amendment 

Part 2- The Decision Summary 

APPENDIX A 

TABLES AND FIGURES NOT IN ROD TEXT 

Record of Decision Amendment - Operable Unit I 42 Version: Final 

Eastland Woolen Mill Superfund Site Date: September 28, 2006 

Corinna, Maine 
TABLE 8 

PRESENT VALUE OF ANNUAL AND PERIODIC COSTS - YEARS 1 THROUGH 80 

ALTERNATIVE GW4a: MASS REDUCTION WITHOUT HYDRAULIC CONTAINMENT 

OU1 FOCUSED FEASIBILITY STUDY REPORT 

EASTLAND WOOLEN MILL SUPERFUND SITE 

Year (t) GW 

Monitoring 

Synoptic 

GW 

Levels 

IC 

Monitoring 

Pump and 

Treat O&M 

CORINNA, MAINE 

Annual 

Reporting 

Biostimulan 

t ReInjection 

Five-Year 

Reviews Contingenc 

y (@ 10%) 

PM (@ 

5%) 

Tech. 

Support (@ 

10%) 

Total NonDiscounted 

Cost 

Total 

Present 

Value 

0 $ - $ - $ - $ - $ - $ - $ - $ - $ - $ - $ - $ -

1 $ 55,000 $ - $ - $ - $ 5,000 $ - $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 76,846

2 $ 55,000 $ - $ - $ - $ 5,000 $ 96,363 $ 5,000 $ 16,136 $ 8,875 $ 17,750 $ 204,124 $ 178,290

3 $ 55,000 $ - $ - $ - $ 5,000 $ - $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 67,120

4 $ 55,000 $ - $ - $ - $ 5,000 $ 96,363 $ 5,000 $ 16,136 $ 8,875 $ 17,750 $ 204,124 $ 155,725

5 $ 55,000 $ - $ - $ - $ 5,000 $ - $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 58,625

6 $ - $ - $ - $ - $ - $ 96,363 $ 5,000 $ 10,136 $ 5,575 $ 11,150 $ 128,224 $ 85,441

7 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 3,939

8 $ - $ - $ - $ - $ - $ 96,363 $ 5,000 $ 10,136 $ 5,575 $ 11,150 $ 128,224 $ 74,628

9 $ 55,000 $ - $ - $ - $ 5,000 $ - $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 44,725

10 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 3,215

11 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 3,005

12 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 2,808

13 $ 55,000 $ - $ - $ - $ 5,000 $ - $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 34,120

14 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 2,453

15 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 2,292

16 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 2,142

17 $ 55,000 $ - $ - $ - $ 5,000 $ - $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 26,030

18 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 1,871

19 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 1,749

20 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 1,635

21 $ 55,000 $ - $ - $ - $ 5,000 $ - $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 19,858

22 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 1,428

23 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 1,334

24 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 1,247

25 $ 55,000 $ - $ - $ - $ 5,000 $ - $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 15,150

26 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 1,089

27 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 1,018

28 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 951

29 $ 55,000 $ - $ - $ - $ 5,000 $ - $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 11,558

30 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 831

31 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 777

32 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 726

33 $ 55,000 $ - $ - $ - $ 5,000 $ - $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 8,817

34 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 634

35 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 592

36 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 554

37 $ 55,000 $ - $ - $ - $ 5,000 $ - $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 6,727

38 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 484

39 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 452

40 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 422

41 $ 55,000 $ - $ - $ - $ 5,000 $ - $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 5,132

42 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 369

43 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 345

44 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 322

45 $ 55,000 $ - $ - $ - $ 5,000 $ - $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 3,915

46 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 281

47 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 263

48 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 246

49 $ 55,000 $ - $ - $ - $ 5,000 $ - $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 2,987

50 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 215

51 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 201

52 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 188

53 $ 55,000 $ - $ - $ - $ 5,000 $ - $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 2,279

54 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 164

55 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 153

56 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 143

57 $ 55,000 $ - $ - $ - $ 5,000 $ - $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 1,738

58 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 125

59 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 117

60 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 109

61 $ 55,000 $ - $ - $ - $ 5,000 $ - $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 1,326

62 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 95

63 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 89

64 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 83

65 $ 55,000 $ - $ - $ - $ 5,000 $ - $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 1,012

66 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 73

67 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 68

68 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 64

69 $ 55,000 $ - $ - $ - $ 5,000 $ - $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 772

70 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 55

71 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 52

72 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 48

73 $ 55,000 $ - $ - $ - $ 5,000 $ - $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 589

74 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 42

75 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 40

76 $ - $ - $ - $ - $ - $ - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 37

77 $ 55,000 $ - $ - $ - $ 5,000 $ - $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 449

78 $ 55,000 $ - $ - $ - $ 5,000 $ - $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 420

79 $ 55,000 $ - $ - $ - $ 5,000 $ - $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 392

80 $ 55,000 $ - $ - $ - $ 5,000 $ - $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 367

TOTAL $ 1,430,000 $ - $ - $ - $ 130,000 $ 385,452 $ 400,000 $ 234,545 $ 129,000 $ 258,000 $ 2,966,997 $ 926,674

Total before applied costs $ 2,345,452 

PV Discount Rate (i) 

0.070 

PV = non-discounted cost X 1/((1+i)t) 
ROD TABLE 10 

LOCATION-SPECIFIC ARARS FOR ALTERNATIVE GW4A 

OU1 FOCUSED FEASIBILITY STUDY 

EASTLAND WOOLEN MILL SITE’ 

CORINNA, MAINE 

Regulatory 

Authority 

Location 

Characteristic Regulations Status Requirement Synopsis Action to 

Federal Floodplains Floodplain Management 

Executive Order No. 11988 [40 

Applicable Requires federal agencies to evaluate potential 

adverse effects associated with direct and indirect 

Only de minimis impacts expected as part of this a

Code of Federal Regulations (CFR) Part 6, App. A] 

development of a floodplain. Alternatives that involve modification/construction within a floodplain may not be selected unless a determination is made that no practicable alternative exists. If no practicable alternative exists, potential harm must be minimized and action taken to restore and preserve the natural and beneficial values of the floodplain. United States Environmental Protection Agency (USEPA) must also provide the public with early and continuing information concerning floodplain 

installation of the dischagroundwater treatment sinstallation of the dischamade to minimize adverspracticable. Least damaremedial goals. Restoranatural and beneficial va

management. 

Federal Wetlands Protection of Wetlands 

Executive Order No. 11990 [40 CFR Part 6, App. A] 

Applicable Under this Order, federal agencies are required to 

minimize the destruction, loss, or degradation of wetlands, and preserve and enhance natural and beneficial values of wetlands. If remediation is required within wetlands areas, and no practical alternative exists, potential harm must be minimized and action taken to restore natural and 

Only de minimis impacts expected as part of this ainstallation of the dischagroundwater treatment sinstallation of the dischamade to minimize advers

beneficial values. 

Federal Navigable Waters Rivers and Harbors Act of 

1899 [33 USC 403 et seq.; 33 CFR Parts 320-323] 

Relevant and Appropriate 

Section 10 of the Rivers and Harbors Act of 1899 requires that the construction of any structure in or over any "navigable water of the U.S." including the excavation from or deposition of material in such waters, or any obstruction of alteration in such waters, obtain authorization from the 

Only de minimis impacts expected as part of this adesigned and implementalteration of navigable w

Secretary of the Army acting through the U.S. Army Corps of Engineers. 

Federal Endangered Species Endangered Species Act [16 

United States Code (USC) 1531 et seq.; 40 Code of Federal Regulations (CFR) 6.302(h); 50 CFR Part 200, 50 CFR Part 402] 

Applicable, if such species are encountered 

This statute requires that federal agencies avoid activities that jeopardize threatened or endangered species or adversely modify habitats essential to their survival. Mitigation measures should be considered if a listed species or habitat may be jeopardized. 

Although no current listetheir nests have been idebeen noted in the area. lists will be reviewed to amay be present. During relocation or seasonal wimplemented to protect l

Table 11 GW4a ARARs.xls Page 1 of 3 
ROD TABLE 10 

LOCATION-SPECIFIC ARARS FOR ALTERNATIVE GW4A 

OU1 FOCUSED FEASIBILITY STUDY 

EASTLAND WOOLEN MILL SITE’ 

CORINNA, MAINE 

Regulatory 

Authority 

Location 

Characteristic Regulations Status Requirement Synopsis Action to 

Federal Surface Waters Fish and Wildlife Coordination 

Act [16 USC 661 et seq.; 40 

Applicable Requires Federal agencies involved in actions that 

will result in the control of structural modification of 

Only de minimis impacts expected as part of this a

CFR Section 6.302(g); 33 CFR Part 320] 

any stream or body of water for any purpose, to take action to protect the fish and wildlife resources that may be effected by the action. USEPA must consult with the U.S. Fish and Wildlife Service and the appropriate state agency to ascertain the means and measures necessary to mitigate, prevent, and compensate for projectrelated losses of wildlife resources and to enhance 

installation of the dischagroundwater treatment sinstallation of the dischamade to minimize adversUSEPA will take measurproject-related impacts, U.S. Fish and Wildlife Sewill be consulted. 

the resources. 

State Wetlands Maine Wetlands Protection 

Rule [06-096 Code of Maine Regulations (CMR), Chapter 310] 

Applicable These regulations outline requirements for certain 

activities related to fresh water wetlands greater than 10 acres or with an associated stream, brook, or pond. The regulations prohibit activities, which would have an unreasonable impact on the 

Only de minimus impacts expected as part of this ainstallation of the dischagroundwater treatment sinstallation of the discha

wetland or cause a loss in wetland area, functions, and values if there is a less practicable alternative to the project that would be less damaging to the environment. If there is no practicable alternative, there must be minimal alteration of the wetland and compensation (off-setting) may be required. 

made to minimize adversalternative will be designstandards. Remedial acSebasticook River will be unreasonably interfere wminimize adverse effects aquatic life. Function anfor existing wetland/habitso that post-remediationexisting on-site wetlands

State Wetlands 

Surface Waters 

Maine Natural Resources Protection Act, permit-by-Rule 

Applicable This rule prescribes standards for specific 

activities that may take place in or adjacent to 

Response actions that inor adjacent to a wetland, 

Standards [06-096 CMR, Chapter 305] 

wetlands and water bodies. The standards are designed to ensure that the disturbed soil material is stabilized to prevent erosion and siltation of the 

these standards. Only driver channel are expecte

water. 

State Endangered Species Maine Endangered Species 

Act and Regulations [12 Maine 

Applicable The State of Maine has authority to research, list, 

and protect any species deemed endangered or 

Endangered and threateassess whether Maine lis

Revised Statutes Annotated (MSRA) Section 7751-7756; 09-137 CMR 008] (Revised: Maine Endangered Species Act and Regulations [12 Maine Revised Statutes Annotated (MSRA) Section 12801-12809; 09-137 CMR 008]) 

threatened. These species are listed as either endangered or threatened in the state regulations. The Maine Department of Inland Fisheries and Wildlife also has developed the following administrative categories for species not considered endangered or threatened, but considered important for research and further evaluation: Maine Watch List, Special Concern List, and Indeterminate Category. The Department determines appropriate use(s) of various habitats on a case-by-case basis. The Maine lists may differ from the federal lists of endangered species. 

remedial action, measurespecies if identified or en

Table 11 GW4a ARARs.xls Page 2 of 3 
ROD TABLE 10 

LOCATION-SPECIFIC ARARS FOR ALTERNATIVE GW4A 

OU1 FOCUSED FEASIBILITY STUDY 

EASTLAND WOOLEN MILL SITE’ 

CORINNA, MAINE 

Regulatory 

Authority 

Location 

Characteristic Regulations Status Requirement Synopsis Action to 

State Shoreland areas Mandatory Shoreland Zoning 

Act [Title 38, Maine Revised 

Applicable To protect and conserve shoreland areas by 

controlling activities within 250 feet of high water 

Only de minimus impacts this alternative. The only 

Statue Annotated (MRSA), Sections 435-449]. Town of Corinna Shoreland Zoning Ordinance, enacted 29 

mark, as defined in state law. discharge pipe for the dis

system. The impacts asdischarge are unavoidabadverse effects to shore

September 1991.(Revised: Mandatory Shoreland Zoning Act [Title 38, Maine Revised Statue Annotated (MRSA), Sections 435-449]. Town of Corinna Shoreland Zoning Ordinance, enacted 29 

during selection, design, to comply with the ordina

September 1991 and amended March 2004.) 

State Activities that expose 

soil with potential for erosion 

Erosion and Sedimentation Control [38 MRSA subsection 420-C], Chapter 500, Stormwater Management Rules and Chapter 502, Direct Watershed of Waterbodies 

Applicable Erosion control measures must be in place before 

activities, such as filling, displacing or exposing soil or other earthen materials take place. 

Where Site activities desoccur, USEPA will impleerosion, sedimentation ameasures will be in place groundwater treatment p

Most at Risk from New Development. 

(References the revised 

(Revised: Erosion and Sedimentation Control [Title 38 MRSA subsection 420-Cand 

420-D], Chapter 500, Stormwater Management Rules and Chapter 502, Direct Watershed of Waterbodies Most at Risk from New Development.) 

State Business/Residential 

District of Corinna 

Maine Site Location of Development Law and regulations (38 MRSA Sections 481-490, CMR Chapter 375). 

Applicable Regulations apply to control activities at certain 

federal developments so that there are minimal adverse impacts to natural resources, to include specifically, erosion and sedimentation control, noise control, and air quality control. 

To the extent that USEPfor a period of a year or impervious area, remedirequirements, if deemed groundwater treatment pexpected to be less than management, erosion ancontrols will be designed effects on natural resour

State Special Habitats and Maine Natural Areas Program To Be Considered if These state programs govern special habitats or If such special areas are Criteria, Communities (12 MRSA Section 544) such special areas communities. state programs will be coAdvisories are identified at the and site Guidance 

Table 11 GW4a ARARs.xls Page 3 of 3 
ROD TABLE 11 

CHEMICAL-SPECIFIC ARARS FOR ALTERNATIVE GW4A 

OU1 FOCUSED FEASIBILITY STUDY 

EASTLAND WOOLEN MILL SITE 

CORINNA, MAINE 

Regulatory Authority Chemical Medium Regulations Status Requirement Synopsis Action 

Federal Groundwater Safe Drinking Water Act (SDWA), 

National Primary Drinking Water Regulations (NPDWR), Maximum Contaminant Levels [40 Code of Federal Regulation (CFR) Parts 141.11 - 141.16 and 141.50 - 141.53] 

Relevant and Appropriate 

The National Primary Drinking Water Regulations establish Maximum Contaminant Levels (MCLs) and Maximum Contaminant Level Goals (MCGLs) for several common organic and inorganic contaminants. MCLs specify the maximum permissible concentrations of contaminants in public drinking-water supplies. MCLs are federally enforceable standards based in part on the availability and cost of treatment techniques. 

MCLs and non-zero groundwater cleanuAggressive in-situ tgroundwater extractime to attain MCLs to 90 years. 

State Maine Department of Human 

Services Rules Relating to Drinking Water [10-144A Code of Maine Regulations (CMR) Chapter 231-233] 

MCLGs specify the maximum concentration at which no 

known or anticipated adverse effect on humans will occur. MCLGs are non-enforceable health-based goals that are always set equal to or lower than MCLs. 

(Revised: Maine Department of Health and Human Services Rules 

Relating to Drinking Water [10-144A Code of Maine Regulations (CMR) Chapter 231-233]) 

State Criteria, Advisories and Guidance 

Groundwater Maine Standards for Hazardous 

Waste Facilities, Miscellaneous Units (06-096 CMR Chapter 854, Section 15) Maximum Exposure Guidelines (MEGs). (Maine Department of Human Services Bureau of Health Maximum 

Relevant and Appropriate 

The Maine MEGs are relevant and appropriate because they are the basis for some of the interim cleanup levels (i.e., the Interim Groundwater Cleanup Levels) for the Site groundwater. MEGs were identified as a action specific standard in the FS. The Maine standards for Hazardous Waste Facilities require that a miscellaneous unit must be closed in a manner that will ensure that hazardous waste 

MEGs were used to when the MEG conzero MCLG for that Cleanup actions wi

Exposure Guidelines for Drinking Water (1992)) 

shall not appear in ground or surface waters above MEGs. The Site is considered analogous to a miscellaneous hazardous waste unit. 

[Revised: Maine Standards for Hazardous Waste Facilities, Miscellaneous Units (06-096 CMR Chapter 854, Section 15) Maximum Exposure Guidelines (MEGs). (Maine Department of Health and Human Services 

The MEGs are non-promulgated non-enforceable recommendations for concentrations of chemical constituents in drinking water below which there is minimal risk of deleterious health effects resulting from long-term ingestion. 

Bureau of Health Maximum Exposure Guidelines for Drinking Water (1992))] 

ROD Table 12GW4a ARARs.xls Page 1 of 2 
ROD TABLE 11 

CHEMICAL-SPECIFIC ARARS FOR ALTERNATIVE GW4A 

OU1 FOCUSED FEASIBILITY STUDY 

EASTLAND WOOLEN MILL SITE 

CORINNA, MAINE 

Regulatory Authority Chemical Medium Regulations Status Requirement Synopsis Acti

Federal Criteria, Groundwater United States Environmental To Be Risk reference doses (RfDs) are estimates of daily RfDs were used Advisories and Protection Agency (USEPA) Risk Considered exposure levels that are unlikely to cause significant assessment. Guidance Reference Doses adverse non-carcinogenic health effects over a lifetime. Federal Criteria, Groundwater USEPA Carcinogenic Assessment To Be CSFs are used to compute the incremental cancer risk CSFs were used Advisories and Group, Cancer Slope Factors Considered from exposure to site contaminants and represent the assessment. Guidance (CSFs) most up-to-date information on cancer risk from USEPA's 

Carcinogenic Assessment Group. 

Federal Criteria, Advisories and Guidance 

Groundwater Guidelines for Carcinogen Risk 

Assessment EPA/630/P03/001F (March 2005) 

To Be Considered 

Provides guidance on conducting risk assessments involving carcinogens. 

Until updated or EPA to evaluate conducted in the 

Supplemental Guidance for Assessing Susceptibility from Early-Life Exposure to Carcinogens EPA/630/R03/003F (March 2005) 

State Criteria, Groundwater Maine Draft Remedial Action To Be These draft guidelines provide specific chemical These guidelines Advisories and Guidelines for Hazardous Considered concentrations determined by the State of Maine levels for the NonGuidance Substances in Soil Department of Environmental protection (MEDEP) to be to evaluate the le

protective under various exposure scenarios and for application. groundwater. 

ROD Table 12GW4a ARARs.xls Page 2 of 2 
ROD TABLE 12 

ACTION-SPECIFIC ARARS FOR ALTERNATIVE GW4A 

OU1 FOCUSED FEASIBILITY STUDY 

EASTLAND WOOLEN MILL SITE 

CORINNA, MAINE

Regulatory 

Authority Action Regulations Status Requirement Synopsis Action 

Federal In-situ treatment Safe Drinking Water Act (SDWA) 

Underground Injection Control (UIC) Program (40 Code of Federal Regulations (CFR) Parts 144, 146, and 147) 

Applicable These regulations outline minimum program and 

performance standards for underground injection programs. Technical criteria and standards for siting, operation and maintenance, closure, and reporting and record keeping as required for permitting are set forth in Part 146. 

This alternative inv

the in-situ reagents 

be implemented in set forth in these re

Federal Treatment, 

storage, or disposal of hazardous waste 

Resource Conservation and Recovery Act (RCRA), 42 United States Code (USC) §6901 et seq., Air Emissions Standards for Equipment Leaks, 40 CFR 264 Subpart BB 

Applicable if relevant equipment contains or contacts hazardous wastes with organic concentrations of at least 10 percent by weight. 

This regulation applies to equipment that contains or contacts hazardous wastes with organic concentrations of at least 10 percent by weight that are managed in particular types of treatment, storage or disposal units. The regulation addresses equipment leaks and includes standards for particular types of equipment (compressors and open-ended valves or lines, for example), record keeping standards and reporting standards. 

Data collected to d

hazardous waste wpercent by weight. equipment in the goperated and recorstandards. 

Federal Groundwater 

monitoring for the Treatment, storage, or disposal of hazardous 

RCRA, 42 USC §6901 et seq., Releases from Solid Waste Management Units, 40 CFR Part 264, Subpart F 

Applicable Requirements for the installation of groundwater 

monitoring wells and compliance monitoring. 

This alternative woinstallation of groumonitoring program

waste 

Federal Discharge of 

dredged (excavated soil) materials to surface waters and wetlands 

Clean Water Act (CWA), 33 USC §§1251-1357 

Applicable Section 404 of the CWA regulates the discharge 

of dredged or fill materials to U.S. waters, including wetlands. Filling wetlands would be considered a discharge of fill materials. Procedures for complying with regulatory conditions are contained in 33 CFR Part 323. 

Only de minimus im are expected as p

be the installation 

from the groundwaassociated with the unavoidable and 

Guidelines for Specification of Disposal Sites for Dredged or Fill Material at 40 CFR Part 230, promulgated under CWA Section 404(b)(1), maintain that no discharge of dredged or fill material will be permitted if there is a practical alternative that would have less effect on the aquatic ecosystem. If adverse impacts are unavoidable, action must be taken to restore or create alternative wetlands. 

efforts will be made ecosystems. Funcperformed for existactivities performed and river are at leaProposed activities Programmatic Genpracticable. 

Federal Surface Water 

Discharge 

CWA National Pollutant Discharge Elimination System (NPDES) 40 CFR 122, 125, 131 and 136 

Applicable This rule limits for the discharge of pollutants from 

any point source into U.S. waters. This rule takes into account the federal and state ambient water quality standards. 

All substantive reqrespect to the disctreatment plant. Awith best managemand treated ground

s Page 1 of 3 
ROD TABLE 12 

ACTION-SPECIFIC ARARS FOR ALTERNATIVE GW4A 

OU1 FOCUSED FEASIBILITY STUDY 

EASTLAND WOOLEN MILL SITE 

CORINNA, MAINE

Regulatory 

Authority 

Action Regulations Status Requirement Synopsis Actio

State Surface Water 

Discharge 

Waste Discharge Permitting Program [06-096 Code of Maine Regulations (CMR) Chapters 520-529] 

Applicable This rule requires permits issued by Maine 

Department of Environmental Protection (MEDEP) for the discharge of pollutants from the point sources. 

All substantive reqrespect to the disctreatment plant. Awith best managemand treated ground

State In-situ treatment Underground Injection Control (UIC) 

Program [06-096 CMR Chapter 543] 

Applicable These regulations outline minimum program and 

performance standards for underground injection programs. Technical criteria and standards for siting, operation and maintenance, closure, and reporting and record keeping as required for permitting are set forth in Part 146. 

This alternative invthe in-situ reagents be implemented in set forth in these re

State Actions that may 

degrade surface water quality 

Maine Water Classification Program (38 Maine Revised Statutes Annotated (MRSA) Section 464- 470) 

Applicable This program sets forth standards for the 

classification of Maine's water. The East Branch Sebasticook River is classified as Class C. Activities in a water body cannot lower water quality below the designated classification. 

The groundwater timplemented in a mdegrade the chemiEast Branch Sebas

State Actions that may 

degrade surface water quality 

Maine Surface Water Toxics Program [38 MRSA Section 420, 06-096 CMR Chapter 530.5] (Revised: Maine Surface Water Toxics Program [38 MRSA Section 420, 06-096 CMR Chapters 530 and 584]) 

Applicable This performance standard establishes numerical 

surface water quality standards for all Maine surface water. 

The groundwater timplemented in a mdegrade the chemiEast Branch Sebas

State Management of 

contaminated media 

Maine Hazardous Waste Management Rules [38 MRSA Section 1301 et seq., 06-096 CMR Chapter 850-857] 

Relevant and Appropriate 

These rules establish performance standards for treatment, disposal, and/or storage of media contaminated with hazardous waste piles, tanks, and miscellaneous units. 

To the extent they requirements, and Environmental Prooperate response arequirements of the

State Activities that 

expose soil with potential for erosion 

Erosion and Sedimentation Control [38 MRSA subsection 420-C], Chapter 500, Stormwater Management Rules 

Applicable Erosion control measures must be in place before 

activities, such as filling, displacing or exposing soil or other earthen materials take place. 

Where Site activitieMRSA 481-490 occontrols to address Applicable plans wimplementation. 

State Generation of air 

emissions 

Maine Air Quality Control Laws; Protection and Improvements of Air (38 MRSA 581-608A), Chapters 101, 105, 110, and 115 

Applicable This law and its associated regulations detail the 

requirements, limitations, and exemptions of state air emissions, including fugitive dust and emissions from air strippers. 

If remedial activitiethat includes emisstaken under this al

Federal Generation of 

Investigation Derived Waste (IDW) 

USEPA Office of Solid Waste and Emergency Response (OSWER) Publication 9345.3-03 FS, January 1992 

To Be Considered Management of IDW must ensure protection of 

human health and the environment. 

IDW that may be pgroundwater sampprotect human hea

s Page 2 of 3 
ROD TABLE 12 

ACTION-SPECIFIC ARARS FOR ALTERNATIVE GW4A 

OU1 FOCUSED FEASIBILITY STUDY 

EASTLAND WOOLEN MILL SITE 

CORINNA, MAINE

Regulatory 

Authority 

Action Regulations Status Requirement Synopsis Action 

State Criteria, Advisories and Guidance 

Generation of air emissions 

Maine Department of Human Services Interim Ambient Air Guidelines, Memorandum February 23, 1993(Revised: Maine 

Department of Human Services Ambient Air Guidelines, dated April 2004) 

To Be Considered Interim ambient air guidelines are derived from 

risk assessment-based criteria or from occupational exposure criteria that are protective of ambient air quality. 

These guidelines wemissions control e

s Page 3 of 3 
USGS TOPOGRAPHIC MAP

APPROXIMATE SCALE

CORINNA, MAINE 1 INCH = 2,000 FEET

1982

FIGURE 1

SITE LOCATION

EASTLAND WOOLEN MILL SITE

GROUNDWATER (OU1) RECORD OF DECISION

CORINNA, MAINE
FDRHER EASTLAND WDDLEN MILLDPERABLE UNIT I

0

SCHDDL STREET YARD

0' 175' ISO'

BUILDING 9 EXCAVjfflDR- •

(AREA 4) /

/

AREA 2.5 EXCAVATIDN

AREA 3 EXCAVATIDN

LEGEND

RI-TARGETED AREAS

NTCRA EXCAVATIDN AREAS

LIMITS DF DPERABLE UNITS

APPROXIMATE SCALE

FIGURE 2

OU I, OU II, AND NTCRA WORK AREAS

EASTLAND WOOLEN MILL SITE

GROUNDWATER (0U1) RECORD OF DECISION

CORINNA, MAINE
BUILDING 14 AREA

SOIL CONTAMINATION

(NTCRA PHASE I)

REMAINING AREA

SOIL CONTAMINATION

(NTCRA PHASE II/OU I AREA)

FIGURE 3

AREAS OF REMINING SOIL CONTAMINATION AFTER

THE NTCRA EXCAVATION PROGRAM

LIMIT OF NTCRA SOIL EXCAVATION

TO BEDROCK SURFACE

LIMIT OF SOIL CONTAMINATION REMAINING

AFTER NTCRA EXCAVATIONS COMPLETED

APPROXIMATE SCALE

0' 50' 100' 200'

EASTLAND WOOLEN MILL SITE

GROUNDWATER (0U1) RECORD OF DECISION

CORINNA, MAINE
14 AREA

SOIL CONTAMINATION

REMAINING AREA 1 BEDROCK

° SURFACE CONTAMINATION ~

LINE OF CROSS-SECTION DEPICTED IN

IN FIGURE 5

LINE OF CROSS-SECTION DEPICTED IN

IN FIGURE 6

LIMIT OF NTCRA SOIL EXCAVATION

TO BEDROCK SURFACE

LIMIT OF SOIL CONTAMINATION REMAINING

AFTER NTCRA EXCAVATIONS COMPLETED

AREAS OF CONTAMINATION DESIGNATED AS

THE OU I ISCO TARGET AREA

AREAS OF CONTAMINATION DESIGNATED FOR

LONG-TERM MONITORING

APPROXIMATE SCALE

FIGURE 4

OU I FOCUS AREAS

0' 50' 100' 200'

EASTLAND WOOLEN MILL SITE

GROUNDWATER (0U1) RECORD OF DECISION

CORINNA, MAINE
: DATUM ELEV

0+00 170.00

NO. mLLJ

LLJ

Q

LJ:ox.

0.

CL

VATI

<

FENCE

V ••••"•••• WASHOUT ' TILL'V.-'*'--'.""' :-v. •'

0+50

FILL

•:x:x::x:x SAND

] BASAL |,..^..----.-jMELT0UT

4 TILL [I' 1. '...'•ITILL

] GRAVEL g? " | BEDROCK

1+00

LEGEND

|>10ppm

I TOTAL VOCs

1+50

STATIC WATER TABLE

• BEDROCK

STATIC WATER TABLE

OVERBURDEN

2+00

NON-STATIC WATER TABLE

BEDROCK

NON-STATIC WATER TABLE

BEDROCK

FIGURE 5

AREA 1 CONTAMINATION REMAINING AFTER

NTCRA - OU I FOCUS AREA

EASTLAND WOOLEN MILL SITE

GROUNDWATER (0U1) RECORD OF DECISION

CORINNA, MAINE
UNCONTAMINATED

NATIVE TILL

^/W/tfWWJW/WjW/%%0%, 7///////////////////////. /

///A7////////////^AV////A y/////v/////////////

//7////.

\

CONTAMINATED TILL REMAINING AFTER NTCRA; TO

BE TREATED WITH ISCO (PHASE II)

CONTAMINATED WEATHERED BEDROCK REMAINING

AFTER NTCRA TO BE TARGETED BY ISCO AND

BIOSTIMULATION (PHASE III)

CONTAMINATED BEDDING PLANE FRACTURE

NETWORK TO BE TREATED WITH ISCO AND

BIOSTIMULATION (PHASE IV)

1 . NOT TO SCALE

2 . BEDDING PLANE FRACTURES STRIKE TO THE

SOUTHEAST AND DIP AT APPROXIMATELY 55-65- .

FIGURE 6

BEDROCK SOURCE CONTAMINATION REMAINING

AFTER NTCRA - OU I FOCUS AREA

EASTLAND WOOLEN MILL SITE

GROUNDWATER (OU1) RECORD OF DECISION

CORINNA, MAINE
STREET MAIN 

RENEWAL DRIVE 

ROUTE 7/11

EAST BRANCH 

SEBASTICOOK RIVER 

OM-06-75 

OM-06-74 

OM-06-73 

OM-06-72 

OM-06-71 

OM-06-70 

OM-06-69 

OM-06-68 

OM-06-67 

OM-06-66 

BM-06-44 

BM-06-43 

RB-04-02 

OM-01-57/58 

OM-01-51 

OM-01-50 

OM-00-46 

OM-00-45 

OM-00-20 

IM-05-07 

IM-04-04 

BM-99-09 

BM-04-37

BM-04-34 

BM-04-32 

BM-99-12F 

BM-99-10F 

Map 18 Lot 44 

Map 18 Lot 42 

Map 18 Lot 62F 

Map 18 Lot 41A 

BM-06-45 

FIGURE 7 EASTLAND WOOLEN MILL SITE 

Legend 

Estimated Limit of 2005 Chlorobenzene Compounds

Detected at or Above Cleanup Levels in

Overburden Groundwater 

Estimated Limit of 2005 Chlorobenzene Compounds

Detected at or Above Cleanup Levels in

Bedrock Groundwater 

Estimated Limit of 2002 Chlorobenzene Compounds

Detected at or Above Cleanup Levels in

Overburden Groundwater 

Estimated Limit of 2002 Chlorobenzene Compounds

Detected at or Above Cleanup Levels in

Bedrock Groundwater 

Existing Bedrock Long-Term Monitoring Location 

Existing Overburden Long-Term Monitoring Location 

Existing Bedrock Flute-Well Monitoring Location 

Former Drinking Water Well Long-Term

Monitoring Location 

Active Drinking Water Long-Term Monitoring Location 

New Overburden Groundwater Monitoring Location 

New Bedrock Groundwater Monitoring Location

115 57.5 0 115

Feet 

GROUNDWATER CONTAMINATION GROUNDWATER (OU1) RECORD OF DECISION

2002 vs. 2005 CORINNA, MAINE 
222

ROUTE 7/11

STETSON 

NOKOMIS 

LAKE 

SEBASTICOOK 

RIVER 

ROAD 

ROUTE 11/43 

ST 

ALBANS 

ROUTE 43 

ROAD 

DEXTER 

ROUTE 

EXETER 

CORUNDEL 

EAST BRANCH 

ROUTE 7 

ROAD 

ROAD 

ROAD 

ROUTE 7 

EAST BRANCH 

MAIN STREET 

HILL 

STREET 

The areas inside the yellow line (excluding the active 

groundwater cleanup areas shown in cross-hatching)

are former work areas where the cleanup has been 

completed and are currently available for reuse. 

FIGURE 8

AREAS AVAILABLE FOR REUSE 

EASTLAND WOOLEN MILL SITE

GROUNDWATER (OU1) RECORD OF DECISION

CORINNA, MAINE 

250 125 0 250

Feet 

Legend 

Active Groundwater

Cleanup Area 

Limit of Eastland Woolen Mill Superfund

Site Cleanup Activities and Extent of

Area Available for Reuse 
STREET MAIN 

RENEWAL DRIVE 

ROUTE 7/11

EAST BRANCH 

SEBASTICOOK RIVER 

Slab Area 

115 57.5 0

Feet 

Legend 

ALTERNATIVE GW4a FEATURES 

Groundwater Above Cleanup Levels 

Estimated Limit of 2005 Chlorobenzene Compounds

Detected at or Above Cleanup Levels in

Bedrock Groundwater 

Estimated Limit of 2005 Chlorobenzene Compounds

Detected at or Above Cleanup Levels in

Overburden Groundwater 

Mass Removal Components 

Extraction Well 

Horizontal ISCO Injection Well 

Estimated Limit of Soil Contamination Which Remains 

at Concentrations in Excess of NTCRA Clean Up Goals 

ISCO Injector Well 

ISCO Injection Monitoring Well 

Bedrock Borehole/ISCO Monitoring Well 

Injection/Extraction Well for Enhanced

Biological Treatment (Bedrock) 

Limit of Area Scoured to Bedrock Surface

Where Confirmation Samples Exceeded

NTCRA Clean Up Goals 

Long Term Groundwater Monitoring Components 

Inactive Bedrock Drinking Water Well to be Monitored 

Bedrock Monitoring Well/Borehole to be Monitored 

Bedrock Flute Monitoring Well to be Monitored 

Overburden Monitoring Well to be Monitored 

Active Bedrock Drinking Water Well to be Monitored 

New Long-Term Bedrock Monitoring Well 

New Long-Term Overburden Monitoring Well 

O

GURE 9 

EASTLAND WOOLEN MILL SITE

FI

I GW-4a COMPONENTS 

GROUNDWATER (OU1) RECORD OF DECISION

CORINNA, MAINE 
EAST BRANCH

SEBASTICOOK

RIVER

ST. ALBANS 

ROAD

NOKOMIS

ROAD

NEWPORT

ROAD

MILL

STREET

ROUTE 7

DEXTER

ROAD

EXETER

ROAD

STETSON

ROAD

IRELAND

AVENUE

HILL

STREET

MAIN

STREET

SUNSHINE VILLAGE DR.

FIGURE 10

INSTITUTIONAL CONTROL

ZONE LAYOUT

EASTLAND WOOLEN MILL SITE

GROUNDWATER (OU1) RECORD OF DECISION

RORINNA, MAINE

Legend

Pre-Existing Institutional Control Zone

Limit of Institutional Control Zone

Buildings Currently Served by

the Public Water System

Areas of Treated Soil Placement

Locations Currently on Public Water

Groundwater Use Prohibited (ICZ-A)

Locations Currently on Private Water

That Require Groundwater

Use Restrictions (ICZ-C)

0 400 800 1,600

Feet
OU I Record of Decision Amendment 

 Appendix C 

APPENDIX B 

STATE OF MAINE CONCURRENCE LETTER 
SEP-27-2006 10 :27 DEP LOBBY 2877826 P .01 

STATF OF MAINE 

DT.PARTMENT OF ENVIRONMENTAL PROTECTION 

JOHN ELIAS BALDACCI DAVID P LIT-TELL 

cOv. S^ 'O'ro GOVE.10~ 

September 26, 2006 

Ms. Susan Studlien, Director 

Office of Site Remediation and Restoration 

EPA New England 

1 Congress Street, Suite 1100 

Boston, MA 02114-2023 

Re : September 2006 Final Draft Record of Decision Amendment, Eastland Woolen 

Mill Superfund Site, Corinna, Maine 

Dear Ms . Studlien : 

The Maine Department of Environmental Protection (MEDEP) has reviewed the 

September 2006 Final Draft Record of Decision Amendment (ROD Amendment) with 

regard to the selected remedy for Operable Unit 1 (i .e., the groundwater) at the 

Eastland Woolen Mill Superfund Site located in Corinna, Maine . 

Based on the ROD Amendment review, the MEDEP is very pleased to concur with the 

selected remedy, Alternative GW-4a: Contaminant Mass Reduction without Active 

Hydraulic Containment for Operable Unit 1 . The major components of the selected 

remedy are listed below : 

1 . In-situ Chemical oxidation of the source material in the deep overburden 

and the shallow and deep bedrock . 

2. Application of biostimulants after the in-situ chemical oxidation program . 

3. Connection of residences to the public water supply . 

4. Implementation of institutional controls to restrict future groundwater use . 

5. Long-term monitoring . 

6. Five-year reviews. 

The MEDEP understands that with the selection of Alternative GW-4a, three 

components from the alternative selected in 2002 for the operable unit 1 are being 

deleted from the remedial action . Specifically, the three deleted components are the 

construction of a long-term groundwater treatment facility, long-term extraction and 

treatment of groundwater and the use of a co-solvent flush . 

AUGUSTA 

17 STATE HOUSE STATION BANGOR PORTLAND PRESQUE ISLE 

AUGUSTA, MAINE 04333.0017 106 HOGAN ROAD 312 CANCO ROAD 1235 CENTRAL DRIVE, SKYWAY PARK 

(207) 2874688 FAX : (207) 287 .7526 BANGOR, MAINE 04401 PORTLAND, MAINE 04103 PRESQUE ISLE, MAINE 04769-2094 

(207) 764-0477 FAX : (207) 760-3143 RAY BLDG, HOSPITAL ST. (207) 441 .4570 FAX : (207) 941 .4584 (207) 822•(,300 FAX : (207) 822,6303 

P,mied mr r e eyded piper

web 
SEP-27-2006 10 :27 DEP LOBBY 2877826 P.02 

Also, as stated in MEDEP's September 19, 2002, ROD concurrence letter the following 

still apply: 

a) This concurrence is based upon MEDEP's understanding that at the completion of 

the remedy, the residual risk posed by the site will be recalculated . As you know, 

per State of Maine policy, the upper bound incremental lifetime cancer risk that 

MEDEP can accept is 1 in 100,000 ; the upper bound hazard index that MEDEP 

can accept is 1 . 

b) MEDEP understands EPA will be responsible for the selected remedy for up to ten 

(10) years, or until the cleanup goals have been met, whichever is sooner . 

Further, the MEDEP understands that the MEDEP is responsible for paying ten 

percent (10%) of the costs during the construction and the initial ten (10) year 

period and for 100% of the selected remedy costs after the initial ten (10) year 

period. 

Lastly, it has been my experience during the past 8 or so years, that MEDEP and EPA 

have worked collaboratively at this site as well as others . Overall it has been a very 

successful partnership and MEDEP looks forward to continuing with our excellent 

working relationship with EPA at this site . If you need additional information, do not 

hesitate to contact myself or members of my staff at (207) 287-2651 . 

Respectfully, 

Mark Hyland!Kcting Director 

Bureau of Remediation & Waste Management 

PC: Mary Jane O'Donnell, EPA 

Edward Hathaway, EPA 

Rebecca Hewett, MEDEP 

Ted Wolfe, MEDEP 

Hank Aho, MEDEP 

Amended RODCOncurrenceltr 9-2006 .doc 

TOTAL P .02 
APPENDIX C 

RECORD OF DECISION RESPONSIVENESS SUMMARY 

PREFACE: 

The purpose of this Responsiveness Summary is to document EPA’s responses to the questions 

and comments raised during the public comment period. EPA considered all of the comments 

summarized in this document before selecting a final remedial alternative to address 

contamination at the Site. Attachment A to the Responsiveness Summary contains a copy of the 

transcript from the public hearing held on Thursday, May 25, 2006 at the Corinna School in 

Corinna, Maine. All of the original comments submitted by citizens and the State of Maine are 

included in the Administrative Record. 

This Responsiveness Summary addresses comments pertaining to the Proposed Plan and FFS 

Report that were received by EPA during the comment period held from May 25 to June 25, 

2006. No comments were received from local residents or the Town of Corinna. The State of 

Maine and two other entities submitted comments to EPA either in writing or at the public 

hearing. None of the comments received were in opposition to the proposed cleanup action. 

SUMMARY OF COMMENTS FROM STATE AND LOCAL OFFICIALS AND 

CITIZENS 

Only two letters were received during the comment period. The letters were from two insurance 

companies that had been notified of the proposed ROD amendment as potentially interested 

parties, and both letters essentially consisted of a denial of liability for the cleanup. Neither 

provided any comments regarding the cleanup action or regarding the proposed change to the 

remedy. The State of Maine offered comments during the Public Hearing and submitted a copy 

of the statement as a comment to the public record. The State of Maine supports the proposed 

changes to the OU I Remedial Action. ME DEP stated that it concurs with the proposed cleanup 

alternative, Alternative GW-4a, as proposed by EPA, which it understands will comply with state 

and federal applicable or relevant and appropriate requirements. EPA appreciates the support of 

the State of Maine for the proposed Amendment to the 2002 OU I ROD. 

THE SELECTED REMEDY’S CHANGES TO THE PROPOSED REMEDY MADE 

BASED UPON PUBLIC COMMENTS 

There have been no significant changes to the Proposed Amended Remedy as a result of public 

comments. No comments were received from the local public. The State of Maine is supportive 

of the EPA Amended Proposed Remedy. 
Eastland Woolen Mill

Superfund Site

Administrative Record Index 

for the Record of Decision (ROD) Amendment 

Operable Unit 1 

ROD

Signed: September 28, 2006 

Released: October 13, 2006 

Prepared by 

EPA New England 

Office of Site Remediation & Restoration 

With Assistance from 

ASRC Management Services 

6301 Ivy Lane, Suite 300 

Greenbelt, MD 20770 
INTRODUCTION

This is the Administrative Record Index for the Record of Decision Amendment to the

Eastland Woolen Mill Superfund site, Corinna, ME, Operable Unit 1 [OU01 (sitewide)].

The Record of Decision (ROD) Amendment was released on October 13, 2006. Section I

of the Index cites site-specific documents, and Section II cites guidance documents used

by the EPA staff in selecting a response action at the site.

This file includes, by reference, the Administrative Record for the Eastland Woolen Mill,

Operable Unit 2 (OU02) Record of Decision (ROD), issued on September 30, 2004, the

Administrative Record, Operable Unit 1 (OU01) Record of Decision, issued on

September 19, 2002, and the Administrative Record file for the Non-Time Critical

Removal Action for the Eastland Woolen Mill with an Action Memorandum signed on

July 22, 1999.

The Record of Decision (ROD) Amendment is available on-line at the link below and for

public review at:

EPA New England Superfund Records & Information Center

1 Congress Street, Suite 1100 (HSC)

Boston, MA 02114

(617)918-1140 (phone)

(617) 918-1223 (fax)

http://www.epa.gov/region01/superfund/resource/records.htm

Corinna Public Library (Stewart Free Library)

1 Stewart Lane

Corinna, ME 04928

(207) 278-2454 (phone)

(207) 278-5200 (fax)

Questions about this Administrative Record file should be directed to the EPA New

England site manager.

An Administrative Record is required by the Comprehensive Environmental Response,

Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments

and Reauthorization Act (SARA).
AR Collection: 3871 10/13/200* 

ROD AMENDMENT ADMIN RECORD Page 1 of 7 

AR Collection QA Report 

***For External Use*** 

02: REMOVAL RESPONSE 

240719 PRELIMINARY DRAFT OVERALL COMPLETION REPORT FOR THE NON-TIME-CRITICAL REMOVAL 

ACTION (NTCRA) 

Author: WESTON SOLUTIONS INC Doc Date: 04/01/2004 # of Pages: 856 

Addressee: US ARMY CORPS OF ENGINEERS File Break: 02.02 

Doc Type: REPORT 

240718 TRANSMITTAL FOR THE PRELIMINARY DRAFT OVERALL COMPLETION REPORT FOR THE 

NON-TIME-CRITICAL REMOVAL ACTION (NTCRA) 

Author: MICHAEL J WAGNER WESTON SOLUTIONS INC Doc Date: 04/16/2004 # of Pages: 2 

Addressee: DAVID O'CONNOR US ARMY CORPS OF ENGINEERS File Break: 02.02 

Doc Type: LETTER 

248090 TECHNICAL MEMORANDUM FOR OPERABLE UNIT 1 GW4 REMEDIAL ACTION - AREA-WIDE 

GROUND WATER SAMPLING 

Author: NOBIS ENGINEERING INC Doc Date: 03/29/2006 # of Pages: 163 

Addressee: US ARMY CORPS OF ENGINEERS File Break: 02.02 

Doc Type: REPORT 

259300 POLLUTION REPORT (POLREP) FINAL, EASTALND WOOLEN MILL 

Author: US EPA REGION 1 Doc Date: 05/10/2006 # of Pages: 8 

Addressee: File Break: 02.04 

Doc Type: POLREP 

Doc Type: REPORT 
AR Collection: 3871 

ROD AMENDMENT ADMIN RECORD 

AR Collection QA Report 

***For External Use*** 

04: FEASIBILITY STUDY (FS) 

248091 FOCUSED FEASIBILITY STUDY (FS) 

Author: NOBIS ENGINEERING INC 

Addressee: US ARMY CORPS OF ENGINEERS 

US EPA REGION 1 

Doc Type: REPORT 

248096 EPA PROPOSES CHANGES TO THE OPERABLE UNIT 1 CLEANUP PLAN 

Author: US EPA REGION 1 

Addressee: 

256000 EASTLAND WOOLEN MILL COMMENT - CLAIM# 870546071 

Author: FLO ANN WILSON GREAT AMERICAN INSURANCE GROUP 

Addressee: SUSA N STUDLIEN US EPA REGION 1 - OFFICE OF SITE REMEDIATION & RESTORATION 

Doc Type: LETTER 

Doc Date:

File Break:

Doc Date:

File Break:

Doc Date:

File Break:

10/13/200* 

Page 2 of 7 

 05/01/2006 # of Pages: 127 

 04.06 

 05/01/2006 # of Pages: 17 

 04.09 

 06/07/2006 # of Pages: 1 

 04.09 
AR Collection: 3871 

ROD AMENDMENT ADMIN RECORD 

AR Collection QA Report 

***For External Use*** 

04: FEASIBILITY STUDY (FS) 

250598 COMMENT - NOTE STATING TRAVELERS IS NOT INVOLVED IN MATTER 

Author: ILLEGIBLE ST PAUL TRAVELERS 

Addressee: SUSA N STUDLIEN US EPA REGION 1 - OFFICE OF SITE REMEDIATION & RESTORATION 

Doc Type: LETTER 

05: RECORD OF DECISION (ROD) 

256941 STATE CONCURRENCE - SEPTEMBER 19, 2006 CONSTRUCTION COMPLETE INSPECTION 

Author: REBECCA L HEWETT ME DEPT OF ENVIRONMENTAL PROTECTION 

Addressee: EDWARD M HATHAWAY US EPA REGION 1 

Doc Type: LETTER 

256943 STATE CONCURRENCE - SEPTEMBER 2006 FINAL DRAFT ON RECORD OF DECISION (ROD) AMENDMENT 

Author: MARK HYLAND ME DEPT OF ENVIRONMENTAL PROTECTION 

Addressee: SUSA N STUDLIEN US EPA REGION 1 - OFFICE OF SITE REMEDIATION & RESTORATION 

Doc Type: LETTER 

Doc Date: 06/09/2006 

File Break: 04.09 

Doc Date: 09/20/2006

File Break: 05.01 

Doc Date: 09/26/2006

File Break: 05.01 

10/13/200* 

Page 3 of 7 

# of Pages: 2 

# of Pages: 1 

# of Pages: 2 
AR Collection: 3871 10/13/200* 

ROD AMENDMENT ADMIN RECORD Page 4 of 7 

AR Collection QA Report 

***For External Use*** 

05: RECORD OF DECISION (ROD) 

259301 RECORD OF DECISION (ROD) AMENDMENT FOR OPERABLE UNIT 1 (OU1) 

Author: US EPA REGION 1 Doc Date: 09/28/2006 # of Pages: 81 

Addressee: File Break: 05.04 

Doc Type: DECISION DOCUMENT 

Doc Type: RECORD OF DECISION 

06: REMEDIAL DESIGN (RD) 

240720 TRANSMITTAL FOR FINAL OU 1 REMEDIAL DESIGN (RD) REPORT 

Author: ANDREW J BOECKELER NOBIS ENGINEERING INC Doc Date: 08/09/2005 # of Pages: 1 

Addressee: SCOTT E ACONE US ARMY CORPS OF ENGINEERS File Break: 06.04 

Doc Type: LETTER 

240721 FINAL REMEDIAL ACTION DESIGN REPORT (TEXT, FIGURES, APPENDICES A THROUGH I, AND 

INSTITUTIONAL CONTROLS) 

Author: NOBIS ENGINEERING INC Doc Date: 08/09/2005 # of Pages: 32 

Addressee: US ARMY CORPS OF ENGINEERS File Break: 06.04 

Doc Type: REPORT 
AR Collection: 3871 10/13/200* 

ROD AMENDMENT ADMIN RECORD Page 5 of 7 

AR Collection QA Report 

***For External Use*** 

08: POST REMEDIAL ACTION 

240717 2005 PHASE 1 AND PHASE 2 ISCO REMEDIAL PERFORMANCE ASSESSMENT (TEXT, FIGURES, 

APPENDICES A THROUGH J) 

Author: NOBIS ENGINEERING INC Doc Date: 01/01/2005 # of Pages: 640 

Addressee: US ARMY CORPS OF ENGINEERS File Break: 08.04 

Doc Type: REPORT 

259302 PRELIMINARY CLOSE OUT REPORT (PCOR) FOR NON-TIME CRITICAL REMOVAL ACTION AND FINAL 

SITE ACTION - OPERABLE UNIT 1 (OU1) 

Author: US EPA REGION 1 Doc Date: 09/28/2006 # of Pages: 16 

Addressee: File Break: 08.03 

Doc Type: REPORT 

13: COMMUNITY RELATIONS 

250436 PUBLIC INFORMATION MEETING [JULY 11, 2000] 

Author: Doc Date: 07/11/2000 # of Pages: 23 

Addressee: File Break: 13.04 

Doc Type: PUBLIC MEETING RECORD 
AR Collection: 3871 

ROD AMENDMENT ADMIN RECORD 

AR Collection QA Report 

***For External Use*** 

13: COMMUNITY RELATIONS 

248064 FACT SHEET - SOIL TREATMENT COMPLETED, COMMUNITY UPDATE #12 

Author: US EPA REGION 1 

Addressee: 

Doc Type: FACT SHEET 

248065 FINAL EPA FACT SHEET - RE-USE SUCCESS AT EASTLAND WOOLEN MILL SITE, COMMUNITY UPDATE 

#13 

Author: US EPA REGION 1 

Addressee: 

Doc Type: FACT SHEET 

250431 PROPOSED CHANGES TO THE GROUNDWATER CLEANUP 

Author: DON THOMPSON & ASSOCIATES COURT REPORTING 

Addressee: NOBIS ENGINEERING INC 

US EPA REGION 1 

Doc Type: PUBLIC MEETING RECORD 

250432 PROPOSED CHANGES TO THE GROUNDWATER CLEANUP 

Author: DON THOMPSON & ASSOCIATES COURT REPORTING 

Addressee: NOBIS ENGINEERING INC 

US EPA REGION 1 

Doc Type: PUBLIC MEETING RECORD 

Doc Date:

File Break:

Doc Date:

File Break:

Doc Date:

File Break:

Doc Date:

File Break:

10/13/200* 

Page 6 of 7 

 03/01/2004 # of Pages: 10 

 13.05 

 02/23/2006 # of Pages: 7 

 1305 

 05/25/2006 # of Pages: 13 

 13.04 

 05/25/2006 # of Pages: 9 

 1304 
AR Collection: 3871 10/13/200* 

ROD AMENDMENT ADMIN RECORD Page 7 of 7 

AR Collection QA Report 

***For External Use*** 

13: COMMUNITY RELATIONS 

250433 PROPOSED CHANGES TO THE GROUNDWATER CLEANUP 

Author: DON THOMPSON & ASSOCIATES COURT REPORTING Doc Date: 05/25/2006 # of Pages: 7 

Addressee: NOBIS ENGINEERING INC 

File Break: 13.04 

US EPA REGION 1 

Doc Type: PUBLIC MEETING RECORD 

250599 CONDENSED TRANSCRIPT - DEP PROPOSED CHANGES TO THE GROUNDWATER CLEANUP, EASTLAND 

WOOLEN MILL SUPERFUND SITE 

Author: DON THOMPSON & ASSOCIATES COURT REPORTING Doc Date: 05/25/2006 # of Pages: 7 

Addressee: NOBIS ENGINEERING INC 

File Break: 1304 

Doc Type: PUBLIC MEETING RECORD 

Number of Documents in Collection22 
EPA Region 1 AR Compendium GUIDANCE DOCUMENTS

EPA guidance documents may be reviewed at the EPA Region I Superfund Records Center in 

Boston, Massachusetts. 

TITLE 

GUIDE TO PREPARING SUPERFUND PROPOSED PLANS RECORDS OF DECISION AND OTHER REMEDY SELECTION DECISION DOCUMENTS 

DOCDATE OSWER/EPA ID DOCNUMBER 

7/1/1999 OSWER9200.1-23P C525 

TITLE 

GUIDANCE FOR MONITORING AT HAZARDOUS WASTE SITES: FRAMEWORK FOR MONITORING PLAN DEVELOPMENT AND 

IMPLEMENTATION 

DOCDATE OSWER/EPA ID DOCNUMBER 

1/1/2004 OSWER 9355.4-28 C561 

TITLE 

CLOSE OUT PROCEDURES FOR NATIONAL PRIORITIES LIST SITES 

DOCDATE OSWER/EPA ID DOCNUMBER 

1/1/2000 OSWER 9320.2-09A-P C621 

TITLE 

DRINKING WATER HEALTH ADVISORY FOR MANGANESE 

DOCDATE OSWER/EPA ID DOCNUMBER 

1/1/2004 EPA-822-R-04-003 C636 

TITLE 

2004 EDITION OF THE DRINKING WATER STANDARDS AND HEALTH ADVISORIES 

DOCDATE OSWER/EPA ID DOCNUMBER 

11/1/2004 EPA-822-R-04-005 C637 

TITLE 

SUPPLEMENTAL GUIDANCE FOR ASSESSING SUSCEPTIBILITY FROM EARLY-LIFE EXPOSURE TO CARCINOGENS 

DOCDATE OSWER/EPA ID DOCNUMBER 

3/5/2005 EPA/630/R-03/003F C638 

Wednesday, September 27, 2006 Page 1