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U.S. ENVIRONMENTAL PROTECTION $G*E^Y—2.

REGION I

1 CONGRESS STREET, SUITE 1100, BOSTON, MA 02114-2023

MEMORANDUM

DATE: September 21, 2000

SUBJ: ACTION MEMORANDUM - Request for a Ceiling Increase for the Non-Time Critical Removal Action at

the Eastland Woolen Mill Superfund Site, Corinna, Maine

FROM: Edward M. Hathaway, Remedial Project Manager

ME/VT/CT Superfund Section

THRU: Don Berger, Chief

OSRR II Branch

Steve Novick, Acting Chie

Emergency Planning and Re

Patricia L. Meaney.

Office of Site Remediation a'nd Restcfifotion

SiteID#01T6

I. PURPOSE

This Action Memorandum requests and documents your approval of a second ceiling increase for

the non-time-critical removal action (NTCRA) described herein for the Eastland Woolen Mill

Superfund Site, located on Route 7 in Corinna, Maine.

|> • T'] K ' ooo 'in \ TMIV" ""000 \rtin n Memoranda pppro\r>d n onn<;ic1encv exemption from the $2

million and 12-month statutory limits on fund lead removal actions. The same basis for a

statutory exemption applies to this ceiling increase.

The July 1999 Action Memorandum approved a removal ceiling of $9.7 million. The June 2000

ceiling increase was based upon additional costs related to:(l) the increased volumes of

contamination identified during the NTCRA pre-design activities: (2) the need for extensive

pretreatment of certain soils prior to excavation; (3) the need lor a pilot study involving in-situ

pretreatment of certain soils prior to excavation; (4) re-location of a building as required by the

National Historic Preservation Act; and (5) cost increases relating to actual cost estimates in

comparison to the initial estimates. This ceiling increase is based upon updated volume and cost

estimates.
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE

As stated in the July 1999 Action Memorandum, the overall objective of the NTCRA is to

eliminate the source of the soil, groundwater, and sediment contamination in order to protect

current and future users of groundwater at or near the Site, future users of the Site property, and

ecological receptors. In general terms, the NTCRA consists of the 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 established in the July 1999 Action

Memorandum. This NTCRA will be performed by EPA using fund money as no PRP is available

to implement the response action in a timely manner. This Action Memorandum does not

include any activities that would require Post-Removal Site Control (PRSC).

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).

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 Eastland Woolen Mill ceased

operation in 1996 and the majority of the Mill property is now owned by the Town of Corinna.

1. Removal Site Evaluation

See July 22, 1999 Action Memorandum for this information, except that the former mill

building^ and all but one of the buildings along Main Street in downtown Corinna have

now been removed as part of the on-going EPA response action.

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 of the Site and 2.500 with 4 miles.
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE

The Site was originally dominated by the 250,000 square foot Eastland Woolen Mill.

The former mill has been removed. Three dams are found in the vicinity of the Site. One

dam is approximately 500 feet north (upstream) of the location of the former Eastland

Woolen Mill and serves as the outlet for Corrundel Lake. A second dam is located in a

position which was beneath the Eastland Woolen Mill when the Mill buildings were still

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

approximately 0.5 miles down river of the 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 of the Eastland Woolen Mill

buildings are located.

3. Site Characteristics: See July 22, 1999 Action Memorandum for this information,

except that the former mill buildings have now been removed as part of the ongoing EPA response action.

4. Release or Threatened Release: See July 22. 1999 Action Memorandum for this

information, except that the former mill buildings have now been removed as part

of the on-going EPA response action.

5. NPL Status: The Site \\as placed on the NPL in July 1999.

6. Maps, pictures, and other graphic representations: See July 22. 1999 Action

Memorandum for this information, except that the former mill buildings have now

been removed as part of the on-going EPA response action.

7. Current Status ot N 1CRA

The NTCR'\ \\as initiated with the signing of the Action Memorandum in July 1999.

During fall 1999, EPA began the design for the excavation and treatment activities and

the demolition of the former Eastland Woolen Mill. The Mill building demolition was

completed in May 2000. The design of the NTCRA was completed in August 2000. A

pre-design effort to better define the extent of the contamination requiring excavation was

performed in fall 1999 and a second delineation program was performed in May/June

2000. Mobilization for the excavation activities occurred in June 2000. The five

additional structures along Main Street that were within the area of the Site work have

been removed. The relocation of the Odd Fellows building pursuant to the National
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE

Historic Preservation Act should occur in September/October 2000. EPA has begun

excavation in two areas of contamination within the river channel. Each area has

contained substantially more contamination than expected. Air monitoring has been

performed to confirm that the ambient air is of acceptable quality. The NTCRA is

expected to be completed by December 2001.

8. Basis for Ceiling Increase

The initial $9.7 million dollar estimate for the NTCRA that was presented in the

Engineering Evaluation and Cost Analysis (EE/CA) and July 1999 Action Memorandum

was based upon the information known at the time and using EPA and US Army Corp

cost estimates for the work to be performed. This ceiling increase is based upon an

number of factors:

(1) volumes of contaminated soil in excess of the first and second estimates have been

removed from the first two areas of excavation. The initial estimate was 6,000 cubic

yards of material and the actual volume will be close to 20,000 cubic yards of material.

The associated support costs for the on-site laboratory, air monitoring program, and soil

stockpile management also contribute to costs related to the additional volume of soil.

An additional $1,150,000 is being requested to provide for the excavation volume

encountered to date and anticipated in the near future;

(2) the original cost for site preparation did not anticipate several of the costs that were

necessary to set up the site facilities, including decontamination areas, haul roads,

intensive traffic control, along with the cost of the removal of the additional structures

has added an estimated $750.000 to the projected costs for the Site Preparation task;

(3) the relocation of the Odd Fellows Buildings is currently projected to cost $507,000

based upon the awarded contract as opposed to the June 2000 estimate of $325.000.

This results in the need for an additional $200.000;

(4) the cost for the road detour, new bridge, and river diversion has increased to

Si .400.000 a1? n result of the awarded amount as compared to the design cost estimate:

(5) A additional $1,000,000 is estimated for backfill and restoration to address the new

requirements for restoration of the upper river channel, the stabilization of the Corrundel

Lake dam due to the reduced water levels necessary for the NTCRA. the need for a river

crossing to restore the railroad property as well as the additional soil backfill due to the

increased volumes of excavation; and
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE

(6) the estimated cost for treatment has been increased by $2.5 million based upon the

additional volumes of soil and the possibility that a thermal desorption treatment unit will

likely be required as opposed to the soil pile thermal treatment that was the basis for the

cost estimate. Both approaches are within the scope of the Action Memorandum. The

thermal piles become more challenging as the volume of soil increases since there may

not be sufficient space to allow for the treatment of all soil in 2001.

In addition, some additional design work relating to de-watering and management of the

additional soil volumes will be necessary.

While the costs have increased, all of the activities are consistent with the original scope

of the NTCRA. The additional volume is based upon a better understanding of the

contaminant distribution. The additional costs for the bridge, road, and relocation are

based upon the more specific estimate that can be prepared at the draft final design stage.

In addition, the complexity of this project has necessitated a significant increase in the

pre-design and design activities required to assure that the NTCRA will be implemented

in a manner that does not create unacceptable impacts to air quality, traffic flow, or utility

services.
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE

NTCRA COST TABLE 9/2000

Task Description

Pre-Design Investigations

Design/Work Plans

Building Demolition

Site Preparation (includes other

building demo, haul roads, detours,

decon pads, traffic control)

Soil Excavation

Area 1

Area 2

Area 3

Area 4

Area 5

River Diversion

Road Detour

Bridge

Estimated

Cost

$260,541

$115,200

$3,828,000

$80,200

$790,571*

No Cost

S168,198

No Cost

$325,90J)

$37,800

$237,200

6/2000 Design

Cost Estimate

$1,338,730

$517,880

$3,635,600

$150,000

$1,250,000

$120,000

$110,000

$476,050

$500,000

$325,900

$400,000

$550,000

9/2000 Post-Award

and Work

Progress Estimate

$1,339,000

$618,000

$3,750,000

$900,000

$1,250,000

combined 2/3/4

$1,850,000

$500,000

Combined bridge,

road, diversion

$2,700,000

Totals

$6.607

$3.6

1

1 1

$2.7

$507,000 |

On-Site Soil Treatment

Soil Screening/Washing

Pilot Scale

Full Scale

$55,700

$84,600

$728,730

$55,700

$84,600

$1,000,000

$56,000

$200,000

$3,500,000

| Backfill and Restoration $771,558 $771358 $1,772,000 $5.528

Multi-Phase Extraction

Other Costs (PM, Con. S&A, EDC)

Contingency (approx. 5%) | $535,702] 0 | $1.112

TOTAL: $9,700,000 $14,611,018 $23,354,000

$1.1 12J

$23.354
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE

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

STATUTORY AND REGULATORY AUTHORITIES

Section 300.415(b)(2) of the 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

(vin ) Other situations or ractors that ma> pose threats to public licaiui 01 uc

of the United States or the environment.

This Action Memorandum is based upon the same factors as the July 22, 1999 Action

Memorandum. The pre-design investigations have confirmed that substantial concentrations of

chloroben/enes present in the soil and groundwater at the Site. This contamination is having an

impact on the ecological community and threatens local water supplies.
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 ceiling increase will require additional funding above the statutory ceiling of $2 million

dollars and require more than 1 year to implement. As documented in the July 22, 1999 Action

Memorandum, this NTCRA will require funding above the statutory ceiling of $2 million

dollars and will require more than 1 year to implement. The July 22, 1999 Action

Memorandum projected costs of $9.7 million and a time frame of 18-24 months to complete.

The ceiling for the NTCRA was increased to $15.4 million in June 2000. The revised ceiling

based in this Action Memorandum will be $23,954,000. The same basis for the statutory

requirements apply to this Action Memorandum. This Action Memorandum re-affirms the

finding that a "consistency" exemption is appropriate in order to implement the NTCRA

proposed in this Action Memorandum.

The proposed response action described in the July 1999 and June 2000 Action Memorandum

and this Action Memorandum, are otherwise appropriate and consistent with the remedial action

to be taken. The NTCRA activities included in this Action Memorandum will remove the

source of contamination to the bedrock aquifer and the East Branch of the Sebasticook River.

Excavation and on-site treatment is a response action that is 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.

Ihe implementation of the MC'RA is necessary to pre\ent the lurtlier migration 01 tne

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

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

implement the NTCRA as described in this Action Memorandum.
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 environment through flooding and further degradation

of the structure from fire.

To meet the removal action objectives, EPA selected in the July 22, 1999 Action

Memorandum, a NTCRA to remove the source of the soil and groundwater

contamination. This alternative was referred to as Alternative 2 in the EE/CA. The scope

of the NTCRA has not significantly changed since the July 22, 1999 Action

Memorandum..

1. Proposed Action Description (See July 1999 and June 2000 Action Memoranda)

The actions proposed in the July 1999 and June 2000 Action Memoranda remain the

same.

2. Contribution to Remedial Performance

The NTCRA proposed in this document in combination with the July 1999 and June 2000

Action Memoranda is expected to contribute significantly to the long-term remedial

action. Ihe remedial goal for this Site is to protect public Health and the envnoiuneni.

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 of the

Sebasticook River and the associated ecosystems and to protect private water supplies.

The removal of the source of the contamination is entirely consistent with all potential

future remedial responses.

The RI/FS is expected to identify any further cleanup actions necessary at the Site. Longterm groundwater restoration, downstream sediment contamination, and the former dump

for the Eastland Woolen Mill are all issues that will be addressed by the RI/FS.
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE

B. Estimated Costs

Extramural Costs

Regional Allowance Costs $23,354,000

(Money from national cleanup fund with contingency)

Other extramural costs

CLP $200,000

State of Maine Cooperative Agreement $50,000

Total Extramural Costs $23,604.000

Intramural Cost

Intramural Direct $150,000

Intramural Indirect $200.000

Total Intramural $350,000

Total Estimated Removal Ceiling S23.954.000

Notes:

Fxistin? Removal Proiected Ceiline

based upon June 2000 Action Memorandum: $15.400.000

Additional Ceiling Increase requested: <CR.<v<

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ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE

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 of the Sebasticook River. Some of the 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 of the groundwater contamination has not been

controlled.

X. RECOMMENDATION

This decision document represents a ceiling increase and re-affirmation of the statutory' basis

and consistency exemption for 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 continue to meet the NCP criteria for a removal action as specified at 40

C.F.R. § 300.415(b)(2) and the CERCLA section 104(c) consistenc> exemption. I recommend

your approval of the proposed project ceiling increase of $8.554.000. The total project ceiling

for the NTCRA, if approxed, \\ill be $23,954,000. I also recommend and request \our approxal

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

actions.

Approve ^ Disapprove

nal,

Patricia L. Meaney, Djjector

/ Office of Site Remediation and Restoration

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