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Final Pollution Report (POLREP)

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I. Heading

Date:

Subject:

From:

POLREP No.

OSC/RPM:

SDMS DocID 259300

September 27, 2006

Eastland Woolen Mill Superfund Site, Non-TimeCritical Removal Action (NTCRA), Corinna, Maine

U.S. EPA Region 1 - Boston, MA

Final

Edward Hathaway, RPM-/.^

II. Background:

Site ID. No.:

Delivery Order No.:

Response Authority:

ERNSNo.:

CERCLIS:

Site ID No:

NPL Status:

State Notification:

Action Memorandum:

Start Date:

Completion Date:

01T6

N/A

CERCLA

N/A

MED980915474

0101043

Final NPL (July 1999)

Yes, Maine DEP Notified

Signed July 22, 1999

November 19, 1999

May 10,2006

Site Information

A. Physical Location/Site Characteristics

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

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

Bangor, Maine. Approximately 800 people live within one mile of the Site and 2,500

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

Sebasticook River (EBSR) watershed, which drains to Sebasticook Lake approximately

three miles south of the Town. Topography within the watershed is typified by gently
rolling hills to steeply sloping ridges, varying from narrow valleys to fairly expansive

low-lying floodplains. Elevations within the immediate vicinity of Corinna range from

200 to 320 feet above mean sea level (msl). The former Eastland Woolen Mill

straddled the EBSR and the southern portion of the former Mill Pond.

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

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

center of town, currently occupied by the Site, has been targeted for a mix of

commercial, residential and mixed-use development. An expansion of the water supply

has been implemented by the local water district to support future growth. The

majority of the Site is available for re-use since the current cleanup program only

occupies about three of the 25 acres covered by the Site. The available 22 acres are

currently being marketed by the Town of Corinna. The back portion of the Site has

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

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

B. Removal Site Evaluation

Prior to closing in 1996, Eastland Woolen Mill was a manufacturer and finisher of wool

and blended woven fabric. Fabric finishing included dyeing of the fabric to meet

product or customer requirements. This dying operation took place in dye kettles and

utilized various chemicals, including dyes and dye-aid. Dye mixtures consisted of

varying amounts of water, dye, dye-aid, and other chemicals.

Dye-aid, which Was used to improve absorption of dye by wool fabric, typically

contained chlorinated benzene compounds. The time of dye-aid use has not been

documented, although it may have been as early as the 1950s through the closing of the

mill in 1996. The 1991 Spill Containment and Prevention Plan prepared by Acheron,

Inc. (Acheron, 1991) indicates that Eastland Woolen Mill used approximately 50

gallons of Carolid MXS every day. Reportedly, a monochlorotoluene-based dye-aid

was also used at the mill (MEDEP, 1990). The dye-aid Carolid MXS reportedly

contained approximately 65 percent dichlorobenzenes and approximately 35 percent

biphenyl. The dye-aid Carolid EWS contained up to 31 percent chlorinated benzene

compounds, including 1,2-dichlorobenzene, 1,3-dichlorobenzene, 1,4-dichlorobenzene,

and 1,2,4-trichlorobenzene.

Until construction of the Town of Corinna Wastewater Treatment Plant (WWTP) in

1969, liquid wastes from the mill were discharged to the EBSR. This occurred either

by overland flow to the river following discharge to the ground surface beneath mill

buildings, or by direct discharge to Mill Pond Dam tailrace also located below

Eastland's buildings. It was not until 1977 that all liquid waste streams were finally

directed to the WWTP.

As a result of these discharge practices, overburden soil and bedrock underlying mill

buildings, and river sediment and underlying soil extending several hundred feet

downgradient were contaminated with chlorinated benzene compounds. Groundwater
was contaminated at concentrations well above federal drinking water Maximum

Contaminant Levels (MCLs) and State of Maine drinking water Maximum Exposure

Guidelines (MEGs). Routine pumping of nearby residential bedrock wells served to

spread the contamination laterally along bedrock bedding-plane fractures. To address

potential risks from use of contaminated groundwater, several nearby residential water

supply wells were fitted with activated carbon filters between 1983 and 1993, and a

public drinking water supply system was installed in 1995.

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

within the Eastland Woolen Mill.

C. Other Actions To-Date

In addition to the removal activities, EPA has also performed a remedial investigation

and feasibility study (RI/FS) for the Site. The initial RI/FS activities began in fall 1999.

In September 2002, EPA signed a Record of Decision (ROD) to select a remedial

action for the Operable Unit I area of the Site. In September 2004, EPA signed a No

Further Action ROD for the OU II area of the Site. EPA completed an amendment to

the OU I ROD in September 2006.

EPA has kept the community well informed through the release of public information

fact sheets and public meetings.

IV. Response Information

A. Situation

\

1. Current Situation

The NTCRA field activities were completed in November 2005. The final activity

for the NTCRA was the submittal of the 2005 Phase I and Phase II Remedial

Performance Assessment Report on May 10, 2006.

2. Removal Activities to Date

The Site was proposed for inclusion on the NPL on April 23, 1999 (64 Fed. Reg.

19968). It was listed for final inclusion on the NPL on July 22, 1999 (64 Fed. Reg.

39878-39885). In July 1999, EPA signed an Action Memorandum to initiate a

NTCRA at the Eastland Woolen Mill Site to address the contamination in the soil
that was acting as a continuing source of contamination to grounclwater and surface

water. The NTCRA included two approaches to removal contamination in soil that

is acting as a source of contamination. The first approach was to physically

excavate the contaminated soil and reduce the contaminant concentrations through

thermal treatment. This approach required the removal of the former Eastland

Woolen Mill structures and eight other structures. This approach also resulted in the

permanent re-location of the ESBR, the removal of the dam that was located under

the former Eastland Woolen Mill, and the re-location of Main Street (Route 7). The

second approach used an in-situ treatment technology to reduce the contaminant

concentration in those soils that were not accessible during the excavation and exsitu treatment program.

NTCRA Excavation and Ex-Site Treatment Program:

Beginning in 1999, the USEPA retained the United States Army Corps of Engineers

(USAGE) to implement the NTCRA. The USAGE retained Weston Solutions, Inc.

(Weston) as the prime contractor to perform the NTCRA cleanup activities. This

NTCRA has included the removal of the mill buildings (performed during the

winter of 1999/2000) and contaminated soils from four areas (performed from

2000-2001). NTCRA work areas are described as:

• Area 1 :Region underlying former Eastland Woolen Mill Buildings 1,

1A, 3 extending across the former location of Main Street (Route 7), and

including the segment of the EBSR beneath the former Eastland Woolen

Mill and extending across the former Main Street. The contaminated

soil in this area was removed in 2001.

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

Mill to the abandoned railroad trestle. The contaminated soil and

sediment in this area was removed in 2000.

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

Area 2 and Area 3. The contaminated soil and sediment in this area was

removed in 2000.

• Area 3: Segment of EBSR for a distance of several hundred feet beyond

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

removed in 2000.

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

miscellaneous areas. The initial contaminated soil removal for these

areas occurred in 2000 and 2001. Additional contaminant soil removal

for the Building 14 Area was performed in 2005.

During 2000 and 2001 approximately 75,000 yd3 of chlorinated-benzene contaminated

soils were excavated and stockpiled at the Site in lined containment structures.

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

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

goals established for the NTCRA. Full-scale treatment of contaminated soil using an
on-site ex-situ low temperature thermal system began in October 2002 and was

completed in October 2003. Quality control testing of the soil after treatment

documented that all of the soil that was used for on-site backfill contained residual

levels of contamination below residential cleanup standards and met the NTCRA

groundwater leaching criteria that were developed during the NTCRA.

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

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

groundwater infiltration during excavation activities. One bedrock well and four

overburden wells were connected to a temporary treatment system. The system

remained operational until November 2004 to provide hydraulic control over the

groundwater plume during the initial phase of the NTCRA. Since 2004, the

groundwater management system has been operated as necessary to support the

NTCRA in-situ oxidation program.

Details concerning the NTCRA excavation and thermal treatment program are

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

Remediation NTCRA, Eastland Woolen Mill Superfund Site, Corinna, Maine, (Weston,

2001). Weston Solutions, (Weston) (2001). Final Completion Report Areas 2,3,4-Lot

88 and 4-Building 4 Soil Remediation Non-time Critical Removal Action, Eastland

Woolen Mill Superfund Site, Corinna, Maine, June 2001; Weston Solutions, (Weston)

(2002). Final Completion Report Areas 1 and 4 Soil Remediation Non-time Critical

Removal Action, Eastland Woolen Mill Superfund Site, Corinna, Maine, June 2001

NTCRA In-Situ Treatment Program:

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

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

Building 14 Area. These remaining soils are located in the saturated zone between

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

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

oxidation (ISCO). EPA also retained the USAGE to implement this component of the

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

remaining NTCRA activities.

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

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

ISCO injector wells in Area 1 to depths ranging from 35 to 40 ft bgs. Following

injector installations, a field-scale pilot study was performed by a subcontractor to

Nobis, Xpert Design and Diagnostics (XDD), and Nobis in November 2004. The pilot

study was designed to evaluate effectiveness of two potential oxidant technologies,

Fenton's reagent and iron-catalyzed sodium persulfate (ICP). The Fenton's Study Area

consisted of injection of 10,000 gallons of sulfuric acid and 11,534 gallons of hydrogen

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

5,580 gallons of persulfate and chelated Fe+2 catalyst into two injection wells.
The results of this pilot study indicated that ICP achieved superior subsurface

distribution relative to Fenton's reagent due to its longer reaction half-life. Based on

post-pilot study soil sampling, a 48% total mass reduction was estimated over the pilot

study area (XDD, 2005a). Based on these results, ICP was selected as the oxidant for

full-scale treatment application for the NTCRA ISCO program. The NTCRA ISCO

Pilot Study was also incorporated in the Remedial Design for the OUI ISCO program

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

Action ISCO programs.

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

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

Phase II, which included the contaminated soil associated with Area 1.

Phase I Activities:

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

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

small quantity of contaminated soil that was present in the vadose zone adjacent to the

loading dock. The excavation did not extend below the water table. Analytical results

for confirmation soil samples collected from base of the excavation indicated

contaminated soil remain in-place at depths below the water table (approximately 6 ft

bgs).

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

Building 14 Area to depths ranging from 15 to 30 ft bgs. ISCO treatment consisted of

two full-scale injections of ICP, followed by confirmatory soil borings and ground water

sampling. These injections were performed in July and October/November 2005. A

total of 13,319 gallons of persulfate solution (22,120 Ibs of oxidant) and 13,514 gallons

of chelated iron solution were delivered to the UST and Building 14 areas.

Confirmatory soil borings and groundwater sampling indicated an approximate 90%

reduction of dissolved phase contamination and an approximate 71% reduction in

sorbed phase soil contamination following the Phase I ICP applications. The Phase I

Task Plan (Nobis, 2005b) and the Chemical Oxidation Phase I ISCO Work Plan (XDD,

2005b) describe in detail the activities that were performed to complete the NTCRA

source reduction in this area. The 2005 Phase I and Phase II ISCO Remedial

Performance Assessment documents that the ISCO has been successful in reducing the

mass of contamination in the Phase 1 Area. The NTCRA for the Phase 1 area is

complete. The OU I Remedial Action will include long-term monitoring of the Phase I

Area to confirm whether groundwater restoration is achieved.

Phase II Activities:

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

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

Approximately 19,256 gallons of persulfate (31,947 Ibs of oxidant) and 19,423 gallons

of chelated iron solution (2,429 Ibs) were delivered to the Phase II treatment area.
Confirmatory groundwater sampling performed following full-scale [SCO application

indicated a reduction of dissolved phase contamination by approximately 63%. Soil

sampling performed following the ISCO Pilot study indicated a 38% reduction in

residual DNAPL contamination. The Phase II Task Plan (Nobis, 2004b) and Phase II

Full Scale ISCO Injection Plan - Application #1 (XDD, 2005c) describe the activities

that were performed to further the completion of NTCRA source reduction in this area.

The 2005 Phase I and Phase II ISCO Remedial Performance Assessment Eastland

Woolen Mill Superfund Site, Non-Time Critical Removal Acion, Corinna, Maine, May

2006 documents that the ISCO has been successful in reducing the mass of

contamination in the Phase II Area. The Phase II program will continue as part of the

OU I Remedial Action that targets

3. Enforcement

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

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

family-owned company is now defunct (it ceased operations shortly after completing a

reorganization plan pursuant to Chapter 7 of the Bankruptcy Code), and most of its

officers are deceased.

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

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

abandonment, and the Town of Corinna acquired its title through tax

foreclosure/eminent domain. There is currently one private owner of a portion of the

Mill complex who acquired title at a creditor's auction.

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

B. Planned Removal Activities

There are no additional planned removal activities. All of the. removal actions required

by the Action Memoranda have been completed.

C. Next Steps

No additional removal activities are anticipated at the Site. A detailed summary of the

removal activities is presented in the Preliminary Close-Out Report and

D. Key Issues

There area no key issues at this Site relative to the NTCRA.
V. Cost Information

The removal ceiling for this NTCRA is $61,000,000. There are no previous removal

actions that contribute to the ceiling. The current level of expenditure for the NTCRA

is $59,178,973. There are likely to be some trailing cost due to the time lag for

invoices and payment that will increase this cost to just under the ceiling of

$61,000,000.

VI. Disposition of Waste

The majority of the contaminated soil was excavated, treated to meet cleanup levels,

and used on-site as fill. Soil that did not meet the cleanup levels was transported to an

off-site facility. Treatment plant residuals were also transported to off-site facilities.

The disposition of waste is documented in Final Completion Report Areas 2, 3, 4-Lot

88 and 4-Building 4 Soil Remediation Non-time Critical Removal Action, Eastland

Woolen Mill Superfund Site, Corinna, Maine, June 2001. Final Completion Report

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

Mill Superfund Site, Corinna, Maine, June 2001