FIVE-YEAR REVILW REPORT FOR
SACO TANNERY WAST* PITS SIPERFl NB SIT t
YORK COUNTY, MAINE
m
Prepared by
I'.Si. Fnvimiimi-lllHl l'POt«eH(Hl Agency
lUftinit 1
BOS1 ON, MASS A CI 1IISETTS
-4S^ Vlil-illA-
Jamts T.|^»ieua, 111, Director/ , Unlf
Office Of kite KtkKillilion HniilRtMuruiigU
SDMS Doc ID 564059
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2014 FIVE-YEAR REVIEW
SACO TANNERY WASTE PITS SUPERFUND SITE
TABLE OF CONTENTS
EXECUTIVE SUMMARY 1
I. INTRODUCTION 5
II. PROGRESS SINCE THE LAST REVIEW 5
III. FIVE-YEAR REVIEW PROCESS 7
IV. TECHNICAL ASSESSMENT 21
V. ISSUES/RECOMMENDATIONS AND FOLLOW-UP ACTIONS 25
VI. PROTECTIVENESS STATEMENTS 26
VII. NEXT REVIEW 26
TABLES
1 Protectiveness Determinations/Statements from the 2008 FYR 6
2 Status of Follow-up Actions from the 2008 FYR 6
3 Groundwater Sampling Results Since the 2008 FYR 10
4 Sediment Sampling Results Since the 2008 FYR 19
5 Groundwater Standards since the 1989 ROD 23
6 Issues and Recommendations/Follow-up Actions 25
FIGURES
1 Monitoring Locations 11
2 O&M Plan Sampling Locations 12
3 Arsenic Concentrations in Overburden Wells, 1992-2013 13
4 Chromium Concentrations in Overburden Wells, 1992-2013 13
5 Lead Concentrations in Overburden Wells, 1992-2013 14
6 Manganese Concentrations in Overburden Wells, 1992-2005 14
7 Arsenic Concentrations in Bedrock Well MW-101,1992-2013 15
8 Arsenic Concentrations in Bedrock Well MW-114B, 1992-2013 15
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9 Chromium Concentrations in Bedrock Wells, 1992-2013 16
10 Lead Concentrations in Bedrock Wells, 1992-2013 16
11 Manganese Concentrations in Bedrock Wells, 1992-2005 16
APPENDICES
A EXISTING SITE INFORMATION
B ADDITIONAL FIGURES FOR REFERENCE
C PRESS RELEASE ANNOUNCING FIVE-YEAR REVIEW
D DOCUMENT REVIEW LIST and REFERENCES
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LIST OF ACRONYMS
ACL
Alternate Concentration Limit
ARAR
Applicable or Relevant and Appropriate Requirement
AWQC
Ambient Water Quality Criteria
BDL
Below Detection Limit
COC
Contaminant of Concern
CERCLA
Comprehensive Environmental Response, Compensation, and Liability Act
CFR
Code of Federal Regulations
EPA
U.S. Environmental Protection Agency
ESD
Explanation of Significant Differences
ET
Ecotox Threshold benchmark value
FAME
Finance Authority of Maine
FSSB
Freshwater Sediment Screening Benchmarks
FYR
Five-Year Review
MCL
Maximum Contaminant Level
MEDEP
Maine Department of Environmental Protection
MEGs
Maximum Exposure Guidelines
mg/kg
milligrams per kilogram
NCP
National Contingency Plan
NPL
National Priorities List
O&M
Operations and Maintenance
ppb
parts per billion
ppm
parts per million
RAG
Remedial Action Guideline
RAO
Remedial Action Objective
RI/FS
Remedial Investigation/Feasibility Study
ROD
Record of Decision
SEL
Severe Effect Level
ssc
Superfund State Contract
svoc
Semi-volatile organic compound
TBC
To be Considered
TCL
Target Compound List
VOC
volatile organic compound
^g/1
micrograms per liter
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EXECUTIVE SUMMARY
This is the fourth Five-Year Review (FYR) for the Saco Tannery Waste Pits Superfund (Site)
located in Saco, York County, Maine. The purpose of this FYR is to review information to
determine if the remedy is and will continue to be protective of human health and the
environment. The triggering action for this statutory FYR was the signing of the previous FYR
on December 30, 2008.
In 1956, a tanning company purchased the Site for disposal of its process wastes. The process
wastes characteristically had high concentrations of chromium, volatile organic compounds,
semi-volatile organic compounds, acids, leather hides and scraps. For nearly two decades,
wastes were disposed in two lagoons (approximately two acres each in size) and 57 smaller
disposal pits. By the early 1980s the tanning company went bankrupt and the title transferred to
a state agency, the Finance Authority of Maine (FAME).
Investigations in the early 1980s and a removal action in 1983 were followed by completion of a
Remedial Investigation/Feasibility Study in October 1987. A Record of Decision (ROD) was
signed on September 27, 1989. The ROD set forth a remedy that combined a source control
cover system with institutional controls to restrict access and use of the Site and a monitoring
program. The primary contaminants of concern affecting on-site soil, groundwater, surface
water, and sediment were determined to be arsenic, chromium, lead, manganese, chlorobenzene,
and bis(2-ethylhexyl)phthalate. Safe Drinking Water Act Maximum Contaminants Levels
(MCLs) were set as the action levels for all groundwater contaminants, except arsenic at four
locations where alternate concentration limits were established.
On May 22, 1989, the Maine state legislature passed a Legislative Resolve that permanently
converted the Site to a wildlife preserve. The Legislative Resolve prohibits development for
residential or commercial use, excavation that penetrates the soil cover systems, and utilization
of the groundwater as a drinking water source. In addition to the Legislative Resolve, in 1991 a
Conservation Easement was implemented on the property as a further assurance of the
restrictions on future land use.
An Explanation of Significant Differences (ESD) was signed on January 16, 1993. The ESD
changed the compensatory wetland requirement of the ROD to allow for the purchase of an off-
site wetland area, the Saco Heath, because insufficient acreage was available on the Site to
mitigate the wetlands lost as a result of the construction of the soil covers. The ESD also
allowed water collected from dewatering the pits and lagoons to be treated onsite and used for
dust suppression during construction of the soil cover systems rather than transported offsite for
disposal.
Source control preparation activities were completed in the fall 1992. Construction of the soil
cover systems took place from March through October 1993. Between April 1990 and March
1995, EPA conducted the monitoring program that included quarterly sampling of on-site
monitoring wells, semi-annual surface water and sediment sampling, and annual sampling of
residential wells on Flag Pond, Jenkins and Hearn Roads. In April 1995, responsibility for the
monitoring program was transferred to Maine Department of Environmental Protection
(MEDEP).
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MEDEP and FAME continue operation and maintenance under a division of responsibility
defined in a 1991 Memorandum of Agreement and 2001 Amended Memorandum of Agreement.
The operation and maintenance activities have been modified since the last five-year review.
MEDEP has reduced the groundwater and sediment sampling frequency to every two years, has
reduced the number of monitoring wells sampled, and has proposed further modifications to the
monitoring program. EPA concurred with the changes in frequency and number of wells and is
reviewing the latest proposal.
Based on the data reviewed, observations from the site inspection, and interviews, the remedy is
functioning as intended by the ROD. The source control portion of the remedy is complete and
inspections have confirmed that the remedy is functioning as designed and remains protective of
human health and the environment. Groundwater and sediment monitoring continue, as does
maintenance, although ongoing vandalism remains a concern. The effective implementation of
institutional controls prohibiting development and use of Site groundwater have prevented
exposure to Site soils and groundwater. Although vandalism has created openings in the interior
fencing, the cover systems remain intact.
The primary ARARs for groundwater on the Site are the MCLs and 1992 Maine Maximum
Exposure Guidelines. While the MCL for arsenic has been reduced to 10 |ig/l, and a number of
the monitoring wells exceed this value, the restriction on groundwater use prevents any
exposure.
Land use at the Site and adjacent properties has not changed appreciably since the previous five-
year review and is not expected to change, and there are no additional routes of exposure.
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Five-Year Review Summary Form
SITE IDENTIFICATION
Site Name: Saco Tannery Waste Pits Superfund Site
EPA ID:
MED980520241
Region: 1
State: Maine
City/County: Saco/York County
NPL Status: Deleted
Multiple OUs?
No
Has the site achieved construction completion?
Yes
Lead agency: State
[If "Other Federal Agency", enter Agency name/: Click here to enter text
Author name (Federal or State Project Manager): Terrence Connelly
Author affiliation: EPA
Review period: 6/26/2013 - 9/30/2014
Date of site inspection: December 10, 2013, and April 9, 2014
Type of review: Statutory
Review number: 4
Triggering action date: 12/30/2008
Due date (fiveyears after triggering action date): 12/30/2013
Issues/Recommendations
Issues and Recommendations Identified in the l"i\e-Year Rexiew:
OU(s): Sitewide
Issue Category: Site Access/Security
Issue: Ongoing vandalism
Recommendation: Partner with local groups to create solution
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
No
Yes
MEDEP/FAME
MEDEP
7/30/2015
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Issues and Recommendations 1 dentil'ied in (lie l"i\e-Year Rcxicw:
OU(s): Sitewide
Issue Category: Remedy Performance
Issue: Potential Sediment Toxicity
Recommendation: Evaluate sediment toxicity to aquatic organisms
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
No
Yes
MEDEP
MEDEP
7/30/2018
Protectiveness Statement(s)
Site-wide Protectiveness Statement
Protectiveness Determination: Addendum Due Date (if applicable):
Short-term Protective
Protectiveness Statement: The site-wide remedy currently protects human health and the environment
because the remedy is functioning as designed. Institutional controls restrict future use of the Site and
its groundwater. However, in order for the remedy to be protective in the long-term, a solution is
needed to prevent ongoing vandalism of the interior fencing and gates, and an evaluation of potential
sediment toxicity to aquatic organisms should be performed.
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I. INTRODUCTION
The purpose of a Five-Year Review (FYR) is to evaluate the implementation and performance of
a remedy in order to determine if the remedy will continue to be protective of human health and
the environment. The methods, findings, and conclusions of reviews are documented in five-
year review reports. In addition, FYR reports identify issues found during the review, if any, and
document recommendations to address them.
The U.S. Environmental Protection Agency (EPA) prepares FYRs pursuant to the
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section
121 and the National Contingency Plan (NCP). CERCLA 121 states:
If the President selects a remedial action that results in any hazardous substances,
pollutants, or contaminants remaining at the site, the President shall review such
remedial action no less often than each five years after the initiation of such remedial
action to assure that human health and the environment are being protected by the
remedial action being implemented. In addition, if upon such review it is the judgment of
the President that action is appropriate at such site in accordance with section [104] or
[106], the President shall take or require such action. The President shall report to the
Congress a list offacilities for which such review is required, the results of all such
reviews, and any actions taken as a result of such reviews.
EPA interpreted this requirement further in the NCP; 40 Code of Federal Regulations (CFR)
Section 300.430(f)(4)(ii), which states:
If a remedial action is selected that results in hazardous substances, pollutants, or
contaminants remaining at the site above levels that allow for unlimited use and
unrestricted exposure, the lead agency shall review such actions no less often than every
five years after the initiation of the selected remedial action.
EPA has conducted three FYRs on the remedy implemented at the Saco Tannery Waste Pits
Superfund Site (Site) in Saco, York County, Maine. EPA was the lead agency for developing
and implementing the remedy for the Site. Maine Department of Environmental Protection
(MEDEP), as the support agency representing the State of Maine during the implementation of
the remedy, has been the lead agency since 1995. MEDEP reviewed all supporting
documentation and provided input to EPA for each FYR.
This is the fourth FYR for the Site. The triggering action for this statutory review is December
30, 2008, the completion date of the third FYR. This FYR is required since hazardous
substances, pollutants, or contaminants remain at the Site above levels that allow for unlimited
use and unrestricted exposure. The Site consists of one Operable Unit.
II. PROGRESS SINCE THE LAST REVIEW
The third Five-Year Review Report was signed on December 30, 2008. The 2008 review found
that the site-wide remedy was protective because the remedial activities have been implemented
and are complete. Institutional controls have been enacted (a 1989 State of Maine Legislative
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Resolve and a 1991 Conservation Easement) that prohibits use of groundwater and restricts
future use of the Site. Tables 1 and 2 below present the protectiveness determination and follow-
up actions from the 2008 FYR. The 2008 FYR did not identify any issues or any
recommendations but did note two follow-up actions.
Table
L: Protectiveness Determinations/Statements from the 2008 FYR
ou#
Protectiveness
Determination
Protectiveness Statement
1
Protective
Because the remedial actions implemented for the Site are protective, the Site is protective
of human health and the environment. The soil cover systems constructed under the
source control remedy are functioning as designed and remain in good condition, thus
preventing contact with soils and sludge in the pits and lagoons. Institutional controls,
including the resolution creating a wildlife preserve at the Site, the conservation easement
restricting future use of the Site and its groundwater, and fencing restrict access to the soil
cover systems and prevent exposure to soils and groundwater ensuring the Site remains
protective of human health and the environment. Groundwater and sediment monitoring
have shown reductions in concentrations of contaminants of concern, below many of the
target levels established in the ROD. The monitoring results demonstrate that there is no
off-site migration and on-site contamination is identifiable and localized. The monitoring
program will continue to ensure that concentrations remain within acceptable ranges.
Table 2: Status of Follow-up Actions from the 2008 FYR
OU#
Issue
Follow-up Actions
Party
Responsible
Oversight
Party
Original
Milestone
Date
Current
Status
Completion
Date (if
applicable)
1
No issues
identified
Continue O&M
activities and
periodically review
to assure that they
remain current with
site conditions
State
EPA
None
Ongoing
1
No issues
identified
Monitor chromium
concentrations in
downstream
locations as they
appear to have
increased
State
EPA
None
Ongoing
Follow-up Action 1
• O&M activities continue through a contract that the Finance Authority of Maine (FAME)
has with the City of Saco and contractors with oversight provided by MEDEP.
Follow-up Action 2
• Sediment samples have been collected three times (2009, 2011, and 2013) since the last
five-year review and are discussed in Section III below.
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Remedy Implementation Activities
No remedial implementation activities were performed since the previous FYR.
System Operation/Operation and Maintenance Activities
The first Operation and Maintenance (O&M) plan for the Site was prepared as part of the
September 1992 Remedial Design Report, and it was included in the 1993 Superfund State
Contract. MEDEP has periodically updated the O&M Plan with the last update made February
2, 2009. The O&M activities include periodic inspections and maintenance, annual mowing of
and around the soil covers, and performing all necessary repairs due to erosion, burrowing
animals, off-road vehicles and other forms of cover damage with adequate materials. Inspection
observations and details of any maintenance and repairs are required to be documented in an
Inspection and Maintenance Report that is to be submitted after each Site inspection is
conducted.
During this five-year period, the Site was inspected on August 31, 2010; July 8, 2011; October
16, 2012; and August 21, 2013, by a contractor for FAME. Damage to the fences and gates,
either damaged by trees falling or vandalism, have been noted in the inspection reports and have
been repaired but documentation of these repairs were not submitted to MEDEP. The inspection
reports do not indicate any problems with the soil cover systems, roads, or drainage culverts.
III. FIVE-YEAR REVIEW PROCESS
Administrative Components
MEDEP was notified of the initiation of the five-year review on June 26, 2013. The FYR was
led by Terrence Connelly, EPA's Remedial Project Manager for the Site. Danielle Obery of
MEDEP assisted in the review as the State Project Manager.
The review consisted of the following components:
• Community Involvement;
• Document Review;
• Data Review;
• Site Inspection; and
• Five-Year Review Report Development and Review.
Community Notification and Involvement
Activities to involve the community in the five-year review process were initiated by the
Remedial Project Manager in June 2013 with a summary of the Site sent to the regional team.
Per Region 1 policy, a region-wide press release announcing all upcoming five-year reviews in
New England was sent to all regional newspapers including the Portland Press Herald. The press
release was sent on May 9, 2013 and is attached in Appendix B. The results of the review and
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the report will be made available at the Site information repository located at:
Saco City Hall1
300 Main Street
Saco, Maine 04072
and at
Superfund Records Center
US Environmental Protection Agency
5 Post Office Square, Suite 100
Boston, MA 02109-3912
Document Review
This five-year review consisted of a review of relevant documents including O&M records and
monitoring data provided by FAME/MEDEP. Groundwater and surface water cleanup standards
and sediment target clean-up levels, as listed in the September 1989 Record of Decision (ROD),
were also reviewed.
Data Review - Groundwater
The 1989 ROD set MCLs as the groundwater performance standards for the six groundwater
Contaminants of Concern: arsenic, chromium, lead, manganese, chlorobenzene, and bis(2-
ethylhexyl)phthalate (plus four individual Alternate Concentration Limits (ACLs) for arsenic).
During this review period, 2008-2013, groundwater samples were collected from nine
monitoring wells on a biennial schedule. (See Figure 1 for sampling locations. Figure 2 also
shows the sampling locations relative to the five waste management areas that are enclosed by
fencing. In Appendix B, Figure 2 identifies the individual waste pits and the two lagoons.)
Analysis of the groundwater data since the 2008 FYR follows below and the data from this
review period are presented in Table 3. Historical data from 1992 (pre-remedy through 2013 are
presented on Figures 3-11.
Arsenic
The 1989 ROD established ACLs for four overburden monitoring wells: MW-101, MW-103,
MW-11 IB, and MW-114. For the remainder of the monitoring wells, the arsenic performance
standard was the MCL. At the time of the ROD, the arsenic MCL was 50 ug/L. The MCL was
revised to 10 |ig/l in 2001 and became effective in February 2002. During this review period,
arsenic concentrations exceeded the ACL of 123 ppb in MW-103 which is consistent with
previous review periods in both the location (concentrations were below the respective ACLs at
the other three wells) and the concentrations detected. Also during this review period, there have
been eight exceedances of the revised MCL in the other five wells in the long-term monitoring
program, with concentrations ranging from 12 to 24 jj.g/1. For these wells the concentrations
appear stable with little fluctuation since the last FYR in 2008.
1 Dyer Public Library served as the original local repository for the Site but after years of no requests for the Site's
Administrative Record, the library transferred the Record to City Hall on December 9, 2004.
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Chromium
The MCL for chromium is 50 ju.g/1. Since the completion of the remedial actions in 1993,
concentrations of chromium (the metal foremost associated with tanning operations) have been
below the detection limit at all locations except at MW-114B, where concentrations have ranged
from below the detection limit up to 160 jj.g/1. During this review period, chromium
concentrations at MW-114B fluctuated between 13 and 73 jj.g/1.
Lead
The action level for lead is 15 jj.g/1. Since the completion of the remedial actions in 1993,
concentrations of lead have been below the detection limit of between 5-10 ug/1 in 27 of the 29
sampling events. (Seven of nine wells exceeded the action level in April 2002 and lead was
reported at all nine wells in November 2006 with one exceedance. Given the entire data history,
these two separate events appear to be outliers, possibly caused by cross-contamination either in
the field or in the laboratory.)
Manganese
Manganese concentrations exceeded the Maine 2000 MEG (a TBC) of 500 ug/L in six of the
nine monitoring wells in 2003 through 2005. In the 2005 hydraulic assessment, MEDEP noted
that manganese concentrations had remained stable since monitoring began with no marked
decline in concentrations following the completion of the remedial actions in 1993.
Consequently, with these stable results and recognition that manganese is not associated with the
tanning industry, MEDEP recommended discontinuation of monitoring for manganese. EPA
concurred with this recommendation and manganese was dropped from the long-term monitoring
program in 2005. For historical purposes, charts of manganese concentrations from 1992-2005
are included in this report
Chlorobenzene (also identified as monochlorobenzene)
Following the 2005 hydraulic assessment, MEDEP discontinued monitoring for
monochlorobenzene except at MW-114A. This was done because for the other eight wells in the
long-term monitoring program, six never exceeded the MCL (100 |ig/l) and the other two wells
only exceeded the MCL once each. The MCL was exceeded slightly at MW-114A seven times
(100-130 |ig/l) from 2000 - 2005 but has not been exceeded in the five sampling events since
2005.
Bis(2-ethylhexvDphthalate
Sampling has not been performed for bis(2-ethylhexyl)phthalate after MEDEP assumed O&M
responsibilities in 1995. It was listed as a COC in the 1989 ROD after it was detected in four of
thirty-two groundwater samples (reported concentrations of 10, 16, 24, and 1,500 jj.g/1. The well
with the reported 1,500 jj.g/1 had no other COCs, nor did the four other wells in the vicinity). The
current Maine MEG is 30 ju.g/1. At the time of the Remedial Action in 1993, the MEG was 4
|ig/l. The MCL is 6 |ig/l. In the twenty quarterly monitoring rounds performed by EPA from
April 1990 through March 1995, 256 samples from monitoring wells and 50 samples from
residential wells were analyzed for bis(2-ethylhexyl)phthalate. It was detected twice in
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monitoring wells above the laboratory detection limit (ranging from 0.7 to 10 jj.g/1), at 25 and 46
|ig/l, and once in a residential sample at 40 jj.g/1.
Table 3: Groundwater Sampling Results Since the 2008 FYR
Arsenic
MCL 10 ng/l *
ACL- well specific
Chromium
MCL 50 ng/l
Lead
Action Level 15 \xg/\
Sampling
Location
2009
2011
2013
2009
2011
2013
2009
2011
2013
MW-1
14
16
15
<10
15U
10U
<10
5U
5U
MW-101
ACL 70 ng/l
40
29
59
<10
15U
10U
<10
5U
5U
MW-114A
15
16
24
<10
15U
10U
<10
5U
5U
MW-114B
ACL 77 |ig/l
12
8U
8U
13
56
73
<10
5U
5U
MW-111A
<10
12
8U
<10
15U
10U
<10
5U
5U
MW-111B
ACL 64 ng/l
22
8U
8U
<10
15U
10U
<10
5U
5U
MW-113A
<10
8U
15
<10
15U
10U
<10
5U
5U
MW-3
<10
8U
8U
<10
15U
10U
<10
5U
5U
MW-103
ACL 123 ng/l
19
199
127
<10
15U
10U
<10
5U
5U
Monochlorobenzene
MCL 100
MW-114A
69
72
1U
* The arsenic MCL was 50 ng/l at the time of the ROD; in 2001, it was revised to 10 ng/l
Bold: exceeds performance standard
U: Undetected at this concentration
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11
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Figure 2: Operation and Maintenance Plan Sample Locations
Saco Tannery Waste Pits
12
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Figure 3: Arsenic Concentrations in Overburden Wells, 1992-2013
Arsenic Overburden MWs
350
_ 300
_i
^ 250
| 200
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OJ
£ 150
¦ 1 ¦
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u
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~ MW-101
¦ MW-103
~ MW-111B
X MW-114B
MEG 10 ug/L
Figure 4: Chromium Concentrations in Overburden Wells 1992-2013
Total Chromium Overburden MWs
1000
— 100
o
'+-»
(D
10
O
U
X
~
ii
X
>
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~ MW-101
¦ MW-103
~ MW-111B
X MW-114B
MEG 20 ug/L
MCL 100 ug/L
13
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Figure 5: Lead Concentrations in Overburden Wells, 1992-2013
40
^ 35
30
T 25
o
'« 20
15
10
o
u 5
0
Lead Overburden MWs
A
¦
¦
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r
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t
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i >
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^ ¦
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' c/
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' ^
1111111
i i i i i i
/
~ MW-101
¦ MW-103
~ MW-111B
X MW-114B
MEG 10 ug/L
MCL15 ug/L
4000
3500
^ 3000
2500
0
2000
1 1500
5 iooo
u
Figure 6: Manganese Concentrations in Overburden Wells, 1992 -2005
Manganese Overburden MWs
d
k
¦
A A
¦
A
~
A A
<~
A
¦
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n-r-i-A
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0
05/01/92 05/01/94 05/01/96 05/01/98 05/01/00 05/01/02 05/01/04
~ MW-101
¦ MW-103
~ MW-111B
X MW-114B
MEG 500 ug/L
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Figure 7: Arsenic Concentrations in Bedrock Well MW-101,1992-2013
100
90
80
70
WJ
3
60
C
o
E
50
+-»
c
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Figure 9: Chromium Concentrations in Bedrock Wells, 1992-2013
Total Chromium Bedrock MWs
100 *
bJQ
f 10
O
"+-»
(D
X
<
X
X
X
X
<
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A
MW-113A
X
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X
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MEG 500 ug/L
05/01/92 05/01/94 05/01/96 05/01/98 05/01/00 05/01/02 05/01/04
16
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Data Review - Surface Water and Sediment
The 1989 ROD set Ambient Water Quality Criteria as the surface water cleanup target for the
same six Contaminants of Concern as in groundwater: arsenic, chromium, lead, manganese,
chlorobenzene, and bis(2-ethylhexyl)phthalate. MEDEP discontinued surface water sampling in
1999 because all prior sampling results showed no detections of any Contaminants of Concern.
The 1989 ROD set cleanup target levels for four sediment Contaminants of Concern: arsenic,
total chromium, lead, and antimony. These levels were set for two areas of the Site, beyond
Waste Pit #9 where the berm was incomplete allowing for overland flow and a seep was
identified from Chromium Lagoon #2 (Waste Pit #9 is located in Area 2 [Figure 2 in Appendix
B] and SED-301 is located downstream of the lagoon seep [Figure 2 above]). These target levels
were expanded to include the entire Site in 1993 for the long-term monitoring program. During
this review period, 2008-2013, sediment samples were collected from five locations (See Figure
1 and 2 above for sampling locations) on a biennial schedule.
The total chromium ROD cleanup target level was a "To Be Considered" (TBC) for sediments
based on a risk calculation from a 1980 stream water quality study associated with a Maine
tannery. After this risk-based action level was established in 1989, EPA began using Ecotoxicity
Threshold benchmark values (ETs) for sediment and stream quality screening, comparing
maximum measured contaminant concentrations to an ecotoxicological-based benchmark. As
noted in the 1998 FYR, these values are intended for screening; they are not regulatory criteria,
site-specific cleanup standards, or remediation goals. These screening values in turn have been
supplanted by the Freshwater Sediment Screening Benchmarks (FSSB) developed in 2004 by
EPA Region 3.
Similarly, MEDEP had been using the Ontario Ministry of Environment Severe Effect Level
(SEL) as a screening level. SELs are listed in Guidelines for the Protection and Management of
Aquatic Sediment Quality in Ontario, March 1993. A SEL is defined as the level at which
pronounced disturbance of the sediment-dwelling community can be expected. Now however,
MEDEP also uses the FSSB.
MEDEP has modified the sediment sampling program three times after they took over
responsibility for long-term monitoring of the Site in 1995: the number of locations was
decreased in 1998; the frequency was reduced from semi-annual to annual sampling in 2002; and
following the hydraulic assessment in December 2005, the frequency was further reduced to
every two years. EPA concurred with these modifications.
Since the last five year review in 2008, EPA Region 1 has recommended the use of Threshold
Effect Concentrations (TEC) and Probable Effect Concentrations (PEC) from Macdonald et al
(2000). These consensus-based sediment quality guidelines are based on the geometric average
of five freshwater sediment guidelines. These consensus-based guidelines are viewed as reliably
predicting presence or absence of sediment toxicity.
Sediment data collected since the 2008 FYR are compared against sediment guidelines in Table
4 and are discussed below. Sediment data collected from 1992 to 2013 are presented in Figures
13-17 and provide an overall picture of Site.
17
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Arsenic
Since the 2008 FYR, arsenic concentrations have been within the ROD action level of 60 mg/kg
in four of the five sampling locations. Only SED-301, which is the location closest to the
historical Chromium Lagoon #2 seep, has had arsenic concentrations above the ROD action
level. Both sampling locations downstream of SED-301 (i.e., at locations SED-103 and SED-
104) continue to be below the ROD action level and fluctuate below or slightly above the ET-
ERL and FSSB. Arsenic was higher than the PEC in SED-301 in 2011 and 2013.
Chromium
Chromium continues to be detected in the sediment in the Stuart Brook drainage (SED-204,
SED-301, SED-104, and SED-103) and in the Cascade Brook drainage (SED-101) but all
concentrations are well below the ROD action level of 2,000 mg/kg and four of the five locations
also are below the ET-ERL and FSSB. Only SED-204, which is the location closest to the
surface water divide between the two drainages, had consistently elevated concentrations higher
than the PEC in 2009, 2011, and 2013. Chromium also occurred above the PEC in SED-103 in
2011, but not later. Chromium has not been detected in monitoring wells MW-103 and MW-3,
which are located between the waste pits and the wetlands where SED-204 is located, and the
chromium concentrations at the two downstream sediment locations from SED-204 are about an
order of magnitude lower than at SED-204. This suggests the spillage from Waste Pit #9 has
attenuated within a short distance from Waste Pit #9.
Lead
Lead concentrations have been within its ROD action level of 125 mg/kg since the 2003 FYR.
The lead concentrations at four of the five locations have also been below the ET-ERL, FSSB,
and TEC since the 2008 FYR. As with chromium, the only location with elevated lead
concentrations was SED-204. Lead exceeded the FSSB and TEC in SED-204 in 2013, but did
not exceed the PEC during this five-year review period. This further suggests a limited extent of
spillage from Waste Pit #9.
Antimony
The 1989 ROD set 30 ppm for the target cleanup level for antimony. No ET-ERL or SEL value
has been established for antimony. The 2008 FYR (page 29) provided a detailed review of
antimony data. Antimony was selected as a Contaminant of Concern as result of one detection in
six samples during the 1988 Phase IIRI. In the ten semi-annual sampling events following the
ROD, April 1990 through January 1995, forty-three sediment samples were collected and all but
one October 1993 sample were below the ROD target cleanup level for antimony and almost all
were non-detect (generally less than 10 ppm). Consequently EPA and MEDEP agreed that
antimony did not need to be added to the sediment sampling program.
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Table 4: Sediment Sampling Results Since the 2008 FYR
(all concentrations in mg/kg)
Arsenic
Chromium
Lead
1989 ROD PerfStd
60
2,000
125
ET-ERL
8.2
81
47
1993 Ontario MOE
SEL
33
110
250
2004 FSSB
9.8
43.4
35.8
TEC
9.79
43.4
35.8
PEC
33
111
128
2009
2011
2013
2009
2011
2013
2009
2011
2013
Stuart Brook Drainage
S ED-103
6.8
21
18.6
22
134
28.3
6.9
16
12.7
S ED-104
3
9.3
5.6
22
64.5
39.4
5.1
17.1
12.6
SED-301
38
151
72.6 1 29
69.4
30.9
14
26.4
27.9
S ED-204
<3
5.8
10 i 900
236
1420
39
17.1
70.5
Cascade Brook Drainage
SED-101
<3
0.89
3.9
1.5
18
5.7
ET-ERL: Ecotoxicity Threshold - Effects Range, Low
SEL: Ontario Ministry of Environment - Severe Effect Levels
FSSB: EPA Freshwater Sediment Screening Benchmarks
TEC: Threshold Effect Concentration
PEC: Probable Effect Concentration
Bold: exceeds 1989 ROD performance standard
Shaded: exceeds PEC
Site Inspection
The Site was initially inspected for this FYR on December 10, 2013. In attendance were Terry
Connelly, EPA Remedial Project Manager, Ronald Gonzalez, EPA Site attorney, and Danielle
Obery, MEDEP State Project Manager. Because the Site was covered in snow when the initial
inspection was conducted, a follow-up inspection was conducted on April 9, 2014. In attendance
were Terry Connelly, Danielle Obery, and Jason Langley, MEDEP Hydrogeologist. The purpose
of the FYR inspections was to assess the protectiveness of the remedy.
The Site received about two inches of snow the day before the scheduled December inspection
so it was not possible to observe the conditions of the lagoon and waste pits soil covers. The
inspection did note the absence of any vegetation such as saplings or shrubs or woody stem
plants (roses, raspberries, blackberries, bittersweet) on the soil covers. By the height of the
vegetation on the lagoon and waste pit covers, it appeared that they had been mowed in late fall.
While the front gate was securely locked, several of the interior gates had been removed from the
fence posts.
The Site was inspected again on April 9, 2014, with only small amounts of snow remaining on
the Site roads. The soil cover systems appeared to be well vegetated with no apparent bare spots
nor were any signs of erosion observed. The roads and drainage culverts also were in good
condition. There were no significant blow-downs of trees on the interior fences though the ftve-
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foot wide strip that had been cleared on either side of the interior fences prior to the 2008 FYR
has become overgrown again with woody stem brush and saplings. Of much greater concern,
more damage to the gates had occurred between the two inspections. In more than one location,
it appeared that the gate locks had been burned, apparently to remove them, and several gates
(these are at least ten-foot wide vehicular gates) had been torn from their posts, snapping the
hinges. A section of the fence on the east side of Chromium Lagoon #2 had been disconnected
from the horizontal bars, one vertical steel fence post pulled out of the ground (with its two-foot
concrete footing), and the adjacent pedestrian gate broken from its hinges.
Interviews
During the FYR process interviews were conducted with parties impacted by the Site, including
MEDEP, FAME, and City of Saco, all who are involved in Site activities or aware of the Site.
The purpose of the interviews was to document any perceived problems or successes with the
remedy that has been implemented to date. Interviews were conducted during the five-year
review process and are summarized below.
Per the 1993 Superfund State Contract (SSC) with EPA, the State of Maine is responsible for the
overall operation and maintenance of the Site. In Paragraph 28.B of the SSC, MEDEP and
FAME are identified as the organizational units that are responsible for the operation and
maintenance (O&M) of the Site. MEDEP has been the lead agency for the Site since 1995.
MEDEP is aware of the CERCLA requirement for five-year reviews when waste is left in place
that prevents unrestricted use yet also notes the SSC says "that the State will assure all future
operation and maintenance of response actions at the Site, for thirty years from the start date of
Operations and Maintenance." With the 1995 start date, it is now nearly twenty years since the
State of Maine assumed O&M responsibility for the Site and believes it is time to start planning
for the completion of its responsibilities. MEDEP seeks to allocate the appropriate resources to
assure the continued protectiveness of the remedy and fulfill its obligations. Within that context
and with the remedy functioning as intended, MEDEP is receptive to finding a local or another
State entity that will be able to manage the Site in a more suitable manner.
FAME acquired the Site in the early 1980s when the prior owner, NKL Tanning Inc., who used
the Site as collateral for a FAME-backed loan, went bankrupt. Per a Memorandum of
Agreement with MEDEP, FAME is responsible for the O&M of the Site. FAME has contracted
with the City of Saco Public Works Department and local contractors to perform the annual
inspections and O&M activities and is pleased that these activities have kept on top of Site
conditions. FAME officials are aware of the recent increase in vandalism. For the short-term
FAME is reaching out to law enforcement agencies for assistance. For the long-term, FAME is
also receptive to working with local and State entities to find a more lasting solution to the
vandalism and management of the Site. FAME acknowledged the CERCLA requirement for
five-year reviews while hopeful that someday that requirement would end and also seeks
clarification of the thirty-year assurance in the SSC.
Discussions were held with City of Saco officials in the Economic and Development and
Planning Departments. City Hall serves as the repository for the Administrative Record; because
it has been years since anyone asked to review the Administrative Record, it has been moved
into storage space within City Hall.
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Both departments expressed interest in returning the Site to some use, understanding the
restraints placed on the Site by the Legislative Resolve and Conservation Easement.
The City of Saco's March 2011 Comprehensive Plan, zoning ordinances, and tax maps were
reviewed. The Comprehensive Plan "serves as a guide for the decisions the City must make
about growth, development, redevelopment, and change over the coming decade. The Plan
continues the City's established long range planning process, and creates a framework for
managing future development." For the Site and surrounding area, the Comprehensive Plan
seeks to maintain its rural character, directing development elsewhere where city services are
available.
The Site and surrounding area is zoned C-l Conservation District. The C-l District zoning is
designed to promote and preserve agriculture and open space, while permitting low density
residential uses that do not conflict with this overall purpose (City of Saco Zoning Ordinance,
amended through July 2013). This zoning designation and definition have not changed since at
least the 2003 FYR (the 1998 FYR did not state what the zoning was).
A comparison of 2008 and 2013 tax maps indicated a net increase of two properties in five years
(four properties have been sub-divided while four other properties shown on the 2008 maps have
since been merged into two properties). This is another indication of the land use stability in the
surrounding area.
IV. TECHNICAL ASSESSMENT
Question A: Is the remedy functioning as intended by the decision documents?
Yes.
Remedial action performance. The 1998 FYR noted that the remedy had achieved all four
Remedial Action Objectives and that exposures through direct contact or ingestion of soils and
groundwater had been eliminated by the cover systems and restrictions formalized in the
Legislative Resolve and Conservation Easement. This generally continues to be the case for this
FYR (except for the ongoing vandalism allowing access to the fenced areas). The cover systems
remain in good condition, and future land and groundwater use is restricted. The groundwater is
meeting the lead standard at all nine locations and the chromium standard at eight locations.
Arsenic exceeded either the individual ACL or the new MCL in ten of the twenty-seven samples
collected during this FYR period, but there was no trend of increasing concentrations. With the
possible exception of chromium and lead, concentrations in sediment remain stable. The ROD
target cleanup levels are being met, but with some exceedances of the FSSB, TEC, and PEC
values.
Operations and Maintenance. The required "operational and functional" periods for each
component of the Site remedy have been successfully completed. EPA was responsible for
monitoring from 1990 to 1995, when O&M responsibilities were transferred to MEDEP.
MEDEP and FAME have continued the O&M activities at the Site under a division of
responsibility defined in a 1991 MO A (and as amended in 2001). The O&M activities have been
modified since MEDEP prepared the 1995 O&M Plan. The Plan allows for reevaluation and
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changes to inspection frequency, monitoring frequency, and analyses. Site inspections have been
performed regularly since the 2008 FYR and have been appropriately documented although
documentation of repairs have not been submitted. Annual mowing of the cover systems has not
always occurred, but there has not been any emergence of woody-stem vegetation on the soil
covers. Fencing and gates that have been repaired have been targets of subsequent vandalism
and the vandalism remains an issue.
Opportunities for Optimization. Based on the extensive post-construction monitoring history,
MEDEP has proposed further reductions in both monitoring frequency, monitoring locations,
and analyses. With conditions stable, institutional controls in place that prevent the use of
groundwater and land use in the surrounding area having changed little (three homes built in the
twenty years since remedy construction), it may be appropriate to reduce the monitoring to once
in the year preceding the five-year reviews. It is recommended that, if these modifications are
made, they are conditioned on development of a stronger arrangement for site inspections and
more frequent sediment and surface water sampling as part of an evaluation of potential sediment
toxicity due to the exceedances of PECs at SED-204 and SED-301.
Indicators of Remedy Problems. The continuing vandalism of the interior fences and gates raises
concern over potential damage to the soil cover systems and thereby increasing O&M costs.
Implementation of Institutional Controls and Other Measures. There has been no change in the
institutional controls since the 2003 FYR which described the 1989 State of Maine Legislative
Resolve and the 1991 Conservation Easement placed on the property. Both documents were
appended to the 2008 FYR. As noted above, although the fencing and gates have been
vandalized, to date, the soil cover systems have remained intact and there is no indication of
exposure to the waste.
Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action
objectives (RAOs) used at the time of the remedy selection still valid?
Yes.
Changes in Standards and TBCs. There have not been any changes to ARARs since the 2008
FYR. The Maine Maximum Exposure Guidelines for Drinking Water (MEGs) were last updated
in 2012 and are TBCs. EPA and MEDEP now use EPA's FSSB rather than ET-ERL or SEL as
the TBC for sediment. Although EPA Region 1 prefers the use of TECs, the TECs for arsenic,
chromium, and lead are the same as the FSSBs for these chemicals.
There are no current chemical-specific ARARs that apply to soil contaminants at the Site.
Guidance that was written following the 1989 ROD includes the 1997 Maine Remedial Action
Guidelines (RAGs) developed for three exposure scenarios, e.g. residential, trespasser, and adult
worker. With the Legislative Resolve and Conservation Easement in place on the Site, the only
potentially applicable scenario is a trespasser. The trespasser RAG for lead in soil is 700 mg/kg,
significantly above the 125 mg/kg target level established in the ROD. The trespasser RAG for
arsenic in soil is 30 mg/kg, or half the 60 mg/kg target level. Although the interior fences are not
secure because of vandalism, there were no signs that the soil cover systems had been negatively
affected and therefore this potential route of exposure is highly unlikely to be occurring at the
Site.
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The chemical-specific ARARs that apply to groundwater contaminants are MCLs and 1992
MEGs (the 1992 MEGs were promulgated by reference and are ARARs whereas subsequent
values have not been promulgated and are TBCs). The MEGs have been updated several times
since the 1989 ROD, most recently in 2012. The MCL for arsenic was lowered to 10 |ig/l
effective February 2002. The MCL for chromium was increased from 50 ju.g/1 to 100 jug/1 in
1994. The MCL for monochlorobenzene (100 |ig/l) was established after the ROD was signed.
A comparison of the MCLs in effect at the time the ROD was signed (1989), the current MCLs,
and the 1992 MEGs and 2012 MEGs is shown in the table below.
Table 5: Groundwater Standards and TBCs since the 1989 ROD
Contaminant
MCL at ROD
(ng/i)
Current MCL
(ng/i)
1992 MEG
(ng/i)
2012 MEG
(TBC) (ng/l)
Arsenic
50
10
NS1
10
Chromium
50
100
100
20
Lead
152
15
20
10
Manganese
NS
NS3
200
500
Monochlorobenzene
NS
100
47
100
Bis (2-ethylhexyl) phthalate
NS
6
25
30
NS- No Standard
2Action Level; no MCL established
3EPA Health Advisory, a TBC, for manganese is 300 ug/L
The 1989 ROD set chemical-specific target cleanup levels for sediments. The total chromium
target level was risk-based. After the ROD, EPA began using Ecotox Threshold - Low Range
Level benchmark values (ET-ERL) for sediment screening. EPA and MEDEP now use the
FSSB for screening purposes for stream and sediment quality. In addition, since the last FYR,
EPA Region 1 recommends the use of TEC values. The FSSB and TEC values for arsenic,
chromium, and lead are 9.8 mg/kg, 43.4 mg/kg, and 35.8 mg/kg, respectively. During this
review period, these screening levels have been exceeded in 5 of 14 samples for arsenic, in 6 of
14 samples for chromium, and in 2 of 14 samples for lead. The target clean-up level established
in the ROD for arsenic was exceeded twice; chromium and lead target levels were met in the
three sampling events that occurred within this review period. It is unknown whether the
exceedances of PEC values in SED-204 indicates that toxicity to aquatic organisms may be
occurring so an evaluation is recommended prior to the next FYR. The remedy is protective to
the environment in the short term because only one of the sediment locations (SED-204) exceeds
the PEC, and it is uncertain whether exceedances of the PEC have a site-specific adverse impact
on aquatic organisms in sediment.
Changes in Exposure Pathways. No new exposure pathways were been identified as part of this
FYR. The 1989 ROD identified unacceptable risk from future dermal contact with soils/sludge
and sediment and ingestion of groundwater. With the implementation of the soil cover systems
and the institutional controls, these exposure pathways have been prevented. In 2002, EPA
issued draft guidance on vapor intrusion to address the potential pathway of vapors moving from
23
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the subsurface into indoor air of a structure. However, because the Contaminants of Concern are
primarily metals (not volatile in the subsurface) and monochlorobenzene is limited to one area of
the Site (MW-114A), and institutional controls that prevent any development on the Site are in
place, this potential exposure pathway is not a concern. Since the 2002 draft guidance EPA has
issued guidance on inhalation risk assessment (EPA, 2005), default exposure factors (2011 and
2014), calculating groundwater exposure point concentrations (EPA, 2014), and vapor intrusion
screening levels. All related exposure pathways have been prevented by the soil cover and
institutional controls. Land use around at the Site has not changed and is not expected to change.
Changes in Toxicity and Other Contaminant Characteristics. A review of EPA's Integrated Risk
Information System did not indicate any changes in toxicity values since the 2008 FYR for the
Contaminants of Concern identified in the 1989 ROD. Arsenic toxicity was last updated in
1995; chromium (both III and VI) in 1998, lead in 2004, manganese in 1995,
monochlorobenzene in 1990, and bis (2-ethylhexyl) phthalate in 1988. The 2008 FYR
concluded the remedy was protective therefore the protectiveness of the remedy remains
unchanged relative to toxicity and other contaminant characteristics.
Changes in Risk Assessment Methods. Although there have been some changes in risk
assessment methods (EPA, 2005, 2009, 2011, 2013, 2014a, 2014b) they do not affect the
protectiveness of the remedy because exposure has been prevented by implementation of the soil
cover and institutional controls.
Expected Progress Towards Meeting RAOs. The four RAOs set by the 1989 ROD have been
met. Sitewide monitoring and O&M continue to assure that conditions remain unchanged.
Question C: Has any other information come to light that could call into question the
protectiveness of the remedy?
No.
Technical Assessment Summary
Based on the data reviewed, observations from the site inspection, and interviews, the remedy
continues to function as intended by the ROD and remains protective of human health and the
environment in the short term. Uncertainty about the significance of exceedances of the PEC by
arsenic in SED-301 and by chromium in SED-204 suggests that the remedy for sediment may
not be protective in the long term. The source control portion of the remedy is complete and the
integrity of the soil cover systems remains intact. Groundwater monitoring data for this review
period do not indicate any significant changes in contaminant concentrations as nearly all
sampling locations are meeting the standards set in the ROD. The implemented institutional
controls prohibit development on the Site and use of the groundwater. Inspections have
identified a maintenance issue with the recurring vandalism of the interior fences and gates.
The primary ARARs for groundwater on the Site are the MCLs and the 1992 MEGs. While the
MCL for arsenic has been reduced to 10 |ig/l, and a number of the monitoring wells have values
slightly above this value, the restriction on use of site groundwater prevents any exposures.
24
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During this review period, arsenic concentrations appear to be increasing at SED-301 and
chromium concentrations at SED-204. During the 2003-2008 FYR period, chromium
concentrations increased at SED-103 and SED-104 whereas during this review period they
remained relatively stable (they are also located downstream of SED-301 and SED-204 so if
there was a leaching of contaminated sediment from the covered pits and lagoons, the increases
would have been expected to be seen first in SED-301 and SED-204). Following similar results
in 1998 when elevated chromium concentrations were detected in SED-104 and SED-204, in
1999 EPA performed extensive sediment sampling and concluded that the increases were natural
fluctuations associated with sediment sampling. Subsequent sampling will be done to confirm
this interpretation, and an evaluation of the potential sediment toxicity to aquatic organisms will
be conducted.
Land use at the Site and surrounding properties have not changed and is not expected to change,
and there are no additional routes of exposure.
V. ISSUES/RECOMMENDATIONS AND FOLLOW-UP ACTIONS
Table 6: Issues and Recommendations/Follow-up Actions
ou#
Issue
Recommendations/
Follow-up Actions
Party
Responsible
Oversight
Agency
Milestone
Date
Affects
Protectiveness?
(Y/N)
Current
Future
Site-wide
Ongoing
vandalism
Partner with local
groups to create
solution
MEDEP/
FAME
MEDEP
7/30/2016
No
Yes
Site-wide
Potential
sediment
toxicity
Evaluate sediment
toxicity to aquatic
organisms
MEDEP
MEDEP
7/30/2018
No
Yes
In addition, the following are follow-up actions that could improve management of O&M (and
possibly reduce costs) but do not affect current protectiveness as identified during this Five-Year
Review:
• Increase frequency of Site inspections including updates on land use in surrounding
properties
• Track vandalism-related repair costs by O&M contractor
• The repairs made as a result of Site inspections should be documented as required by the
O&M Plan
• Reduce groundwater monitoring frequency to once every five years such that the
sampling events occur the year prior to the five-year reviews
• Add co-located surface water samples at existing sediment sampling locations once every
five years such that the sampling events occur the year prior to the five-year reviews
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VI.
PROTECTIVENESS STATEMENT
Site-wide Protectiveness Statement
Protectiveness Determination: Addendum Due Date (if applicable):
Short-term Protective
Protectiveness Statement: The site-wide remedy currently protects human health and the environment
because the remedy is functioning as designed. Institutional controls restrict future use of the Site and
its groundwater. However, in order for the remedy to be protective in the long-term, a solution is
needed to prevent ongoing vandalism of the interior fencing and gates, and an evaluation of potential
sediment toxicity to aquatic organisms.
VII. NEXT REVIEW
The next five-year review report for the Saco Tannery Waste Pits Superfund Site is required five
years from the signature date of this review.
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APPENDIX A - EXISTING SITE INFORMATION
A. SITE CHRONOLOGY
EVENT
DATE
A tanning company purchased the property (previously a homestead/
farmland) and utilized it for disposal of process wastes
1956
Waste disposal on-site ceased
Late 1970s
Tannery went bankrupt and title passed to Finance Authority of Maine
(FAME)
1981
MEDEP, in conjunction with EPA, began site investigations
Early 1980s
Removal response action was conducted
July - October 1983
Site placed on National Priorities List (NPL)
September 1983
MEDEP began initial Remedial Investigation (Phase IRI)
1985
EPA initiated a Phase II RI and a Feasibility Study
October 1987
Maine legislature passed the resolution converting the Site to a permanent
wildlife preserve
May 22, 1989
EPA issued a Wetlands and Floodplains Assessment and an FS addendum
June 1989
ROD signed
September 27, 1989
EPA began a monitoring program of on-site groundwater, surface water
and sediment and residential wells adjacent to the Site
April 1990
Memorandum of Agreement between MEDEP and FAME signed
September 23, 1991
Conservation Easement created by FAME recorded in the York County
June 23, 1992
Registry of Deeds
Explanation of Significant Differences signed
January 16, 1993
Site Preparation Remedial Action performed
October 6, 1992 -
December 15, 1992
Soil Cover/Compensatory Wetlands Remedial Action performed
March 1, 1993 - October
20,1993
Construction inspection
September 1993
Superfund State Contract for road repairs with MEDEP and City of Saco
April 1994
Operational and Functional Period for Soil Covers
October 20, 1993 -
October 1, 1994
Operational and Functional Period for Compensatory Wetlands
October 20, 1993 -
October 1, 1997
O&M for soil covers by MEDEP
October 1, 1994 -
ongoing
Final inspection of soil covers; transfer of O&M responsibilities from EPA
to MEDEP
March 24, 1995
Final inspection for restored on-site wetlands component of the remedial
July 1996
action
First Five-Year Review signed
December 31, 1998
EPA conducted sediment sampling in response to a possible re-emergence
of seeps from Chromium Lagoon 2 and Wet Area 1.
Spring 1999
Site deleted from the NPL
September 1999
Amended Memorandum of Agreement between MEDEP and FAME
July 10, 2001
signed
Second Five-Year Review signed
December 19, 2003
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MEDEP updated O&M Plan
2004 and 2007
O&M activities, including annual inspections, mowing, and repairs as
needed, continued to be performed for FAME
2004 - 2008
Long-term monitoring of groundwater and sediments continued to be
performed by MEDEP
2004-2007
MEDEP abandoned monitoring wells that were no longer part of the long-
term monitoring program
2005
MEDEP performed hydrological assessment
2005
Third Five-Year Review
December 30, 2008
B. BACKGROUND
Physical Characteristics
The Site is located off Flag Pond Road in a rural, residential area of Saco, Maine (Figure 1). The
approximately 212-acre parcel is relatively flat. It is bounded on the east by the Maine Turnpike,
on the west by residential properties, on the south by Flag Pond Road, and on the north by the
woods and fields. The majority of the Site is forested, both uplands and wetlands. Non-forested
land consists of scrub-shrub wetlands, bedrock outcrops, and the covered pits and lagoons.
Grasses are well established on the soil covers.
The Site is within two miles and in the same watershed as the Saco Heath, the southern-most
coalesced domed bog in Maine. Saco Heath and the surrounding forest cover over 1000 acres
and include a mosaic of habitat types including forested bog, wooded shrub heath and shrub
heath. Several rare natural communities, rare plants, and rare animal species have been
documented in the heath, including species only known in a few locations in Maine and other
species at the northern edge of their range. Over 250 acres of the Heath was purchased by
MEDEP as part of the wetlands mitigation required by the 1989 ROD.
Hydrology
There are two surface water drainage-ways onsite, located in the northern and southwestern
portions of the property. Both originate in a swampy region in the western part of the property
near Waste Pits 7, 8, and 9 (Figure 2). One drainage-way flows in a southerly direction via
poorly defined channels towards Flag Pond Road and eventually to Cascade Brook. The other
drainage-way flows in a northeast direction to form the well-defined Stuart Brook. Stuart Brook
then flows in a southeastern direction where it exits the site beneath the Maine Turnpike.
Approximately one and a half mile farther downstream Stuart Brook joins Cascade Brook, which
then flows another mile before discharging into Scarborough Marsh (thus, the entire site is
located within the same watershed). A 100-year flood plain is located within the property
boundaries, but the waste pits or lagoons are not located within the flood plain.
The site geology consists of unconsolidated glacial sediments and till that overlie the bedrock.
The thickness of the glacial deposits ranges from 0 to 55 feet below ground surface with the
maximum overburden located north of Stuart Brook along the northern edge of the Site.
Topographically the Site slopes gently toward the north, west and east in a radial pattern.
Land and Resource Use
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Surrounding land uses to the west and south are primarily residential and agricultural. Interstate
1-95 borders the Site to the east and this highway was expanded from two to three lanes in each
direction between the 2003 and 2008 FYRs. A large wooded parcel bordered the Site to the
north at the time of the 2003 FYR but portions of this parcel were clear cut prior to the 2008
FYR. A large-scale rotating irrigation system was in place on this property at the time of the
2008 FYR but is no longer present.
A review of the current City of Saco zoning map indicated that the area around the Site remains a
Conservation District, or Zone C-l. This zoning classification, C-l, is "designed to promote and
preserve agriculture and open space, while permitting low density residential uses that do not
conflict with this overall purpose." Examples of permitted uses include, but are not limited to,
cemeteries, single- and two-family dwellings, cluster residential projects, public parks, and
agriculture.
Historical records indicate that from the 1800s until the 1950s farming and residential uses were
the primary land uses of the Site and surrounding properties. Although the Site was converted
into a commercial disposal area in 1956, the surrounding properties have continued to be
residential areas and farms. There were approximately 60 single-family homes located within a
half-mile radius of the Site at the time the ROD was signed in 1989; the number has gradually
increased as farmland is converted into residential properties. Residential development is
concentrated along Hearn Road and Flag Pond Road. All of the homes in the area have private
wells and rely on groundwater for their water supply. A comparison of City of Saco tax records
and aerial photography indicates that there have been only two additional homes constructed on
the site-sides of Flag Pond and Hearn Roads since the previous five-year review. Figure 3 is an
aerial photograph taken on August 5, 2007, and illustrates the land use that has remained
relatively unchanged over the past twenty-five years.
The groundwater aquifer in the area of the Site is classified under federal standards as IIB,
suitable for use as a public water supply. Site groundwater flows radially outward from the
highest point (located near monitoring wells MW-114) toward and discharging into the streams
that originate on the Site. Groundwater also flows from the residential properties towards the
Site. Therefore the potential for site contamination to migrate offsite into the private water
supply wells is unlikely.
History of Contamination
In 1956, a tanning company purchased the Site for disposal of its process wastes. Prior to that
time the property was used as a homestead and farm. For nearly two decades, until the late
1970s, tanning process wastes were transported for disposal on the Site from the tannery facility
located on the Saco River approximately three miles away. The process wastes characteristically
had high concentrations of chromium, volatile organic compounds (VOCs), and semi-volatile
organic compounds (SVOCs), and included acids, and leather hides and scraps. Wastes were
disposed of onsite in two large lagoons (approximately two acres each in size) and 57 smaller
disposal pits (during the initial investigations 53 pits were discovered; four additional pits were
uncovered in 1993 during the initial source control activities). The lagoons are located in the
northwestern and northeastern portions of the property and are identified as "Chromium Lagoon
1" and "Chromium Lagoon 2" (see Figure 2 for pit and lagoon locations). The smaller 57
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disposal pits are located throughout the property along both sides of the road system. By the
early 1980s the tanning company went bankrupt, and title transferred FAME.
Initial Response
In the early 1980's MEDEP and EPA conducted the first recorded site investigation. During a
1982 EPA investigation, three acid pits, known as Waste Pits 1, 27 and 30, were identified as
areas that posed immediate and significant human health risks. Between July and October 1983,
EPA remediated the three acid pits by removing the liquids, neutralizing the sludge in place with
lime, and capping the pits. A fence was also erected along Flag Pond Road. EPA estimated that
the total surface area of contamination was approximately 13 acres. The Site was placed on NPL
in September 1983.
Basis for Taking Action
From 1985 through 1987, under a Cooperative Agreement with EPA, MEDEP conducted a
Phase I Remedial Investigation (RI) and Baseline Risk Assessment to determine the nature and
extent of contamination and associated health risks at the Site. EPA initiated a Phase II RI and
Feasibility Study (FS) in October 1987.
The RI found that the contaminated soil and standing water in the two lagoons and waste pits
included high concentrations of chromium and lead, along with low VOC and SVOC
concentrations. With the exception of two discrete areas on the Site, the western berm of Waste
Pit 9 and the northern berm of Chromium Lagoon 2, contaminants levels were found to decrease
significantly immediately below the visibly contaminated waste sludge. The FS evaluated
potential cleanup alternatives for the Site and provided information used to select a remedy.
Groundwater contaminants included arsenic and monochlorobenzene at concentrations that
exceeded the MCLs. (The MCL for monochlorobenzene was established after the ROD was
signed.) No definitive source of arsenic was identified in the RI; arsenic is not a characteristic of
tannery wastes. The RI identified the sludge in the waste pits and lagoons as the VOC source.
Water quality data from residential wells in the immediate vicinity of the Site did not indicate
any exceedances of MCLs. The investigations found no evidence of a hydraulic connection
between the residential wells and the Site.
In June 1989, EPA issued a Wetlands and Floodplains Assessment report and a revised Proposed
Plan that was accepted by MEDEP. Based on the results of these investigations, ARARs and
other guidance, target cleanup goals were established to protect human health and the
environment from the identified risks. On September 27, 1989, the ROD was signed. The ROD
set forth a remedy for the Site that combined a source control cover system with institutional
controls to restrict access to and use of the Site. The primary contaminants of concern affecting
on-site soil, groundwater, surface water and/or sediment were determined to be arsenic,
chromium, lead, and a few SVOCs and VOCs.
C. REMEDIAL ACTIONS
Remedy Selection
30
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The ROD specified a multi-component remedy to address contaminated soils and groundwater.
The following remedial action objectives (RAOs) were identified for the Site:
• Minimize exposure to contaminants or reduce contaminants to levels that are protective
of human health and the environment;
• Reduce the threat of future leaching of chromium and/or reduce the levels of chromium
in the sludge that could leach into the groundwater in the future;
• Prevent ingestion of contaminated groundwater; and
• Minimize exposure of wildlife to contaminated soil, sediments, and standing water.
The remedy selected in the ROD specified:
• Construction of soil cover systems over the waste pits and lagoons to minimize direct
contact with contaminated soils and sludge;
• Creation of a legislatively-enacted institutional control to convert the Site to a permanent
wildlife preserve within two years of ROD signing;
• Implementation of a groundwater monitoring network to monitor for releases of
chromium into the groundwater;
• Performance of a groundwater, surface water, and sediment monitoring program and
contingencies based on the monitoring results;
• Creation of compensatory wetlands on-site to replace the wetlands lost due to covering
the pits and lagoons; and
• Performance of five-year reviews.
The source control component of the remedy specified construction of cover systems for all the
pits and lagoons. Based on a review of the sampling data and other factors, the ROD did not
require additional sampling to confirm the extent of contamination since, except for two discrete
areas, the available data indicated that the contaminated soils and sludge were confined to the
waste pits and lagoons. The two areas of the Site, located near Waste Pit 9 and a seep area near
Chromium Lagoon 2 (see Figure 2), required further investigation prior to construction of the
cover system. Sediment beyond Waste Pit 9 contained chromium and lead concentrations that
were attributed to a break in the pit berm. Sediment beyond the lagoon seep contained high
arsenic concentrations. The ROD established the cleanup target levels shown below to
determine the extent of remediation required for these two areas.
Contaminant
Target Cleanup Level
(mg/kg)
Antimony
30
Arsenic
60
Total Chromium
2,000
Lead
125
The ROD required the design and installation of a monitoring network and established action
levels for the groundwater/surface water monitoring program. If the action levels were
exceeded, the ROD required a further evaluation of the remedial action via contingencies
described in the ROD. Safe Drinking Water Act Maximum Contaminant Levels (MCLs) were
31
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set as the action levels, or standards, for all groundwater contaminants, except for arsenic at four
locations. EPA established Alternate Concentration Limits (ACLs) for four site monitoring
wells (MW-101, MW-103, MW-11 IB, MW-114B) based on the maximum concentrations
observed in the four wells during the RI. The arsenic ACLs for the four monitoring wells are
shown in the table below.
Contaminant
ACL fog/l)
Where Applicable
Arsenic
123
MW-103
Arsenic
77
MW-114B
Arsenic
64
MW-11 IB
Arsenic
70
MW-101
The ROD required quarterly groundwater monitoring for the five COC target compounds
(arsenic, lead, manganese, monochlorobenzene, and bis(2-ethylhexyl) phthalate) and annual
monitoring for Target Compound List (TCL) metals, VOCs and SVOCs. Monitoring of
residential wells located contiguous to the Site was also included in the ROD. The residential
well program included periodic collection and analysis of samples for TCL metals, VOCs and
SVOCs from existing and new wells. Should new residential wells be installed, the ROD
required the collection of water level data using continuous recorders to check for possible
changes in groundwater flow patterns. The ROD specified that surface water and sediment
samples be collected from on-site streams twice a year (low/high flow seasons) and analyzed, at
a minimum, for the five target compounds.
The groundwater, residential well, surface water and sediment monitoring programs specified in
the ROD were required for at least three years following completion of the soil cover systems.
At that point, the ROD allowed for an evaluation of the data and a possible reduction in the
monitoring program. Following the initial reassessment, the monitoring program would be
reassessed periodically based on the data and trends. At a minimum the ROD required a
reassessment at the time of each five-year review.
The ROD also included several contingencies to evaluate the need for additional remedial
actions based on the results of the required monitoring. The first contingency was associated
with the results of the groundwater monitoring program. A second contingency was associated
specifically with chromium in groundwater. If chromium was detected in groundwater from any
of the wells along the property boundary at concentrations of 500 jj.g/1, (i.e., ten times the MCL
for chromium), a source control remedial alternative using a treatment technology would be
selected and implemented.
Since implementation of the selected remedy would result in contaminants remaining on the Site,
the ROD required that EPA conduct five-year reviews. The reviews are required to assess site
data to ensure that the remedial action continues to be protective of human health and the
environment.
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On January 16, 1993, EPA signed an Explanation of Significant Differences (ESD) which
changed several provisions of the ROD. Rather than off-site treatment and disposal of the
standing water from the waste pits and lagoons, the approximately 569,000 gallons of water were
treated on-site and subsequently used for dust control on the three miles of dirt roads during the
construction of the soil cover systems. In addition, the ESD changed the ROD requirement for
creation of on-site compensatory wetlands because there was insufficient acreage on the Site to
create wetlands to compensate for the 9.6 acres lost during construction of the remedy. The ESD
documented the purchase of off-site wetlands by MEDEP as the State's ten percent cost share for
the remedial action.
Remedy Implementation
The source control remedial activities were divided into two phases to accommodate the short
construction season in Maine. Site preparation activities were completed between October and
December 1992; the soil cover/compensatory wetlands activities were completed between March
and October 1993.
Following a post-ROD assessment that determined there was insufficient acreage onsite to
satisfy the requirements for wetlands creation under the ROD, EPA and MEDEP structured the
1993 SSC to allow the purchase of compensatory off-site wetlands to serve as the State's cost
share for the remedial action. MEDEP negotiated the purchase of 247 acre parcel within the
Saco Heath, a unique habitat where northern range and southern range species overlapped. The
owners of this parcel had a peat mining permit which if implemented would have significantly
altered the heath.
On May 22, 1989, the Maine state legislature passed a resolution which permanently converted
the Site to a wildlife preserve. The resolution prohibits development for residential or
commercial use, excavation that penetrates the soil cover and/or utilization of the groundwater as
a drinking water source. In addition to the legislative action, a deed restriction in the form of a
Conservation Easement was implemented on the property as a further assurance of the
restrictions on future land use. MEDEP and FAME signed a Memorandum of Agreement in
1991, and amended it in 2001. These agreements established rules and regulations governing the
use of the preserve and the agencies' responsibilities for O&M.
System Operation/Operation and Maintenance
The first O&M plan for the Site was prepared as part of the September 1992 Remedial Design
Report, and it was included in the 1993 SSC. MEDEP updated the O&M Plan on April 5, 1995
and again in February 2009. The O&M activities include periodic inspection and maintenance,
annual mowing of and around the soil covers, perform necessary repairs due to erosion,
burrowing animals, off-road vehicles, and other forms of cover destruction with adequate
materials. Inspection observations and details of any maintenance and repairs are required to be
documented in an Inspection and Maintenance Report that is to be submitted after each site
inspection is conducted.
33
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APPENDIX B - ADDITIONAL FIGURES FOR REFERENCE
y[
2
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a
Saco Tannery
Waste Pits
Hag Pond Road
Saco, Mane
Area Overview
August. 2007 Aerial Photo
Legend:
Approximate site Boundary
Town Boid^xJcry
Streams
NWl wetlands
SitiLrarine and Marine Deepft ater
fe-hjarine cwici Marine HlfeHand
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Abes Eqhi'inMTU Pmwitnri
Br*
Data Sources
toads cncJ Taww. Boundaries: loteAlks
Aerial Fheco: r*artalGlade fOvQV2CD?l
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34
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Saco, Mesne
August, 2QQ7 Aerial Photo
Legend:
Approximate Site Boundary
Town Boundary
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FIGURE 3
35
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Saco Tannery
Saco, Maine
Map derived from
Final As-BuiN Survey
Comer post l_ana surveying
Fetmiaiy 10,1995
Flrtft4wrt#FA10
ME DEP swnned May 14.2002
Last update: 04-26-04: Wayne Paradis, DEP
Formatted! tor printing on 11" x 1T
36
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APPENDIX C
PRESS RELEASE ANNOUNCING FIVE-YEAR REVIEW
($ A Trt
wl
EPA New England News Release
Protecting Human Health and the Environment
ww.epa.gov/ regionl/news
News Release
U.S. Environmental Protection Agency
New England Regional Office
May 9, 2013
Contact: David Deegan, (617) 918-1017
EPA Conducts "Five-Year Review" for 16 New England Superfund
Sites
(Boston, Mass. - May 9, 2013) - EPA is beginning the process of routine Five-Year Reviews of 16
Superfund sites across New England.
EPA conducts evaluations every five years on previously-completed clean up and remediation work
performed at sites listed on the "National Priorities List" (aka Superfund sites) to determine whether the
implemented remedies at the sites continue to be protective of human health and the environment. Further,
five year review evaluations identify any deficiencies to the previous work and, if called for, recommend
action(s) necessary to address them.
In addition to a careful evaluation of technical work at the sites, during the Five Year Review process EPA
also provides the public with an opportunity to evaluate preliminary findings and to provide input on potential
follow up activity that may be required following the review process.
The Superfund sites at which EPA is performing Five Year Reviews over the following several months
include the following sites. Please note, the Web link provided after each site provides detailed information
on site status and past assessment and cleanup activity.
Massachusetts
Iron Horse Park, North Billerica http://www.epa.qov/reqion1/superfund/sites/ironhorse
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Nyanza Chemical Waste Dump, Ashland http://www.epa.aov/reaion1/superfund/sites/nvanza
Re-Solve, Inc., North Dartmouth http://www.epa.aov/reqion1/superfund/sites/resolve
Sullivan's Ledge, New Bedford http://www.epa.aov/reaion1/superfund/sites/sullivansledae
Maine
McKin Co., Gray http://www.epa.aov/region1/superfund/sites/mckin
Saco Tannery Waste Pits, Saco http://www.epa.gov/reqion1/superfund/sites/sacotannerv
West Site/Howe's Corner, Plymouth http://www.epa.gov/reqion1/superfund/sites/hows
New Hampshire
Kearsarge Metallurgical Corp., Conway http://www.epa.gov/region1/superfund/sites/kearsarge
Ottati & Goss, Kingston http://www.epa.gov/region1/superfund/sites/o&g
South Municipal Water Supply Well, Peterborough http://www.epa.gov/region1/superfund/sites/southmuni
Tinkham Garage, Londonderry http://www.epa.gov/region1/superfund/sites/tinkham
Town Garage/Radio Beacon, Londonderry http://www.epa.gov/region1/superfund/sites/towngarage
Rhode Island
Central Landfill, Johnston http://www.epa.gov/region1/superfund/sites/central
Picillo Farm, Coventry http://www.epa.gov/region1/superfund/sites/picillo
Vermont
Elizabeth Mine, Strafford http://www.epa.gov/region1/superfund/sites/elizmine
Old Springfield Landfill, Springfield http://www.epa.gov/region1/superfund/sites/oldspringfield
# # #
Learn More about the Latest EPA News & Events in New England
(http://www.epa.gov/reaion1/newsevents/index.html')
Follow EPA New England on Twitter (http://twitter.com/epanewenaland')
More info on EPA's Environmental Results in New England (http://www.epa.gov/reqion1/results/index.html')
If you would rather not receive future communications from U.S. EPA, Region 1, let us know by clicking here.
U.S. EPA, Region 1, 5 Post Office Square, Suite 100, Boston, MA 02109-3912 United States
38
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APPENDIX D
DOCUMENT REVIEW LIST and REFERENCES
EPA, 1989. Record of Decision, Saco Tannery Waste Pits Site, Saco, Maine. U.S. Environmental
Protection Agency, Region 1, Boston, Massachusetts. September 27, 1989.
EPA, 1993. Superfund State Contract Between The State of Maine and the U.S. Environmental
Protection Agency for the Soil Cover System/Compensatory Wetlands. Saco Tannery Waste Pits Site,
Saco, Maine. January 28,1993.
EPA, 1995. Pre-FinalInspection Report, Saco Tannery Waste Pits Site, Saco, Maine. U.S.
Environmental Protection Agency. June 1995.
EPA, 1998. Five-Year Review Report, Saco Tannery Waste Pits Site, Saco, Maine. U.S. Environmental
Protection Agency. December 31, 1998.
EPA, 1999. National Recommended Water Quality Criteria for Priority Toxic Pollutants. U.S.
Environmental Protection Agency. April 1999.
EPA, 1999. Sediment Sampling Memorandum, Saco Tannery Waste Pits Site, Saco, Maine. Terrence
Connelly, U.S. Environmental Protection Agency. May 21, 1999.
EPA, 2001. Comprehensive Five-Year Review Guidance. U.S. Environmental Protection Agency,
Office of Emergency and Remedial Response. OSWER Directive 9355.7-03B-P. June 2001.
EPA, 2002. 2002 Edition of the Drinking Water Standards and Health Advisories. U. S. Environmental
Protection Agency - Office of Water. EPA 822-R-02-038. Summer 2002.
EPA, 2003. Second Five-Year Review Report, Saco Tannery Waste Pits Site, Saco, Maine. U.S.
Environmental Protection Agency. December 19, 2003.
EPA, 2008. Third Five-Year Review Report, Saco Tannery Waste Pits Site, Saco, Maine. U.S.
Environmental Protection Agency. December 30, 2008.
Halliburton, 1993. Draft Technical Memorandum No. 5, Interim Monitoring Program Round 9 (May
1992) and Round 10 (July 1992) Sampling and Analysis Results, Saco Tannery Waste Pits Site, Saco,
Maine. Halliburton NUS Corporation. October 1992.
Halliburton, 1993. Draft Technical Memorandum No. 6, Interim Monitoring Program Round 11
(October 1992) and Round 12 (January 1993) Sampling and Analysis Results, Saco Tannery Waste Pits
Site, Saco, Maine. Halliburton NUS Corporation. May 1993.
Halliburton, 1994. Draft Technical Memorandum No. 7, Interim Monitoring Program Round 13 (June
1993) and Round 14 (September 1993), Saco Tannery Waste Pits Site, Saco, Maine. Halliburton NUS
Corporation. January 1994.
Halliburton, 1994. Draft Technical Memorandum No. 8, Results From Interim Monitoring Program
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Round 15 (October 1993) and Round 16 (January 1994) Sampling and Analysis Results, Saco Tannery
Waste Pits Site, Saco, Maine. Halliburton NUS Corporation. June 1994.
Halliburton, 1995. Draft Technical Memorandum No. 9, Interim Monitoring Program Round 17 (April
1994) and Round 18 (August 1994) Sampling and Analysis Results, Saco Tannery Waste Pits Site, Saco,
Maine. Halliburton NUS Corporation. January 1995.
Halliburton, 1995. Draft Technical Memorandum No. 10, Interim Monitoring Program Round 19
(October 1994) and Round 20 (December 1994), Saco Tannery Waste Pits Site, Saco, Maine.
Halliburton NUS Corporation. March 1995.
NUS, 1990. Draft Technical Memorandum, Interim Monitoring Program Round 1 (April 1990) and
Round 2 (July 1990) Sampling and Analysis Results, Saco Tannery Waste Pits Site, Saco, Maine. NUS
Corporation. October 1990.
NUS, 1991. Draft Technical Memorandum No. 2, Interim Monitoring Program Round 3 (October
1990) and Round 4 (January 1991) Sampling and Analysis Results, Saco Tannery Waste Pits Site, Saco,
Maine. NUS Corporation. April 1991.
NUS, 1991. Draft Technical Memorandum No. 3, Interim Monitoring Program Round 5 (April 1991)
and Round 6 (July 1990) Sampling and Analysis Results, Saco Tannery Waste Pits Site, Saco, Maine.
NUS Corporation. November 1991.
NUS, 1992. Draft Technical Memorandum No. 4, Interim Monitoring Program Round 7 (October
1991) and Round 8 (February 1992) Sampling and Analysis Results, Saco Tannery Waste Pits Site,
Saco, Maine. NUS Corporation. May 1992.
MacDonald, D, C. Ingersoll, and T. Berger. 2000. Development and evaluation of consensus-based
sediment quality guidelines for freshwater ecosystems. Archives of Environmental Contamination and
Toxicology 39, 20-31.
Maine, 1989. "Resolve, to Protect and Preserve Certain Property in Saco Owned by the Finance
Authority of Maine.'" State of Maine Legislature, Document No. 1682, H.P. 1210. May 22, 1989.
Maine, 1992. Conservation Easement. Finance Authority of Maine. September 23, 1991, recorded at
York County Registry of Deeds June 23, 1992.
Maine, 2008. Maine Bureau of Health Maximum Exposure Guidelines for Drinking Water. Department
of Human Services, State of Maine. July, 2008.
MEDEP, 1991. Memorandum of Agreement. August 28, 1991.
MEDEP, 1995. Operation and Maintenance Plan, Saco Tannery Waste Pits Site, Saco Maine. Maine
Department of Environmental Protection. April 5, 1995.
MEDEP, 2007. Operation and Maintenance Plan, Saco Tannery Waste Pits Site, Saco Maine. Maine
Department of Environmental Protection. December 19, 2007
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MEDEP Monitoring data summary provided by Tracy Weston Kelly, December 31, 2007
MEDEP, 2014. 2013 Biennial Sampling Report, Saco Tannery Waste Pits Site, Flag Pond Road, Saco
Maine. Maine Department of Environmental Protection. April 30, 2014
Saco, 2003. City of Saco Zoning Ordinance, amended through July, 2003.
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