U.S. ENVIRONMENTAL PROTECTION AGENCY REGION 1 5 POST OFFICE SQUARE, SUITE 100 BOSTON, MASSACHUSETTS 02109 -3912

EASTLAND WOOLEN MILL SUPERFUND SITE PARTIAL DELETION

DATE: September 18, 2012

TO: Site File

FROM: Ed Hathaway Remedial Project Manager

RE: Eastland Woolen Mill Superfund Site, Corinna, Maine

Purpose:

This memorandum to the Site file documents EPA’s determination that the one letter of comment received with respect to the proposed partial deletion action for the Eastland Woolen Mill Superfund does not constitute an “adverse comment”. The comment period for the proposed rule began on August 2, 2012 and the comment period ended on September 4, 2012. Since no adverse comments were received, the partial deletion will become effective on October 1, 2012 as presented in the direct final rule for partial deletion that was published on August 2, 2012. The basis for the determination that the comment s provided were not adverse is presented in this memorandum.

Background:

The proposed rule presenting the intent for a partial deletion at the Eastland Woolen Mill Superfund Site (40 CFR Part 300 [EPA–HQ

– SFUND –1999–0010– ; FRL–9704– 3]) was published in the Federal Register , Vol. 77, No. 149 on Thursday, August 2, 2012 under Proposed Rules on pages 46009 – 46010. The direct final rule for partial deletion of the Eastland Woolen Mill(40 CFR Part 300 [EPA–HQ

– SFUND –1999–0010; FRL 9704–4] was published the Federal Register , Vol. 77, No. 149 on Thursday, August 2, 2012 under Rules and Regulations on pages 45968 - 45978.

Evaluation of Comments Submitted Regarding Partial Deletion of Eastland Woolen Mill Superfund Site :

EPA received a le tter from an individual stating several objections to the partial deletion action at the Eastland Woolen Mill Superfund Site. After careful consideration of the comments and a conversation with the author of the comments, EPA believes that the comments are not adverse comments. The actual intent of the author of the comments was to seek the removal of the Winchester park property from the boundary of the Eastland Woolen Mill Superfund Site, although by a different mechanism than the proposed partial deletion. Since the intent of the comment was to remove the property from the Site boundaries, as was the intent of the proposed

## Eastland Woolen Mill Partial Deletion

2 partial deletion, the comment is not an adverse comment to the proposed partial deletion. In addition, the commentor submitted a letter clarifying his position in support of the partial deletion.

The commentor was also seeking changes to the Site documents to clarify what he felt were inaccuracies in the support documentation for the partial deletion. The individual comments are
presented below along with a response:

Comments relating to the partial deletion:

1. Comment: I object to Winchester Park being listed within the boundaries of the EWM Superfund Site: Figure 10, Institutional Control Zone Layout, Tax Map 18 Lot 53; Figure 11, Areas to be Deleted and Remaining Boundary of the Site; Figure 12, Site Deletion and Site Boundary with NTCRA and Groundwater Information.

a. Th is comment was clarified based on a telephone conversation between the EPA RPM and the author of the comments on September 6, 2012 . The comment objected to the partial deletion action on the basis that the property known as Winchester P ark should not require deletion because it should never have been considered within the boundaries of the Eastland Woolen Mill Superfund. The commentor clarified that he supports the removal of the Winchester Park from the Site as proposed in the deletion and has no objection to the partial deletion action for the other properties. The intent of the objective was to request that E PA go back and remove all references in text and maps that show Winchester Park within the boundaries of the Site. If that was done, there would be no need to include Winchester Park in the partial deletion. 1

Response: Winchester Park is a small parcel at the edge of the properties that were formally the Eastland Woolen Mill. The Town of Corinna acquired the Eastland Woolen Mill properties as part of a tax lien action. In 2004, the Town of Corinna created a subdivision plan for the former Eastland Woolen Mill and included Winchester Park on the plan. Winchester Park was identified as a property that would require land use restrictions, which have been finalized, to prevent installation of a groundwater well that could impact the nearby groundwater contamination. A portion of Winchester Park was also disturbed and restored as part of the EPA Non

- Time

- Critical Action (“NTCRA”) due to its close proximity to the contaminated soil excavation. The Winchester Park property had been generally included in some of the Site definition maps and boundary descriptions creating some ambiguity as to whether Winchester Park was part of the Site.

To remove any ambiguity, EPA included the Winchester Park property within the area identified for the partial deletion. The partial deletion is the appropriate administrative mechanism to remove a property from a Site boundary. While the commentor would have preferred that EPA go back and remove any reference that infers that Winchester Park is within the Site boundaries,

1 Subsequent to receiving this comment and the September 6 telephone conversation with the commenter to clarify the comment, EPA received a second letter from the commenter dated September 10, a copy of which is attached to this memorandum.

## Eastland Woolen Mill Partial Deletion

3 the only effective way to formally remove Winchester Park from the Site boundaries, is the partial deletion process.

Since the intent of the comment is to remove Winchester Park from the boundary of the Site, the comment is not an “adverse comment” but rather a preference that the mechanism to remove the property from the Site boundary should have been to revise all of the previous documents. The commentor’s objection was that he did not want to acknowledge that Winchester Park was ever within the boundari es of the Site even if that acknowledgement was accompanied by the deletion. As stated above, because response costs were incurred on a portion of the Park as part of the NTCRA, the partial deletion process being administered by EPA is the appropriate

me chanism to accomplish the removal of Winchester Park from the EWM Site boundary.

2. Object to Figure 10, 11 and 12: T ax Map 18 Lot 52. At first glance it would be nearly impossible to determine Lot 52 Tax Map 18 was included in the EWM Site when the mill closed on October 13, 1997. The lot appears to only have an innocent connection to the Superfund Site as indicated in Figure 10, “IC (Institutional Control) area where properties outside of the Eastland Woo len Mill Site are being restricted to permit prevent expansion of the groundwater plume.” In an attempt to partially recover a $2.5 million load to Eastland Woolen Mill, the Finance Authority of Maine (FAME) acting in its capacity as creditor held an auction. The so-called Emery/Hutchins house, buildings and lot were sold by FAME to David and Jeanne Carcieri on May 5, 1997. I object to Lot 52 Tax Map 18 being excluded from the partial delisting boundary of the EWM Superfund Site. Lot 52 experienced a le vel of EPA cleanup activity at least equivalent with parcels to the south, east and north on the EWM Site. Figure B shows “2,200 Gal. Aqua Amonia ASTS” storage tanks on Lot 52. Although having become a private lot separate from EWM, the lot – particularl y the easterly open space

- was subject to low level contamination soil cleanup at the mill Site. Lot 52 extended to the southwest corner of the EWM building and mill yard.

Response: The comment questions why Figures 10, 11 and 12 and the proposed partial deletion boundary do not include Tax Map 18 Lot 52 as being included in the Site boundary and then subject to the deletion – as is the case for Winchester Park . Tax Map 18 Lot 52, similar to Wi nchester Park, is adjacent to the former Eastland Woolen Mill. In addition, no soil or groundwater contamination was found on Tax Map 18 Lot 52. The property is required to have a land use restrictions that will preventthe installation of a water suppl y well that could influence the movement of the groundwater contamination. The Eastland Woolen Mill had encroached on this property, which was owned by the mill owners. The back portion of Tax map 18 Lot 52 was used by the mill as a road, parking, and also in cluded several storage tanks. The tanks were removed as part of the Non-Time Critical Removal Action but no contamination was found on the property. Figure 3, not Figure B shows the former ammonia tanks. The portion of the Tax Map 18 Lot 52 property that was within the former Eastland Woolen Mill footprint was also used during the cleanup action and, similar to Winchester Park, the disturbed areas were restored. Similar to Winchester Park, portions of Tax Map 18 Lot 52 have been described as bein g within the boundaries of the EWM Site.

## Eastland Woolen Mill Partial Deletion

4 The land use restriction for Tax Map 18 Lot 52 is not finalized so the property could not have been included in the partial deletion as one of the properties to be deleted. Once the land use restriction is in place, EPA will evaluate whether to include that portion of Tax Map 18 Lot 52 in a future deletion notice. The one main difference between Winchester Park and the property
at T ax Map 18 Lot 52 is that Winchester Park is one of the Town owned properties that is shown on the subdivision plan and the Town- owned properties on that plan were, at times, general ly depicted as being within the boundary of the Site. It seemed appropriate to include Winchester Park in the partial deletion to provide clarity that willno longer be included in the boundary of the EWM site. Tax Map 18 Lot 52 is an owner occupied residential property that is not Town owned and a portion of the property was subject to response actions as part of the NTCRA.

Other Comments:

1. I object to Winchester Park being included in the Subdivision Plan for the Town of Corinna, Plan File 2004, No. 167, Penobscot Registry of Deeds, October 19, 2004.

Response: This is not a comment relevant to the EPA activities. EPA suggests that the commentor address this issue with the Town of Corinna.

2. I object to the configuration of Winchester Park as represented in the Survey Plan Showing Properties In Corinna Subject To Proposed Environmental Controls; Maine Department of Environmental Protection, September 20, 2011; the Plan as filed in Penobscot County Registry of Deeds, Plan File 2012, No. 20, dated March 29, 2012, also showing the 2004 Town of Corinna Tax Map Subdivision Plan.

Response: This plan was developed by Maine DEP and reviewed by the Town of Corinna. EPA suggests that the commentor address this issue with the Town of Corinna and the Maine DEP. EPA does agree, based on the telephone conversation between the RPM and author of the comments, that any future map used for land use restrictions should clearly identify Winchester Park as a parcel separate from the subdivision lots.

3. By recording Winchester park as a part of the EWM Superfund Site, the Town of Corinna and the EPA are ignoring provisions of the 1913 deeded covenant that prevent combining the park with adjacent tax-acquired EWM property. Tax-acquired property can be sold by the Town of Corinna. The legislative body at annual town meeting voted “to authorize the Board of Selectmen, on behalf of the town, to sell and dispose of any real estate acquired by the town for nonpayment of taxes, thereon and on such terms as they deem advisable, based upon the fair value of said property and determine to be most beneficial to the town and its inhabitants and to execute quitclaim deeds to such property.” Town of Corinna Annual Report 2011, Article 9, p.60, March 2012. The town voted “ to authorize the Board of Selectmen to dispose of any town owned real estate on such terms as they deem advisable ” Town of Corinna Annual Report, Article 10, p.60, March 10, 2012. Winchester Park is a town owner Civil War park. The park was donated to the inhabitants of the town of Corinna by the Elizabeth Winche ster family in 1913, Penbscot Registry of Deeds, book 835, Page 391.

## Eastland Woolen Mill Partial Deletion

5 Response: The federal action at the EWM Superfund Site does not alter any of the legal property boundaries of description. The Site boundary is not a property boundary but rather the limits of the area where contamination has come to be located or where cleanup action is needed. Neither the cleanup action, including the land use restrictions, nor the partial deletion have changed the Winchester Park property boundary nor have the EPA actions attempted to legally combine Winchester Park into other property. EPA identified Winchester Park as a separate property in the partial deletion and in the development of the land use restrictions. Figures which show a general “Site” boundary that is inclusive of Winchester Park and the other Town properties are not legal property descriptions but rather are generic Site depictions. Any issues relating to the Town of Corinna management of the property should be addressed to the Town of Corinna.

4. Winchester Park was never owned by Eastland Woolen Mill. The park was never subject to EPA Non -Time Critical Removal Action. Benzene contaminated soil was never excavated and removed from Winchester Park. The soil and groundwater in Winchester Park were never treated with in -situ chemical oxidation. Historic boundary lines of the park were surveyed and marked during the EPA cleanup activities at the EWM Superfund Site. In autumn 2003 the EPA graded the easterly boundary of Winchester Park to
restore as close as possible the historic slope of the Site within the context of the westerly properties abutting the EWM Site. Town of Corinna officials and EPA engineers verbally agreed to return the granite boundary line markers once the easterly line of Winc hester Park had been graded. Absence of the granite boundary line marker smooths the way for the free plunder of Winchester Park.

Response: EPA has not stated the Winchester Park was part of the former Eastland Woolen Mill property. The boundary of the Eastland Woolen Mill Site is not limited to the former property of the Eastland Woolen Mill. The Site is the term EPA uses to describe where cleanup actions are necessary and where contamination has come to be located. EPA did document that Winchester Park was not contaminated in federal register notice. The federal register notice for the partial deletion states that “The properties proposed for deletion that are identified in the Town of Corinna subdivision plan as Lots 2, 3, 4, 5, 6, 8, 9, and 10, portions of Lot 54 on Tax Map 18, the property identified as Lot 53 on Tax Map 18 and the property owned by Central Maine Power were not within the areas where substantial contamination was located. These properties contained open space, the dry processing portions of the former Eastland Woolen Mill, and office space.” The federal register notice later states “ In summary, the Town of Corinna subdivision lots 2, 3, 4, 5, 6, 8, 9, and 10, the portion of Subdivision Lot 1 north of the Central Maine Power property , a portion of Lot 54 on Tax Map 18, the property identified at Map 18 Lot 53 (Winchester Park) and the property owned by Central Maine Power have been evaluated during the RI and NTCRA activities. The RI documented that the area was not a substantial threat to groundwater. The NTCRA sampling further documented that these properties do not contain soil contamination above the Site specific cleanup levels.”

If the property boundary marker for the easterly line of Winchester Park has not restored, EPA will address this issue to correct the omission. Any concerns regarding the management of the Town owned properties should be addressed to the Town of Corinna.

## Eastland Woolen Mill Partial Deletion

6 5. Response to Figure 10, and companion Figures 11 and 12, Odd Fellows Building: I object to the Odd Fellows Building listed as a “Demolished Building”. A federally funded Historic Inventory and Survey determined the significantly historic building eligible for listing on the National Registe r of Historic Places. In autumn 2000 the EPA moved the Odd Fellows Building from Main Street to Stetson Road, Tax Map 18 Lot 118. The move was a cooperative effort between the Odd Fellows, Town of Corinna, and the EPA. A state advocate and oversight organization for the Odd Fellows Building is the Maine Historic Preservation Commission. The Odd Fellows Building is located on town owned tax-acquired property, a former parking lot used by EWM. The lot was subject to no small amount of EPA activity involving the determination of land ownership, foundation construction, moving and preparation for building use. The Old Fellows Buildings is now owned by Parian Ladge of Masons. A deeded land- lease agreement is contingent on a 20 year continuous owner occupancy. The cost of moving the Odd Fellows Building by the EPA was reportedly $500,000.

Response: Figure 8 does incorrectly show the Odd Fellows building as one of the buildings subject to demolition rather than as the one building that was relocated. EPA will make this correction if a similar figure is developed in the future. Figures 10, 11 and 12 correctly show the location of the Odd Fellows building as an existing structure and make no reference to demolition.

6. Comments on Site Operational History, page 2, Delisting Memorandum: “The original woolen mill structure was built in the late 1800’s” and “The property was a woolen mill” I have found information showing textile activity on the Eastland Woolen Mill site dating back to the 1800’s. In 1875 Burill and Ireland owned a wool carting mill in Corinna village. Th e carding mill was east of the river and bounded by mill pond, railroad line and Main Street. Corinna Manufacturing Company, the predecessor of what was later renamed Eastland Woolen Mill was built in 1912.

Response: EPA appreciates the clari fication with respect to the Site history.

7. Eastland Woolen Mill Site Deletion, Operable Unit 1 town owner subdivision lots, institutional controls and covenants including: soil excavation restrictions?; soil removal restrictions?; off -site disposal restrictions?; short and long term financial, and engineered design capacity of the Corinna Water District; Short and long term financial, and engineered design capacity of Corinna Sewer District; Total cost of upgrading the Corinna Water District infrastructure during the EPA Superfund project.

Respon se: It is difficult to determine the intent of the comments as they do not relate to the partial deletion. The questions regarding the Corinna Water District and Corinna Sewer District should be addressed to those entities. The cost and funding questions also do not relate to the deletion and this information is not readily available at this time. The institutional controls for the town lots are separated into two basic documents. One is for the properties no longer included within the Site and the other is for the property remaining within the Site.

The property restrictions for the town property that will be deleted are listed below:

## Eastland Woolen Mill Partial Deletion

7 Activity and Use Limitations . The following covenants, conditions, and restrictions apply to the use of the Property , shall run with the land, and shall be binding on the Grantor, its successors and assigns in perpetuity:

a. Groundwater underlying the Property shall not be extracted, consumed, exposed or utilized in any way, except for the limited purpose of extracting, treating and/or monitoring groundwater contamination levels in accordance with plans approved by the Holder and the EPA. Groundwater supply wells shall not be installed or utilized on any part of the Property, nor shall the hydrology of such groundwater be altered in any way.

b. Any surface or subsurface materials displaced as a result of filling, drilling, or excavation shall remain on the Property or, if removed from the Property, shall be relocated to the Village Cemetery on Stetson Road in Corinna, Maine, or any other site approved by both the Holder and EPA.

c. No septic system shall be constructed or installed on the Property; any improvements on the Property shall be connected to municipal water delivery and sewer collection systems.

d. Any building constructed on the Property shall be equipped with a sub- slab vapor system or its equivalent designed to prevent migration of soil vapors into the interior of the building.

The property restrictions for the town owner property to remain with in the Site are:

Activity and Use Limitations . The following covenants, conditions, and restrictions apply to the use of the Property, shall run with the land, and shall be binding on the Grantor, its successors and assigns in perpetuity:

a. Groundwater underlying the Property shall not be extracted, consumed, exposed or utilized in any way, except for the limited purpose of extracting, treating and/or monitoring groundwater contamination levels in accordance with plans approved by the Holder and the EPA. Groundwater supply wells shall not be installed or utilized on any part of the Property, nor shall the hydrology of such groundwater be altered in any way.

b. No use or activity shall be permitted on the Property, unless otherwise provided herein, which may impede the construction or implementation of the remedial action or which will disturb any of the remedial measures implemented as the first operable unit or damage any of the equipment or machinery installed at the Property in connection therewith. Such remedial measures include, without limitation, the injection of chemical reagents or other substances to treat soil and groundwater, collection, treatment, and discharge of groundwater; the excavation, de-watering, storage, consolidation, treatment and disposal of soils; and the monitoring of air, groundwater, surface waters, soil, sediment and biota.

## Eastland Woolen Mill Partial Deletion

8 c. Any surface or subsurface materials displaced as a result of filling, drilling, or excavation shall remain on the Property or, if removed from the Property, shall be relocated to the Village Cemetery on Stetson Road in Corinna, Maine, or any other site approved by both the Holder and EPA.

d. No septic system shall be constructed or installed on the Property; any improvements on the Property shall be con nected to municipal water delivery and sewer collection systems.

e. Any building constructed on the Property shall be equipped with a sub- slab vapor system or its equivalent that is designed to prevent migration of soil vapors into the interior of the building.

8. Objections to Maps/Road Names: It would be accommodating to present and future generations, for the sake of clarity, to indicate the road names in Corinna village within the context of the town ordinance approved road names representing Corinna in 2012. Conflicting surveys, maps and deed registrations contribute to an accumulation of revisionist Corinna history that has begun working its way into the permanent record.

a. Figure 8: Location of Major NTCRA Activities i. “Center Street” is Dexter Road ii. “Spring Street” is Stetson Road iii. “Route 43” is St. Albans Road iv. “Palmyra Spur Road” is Renewal Street

v. “New Main Street Bridge” is correct. Corinna has two new Main Street highways: Route 7/43 at intersection of St. Albans Road to Route 222 Stetson Road (2002); Main Street in EWM Subdivision to Route 43/St. Albans Road (2003). b. Figure 10: Institutional Control Zone Layout i. Nokomis Road” is St. Albans Road (Route 43between Route 7 intersection and Nokomis Road/St. Albans Road “V” intersection.

c. Figure B: i. “Pleasant Street” is St. Albans Road. ii. “Palmyra Road” is Nokomis Road. iii. “School Street” is Renewal Street. iv. “Nokomis Road (on Route 43) is St. Albans Road.

v. “School Street” is Stetson Road vi. “East Main Street: is Exeter Road. vii. “New Route 7” is Newport Road south of St. Albans/Route 7 intersection, and becomes Main Street north of the Route 7/43 intersection to the Stetson Road/Route 222 intersection.

Response: EPA appreciates the identification of the updated road names and will make every effort to use the correct roadnames on future maps.Ed Hathaway U.S. Environmental Protect ion Agency, Region 1 

### 5 Post Office Square, Suite 100 Boston, Massachusetts 02 1 09-3912

Subject: EPA Proposed Deletion of Portions of Eastland Woolen Mill Site, Corinna, Maine.

Response: Eastland Woole n Mill Partial Deletion Technical Memorandum, June 29, 2012.

Notwithstanding the lack o f a viable EPA Technical Assistance Grant Committee in Corinna,

a critical response is directed to the U.S. Environmental Protection Agency and the Town of Corinna concerning the Ea s tland Woolen Mill Superfund Partial Deletion Memorandum.

I object to Winchester Par k being listed within the boundaries of the EWM Superfund Site: Figure 10, Institutional Control Zone Layout, Tax Map 18 Lot 53; Figure 11, Areas To Be Deleted And Remaining Bo undary of Site ; Figure 12, Site Deletion And S ite Boundary With NTCRA And Groundwater Information.

I object to Winchester Par k being included in the Subdivision Plan for t he Town of Corinna, Plan File 2004, No. 167

, Pen obscot County Registry of Deeds, October 19, 2004.

I objec t to the configuratio n of Winchester Park as represented in the Survey Plan Showing Properties In Corinna Subj e ct To Proposed Environmental Controls; Maine Department of Environmental Protection

, September 20, 2011; the Plan as filed in Penobscot County Registry of Deeds, Plan Fil e 2012

, No. 20

, dated March 29, 2012

, also s howing the 2004 Town of Corinna Tax Map Subdivision Plan.

By recording Wincheste r Park as a part of the EWM Superfund Site, the Town of Corinna and the EPA are ignoring provisions of a 1913 deeded covenant that prevents combining the park with adjacen t tax- acquired EWM property.

Tax-acquired property c a n be sold by the Town of Corinna.

The legislative body a t annual town meeting voted "to authorize the Board of Selectmen

, on behalf of the town, to se ll and dispose of any real estate acquired by the town for nonpayment of taxes, thereon and on such terms as they deem advisable, based upon the fair value of said property a nd determined to be most beneficial to the town and its inhabitants and to execute quitclaim deeds to such property." Town of Corinna Annual Report 2011, Article 9
, p. 60. March 10, 2012

.

The town voted " to authori ze the Board of Selectmen to dispose of any town owned real
estate on such terms a s th e y deem advisabl e. " Town of Corinna Annual Report, Article 10

, p. 60, March 10

, 2012

.Winchester Park is a town owned Civil War park. The park was donated to the .inhabitants of the town of Corinna by the Elizabeth Winchester family in 1913; Penobscot County Registry of Deeds, Book 8 3 5, Page 391.

Winchester Park was never owned by Eastland Woolen Mill. The park was never subject to EPA Non-Time Critical Re m oval Action. Benzene contaminated soil was never excavated and removed from Winch e ster Park. The soil and groundwater in Winchester Park were

never treated with in-situ c hemical oxidation.

Historic boundary lines of the park were surveyed and marked during the EPA cleanup activities at the EWM Sup e rfund Site.

In autumn 2003 the EPA graded the easterly boundary of Winchester Park to restore as close as possible the histo r ic slope of the Site within the context of westerly properties abutting the EWM Site.

Town of Corinna officials a nd EPA engineers verbally agreed to return the granite boundary line markers once the easterly line of Winchester Park had been graded.

Absence of granite boundary line markers smooths the way for the free plunder of Winchester Park.

Objection to Figure 10, 11 and 12: Tax Map 18 Lot 52

At first glance it wou ld be nearly impossible to determine Lot 52 Tax Map 18 was included in the EWM Site when the mill closed on October 13, 1997. The lot appears to only have an innocent connection to th e Superfund Site as indicated in Figure 10, "IC (Institutional Control) area where prop e rties outside of the Eastland Woolen Mill Site are being restricted to permit prevent expansion of the groundwater plume."

In an attempt to partially r ecover a $2.5 million loan to Eastland Woolen Mill, the Finance Authority of Maine (FAME ) acting in its capacity as creditor held an auction.

The so-called Emery/Hutch ins house, buildings and lot were sold by FAME to David and Jeanne Carcieri on May 5 , 1 997

.

I object to Lot 52 Tax Map 18 being excluded from the partial delisting boundary of the EWM Superfund Site

. Lot 5 2 experienced a level of EPA cleanup activity at least equivalent with parcels to the south, east and north on the EWM Site. Figure B shows "2,200 Gal. Aqua Amonia ASTS"storage tanks on Lot 52.

Although having become a private lot separate from EWM, the lot- particularly its easterly
open space -was subject t o low level contaminated soil cleanup at the the mill Site. Lot 52 extended to the southwes t corner of the EWM building and mill yard.

Response to Figure t O, and companion Figures 11 and 12, Odd Fellows Building:I object to the Odd Fellows Building being list e d as a "DEMOLISHED BUILDING."

A federally funded Historic Inventory and Survey determined the significantly historic building eligible for listing on the National Register of Historic Places.

In autumn 2000 the EPA moved the Odd Fellows Building from Main Street to the Stetson Road, Tax Map 18 Lot 118. The move was a cooperative effort between the Odd Fellows, Town of Corinna and the EPA. A state advocate and oversight organization for the Odd Fellows Building is the Ma i ne Historic Preservation Commission.

The Odd Fellows Building i s located on town owned tax-acquired property, a former parking lot used by EWM. The lot was subject to no small amount of EPA activity involving the determination of land ownership, foundation construction, moving and preparation for building use.

The Odd Fellows Building i s now owned by Parian Lodge of Masons. A deeded land-lease agreement is contingent o n a 20 year continuous owner occupancy.

The cost of moving the Odd Fellows Building by the EPA was reportedly $500,000.

Comments on Site Operational History, page 2, Delisting Memorandum:

"The original woolen mill structure was built in the late 1800's" and "The property was a woolen mill."

I have found information s h owing textile activity on the Eastland Woolen Mill site dating to the 1800's. In 1875 Burrill and Ireland owned a wool carding mill in Corinna village. The carding mill was east of th e river and bounded by the mill pond, railroad line and Main Street

Corinna Manufacturing Company, the predecessor of what later was renamed Eastland Woolen Mill was built in 1 9 12.

Eastland Woolen Mill Site Deletion, Operable Unit 1 town owned subdivision lots, institutional controls and covenants including:

1. Soil excavation restricti o ns?

2. Soil removal restriction s ?

3. Off-Site soil disposal res trictions?

4. Short and long term financial, and engin e ered design capacity of the Corinna Water District?5

. Short and long term fin a ncial, and engineered de s ign capacity of the Corinna Sewer District?

6. Total cost of upgrading t h e Corinna Water District infrastructure during the EPA Superfund project?

7

. Total cost of upgrading th e Corinna Water District infrastructure during the EPA Superfund project?

Objections to Maps/Road N ames:

It would be accommodating to present and future generations, for the sake of clarity, to indicate the road names in C orinna village within the context of the town ordinance approved road names repr e senting Corinna in 2012

. Figure 8 : Location of Major NTCRA Activitie s

1. "Center Street " is Dexter Road

. 2. "Spring Street is Ste ts on r oad

. 3. "Route 43" is St. Albans Road

. 4

. "Palmyra Spur Road" is R enewal Street. 5

. "New Main Street Bridg e " is correct. Corinna has two new Main Street highways

. 1) Route 7/43 at inte rsection of St. A l bans Road to Route 222 Stetson Road (2002)

. 2) Main Street in EWM Subdivision to Route 43/St. Albans Road (2003)

.

Figure 10 : Institutional Co n trol Zone Layout

1. "Nokomis Road" is St. Al b ans Road (Route 43 between Route 7 intersection and Nokomis Road/St. Alba n s Road "V" intersection.

Figure B:

1. "Pleasant Street " is S t. Albans Road. 2. "Palmyra Road" i s No komis Road

. 3. "School Street" is R e n e w al Street. 4. " Nokomis Road " (o n Route 43) is St. Albans Road. 5. "School Street'' is St e tson Road

. 6. "East Main Street'' is Exeter road. 7. "New Route,7" i s N e wport Road south of St. Albans Road/Route 7 intersection, and becomes Main Stre e t no rth of the Route 7 

### f 43 intersection to the Stetson Road/Route 222 in t e rsection.

Conflicting surveys , maps a nd deed registrations contribute to an accumulation of revisionist Corinna history that has begun working its way into the permanent record.A good Technical Assistance Grant Commi ttee is hard to find.

Yours in citizenship,

Everett E. Simpson 88 Pleasant Vale Road Corinna, Maine 04928

August 29, 2012Edward Hathaway U.S

. Environmental Protection Agency, Region 1 5 Post Office Square, Suite 100 Boston, Massachusetts 02109-3912

Subject: E PA Proposed Deletion of Portions of Eastland Woolen Mill Site, Corinna, Maine.

Amended Response: Eastland Woolen Mill Partial Deletion Technical Memorandum, June 29,2012.

In honor of the many who made possible the Eastland Woolen Mill Site cleanup, I support the proposed 2012 U.S. En v ironmental Protection Agency partial delisting of the E WM Superfund Site in Corinna, Maine

.

I further suppo rt the EPA partial Site delisting from the National Priorities List with special emphasis on the 2012 removal of historic Winchester Park from the EWM Superfund Site boundaries; Town of Corinna Tax Map 18 Lot 53, Penobscot County Re gis try of Deeds, 1913.

When creating future EPA reports and maps concerning the E WM Superfund Site in Corinna, please consider the information now in the public domain via my delisting
response letter to the EP A dated Au gu st 29, 2012.

Thank you kindly,

Everett E. Simpson 88 Pleasant Vale Road Corinna, Maine 04928

September 10, 2012