U.S. ENVIRONMENTAL PROTECTION AGENCY 

REGION I 

1 CONGRESS STREET, SUITE 1100, BOSTON, MA 02114-2oi., 

MEMORANDUM 

DATE: July 22, 1999 

SUBJ: ACTION MEMORANDUM - Request for a Non-Time Critical Removal Action at the Eastland Woolen 

Mill Superfund Site, Corinna, Maine 

FROM: Edward M. Hathaway, Remedial Project Manager .. 

MEA/T/CT Superfund Section 

THRU: Don Berger, Chief ^ 

OSRR II Branch^^^^ 

Dennisses Valdes, Acting ^ie|4dj,-;^,^.s.,i^-.c> '/fcifflA 

Emergency Planning and Response Branch 

TO: Patricia L. Meaney, Director 

Office of Site Remediation and Restoration 

V'^ . -., Superfurtd Records Ceniei\ 

BKbAK.: Z 

'UTlTEKr/^Sf^ 

SiteID#01T6 

I. PURPOSE 

This Action Memorandum requests and documents your approval ofthe non-time-critical 

removal action (NTCRA) described herein for the Eastland Woolen Mill Superfund Site, located 

on,Route 7 in Corinna, Maine. This Action Memorandum also requests and documents the 

approval of a "consistency" exemption from the $2 million and 12 month statutory limits. This 

NTCRA is expected to be completed within 12-24 months of mobilization and require 

approximately $9.7 million in funding. 

The overall objective ofthe NTCRA is to eliminate the source ofthe soil, groundwater, and 

sediment contamination in order to protect current and future users of groundwater at or near the 

Site, future users ofthe Site property, and ecological receptors. In general terms, the NTCRA 

consists ofthe excavation of soils with concentrations of monochlorobenzene, benzene, (1,2; 1,3; 

and 1,4) dichlorobenzene, and (1,2,3 and 1,2,4) trichlorobenzene above the soil cleanup levels 

specified in this Action Memorandum. The excavated soil will be treated using thermal 

desorption with combustion ofthe emissions. This NTCRA vvill be performed by EPA using 

fund money as no PRP is available to implement the response action in a timely manner. 
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE 

This Action Memorandum does not include a request to fund any Post-Removal Site Control 

(PRSC). The State of Maine has provided a letter of concurrence with the NTCRA and has 

indicated that it is willing to enter into a Memorandum of Understanding with EPA to perform 

and finance any long-term obligations that may result from the bridge replacement or surface 

water management structures. 

This NTCRA will ensure that EPA can provide a timely response to effectively minimize threats 

to public health or welfare or the environment which may result from the continuing release 

and/or threat of release of hazardous substances at and from the Site, and is consistent with 

EPA's Superfund Accelerated Cleanup Model (SACM). 

While the NTCRA will accelerate the overall Site cleanup by containing and reducing site 

contamination, it may not constitute the complete and final cleanup plan for the Site. Additional 

NTCRA's may be considered as more information regarding the Site conditions become 

available. The January 1999 Approval Memorandum included authorization to implement a 

second NTCRA regarding downstream contamination and groundwater, if necessary. 

EPA may select additional response actions in a Record of Decision (ROD), scheduled for the 

fall of 2001. The ROD is expected to define the levels of contaminant reduction necessary for 

long-term public health and envirormiental protection, and define what steps, if any, are 

necessary to address restoration ofthe contaminated groundwater and other Site media. 

II. SITE CONDITIONS AND BACKGROUND 

A. Site Description 

CERCLIS ID No.: MED980915474 

Site ID. No.: 01T6 

Category Non-time-critical 

The Site includes the former Eastland Woolen Mill and the local areas contaminated by the 

release of hazardous substances from the Eastland Woolen Mill. Eastland Woolen Mill was a 

textile mill that began operation in approximately 1909. The existing Mill structure includes 

several connected building with a floor space of approximately 250,000 square feet. The 

Eastland Woolen Mill ceased operation in 1996 and the majority ofthe Mill property is now 

owned by the Town of Corinna. 
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE 

1. Removal Site Evaluation 

From a period of 1909 to 1971, the Eastland Woolen Mill disposed of its liquid wastes 

into the East Branch ofthe Sebasticook River and the soils beneath the Mill building. 

There were also historical leaks from the underground storage tanks. In 1971, the 

Eastland Woolen Mill began discharging most of its waste to the Corirma Sewer system. 

By 1977, all waste water from the Eastland Woolen Mill was directed into the sewer line. 

(See Attachment 3 for more information regarding Site History). 

The State of Maine performed a removal action assessment prior to initiation of an 

emergency response in 1996 and also completed the Preliminary Assessment and Site 

Inspection Reports in support of placing the site on the National Priorities List. In April 

1999, the Eastland Woolen Mill Site was proposed for inclusion on the National Priorities 

List. The Site was listed as a final NPL Site in July 1999. 

In November 1998, EPA performed a field program to further define the basis for listing 

or the need for a removal action. In April 1999, EPA initiated the remedial investigation 

and feasibility study (RI/FS) for the Site. The data collected during these activities 

further documented that substantial concentrations of monochlorobenzene, 

dichlorobenzenes (1,2; 1,3; and 1,4), and trichlorobenzenes (1,2,3 and 1,2,4) have been 

released into the environment. The soils, groundwater, and the sediment ofthe Site area, 

including the East Branch ofthe Sebasticook River have been contaminated. Several 

homes have lost the use of their water supply well and several additional homes have 

contamination (below drinking water standards) in their current water supply well. 

Based upon the preliminary results ofthe previous investigations and the RI/FS, EPA 

signed an Approval Memorandum in January 1999 to initiate an Engineering 

Evaluation/Cost Analysis (EE/CA) to assess various options for controlling and 

containing the source of contamination at the Site. See EE/CA Approval Memorandum 

(Attachment 2). 

2. Physical Location 

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

Maine. The Town of Corinna is located approximately 25 miles northwest of Bangor, 

Maine. Approximately 800 persons live within 1 mile ofthe Site and 2,500 with 4 miles. 

(See Figure 1 for general Site location) 

The Site is located in the center dominated by the 250,000 square foot Eastland Woolen 

Mill (See Figure 2). Portions ofthe Eastland Woolen Mill are located on both sides of 
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE 

the East Branch ofthe Sebasticook River as well as above the river. Side buildings and 

former tank areas are also located at the Site. Three dams are found in the vicinity ofthe 

Site. One dam is approximately 500 feet north (upstream) ofthe Eastland Woolen Mill 

and serves as the outlet for Corrundel Lake. A second dam is located beneath the 

Eastland Woolen Mill and serves as the outlet for the Mill Pond. The third dam is located 

approximately 0.5 miles down river ofthe Eastland Woolen Mill. 

The Site has been used as industrial property since at least 1912. The Eastland Woolen 

Mill building may have been constructed as early as the late 1800's. The Eastland 

Woolen Mill Company owned and operated the mill from 1936 until 1996. The company 

assets were sold at a real estate foreclosure auction in 1997. In 1997, the Town of 

Corinna took title to the parcel on which the majority ofthe Eastland Woolen Mill 

buildings are located. The Eastland Woolen Mill and its associated side buildings are 

currently abandoned. 

3. Site Characteristics 

The Eastland Woolen Mill is currently an abandoned structure. The building has 

experienced flooding, trespass, and there is no electric power or fire suppression system 

at this time. Hazardous substances were likely used throughout the entire operating 

history ofthe Mill. Chlorobenzenes were reportedly used in large quantities from the 

1960's through closure. Chlorobenzenes are a major component ofthe dye-aid used in the 

dye kettles to add color to the wool. The original disposal practice was to discharge the 

waste either directly into the East Branch ofthe Sebasticook River or into a tail race that 

led to the river. In addition, wastes were also dumped directly onto the concrete floors 

and allowed to infiltrate the floor or flow over the floor toward the river. 

In 1971, most ofthe waste stream was diverted from the river to the Town of Corinna 

sewer. No pre-treatment ofthe waste was performed prior to discharge into the sewer. 

By 1977, all wastes from the Eastland Woolen Mill were discharged to the publically 

owned treatment works (POTW) for the Town of Corinna. The Eastland Woolen Mill 

represented over 80% ofthe flow to the POTW. A sample ofthe waste water discharging 

to the POTW after a spill of a dye aid chemical at the Eastland Woolen Mill revealed over 

12 mg/l of dichlorobenzene and 1 mg/l of trichlorobenzene in the waste water. 

All drinking water in the Town of Corirma was originally obtained from private water 

supply wells drilled into the bedrock. Each residence or business had an individual water 

supply well as a public or private water supply line was not available prior to 1995. 

Contamination of local water supplies was first detected in 1983 when a member ofthe 

Maine Department of Environmental Protection (Maine DEP) had the water at a local 
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE 

restaurant tested based upon a peculiar odor and taste to the water. After testing revealed 

that the water at five locations was contaminated with chlorobenzene compounds above 

drinking water standards, the Eastland Woolen Mill Company installed activated carbon 

filters at these locations. The locations were in the immediate vicinity ofthe mill. The 

Eastland Woolen Mill Company also initiated a quarterly sampling program under the 

oversight ofthe Maine DEP. By 1988, testing ofthe water supplies of private residences 

and local businesses revealed 11 locations with levels of chlorobenzenes warranting 

carbon filters. Contamination was detected in an area spreading approximately 800 feet 

from the Eastland Woolen Mill. 

In 1984, the Eastland Woolen Mill Company hired a consultant to perform a 

hydrogeologic characterization ofthe downtown area. The work included the installation 

of monitoring wells and soil borings to allow sampling ofthe soil and groundwater. In 

1988, a study ofthe contamination, including the possible location of.a new water supply 

that could serve the contaminated properties, was completed. A second study was 

completed in 1993 that identified the tail race beneath the Eastland Woolen Mill and an 

underground storage tank as the most likely sources of contamination. 

The Eastland Woolen Mill Company removed several underground storage tanks in 1994 

and installed a groundwater recovery well at the location ofthe tanks to address low pH 

groundwater and to remove chlorobenzene compounds from a smear zone. The pumping 

of this well was discontinued in 1996. The Eastland Woolen Mill Company also began 

pumping one ofthe most contaminated former private water supply wells as a 

groundwater recovery well. The water from this well was discharged into the Town of 

Corinna sewer line without pre-treatment. The State of Maine ceased operation ofthe 

recovery well in 1999. 

In 1995, a water supply line was installed to serve the downtown area of Corirma. The 

water supply well is located approximately 1000 feet east ofthe Eastland Woolen Mill on 

Palmyra Road and runs along Palmyra to the intersection with Routes 7 and 11 where the 

water extends a short distance east on Route 7 and 11 before crossing the East Branch of 

the Sebasticook River near the railroad bridge. The water line then runs along Main 

Street before splitting in three directions. One section runs up Spring Street to the 

Corinna Elementary School, one section runs up Exeter Street (Routes 11 and 43) and the 

third section runs up Dexter Road (Route 7) (See Figure 2). Not all residences located 

along the water line are connected to the water line. 

The water supply line'was installed by funds provided by the Eastland Woolen Mill 

Company, the Farmers Home Administration and a Community Development Block 

Grant. The Eastland Woolen Mill Company also agreed to fund the operation and 
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE 

maintenance ofthe water line. During installation of a sewer line across the East Branch 

ofthe Sebasticook River, high concentrations of chlorinated benzenes were detected in 

the sediments: Further investigation ofthe river sediments revealed additional pockets of 

contamination extending several hundred feet down river. 

In 1996, when the Eastland Woolen Mill closed, the Maine DEP assumed the 

responsibility for the quarterly monitoring program and has provided fiinding to maintain 

and operate the water supply line. 

In 1997 and 1998, the Maine DEP performed additional investigations to confirm the 

extent of river contamination. These investigations confirmed that high levels of 

chlorinated benzenes are found in the river bed extending over 1000 feet down river of 

the Eastland Woolen Mill. 

In 1997, the Maine DEP performed an emergency response action to remove 54,673 

pounds of various hazardous substances from process pipes, containers, and vessels 

located within the Eastland Woolen Mill. 

EPA began an expanded Site inspection in November 1998 to better define the 

contamination in the soil under the Eastland Woolen Mill main building and in the 

subsurface soils adjacent to the Eastland Woolen Mill. 

4. Release or threatened release into the environment of a hazardous substance, or 

pollutant or contaminant 

Information gathered from state, federal and owner/operator records indicate that 

hazardous substances were used and disposed at to the Site. As a result of improper 

waste disposal practices many ofthe hazardous substances have been released into the 

environment. Site investigations, as further documented below, have detected 

hazardous substances in the soils, groundwater, and sediments within and adjacent to the 

Site. In particular, benzene, monochlorobenzene, dichlorobenzenes (1,2; 1,3; and 1,4), 

and trichlorobenzene (12,3, and 1,2,4) have been detected at concentrations above those 

acceptable for human and ecological exposure. All ofthe compounds of concern are 

"hazardous substances" as defined by CERCLA Section 101(14) and 40 C.F.R. Section 

300.5. 

The release ofthe hazardous substances into the environment has resulted in the 

contamination of soils, groundwater, and sediments. While these hazardous substances 

do not represent a fire or explosion threat, substantial human health and environmental 
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE 

risks may occur as a result ofthe hazardous substances found on Site. 

Nature and Extent of Contamination 

As described above, several investigations have been performed at the Site. While 

company records and work performed by the contractor for the Eastland Woolen Mill 

Company provide the most substantial basis for the type and quantity of contamination, 

the investigations undertaken by the Maine DEP and EPA further verified the presence of 

substantial contamination at the Site. 

The current conceptual Site model is that the groundwater and sediments have been 

significantly impacted by the historical release of contamination from the Eastland 

Woolen Mill building and storage tanks. Some ofthe contamination has migrated into 

the associated subsurface soils and also into the surface water, sediments, and 

groundwater. Substantial quantities of contamination are present in the soils beneath and 

adjacent to the Eastland Woolen Mill main building. This contamination represents a 

long-term source of hazardous substances that will contribute to the contamination 

currently detected in the surface water, groundwater, and sediments. The presence of 

non-aqueous phase liquid (NAPL) in sediments has been reported based upon visual 

observations during the installation ofthe water line and the Maine DEP investigation 

program. 

Each Site medium will be discussed separately. 

a. Soils: 

The soils under the building and at a near-by vacant lot (known as Lot 88) are 

contaminated with various chemicals. In particular, mono, di, and tri chlorobenzene have 

been disposed into the subsurface under the building. The dye-aid material used at the 

Site was comprised of 65% dichlorobenzene, 28% biphenyl, 1-2% chlorobenzene, and 1-

2% trichlorobenzene. The waste water from the facility was disposed through a trap door 

in the floor into a "tail race" that ran into the East Branch ofthe Sebasticook River. 

Some ofthe contamination also migrated into the soils beneath the tail race. In locations 

separate from the tail race, the waste material was allowed to drain onto the concrete floor 

resulting in run-off to the river or migration directly into the subsoils. Field screening 

and laboratory results obtained during the EPA 1998 field program support that 

contamination is still located in the soils beneath the building and on Lot 88. Lot 88 was 

the location of a warehouse which materials used at the Mill were stored before and after 

use. The chlorobenzenes were detected in several borings that were drilled through the 

basement ofthe former Mill building. Soil contamination extended to a depth of 
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE 

approximately 20 feet. (See Figures 3 and 4 for extent of soil contamination). Table 1 

below provides a comparison ofthe contaminant concentrations detected in the soil with 

EPA screening criteria that are set at levels protective of human health. 

The Maine DEP has estimated that 27,500,000 gallons of waste water containing 

chlorobenzenes were used and disposed into the tail race and soils from 1961 to 1971. 

Additional quantities of contamination, in the form of chemical spills, were also released 

into the environment after 1971 when the facility began discharging its wastewater to the 

POTW. 

The subsurface soils adjacent to the Eastland Woolen Mill building were also found to be 

contaminated with chlorobenzenes. Former storage tanks on the property are the 

suspected source of this contamination. 

Soil 

Table 1 

Contamination 

Compound 

benzene 

monochlorobenzene 

1,3 dichlorobenzene 

1,2 dichlorobenzene 

1,4 dichlorobenzene 

1,2,4 trichlorobenzene 

Range of 

Detections/max 

(mg/kg) 

nd-14 

nd - 700 

nd -2,300 

nd -1,800 

nd -3,400 

nd -6,000 

EPA Screening 

Level for 

Direct Contact 

(residential) 

mg/kg 

0.62 

54 

41 

370 

3 

480 

Maine 

Remediation Level 

for Direct Contact 

(residential) 

(mg/kg) 

5 

310 

2670 

540 

EPA Soil Screening 

Level for 

groundwater 

protection 

(mg/kg) 

0.03 

1 

17 

2 

5 

The compounds shown in the above Table 1 are substantially above levels considered 

protective of human health from a direct contact and groundwater exposure perspective. 

This further supports the conclusion that the contaminated soils are acting as a source for 

the continued degradation ofthe groundwater, surface water, and sediments. 
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE 

b. Groundwater: 

The chlorobenzenes disposed at the Site have migrated into the overburden and bedrock 

groundwater. As a result of this contamination several water supplies were required to be 

treated, then replaced with an altemative water supply. Several area residents are 

drinking water with Site-related contamination (the levels are not above drinking water 

standards). The levels in at least one location have been increasing. There is a 

continuing release of contamination from the. soil into the groundwater. 

The groimdwater contamination extends in several directions from the Eastland Woolen 

Mill for approximately 800 feet (See Figure 5). Data has been collected from former 

private residences and business water supply wells by the Maine DEP since 1996 and 

EPA collected additional groundwater data in April 1999. The data in column 2 in the 

table below shows the concentrations in wells that have been connected to the water line 

or from monitoring wells. The data from these wells reveals concentrations well above 

federal and state drinking water standards or risk based standards for the compounds 

monochlorobenzene, benzene, 1,2 dichlorobenzene, 1,4 dichlorobenzene, and 1,2,4 

trichlorobenzene. 

Sampling of current private water supply wells reveals that the plume extends beyond the 

limits ofthe water line. The results ofthe sampling ofthe individual private water supply 

wells still in use are shown in column 3 ofthe table below. There are currently 13 water 

supply wells that are still in use which contain low levels of contamination. 

Table 2 

Groundwater Contamination 

Compound 

chlorobenzene 

benzene 

1,2 dichlorobenzene 

1,3 dichlorobenzene 

1,4 dichlorobenzene 

1,2,4 trichlorobenzene 

Maximum concentration in 

former water supply wells 

(ug/1) 

9,000 

454 

2,400 

790 

4,300 

1„800 

Maximum concentration in 

current water supply wells 

(ug/L) 

17.4 

0.5 

5.9 

0.9 

5.0 

9.8 

MCL 

(ug/1) 

100 

5 

600 

75 

70 

State of 

Maine 

(MEG) 

(ug/1) 

47 

5 

85 

85 

27 

70 
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE 

The nature ofthe groundwater system at the Site is that bedrock is the predominant 

aquifer. The overburden in the area ofthe Site is a sequence of two compact tills. Till 

thickness ranges from 0-40 feet. No true confining layers have been identified, therefore, 

the overburden and bedrock are considered one groundwater unit. The bedrock is a 

fractured phyllite with several preferred flow directions. The migration ofthe 

contamination indicates that the bedrock is well fractured and that the fractures are 

cormected. Bedrock water supplies in the area vary in depth, with wells as shallow as 75 

feet and as deep as 544 feet. 

Additional characterization of the groundwater will occur during the expected remedial 

investigation. It is reasonable to conclude that the groundwater contamination was 

caused by the release of hazardous substances from the Eastland Woolen Mill. 

c. Sediments and Surface Water: 

Chlorobenzene, dichlorobenzene, and trichlorobenzene were detected by Maine DEP in 

the surface water ofthe East Branch ofthe Sebasticook River. Concentrations of 12-28 

ug/1 were detected for these three constituents in the surface water. There are no acute or 

chronic ambient water quality criteria for the chlorobenzenes. 

The sediments within the East Branch ofthe Sebasticook" River also appear to be 

significantly impacted by the Eastland Woolen Mill. The East Branch ofthe Sebasticook 

River is a class C river according to the State of Maine classification program. Based 

upon this classification, the State of Maine expects the river to be useable as a drinking 

water source, fishing location, and swimming location. The river does not meet the 

requirements for a class C river at this time. 

The 1997 investigation program performed by the Maine DEP revealed contamination in 

the river sediments extending over 1000 feet down river ofthe Eastland Woolen Mill. 

Chlorobenzene, dichlorobenzene, and trichlorobenzene were detected at concentrations 

up to 190, 710, and 400 mg/kg respectively. The 1998 Maine DEP investigation program 

confirmed that chlorobenzenes were present in the sediments, although the levels detected 

in 1998 were substantially lower than 1997. 

d. Building Contamination: 

In addition to the contamination detected in the soils, groundwater, surface water, and 

sediment, the Eastland Woolen Mill main building also contains a significant quantity of 

asbestos as well as some lead based paint on the interior. 

10 
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE 

5. NPL Status 

The Site was proposed for inclusion on the National Priorities List (NPL) on April 23, 

1999 (64 Fed. Reg. 19968). The comment period for the NPL listing closed June 23, 

1999. No comments were received in opposition to the listing. The Site was finalized on 

the NPL on July 22, 1999. 

EPA began the remedial investigation and feasibility study ofthe Site in April 1999. 

6. Maps. Pictures and Other Graphic Representations 

Attachment 1 - Figures and Tables 

Attachment 2 - EE/CA Approval Memo 

Attachment 3 - Site Chronology 

Attachment 4 - ARAR Tables 

Attachment 5 - EE/CA Fact Sheet 

Attachment 6 - Response to Comments 

Attachment 7 - Public Hearing Transcript 

Attachment 8- Administrative Record Index 

Attachment 9 - Enforcement Addendum 

II. B. Other Actions to Date 

1. Previous Actions 

As previously mentioned, the Maine DEP completed a removal action at the Site in 1997. 

The Eastland Woolen Mill also completed the removal of several underground storage 

tanks. 

1 1 
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE 

2. Current Actions 

The Site is currently under investigation as part of a RI/FS. At the same time, in order to 

control the continuing contamination ofthe surface soils, sediments, and groundwater as 

expeditiously as possible, EPA conducted an EE/CA to support a non-time critical 

removal action, (see EE/CA Approval Memorandum, Attachment 2). The EE/CA 

evaluated various response actions to control the source of contamination at the Site, 

based upon cost, effectiveness, and implementability. The EE/CA was completed by an 

EPA contractor under EPA oversight. 

The final EE/CA Report was placed into the site file in May 1999. EPA mailed copies of 

the EE/CA Fact sheet describing the proposed NTCRA to the State of Maine, local 

officials, local residents, PRPs, and other interested parties. EPA held a public 

informational meeting on May 27, 1999 to present the EE/CA and EPA's preferred 

alternative (see EE/CA Fact Sheet, Attachment 5). EPA then held a public hearing on 

June 24, 1999 to receive oral comments. The public comment period began on May 28 

and ended on June 28. The NTCRA selected in this Action Memorandum is EPA's 

formal decision stemming from the EE/CA process. Approximately 80 comments were 

received in writing and at the public hearing. All comments received during the public 

hearing and via mail were in support ofthe EPA proposed action. 

While the NTCRA will accelerate the overall Site cleanup by containing and reducing site 

contamination, it may not constitute the complete and final cleanup plan for the Site. 

Additional NTCRA's may be considered as more information regarding the Site 

conditions become available. The January 1999 Approval Memorandum included 

authorization to implement a second NTCRA regarding downstream contamination and 

groundwater, if necessary. The NTCRA is consistent with the RI/FS and long-term 

remedial response at the Site. 

C. State and Local Authorities' Role 

1. State and Local Actions to Date 

The State of Maine has performed response actiiDns at the Site pursuant to the 

Maine Uncontrolled Hazardous Substance Sites Law. The State supported the 

inclusion ofthe Site on the NPL and has since reviewed and commented on the 

various components ofthe RI/FS. EPA consulted with the State regarding the 

performance of a non-time-critical removal action at the Site, and the State has 

indicated its full support for this expedited approach to site cleanup. 

12 
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE 

Local authorities have been actively involved in the Site since the Town of 

Corinna owns a large portion ofthe Site. 

2. Potential for Continued State/Local Response 

The State and local authorities are expected to maintain a high level of interest in 

the Site. The State is expected to review and comment on the upcoming RI/FS 

activities, as well as the final selection of a remedial action. The State will 

participate in the implementation ofthe NTCRA as a support agency. 

III. THREATS TO PUBLIC HEALTH OR WELFARE OR THE ENVIRONMENT. 

AND STATUTORY AND REGULATORY AUTHORITIES 

Section 300.415(b)(2) ofthe National Contingency Plan (NCP) lists a number of factors for EPA 

to consider in determining whether a removal action is appropriate, including: 

(i) Actual or potential exposure to nearby human populations, animals, or the food 

chain from hazardous substances or pollutants or contaminants; 

(ii) Actual or potential contamination of drinking water supplies or sensitive 

ecosystems; 

(iii) Hazardous substances or pollutants or contaminants in drums, barrels, tanks, 

or other bulk storage containers, that may pose a threat of release; 

(iv) High levels of hazardous substances or pollutants or contaminants in soils 

largely at or near the surface, that may migrate; 

(v) Weather conditions that may cause hazardous substances or pollutants or 

contaminants to migrate or be released; 

(vi) Threat of fire or explosion; 

(vii) The availability of other appropriate federal or state response mechanisms to 

respond to the release; and 

(viii) Other situations or factors that may pose threats to public health or welfare 

ofthe United States or the environment. 

1 3 
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE 

An evaluation ofthe conditions at the Eastland Woolen Mill Site conclude that factors (i), (ii), 

(iv), (v), (vi), (vii), and (viii) are applicable as described below. 

(i) Actual or potential exposure to nearby human populations, animals, or the food chain from 

hazardous substances or pollutants or contaminants - At present, the contamination in the 

groundwater and sediments represents the most significant threat to human health and the 

environment. The groundwater has been declared unsafe to drink in portions ofthe community 

and concentrations are increasing outside the area ofthe water line. The ecological community is 

being impacted by the presence of substantial contamination in the riverbed soil and sediments. 

If the Eastland Woolen Mill were to catch fire as a result of its abandoned condition, substantial 

releases to the soil, surface water, sediments, and groundwater would occur. In addition, the 

Town has indicated a desire for future residential development at the Site. As a result, 

subsurface soils could be exposed during future excavations. In the long term, significant human 

health and ecological harm will occur if the primary source of groundwater, surface water, and 

sediment contamination at the Site - soil - is not remediated, and if the building is not 

demolished in order to remediate subsurface soils. 

(ii) Actual or potential contamination of drinking water supplies or sensitive ecosystems -

Residents ofthe community have been exposed to contamination through ingestion of 

contaminated groundwater. A water line protects residences that have well water with 

contaminants above MCLs. Analysis of samples from private water supplies not currently on the 

water line shows elevated levels of contamination, although those levels are not currently above 

MCLs. In addition, substantial concentrations of chlorinated benzenes (mono-, di-, and tri-) have 

been detected in the surface water and riverbed soil of the East Branch of the Sebasticook River. 

The contamination seriously impairs the pond and river ecological system. 

(iv) High levels of hazardous substances or pollutants or contaminants in soils largely at or near 

the surface, that may migrate - High levels of contamination are believed to be in the 

floor/basement ofthe Eastland Woolen Mill and have been confirmed in the soils beneath, and 

adjacent to, the Eastland Woolen Mill. The contamination in these locations represents a source 

of material that are contaminating the groundwater, and the surface water and sediments ofthe 

East Branch ofthe Sebasticook River. Pockets of NAPL likely exist in the riverbed soils and are 

a source of contamination that may continue to affect surface water and may migrate down river 

during high river stage. 

(v) Weather conditions that may cause hazardous substances or pollutants or contaminants to 

migrate or be released - The Site is located in an area of high rainfall and snowfall. During the 

1997-1998 winter, a portion ofthe structure collapsed due to snow/ice weight. Further collapse 

may result in portions ofthe Eastern Woolen Mill main building falling into the East Branch of 

the Sebasticook River. Spring run-off in 1998 caused the dam under the building to overtop, 

resulting in water flowing through the structure, which is believed to be contaminated, and 

14 
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE 

bringing additional hazardous substances into the environment. Because the floor of the Eastland 

Woolen Mill is believed to be contaminated due to former operations in the building, winter and 

spring weather conditions may have already resulted in hazardous substances being released to 

the environment. Without remediation, further releases are likely to occur. 

(vi) Threat of fire or explosion - The Site itself is not an imminent threat with respect to an 

explosion. However, as previously discussed, the Eastland Woolen Mill is abandoned. There is 

evidence that the Eastland Woolen Mill has been accessed by trespassers and vandals. If 

accessed by homeless trespassers, it is likely that they will set fires for warmth. It would be 

difficult for the Town of Corinna to handle any major fire due to both the magnitude ofthe fire 

and the potential hazardous substances that could be released by both the fire itself and efforts to 

combat the fire (water run-off, etc). The building has no power to maintain a fire suppression 

system. 

(vii) The availability of other appropriate federal or state response mechanisms to respond to the 

release - There are no other known federal or state funds or response mechanisms available to 

finance this action. 

(viii) Other situations or factors that mav pose threats to public health or welfare or the 

environment - The contamination believed to be within and under the building floor/basement is 

a likely continuing source ofthe soil, groundwater, sediment, and surface water contamination. 

Based upon the NCP factors previously listed, a threat exists to public health or welfare or the 

environment due to the release of hazardous substances into the environment. A non-time 

critical removal action is therefore appropriate to abate, prevent, minimize, stabilize, mitigate, or 

eliminate such threats. In particular, a non-time critical removal action involving source control 

measures is necessary to remove, control or contain the risk of future ingestion of groundwater, 

and the risk of a release of hazardous substances from the Site to East Branch ofthe Sebasticook 

River. 

This removal is designated as non-time-critical because more than six months planning time is 

available before on-site activities must be initiated. Prior to the actual performance of a non-time 

critical removal at this Site, Section 300.415(b)(4) ofthe NCP requires that an engineering 

evaluation/cost analysis (EE/CA) be performed in order to weigh different response options. An 

EE/CA was performed, and the EE/CA Report has been distributed (and made available) to the 

public, as discussed previously. 

1 5 
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE 

IV. ENDANGERMENT DETERMINATION 

Actual or threatened releases of hazardous substances, pollutants, or contaminants, from this Site, 

if not addressed by implementing the response action selected in this Action Memorandum, may 

present an imminent and substantial endangerment to public health, or welfare, or the 

environment. 

V. EXEMPTION FROM STATUTORY LIMITS 

This removal will require funding above the statutory ceiling of $2 million dollars and may 

require more than 1 year to implement. The proposed NTCRA is projected to cost $9.7 million 

and take 18-24 months to complete. Therefore, the statutory ceilings with respect to funding and 

duration will be exceeded. A "consistency" exemption is sought to exceed $2 million ceiling and 

12 month limit in order to implement the NTCRA proposed in this Action Memorandum. 

The proposed continued response actions, as described in this Action Memorandum, are 

otherwise appropriate and consistent with the remedial action to be taken. The NTCRA included 

in this Action Memorandum will remove the source of contamination to the bedrock aquifer and 

the East Branch ofthe Sebasticook River. Excavation and on-site treatment is a response action 

that would be consistent with the type of actions that would be considered as part of the expected 

remedial response and do not preclude any future remedial response that may be necessary. 

The implementation ofthe NTCRA is necessary to prevent the further migration ofthe 

contamination in the soils. Authorization is, therefore, hereby requested for a "consistency" 

exemption to exceed the statutory limits of $2 million and 1 year on removal actions in order to 

implement the NTCRA as described in this Action Memorandum. 

16 
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE 

VI. PROPOSED ACTIONS AND ESTIMATED COSTS 

The following removal action objectives have been developed for the Site: 

* Prevent, to the extent practicable, direct contact with and ingestion of surface and 

subsurface soils that represent an unacceptable health risk; 

* Prevent, to the extent practicable, the migration of chlorinated benzenes (and 

other contaminants) in soils to the groundwater and surface water; and 

* Prevent, to the extent practicable, the release of contamination believed to be 

within the building to the envirormient through flooding and further degradation 

of the structure from fire. 

To meet the removal action objectives, EPA has selected a NTCRA to remove the source 

ofthe soil and groundwater contamination. This alternative was referred to as Alternative 

2 in the EE/CA. The scope ofthe NTCRA has not changed as a result ofthe public 

comment on the EE/CA. 

1. Proposed Action Description 

Altemative 2: Excavation and On-Site Treatment 

The proposed action is the excavation of soils with contaminant concentrations above the 

cleanup levels specified in Table 3. The excavated soils will be treated at an on-Site 

treatment facility to reduce the level of contamination such that the soil can be placed 

back on to the ground with no future restrictions. At a minimum, the soil will be treated 

to meet the cleanup levels specified in Table 3. Debris from the building demolition and 

soils containing contaminants that cannot be treated to levels acceptable for on-Site 

disposal will be shipped for off-Site disposal. 

The treatment technology will use heat to remove the contamination from the soil. The 

contamination will then be in the air.or vapor phase. The contaminated air that is 

removed from the treatment system will be treated with a technology that will reduce the . 

concentrations to levels protection of human health and the environment. It is anticipated 

that a catalytic oxidation technology will be used to treat the contaminated off-gas, but 

carbon adsorption is also a possibility. Any water removed from the treated soil or 

collected as part ofthe excavation will be treated prior to discharge to either the local 

sewer line or infiltrated into the ground. See Figures 6 - 8 for a conceptual diagram ofthe 

treatment system, staging locations, and areas of excavation. 

1 7 
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE 

The major components ofthe proposed cleanup include: 

, Pre-Design and Design Activities: This will include sampling ofthe soils in the 

source area to provide a better estimate ofthe area to be excavated as 

docimientation of current building and property condition (to provide a baseline 

for any restoration activities). Also, engineering work to develop a set of plans 

and specifications will be performed prior to the start ofthe work. 

Mobilization and Site Preparation: Erosion controls will be installed to minimize 

the transport of contaminated soils into the East Branch ofthe Sebasticook River. 

Also, Site offices and facilities, including the soil treatment pads, will be 

established to support the cleanup. 

Building Demolition: The Eastland Woolen Mill structure will be removed. In 

addition, the dam beneath the Eastland Woolen Mill will be stabilized or removed 

depending upon the surface water management requirements. Special precautions 

will be taken to minimize the potential for material from the demolition to enter 

the East Branch ofthe Sebasticook River. 

Surface Water Management: The surface water ofthe East Branch ofthe 

Sebasticook River will be managed to allow for the building demolition and soil 

excavation. Surface water management may be accomplished by using culverts or 

by a temporary diversion ofthe river. The diversion option is the preferred 

approach provided access issues do not preclude the implementation of this 

option. If implemented, a 400- 600 foot section of the East Branch of the 

Sebasticook River will be re-located to allow for the excavation ofthe soils 

beneath the river between the former mill and the railroad crossing. 

Excavation: The Source Area includes those soils on the property containing the 

Eastland Woolen Mill and other soils extending along the East Branch of the 

Sebasticook River at least to the railroad crossing and possibly further. The 

Source Area also includes contaminated soils on Lot 88. All soils in the Source 

Area that contain concentrations above the specified soil cleanup levels listed in 

Table 3 will be excavated for on-Site treatment. Excavation will proceed 

horizontally and vertically until all ofthe contaminated soils are removed. Special 

precautions will be taken to minimize erosion and to prevent contaminated soils 

from washing into the East Branch ofthe Sebasticook River. All excavation areas 

will be back filled with treated soil or clean soil and graded similar to the preexcavation contours. The surface will be seeded to re-establish vegetation and 

erosion control measures will be implemented to prevent erosion. In addition, 

1 8 
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE 

ambient air monitoring will be performed to protect workers and local residents. 

Fugitive emissions of contaminants will be minimized, to the extent practical, by 

good construction practices. 

On-Site Treatment: Excavated soils will be treated to reduce the contamination to 

acceptable levels. The treatment technology is thermal desorption. The soil will 

be heated to cause the contamination to leave the soil in a gas phase. The 

contaminated gas will be collected and treated to meet air discharge requirements. 

The soil will be treated to achieve the soil cleanup levels, at a minimum. The soil 

may be treated to levels lower that the cleanup levels as required to allow for the 

determination that the soil is no longer regulated by RCRA and may be placed 

back into the ground with no future restrictions on Site use. Air monitoring will 

be performed to protect workers and local residents. It is estimated that 22,000 

cubic yards of soil will require excavation. Oversized material will be removed 

from the soil prior to treatment. Oversized materials (stones) will be washed 

before placement in the ground. Water that drains the soil treatment piles or that 

is collected during excavation activities will be treated prior to discharge to either 

the ground or the sewer line. Additional quantities of contaminated soil may be 

excavated depending upon the outcome of the soil sampling that will take place 

during the excavation program or as part ofthe on-going RI/FS. A sampling 

program will be implemented to manage the excavation. 

Traffic Management: EPA will need to re-locate the bridge crossing Main Street 

as part ofthe excavation activities. EPA will work with DOT and the community 

to develop a traffic control plan. A replacement bridge will be installed upon 

completion of the excavation. EPA has received a written commitment from the 

Maine DOT to assist with the bridge design. EPA expects DOT to arrange for any 

property transfers required to place the bridge in a new location (as opposed to 

rebuilding it in the original location as part ofthe Site restoration). 

Wetlands and Floodplains. Some wetlands may be destroyed to install the surface 

water diversion. The area of wetlands to be impacted is expected to be small 

unless the excavation extends substantially downriver. Any wetlands that are 

destroyed will be replaced or compensated, as appropriate. While work will be 

performed within the floodplain, the final Site conditions are expected to be equal 

to, or better, than the existing floodplain. 

Site restoration: The Site will be restored (included any floodplain and wetland 

activities) upon completion ofthe NTCRA. It is expected that the surface water 

diversion will be terminated and the original flow ofthe East Branch ofthe 

Sebasticook restored unless a ROD calls for the temporary diversion to become 

19 
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE 

permanent. 

The cleanup levels that will be used to delineate the areas to be excavated are listed 

below. 

Table 3: 

Soil Cleanup Levels 

Contaminant 

benzene 

chlorobenzene 

1,2 dichlorobenzene 

1,3 dichlorobenzene 

1,4 dichlorobenzene 

1,2,4 trichlorobenzene 

Cleanup Level (ug/kg or parts 

per billion) 

30 

1,000 

17,000 

41,000 

2,000 

5,000 

3. Contribution to Remedial Performance 

The NTCRA proposed in this document is expected to contribute significantly to the 

long-term remedial action. The remedial goal for this Site is to protect public health and 

the environment. More specifically, the remedial response will seek to restore the Site to 

a condition that will allow for future Site use and minimize any long term threats to the 

East Branch ofthe Sebasticook River and the associated ecosystems and to protect private 

water supplies. The removal ofthe source ofthe contamination is entirely consistent with 

all potential future remedial responses. 

The completion ofthe RI/FS will focus on the need for additional source control beyond 

the NTCRA and the need for long-term groundwater response. Additional EE/CAs may 

20 
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE 

be prepared and NTCRAs proposed if Site conditions reveal the need for source control 

actions in addition to those required under a future ROD. 

3. Description of Altemative Technologies 

In addition to the selected NTCRA described above, which utilizes excavation and oriSite treatment to protect human health and the environment at the Site, other general 

response measures were identified, screened, and analyzed in the EE/CA for potential 

applicability at the Site. These alternative response measures included: excavation and 

off-Site disposal; on-Site in-situ treatment using chemical oxidation; and on-Site in-Situ 

treatment using thermal destruction. 

During the EE/CA process, all ofthe alternatives were evaluated independently based 

upon cost, effectiveness, and implementability. Cost was used to assess options of 

similar effectiveness and implement ability. The direct capital, indirect capital, and postremoval site control costs (operation and maintenance) were estimated for each 

altemative. Effectiveness was based upon the ability ofthe alternative to meet the 

removal action objectives. The effectiveness evaluation also involved the assessment of 

federal and state applicable or relevant and appropriate requirements (ARARS), the short 

term risks associated with the alternative, timeliness, and the overall protection of human 

health in the environment. Implementability involved the assessment of construct ability 

and operational issues. 

In the EE/CA's independent analysis of each alternative, all ofthe alternatives were 

deemed effective in terms of overall protectiveness by reducing potential long-term risks 

at the Site and technical feasibility. The off-Site disposal option had additional cost that 

would not be proportional to the benefit. The heterogeneities ofthe Site soils (silts, 

sands, and clays) would limit the effectiveness and time frame ofthe in-situ technologies. 

The preferred altemative would provide the highest degree of effectiveness and 

implementability. The two in-situ treatment altematives would have major uncertainties 

with respect to implementability and effectiveness due to Site conditions. The preferred 

altemative is the least expensive as compared to the other altematives. The preferred 

altemative fully satisfies all ofthe criteria and provides the best balance ofthe evaluation 

criteria. See the EE/CA for a more detailed presentation ofthe cost and the basic 

components of each altemative. 

2 1 
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE 

4. EE/CA 

Attachment 2 is the EE/CA Approval Memorandum, Attachment is the EE/CA Fact Sheet 

(EPA's Proposed Plan), and Attachment 6 is EPA's Response to Comments on the EE/CA 

and EE/CA fact Sheet. The EE/CA Report itself is found in the Administrative Record 

for the Site. 

5. Applicable or Relevant and Appropriate Requirements 

Through the EE/CA process, EPA has evaluated the universe of federal and state 

applicable or relevant and appropriate requirements (ARARS) which are within the scope 

of this NTCRA. Attachment 4 is a list of all such ARARS. EPA has determined that the 

selected NTCRA will be designed, constructed, operated, and maintained to attain all of 

the idenfified ARARS, in accordance with 40 C.F.R. § 300.415(1). 

6. Project Schedule 

Upon the Division Director's signature of this Action Memorandum, EPA intends to 

begin implementation of the NTCRA with federal funds in 1999. The NTCRA 

construction activities should be completed in early 2001. 

22 
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE 

B. Estimated Costs 

Extramural Costs 

Regional Allowance Costs $9,450,000 

(Money from national cleanup fund with contingency) 

Other extramural costs 

CLP $80,000 

State of Maine Cooperative Agreement $20,000 

Sub-Total Extramural Costs $9,550,000 

Total Extramural $9,550,000 

Intramural Cost 

Intramural Direct . $50,000 

Intramural Indirect $ 100,000 

Total Intramural $ 150,000 

Total Removal Projected Ceiling 

for this action $9,700,000 

VII. EXPECTED CHANGE IN THE SITUATION SHOULD ACTION BE DELAYED 

OR NOT TAKEN 

If the NTCRA is not implemented, the contaminants will continue to leach from the soils into the 

groundwater further contributing to the groundwater contamination and causing impacts to the 

East Branch ofthe Sebasticook River. Some ofthe local water supplies that are not on the water 

supply line have concentrations of chlorobenzenes that are increasing. Failure to implement the 

NTCRA means that the source ofthe groundwater contamination has not beencontrolled. 

23 
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE 

VIII. OUTSTANDING POLICY ISSUES 

There are several policy issues at this Site. The excavation and on-Site treatment of contaminated 

soils is entirely consistent with national and regional practices. However, the extent ofthe 

surface water management and construction implementation issues are relatively unique to this 

project. Few CERCLA removal projects require the relocation of a highway bridge and a section 

of a river. However, a temporary river relocation has been performed at a Maine CERCLA Site 

with success and EPA has the support ofthe State and local citizens at this Site. EPA has 

consulted with numerous stakeholders to develop an understanding of the potential concerns with 

diversion of the river or highway re-location. All parties agree with the conceptual river 

diversion plan and Maine DOT has provided a written letter in support ofthe NTCRA. 

IX. ENFORCEMENT 

Additional information on the enforcement strategy for this case is contained in Attachment 9 

(Enforcement Confidential - Not for Public Release). 

X. RECOMMENDATION 

This decision document represents the selected removal action for the Eastland Woolen Mill 

Superfund Site, in Corinna, Penobscot County, Maine, developed in accordance with CERCLA 

as amended, and is not inconsistent with the NCP. This decision is based upon the 

Administrative Record for the Site. 

Conditions at the Site meet the NCP criteria for a removal action as specified at 40 C.F.R. § 

300.415(b)(2). I recommend your approval ofthe proposed removal action. The total project 

ceiling for the NTCRA, if approved, will be $9,700,000. I also recommend and request your 

approval of a "consistency" exemption to the statutory limits of $2 million and one year on 

removal actions. 

Approve \ ^ Disapprove 

Patricia L. Meaney, Director 

Office of Site Remediation and Restoration 

Date: 7/^//'/'/' 

24 
Eastland Woolen Mill Superfund Site - Action Memorandum 

List of Attachments 

Attachment 1 - Figures and Tables 

Attachment 2 - EE/CA Approval Memo 

Attachment 3 -Site Chronology 

Attachment 4 - ARAR Tables 

Attachment 5 - EE/CA Fact Sheet 

Attachment 6 - Response to Comments 

Attachment 7 - Public Hearing Transcript 

Attachment 8- Administrative Record Index 

Attachment 9 - Enforcement Addendum 
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE 

ATTACHMENT 1 

FIGURES and TABLES 
I I Mile«Comef\ ^Lii ff)^m-Bri(lge 

Quadrangle Location 

© Scale in Miles 

Source; DeLorme, Street Atlas USA, Version 3.0, 

Dated 1995. Modified by HLA, 1999. 

FIGURE 1 

SITE LOCATION MAP EASTLAND WOOLEN MILL SITE 
T;\247B-01\2478F012 7/13/99 

g ^ OBSERVED BELOW MCU AND MECs 

SERVICED BT PUBLIC WATER SUPPLY 

WATER SUPPLY LINE 

(MOOUnED AnER MDEP CIS MAP 1999) 

TARGET CONTAMINANTS' ARE DEFINED AS CONTAMINANTS 

CURRENTLY THOUGHT TO EXIST AS A RESULT OF A R£1£ASE 

FROM Acnvmes AT THE EASTLAND WOOLEN MILL 

200 400 

SEW«CE TREATVtEKT PLANT 

O 

Scale in feet 

FIGURE 2 

DETAILED SITE MAP 

EASTLAND WOOLEN MILL SITE 
•:\2*76-01\2*76F042 7/U/99 

FIGURES 

PLAN VIEW OF SOIL CONTAMINATION 

EASTLAND WOOLEN MILL SITE 
Building 4 

Bedrock 

LEGEND 

Interpreted extent of chlorinated benzene 

^A/AAt contamination exceeding cleanup levels 

-V I nte rpreted water table 

Horizontal Scale In Feet 

Bedrock 

0 60 120 

Vertical Exaggeration 4X 

Building 1AI Building 2 

' ^ 

FIGURE 4 

SIDE VIEW OF CONTAMINATION EASTLAND WOOLEN MILL SITE 
T:\2478-01\2478F029 7/14/99 

CHLORINATED ORGANICS 

NON-DETECTION 

BOUNDARY 

LEGEND 

STRUCTURE NOT SAI«>LED 

TARGET C0NTAMNANT5 OBSERVED 

BELOW MCLs AND MEG* 

V//A A WSTORICAaY SAMPLED 

y / X NON-DETECT 

NON TARGET CONTAMINANTS 

OBSERVED BELOW MCLa AND MEGa 

SERVICED BY PUBLIC WATER SUPPLY 

WATER SUPPLY LINE / , 

(MODIRED AFTER MDEP GIS MAP 1999) 

TARGET COffTAMINANTS* ARE DEFINED AS CONTAMINANTS 

CURREKILY THOUGHT TO EXIST AS A RESULT OF A RELEASE 

FROM ACTIVITIES AT THE EASTLAND WOOLEN MLL 

SEWAGE TKEATUENT PUWT 

0 200 400 

Scale in feet 

FIGURE 5 

ESTIMATED AREA OF 

GROUNDWATER CONTAMINATION 

EASTLAND WOOLEN MILL SITE 
T:\2478-Q1\2478F028 7/14/99 

T 

FIGURE 6 

PLAN OF TREATMENT AREA 

EASTLAND WOOLEN MILL SITE 
CO 

o 

o 

o 

OJ 

1,000cy Soil Pile 

Approximately 45 ft. x 100 ft x 10 ft Blower 

Thermal 

Oxidizer 

1,500-1,800°F 

0.5 -1.0 sec. 

Fuel 

(Propane) 

.^^ . 

Catalytic 

Oxidizer 

Treated Air 

• • to Atmosphere 

(10 to 15%) 

Recirculating Air 

(85 to 90%) 

Make-up Air 

(10 to 15%) 

FIGURE? 

SCHEMATIC OF ON-SITE THERMAL TREATMENT EASTLAND WOOLEN MILL SITE 
•:\247a-Ol\2478F03O 7/14/i 

/ 

FIGURE 8 

SOIL EXCAVATION LIMITS 

EASTLAND WOOLEN MILL SITE 
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE 

ATTACHMENT 2 

EE/CA APPROVAL MEMORANDUM 
or Sr 

SB J 

•<• • , A 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 1 

JOHN F. KENNEDY FEDERAL BUILDING 

BOSTON, MASSACHUSETTS 02203-0001 

MEMORANDUM 

DATE: January 29, 1999 

SUBJ: Eastland Woolen Mill Site - Approval Memorandum to perform two Engineering 

Evaluation/Cost Analyses for a Non-Time Critical Removal Action 

FROM: 

THRU: 

TO: 

Edward Hathaway, Rl^M MEA'T/CT Superfund Section I / . , < : .• -

Donald Berger, Chi 

Remediation and R ipn^ranch 11 

l/f 

Steve Novick, Acting Chje> 

Emergency Planning and Response Branch 

Patncia L. Meaney, Director 

Office of Site Remediation and Restoration 

I. Subject 

Investigations have detennined that-there has been a release of hazardous substances to the 

en\-ironment at the Eastland Woolen .Mill Sue m Corinna, Maine. This Site is a National 

Pnonties List (NPL) caliber site and a lisiinu packa^e has been sent to EPA by the State of Maine. 

The Governor of Maine has agreed that the Site should be listed on the NPL. 

This memorandum documents the decision to proceed with two Engineering Evaluation/Cost 

Analyses (EE/C.As) for a non-time cntical removal action (NTCR.A) at the Eastland Woolen Mill 

Site. Both EE/CAs will evaluate cleanup alternatives for source control measures at this Site. 

The first EE/CA will address the soil contamination and building demolition. A second EE/CA 

will address cleanup altematives for source control remediation ofthe sediments, surface water, 

and the groundwater. The EE/C.As \sill be prepared b\- a contractor working for the United States 

.-Vrmy Corps of Engineers (COE) under EP.A ONxrsiehi. This approval memorandum authonzes 

the expenditure of federal funds for the EE/C.\s When the Siteis listed on the NPL, the remedial 

investigation and feasibility study addressing all areas not fully remediated as a result ofthe 

NTCR,A will be conducted 

The decision to proceed wAv-. IIICSL- EE'C.AS IS coiisisteni wnh EP.A guidance regarding Superfund 

Accelerated Cleanup Model (S.ACM) early actions and the long-term remedial strategy for this 

'•.-] • Pitip //wv/v,' Gpa.ac''.' 

f^ecvclcc].'>^«cycldDl^ ' •' • .-',"/ci';r: f'aj)',*' f^/lnirTUJfn .'".'"••o ''o;;i c 
EASTLAND WOOLEN MILL SITE APPROVAL MEMO 

Site. This memorandum is not a final Agency decision regarding the selection of a response 

action for the Site. 

n . Background 

A. Site Description and History 

The Eastland Woolen Mill Site is located in the Town of Corinna, Penobscot County, Maine. The 

Town of Corinna is located approximately 25 miles northwest of Bangor, Maine. Approximately 

800 persons live within 1 mile ofthe Site and 2,500 with 4 miles. 

The Site is dominated by the 250,000 square foot Eastland Woolen Mill (see Attachment A). 

Portions ofthe Eastland Woolen Mill are located on both sides ofthe East Branch ofthe 

Sebasticook River as well as above the river. Side buildings and former tank areas are also 

located at the Site. Three dams are found in the vicimty ofthe Site. One dam is approximately 

500 feet north (upstream) ofthe Eastland Woolen Mill and serves as the outlet for Corrundel 

Lake. A second dam is located beneath the Eastland Woolen Mill. The third dam is located 

approximately 0.5 miles down nver ofthe Eastland Woolen Mill, 

The Site has been used as industnal property since 1912. The Eastland Woolen Mill building may 

have been constructed as early as the late 1 SOO's. The Eastland Woolen Mill Company owned and 

operated the mill from 1936 until 1996. The company assets were sold at a real estate foreclosure 

auction in 1997. In 1997, the Town of Connna took title to the parcel on which the Eastland 

Woolen Mill was located based upon taxes due and potential public hazards.' The Eastland 

Woolen Mill and its associated side buildings are now abandoned. 

Hazardous substances were likely used throughout the entire operating history. Chlorobenzenes 

were reportedly used in large quantities from the 1960's through closure. Chlorobenzenes are a 

major component ofthe dye-aid used in the dye kettles to add color to the wool. The onginal 

disposal practice was to discharge the waste either directly into the East Branch ofthe Sebasticook 

River or into a tail race that lead to the river. In addition, wastes were also dumped directly onto 

the concrete floors and allowed to infiltrate the floor or flow over the floor toward the river. 

In 1971, most ofthe waste stream was divened fi-om the river to the Town of Corinna sewer. No 

pre-treatment ofthe waste was performed pnor to discharge into the sewer. By 1977, all wastes 

from the Eastland Woolen Mill were discharged to the publically owned treatment works (POTW) 

for the Town of Connna The Eastland Woolen Mill represented over 80% ofthe flow to the 

POTW. A sample ofthe waste water discharging to the POTW after a spill of a dye aid chemical 

at the Eastland Woolen Mill revealed over 12 mg-l of dichlorobenzene and 1 mg/l of 

trichlorobenzene in the waste water 
EASTL.AND WOOLEN MILL SITE APPROVAL MEMO 

All drinking water in the Town of Corinna was originally obtained from private water supply 

wells drilled into the bedrock. Each residence or business had an individual water supply well as 

a public or private water supply line was not available prior to 1995. Contamination of local 

water supplies was first detected in 1983 when a member ofthe Maine Department of 

Environmental Protection (Maine DEP) had the water at a local restaurant tested based upon a 

peculiar odor and taste to the water. After testing revealed that the water at five locations was 

contaminated with chlorobenzene compounds above drinking water standards, the Eastland 

Woolen Mill Company installed activated carbon iiiiers at these locations. The locations were in 

the immediate vicinity ofthe mill. The Eastland Woolen Mill Company also initiated a quarteriy 

sampling program under the oversight ofthe Maine DEP. By 1988, testing ofthe water supplies 

of private residences and local businesses revealed 11 locations with levels of chlorobenzenes 

warranting carbon filters. Contamination was detected in an area spreading approximately 800 

feet from the Eastland Woolen Mill (See Attachment B). 

In 1984, the Eastland Woolen Mill Company hired a consultant to perform a hydrogeologic 

charactenzation ofthe dov.Titov,Ti area. The work included the installation of monitoring wells 

and soil borings to allow sampling ofthe soil and groundwater. In 1988, a study ofthe 

contamination, including the possible location of a new water supply that could serve the 

contaminated properties, was completed. .A second study was completed in 1993 that identified 

the tail race beneath the Eastland Woolen Mill and an underground storage tank as the most likely 

sources of contamination. 

The Eastland Woolen Mill Company removed several underground storage tanks in 1994 and 

installed a groundwater recovery well at the locatior ofthe tanks to address low pH groundwater 

and to remove chlorobenzene compounds from a smear zone. The pumping of this well was 

discontinued in 1995. The Eastland Woolen Mill Company also began pumping one ofthe most 

contaminated former pnvate water supplv wells as a groundwater recovery well. The water from 

this well was discharged into the Town of Connna sewer line without pre-treatment. The State of 

Maine currently operates this recoverA' well. 

In 1995, a water supply line was installed to serve the downtown area of Corinna. The water 

supply well is located approximately 1000 feet east ofthe Eastland Woolen Mill on Palmyra Road 

and runs along Palmyra to the intersection with Routes 7 and 11 where the water extends a short 

distance east on Route 7 and 11 before crossing the East Branch ofthe Sebasficook River near the 

railroad bridge. The water line then runs along Main Street before splitting in three directions. 

One section runs up Spnng Street to the Connna Elementary' School, one section runs up Exeter 

Street (Routes 1 1 and 43) and the third section runs up Dexter Road (Route 7) (See .Attachment 

.A) Not all residences located along the water line are connected to the water line. 

The water supply line was installed by funds provided by the Eastland Woolen Mill Company, the 

Farmers Home .Administration and a Community Development Block Grant. The Eastland 

Woolen Mili Companx' also agreed lo fund the operation and maintenance ofthe w-ater line. 
EASTLAND WOOLEN MILL SITE .APPROVAL MEMO 

During installation of a sewer line across the East Branch ofthe Sebasficook River, high 

concentrations of chlorinated benzenes were detected in tbe sediments. Further investigation of 

the river sediments revealed additional pockets of contamination extending several hundred feet 

down river. 

In 1996, when the Eastland Woolen Mill closed, the Maine DEP assumed the responsibility for 

the quarterly monitoring program and has provided ftinding to maintain and operate the water 

supply hne. 

In 1997 and 1998, the Maine DEP perfonned additional investigations to confirm the extent of 

river contamination. These investigations confirmed that high levels of chlorinated benzenes are 

found in the nver bed extending over 1000 feet down nver ofthe Eastland Woolen Mill. 

In 1997, the Maine DEP performed an emergency response action to remove 54,673 pounds of 

various hazardous substances from process pipes, containers, and vessels located within the 

Eastland Woolen Mill. 

EPA began an expanded Site inspection in November 1998 to better define the contamination in 

the soil under the Eastland Woolen Mill main building and in the subsurface soils adjacent to the 

Eastland Woolen Mill. 

C. Nature and Extent of Contamination 

.As descnbed above, several investigations have been performed at the Site. While company 

records and work perfonned by the contractor for the Eastland Woolen Mill Company provide the 

most substantial basis for the V)'pe and quantity of contamination, the investigations undertaken by 

the Maine DEP and EP.A further venfied the presence of substantial contamination at the Site. 

The cunent conceptual Site model is that the groundwater and sediments have been significantly 

impacted by the histoncal release of contamination from the Eastland Woolen Mill building and 

storage tanks. Some ofthe contamination has migrated into the associated subsurface soils and 

also into the surface water, sediments, and groundwater. Substantial quantities of contamination 

are thought to be in the soils beneath and adjacent to the Eastland Woolen Mill main building. 

This contamination represents a long-term source of hazardous substances that will contribute to 

the contamination currently detected in the surface water, groundwater, and sediments. The 

presence of non-aqueous phase liquid (N.APL) in sediments has been reported based upon visual 

obserx'ations dunng the insiallation ofthe water line and the Maine DEP investigation program. 

Each Site medium will be discussed separately. 
EASTLAIsOD WOOLEN MILL SITE APPROVAL MEMO 

1. Soils: 

The soils under the building are contaminated with various chemicals. In particular, mono, di, 

and tri chloro benzene have been disposed into the subsurface imder the building. See Attachment 

C for the approximate portions ofthe building that overlie the soil contamination. The dye-aid 

material used at the Site was comprised of 65% dichlorobenzene, 28% biphenyl, 1-2% 

chlorobenzene, and 1-2%) trichlorobenzene. The waste water from the facility was disposed 

through a trap door in the floor into a "tail race" that ran into the East Branch ofthe Sebasticook 

River. Some ofthe contamination also migrated into the soils beneath the tail race. In locations 

away from the tail race, the waste material was allowed to drain onto the concrete floor resulting 

in run-off to the river or migration directly into the subsoils. Field screening results obtained 

dunng the EPA 1998 program support that contamination is still residing beneath the building. 

The Maine DEP has estimated that 27,500,000 gallons of waste water containing chlorobenzenes 

were used and disposed into the tail race and soils from 1961 to 1971. Additional quantities of 

contamination, in the form of chemical spills, were also released into the environment after 1971 

when the facility began discharging its wastewater to the POTW. 

The subsurface soils adjacent to the Eastland Woolen Mill building were also found to be 

contaminated with chlorobenzenes. Former storage tanks on the propeny are the suspected source 

of this contamination. 

Compound 

chlorobenzene 

1.3 dichlorobenzene 

1,2 dichlorobenzene 

1,4 dichlorobenzene 

1,2,4 trichlorobenzene 

1.2.3 trichlorobenzene 

Naphthalene 

Xylene 

Soil Contaminatio n 

Range of 

Detecuons.'max 

(mg/kg) , 

22 - 14(1 

0.008 - 240 

0.03 - 2,00(1 

0.05 - 1 J3(l 

0.4 - 1.200 

26(1 

8.6 

17 

EP.^ Screening 

Lc\cl for Direct 

Conuir. 

(rcsidcnual) 

mgkg 

54 

41 

370 

_1 

480 

55 

210 

Maine 

Remediation Level 

for Direct Contact 

(residential) 

(mg/kg) 

310 

2670 

540 

245 

10,000 

EPA Soil Screening 

Level for 

groundwater 

protection 

(mg/kg) 

1 

17 

2 

5 

84 

190 

.As shown in the table, the compound? 1.4 dichlorobenzene and 1.2.4 trichlorobenzene are 
EASTLAND WOOLEN MILL SITE APPROVAL MEMO 

substantially above levels considered protective of human health from a direct contact and 

groundwater exposure perspective. In addition, chlorobenzene and 1,2 dichlorobenzene also 

greatiy exceed the levels that are protective of human health from exposure to grovmdwater. 

2. Groundwater: 

The chlorobenzenes disposed at the Site have migrated into the overburden and bedrock 

groundwater. There is a continuing release of contamination from the soil into the groundwater. 

The existing water supply line has been extended to those residences and businesses with 

contamination above the State of Maine action levels. 

The groundwater contamination extends in several directions from the Eastland Woolen Mill for 

approximately 800 feet (See Attachment B). Data has been collected from former private 

residence and business water supply wells. The data in column 2 in the table below shows the 

concentrations in wells that have been connected to the water line or from monitoring wells. The 

data from these wells reveals concentrations well above federal drinking water standards or risk 

based standards for the compounds chlorobenzene, benzene, 1,2 dichlorobenzene, 1,4 

dichlorobenzene, and 1,2,4 trichlorobenzene. 

Sampling of cunent private water supply wells reveals that the plume extends beyond the limits of 

the water line. The results ofthe sampling ofthe individual private water supply wells still in use 

are shown in column 3 ofthe table below. There are currently 13 water supply wells that are still 

in use which contain low levels of contamination. 

The overburden in the area ofthe Site is a sequence of two compact tills. Till thickness ranges 

from 0-40 feet. No true confining Javers have been identified. The till and bedrock are, therefore, 

considered one groundwater unit. The bedrock is a phyllite. The migration ofthe contamination 

indicates that the bedrock is well fractured and that the fractures are connected. Bedrock water 

supplies in the area vary in depth, with wells as shallow as 75 feet and as deep as 544 feet. 
EASTLAND WOOLEN MILL SITE APPROVAL MEMO 

Groundwater 

Compound 

chlorobenzene 

benzene 

1,2 dichlorobenzene 

1,3 dichlorobenzene 

1,4 dichlorobenzene 

dichlorofluoromethane 

1.1 dichloroethane 

1.2.3 tnchlorobenzene 

1.2.4 trichlorobenzene 

Maximum concentration in 

fonner water supply wells 

(ug/1) 

5.869 

25 

2,230 

92 

2,230 

4 

6 

441 

2.335 

Maximum concentration in 

current water supply wells 

(ug/L) 

17.4 

0.5 

5.9 

0.9 

5.0 

3.4 

0.7 

9.8 

MCL 

(ug/1) 

5 

600 

600 

75 

70 

Risk based 

level 

(ug/1) 

39 1 

390 

810 

.Additional charactenzation ofthe groundwater will occur during the expected remedial 

in\'estigation. It is reasonable to conclude that the groundwater contamination was caused by the 

release of hazardous substances from the Eastland Woolen Mill and that the contamination has 

not attenuated. 

3. Sediments and Surface Water: 

Chlorobenzene, dichlorobenzene, and tnchlorobenzene were detected by Maine DE P in the 

surface water ofthe East Branch ofthe Sebasticook River, Concentrations of 12-28 ug/1 were 

detected for these three constituents in the surface water There are no acute or chronic ambient 

water qualiU' cntena for the chionnated benzenes. 

The sediments within the East Branch ofthe Sebasticook River also appear to be significantly 

impacted by the Eastiand Woolen Mill The East Branch ofthe Sebasticook River is a class C 

river according to the State of Maine classification program Based upon this classification, the 

n\-er is expected to be useable as a drinking uater source (after treatment), fishing location, and 

swimming location. Bald eagles are known to use the stretch ofthe East BrEuich that has been 

contaminated. The 1997 investigation program performed by the Maine DEP revealed 

contamination in the nver sediments extending over 1000 feet down river ofthe Eastiand Woolen 

Mill Chlorobenzene, dichlorobenzene, and tnchlorobenzene were detected at concentrations up 

to 190, 710, and 400 mu.''ku rcspccn\el\- The 199S Maine DEP investigation program confirmed 
EASTLAND WOOLEN MILL SITE APPROVAL MEMO 

(i) Actual or potential exposure to nearby human populations, animals, or the food chain from 

hazardous substances or pollutants or contaminants - At present, the contamination in the 

groundwater and sediments represents the most significant threat to human health and the 

environment. The groundwater has been declared unsafe to drink in portions ofthe community 

and concentrations are increasing outside the area ofthe water line. The ecological community is 

being impacted by the presence of NAPL in the sediments ofthe river. If the Eastiand Woolen 

Mill were to catch fire as a result of its abandoned condition, substantial releases to the soil, 

surface water, sediments, and groundwater would occur. In addition, the Town has indicated a 

desire for fiature residential development at the Site. As a result, subsurface soils could be 

exposed during fijture excavations. In the long term, significant human health and ecological 

harm will occur if the source of groundwater, surface water, and sediment contamination at the 

Site (soil) is not remediated, and if the building is not demolished in order to remediate subsurface 

soils. 

(ii) Actual or potential contamination of~dnnkine water supplies or sensitive ecosystems -

Residents ofthe community have been exposed to contamination through ingestion of 

contaminated groundwater. A water line does protect some residences. However, the 

contamination is spreading and analysis of samples from pnvate water supplies not cunentiy on 

the water line have shown elevated levels of contamination. In addition, substantial 

concentrations of chlorobenzenes (mono, di, and tn) have been detected in the surface water and 

sediment ofthe East Branch ofthe Sebasticook Rjver. This contamination senously impairs the 

ecological system. 

(iv) Hieh levels of hazardous substances or pollutants or contaminants in soils lareelv at or near 

the surface, that mav mierate - Hich levels of contamination are believed to be in the 

fioor/basement ofthe Eastiand WcK)len Mill and have been confirmed in the soils beneath, and 

adjacent to. the Eastland Woolen Mill, The contamination in these locations represents a source 

of matenal that are contaminating the groundwater, and the surface water and sediments ofthe 

East Branch ofthe Sebasticook Rjver, The pockets of N.APL in the sediments are a source of 

contamination that may continue to impact surface water and may migrate down nver dunng high 

river stage 

(v) Weather conditions that mav cause hazardous substances or pollutants or contaminants to 

migrate or be released - The Site is located in an area of high rainfall and snowfall. During the 

1997-1998 uinter, a portion ofthe structure collapsed due to snow/ice weight. Further collapse . 

mav result in portions ofthe Eastem Woolen Mill main building falling into the East Branch of 

the Sebasticook River Spnng run-off in 1 99S caused the dam under the building to overtop, 

resulting in water flowing through the structure, which is believed to be contaminated, and 

bnnging additional hazardous substances into the environment. Because the floor ofthe Eastland 

Woolen Mill is believed to be contaminated due to former operations in the building, winter and 

spnng weather conditions ma\' have already resulted in hazardous substances being released to the 

environment Without remediation, t^urther releases are likely to occur. 
EASTLAND WOOLEN MILL SITE APPROVAL MEMO 

(vi) Threat of fire or explosion - The Site itself is not an imminent threat with respect to an 

explosion. However, as previously discussed, the Eastiand Woolen Mill is abandoned. There is 

evidence that the Eastland Woolen Mill has been accessed by trespassers and vandals. If accessed 

by homeless trespassers, it is likely that they will set fires for warmth. It would be difficuh for the 

Town of Corinna to handle any major fire due to both the magnitude ofthe fire and the potential 

hazardous substances that could be released by both the fire itself and efforts to combat the fire 

(water run-off, etc). The building has no power to maintain a fire suppression system. 

(vii) The availability of other appropriate federal or state response mechanisms to respond to the 

release - There are no other known federal or state fijnds or response mechanisms available to 

finance this action. 

(viii) Other situations or factors that mav pose threats to public health or welfare or the 

environment - The contamination believed to be within and under the building floor/basement is a 

likely continuing source ofthe soil, groundwater, sediment, and surface water contamination. 

Based upon the NCP factors previously listed, a threat exists to public health or welfare or the 

environment due to the release of hazardous substances into the environment. A non-time cntical 

removal action is therefore appropnate to abate, prevent, minimize, stabilize, mitigate, or 

eliminate such threats. In particular, a non-time cntical removal action is necessary to remove, 

control or contain the nsk from the potential nsk from fiiture ingestion of groundwater, and the 

release of hazardous substances from the Site to East Branch ofthe Sebasticook River through 

source control measures. 

This removal is designated as non-time cntical because more than six months planning time is 

a\ailable before on-site activities roust be initiated. Prior to the actual performance of a non-time 

cntical removal at this Site, Section 300.415(b)(4) ofthe NCP requires that an engineenng 

evaluation/cost analysis (EE/CA) be perfonned in order to weigh different response options. 

r\'. Scope of the EE/CAs 

The purpose ofthe EE/CAs will be to evaluate alternatives for initial source control response 

measures related to contamination in the soil, groundwater, sediments, and surface water. The 

first EE/CA will consider alternatives which meet the following general removal action 

objectives: 

Prevent, to the extent practicable, direct contact with and ingestion of surface and 

subsurface soils that represent an unacceptable health risk, 

* Prevent, to the extent practicable, the migration of chlorobenzeines (and other 

coniaminanis I i;i soils to I'nc iiroundwater and surface water: a-tid 

10 
EASTLAND WOOLEN MILL SITE APPROVAL MEMO 

* Prevent, to the extent practicable, the release of contamination believed to be within the 

building into the environment through flooding and fiirther degradation ofthe structure or 

from fire. 

The second EE/CA will be prepared to focus on additional source control measures related to 

contamination in the groundwater, surface water, and sediments. This EE/CA will consider 

altematives which meet the following general removal action objectives: 

* Prevent, to the extent practicable, the migration of groundwater with contaminant 

concentrations above state or federal drinking water standards, or in there absence a level 

equal to a hazard quotient of 1 or an excess carcinogenic risk of 1 x 10"* beyond the edge 

ofthe Site, and 

* Prevent, to the extent practicable, continued environmental impacts from high 

concentrations of contaminants in the sediments and surface water ofthe East Branch of 

the Sebasticook River. 

Based upon the above removal action objectives the following cleanup levels will be used to 

evaluate altematives in the first (soil/building) EE/CA: 

Proposed Soil Cleanup Levels 

Compound 

chlorobenzene 

1.2 diclilorobcnzcnc 

1,4 dichlorobenzene 

1,2.4 tnchlorobenzene 

Naphthalene 

Xylene 

Soil Cleanup Level for groundwater prelection 

(mg/kg) 

1 

17 

1 

> 

84 

190 

These initial cleanup levels are based upon the EP.A screening levels established to protect 

groundwater. These cleanup levels ma\' be modified during the development ofthe first EE/CA 

or as a result of public comment on the EE/CA, The final cleanup levels will be specified in the 

Action Memorandum. 

Cleanup levels are not being set for groundwater or sediment. The cleanup levels for the second 

EE/CA will be determined dunne the development ofthe second EE/CA and may be modified as 

a result of public commcn; on the second EE/CA, 

1 1 
EASTLAND W^OOLEN MILL SITE APPROV.AL MEMO 

Pursuant to EPA guidance on EE/CAs, altematives will be evaluated based upon effectiveness, 

implementability, cost, and compliance with ARARs. Further, altematives which exceed $2 

million dollars will be evaluated to determine their consistency with future remedial actions to be 

taken at the Site. 

In developing the range of altematives to be evaluated in each EE/CA, EPA will consider 

300.415(d) ofthe NCP as well as relevant guidance. Section 300.415(d) of the NCP identifies 

various removal actions which may be appropriate in given situations, including: 

(2) Drainage controls, for example, run-off or run-on diversion - where needed to reduce 

mieration of hazardous substances...; 

(4) Capping of contaminated soils or sludges - where needed to reduce migration of 

hazardous substances or pollutants or contaminants into soil, ground or surface water, or 

air; 

(6) Excavation, consolidation, or removal of highly contaminated soils from drainage or 

other areas - where such actions will reduce the spread ofthe release, and 

(8) Containment, treatment, disposal, or incineration of hazardous materials - where 

needed to reduce the likelihood of human, animal, or food chain exposures. 

The alternatives that are expected to be evaluated in the first EE/CA are: 

• Removal of on-Site structures; 

• Excavating contaminated soils for on-Site treatment and/or off-Site disposal; and 

• On-Site in-situ treatment ofvolatile soil contamination by vapor extraction or air 

sparging 

12 
EASTLAND WOOLEN MILL SITE APPROVAL MEMO 

The altematives that are expected to be evaluated in the second EE/CA include: 

• Excavating contaminated sediments for on-Site treatment and/or off-Site disposal; 

and 

• On-Site containment of contaminated groundwater to prevent direct contact and 

protect groundwater. 

EP.A plans to develop two EE/CAs based upon the above objectives. The first EE/CA will 

evaluate the options to address the building and contaminated soil. The second EE/CA will 

address additional source control measures with respect to the contaminated groundwater, surface 

water, and sediments. Additional information is required to completed the EE/CA for the 

groundwater and sediment, therefore it would be more efficient to separate these medium from the 

soil. 

V. Enforcement Strategy 

See the Enforcement .Addendum, Attachment E, for more infonnation regarding the EPA 

enforcement strateg}'. 

VI. Estimate Costs 

The EE/CAs for the proposed NTCR.A at the Eastland Woolen Mill Site will be developed by a 

contractor working for the US COE. under the oversight of EP.A, 

Extramural costs associated with the preparation ofthe EE/CAs for the Eastland Woolen Mill 

Site, including communitv relations acti\-iiies and development of an Administrative Record, are 

expected to be approximately 5150,000 - 5200,000, Based upon preliminary EPA estimates, costs 

associated with the response action for the building and soil range from $5 to $10 million. Am 

additional $3 - S5 million could be required to initiate a source control action for the 

contamination in the groundwater, surface water, and sediments. The costs related to the first 

EE/CA will be significantly affected by the volume of building material that requires disposal as 

hazardous waste. 

\'0 . Other Considerations 

The proposed NTCRA is expected to be consistent with any future remedial actions. The 

preliminar\' nsk evaluation presented in section 3 of this Approval Memo documents that the . 

nature ofthe threat at the Site v.ould require a remedial response similar in nature to the proposed 

NTCRA. 

13 
EASTLAND WOOLEN MILL SITE APPROVAL MEMO 

If this Site is placed on the NPL, EPA expects to continue the Superfiind process and complefe a 

remedial investigation and feasibility study. 

The State of Maine supports an early action at this Site. A letter documenting the position ofthe 

State of Maine is included at attachment D. 

Vni. Recommendation 

EPA and Maine DEP investigations have determined that there has been a release of hazardous 

substances to the environment at the Site. Consistent with Section 104(b) of CERCLA fiirther 

investigation is necessary to plan and direct future response actions. We recommend your 

approval of this request to perform two EE/CALS at the Eastland Woolen Mill Site. The total 

estimated extramural cost of performing the two EE/CAs approximately $200,000. 

Date Patricia L. Meaney, Director 

Office of Site Restoration and Remediation 

.A.ttachments: 

A, Site Location Map 

B- Groundwater Contamination Area Map 

C, Subsurface Contamination Beneath Building Map 

D, State Letter of Support 

E, Confidential Enforcement .A.ddendum 

14 
A''-. 

,'< ^ 

Eastlan d Woolen .Mill 

Cor iiitid. Alaitic 

.i,,woroM.n"-y«1viM: 

, Al, "'''^'<-::"f/'llf l well l"C.'ti"ns hav 

/^V / A 
<>. 

tec 

cov?:=.'i>v'r^T ^'jr^;^ ;c: 

HCuSisC 

BUSI-M^S5L 5 

TO £•; R-IMO'/Lb 

BAC K PORIION- G" U,-J. 

Scoi't '• = j;O r 

/4Vy 

FIGURE 3 

EPA T993 NATIONAL BROWNFIELD S 

ECONOMIC REDEVELOPMENT PILOT 

: 3 i TL PLAN 

Town Of Corinna. Maint 

/ •• 
_J Eastland Woolen Mill, Corirma | 
STATE OF MAINE 

DEPARTMEN T OF ENVIRONMENTA L PROTECTIO N 

ANGUSS. KING. JR. 

GOVERNOR 

EDWARD O, SULLIVAN 

COMMISSIONER 

Januar>'20, 1999 

Mr. Ed Hathaway 

US EPA Region 1 

1 Congress Street, Suite 1100 

Boston, MA 02114-2023 

Re: Eastland Mill 

Dear Mr. Hathaway: 

This letter is written to support EPA's efforts to investigate and take actions to remove 

contaminants from beneath the Eastland Mill site, Corinna, Maine. 

The situation in Corinna is serious and warrants attention. The groundwater beneath the 

dowTitowTi area of Corinna is contaminated with hazardous substances at levels above 

published maximum contamination limiis (MCLs). While a recently installed waterline 

provides alternate water, the plume continues to migrate. We expect additional private 

wells are al risk and expansion ofthe waterline is anticipated. 

Removing the source to eliminate continuing contribution is a necessary step to an\' 

selected.remedy. Undertaking this action sooner, rather than later, may reduce the need 

for waterline expansion and will mitigate impacts to the Sebasticook River. The state 

urges EPA to undertake this Action. 

The stale has been involved at this site since 1983. In fact, the contaminated groundwater 

was first noticed by a DEP staff person while in towti. Upon discovery ofthe tainted 

water the state required the responsible party. Eastland Mill, to provide filters to impacted 

users and maintain them. In addition, the state worked with Eastland to investigate the 

problem. Eastland also participated in the constmction of a waterline to bring clean 

water lo users in the downtowTi area. Eastland also agreed to provide water at no cost to 

those users with contaminated private water supplies. In the fall of 1996, Eastland s 

financial woes, forced the mill to close. 

Since 1996 the state has committed considerable personnel and financial resources to 

investigate and mitigate threats to human health and the environment posed by hazardous 

substances released at the site. Actions taken by the state include: 

Remoxal of Hazardous Substances Abandoned at the Mil! 

\ l: ( a - I \ 

17 ST,.\" n Mil l '^ 1 ST ,.\ I KI N 

- \ l .( . l'> l ..X, -M.\ IN I .M I t l.,>,> 

ll, \ NC .( Il l 

li I I ! ^ I • 1 ; 

!•( )K I I .\ N n 

M : I A.N . . 1 m i, \ 11 

l-t I K I 1 \ ,N n , ,M A I ,N I 

'.•.• : i •• .• : • . I.-. - I \ \ 

ruiMji . 1. isi i 

,:•. ^ I I N l i;-M nKi\- | . -K^\\•A^ • I'AU K 

r i < I Nl 11 I IS I I , ,\1 A I ,N I .>.! T-"-.'.""- ' 
Teams of state specialists conducted a detailed inventory to document the presence of all 

hazardous materials abandoned at the mill. Once inventoried, the state hired a contractor 

to consolidate the hazardous materials, repack them as necessary and send them off site 

for approved disposal or reuse. 

Investigation of Sebasticook River 

Teams of specialists for the DEP conducted investigations ofthe Sebasticook River in 

1997 and 1998 to determine whether contaminants were present. The investigation 

documented significant contamination in the river bottom. 

Operation ofthe Public Water System 

Without Eastland's financial support the Corinna Water District was in danger of 

collapse. Once this happened, people would be without water. To keep the system from 

collapsing, the state is providing financial support to the CWD. 

While the state strongly supports the clean-up of this site, our finite funding is a reality. 

State actions are fimded through the sale of bonds authorized by the taxpayers ofthe 

state. These funds must be judiciously used and spread as far as possible. Without bond 

money, there is no state program. Having reviewed our situation, the state is not in a 

position where it can agree to a percentage of an unkno\\m dollar amoimt. There is the 

danger that such a commitment could break the bank, so to speak. The state has funded 

significant activity to date. Cunentiy the amount spent or contmitted is approaching 

5500,000. We request that EP.A consider this as proof of the state's commitment to 

address the problem in Corinna. The state is also willing to provide-in-kind ser\'ice 

support on a case by case basis. 

In closing, the state applaud? EPA in it's effort to investigate and mitigate contamination 

at the Eastland Mill. Furthermore, as elimination of the source material is a key element 

of any viable remedy, the stale supports a timely removal action. Such action will not . 

only mitigate threats to human health and the environment, but provide a shot in the arm 

to this economically depressed rural area. Thank you for your interest. 

Sincerely, 

Mark Hylai^dyDirector 

Division of Remediation 

Cc: Don Berger, EPA 

Mary Jane O'Donnell, EPA 

Kathy Niziolek, DEP 

Denise Messier, DEP 

Hank Aho, [)\-.\> 
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE 

ATTACHMENT 3 

SITE CHRONOLOGY 
TABLE 2-1 

SUMMARY OF ENVIRONMENTAL INVESTIGATIONS 

SITE SUMMARY REPORT 

EASTLAND WOOLEN MILL SITE 

CORINNA, MAINE 

YEAR 

1984 

1983-1986 

1987-1995 

1988 

199? 

199." 

1995 

1996-1998 

1996 

1 ')<n 

I'l'l K 

INVESTIGATION 

Preliminary 

Hydrogeologic 

Investication 

Water Supply Well 

Sampling 

Water Supply Well 

Sampling 

Feasibility Study of 

Water Supply System 

Ph.Tse 1 ln\'estigation 

of C^hlorobenzene 

(!"ontaminalion 

Silc .-Viscssnient for 

E.xcavation and 

Removal of 

H.'i:;ardou.s .Sub.slance 

Sloragc Tank,-; 

Sediment Sampling 

Water Supply Well 

Sampling 

L-ST Residual Soil 

Investigation 1 

Sediment Surface 

Water Screening 

Hiiilcliiu: Walui 

INVESTIGATOR 

Eastland Consultant-J.K. 

Richards Assoc. 

Bastland ConsultantAcheron Inc. 

Eastland ConsultantAcheron Inc. 

Eastland ConsultantAcheron Inc. 

Eastland ConsultantAcheron Inc. 

Eastiand ConsultantAcheron Inc. 

Eastland ConsultantAcheron Inc. 

MEDEP 

MEDEP 

MEHEl' 

Mi:i)r:r 

•-SCOPES \:.'-

13 borings completed mostly 

downgradient ofthe mill; 3 completed 

asMWs 

Collected groundwater samples from 

various residential supply wells 

Collected groundwater samples from 

various residential supply wells 

Discussed the known area of 

chlorbcnzene in groundwater and the 

location of a altemative water supply 

well, and distribution system. 

Conducted a records review. 

summarized existing data and collected 

3 sediments samples from tailrace area. 

Collected .samples and observations 

made during tlie removal ofthe three 

UST near Building No. 13. 

Collected 8 sediment and 8 

groundwater samples from the river 

bottom and floodplain using hand 

driven geoprobe. .Ml samples screened 

with onsite C'rC; ofi'-sitc laboratory 

analvsis conducted on a subset of 

samples. 

Samples collected from varying subsets 

of residential wells, some on the 

periphery ofthe water distribution 

system at appro.timalely quarterly 

Completed 9 geoprobe borings in the 

former footprint ofthe 3 USTs ofthe 

'cast side ofthe mill complex. Five soil 

samples and 1 groundwater sample 

subniilleci tor olV-site lah analvsis. 

Samples collected across 14 transect 

lines across the river. Multiple samples 

were collected from each line. Samples 

were screened witli a portable field OC 

r<M- niuno. Ji-. and triclllorohcnzcnes. 

1 Dilceled sample of \..aler in ha.scnlciil 

of mill for VO(,' and metals analysis. 

FINDINGS 

Traces of chlorobenzenes found in overburden 

around USTs and downgradient of mill 

Chlorobenzenes detected in 7 residential wells. 

Five wells had GAC filters iiutalled prior to 

1987. 

Chlorobenzenes detected in three additional 

wells during expanded sampling; 5 additional 

residential wells supplied with GAC filters 

between 1987 and 1988. 

Water supply system could be installed to sene 

affected residences by installation of a new 

supply well northwest of the mill and town 

center. 

Documented use of tailrace for waste disposal. 

Chlorobenzenes, ethylbenzene, PCE, x-ylenes. 

and toluene foimd m sediment collected from 

the tailrace. Fracture trace analysis conducted. 

Chlorobenzenes were found in soil on the west 

side of the excavation between tile two most 

northem USTs. A recovery well was installed. 

Water sample from recover)' well indicated 

chlorobenzenes in the overburden groundwater. 

.^ 55 gallon drum was also unearthed during 

the UST excavation and stained soils were seen 

below the drum. 

Chlorobenzene, and fiiel oil found in a majority 

of sediment samples and overburden 

groundwater below the river bottom collected 

for analyses. 

Chlorbcnzene concentrations in contaminated 

wells appear to be relatively consistent. 

Results showed the presence of 

chlorobenzenes, trimethylbenzene. xylene, 

ethyl benzene, and toluene in soil; and 

chlorobenzenes and benzene in groundwater. 

Samples results show the presence of 

chlorobenzenes in a 35 out of 40 sediment 

samples and 5 of 7 water samples. 

No V( X ".s were detected in lh),s sample. 
TABLE 2-1 

SUMMARY OF ENVIRONMENTAL INVESTIGATIONS 

SITE SUMMARY REiPORT 

EASTLAND WOOLEN MILL SITE 

CORINNA, MAINE 

YEAR 

1998 

1998 

1998 

199H 

INVESTIGATION 

UST Residual Soil 

Investigation 11 

Old Dump 

Investigation 

Sediment and Surface 

Water Sampling for 

the HRS Scoring 

Package 

Source 

Characterization and 

F:iuilding 

("liaraclerization 

INVESTIGATOR 

MEDEP 

MEDEP 

MEDEP 

USACE 

SCOPE 

Collected 4 soil samples fix)m UST 

grave and 1 background sample and 

analyzed for VOCs and SVOCs. 

Two soil samples and 4 water samples 

were analyzed for VOCs and /or 

SVOCs. 

Collected 8 sediment and surface water 

samples from the Sebasticook River in 

support of tlie HRS scoring package. 

In addition, 3 sediment and 1 surface 

sample was collected from a 

background locations. Sediment 

samples collected for VOC, SVQC, 

P/P, and metals. 

Completed 29 soil borings including 16 

inside the mill and 2 at Lot 88, a site of 

chemical storage used by the mill. 

Sampling focased on soil below the 

dam tailrace and at the location of tiie 

fomier USTs on llie cast side ofthe site. 

Tiiree new MWs were installed. 

FINDINGS 

Results showed the presence of several 

compounds including chlorobenzenes, 

trimethylbenzene, xylenes, ethyl benzene, and 

naphthalene, polyaromatic hydrocarbons. 

No target conmpounds were detected. 

Several sediment samples contained 

chlorobenzenes. Surface water relaliveh free 

of contaminants. 

Data showed the presence of chlorobenzenes in 

soil below the building and sediments in the 

dam tailrace. Clorobenzenes. 

trimelhvlbenzenes. and benzene were detected 

in soil at the locaiion ofthe fomier USTs 

Chlorobenzenes were also delected in soil al 

Lot.88. 

NoU";: 

\1Ws= inoniionnE well.s 

Pi-:>icniich|.'ioelhen^-

I.S'is=- uiiiieipound slcrage t;ir\t:s 

i i.Ai •-gjaiuilar acimiltrd c^ri'i'ii 

MRDEP-Mame !.>cpartnienl of EnMromiienlal Prelection 

liS.AC.'OU.S Aniiy ("oqi of Enpjieers 
SECTION 2 

2.0 SITE HISTORY AND BACKGROUND 

2.1 HISTORY OF OPERATIONS AT THE MILL 

Operations at the mill began in 1909 according to historical narratives written by 

Eastland. Eastland manufactured wool and blended woven fabrics at the site since it took 

ownership in the 1930's. According to Eastland's self described history, recycled wool 

products have always accounted for a portion of the manufactunng. Virgin wool was 

also processed at the plant. The James Striar Family Foimdation which owned the 

Eastland mill, also operated a mill in Orono, Maine. At the Corinna mill, the primary 

operations were yam and fabric manufacturing, and fabric finishing. According to 

Eastland, six specific operations were conducted at the two mills as follows: 

1. Fiber preparation and blending; virgin and recycled fibers were blended and 

dyed as needed. These operations appear to have been principally conducted 

at the Orono facility. Prepared fibers were then trucked to Corinna. 

2. Yam manufacturing which involves "carding" and spinning fiber to form 

yam. Appears to be a "dry" operation that did not involve chemical 

processes; 

3. Fabric manufacturing involved weaving the yam into woven fabric. Appears 

to be a "dry" operation that did not involve chemical processes; 

Harding Lawson Associates 

W0().S')92 IXX' :.;7K-01 
SECTION 2 

4. Fabric finishing which involved fulling, scouring, carbonizing, dyeing, drying, 

and pressing of the fabric to meet product or customer requirements. These 

operations involved various chemicals including dyes, and dye-aid which was 

applied to the fabric to facilitate the absorption of dye, thus, this was termed a 

"wet" process. Dye aid was mixed with heated water in preparation of the 

fabric for dyeing. Soap compoimds were also used to wash the fabric before 

and after dyeing. 

5. Final inspection and packaging which was another dry operation involving 

rolling , inspection, counting and invoicing of fabric product. 

6. Blanket manufacturing was a dry operation that involved cutting, stitching, 

and packaging of fabric as blankets. This was the only finished product that 

Eastland sold. All other products were in the form of bulk fabric that were 

purchased and used by other manufacturers (e.g., clothing) for product 

production. 

and 4. 

Harding Lawson Associates 

WI)l)5'i'>?..iy<K' 247K-0I 

2-2 

I 

I 

I 

The key operation that generated liquid wastes at the Corinna mill was the fabric 

finishing operation. According to maps of the mill, a majority of the "wet" processes 

(i.e., dyeing and washing ofthe fabnc) occuned in the basement of Buildings 1, IA, 3, • 

I 

I 

I 

I 
I SECTION 2 

I 

I According to former mill personnel, mixing of the chemical recipe was conducted in a 

wooden structure immediately below the dam and above the river on the north side of 

Building Sin what was known as the "Drug Room". It is possible that undiluted chemical 

I product was spilled directly into the river from this location. In addition, chemically 

saturated floor boards were reportedly removed from this location and stored at Lot 88. 

In 1977, the new Dye House was constmcted and the dyeing operations were to take 

place in this portion of the facility after completion, however, the exisfing dye kettles 

were still used after the completion ofthe new Dye House. Reportedly, the dyeing of 

fabrics occurred in dye "kettles" which were essentially large vats. The dye mixture 

consisted of varying amoimts ofthe following (Acheron, 1993a): 

I 

I 

I 

I 

8 

I 

I 

I 

I 

I 

I 

I 

I 

• water 

• dye (coal-tar derivative) 

I • dye-aid (e.g., Carolid MXS or Carolid EWS) 

I • acid 

• caustic 

• ammonia. 

According to former Eastland personnel, the chemical make-up of the wet process taking 

place within the dye was vanable and was a function of the product being made. The 

dye-aid was the component of the dyeing process that contained chlorobenzenes and was 

used to improve the absorption of dye by the fabric. The time frame of dye-aid use has 

nol been documented although it may have been as early as the 1950's through the 

Harding Lawson Associates 

WimV)')?. IKX' 2.:7S-()I 

2-3 
SECTION 2 

closing ofthe mill in 1996. Carolid MXS reportedly contained approximately 65 percent 

dichlorobenzene. Biphenyl also makes up a large percentage (approximately 35 percent) 

oi Carolid MXS. Carolid EWS contained up to 31 percent chlorobenzene compounds 

including ortha-, para-, and meta-dichlorobenzenes, and 1,2,4-trimethylbenzene. Section 

6 discusses the quantity of dye-aid used at the mill. Rqjortedly, monochlortoluene-based 

dye-aid was also used at the mill (MEDEP, 1990). Chrome-based dyes were also 

occasionally used. 

A former building (i.e.. Building No. 12) located on Lot 88, east ofthe mill, was used for 

storage of chemicals and wool (Figure 2-1). The Town of Corinna garage was also 

formerly located south of Lot 88. Reportedly, wool was stored in the southem end and 

dmms were stored in the north end. The building had a wood floor, so spills of chemicals 

could infiltrate into underlying soil. According to a former employee, chemical spills 

were common. Reportedly, after the building was demolished, a heavy rain caused 

colored dye to surface from the ground and was seen migrating with surface water runoff 

(USACE-NAE, 1998). Fire protection maps, dated 1955, indicate that chemical and dye 

storage also occurred in Building No. 14, located on the east side ofthe mill complex. 

The School Street Yard, located on Route 7 on the west side of Corinna, consisted of four 

buildings and was used as a carpentry area and painting shop. According to fire 

protection maps, the Moosehead Mill was used to store fiber and dry supphes. Eastland 

drawings indicate the presence of a fuel oil and kerosene storage tank at this location. 

Harding Lawson Associates 

W()05'.'92 IXK' 247R-0I 

2-4 
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE 

ATTACHMENT 4 

ARAR TABLES 
TABLE D-4 

LOCATION-SPECIFIC ARARS FOR ALTERNATIVE 2 

ENGINEERING EVALUATION/COST ANALYSIS 

EASTLAND WOOLEN MILL SITE 

CORINNA, MAINE 

REGULATORY 

AUTHORITY 

Feaeral 

Federal 

Federal 

LOCATION 

CHARACTERISTIC 

Floodplains 

Wetlands 

Navigable Waters 

REQUIREMENT 

Floodplain Management 

Executive Order No. 11988 [40 

CFR Pan 6, App. A) 

Protection of Wetlands Executive 

Order No. 11990 [40 CFR Part 6, 

App. AJ 

Rivers and Harbors Act of 1899 

[33 USC 403 et seq.; 33 CFR 

Patis 320-323] 

STATUS 

Applicable 

Applicable 

Relevant and 

Appropriate 

REQUIREMENT SYNOPSIS 

Requires federal agencies to evaluate 

potential adverse effects associated with 

direct and indirect development of a 

floodplain. Alternatives that involve 

modification/construction within a floodplain 

may not be selected unless a detennlnation 

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. EPA must also provide the public 

with early and continuing information 

concerning floodplain management. 

Under this Order, federal agencies are 

required to'mlnimize 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 altemative 

exists, potentiai harm must be minimized 

and action taken to restore natural and 

beneficial values. 

Section 10 of the Rivers and Harbors Act of 

1899 requires an authorization from the 

Secretary of the Army, acting through the 

U.S. Army Corps of Engineers, for the 

constmction of any structure in or over any 

"navigable water of the U.S."; the excavation 

from or deposition of material in such 

waters, or any obstnjction of alteration in 

such waters. 

ACTION TO BE TAKEN TO ATTAIN ARA R 

TO THE EXTENT PRACTICABLE 

Modification of the floodplain will be avoided to 

the extent practical. Any removal action within 

floodplain will be implemented In a manner fo 

minimize adverse effects on floodplains to the 

extent practicable. Least damaging methods 

will be specified to achieve removal goals. 

Restoration actions will be taken fo restore 

natural and beneficial values of the floodplain. 

EPA will also provide the public with floodplain 

management information In the proposed plan 

for this NTCRA. 

Wetlands protection will be considered during 

development, evaluation, and Implementation 

of removal actions fo minimize adverse effects 

on wetlands to the extent practical. 

Site activities will be designed and 

implemented to avoid obstruction and minimize 

alteration of navigable waters. Disturbed areas 

will be restored. 

The proposed surface water diversion plan will 

entail some unavoidable disturbance to 

wetland areas not requiring remediation 

(excavation). Affected areas are expected to 

recover upon restoration of preexisting 

hydrologic conditions. Wetlands disturbed to 

construct surface water diversion structures or 

for removal of contamination will be restored. 

Proposed activities v^ll meet substantive 

requirements of all nationwide pennit 

conditions, except that surface water 

management activities may temporarily affect 

movement of aquatic life. 

\>..-.,8aP0RTHDATA\GR0UF'S\PROJECTS\Corinna\A RARsWll_2_ARARTbls.DOC Page 1 of 4 May 20, 1999 
coMiinued 

TABLE D-4 

LOCATION-SPECIFIC ARARs FOR ALTERNATIVE 2 

ENGINEERING EVALUATION/COST ANALYSIS 

EASTLAND WOOLEN MILL SITE 

CORINNA, MAINE 

REGULATORY 

AUTHORITY 

Federal 

Federal 

Federal 

Sir.ie 

LOCATION 

CHARACTERISTIC 

Endangered Species 

Surface Waters 

Floodplains 

Wetlands 

REQUIREMENT 

Endangered Species Act [16 USC 

1531 et seq; 40 CFR 6.302(h); 

50 CFR Pan 200, 50 CFR Part 

402) 

Fish and Wildlife Coordination Act 

[16 USC 661 et seq; 40 CFR 

Section 6.302(g); 33 CFR Part 

320) 

RCFIA Floodplain Restrictions for 

Hazardous Waste Facilities (40 

CFR 264, 18(b)] 

Maine Wetlands Protection Rule 

[06-096 CMR, Chapter 310] 

STATUS 

Applicable, if 

such species are 

encountered 

Applicable 

Applicable 

Applicable 

REQUIREMENT SYNOPSIS 

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. 

Requires Federal agencies involved in 

actions that will result in the control of 

structural modification of any stream or body 

of water for any purpose, to take action to 

protect the fish and wildlife resources that 

may be affected by the action. EPA must 

consult with the Fish and Wildlife Service 

and the appropriate state agency to 

ascertain the means and measures 

necessary to mitigate, prevent, and 

compensate for project-related losses of 

wildlife resources and to enhance the 

resources. 

A hazardous waste facility located in a 100-

year floodplain must be designed, 

constructed, operated, and maintained to 

prevent washout of any hazardous waste by 

a 100-year flood or to result In no adverse 

effects on human health or the environment 

if washout were to occur. 

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 

ACTION TO BE TAKENTOATTAI N ARA R 

TOTHE EXreNiPRACtibABLE 

Although no currently listed endangered or 

threatened species or their nests have been 

identified af the site, their presence has been 

noted in the area. As part of the NTCRA, 

pertinent lists will be reviewed to assess 

whether Federally listed species may be 

present. During the removal action, measures 

such as relocation or seasonal work limits for 

specific actions would be implemented to 

protect listed species, if any are Identified. 

USEPA will take measures fo mitigate or 

compensate adverse project-related Impacts to 

fish and wildlife resources. The U.S. Fish and 

Wildlife Service and the appropriate state 

agency will be consulted. 

Any on-site facility located within the 100-year 

floodplain which treats, stores, or disposes of 

hazardous wastes will be designed, 

constructed, operated, and maintained to 

prevent washout of hazardous materials by a 

100-year flood through surface water 

management. In the event prevention Is not 

achievable, human health and the environment 

will be protected through sedimentation 

confrols such as silt curtains or sedimentation 

basins to the extent practical. 

Removal actions will be developed and 

implemented to meet activity standards. 

Removal actions within 100 feet of the East 

Branch Sebasticook River wnll be designed and 

\WBHPORTn' lROUPS\PROJECTS\Corinna\ARAR5\Al l 2_ARARTbls.DOC ''of 4 Ma •\1999 
continued 

TABLE D-4 

LOCATION-SPECIFIC ARARS FOR ALTERNATIVE 2 

ENGINEERING EVALUATION/COST ANALYSIS 

EASTLAND WOOLEN MILL SITE 

CORINNA, MAINE 

REGULATOR Y 

AUTHORITY 

State 

State 

LOCATIO N 

CHARACTERISTI C 

Wetlands 

Surf.'ice Waters 

Endangered Species 

REQUIREMENT 

Maine Natural Resources 

Protection Act. Permit-by-Rule 

Standards (06-096 CMR. Chapter 

305) 

Maine Endangered Species Act 

and Regulations (12 MRSA 

Section 7751-7756; 09-137 CMR 

008] 

STATUS 

Applicable 

Applicable 

REQUIREMENT SYNOPSIS 

regulations prohibit activities, which would 

have an unreasonable impact on the 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. 

This rule prescribes standards for specific 

activities that may take place in or adjacent 

to wetlands and water bodies. The 

standards are designed to ensure that the 

disturbed soil material is stabilized to 

prevent erosion and siltation of the water. 

The state of Maine has authority to research, 

list, and protect any species deemed 

endangered or 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. 

ACTION TO BE TAKE N T O ATTAI N ARA R 

TOTHE EXTEN T PRACTICABLE 

implemented so as to not unreasonably 

interfere with stream flow or water quality and 

to minimize adverse effects on aquatic habitat, 

fisheries, and aquatic life. Function and value 

assessments will be performed for existing 

wetland/habitat, and restoration activities 

performed so that post-remedlatlon on-site 

wetlands are at least comparable to existing 

on-site wetlands. 

Response actions that involve the disturbance 

of soil material in or adjacent to a wetland, 

great pond, stream or brook will meet these 

standards. 

Endangered and threatened species lists will 

be reviewed as part of the NTCRA to assess 

vi4iether Maine listed species may be present. 

During the removal action, measures vAW be 

implemented to protect listed species if 

identified or encountered. 

\V.BP.PORTnDATA\GROUPS\P!(OJECTS\CorinnaWP.ARs\Alt_2_ARARTblS.DOC Page 3 of 4 May 20, 1999 
continued 

TABLE D-4 

LOCATION-SPECIFIC ARARS FOR ALTERNATIVE 2 

ENGINEERING EVALUATION/COST ANALYSIS 

EASTLAND WOOLEN MILL SITE 

CORINNA, MAINE 

REGULATORY 

AUTHORITY 

Stp.in 

St.-ie 

State 

State Criteria, 

Advisories and 

Guidance 

LOCATION 

CHARACTERISTIC 

Shoieland areas 

Activities that expose 

soil v/ith potential for 

erosion 

Business/Residential 

Distiict of Corinna 

Special Habitats and 

Cominunities 

REQUIREMENT 

Town of Corinna Shoreland 

Zoning Ordinance, enacted 29 

September 1991. Mandatory 

Shoreland Zoning Act (Title 38, 

MRSA. sections 435-449). 

Erosion and sedimentation 

control [38 MRSA subsection 

420-C], Chapter 500, Stormwater 

Management Rules and chapter 

502. Direct Watershed of 

Walerbodies Most at Risk from 

New Development. 

Maine Site Location of 

Development Law and 

Regulations (38 MRSA Sections 

481-490, CMR Chapter 375) 

Maine Natural Areas Program 

STATUS 

Applicable 

Applicable 

Applicable 

To be considered 

if such special 

areas are 

identified at the 

site 

REQUIREMENT SYNOPSIS 

To protect and conserve shoreland areas by 

controlling activities within 250 feet of high 

water mark, as defined in state law. 

Erosion control measures must be in place 

before activities, such as filling, displacing or 

exposing soil or other earthen materials take 

place. Prior MEDEP approval is needed if a 

disturbed area is in the direct watershed of a 

body of water most at risk (i.e., Sebasticook 

Lake). 

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. 

These state programs govern special 

habitats or communities. 

ACTION TO BE TAKEN TO ATTAIN ARA R 

TO THE EXTENT PRACTleABLE 

Measures will be taken fo comply with the 

ordinance wherever practicable. 

Where Site activities described In 38 MRSA 

420D or 38 MRSA 481-490 occur, USEPA will 

implement appropriate controls to address 

erosion, sedimentation and stormwater. 

Applicable plans will be coordinated with 

MEDEP prior to Implementation. 

To the extent that USEPA leaves three or more 

acres unvegetated for a period of a year or 

more, or requires 20,000 square feet of 

impervious area, removal altematives will 

comply wrfth these requirements, if deemed 

appropriate. Stormvrater management, erosion 

and sedimentation controls, and traffic controls 

will be designed and Implemented so that 

adverse effects on natural resources are 

minimized. 

If such special areas are Identified at the site, 

the appropriate state programs will be 

consulted. 

Notes: 

CFiv = Code of Federal Regulations 

CMR = Code of Maine Regulations 

MRSA = Maine Revised Statutes Annotated 

NTCRA = Non Time Critical Removal Action 

USC = United States Code 

USEPA = U.S. Environmental Protection Agency 

\V%nBr.ORTr •;ROUPS\PROJECTS\Connna\ARARs\Alt_2_ARARTblS,OOC 1 of 4 M? 1999 
TABLE D-5 

CHEMICAL-SPECIFIC ARARS FOR ALTERNATIVE 2 

ENGINEERING EVALUATION/COST ANALYSIS 

EASTLAND WOOLEN MILL SITE 

Corinna, Maine 

REGULATORY 

AUTHORITY 

Federal 

Federal Criteria, 

Advisories and 

Guidance 

Federal Criteria, 

Advisories and 

Guidance 

Federal Criteria, 

Advisories and 

Guidance 

CHEMICAL 

MEDIUM 

Soil 

Soil 

Soil 

Soil 

REQUIREMENT 

Safe Drinking Water Act, 

National Primary Drinking Water 

Regulations, Maximum 

Contaminant Levels (40 CFR 

Parts 141 11 - 141.16and 

141.50- 141.53) 

USEPA Risk Reference Doses 

USEPA Carcinogenic 

Assessment Group Cancer 

Slope Factors 

EPA Region IX Preliminary 

Remediation Goals, 1998 

STATUS 

Relevant and 

Appropriate 

To Be 

Considered 

To Be 

Considered 

To Be 

Considered 

REQUIREMENT SYNOPSIS 

The National Primary Drinking Water 

Regulations (NPDWR) establish Maximum 

Contaminant Levels (MCLs) and Maximum 

Contaminant Level Goals (MCLGs) 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. 

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. 

Risk reference doses (RfDs) are estimates 

of daily exposure levels that are unlikely to 

cause significant adverse noncarcinogenic 

health effects over a lifetime. 

Cancer slope factors (CSFs) represent the 

upper-bound estimate of the probability in 

excess of general population risk that an 

individual will develop cancer as a result of a 

lifetime of exposure to a chemical. 

Region IX Preliminary Remediation Goals 

are guidance levels for cleanup of 

contaminated soil. The guidance provides 

PRGS that are protective of human health for 

direct contact with soil and Soil Screening 

Levels (SSLs) for protection of groundwater. 

ACTION TO BE TAKEN TO ATTAIN 

ARAR t o THE EXTENT PRACTICABLE 

Risk-based soil cleanup levels were 

developed In part to prevent groundwater 

contamination exceeding MCLs and non-zero 

MCLGs. All soils exceeding cleanup levels 

will be removed or treated to achieve cleanup 

levels. 

Risk-based soil cleanup levels were 

developed in part on RfDs, which were 

evaluated during the assessment of 

acceptable risk levels and the development of 

removal action objectives.. All soils exceeding 

cleanup levels will removed or treated to 

achieve cleanup levels. 

Risk-based soil cleanup levels were 

developed In part on CSFs, which were 

evaluated during the assessment of 

acceptable risk levels and the development of 

removal action objectives. All soils exceeding 

cleanup levels will removed or treated to 

achieve cleanup levels. 

Region IX PRGs and SSLs were used during 

development of cleanup levels for the Site. All 

soils exceeding cleanup levels will removed or 

treated to achieve cleanup levels. 

vVAiil;l'0RTnDATA\GR0UPSiPROJECTS\Corinna\ARAR5\AII 2 ARARTbls.DOC Page 1 of 2 May 20, 1999 
continued 

TABLE D-5 

CHEMICAL-SPECIFIC ARARS FOR ALTERNATIVE 2 

ENGINEERING EVALUATION/COST ANALYSIS 

EASTLAND WOOLEN MILL SITE 

Corinna, Maine 

REGULATORY 

AUTHORITY 

suae 

State Criteria, 

Advisories and 

Guidance 

Stato Criteria. 

Advisories and 

Guidance 

CHEMICAL 

MEDIUM 

Soil 

Soil 

Soil 

REQUIREMENT 

Maine Department of Human 

Services Rules Relating to 

Drinking Water (10-144A CMR 

Chapter 231-233) 

Maine DEP Draft Remedial 

Action Guidelines for Hazardous 

Substances in Soils (July 1997) 

Maine Procedural Guidelines for 

Establishing Standards for the 

Remediation of OilContaminated Soil and Ground 

Water in Maine (February 1. 

1995) 

STATUS 

Relevant and 

Appropriate 

To Be 

Considered 

To Be 

Considered 

REQUIREMENT SYNOPSIS 

These rules establish Maine primary drinking 

water standards as being equal fo federal 

MCLs. 

These guidelines contain chemical-specific 

concentrations for hazardous substances in 

soil for protection of human health through 

direct contact and protection of groundwater. 

This policy sets forth soil and groundwater -

clean-up levels for hydrocarboncontaminated soils and is based on 

MEDEP's Hydrocarbon Spill Decision Tree 

with three levels of clean-up goals: stringent, 

intermediate, and baseline. 

ACTION TO BE TAKEN TO ATTAIN 

ARAR TO THE EXTENT PRACTICABLE 

Risk-based soil cleanup levels were 

developed in part fo prevent groundwater 

contamination exceeding MCLs and nori-zero 

MCLGs. All soils exceeding cleanup levels 

will removed or treated to achieve cleanup 

levels. 

Soil cleanup levels were selected in part on 

these guidelines. All soils exceeding cleanup 

levels will removed or treated to achieve 

cleanup levels. 

These standards will be considered during 

development of removal action objectives if 

oil-contaminated soil is encountered. 

Notes: 

AVVQC 

CERCLA 

CFR 

CMR 

CSF 

CWA 

MCL 

MCLG 

NPDWR 

NSDWR 

RfD 

SMCL 

USEPA 

Ambient Water Quality Criteria 

Compretiensive Environmental Response, Compensation, and Liability Acl 

Code of Federal Regulations 

Code of Maine Regulations 

cancer slope factor 

Clean Water Act 

Maximum Contaminant Level 

Maximum Contaminant Level Goal 

National Primary Drinking Water Regulations 

National Secondary Drinking Water Regulations 

risk reference dose 

Secondary Maximum Contaminant Level 

U.S, Environmental Protection Agency 

"jROUPS\PROJECTS\Corinn3WRARs\AII 2 ARARTbls.DOC •?of2 Mr- 1999 
TABLE D-6 

ACTION-SPECIFIC ARARS FOR ALTERNATIVE 2 

ENGINEERING EVALUATION/COST ANALYSIS 

EASTLAND WOOLEN MILL SITE 

CORINNA, MAINE 

REGULATORY 

AUTHORITY 

Federal 

Federal 

Federal 

Federal 

Federal 

ACTION 

E.vcavation and 

treatment of soil 

E.xcavation and 

treatment of soil 

On-Site disposal of 

excavated soils 

Storage of 

hazardous waste in 

containers and 

tanks 

Placement of 

excavated soils 

REQUIREMENT 

Resource Conservation and 

Recovery Act, 42 U.S.C. 

§6901 et seq.. Standards for 

Owners and Operators of 

Hazardous Waste TSD, 40 

CFR Part 264 

Resource Conservation and 

Recovery Act, 42 U.S.C. 

§6901 et seq.i Identification 

and Listing of Hazardous 

Waste; Toxicity Characteristic, 

40 CFR §261.1 

Resource Conservation and 

Recovery Act, 42 U.S.C. 

§6901 et sea.. Land Disposal 

Restrictions, 40 CFR Part 268 

Resource Conservation and 

Recovery Act, 42 U.S.C. 

§6901 etsea.. Useand 

Management of Containers, 

40 CFR 264 Subpart 1, Tank 

Systems 40 CFR 264 Subpart 

J 

Resource Conservation and 

Recovery Act, 42 U.S.C. 

STATUS 

Applicable 

Applicable 

Applicable 

Applicable 

Applicable if 

soils to be 

REQUIREMENT SYNOPSIS 

Maine has been delegated the authority to 

administer these RCRA standards through 

its state hazardous waste management 

regulations. The relevant and appropriate 

provisions of 40 CFR Part 264 are 

incorporated by reference. 

Defines those wastes that are subject to 

regulation as hazardous waste under 40 

CFR Parts 124 and 264 

Land disposal of RCRA hazardous waste is 

prohibited without specified treatment. For 

each restricted waste, the regulations 

specify that the waste must be treated 

either by a treatment technology or to a 

particular concentration level prior to 

disposal in a RCFIA Subtitle C permitted 

facility. If a hazardous waste is treated to a 

level at which it is below land disposal 

restriction treatment standards and no 

longer exhibits a hazardous characteristic, 

it is no longer considered hazardous, then 

it may be disposed of on-site.without 

restriction. 

These regulations concern the storage of 

hazardous wastes in containers (including 

requirements addressing the condition of 

the containers, the compatibility of waste 

with the containers, the management of the 

containers, inspection of the containers 

and containment systems for the 

containers) and in tanks (including 

requirements regarding assessment of the 

tank system's integrity, design and 

installation of new tank systems or 

components, containment and detection of 

releases, general operating requirements, 

inspections, and responses to leaks or 

spills) 

This regulation includes a number of 

requirements including specific desiqn and 

ACTION TO BE TAKEN TO ATTAIN ARAR 

TO THE EXTENT PRACTICABLE 

Soils will be excavated and treated In 

accordance with state hazardous waste 

regulations. 

Analytical results will be evaluated against the 

criteria and definitions of hazardous waste. 

The criteria and definition of hazardous waste 

will be referred to and utilized during 

excavation and treatment of soils. 

If the soil meets the definition of a hazardous 

waste, soil will be thermally treated to a level at 

virfiich it no longer exhibits a hazardous 

characteristic and is below land disposal 

restriction treatment standards. 

Tanks and containers used for storage of 

hazardous waste will be designed, installed, 

operated, and maintained in accordance with 

these requirements. Contingency planning 

and closure requirements will be followed. 

Soil/waste piles containing hazardous wastes 

will be designed, constructed, and maintained 

\>ABBPORTnDATA\GROUPS« •ROJECTS\Corinna\ARARsVMt_2_ARARTbls.DOC Page 1 of 5 May 20, 1999 
continued 

TABLE D-6 

ACTION-SPECIFIC ARARS FOR ALTERNATIVE 2 

ENGINEERING EVALUATION/COST ANALYSIS 

EASTLAND WOOLEN MILL SITE 

CORINNA, MAINE 

REGULATORY 

AUTHORITY 

Federal 

Federal 

F-ederal 

Federal 

Federal 

ACTION 

containing 

iiazardous wastes in 

a pile on Site 

Heating of soil lo 

remove 

contaminants by 

passing hot air 

ttirough rotating 

drum 

Treatment of vapor 

with a carbon filter 

OR with a catalytic 

oxidizer (where 

flame heats a metal 

element, and 

element is located in 

a chamber that the 

vapor passes 

ttirough) 

Thermal Treatment 

ol Hazardous Waste 

Use of a treatment 

system with process 

vents 

Treatment, storage. 

or disposal of 

hazardous waste 

REQUIREMENT 

§6901 et seq.. Waste Piles, 

40 CFR Subpart L 

Resource Conservation and 

Recovery Act. 42 U.S.C 

§6901 et seq.. Miscellaneous 

Units. 40 CFR 264 Subpart X 

Resource Conservation and 

Recovery Act, 42 U.S.C. 

§6901 et seq.. Miscellaneous 

Units. 40 CFR 264 Subpart X 

RCRA - Thermal Treatment 

[40 CFR 265 Subpart P] 

RCRA Emission Standards for 

Process Vents [40 CFR 264 

Subpart AA] 

Resource Conservation and 

Recovery Act, 42 U.S.C. 

§6901 et seo.. Air Emissions 

Standards for Equipment 

Leaks, 40 CFR 264 Subpart 

BB 

STATUS 

stockpiled at the 

Site are a 

hazardous 

waste 

Applicable if hot 

air rotating drum 

unit is selected 

in design phase 

Applicable if one 

of these 

methods of 

vapor treatment 

is selected in 

design 

Applicable 

Applicable if 

treating 

hazardous 

waste with a 

total organic 

concentration of 

10 ppmw or 

greater. 

Applicable if 

relevant 

equipment 

contains or 

contacts 

hazardous 

wastes with 

organic 

REQUIREMENT SYNOPSIS 

operating requirements, as well as 

monitoring and inspection requirements. 

This regulation contains location, design, 

construction, operation, maintenance antj 

closure standards for the unit. 

This regulation contains location, design, 

construction, operation, maintenance and 

closure standards for the unit. 

This regulation details operating 

requirements and performance standards 

for thermal treatment of hazardous wastes 

This regulation contains air pollutant 

emission standards for process vents, 

closed-vent systems, and control devices 

at hazardous waste TSD facilities. This 

subpart applies to equipment associated 

with solvent extraction of air/steam 

stripping operations that treat wastes that 

are identified or listed RCFIA hazardous 

wastes and have a total organic 

concentration of 10 ppm or greater. 

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 

ACTION TO BE TAKEN TO ATTAIN ARAR 

TO THE EXTENT PRACTIGABLE 

to meet these requirements. 

If rotating drums with hot air heating are used, 

they wflll be operated and monitored to meet 

these requirements. 

If treatment vapors are treated vtrith activated 

carbon or a catalytic oxidizer, the unit will be 

designed, operated, and monitored to comply 

with these requirements. 

Removal actions that include thermal 

treatment of soil or thermal or catalytic 

oxidation of off-gases would be designed and 

operated in compliance with this regulation. 

Air emissions from treatment units will be 

monitored fo ensure compliance with this 

regulation. 

If threshold conditions are met, equipment will 

be operated and record keeping performed to 

meet these standards. 

~.ROUPS>.PROJECTS\CorinnaV\FRARsV\lt 2 ARARTbls.DOC lot s Mr •1999 
continued 

TABLE D-6 

ACTION-SPECIFIC ARARS FOR ALTERNATIVE 2 

ENGINEERING EVALUATION/COST ANALYSIS 

EASTLAND WOOLEN MILL SITE 

CORINNA, MAINE 

REGULATORY 

AUTHORITY 

Federal 

Federal 

Federal 

Federal 

ACTION 

Discharge of 

dredged (excavated 

soil) materials to 

surface waters and 

wetlands 

Demolition of 

asbestos-containing 

buildings 

Discharge to POTW 

Asbestos 

REQUIREMENT 

Clean Water Act, 33 U.S.C 

§§1251-1357 

Clean Air Act, 42 U.S.C 

§7401 et seq.; 40 CFR 

§61.145 Standard for 

demolition and renovation: 40 

CFR §61.150 Standard for 

waste disposal for 

manufacturing, fabricating, 

demolition, renovation, and 

spraying operations 

Clean Water Act, 33 U.S.C. 

§§1251 etseq.; General 

pretreatment regulations for 

existing and new sources of 

pollution 40 CFR §403.5 

Clean Air Act, National 

STATUS 

concentrations 

of at least 10 

percent by 

weight. 

Applicable 

Applicable 

Applicable if 

POTW is used 

to dispose of 

water from soil 

dewatering 

process 

Applicable 

REQUIREMENT SYNOPSIS 

and includes standards for particular types 

of equipment (compressors and openended valves or lines, for example), record 

keeping standards and reporting 

standards. 

Section 404 of the Clean Water Act 

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. Guidelines for Specification of 

Disposal Sites for Dredged or Fill material 

at 40 CFR Part 230, promulgated under 

Clean Water Act 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. 

Provides requirements for demolition of 

asbestos-containing buildings and for 

waste disposal as a result of the demolition 

of such buildings. 

This regulation prohibits a user (here, EPA) 

from introducing into a POTW any 

pollutant(s) which may cause Pass 

Through or Interference. These 

regulations also list specific prohibitions. 

These regulations specify minimal removal. 

ACTION TO BETAKEN TO ATTAIN ARAR 

TO THE EXTENT PRAGticABLE 

To the extent that placement of fill in wetlands 

and the river channel Is unavoidable, efforts 

will be made to minimize adverse effects to 

aquatic ecosystems. Function and value 

assessments will be perfonned for existing 

wetland/habitat, and restoration activities 

performed so that post-remediation on-site 

wetlands and river are at least comparable to 

existing on-site wetlands. Proposed activities 

will meet the substantive requirements of 

Programmatic General Pennit conditions, to 

the extent practicable. 

Engineering controls and monitoring will be 

performed to meet these requirements. 

Asbestos-containing waste will be disposed of 

in confonnance with these requirements. 

Any discharge of nondomestic wastewater to the 

Corinna WWTP will be prefreated to meet 

applicable pretreatment standards and to 

prevent pass-through or interference. 

This removal action will be designed to meet the 

VABBPORTUOATA\GROUPS\!'ROJECTS\CorinnaV\RARsVMl 2 ARARTbls.DOC Page 3 of 5 May 20, 1999 
continued 

TABLE D-6 

ACTION-SPECIFIC ARARS FOR ALTERNATIVE 2 

ENGINEERING EVALUATION/COST ANALYSIS 

EASTLAND WOOLEN MILL SITE 

CORINNA, MAINE 

REGULATORY 

AUTHORITY 

State 

St.nte 

•State 

State 

State 

State 

ACTION 

At)atement and 

tasks relating to 

managing removal, 

transport, and 

disposal of asbestos 

containing material 

Actions that may 

degrade surface 

wnter quality 

Actions that may 

degrade surface 

water quality 

Generation of 

particulate air 

emissions during 

excavation 

Generation of 

particulate air 

emission in the soil 

heating and vapor 

treatment process 

Generation of new 

source particulate air 

emissions in the soil 

heating and vapor 

treatment process 

Management of 

Contaminated 

Media 

REQUIREMENT 

Emission Standards for 

Hazardous Air Pollutants 

(NESHAP) 

Maine Water Classification 

Program (38 MRSA, Sections 

464-470). 

Maine Surface Water Toxics 

Program (06-096 CMR 

Chapter 530.5) 

Maine Ambient Air Quality 

Standards [38 MRSA 584; 06-

096 CMR, Chapter 110] 

Maine Incinerator Particulate 

Emission Standard [CMR 

Chapter 104) 

Maine Air Pollution Control 

Laws-Maine Emissions License 

Regulations [38 MSRA 585, 

590-591 CMR, Chapter 115] 

Maine Hazardous Waste 

Management Rules (06-096 

CMR Chapter 850-857). 

STATUS 

Applicable 

Applicable 

Applicable 

Applicable 

Applicable 

Applicable 

REQUIREMENT SYNOPSIS 

notification, transportation, storage, 

licensing, and disposal requirements for 

projects exceeding 200 linear or 100 square 

feet. 

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. 

This program establishes numerical 

surface water quality standards for all 

Maine surface water. 

This chapter establishes ambient air quality 

standards that are maximum levels of a 

particular pollutant permitted in the ambient 

air. 

These regulations establish a limitation on 

the amount of particulate matter allowed to 

be emitted fi-om each of several categories 

and sizes of incinerators, and a limitation on 

the capacity of emissions fi-om all 

incinerators. 

Requires new sources of air emissions to 

demonstrate that its emissions do not violate 

ambient air quality standards. New sources 

must meet preconstruction monitoring and 

post-construction monitoring requirements, 

and must undergo analysis of the Best 

Available Confi-ol Technology to quantify 

emission levels and analyze control 

techniques. 

These mles establish performance 

standards for treatment, disposal, and/or 

storage of media contaminated with 

ACTION TO BE TAKEN TO ATTAIN ARAR 

TO THE EXTENT PRAGTIGABLE 

substantive requirements of these regulations. 

Site activities will be designed and 

implemented in a manner that does not 

degrade the chemical, physical, or biological 

integrity of the East Branch Sebasticook River. 

Site activities will be designed and 

implemented in a manner that does not 

degrade the chemical, physical, or biological 

integrity of the East Branch Sebasticook River. 

Standards for particulate matter-150 pg/m', 

24-hour average concenb^tion. Dust 

suppression will be utilized as needed to comply 

with this standard. 

Incinerators and thenrnal desorption units will be 

designed and operated to comply witti these 

emission limits. 

Removal actions that may generate air 

emissions will comply with the substantive 

requirements of ttiis regulation ttirough a 

monitoring and appropriate control program . 

To the extent they are more stringent than 

federal RCFJA requirements, and to the extent 

practicable, EPA will design and operate 

\WBBI'ORTr.r 'ROUPS\PROJECTS\CorinnaV\RARs\Alt 2 ARAR'rbls.CKX of 5 M? ...1999 
continued 

TABLE D-6 

ACTION-SPECIFIC ARARS FOR ALTERNATIVE 2 

ENGINEERING EVALUATION/COST ANALYSIS 

EASTLAND WOOLEN MILL SITE 

CORINNA, MAINE 

REGULATORY 

AUTHORITY 

St.nte 

State Criteria, 

Advisories and 

Guidance 

State 

ACTION 

Activities that 

exuose soil with 

potential for erosion 

Generation of air 

emissions 

Asbestos 

Abatement and 

tasks relating to 

managing removal, 

transport, and 

disposal of asbestos 

containing material 

REQUIREMENT 

Erosion and sedimentation 

control (38 MRSA subsection 

420-C), Chapter 500, 

Stormwater Management 

Rules 

Maine Department of Human 

Services Interim Ambient Air 

Guidelines, Memorandum 

Febnjary23, 1993. 

Maine DEP Asbestos 

Management Regulations (38 

MRSA Chapter 12-A, 06-096 

CMR Chapter 425] 

STATUS 

Applicable 

To be 

considered. 

Applicable 

REQUIREMENT SYNOPSIS 

hazardous waste. They include 

performance standards for hazardous 

waste piles, tanks, and miscellaneous 

units. 

Erosion control measures must be in place 

before activities, such as filling, displacing 

or exposing soil or other earthen materials 

take place. Prior MEDEP approval is 

needed if a disturbed area is in the direct 

watershed of a body of water most at risk 

(i.e., Sebasticook Lake). 

Interim ambient air guidelines are derived 

from risk assessment-based criteria or 

from occupational exposure criteria that are 

protective of ambient air quality. 

Asbestos abatement measures described 

herein ensure that activities related to ttie 

management and abatement of friable 

asbestos-containing materials are property 

conducted in a manner to protect ttie public 

health. These regulations specify minimal 

removal, notification, fi-ansportation, storage, 

and disposal requirements for projects 

exceeding three linear or square feet. 

ACTION TO BE TAKEN TO ATTAIN ARAR 

TO THE EXTENT PRAGTIGABLE 

response actions to meet the substantive 

requirements of these regulations. 

Where Site activities described in 38 MRSA 

420D or 38 MRSA 481-490 occur, USEPA will 

implement appropriate controls to address 

erosion, sedimentation and stormwater. 

Applicable plans will be coordinated with 

MEDEP prior to implementation. 

These guidelines will be considered during the 

design of emissions control equipment. 

Remediation activities related to ttie demolition 

and disposal of asbestos-containing materials 

shall be designed and conducted in a manner 

consistent vintti State of Maine regulations. 

iiA,BBPORTnDATA\GRO(JPSiPROJECTS\Corinna\ARARsWI_2_ARARTbls.DOC Page 5 of 5 May 20, 1999 
continued 

Notes: 

TABLE D-6 

ACTION-SPECIFIC ARARS FOR ALTERNATIVE 2 

ENGINEERING EVALUATION/COST ANALYSIS 

EASTLAND WOOLEN MILL SITE 

CORINNA, MAINE 

ARAR 

CFR 

CMR 

LDRs 

MRSA 

NPDES 

PCB 

ppm 

RCRA 

TSCA 

TSD 

USE.OA 

iigh'A 

VOC 

,3 

Applicable or Relevant and Appropriate Requirement 

Code of Federal Regulations 

Code of Maine Regulations 

Land Disposal Restrictions 

Maine Revised Statutes Annotated 

National Pollutant Discharge Elimination System 

polychlorinated biphenyl 

parts per million 

Resource Ckinservation and Recovery Act 

Toxic Substances Control Act 

treatment, storage, disposal 

U S, Environmental Proiection Agency 

micrograms per cubic meter 

volatile organic compound 

"•.R0UPS\PR0JECTS\ConnnaWF^.\RsVs,ll_2_ARARTbls.DOC Sof 5 Mr ^ 1999 
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE 

ATTACHMENT 5 

EE/CA FACT SHEET 
EPA Superfund Program May, 1999 

The Cleanup Proposal.. 

Based on EPA's detection of 

significant levels of 

contaminants in the soils at 

the Eastland Woolen Mill 

Superfund Site (Figure 1: 

Location Map), EPA 

proposes the foUowing early 

cleanup plan to reduce risks 

to human health and the 

environment from site 

contamination: 

• Remove soils 

contaminated with 

chlorobenzenes. The 

excavated soil will be 

treated on-site using a 

thermal desorption and 

vapor phase treatment 

technology (i.e., heat 

the soils to evaporate 

the chlorobenzenes, and 

separate or treat the 

contaminants from the 

vapor). 

• Demolish portions of 

the former woolen mill 

to allow access to 

contaminated soils. 

• Manage surface water 

to allow for soil 

excavation below the 

riverbed. 

More on page 2 

EPA Plmi§ B&ll GImmip 

Eastland Woolen Mill Superfund Site 

Corinna, Maine 

How would the cleanup 

affect the local area? 

Find out about the proposed 

cleanup plan and how it compares 

with other cleanup options for the 

site at a public informational 

meeting on Thursday, May 27, 

1999 at the Corinna School. At 

the meeting, EPA wUl respond to 

your questions and concems 

about the proposed cleanup and 

You are invited to participate 

in evaluating a proposed 

cleanup plan for the 

Eastland Woolen Mill 

Superfund Site!! 

Come to the public 

information session on 

Thursday, May 27,1999 at 

7:00p.m. 

Corinna School 

Corinna, Maine 

Leam more about how you 

can comment on the 

proposed plan during the 

30-day public comment 

period. 

Second MeetJng; 

Formal Public Comment Session 

Thursday, June 24, 1999 at 

7:00p.m. 

Corinna School 

how it may affect you. For further 

information about the meeting, 

call Erin Heskett, EPA 

Communit y I nvo l v e in e n t 

Coordinator at (617) 918-1054. 

What do you think? 

EPA is accepting public 

comment on this proposal from 

May 28, 1999 through June 28, 

1999. You do not have to be a 

technical expert to comment; if 

you have a concem or preference, 

then EPA would like to hear from 

you before making a final decision 

on how to protect your 

community. 

To comment formally, you can: 

•Submi t oral comments 

during the comment portion ofthe 

pubUc hearing on June, 24 1999, 

(see page 10 for details) 

•Send written comments 

postmarked no later than June 28, 

1999 to: 

Edward Hathaway 

Remedial Project Manager 

U.S.EPA Region I, HBT 

1 Congress Street, Suite 1100 

Boston, MA 02114-2023 

•E-mail comments to 

hathawa\.ed@epamail.epa by 

June 28, 1999. 
A Closer Look at EPA's Proposal... 

The primary goal of EPA's proposed cleanup for the Eastland Woolen Mill Site is to remove the source of 

contamination in soils, thereby reducing the amount of contamination that is migrating into the groundwater 

and the East Branch of the Sebasticook River. EPA proposes to excavate and treat on-site the contaminated 

soils that represent a threat to human health and the environment. The chlorobenzenes 

(monochlorobenzene, dichlorobenzene, and trichlorobenzene) In the soils pose a potential significant threat 

to future users of the groundwater; to humans who come into direct contact with the contaminants; and to 

the sensitive Sebasticook River ecosystem. The proposed major cleanup activities are outlined as follows: 

/. Site clearing, sampling, and contamination 

delineation. EPA wiU: 

• Establish a site office and mobile laboratory onsite. 

• Stabilize the site to minimize any soU erosion into 

the East Branch of the Sebasticook River. 

• Remove portions of the former Eastland Woolen 

building to allow access to the soil contamination 

and provide space for the cleanup operations. 

• Perform soil sampling to determine the limits of 

the excavation areas and to confirm that the soOs 

remaining after e:-cavation are below cleanup 

levels. 

• Temporarily relocate other buildings/structures in 

the area if needed. 

• Establish traffic control and air monitoring 

programs. 

2. Remove soil that presents the highest risks to 

human health and the environment (See Figures 2 

& 3). EPA will: 

• Excavate soil 9ontaminated with levels of 

chlorobenzenes that present a significant threat to 

human health as defined by the cleanup levels 

specified in Table 3. 

• Treat the excavated soils td acceptable levels and 

place the treated soil back into the ground. The 

soils will be cleaned using a technology that uses 

heat to drive the contamination out of the soil as a 

vapor, which is collected and treated (See Figure 4 

& 5). The vapor may be treated using activated 

carbon drums or by using a technology that 

destroys the chemicals using a high temperature 

flame or heating element. EPA will identify the 

specific treatment technology during the design 

phase. 

• Conduct air monitoring to insure that the 

surrounding Corinna neighborhood is not exposed 

to unacceptable levels of contaminants during the 

cleanup. However, EPA expects that there likely 

will be a noticeable, non-hazardous odor during 

excavation. 

3. Other required activities. EPA will: 

• Remove the bridge on Main Street and install a 

temporary bridge in a nearby location to allow for 

excavation in the river. At least one building on 

Main Street may require temporary relocation to 

allow for excavation down river beyond the bridge. 

• Divert and manage water flow in the East Branch 

of the Sebasticook River to allow for excavation 

beneath the riverbed. A 420 foot reach of the river 

will be either re-located during excavation 

activities, or routed through a culvert. 

• Stabilize or remove the dam that is located under 

the former woolen mill. 

• Treat to safe levels and dispose of any water 

drained from excavated contaminated soils or 

withdrawn from the ground. EPA wiU likely 

discharge the treated water to the Corinna Sewer 

and POTW. If not, then the treated water will be 

re-injected into the ground. 

Once the cleanup is complete, EPA will remove the 

treatment system, regrade and stabilize the site, and 

restore the river and Main Street. 

Cost: Approximately $9.7 milUon. 

Pro.iect Completion Schedule 

• Demolition and sampling work: 1999 

• Excavation and treatment; initial restoration 

acfivities: 2000 

• Final site restoration: 2001 
Scope an d Role of 

Action 

The Superfund law authorizes EPA 

to implement cleanup actions under 

EPA's "Removal" or "Remedial" 

Programs. The Remedial Program 

provides resources to address longterm issues, such as groundwater 

contamination. On the other hand, 

EPA often uses the Removal 

Program to respond to short-term 

emergency situations that are time 

critical. EPA may also perform a 

removal action at a site when 

prompt action is necessary, but 

more than six months of planning 

and preparation time is available 

before on-site cleanup work must 

begin. This approach is caUed a 

non-time critical removal action 

(NTCRA). (Please refer to EPA's 

Community Update #2, February 

1999, for a description of how EPA 

is applying the NTCRA process to 

the Eastland Woolen Mill Site). 

EPA will generally use NTCRA 

authority to accelerate a response to 

address the source of contamination 

at a site. This is consistent with 

EPA's Superfund Accelerated 

Cleanup Model (SACM). EPA 

developed the SACM strategy to 

speed up Superfund cleanups and 

make them more timely and 

efficient. In particular, the SACM 

authorizes the use of Removal and 

Remedial authorities earlier in the 

Superfund process to achieve rapid 

risk reduction as compared with 

more traditional Superfund 

cleanups. 

Why Take Action Now? 

The soil contamination at the 

Eastland Woolen Mill Site qualifies 

for a NTCRA because immediate 

control of the contaminated source 

material on-site is necessary to 

protect the surrounding environment 

and community, and to prevent 

further contamination of the 

groundwater. The contamination in 

the soils on-site poses a significant 

threat to the bedrock aquifer and the 

East Branch of the Sebasticook 

River (See Figure 6). This 

contamination will continue to 

migrate into the bedrock aquifer and 

the river unless it is contained, 

removed, or otherwise treated. As 

shown in Tables 1 and 2, the 

concentrations detected in . 

surrounding former water supply 

weUs and in the soils far exceed 

state and federal health-based 

standards. 

EPA further confirmed the threat 

posed by the contamination in the 

soils in a preUminary human health 

risk evaluation, which is presented 

iri a study called, Engineering 

Evaluation/Cost Analysis (EE/CA). 

EPA win use the EE/CA to evaluate 

different options for controlling the 

source of contamination. The 

EE/CA is now available to the 

pubhc at the Corinna PubUc Library. 

At the Eastland Woolen MUl Site, 

EPA has appUed the NTCRA 

authority as an accelerated . . 

approach, with work beginning in 

1999. IfEPAhadfoUowedthe 

standard Superfiind Program 

approach at this Site, the cleanup 

could not have been initiated untU 

the summer of 2002, at the earUest. 

Cleanup Actions Beyond the 

NTCRA 

While the proposed action will 

accelerate the overall site cleanup 

by eliminating a major source of 

the chlorobenzenes in the soils, it 

does not alone constitute the 

complete cleanup plan for the site. 

During the remainder of 1999 and 

into 2001, EPA anticipates 

completing a comprehensive study of 

the entire site, termed the Remedial 

Investigation and Feasibility Study 

(RI/FS). EPA wUl use the results of 

each investigation ofthe site in 

combination with the hunian health 

and ecological risk assessments to 

determine the need for any additional 

cleanup actions beyond EPA's nearterm NTCRA. 

The EPA currently anticipates 

addressing the foUowing cleanup 

issues after the NTCRA is 

completed: 

• long-term groundwater cleanup to 

restore the groundwater to 

drii\king water standards or to 

control the movement of 

contaminants; 

• sediment and/or surface water 

cleanup; and, 

• controls on groundwater and land 

use in the vicinity of the site. 

Currently, EPA is working with the 

Maine Department of Environmental 

Protection (DEP) to determine 

whether the site wUl be designated 

on the Superfund Program's 

National Priorities List (NPL). The 

site was proposed for inclusion on 

the NPL on April 23, 1999. If 

designated, then EPA wUl seek funds 

to complete the Remedial 

Investigation, Human Health Risk 

Assessment, Ecological. Risk 

Assessment, and Feasibility Study 

reports, aU of which should be 

avaUable by early 2001 if the site is 

placed on the NPL. 
T:\2478-01\2478F012 03-02-99 DEL 

(MODIRED AFTER MDEP GIS MAP 1899 ) 

TARGET CONTAMINANTS" ARE DEFINED AS CONTAMINANTS 

CURRENTLY THOUGW TO EXIST AS A RESULT OF A RELEASE 

FROM ACTTVMES AT THE EASRAND WOOLEN MI U 

Socle in feet 

FIGURE 1 

LOCATION MAP 

EASTLAND WOOLEN MILL SITE 
T:\247a-01\247ar030.0WG 04/19/99 PEL 

LEGEND 

SOIL BORING LOCATION 

AREAS TARGETED FOR REMOVAL ACTION 

TEMPORARY RIVER RELOCATION 

i|© 

FIGURE 2 

SOIL EXCAVATION LIMITS 

EASTLAND WOOLEN MILL SITE 
Building 4 

Bedrock 

LEGEN D 

y/AAAAt Inferpreted extent of chlorinated benHene 

Bedrock 

Horizontal Scale in Feet 

0 60 120 

Vertical Exaggeration 4X 

Building 2 

m 

^ 

FIGURE 3 

SIDE VIEW OF CONTAMINATION EASTLAND WOOLEN MILL SITE 
1,000cy Soil Pile 

Approximately 45 ft. x 100 ft x 10 ft. Blower 

Thermal 

Oxidizer 

1,500-1,800°F 

0.5-1.0 sec. 

Fuel 

(Propane) 

1 ^ 

YAA2 2 y^ 

z 

Catalytic 

Oxidizer 

Treated Air 

" ^ to Atmosphere 

(10 to 15%) 

Recirculating Air 

(85 to 90%) 

Make-up Air 

(10 to 15%) 

FIGURE 4 

SCHEMATIC OF ON-SITE THERMAL TREATMENT EASTLAND WOOLEN MILL SITE 
FIGURES 

PLAN OF TREATMENT AREA 

EASTLAND WOOLEN MILL SITE 
T:\2478-01\247BF029 04-16-99 DO. 

LEGEND 

STRUCTURE NOT SAMPLED 

TARGET CONTAMINANTS OBSERVED 

BELOW MCLs ANO MEGl \ 

HISTORICALLY SAMPLED 

NON-DETECT 

NON TARGET CONTAMINANTS / / 

OBSERVED BELOW MCLi AND MEGg// 

SERVICED BY PUBUC WATER SUPPLY 

^•> ^ WATD^ SUPPLY UNE 

(MODIRED AFTER MDEP GIS MAP 1899) 

"TARGET CONTAMINANTS" ARE DEFINED AS CONTAMINANTS 

CURRENTLY THOUGHT TO EXIST AS A RESULT OF A RELEASE 

FROM ACnvmES AT THE EASTLAND WOOLEN Mi a 

Scale in feet 

FIGURE 6 

ESTIMATED AREA OF 

GROUNDWATER CONTAMINATION 

EASTLAND WOOLEN MILL SITE 
Table 1: Levels of Contaminants Found Onsite in Soils Compared to Acceptable State and 

Federal Levels 

Site Contaminants 

of Concem for Soil 

benzene 

chlorobenzene 

1,2 dichlorobenzene 

1,3 dichlorobenzene 

1,4 dichlorobenzene 

1,2,4 trichlorobenzene 

Acceptable SoU Level for 

Protection of Groundwater 

30 

1000 

17000 

41000 

2000 

5000 

Maximum Soil Concentration 

Found on Site 

14,000 

140,000 

1,400,000 

2,300,000 

3,400,000 

1,200,000 1 

Table 2: Levels of Contaminants Found Onsite in Groundwater Compared to Acceptable 

State and Federal Levels 

1 Site Contaminants of 

1 Concern in ttie 

benzene 

Chlorobenzene 

1,2 dichlorobenzene 

1,3 dichlorobenzene 

1,4 dichlorobenzene 

1.P.4 tnchlorobsnzetie 

Federal Maximum 

Contaminant Level (MCL) 

5 

100 

600 

No MCL 

75 

m 

Maximum Concentration found 

on Site 

(oarts oer billion) 

43 

5,869 

2,230 

1,800 

2,935 

2.335 

TcU}le 3: Proposed Soil Cleanup Levels 

(During soil treatment, it is likely that EPA will reduce concentrations of some contaminants to levels that 

are below the cleanup levels presented in this table). 

Contaminant 

benzene 

chlorobenzene 

1,2 dichlorobenzene 

1,3 dichlorobenzene 

1,4 dichlorobenzene 

1,2,4 trichlorobenzene 

Cleanup Level (parts per billion) 

30 

1000 

17000 

41000 

2000 

5000 
Cleanup Altematives for the Eastland Woolen Mill Superfund Site 

In the Eastiand Woolen Mill Site Engineering 

Evaluation/Cost Analysis report, EPA reviewed 

the potential options for cleanup, as well as 

EPA's proposed cleanup plan. The cleanup 

alternatives are different combinations of plans 

to contain, remove, or treat contannination to 

protect public health and the environment. 

During ttie upcoming comment period from 

May 28, 1999 to June 28, 1999, EPA 

welcomes your comments on the proposed 

cleanup plan as well as tfie other technical 

approaches that EPA evaluated. The cleanup 

alternatives are summarized below. Please 

consult the Eastland Woolen Mill Site EE/CA 

report for more detailed information, now 

available at the Corinna Public Library. 

Soil 

Cleanup Alternatives 

All of the alternatives evaluated in the EE/CA 

included the demolition of the former Eastland 

Woolen Mill building. Management of surface 

water through culverts or diversion was also 

included in all alternatives. The excavation 

alternatives included measures to either 

stabilize or remove the dam beneath the 

Eastland Woolen Mill, and temporarily re-route 

traffic to allow removal of the Main Street bridge 

to excavate soil below the bridge. 

Move contaminants off site 

Alternative 1: Off -site disposal at a 

chemical waste landfill 

• Remove soil with concentrations of 

chlorobenzenes and benzene above cleanup 

levels (See Table 2 above). 

• Send excavated soil off-site to an approved 

hazardous waste landfill and/or treatment 

facility. 

• Cover excavated areas with clean fill. 

Treat contaminants on site 

!A5:aS£t£i^i;ft3i^3s5^t3-«.:fei«£c:2i ..:A:..'H:-C^ 

Alternative 2: Thermal desorption 

This alternative involves excavating soils that 

contain levels of contamination that are above 

the cleanup levels listed in Table 2, and treating 

these soils on-site. The contamination will be 

removed by heating the soil which drives the 

contamination into the gas (vapor) phase. This 

contaminated vapor is then captured and 

treated with either granular activated carbon or 

other treatment technology of equivalent 

effectiveness. The treated soil would be placed 

back on Site (See Page 2 for more detail on 

EPA's preferred cleanup alternative). 

Alternative 3: In-Situ Chemical Oxidation 

This alternative involves the installation of either 

vertical wells or trenches to allow for the 

injection of a chemical that would react with the 

contaminants in the soil. The reaction would 

destroy the contaminants and leave no 

hazardous residuals. 

Alternative 4: In-Situ Thermal Destruction 

This alternative involves the use of an electrical 

current to heat the soil and either destroy or 

vaporize the contaminants. The vapors would 

be collected and treated. 

Wetland/Floodplain Impacts 

AU of the cleanup altematives considered by EPA in 

the EE/CA would unavoidably impact the river 

floodplain and wetlands adjacent to the site. 

However, if implemented, EPA's preferred 

ahemative will result in less impacts to the floodplain 

and wetlands than the other altematives that EPA 

considered. In addition, EPA would restore and 

monitor wetland areas that were adversely affected 

during cleanup activities. Restoration activities could 

include placement of additional soil and plantings of 

native trees and grasses. Please refer to the EE/CA 

for more information about potential impacts of 

cleanup activities to the floodplain and wetlands. 
The Three Criteria 

for Choosing a Cleanup 

EPA uses three criteria to balance the pros and 

cons of cleanup alternatives. EPA has aheady 

evaluated how well each of the cleanup 

alternatives developed for the Eastland Woolen 

MiU Superfund Site meet these criteria (See Table 

4). Once comments from the state and the 

community are received, EPA will select the 

cleanup plan. 

A. Effectiveness: This criteria evaluates five 

specific subcriteria 

(1) Overall protection ofhuman health and the 

environment: WiU it protect you and the 

plant and animal life on and near the site? 

EPA wiU not choose a plan that does not meet 

this basic criterion. 

(2) Compliance with Applicable or Relevant 

and Appropriate Requirements (ARARs): 

Does the altern.itive meet aU federal and state 

environmental statutes, regulations and 

requirements on-site? 

(3) Long-term effectiveness and permanence: 

WiU the effects of the cleanup plan last or 

could contamination cause future risk? 

(4) Reduction of toxicity, mobility or volume 

through treatment: Does the alternative 

reduce the harmful effects of the 

contaminants, the spread of contaminants, and 

the amount of contaminated material? 

(5) Short-term effectiveness: How soon wiU site 

risks be adequately reduced? Could the 

cleanup cause short-term hazards to workers, 

residents or the environment? 

B. Implementability: Is the alternative 

technicaUy and administratively feasible? 

Are the right gcxxls and services (i.e. 

treatment machinery; space at an approved 

disposal faciUty) available for the plan? 

C. Cost: What is the total cost of an alternative 

over time? EPA must find a plan that gives 

necessary protection for a reasonable cost. 

EPA also strongly considers state and 

community input prior to finalizing the 

selection of the cleanup altemative. 

COV6, 

Four Kinds of Cleanup 

EPA examines numerous technical approaches to determine 

the best way to reduce the risks presented by a Superfiind site. 

Reducing risk to human health and the environment often 

involves combinations of highly technical processes. There 

are four basic cleanup options: 

Take limited or no 

action: Leave the site as it 

is, or restrict access to the 

site and monitor the 

contaminatioa 

Contain 

contamination: Leave 

contamination where it is 

and covCT or contain it to 

prevent exposure to, OT 

spread of contaminants. 

This method reduces risks 

firom exposure to 

contamination, but does not 

destroy OT reduce it. 

Move contamination 

off-site: Remove 

contaminated matoial (soU, 

groundwatCT, rtc.) and 

dispose of it OT treat it 

elsewhere. 

Trea t contamination 

on-site: Use a chemical 

or physical process on-site 

to destroy OT remove the 

contaminants. Treated 

material can be left on-site. 

Contaminants captured by 

the treatment process are 

disposed of at an off-site 

hazardous waste faciUty. 

B 
Table 4: Comparison of Removal Cleanup Alternatives 

Nine Criteria 

Effectiveness 

(l)Protects human 

health and 

environment 

(2)Meets federal 

and State 

requirements 

(3)Provides 

long-term 

protection 

(4)Reduces 

mobility, toxicity 

and volume 

(5)Provldes shortterm protection 

Implementable 

(Can it be done?) 

Cost SMillion 

Time to reach 

cleanup goal 

1 

Off-Site Disposal 

• 

• 

• 

^ 

• 

• 

39 

12-18 months 

2 

'Thermal Desorption 

• 

• 

• 

• 

• 

• 

1 '-^ 

12 -18 months 

3 

In-Situ Chemical 

Treatment 

• 

• 

• 

• 

• 

A / 

14 

12-24 months 

4 

In-Situ Thermal 

Treatment 

• 

• 

^ 

• 

• 

^ 

18 

12-24 months 

^ EPA's preferred altemathre • Meets or exceeds criterion 

^ Partially meets criterion ^ Does NOT meet criterion 
Site History 

The 25-acre Eastland Woolen Mill Superfund 

Site includes the former Eastland Woolen Mill, 

located on Main Street in Corinna, Maine. 

1912 Eastland Woolen Mill begins operating 

as a textile mill. 

1971 Mill connected to sewer line. 

Previously, all wastewater was disposed 

of in the Sebasticook River. 

1977 All liquid wastes diverted to sewer. 

1983 Contamination first confirmed in local 

water supplies, water quality complaints 

reported as early as the 1970's. 

1983 Five homes and/or businesses provided 

with carbon treatment. 

1983 Eastland Woolen Mill begins site 

investigations. 

1988 Homes and businesses provided with 

carbon filters for drinking water. 

1993 Excavation and removal of three 

underground tanks. 

1995 I\iblic water supply wells and water line 

installed. Corinna Water District 

formed. Ten of original eleven 

locations were connected to water line 

1995 Eastland Woolen Mill performs 

sediment sampling 

1996 Eastland Woolen Mill closed. Maine 

DEP assumes financial obligations of 

Corinna Water District 

1996 Water District excavation detects 

contamination in East Branch of the 

Sebasticook River 

1996 DEP begins residential water quality 

monitoring 

1997 DEP and Corinna Water District work 

on fiinding assistance package to 

subsidize water supply. 

1997 DEP performs field work confirming 

contamination in river bottom and soils 

near building 

1997 DEP removes approximately 55,000 

pounds of hazardous materials from the 

closed mill 

1998 EPA meets with Town Officials 

1998 DEP confirms contamination in river 

bottom 

1998 EPA initiates Site work 

What impacts would the cleanup 

have on the local community? 

^ Any actions that distuH> tlie contamination during cleanup 

could present shon-term risks. As a result, EPA will monitor 

air and other emissions to ensure that unsafe levels of 

contaminants are not released beyond the site boundary. 

There will likely be significant non-hazardous odors during 

excavation woric 

• For both on-site and off-site treatment options, careful traffic 

management will be required to ensure the safe transport of 

contaminated soil off-site or for treatment within the site. A 

traffic detour of Main Street will be constructed while the soils 

under the current Main Street bridge are exca vated. 

• Kiver re-location will require a new 

bridge and land for the temporary 

path of the river. EPA will 

coordinate significant residential 

or business disruptions with 

affected property ownen and Town •_ " 

of Corinna officials. 
I 

Summary 

At the Eastland Woolen Mill Site in Corinna, Maine, EPA is proposing an accelerated 

cleanup of contaminated soils that pose an imminent threat to human health and the 

environment. Until these contaminated soils are addressed, high concentrations of 

chlorobenzenes in the soils will continue to contaminate the East Branch of the Sebasticook 

River and threaten surrounding groundwater drinking water supplies. Concentrations of 

several different chlorobenzenes in the soil and groundwater significantly exceed established 

state and federal health standards. 

EPA's proposed early cleanup would involve the excavation of soils above the cleanup levels 

specified in Table 3, on page 4. EPA is proposing to treat (or clean) these soils using a 

technology that drives the contamination into a vapor that is collected and treated. The vapor 

may be treated using a thermal destruction technology or by activated carbon. 

EPA's proposed cleanup plan presented in this newsletter represents the best balance of cost, 

effectiveness, and implementability compared to other viable alternatives. This proposed 

cleanup plan is currently available for public review and comment until June 28,1999. 

Specifically, EPA is seeking public comments on the following items: 

• The justification for EPA's proposed cleanup plan at the Eastland Woolen Mill Site; 

• the Engineering Evaluation and Cost Analysis Report (EE/CA) that describes the Site 

conditions and presents a discussion of the cleanup alternatives considered (this report is 

available at the Corinna Public Library); 

• EPA's determination that all ofthe cleanup alternatives considered by EPA in the EE/CA 

would unavoidably impact the river floodplain and wetlands adjacent to the site, and EPA's 

plan to restore and monitor wetland areas adversely impacted by cleanup activities. 

• the cleanup levels specified in the EE/CA and proposed plan as protective of human health 

and the environment. 

Once the comment period is complete, EPA will consider all public comments received and 

respond to those comments in a formal document called, the Responsiveness Summary. 

Orice completed, EPA will make available,a copy ofthe Responsiveness Summary at the 

Corinna Public Library. 

Finally, EPA will fully consider public comments on the proposed cleanup plan and EE/CA to 

prepare an Action Memorandum, which documents the selection of the early cleanup action. 

Once the Action Memorandum is approved, and assuming that funding is available, EPA will 

implement the early cleanup. 
-:i-^ .^r:;i^.5'.56^^=i? iSf §?Si=2 i^v i^ ^:;.^:?>.ssi»:-.tesnet;;= •:i}^:Vp iiJi Si5a^Xiai;X?SV.;5'5?:w:5=-i^;^'='JAS^ cTSil-J^^avT^^irr ' :ft:;-"Avr^.?r^'T-;i» ji 

Wfea^ IS a Formal Comment? 

During the 30-day pubUc comment period from 

May 28, 1999 to June 28, 1999, EPA wiU accept 

formal written comments and hold a pubUc hearing 

at the end of the 30-day period. EPA uses this 

pubhc input to improve the cleanup proposal. 

To make a formal comment you need only speak 

during the pubUc hearing on June 24, 1999, or 

submit a written comment by June 28, 1999. 

WhUe EPA considers input from the community 

throughout site investigations and cleanup, EPA is 

required to respond in writing to formal 

comments about the proposed cleanup plan 

presented by citizens at the pubUc hearing only. 

Upon completion of the formal comment portion 

ofthe pubUc hearing, EPA wUl discuss the cleanup 

proposal with meeting participants and answer 

questions. 

EPA wiU review the transcript of aU formal 

comments received at the hearing and aU written 

comments received during the formal comment 

period before making a final cleanup decision. 

EPA wiU then prepare a written response to aU 

formal written and oral comments. 

Your formal input and ideas wUl become part of 

the official pubhc record. The transcript of 

comments and EPA's written responses wiU be 

issued in a document caUed a Responsiveness 

Summary when EPA releases the fmal cleanup 

decision. Once complete, the Responsiveness 

Summary wiU be available at the Corinna PubUc 

Library for review. 

For More Detailed Information 

To help you understand and comment on EPA's proposed cleanup plan for the Eastland Woolen MUl Site, all of the 

technical and public information publications prepared to date for the site are available for public review at the following 

locations: 

Corinna Public Library 

Reference Librarian 

Corinna, Maine 

(207) 278-2454 

Hours: 

Wednesday, l:30-7:00p.m. 

Saturday, 9:00 a.m. - 12:00 p.m. 

EPA Records Center 

90 Canal Street 

Boston, MA 02114 

(617)918-1453 

Hours: 

Monday-Friday 

10:00 am-noon 

2:00 pm-5:00 pm 

10 
UNITE

D STATES 

ENVIRONMENTAL PROTECTION AGENCY 

Eastland Woolen Mill Superfund Site 

REGION I 

1 Congress Street, Suite 1100 

BOSTON, MA 02114-2023 

Forwarding address correction requested 

First Class Mail 

Postage and Fees 

Paid by EPA 

Pemiit No. G-35 

Penalty for Pnvate Use 

Official Business 

$300 
Use This Space to Write Your Comments 

or to be added to the mailing list 

EPA encourages you to provide your written comments and ideas about the cleanup options under consido-ation for 

dealing with the contamination at the Eastland Woolen Mill Superfiind Site. You can use the form below to send written 

comments. If you have questions about how to comment, please caU EPA Community Involvement Coordinator Erin 

Heskett at 617.918.1054. Please maU this form or additional sheets of written comments, postmarked no later than, 

June 28,1999 to: 

Ed Hathaway 

Remedial Project Manager 

U.S. Environmental Protection Agency 

Region I, (HBT) 

1 Congress Street 

Boston, MA 02114 - 2023 

or send E-mail to: 

hathaway.ed @epamail.epa.gov 

(Attach sheets as needed) 

Comment Submitted by: June 28, 1998 

Mailing list additions, deletions or changes 

/ would like to: 

a be added to the site mailing list Name : _ 

n note a change of address Address: 

O be deleted from the mailing list 
Eastland Woolen MiU Superfund Site 

Public Comment Sheet (cont...) 
Fold, staple, stamp, and maUEd Hathaway 

Remedial Project Manager 

U.S. Environmental Protection Agency 

Region I (HBT) 

1 Congress Street, Suite 1100 

Boston, MA 02114-2023 
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE 

ATTACHMENT 6 

RESPONSE TO COMMENTS 
Response to Comments Received 

Regarding Proposed Non-Time Critical Removal Action 

Eastland Woolen Mill Superftmd Site 

Corirma, Maine 

Introduction: 

This Response to Comments documents the public comments received by EPA regarding a 

proposed Non-Time Critical Removal Action (NTCRA) at the Eastland Woolen Mill Superfiind 

Site in Corinna, Maine. All comments received by EPA between May 28, 1999 and June 28, 

1999 were considered in this Response to Comments. An informal public hearing was held June 

24, 1999 at which EPA recorded oral comments offered by the public. A copy ofthe transcript 

ofthe informal public hearing is attached. 

Background: 

EPA began work at the Site in November 1998. A public information fact sheet was issued in 

December 1998 to introduce the public to EPA. EPA issued a second public information fact 

sheet in February 1999 to update the public with respect to the EPA preliminary Site activities. 

A public information meeting was held on March 4, 1999 to discuss the EPA activities at the 

Site. Approximately 80 people attended this meeting. EPA also attended several local meetings 

ofthe Board of Selectmen and the Corinna Revitalization Committee to gain insight into local 

concerns. EPA held a stakeholders meeting April 8, 1999 to discuss a potential early cleanup 

action with representatives ofthe Town, citizen groups, and State Officials. 

In May 1999 EPA released a fact sheet describing the proposed NTCRA. An informal public 

meeting was held on May 27, 1999 to present the results ofthe investigations, summarize the 

Engineering Evaluation and Cost Analysis (EE/CA), and to answer questions. The comment 

period began May 28, 1999. All comments postmarked by June 28, 1999 were accepted by EPA. 

All comments received up to the date of the Action Memorandum were considered by EPA. 
Written Summary and Response to Comments submitted 

Comments made at the Public Hearing: 

Comment 1: The State of Maine provided a oral summary ofthe concurrence letter regarding 

the proposed NTCRA. 

EPA Response: EPA appreciates the support ofthe Maine DEP. 

Comment 2: Two representatives for the Town of Corinna expressed their support for the 

proposed NTCRA. 

EPA Response: EPA appreciates the support of the Town of Corirma. 

Comment 3: A local resident expressed his support for the proposed NTCRA. 

EPA Response: EPA appreciates the support ofthe local residents. 

Comment 4: A local resident and chairperson ofthe Downtown Revitalization Committee 

expressed her support for the proposed NTCRA. 

EPA Response: EPA appreciates the support and wants to express that the Agency also has 

an interest in the re-vital ization ofthe community through cleanup ofthe 

environmental hazards that may serve as obstacles to re-use. 

Comment 5: The President ofthe Sebasticook River Watershed Association expressed the 

support the organization for the proposed NTCRA. 

EPA Response: EPA appreciates the support and wants to express that the Agency has also 

has an interest in the restoration ofthe East Branch ofthe Sebasticook 

River 

Written Comments received by EPA 

Comment 1: EPA received a letter from United States Senator Olympia J. Snowe expressing 

support for the proposed NTCRA. 

EPA Response: EPA appreciates the support for the NTCRA. 

Comment 2: EPA received two letters from United States Senator Susan M. Collins expressing 

support for the NPL listing, the cleanup of on-Site contamination, and the 

proposed NTCRA. 

EPA Response: EPA appreciates the support for the NTCRA. 
Comment 3: EPA received a letter from the Town of Corinna expressing support for the 

NTCRA. The Town also expressed concems with the safety of a water tower 

located on the Mill property. 

EPA Response: EPA appreciates the support for the NTCRA. EPA expects that the water 

tower would only be removed if: contamination is detected beneath the 

structiu-e such that excavation is required; the water tower is in such poor 

condition that it represents a hazard to the EPA workers at the Site; or if 

the water tower is located in an area that is required for use by EPA. 

Comment 4: EPA received a letter of concurrence from the Maine DEP. 

EPA Response: EPA appreciates the support for the NTCRA. EPA and the Maine DEP 

have worked closely on the project. 

Comment 5: EPA received a letter of support from the Maine DOT. Several other issues were 

also presented in the Maine DOT letter. The letter provides assurance that Maine 

DOT will accept responsibility for any replacement bridge constructed by EPA 

with several conditions: (1) bridge and approaches are built to DOT 

specifications; (2) EPA releases DOT from liability for any contamination found 

in association with the bridge; (3) EPA will provide a deed for the bridge; and (4) 

EPA will obtain all permits. 

EPA Response: EPA appreciates the support for the NTCRA. With respect to the issues, 

EPA offers the following response: 

(1) EPA will work with DOT to construct the bridge and approaches to 

DOT specification; 

(2) EPA is able to offer releases from CERCLA liability in limited 

circumstances. EPA is willing to discuss a potential liability release with 

the DOT. EPA notes that since the replacement permanent bridge will be 

constructed in an area where the soil is clean, there may not be a need for a 

release from liability. 

(3) It is the imderstanding of EPA that DOT has the appropriate property 

rights for the placement of the original bridge and the replacement of the 

existing bridge in its current location. EPA is responsible for access 

agreements necessary to allow for a temporary bridge at alternate 

locations. However, it is the expectation of EPA that DOT will obtain any 

property rights necessary for the re-placement ofthe original bridge in any 

location other than the existing location for the Main Street Bridge. 

(4) EPA is exempt from State and local permits for work that occurs 

within the boundaries ofthe Superfund Site under Section 121(e) of 

CERCLA. The bridge work would clearly fall within the area that would 

provide for a permit exemption. EPA will work closely whh DOT to 

identify design, construction, and traffic flow issues. 
Comment 6: 

EPA Response: 

EPA received a letter from the Maine DEP further support for the proposed 

NTCRA and accepting any post-removal site control for the temporary or 

permanent diversion ofthe East Branch ofthe Sebasticook River. 

EPA appreciates the additional support and the intent to accept PRSC. At 

this time it is anticipated that the river diversion will be temporary in 

nature unless EPA issues a decision under its CERCLA remedial authority 

to permanently divert the river. 

Comment 7: 

EPA Response: 

Comment 8: 

EPA received a letter from the Maine DOC, Bureau of Parks and Lands in support 

of-the proposed NTCRA and requesting that EPA provide an alternate route for 

recreational traffic (snowmobiles, bicycles, and ATVs). 

EPA appreciates the support for the proposed NTCRA. EPA will consider 

public access as part ofthe traffic management plan. It is unlikely that the 

railroad crossing bridge will be removed prior to spring 1999. There will 

be a period of time when bicycle traffic will need to follow the road 

crossing. ATV traffic may be restricted for a substantial portion of 2000 

and into 2001 if the vehicles are unable to to legally travel on the 

temporary road constructed by EPA. This is an unfortunate consequence 

ofthe need to remove the contamination. There may be no loss of access 

to the trail if the contamination does not extent to the railroad crossing. 

EPA received a letter from a resident of a local community in support ofthe 

proposed NTCRA and also expressing concern that the river re-location occur 

prior to building demolition to prevent the downstream flow of contamination that 

may occur during demolition. 

EPA Response: EPA appreciates the support for the proposed NTCRA. EPA will make 

every effort to prevent contamination from the building from entering the 

East Branch ofthe Sebasticook River. EPA will consider the timing ofthe 

river re-location with respect to the building demolition. There may be 

issues that arise which prevent the re-location prior to building demolition. 

Comment 9: EPA received a letter in support ofthe proposed NTCRA from the Sebasticook 

River Watershed Association. The letter also requested more public outreach 

- regarding the extent of contamination; more information regarding erosion control 

practices diu-ing the cleanup; the restoration requirements for the East Branch of 

the Sebasticook River; and further evaluation of the benefit ofthe removal ofthe 

dam beneath the Mill. 

EPA Response: EPA appreciates the support for the proposed NTCRA. EPA is actively 

working with several public groups such as the Sebasticook River 

Watershed Association to inform the public and gain a better perspective 
regarding local issues. EPA is committed to a strong public outreach 

program (three fact sheets and two public meetings within 8 months). 

EPA expects to release additional fact sheets and hold additional public 

meetings during the NTCRA and RI/FS. Erosion control will be a major 

focus during the implementation ofthe cleanup. The East Branch ofthe 

Sebasticook River will be restored to meet the characteristics of its 

designated use, to the extent practicable. EPA will work with the Maine 

DEP regarding the river restoration activities. It must be vmderstood that 

other sources of contamination may affect the river and prevent 

achievement ofthe river standards. Under CERCLA, EPA can only 

respond to contamination that has been released from a Site and may not 

be able to address contamination that is not related to a release from the 

Site. EPA will perform a cost benefit analysis and seek stakeholder 

feedback regarding removal ofthe dam. Any impacts to the wetlands as a 

result of dam removal or stabilization activities will be minimized, to the 

extent practicable. 

Comments 10-83: EPA received 73 additional comments from local citizens in support ofthe 

proposed NTCRA. 

EPA response: EPA appreciates the tremendous support from the local residents. 
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE 

ATTACHMENT 7 

PUBLIC HEARING TRANSCRIPT 
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c@ 

JUNE 24, 1999 

PUBLIC HEARING 

TOWN OF CORINNA 

CORINNA SCHOOL 

7:05 P.M. 

RE: EASTLAND WOOLEN MILL SITE 

SPEAKERS: 

EDWARD HATHAWAY, PROJECT MANAGER 

MARY JANE O'DONNELL, USEPA 

PY 

ALLEY & MORRISETTE REPORTING SERVICE 626-0059 
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18 

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SPEAKERS: 

INDE X 

Edward Hathaway 

Mary Jane O'Donnell 

PAGE 

3,6 

3 

ALLEY Sc MORRISETTE REPORTING SERVICE 626-0059 
1 PROCEEDINGS 

2 MR..HATHAWAY: One minor detail tonight, 

3 we don't have a PA system this evening, so if any of 

4 our voices trail off, please just let us know if you 

5 can't hear us clearly. When we get to the hearing 

6 part, we'll actually ask you for the same thing, make 

7 sure you speak clearly so we can hear you. 

8 What I'd like to do right just quickly is just • 

9 say, good evening, welcome, thank you for coming out 

10 tonight for the public hearing for the proposed 

11 cleanup at the Eastland Woolen Mill site. 

12 I am now going to introduce my Section Chief, 

13 Mary Jane O'Donnell, who will be the EPA's hearing 

14 officer for the evening. So with that, I will turn 

15 it over to Mary Jane. 

16 MS. O'DONNELL: Thanks, Ed. I'd also like 

17 to say, good evening and thank you for making the 

18 effort to come to tonight's meeting. As Ed said, my 

19 name is Mary Jane O'Donnell. I'm the Section Chief 

20 of the EPA in Boston. I work in the states of Maine, 

21 Vermont and Connecticut. Hopefully you all can hear 

2 2 me. 

23 AUDIENCE: Not very good. 

24 MS. O'DONNELL: Well, I'll try to raise my 

25 voice a little bit. Those of you who were here at 

ALLEY & MORRISETTE REPORTING SERVICE 626-0059 
1 our May 27th meeting, tonight's format will be a 

2 little different. It's a bit more formal in the 

3 sense we have a court stenographer who's going to 

4 transcribe everything that's said during tonight's 

5 meeting. The purpose for that is that we want to 

6 make sure we hear what your comments are on the 

7 cleanup plan and make sure we know what they are 

8 afterwards. Once we get the transcript from this 

9 meeting along with the comments that we receive 

10 during the comment period, we will review those 

11 comments and make any changes as necessary to the 

12 cleanup plan. 

13 In terms of a few other things that we wanted to 

14 accomplish this evening -- a couple of things we 

15 wanted to accomplish, we wanted to review the 

16 proposed cleanup plan similar to what we did in the 

17 May 27th meeting. We also wanted to discuss some of 

18 the impacts of that plan. On the overhead, it 

19 mentions wetlands and flood plains. In addition, 

20 we'll talk a little bit about some of the traffic 

21 impacts, surface water impacts and air impacts. We 

22 also wanted•to review the^public involvement 

23 opportunities, the,comment period opened the end of 

24 May and it closes June 28th. Tonight is the public 

25 hearing, as I mentioned. We also wanted to give you 

ALLEY & MORRISETTE REPORTING SERVICE 626-0059 
1 folks an opportunity to speak at tonight's meeting to 

2 make sure we hear what your concerns are. 

3 In terms of the format for tonight's meeting, as 

4 I said, let tne go over the agenda and get a sense of 

5 that. After I finish my few introductory remarks, 

6 I'm going to turn things over to Ed and he's going to 

7 discuss the cleanup plan, our rationale, some of the 

8 environmental impacts and he's going to go into some 

9 of the details in terms of how you folks can comment 

10 outside of tonight's meeting. After Ed's 

11 presentation, I'm going to open the floor for 

12 comments and I'm going to ask anyone who would like 

13 to make a comment to identify yourself to the rest of 

14 the group. You may know each other, but there may be 

15 some people in the audience who don't know who you 

16 are. So I'll ask you to come forward to identify 

17 . yourself, to state your affiliation with the project 

18 and very briefly, if you could state your comment for 

19 the record. 

20 After I do that, and hopefully there will be 

21 enough time for those people who do want to speak to 

22 have a chance to speak, I'll close the record and at 

23 that point Robin will stop transcribing the meeting 

24 and then we'll open the floor for any other questions 

25 "" that you might have. During the formal part of the 

ALLEY & MORRISETTE REPORTING SERVICE 626-0059 
1 meeting while the meeting is being transcribed, we 

2 won't be in dialogue with you folks in terms of what 

3 do you think about this, what do you think about 

4 that, but we certainly do want to answer the 

5 questions you do have, so I'll close the meeting and 

6 then we'll open the floor to any other questions you 

7 might have. 

8 So that's the background. I assume there aren't 

9 any questions or if there are any questions, I'll be 

10 happy to answer in terms of the format of the 

11 meeting. Okay. With that as background, we're going 

12 to turn things over to Ed Hathaway. 

13 MR. HATHAWAY: Again, good evening, 

14 everyone. What I'd like to do, as Mary Jane, 

15 indicated, is do a review. I'm going to quickly 

16 restate the proposed cleanup action, why we're here 

17 tonight, what we're seeking your comment on and then 

18 go through sort of the site history and the reasons 

19 why we decided to propose early cleanup action and 

20 then restate the proposed cleanup action and the 

21 opportunity for public comment. 

22 The proposed cleanup action as described in the 

23 proposed plan and engineering analysis is the 

24 excavation and treatment of contaminated soils that 

25 represent a source of groundwater, surface water and 

ALLEY 5c MORRISETTE REPORTING SERVICE 626-0059 
1 sediment contamination. 

2 Now, as we've discussed at the previous meetings 

3 and you can see easier on this figure here; at this 

4 time, we expect the contamination that needs to be 

5 addressed to run from about the facility down below 

6 the river just to the railroad trestle although it 

7 may go further if we find more contamination 

8 downstream. 

9 The major components or aspects of this cleanup 

10 are the removal of the former Mill Complex. We have 

11 to tear the whole thing down to get to the 

12 contaminated soil. The excavation and treatment of 

13 contaminated soil. The treatment will hopefully 

14 reduce that contamination or will reduce that 

15 contamination to a level protective of human health. 

16 Now, the treatment of the soil as currently 

17 proposed involves heating soil piles that will cause 

18 the contamination to leave the soil in a vapor that 

19 will be collected and treated using a coinbustion 

20 unit. In effect, we will basically burn the gas, the 

21 vapor, the volatile vapor and destroy it. We may 

22 recycle some of that hot air back into the system to 

23 help reheat the pile or other piles. It's possible 

24 and very likely we will need to relocate the East 

25 Branch of the Sebasticook along the stretch where 

ALLEY Sc MORRISETTE REPORTING SERVICE 626-0059 
1 we're excavating. We will definitely have to do 

2 temporary relocation of Main Street and the Main 

3 Street Bridge as well as the collection and treatment 

4 of any water that drains the excavated soils. 

5 Our PA system has arrived. Other aspects of the 

6 proposed cleanup are that we do expect there to be 

7 some impacts to the wetlands and floodplains and we 

8 highlight this because Federal policy requires that 

9 any time there is a potential impact of floodplains 

10 or wetlands we make a full disclosure to the public 

11 of that to make sure you've had an opportunity to 

12 provide comments regarding any impact to the 

13 floodplains or wetlands and whether you concur with 

14 the EPA's finding that there was no practical 

15 alternative to that impact. In addition, we expect 

16 the action to take 18 to 24 months and cost about 

17 $9.7 million. The time frame is entirely dependent 

18 upon when we get our funding and whether we're able 

19 to start work this year or not. 

2 0 A major portion of the proposed cleanup is to 

21 present to the public the contaminant that we have 

22 identified as our major contaminant of concern and 

23 the concentrations of which we propose to cleanup to, 

24 meaning we will excavate any soils that exceed these 

25 levels. And for benzene it's 30 parts per billion or 

ALLEY & MORRISETTE REPORTING SERVICE 626-0059 
1 microgram per kilogram; for chlorobenzene, it's 1,000 

2 parts per billion; for 1,2 dichlorobenzene, it's 

3 17,000; for 1,3 dichlorobenzene, it's 41,000; for 1,4 

4 dichlorobenzene, it's 2,000; for 1,2,4 

5 trichlorobenzene, it's 5,000. That's going to 

6 control our excavation. There are also regulations 

7 that control exactly how low you have to treat a soil 

8 to either put it back in place or to take it to a 

9 landfill and we will look at all those regulations 

10 and if any of those other numbers are lower, we will 

11 treat the soils for a lower number than even this. 

12 It will not be treated to a higher level. These 

13 numbers were all selected based upon an EPA 

14 evaluation by toxicologist risk assessment, these are 

15 numbers which if left in the ground would be 

16 completely safe for public exposure over a lifetime. 

17 I want to just restate the reasons why we feel 

18 the cleanup action is necessary at this time, 

19 because high levels of contamination were detected in 

20 the soil beneath the former Eastland Woolen Mill and 

21 in the East Branch of the Sebasticook River. This 

22 contamination represents a continuing source to the 

23 groundwater as well as the surface water. What we 

24 mean is that the contamination that is in that 'soil 

25 is in a state where it's still moving and causing 

ALLEY & MORRISETTE REPORTING SERVICE 626-0059 
10 

1 contamination elsewhere. So that's why we call it 

2 source material. And if you can get in and remove a 

3 source, you shorten the time frame for those other 

4 areas like the bedrock aquifer, surface water and 

5 sediment to become clean. 

6 MS. O'DONNELL: Ed, can we take a quick 

7 break to plug --

8 MR. HATHAWAY: Sure. 

9 (Break.) 

10 MR. HATHAWAY: Okay. I guess that will 

11 work as well. Hopefully, I can now jump back and 

12 forth between the overhead and the podium here so you 

13 can hear me better. To pick up where I left off, 

14 other reasons are that it's well documented in this 

15 area that local water supplies have been 

16 significantly impacted since the 1980s and we realize 

17 that most of those have been placed on the water 

18 supply system. However, you know, the fact that they 

19 were contaminated is a reason to get out there and 

20 act. In addition, one of the other reasons we're 

21 proposing an early cleanup action is that we believe 

22 that the contamination that exists is accessible and 

23 we can actually do something about it. We can get to 

24 it and clean it up. 

25 And finally, one of the requirements for 

ALLEY Sc MORRISETTE REPORTING SERVICE 626-0059 
11 

1 Superfund is that we have made a finding that there 

2 is no one else out there who can do this. No one has 

3 the funding and the ability at this point in time to 

4 get out there and do this cleanup, so that's why we 

5 are proposing it. 

6 I'm going to step back for a second and just for 

7 anyone who is not familiar with the project, spend a 

8 little time just refocussing so that we realize that 

9 we're here tonight to talk about Eastland Woolen 

10 Mill. And generally, the area of concern that we're 

11 working with, and it can be seen best on this large 

12 figure, is essentially this entire area with the 

13 focus of the early cleanup is really up around the 

14 • Mill and immediately downstream of it. The 

15 investigation that we're going to do for the entire 

16 site to.assess where the contamination exists, we'll 

17 look at this entire area over the next couple of 

18 years. But right now, we're only targeting the 

19 initial cleanup phase with the mill and just 

2 0 downgrading it. 

21 I have included in these overheads, as I have in 

22 the past, and it's also included in all of our 

23 mailings, my name and address with the e-mail, the 

24 name and address and e-mail for Erin Heskett, our 

25 Community Involvement Coordinator as well as the name 

ALLEY & MORRISETTE REPORTING SERVICE 626-0059 
12 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

and address of several other key players and that is 

Scott Acone, who's here with the Corps of Engineers 

in the back; Kathy Niziolek, State Project Manager. , 

And also in the back there with her is also Hank Aho 

and Mark Hyland from the State of Maine. In 

addition, of course, is Judy Doore, whom you all know 

and love in this area and is much better known than 

us -

I want to quickly just restate the relevant 

facts of sort of a site history and that is we're 

looking at the .Eastland Woolen Mill being in 

operation from about 1909 through 1996. We're 

looking at a time period where essentially all of the 

waste water from that facility was disposed into the 

environment until 1971, when about -- most of their 

waste stream was then diverted to the Town of Corinna 

sewer system. And that represented about 80 percent 

of the Town's flow. By '77, all of the liquid waste 

would divert to the sewer line. 

In 1996, the Maine DEP picked up the monitoring 

of the water supply system. In '97, the DEP went out 

and followed up on some previous work done by Acheron 

to do some additional investigations of the river 

bottom and some soils near some former tanks. In '97 

as well, the DEP went out and removed all the liquids 

ALLEY Sc MORRISETTE REPORTING SERVICE 626-0059 
13 

1 in containers that were at the site, stabilized the 

2 site in the short-term. In '98, the DEP also went 

3 out and did some additional sampling. In 1998, EPA 

4 began its involvement in the site, some initial field 

5 work beginning in Novetnber running right through this 

6 spring in 1999. In April, one important -- very 

7 important factor is the site was proposed for 

8 inclusion on what's called the National Priority 

9 List. And that is also open for public comment. Is 

10 it closed on the comment period on , the -- did it 

11 close yesterday? 

12 SCOTT ACONE: Yes. 

13 MR. HESKETT: It ended June 23rd. 

14 MR. HATHAWAY: And that should go forward I 

15 would assume pretty readily. And this May, just a 

16 • month ago, we issued a fact sheet describing our 

17 proposed action. On May 27th, we had our first 

18 meeting. The public comment period is going to run 

19 from May 28th to June 28th and we're here tonight to 

20 have the formal or rather call it the informal public 

21 hearing. 

22 Just to recap, some of the activities that 

23 EPA has done in the short time we've been on the site 

24 is that this last fall and winter we put in 29 soil 

25 borings; we installed three additional monitoring 

ALLEY Sc MORRISETTE REPORTING SERVICE 626-0059 
14 

1 wells; we took 50 soil samples and 20 building 

2 samples and we sampled 30 former water supply wells. 

3 As a result of that work, we found significant 

4 contamination of the soil and the major contaminants 

5 that were identified were chlorobenzene, benzene, 

6 dichlorobenzenes, there's three of those, 

7 trichlorobenzenes, predominantly two of those that 

8 we've mentioned here, and we did find some inorganic 

9 or metal contamination, chromium, lead, and mercury, 

10 and some PCBs, but those were only in the building, 

11 we didn't find them out in the environment. 

12 Your handout shows -- also it shows in the 

13 figure up here the area that we have determined is 

14 where the primary area of contamination is located 

15 and that's the box here as well as these two circles 

16 as well as the small area of contamination over on 

17 what we call lot 88. 

18 I'll give you a side perspective look at what 

19 contamination might look like if you could see into 

2 0 the ground. It runs about 17 feet below the riverbed 

21 under the building and then about 10 feet or so under 

22 some of the other buildings and tanks. So we're 

23 looking at a fairly extensive area of heavily 

24 contaminated soil. 

25 The groundwater contamination at this point in 

ALLEY Sc MORRISETTE REPORTING SERVICE 626-0059 
15 

1 time it's believed to extend down to about the sewer 

2 plant. We don't -- this figure is conceptual in that 

3 we don't have enough information right now to say 

4 exactly where that contamination is. We know from 

5 the former water supply wells that at that point the 

6 groundwater is definitely contaminated up in the 

7 center of the Town and a little offset over the 

8 Sunshine Village. This area down here is unknown and 

9 we certainly hope to focus on that this summer. 

10 Just to give you some reference criteria. We 

11 took the contaminants of concern and we presented 

12 what the acceptable concentration would be in this 

13 case for soil where you come in contact with that 

14 soil over a lifetime or for that soil to be 

15 acceptable so that it doesn't represent a threat to 

16 groundwater and then we presented what were the 

17 maximum -- the highest concentrations found in the 

18 samples we took at the site. And you can see that 

19 you're looking at concentration differences where the 

20 stuff on site is upwards of 100 to 1000 fold higher 

21 than the safe concentrations. So clearly there's a 

22 lot of contamination in the soil. 

23 When you look for evidence that that soil 

24 contamination is creating a groundwater problem, we 

25 once again do the same type of comparison. We take 

ALLEY Sc MORRISETTE REPORTING SERVICE 626-0059 
16 

1 what would be considered a safe level for you to 

2 ingest in the groundwater and we compare them to the 

3 highest concentrations that we detected in the wells. 

4 And you can see once again that we're dealing with 

5 hundred folds difference. There's just a tremendous 

6 ' amount of contamination in some of the groundwater 

7 near the site. And that just reinforces the model 

8 that we have that says that the contamination is in 

9 the soil, it's causing, that contamination is moving 

10 into the bedrock groundwater representing a threat to 

11 anyone that might have to use that groundwater and is 

12 also impacting the river system. 

13 At every site EPA routinely evaluates the 

14 information to determine if an early cleanup is 

15 warranted. The EPA what's called a non-time critical 

16 removal authority is a form of legal action that EPA 

17 can take to respond to environmental contamination. 

18 It isn't an emergency, but is a clear source of 

19 contamination that should be removed or controlled 

20 more quickly than would be possible under the 

21 standard remedial process. And the reason we say 

22 standard remedial process is that at most Superfund 

23 sites the process is that we study the area for a 

24 time period of two to five years before we propose 

25 any action whatsoever. The Agency has really tried 

ALLEY Sc MORRISETTE REPORTING SERVICE 626-0059 
17 

1 to improve its responsiveness to cleaning up the 

2 environment at many sites by initiating early 

3 actions. And a non-time critical removal is a type 

4 of early action. A non-time critical removal 

5 involves the preparation of an engineering evaluation 

6 and cost analysis to evaluate cleanup options and a 

7 non-time critical removal action must undergo public 

8 comment and that's one of the reasons we're here 

9 tonight is to seek that public comment. 

10 The purpose of the engineering analysis, 

11 evaluation and cost analysis is to summarize the site 

12 . information, tp present a basis for the non-time 

13 critical removal action, to identify the removal 

14 action objectives. What are we trying to accomplish 

15 at the site? To evaluate a set of cleanup options, 

16 you know, what type of actions could you take to 

17 cleanup the site using three criteria, cost, 

18 effectiveness and implementability. It also serves 

19 as one of the major administrative support documents. 

2 0 And a copy of this engineering evaluation is at the 

21 Town Office for your review. 

22 The removal action objectives that were just 

23 mentioned are goals of this cleanup, how to prevent 

24 the direct contact with an injection of surface and 

25 subsurface soils that represent an acceptable health 

ALLEY Sc MORRISETTE REPORTING SERVICE 626-0059 
18 

1 risk. Basically, that means is we want to make sure 

2 we remove any soil that if you came in contact with 

3 it, it would represent a threat to you. We want to 

4 prevent the migration of chlorobenzenes, all of 

5 those, dichloro, the trichloro and the monochloro as 

6 well as the benzene that's in the soil into the 

7 groundwater and the surface water so that those 

8 mediums will be no longer degraded by that 

9 ' chlorobenzenes. We want to prevent the release of 

10- any contamination that's believed to still exist 

11 within the building into the environment that might 

12 happen by the continued flooding, further degradation 

13 or even fire that could occur in that structure. 

14 Based upon the contamination that we found, the 

15 concentrations we have found, the extent and the 

16 removal action objectives that we have just presented 

17 there were really only four options that we could see 

18 that made sense to evaluate in the engineering 

19 evaluation. And that was to excavate the soil, take 

20 it off-site for disposal, to excavate the soil and 

21 treat it on-site using a low temperature thermal 

22 absorption and vapor treatment, to try to treat all 

23 the contaminants in place without removing it using a 

24 chemical oxidation procedure, to treat it all in 

25 place using an in-situ, an in-ground thermal 

ALLEY Sc MORRISETTE REPORTING SERVICE 626-0059 
19 

1 destruction procedure. I want you to realize that 

2 every alternative we evaluated would have required 

3 removal of the former Mill and substantial surface 

4 water management, which would likely need to include 

5 relocation of the river as well as the likely removal 

6 and replacement of the highway bridge. 

7 When you look at the four options, it becomes 

8 pretty apparent quickly which is the one that makes 

9 the most sense. When you just look at costs, you 

10 know, the only one that's even under $10 million was 

11 Alternative 2, which was the on-site treatment. When 

12 you look at time, the only one that really has a 

13 shorter time frame of 18 months was Alternatives 1 

14 and 2, but once again, 2 was the least costly. When 

15 you look at the major benefits, you see that for 

16 Alternative 2 you're getting a reliable technology 

17 and you know that you're going to get rid of the 

18 contamination because you're going to go after it, 

19 dig ,it up and that we know we can treat it on site to 

20 levels that are safe. 

21 Now, the. other two alternatives that were very 

22 expensive, in-situ oxidation and in-situ thermal 

23 treatment would have less short-term impacts to the 

24 community because you would never have to expose the 

25 contamination to the air. The disadvantages of any 

ALLEY Sc MORRISETTE REPORTING SERVICE 626-0059 
20 

1 of these alternatives are fairly similar. For the 

2 first two, instead you're going to have truck 

3 traffic, some volatilization into the air and a lot 

4 of impact, short-term impact on the bridge and the 

5 river. Another disadvantage is you're going to get a 

6 short-term volatilization of some of the contaminants 

7 by the act of excavating it. The disadvantages of 

8 the final two, the in-situ alternatives is that they 

9 have a longer time frame and there's a lot of 

10 uncertainty when you try to treat something in place 

11 without removing it because you're never quite sure 

12 if you've got it all. 

13 So once again, I want to reiterate that we have 

14 proposed, based upon the engineering analysis, that 

15 the proposed option for treating the contaminated 

16 soils is low temperature thermal absorption. And 

17 that would involve the major components, we do a 

18 pre-design treatability and contaminant delineation 

19 study, we go out there, make sure it works, find out 

2 0 where all the contamination is located, we demolish 

21 the building, we divert the river, we'd set the 

22 treatment system up in part of the footprint of the 

23 former Mill, probably on the backside. We would then 

24 excavate and treat the soil on the north side of Main 

25 Street to allow us to get that soil removed, treated. 

ALLEY Sc MORRISETTE REPORTING SERVICE 626-0059 
21 

1 and have an area to work in. We would then have to 

2 move the bridge, install a temporary bridge for a 

3 bypass for the traffic and then we would excavate and 

4 treat soils at least down to the railroad bridge, 

5 further if necessary. 

6 Finally, we would perform site restoration, put 

7 in a peirmanent bridge, either put the river back in 

8 place or make the river permanent, if so required, 

9 and also, you know, stabilize any properties that are 

10 impacted by the cleanup. We're hoping that if we get 

11 the money this summer we would do our design work and 

12 the demo work this year and do the excavation next 

13 year. 

14 A picture of what the treatment system might 

15 look like is that you've got a soil pile where we run 

16 hot air into one side, we pull all the air out the 

17 other side, we burn the air before it's released into 

18 the environment, it would be treated to a level which 

19 would allow that air to not represent a threat. It 

20 would be essentially clean air once it's incinerated 

21 by the oxidizer. 

22 We provide in our fact sheet and also our 

23 handouts a conceptual idea of what the relocation of 

24 the bridge around the river might look like. I 

25 stress the word conceptual. There's a lot that needs 

ALLEY Sc MORRISETTE REPORTING SERVICE 626-0059 
22 

1 to be determined before we know exactly where the 

2 relocation might be, exactly where the bridge might 

3 be located, but just so you can get a perspective of 

4 that, we will have to do both of those that's 

5 presented in a figure for you. 

6 You've seen this figure before. This figure is 

7 to show you our concept of where the excavation might 

8 even take place. Under the former Mill building, a 

9 few isolated areas, over in lot 88 and down to about 

10 the railroad bridge. Possibly past it, we're not 

11 sure yet. 

12 Once again, I wanted to reiterate the post 

13 cleanup levels for the benzene, chlorobenzene, and 

14 ,1,2 dichlorozene benzene, 1,3 dichlorobenzene, and 

15 1,4 dichlorobenzene, and 1,2,4 trichlorobenzene. The 

16 numbers are here. As part of this comment process, 

17 we want you to provide whatever comments you may have 

18 oh those proposed nutubers. 

19 Revisiting, once again, the main reasons for the 

20 cleanup. There's high levels of contamination in the 

21 soil beneath the building. That contamination is a 

22 source of contamination to the bedrock, to the 

23 surface water, to the sediments. We've seen impacts 

24 in local water supplies historically. We know•the 

25 contamination is there and we can get to it and 

-ALLEY Sc MORRISETTE REPORTING SERVICE 626-0059 
23 

1 there's no one else available to do so. 

2 We are also letting the public know that there 

3 is likely to be impacts to wetlands and floodplains. 

4 There are wetlands along Mill Pond. Some impact 

5 _ would occur especially if we install a diversion to 

6 the river. There's likely to be some destroyed 

7 wetlands that we would have to compensate or recreate 

8 in that area. The Mill itself is located in a 

9 floodplain. There would be some impact, although we 

10 would very likely improve the floodplain 

11 characteristics as a result of our work. There is no 

12 practicable alternative to the work we're going to do 

13 and the proposed cleanup actually gives us the most 

14 flexibility in protecting these resources. 

15 The potential local impacts is that you have to 

16 realize that the excavation will release some 

17 quantity of contamination into the atmosphere. We 

18 will monitor the air, we will control our excavations 

19 to make sure that there is not a threat to public 

20 health, but there will likely be odors and there's 

21 nothing we can do about that. If you excavate 30,000 

22 yards of contaminated soil, there's going to be some 

23 level of volatilization of that soil, but we are 

24 going to try to make sure that we minimize any '. 

2 5 release to the environment through our construction 

ALLEY Sc MORRISETTE REPORTING SERVICE 626-0059 
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1 practices. Traffic flow will be disrupted by the 

2 cleanup activities. You know, it's going to be a lot 

3 more difficult getting through downtown for a period 

4 of time. There's nothing we can do about that. 

5 River diversion may require access or it will require 

6 access to several private properties, maybe long-term 

7 access if the diversion has to go through certain 

8 properties. 

9 As I've mentioned, some of the activities we're 

10 going to do to address these impacts is we're going 

11 to cover our excavated soil as quickly as possible, 

12 we're going to design our treatment system and our 

13 excavation to minimize the release of contaminants 

14 and certainly our.treatment system will not allow for 

15 the release of any contamination above health levels. 

16 We're going to work very closely with DOT, the Town 

17 of Corinna and all of our other stake holders to man 

18 traffic and to make sure the right bridge design and 

19 location takes place. We're going to optimize 

2 0 surface water management so that we create the least 

21 impact on the total flow through for the Sebasticook 

22 and of course we're going to work closely with the 

2 3 property owners. 

24 That summarizes what the proposal is and 

25 why we think we need to do it. I have a few slides 

ALLEY Sc MORRISETTE REPORTING SERVICE 626-0059 
25 

1 here that I just want to refocus the main reason why 

2 we're here tonight. Now, this is part of the public 

3 comment period. It's going to run from May 28 to 

4 June 28. We are seeking your comment, essentially 

5 whatever you'd like to comment on, but very 

6 specifically on the engineering evaluation cost 

7 analysis as part of the administrative record and you 

8 are free to comment on anything that's in the 

9 administrative record including the facts sheet. All 

10 of the documents that you may want to review are at 

11 the Corinna Library or actually the Town Hall or at 

12 the EPA Record Center in Boston, Mass. If you wish 

13 , to submit written comments, they must be postmarked 

14 by June 28. If you would like to present an oral 

15 comment to speak your comment to the record, that's 

16 what tonight is for. We're going to give you that 

17 opportunity shortly. 

18 All comments spoken tonight during the open 

19 session will be made an official part of the record. 

20 This is your chance to be heard. Your written 

21 comments and your oral comments are all that EPA has 

22 to judge whether or not the community is either in 

23 favor or not supportive of the action we're proposing 

24 and what type of activities you are most concerned 

25 about for our design implementation. So please take 

ALLEY Sc MORRISETTE REPORTING SERVICE 626-0059 
26 

1 advantage of that. And I once again want to refocuss 

2 that we are looking for your comments on what you 

3 think we should --we need to take this action, 

4 whether you think the EE/CA is appropriate in 

5 identifying alternatives in supporting what we're 

6 doing, whether you agree with the cleanup levels 

7 we've specified. 

8 I want to close tonight by just reiterating a 

9 few basic points, that EPA has completed sufficient 

10 work to'identify the need for an early response 

11 • action at the site, that EPA is proposing to excavate 

12 the contaminated soils and treat the soils with a 

13 thermal desorption technology, that the collected 

14 vapors will be destroyed using a combustion unit, the 

15 EPA will monitor the air to protect local residents, 

16 that any impacts to wetlands and floodplains are 

17 unavoidable, that the river and road diversion are 

18 necessary to implement the cleanup action and that we 

19 really seek your support and ask that you review the 

20 fact sheet and EE/CA and any other documents that you 

21 would like to so that you can be informed about our 

22 action. 

23 With that, I want to really thank you for coming 

24 out tonight and I want to turn over the hearing to 

25 Mary Jane O'Donnell to open the comment session. And 

ALLEY Sc MORRISETTE REPORTING SERVICE 626-0059 
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1 ' I just want to -- I know Mary Jane will say this, but 

2 this is sort of an awkward part of most of our 

3 meetings, but for the next few minutes or tens of 

4 minutes, we are not going to respond to any of your 

5 comments. It's a hearing, which means we're going to 

6 ask you to speak your comments into the record, we'll 

7 listen to them, but the purpose is to actually get 

8 them recorded. When the hearing is completed and we 

9 close the hearing, if you have any questions, I'll be 

10 glad to answer them both in general or one on one, 

11 but just so that you don't misunderstand, for the 

12 next period of time, we will not respond to anything 

13 you say. 

14 MS. O'DONNELL: Thanks, Ed. Just to 

15 provide some organization, hopefully there won't be 

16 any chaos. What I would like to do in terms of if 

17 any folks have comments, what I was going to do was 

18 have State folks go first. Congressional folks, if 

19 there are any in the audience, local elected 

20 officials and then open the floor to anyone else in 

21 the audience that might like to come forward and make 

22 a comment. I'd ask those folks that would have a 

23 comment to come forward, come to the podium, identify 

24 themselves and identify their association with the 

25 site. As Ed said, we won't be getting into a 

ALLEY Sc MORRISETTE REPORTING SERVICE 626-0059 
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1 dialogue with you folks at this point, however, once 

2 we have received all the comments tonight, I'll close 

3 the meeting and then we'll open the floor to any 

4 comments that you folks might have. So with that as 

5 background, I guess we'll start off with State 

6 Officials. Is there any one here from the State of 

7 Maine that would like to make some formal comment for 

8 the record? 

9 KATHY NIZIOLEK: My name is Kathy Niziolek, 

10 and I'm a representative of the site for the Maine 

11 Department of Environmental Protection. I'm 

12 presenting testimony on behalf of Martha G. 

13 Kirkpatrick, Commissioner of the Maine Department of 

14 Environmental Protection concerning the U.S. EPA's 

15 proposed plan for non-time critical removal action at 

16 the Eastland Woolen Mill proposed Superfund site. 

17 The Maine Department of Environmental Protection 

18 has reviewed the final engineering evaluation cost 

19 analysis document and the proposed cleanup plan for 

20 the Eastland Woolen Mill site and offers the 

21 following comment on the U.S. EPA's proposed cleanup 

22 plan for non-time critical removal action. The 

23 proposed cleanup plan consists of removing the source 

24 of contamination in soils, thereby reducing the 

25 amount of contamination that has migrated into the 

ALLEY Sc MORRISETTE REPORTING SERVICE 626-0059 
29 

1 groundwater and into the East Branch of the 

2 Sebasticook River. The Maine Department of 

3 Environmental Protection concurs with the proposed 

4 method for removal of contamination in soils, 

5 referred to as Alternative 2, excavation and on-site 

6 thermal treatment. Alternative 2 is excavation and 

7 on-site treatment of contaminated soils that present 

8 a threat to the human health and the environment, 

9 that is soils contaminated with chlorobenzenes. As 

10 presented, the Maine Department of Environmental 

11 Protection understands that Alternative 2 will 

12 consist of the following: 

13 Number 1, site clearing, sampling and 

14 contamination delineation which includes establishing 

15 a site office and on-site mobile laboratory; they'll 

16 stabilize the site to minimize any soil erosion into 

17 the East Branch of the Sebasticook River; they'll 

18 remove portions of the former Eastland Woolen Mills 

19 building to allow acce'ss to the soil contamination 

2 0 and to provide space for the cleanup operation; 

21 they'll perform soil sampling to determine the limit 

22 of excavation areas and to confirm that the soils 

23 remaining after excavation are below the cleanup 

24 levels; they'll temporary relocate other buildings 

25 and structures in the area as needed and establish 

ALLEY Sc MORRISETTE REPORTING SERVICE 62 6-005 9 
30 

1 traffic controls and air monitoring programs. 

2 Number 2, they'll remove soils that present the 

3 highest risk to the human health and to the 

4 environment which include to excavate soils 

5 contaminated with levels of chlorobenzenes that 

6 present a significant threat to human health as 

7 defined by the cleanup level; they'll treat those 

8 excavated soils to acceptable levels and place the 

9 treated soil back into, the ground. The soil will be 

10 treated by using a technology t:hat uses heat to drive 

11 the contamination out of the soil as a vapor and the 

12 vapor in turn may be treated using activated carbon 

13 drums or by using a technology that destroys the 

14 chemical with high temperature flame or heating 

15 elements. They will then conduct air monitoring to 

16 ensure that the surrounding neighborhood is not 

17 exposed to unacceptable levels of contaminants during 

18 the cleanup. 

19 Number 3, other required activities which 

2 0 include removal of the bridge on Main Street and 

21 installation of a temporary bridge in a nearby 

22 location to allow for excavation in the river; the 

23 temporary relocation of at least one building on Main 

24 Street to allow for excavation downriver beyond the 

25 bridge; will divert and manage water flow in the East 

ALLEY Sc MORRISETTE REPORTING SERVICE 626-0059 
31 

1 Branch of the Sebasticook River to allow for 

2 excavation beneath the riverbed by relocation of a 

3 420-foot reach of the River or routing through a 

4 culvert. They will stabilize or remove the dam that 

5 is located under the former Woolen Mill. And they 

6 will treat to safe levels and dispose of any water 

7 drained from excavated contaminated soils or 

8 withdrawn from the ground. The treated water will 

9 either be discharged into the Corinna sewer and POTW 

10 or re-injected into the ground. 

11 Additionally, the Maine Department of 

12 Environmental Protection understands that Alternative 

13 2 will comply with Federal and State Applicable or 

14 Relevant and Appropriate Requirements commonly known 

15 as ARARs. Any institutional controls pertaining to 

16 the future use of'the site will be defined when the 

17 record of decision is issued for this site. 

18 The Department has been concerned and actively 

19 worked on the site for a number of years. When the 

20 Mill closed in 1996, the Department assumed the 

21 financial obligations of the Corinna Water District 

22 and the residential water quality monitoring so that 

23 residents affected by groundwater contamination could 

24 continue to receive clean drinking water. In 1997 

25 and 1998, DEP conducted the field work in the East 

ALLEY Sc MORRISETTE REPORTING SERVICE 626-0059 
32 

1 Branch of the Sebasticook River that confirmed 

2 chlorobenzene contamination in the riverbed and in 

3 the soils on the Mill site. In addition, because of 

4 fire and security concerns expressed by Corinna's 

5 selectmen, the Department removed and properly 

6 disposed of nearly 55,000 pounds of hazardous7 materials from the Mill building in 1997. 

8 The magnitude of the contamination and the 

9 potential costs of the cleanup led Governor King to 

10 request that the U.S. EPA list the Eastland Woolen 

11 Mill on the National Priorities List or NPL in May of 

12 1998. The Department is pleased to see that this 

13 project is moving rapidly forward and will continue 

14 to work cooperatively with EPA and with the community 

15 as this cleanup occurs. Thank you. 

16 MS. O'DONNELL: Thank you, Kathy. ' Is there 

17 anyone else from the State of Maine that would like 

18 to make a comment? (No response.) Is there anyone 

19 from a Congressional Delegation that would like to 

20 make a comment? (No response.) Okay. Local 

21 Officials? 

22 STEVEN BUCK: My name is Steven Buck. I 

23 serve on the Board of Selectmen here for the Town of 

24 Corinna. As a selectman in Town, I'd like to 

25 reiterate to the community our overall support of the 

ALLEY S. MORRISETTE REPORTING SERVICE 626-0059 
33 

1 Non-Time Critical Remediations Act in this early 

2 EE/CA proposed design. 

3 The community as a whole has been through an 

4 evolutionary process whereby we have examined all 

5 alternatives as to what would produce a cleanup of 

6 the facility. We have gone through the ground field 

7 application; we have worked cooperatively with DEP 

8 and realize that due to the enormity and scope df the 

9 project it was beyond the Town's capabilities, beyond 

10 the State's capabilities to handle this project. And 

11 immediately upon entering into conversations with 

12 EPA, I would like to express the Town's favorable 

13 response to EPA's open and dialogue with the 

14 community and their ability to address our concerns 

15 as needed. 

16 Consecutively, the Town has been working on a 

17 comprehensive plan and a revitalization vision as to 

18 what will take place within the community after the 

19 cleanup has taken place and I feel strongly that the 

2 0 proposed actions to date by EPA is wholly in support 

21 of the vision that I see developing by the community. 

22 Therefore, I would like to again express my support 

23 as a selectman for this project. 

24 MS. O'DONNELL: Thank you, Steven. Is 

25 there anyone else, any other elected official that 

ALLEY Sc MORRISETTE REPORTING SERVICE 626-0059 
34 

1 would like to make a comment? 

2 DOUG TIBBETTS: Doug Tibbetts, selectman. 

3 I would just like to briefly say that -- to say that 

4 I am pleased with the timeliness of the EPA's action 

5 would be an understatement. They have been 

6 absolutely unbelievable in my opinion and I hope that 

7 we can all work together in the future. There are 

8 going to be a lot of inconveniences, but I hope that 

9 we all will have the tolerance to get through this. 

10 There is no question in my mind that this is a 

11 warranted project and that we are very fortunate to 

12 have received the level of attention that we have. 

13 Thank you. 

14 MS. 0'DONNELL: Thanks, Doug. Any other 

15 elected official that would like to make a comment? 

16 (No response.) Okay. I'll start with this side bf 

17 the room and then go to this side. Anyone bn this 

18 side of the room that would like to make a comment? 

19 KEN DOW: My name is Ken Dow. I'm a 

20 life-long resident of Corinna. I'm sure it's a vast 

21 understatement to say this Town is never going to 

22 look the same again, but I also am thoroughly 

23 convinced by the materials that have been presented 

4 by the EPA's proposed action is appropriate and 

25 absolutely necessary. 

ALLEY & MORRISETTE REPORTING SERVICE 626-0059 

n 
35 

1 MS. O'DONNELL: Thanks, Ken. And hopefully 

2 I won't trip on this wire before the night is over. 

3 Anyone else on this side of the room that would like 

4 to make a comment? 

5 LINDA SMITH: My name is Linda Smith and 

6 I'm chairperson of the Downtown Revitalization 

7 Committee. And in 1996, when the Mill closed, we all 

8 asked ourselves, where do we go from here. And Steve 

9 Buck has told you exactly what I was going to say, 

10 but I also want to say that we have had overwhelming 

11 support from the community for this cleanup and I 

12 couldn't be more pleased with everyone that has 

13 turned out for the meetings that we have held and I 

14 am totally in support of this project. 

15 MS. O'DONNELL: Thanks, Linda. There's one 

16 other person on this side of the room. 

17 MATT BERNIER: My name is Matt Bernier. 

18 I'm actually a resident of Pittsfield, Maine and I'm 

19 here tonight because I became the President of a new 

20 organization. The Sebasticook River Watershed 

21 Association. I'll just read part of the letter that 

22 I am submitting to the EPA in support of this 

23 cleanup. 

24 I recently became President of the newly formed 

25 organization called the Sebasticook River Watershed 

ALLEY Sc MORRISETTE REPORTING SERVICE 626-0059 
36 

1 Association. This Association, led by 10 other 

2 directors, is in its organizational year and hopes to 

3 begin recruiting members in early 2000. The mission 

4 of the Sebasticook River Watershed Association, the 

5 SRWA, is to protect, restore and inspire stewardship 

6 of the Sebasticook River contributing waters through 

7 community-based education, research and conservation. 

8 I feel privileged as a citizen to write this letter 

9 in support of the proposed cleanup of the Eastland 

10 Woolen Mill site on the East Branch of the 

11 Sebasticook River. The proposed cleanup is 

12 consistent with all aspects of the Sebasticook River 

13 Watershed Association Mission statement. The primary 

14 goals of the cleanup, the removal of hazardous 

15 substances from sediments and soils and aquifers 

16 adjacent to the River will serve as protection 

17 against additional contamination of the River and 

18 groundwater. The contamination of drinking water 

19 within the Town of Corinna is a tragedy. Anyone, 

20 . including myself, who relies on a private well for 

21 drinking water empathizes with those who have lost 

22 this precious resource. Thank you for offering them 

2 3 hope. 

24 In addition to the restoration of the aquifer, 

25 I'm very excited about the restoration potential for 

ALLEY Sc MORRISETTE REPORTING SERVICE 626-0059 
37 

1 the East Branch of the Sebasticook River. As a 

2 fellow board member pointed out, the portion of the 

3 River in the vicinity of the Mill is biologically 

4 dead. The removal of the contamination will allow 

5 the mackerel and vertebrate fish communities and 

6 bring back the River that Corinna deserves. Just as 

7 the Sebasticook River was the inspiration for 

8 Corinna's settlement, the cleanup will be an 

9 inspiration for stewardship of the rest of the 

10 Sebasticook River Watershed which includes nearly 40 

11 other towns. The entire watershed community is 

12 pulling for Corinna. 

13 MS'. O'DONNELL: Thank you, Matt. Anyone 

14 else on this side of the room that would like to make 

15 a comment? (No response.) Moving to this side, 

16 anyone else who would like to make a comment. (No 

17 response.) Seeing that there aren't any, the formal 

18 part of the meeting is closed. The transcription of 

19 this meeting will now stop. 

20 (Hearing concluded at 7:53 p.m.) 

21 

22 • 

23 

24 

25 

ALLEY Sc MORRISETTE REPORTING SERVICE 626-0059 
38 

1 

2 

3 

4 

5 

6 

7 

8 

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13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

CERTIFICATE 

I, Robin J. Dostie, a Notary Public in and 

for the State of Maine, hereby certify that the 

within-named deponent was sworn to testify the truth, 

the whole truth, and nothing but the truth, in the 

aforementioned cause of action. 

I further certify that this deposition was 

stenographically reported by me and later reduced to 

print through Computer-Aided Transcription, and the 

foregoing is a full and true record of the testimony 

given by the deponent. 

I further certify that I am a disinterested 

person in the event or outcome of the above-named 

cause of action. 

IN WITNESS WHEREOF I subscribe my hand and 

affix my seal this 25th day of June, 1999. Dated at 

Augusta, Maine. 

-

My Commission Expires 

February 6, 2 0 05 

J ^ . C\ •-'T^Y^^-nh^,'^' ^ 

Notary 

k/Uu^ 

Public 

i)^-

UP.. 

ALLEY Sc MORRISETTE REPORTING SERVICE 626-0059 
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE 

ATTACHMENT 8 

ADMINISTRATIVE RECORD INDEX 
Eastland Woolen Mill 

Superfund Site 

Administrative Record 

for the Non-Time Critical Removal Action 

Index 

Compiled: May 27, 1999 

Action Memorandum Issued: July xx, 1999 

Prepared by 

EPA New England 

Office of Site Remediation & Restoration 
INTRODUCTION 

This is the Index to the Administrative Record compiled in connection with the Non-Time 

Critical Removal Action at the former Eastland Woolen Mill Superfund Site. The Index cites sitespecific documents used by Environmental Protection Agency (EPA) staff in selecting the response 

action. The documents in the Administrative Record are arranged in order ofthe Document Number 

included at the end of each citation in the Index. 

The Administrative Record for the Eastland Woolen Mill Superfund site is available for 

public review at the EPA Region I Superfund Records Center, One Congress Street, Suite 1100, 

Boston, MA, 02114 [(617) 918-1258], and the Corinna Public Library, Corinna, ME. The staff of 

the Superfiind Records Center recommends that you set up an appointment prior to your visit. 

The EPA guidance documents listed at the end ofthe Index are also available for review only 

at the Superfund Records Center. Documents cited with the notation, [Confidential], are stored at 

the Superfund Records Center but are available for judicial review only. 

Questions conceming the Administrative Record should be addressed to the EPA project 

manager for the Eastland Woolen Mill Superfund Site. 

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). 
ADMINISTRATIVE RECORD INDEX 

EASTLAND WOOLEN MILL FACILIT Y 

Q1I/2Q/99 

Page 1 

01.06 SITE ASSESSMENT HAZARD RANKING SYSTEM PACKAGES 

Title: Hazard Ranking System Package, Eastland Woolen 

Mill, Corinna, Maine. 

Authors: US EPA REGION 1 

Date: April 9, 1999 

Format: REPORT, STUDY No. Pgs: 14 8 

AR No. 01.06.1 Document No. 000025 

02.01 REMOVAL RESPONSE CORRESPONDENCE 

Title: 

Addressee: 

Authors: 

Date: 

Format: 

AR No. 

Corinna's New Beginning Meeting. 

JEAN FIRTH -

STEVEN BUCK - TOWN OF CORINNA 

November 9, 1998 

MEMORANDUM No. Pgs: 1 

02.01.1 Document No. 000001 

02.02 REMOVAL RESPONSE - REMOVAL RESPONSE REPORTS 

Title: 

Addressee 

Authors: 

Date : 

Format: 

AR No. 

Approval Memorandum to Perform Two Engineering 

Evaluation/Cost Analyses for a Non-Time Critical 

Removal Action. 

PATRICIA MEANEY - US EPA REGION 1 

ED HATHAWAY - US EPA REGION 1 

January 2 9, 199 9 

MEMORANDUM No. Pgs: 19 

02.02.1 Document No. 000006 

Title: 

Addressee 

Authors: 

Date : 

Format: 

AR No. 

Eastland Woolen Mill Site Approval Memo, 

Attachment E, Enforcement Addendum 

[Confidential]. 

PATRICIA MEANEY - US EPA REGION 1 

US EPA REGION 1 

January 29, 1999 

MEMORANDUM No. Pgs: 2 

02.02.2 Document No. 00000 7 
ADMINISTRATIVE RECORD INDEX 

EASTLAND WOOLEN MILL FACILITY 

07/20/99 

Page 2 

Title: Final Site Summary Report, Eastland Woolen Mill 

Site, Corinna, Maine. 

Authors: US ARMY CORPS OF ENGINEERS 

Date: March 1999 

Format: REPORT, STUDY No. Pgs: 10 9 

AR No. 02.02.3 Document No. 000002 

Title: 

Addressee: 

Date: 

Format: 

AR No. 

Comments on Draft Engineering Evaluation/Cost 

Analysis. 

US EPA REGION 1 

March 1999 

MEMORANDUM No. Pgs: 6 

02.02.4 Document No. 000003 

Title: 

Addressee: 

Authors: 

Date : 

Format: 

AR No. 

Comments Regarding March 1999 Draft EE/CA for 

Eastland Woolen Mill, Corinna, Maine. 

ED HATHAWAY - US EPA REGION 1 

KATHY NIZIOLEK -

April 16, 1999 

LETTER No. Pgs: 1 

02.02.5 Document No. 000004 

Title: 

Addressee 

Authors: 

Date: 

Format: 

AR No. 

Eastland Woolen Mill Superfund Site, Draft EE/CA 

Comments - State ARARs. 

KATHY NIZIOLEK -

CATHERINE GARYPIE - US EPA REGION 1 

April 30, 1999 

LETTER No. Pgs: 4 

02.02.6 Document No, 000005 

Title: Final Engineering Evaluation/Cost Analysis, 

Eastland Woolen Mill Site, Corinna, Maine. 

Authors: US ARMY CORPS OF ENGINEERS 

Date: May 20, 1999 

Format: REPORT, STUDY No. Pgs: 342 

AR No. 02.02.7 Document No. 000028 
ADMINISTRATIVE RECORD INDEX 

EASTLAND WOOLEN MILL FACILITY 

07/20/99 

Page 3 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: VIRGINIA LISTER 

Date: May 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.8 Document No. 000039 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: SUSAN M. COLLINS - UNITED STATES SENATE 

Date: May 27, 1999 

Format: LETTER No. Pgs: 1 

AR No. 02.02.9 Document No. 000040 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: CARL D. SMITH 

Date: May 30, 1999 

Format: MEMORANDUM No. Pgs: 1 

AR No. 02.02.10 Document No. 000041 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: ROBERT PEARSON 

Date: June 1, 199 9 

Format: LETTER No. Pgs: 3 

AR No. 02.02.11 Document No. 000042 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: LINDA E. SMITH 

Date: June 3, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.12 Document No. 000043 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: VIVIAN H. DAVIS 

Date: June 10, 1999 

Format: LETTER No. Pgs: 3 

AR No. 02.02.13 Document No. 000044 
ADMINISTRATIVE RECORD INDEX 

EASTLAND WOOLEN MILL FACILITY 

07/20/99 

Page 4 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: THOMAS A. MORRISON - MAINE DEPT OF CONSERVATION 

Date: June 16, 1999 

Format: LETTER No. Pgs: 4 

AR No. 02.02.14 Document No. 000045 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: JOHN G. MELROSE - MAINE DEPT OF TRANSPORTATION 

Date: June 16, 199 9 

Format: LETTER No. Pgs: 2 

AR No. 02.02.15 Document No. 000048 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: LYNN CIANCHETTE 

Date: June 17, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.16 Document No. 000046 

Title: 

Addressee: 

Authors: 

Date: 

Format: 

AR No. 

Comments on Proposed Plan. 

ED HATHAWAY - US EPA REGION 1 

MARTHA G. KIRKPATRICK - MAINE DEPT OF 

ENVIRONMENTAL PROTECTION 

June 22, 1999 

LETTER No. Pgs: 2 

02.02.17 Document No. 000047 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: PAMELA D. BUCK - TOWN OF CORINNA 

Date: June 23, 1999 

Format: LETTER No. Pgs: 1 

AR No. 02.02.18 Document No. 000049 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: DARRELL L. 'HARTNEY - TOWN OF CORINNA 

Date: June 2 3, 1999 

Format: LETTER No. Pgs: 1 

AR No. 0 2.02.19 Document No. 000050 
ADMINISTRATIVE RECORD INDEX 

EASTLAND WOOLEN MILL FACILITY 

07/20/99 

Page 5 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: MATT BERNIER - SEBASTICOOK RIVER WATERSHED 

ASSOCIATION 

Date: June 24, 1999 

Format: LETTER No. Pgs: 4 

AR No. 02.02.20 Document No. 000051 

Title: Comments on Proposed. Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: DORA LITTLEFIELD 

Date: June 24, 1999 

Format: LETTER No. Pgs: 3 

AR No. 02.02.21 Document No. 000052 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: DORA LITTLEFIELD 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.22 Document No, 000053 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: MIRIAM H. KING 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.23 Document No, 000054 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: ROBERT F. ANDERSON 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.24 Document No. 000055 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: RALPH A. EMERY 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 0 2.02.25- Document No. 000056 
ADMINISTRATIVE RECORD INDEX 

EASTLAND WOOLEN MILL FACILITY 

07/20/99 

Page 6 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: ANNA M. AMSDEN 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.2 6 Document No, 000057 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: BEULAH KNOWLES 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.27 Document No 000058 

Title: Comments on Proposed Plan.. 

Addressee: ED HATHAWAY - US EPA-REGION 1 

Authors: JOHN H. WILSON 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.2 8 Document No. 000059 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: DARLENE L. SHARPE 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.29 Document No. 000060 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: lONE WILSON 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.3 0 Document No. 000061 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: JEAN LITTLEFIELD 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.31 Document No. 000062 
ADMINISTRATIVE RECORD INDEX 

EASTLAND WOOLEN MILL FACILITY 

0l/2Q)/9 9 

Page 7 

Title: 

Addressee 

Authors: 

Date: 

Format: 

AR No. 

Comments on Proposed Plan. 

ED HATHAWAY - US EPA REGION 1 

JUDITH M. HARTLEY 

June 24, 1999 

LETTER No. Pgs: 2 

02.02.3 2 Document No. 000063 

Title: 

Addressee 

Authors: 

Date: 

Format: 

AR No. 

Comments on Proposed Plan. 

ED HATHAWAY - US EPA REGION 1 

SHARON BLACK 

June 24, 1999 

LETTER No. Pgs: 2 

02.02.3 3 Document No. 000064 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: RONALD CORZINE 

Date: June 24, 1999 

Format: LETTER , No. Pgs: 2 

AR No. 02.02.34 Document No. 000065 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: STEVEN BUCK 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.3 5 Document No. 000066 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: DARLENE HARTLEY 

Date: June 24, 1999 

Format: LETTER ' No. Pgs: 2 

AR No. 02.02.3 6 Document No, 000067 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: JUNE JAWORSKI 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.3 7 Document No. 000068 
ADMINISTRATIVE RECORD INDEX 

EASTLAND WOOLEN MILL FACILITY 

07/20/99 

Page 8 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: RITA M. SINCLAIR 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 0 2.02.38 Document No. 000069 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: PAMELA D. BUCK 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.3 9 Document No. 000070 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: STEPHEN LAWSON 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.40 Document No. 000071 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: KEN GILMORE 

Date: June 24, 1999 

Format: LETTER - . No. Pgs: 2 

AR No. 02.02.41 Document No. 000072 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: MARIE E. GALLISON 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.42 Document No. 000073 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: DAVID L. SHARPE 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.43 Document No, 000074 
ADMINISTRATIVE RECORD INDEX 

EASTLAND WOOLEN MILL FACILITY 

07/20/99 

Page 9 

Title: 

Addressee: 

Authors: 

Date : 

Format: 

AR No. 

Comments on Proposed Plan. 

ED HATHAWAY - US EPA REGION 1 

MATTIE WOODBURY 

June 24, 1999 

LETTER No. Pgs : 2 

02.02.44 Document No, 000075 

Title: 

Addressee; 

Authors: 

Date: 

Format: 

AR No. 

Comments on Proposed Plan. 

ED HATHAWAY - US EPA REGION 1 

ROGER SIMPSON 

June 24, 1999 

LETTER No. Pgs: 2 

02.02.45 Document No, 000076 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: RONALD SIMPSON 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 0 2.02.46 Document No. 000077 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA, REGION 1 

Authors: FRED D. ANNIS 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.47 Document No. 000078 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: CAROLINE E. ANNIS 

Date: June 24, 1999 

Format: LETTER No .• Pgs: 2 

AR No. 02.02.48 Document No. 000079 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: JAMES P. EMERSON 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.4 9 Document No, 000080 
ADMINISTRATIVE RECORD INDEX 

EASTLAND WOOLEN MILL FACILITY 

07/20/99 

Page 10 

Title: - Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: THOMAS W. CLARK 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.50 Document No, 000081 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: RICHARD E. SEAMANS 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.51 Document No. 000082 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: CARL E. THURLOW 

Date: June 24, 1999 

Format:. LETTER No. Pgs: 2 

AR No. 02.02.52 Document No 000083 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: FRED COOLEY 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.53 Document No. 000084 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: HEIDI LAWSON 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.54 Document No. 000085 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: CAROL L. SMITH ^ 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 0 2.02.55 Document No, 000086 
ADMINISTRATIVE RECORD INDEX 

EASTLAND WOOLEN MILL FACILITY 

01/20/9 9 

Page 11 

Title: 

Addressee; 

Authors: 

Date: 

Format: 

AR No. 

Comments on Proposed Plan. 

ED HATHAWAY - US EPA REGION 1 

JOHN A. SOMES 

June 24, 1999 

LETTER No. Pgs: 2 

02.02.56 Document No. 000087 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: BARRY H. STANKEVITZ 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.57 Document No. 000088 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: GALEN P. MCKENNEY 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.58 Document No. 000089 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: THOMAS N. LLOYD 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.59 Document No. 000090 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: ROBERT A. BERG 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.60 Document No. 000091 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: RICHARD D. CULLEN 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.61 Document No. 000092 
ADMINISTRATIVE RECORD INDEX 

EASTLAND WOOLEN MILL FACILITY 

07/20/99 

Page 12 

Title: 

Addressee: 

Authors: 

Date: 

Format: 

AR No. 

Comments on Proposed Plan. 

ED HATHAWAY - US EPA REGION 

CARL D. SMITH 

June 24, 1999 

LETTER 

02.02.62 

No. Pgs: 2 

Document No. 000093 

Title: 

Addressee 

Authors: 

Date: 

Format: 

AR No. 

Comments on Proposed Plan. 

ED HATHAWAY - US EPA REGION 1 

JAMES A. LOUDEN 

June 24, 1999 

LETTER No. Pgs: 2 

02.02.63 Document No. 000094 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: ALLAN REED 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.64 Document No 000095 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY- US EPA REGION 1 

Authors: GEORGE A. CRAST 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.65 Document No, 000096 

Title: 

Addressee 

Authors: 

Date: 

Format: 

AR No. 

Comments on Proposed Plan. 

ED HATHAWAY - US EPA REGION 1 

TOM CAVANAUGH 

June 24, 1999 

LETTER No. Pgs: 2 

02.02.66 Document No. 000097 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: CHARLES A. DIMOPOULOS 

Date: June 24, 1999 • 

Format: LETTER No. Pgs: 2 

AR No. 02.02.67 Document No, 000098 
ADMINISTRATIVE RECORD INDEX 

EASTLAND WOOLEN MILL FACILITY 

07/20/99 

Page 13 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: GLENN M. CHARLES 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.68 Document No. 000099 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: LLOYD ALDEN BOLSTIDGE, JR. 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.69 Document No. 000100 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: LINDA POULIN 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.7 0 Document No. 000101 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: BARBARA & WILL SHANA 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.71 Document No, 000102 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: ELIZABETH GUDROE 

Date: June 24, 1999 

Format: LETTER No. Pgs:' 2 

AR No. 02.02.72 Document No, 000103 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: PAUL R. PIPIN 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.73 Document No, 000104 
ADMINISTRATIVE RECORD INDEX 

EASTLAND WOOLEN MILL FACILITY 

07/20/99 

Page 14 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: GARY CUNNINGHAM 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.74 Document No. 000105 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1. 

Authors: PAUL SHORTTALL 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.75 Document No. 000106 

Title: 

Addressee 

Authors• 

Date : 

Format: 

AR No. 

Comments on Proposed Plan. 

ED HATHAWAY - US EPA REGION 1 

WILLIAM DOHERTY 

June 24, 1999 

LETTER No. Pgs: 2 

02.02.76 Document No. 000107 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: LARRY R. LARRABEE 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.77 Document No. 000108 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: ROBERT M. FADER 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.78 Document No. 000109 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: WANDA BUTLER 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.79 Document No. 000110 
ADMINISTRATIVE RECORD INDEX 

EASTLAND WOOLEN MILL FACILITY 

07/20/99 

Page 15 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: KIMBERLY CARSON 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.80 Document No. 000111 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US.EPA REGION 1 

Authors: BRUCE D. FOWLE' 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.81 Document No. 000112 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: KENNETH A. KING 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. . 02.02.82 Document No. 000113 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: ROGER A. WHITNEY 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.83 Document No. 000114 

Title: Comments on Proposed Plan. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: FRED HARRIS 

Date: June 24, 1999 

Format: LETTER No. Pgs: 2 

AR No. 02.02.84 Document No. 000115 

Title: Comments on Proposed Plan. 

Addressee: ERIN HESKETT - US EPA REGION 1 

Authors: KEN DOW 

Date: June 25, 1999 

Format: MEMORANDUM No. Pgs: 1 

AR No. 02.02.85 Document No, 000116 
ADMINISTRATIVE RECORD INDEX 

EASTLAND WOOLEN MILL FACILITY 

07/20/99 

Page 16 

Title: 

Addressee; 

Authors: 

Date: 

Format: 

AR No. 

Comments on Proposed Plan. 

ED HATHAWAY - US EPA REGION 1 

SUSAN M. COLLINS - UNITED STATES SENATE 

June 25, 1999 

LETTER No. Pgs: 1 

02.02.86 Document No. 000129 

Title: 

Addressee 

Authors: 

Date: 

Format: 

AR No. 

Comments on Proposed Plan. 

ED HATHAWAY - US EPA REGION 1 

JUDITH DOORE - TOWN OF CORINNA 

June 28, 1999 

LETTER' NO. Pgs: 2 

02.02.87 Document No. 000117 

Title: 

Addressee 

Authors: 

Date: 

Format: 

AR No. 

Comments on Proposed Plan. 

ED HATHAWAY - US EPA REGION 1 

EVERETT E. SIMPSON 

June 28, 1999 

LETTER ' No. 

02 .02 .8! 

Pgs 

Document No. 000118 

Title: 

Addressee 

Authors: 

Date: 

Format: 

AR No. 

Comments on Proposed Plan. 

ED HATHAWAY - US EPA REGION 1 

JAMES M'. SMALL - PEOPLES HERITAGE BANK 

June 28, 1999 

LETTER No. Pgs: 1 

02.02.89 Document No, 000119 

Title: 

Addressee; 

Authors: 

Date: 

Format: 

AR No. 

Comments on Proposed Plan. 

ED HATHAWAY - US EPA REGION 1 

OLYMPIA J. SNOWE - UNITED STATES SENATE 

June 28, 1999 

LETTER No. Pgs: 1 

02.02.90 Document No. 000120 

Title: 

Addressee 

Authors: 

Date: 

Format: 

AR No. 

Comments on Proposed Plan. 

ED HATHAWAY - US EPA REGION 1 

PATTY K. HILL 

June 29, 1999 

LETTER No. Pgs: 2 

02.02.91 Document No. 000130 
ADMINISTRATIVE RECORD INDEX 

EASTLAND WOOLEN MILL FACILITY 

07/20/99 

Page 17 

02.09 REMOVAL RESPONSE ACTION MEMORANDA 

Title: Action Memorandum. 

Authors: ED HATHAWAY - US EPA REGION 

Date: 1999 

Format: MEMORANDUM 

AR No. 02.09.1 Document No. 000131 

09.01 STATE COORDINATION CORRESPONDENCE 

Title 

Addressee 

Authors: 

Date : 

Format: 

AR No. 

Summary of Needed Cleanup Activites at Various 

Portions of the Eastland Woolen Mill Superfund 

Site. 

ED HATHAWAY - US EPA REGION 1 

KATHY.NIZIOLEK -

February 19, 19 98 

MEMORANDUM • No. Pgs: 8 

0 9.01.1 Document No. 000009 

Title: 

Addressee 

Authors: 

Date: 

Format: 

AR No. 

Issues that EPA Wants to Raise at the Next 

EPA/MADE P Management Review Meeting for the 

Eastland Woolen Mill Superfund Site. 

•MARK HYLAND -

DONALD BERGER - US EPA REGION 1 

March 12, 1999 

LETTER No. Pgs: 3 

09.01.2 Document No. 000010 

Title: 

Addressee 

Authors: 

Date : 

Format: 

AR No. 

Maine's Position on Post-NTCRA Site Control 

Activities at the Eastland Woolen Mill Superfund 

Site. 

DONALD BERGER - US EPA REGION 1 

MARK HYLAND -

April 6, 1999 

LETTER No 

09.01.3 

Pgs: 1 

Document No, 000011 
ADMINISTRATIVE RECORD INDEX 

EASTLAND WOOLEN MILL FACILITY 

07/20/99 

Page 18 

11.09 POTENTIALLY RESPONSIBLE PARTIES - PRP-SPECIFIC DOCUMENTS 

Title 

Addressee 

Authors: 

Date: 

Format: 

AR No. 

Notification to Potentially Interested Party of 

EPA's Forthcoming Proposed Cleanup Plan for the 

Eastland Woolen Mill Superfund Site. 

RALPH BERG 

PATRICIA MEANEY - US EPA REGION 1 

May 21, 1999 

LETTER No. Pgs: 2 

11.09.1 Document No. 000031 

Title 

Addressee 

Authors: 

Date: 

Format: 

AR No. 

Notification to Potentially Interested Party of 

EPA's Forthcoming Proposed Cleanup Plan for the 

Eastland Woolen Mill Superfund Site. 

DAVID Sc JEANNE CARCIERI 

PATRICIA MEANEY - US EPA REGION 1 

May 21, 1999 

LETTER No. Pgs: 2 

11.09.2 Document No. 000032 

Title: 

Addressee 

Authors: 

Date : 

Format: 

AR No. 

Notification to Potentially Interested Party of 

EPA's Forthcoming Proposed Cleanup Plan for the 

Eastland Woolen Mill Superfund Site. 

FINOVA CAPTITAL CORPORATION 

PATRICIA MEANEY - US EPA REGION 1 ' 

May 21, 1999 

LETTER No. Pgs: 2 

11.09.3 Document No, 000033 

Title: 

Addressee 

Authors: 

Date : 

Format: 

AR No. 

Notification to Potentially Interested Party of 

EPA's Forthcoming Proposed Cleanup Plan for the 

Eastland Woolen'Mill Superfund Site. 

CYNTHIA SCARANO - GUIFORD TRANSPORTATION 

PATRICIA MEANEY - US EPA REGION 1 

May 21, 1999 

LETTER No. Pgs: 2 

11.09.4 Document No. 000034 
ADMINISTRATIVE RECORD INDEX 

EASTLAND WOOLEN MILL FACILITY 

07/20/99 

Page 19 

Title 

Addressee 

Authors: 

Date: 

Format: 

AR No. 

Notification to Potentially Interested Party of 

EPA's Forthcoming Proposed Cleanup Plan for the 

Eastland Woolen Mill Superfund Site. 

ALAN STRIAR 

PATRICIA MEANEY - US EPA REGION 1 

May 21, 1999 

LETTER ' No. Pgs: 2 

11.09.5 ' Document No. 000035 

Title: 

Addressee 

Authors: 

Date: 

Format: 

AR No. 

Notification to Potentially Interested Party of 

EPA's Forthcoming Proposed Cleanup Plan for the 

Eastland Woolen Mill Superfund Site. 

STEVEN STRIAR 

PATRICIA MEANEY - US EPA REGION 1 

May 21, 1999 

LETTER No. Pgs:, 2 

11.09.6 Document No. 000036 

13.02 COMMUNITY RELATIONS - COMMUNITY RELATIONS PLANS 

Title: Community Relations Plan, Draft Final, Eastland 

Woolen Mill Site, Corinna, Maine. 

Authors: US EPA REGION 1 

Date: May 1999 

Format: REPORT, STUDY 

AR No. 13.02.1 

No. Pgs: 51 

Document No. 000037 

13.03 COMMUNITY RELATIONS - NEWS CLIPPINGS/PRESS RELEASES 

Title: Corinna Awaits Word on Funding: EPA Team to Tour 

Eastland Once More. 

Authors: LARRY GRARD - WATERVILLE MORNING SENTINEL 

Date: February 23, 1998 

Format: NEWS CLIPPING No. Pgs: 4 

AR No. 13.03.1 Document No. 000014 
ADMINISTRATIVE RECORD INDEX 

EASTLAND WOOLEN MILL FACILITY 

07/20/99 

Page 2 0 

Title: Corinna Panel Poised for Progress. 

Authors: LARRY GRARD - WATERVILLE MORNING SENTINEL 

Date: Noven±)er 24, 1998 

Format: NEWS CLIPPING No. Pgs: 1 

AR No. 13.0 3.2 Document No. 000012 

Title: Townspeople Expect to Learn Extent of Chemical 

Pollution, Cleanup Timetable. 

Authors: MIKE LABERGE - BANGOR DAILY NEWS 

Date: February 18, 1999 

Format: NEWS CLIPPING No. Pgs: 2 

AR No. 13.03.3 Document No. 000013 

Title: Contamination Deep in Corinna. 

Authors: BRENDA SEEKINS - BANGOR DAILY NEWS 

Date: March 5, 1999 

Format: NEWS CLIPPING No. Pgs: 2 

AR No. 13.03.4 Document No 000015 

Title: Corinna Approves Funding. 

Authors: MIKE LANGE - BANGOR DAILY NEWS 

Date: May 26, 1999 

Format: NEWS CLIPPING No. Pgs: 1 

AR No. 13.03.5 Document No. 000127 

Title: Discovery Could DElay Superfund Cleanup. 

Authors: DIANA GRAETTINGER - BANGOR DAILY NEWS 

Date: May 28, 1999 

Format: NEWS CLIPPING No. Pgs: 1 

AR No. 13.03.6 Document No, 000126 

Title: EPA Cleanup to Move Corinna River. 

Authors: BRENDA SEEKINS - BANGOR DAILY NEWS 

Date: May 29, 1999 

Format: NEWS CLIPPING No. Pgs: 1 

AR No. 13.03.7 Document No. 000124 
k. 

ADMINISTRATIVE RECORD INDEX 

EASTLAND WOOLEN MILL FACILITY 

07/20/99 

Page 21 

Title: EPA Cleanup To Move Adults Reach Out. 

Authors: BRENDA SEEKINS - BANGOR DAILY NEWS 

Date: May 29, 1999 

Format: NEWS CLIPPING No. Pgs: 2 

AR No. 13.03.8 Document No. 000128 

Title: EPA Cleanup Plan Sparks Corinna Rehab Vision. 

Authors: BRENDA SEEKINS - BANGOR DAILY NEWS 

Date: June 17, 1999 

Format: NEWS CLIPPING No. Pgs: 1 

AR No. 13.03.9 Document No. 000125 

13.04 COMMUNITY RELATIONS - PUBLIC MEETINGS/HEARINGS 

Title: Eastland Woolen Mill Site Public Information 

Meeting. 

Date: March 4, 1999 

Format: PUBLIC MEETING RECORDS No. Pgs: 54 

AR No. 13.04.1 Document No. 00003 0 

Title: Eastland Woolen Mill Site, River/Bridge 

Stakeholder Meeting. 

Authors: US EPA REGION 1 

Date: April 8, 1999 

Format: PUBLIC MEETING RECORDS No. Pgs: 28 

AR No. 13.04.2 Document No. 000016 

Title: Eastland Woolen Mill Site, Public Information 

Meeting. 

Authors: US EPA REGION 1 

Date: May 27, 1999 

Format: PUBLIC MEETING RECORDS No. Pgs: 58 

AR No. 13.04.3 Document No. 000038 

Title: May 26, 1999 Corinna Coalition Committee Meeting 

Minutes. 

Addressee: ED HATHAWAY - US EPA REGION 1 

Authors: MICHELE GAGNON - EASTERN MAINE DEVELOPMENT 

CORPORATION 

Date: June 2, 1999 

Format: MEMORANDUM No. Pgs: 7 

AR No. 13.04.4 Document No. 000123 
ADMINISTRATIVE RECORD INDEX 

EASTLAND WOOLEN MILL FACILITY 

07/20/99 

Page 22 

Title: Meeting Notice,for Corinna Coalition Committee 

Roundtable Discussion. 

Authors: EASTERN MAINE DEVELOPMENT CORPORATION 

Date: June 16, 1999 

Format: MEMORANDUM No. Pgs: 1 

AR No. 13.04.5. Document No. 000122 

Title: Public Hearing Re: Eastland Woolen Mill Site. 

Authors: ALLEY Sc MORRISETTE REPORTING SERVICE 

Date: June 24, 1999 

Format: PUBLIC MEETING RECORDS No. Pgs: 3 9 

AR No. 13.04.6 Document No. 000121 

13.05 COMMUNITY RELATIONS - FACT SHEETS/INFORMATION UPDATES 

Title: USEPA Launches Investigation Program at Eastland 

Woolen Mill Facility. 

Authors: US EPA REGION 1 

Date: December 1998 

Format: FACT SHEET, PRESS RELEASE No. Pgs: 2 

AR No. 13.05.1 Document No. 000017 

Title: EPA Completes Initial Field Work; Announces 

Upcoming Public Information Meeting. 

Authors: US EPA REGION 1 

Date: February 1999 

Format: FACT SHEET, PRESS RELEASE No. Pgs: 3 

-AR No. 13.05.2 Document No. 000018 

Title: 

Date: 

Format 

AR No. 

EE/CA Fact Sheet: EPA Plans Soil Cleanup (Cross 

Reference to File Break 2.2). 

May 1999 

WORK PLAN No. Pgs: 2 0 

13.05.3 Document No. 000029 
ADMINISTRATIVE RECORD INDEX 

EASTLAND WOOLEN MILL FACILITY 

07/20/99 

Page 2 3 

16.01 NATURAL RESOURCE TRUSTEE CORRESPONDENCE 

Title: Notification of Potential Natural Resource 

Damages. 

Addressee: ANDREW RADDANT - DEPARTMENT OF INTERIOR 

Authors: DONALD BERGER - US EPA REGION 1 

Date: May 18, 1999 

Format: LETTER No. Pgs: 5 

AR No. 16.01.1 Document No. 000026 

Title: Notification of Potential Natural Resource 

Damages. 

Addressee: KENNETH FINKELSTEIN - DEPARTMENT OF COMMERCE-NOAA 

Authors: DONALD BERGER - US EPA REGION 1 

Date: May 18, 1999 

Format: LETTER No. Pgs: 5 

AR No. 16.01.2 Document No. 000027 

17.02 SITE Mi^NAGEMENT RECORDS - ACCESS RECORDS 

Title: 

Addressee: 

Authors: 

Date : 

Format: 

AR No. 

Consent for Access to Property.• 

ED HATHAWAY - US EPA REGION 1 

JUDITH DOORE - TOWN OF CORINNA 

November 30, 1998 

LETTER No. Pgs: 

17.02.1 Document No, 000019 

17.07 SITE MANAGEMENT RECORDS - REFERENCE DOCUMENTS 

Title 

Authors: 

Date : 

Format: 

AR No. 

Canadian Environmental Protection Act, Priority 

Substances List Assessment Report No. 3, 

Chlorobenzene. 

GOVERNMENT OF CANADA 

1992 

REPORT, STUDY No. Pgs: 2 4 

17.07.1 Document No. 000021 
ADMINISTRATIVE RECORD INDEX 

EASTLAND WOOLEN MILL FACILITY 

07/20/99 

Page 24 

Title 

Authors 

Date: 

Format: 

AR No. 

Canadian Environmental Protection Act, Priority 

Substances List Assessment Report, 

1,4-Dichlorobenzene. 

GOVERNMENT OF CANADA 

1993 

REPORT, STUDY No. Pgs: 3 6 

17.07.2 Document No. 000022 

Title: 

Authors 

Date: 

Format: 

AR No. 

Canadian Environmental Protection Act, Priority 

Substances List,' Assessment Report, 

Trichlorobenzenes. 

GOVERNMENT OF CANADA 

1993 

REPORT, STUDY No. Pgs: 4 5 

17.07.3 Document No. 000023 

Title: 1,4-Dichlorobenzene. 

Authors: AGENCY FOR TOX SUBS AND DISEASE REGISTRY 

Date: April 1993 

Format: FACT SHEET, PRESS RELEASE No. Pgs: 2 

AR No. 17.07.4 Document No. 000020 

Title: Environment Writer, 1,4-Dichlorobenzene (C6H4C12) 

Chemical Backgrounder. 

Authors: NATIONAL SAFETY COUNCIL/ENV HEALTH CTR 

Date: July 1, 1997 

Format: REPORT, STUDY No. Pgs: 2 

AR No. 17.07.5 Document No. 000024 
GUIDANCE DOCUMENTS 

The EPA guidance docmnents listed below were considered during the process of selecting the 

response action for the Eastland Woolen Mill Superfund Site. These EPA guidance documents may 

be reviewed at the EPA Region I Superfund Records Center. 

1. Guidance on Conducting Non-Time Critical Removal Actions Under CERCLA. U.S. 

Environmental Protection Agency, Office of Emergency and Remedial Response. 

(EPA/540-R-93-057). August 1993. [C186] 

2. Management of Remediation Waste Under RCRA. U.S. Environmental Protection Agency. 

(EPA530-F-98-026). October 14, 1998. [C486] 

3. Presumpfive Remedies for CERCLA Sites with VOCs in Soils. U.S. Environmental 

Protection Agency. OSWER Directive # 9355.0-48FS. (EPA 540-F-93-048). September 

1993. [C491] 

4. Superfund Removal Procedures: Action Memorandum Guidance. U.S. Environmental 

Protection Agency, Office of Solid Waste and Emergency Response. (EPA/540/P-90/004). 

December 1990. [C452] 

5. Toxicological Profile for 1.4-Dichlorobenzene (Update). U.S. Department of Health and 

Human Services, Agency for Toxic Substances and Disease Registry. December 1998. 

[C490] 

6. Toxicological Profile for Chlorobenzene. U.S. Department of Health and Human Services, 

Agency for Toxic Substances and Disease Registry. December 1990. [C489]