Superfund Records Center 

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U.S. ENVIRONMENTAL PROTECTION AGENCY1 " ^ 

NEW ENGLAND 

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

MEMORANDUM 

DATE: June 8, 2004 

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: Mary Sanderson, Chief •> 

OSRRII Branch 

TO: 

Arthur Johnson, Chief 

Emergency Planning and Re^onse Branch 

Susan Studlien, Director 

Office of Site Remediation and Restoration 

SiteID#01T6 

I. PURPOSE 

This Action Memorandum requests and documents your approval of a fourth 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. The ceiling for the NTCRA will be 

increased by $3,275,189 to $61,000,000. This is expected to be the final ceiling increase for the 

NTCRA. 

The July 1999, June 2000,,September 2000, and May 2001 Action Memoranda approved a 

consistency 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. 

This Action Memorandum also clarifies that In-Situ Oxidation will be used to address the deep 

overburden and shallow bedrock source material that was not accessible during the excavation of 

contaminated soil. 

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 treatment of soil containing 

SDMS DocID 

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504385 
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE - JUNE 2004 

concentrations of monochlorobenzene, benzene, 1,2 dichlorobenzene, 1,3 dichlorobenzene, 1,4 

dichlorobenzene, 1,2,3 trichlorobenzene, 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 the original information relating to the 

removal site evaluation. Since the signing of the July 1999 Action Memorandum, EPA 

has completed the demolition of the former mill structures as well as the excavation and , 

treatment of the contaminated soil. The remaining NTCRA activities include restoration 

of the areas disturbed as part of the NTCRA and in-situ treatment of the remaining source 

contamination in the deep overburden soil and shallow bedrock. EPA signed a Record of 

Decision for the groundwater within downtown Corinna, referred to as Operable Unit I, in 

September 2002. The Operable Unit I remedial action will target the restoration of the 

bedrock and overburden aquifers. EPA has completed the remedial investigation and 

feasibility study for Operable Unit II and expects to issue a cleanup proposal in summer 

2004- Figure 1 shows the areas subject to the NTCRA, Operable Unit I, and Operable 

Unit II activities. 
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE - JUNE 2004 

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. 

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

The former mill has been removed. Two 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. The second 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 the site 

characteristics that were the basis for the NTCRA. 

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

release or threatened release information that was the basis for the NTCRA. 

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

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

Memorandum for this information. Figure 2 shows the area where NTCRA 

activity will be complete in 2004 and where the additional NTCRA work will 

occur. 

7. Current Status of NTCRA 

The NTCRA is about 90% complete. The contaminated soil that was accessible has been 

excavated and treated to levels that allow,for site re-use. The areas disturbed by the 

NTCRA have been partially restored as of April 2004. The remaining NTCRA activities 

include the in-situ treatment of source areas that were not accessible for excavation and 

treatment as well as the remaining restoration activities. The NTCRA is expected to be 

completed in 2006. 
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE - JUNE 2004 

8. Basis for Ceiling Increase 

This ceiling increase is based upon the updated Site cost information. With 90% of the 

work complete, an accurate picture of the cost to complete has been developed. The 

actual extramural direct increase is $1.7 million from $44.9 million to $46.6 million, 

which is less than 5% of the total NTCRA costs. The basis for the funding increase is a 

more realistic cost estimate for the in-situ treatment of the deep overburden source 

material based upon the completion of the design and the updated cost to demolish the 

soil treatment facility and restore the Site areas disturbed as part of the NTCRA. 

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 

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

of the United States or the environment. 

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

4 
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE - JUNE 2004 

Action Memorandum. The draft final design activities have confirmed that substantial 

concentrations of chlorinated benzene.contamination are present in the soil and groundwater at 

the Site. The contamination is having an impact on the ecological community and threatens local 

water supplies. 

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 duration of the removal has been 

revised to an expected time frame of 7 years. 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, June 2000, September 2000, and May 

2001 Action Memoranda and this Action Memorandum, is considered to be appropriate and 

consistent with the remedial action(s) to be taken at the Site. More specifically, the remaining 

actions to be performed under the NTCRA are precursors to the Operable Unit I groundwater 

cleanup action. 

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

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. 
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE - JUNE 2004 

VI. PROPOSED ACTIONS AND ESTIMATED COSTS 

A. Proposed Actions 

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, June 2000, September 2000 and 

May 2001 Action Memoranda) 

The actions proposed in the July 1999, June 2000, September 2000, and May 2001 

Action Memoranda remain the same. 

2. Contribution to Remedial Performance 

The Operable Unit I Record of Decision identified restoration to drinking water standards 

as the long-term cleanup strategy for the groundwater. The elimination of the material 

that is acting as a source of the groundwater contamination is. critical to the success of the 

Operable Unit I cleanup action. As a result, the NTCRA is.entirely consistent with all 

potential future remedial responses. 
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE - JUNE 2004 

B. Estimated Costs 

Extramural Costs 

Regional Allowance Costs $46,500,000 

(Money from national cleanup fund with contingency) 

Other extramural costs 

r

 State of Maine Cooperative Agreement $100,000 

Extramural Direct Costs 

Extramural Indirect Costs 

Total Extramural 

Intramural Cost 

Intramural Direct $500,000 

$46,600,000 

$13.900.000 

$60,500,000 

Total Intramural 

Total Estimated Removal Ceiling 

$500,000 

$61.000.000 

Notes: 

Existing Removal Projected Ceiling 

based upon May 2001 Action Memorandum: $57,724,811, 

Additional Ceiling Increase requested: $3,275,189 

r-
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE - JUNE 2004 

VII. EXPECTED CHANGE IN THE SITUATION SHOULD ACTION BE DELAYED 

OR NOT TAKEN 

The activities covered by the ceiling increase will allow for the completion of the NTCRA and 

facilitate the complete re-development of the Site. The funding needed to complete the NTCRA 

has already been received by the Region. 

VIII. 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) consistency exemption. I recommend 

your approval of the proposed project ceiling increase of $3,274,189 . The total project ceiling 

for the NTCRA, if approved, will be $61,000,000. 

Approve vX Disapprove 

Date: O(o\o%jo^\ 

&lf^ii ffr^dlign 

Susan Studlien, Director 

Office of Site Remediation and Restoration 
FORMER EASTLAND WOOLEN MILL 

BUILDING 14 AREA 

OPERABLE UNIT 

OPERABLE UNIT II 

.LEGEND 

<3 

AREAS SUBJECT TO EARLY CLEANUP 

EXTENT OF 

OPERABLE UNITS 

375 750 

SCALE: 1"=750' 

1500 FEET 

FIGURE 1 

SITE PLAN SHOWING OPERABLE 

UNIT BOUNDARIES AND 

STUDY AREAS 

OLD DUMP 

EAST BRANCH 

JSEBASnCOOK RIVER 

EASTLAND WOOLEN MILL SITE 

CORINNA, MAINE 
Corundel Lake 

Available For Redevelopment 

Activities in Sprtyig 2004 

200 400 

5 Feet 

FIGURE 2 

LAND AVAILABLE FOR REUSE IN 2004 

EASTLAND WOOLEN MILL SITE 

CORINNA, MAINE 

P. lProjBOT\CoTMna\EO _ Figiirto. 2