RECORD OF DECISION
KEDDY MILL SUPERFUND SITE
WINDHAM, MAINE
EPA SITE ID: MEN000106078
PREPARED BY:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 1 - NEW ENGLAND
SEPTEMBER 2023
IllHIlillllllll
SEMS Doc ID 677537
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PART
1: THE DECLARATION FOR THE RECORD OF DECISION
1
A. SITE NAME AND LOCATION 1
B. STATEMENT OF BASIS AND PURPOSE 1
C. ASSESSMENT OF SITE 1
D. DESCRIPTION OF SELECTED REMEDY 1
E. STATUTORY DETERMINATIONS 2
F. SPECIAL FINDINGS 3
G. DATA CERTIFICATION CHECKLIST 4
H. AUTHORIZING SIGNATURES 4
PART 2: THE DECISION SUMMARY 5
A. SITE NAME, LOCATION, AND DESCRIPTION 5
B. SITE HISTORY AND ENFORCEMENT ACTIVITIES 6
C. COMMUNITY PARTICIPATION 6
D. SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION 9
E. SITE CHARACTERISTICS 10
F. CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES 22
G. SUMMARY OF SITE RISKS 24
H. REMEDIAL ACTION OBJECTIVES 38
I. DEVELOPMENT AND SCREENING OF ALTERNATIVES 39
J. DESCRIPTION OF ALTERNATIVES 40
K. COMPARATIVE ANALYSIS OF ALTERNATIVES 45
L. THE SELECTED REMEDY 53
M. STATUTORY DETERMINATIONS 66
N. DOCUMENTATION OF NO SIGNIFICANT CHANGES 71
O. STATE ROLE 71
PART 3: THE RESPONSIVENESS SUMMARY 72
PUBLIC COMMENTS AND EPA RESPONSES 72
TRANSCRIPT OF PUBLIC HEARING 78
APPENDICES 88
Appendix A - Maine Department of Environmental Management Letter of Concurrence 89
Appendix B - Tables 92
Appendix C - Figures 155
Appendix D - ARARs Tables 172
Appendix E - Acronyms and Abbreviations 196
Appendix F - TSCA Determination 198
Appendix G - Administrative Record Index and Guidance Documents 202
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Keddy Mill Superfund Site
Record of Decision
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PART 1: THE DECLARATION FOR THE RECORD OF DECISION
A. SITE NAME AND LOCATION
Keddy Mill Superfund Site
Windham, Cumberland County. Maine
CERLCIS ID#: MEN000106078
B. STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the Keddy Mill Superfund Site in
Windham. Maine (the Site), which was chosen in accordance with the Comprehensive Environmental
Response. Compensation, and Liability Act of 1980 as amended (CERCLA. also commonly referred to as
"Superfund"). 42 U.S.C. § 9601 et seq., and. to the extent practicable, the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP) as amended. 40 C.F.R. Part 300. The Region 1 Director of
the Superfund and Emergency Management Division (SEMD) has been delegated the authority to
approve this Record of Decision (ROD).
This decision was based on the Administrative Record for the Site, which has been developed in
accordance with Section 113(k) of CERCLA. 42 U.S.C. § 9613(k). The Administrative Record is
available for review online at www.epa.gov/superfimd/keddv. via computer at the Windham Public
Library at 217 Windham Center Road. Windham. Maine, and at the U.S. Environmental Protection
Agency (EPA) Region 1 Records Center located at 5 Post Office Square. Boston. Massachusetts. The
Administrative Record I ndex (Appendix G of this ROD) identifies each of the items comprising the
Administrative Record upon which the selection of the remedial action is based.
The State of Maine, as the support agency, concurs with the selected remedy (see Appendix A of this
ROD for a copy of the concurrence letter).
C. ASSESSMENT OF SITE
The remedial action selected in this ROD is necessary to protect the human health or welfare or the
environment from actual or threatened releases of hazardous substances, pollutants, or contaminants into
the environment. The November 2021 Remedial Investigation (Rl) Report for the Site summarizes the
nature and extent of the contamination and was used to prepare the June 2023 Feasibility Study (FS)
Report that identified all the remedial alternatives considered for cleanup of the Site.
D. DESCRIPTION OF SELECTED REMEDY
This ROD sets forth the selected remedy for the Site, which is a comprehensive cleanup approach and is
based on a combination of remedial alternatives set out in a Proposed Plan issued for public comment in
June 2023. The selected remedy, which is to be implemented following the substantial completion of an
EPA-approved Non-Time-Critical Removal Action (NTCRA) to demolish, at a minimum, the majority of
the mill complex and associated structures, addresses soil within the boundaries of the 7 Depot Street
parcel (the "Mill Complex Property") within the Site, groundwater, and sediment within the Presumpscot
River adjacent to and downstream of the Mill Complex Property (to address both the contaminated
SECTION D: DESCRIPTION OF SELECTED REMEDY
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sediment itself and to achieve risk-based cleanup standards in fish tissue).1 The selected remedy utilizes
excavation and off-site disposal of contaminated soil and sediment, in-situ treatment to restore
groundw ater to its beneficial use as a source of drinking water, and land use restrictions (called
"institutional controls" or ICs) to prevent exposure to groundwater and fish tissue until cleanup levels are
achieved.
The major components of the remedy selected in this ROD include the following:
• Excavation and off-site disposal of approximately 22,000 cubic yards of contaminated soil and
debris from the Mill Complex Property;
• Targeted treatment of soil (within the footprint of the excavation) with amendments in support of
groundw ater cleanup;
• In situ treatment of groundwater to reduce the mass, mobility and toxicity of contaminants;
• Excavation and off-site disposal of approximately 320 cubic yards of contaminated sediments
from the Target Reach of the Presumpscot River;
• Treatment of water generated from soil and sediment dew ate ring and removed from excavations
based on applicable water discharge standards, as required;
• Restoration of the portions of the Presumpscot River riverbed, riverbank, wetland and floodplain
habitat altered by the remedial action;
• Institutional Controls to prevent exposure to Site-related contaminants in groundwater and fish
tissue until cleanup levels are met;
• Inspections to evaluate Site restoration and stabilization activities, as well as O&M;
• Monitoring of groundw ater and fish tissue to evaluate the achievement of cleanup levels; and
• Periodic reviews, at a minimum of every five years, to assess the protectiveness of the remedy
until cleanup levels are achieved.
E. STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the environment; complies with federal and State
requirements that are applicable or relevant and appropriate to the remedial action; is cost-cffective; and
utilizes permanent solutions and alternative treatment technologies to the maximum extent practicable.
The selected remedy satisfies the statutory preference for treatment as a principal element of the remedy.
Because this remedy will result in Site contaminants remaining in groundwater and fish tissue above
levels that would allow for unlimited use and unrestricted exposure. Institutional Controls are required
until cleanup levels are achieved and a review will be conducted within five years follow ing initiation of
the remedial action to ensure that the remedy continues to provide adequate protection of human health
1 EPA's Action Memorandum (September 2018) identified partial demolition (i.e., West Wall and potentially a
portion of the basement floor slab would remain) as the removal action; however, the feasibility of removing the
entirety of the mill complex will be further evaluated based on the results of the pre-design investigation. The
subsequent design is anticipated to reflect either a partial or full demolition approach.
SECTION E: STATUTORY DETERMINATIONS
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Keddv Mill Superfund Site
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and the environment. Five-Year Review s for the Site will continue as long as waste remains at the Site
above levels that would allow for unlimited use and unrestricted exposure.
F. SPECIAL FINDINGS
Issuance of this ROD embodies the following specific determinations:
Wetlands Impacts
Pursuant to Section 404 of the Clean Water Act (CWA), EPA has determined that, due to the presence of
Site-related contamination, there is no practicable alternative to conducting work in protected aquatic
habitats and limited portions of emergent wetlands. EPA has also determined, through its analysis of the
various alternatives, that the selected remedy which impacts federal jurisdictional wetlands and aquatic
habitats meet the CWA's "Least Environmentally Damaging Practicable Alternative" (LEDPA) standards
for protecting such resources. EPA will minimize potential harm and avoid adverse impacts to protected
aquatic habitats and wetlands by using Best Management Practices (BMPs) and by restoring or mitigating
these areas consistent with federal and state wetlands protection law s. Any aquatic habitats or wetlands
affected by remedial work will be restored with clean, imported materials and native vegetation consistent
with p re-remediation conditions and such restoration will be monitored until the vegetation becomes re-
established. Other mitigation measures will be used to protect wildlife and aquatic life during remediation
and restoration, as necessary.
Federal regulations at 44 C.F.R. Part 9, implementing wetland protection requirements under Executive
Order 11990, required EPA to specifically solicit public comment on its proposal to impact federal
jurisdictional wetlands. As required under applicable federal wetlands regulations. EPA solicited public
comment regarding the remedies" potential impacts on wetland resources in its Proposed Plan and
received no negative comments (see Part 3 of this ROD).
The State Natural Resources Protection Act - Wetlands and Waterbodies Protection Rules (Chapter 310)
includes jurisdiction over areas in. on. over or adjacent to State regulated wetlands and waterbodies.
Under the State standards the area within 75-feet, measured horizontally, of the normal high-water line of
a great pond, river, stream or brook or the upland edge of a coastal wetland or freshwater wetland is also
regulated. Work within areas within 75-feet of the Presumpscot River and any State-regulated wetlands
(approximately 0.78-miles of emergent wetland vegetation along the river shoreline) will be conducted to
protect State-regulated natural resources, as described above relative to federal wetland protection
requirements.
Floodplain Impacts
Pursuant to Executive Order 11988 (Floodplain Management) and federal regulations at 44 C.F.R. Part 9,
EPA has determined that there is no practicable alternative to activities that affect or result in the
occupancy and modification of the 100-and 500-year floodplain. EPA has also determined that the
selected remedy will cause temporary impacts to 100-year and 500-year floodplains but will not result in
the permanent occupancy and modification of floodplains. BMPs will be used to minimize temporary
impacts to floodplains and excavated areas will be returned to original grade to avoid diminishing flood
storage capacity. Restoration and monitoring activities are included in the selected remedy. As required
under applicable federal floodplains regulations. EPA solicited public comment regarding the remedies"
SECTION F: SPECIAL FINDINGS
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potential impacts on floodplain resources in the Proposed Plan and received no negative comments (see
Part 3 of this ROD).
Toxic Substances Control Act
In accordance with the requirements under the TSCA and 40 C.F.R. § 761.61(c). EPA has made a finding
that the manner of sampling, storage, cleanup and disposal of PCB-contaminated soil and debris,
groundwater and sediment as set out in this Record of Decision will not pose an unreasonable risk of
injury to health or the environment as long as the conditions in a TSCA Determination attached to this
document (Appendix F of this ROD) are met. EPA solicited public comment on its draft TSCA
Determination in the Proposed Plan and received no negative comments (see Part 3 of this ROD).
G. DATA CERTIFICATION CHECKLIST
The follow ing information is included in the Decision Summary section of this ROD. Additional
information can be found in the Administrative Record file for this Site.
13
Chemicals of concern (COCs), also known as contaminants of concern, and their respective
concentrations.
Tables G1 - G8
13
Baseline risk represented by the COCs.
Tables G13 - G30
13
Cleanup levels established for COCs and the basis for these levels.
Table L-l
13
Current and reasonably anticipated future groundwater use assumptions used in baseline
human health risk assessment.
Section F
13
Current and potential future groundwater uses as a result of the selected remedy.
Section L
13
Estimated capital, annual operation and maintenance (O&M), and total present worth costs,
discount rate, and the number of vcars over which the reincdv cost estimates arc projected.
Section L
13
Decisive factors that led to selecting the remedy.
Section K
H. AUTHORIZING SIGNATURES
This ROD documents the selected remedy for soil, groundw ater, and sediment (also addressing fish tissue
risks) associated with the keddy Mill Superfund Site. This remedy was selected by EPA with concurrence
of the Maine Department of Environmental Protection (MEDEP). A copy of the State's concurrence letter
is attached to this ROD (Appendix A). The follow ing signature also authorizes the measures identified in
the attached TSCA Determination (Appendix F) to address PCB contamination at the Site, so as to not
pose an unreasonable risk of injury to health or the environment.
Digitally signed by Olson,
Olson, Bryan 5"20i,0,l28
By: 08:35:45 -04'00' Date:
Bryan Olson. Director
Superfund and Emergency Management Division
SECTION H: AUTHORIZING SIGNATURES
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PART 2: THE DECISION SUMMARY
A. SITE NAME, LOCATION, AND DESCRIPTION
The keddy Mill Superfund Site (CERCLIS ID#: MEN000106078) or "Site" is located in Windham,
Cumberland County. Maine. EPA is the lead agency and MEDEP is the support agency.
The Site consists of a 6.93-acre abandoned mill complex property, located at 7 Depot Street (the Mill
Complex Property), an adjacent reach of the Presumpscot River, and associated riparian properties.2 The
Mill Complex Property is in a mixed commercial/residential area in the village of South Windham. The
Mill Complex Property is bounded to the north by Depot Street with commercial and residential
properties beyond; to the immediate northeast by a multi-unit apartment complex; to the east by a former
Maine Central Railroad right-of-way; to the south and southwest by an undeveloped property referred to
herein as the Transmission Line Property; to the south-southwest by the Presumpscot River; to the west
by a property that includes a dam and a hydroelectric power generating station (referred to herein as the
"Hydro Property"); and to the northwest by a multi-unit senior housing complex (Little Falls Landing).
The Mill Complex Property was historically part of a larger property that included portions of several of
the abutting properties.
The central portion of the Site, where the mill complex is situated adjacent to/over the Presumpscot River,
is relatively level and is bounded by steeper terrain to the north, east, and west. The Mill Complex
Property is currently vacant and a chain-link fence restricts access the northern portion of the parcel as
well as into the mill buildings. Trespassers have periodically entered and damaged portions of the mill
complex. The abandoned mill complex currently includes several connected buildings; however, the
function and configuration of the buildings has changed overtime. The Site lies on the northern and
eastern side of the Presumpscot River, adjacent to the Little Falls Dam and approximately '/2 mile
upstream of the Mallison Falls Dam. A segment of the river flows beneath the western portion of the mill
complex.
A Site Locus Map is provided as Figure 1 in Appendix C and a Site Plan is provided as Figure 2 in
Appendix C.
As noted in Part 1 of this ROD. a NTCRA has been authorized, but not yet implemented, to expedite a
limited cleanup action of PCB contamination and asbestos-containing material (ACM) through the
demolition and removal of the mill complex (partially or in full as determined by the design) and
associated mill building materials. Risks associated with the structure are to be addressed as part of the
NTCRA, and are not part of the remedy selected in this ROD.
2 A portion of the Presumpscot River, immediately south of the mill complex, is included in the Site boundary.
Abutting portions of the Target Reach of the Presumpscot River arc comprised of Presumpscot Hydro LLC-owned
parcels, including south of the terrestrial portions of the "Hydroelectric" property and along the bank of the
"Transmission Line" property.
SECTION A: SITE NAME, LOCATION. AND DESCRIPTION
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B. SITE HISTORY AND ENFORCEMENT ACTIVITIES
History of Site Use
Mills were established on both sides of the Little Falls portion of the Presumpscot River as early as the
1750s, with a sawmill built on the north side of the river (i.e., general vicinity of the Site) sometime
before 1756. After the saw mill ceased operations in 1822, the mill site was unoccupied except for two
small buildings used as a grist mill and carding mill. By the 1870s, the mill site was vacant. In 1875, the
Sebago Wood Board Company acquired the mill site and constructed a pulp mill complex, which
included a three-story main mill building, machine room, drying rooms, a wood preparing house, and a
100-foot external chimney. Between the late 1800s and 1922, additional process buildings/facilities were
added including storehouses, a railroad siding, a finishing and shipping building, a water tank, a machine
room, and an engine room. The mill was used for pulp and box-board manufacturing through the 1940s.
By 1945, the complex shifted from manufacturing paper to steel products (e.g., heavy equipment
buckets). Scrap metal was transported by rail cars to the mill and melted into steel billets, which were
then used to manufacture steel parts. During the 1960s and early 1970s, manufacturing included flanges
and fire suppression materials. It was during this period that disposal of hazardous substances, including
PCBs. may have occurred at the Site. A large oil-based fire in late 1969 heavily damaged the mill
complex and destroyed several blast furnaces. Several incidents of smaller fires within the mill complex
also occurred between 1969 and 1997. Between 1973 through 1974, heavy machinery in the mill complex
was removed from the property, which suggests fabrication of metal parts likely ended by 1973 or earlier.
In 1974, a scrap recycler began operations in the mill building. Minimal records were located regarding
the Site's use through 1997; however, the property appeared to be lightly used as a machine shop and for
equipment storage.
History of Investigations, Remedial Actions and Enforcement Activities
Environmental Investigations
Environmental investigations were initiated in the 1990s by various owners of the Mill Complex
Property. Throughout the 1990s several environmental assessment activities were conducted. These
activities generally focused on reconnaissance and inspections, review of existing property information,
interviews, and limited investigation to evaluate potential contamination at the Mill Complex Property
and abutting parcels. Environmental investigation activities continued and expanded in the 2000s
primarily due to interest in private redevelopment and subsequent Brownfields assessment by the Town in
coordination with MEDEP.
An EPA Preliminary Assessment and a Site Inspection were completed in 2013. Information collected
during the Site Inspection was used to score the Site under the EPA's Hazard Ranking System; the Site
scored 50 making it eligible for placement on the National Priorities List (NPL). The Site was proposed
for addition to the NPL on December 12, 2013 and the listing was finalized on May 12, 2014.
Rl field activities and data collection were largely completed between October 2015 and October 2019.
The Rl included ecological surveys and wetland evaluation; topographic survey; archaeological and
architectural survey; geophysical surveys; soil boring and bedrock drilling; monitoring well installation;
SECTION B: SITE HISTORY AND ENFORCEMENT ACTIVITIES
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and soil, groundwater, sediment, surface water, biota and private well sampling.3 The Rl Report was
developed in November 2021. The Rl data also supported development and refinement of the Baseline
Human Health Risk Assessment (BHHRA) and Ecological Risk Assessment (ERA) in June 2023. A
Feasibility Study was also completed in June 2023.
Prior Response Actions
Previous responses actions undertaken at the Site include the follow ing:
• Excavation of approximately 1 1 tons of petroleum-contaminated soil from the north-central
portion of the Mill Complex Property under the oversight of MEDEP. The excavation followed
the discovery and removal of free product (No. 6 fuel oil) in a Depot Street concrete junction box.
Two former underground storage tanks (USTs) located proximate to the junction box were
previously removed from the Site and the discovery of residual contamination resulted in further
MEDEP evaluation of fuel oil storage at the Mill Complex Property.
• A spill was also reported to MEDEP on July 5, 2005, which included the release of between 30 to
40 gallons of PCB-containing fluid from vandalized electrical equipment within the mill building. A
contractor was hired to clean up the spill under MEDEP oversight and no further action was deemed
necessary.
• In April 2006, on behalf of a private developer, a three-phase cleanup plan was proposed to
remediate the PCB contamination at the Site. The Phase I Self-Implementing Cleanup Plan
(SICP) was approved by EPA in June 2006; however, the design phase of the redevelopment was
delayed and the SICP was subsequently modified. The Phase I SICP. which included removal of
PC B-contam inated oil from piping, capping of piping, removal of PCB-contaminated sludge, dirt,
debris and oil materials from the building, and temporary capping of exposed interior soils, was
completed in 2010. The solid waste generated (approximately 103 tons) was transported for
disposal at a permitted facility. Subsequent phases of the SICP were not approved or
implemented as the redevelopment plan was abandoned.
EPA Removal Action
A NTCRA has been authorized, but not yet implemented, to expedite the demolition and removal of the
contaminated mill complex structures (partially or in full as determined by the design) and associated mill
building materials. EPA entered into an Administrative Settlement Agreement and Order on Consent
(AOC) in May 2017 for a Potentially Responsible Party (PRP) to develop an Engineering Evaluation and
Cost Analysis (EE/CA) to identify initial alternatives, collect supporting data, and recommend a preferred
alternative. The EE/CA was finalized in May 2018. The Removal Action, as documented in EPA's Action
Memorandum, is limited to:
1) Complete demolition of the East Wing and Press Wing;
2) Demolition and removal of the West Wing with the exception of the below ground section of the
West Wall and potentially a portion of the basement floor slab; and
3) Air and surface water monitoring in the Presumpscot River to ensure unacceptable releases do not
occur during the Removal Action.
3 Sediment is defined as particulate material found at the bottom of a water body including silt, clay, sand, gravel
and decaying organic matter (i.e., particulate material that usually lies below water).
SECTION B: SITE HISTORY AND ENFORCEMENT ACTIVITIES
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A subsequent AOC for the PRP's performance of a geophysical investigation, drainage study, and site
security measures was signed in October 2019. The PRP completed the work by this AOC and EPA
approved the PRP's Geotechnical Investigation and Drainage required Study Data Summary Report on
February 2, 2022.
EPA and the PRP recently completed negotiations to perform PDI activities, design, and demolition of the
mill complex (partially or in full as determined by the design). An AOC to complete these activities was
signed in July 2022 and a PDI Field Sampling Plan (FSP) was conditionally approved by EPA in June
2023. The selected remedy described herein is to be implemented follow ing the substantial completion of
the NTCRA.
C. COMMUNITY PARTICIPATION
The Rl Report. FS and Proposed Plan for the Keddy Mill Superfund Site were made available to the
public in June 2023. They can be found in the Administrative Record file and the information repository
accessible via computer at the Windham Public Library, or online at www.epa.gov/superfimd/keddv.
Throughout the Site's history, community concern and involvement has been moderate and consistent.
EPA has kept the community and other interested parties apprised of Site activities through informational
meetings, fact sheets, press releases, emails and physical mailings and public meetings. Additionally.
EPA has continually worked with Town Officials to help keep the community involved. Below is a brief
chronology of public outreach efforts.
• On May 30, 2013, EPA and MEDEP held a public meeting to discuss the status of the Keddy
Mill property and potential for listing on the NPL.
• On December 12, 2013, EPA published a press release proposing the Site for inclusion on the
NPL.
• In May 2014, EPA announced the placement of the Site on the NPL.
• On April 22, 2015, EPA initiated consultation with Maine's Historic Preservation Officer,
National Oceanic and Atmospheric Administration. U.S. Department of the Interior, and several
Tribal Historic Preservation Officers (i.e., Penobscot Indian Nation. Houlton Band of Maliseet
Indians, Passamaquoddy Tribe of Indians - Indian Tow nship Reservation/Pleasant Point
Reservation, and Aroostook Band of Micmacs) pursuant to EPA's obligations under Section 106
of the National Historic Preservation Act of 1966, as amended, to provide notification concerning
the upcoming RI/FS activities.
• On October 26. 2015, EPA published a press release announcing the start of the Rl.
• On February 2, 2016, EPA published a Site update fact sheet providing background about the
Site, summarizing contaminants of concern, and describing what the community could expect
during the Rl.
• On September 6. 2017, EPA mailed out to its Site mailing list a postcard soliciting community
participation in the development of a Community Involvement Plan (CIP) .
• In May 2018, EPA developed a Reuse Assessment, which included community interview s,
summarizing preliminary reuse considerations for the Site.
SECTION C: COMMUNITY PARTICIPATION
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• On March 21, 2022, EPA published a fact sheet (English and Spanish versions) Site update which
provided a summary of the Superfund process. Site status update, next steps, and ways for the
public to get involved.
• On March 22, 2022, representatives from EPA participated in a hybrid (in person and online)
Town Council meeting in Windham. Maine to provide an update on the Site's status and answer
questions.
• In October of 2022, EPA mailed out additional letters soliciting community participation in the
development of the CIP.
• From July 2022 through January 2023 EPA conducted community interviews for the CIP and
interviewed Town Officials, nearby business owners. Friends of the Presumpscot River, and
residents neighboring the property.
• On June 1. 2023, EPA published the CIP to the Site's website. EPA also published a flyer
announcing a hybrid informational meeting to be held on June 27. 2023, the anticipated release of
the Proposed Plan, and the start of the public comment period on June 28, 2023.
• On June 26. 2023, EPA published a press release announcing the proposed cleanup, details of the
hybrid informational meeting, details on a hybrid public hearing, and how the public could find
more information about the Site.
• EPA held the hybrid informational meeting on June 27. 2023 to update the community on EPA's
findings in the Remedial Investigation and Feasibility Study Reports, which were made available
for public review via the Site's website, EPA's office in Boston. MA and the Windham Public
Library.
• From June 28, 2023 through July 28, 2023, EPA held a thirty-day public comment period to
accept public comments on EPA's proposed remedy for the Site presented in the Proposed Plan.
• EPA published legal notice of the availability of the Proposed Plan and public hearing in The
Portland Press Herald and Windham Eagle on July 14, 2023.
• A hybrid public hearing was held on July 18, 2023 at which community members could provide
written or oral comments on the Proposed Plan. A transcript of this meeting and the comments
received at the hearing, as well as EPA's response to comments, comprise the Responsiveness
Summary, which is included as Part 3 of this ROD.
D. SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION
The selected remedy was developed by combining source control and management of migration
components to obtain a comprehensive approach for Site remediation. Implementation of the selected
remedy will follow the substantial completion of the NTCRA to demolish the mill complex and
associated structures (partially or in full as determined by the design). In summary, the selected remedy
provides:
• Excavation and off-site disposal of approximately 22,000 cubic yards of contaminated soil and
debris from the Mill Complex Property;
• Targeted treatment of soil (within the footprint of the excavations) with amendments in support of
groundw ater cleanup;
SECTION D: SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION
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• In situ treatment of groundwater to reduce the mass, mobility and toxicity of contaminants;
• Excavation and off-site disposal of approximately 320 cubic yards of contaminated sediments
from the Target Reach of the Presumpscot River;
• Treatment of water generated from soil and sediment dewatering and removed from excavations
based on applicable water discharge standards, as required;
• Restoration of the portions of the Presumpscot River riverbed, riverbank, wetland and floodplain
habitat altered by the remedial action;
• Institutional Controls to prevent exposure to Site-related contaminants in groundwater and fish
tissue until cleanup levels are met;
• Inspections to evaluate Site restoration and stabilization activities, as well as O&M;
• Monitoring of groundw ater and fish tissue to evaluate the achievement of cleanup levels; and
• Periodic reviews, at a minimum of every five years, to assess the protectiveness of the remedy
until cleanup levels are achieved.
No principal threat wastes were identified at the Site. Principal threat wastes are those source materials
considered to be highly toxic or highly mobile which generally cannot be contained in a reliable manner
or would present an unacceptable risk to human health or the environment should exposure occur. Wastes
generally considered to be principal threats are liquid, mobile and/or highly-toxic source material.
However, source material at the Site, consisting primarily of COCs in the soil and debris that have
migrated to groundwater, sediment and fish tissue, constitute a low -level threat waste. Low -level threat
wastes are those source materials that generally can be reliably contained and that would present only a
low risk in the event of exposure. Wastes that are generally considered to be low-level threat wastes
include non-mobile contaminated source material of low to moderate toxicity, surface soil containing
COCs that are relatively immobile in air or groundwater, low leachability contaminants, or low toxicity
source material. The selected response actions will address low-level threat wastes at the Site through
excavation and off-site disposal of soil, debris and sediment; treatment of groundw ater; implementation of
Institutional Controls; monitoring; and Five-Year Reviews.
There is no current exposure to contaminated groundwater at the Site; however, all groundwater in Maine
is classified as not less than Class GW-A, which is suitable for use as a public water supply. Therefore,
the remedy reflects a need to achieve federal drinking water standards that constitute the beneficial use
standard for groundw ater beneath the Site. The selected remedy provides for removal of soil source
material and treatment within the excavation footprints with amendments, in situ treatment of
contaminated groundwater, restrictions to prevent exposure to contaminated groundwater until
groundw ater cleanup levels are achieved, and monitoring to document achievement of cleanup levels.
E. SITE CHARACTERISTICS
The most recent significant Site findings can be found in the Rl Report (November 2021) and the FS
Report (June 2023) and are summarized below .
SECTION E: SITE CHARACTERISTICS
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Physical Setting
The Site consists of a 6.93-acre abandoned mill property, located at 7 Depot Street (the Mill Complex
Property), an adjacent reach of the Presumpscot River, and associated riparian properties. The Mill
Complex Property is bounded to the north by Depot Street with commercial and residential properties
beyond; to the immediate northeast by a multi-unit apartment complex; to the east by a former Maine
Central Railroad right-of-way; to the south and southwest by an undeveloped property referred to herein
as the Transmission Line Property; to the south-southwest by the Presumpscot River; to the west by a
property that includes a dam and a hydroelectric power generating station (referred to herein as the
"Hydro Property"); and to the northwest by a multi-unit senior housing complex (Little Falls Landing).
The Mill Complex Property is currently vacant and a chain-link fence restricts access to the northern
portion of the parcel as well as into the mill buildings. The abandoned mill complex currently includes
several connected buildings. The Site lies on the northern and eastern side of the Presumpscot River,
adjacent to the Little Falls Dam and approximately '/2 mile upstream of the Mai li son Falls Dam. A
segment of the river flows beneath the western portion of the mill complex.
A Site Locus Map is provided as Figure 1 in Appendix C and a Site Plan is provided as Figure 2 in
Appendix C. More information about the land uses at and around the Site can be found in Section F.
Site Topography and Surface Features
The topography of the Mill Complex Property is depicted in Figures 3 in Appendix C. In the northern
portion of the Mill Complex Property, the terrain generally slopes downwards from the northern, eastern
and western perimeter tow ards the property center where the mill complex is located. Immediately north
of the mill complex are remnants of two building foundation slabs. The area north of the slabs is occupied
by fill consisting of demolition debris and byproducts of past metals fabrication and manufacturing. The
Mill Complex Property is generally vegetated by brush, saplings, and small trees; however, intermittent
vegetation clearing has been implemented for public safety purposes. The area north of the mill complex,
including soil and debris, is populated predominantly by ground cover.
A 6-foot-high chain-link fence encloses a portion of the Mill Complex Property along the western,
northern, eastern and southern perimeters and deters potential trespassers; however, trespassers have
continued to periodically enter the mill complex.
Site Geology
Geologic formations beneath the Site and surrounding areas consist of fractured crystalline (igneous
and/or metamorphic) bedrock, overlain by unconsolidated surficial (overburden) deposits of glacial and
post-glacial origin.
Fill was encountered in many of the borings and in the test pits advanced throughout the Site with
thicknesses generally ranging from approximately 5 feet to 15 feet. Anthropogenic fill included evidence
of burning (ash. coal, and/or slag), building debris (brick, concrete, and/or shingles), glass, metal, railroad
ties, plastic, rubber, leather scraps, and other fibrous material. Native materials primarily included sand,
some silt layers, and clay units in areas of deeper bedrock. Bedrock was encountered betw een 8.5 feet to
55 feet below ground surface (bgs).
The bedrock topography at the Site is dominated by a north-south bedrock trough. The bedrock surface
elevations drop off steeply (approximately 50 feet) from the western and northern perimeters of the Site to
the trough and increase more gradually from the trough to the eastern edge of the Site. In the vicinity of
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the mill complex, depth to top of bedrock ranges from -40 feet (SB-48) to 9 ft (SB-53), and almost 60
feet (SB-41) near Depot Street. Figure 4 in Appendix depicts the bedrock topography and outcrops based
on information developed during the Rl and prior investigations.
Hydrogeology
Overburden groundwater within the northeastern portion of the Site flows generally south, toward the
central portion of the property. The groundwater flow in the northwestern and western portions of the Site
may be impacted by mounding of groundwater behind the dam. Overburden groundwater in the east and
southeast portions of the Site, where present, can be expected to migrate toward the southwest and the
river (Figure 5 in Appendix C). Groundwater was encountered between approximately 6 feet bgs and 23
feet bgs.
Fractured bedrock underlies the Site and is anticipated to have little or no primary porosity or
permeability, so groundwater flow in bedrock can be expected only along permeable bedrock fractures
(Figure 6 in Appendix C).
Overburden and shallow bedrock groundwater at the Site are expected to discharge to the Presumpscot
River.
Surface Water and Wetlands
Storm water enters the Site through direct precipitation on the Mill Complex Property and from off
property drainage channeled into the Site. Figure 7 of Appendix C depicts the estimated drainage onto
and at the Mill Complex Property, including the approximate areal extent of ponding immediately north
of the mill complex. Some of the storm water and precipitation falling on the Site has been observed to
accumulate in the level portion of the Mill Complex Property, north of the mill complex, prior to entering
the basement and ultimately discharging through holes in concrete floor into the Presumpscot River.
The Site is located within and adjacent to the Presumpscot River, which begins at the outlet of Sebago
Lake. For the purposes of the RI/FS. three reaches of the Presumpscot River were defined (i.e., Upper
Reach. Target Reach and Lower Reach). The Target Reach was defined as the stretch of the Presumpscot
River between the Little Falls Dam and the nearest dow nstream dam (Mallison Falls Dam) and is
approximately 0.5 miles long. The Upper Reach is defined by the segment of the river upstream
(background) of the Little Falls Dam. while the Lower Reach is represented by the segment of the river
downstream of the Mallison Falls Dam. The Target Reach averages about 130 feet wide with a maximum
depth of 9 feet at mean high water flow (w ith variable flows depending on seasonal and overall
precipitation patterns and operation of the upstream dams) and is predominantly linear, with few coves
and a relatively uniform shoreline. Aquatic vegetation is sparse. Hard substrates predominate the river
bottom (gravel, cobble, boulder, bedrock), although sand is common in many areas. A portion of the
Target Reach flows beneath the western portion of the mill complex. The mean river discharge recorded
approximately 6 miles downstream of the Site is approximately 965 cubic feet per second (cfs).
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Water quality from the outlet of Sebago Lake to the confluence with Pleasant River (upstream of the Site)
is classified by MEDEP as Class A. Water quality from this point downstream to Saccarappa Falls, which
includes the Target Reach, has been classified as Class B.4 The river is Class C downstream of
Saccarappa Falls (Westbrook. Maine) to the tidewater. Presumpscot River tributaries are classified as
Class B.5
The westernmost portion of the Site is located in the 100-year Flood Zone. In this area the 500-year flood
zone is at a similar elevation, due to the presence of the adjacent dams that control the river's flow. An
estimated extended area of 500-year floodplain is also present approximately 400 feet west of the Site
boundary (i.e., west of Main Street/Route 202).
There are no vegetated freshwater wetlands identified on the upland portions of the Site; however,
approximately 5.6-acres along the eastern bank of the Target Reach fall within the jurisdiction of the State
Natural Resources Protection Act (NRPA). approximately 0.85-acres of which is within the footprint of
the Mill Complex Property. A wetland survey was completed within the Target Reach of the Presumpscot
River to identify and map federal jurisdictional wetland resources along the banks of the Presumpscot
River in support of Hazard Ranking System (HRS) scoring.' The survey identified approximately 0.783-
miles of federal jurisdictional wetland (R2EM2 - Riverine Lower Perennial Emergent Nonpersistent)
frontage, including approximately 0.068 miles abutting the Mill Complex Property and northwestern limit
of the Transmission Line Property.
Conceptual Site Model
A conceptual site model (CSM) is an iterative representation of a site that describes the know n and
suspected sources of contamination, types of contaminants, distribution and migration of contaminants for
various media, as well as the site-specific conditions that affect the potential migration and fate of
contaminants in the environment and know n or potential human health and ecological receptors.
The text in this section is also supported by a graphical CSM (see Figure 8 in Appendix C).
Known and Suspected Sources of Contamination
Know n and potential sources of contamination are generally related to past operations at the mill complex
and on-site disposal of manufacturing wastes, demolition debris, and ash from the heating or firing of the
furnaces. Know n and potential contaminant sources include:
• Mill wastes identified at the Site, including metal cuttings, billets and scraps, brick, wood, slag,
crushed drums, and concrete debris. Mill complex-related debris has also been observed within
4 Class B waters must be of such quality that they arc suitable for the designated uses of drinking water supply after
treatment; fishing; agriculture; recreation in and on the water; industrial process and cooling water supply;
hydroelectric power generation, except as prohibited under Title 12, section 403; navigation; and as habitat for fish
and other aquatic life. Class B waters must be of sufficient quality to support all aquatic species indigenous to those
waters without detrimental changes in the resident biological community. MRS Title 38, §465(3).
5 The State of Maine has four classes for freshwater rivers (AA, A, B. C from highest to lowest classification) as
described in MRS Title 38, §465. Standards for Classification of Fresh Surface Waters.
6 40 CFR 230.3 defines wetland as. "those areas that are inundated or saturated by surface or ground water at a
frequency and duration sufficient to support, and that under normal circumstances do support, a prevalence of
vegetation typically adapted for life in saturated soil conditions"
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the Presumpscot River adjacent to the Site, likely as a result of building deterioration and
vandalism;
• Surface staining and presence of byproducts of combustion (i.e., coal, ash) and high temperature
combustion (i.e., slag);
• Past use of multiple storage tanks located ad jacent to Depot Street, two above-ground storage
tanks (AST) in the northeast corner of the property, and several tanks within the mill complex.
Petroleum product was also encountered in select soil borings and monitoring wells proximate to
Depot Street during the Rl and other investigations;
• An exterior electrical substation with three transformers;
• PCB contamination detected within the mill complex building materials;
• A sump in the floor of the former Melt Building which, along with several floor cutouts,
discharged directly to the Presumpscot River;
• Mill complex walls and floors contaminated by PCB-containing dielectric fluid as the result of
electrical equipment, possibly transformers, overheating and bursting were historically cleaned
with a chlorinated solvent which could mobilize contaminants to other environmental media (e.g.,
soil);
• Two 1,000-gallon septic tanks historically located adjacent to the southeastern exterior wall of
mill complex; and
• Asbestos at greater than regulatory thresholds in building materials and debris.
Chemical concentrations detected in soil, groundwater, sediment, surface water (Presumpscot River) and
biota may have originated from various potential sources detailed above. Contaminants may migrate from
the original release or disposal locations through multiple fate and transport processes (e.g., erosion and
runoff, dissolution). Fill was encountered throughout the Site, in some areas at the ground surface and
therefore subject to erosion, at thicknesses of 5 to more than 15 feet. Fill frequently contained ash. coal,
slag, building debris, and miscellaneous rubbish. The fill material is relatively coarse, allow ing for
percolation and migration of water and contaminants. As a result, soil and debris material are considered
the primary source of contamination at the Site. Mobilization of contaminants from soil and debris is
understood to have impacted groundwater (e.g., leaching), sediment (e.g., erosion and runoff) and fish
tissue via food chain uptake within the Target Reach of the Presumpscot River.
Nature & Extent of Contamination
The follow ing summarizes the interpreted nature and extent of soil and debris material, groundw ater
(overburden, bedrock and associated vapors), surface water, sediment, and fish tissue contamination.
Consideration of the leaching from soil to groundwater and vapor intrusion pathways are also described.
Soil
Soil and debris are the primary impacted media at the Site. Figures 9A and 9B in Appendix C provide
the estimated extents of cleanup level exceedances in shallow and aggregate soil, respectively.
Contaminants detected in soil included volatile organic compounds (VOCs). semi-volatile organic
compounds (SVOCs) (particularly polyaromatic hydrocarbons | PAHs|). PCBs. dioxins/furans, metals.
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and cyanide. Pesticides and per- and polyfluorinated alkyl substances (PFAS) were infrequently detected
at concentrations below soil screening criteria.
VOCs. primarily associated with chlorinated solvents, were detected at generally low concentrations. Past
disposal of ash. slag, and manufacturing wastes and release of fuel have resulted in the presence of
SVOCs. in particular carcinogenic PAHs. throughout the Site at concentrations exceeding screening
criteria. Elevated concentrations of PAHs. primarily benzo(a)pyrene. were detected in the vicinity of the
mill complex and adjacent to Depot Street. Past releases and demolition activities have resulted in PCBs
present in surface (0 to 0.5 feet) and subsurface (>0.5 feet) soil throughout the Mill Complex Property at
concentrations above screening criteria. The highest total PCB concentrations were detected in samples
obtained near the mill complex and from the debris piles situated north of the mill complex. Dioxins and
furans were detected sporadically throughout the area north of and around the mill complex. Antimony,
arsenic, copper, iron. lead, and mercury appear to be present at concentrations in soil above Site-specific
background as a result of past industrial activities at the Site. With the exception of arsenic, elevated
metals were generally distributed north of and near the mill complex. Elevated arsenic was detected
throughout the Site, but the highest concentrations were detected close to the edge of and south of the mill
complex.
Leachabilitv from Soil to Groundwater
Surface and subsurface soil results above the water table were compared to EPA's protection of
groundwater soil screening levels (SSL), assuming a dilution attenuation factor (DAF) equal to 10.7 The
results were also compared to the State screening levels for leachabilitv of contaminants in soil to
groundwater. The leachabilitv criteria represent conservative values and can overestimate the actual
leachabilitv of soil chemicals. These comparisons provide an indication of potential leachabilitv.
Chemicals detected in groundwater (discussed below) provide a more representative indication of which
chemicals can leach and to what degree.
The leachabilitv comparison suggests that VOCs. which can exhibit relatively low solubility and high
vapor pressure and will preferentially volatilize or dissolve into water rather than sorb to soil particles or
organic matter (e.g., TCE), in soils within localized portions of the Site may migrate and cause a potential
threat to groundwater quality. SVOCs. PCBs and dioxins/furans may also pose a threat to groundwater
quality based on the comparison of soil data to screening criteria; however, the presence of elevated
concentrations of these compounds in overburden groundwater was limited (see discussion below). The
leaching evaluation also suggests that metals may pose a risk of leaching to groundwater; however, site-
specific conditions such as the soil's buffering capacity. pH of the precipitation, and the ionic state of the
metal may affect the metal's propensity to leach. The evaluation indicates that both Site-related (e.g.,
arsenic) and naturally-occurring metals (e.g., aluminum) may be leaching to groundwater.
Groundwater (Overburden and Bedrock)
Consistent with contaminants detected in Mill Complex Property soils, contaminants detected in
overburden groundwater include VOCs. SVOCs (particularly PAHs). PCBs. dioxins/furans. metals and
7 EPA guidance established a default D AF equal to 1 (i.e., the lowest possible D AF which assumes no dilution or
attenuation of the contaminant); however, as is the case for many NPL sites, this assumption is conservative when
sitc-spccific conditions arc evaluated. A default D AF of 10 is cited in EPA guidance (U.S. EPA, 1996b) as
protective of sites ranging from 3 to more than 30-acres in si/c and. based on Sitc-spccific conditions, was deemed
appropriate.
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cyanide. How ever, there are no well-defined plumes of contamination, only localized areas with elevated
chemical concentrations. Pesticides were not detected or were infrequently detected at concentrations
below groundwater screening criteria and therefore do not represent significant Site-related contaminants.
The analytical results suggest that select contaminants have migrated from soil and/or debris, as well as
other potential sources (e.g., former fuel tanks proximate to Depot Street) into groundwater. Figure 10 in
Appendix C provides the estimated extent of cleanup level exceedances in groundw ater.
Generally low concentrations of VOCs were detected in overburden groundwater with few exceedances
of screening criteria. Samples obtained from monitoring wells located close to the mill complex exhibited
elevated TCE. While SVOCs were detected, elevated concentrations of these compounds were limited to
monitoring wells situated adjacent to Depot Street, close to where fuel oil tanks were previously installed.
Both benzo(a)pyrene and bis(2-cthylhexyl)phthalate were detected above Safe Drinking Water Act
(SDWA). Maximum Contaminant Levels (MCLs) in overburden monitoring well MW-08. Measurable
petroleum-based product was observed in MW-08, petroleum product was observed during the
installation of MW-03 in 2016 and a thick liquid was observed in MW-01 in December 2021. PCBs were
detected in all overburden groundwater samples, but at generally low concentrations and almost all results
were below screening criteria. One sample collected from MW-08 exceeded screening criteria for total
PCB homologues. This detection is co-located with the above noted SVOC impacts near Depot Street.
Dioxins and furajis were detected in one sample collected from overburden monitoring well MW-09S
above screening criteria. Based on past Site activities and related metals detected at elevated
concentrations in soil and/or debris samples, target metals (arsenic, iron, and manganese) and cyanide
were detected in overburden and/or bedrock groundwater at elevated levels. Arsenic was the only
detected chemical in groundwater that exceeded the MCL. PFAS were also infrequently detected in
overburden groundwater. One overburden well exhibited a perfluorooctane sulfonate (PFOS)
concentration of 6.9 nanograms per liter (ng/L) (7.0 ng/L in the duplicate sample).
Consistent with contaminants detected in Mill Complex Property soil and overburden groundwater,
contaminants detected in bedrock groundwater include VOCs. SVOCs. PCBs. and metals. Pesticides and
dioxins/furans were not detected in any of the bedrock groundwater samples analyzed.
While several VOCs were detected, only a few exceeded screening criteria. Samples obtained from
bedrock monitoring wells located close to the mill complex exhibited elevated TCE, which is the only
VOC that was detected above an MCL. Select SVOCs were detected in bedrock groundwater; however,
all detections were below screening criteria. PCBs were detected in all bedrock groundwater samples;
however, only one sample (MW-06B) exceeded the MCL. Based on past Site activities and related metals
detected at elevated concentrations in soil and/or debris samples, arsenic, cobalt, iron, and manganese,
were detected in bedrock groundwater at elevated levels and above screening criteria. Arsenic was the
only detected chemical in groundwater that exceeded the MCL (MW-07B). Only one PFAS compound
(PFHxA) was detected in one sample (MW-07B) at a concentration of 6.5 ng/L.
Vapor Intrusion from Groundwater to Air
Noting that partial or full demolition of the mill complex will occur during the implementation of the
NTCRA, an evaluation of potential vapor intrusion risk was conducted in support of the RI/FS. Localized
groundwater TCE concentrations near the mill building (if used for residential or commercial purposes)
may impact indoor air. based on exceedances of both the commercial and/or residential vapor intrusion
screening levels (VISL) in samples collected from select monitoring wells (MW-09S, MW-10D. MW-
05B). Ethylbenzene. naphthalene (the only SVOC with an established VISL) and vinyl chloride were all
detected above commercial and/or residential VISLs in overburden groundwater collected near Depot
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Street (MW-08) and may impact indoor quality if a structure is constructed in this area of the Site.
Bedrock groundwater collected from MW-06B exceeded the residential VISL for the PCB-126 congener;
however, this monitoring well is located south of the mill complex within the bedrock and is unlikely to
impact indoor air quality. None of the detected dioxins/furans. mercury or cyanide concentrations in
groundwater exceeded applicable VISLs.
Surface Water
Surface water (total and dissolved) were collected from various segments of the Presumpscot River (i.e.,
Upper. Target and Low er Reaches). The distribution of Rl samples and exceedances of screening criteria
are depicted in Figure 11 in Appendix C.
No VOCs. SVOCs or dioxins/furans were detected in any of the surface water samples. Pesticides
including 4.4'-dichlorodiphenyltrichloroethane (4.4-DDT). dieldrin. and endrin were detected in one
sample (SW-29 within the Target Reach) in excess of screening criteria; how ever, pesticides were not
detected in any other surface water samples. PCBs were detected in many samples, including all Upper
and Low er Reach samples and the majority of Target Reach samples, and all detections exceeded
screening criteria. The highest total PCBs concentration were detected in the SW-05 sample located
southwest of the mill complex near the western perimeter of the Site. PCBs appear to be the primary Site-
related contaminant present in surface water; however. PCBs were also detected in Upper Reach samples.
The presence of PCBs in excess of screening criteria in the Upper Reach indicates that, in addition to the
Site, upstream sources are likely contributing to the presence of PCBs within the Target and Lower
Reaches. For metals, only aluminum was detected (four Target Reach samples only) above screening
criteria. Notably, aluminum in soil was determined to be present at concentrations consistent with
background.
Sediment
VOCs were detected in all three river reaches sampled in support of the Rl. pesticides were detected in
select Target Reach sediment samples, and the focused sampling for dioxins/furans indicated the presence
of these compounds in all three river reaches. However, the detected concentrations of these contaminant
classes did not exceed sediment screening criteria.
SVOCs were detected in samples from all three river reaches with PAHs exceeding screening criteria.
Target Reach samples exhibited higher PAH concentrations than the Upper Reach samples. PCBs were
detected in samples from all three river reaches and samples collected within the Target Reach near the
mill complex (SED-05 and SED-06) exceeded screening criteria. Several metals of interest related to past
industrial activities at the Site exceeded screening criteria (e.g., antimony, arsenic, iron, lead and
manganese). Samples located closest to the Site exhibited higher concentrations of metals (e.g., arsenic
and lead). Figures 11 and 12 in Appendix C depicted the Rl distribution of PCBs and metals,
respectively, within the Presumpscot River.
Although Upper Reach sediment samples exhibited elevated concentrations of SVOCs. PCBs. and select
metals, indicating an upstream contribution of these contaminants, a greater number of analytes at higher
concentrations were generally detected within the Target Reach. The presence of elevated concentrations
of SVOCs. PCBs. and select metals in Presumpscot River sediments appears to be related, in part, to past
industrial activities at the Site. Migration to the river sediments is likely primarily the result of runoff
resulting in soil erosion or from releases from the mill buildings (some of which overhang the river).
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Biota
Various types of fish and earthworms were sampled to support risk assessment activities for the Site. Fish
tissue (smallmouth bass fillets) samples indicate the follow ing:
• Upper Reach - Arsenic was detected above the screening criterion in one sample;
• Target Reach - All samples exceeded the PCB congener toxicity equivalence quotient (TEQ) and
total PCB homologues criteria and one sample exceeded the copper criterion. Aluminum, copper,
lead, nickel, and zinc also exceeded ecological benchmarks; and
• Lower Reach - All samples exceeded the PCB congener TEQ and total PCB homologues criteria.
The frequency of PCB detections and exceedances of screening criteria (w hich does not necessarily
trigger unacceptable risk) in the Target Reach and Lower Reach samples compared to those in the Upper
Reach samples, which did not have detections in excess of screening criteria, suggests that the PCBs
ingested by the fish are likely, in part. Site-related. Furthermore, the average concentrations of total PCBs
in Lower Reach fish tissue (i.e., smallmouth bass fillet and whole body concentrations of 0.0596 and
0.272 milligrams per kilogram wet weight | mg/kg ww], respectively) were significantly less than in the
Target Reach (i.e., 0.455 and 1.24 mg/kg ww, respectively). This is consistent with the localized presence
of elevated PCBs in sediments, primarily in close proximity to the mill complex, contributing to Target
Rach fish tissue concentrations via food chain uptake and a relative lack of a significant Site-related
source material within the Lower Reach contributing to fish tissue concentrations.
Earthworm tissue data (background and Site-related) were collected and used to reduce the uncertainty
associated with dietary exposure to wildlife inhabiting the terrestrial habitat of the Site, and were used to
refine the risk estimate for invertivores birds and mammals in the ecological risk assessment. One SVOC
(bis(2-cthylhexyl)phthalate). PCB homologues. dioxins/furans and target metals (w ith the exception of
beryllium) were detected in both Site-related and background earthworm samples.
Private Wells
Following an assessment to identify private wells within a 1 -mile radius of the Site, select homeowners in
the vicinity of the Site were offered the opportunity by EPA for their private wells to be sampled to assess
whether their potable water supply might be affected by contaminated on-site groundwater. The nearest
private wells were situated hydraulically upgradient of the Site to the east and southeast.
Five private well owners located in South Windham agreed to have samples collected and analyzed for
suspected Site-related COCs. The analytical results indicate that, while several VOCs (primarily gasoline
constituents). SVOCs. PCBs. and metals were detected, none exceeded the federal MCLs or Health
Advisories. Based on a comparison of the private well results with monitoring wells located at the Site,
the private wells do not appear to have been impacted by contamination from the Site. The private wells
are located hydraulically upgradient of the Site, indicating that groundwater would tend to flow from the
private wells toward the Site and/or the Presumpscot River. Additionally, the individual compounds and
metals detected in the private wells are generally dissimilar to those detected in Site groundwater samples
and/or generally consistent with local conditions.
Contaminant Fate and Transport
The primary COCs at the Site include, but are not limited to the follow ing:
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• Volatile Organic Compounds (VOCs) - VOCs include a variety of chemicals which are used as
ingredients in many products and materials such as glue, paint, and solvents. Volatile organic
compounds are organic chemical compounds that easily evaporate. VOCs found in soil and
groundwater at the Site include TCE, chloroform. 1.4-dichlorobenzene and vinyl chloride.
• Semivolatile Organic Compounds (SVOCs) - SVOCs are chemicals that tend to have a higher
molecular weight and boiling point than VOCs. Bis(2-cthylhexyl)phthalate and
pentachlorophenol are present primarily in groundwater at the Site.
• Polvaromatic Hydrocarbons (PAHs) - PAHs are a subgroup of SVOCs formed during the
incomplete burning of coal, oil and gas. garbage, and other organic substances like tobacco or
charbroiled meat. Several Site-related PAHs. including benzo(a)pyrene. chrysene.
dibenz(a.h)anthracene. naphthalene and 2-methylnaphthalene were detected primarily in soil
and/or groundw ater.
• Polvchlorinated Biphenvls (PCBs) - PCBs are man made chemicals that were used in electrical
manufacturing and were banned in 1979. They are persistent in the environment, meaning they do
not readily degrade and are known to bioaccumulate. PCBs are present primarily in soil,
sediment, groundwater, and fish tissue at the Site.
• Dioxins/Furans and Dioxin-like PCBs - Dioxins/furans are a family of chemicals that are
primarily created when other chemicals or products are made (i.e., dioxins/furans are not
intentionally produced) including in the pulp and paper industry. The most well-known chemical
is 2,3,7,8-Tetrachlorodibenzo-p- Dioxin (2,3,7,8-TCDD). Dioxin-like PCBs have a similar
toxicity and share chemical characteristics with dioxins/furans. Dioxins/furans and dioxin-like
PCBs are primarily present in soil and groundwater at the Site.
• Metals - Metals are minerals that naturally occur in the Earth's crust and vary based on local
geology. Human activities and land disturbance can redistribute or concentrate metals in areas
where they may not have been present, or mobilize metals (e.g., dissolving them into
groundwater). While some metals are essential as nutrients, all metals can be toxic at some level.
Metals present at the Site include antimony, arsenic, cyanide, iron, and manganese. These metals
were primarily found in soil and/or groundwater at the Site.
• Cvanide - Cyanides are sorbed by various natural media, including clays, biological solids, and
sediments. Cyanide was primarily detected in soil and overburden groundwater at the Site.
The primary pathways for contaminants to migrate from the Site are storm water erosion of soil particles,
dust erosion, and precipitation infiltration, dissolution, and advection of dissolved chemicals in
groundwater. Contaminants in soil and groundwater can be mobilized and migrate into the adjacent
Presumpscot River surface water and sediments. Soil and debris contaminated with VOCs. SVOCs
(primarily PAHs). PCBs. metals, and/or dioxins/furans can be transported through airborne dust, erosion,
and storm water runoff that carries the contaminants into the river. Precipitation infiltration can leach
some organic compounds and metals into groundwater. While some of the leached chemicals may be
sorbed to subsurface materials, others will continue to be mobilized with groundwater advection. Based
on the evaluation of hydraulic heads and groundw ater gradients, soluble chemicals in overburden and
bedrock groundwater are expected to discharge to the river. Soluble chemicals including VOCs. some
SVOCs. some PCB compounds, and some metals are expected to migrate through groundwater advection.
Once chemicals enter the river either sorbed to particles or in the dissolved phase, the chemicals may
volatilize and undergo degradation in the atmosphere, sorb to sediment that are transported downstream
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via surface water or are deposited in the river channel, or may undergo further geochemical or biological
transformation processes.
Routes of Exposure and Potential Receptors
Exposure occurs when people or other living organisms eat. drink, breathe or have direct contact with a
substance or waste material. There must be a current or potential exposure to a hazardous substance for
there to be a risk to human health. EPA develops various exposure scenarios to determine potential risks,
appropriate cleanup levels for contaminants, and potential cleanup approaches. Exposure scenarios for the
Site were developed considering the nature and extent of contamination, the location of the Site, current
and future potential use of the Site, and potential receptors and exposure pathways.
Human Health
The Site is currently vacant and access to the northern portion of the Mill Complex Property is restricted
by a fence and two gates; however, trespassing is know n to occur. The nearest residence to the Site is a
multi-unit complex (Station Lane complex) abutting the Mill Complex Property to the northeast. A senior
housing complex (Little Falls Landing) also abuts the Mill Complex Property to the west. The nearest
childcare center is located approximately 2.1-miles from the Site.
The Site includes a portion of the Presumpscot River (Target Reach) and the western portion of the mill
complex rests over the river. The Presumpscot River is know n to be used for various recreational
activities including fishing, kayaking and canoeing; however, recreational use of the Target Reach is
restricted by the presence of private properties and limited public access points (e.g., hand carry boat
launches). Current recreation exposure, including ingestion of fish tissue, was evaluated.
The closest public water supply is provided by the Portland Water District (PWD), which recently
expanded infrastructure along Depot Street and the surrounding neighborhood north-northeast of the Site.
The PWD uses surface water intake pipes from the southern edge of Sebago Lake, located upstream of the
Site. Most of the nearby residents have access to public drinking water provided by the PWD.
Groundwater from the Site is understood to discharge to the Presumpscot River. Properties that have
private wells are located hydraulically upgradient of the Site or on the western side of the Presumpscot
River. Therefore, current nearby receptors are not expected to contact Site groundwater as drinking water
or for household use. There are no current structures at the Site that could potentially result in exposure to
contaminants in indoor air via the vapor intrusion pathway.
To evaluate potential future exposures, it was assumed that no additional remedial action was taken and
the levels of contamination currently present at the Site would remain unchanged. How ever, since future
activities at the Site may differ (e.g., removal of security fence), potential exposure to anticipated future
receptors was also considered. Receptors included in future use exposure scenarios include future
trespassers, residents, commercial/industrial workers, construction/excavation workers, and recreational
visitors.
The follow ing table provides a summary of human health exposure pathways evaluated for each exposure
seenario/exposure point in the BHHRA dated June 2023:
Receptor
Population
Scenario
Timeframe
Exposure
Medium
Exposure Point
Exposure Route
Trespasser
Current /
Future
Soil
Surface Soil (Mill
Complex Property)
Ingestion
Dermal Contact
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Receptor
Population
Scenario
Timeframe
Exposu re
Medium
Exposure Point
Exposure Route
Inhalation
Resident
Future
Soil
Surface Soil (Mill
Complex Property)
Ingestion
Dermal Contact
Inhalation
Commercial /
Industrial Worker
Future
Soil
Surface Soil (Mill
Complex Property)
Ingestion
Dermal Contact
Inhalation
Recreational Visitor
Future
Soil
Surface Soil (Mill
Complex Property)
Ingestion
Dermal Contact
Inhalation
Resident
Future
Soil
Aggregate Soil (Mill
Complex Property)
Ingestion
Dermal Contact
Inhalation
Commercial /
Industrial Worker
Future
Soil
Aggregate Soil (Mill
Complex Property)
Ingestion
Dermal Contact
Inhalation
Construction /
Excavation Worker
Future
Soil
Aggregate Soil (Mill
Complex Property)
Ingestion
Dermal Contact
Inhalation
Resident
Future
Groundwater
(Overburden
and Bedrock)
Tapwater
Ingestion
Dermal Contact
Inhalation
Construction /
Excavation Worker
Future
Shallow
Groundwater (0
to 8 feet)
Shallow Groundwater
Dermal
Recreational Visitor
Current /
Future
Surface Water
Target Reach of the
Presumpscot River
Dermal
Recreational Visitor
Current /
Future
Sediment
Target Reach of the
Presumpscot River
Ingestion
Dermal
Recreational Visitor
Current /
Future
Fish Tissue
Sinallmouth Bass -
Target Reach of the
Presumpscot River
Ingestion
Resident
Future
Air
Indoor Air (Mill
Complex Property)
Inhalation
Construction /
Excavation Worker
Future
Air
Excavation / Trench Air
Inhalation
Ecological
The ERA focused on the receptors that are ecologically significant, of high societal value, highly
susceptible, and/or representative of broader groups. The ERA dated June 2023 evaluated the follow ing
potential ecological exposure pathways:
Exposure Media
Receptor(s)
Exposure Area
Assessment Endpoint
Soil (Direct Exposure -
Mill Complex Property)
Terrestrial Plants
Mill Complex Property
Plant growth, yield or
germination
Terrestrial Invertebrates
Mill Complex Property
Growth, reproduction or
activitv
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Exposure Media
Recei>tor(s)
Exposure Area
Assessment Endpoint
Soil (Indirect Exposure -
Mill Complex Property)
Avian Community
(Invcrtivores)
Mill Complex Property
Survival, growth or
reproduction
Small Mammal
Community (Invcrtivores)
Survival, growth or
reproduction
Sediment (Direct
Exposure)
Benthic Community
Target Reach of the
Presumpscot River
Survival, growth or
reproduction
Surface Water (Direct
Exposure)
Aquatic Community
Target Reach of the
Presumpscot River
Survival, growth or
reproduction
Herptile Community
Survival, growth or
reproduction
Fish Community
Survival, growth or
reproduction
Sediment / Surface Water
(Indirect |Dietary|
Exposure)
Avian Community
(Invcrtivore / Piscivore)
Target Reach of the
Presumpscot River
Survival, growth or
reproduction
Mammalian Community
(Invcrtivore / Piscivore)
Survival, growth or
reproduction
There is no direct evaluation of groundw ater data because it is assumed that the current surface water data
reflect potential influences from groundwater discharging to surface water. The major exposure routes to
ecological receptors consist of direct contact with soil, sediment and surface water, as well as indirect
exposure (food chain transfer) from soil, sediment and surface water.
Although inhalation and dermal absorption pathways are possibly complete for some receptors, these
pathways are considered to be minor compared to dietary ingestion and were not evaluated.
F. CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES
Land Uses
The current and reasonably anticipated future land uses of the Site form the basis for the exposure
assumptions that are used for the risk assessment, are considered in the development of remedial
objectives and remedial alternatives, and are considered in the selection of the appropriate remedial
action. The follow ing summarizes the currently understood and reasonably anticipated future land uses
for the various portions of the Site.
Mill Complex Property
The Mill Complex Property, which constitutes the majority of the Site, is currently unoccupied and is
zoned as part of a Village Commercial (VC) district and is in a Shoreland General Development (GD)
district zone. Per Section 400 (Zoning Districts) of the Town's Land Use Ordinance, the VC zoning
allows for multiple uses including: residential, childcare. senior housing, commercial facilities,
restaurants, and recreational facilities. The Shoreland Zoning District was previously rezoned from an
Industrial Zone designation by contract between the Tow n and the Village at Little Falls. LLC. The
Village at Little Falls Contract Zone (VLF) was established on June 1. 2005 to amend the area's zoning
from industrial to multi-unit residential. A previously proposed development contained a combination of
apartments, "porch units", duplexes, tow nhouses. and an expanded tow nhouse.
The Site is strategically located within the Town of Windham, as well as on the opposite bank of the
Presumpscot River from the Tow n of Gorham. close to major highways (e.g., Interstate 95) and major
cities (e.g., Portland. Maine). Recent discussions with the Tow n, as well as development of an updated
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Master Plan, confirmed significant municipal interest in the future use of the Mill Complex Property
including potential mixed residential, recreational and retail/commercial uses.
Transmission Line Property
In addition to the Mill Complex Property. Site-related contamination (e.g., PCBs) has come to be located
within portions of the parcel to the south, which encompasses upland areas along the eastern bank of the
Presumpscot River and submerged portions of the river; however, the upland (terrestrial) portion of the
parcel is being managed through State authority and oversight. The parcel is currently owned by
Presumpscot Hydro, a wholly ow ned subsidiary of Dichotomy Power Maine. LLC. Prior to November
2022, this parcel, as well as the Hydro Property, were ow ned by Sappi.
An Environmental Covenant, applicable to both the Hydro and Transmission Line Properties, was
executed on November 10, 2015 and included perpetual activity and use limitations (i.e., no extraction of
groundw ater without permission from MEDEP, no excavation of soil without permission from MEDEP.
and acceptable uses of the property only include "utility purposes").
Per the Amendment to the Joint Application for Approval License Transfer and Lease submitted to the
Federal Energy Regulatory Commission on June 21, 2021 for the Saccarappa. Mallison Falls. Little Falls.
Gam bo. Dundee and Eel Weir Projects, the investigation and remediation obligations under MEDEP's
Voluntary Response Action Program (VRAP) were retained by Sappi. As the current owner. Presumpscot
Hydro will also be required to meet certain obligations under the VRAP and CERCLA (e.g., providing
reasonable access to and across the Transmission Line Property). As a result, it is anticipated that the
terrestrial portion of the Transmission Line Property (i.e., upland and bank soil exclusive of Presumpscot
River sediments in the Target Reach), will continue to be managed and adequately remediated under State
authority and oversight. EPA will continue to coordinate with the MEDEP to ensure implementation of
the Transmission Line Property remedy is protective of human health and the environment.
Presumpscot River
The Site is located adjacent to and includes a limited segment (i.e., Target Reach) of the Presumpscot
River, which begins at the outlet of Sebago Lake and flows through the Towns of Standish. Gorham.
Windham. Westbrook. Falmouth, and Portland before draining into Casco Bay. The Presumpscot River is
approximately 24 miles long and drains an area of approximately 615 square miles. The Presumpscot
River provides recreational benefits to the surrounding communities and there is local interest in
enhanced river recreation and public access for activities such as fishing, boating, walking and hiking
in/along the Target Reach.
Ground and Surface Water Uses
While groundwater is currently not used as a potable supply, it may be used as a potable supply under a
future residential scenario and all groundwater in Maine is classified as not less than Class GW-A, unless
otherw ise provided by the statute. In the State of Maine, Class GW-A is defined as being the highest
classification and of such quality that it can be used for public water supplies.
The closest public water supply is provided by the PWD. The PWD uses surface water intake pipes from
the southern edge of Sebago Lake, located upstream of the Site. The PWD provides potable water to
customers in both Windham and Gorham.
The Presumpscot River is used for hydroelectric power, recreational use. and fishing. As a navigable
water body that is classified as Class A-C, the river is protected under the CWA. The Little Falls
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hydroelectric dam is located ad jacent to the Site and has a generation capacity of approximately 1,000
kilowatts. There is no current timeframe for the potential removal of the dam. which would likely be
based, in part, on the reestablishment of fish migration within lower reaches of the Presumpscot River.
The Presumpscot River is managed as a multi-species fishery along its entire length. The river, both in
Windham and other areas, and several tributaries are stocked with brook trout, brow n trout, and
landlocked salmon; however, fish are not stocked between the Little Falls and Mallison Falls dams (i.e.,
Target Reach) due to a lack of habitat and limited river access. The river is primarily managed for its
salmonid population; however, largemouth bass, smallmouth bass, brown bullhead, and yellow perch are
also present. The area dow nstream of Mallison Falls (i.e., Lower Reach) is used for consumptive fishing.
G. SUMMARY OF SITE RISKS
Human Health Risk Assessment
A BHHRA. conducted pursuant to EPA Risk Assessment Guidance for Superfund (RAGS), was
completed to evaluate the likelihood and magnitude of potential human health effects associated with
current and possible future land uses of the Mill Complex Property as listed on the NPL inclusive of
portions of the Presumpscot River.8 The BHHRA generally included the following evaluations:
• Hazard Identification - Identified those hazardous substances which, given the specifics of the
Site, were of significant concern;
• Exposure Assessment - Identified actual or potential exposure pathways, characterized the
potentially exposed populations, and determined the extent of possible exposure;
• Toxicity Assessment - Considered the types and magnitude of adverse health effects associated
with exposure to hazardous substances, and
• Risk Characterization and Uncertainty Analysis - Integrated the three earlier steps to summarize
the potential and actual risks posed by hazardous substances at the Site, including carcinogenic
and non-carcinogenic risks and a discussion of the uncertainty in the risk estimates.
The results of the BHHRA were refined in a HHRA Addendum (2020), that assessed the results of
supplemental data collection including private well sampling and chromium speciation data, and further
considered Site-specific exposure assumptions in a May 2023 technical memorandum. The cumulative
results of these evaluations are summarized below .
Hazard Identification
Forty-eight of the approximately 108 chemicals detected at the Site were selected for evaluation in the
HHR A as chemicals of potential concern (COPCs). The COPCs were selected based on toxicity,
concentration, frequency of detection, and mobility and persistence in the environment, and can be found
in Tables 2.1 through 2.8 of the BHHRA. The COPCs are listed in Tables G-l through G-8 of Appendix
B along with the exposure point concentrations (EPCs) used to evaluate the reasonable maximum
8 Risk characterization at the abutting the Hydro Property and along the bank of the Transmission Line Property
were conducted by S.D. Warren Company dba Sappi Fine Paper North America in coordination with EPA and
MEDEP. Human health risks identified at the Transmission Line Property arc being managed by MEDEP through
the VRAP. See Phase II Site Characterization and Remedial Options Analysis (TRC, 2013).
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exposure (RME) scenario in the BHHRA. Estimates of average or central tendency exposure (CTE)
concentrations for the COPCs and all COPCs can be found in Appendix A .Tables 3.1 through 3.8 of the
BHHRA (Nobis, 2021).
From the list of COPCs. a subset of the chemicals was initially identified in the Remedial Technologies
Screening Technical Memorandum (Nobis, 2021) as presenting a significant current or future risk and/or
were identified at the Site in excess of the appropriate chemical-specific Applicable or Relevant and
Appropriate Requirement (ARAR) value requiring Preliminary Remediation Goal (PRC) development.
These chemicals are referred to as the COCs and. as refined for the purposes of the FS Report, include the
following:
Exposure Media
Contaminants of Concern
Soil (Mill Complex
Property)
Benzol a )py renc. dibcn/o(a.h)anthraccnc. 2,3,7,8-TCDD TEQ, total PCBs.
antimony, arsenic, and iron
Groundwater
1,4-Dichlorobenzene, chloroform, trichlorocthenc. vinyl chloride.
benzo(a)pyrene, bis( 2-cthy lhcxy 1 Iphthalate. 2-mcthvlnaphthalcne.
pcntachlorophenol. 2,3,7,8-TCDD TEQ, total PCBs, arsenic, iron and manganese
Shallow Groundwater
(Construction Trenches)
Naphthalene and cyanide
Sediment
No COCs selected (no unacceptable human health risk)
Surface Water
No COCs selected (no unacceptable human health risk)
Fish Tissue (Target Reach
of the Presumpscot River)
Total PCBs
Hexavalent chromium and thallium, identified as soil risk drivers in the BHHRA. were determined to be
consistent with background concentrations in soil. Based on supplemental data collection (e.g., chromium
speciation result), consistency with background and a lack of known Site-related sources, hexavalent
chromium and thallium were removed as COCs in soil. Details regarding these determinations can be
found in the Summary of Exposure Assumption Refinements to Baseline Human Health Risk Assessment
technical memorandum dated May 22, 2023.
Benzo(a)pyrene and b i s( 2 -cthy 1 he xy 1)phthalate in groundwater were not identified as COCs; however,
they are included because their maximum detected concentrations in groundwater exceed a chemical
specific-ARAR value (e.g., MCLs).
Exposure Assessment
EPCs are the CO PC concentrations that a receptor is assumed to encounter during exposure to Site
contaminated media. In general, the 95% upper confidence level (UCL) of the arithmetic mean
concentration was used as the EPC for both CTE and RME scenarios, where an adequate sample size
existed. In cases where a CO PC within an exposure point had a small sample size or a small number of
detected concentrations, the maximum concentration was selected as the EPC. The EPCs used to evaluate
the RME and CTE scenarios can be found in Appendix A, Tables 3.1 through 3.8 of the BHHRA (Nobis,
2021).
Exposure doses are dependent upon the magnitude, frequency, and duration of exposure. They are
estimated by combining the CO PC concentration (i.e., the EPC) and the exposure parameters. The
exposure doses are expressed as intakes in milligrams of CO PC per kilogram of body weight per day
(mg/kg-day). The lifetime average daily dose (LADD) or the lifetime average daily exposure (for
inhalation pathways), which is averaged over a 70-year lifetime, was used to estimate exposure dose for
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carcinogens. The average daily dose (ADD) or average daily exposure (for inhalation pathways), which is
averaged over the actual exposure duration for each receptor, was used to estimate exposure dose for non-
cancer compounds.
As described in the Summary of Exposure Assumption Refinements to Baseline Human Health Risk
Assessment technical memorandum dated May 22, 2023, limited refinement of the exposure assumptions
in the BHHRA occurred in support of development of human health PRC. The follow ing summarize the
exposure assumption refinements; however, the overall conclusions of the comprehensive BHHRA
remained unchanged:
• The RME assumptions used in the BHHRA to assess potential lead exposure in contaminated soil
by adults for the future commercial/industrial worker and the future construction/excavation
worker scenarios were determined to be overly conservative and inconsistent with EPA guidance.
The adult lead exposures were recalculated using CTE assumptions. Lead in soil was determined
to no pose an unacceptable risk to future on-site workers.
• The BHHRA's use of default assumptions for the recreational fishing scenarios was determined
to have overestimated the health risks because the amount of fishing and fish consumption is
limited by Site-specific conditions. It was deemed appropriate to consider a fish intake rate based
on rivers/streams ("flowing") rather than "all waters" (i.e., default assumption in the BHHRA)
and a reduced fraction ingested (Fl) value (i.e., 0.5), which would also yield an ingestion rate
consistent with the state's fish consumption advisory.
• The BHHR A exposure assumptions for the adolescent trespasser scenario were based on
professional judgement including the receptor age (6 to 16-years). exposure frequency (78
days/year) and/or exposure duration (10-years). Exposure assumptions for this scenario were
refined based on a slightly older adolescent age range (e.g., 8 to 17-years) and associated body
weight (e.g., 49.7 kg), which are more consistent with the understood characteristics of
trespassers at the Mill Complex Property. However, this change does not impact the overall
outcome of the BHHRA.
Exposures to COCs were estimated quantitatively or qualitatively through the development of several
different exposure scenarios. Exposure scenarios were developed based on the nature and extent of
contamination, the location of the Site, current and future potential use of the Site, and identification of
potential receptors and exposure pathways.
The Site is currently vacant and access to the Mill Complex Property is partially restricted by a fence. The
Mill Complex Property, which constitutes the majority of the Site, is zoned as part of a VC district and is
in a GD district zone. The VC zoning allow s for multiple uses including residential, childcare. senior
housing, commercial facilities, restaurants, and recreational facilities. The nearest residence is the multi-
unit apartment complex abutting the Mill Complex Property to the northeast. A senior housing complex
(Little Falls Landing) abuts the Site along the western perimeter.
The Site is located adjacent to and includes a limited segment (i.e., Target Reach) of the Presumpscot
River. The Presumpscot River is used for recreational activities (e.g., fishing, kayaking and canoeing) and
hydroelectric power. The Presumpscot River is managed as a multi-species fishery along its entire length.
While groundwater is currently not used as a potable supply, it may be used as a potable supply under a
future residential scenario and all groundwater in Maine is classified as not less than Class GW-A, unless
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otherwise provided by the statute. In the State of Maine, Class GW-A is defined as being the highest
classification and of such quality that it can be used for public water supplies.
The following provides a brief summary of the exposure pathways that were found to present an
unacceptable risk (Incremental Lifetime Cancer Risk [ILCR] greater than 10"4 or a Hazard Index [HI] > 1)
at the Site assuming a RME scenario. A more thorough description of all exposure pathw ays evaluated in
the risk assessment, including estimates for an average exposure scenario, can be found in Appendix A,
Tables 4.1 through 4.19 of the BHHRA (Nobis. 2021).
The follow ing current exposure pathways were found to present an unacceptable risk at the Site. These
scenarios apply in the future as well, assuming continued trespasser and recreational use of the Site and
surrounding area:
• Trespasser (adolescent) exposure to surface soil.
• Recreational angler (child, adult and lifetime) exposure to fish tissue from the Target Reach of the
Presumpscot River.
The follow ing future exposure pathways were found to present an unacceptable risk at the Site:
• Resident (child, adult and lifetime) exposure to surface soil and aggregate soil.
• Commercial / Industrial Worker exposure to surface soil and aggregate soil.
• Construction / Excavation Worker exposure to surface soil and aggregate soil.
• Recreational visitor (child) exposure to surface soil and aggregate soil.
• Resident (child, adult and lifetime) exposure to groundwater used as tap water.
• Construction Worker exposure to groundwater in construction trenches.
• Construction Worker exposure to vapors from groundwater in construction trenches.
Exposure to surface water and sediment at the Site (current/future child and adult scenarios) were
determined not to be associated with unacceptable human health risks.
Exposure to indoor air through vapor intrusion of shallow groundw ater contaminants was evaluated
qualitatively through comparison of shallow groundwater to VISLs. Although the maximum
concentrations of naphthalene. TCE, and vinyl chloride in shallow groundwater at the Site exceeded
VISLs. associated potential RME cancer risks from vapor intrusion based on maximum detected
concentrations are less than EPA's risk limit.
Toxicity Assessment
Carcinogenic Effects
The potential for exposure to a chemical to result in a carcinogenic effect is generally described by two
factors: a statement reflecting the degree of confidence that the compound causes cancer in humans and a
potency estimate, indicating how potent the chemical may be at causing cancer, with the general
assumption that every exposure has some probability of resulting in cancer. The descriptor reflecting the
degree of confidence that the compound causes cancer in humans may be either an alpha-numeric value
or a narrative. Both are closely tied to the nature and extent of information available from human and
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animal studies. The cancer potency estimate is a quantitative measure of a compound's ability to cause
cancer, and is generally expressed as either a cancer potency factor or an inhalation unit risk value.
Cancer potency estimates and unit risk values are toxicity estimates developed by EPA based on
epidemiological and/or animal studies, and they reflect a conservative "upper bound" of the potency of
the carcinogenic compound. That is, the true potency is unlikely to be greater than the potency described
by EPA. Tables G-9 and G-10 in Appendix B present these cancer toxicity values (oral/dermal and
inhalation, respectively) for the COCs at the Site. EPA's Cancer Guidelines and Supplemental Guidance
(March 2005) have been used as the basis for analysis of carcinogenicity risk assessment.
Non-Carcinogenic Effects
Non-carcinogens refer to contaminants that cause toxic effects other than cancer. Non-cancer effects can
include central nervous system damage, reproductive effects, and other systemic effects. For addressing
non-carcinogenic effects, it is EPA's policy to assume that a threshold level exists, below which adverse
effects are not expected to occur. This threshold level is described by the reference dose (RfD) or
reference concentration (RfC) for inhalation exposures. RfDs and RfCs have been developed by EPA as
an estimate of a daily exposure that is likely to be without an appreciable risk of an adverse health effect
during a lifetime. RfDs and RfCs are derived from epidemiological and/or animal studies and incorporate
uncertainty factors to help ensure that adverse health effects will not occur. The RfDs and RfCs relevant
to the Site are presented in Table G-ll and G-12 of Appendix B (oral/dermal and inhalation,
respectively).
Risk Characterization
The risk characterization combines the exposure estimate with the toxicity information to estimate the
probability or potential that adverse health effects may occur if no action were to be taken at a site.
Carcinogenic risks were calculated for those COPCs with evidence of carcinogenicity and for which
cancer toxicity values are available. Non-cancer health effects were evaluated for all COPCs (i.e.,
including carcinogens) for which non-cancer toxicity values are available. Cancer risks are generally
expressed as a probability whereas the potential for adverse non-cancer effects (and carcinogenic effects
resulting from non-linear [i.e., exhibiting a threshold of toxicity] mode of action [MOA] compounds) are
described in terms what is thought to be a safe exposure level.
Cancer Health Effects
Potential cancer risk from the ingestion and dermal contact pathways was calculated by multiplying the
estimated LADD (or lifetime average daily dose) for each CO PC by the chemical-specific cancer slope
factor (CSF). The LADD is expressed as intake averaged over a 70-year lifetime as mg COPC/kg-body
weight per day. The CSF is the COPC- and route-specific cancer slope factor (mg/kg-day)"1. CSFs are
upper-bound estimates of the excess risk of developing cancer as a result of a period of continuous
exposure to a chemical, averaged throughout the course of a 70-year lifetime and are developed based on
the assumption that there is no threshold level of exposure below which adverse effects will not be seen.
For exposure to most known or potentially carcinogenic substances. EPA believes that as the exposure
increases, the cancer risk increases. In characterizing risk to these types of carcinogenic compounds, a
chemical- specific exposure level is generally multiplied with the cancer potency factor or inhalation unit
risk to estimate incremental lifetime cancer risk as a result of exposure to site contaminants. To the extent
that EPA has deemed that data are sufficient to apply the provisions of the 2005 Supplemental Guidance
for Assessing Susceptibility from Early-Life Exposure to Carcinogens, special consideration of the
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increased susceptibility to carcinogenic effects that children may have, was included in the risk
characterization. The 2005 Supplemental Guidance for Assessing Susceptibility from Early-Life Exposure
to Carcinogens were used to describe any such heightened susceptibility among potentially exposed
children. Typically, the resulting cancer risk estimates are expressed in scientific notation as a probability
(e.g., 1 x 10"6 or 1E-06 for 1/1,000,000) and indicate (using this example), that an average individual is
not likely to have greater that a one in a million chance of developing cancer over 70-years as a result of
site-related exposure (as defined) to the compound at the stated concentration.
All risks estimated represent an incremental risk of cancer from exposures to contamination originating
from the Site, which go beyond an individual's baseline risk of developing cancer. The chance of an
individual developing cancer from all other (unrelated to the Site) causes has been estimated to be as high
as one in three. These are risks above and beyond that which we face from other causes such as from
cigarettes or ultra-violet radiation from the sun. EPA generally views site related cancer risks in excess of
10"4 (1 in 10,000) as unacceptable. Current EPA practice considers carcinogenic risks to be additive when
assessing exposure to a mixture of hazardous substances.
Non-Cancer Health Effects
In assessing the potential for adverse non-carcinogenic effects (and carcinogenic effects resulting from
non-linear MO A compounds), a hazard quotient (HQ) is calculated by expressing the exposure (or the
exposure concentration in the case of air exposures) as a ratio of the reference value (RfD or RfC). A HQ
< 1 indicates that a receptor's exposure to a single contaminant is less than the safe value and that adverse
effects are unlikely. Conversely, a HQ > 1 indicates that adverse effects as a result of exposure to the
contaminant are possible. To account for additive effects resulting from exposure to more than one
compound, a Hazard Index (HI) is generated by adding the HQs for all chemicals of concern that have the
same or a similar mechanism or mode of action. As a conservative measure and a common practice. HQs
are often added for all compounds of concern that affect the same organ or system (i.e., liver, nervous
system) since the mechanism or mode of action is not alw ays known. A HI < 1 indicates that adverse
effects are unlikely whereas a HI > 1 indicates adverse effects are possible. Generally. EPA views HI
values based on site-related exposure in excess of unity (i.e., above 1) as unacceptable. It should be noted
that the magnitude of the HQ or HI is not proportional to the likelihood that an adverse effect will be
observed.
Lead Modeling
EPA has not assigned verified or provisional toxicity values (i.e., CSFs and RfDs) to lead because the
toxicity data available to date are inadequate for evaluation by the current methodology. Therefore, lead
risk was not evaluated using the conventional risk assessment approach. The EPA's Integrated Exposure
Uptake Biokinetic (IEUBK) model for lead was used to assess residential exposures to lead in soil and
fish tissue. Exposures to lead in soil by non-residential adults (workers) were evaluated by use of the adult
lead methodology (ALM), a slope-factor approach developed by the EPA Technical Review Work Group
for Lead (EPA. 2003b and 2017a). Both models estimate blood lead concentrations and a target blood
lead level (BLL) of 5 micrograms per deciliter ((.ig/dL) was used in the BHHRA lead models. Neither of
the lead models are appropriate for evaluating recreational exposures to lead in sediment. Therefore, a
qualitative comparison of sediment lead concentrations to the residential soil screening level was
performed.
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Risk Characterization Results
The following is a summary of the media and exposure pathways that were found to present a risk
exceeding EPA's cancer risk range or non-cancer risk threshold at the Site. Only those exposure pathways
that will be addressed by the selected remedy are presented in this ROD. See Section 6.2 and Appendix
A, Tables 7. 9 and 10 of the BHHRA for a more comprehensive risk summary of all exposure pathways
evaluated for all COPCs. and for estimates of central tendency risk. Please refer to Table 1-1 of the FS
Report for a summary of human health risk reflective of refinements consistent with the Summary of
Exposure Assumption Refinements to Baseline Human Health Risk Assessment technical memorandum
dated May 22, 2023.
• Trespasser - Surface Soil (Mill Complex Property): Table G-13 of Appendix B depicts the
carcinogenic and non-carcinogenic risk summaries for the COPCs in Mill Complex Property
surface soil evaluated to reflect current/future trespasser exposure corresponding to the RME
scenario. For an adolescent trespasser, non-carcinogenic risk (HI = 1.5) exceeded the EPA target
organ HI of 1 for Mill Complex Property surface soil. The exceedance was due primarily to the
presence of total PCBs. the PCB dioxin-like congener TEQ. and arsenic.
• Resident - Surface Soil (Mill Complex Property): Tables G-14 through G-16 of Appendix B
depict the carcinogenic and non-carcinogenic risk summaries for the COPCs in Mill Complex
Property surface soil evaluated to reflect future resident exposure corresponding to the child,
adult and lifetime (aged adjusted) RME scenarios, respectively. For a child and adult resident,
non-carcinogenic risks (HI = 33 and 3.6. respectively) exceeded the EPA target organ HI of 1 for
surface soil. The exceedances were due primarily to the presence of total PCBs. the PCB dioxin-
like congener TEQ. arsenic and iron. For a lifetime resident, carcinogenic risks exceeded the EPA
acceptable risk range of 10"6 to 10"4 for Mill Complex Property surface soil (2E-04) primarily due
to total PCBs. the PCB dioxin-like congener TEQ. arsenic and the 2,3,7,8-TCDD TEQ.
• Commercial / Industrial Worker - Surface Soil (Mill Complex Property): Table G-17 of
Appendix B depicts the carcinogenic and non-carcinogenic risk summaries for the COPCs in
Mill Complex Property surface soil evaluated to reflect future commercial/industrial worker
exposure corresponding to the RME scenario. For a commercial/industrial worker, non-
carcinogenic risks (HI = 2.3) exceeded the EPA target organ HI of 1 for Mill Complex Property
surface soil. The exceedance was due primarily to the presence of total PCBs. the PCB dioxin-
like congener TEQ. arsenic and the 2,3,7,8-TCDD TEQ.
• Recreational Visitor - Surface Soil (Mill Complex Property): Table G-18 of Appendix B depicts
the carcinogenic and non-carcinogenic risk summaries for the COPCs in Mill Complex Property
surface soil evaluated to reflect future child recreational visitor exposure corresponding to the
RME scenario. For a child recreational visitor, non-carcinogenic risks (HI = 7.4) exceeded the
EPA target organ HI of 1 for Mill Complex Property surface soil. The exceedance was due
primarily to the presence of total PCBs. the PCB dioxin-like congener TEQ. arsenic and the
2,3,7,8-TCDD TEQ.
• Resident - Aggregate Soil (Mill Complex Property): Tables G-19 through G-21 of Appendix B
depict the carcinogenic and non-carcinogenic risk summaries for the COPCs in Mill Complex
Property aggregate soil evaluated to reflect future resident exposure corresponding to the child,
adult and lifetime (aged adjusted) RME scenarios, respectively. For a child and adult resident,
non-carcinogenic risks (HI = 38 and 4.2, respectively) exceeded the EPA target organ HI of 1 for
Mill Complex Property aggregate soil. The exceedances were due primarily to the presence of
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total PCBs. the PCB dioxin-likc congener TEQ, antimony, arsenic, iron, and the 2,3,7,8-TCDD
TEQ. For a lifetime resident, carcinogenic risks exceeded the EPA acceptable risk range of 10"6 to
10~4 for Mill Complex Property aggregate soil (3E-04) primarily due to total PCBs. the PCB
dioxin-like congener TEQ and arsenic.
• Commercial / Industrial Worker - Aggregate Soil (Mill Complex Property): Table G-22 of
Appendix B depicts the carcinogenic and non-carcinogenic risk summaries for the CO PCs in
Mill Complex Property aggregate soil evaluated to reflect future commercial/industrial worker
exposure corresponding to the RME scenario. For a commercial/industrial worker, non-
carcinogenic risks (HI = 2.6) exceeded the EPA target organ HI of 1 for Mill Complex Property
aggregate soil. The exceedance was due to the presence of total PCBs.
• Construction / Excavation Worker - Aggregate Soil (Mill Complex Property): Table G-23 of
Appendix B depicts the carcinogenic and non-carcinogenic risk summaries for the CO PCs in
Mill Complex Property aggregate soil evaluated to reflect future construction/excavation worker
exposure corresponding to the RME scenario. For a construction/excavation worker, non-
carcinogenic risks (HI = 5.7) exceeded the EPA target organ HI of 1 for Mill Complex Property
aggregate soil. The exceedance was due to the presence of total PCBs and the PCB dioxin-like
congener TEQ.
• Recreational Angler - Fish (Target Reach of the Presumpscot River): Tables G-24 through G-26
of Appendix B depict the carcinogenic and non-carcinogenic risk summaries for the COPCs in
Target Reach fish evaluated to reflect current/future recreational angler exposure corresponding
to the child, adult and lifetime (aged adjusted) RME scenarios, respectively. For a child and adult
angler, as refined in support of the FS Report, the non-carcinogenic risks (HI = 18 and 8,
respectively) exceeded the EPA target organ HI of 1 for Target Reach fish. The exceedances were
due to the presence of total PCBs. For a lifetime recreational angler, as refined for the purposes of
the FS Report, carcinogenic risks exceeded the EPA acceptable risk range of 10"6 to 10"4 for
Target Reach fish (1.5E-04) due to total PCBs and the PCB dioxin-like congener TEQ.
• Resident - Groundwater as Tap Water (Site-Wide): Tables G-27 through G-29 of Appendix B
depict the carcinogenic and non-carcinogenic risk summaries for the COPCs in overburden and
bedrock groundwater evaluated to reflect potential future residential potable water exposure
corresponding to the child, adult and lifetime (aged adjusted) RME scenario (under the
assumption that groundw ater associated with the Site is used as a source of potable water in the
future). For a child and adult resident, non-carcinogenic risks (HI = 41 and 29, respectively)
exceeded the EPA target organ HI of 1 for groundwater use as tap water. The exceedances were
due primarily to the presence of total PCBs. benzo(a)pyrene. dibenzofuran. naphthalene. 2-
methylnaphthalene. TCE, arsenic, manganese and iron. For a lifetime resident, carcinogenic risks
exceeded the EPA acceptable risk range of 10"6 to 10"4 for future groundwater use as tap water
(1.5 E-03) primarily due to total PCBs. the PCB dioxin-like congener TEQ. benzo(a)pyrene.
bis(2-cthylhexyl)phthalate. chrysene. naphthalene, pentachlorophenol. chloroform. 1,4-
dichlorobenzene. TCE, vinyl chloride and the 2,3,7,8-TCDD TEQ.
• Construction Worker - Trench Groundwater and Trench Vapors (Site-Wide): Table G-30 of
Appendix B depicts the carcinogenic and non-carcinogenic risk summaries for the COPCs in
overburden groundwater evaluated to reflect potential shallow groundwater and vapors in
trenches corresponding to the future construction worker RME scenario. For a future construction
worker, non-carcinogenic risks (HI = 1.5) exceeded the EPA target organ HI of 1 for groundwater
in shallow trenches; however, none of the individual chemicals contributed to an organ-specific
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HI greater than 1. The non-carcinogenic risks (HI = 38) also exceeded the EPA target organ HI of
1 for vapors in construction trenches due to the presence of naphthalene and cyanide.
Uncertainties
The follow ing summarizes uncertainties associated with the BHHRA. including applicable refinements,
and identifies supplemental evaluations undertaken to reduce those uncertainties (where applicable):
• Data Evaluation - Selection of the data to be used in the BHHRA can introduce uncertainty. The
BHHRA selected the most current data available and data representative of potential exposure
areas at the Site and immediately adjacent areas which may have been impacted by Site activities.
• Exposure Assessment - Uncertainty in the exposure assessment arises from the selection of
receptors and selection of exposure parameters. For COPCs detected infrequently or datasets with
a small number of samples. EPCs were based on maximum concentrations. The use of maximum
concentrations likely results in an overestimate of risks.
The RME estimates were obtained by combining estimates of likely "high-end" exposure factors
with average factors, which are not likely to underestimate risk. The BHHRA Addendum (2020)
included an evaluation of supplemental chromium and hexavalent chromium soil data.
The results of the background chromium speciation investigation indicate that hexavalent
chromium soil concentrations used to calculate on-site risk in the BHHRA are consistent with
background conditions. The BHHRA Addendum concluded that exclusion of these risks from
total site risks would lower total cancer risks slightly, but would not change the conclusion of the
BHHRA.
The RME assumptions used in the BHHRA to assess potential lead exposure in contaminated soil
by adults for the future commercial/industrial worker and the future construction/excavation
worker scenarios were determined to be overly conservative and inconsistent with EPA guidance
which recommends the use of CTE assumptions as plausible estimate of adult lead exposure. The
adult lead exposures were subsequently recalculated using CTE assumptions in support of the FS.
Lead in soil was determined to not pose an unacceptable risk to future on-site workers.
The BHHRA's use of default assumptions for the recreational fishing scenarios was determined
to have overestimated the health risks because the amount of fishing and fish consumption is
limited by Site-specific conditions. It was deemed appropriate to consider a fish intake rate based
on rivers/streams ("flowing") rather than "all waters" (i.e., default assumption in the BHHRA)
and a reduced Fl value (i.e., 0.5), which would also yield an ingestion rate consistent with the
state's fish consumption advisory.
The BHHR A included an evaluation of construction worker exposures to shallow groundw ater in
excavation trenches through dermal exposure and inhalation of volatiles in trench air. At the
request of MEDEP. the ingestion pathway (assuming a rate of 15 mi llil iters/day) was evaluated
and found not to add significantly (approximately 0.1%) to the construction worker scenario.
Uncertainty exists in the evaluation of the vapor intrusion pathway scenario. Risks were not
quantified for the vapor intrusion scenario because no occupied buildings are present at the Site.
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• Toxicological Evaluation - The RfD and RfC represent estimates (with uncertainty spanning
perhaps an order of magnitude or greater) of a daily exposure level for the human population,
including sensitive subpopulations. that is likely to be without an appreciable risk of deleterious
effects during a lifetime. Vanadium may be present in a variety of oxidation states, which differ
in their relative toxicities. Since the oxidative state of the measured vanadium concentrations is
unknow n, the toxicity values available for vanadium may under or overestimate risks.
Exposures of residents to lead were evaluated by use of the IEUBK model. Exposures of
commercial/industrial workers to lead were evaluated by use of the ALM model. These models
represent conservative approaches for predicting BLLs in children and infants and are designed to
overestimate risks. A target BLL of 5 ng/dL. which reflects current scientific literature on lead
toxicology and epidemiology that provides evidence that the adverse health effects of lead
exposure do not have a threshold, was used in the BHHRA.
• Risk Characterization - Cancer risks are added to estimate the total incremental risk as a result of
exposure to chemicals. Summing cancer risks may overestimate total risks. The lack of
information on synergistic effects of multiple contaminants may underestimate risks and the lack
of information on antagonistic effects may overestimate risks.
The complete BHHRA. including associated refinements, can be found in Volume 11 of the Draft Final
Remedial Investigation Report (Nobis, 2023).
Ecological Risks
A Screening Level Ecological Risk Assessment (SLERA; Nobis 2018) was developed for the Mill
Complex Property as listed on the NPL and portions of the Presumpscot River, followed by a SLERA
Update (Nobis, 2020). The ecological risk assessment was subsequently refined in an ERA Technical
Memorandum (Nobis, 2023). The ERA assessed contaminants detected in soil, sediment, surface water,
and fish and earthworm tissue samples and evaluated potential adverse impacts based on ecological
screening benchmark criteria. The following summarizes the findings of the ERA and associated
refinements.
Identification of Chemicals of Potential Concern
The following two ecological relevant exposure areas were identified for the purposes of the ERA based
on habitat types, contaminant fate and transport pathways, and hydrogeology:
• Terrestrial Habitat within the Mill Complex Property;
• Aquatic Habitat within the Presumpscot River.
In addition to Site-related samples collected from various environmental media during the Rl. sample
locations were identified to represent background or reference locations for both the terrestrial and aquatic
habitats.
In general, a chemical was selected as a contaminant of potential ecological concern (COPEC) if the
maximum detected concentration in various media (e.g., soil) exceeded the screening benchmark or if a
screening benchmark was not available for any of the potential receptors. The initial screening compared
maximum concentrations to the no observed adverse effect level (NOAEL)-based benchmarks. The
refinement evaluation in the SLERA used statistically-derived, chemical-specific EPCs to calculate
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exposure doses for avian and mammalian receptors for comparisons with NO A EL- and lowest observed
adverse effect level (LOAEL)-based Toxicity Reference Values (TRVs). The COPECs in the SLERA
included several VOCs. SVOCs. PAHs (primarily low- and high molecular weights PAHs).
dioxins/furans. pesticides. PCBs. PFAS, and metals.
Because certain COPECs detected in the on-Site media are naturally occurring or from non-Site related
anthropogenic sources, comparisons with background concentrations were made. The results of the
background comparison indicated that the Site concentrations of the following initial COPECs in the
noted media were consistent with background concentrations:
• Soil (Mill Complex Property) - methyl acetate, aluminum and vanadium.
• Sediment (Target Reach) - methyl acetate, dimethylphthalate. phenol. 2,3,7,8-TCDD TEQ
(mammal), and beryllium.
• Sediment (Lower Reach) - acetone, dimethylphthalate. 2,3,7,8-TCDD TEQ (mammal). PCB
dioxin-like Congener TEQ (mammal), aluminum, and beryllium.
• Fish (Target Reach) - 2,3,7,8-TCDD TEQ (bird/mammal). DDT and metabolites, endrin. barium,
chromium, manganese, mercury, and selenium.
• Fish (Lower Reach) - 2,3,7,8-TCDD TEQ (bird/mammal). DDT and metabolites,
betahexachlorocyclohexane. total PCBs. arsenic, chromium, mercury, selenium, and zinc.
Further refinement of the COPECs. documented in the ERA Technical Memorandum (Nobis, 2023),
included the follow ing:
• Corrected the dataset to include the SW-16/SED-16 sample location, which is located above the
Mallison Falls dam. within the Target Reach dataset rather than Lower Reach (i.e., samples
collected downstream of the Mallison Falls dam). The SLERA mistakenly evaluated this location
as part of the Lower Reach, which inappropriately skewed the dataset.
• Analytes retained as an initial COPEC because no screening benchmark available were
eliminated from the refined COPEC list because a quantitative risk evaluation is not possible.
• Barium and selenium were eliminated as COPECs in Target Reach fish due to detections in less
than 5% of the samples (minimum of 20 samples).
• Earthworm tissue sample results were used to reduce uncertainty in the SLERA food chain
modeling. PAHs and thallium were not detected in earthworm tissue and eliminated as terrestrial
food chain modeling COPECs. Comparisons between Site and background earthworm
concentrations resulted in the elimination of the following COPECs for invertivorous birds and
mammals: aluminum, arsenic, chromium, cobalt, lead, manganese, mercury, nickel, selenium,
and vanadium.
• Aluminum was eliminated as a terrestrial receptor COPEC and is not expected to pose an
ecological risk to flora and fauna based on a Site-specific soil pH ranging from 5.8 to 9.0
(average of 7.0).
• Antimony, cadmium, copper, lead, mercury, and nickel were eliminated as COPECs for direct
contact with sediment based on acid volatile sulfide/simultaneously extracted metals (AVS/SEM)
results determining that these metals are not bioavailable in the Presumpscot River portion of the
study area.
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Table G-31 of Appendix B provides a summary of the refined COPECs.
Exposure Assessment
Terrestrial habitat dominates the Mill Complex Property with the exception of those areas occupied by the
footprint of the mill building and remnant concrete pads. Early-seral stage (also referred to as the "non-
tree" stage) succession typical of disturbed fields, along with a variety of grasses, shrubs and herbaceous
plants characterize the ground vegetation. Some larger trees (e.g., red oak. gray birch) are present.
Limited presence of wildlife (e.g., gray squirrels, woodchuck burrows) have been observed within the
Mill Complex Property. The Presumpscot River represents the only aquatic habitat at the Site. Aquatic
vegetation is sparse and is limited primarily to a shoreline fringe of pickerelweed in the shallow areas.
Hard substrates characterize the river bottom (gravel, cobble, boulder, bedrock), although sand
accumulations occur in areas protected from the heaviest river flow. No potential risk to Endangered.
Threatened or Special Concern species was identified at the Site.
The ERA focuses on the receptors that are ecologically significant, of high societal value, highly
susceptible, and/or representative of broader groups. Complete exposure pathways identified in the ERA
included the uptake of COPECs from soil through roots (vegetation), ingestion of contaminants bound to
soil (terrestrial invertebrates), sediment (benthic community), and surface water (aquatic, herptile and fish
communities), and dietary exposure to COPECs in soil (invertivorous birds and mammals) and
sediment/surface water (invertivorous/piscivorous birds and mammals). Based on the preliminary
assessment and measurement endpoints and the results of the COPEC screenings. Table G-32 of
Appendix B summarizes the refined receptor groups, lines of evidence, and endpoints evaluated in the
ERA.
EPCs are the COPEC concentrations that a receptor is assumed to be exposed to within an exposure area.
EPCs for COPECs in soil, sediment, surface water and fish were calculated in terms of RMEs and CTEs.
EPCs were calculated based on the maximum detected concentration (if few er than 10 samples were
collected within a data grouping or if 10 or more samples were collected and there were fewer than 4
detects within a data grouping) or the 95% UCL (if 10 or more samples were collected within a data
grouping and there were at least 4 detections).
Exposure of wildlife (i.e., birds and mammals) to site COPCs was estimated using food chain models.
Avian and mammalian receptors were assessed by comparing estimates of daily doses of COPECs
resulting from exposure to COPECs in surface water, their diet, as well as the incidental soil or sediment
ingestion with NO A EL- and LOAEL-based TRVs. The NOAEL-based TRY represents the highest dose
at which there is no biologically significant increase in the frequency or severity of an adverse effect. The
LOAEL-based TRV represents the lowest dose at which there is no biologically significant increase in
frequency or severity of an adverse effect.
Additionally, the ecological significance of the estimated risk was evaluated to determine whether
elevated risk to wildlife posed by the Site was significantly different from that risk posed by background
areas of similar habitat. To address the significance of the Site risk, the residual risk (i.e., the Site risk
subtracting the background area risk) was calculated for both the terrestrial and aquatic birds and
mammals. The residual risk provides a measure of the exposure and consequent ecological risk that is
likely attributable to the Site alone, and possibly requiring mitigation.
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Ecological Effects Assessment
Initial conclusions were drawn separately for each measurement endpoint using the COPEC-specific
HQs. COPEC-specific HQs were calculated as the exposure estimate divided by the benchmark (NOAEL
and LOAEL benchmarks, or acute and chronic benchmarks for surface water). This approach resulted in
two separate HQs for each CO PEC, with the NOAEL-based HQ being more conservative and the
LOAEL-based HQ being less conservative. The HQ reflects the magnitude by which the sample
concentration or dose exceeds or is less than the TRV (i.e., soil screening level, ecological benchmark,
criterion or estimated threshold dose [NOAEL or LOAEL]). Although the HQ method does not measure
risk in terms of likelihood or probability of effects at the individual or population level, it does provide a
functional benchmark for judging potential risk.
A ranking scheme of possible risk outcomes and associated uncertainties was developed to help interpret
the COPEC-specific HQ and residual risk values. This approach provided a framework to distinguish
among the multiple COP EC's, benchmarks, exposure units, receptors, and exposure scenarios at the Site,
as well as to focus the discussion on the COPECs with the highest potential for population-level adverse
effects and the highest confidence in results. The following matrix summarizes the interpretive risk matrix
for soil, sediment, surface water and wildlife receptors used to characterize the relative risk:
Interpretive Risk Matrix for HQs for Terrestrial Receptors'1'
Risk
Scenario
No Effect-Based
(NOAEL)
Effect-Based (LOAEL)
Potential for
Population-Level
Adverse Effects
Confidence
RME
CTE
RME
CTE
No. 1
RR s 1
RR < 1
RR < 1
RR< 1
Unlikely
High
No. 2
RR > 1
RR s 1
RR < 1
RR < 1
Unlikely
Moderate
No. 3
RR > 1
RR > 1
RR £ 1
RR < 1
Unlikely
Low
No. 4
RR > 1
RR< 1
RR > 1
RR £ 1
Possible
Low
No. 5
RR > 1
RR > 1
RR > 1
RR < 1
Possible
Moderate
No. 6
RR > 1
RR > 1
RR > 1
RR > 1
Possible
High
Interpretive Risk Matrix for Aquatic11'
Risk
Scenario
No Effect-Based
(NOAEL)
Effect-Based (LOAEL)
Potential for
Population-Level
Adverse Effects
Confidence
No. 1
RR s 1
RR< 1
Unlikely
High
No. 2
RR > 1
RR < 1
Possible
Moderate
No. 3
RR > 1
RR > 1
Possible
High
Notes: Residual Risk (RR) calculated by subtracting reference HQs from Site HQs for each COPEC.
Remedial action is considered appropriate for chemical concentrations resulting in residual risk HQ(s)>l
consistent with above noted Risk Scenario No. 6 for terrestrial receptors, and Risk Scenario No. 3 for
aquatic receptors (i.e., risk evaluation based on Site-specific conditions showing a residual risk HQ(s) > 1
at the low effect level).
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Ecological Risk Characterization
The initial risk evaluation identified high confidence of possible adverse population-level effects within
both the terrestrial (plants and invertebrates) and aquatic (fish, benthic invertebrates and aquatic
community) exposure areas. Refinement of the ERA. based on rece pto r-spec i fic considerations, included
the follow ing:
• Elimination of several metals (i.e., aluminum, barium, chromium, copper and manganese) and
cyanide as COP EC's in soil and/or sediment due to limited detections, consistency with
background soil concentrations and/or a lack of a Site-related source(s).
• Exceedances of phytotoxicity NOAEL-based HQs for total PCBs. arsenic, cobalt, mercury,
selenium and thallium were limited and it was determined that these contaminants are not
expected to present a Site-related population risk to plants.
• Zinc was found to be consistent with background and therefore does not present a Site-related
population risk to the soil invertebrate community.
• The presence of DDT and metabolites in the Presumpscot River were determined to likely be
related to upstream and/or regional input, not a Site-related source.
• Based on the presence of PCBs in Upper Reach surface water samples, the residual risk from
surface water to the aquatic community in the Target Reach was calculated to be essentially zero.
• It was found that select metals were unlikely to adversely affect the fish population in the Target
Reach due to limited exceedances of NOAEL-based HQs (lead and nickel) and overly
conservative fish tissue critical body residue (CBR) assumptions in the ERA (i.e., copper and
zinc).
• Due to limited exceedances of low-end benchmarks, acetone, carbon disulfide, dibenzofuran, 4,4-
DDT and individual PAHs in Target Reach sediments were determined to not adversely affect the
benthic community.
• Di-n-butylphthalate was determined to be unrelated to the Site and was not evaluated further.
The results of the ERA. inclusive of applicable refinements, indicate a high confidence of adverse effects
to the follow ing receptors:
• Soil invertebrates due to total PCBs and arsenic in soil; and
• Benthic invertebrates within the Target Reach of the Presumpscot River due to total PCBs in
sediment.
Uncertainties
There is uncertainty associated with estimates of risk in any ER A because the risk estimates are based on
a number of assumptions regarding exposure and toxicity. More specifically, there is inherent variability
and uncertainty associated with the data collected to characterize exposure concentrations and
assumptions about the bioavailability of the selected COPECs. There are also assumptions and limitations
inherent in food chain modeling, including selection of exposure and modeling parameters (e.g., dietary
intake, body weight, and age), uptake factors, and toxicological data (e.g., TRVs).
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The food chain models assumed that 100% of the receptor's diet was derived from the study area and
100% ingested COP EC's are absorbed. Site-specific tissue (earthworm) data collected for the
invertivorous bird and mammal models reduced the uncertainty for the exposures to these receptors by
measuring the concentration in tissue under Site-specific soil conditions.
Overall, the conservative nature of food chain models likely overestimates the risk and the low risks
identified in the models are unlikely to correspond to risk at a population level.
Basis for Action
The BHHRA and associated refinements determined that current and future trespassers and recreational
anglers exposed to COCs in surface soil at the Mill Complex Property via direct contact (primarily due to
ingestion) and fish in the Target Reach via ingestion present an unacceptable risk to human health. Future
resident exposure to soil and groundwater use as tap water, commercial/industrial worker, construction/
excavation worker and recreational visitor exposure to Mill Complex Property soil, and construction
worker exposure to trench groundwater and trench vapors present an unacceptable risk to human health
(see Table 1-1 of the FS Report). Unacceptable human health risk was based on cancer risks exceeding
the EPA acceptable risk range of 10"6 to 10"4 and non-carcinogenic hazards exceeding an HI of 1.
Predicted BLLs did not exceed the target BLL of 5 ng/dL in more than 5% of the population exposed.
Unacceptable ecological risk was based the results of the ERA. inclusive of applicable refinements, which
indicated a high confidence of adverse effects to soil invertebrates at the Mill Complex Property due to
total PCBs and arsenic and to benthic invertebrates within the Target Reach of the Presumpscot River due
to total PCBs in the sediments.
The remedial action selected in this Record of Decision is necessary to protect the human health or
welfare or the environment from actual or threatened releases of hazardous substances from this Site
which may present an imminent and substantial endangerment to human health or welfare or the
environment.
H. REMEDIAL ACTION OBJECTIVES
Remedial Action Objectives (RAOs) are media-specific cleanup goals that define the objective of
remedial actions to protect human health and the environment. RAOs specify the COCs. potential
exposure routes and receptors and provide a general description of what the cleanup will accomplish. The
RAOs are based on available information and standards, such as ARARs. To Be Considered (TBC)
guidance, and site-specific risk-based levels. These RAOs were developed to mitigate, restore, and/or
prevent existing and future potential threats to human health and the environment and to attain ARARs.
The COCs and associated soil, groundwater, sediment and fish tissue cleanup levels are presented in
Table L-l in Appendix B of this ROD. The RAOs for the selected remedy for the Site are:
Protection of Human Health:
• Prevent direct exposure (dermal contact, ingestion or inhalation) to COCs in soil and debris in
excess of risk-based cleanup levels.
• Prevent the migration of contaminants from soil and debris (including up to a 500-year flood
event) to groundwater, sediments and fish tissue within the Target Reach of the Presumpscot
River.
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• Prevent direct exposure (dermal contact, ingestion or inhalation) to COCs in groundwater in
excess of ARARs and risk-based cleanup levels.
• Restore contaminated groundwater to levels that allow beneficial use.
• Reduce the amount of total PCBs in sediment to ensure that concentrations in fish tissue no
longer present an unacceptable human consumption risk in the Target Reach of the Presumpscot
River.
• Prevent direct exposure (ingestion) by individuals consuming fish tissue from the Target Reach of
the Presumpscot River until fish tissue no longer presents an unacceptable fish consumption risk.
• Prevent direct exposure (inhalation) to COCs in vapors that off gas from shallow groundwater in
construction trenches above levels that are protective for construction workers until groundwater
is restored to its beneficial use.
Protection of the Environment:
• Prevent exposure of ecological receptors to COCs in soil and debris that present an unacceptable
ecological risk.
• Prevent exposure of ecological receptors to COCs in sediment within the Target Reach of the
Presumpscot River that present an unacceptable ecological risk.
• Prevent further migration of COCs from soil and debris to sediments within the Target Reach of
the Presumpscot River (including up to a 500-year flood event).
I. DEVELOPMENT AND SCREENING OF ALTERNATIV ES
Statutory Requirements/Response Objectives
Under its legal authorities. EPA's primary responsibility at Superfund sites is to undertake remedial
actions that are protective of human health and the environment. The goal of the Superfund program as
stated in the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) at 40 C.F.R.
§300.430(a)(l)(i) is to select remedies that are protective of human health and the environment, that
maintain protection overtime, and that minimize untreated waste. In addition. Section 121 of CERCLA
establishes several other statutory requirements and preferences, including: 1) a requirement that EPA's
remedial action, when complete, must comply with all federal environmental and more stringent state
environmental and facility siting standards, requirements, criteria, or limitations, unless a waiver is
invoked; 2) a requirement that EPA select a remedial action that is cost-effective and that utilizes
permanent solutions and alternative treatment technologies or resource recovery technologies to the
maximum extent practicable; and 3) a preference for remedies in which treatment permanently and
significantly reduces the toxicity, mobility, or volume of the hazardous substances over remedies not
involving such treatment. Remedial alternatives were developed to be consistent with these statutory
requirements and preferences.
Technology and Alternative Development and Screening
CERCLA and the NCP set forth the process by which remedial actions are evaluated and selected. In
accordance with these requirements, a range of remedial alternatives were developed for the Site.
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With respect to source control, the FS developed a range of alternatives in which treatment that reduces
the toxicity, mobility, or volume of the hazardous substances is a principal element. This range included
an alternative that removes or destroys hazardous substances to the maximum extent feasible, eliminating
or minimizing to the degree possible the need for long-term management. This range also included:
alternatives that treat the primary threats posed by the Site but vary in the degree of treatment employed
and the quantities and characteristics of the treatment residuals and untreated waste that must be
managed; alternatives that involve little or no treatment but provide protection through engineering or
Institutional Controls; and a no action alternative.
As discussed in Section 3.0 of the FS. soil, groundwater and sediment treatment technology options were
identified, assessed, and screened based on impleinentability. effectiveness, and cost. Section 4.0 of the
FS presents the remedial alternatives developed by combining the technologies identified in the previous
screening process in the categories identified in Section 300.430(e)(3) of the NCP. The purpose of the
initial screening was to narrow the number of potential remedial actions for further detailed analysis while
preserving a range of options. Each alternative was then evaluated in detail in Section 5.0 of the FS.
In summary, of the 93 source control and management of migration remedial technologies and process
options screened in Section 3.0 of the FS for all impacted media including soil, groundwater and sediment
(inclusive of fish tissue). 36 were retained as possible options for the cleanup of the Site. From this initial
screening, remedial options were combined, and 9 source control and management of migration
alternatives were selected for detailed analysis. Although the alternatives are media-specific, the media
and alternatives are interrelated such that one alternative for a particular medium may impact the remedial
alternative options for other media. For example, because it is not practical to directly address
contaminated fish tissue, fish tissue will be addressed through sediment options by addressing the primary
source of contaminants to the food chain.
J. DESCRIPTION OF ALTERNATIV ES
This section provides a narrative summary of each remedial alternative retained following screening and
evaluation in the detailed analyses (Section 5.0) of the FS Report (June 2023). These alternatives were
developed by combining response actions and technologies to address the estimated exposure risks to
human health and the environment. The alternatives were also developed, to the extent practicable, to
represent a range of effectiveness, duration of time required to achieve the RAOs. and cost to implement.
The specific details of each remedial alternative are conceptual and are used for costing purposes. The
specific design details and costs for the selected remedy will be re-evaluated during the remedial design.
The costs are intended to be within the target accuracy of -30 to +50% of the actual cost. All present
worth costs associated with O&M and periodic expenditures are based on a 7% discount rate over 30-
years. Refer to Section L of this ROD for a breakdown of costs (including capital and O&M) for the
selected remedy, as well as discussion on the estimated time to construct and meet RAOs.
The media-specific remedial alternatives include the follow ing. The remedial action alternatives are
numbered to correspond with the FS Report.
• Soil Alternatives (Mill Complex Property):
o SO-1 - No Action
o SO-2 - Excavation. Off-Site Disposal. On-Site Consolidation and Institutional Controls
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o SO-3 - Excavation and Off-Site Disposal
• Groundwater Alternatives:
o GW-1 - No Action
o GW-2 - Monitored Natural Attenuation and Institutional Controls
o GW-3 -In-Situ Treatment. Baseline and Post-Treatment Monitoring and Institutional
Controls
• Sediment Alternatives (Target Reach of the Presumpscot River inclusive of fish tissue):
o SED-1 - No Action
o SED-3A - Mechanical Excavation. On-Site Consolidation and Institutional Controls
o SED-3B - Mechanical Excavation and Off-Site Disposal
Each of the remedial alternatives is summarized below. A more complete, detailed presentation of each
alternative can be found in Section 5.0 of the FS Report.
Soil Alternatives (Mill Complex Property)
Alternative SO-1: No Action
A No Action alternative (SO-1) is required under CERCLA to serve as a baseline to which other remedial
alternatives have been compared. No active remediation or Institutional Controls to reduce potential
health or ecological risks posed by contaminated Mill Complex Property soils or migration of soil
contamination to groundwater or the Presumpscot River are included in this alternative. The current levels
of contamination in soil, reduced only by contaminant migration to groundw ater or the Presumpscot
River, are assumed to remain unchanged. The capital cost for this alternative is $0 and the net present
value is $0.
Alternative SO-2: Excavation. Off-Site Disposal. On-Site Consolidation and Institutional Controls
Alternative SO-2 was developed to use engineering controls that prevent or limit human and ecological
exposure to contaminated Mill Complex Property soil and migration of contaminated soil to groundwater
and the Presumpscot River. If implemented the alternative would also provide an on-site disposal facility
for contaminated sediment were Alternative SED-3A also implemented. Any contaminants that exceed
hazardous waste characteristic standards or exhibit in situ total PCB concentrations at or greater than 50
mg/kg would be excavated, dew ate red and disposed of in an approved TSCA or hazardous waste disposal
facility. Soils with in situ total PCB concentrations greater than 10 mg/kg and less than 50 mg/kg and
those with fuel-oil or product contamination would be disposed of off-site at a facility licensed to accept
the contaminated soil. Treatment reagent (also referred to as "amendments") would also be applied during
backfilling of the excavation should baseline groundwater and PDI soil analytical results indicate that
application of a treatment reagent would be beneficial to the achievement of groundwater RAOs.
Soil with contaminants exceeding cleanup levels that do not exceed hazardous waste characteristics, or
with PCBs equal or greater than the cleanup level of 1 mg/kg and less than or equal to 10 mg/kg would be
excavated and consolidated in an on-site consolidation area under a low-permeability, multi-layer,
engineered cover consistent with an approved risk-based approach under the TSC A regulations at 40 CFR
§ 761.61(c). The engineered cover would meet the requirements for capping of high occupancy areas
under CFR § 761.61(a)(7).
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Post-remedial grading (including stabilizing the riverbank) would be conducted in a manner that improves
drainage and addresses current erosion and contaminant migration conditions while resulting in no flood
storage loss. This alternative would also include the use of Institutional Controls to prevent cover
disturbance, long-term monitoring of groundwater around the covered waste, and O&M of the cover. The
cleanup area outside of the covered waste would be protective for unrestricted use while the covered area
would be protective for activities that do not negatively impact the cover's protectiveness. Five-Year
Review s would be carried out for as long as waste exceeding CERCLA risk standards remains on-site.
The estimated capital cost for this alternative is $9,716,000 and the net present value is $10,803,000,
inclusive of approximately $1,087,000 in O&M. long-term monitoring, and Five-Year Review costs.
Alternative SQ-3: Excavation and Off-Site Disposal
Alternative SO-3 would prevent exposure to contaminated Mill Complex Property soil through the
excavation of all soil exceeding cleanup levels and disposing the excavated materials at off-site licensed
disposal facilities. Treatment reagent would also be applied during backfilling of the excavations should
baseline groundwater and PDI soil analytical results indicate that application of a treatment reagent would
be beneficial to the achievement of groundwater RAOs. Post-remedial grading (including stabilizing the
riverbank) would be conducted in a manner that improves drainage and addresses current erosion and
contaminant migration conditions while resulting in no flood storage loss. Institutional Controls, long-
term monitoring and O&M would not be required because no soil contaminants above cleanup levels
would remain at the Site. Five-Year Reviews would not be required for the soil component of the remedy.
The alternative would require no restrictions on the redevelopment of the property.
The estimated capital cost for this alternative is $14,113,000 and the net present value is $14,113,000 as
O&M, long-term monitoring and Five-Years would not be required.
Groundwater Alternatives
Alternative GW-1: No Action
A No Action alternative (GW-1) is required under CERCLA to serve as a baseline to which other
remedial alternatives have been compared. For Alternative GW-1. no source control remedial action is
assumed. No active remediation or Institutional Controls to reduce potential health risks posed by
contaminated groundwater are included in this alternative. There are no restrictions to prevent the use of
contaminated groundwater or prevent the installation of new potable supply wells, or prevent construction
worker exposure to contaminated groundwater or vapors in trenches. The capital cost for this alternative
is $0 and the net present value is $0.
Alternative GW-2: Monitored Natural Attenuation and Institutional Controls
Alternative GW-2 uses MNA and Institutional Controls to protect human health by preventing or
controlling exposure to hazardous substances in groundwater without active remediation until
groundwater cleanup levels are achieved through natural processes. This alternative would only be
implemented once a soil source control action has been completed. Reduction of risks posed by
contaminated groundwater until groundwater cleanup levels are achieved would be addressed using
Institutional Controls to prevent exposure to groundwater from residential tap water use (via ingestion,
inhalation, and dermal exposure) and exposure to groundwater in trenches (construction worker exposure
to trench groundwater and vapors) until cleanup levels are achieved (estimated in 30-years). Long-term
monitoring and Five-Year Reviews would be required until cleanup levels are achieved.
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The estimated capital cost for this alternative is $83,770 and the net present value is $714,000 inclusive of
approximately $630,000 in O&M, long-term monitoring, and Five-Year Review costs.
Alternative GW-3: In situ Treatment. Baseline and Post-Treatment Monitoring and Institutional Controls
Alternative GW-3 considers focused in situ treatment to address cleanup level exceedances in Site
groundwater and post-treatment monitoring to assess the effectiveness of the treatment approach and
determine if further in situ treatment of overburden and/or bedrock groundw ater is warranted and to
evaluate stabilization of groundwater to natural geochemical conditions following chemical treatment
until groundwater cleanup levels are achieved. Baseline groundwater monitoring would be performed
before and after the source control action to provide information for the remedial design. Institutional
Controls would prevent ingestion, inhalation, and dermal exposure to contaminated groundw ater that pose
threats to future residents and exposure of construction workers to trench groundw ater and vapor until
groundwater cleanup levels are achieved (estimated in 15-years). This alternative assumes that an active
soil remedial action would be implemented to remove sources of groundwater contamination.
In situ treatment technologies would be assessed and selected based on Site-specific conditions follow ing
the remedial action for soil and may vary to adequately address on-site localized groundwater
contamination. Treatment technologies suitable to address the former loading dock area groundwater (i.e.,
primarily VOC contamination) may differ from those suitable for groundwater in the northern portion of
the Site (i.e., primarily petroleum/PAHs contamination including naphthalene).
The estimated capital cost for this alternative is $1,573,000 and the net present value is $2,035,000
inclusive of approximately $482,000 in O&M. long-term monitoring, and Five-Year Review costs.
Sediment Alternatives (Target Reach of the Presumpscot River)
Alternative SED-1: No Action
The No Action alternative (SED-1) required under CERCLA serves as a baseline to which other remedial
alternatives have been compared. No active remediation or Institutional Controls to reduce potential
ecological and human health risks posed by contaminated Site sediment are included in this alternative.
The current levels of contamination in sediment are assumed to remain unchanged and therefore provide
no benefit to addressing ecological or fish consumption risks. The capital cost for this alternative is $0
and the net present value is $0.
Alternative SED-3A: Mechanical Excavation. On-Site Consolidation and Institutional Controls
Alternative SED-3 A includes targeted mechanical excavation of sediments within the Target Reach
exceeding the ecological PCB cleanup level that will also reduce the primary PCB source to the aquatic
food chain which would result in reducing PCB levels in fish tissue that pose a human consumption risk.
The alternative includes sediment dew ate ring prior to disposal (including treatment of the water
generated, if required) with up to 10 mg/kg of PCBs (in situ) would be disposed of in an on-site
consolidation area (which would be constructed only if Alternative SO-2 is selected) under a low-
permeability, multi-layer, engineered cover consistent with an approved risk-based approach under the
TSCA regulations 40 CFR § 761.61(c). The engineered cover would meet the requirements for capping of
high occupancy areas under CFR § 761.61(a)(7). Sediments with in situ total PCB concentrations of
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greater than 10 mg/kg would be disposed of off-site at a facility licensed to accept the contaminated
sediment.
This alternative can only be implemented if soil alternative SO-2 is selected since the consolidation area
would only be created under that soil alternative. Alternative SED-3A would involve temporarily
enclosing limited areas of the river, dewatering the enclosed area and discharging the water back to the
river to provide access for the sediment excavation. Cofferdams or similar measures would be required to
dewater the excavation areas and resource area/habitat restoration would be required.
Alternative SED-3A assumes that remediation of soil and sediment would result in a reduction in the
uptake of contaminants by fish. Due in part to the physical limitations of the Target Reach (e.g., limited
length, up- and downstream dams without fish ladders, stream bed conditions, etc.). the quantity, types
and sizes of fish that can be caught on a periodic (i.e., annual) basis are typically inconsistent from year to
year, which may pose difficulties in assessing trends. As a result, fish tissue sampling would be
implemented periodically (e.g., in support of Five-Year Review s) to evaluate the achievement of cleanup
levels. Protection of human health resulting from consumption of PCB-contaminated fish tissue can be
achieved through the use of long-term monitoring and Institutional Controls such as fish consumption
advisories and/or fishing restrictions (i.e., catch and release) in the Target Reach of the Presumpscot
River, placement and maintenance of signage advising against fish consumption and public outreach until
fish consumption no longer poses a risk.
This alternative relies on the Institutional Controls, long-term monitoring, and O&M components of the
SO-2 alternative to maintain the protectiveness of the permanent on-site disposal of the contaminated
sediments. Five-Year Reviews would be required for as long as the contaminated sediments remain on-
site within the consolidation area.
The estimated capital cost for this alternative is $627,000 and the net present value is $735,000, inclusive
of approximately $108,000 in O&M. long-term monitoring, and Five-Year Review costs.
Alternative SED-3B: Mechanical Excavation and Off-Site Disposal
Alternative SED-3B includes mechanical excavation of targeted sediments within the Target Reach
exceeding the ecological sediment PCB cleanup level that will also reduce the primary PCB source to the
aquatic food chain which would result in reducing PCB levels in fish tissue that pose a human
consumption risk. As also described for Alternative SED-3 A. the alternative includes sediment
dewatering prior to disposal (including treatment of the water generated, if required). Disposal under
Alternative SED-3B consists of off-site disposal of all of the contaminated sediment. Alternative SED-3B
would involve temporarily enclosing limited areas of the river, dewatering the enclosed area and
discharging the water back to the river to provide access for the sediment excavation. Cofferdams or
similar measures would be required to dewater the excavation areas and resource area/habitat restoration
would be required. Long-term monitoring. Institutional Controls, and O&M would be required to address
fish tissue risk, until there is no longer is a consumption risk. Monitoring would consist of periodic fish
tissue sampling as described in Alternative SED-3A. until fish consumption no longer poses a risk.
The estimated capital cost for this alternative is $769,000 and the net present value is $860,000, inclusive
of approximately $91,000 in O&M. long-term monitoring, and Five-Year Review costs.
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K. COMPARATIVE ANALYSIS OF ALTERNATIV ES
Section 121(b)(1) of CERCLA presents several factors that, at a minimum. EPA is required to consider in
its assessment of remedial alternatives. Building upon these specific statutory mandates, the NCP
describes nine evaluation criteria to be used in assessing the individual remedial alternatives.
A detailed analysis was performed on the soil, groundw ater and sediment (inclusive of fish tissue)
alternatives using the nine evaluation criteria in order to select a Site remedy. The comparative analysis of
alternatives was presented in Section 6.0 of the FS Report (June 2023). The following is a summary of the
comparison of each alternative's strength and weakness with respect to the nine evaluation criteria. These
criteria are summarized as follows:
Threshold Criteria
The two threshold criteria described below must be met for the alternatives to be eligible for selection in
accordance with the NCP.
1) Overall protection of human health and the environment addresses whether a remedy
provides adequate protection and describes how risks posed through each pathway are eliminated,
reduced, or controlled through treatment, engineering controls, or institutional controls.
2) Compliance with applicable or relevant and appropriate requirements (ARARs) addresses
whether a remedy will meet all promulgated Federal environmental and more stringent State
environmental and facility siting standards, requirements, criteria, or limitations, unless a waiver
is invoked.
Primary Balancing Criteria
The follow ing five criteria are utilized to compare and evaluate the elements of one alternative to another
that meet the threshold criteria:
3) Long-term effectiveness and permanence address the criteria that are utilized to assess
alternatives for the long-term effectiveness and permanence they afford, along with the degree of
certainty that they will prove successful.
4) Reduction of toxicity, mobility, or volume through treatment addresses the degree to which
alternatives employ recycling or treatment that reduces toxicity, mobility, or volume, including
how treatment is used to address the principal threats posed by the site.
5) Short term effectiveness addresses the period of time needed to achieve protection and any
adverse impacts on human health and the environment that may be posed during the construction
and implementation period, until cleanup goals are achieved.
6) Implementability addresses the technical and administrative feasibility of a remedy, including
the availability of materials and services needed to implement a particular option.
7) Cost includes estimated capital and O&M costs, as well as present value costs.
Modifying Criteria
The modifying criteria are used as the final evaluation of remedial alternatives, after EPA has received
State and public comments on the Proposed Plan:
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8) State acceptance addresses the State's position and key concerns related to the preferred
alternative and the other alternatives described in the Proposed Plan and FS, and the State's
comments on ARARs or the proposed use of waivers.
9) Community acceptance addresses the public's response to EPA's proposed remedy described in
the Proposed Plan and its administrative record.
Following the detailed analysis of each individual alternative, a comparative analysis was conducted
focusing on the relative performance of each alternative against the nine criteria. This comparative
analysis can be found in Section 6.0 of the FS Report and Table K-l of Appendix B of this ROD.
The following presents the nine criteria and a brief narrative summary of the alternatives and the strengths
and weaknesses to the detailed and comparative analysis. A summary of the modifying criteria for
Alternatives SO-3, GW-3 and SED-3B can be found at the end of the section.
Comparative Analysis of Soil Alternatives
Overall Protection of Human Health and the Environment
Alternative SO-1 (No Action) would not be protective of human health or the environment because
potential exposure to contaminated soil would not be prevented. Alternative SO-1 does not meet this
Threshold Criterion.
Alternative SO-2 is protective of human health and the environment as soil with COCs in excess of
cleanup levels will be excavated and either consolidated and covered on-site or. for soil exceeding certain
contaminant levels, disposed of off-site. For Alternative SO-2 contaminated soil exceeding certain
cleanup levels will remain on-Site under a protective cover, with long-term controls required to ensure
protection of human health and the environment, while allowing for redevelopment of the Site. As a
result, this alternative requires long-term monitoring. Five-Year Reviews and Institutional Controls.
Alternative SO-3 is considered the most effective at protecting human health and the environment as the
alternative prevents potential exposure by human health and ecological receptors through the removal of
soil with COCs in excess of cleanup levels. Backfilling with documented clean, imported material will
meet the unrestricted future use standards.
Compliance with ARARs
Only chemical-specific ARARs apply to No Action alternatives; however, there are no chemical-specific
ARARs for soil. Alternative SO-1 does not achieve risk-based soil cleanup levels developed using
chemical-specific TBC guidances and does not prevent exposure to contaminated soil exceeding the risk-
bascd cleanup levels. With proper implementation, it is anticipated that Alternatives SO-2 and SO-3
would meet all chemical-specific, action-specific and location-specific ARARs and risk-based standards
developed using TBC guidances. The ARARs and TBCs for these alternatives are outlined in Tables D-l
through D-3 in Appendix D of this ROD.
Long-term Effectiveness and Permanence
Alternative SO-1 is not effective in the long-term and does not provide permanent protection from
contaminants in soil.
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Alternative SO-2 would be effective in the long-term in mitigating risks after RAOs have been met but
removes less soil from the Site than Alternative SO-3. Alternative SO-2 would rely on controls,
inspections, and long-term monitoring activities as residual soils would remain on the Site covered under
the consolidation area. The consolidation cell component of Alternative SO-2 is reliable, based on the
establishment and maintenance of Institutional Controls, long-term monitoring, and Five-Year Review s.
Alternative SO-3 is permanent and has the highest long-term effectiveness in mitigating risks remaining
at the Site after RAOs have been met and eliminating risks from untreated wastes or residual soils as all
soil exceeding cleanup levels would be excavated and subject to off-site disposal. Alternative SO-3 is also
the most resilient to a changing climate as this alternative removes soil with COCs in excess of cleanup
levels for off-site disposal so there is no risk that flooding would release contaminants.
Reduction of Contaminant Toxicity, Mobility, or Volume through Treatment
Alternative SO-1 does not utilize an active treatment process and does not meet this criterion. Treatment
reagent will be applied during excavation/backfi 11 ing in association with Alternatives SO-2 and SO-3
should baseline groundw ater and PDI soil analytical results indicate that application of a treatment
reagent would be beneficial to the achievement of groundwater RAOs. The only other potential treatment
included in Alternatives SO-2 and SO-3 is either the treatment of any water generated from soil
dew ate ring or dew ate ring of excavations or any pre-treatment that may be required to dispose of waste
off-site. As a result. Alternatives SO-2 and SO-3 equally meet this criteria.
Short-term Effectiveness
Alternative SO-1 is considered to have no short-term impacts to the community, workers and the
environment as no action will occur; however. RAOs will not be met. Alternative SO-2 has slightly fewer
impacts to the community than SO-3 due to a lesser amount of traffic. However. Alternative SO-2
requires a greater degree of on-site soil handling and management and includes the construction of an on-
site consolidation area. The increased material handling and construction activities, relative to Alternative
SO-2. results in a greater degree of short-term risk to workers and potential for temporary environmental
impacts. Alternatives SO-2 and SO-3 have similar estimated durations and energy consumption.
Alternative SO-3 best meets this criterion.
Implement ability
Alternative SO-1 is considered the most implementable as no action is to occur; however. Alternatives
SO-2 and SO-3 have no significant implementability issues.
Implementation of Alternatives SO-2 and SO-3 are not highly complicated given the Site conditions and
based on the currently assumed extents of soil contamination. Both alternatives may have
implementability issues maintaining the West Wall of the former mill building (if it is retained after
completion of the NTCRA) due to its contamination status and the need to retain it to protect the integrity
of the adjoining property. Alternative SO-2 is slightly more complicated than Alternative SO-3 due to the
increased effort necessary to construction of an on-site consolidation cell, slightly greater effort necessary
to conduct additional remedial actions, and slightly less reliable technology that requires Institutional
Controls and O&M. Since Alternative SO-3 would remove all contamination exceeding PRCs, additional
remedial actions can be performed with greater ease than Alternative SO-2. Alternative SO-2 would also
have additional administrative processes associated with monitoring and enforcing Institutional Controls;
however, these processes are easily administered. All services and materials required for Alternatives SO-
2 and SO-3 would be relatively easy to obtain and competitively bid.
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Costs
There is no cost associated with Alternative SO-1. The costs for Alternative SO-2 and Alternative SO-3
are estimated to be $10,803,000 and $14,113,000, respectively.
Comparative Analysis of Groundwater Alternatives
Overall Protection of Human Health and the Environment
Alternative GW-1 (No Action) would not be protective of human health or the environment because no
action will be taken to reduce the risk presented by contamination in groundwater. Alternative GW-1 does
not meet this Threshold Criterion.
Alternative GW-2 is protective of human health through the implementation of the MNA remedy,
including physical, chemical or biological processes that occur naturally overtime to degrade the
contaminants, in combination with Institutional Controls. Groundwater cleanup under Alternative GW-2
would also benefit from the soil source control action and placement of amendments during backfilling
activities, to supplement the improvement of groundwater conditions. Alternative GW-2 protects human
health from exposure to the contaminated groundwater and its associated vapors through Institutional
Controls, that will be implemented and enforced until groundwater cleanup levels are achieved.
Alternative GW-3 provides overall protection of human health and the environment by supplementing the
soil source removal with in situ treatment of COCs exceeding cleanup levels. Alternative GW-3 will be
protective of human health through the implementation and enforcement of Institutional Controls that will
prevent exposure to contaminated groundwater until groundwater cleanup levels are achieved and
groundwater geochemistry has reverted to ambient conditions that no longer potentially mobilize metals.
Alternatives GW-2 and GW-3 are protective of the environment because groundwater does not directly
contribute to ecological risks.
Compliance with ARARs
Only chemical-specific ARARs apply to No Action alternatives. Alternative GW-1 will not attain the
chemical-specific ARARs nor does Alternative GW-1 achieve risk-based groundwater cleanup levels
developed using chemical-specific TBC guidances.
Once soil source control action is completed. Alternative GW-2 will attain the chemical-specific ARARs
within a reasonable time period following attenuation of the remaining groundwater to ambient
geochemical conditions. The Site's natural process will be further enhanced by placement of amendments
during excavation/backfilling as part of an active soil remedy. Alternative GW-2 can be implemented to
meet all location- and action-specific ARAR requirements, including requirements for monitoring wells
and management/disposal of investigation-derived wastes.
Alternative GW-3 will attain chemical-specific ARARs and risk-based cleanup levels (developed using
chemical-specific TBC guidances) through in situ treatment of groundwater contaminants, attenuation as
groundwater geochemistry is restored to ambient conditions, and Institutional Controls to prevent
exposure to groundwater contamination and vapors until groundw ater cleanup levels are achieved.
Alternative GW-3 can be planned and implemented to comply with location- and action-specific ARARs.
including requirements for injection and monitoring wells, management/disposal of wastes, and
implementation of in situ remediation.
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The ARARs and TBCs for these alternatives are outlined in Tables D-4 through D-6 in Appendix D of
this ROD.
Long-term Effectiveness and Permanence
Alternative GW-1 is not effective in the long-term and does not provide permanent protection from
contaminants in groundwater.
Alternative GW-2 relies on Institutional Controls in the long term to prevent potential exposures to
contaminated groundwater until groundwater cleanup levels are achieved. The amendment application
into the open excavations during the soil source control action will initiate treatment of COCs. which will
help to permanently decrease the contaminant concentrations in groundwater. Alternative GW-2 is
dependent on the proper implementation, monitoring, and enforcement of Institutional Controls coupled
with periodic review s of land use at the Site to ensure the Institutional Controls remain effective in the
long term. As a result, the long-term effectiveness is only as good as the measures taken to ensure the
reliability of controls.
Alternative GW-3 provides for the permanent decrease in groundwater contaminant concentrations within
a faster time period (estimated to be within 15-years) as compared to Alternative GW-2. In situ chemical
treatment technologies have been demonstrated to be effective at many sites with groundwater
contaminant concentrations similar to those found at the Site. In situ treatment is expected to be reliable
and effective. Similar to Alternative GW-2, Alternative GW-3 is dependent on the proper implementation,
monitoring, and enforcement of Institutional Controls, coupled with periodic review s of land use at the
Site, to remain effective. Alternative GW-3 is slightly more resilient to climate change than Alternative
GW-2 as it is anticipated to achieve RAOs in a shorter timeframe.
Reduction of Contaminant Toxicity, Mobility, or Volume through Treatment
Alternatives GW-1 and GW-2 will not satisfy CERCLA's statutory preference for treatment and no
reduction in toxicity, mobility or volume is provided; how ever, placement of amendments into the open
excavations during the soil source control will aid in treating groundwater contaminants under Alternative
GW-2.
Alternative GW-3 will use in situ treatment to address the groundwater contaminants, which will reduce
toxicity, mobility, and volume and satisfy CERCLA's statutory preference for treatment. The mass of
contaminants will be permanently and irreversibly destroyed. No treatment residuals are expected that
require management. For metals, changes in geochemical conditions through treatment will result in
decreased dissolved arsenic, iron, and manganese concentrations and prevent the mobilization of metals
from soil.
Short-term Effectiveness
Alternative GW-1 is considered to have no short-term impacts to the community, workers and the
environment as no action will occur. Impacts to the community, workers and the environment are also
anticipated to be limited for Alternative GW-2. as limited active remedial action will be undertaken.
Alternative GW-3 will have the greatest potential short-term impacts to the community, workers and the
environment; however, this alternative will achieve RAOs in the shortest amount of time (estimated at 15-
years) as compared to Alternative GW-2 (estimated at 30-years) and Alternative GW-1 (anticipated to be
greater than 500-years). Notably, the preceding timeframes for Alternatives GW-2 and GW-3 assume that
the groundwater components of the remedy will be implemented following the soil source control action
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and associated placement of amendments in targeted excavations. No such assumption was applied to the
estimated timeframe for Alternative GW-1 (No Action), which results in a significant longer estimated
timeframe.
Implement ability
Alternative GW-1 is considered the most implementable as no action is to occur; however, Alternatives
GW-2 and GW-3 have no significant implementability issues; however, Alternative GW-3 is considered
slightly more difficult to implement than Alternative GW-2 due to the need for in situ treatment
chemicals. There are no significant construction activities associated with Alternatives GW-2 and GW-3
or significant administrative processes. There are no limitations in availability of firms, equipment, or
materials that would limit the implementation of Alternatives GW-2 and GW-3; however. Alternative
GW-3 will require firms with specialized experience, equipment and reagents to implement the in situ
treatment.
Costs
There is no cost associated with Alternative GW-1. The costs for Alternative GW-2 and Alternative GW-
3 are estimated to be $714,000 and $2,035,000, respectively.
Comparative Analysis of Sediment Alternatives
Overall Protection of Human Health and the Environment
Alternative SED-1 (No Action) would not be protective of human health or the environment because no
action will be taken to reduce the ecological risk presented by contamination in sediment or to address
contaminated sediments" impact on the contamination of fish tissue that poses a human health risk.
Alternative SED-1 docs not meet this Threshold Criterion.
Alternative SED-3A is protective of human health and the environment as the most severely contaminated
sediments will be removed in support of mitigating the risk to human health from the consumption of
contaminated fish, as well as concentrations of PCBs in excess of the ecological cleanup level will be
excavated. It is expected that most of the excavated sediments (i.e., sediments with up to 10 mg/kg of
PCBs in situ), will be placed in an on-site consolidation cell (contingent upon the Alternative SO-2 soil
remedy being implemented). Therefore, the overall protectiveness of the Alternative SED-3A remedy
relies on maintaining the long-term protectiveness of the Alternative SO-2 remedy, if chosen. The other
components of the Alternative SED-3A remedy rely on Institutional Controls (i.e., prevent human health
exposure to fish tissue via consumption). O&M of the physical components of the Institutional Control
(i.e., signage), long-term monitoring of fish tissue, and Five-Year Reviews to maintain protectiveness.
Protection of the environment is anticipated to be achieved upon completion of the sediment excavation
activities for both Alternative SED-3A and SED-3B, which will remove contaminated sediment in excess
of the ecological cleanup level for PCBs. Alternative SED-3B is considered the most effective at
protecting human health and the environment, as this alternative removes sediment consistent with an
approved risk-based approach under the TSCA regulations at 40 CFR § 761.61(c) and disposes of them
off-site. Similar to Alternative SED-3A, this alternative includes Institutional Controls, long-term
monitoring and Five-Year Reviews to prevent human health exposure to fish tissue via consumption until
the risk-based cleanup level in fish tissue is achieved.
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Compliance with ARARs
Only chemical-specific ARARs apply to No Action alternatives. There are no chemical-specific ARARs
for sediments, but there are risk-based standards developed using chemical-specific TBC guidances.
Alternative SED-1 includes no action to prevent human health and ecological exposure and will not
achieve risk-based standards developed using TBC guidance.
Alternatives SED-3A and SED-3B will achieve risk-based cleanup levels developed using chemical-
specific TBC guidance because human health and ecological cleanup levels were developed using the
appropriate guidelines so that the remedial alternatives can achieve the cleanup levels for sediment and
fish tissue. Alternatives SED-3A and SED-3B will comply with location-specific ARARs during
implementation by taking measures, as appropriate, preventing temporary impacts from diverting the river
to access the contaminated sediments, restoring the riverbed and riverbank after sediment excavation, and
minimize or avoid impacts to sensitive habitats, floodplains. wetlands, and/or aquatic resources.
Alternatives SED-3A and SED-3B are generally comparable, although Alternative SED-3A includes
transportation of dewatered. contaminated sediments to an on-site consolidation cell (the construction and
management of which would be done under the soil component of the remedy) and will comply with the
action-specific ARARs through proper remedy implementation. EPA also determined that Alternative
SED-3B is the "Least Environmentally Damaging Practicable Alternative." as required under the federal
Clean Water Act, since contaminants impacting wetlands and aquatic resources will be removed and
disposed of off-site and impacted resources will be restored on-site.
The ARARs and TBCs for these alternatives are outlined in Tables D-7 through D-9 in Appendix D of
this ROD.
Long-term Effectiveness and Permanence
Alternative SED-1 is not effective in the long-term and does not provide permanent protection from
contaminants in sediment.
Alternative SED-3B has the highest long-term effectiveness in mitigating risks remaining at the Site after
sediments exceeding cleanup levels have been removed from the river consistent with an approved risk-
bascd approach under the TSCA regulations at 40 CFR § 761.61(c) since contaminated sediment will be
transported off-site for disposal. Alternative SED-3A would rely on O&M, long-term monitoring
activities and Institutional Controls of the soil component of the remedy (Alternative SO-2) as sediments
would remain on-site in the consolidation cell. Alternatives SED-3A and SED-3B rely on Institutional
Controls, long-term monitoring and Five-Year Reviews to maintain the long-term protectiveness of the
remedy until the risk-based fish tissue cleanup level is achieved. Both alternatives are reliable and have
adequate methods to achieve RAOs and ensure reliability of the controls as long as enforcement of
Institutional Controls is maintained until fish tissue risk-based standards are achieved.
Alternative SED-3B is the most resilient to a changing climate as this alternative includes targeted
removal of contaminated sediment for off-site disposal. Both alternatives have the same excavation
footprint and therefore identical vulnerability associated with the "submerged" (riverbed) portions of the
alternatives. These remedy components, which temporarily will impact the river, can also be designed in a
manner that limits vulnerability during implementation.
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Reduction of Contaminant Toxicity, Mobility, or Volume through Treatment
Alternative SED-1 does not utilize an active sediment treatment process and therefore docs not meet this
criterion. Alternatives SED-3A and SED-3B may include some minor treatment of water generated from
dewatering activities. Otherw ise, the removal and off- or on-site disposal of contaminated sediments does
not meet the criterion.
Short-term Effectiveness
Alternative SED-1 is considered to have the least risk in the short-term for the community, workers, and
the environment as no action is occurring for the alternative. Alternatives SED-3A and SED-3B have
comparable, but slightly higher short-term risks to the community and the environment than Alternative
SED-1. Alternative SED-3A has a slightly higher risk to construction workers than Alternative SED-3B
due to the added handling required to dispose of the dewatered sediment into the on-site consolidation
cell. Alternatives SED-3A and SED-3B are anticipated to take approximately the same amount of time to
achieve RAOs related to sediment and fish tissue. No permanent adverse impacts to the environment are
anticipated as the result of Alternative SED-3A or SED-3B.
Implement ability
Alternative SED-1 is considered the most implementable as no action is to occur; however. Alternatives
SED-3A and SED-3B have no significant implementability issues and these alternatives are considered
equally implementable. Alternative SED-3A is slightly more complicated than Alternative SED-3B due to
the on-site disposal of dewatered sediments into the consolidation cell. Alternatives SED-3A and SED-3B
both require implementation of Institutional Controls and long-term monitoring to assess whether fish
tissue risk-based standards are achieved overtime, once the sediment removal under each alternative is
completed. The ease of undertaking additional remedial actions, if warranted by future Site conditions or
requirements, is consistent between Alternatives SED-3A and SED-3B, they have comparable
administrative requirements, and materials and service pertaining to both alternatives are readily
available.
Costs
There is no cost associated with Alternative SED-1. The costs for Alternative SED-3A and Alternative
SED-3B are comparable and estimated to be $735,000 and $860,000, respectively.
Modifying Criteria (Applicable to Alternatives SO-4, GVV-3 and SED-3B)
State Acceptance
The State of Maine, through its lead agency. MEDEP, has expressed its support for EPA's preferred
alternative presented in the Proposed Plan (June 2023), and concurs with the selected remedy outlined in
this ROD (see Appendix A of this ROD for the State concurrence letter).
Community Acceptance
EPA's community engagement efforts at the Site included the publication of a Proposed Plan in June
2023; a hybrid public informational meeting held on June 28, 2023; and a hybrid public hearing held on
July 18, 2023. A transcript was created for this hearing and has been included in the Responsiveness
Summary located in Part 3: The Responsiveness Summary of this ROD. In addition to the oral
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comment received at the hearing, several written comments were also received. The comments generally
request further information/clarification related to traffic routes during remedy implementation. PFAS
sampling and private well sampling. The Proposed Plan specifically requested public comment on EPA
draft TSCA Determination regarding the remediation of PCB contamination and proposed temporary
impacts to wetland and floodplain resources (with restoration). No negative comments were received
concerning these specific issues. A summary of the comments and EPA's responses to these comments
are included in Part 3: The Responsiveness Summary of this ROD.
L. THE SELECTED REMEDY
1. Summary of the Rationale for the Selected Remedy
The selected remedy for the Site is a comprehensive remedy which utilizes source control and
management of migration components to address risk from contamination at the Site. Source control
measures are required to address soil (selected Alternative SO-3) and sediment (selected Alternative
SED-3B) that present unacceptable risks to human health, including fish consumption, and environmental
receptors. The management of migration component addresses contaminants in groundw ater (selected
Alternative GW-3) that present unacceptable risks to human health. Of all the alternatives, the selected
remedy best satisfies the statutory criteria for remedy selection.
The major components of the remedy are as follows:
• Excavation and off-site disposal of approximately 22,000 cubic yards of contaminated soil and
debris from the Mill Complex Property;
• Targeted treatment of soil (within the footprint of the excavation) with amendments in support of
groundw ater cleanup;
• In situ treatment of groundwater to reduce the mass, mobility and toxicity of contaminants;
• Excavation and off-site disposal of approximately 320 cubic yards of contaminated sediments
from the Target Reach of the Presumpscot River;
• Treatment of water generated from soil and sediment dew ate ring and removed from excavations
based on applicable water discharge standards, as required;
• Restoration of the portions of the Presumpscot River riverbed, riverbank, wetland and floodplain
habitat altered by the remedial action;
• Institutional Controls to prevent exposure to Site-related contaminants in groundwater and fish
tissue until cleanup levels are met;
• Inspections to evaluate Site restoration and stabilization activities, as well as O&M;
• Monitoring of groundwater and fish tissue to evaluate the achievement of cleanup levels; and
• Periodic reviews, at a minimum of every five years, to assess the protectiveness of the remedy
until cleanup levels are achieved.
The estimated present value of total cost of the selected remedy is approximately $17 million. The cost
analyses include an estimation of the capital costs and annual operation and maintenance costs. In
addition, the cost estimate is based on a present worth analysis by discounting to a base year or current
year using a 7 percent discount rate. The selected remedy, which is to be implemented follow ing the
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substantial completion of the NTCRA to demolish the mill complex and associated structures (partially or
in full as determined by the design), is anticipated to take two to four years to design and implement.
Soil cleanup levels are anticipated to be achieved upon completion of the excavation activities. Sediment
is estimated to achieve ecological cleanup levels upon completion of the excavation activities; however, it
will take more time for the sediment removal to result in the reduction of contaminated fish tissue to
below human consumption risk levels (approximately 14-years after the sediment removal). Groundwater
is estimated to achieve cleanup levels following implementation of in situ treatment and attenuation of
groundwater geochemistry to ambient conditions (in approximately 15-years). The performance of the
remedy will be assessed at least every five years to evaluate the protectiveness of the remedy until all
cleanup levels are achieved.
2. Description of Remedial Components
A detailed description of the components of the selected remedy, including media-specific and remedy-
wide elements, is provided below. The final selected remedy for the Site is consistent with EPA's
preferred alternatives outlined in the Proposed Plan (June 2023).
Section 121(e) of CERCLA and the NCP only require on-site Superfund actions to comply with
substantive standards of other laws, and therefore Federal, state, and local permits are not required. With
the exception of off-site transportation and disposal, the remedy will largely be implemented on-site (i.e.,
within the areal extent of contamination and all suitable areas in very close proximity to the
contamination necessary for implementation of the response action). Off-site activities will comply with
all substantive and administrative applicable laws and regulations.
Soil (Mill Complex Property)
The selected remedy for soil (Alternative SO-3 - Excavation and Off-Site Disposal) will prevent or limit
exposure to contaminated soil through the excavation of soil and debris exceeding cleanup levels within
the Mill Complex Property and disposing of the excavated material at off-site licensed disposal facilities.
Soil with in situ total PCB concentrations equal or greater than 50 mg/kg will be excavated and disposed
of off-site at an approved TSCA or hazardous waste disposal facility. Soils with in situ total PCB
concentrations betw een 1 mg/kg and less than 50 mg/kg will be excavated and disposed of off-site at a
facility licensed to accept the soils. Soils that exceed hazardous waste characteristic thresholds will be
excavated, segregated from the other wastes and disposed of off-site at a licensed hazardous waste
disposal facility unless the soil can be cost-cffectively rendered non-hazardous through treatment on-site
prior to transportation off-site for disposal. Fuel oil or product-contaminated soil in the vicinity of
monitoring wells MW-01, MW-03/03B and MW-08 will be targeted for excavation to remove PAH-
impacted (e.g., naphthalene)source material that pose threats to groundwater quality, including associated
vapors.
The excavated source material will be dew ate red and disposed of off-site. The water generated from the
dew ate ring will be treated, if required, prior to management (e.g., to the river, a municipal sewer system,
to groundwater or sent to an off-site disposal facility). In the event groundwater COCs are detected in the
saturated zones of the excavation areas such that treatment of the open excavation areas would be
beneficial, amendments (e.g., sodium persulfate) will placed at the excavation bottom to contribute to the
groundwater treatment.
Institutional Controls. O&M, and Five-Year Reviews for the soil component of the Site remedy will not
be required because no soil contaminants above cleanup levels will remain at the Site.
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The soil component of the Site remedy includes the following elements. A conceptual construction layout
for the soil component of the remedy is included as Figure 13 of Appendix C.
Excavation. Treatment. Backfilling and Restoration
Excavation, treatment, backfilling, and restoration activities will include the following:
• The excavation and backfilling sequence will be determined during the design; however, the
process is generally anticipated to include construction of any floodplain mitigation measures
required prior to initiating soil removal actions in the 100- or 500-year floodplain (only temporary
impacts to the floodplains are anticipated), establishment of staging and decontamination areas
outside of the 100- and 500-year floodplains. excavation of impacted soil and debris followed by
stockpiling, hazardous waste testing (per regulatory requirements and the receiving facilities
permit requirements), and off-site disposal. Handling of the materials includes temporary storage
in the staging area and off-site disposal. Any material that is characterized as hazardous or that
equals or exceeds 50 mg/kg PCBs in situ will be excavated and stockpiled separately. Excavation
materials management may also be required due to the presence of debris. This may include
concrete/brick crushing or magnetic removal of various metal debris (i.e., piping, rebar).
• Shoring is anticipated to be needed to maintain structural integrity of the surrounding areas for
excavation areas that will extend to 15 feet bgs or greater and border roadw ays or the riverbank.
The shoring is anticipated to be temporary and will be removed once the excavation areas are
backfilled. Further stabilization of the West Wall of the mill building (if left after the completion
of the NTCRA) may also be necessary.
• Removal and off-site disposal of any concrete mill building flooring left behind by the NTCRA.
• Installing any permanent stabilization measures required for the West Wall of the mill building, if
left behind by the NTCRA.
• Certain monitoring wells may need to be decommissioned during the excavation activities. A
suitable monitoring well netw ork will be reestablished in support of long-term monitoring
activities.
• Where needed, measures such as water sprays and mists will be used for dust and odor
suppression during excavation. In addition, it is anticipated that monitoring of perimeter up- and
dow n-w ind air quality will be performed to ensure the safety of neighboring properties. An air
quality management and monitoring program will be established that includes real-time
monitoring of dust using a field dust meter. Air monitoring locations will be established and
routinely monitored during excavation, stockpiling, transportation, and consolidation activities.
• Dew ate ring (e.g., pumping, soil draining, etc.) may be needed when addressing the soils
approaching the water table. Water will be managed, treated if necessary and discharged/disposed
of off-site, in accordance with ARARs. Any required treatment will be developed as part of the
PDI.
• Confirmation sampling is also anticipated and it is assumed that confirmation samples will be
collected from the sidewalls of the excavated areas Confirmation samples will be collected from
the bottom of the excavation areas where excavation is attempting to provide unrestricted future
use.
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• Based on the results of the baseline groundwater sampling and PDI soil result, an appropriate
amendment will be applied to open excavation areas prior to backfilling. It is anticipated that an
oxidant appropriate for an active groundwater remediation (e.g., sodium persulfate) will be
applied to the open excavations identified as benefitting from treatment.
• The excavations will be backfilled with clean imported material, followed by grading and
compaction to return the excavation areas to their final grade and restoration of excavation areas.
Grading will be conducted in a manner that improves drainage, addresses current erosion and
sediment migration pathw ays in support of future redevelopment consistent with the reasonably
anticipated future land use of the Site, including potential mixed residential use. and does not
dimmish flood storage capacity. Similarly, no flood storage loss will occur in association with
riverbank stabilization. Restoration of excavation areas, including altered wet 1 ajid/fl oodp 1 ai n
habitat, will include documented clean, imported backfill to grade, and re-vegetation with native
vegetation to control erosion.
• The ground surface in previously vegetated areas will be seeded with a mixture of grasses to
establish a stable grass surface. Riverbank and wetland/floodplain habitat restoration using native
species will also be completed consistent with the restoration plan. Climate resiliency planning
will be further evaluated (e.g., vulnerability assessment, consideration of measures to increase the
remedy's resilience to a changing climate, and ensuring capacity to adapt to climate change)
during the remedial design and incorporated into restoration activities.
Off-Site Disposal
Soil with total PCB concentrations equal or greater than 50 mg/kg in situ will be disposed of off-site at an
approved TSCA or hazardous waste disposal facility. Soils with in situ total PCB concentrations greater
than 1 mg/kg and less than 50 mg/kg will be disposed of off-site at a facility licensed to accept the soils.
Soils that exceed hazardous waste characteristic thresholds will be disposed of off-site at a licensed
hazardous waste disposal facility unless the soil can be cost-cffectively rendered non-hazardous through
treatment on-site prior to transportation off-site for disposal. An estimated total of 25,500 cubic yards
(inclusive of a swell or "fluff factor" of 1.2 beyond the natural [pre-excavation] volume estimate) are
anticipated for off-site disposal, including approximately 1,200 cubic yards of material with in situ total
PCBs greater than 50 mg/kg.
The PDI will be used to refine this estimate and identify locations where hazardous and TSCA waste
exists prior to the start of excavation. Soil will be transported in accordance with applicable standards.
Groundwater
The selected remedy for groundwater (Alternative GW-3 - In Situ Treatment. Baseline and Post-
Treatment Monitoring and Institutional Controls) will use focused in situ treatment to address
exceedances of cleanup levels in groundwater and post-treatment monitoring to assess the effectiveness of
the treatment approach and determine if further in situ treatment (overburden and/or bedrock
groundwater) is warranted and to evaluate stabilization of groundwater to natural geochemical conditions
follow ing chemical treatment, and Institutional Controls to limit exposure to contaminated groundwater
and associated vapor that poses threats to future residents and construction workers until groundw ater
cleanup levels are achieved. The groundwater component of the remedy will be coordinated with the
active soil remedial actions and will be implemented based on the Site-specific conditions present
follow ing the soil source control action and associated placement of amendments in targeted excavations.
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Treatment technologies would be assessed and selected during the design based on site-specific
conditions and may vary to adequately address on-site localized groundwater contamination. Treatment
technologies suitable to address the former loading dock area groundwater VOCs may differ from those
suitable for groundwater PAHs (e.g., naphthalene) in the northern portion of the Site.
After completion of in jections, the groundw ater geochemistry is expected to revert back to ambient
conditions and mobilization of naturally occurring metals will decline and cease. Groundw ater
geochemical and chemical conditions will be monitored through the post-treatment monitoring
component of the alternative. After completion of the overburden treatment, post-treatment monitoring
will be performed to assess effectiveness of treatment and whether bedrock groundwater may have also
been improved consequentially. The post-treatment sampling data will be used to determine whether
bedrock groundwater treatment is still necessary.
The groundwater component of the Site remedy includes the following elements. A conceptual layout of
the groundwater component of the remedy is included as Figure 14 of Appendix C.
Baseline Groundwater Sampling
A baseline groundwater sampling program will be performed prior to initiation of the groundwater
component of the remedy. The existing network of monitoring wells (overburden and bedrock) will be
sampled prior to completion of the soil source control action and the data will be used, in part, to support
the strategic treatment of excavations areas. Any wells damaged as a result of the NTCRA will either be
repaired or replaced prior to conducting the first sampling round. A second round of baseline groundw ater
sampling will be performed following the implementation of the soil remedy, including excavation area
treatment, once a suitable well network is reestablished as monitoring well abandonment will be
necessary during implementation of the soil component of the remedy.
Treatability Study
Bench-top treatability studies will be performed to identify the appropriate reagents to address the COCs
at each area of concern in groundw ater. Sufficient quantities of groundw ater will be collected from the
overburden monitoring wells and provided to a laboratory to perform treatability evaluations. Reagents
will be tested for efficacy of degrading the target COCs. Additionally, colloidal activated carbon can be
tested to evaluate sorption and immobilization of non-VOC organic contaminants (e.g., PAHs such as
naphthalene). For dissolved metals, reagents that adjust redox or pH conditions will be tested to assess
their efficacy. Results of the treatability study will be used to determine the appropriate reagents to be
applied in the overburden and bedrock.
In Situ Treatment
Selected reagents will be in jected into the aquifer for in situ degradation or stabilization of organic
contaminants and for in situ stabilization of inorganic contaminants in portions of the aquifer that exceed
cleanup levels. The reagents can be delivered using temporary direct push injections or constructed
injection wells. Due to the localized nature of groundwater contamination, reagents will be injected into
monitoring wells with cleanup level exceedances.
In the overburden, oxidizers such as catalyzed sodium persulfate. hydrogen peroxide, and sodium or
potassium permanganate can be used to abiotically degrade and destroy chlorinated VOCs (e.g., TCE)
and petroleum hydrocarbons (including PAHs such as naphthalene). While the in situ treatment is focused
on destroying organic COCs. injection of oxidizing reagents will also result in an oxidizing environment
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that can help stabilize or precipitate dissolved arsenic, iron, and manganese. Such conditions will require
monitoring follow ing reagent injections.
For the FS conceptual design (see Figure 14 of Appendix B). it was assumed that sodium persulfate will
be used as the representative oxidizing reagent as it is safer to handle than hydrogen peroxide and does
not increase manganese concentration, which occurs with the use of permanganate. Due to the highly
localized extent of overburden groundw ater contamination, it is assumed that an area of 20 feet by 20 feet
in the vicinity of selected monitoring wells will be treated. In jections are assumed to be performed at 10
feet on center and at 10 feet depth intervals commencing from the bottom of the treatment zone and up
(i.e., top of the bedrock surface to the top of the water table).
It is assumed that a pre-application test using clean water will be performed to assess the hydraulic
capacity and limitations of each zone. After the initial in jection round, groundw ater samples will be
collected at approximately 2 months and 6 months for post-treatment monitoring to assess treatment
effectiveness and potential rebound. As appropriate, additional injections will be applied to further treat
the residual cleanup level exceedances followed by post-treatment monitoring at 2 months and 6 months
intervals. If PAHs prove to be recalcitrant to in situ chemical treatment, colloidal activated carbon may be
applied to stabilize or immobilize the PAHs and promote in situ biodegradation by native microbes.
Follow ing the soil remedial action, including targeted excavation treatment, and contingent upon
overburden treatment and groundwater monitoring results (e.g., baseline testing, post-treatment
monitoring of overburden, etc.). reagent will be injected into targeted bedrock wells to create an oxidizing
condition that can destroy chlorinated VOCs and decrease metals mobilization (e.g., arsenic and
manganese). Bedrock well MW-06B, which slightly exceeded the MCL for total PCBs during initial
sampling but the result was not confirmed during the subsequent event, will be further assessed during the
baseline sampling and PDI. It is assumed that reagent will be applied throughout the length of the bedrock
well/borehole and, consistent with the treatment of the overburden, groundwater samples will be collected
at approximately 2 months and 6 months to assess treatment effectiveness and potential rebound. As
appropriate, additional injections may be applied to further treat the residual cleanup level exceedances.
Post-Treatment Monitoring
Following completion of the in situ treatment, groundwater sampling of the monitoring wells network
will be performed to provide post-treatment data to assess the effectiveness of in situ treatment, assess
presence of residual groundw ater contaminants, and assess whether groundw ater geochemical conditions
have reverted to ambient conditions (that will result in decreased mobilization of naturally occurring soil
and bedrock metals). As previously noted, after each injection event, two rounds of groundwater
monitoring will be performed to assess post-treatment conditions. Notably, additional monitoring wells
may need to be installed follow ing soil remedy implementation.
Residual dissolved metals may be present (estimated to be up to 15-years) after completion of the
injection activities. As a result, annual monitoring of the groundwater will occur. The annual sampling
results will be compiled and evaluated to determine whether treatment was effective in the long-term and
the geochemical conditions are stabilizing. The results will be incorporated into the Five-Year Reviews.
As part of the post-treatment monitoring program, annual inspections will be performed to assess whether
changes in land use may affect groundwater quality or alter flow of contaminated groundw ater, resulting
in groundwater cleanup taking longer than anticipated.
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Sediment (Target Reach of the Presumpscot River)
The selected remedy for sediment (Alternative SED-3B - Mechanical Excavation and Off-Site Disposal)
will prevent or limit exposure to contaminated sediment through the excavation of sediment exceeding
cleanup levels and disposing of the excavated material at off-site licensed disposal facilities. Reduction of
risks posed by contaminated fish consumption would be achieved using Institutional Controls (e.g.,
fishing restrictions, fish consumption advisories) and engineering controls (e.g., signage) to prevent fish
consumption. Fish tissue sampling and analysis will be conducted on a periodic basis to evaluate the
achievement of cleanup levels. In addition to Institutional Controls, monitoring. O&M and Five-Year
Review s will be required until fish tissue no longer poses a human health risk.
The sediment component of the Site remedy includes the follow ing elements. A conceptual layout for the
sediment component of the remedy is included as Figure 15 of Appendix C.
Excavation. Dewatering and Transportation
Prior to the initiation of sediment excavation activities, appropriate Site preparation activities will be
implemented in coordination with activities presented in association with the soil remedy. Any required
mitigation that is needed to address either temporary or permanent alteration within the 100- and 500-year
floodplains and wetlands will be implemented before any work is done in floodplain or wetlands. A
sediment staging area will also be necessary to temporarily store and dewater excavated sediment prior to
transportation off-site. The staging area will be either located outside of the 100- and 500-year floodplain
or flood-proofed so as not to pose a risk that the staging area will become flooded in up to a 500-year
flood event.
The sediment remedy will likely involve temporarily enclosing limited areas of the river, dewatering the
enclosed area and discharging the water back to the river (w ith proper treatment, if required) to provide
access for the sediment excavation. If. during remedial design, this approach is adopted, it is estimated
that a portable. 3-sided cofferdam (or similar) will be installed along the eastern edge of the Presumpscot
River, directly adjacent to the sediment excavation areas. Based on the limited size of the sediment
excavation areas, management of river volume within the Target Reach by the Little Falls and M alii son
Falls dams, and anticipated flow rate and volume of water to be discharged to isolate the riverbed for
excavation purposes, no impacts to downstream floodplain receptors are anticipated; however, temporary
flood impacts from placement of temporary riverbed enclosures and dewatering. if present, will be
mitigated prior to altering the river.
Following dewatering of the excavation areas, the excavation activities are anticipated to include the
following:
• Mechanical excavation (e.g., long-arm excavator) of the approximately 320 cubic yards
contaminated sediment to a target depth of 12-inches;
• Segregating any sediments that equal or exceed 50 mg/kg total PCBs in situ;
• Loading of sediment into trucks and transportation of sediments to the on-site dew atering beds;
• Potential application of a drying agent (e.g., lime kiln dust or quicklime) to ensure complete
dewatering of the sediments;
• Testing of the sediment to determine if any exceed characteristic hazardous waste standards;
• Collection and filtration/treatment of water generated from dewatering and appropriate
management/disposal;
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• Confirmation sampling (excavation bottom and sidewalls) in the sediment excavation areas;
• Loading of dewatered sediments into trucks and transportation off-site for disposal at an
appropriately licensed facility.
Backfilling and Restoration
Backfilling and Site restoration activities associated with the sediment remedy will include the follow ing:
• Backfilling excavation areas and restoration/revegetation of the riverbank area temporarily
impacted by equipment, the cofferdam (or similar), access ramps, and excavation activities. The
excavation areas will be backfilled with clean, imported material followed by grading and
compaction to return disturbed areas (including the riverbed) to the original grade.
• Some infrastructure such as access roads may be retained to create public access to the river
within the Mill Complex Property, consistent with reuse plans for the Site.
• Restoration will include native riparian vegetation or other measures to prevent erosion of the
riverbank and establish shoreline habitat;
• The dispositional area within the Target Reach immediately south of the mill complex is
considered valuable habitat. The sediment that is removed from the riverbed portion of the
sediment excavation area will also be backfilled with material suitable for reestablishing the
benthic habitat;
• Any temporary flood mitigation measures constructed to address temporary flood impacts will be
removed and the area impacted restored, as may be required.
Off-Site Disposal
All excavated contaminated sediment with less than 50 mg/kg PCBs in situ will be disposed of at a
facility licensed to accept the material.' Any contaminated sediment equal or exceeding 50 mg/kg PCBs
in situ will be designated for off-site disposal at RCRA Class D or a TSCA approved permitted hazardous
waste disposal facility. Any sediments exceeding characteristic hazardous waste standards will be sent to
a permitted hazardous waste facility unless the soil can be cost-cffectively rendered non-hazardous
through treatment on-site prior to transportation off-site for disposal. The PDI will be used to refine this
estimate, identify locations where sediments with equal or greater than 50 mg/kg PCBs in situ may exist
prior to the start of excavation, and validate risk characterization assumptions. These sediments will be
stockpiled separately and managed under applicable TSCA requirements, sampled, and disposed of off-
site at a TSCA or hazardous waste disposal facility. This work element includes the activities associated
with the sampling, handling, and disposal of sediment after it is placed in the staging area. Off-site
disposal of sediment will be performed consistent with the soil remedy disposal activities.
Operation and Maintenance
O&M activities are anticipated to include inspection and maintenance of revegetated areas including the
restored riverbank, sediment staging area, and temporary access and haul routes and ramps. Site
9 Sediment PCB concentrations did not exceed 50 mg/kg during the Rl; however, uncertainty remains is association
with material beneath the mill complex that may be exposed once the buildings arc removed.
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inspections will be conducted annually until the Site is stabilized. There will also be O&M of Institutional
Controls (e.g., signage) until fish tissue risk-based standards are achieved.
Remedy-Wide Components
Pre-Design Investigation (PD1):
A PDI will be performed to obtain information needed for the detailed remedial design. The PDI may be
appropriately phases and is likely to include the follow ing media-specific activities:
• Prior to the excavation and after the mill complex building is removed (partially or in full)
through the NTCRA, sampling will be conducted to refine the horizontal and vertical extents of
soil and debris that exceed cleanup levels and validate risk characterization assumptions
(including in situ sampling for PCBs). If the NTCRA does not completely remove the West Wall
of the mill building, the PDI may need to assess whether additional action is needed to maintain
the integrity of the wall while removing contaminated soil from the area.
• Sampling to establish the extent of localized areas of groundwater contamination and to further
delineate the extent of localized areas where groundw ater exceeds cleanup levels in the
overburden aquifer. The data will be used to support design of the in situ treatment response
action and validate risk characterization assumptions. It is assumed that a direct-push technology
drill rig. or equivalent, will be employed to provide vertical profiling of the water column where
cleanup levels are exceeded. It is anticipated that sampling will occur on a grid and that the grid
may be expanded based on the baseline sampling results.
• Sampling to provide additional chemical data to comprehensively delineate the horizontal and
vertical extent of in situ PCB-contaminated sediment, provide baseline fish tissue data and
validate characterization risk assumptions. As a portion of the mill complex is situated above the
Presumpscot River and uncertainty remains in association with sediment material beneath the mill
complex that may be impacted, the PDI will include sediments within this portion of the river.10
The presence of elevated soil COC concentrations in the bottom of the source control excavations
detected during the PDI. in combination with COC detections during the first round of the baseline
groundwater sampling program (see Groundwater component of the remedy), will be used to determine
the appropriateness of the amendment application, treatment solution, etc. within the open excavation
areas. It is anticipated that an oxidant appropriate for an active groundwater remediation (e.g., sodium
persulfate) be applied to the open excavations.
Long-Term Monitoring
Monitoring of fish tissue will be performed to evaluate the achievement of the human health cleanup level
for fish consumption. Due in part to the physical limitations of the Target Reach (e.g., limited length, up-
arid downstream dams without fish ladders, stream bed conditions, etc.). the quantity, types and sizes of
fish that can be caught on a periodic (i.e., annual) basis are typically inconsistent from year to year, which
may pose difficulties in assessing trends. As a result, fish tissue sampling will be strategically
10 Depending on when the Remedial Action is set to begin, EPA may consider conducting additional sediment
and/or fish tissue sampling to update the "pre-remedial" analytical data.
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implemented to evaluate remedy completion. Fish tissue monitoring will occur, at a minimum, follow ing
the second Five-Year Review, between years 10 and 15 (i.e., beyond the estimated lifecycle of the
targeted fish species present at the time of the remedial action). Additional fish tissue monitoring events
will be implemented, if deemed necessary, to determine if the contaminant concentrations are changing
over time and to validate the assumptions used in assessing the fish tissue risks in support of remedy
completion.
The data will be summarized and evaluated during the FYR to assess the potential need for additional
sampling or other response measures. As appropriate, the frequency of monitoring will be modified based
on assessment of fish tissue results.
Institutional Controls
Institutional Controls, such as deed restrictions, will be implemented to prohibit use of on-site
groundw ater or installation of new wells and other activities (e.g., activities posing a groundwater
exposure and vapor risk to construction workers) until groundwater cleanup levels are achieved. Included
in the Institutional Controls are requirements that a party who plans to perform intrusive subsurface
activities at the Site will need to: notify EPA and MEDEP, provide appropriate work plans and training
for worker protection, and ensure proper protective equipment use. monitoring, and field procedures to
prevent construction worker exposures to trench groundwater contaminants and vapors.
Institutional Controls will also be necessary to prevent human exposure to contaminated fish tissue (e.g.,
fishing restrictions, fish consumption advisories) and engineering controls (e.g., signage) will be placed to
restrict consumption of contaminated fish. Coordination with state and local agencies will be necessary to
ensure posting of the most appropriate fish consumption advisory, consistent with CERCLA, for the
Target Reach of the Presumpscot River.
At a minimum, annual inspections will be performed to verify compliance with the Institutional Controls
and will be incorporated into Five-Year Reviews.
Five-Year Reviews
Five-Year Reviews assessing the groundwater and sediment components of the remedy will be required,
are anticipated after completion of the in situ treatment. As required by CERCLA, the Five-Year Review
will be conducted to ensure the remedy remains protective of human health and the environment. Long-
term monitoring (groundwater and fish tissue) and inspections will be conducted in support of the Five-
Year Reviews.
Remedy Modifications
The selected remedy may change somewhat as a result of the remedial design and construction processes.
More specifically, following implementation of the NTCRA the PDIs will include additional sampling of
soil, groundwater, sediment and fish tissue. The results of the PDIs will be used to refine the horizontal
and vertical extents of contamination in various environmental media and validation risk characterization
assumptions. Any changes to the remedy described in this ROD would be documented using a technical
memorandum in the Administrative Record, an Explanation of Significant Differences (ESD), or ROD
amendment, as appropriate.
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3. Summary of the Estimated Remedy Costs
The estimated total cost of the selected remedy is approximately $17 million. A summary table of the
capital construction and annual O&M cost elements for the selected remedy is show n below and in Table
K-l of Appendix B of this ROD. The discount rate used for calculating total present worth costs was 7%.
The timeframe estimated in the FS Report over which cost expenditures are calculated is 3((-years.
Component of the Remedy
Estimated Capital
Cost
Estimated O&M, Long-
Term Monitoring & Five-
Year Reviews
Estimated Total Cost
(Net Present Value)
Soil ( Alternative SO-3)
$14,113,000
$0
$14,113,000
Groundwater ( Alternative GW-3)
$1,573,000
$462,000
$2,035,000
Sediment ( Alternative SED-3B)
$769,000
$91,000
$860,000
TOTAL
$16,455,000
$553,000
$17,008,000
There are uncertainties associated with the quantitative estimates for each of the remedy components, the
most significant of which include the size of the remediation areas, location and extents of contamination
(e.g., potential for contaminated soil and sediment to be present beneath the mill complex structure),
volume of contaminated groundw ater and contaminant mass, and volume of soil and sediment exceeding
50 mg/kg total PCBs in situ and/or characteristic hazardous waste criteria.
Changes in the cost elements may occur as a result of new information and data collected during the PDIs
or remedial design. Changes may be documented in the form of a memorandum in the Administrative
Record file, an ESD, or a ROD amendment, as appropriate. The above is an order-of-magnitude
engineering cost estimate that is expected to be within -30 to +50 percent of the actual project cost.
4. Expected Outcomes of the Selected Remedy
The expected outcome of the selected remedy is that contaminated soil within the Mill Complex Property
will no longer act as a source of contaminants to groundw ater and sediment, that contaminated sediment
will no longer act a source to fish tissue via food chain uptake, and soil, groundwater, sediment and fish
tissue will no longer present an unacceptable risk to human health and/or the environment. Soil and
sediment will be excavated and transported off-site for disposal. Follow ing sediment removal. Site-related
contaminants will be eliminated from future fish populations in the Target Reach of the Presumpscot
River. Groundwater will be treated in situ to restore the groundwater to its beneficial use. Institutional
Controls will restrict groundwater use and fish consumption until cleanup levels are achieved. It is also
anticipated that the selected remedy will have socioeconomic and community revitalization impacts such
as enhancement of property values, recreational use of the Presumpscot River, and improved ecological
habitat.
Removal of the soil contamination from the Mill Complex Property is anticipated to achieve cleanup
levels upon implementation. The groundw ater is anticipated to be restored to its beneficial use as a future
potential drinking water source within approximately 15-years, inclusive of in situ treatment activities and
a post-treatment stabilization period to allow for residual dissolved metals to equilibrate to natural
geochemical conditions. Removal of the sediment contamination is anticipated to achieve ecological
cleanup levels upon implementation; however, significant time will be necessary to eliminate
contaminants from the Target Reach fish population (i.e., approximately 14-years after the sediment
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removal to achieve the fish tissue cleanup level, inclusive of an estimated 11 -years for a generation of
smallmouth bass to mature)."
The effectiveness of the remedy will be determined based upon attainment of the cleanup levels
(performance standards) outlined in Table L-l in Appendix B of this ROD as well as any additional site-
related COCs added through subsequent decision documents. A monitoring program will be implemented
in order to evaluate remedy performance and progress towards attainment of groundwater and fish tissue
cleanup levels. The details of the monitoring program will be established during the remedial design
phase and will include preparation of a long-term monitoring plan. Monitoring scope and frequency could
change over time based on technical analysis of the remedy, optimization studies, revised conceptual site
model, or other information, as determined by EPA.
The determination that all cleanup levels have been met will consider historical and current monitoring
data, contaminant distribution, trend analysis, and the appropriateness of the compliance monitoring
program (i.e., locations, frequency of monitoring, sampling parameter). After all cleanup levels outlined
in Table L-l in Appendix B have been met. EPA will perform a risk evaluation which considers additive
risk from remaining COCs considering all potential routes of exposure to document the residual risk
based on exposure to soil (Mill Complex Property), groundwater, sediment and fish tissue at the Site. The
residual risk evaluation will document the potential risk associated with the concentrations of the COCs
remaining in soil, groundwater, sediment and fish tissue at the Site (if detected).
Cleanup Levels
Cleanup levels were developed for the COCs identified in the human health and ecological risk
assessments. COCs are the chemicals found at the Site that, based on the results of the risk assessment,
were determined to pose an ILCR greater than 1 in 1 million (10~6) or an HI greater than 1. COCs were
identified for exposure areas that posed:
1) A cancer risk in excess of an ILCR of 10"4;
2) An HI greater than 1; or
3) A significant ecological risk.
Soil Cleanup Levels
Human health risk-based soil cleanup levels were developed in the FS Report (Nobis, 2023) for a
residential exposure scenario based on risks presented earlier in Section G of this ROD and consistency
with the reasonably anticipated future land use of the Mill Complex Property. Site-specific background
soil samples were also used to develop background threshold values (BTVs). based on EPA background
guidance, to ensure that cleanup levels are not set at concentrations below surrounding ambient levels.
In the FS Report. PRCs were developed for COCs in Mill Complex Property surface and aggregate soil
exhibiting an unacceptable cancer or noncancer risk such that they are protective of human health. Risk-
based PRCs were developed for soil associated with potential future cumulative cancer risks greater than
10"4 or target organ His greater than 1 considering the ingestion, dermal contact, and inhalation exposure
pathways in a residential exposure scenario. For those soils, risk-based PRC development was required
for each chemical with an individual cancer risk above 10"6 or with an HQ above 1. These contaminants
11 Smallmouth bass arc the primary edible fish within the Target Reach and the timeframe for cleanup considered
the lifespan of smallmouth bass following implementation of the sediment remedy.
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include benzo(a)pyrene. dibenzo(a,h)anthracene, the 2,3,7,8-TCDD TEQ, total PCBs. antimony, arsenic
and iron.
Final cleanup levels identified in this ROD correspond to target cancer risk levels of 10"6 or 10"5 and a
target non-cancer HQ of 1. For each of the contaminants, risk-based cleanup levels were calculated using
equations and exposure assumptions presented in BHHRA and associated refinements. Toxicity values
used in the calculation of the risk-based cleanup levels are presented in Section G of this ROD.
Risk-based cleanup levels for soil correspond to a cancer risk level of 10"5 for benzo(a)pyrene.
dibenzo(a.h(anthracene, and the 2,3,7,8-TCDD TEQ, a noncarcinogenic HQ of 1 for antimony and iron,
the BTV for arsenic, and EPA guidance recommendation for a risk-based total PCB value of 1 mg/kg.
The selected cleanup level for PCBs in soil is protective of both total PCBs and dioxin-like PCB
exposures. The human health soil cleanup levels for each contaminant are summarized in Table L-l in
Appendix B of this ROD.
As detailed in the Final ERA Technical Memorandum (Nobis, 2023) and discussed in the FS Report
(June, 2023), there is a clear potential for adverse effects to soil invertebrates within the Mill Complex
Property due to total PCBs and arsenic; how ever, follow ing remediation of soils exceeding the human
health derived cleanup levels the recalculated EPCs indicate exposure is unlikely to produce adverse
ecological effects. As a result, implementation of a soil remedy that will achieve cleanup levels for human
health is also anticipated to be protective of ecological receptors. The ecological soil cleanup levels for
total PCBs and arsenic are presented in Table L-l in Appendix B of this ROD.
Groundwater Cleanup Levels
Cleanup levels have been established for groundwater for all COCs found to pose an unacceptable risk to
human health as identified in the BHHRA (as refined) for potential future groundwater used as residential
potable water. These cleanup levels can be found in Table L-l of Appendix B of this ROD. For the
residential potable water scenarios, the cleanup levels were selected based on federal MCLs, risk-based
cleanup goals, or health advisories (i.e., manganese). For those COCs that do not have a federal or state
ARAR at the time this ROD was developed, a risk-based cleanup level was calculated. Risk-based
cleanup levels are based on the residential potable water scenarios with potential future cumulative cancer
risks greater than 10"4 or target organ His greater than 1 considering the ingestion, dermal contact, and
inhalation exposure pathways. Cleanup level development included each chemical with an individual
cancer risk above 10"6 or with an HQ above 1. For each of the contaminants, risk-based cleanup levels
were calculated using equations and exposure assumptions presented in the BHHRA. Toxicity values
used in the calculation of the risk-based cleanup levels are presented in Section G of this ROD.
Sediment Cleanup Level
The results of the ERA indicated that there are potential risk to the benthic community in the Target
Reach of the Presumpscot River due to total PCBs. The selected ecological PRG in the FS Report is a
Refinement Screening Value (RSV) representing the Probable Effect Level (PEL) for total PCBs in
sediment within the Target Reach of the Presumpscot River. The selection of the RSV was based on the
distribution of PCBs within the Target Reach, detected concentrations of PCBs (i.e., low end of the range
for direct toxicity) and Site-specific factors affecting potential PCB toxicity. As documented in the
Recommended Preliminary Remediation Goal for Total PCBs in Sediment Memorandum (EPA. 2023),
the RSV of 0.676 mg/kg was determined to be a reasonable PRG. The PRG identified in the FS Report,
rounded to a level of precision achievable from commercial laboratories (i.e., 0.7 mg/kg) was selected as
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the cleanup level for sediment within the Target Reach of the Presumpscot River. This sediment cleanup
level can be found in Table L-l of Appendix B of this ROD.
Based on the BHHRA. there are no excess human health risks associated with direct contact with
contaminants in sediment. Therefore, human-health cleanup levels based on direct contact are not needed;
however, as discussed below, sediments required further consideration as a source of PCBs to fish tissue
within the Target Reach of the Presumpscot River.
Fish Tissue Cleanup Level
A fish tissue PRC for total PCBs was developed in the FS Report to protect the recreational adult and
child anglers that may consume fish caught in the Target Reach of the Presumpscot River. The fish tissue
PRC was evaluated based on cancer risks greater than 10"4 or target organ His greater than 1 considering
the ingestion. The selected risk-based PRC for total PCBs in Target Reach fish tissue was based on a
cancer risk level of 10"5 (i.e., total PCB concentration of 0.125 mg/kg ww in smallmouth bass). The PRC
considered Site-specific background sediment concentrations from the Upper Reach of the Presumpscot
River to ensure that cleanup levels are not set at concentrations below surrounding ambient levels. The
PRC was retained as the cleanup level for fish tissue within the Target Reach of the Presumpscot River
(see Table L-l of Appendix B of this ROD).
The only practical method for reducing total PCB concentrations in fish tissue is to isolate, reduce, or
eliminate contamination in sediment (i.e., the primary source of total PCBs to fish tissue) as there is no
method for removing PCBs from a contaminated fish. The Target Reach is a fish exposure area where fish
are potentially exposed to Site-related contaminants that have eroded into sediment. The total PCBs in
sediment were correlated to total PCBs in fish tissue by using a biota sediment accumulation factor
(BSAF) consistent with EPA guidance (EPA/600/R-06/047).12 A BSAF of 2.4 was developed using Site-
specific Target Reach data to establish the relationship between contaminants in sediments and edible fish
tissue (Nobis, 2022). Based on the selected risk-based fish tissue total PCB cleanup level for a cancer risk
level of 10"5 (i.e., 0.125 mg/kg ww) and using a calculated BSAF of 2.4. a corresponding post-
remediation average sediment concentration of 0.052 mg/kg total PCBs was calculated. This value
represents the target goal for the post-remediation average total PCB concentration (based on a 95%
UCL) in Target Reach sediments that is anticipated to address fish consumption risks.
Removal of PCB-contaminated sediment above the cleanup level of 0.7 mg/kg is anticipated to result in
an aggregated sediment PCB concentration less than the targeted post-remediation goal of 0.052 mg/kg.
The selected remedial action for sediments is anticipated to remove sufficient total PCB mass from the
food chain in support of achievement of the fish tissue cleanup level within a reasonable timeframe.
M. STATUTORY DETERMINATIONS
The remedial action selected for implementation at the keddy Mill Superfund Site is consistent with
CERCLA and, to the extent practicable, the NCP. The selected remedy is protective of human health and
the environment, will comply with ARARs. and is cost-cffective. In addition, the selected remedy utilizes
permanent solutions and alternate treatment technologies or resource recovery technologies to the
maximum extent practicable and partially satisfies the statutory preference for treatment that permanently
12 Estimation of Biota Sediment Accumulation Factor (BSAF) from Paired Observations of Chemical
Concentrations in Biota and Sediment, EPA/600/R-06/047 (2009).
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and significantly reduces the mobility, toxicity, or volume of hazardous substances as a principal element
to the maximum extent practicable.
1. The Selected Remedy is Protective of Human Health and the Environment
The selected remedy will adequately protect human health and the environment by eliminating, reducing,
or controlling exposures to human receptors through excavation and off-site disposal, in situ treatment,
long-term monitoring, and Institutional Controls. The selected remedy will reduce potential human health
risk levels such that they do not exceed relevant State and Federal standards, or in the absence of such
standards. EPA's target risk range of a total excess lifetime cancer risk of 10"6 to 10"4 and/or a non-cancer
Hazard greater than 1.0. The selected remedy will reduce potential adverse impacts to ecological
receptors from Mill Complex Property soil and sediments within the Target Reach of the Presumpscot
River.
Soil excavation from the Mill Complex Property will be protective of human health and the environment
by preventing direct exposure to contaminants and preventing the migration of contamination to
groundwater and sediment within the Target Reach. Placement of amendments in the soil excavations will
also support cleanup of the groundwater. The in situ treatment of contaminated groundwater will be
protective of human health by restoring the groundwater to beneficial use as a potential potable water
source. Institutional Controls will prevent future resident and construction worker exposure (dermal
contact, ingestion or inhalation) to contaminated groundwater and vapors in construction trenches until
cleanup levels are achieved. Excavation and off-site disposal of sediment from the Target Reach of the
Presumpscot River will be protective of the environment by preventing benthic invertebrate exposure to
contamination. The sediment excavation will also remove the contaminant source impacting fish tissue
through food chain uptake and creating a risk to human health (child and adult recreational angler fish
consumption). Institutional Controls will prevent direct exposure (ingestion) of fish tissue until cleanup
levels are achieved.
2. The Selected Remedy Complies with ARARs
The selected remedy will comply with federal and more stringent state ARARs identified for the Site. The
selected remedy will also incorporate procedures and processes identified by policies, advisories, criteria,
and guidance documents (i.e., TBCs). Detailed lists of ARARs/TBCs for the selected remedy are included
in Appendix D of this ROD. A discussion of the more significant ARAR issues is included below.
Wetlands Impacts
Issuance of the ROD embodies specific ARARs determinations made by EPA. pursuant to federal
regulatory standards. More specifically, as defined by Section 404(b) of the Clean Water Act and
regulations promulgated under the Act at 40 C.F.R. Parts 230, 231, and 33 C.F.R. Parts 320-323, EPA has
determined, with issuance of this ROD. that the selected remedy is the Least Environmentally Damaging
Practicable Alternative for protecting wetland resources. EPA will minimize potential harm and avoid
adverse impacts to protected aquatic habitats and wetlands by using BMPs to minimize harmful impacts
on the wetlands, wildlife or their habitat, and by restoring or mitigating these areas consistent with federal
and state wetlands protection law s. Any aquatic habitats or wetlands affected by remedial work will be
restored with clean, imported materials and native vegetation and such restoration will be monitored until
the vegetation becomes re-established. Other mitigation measures will be used to protect wildlife and
aquatic life during remediation and restoration, as necessary.
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In compliance with relevant and appropriate Wetland Protection and Floodplain Management regulations
(44 C.F.R. Part 9), EPA solicited public comment through the Proposed Plan on the proposed cleanup's
impacts on wetland resources. As required under applicable federal wetlands regulations. EPA solicited
public comment regarding the remedies" potential impacts on wetland resources in its Proposed Plan and
received no negative comments (see Part 3 of this ROD).
The State Natural Resources Protection Act - Wetlands and Waterbodies Protection Rules (Chapter 310)
includes jurisdiction over areas in. on. over or adjacent to State regulated wetlands and waterbodies.
Under the State standards the area within 75-feet, measured horizontally, of the normal high-water line of
a great pond, river, stream or brook or the upland edge of a coastal wetland or freshwater wetland is also
regulated. Work within areas within 75-feet of the Presumpscot River and any State-regulated wetlands
(approximately 0.78-miles of emergent wetland vegetation along the river shoreline) will be conducted to
protect State-regulated natural resources, as described above relative to federal wetland protection
requirements.
Floodplain Impacts
In compliance with relevant and appropriate Wetland Protection and Floodplain Management regulations
(44 C.F.R. Part 9), EPA solicited public comment through the Proposed Plan on its determination that
there is no practicable alternative to temporarily occupy and/or temporarily modify portions of the
floodplains within the Site in order to implement the proposed cleanup plan. EPA solicited public
comment regarding the remedies" potential impacts on floodplain resources in the Proposed Plan and
received no negative comments (see Part 3 of this ROD).
EPA will avoid or minimize potential harmful temporary impacts on floodplain resources within the river
and its 100- and 500-year floodplain. to the extent practicable within cleanup areas to protect on-site and
downstream floodplain resources. While excavation and backfilling with clean soil will occur within
portions of the Mill Complex Property located in floodplains. only temporary impacts to the floodplains
are anticipated. Waste located within the floodplain will be excavated and backfilled with clean, imported
fill and restored to grade so that the current flood storage capacity of these areas will not be diminished
after completion of the remedial actions. Temporary mitigation measures, if required, will be
implemented prior to initiation of the excavation activities to address any short-term floodplain impacts.
BMPs will be used during construction, which include erosion control measures, proper re-grading, and
restoration and monitoring of impacted areas.
Treatment injections associated with the groundwater remedy (in situ treatment) are also anticipated to be
associated with temporary impacts to the floodplain. BMPs will be used during treatment, which include
erosion control measures, proper regrading. and restoration and monitoring of impacted areas.
The sediment remedy will involve temporarily enclosing limited areas of the river, dewatering the
enclosed area and discharging the water back to the river to provide access for the sediment excavation.
Based on the limited size of the sediment excavation areas, management of river volume within the
Target Reach by the Little Falls and Mallison Falls dams, and anticipated flow rate and volume of water
to be discharged to isolate the riverbed for excavation purposes, no impacts to downstream floodplain
receptors are anticipated. How ever, flood mitigation measures will be implemented (as needed) prior to
the placement of temporary riverbed enclosures and dewatering.
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TSCA Requirements
EPA has determined that soil within the Mill Complex Property contaminated with total PCB
concentrations of 1 mg/kg or greater, sediments within the Target Reach at total PCB concentrations of
0.7 mg/kg or greater, and PCBs at 0.5 micrograms per liter (ng/L) in Site groundwater meet the definition
of a PCB Remediation Waste as defined under 40 CFR § 761.3. Tlierefore. these PCB-contaminated soils,
sediments, and groundwater are regulated for cleanup and disposal under 40 CFR § 761 (Polychlorinated
Biphenyls Manufacturing, Processing, Distribution in Commerce, and Use Prohibitions). Under 40 CFR
§ 761.61(c). EPA may authorize disposal of PCBs in a manner not otherw ise prescribed provided that
EPA determines that the disposal will not pose an unreasonable risk of injury to health or the
environment.
Risks from unrestricted exposure to PCBs in soil and debris and sediment (inclusive of fish consumption
risks) will be addressed through excavation and off-site disposal. The physical removal of soil and debris
and associated amendment application, follow ed by in situ treatment of residual contamination in
groundwater, will mitigate the mobilization of PCBs to the shallow groundwater. The selected in situ
treatment technology and subsequent attenuation to natural geochemical conditions is anticipated to
further address residual PCBs in groundwater. Institutional Controls will limit potential exposure to
groundwater and fish tissue until cleanup levels are achieved.
Consistent with Section 40 CFR § 761.61(c) of TSCA. EPA issued a draft determination for public
comment in the Proposed Plan that identified that the management and disposal of PCB contaminated
material as described in the Administrative Record for this cleanup plan does not result in an
unreasonable risk of in jury to human health or the environment as long as certain conditions (identified in
the determination) are met. No negative comments were received from the public on the draft
determination, which is being finalized through this ROD. The 40 CFR § 761 61(c) risk-based disposal
determination is included as Appendix F of this ROD.
National Historic Preservation Act, Section 106
The National Historic Preservation Act, and the state equivalent law , require that prior to work taking
place, a federal agency consider the effects of its undertaking on historic properties. EP A must consult
with the state historic preservation officer (SHPO) as well as any interested tribal historic preservation
officers (THPO) in making determinations and findings concerning the effects of its undertakings on
historic property.
EPA initiated consultation with Maine's Historic Preservation Officer. National Oceanic and Atmospheric
Administration. U.S. Department of the Interior, and several Tribal Historic Preservation Officers (i.e.,
Penobscot Indian Nation. Houlton Band of Maliseet Indians, Passamaquoddy Tribe of Indians - Indian
Township Reservation/P 1 easant Point Reservation, and Aroostook Band of Micmacs) in April 2015. EPA
completed an Archaeological Phase 0 Assessment and Architectural Assessment for the Mill Complex
Property to determine the presence of historic structures and to assess their potential to be preserved or
disturbed. No historic properties (architectural or archaeological) were identified.13
EPA is not currently aw are of any other historic or potentially historic properties or cultural resources that
could be on or in close proximity to the Site. EPA will continue to consult with the SHPO and THPOs
13 Prehistoric site 8.20, which is located below the Mallison Falls dam. is eligible for the National Register as a large
multi-component site with archaeological materials dating from the early Archaic to early historic period (Sappi.
2019).
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during the remedial design to determine whether implementation of the remedy will adversely impact
historic or cultural resources eligible for. or already listed on. the National Register of Historic Places. If
any such adverse impacts cannot be avoided. EPA will work with the SHPO and THPOs to develop a set
of activities to mitigate those impacts, which will be memorialized in a Memorandum of Agreement
between the parties.
3. The Selected Remedy is Cost-Effective
In EPA's judgement. the selected remedy is cost-effective because the remedy's costs are proportional to
its overall effectiveness (see 40 C.F.R. § 300.430(f)(l)(ii)(D)). This determination was made by
evaluating the overall effectiveness of those alternatives that satisfied the threshold criteria (i.e., that are
protective of human health and the environment and comply with all federal and any more stringent
ARARs. or as appropriate, waive ARARs). Overall effectiveness was evaluated by assessing three of the
five balancing criteria: long-term effectiveness and permanence; reduction in toxicity, mobility, or
volume through treatment; and short-term effectiveness; in combination. The overall effectiveness of each
alternative then was compared to the alternative's cost to determine cost-cffectiveness. The relationship of
the overall effectiveness of each of these remedial alternatives was determined to be proportional to its
costs and hence represents a reasonable value for the money to be spent.
The estimated present worth cost of the selected remedy is approximately $17 million. The selected soil
remedy (Alternative SO-3) is more expensive than the on-site consolidation approach (Alternative SO-2);
how ever, a larger mass of soil and debris contamination will be removed from the Site resulting in the
highest long-term effectiveness in mitigating risks and limiting the magnitude of untreated wastes and
residuals remaining at the Site. The selected soil remedy is also the most resilient to a changing climate.
The selected groundwater remedy (Alternative GW-3) is more expensive than the monitored natural
attenuation approach (Alternative GW-2), but will achieve cleanup goals and restore groundwater to
potential beneficial reuse in a significantly shorter period of time. The selected sediment remedy
(Alternative SED-3A) is comparable to the estimate cost of the consolidation approach (Alternative SED-
3 A) and will remove a larger mass of contamination from the Site. Both sediment alternatives will
effectively support the cleanup of fish tissue within the Target Reach of the Presumpscot River.
Table K-l of Appendix B of this ROD demonstrates how the respective selected remedies provide the
best balance of tradeoffs when compared against the evaluation criteria.
4. The Selected Remedy Utilizes Permanent Solutions and Alternative Treatment (or
Resource Recovery) Technologies to the Maximum Extent Practicable
Once the Agency identified those alternatives that attain or. as appropriate, waive ARARs and that are
protective of human health and the environment. EPA identified which alternative utilizes permanent
solutions and alternative treatment technologies or resource recovery technologies to the maximum extent
practicable. This determination was made by deciding which one of the identified alternatives provides
the best balance of trade-offs among alternatives in terms of: 1) long-term effectiveness and permanence;
2) reduction of toxicity, mobility, or volume through treatment; 3) short-term effectiveness; 4)
implementability; 5) cost. The balancing test emphasized long-term effectiveness and permanence and the
reduction of toxicity, mobility, or volume through treatment; and considered the preference for treatment
as a principal element, the bias against off-site land disposal of untreated waste, and community and state
acceptance. The selected remedy provides the best balance of trade-offs among the alternatives.
The selected remedy is protective of human health and the environment, uses proven cleanup
technologies such as excavation, off-site disposal, in situ treatment of groundw ater, and Institutional
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Controls, and is cost-effective while achieving the Site-specific cleanup objectives in a reasonable
timeframe. This cleanup approach provides both short- and long-term protection of human health and the
environment; attains all applicable or relevant and appropriate federal and state environmental laws and
regulations; reduces the toxicity, mobility, or volume of contaminated soil, groundwater, and sediment
through treatment, to the maximum extent practicable; utilizes permanent solutions and uses land use
restrictions to prevent unacceptable exposures in the future to the contaminants that will remain at the Site
(i.e., groundwater and fish tissue).
5. The Selected Remedy Partially Satisfies the Preference for Treatinent as a Principal
Element
The principal elements of the selected remedy are source control and management of migration. The
selected remedy utilizes in situ groundwater treatment to treat contaminated groundwater. Treatment
reagent will also be applied during the soil and debris excavation/backfilling activities; however,
treatment, with the exception of water generated during dewatering. is not a principal element of the
remedial actions for soil or sediment (inclusive of fish tissue).
6. Five-Year Reviews of the Selected Remedy are Required
At the conclusion of the remedy construction, hazardous substances, pollutants or contaminants will
remain at the Site in groundwater and fish tissue. Therefore, as required by law, EPA will review the Site
remedies to ensure that the remedial actions continue to protect human health and the environment at least
once every five years, as part of the EPA's Five-Year Reviews for the entire Site for as long as waste
remains above levels that would allow for unlimited use and unrestricted exposure. These Five-Year
Reviews will evaluate the components of the remedy for as long as contaminated media (i.e., groundwater
and fish tissue) remain in place above cleanup levels.
N. DOCUMENTATION OF NO SIGNIFICANT CHANGES
EPA issued the Proposed Plan for remediation of the Site to the public for review and comment on June
26, 2023. The Proposed Plan described the alternatives considered and EPA's preferred alternative for the
selected remedy.
EPA reviewed all written and verbal comments submitted during the public comment period, which
began on June 28, 2023 and ended on July 28, 2023. Based upon a review of the submitted comments.
EPA determined that no significant changes to the selected remedy, as originally identified in the
Proposed Plan, were necessary.
O. STATE ROLE
The Maine Department of Environmental Protection has reviewed the various alternatives and has
indicated its support for the selected remedy. The State has also reviewed the Remedial Investigation.
Risk Assessments, and Feasibility Study to determine if the selected remedy is in compliance with
applicable or relevant and appropriate state environmental and facility siting laws and regulations. The
State of Maine concurs with the selected remedy for the keddy Mill Superfund Site. A copy of the
declaration of concurrence is attached as Appendix A of this ROD.
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PART 3: THE RESPONSIVENESS SUMMARY
PUBLIC COMMENTS AND EPA RESPONSES
EPA published the notice of availability of the Proposed Plan and Administrative Record through a news
release on June 26, 2023 and released the Proposed Plan to the public by posting a publicly accessible
link on EPA's website at www.epa.gov/superfund/keddv. In addition, postcard notifications were mailed
to residents and businesses located within a 1-mile radius of the Site and those that had signed up for Site-
related announcements. Notifications were made to potentially responsible parties that participated in
previous settlements related to the Site.
From June 28, 2023 through July 28, 2023, EPA held a 30-day public comment period to accept public
comments on the alternatives presented in the Feasibility Study and Proposed Plan.
On June 27. 2023, EPA held a hybrid public informational meeting to update the community on EPA's
findings detailed in the Remedial Investigation and Feasibility Study Reports. A hybrid public hearing
was held on July 18, 2023 at which community members could provide written or oral comments on the
Proposed Plan. A transcript of this hearing and the comments received at the hearing are included in the
Responsiveness Summary.
Four public comments were received during the Public Hearing and four comments were received in
writing during the public comment period. Comments have been paraphrased below. The full text of the
written and oral comments received during the comment period has been included in the ROD
Administrative Record.
Comments Received at the July 18, 2023 Public Hearing
COMMENT No. 1:
One town resident commented that | the cleanup] is a tremendous gift to the Town of Windham and the
neighborhood, indicating that he hoped that as the restoration progresses there will be thought given to
what the final product is going to be and ideally take advantage of the beautiful river. He noted that the
nearby Town of Westbrook has a done a fabulous job restoring the riverwalk area along the Presumpscot
River and hopes that the Town of Windham will similarly plan, including continuing to work with EPA.
the future reuse of the Site.
The resident also requested mindfulness of the history of the mill and the potential for placement of a
monument or marker to commemorate the site's history.
EPA RESPONSE:
In carrying out Superfund response actions that protect human health and the environment, EPA typically
considers the current and reasonably anticipated future land use of a site in the remedy selection process.
The Mill Complex Property, which constitutes the majority of the Site, is zoned by the Town of Windham
as part of a Village Commercial (VC) district and is in the Shoreland General Development (GD) district
zone. Per Section 400 (Zoning Districts) of the Town's Land Use Ordinance, the VC zoning allows for
multiple uses including: residential, childcare, senior housing, commercial facilities, restaurants, and
recreational facilities.
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Use of the Target Reach of the Presumpscot River is anticipated to continue to include recreational use
(e.g., boating, swimming, wading, fishing, etc.). The selected remedy reflects the potential for all such
future land uses. In particular, by removing all soil the poses a human health risk, the Site will be made
available for a broad range of uses, including residential. Any use of groundwater from the Site or
consuming fish from the Target Reach will need to be restricted until cleanup standards are achieve (in
approximately 15-years after the in situ treatment of the groundwater and the completion of the
contaminated soil and sediment removal).
EPA is responsible for ensuring that reasonable assumptions regarding future land use are considered in
the selection of the remedial action and is committed to encouraging the cleanup, reuse, and
redevelopment of Superfund sites to achieve significant environmental, economic, and social benefits in
surrounding communities; however, EPA does not determine the specific reuse or favor one type of
redevelopment over another.
COMMENT No. 2:
A prior resident of the Town of Windham and current president of the Friends of the Presumpscot River
non-profit organization initially thanked EPA for taking on the cleanup, noting that the keddy Mill has
been a problem for many years, is dangerous, and is an impediment to the river. He noted that the
Proposed Plan discusses impacts to the community during proposed construction of the remedy, but stated
that the positive sense of identity and In ability the Town of Windham will gain is huge.
He further stated that, although he has confidence in the Proposed Plan and the details include therein, he
urged EPA to look further at the buildup of sediments behind the Mallison Falls Dam. He noted that a lot
of sediment may move dow n river and settle behind the Mallison Falls Dam.
EPA RESPONSE:
The selected remedial action for sediment is predicated on the Non-Time-Critical Removal Action
(NTCRA) at the Site, which will occur prior to the remedial action described in this ROD. As detailed in
the Feasibility Study Report (June 2023), a pre-design investigation (PDI) will be performed following
the completion of the NTCRA. The PDI will be performed to obtain the information needed to implement
the selected sediment remedy and will include further delineation of the extent of sediments exceeding
cleanup levels and will also provide fish tissue data.
Sampling was previously conducted behind the Mallison Falls Dam (e.g., sediment sample location SED-
16) and the PDI investigation will consider supplemental sampling from this portion of the Target Reach
of the Presumpscot River.
COMMENT No. 3:
One resident indicated that, having reviewed a portion of the Proposed Plan, it was unclear if the mill
would be knocked down as part of the remedy.
EPA RESPONSE:
A Non-Time-Critical Removal Action (NTCRA) has been authorized, but not yet implemented, to expedite
a limited cleanup action ofPCB contamination and asbestos-containing material (or "ACM") through
the demolition and removal of the mill building (partially or in full as determined by the design) and
associated mill building materials. In August 2022, EPA reached an agreement with a "Potentially
Responsible Party " (PRP) to demolish the mill building and remove the contaminated material from the
Site. It is anticipated that the selected remedy described in the Record of Decision will be implemented
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following the substantial completion of the NTCRA. Detailed information associated with the
implementation of the NTCRA is available in EPA's removal action Administrative Record
(www.epa.sov/superfundAeddy).
COMMENT No. 4:
A resident indicated that she was curious about per- and polyfluorinated alkyl substances (PFAS) as it has
been a recent topic in the news. Acknow ledging in her statement that the EPA did test for PFAS at the
Site, she inquired as to what markers were used, how the history of the mill was considered (i.e., she
referenced use as a box factory and for production of fire retardant materials as potential sources of
PFAS). why the detections exhibited low concentrations, and if sediment will continue to be monitored
for PFAS and be remediated in the future'.'
EPA RESPONSE:
PFAS are a complex family of more than 3,000 manmade fluorinated organic chemicals that include both
per- and polyfluorinated chemicals. Due to unique physical and chemical properties, PFAS have been
extensively manufactured and used worldwide. There is no information as to whether PFAS compounds
were used at the Site; however, information available to EPA indicates that the Site was used for metal
manufacturing., paper manufacturing, and the manufacturing offlanges and fire suppression materials
such as piping.
A large oil-based fire in late 1969 heavily damaged the mill complex and destroyed several blast
furnaces. Nine different communities responded to the 1969 fire. Several incidents of smaller fires within
the mill complex also occurred between 1969 and 1997, indicating the potential for PFAS-containing
firefighting foams to have been used at the Site.
As detailed in the Remedial Investigation Report (Volume 1) dated November 2021, surface and
subsurface soil from the Mill Complex Property and overburden and bedrock groundwater were analyzed
for PFAS. Detections of PFAS in soil were limited and below screening criteria (e.g., EPA Regional
Screening Levels [RSLs] and Maine Remediation Action Guidelines [RAGs]). The limited detections and
low concentrations in soil indicate that PFAS were unlikely to have been used during manufacturing or
other activities (e.g., firefighting activities) at the Site.
Consistent with the soil results, PFAS were also infrequently detected in groundwater. Over two sampling
events, one overburden monitoring well exhibited a perfluorooctane sulfonic acid (PFOS) concentration
of 6.9 ng/L (7.0 ng/L in the duplicate sample) andperfluorohexanoic acid (PFHxA) was detected in one
bedrock monitoring well at a concentration of 6.5 ng/L. In May 2022, EPA issued updated noncancer
reference dose (RflD) values for several PFAS compounds, including PFOS. The one detection ofPFOS in
groundwater is less than the RSI, (40 ng/L) based on a Hazard Quotient (HQ) of 1. PFAS were not
identified as risk drivers in soil or groundwater in the risk assessments completed by EPA.
Based on the relatively low concentrations and infrequent detections, PFAS do not represent significant
Site-related contaminants. Barring futures changes to the Conceptual Site Model (CSM), additional
investigation of PFAS is not currently anticipated.
Comments Received in Writing during the Public Comment Period
COMMENT No. 5:
One tow n resident requested:
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1) To know the route that the vehicles will be taking to remove contamination from the Site.
2) That the dam will be checked during the removal of the structure to ensure that it remains
structurally sound. The resident noted that the dam has historically broken and two rivers were
previously diverted into the Presumpscot River.
3) PFAS testing will occur after the structure is removed.
EPA RESPONSE:
1) The impact of truck and vehicle traffic was considered in the comparative analysis (i.e., short-
term effectiveness evaluation) portion of the Feasibility Study (FS) Report as truck and vehicular
traffic are anticipated to increase during remedy implementation; however, the actual traffic
routes will be determined in the future during the remedial design phase. Truck and vehicle
routes will be determined in coordination with the Town of Windham. Per the Scope of Work for
the Non-Time-Critical Removal Action (NTCRA), the party implementing the NTCRA shall
coordinate with the Town of Windham and the residents regarding the project schedule for tasks
that may impact the community, such as heavy trucks on town streets. This includes
communication and appropriate coordination with the Town of Windham and the local residents
and businesses of such plans. The party implementing the NTCRA also must develop a plan which
describes how community concerns/complaints will be received, managed and addressed.
Until such time as these plans are developed, please refer to EPA's website
(www, epa. gov/superfund/keddy) and Community Involvement Plan (CIP) dated June 2023.
2) A NTCRA has been authorized, but not yet implemented, to expedite a limited cleanup action of
PCB contamination and asbestos-containing material (or "ACM") through the demolition and
removal of the mill complex (partially or in full as determined by the design) and associated mill
building materials. The owner of the hydroelectric facility has previous raised concerns
regarding potential impacts to the dam structure, which will be evaluated as part of the design of
the NTCRA. Any structural connection to the dam will continue to be considered throughout the
design and implementation of the NTCRA. It is anticipated that the selected remedy described in
this Record of Decision will be implemented following the substantial completion of the NTCRA.
3) PFAS do not represent significant Site-related contaminants. There are relatively low
concentrations and infrequent detections in Mill Complex Property soil and groundwater
(overburden and bedrock) as noted in EPA's Response to Comment No. 4. Future changes to the
Conceptual Site Model (CSM) could arise as a result of removal of the mill complex structures,
but current information does not support additional investigation of PFAS. Pre-design
investigation (PDI) sampling will be conducted to refine the horizontal and vertical extents of
contamination that exceed cleanup levels and validate risk characterization assumptions and
PFAS will be investigated further if changes to the CSM or the results of PDI support such
efforts.
COMMENT No. 6:
A resident from Van Tassel Drive in Windham indicated that they had not seen the results of private well
testing, requested that supplemental testing occur before the cleanup starts, and requested information
regarding what will be done with residents" private wells.
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EPA RESPONSE:
Following an assessment to identify private wells within a 1-mile radius of the Site, EPA offered select
homeowners in the vicinity of the Site sampling of their private wells to assess whether their potable
water supply may have been affected by contaminated groundwater from the Site. Homeowners with
private wells located on Athens Drive, Paul Avenue, Van Tassel Drive and Winslow Drive accepted the
offer to have their well sampled.
The private well sampling was conducted in 2018 and analytical results indicated that, while several
volatile organic compounds (VOCs; primarily gasoline constituents), semivolatile organic compounds
(SVOCs), polychlorinated biphenyls (PCBs), and metals were detected, none exceeded the federal
maximum contaminant levels (MCLs) or EPA Health Advisories. Based on a comparison of the private
well results with monitoring wells located at the Site, the private wells do not appear to have been
impacted by contamination from the Site. The private wells are located hydraulically upgradient of the
Site, indicating that groundwater would tend to flow from the private wells toward the Site and/or the
Presumpscot River. Additionally, the individual compounds and metals detected in the private wells are
generally dissimilar to those detected in Site groundwater samples and/or are generally consistent with
local conditions.
Details regarding the private well sampling effort are included in the Remedial Investigation Report
dated November 2021 and available in the Administrative Record (www.epa.sov/stiperfimd/keddv).
Barring futures changes to the Conceptual Site Model (CSM) or other information that indicates Site-
related contaminants are potentially impacting a private well, EPA does not currently anticipate any
additional investigation of private wells.
COMMENT No. 7:
A resident from Paul Avenue in Windham indicated that they had not seen the results of private well
testing, requested that supplemental testing occur before the cleanup starts due to the proximity of private
wells to the Site, and requested information regarding what will be done with residents" private wells.
EPA RESPONSE:
Following an assessment to identify private wells within a 1-mile radius of the Site, EPA offered select
homeowners in the vicinity of the Site sampling of their private wells to assess whether their potable
water supply may have been affected by contaminated groundwater from the Site. Homeowners with
private wells located on Athens Drive, Paul Avenue, Van Tassel Drive and Winslow Drive accepted the
offer to have their well sampled.
The private well sampling was conducted in 2018 and analytical results indicated that, while several
volatile organic compounds (VOCs; primarily gasoline constituents), semivolatile organic compounds
(SVOCs), polychlorinated biphenyls (PCBs), and metals were detected, none exceeded the federal
maximum contaminant levels (MCLs) or EPA Health Advisories. Based on a comparison of the private
well results with monitoring wells located at the Site, the private wells do not appear to have been
impacted by contamination from the Site. The private wells are located hydraulically upgradient of the
Site, indicating that groundwater would tend to flow from the private wells toward the Site and/or the
Presumpscot River. Additionally, the individual compounds and metals detected in the private wells are
generally dissimilar to those detected in Site groundwater samples and/or are generally consistent with
local conditions.
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Details regarding the private well sampling effort are included in the Remedial Investigation Report
dated November 2021 and available in the Administrative Record (www, epa. sov/superfund/keddv).
Barring futures changes to the Conceptual Site Model (CSM) or other information that indicates Site-
related contaminants are potentially impacting a private well, EPA does not currently anticipate any
additional investigation of private wells.
COMMENT No. 8:
A second resident from Van Tassel Drive in Windham indicated that they had not seen the results of
private well testing, requested that supplemental testing occur before the cleanup starts, and requested
information regarding what will be done with residents" private wells.
EPA RESPONSE:
Following an assessment to identify private wells within a 1-mile radius of the Site, EPA offered select
homeowners in the vicinity of the Site sampling of their private wells to assess whether their potable
water supply may have been affected by contaminated groundwater from the Site. Homeowners with
private wells located on Athens Drive, Paul Avenue, Van Tassel Drive and Winslow Drive accepted the
offer to have their well sampled.
The private well sampling was conducted in 2018 and analytical results indicated that, while several
volatile organic compounds (VOCs; primarily gasoline constituents), semivolatile organic compounds
(SVOCs), polychlorinated biphenyls (PCBs), and metals were detected, none exceeded the federal
maximum contaminant levels (MCLs) or EPA Health Advisories. Based on a comparison of the private
well results with monitoring wells located at the Site, the private wells do not appear to have been
impacted by contamination from the Site. The private wells are located hydraulically upgradient of the
Site, indicating that groundwater would tend to flow from the private wells toward the Site and/or the
Presumpscot River. Additionally, the individual compounds and metals detected in the private wells are
generally dissimilar to those detected in Site groundwater samples and/or are generally consistent with
local conditions.
Details regarding the private well sampling effort are included in the Remedial Investigation Report
dated November 2021 and available in the Administrative Record (www, epa. sov/superfund/keddv).
Barring futures changes to the Conceptual Site Model (CSM) or other information that indicates Site-
related contaminants are potentially impacting a private well, EPA does not currently anticipate any
additional investigation of private wells.
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TRANSCRIPT OF PUBLIC HEARING
September 2023
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PUBLIC HEARING
IN RE: KEDDY MILL S' ID SITE
; u ; i, u t . .
Loc-it^. i: -*r "Aii
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AP PEARANCE t
Stenographer: Lisa Bishop), RPR, RMR
Bishop Reporting, Inc.
207-233-4 510
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MR. KEE.FE; evening. My name is Dan Keefe
and I am an EPA Superfund Section Chief and work with — in
EPA's New England regional office.
I will be the hearing officer for tonight's
hearing on the proposed cleanup clan for Keddy Mill
Superfund Site in Windham, M 11 .
Public information meetings were held with
residents of Little Falls Landing and the wider community
on June 27th. The purpose of the informational meeting was
to present the proposed cleanup and respond to questions
the site. The public comment period subsequently
. on June 28th, and as a reminder, runs until July 28,
The purpose of tonight's hearing is to formally
accept oral comments on the Proposed Plan that was released
to the public on June 2 6th. EPA has a stenographer here to
r."„"u"d your comments. We will not be respondir- t~
-nts during the formal hearing, but will r to
them in writing after the close of the public comment
period.
For the record, the Proposed Plan includes
excavation and off-site disposal of approximately
22,000 cubic yards of contaminated soil and debris from the
Mill Complex Property. Targeted treatment of soil within
the footprint of the excavation with amendments in support
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of (i in 1 cleanup. In situ, meaning in p ' ,
treatment of groundwater to reduce the mass, mobility and
toxicity of contaminants. Excavation and off-site disposal
of approximately 320 cubic yards of contaminated sediments
from the Target Reach of the Presumpscot River.
Re ion of the portions of the Presumpscot. River
ri , riverbank, wetland and floodplain habitat altered
by the remedial action. Land use restrictions, called
site-related contaminants in groundwater and fish tissue
until cleanup levels are met. Inspections to evaluate site
operation and maintenance. Monitoring of groundwater and
fish tissue to evaluate the achievement of cleanup levels.
And periodic reviews, at a minimum of every five years, to
The total estimated cost of this proposed remedy
is approximately 17 million dollars. Copies of the
Proposed Plan are available -- there may be still some in
the back of the .room — or available on-line.
Those of you wishing to comment should have
indicated your desire to do so by signing up on the sign-in
sheet in back. For those that are calling in virtually
with Teams, please raise your hand to be called upon. To
raise your hand, click on the raise hand function at the
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top of the screen. We will alternate in-person
room and virtual room. For those on the phone, to raise
your hand, press *9, and when called upon, please state
your name and address and or your affiliation. If there
are any others who would like to enter a comment, but did
not sign up, we will take your comments after folks on the
sign-up sheet have offered their comments.
After all the comments have been heard, I will
close the formal hearing. If you wish to submit a written
comment, you can hand them to me tonight or you can mail,
fax or e-mail them to Jeff Saunders at the address in the
Proposed Plan.
At the conclusion of the hearing, please see any
of the EPA representatives if you have any questions about
how to submit a comment. All oral comments that we receive
tonight: and written comments that we receive during the
comment period will be addressed in a responsiveness
summary. It will become part of the administrative record
for the site and will be included in the site's cleanup
decision.
Thank you for coming this evening as public input
is an important factor in EPA's decision-making and we will
now begin the formal hearing. And the first speaker is --
I may mispronounce the last name — Paul Panagrosso.
MR. PANAGROSSO: Thank you all for being here
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i i]i. I'm sure you would p 1 y ra' be sipping
beers with your family. It's a tremendous gift that we
have to the town, to this neighborhood. The only comment I
have on this is that I hope as the restoration process goes
on, there's some thought as to what the final product is
going to be, ideally to take advantage of the
river that we have here.
The mills -- I'm sorry -- the dams have been
coming away from the Presumpscot River slowly upstream.
They are not scheduled 1— I understand this locally here —
but who knows In time. The City of Westbrook has done a
really fabulous job in restoring the river walk area in —
along the Presumpscot River and hopefully this town has
some wisdom to do the same here as opposed to putting some
development there, so I'm hoping the EPA can do something,
work with the town to have that restoration.
And also, be mindful of th< n io ¦ yr of this mill.
It's been around for years, so hopefully there is some
thought that there is some sort of marker or some area that
is going to be respective of what came here before. I just
want to thank the EPA for doing this project too. It's
been a tremendous gift to the town.
MR. KEEFE: Thank you for your comment. If no
one else signed up for a comment, but you are welcome to
make a comment.
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And looking at Charlotte, do we have any
c o mm e n t er s on-1in e ?
MS, GRAY; Not right now. Oh, wait, we do. His
name is Michae1.
MR. KEEFE; Michael, I think I will give you the
light in one second.
Okay. Yeah, I Lit ink we can he a. r you now.
MR. SHAUGHNESSY; All right. I'm president of
the Presumpscot River and I -- as a prior resident, I have
raised some kids in South Windham Village. First of all, I
just want to give a huge thanks to the EPA for taking this
on. The Keddy Mill has been a problem for age " it's
been dangerous, it's been an impediment to the , and
for you to be working on this is I think going to bring new
life into the villages there and be a blessing for the
river and. for many years to come.
I just also want to say that community impact is
just that. Your community impact section talks about the
impacts of the construction and stuff, but again, what this
is going to do in terms of the positive sense of identity
of the community and the liveability of it is going to be
huge. I was on the Town Council in Windham when we first
began actually looking at this and I'm so glad that this
is — this is occurring.
Relative to the river, I have great confidence in
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i plan and I'm 1 hi| .t the sense of detail that it
carries. One thing 1 would urge you to do is to look at
the sediment build-up behind Mallison Falls Dam. And that
may be in there in the first bullet points that you have
under the Presurnpscot River, but a lot of the sediment has
• moved down river and settled behind the dam. I don't
if that's in there. It may be in there, but I would
just like to bring that to your attention. Thank you so
much.
MR. KEEFE: Thanks, Paul, for your comment —
Mi ke.
Anybody else on-line?
MS. GRAY: No.
MR. KEEFE: Anybody else in the room want to
offer a comment on the EPA's proposal?
If you state your name, it would be helpful.
MR. PICKELHAUPT: Sure, Charles Pickelhaupt. I
live right here on Main Street. I've only gone halfway
through this and I see a lot of words on soil and
groundwater and sediment, but does this mean that the mill
will be knocked down, disposed of, the sediment, the mill
is gone, or is it just the groundwater or the soil?
MR. KEEFE: So as part of the hearing, this is on
the remedial — EPA's remedial program. We have a
companion program for which we are negotiating the mill's
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i 11 . This 1 ii ''ii is on what's in the Prep . s Plan
which is to deal with other sources of contamination.
MR, PICKELHAUPT: So it does not include
demolition of the mill?
MR. KEEFE: The remedial program, the remedial
that we've proposed deals 'with all the risks from the
site, excluding the mill building. We have negotiated and
have agreements in place for the mill's removal.
MR. PICKELHAUPT: As long as it comes down. Soil
is great, but get rid of the building.
MR. KEEFE: Other comments here in the room or
on-line? I will give you guys 10 more seconds.
Sure, please come up.
MS. DICKINSON-AMIDON: I don't know If I'm going
to be astute in my comments at present. My name is Holly
Dickinson-Amidon. I live at 93 River Road.
MR. KEEFE: Can I just get you to get a little
bit closer to the mike?
MS. DICKINSON-AMIDONs And I'm. just curious about
PFAS. It's been in the news all over the place. I read
that you tested for It, but what was — what were your
markers? I have read the history of the mill and it has --
It was a box factory. PFAS is known to be present In the
paper industry. And then it was fire retardant materials.
Again, very key. And I don't understand that y'all came up
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September 2023
with no numbers for PFAS. And is going to be going on
continually looking at the sediment and seeing if PFAS is
present? If so, hoi# will you remediate? And I guess
that's my comment — my question, comment.
MR. KEEFE; As I mentioned, all rA^nt;
received, will be resp i I 1 to in a respc u i i . . iry.
There is not that exchange of information at the g.
MS. DICKINSON-AMIDON; Okay.
MR, KEEFE: Thank you for your comment.
Others on-line or in person?
All right. Well, thank you for coming this
evening -- I'm sorry, thank you for participating this
evening. Remember that the public comment period for
making written comments closes on July 28th. The hearing
is now officially closed.
(Time noted: 6:11 P.M.)
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September 2023
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CERTIFICATE
I, Lisa S. Bishop, Registered Professional Reporter,
Registered Merit Reporter, a Notary Public in and for the
State of Maine, do hereby certify that the foregoing
transcript Is true and accurate to the best of my ability.
/s/ Lisa S. Bishop
Notary Public
Commission Expires:
January 27, 2030
PART 3: THE RESPONSIVENESS SUMMARY
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Keddv Mill Superfund Site
Record of Decision
September 2023
APPENDICES
Appendix A:
Maine Department of Environmental Protection Letter of Concurrence
Appendix B:
Tables
Appendix C:
Figures
Appendix D:
ARARs Tables
Appendix E:
Acronyms and Abbreviations
Appendix F:
TSCA Determination
Appendix G:
Administrative Record Index and Guidance Documents
APPENDICES
Page | 88
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Keddv Mill Superfund Site Record of Decision September 2023
Appendix A - Maine Department of Environmental Protection Letter of Concurrence
Page | 89
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Keddv Mill Superfund Site
Record of Decision
September 2023
i§
JANE1 T MIU.S
GOVERNOR
September 26,2023
— ¦
MEiAMIE IOYZ1M
COMMISSIONER
Mr. Daniel Keefe
U.S. L-RV Region 1
5 Post Office Square
Suite UK!
Boston, MA 02ICW-39I2
keefe.tlaiiie]ifl"epa.gs.)v
Subject: Keddv Mill Superfund Site. Windham. Maine
1:PA Site ID: MHNOOO106078
Dear Mi. tveefe.
The Maine Department of linvironmental Protection (Maine DliP) Iras reviewed the September
2023 Final Draft Record of Decision (Rt)!)) with regard to the Selected Remedy for the Keddv
Mill Superfund Site located in Windham, Vlaitie.
Based on the Final Draft ROD review, the Maine DHI* is pleased to concur with the Selected
Remedy for the Site. The Selected Remedy relies on removal, in situ treatment, operation and
maintenance activities, institutional controls, mid Five-Year Reviews. 1 he activities of the
Selected Retried} are listed below:
1. Soil (Mill Complex Property) -Excavation and Off-Site Disposal
a. The selected remedy for soil will prevent or limit exposure to contaminated soil
through the excavation of soil and debris exceeding cleanup levels within the Mill
Complex Property and disposing of the excavated material at off-site licensed
disposal facilities.
b. Institutional Controls, O&Vt, and Five-Year Reviews for the soil component of
the Site remedy will nol be required because no soil contaminants above cleanup
levels will remain at the Sile.
2. Groundwater- In Situ Treatment. Baseline and Post-Treatment Monitoring and
Institutional Controls
a. The selected remedy for groundwater will use focused in situ treatment to address
exeeedances of cleanup levels in groundwater and post-treatment monitoring to
assess the effectiveness of the treatment approach and determine if further in .si In
treatment (overburden and/or bedrock groundwater) is warranted and to evaluate
stabilization of groundwater to natural geocheroical conditions following
chemical treatment, and Institutional Controls to limit exposure to contaminated
groundwater and associated vapor that poses threats to future residents and
construction workers until groundwater cleanup levels are achieved.
Appendix A - Maine Department of Environmental Protection Letter of Concurrence
P a. g c | 90
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Keddy Mill Superfund Site
Record of Decision
September 2023
3. Sediment (Target Reach of the Presumpscot River)- Mechanical Excavation and Off-Site
Disposal
a. The selected remedy for sediment will prevent or limit exposure to contaminated
sediment through the excavation of sediment exceeding cleanup levels and
disposing of the excavated material at off-site licensed disposal facilities,
b. Additionally, reduction of risks posed by contaminated fish consumption will be
achieved using Institutional Controls (e.g., fishing restrictions, fish consumption
advisories) and engineering controls (e.g., signage) to prevent fish consumption.
4, Remedy-Wide Components
a. Five-Year Reviews assessing the groundwater and sediment components of the
remedy will be required and are anticipated after completion of the in site
treatment,
fn addition to being protective of human health and the environment, the expected outcome of
the selected remedy is to have socioeconomic and community revitalization impacts such as
enhancement of property values, recreational use of the Presumpscot River, and improved
ecological habitat.
We commend the Region I Case Team, especially Jeffry Saunders, .Alex Sherrin, Lisa Danek
Burke, and Charlotte Gray.
If you need additional information, do not hesitate to contact myself or members of my staff at
(207) 592 0882 or by email at nick.hodgkins@tmaitie.gov.
Sincerely,
Nicholas J. podgkins
Director, Division of Remediation
Maine Department of Environmental Protection
Appendix A - Maine Department of Environmental Protection Letter of Concurrence
Page | 91
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Kcddv Mill Superfund Site
Record of Decision
September 2023
Appendix B - Tables
Table G-l: Exposure Point Concentration Summary - Surface Soil - Current/Future
Resident
Table G-2: Exposure Point Concentration Summary - Aggregate Soil -
Current/Future Resident
Table G-3: Exposure Point Concentration Summary - Sediment - Target Reach of the
Presumpscot River
Table G-4: Exposure Point Concentration Summary - Surface Water - Target Reach
of the Presumpscot River
Table G-5: Exposure Point Concentration Summary - Fish Tissue - Target Reach of
the Presumpscot River Fish Filet (Smallmouth Bass)
Table G-6: Exposure Point Concentration Summary - Groundwater as Tap Water -
Groundwater
Table G-7: Exposure Point Concentration Summary - Shallow Groundwater -
Groundwater
Table G-8: Exposure Point Concentration Summary - Vapors in Construction Trench
- Shallow Groundwater
Table G-9: Cancer Toxicity Data Summary - Oral/Dermal
Table G-10: Cancer Toxicity Data Summary - Inhalation
Table G-l 1: Non-Cancer Toxicity Data Summary - Oral/Dermal
Table G-12: Non-Cancer Toxicity Data Summary - Inhalation
Table G-13: Calculation of CO PC Cancer Risks and Noncancer Hazards - Adolescent
Trespasser - Surface Soil
Table G-l 4: Calculation of CO PC Cancer Risks and Noncancer Hazards - Child
Resident - Surface Soil
Table G-l 5: Calculation of CO PC Cancer Risks and Noncancer Hazards - Adult
Resident - Surface Soil
Table G-16: Calculation of CO PC Cancer Risks and Noncancer Hazards - Age-
Adjusted Resident - Surface Soil
Table G-l 7: Calculation of CO PC Cancer Risks and Noncancer Hazards -
Commercial/Industrial Worker - Surface Soil
Table G-18: Calculation of CO PC Cancer Risks and Noncancer Hazards - Child
Recreational Visitor - Surface Soil
Table G-19: Calculation of CO PC Cancer Risks and Noncancer Hazards - Child
Resident - Aggregate Soil
Appendix B - Tables
Pai»c I 92
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Keddv Mill Superfund Site
Record of Decision
September 2023
Table G-20:
Table G-21:
Table G-22:
Table G-23:
Table G-24:
Table G-25:
Table G-26:
Table G-27:
Table G-28:
Table G-29:
Table G-30:
Table G-31:
Table G-32:
Table K-l:
Table L-l:
Calculation of CO PC Cancer Risks and Noncancer Hazards - Adult
Resident - Aggregate Soil
Calculation of CO PC Cancer Risks and Noncancer Hazards - Age-
Adjusted Resident - Aggregate Soil
Calculation of CO PC Cancer Risks and Noncancer Hazards -
Commercial/Industrial Worker - Aggregate Soil
Calculation of COPC Cancer Risks and Noncancer Hazards -
Construction/Excavation Worker - Aggregate Soil
Calculation of COPC Cancer Risks and Noncancer Hazards - Child
Recreational Angler - Fish Exposure
Calculation of COPC Cancer Risks and Noncancer Hazards - Adult
Recreational Angler - Fish Exposure
Calculation of COPC Cancer Risks and Noncancer Hazards - Lifetime
Recreational Angler - Fish Exposure
Calculation of COPC Cancer Risks and Noncancer Hazards - Child
Resident - Groundwater as Tap Water
Calculation of COPC Cancer Risks and Noncancer Hazards - Adult
Resident - Groundwater as Tap Water
Calculation of COPC Cancer Risks and Noncancer Hazards - Age-
Adjusted Resident - Groundwater as Tap Water
Calculation of COPC Cancer Risks and Noncancer Hazards -
Construction/Excavation Worker - Groundw ater and Trench Air
Refined Chemicals of Potential Ecological Concern
Summary of Ecological Risk Assessment Refined Screening Evaluation
Comparative Analysis Summary
Cleanup Levels
Appendix B - Tables
Page | 93
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Keddy Mill Superfund Site
Record of Decision
September 2023
TABLE 5-1
EXPOSURE POINT CONCENTRATION SUMMARY - SURFACE SOIL
KEDDY MIL SUPERFUNO SITE
WINDHAM, MAINE
Scenario Timeframe: CurrertFiiuro |
Medium. Soil I
Exposire Medium: Suface SoiP j
Maximum
Exposure
Contaminant of
Units
Arithmetic
95% UCL
Concentration
Exposure Point Concentration
Point
Potential Concern
Mean
WW
Units
Statistic
Rational©
Site
: J7 9-TCOD TEO
mg/kg
0.000018
0 0 00054
0.000091
0 000054
mgfcg
•JS% Adjusted C anuria UCL
ProUCL Recommendation
Ben20iaiarthrs£©n&
mgi/kg
0.25
0.47
1.1
0 47
mg*Vg
95'>. Adjusted Gamma UCL
ProUCL Recommendation
Bsnzoisipyrene
mg/kg
0.24
0.41
1 0
0.41
mg/fcg
Gamma Adjusted KftfrUCL
ProUCL Recommendation
Carbssol©
mg/kg
0.4
NC
0 1
0.1
mg/Vg
Maximum
See footnote
DifcerwHa h)anthrscerte
rng/hg
0,11
0 23
0 09
0 23
mg*g
Gamma AdjuMed KM-ua
ProUCL Recommendation
PTB Dicmn-like Congener TEQ
mg/kg
0.00012
0 00021
0 0030
0 00021
mg^g
95% Adjusted Gamma UCL
ProUCL Recommendation
Total PCBi
mg/kg
8.5
28
280
:?
mgAg
95%KMiCs*a
9*.% Aajusted Gamma UCL
ProUCL Recommendation
Lead
mg/kg
89
146
310
mg/kg
9'j% Ac|usted Gamma UCL
ProUCL tfecommendat Ion
Manganese
mg/kg
485
698
1640
mg/kg
Adjusted Gamma UCL
PtaUCL Recommendation
Nickel
mg/kg
45
86
150
bo
mg/kg
'35% Acjusted C amma UCL
ProUCL Recommendation
Thallium
mg/kg
0.43
NC
0.89
0 J
m9*S
Maxmum
S@® footnote
vanadium
mg/kg
41
50
102
50
mgfe.
-95% Student's 1 UCL
ProUCL Recommendation
MC " Mr,! r.sjajifitfrl
MOTO. MSk'tlTUfFtCf-X
xtod concisnTX-ori used a: l ¦, U-'. i
••lijri. tjtji'.ij'"'j!
4 datoctr
. i* &3«Tfe seo w-30 sufficient, tho
rj
Appendix B - Tables
Page | 94
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Keddv Mill Superfund Site
Record of Decision
September 2023
TABLE 0-2
EXPOSURE POINT CONCENTRATION SUMMARY - AGGREGATE SOIL
KEODY MLL 8UPERFUND SITE
wmamm, name
I- ."i'm'-ji i r ._•» it ¦ _
l-Vi I H
Maximum
Exposure
Contaminant af
Units
Arithmetic
95% UCL
Concentration
Exposure Point Concentration
Point
Potential Concern
Mean
Value
Units
Statistic
Rationale
S*6
1,3-DichIorobsrtiene
i .
1
MC
, -
i 1 1
Vi."iyrri:.;;v-
-,c-
i ¦
0. COO 05-4
i j .
-r l' _ J - if ' i _L
1 t >iJ'_ ¦_ f . n
>1 ! I
2 -Msthylnisphtfialon-i?
I 2
!! ! U'.
4:
4 J:
i a
rn%b KM [C^ebyshev UCL
Fi.UCLF - 'ii
-
I i .
(
0 10
i
' h - T it- • i i 1 I I
1 i ii h i 1 - H -
il h
i I <
0 58
1 i
&5% KM Aopnarimis Gamma UCL
rnU'.Lr. in -
it n
1 !
-' . f - hi it- hi , ii
it h
0 1 ft
i 1
§5% KM Approximate Gamma UCL
| | .1 h | - ||-
il II
fncIeno(1,2,3"CcS}pyreno
1 1
0 36
i
¦u f «.n ti jm n - 'i.L
1 f IJ1. L 1 - I 1
jt h
1 i
Maximum
mm| 1-
I1 J 1
-
i J
!¦¦'. i h : )¦¦¦
Ir.U'.Lh ii
PCB Dies >rMik* Convener 'H~ 0
1 1
i
99%KfvUC^bysri^)UCt
IhlN , | - n -
sl II
Tola! PCBs
i j .
KM H- ULL
Fl 'IJCu F ..ii
Aluminum
I' ! >
1M'-
i 11
1 -rf- -)i ' -if
1 i ill' I F~ ii-
ll II
Ararnony
14
_
r j '=
m% KM (Cr ebysh ev U CL
Fi UllF ... m ."
Ars&rac.
1 1
18
t
95% H-UCL
r i ii ii~ i f - ii--
1! M
Bar-m
r J '
185
p a
05% H-UCL
Fi UCuh.. n "
Oadninm
1 !
1 /
i
¦>'M H-Jr:
1 i nr. f „ >ii •—
11 M
Chromiuir
1 J 1
'.'¦1
r j .
' 1
rnU'—l. mi
j[ ll
Crtromkim
1 , , < • I'M M
- -
* ti
''
-
i
- i it- »i M
1 i Mm 1 - II
il N
- I'l1
1 1
t H
i J '
9-3% H-UCL
li'U'.LI. m
i.i-
lit
i
S5% KM £*>ebyshew)UCI
1 1 MM 1 - ii-
l! ! I
i 'i
1 i "J
95% C^tayshev (Mean, Sd) UCL
f i UllF ..hi.
- Ji P -1"
_! J »
h
1 r i U L L hi., n.
*¦-
ii| t>
I?
1 V
S5% KM (D\ebyshmyoa
Fl 11'"' F- -ri -
if h
M- M
' I
136
95% Cne-byshev {Mean. Sd) UCL
r uUllf ... ii.-
: at .n
"*!> 4M
11 -
11
ft A i
i i
n , . | 1 '
F i ii 11 | F - fi -
it n
. ->L 1
! J 1
41
i. -
f j
»%AwrwuiPale Gamma UCL
Fl M".LI ..ii.
ii n
l!|
' -in
705
v .
r' ---h 1 >i< _a
F> .UCL F " ii
it n
lvo-;e: Wd.>.inuiTrUt-ietted ca^rentratiBf; used ssthe E^Cin rslan reswears tat® samples were ;=ss tnan 31 equsi teS e ic?ss!:han4 detects, b'the sample isrx® was efficient, the PrciUCL
Appendix B - Tables P age | 95
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Keddy Mill Superfund Site
Record of Decision
September 2023
TABLE S-3
EXPOSURE POINT CONCENTRATION SUMMARY - SEDIMENT
KEDDY MILL. SUPERFUND SITE
WINDHAM, MA1KE
Scenario Timeframe Current/Future
Medium1 Sediment
Exposure Medium, Sediment
Exposure
Contaminant of
Units
Arlttimgtie
m% ucl
Maximum
Cmtmte&llm
Exposure Point Concentration
Point
Potential Concern
Mean
Value
Units
Statistic
Rationale
Target Reach
Benzsxajpyrerte
mg/kg
0 072
0,26
0-7B
0,26
mg/kg
95% KM iChebyshevt UCL
ProUCL Recommendation
Carbazole
mg/kg
0 56
NC
0.078
0,07 B
mg/kg
Maximum
See footnote
D)benzanthracene
mg/kg
0016
0,043
0,11
0.043
mg/kg
95% KMiChetyshevillCL
ProUCL Recommendation
Dimethylphthalale
mg/kg
034
0.41
QJ&
0,41
mg/kg
95% Studert's-t UCl
FroUCL Recommendation
PCB Dioxltvllke Congener TEO
mg/kg
0 0000025
0 000017
0,000026
0.000017
mg/kg
99% Chebyshev (Mean Sdi UCL
ProUCL Recommendation
Tola! PC8 Homologues
mg/kg
0 17
0 45
1.6
0,45
mg/kg
36% Adjusted Gamma UCL
ProUCL Recommendation
Aluminum
mg/kg
9854
11524
18000
11524
mg/kg
95% Studeni's-t UCL
ProUCL Recommendation
Antimony
mg/kg
1 8
NC
6,3
6.3
mg/kg
Maximum
See footnote
Arsenic
mg/kg
7.7
11
25
11
mg/kg
95% Adjusted Gamma UCL
ProUCL Recommendation
Chromii*n
mg/kg
29.8
35,99
84
36,0
mg/kg
95% Studertfs-t UCl
ProUCL Recommendation
Chromium 11!
Chromium VI
See text for chromium evaluation
35
1-1
See tetf for chromium evaluation
Cobalt
mg/kg
5 5
56
11
6,8
mg/kg
95% Studert's-i UCL
ProUCL Recommendation
Iron
mg/kg
17704
2436$
77600
24386
mg/kg
95% Adjusted Qsmma UCl
ProUCL Recommendation
Lead
mg/kg
56
14f.
302
146
mg/kg
96% Chebyshev (Mean. Sdi UCL
ProUCL Recommendation
Manganese
mg/kg
211
289
624
m
mg/kg
95% Adjusted Gamma UCL
ProUCL Recommendation
Vanadium
mg*8
27
32
47
32
mg/kg
95% Studert's-i UCL
ProUCL Recommendation
V I'M < ..I L*'.l.
No® Maxiwsi defected cwwiiration ustjd esihe EPC in ih^k,^ vyhere lotd tfiar. of euusl U>$ lher*wer« less than 4 cMeefc. |r ire st/foe?*!, tiie
: ¦! i¦¦iniyi-gji.ii.'ii .oxi
Appendix B - Tables
Page | 96
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Keddy Mill Superfund Site
Record of Decision
September 2023
TABLE G4
EXPOSURE P01HT CONCENTRATION SUMMARY1 - SURFACE WATER
KEDDY MILL SUPERFUND Sill
WINDHAM, MAINE
[Scenario Timeframe: Current/Future
Medium: Surface Water
{Exposure fvtecium: Surface Water
Exposure
B.Iut
rOInC
Contaminant of
Potential Concern
Units
Arithmetic
Mean
85% UCL
Maximum
Concentration
Exposure Point Concentration
Value
Units
Statistic
Rationale
Target Reach"
Oi«ldrin
0.099
HC
0015
0.015
MS*-
Maximum
See footnote
PCB Oioxirvlike Congener TEO
pgi-
0.000000094
HC
0.0000017
0.0000017
USA
Maximum
See footnote
Total PCB Homotogws
pgi-
0.0037
0.036
0.055
0,035
pg/L
99% KM (Chebyshevj UCL
ProUCL Recommendation
Chromium
w-
7.0
1.82
19
IS
ml
95% KM ct> UCl
ProUCL Recommendation
3S£,
JBL
9.5
HC
13
1.3
a
Maximum
See footnote
nusftdssrtift FRCm qmipfismr&sfrssutar or ftqua! to 8 andmr tessrhsn eter&m
Appendix B - Tables
Page | 97
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TABLE C-6
EXPOSURE POINT CONCENTRATION SUMMARY - FISH TISSUE
KEDDY MILL SUPERFUND SITE
WINDHAM, MAINE
Scenario Timeframe: Curent/Future
Medium: Fish Tissue
Exposure Medium: Fish Fie! iSmaHmoutti Bass)
Exposure
Point
Contaminant of
Potential Concern
Units
Arfthmalte
Mu>
95% UCL
Maximum
Concentrate ©rs
Exposure Point Concsntnition
Value
Units
aaBstlc
Rationale
Target Reach
Caprofactam
042
0.54
0 78
0.54
mg/kg
35% KM \i) UCL
ProUCL Recommendation
PCB Dioxirvtike Congener TEO
0 0000017
0.0000029
0,0000051
0.0000 029
mg/kg
35% H-UCL
ProUCL Recommendalion
Total PCB Homoiogues
mgAg
0 4G
1.7
2.4
1J
mg/kg
ys% Chebyshev\Mem. Sd) UCi
ProUCL Recommendation
Copper
m gMg
21
NC
115
115
mg/kg
Maxmum
See footnote
Lead
rn§/S?g
} 5
NC
4.9
4.9
<"9*9
Maximum
See footnote
Mercury
mg/kg
0 14
0.17
0.21
0,17
its
95% KM (I) Ua
ProUCL Recommenddlion
= M--.I
Mete Mg msianceswheretsfalsamsies or eoueUoS trxi<'o; ihers 11 n >m- - i r — n was
sufficient, fie R&UCL rKa-msiidshon v>m use-:!
Appendix B - Tables
Page | 98
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TABLE a-S
EXPOSURE POINT COMCiMTOATION SUMMARY - GROUNDWATER AS TAP WATER
KEDDY MIX SUPERFUND WTE
WINDHAM. MANE
Scenario Timeframe Current/Future
Medium Groundwater
Exposure Medium Groundwater
Egpoiufi!
Contaminant of
fmt,n,nc
95% ucl
Maximum
Concentration
Exposure Point Oonc © ntrati on
Point
PotenBal Concern
Mean
Value
Units
Statistic
Site
1.3-Dichlorobenzene
jjgfL
0 49
NC
0.10
0.10
*
Maximum
S&e footnote
1.4-DcNorobenzene
pgil
0 53
NC
1 3
1 J
H9*-
Maxim wm
See footnote
2,3.7,8-TCDO TEQ
Ml
0 OOGOOG1!
NC
0 00000032
0 00000032
(jg/t
Maximum
See footnote
2-Me!ftytnaphthaiene
pg/L
14
111
390
ni
Gamma Adjusted KM-UCL
ProUCL Recommendation
Benzaaipyrene
iig/l
0,61
NC
16
15
}J§1
Maximum
See footnote
Ben2<*g.h.i>pery*ene
ugl
0%
NC
13
13
(jgyL
Maximum
See footnote
8is<2-ethylhexyi)pN:halate
pgi
5.2
NC
7,0
7.0
HflA.
Maximum
See footnote
Chloroform
pgA.
0,51
NC
0.61
o,ei
pg/l
Maximum
See footnote
Chrysene
pgl
i i
NC
28
28
Hgrt.
Maximum
Se# footnote
cis-1,2-DicMoroethene
wl
1 4
2 1
11
2.1
jjgJL
95% KM i t J UCL
ProUCL Recommendation
Diberzofuran
pgA.
54
NC
14
14
M9^-
Maximum
See footnote
Dimeth^phthatete
pg/L
5,5
NC
3.3
3,3
ygfi.
Maximum
See footnote
Ethy (benzene
|ig/L
0T0
1 2
6.0
1.2
M9*-
Gamma Adjusted KM-UCL
ProUCL Recommendalion
Ffuorene
(igA.
t 7
NC
4?
47
P9^-
Maximum
See footnote
Methylcyclohexane
pg/l
0 63
0 80
2.3
0.80
(jg/L
95% KM (11 UCL
PsoUCL Recommendation
Naphthalene
pgA.
51
39
140
39
ji^t
Gamma Adjusted KM-UCL
ProUCL Recommendation
PCB Dioxirvifce Congener TEQ
0.00000055
0 0000058
0000016
0 000005ft
39% KM fChebyshev) UCL
ProUCL Recommendation
Pertachtorophenoi
pg/L
1 9
NC
0.10
0 10
M9A.
Maximum
See footnote
Phenarrthrene
pgt
8.7
78
190
78
(jgA.
99% m (Chebyshev! UCL
ProUCL Recommendation
Pyrene
pg/L
4.9
59
14®
59
jig/I
rn KM (Chebyshevj UCL
ProUCL Recommendation
Total PCB Homoiogues
0.085
0 44
1?
0,44
Mg/L
97.5% Chebyshev {Mean. Sd> UCL
ProUCL Recommendation
Trichioroethene
pgA.
1,5
I
11
2,1
ijgt
35% KMtllUCl
ProUCL Recommendation
Vinyl chloride
pgA,
0,64
NO
1,7
1.7
{iQfl
Maximum
See footnote
Aiuminurn
pg/L
159
228
2140
228
HgA.
KM H-UCL
ProUCL Recommendation
Arsenic
pgi-
6.3
S 6
44
10
H&t
KM H-UCL
ProUCL Recommendation
Chromium
pg/i
9.:
: i.
29
ugft-
Gamma Adjusted KM-UCL
ProUCL Recommendation
Cobalt
pg/L
19
30
11
30
H9*.
Gamma Adjusted KM-UCL
ProUCL Recommendation
Cyande
pgA-
8.0
1 5
1 5
HS*-
95% KM ill UCL
ProUCL Recommendation
iron
pgfl-
6169
14519
40000
14511
l*
95% Chebyshev (Mean, 3d* UCL
ProUCL Recommendation
Manganese
911
3180
911
*
95% Adjusted Gamma UCL
ProUCL Recommendation
ted rarc^nrrart-nn u?«i ma FPC in
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TABLE G-?
EXPOSURE POINT CONCENTRATION SUMMARY - SHALLOW GROUNDWATER
KEDDY MILL SUPERFUND SITS
WINDHAM, MAINE
Scenario Timeframe: Current/Future
Medium: Groundwater
Exposure Medium; Shallow Groundwater
Exposure
Point
Contaminant: of
Potential Concern
Units
Arithmetic
MMSi
95% UCL
Maximum
Concentration
Exposure Point Concentration
Value
Unite
Sfcitlsfle
Rationale
Shallow
1.3-Dichlorobsnzene
jjgpefyiene
pg/L
4 40
NC
13
13
|jg/l
Maximum
See footnote
Bis(2-e{h>i1hexyl)p(Whalale
|ig/L
&0
NC
7,0
7.0
(jg/l
Maximum
See footnote
Chloroform
(jg/U
0 54
NC
0,81
0,61
HSft-
Maximum
See footnote
Gfrysene
P0/L
9 4
NC
28
28
USA.
Maximum
See footnote
Obenzofuran
pg/L
9$
m
14
14
MgA.
Maximum
See footnote
Dimethyiphthalate
ra"-
14
NC
3.3
3.3
ra"-
Maximum
See footnote
Ethyfb&nzene
(ig/l
25
m
8.0
6.0
(ig/L
Maxinum
See footnote
Fluorene
pg/L
16
NC
47
47
raft.
Maximum
See footnote
Pjfeihylcyclohexane
¦M-
1 T
NC
2 3
2.3
H91-
Maxinum
See footnote
Naphthalene
»»*¦
47
NC
140
140
pg/L
Maximum
See footnote
Pentachlorophenol
w»i
17
NC
0Q6D
0,060
Mi-
Maximum
See footnote
Phenarrthrene
MS"-
m
NC
too
190
ll gA.
Maximum
See footnote
Pyrene
pg/L
47
NC
140
140
M3"-
Maximum
See footnote
Total PCS Hamologues
P3'"L.
0.021
nc
0 052
0.052
H9i-
Maximum
See footnote
Arsenic
Mfl.
28
NC
44
44
ug/l
Maximum
See footnote
Cobal
pgs.
3.1
NC
4.0
4,0
Mg/l
Maximum
See footnote
Cyanide
jjg^L
T.1
NC
1,4
14
pg/L
Maximum
See footnote
Iron
Mg/L
22560
NC
40000
40000
rat
Maximum
See footnote
Manganese
M*
1680
NC
2080
2080
|jgd
Maximum
See footnote
slate Maximum ctetsae
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
KM - RAGS Table 3
TABLE G-S
EXPOSURE POINT CONCENTRATION SUMMARY - SHALLOW GROUNDWATER - VAPORS IN CQMSTMUCTIOM TRENCH
KEDDY MILL SUPERFUND SHE
WINDHAM, MAKE
j Timeframe: CurrertWFuIure
: Groundwater
[Exposure Medium. Shallow Groundwater
Exposure
Point
Contaminant of
Potential Concern
Units
Maximum
Concentration
Exposure Paint Concentration |Cmir|
Trench Mr
Value
Units
Rationale'
Shallow
1,4-DlcNorobenzene
»•'
13
0 0089
mg/rrr'
Modeled from VDEO gw VRP Tsbis E-2
2*Pjtethyinaphthalene
390
2.5
rng/m
Modeled from VDEO gw VRP Table E-2
Chloroform
»*-
0-61
0,004©
mg/m
Modeled from VDEO gw VRP Table E-2
Dlbercofuran
IV
14
0 072
mg/nr
Modeled from VDEQ gw VRP Table E-2
Elhylbenzene
MSA
60
0 046
mg/rrr
Modeled from VDEO gw VRP Table E-2
F lucre ne
MgA
47
0,19
mg/nr
Modeled from VDEO gw VRP Table E-2
Naphlhalene
MflA-
140
0,92
mgArr
Modeled from VDEQ gw VRP Table E-2
Pyrene
|jgA
140
0 15
mgArr
Modeled from VDEQ gw VRP Table E-2
Total PCB Homologues
pg/l
0 0S2
0 00023
mg/rrr
Modeled from VDEO gw VRP Table E-2
Cyanide
. m
S 4
0,013
mgArrr
Modeled from VDEO gw VRP Table E-2
^CsrcsJfirr f in P tnwtof Envircrim^tsiQudrty-(VDEO). i' rn.i1 " 1 '•» F mdiation Prcgr-'-i -F- i - --
Nobis Engineering trie
10/5/20 IS
Appendix B - Tables
Page | 101
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TABLE G-fl
CANCER TOXICITY DATA -- ORAL/DERMAL
KEDDY MILL SUPERFUND SITE
WINDHAM, MAINE
Contaminant
Oral Cancer
Oral Absorption
Absorbed Cancer Slope
Weight of Evidence/
of Potential
Si ope
:actor
Efficiency for Dermal
Factor for Dermal (1)
Cancer Guideline
Oral CSF
Concern
Value
Units
CD
Value
Units
Description
Source(s)
Dates (2)
- — - ¦
NA
.....
NA
10
5.40E-03
P
CalEPA
1.0
1.30E+05
Ass( -ay
CalEPA
NA
NA
(mo/kg-
1.0
i n i 11 1
B2
IRIS
(m^kg
1 0
1 M 1 1 1
A
IRIS
(nig'kg
1.0
fl 1 1 1 1
B2
IRIS
(mg<'kg-day)A-1
1.0
ill IM I
B2
IRIS
2/28/2018
MA
NA
NA
10
B2
1.0
B2
oethene
NA
[hraceno
(rngl
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TABLE G-fl
CANCER TOXICITY DATA -- ORAL/DERMAL
KEDDY MILL SUPERFUND SITE
WINDHAM, MAINE
Contaminant
Oral Cancer
Oral Absorption
Absorbed Cancer Slope
Weight of Evidence/
of Potential
Si ope
Factor
Efficiency for Dermal
Factor for Dermal (1)
Cancer Guideline
Oral CSF
Concern
Value
Units
CD
Value
Units
Description
Source(s)
Dates (2)
Iron
NA
...
NA
...
...
....
Lead
NA
NA
Manganese
NA
NA
Mercury
NA
NA
Nickel
NA
NA
Thallium
NA
NA
Vanadium
NA
...
...
NA
...
...
...
...
Zinc
NA
....
NA
...
ched.
. J as surrogate for T otal PCBs.
icient evidence in animals and
KM- RAGS Table 6.1
Page 2
Nobis Engineering, Inc.
10/4/2018
Appendix B - Tables
Pa t>e I 103
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TABLE G-10
CANCER TOXICITY DATA -¦ INHALATION
KEDDY MILL SUPERFUND SITE
WINDHAM, MAINE
Contaminant
of Potential
Concern
Unit Risk
Weight of Evidence/
Cancer Guideline
Description
Unit Risk: Inhalation CSF
Value
Units
Source(s)
Dates (1)
1,3-Dichlorobenzene
NA
....
....
....
-4 L ill i_ ik
1.10E-05
(Mg/m1)"1
No information
CalEPA
LL lb
3 80E+01
Assessment underway
CalEPA
1 Rh i[ ln'i il<-t -
NA
....
...
C c 1 11 i
6.00E-05
B2
IRIS
^ 11 t 1
6.00E-04
A
IRIS
L- i_ L illii i rit [-eh-
6.00E-05
B2
IRIS
- r in i 1 H-
NA
D
...
2.40E-06
B2
CalEPA
H h it i
NA
-
-
-
i
B2
IRIS
11
(
B2
IRIS
! L i M i •-1 hi©
...
...
me
6 00E-04
(^g/mT
B2
IRIS
2/23/2018
r f t
NA
_
1 )| i:¦! 11 ]! •;!
4.60E-03
(l-ig/m")"1
B2
IRIS
2/28/2018
L h } l |c3!dL«
NA
(l-tg/m-y
___
Ml [ m| Htie
2.50E-06
No information
CalEPA
2017 RSL Table
MA
...
...
1 i 1 ane
6.00E-05
(tag/m3)"3
B2
IRIS
2/28/2018
- 1 i -
NA
....
...
340E-05
{[Ug/'m3)'1
CalEPA
Table
verier TEQ
3.80E+01
?!S
CalEPA
Table
5.10E-06
(^g/m'T1
CalEPA
Table
NA
_
NA
....
...
r t h ill sues (2)
5.70E-04
No information
IRIS
5.70E-04
No information
IRIS
4 10E-06
A
IRIS
4.40E-06
A
IRIS
NA
_
...
NA
4.30E-03
(Mg/mY
A
IRIS
NA
_
1.80E-03
!
B1
IRIS
1
NA
!
...
1
8.40E-02
!
A
IRIS
9.00E-03
(. _ .
No information
PPRTV
20 ... .
NA
....
NA
-
KM-RAGS Table 6.2
Page 1
Nobis Engineering, Inc.
10/4/2018
Appendix B - Tables
Pa ae I 104
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TABLE G-10
CANCER TOXICITY DATA -¦ INHALATION
KEDDY MILL SUPERFUND SITE
WINDHAM, MAINE
Contaminant
of Potential
Concern
Unit Risk
Weight of Evidence/
Cancer Guideline
Description
Unit Risk: inhalation CSF
Value
Units
Source(s)
Dates (1)
Iron
NA
NA
NA
NA
2.60E-04
f|jg/m 3)"J
No information
CalEPA
2017 RSL Table
NA
NA
....
...
....
NA
Definitions. CalEPA = California Environmental Protection Agene
i for Total
IRIS = integrated Risk Information System.
¦eer-Reviewed Toxicity Value
'e available,
nais and
~ Nobis Enqineerinq, Inc.
KM-RAGS Table 6.2 rage I ' to/4/2018
Appendix B - Tables P a g c | 105
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TABLE G-11
NON-CANCER TOXICITY DATA -- ORASJDERMAL
KEDDY MILL SUPERFUND SITE
WINDHAM, MAINE
Contaminant
Chronic/
Oral Absorption
Absorbed RfD
Primary
CorrwrKd
of Pote"tia!
Sub chronic
OralRfD
Efficiencyfor
for Dermal (1)
Targe!
Uncertainty HModif/iny
RfC' Target ijrganis^
Concern
Value
Units
Dermal (1)
Vafue
Unft®
Organ<$)
Factors
Source^
Date's |2i
1.3-D-o;hk«ot»ric-n?
...
Ctenic
7.0CE-02
mC^O'Cljy-
7.0CE-02
Hepat-e
100
Chrcnic
7 OflC-'O
7 OCtC'-iO
=:?produc:h;w
30
1F: i "-
Chfytik-
4.0CC-03
fe'spratorv System
1.000
l
-
~
-
Chrcftic
3.0CE-04
3.0GE-04
Dcvdcprrsnu.
"
-,i/i
Bis(3.friy»iay;fenralale
Chraiic
2,0(E-U2
rngAfg-day
> '! S-..I I /
rn^kj-cby
HepaU
I.000
IRIS
S OCT 0'
nig^f} dsv
? ore in
m£>'k|> day
100
m
MA
,:'ii
Cut mi ic
1 t II !:¦¦ f
t.OUt-02
Unjtk^di!f
H&peU
100
II.'! ¦¦¦,
COCC OS
mg^gdav
/ OOr 03
me^-day
Ui'!r:;-TY! Wiote wtxfc
5,iJjO
MA
1.00E-03
1.OOE-03
mcfkgrday
Whole- Body
tCf.GOO
PPRTV Appsnd-.r
2017 RSL Tabl©
Chrcnfe
7II0E-05
mg&o-day
7 00E-05
irtgfka-day
Hepa-:
I0j
i
Cbtane
¦[
1.0CE-0"
mg'kg-day
Hepatic, Urirary
rooo
.1
Ovxnie
¦100E-U2
mg^day
m^ks-day
BScod
3,000
IRS S
-K
v>.
'¦ ."H M
Cr«
7 OUS-'H)
Rspiodiic^'*
30
1 i !l .'i (.
!-! ¦¦¦¦,
Ch?m:
7.0CE-03>
mgfcg-day
7 0137-03
HepaK
Not assessed jn2*f IRIS
300
Ohf;;
rngkg-tfeiy
immune Defmel. Octifcn
y.tj-
Chr-aiic
2.00E-05
rn^cg-dgy
¦ : i: 17-1 '•.
m#g-d5jy
immune. Dermal Ocular
...
—
Chrome
E- 0O~ 04
mgfcij dsy
7 0CF&1
Impure
100
Chi on ie:
3 00E-4M
FT!i^day
k :
to
Oven ic
1.5DE+00
niC|>Vg-dsiv
0 CI 3
m£k>day
k'one
10)0
3 0017-03
r^f^kQ-ttev'
? 5CJC05
mg-'kg day
None
000
a-Kme
3.0C6-04
rn£l>*k0.d8y
i QCE>04
mgrk^day
3,010
|'L «
Chrcflit
4 nnE.nj
„ ,
Chronic
HI 1 I !
i , .h
"
z,m
Appendix B - Tables
Page | 106
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TABLE G-11
NON-CANCER TOXICITY DATA - ORAL/DERMAL
KEDDY MILL SUPERFUND SITE
WINDHAM, MAINE
Contaminant
Chromci
Orai Absorption
AbNO'Decl RfD
Primary
Corr Dined
of Pote"tia!
Subchiornt
i RfD
Efficiencv to»
for C'errnalOi
Target
Uncrrtw ntv iMoriifyi ny
RfD f•- --i
11,•!:¦¦;
.
i«t i!<
H (¦¦¦..I I",
i .
1
--
11 ii r r,;
ngkg-da^
1 .OllE-04
1 ' if 1
- 1 I- ! » '
i,
in,
•>
& 0(fc-!)4
'
1.00E-05
mg^D-day
! .00&-05
I .HI 11.
Hair
t m> .
Mm
V'tTiOd-um
i.
mi. ii ¦
1/oCE-04
< , .1 I (.
(r-T::;
-
line
in
!>, 'i
I , 1.11.
¦ .1
ll
i4] rvteKync cn='i}?i£St teftiofy vdly* usad rot
i Mel'iyi merejry io* citv vaM? iis«t k«: h;
ss<1 far T»'4«! PCBr and Total PCO! wiologi^s
;oii, «y&a:id»*ate? snusurface wai*r
i ^ :Av/:
Dcfn-ik
HE*ST* Health Eftffit? Ass
IRF-;"" int^rs-racl Ri^lnfam
HA - Nd avaHdDfe
?-r*
Appendix B - Tables
Page 2
r
Page | 107
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TABLEG-12
HON-CANCER TOXICITY DATA - INHALATION
KEDOY MILL SUPERFUND SITE
WINDHAM, MAINE
Contaminant
Primary
Combfmd
<,f Potential
Chrenso
Inhaiafc
on RfC
Target
Uncertainly/Modifying
WC T»rg«Orajn(s| _
Concern
Subchicnic
Va^ue
Units
0ri®«
Factors
ScnncW.s)
Daces (1)
1.3 ' *
1,4C*;i:0fS!;aiienis
-15 t -
!
i
2,3.7,aTCDDTEa
40QE-CS
ing.!m*3
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Banum
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Own*
8.GQE-04
in^rT?.
E^socnrw
3
M2018
Appendix B - Tables
P a g e | 108
-------
Keddy Mill Superfund Site
Record of Decision
TABLEG-12
HON-CANCER TOXICITY DATA - INHALATION
KEDOY MILL SUPERFUND SITE
WINDHAM, MAINE
CortaiTM'unf
Primary
Combined
uf Potential
Chronic/
Inhaiafc
on RfC
Target
UncertainlyiMocfifyina
RfC farqet ^rgan(bj
Concern
Subchronic
Va?ut-
Units
Creams)
Factors
Sources)
Dsffs [If
Iron
...
Manep-«ss;5
M£TCL-y<2j
s oor-os
3. DDE-04
- -i i
i <"!' "i
.¦.o
Fi*
F '
TMH»rr
N&
Vanadium
Zinc
Qirwi:-
1 iXC-M
injiTrt
30
' 1 r ' » i.
{!?• Repress sssr^heci
(?) rJiandstoKi-'fr/vaiia yshelter?":1-, greurxh^sr and surf^M
nnihons- ATSr# - A<|ftnry fnr To*r fniDSt^es -.v.-jMr-;
CalEPA Caifomia E-v.ronmar'-i Prcf^'fron A^mcy
HEAS" - Mo*"h Effects A^osswU 5ufpTaiy T3;v;«
RiS - integrated Pisk i;rorTiat-:ri Syc-terr.
M/' - M i .V.Vill.:-!:;;'-
FPRTV - Peo-'-Re/ie^d Tcxic^y Value (EPA, various tM<
KM-R.AGSTabis 5 2
Appendix B - Tables
Page 2
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
Table G-13(RME)
CALCULATION OF COPC CANCER RISKS AND NONCANCER HAZARDS - ADOLESCENT TRESPASSER - SURFACE SOIL EXPOSURE
KEDDY MILL SUPERFUND SITE
WINDHAM, MAINE
Scenario 1 frorrsni*' Currenf>'Fu1u«
Receptor Population: Trespasser
Receptor Ape: Add-ascent
Medium
Mec^ni
Exposure Point
Exposure
Routs
Cfrsmicsl of
EPC
r on
- Ri^ CMuiijljns
r n .1 ,M
Hazard Ci
ill 1 >
Poieoliel Concern
rrf"
lllt'i-n rnti i
F(t»iKt
r,'
Value
Ji.iU
Units
1 «l t
ini«,
Value
init
s tH.t
as i
Surface Soil
, l"| > -|m-|
inaesfcen
*• MP! 11
-44! t~
n»i
J1 E i J
ima l q'-q-di,
NA
_
f *
Cthfii-* li i nth 1 **ne
,u! ' i
my.Kj
Mi ncrnr Vtccc of "-tin
4 1 El"
1 l i
^ qf-q-da(
NA
M
F E Zic in l!k<= _-figsnerTEO
2 fii/E i 1
mg'Va
T.4E-1?
maiVg-day
E+i"c
^m9lV.g-dayr,•-
E lit-*
1.UE-1U
q • o-da i
TE r
nnq>l3-r3,
0.14
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a TSEtdi
mtv'Kj
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1 h
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e t-i
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t-
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14tE-u4
mq'Ka
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ma^!>-dav
NA
NA
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i
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1,3*3-^
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or
gS3-r! a,
41 L (4
imj Vg-iij
0.0023
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NA
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1 Hi 14
Chromium III
: .:e-.
mg-Kg
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t n iq !> >nv
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Muisaemc Mccc of Asticn
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q'.Jddf
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mini- »,
1 iM!4'
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! n E-
mt'^3
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q '14-Uj r
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mu > i-' ',
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Lead
i tec-y"'
n.Q'kj
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ma^adov
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NA
u IE J>
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:
11114 > i< <<
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S S3E*01
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4 «F f-
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-
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J ltd
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i i
innkjii
0.0016
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•
mc> -3
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NA
NA
4.3E-07
g-jdi
t.OE'Ce
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11 >4'
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4.JJE-0-
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tr
NA
NA
2.4E-05
g'sq-d f
5.QE-03
in.g K^-u j
1 P1H.
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t 1
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f s
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2.28E-01
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6.0E-05
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Ar eni>
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mq >
2 SE-07
ma^ka-dav-
1.5E-KMJ
(mg/ka-day^-i
4.1E-07
1 jE iO
u ' n «1 u
5.0E-C4
inrj> Hi,
0.0084
LBdrnu-
2.S7E~OC>
TiltJ * Q
3 7E-10
mgfcg-day
NA
_
NA
h ¦ E jy
- q»*g riiy
2SE-05
rnij ^ t-i. ij
0.00027
i~ hi < jrni HI
9.03E*01
ru} 5
HA
NA
NA
NA
2.5E-(S
m.nj' v
MA
Lhr-mij- .!
2 j&Ei-m
mgftg
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NA
HA
b-' r
imglg-u-i
r «
Ccteait
1 ?£-•"
ill f T
NA
NA
-
NA
NA
i 1 i 4
inav?.-.j
f"4A
Copper
1
rfig]'r,g
NA
-
NA.
_
NA
HA
-
1' Ft r
imglj- av
MA
Iron
•i
mgtHg
NA
...
NA
__
NA
HA
T.lEl.
inig.'Vg-cay;
NA
Natiis fi
KM - RAGS Tattle 7 • Sal-RME
Appendix B - Tables P a g e | 110
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
T»W« e.13(RME)
CALCULATION OF COPC CAMCER RISKS AND NONCANCSt HAZARDS - ADOLESCiMT TRESPASSER - SURFACE SOIL EXPOSURE
KEBOT MLL SUPERFUND SITE
WINDHAM. MAINE
Seen*nc Timeframe Current/Tutor*
Recsptor Population" TrespasiKS'
R«
Ntedfcm
Medum
b • r urr t11 nt
F
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f.ri i ) i p
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Denial
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Umi-i BTfineering, toe.
KM • RAGS te«e ? . SamiWE
Appendix B - Tables P a g c | 111
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TASLE CJ-14 fRMEJ
CALCULATION OF COfC CANC1R KtSKSMtD NONCANCER HAZARDS • CHILD RESIDENT - SURFACE SOIL EXPOSURE
KEOOY mil SUPERFUNBSffls
WINDHAM. MAINE
Scemno Tiw.fra.rrte: ratur*
Receptor Imputation: Resident
fe«p.o,A8,:
Chiid
Medium
NtedlURl
"b*p«t:e i'ap'i
E
Cr.«nHs* of
Caicef R''SS< Calculat'cns
¦hutv
P i*-C
Paent^Ccncw
Vafcs
Unite
/Exposure Ccrcenlretion
CSfiUmi Risk
Cancer Risk
Irif m i iiiih
1 1 1 n.
h" ' !'f
IUM' (
H( "•!
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Onife
v ei
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mmon
2.3,?.8-TCOD TECS
5,44 E" CIS
tvm%
-
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7.0E-10
r , t. w 1
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4.66E-01
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4 t i n
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3.0E-04
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km . rags te«e ? • samME m&ma
Appendix B - Tables P a g e | 112
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TASLE CJ-14 fRMEJ
CALCULATION OF COfC CANC1R KtSKSMtD NONCANCER HAZARDS • CHILD RESIDENT - SURFACE SOU. EXPOSURE
KEOOY mil SUPERFUNBSffls
WINDHAM. MAINE
Scemno Tiw.fr8.rrte: ratur*
Receptor Imputation: Resident
io- fig* Chi j
Medl ym
NtedlURl
"b*p«t:e Pari "'
Cr.«nHs» of
Cmsm Risk Calculatrr.
Value
Unite
intake/Exposure Concentration
CSRtM Risk.
Cancer Risk
Inf ai i- | u i it i
onopilrBtian
RfD/RfC
Value
Units
Value
Units
v.»Iub
Unite
Vatel
Units
QuoDent
Sotf
Surfeee Soil
7 DsfjiM Street
Darnel
fVi! mnwm
8.&&E-KI2
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4
....
~
WA
-
\3E-04
(rxjAg-doyj
HA
Surtax Sal
2.3,7,8-TCOO TEO
i! ~ L
^•9*3
...
-
_
r;n-
141
4.CE-0S
mQi*r>',3
I i.
T l«w Steel
B«i^cIi*8 Coogerar T£0
7 vSt-(«
- Q*2
_
_
-
_
l fiE-ri?
W
t
ii" ^
¦ \ -
Tc#ei PCBi
: -VE-1
"
_
_
_
_
-j nc t,c
1 J'i'
ik
n&
Aiarnirjrfv
; 4. > 4.
ma/k§
-
-
-
-
~
1 L-—f .
l-J '
TgT !
t h - .
A/itrion-y
i ,_E-»-U
-;-ks
_
-
-
~
: r>= n?
l -J i
MA
Hi
fifsmx
•St,'.
rr.yfcg
_
_
-
,'r' lift
1- i t
i ir,'-
' i > )
rr,. |.,
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1 ir . r
CoCaft
. -
TgfcQ
-
_
-
1 4 >
ftr "
i " .
Co«*r
I F~ 1
-
-
-
1 *i in
1 i i
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iron
> — (4
-
-
„
-
C I'L-Uj
|aj fi .
WA
_
it
Le&d
' 4 E* i"
_
-
-
1 ! >
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W
M*nt»ne*e
i. - i '•<
1 l '
se&-05
M ^
lU
Nickel
h - i T.l
-
-
-
-
h i ~.VR
1
D.OE-05
, -ir i
, u H
Thallium
' O- Hi
-
-
-
-
j i.! .
1 11 k
NA
h(
Vanadium
-
< l :i>.
1 J '
i.e^o*
> H i
InhafataTete
...
Mi' |vs„? v
_
Arwsmc mg*sfton intake i-ictucfc* an assumBd n»l*tve otoavsWiiify ,'HKAl g!6(»
BTfineering, toe.
km . rags te«e ? • samME m&ma
Appendix B - Tables P a g e | 113
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TABUS G-15{RME)
CALCULATION OF COPC CANCER RISKS AND NONCANCER HAZARDS - ADULT RESIDENT - SURFACE SOIL EXPOSURE
KWDQY mil SUPERFUMD SITE
WINDHAM. MAINE
Seesafe TlmefrM-®: Future
%aeep?s?Papulation: Resident
Wfedfcim
Exposure ftfedMinr
Exposure Pant
" ¦ .i
£PC
Cancer fete Calculations
""
R"V>"
Pater Ubs Cancerr
Value
Units
trfe
CSFiUnit
Carta©? Ri
l! <1 | .
k'l i
t - 1
vaiua
Units
Vslue
unite
..hit
II11
^ m
Units
i t
Sctf
Surface Soil
[hi*
Ingest thracers
4 fi6E-0t
mgAg
-
...
-
....
...
• r »
n^n j Jj,
NA
Sefsote^ene
4 07E-CH
n-mq
-
-
-
-
4 i 1
!
(fng^g-day!
in r
Carbsuraie
wortMi
—
—
-
-
1 f i
MA
i
Oiber^a.hiaRSh'S':-:!.1:1
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" »* i
-
-
f H
"lal- a-o-,
PCB D?oso.fi-t«e Canaener i - "i
rr©*g
-
-
...
' F I
rial --1
" € ! i
(rvg^9 f-i ,
4 €« 4
0.0059
Arser.ic
: "5E-u'
-
—
IKl , 1
" >F ' 4
(snp^jKiayi
L X"
'.acrwuiTi
* 2 L*' J
-
_
_
„ 11 It
-1 IK !
i -E-
Crr^%^iay|
1
Ch^cm-ium Of
.iE'('
-^•3K3
.....
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! E-"I1
! 1 ->*•. ! i
« =P+! 1
Q.C60072
'..TiW'-iam v»
; "«£; i i
mg>%g
_
_
-
_
. .C-Jt
n " J •.
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tmgkrntm
j < i 1
Cobalt
4 ~t>"
fT^tg
-
-
-
-
1 c
t ig^ j
¦F- H1
fl!KiK8V!
C-035
Nicks!
- - F* ¦
rogrtig
>_
E- 1
n*>, 1 s
_.,c
Ttialliurn
-
-
„
' b u
Hit i.
i >t « .
(n«iko^s^8yi
i!10SsS« Total
_
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1
!
? Depot Street
Derm*
2.5.7,8-TCDDTEQ
-
-
-
-F I
n;i 1
l ! i
1 (-
:
Bcn2o(8»fil:hrs)««: >*
4 B6E-0!
-
-
-
-
i E
mA S^s
p
B®r«o(B3pjr«i*
4 ore 01
-
-
-
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tilV'J
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?
-
-
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N
ui*
2 286-01
i*.
_
~
_
_
....
1 lb '\
i'UV J-v
ll*
PCS Cona«i«r ft >
s.me-m
ropfkp
-
-
-
-
I'lTK i i t
' -[ 1 i
(rrHj-Wayi
. 4'i
Total pcss-
......
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h 1
• .[ • »,
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1 H
Alurniriurs
¦ t -+ •
rr^ftg
-
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1 ( . -t
> !'i\ . Hy
pmtrmy
t SZi*00
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„
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>- iM •
(ir^g-day)
Arvsric
274E+01
.....
....
4.2E-D6
m i 1 ,
\ tf ' 4
(m§4<§€layi
. >"4
C&mmsm
; • t <
_
-
15E-06
m il1 ,
h '
« !-•»•»-
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S 03E+01
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...
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' 4 i
(mg*g-<1ay;
1-
Ch rwmVl
s.m*w
ma^fl
~
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-fc "'Ij
(me.^Q-dev|
\*
coe*it
umm
....
NA
* I- M
cm^ko^nyi
\*
Copper
1 6TE+02
rrSlVa-
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TABUS G-15{RME)
CALCULATION OF COPC CANCER RISKS AND NONCANCER HAZARDS - ADULT RESIDENT - SURFACE SOIL EXPOSURE
KWDQY mil SUPERFUMD SITE
WINDHAM. MfttME
Seesafe TlmefrM-®: Future
%aeep?s?Papulation: Resident
ftji*
Wfedfcim
Exposure ftfediUT
Exposure Pant
£PC
Career Rusk Gsto'stem
""i f > n
. .
i"i|"
RVr
Pcfctilinl Oarawr
Value
Units
lnMa%lsf»sar# Corvcenlrntian
CSFAJnit ftsk
i Hh * ki i
ll>* il | i il «i ' 1 i 1 I
W'l --i
Valua
Units
Value
Ursfe
V'lut
Units
unit's
Sc*l
Surface Soti
7 Depot Street
•>1
141^02
-
-
-
-
11*
f,-
Manganese
5 98&H®
«#*»
„
~
NA
i i i 4
i^g^ay!
r.
Nickel
-
-
_
NA
«- «t ' 4
< n t. ¦ ,
r**sium
3 SOE-OI
mg*g
~
_
..
NA
. .[ i >
nHii.
4.96E*01
"**«
-
—
_
NA
—
1 _E <1
•tf
Dan T 3
m
Surface Soli
A>- -st
innijisitiof*
2,3,7,8-TCDP TEQ
5.44E-G5
_
_
_
_
¦ b V
r S'ni 3
1 fc «=
Q.QQQa?
7 Ucpo» Street
Beru«.s jartfcKrBSMve
.
rr*t*0
-
-
~
-
1 IE >4
1 rj'rs .
t i
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Be^c*;a)pyrene
S P i 1
_
4 ,H 'r
I u'm'
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Cartwurote
nxj*g
-
--
-
-
! :e-
pa'm j
N-
.....
Dibcras a-hiarittitsccne
rr&kg
-
-
_
--
-
: -E i.'
pj'n i
•a
PCB oexiM)** c®gen«r TEQ
-
W9*9
_
-
_
i ih i
I D'H '
4 ^
iri&'n/'i
'"I
Total P€Bs
mpftf
—
-
-
-
* ie •:
« n'rt C
*1-
Aluminums
mg/kg
-
-
-
-
i sr o"
k. Q 1 ' ~i
b ir
i i'\ n-
1 it > " '
Art^-ony
-
-
_
~
-
- 0£- r
P9 n, 3
NA
....
Arseric
;
- 3 f "
Cadrwum
"* >lt i
1 ii'ln' »
mg.^^3
. t n
Chrmwjm III
re®(%§
-
-
-
_
-
" jC '1
un'm'"
NA
Chrcmium VI
_
«
-
~ <£ '
Mij.'l ¦' i
^ 'i '4
00C00D29
Ccfc*lt
smgftg
_
-
-
-
_
. 'i in
1 Sj'Iii i
, '! ~,
Ccpper
ffNg&g
-
-
-
_
1 f F •
l ij'm' i
* \
4-
iron
TT^%9
-
_
-
~
f it
j H'im ¦
' ft
M-s
i
_
-
-
-
_
1 =!C
I a'm 2
N.A
Mangencsc
rngftg
-
-
'F 'I
l O1!
S If- IS
i H 1 3
NlCKCi
mp%2!
„
_
_
i- ,h It
1 UI'I
t( .i
TfieWum
100*8
-
-
-
ip ^
un'n r
SS[A
V»ns*um
"S M
-
« IL "I
PQ n .
€ 1 4
n ¦ -v.
inkier Tcc«f
il-.. J
total ? Depot Street
mmle insertion intake incfodesen assumed *ei«tive beevtiiibiiity iRBAtof 60%.
Itohis BTfineering, toe.
KM • RAGS te«e ? • SamME 6rt*2«1&
Appendix B - Tables
Page | 115
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TABLK 01B fRME)
CALCULATION OF COfC CANCBX RISKS AND NONCANCER HAZARDS - AQBMMUSTED REMDEMT - SURFACE SOIL EXPOSURE:
«DOY Mil SUPERFUNOSmE
WINDHAM. MAINE
Scenario Timefran>«- Polure
rtai&pti* -COUialxjii Risaloistil;
^ Hr_
Mum
MKfaim
O^mrcsJ of
r ETC
can. =i,l. , .'Mil tki
r.vi'i i rti v Hi *i 1 )i
Route
PotsrvHai Conssm
Vidua
t«S
.1 M, | < -
m. , o ,
¦ - 1 ii .i * <-*
> 11 W >
IntE r>Mi.
r' ¦ iMi
1 ! -HI
M. v
iln'v
Va!u«
Mr ^
LfJJil b
1 iN
asm
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t p I t
2,.3.r,e-TcooTeQ
- 4-*v
s- '
m^Vg-ctey
, ' M
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Ben?o(Bi8n?hfBcarte
4S6E-0J
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Mu-tagiwfc V
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....
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i1
msAQ
Mutagenic Mode of Atikm
It
-
_
~
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Csrfoazcte
1 306-01
mcv'kg
1 JE V
m^Vg-day
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-
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Ctoe^la.hianfhracfifle
*§
"> «f» i b MiOi " f.«
t 11 i tr
_
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PCB Dscwr-like Congener 11
mg.'kg
- "c II
fng^sHtfty
OE+05
m i vi, " i
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_
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...
»
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Tots? PC&5
3 706*0f
i i E >r
tzIq ci'f
2.0E+00
irrn,> t rs, *-
-
_
~
AiufiTlnusrn
1.46EO*
2 Z
mgi'Xg-^y
i'HA
-
-
_
t.92E»00
">r >r
m^ka-^y
NA
IJA
-
-
-
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2.?4E>01
ng/ks
" t£ iIs"
mcvVg-ctey
i te+m
iirn,>,i t!,i* i
-
-
-
~
-
r itnlUr!
2
4 & «o
11 >1.3, >,
NA
N«
...
-
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S.OSEOt
rngfcg
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m#ig-d3y
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Hi
~
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-
-
i." nun i
mgAg
" r Mvrfr "ft-i
a 11 - ii
....
-
Cot) as
1.17E*01
mgMg
- -c. >
MA
_
Ht-
„
_
Osppaf
1 67E«02
me^g
31 U
NA
nt
_
„
-
«>
_
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B.68&Q*
mg/kfl
M ,5. ,
i -^7 m,
NA
NA
-
-
-
...
...
Lead
¦S A&E+02
mgfeg
. ' T-
ma^Q-ctey
¦¦ifK
«
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-
„
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8,98 E*02
1 IL 1
i i'Vj
KA
-
-
Nkfcei
tngftg
>
i .Mi >J
'
....
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-
...
~
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8 90E-01
m^/Vg
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it] w
r^\
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m
—
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•t *
. »h.^\
piPi
~
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..
-
......
-
-
il i, i
<31
1 ff U
Soil
SjrfBce 5®l
¦* ri i i 11 ^ t
Derma!
2.2 J.5-TCOO TEC
V
mgk g
n us—ii ?
_
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...
&eft*o;».iu»>!hitjcen«
4 66E 01
rVKu
0 f !. \\>>H Ti « -l<^
11 1
.....
-
-
Bet>20(a)pyr«re
4 07E-01
mgAig;
! h)L! 1, Mmm if n n
I • ' f
Ctrtjasof-e
I.30E-01
prog/h®.
" • i I ' i
tJA
...
—
DfcerjK® .Ii Mmthrwctrse
2 25E-01
no'kc
• '.jt.B *
1 • »'v»l
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pi t> . \- -.iigenef TL.
2.09E-04
n®/li, t- fj<
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I 'i
-
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1.4SEKH
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MA
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-
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1 92E*C5fi
•ngftft
i^i i-\
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—
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i- .I
mc*e
- ji JL
r.jkKcj Ja,
1.5E+G0
in i_.r j '5^ f' 1
- 1 - Mb
-
_
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.-dniur
2.87E*00
•, rt |.i«f
ri
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....
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"" mil ^ ii
ir-Ef-i
m&§
«
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MA
...
-
,»
-
I 1IU1 < !
27dC*00
m§/kg
1 \'sq-~k '«5i:e ;t - f
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TABLK 01B fRME)
CALCULATION OF COfC CANCBX RISKS AND NONCANCER HAZARDS - AQBMMUSTED REMDEMT - SURFACE SOIL EXPOSURE:
«DOY Mil SUPERFUNOSmE
WINDHAM. MAINE
Scenario Timefran>«- Polure
R*t|4, fto.lt i In
Medium
Madum
1- l OJ
1 ft'HH t'i il
B
i.MlTl
fton-Csnw Harard Calwlations
re
l i(!!itii , I »»r
ViSl«a
Uafc
i ik. '(• | »
MU , 0 1
i - 1» .1 * <-*
> i 1 W >
IntBte.'ftKpKure Concentraticsn
RfartWC
1. V
llM'v
Value
n 1
tot.
¦¦ \ftirii.
D5b ^
Ouoaern
Soil
Surface Soi
7 Depot Street
Dew
IM
•i • O -
NA
NA
iH^d
t.*66*02
®y@fke
*
HA
-
-
-
-
r- .i
6.SSE*02
• \
NA
'J*
„
-
_
S.63E*01
f*ykg
*
WA
...
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i - r
-
~ Dcp-S I r-»«
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4«K1
»«
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f -r iq
«
...
Oenjwiatpywe
4.G?E-01
ng/ks
1 •- 360!u Mo}<* J* *L* f?
» 1 >,-1 1
-
„
-
Catiazoic
1.30E-01
"f ( I '• 1
r.'i
....
_
2.2IS01
r^v-kc
T' 1 jifl 1 '*> f ¦" ll <1111
1 «- M
_
__
_
..
PCB Dioxr-like Congener T!
2.SS&84
¦ngfcg
E I1
yg#n,xS
3.6E+01
j.3ATtA3
NA
r.«
-
-
-
_
Anhmefry
1 .92EOO
vygMQ
1
yjpn*3>
NA
i >t,
...
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-
-
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1 "4 1
M8ffnA3
4 3C-03
'r i
> 'ii i
-
-
Cadmium
2.a 7E*m
! L
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1 9£-03
~ i
_ i_ it
_
O'omiuw 1I [
9.03CO1
yo*n"3
! H
i>
-
-
Chromium VI
2.79E»D0
mg,Vp
Muttoefiie Mode sf Action
i
...
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t -oi
jgjmAZ
| f, t
i- i.
-
¦Ccrppw
1 67E*05
tn&s
l e ir
flA.
f. *
-
„
Iron
6KE»0*
1 T
mwi,x3
i > ->
--
itta
'\M&Q2
nc*S
ni ir-
gg^"3
f-JA
h.
„
Msa ssganese
6.9SB02
-c p.
MA
iw
_
Nickel
6.83EKM
>< ll
MSMW3
2.5C-04
| r, , 1
b rK |l
Thallium
B 90641
mgAs
. E W
(jgrtr»*5
NA
MA
-
-
„
ViMtHum
m»ftS
. t- ib
MA
_
-
~
...
Ir.ha sl'w 'fete!
1 i
-
Td i ¦¦
i Strew:
t '
Motes:
Arsenic mgesta intake include* »n assumed retelive biMWiaMify mm of 60%.
BTfineering, toe.
KM • RAGS te«e ? . SamME 6rt*2«1&
Appendix B - Tables P a g e | 117
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TaMeG-17(RME)
CALCULATION OF COPC CANCER RISKS AND NONCANCER HAZARDS - COMMERC1AUINDUSTR1AL WORKER - SURFACE SOIL EXPOSURE
KEDDY MILL SUPERFUND SITE
WINDHAM, MAINE
£:tfiBno~im©frarriG: Future
?scep:or Pcpulefcon: ComrnQrcie..'Industrial Worker
^Qccpcor Age; Adult
Medium
Madium
Exposure Pant
E
»ouL
Cnemicai of
"
Pi • fjrul.
icrw
r n =i
H M h
1 i wns
Fct n-s a Concern
Velue
Jrots
lr*t«A I iiHiniu
• ^1
ill! I i
i
rrahnl p ^ c'
n «-1 r 'i
Ril
tvt
lini
Value
Units
ki-h
sir*
Units
kcl P
Mn t-
K
P ^ Ml
7 Dwt > it—-r
imjHsU. fi
V « K i Q
ifitKQ
1 , ?
ma *g c1 ,
1 3E+Q5
na^3-d-( i
1 1 H
4 i
mq l«q
i li
rnqtig I-,
1 liH t
Uen'jrn a lunrhi i wne
Ifctt
ig%g
.n £«.„
1.0E-01
niuVa-d3 i
1 1- I!-
b i
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—
riA
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4' i
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tiu >q Q_f
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1.11 11
1 i
mg^T- 3
a.oE-ot
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i i
b-£ %
mc kqu=i
1 .OE-t-OO
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n 1 MM
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_
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PlB CiDvin- I- =< canger;er TEG
tE 1
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1 bZ i
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0.23
rfa » r«
i-t H
igftg
7.6E-C6
-
z I'E+yt
nia1« P-d3
1 I 11'
1 I
mq/ka-cav
2 En
q d:.i
1.1
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UA
....
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1 I -
mq^j -i
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H! 1
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1.32E+00
"
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.....
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F.5E-QS
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-
NA
NA
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imaVq
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NA
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i hul 14
MA
_
NA
~
NA
NA
...
7'"Ent
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NA
Nattis fi
KM - RAGS Table 7 ¦ Soil RME-
Page | 118
Appendix B - Tables
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TkOte G-17 (RM1)
CALCULATION OF CORC CANCER RISKS AMD MOMCANCO* HAZARDS - COMflERCMLANDUSTRIM. WORK® - SURFACE SOIL EXPOSURE
KEOOY MLL SUPERFUND SHE
WINDHAM, MAINE
Scenario Timeframe: Future
^ecepfor Papu-affion- Comn»rdaWnttusMrt Worker
¦Mttcp-o Age
Msdiusm
Medium
Exposure Peart
Exposure
Rente
Cfrsmicai of
H ere
Cttiew Ri®* CsScuMions
? 11 ' 1 C
h i . .s
Pofenfia. Concern
Value
Limb
istafe«,&p®»re Concerctrsiion
GSf AJruJ Risk
.Nk.-Hin '~ 1
M ''Ml'
>j >1 !
Ul':" 3-
Vi!u«
Units
V, ur
Jnif
LSfiils
( .J 1 r
?' Dwt Street
Dermal
Lead
M6E+02
m9%
NA
-
HA
NA
NA
NA
- ,,
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9JM&UZ
m
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NA
NA
i iT I u
1 1 * I H i
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mg?%
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—
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. v t> a Ji i
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K
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2J3E+0C
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5.4E-02
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1 1 M
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1'M
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f j
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eaoDc-
111 V-}
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2.0E-06
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« H < M
ri<-^ •}
iiS$nft3
m
_
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t. ?, E-06'
liaAl
MM
ii'Vr 1
. , - M
i h< i.m »Ui
:H= tlr.
roiii
4.6E-05
Notes
Arsws jngeahen irifete incite-an a«um«1 relative 'RBA1 c« 80%.
Itohis BTfineering, toe.
km . rags te«e ? • samME mmm&
Appendix B - Tables P a g c | 119
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
Table G-18 {RME}
CALCULATION OF COPC CANCER RISKS AND NONCANCER HAZARDS - CHILD RECREATIONAL VISITOR - SURFACE SOIL EXPOSURE
KEDDY MILL SUPERFUND SITE
WIDNHAM, MAINE
W il 1
t i it- I nruic-
t f r * ibtiu R c
io-el Visiior
c r h lr
Medium
tedium
Expcsur© Point
Exposure
RyJa
Chsmica! of
EPG
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F
- Hvt i" I
liluns
Potential Concern
Veil®
Units
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,. P(pr
nfi [• r>-
r - 1 n
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FffC
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i t*
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11 ri, i:n n«
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Mei z>"iia!d t! rai 8 19
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NA
NA
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n nr cm
d-c ^ 1i
"1 i
1 ! il
mg.Vg-dBy
NA
-
WA
TC2 3io- 'lie LfngenerTEij
PIC
mal>g
nt,]>n si
1 S+nc
itujra 1
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7.0E-10
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0.S5
lit- M 1
I HI)
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2.0E+00
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2.OE-05
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mj.V, liii
0.042
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-
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4.0E-U
n 1< i is v
0.014
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S.OE-04
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t.OE-03
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-
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4.7E-07
4.2E-11
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Chromium HI
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NA
NA
NA
rr \J 1im
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NA
r 1" fiy
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m
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MA
_
NA
NA
-
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NA
Coppsr
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-
NA
NA
__
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NA
Irwi
njfcg
m
-
MA
_
NA
NA
—
NA
Nattis fi
KM - RAGS Table 7 . Soil RME-
P a g e | 120
Appendix B - Tables
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
fable 6-18 (RME)
CALCULATION OF COTC CANCER RISKS At® NONCANCER HAZARDS - CHILD RECREATIONAL VISITOR - SURFACE SOIL EXPOSURE
KEDOY MILL SUPERFUND SITE
WtDNHAM, MAINE
IScenaro Tirr*ffl»me Future
Js?cc«*ar PopjfBtiorr RgcreationiBl Viator
Med»um
M»diun
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lift
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Itohis BTfineering, toe.
km . rags te«e ? • samME mmm&
Appendix B - Tables P a g e | 121
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TACUI |. r i
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Appendix B - Tables P a g e | 122
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TACUI „ rir
'I j r,n
r U(,Mri> f ,[
•»r.o,
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Potential Concern
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Appendix B - Tables P a g e | 123
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TACUI ¦ - r k »¦1 1 1 uh>ii
CSPA/oili Risk
tnle ke.'F^pcsiirp Concenlralior;
MlMiC
nji.t
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»tt#W ingesl on rtake hickwte an assumed reIsrfive bksavafeMify (RBA) of 80%
Itohis BTfineering, toe.
km . rags te«e ? • samME mmm&
Appendix B - Tables P a g e | 124
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TABLE G-20 (RME)
CALCULATION Of COPG CANCER RISKS AND MONCANCER HAZARDS - ADULT RESIDENT - AGGREGATE SOIL EXPOSURE
KEDOY MILL SUPERFUND SITE
WINDHAM. MAINE
5-c«i#rto nmefrtrw Fwtore
RecPWcr Populefwv Rfrsidert
Act Au'jll
Medium
Medium
h | • i.r. i u nS
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Appendix B - Tables P a g e | 125
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TABLE G-20 (RME)
CALCULATION Of COPG CANCER RISKS AND MONCANCER HAZARDS - ADULT RESIDENT - AGGREGATE SOIL EXPOSURE
KEDOY MILL SUPERFUND SITE
WINDHAM. MAINE
5„ rir
•U r,|,
, U(,Mri> f ,[
•»r.o,
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KM • RAGS te«e ? . SamME
Appendix B - Tables P a g e | 126
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TABLE G-20 (RME)
CALCULATION Of COPG CANCER RISKS AND MONCANCER HAZARDS - ADULT RESIDENT - AGGREGATE SOIL EXPOSURE
KEDOY MILL SUPERFUND SITE
WINDHAM. MAINE
Skeriarto nmefrtrw Fwtore
ReceWcr Populefwv Rfrsidert
Ajjf_ Ac'jII
Medium
Medium
h | t i.r. i u nS
Exposure
Route
PcrterniaiCoicam
fc^x.,
Can cm Ri«* Cateulafccn*
Nofv-Canccr Hazard Caicu^aborre
St&km
"! >¦ - r«-. 'v »¦1 i i uh>ii
CSPA
mt Rt-sk
Cancer
Risk
tnle ke.'F^pcsiirp Concenlralior;
MlMiC
a-otwl
nji.t
U:Wb
Vaice
i'Ml!
Valye
Units
v__
Ortfe
Soil
Aggregsts Sort
Airal
1>pje!fl«efe»2er»
„
„
MS^3
r f
NA
7 Depot Street
2,3.7 ,S-TCDD T£0
5.44E-35
_
-
-
- TC P»
i
*PFM
HI'
2-W«ihymaf:^thaiane
5: .b» "
HjAu
-
-w
-irr-
?!«.
I t
5 3?£ 01
. J*«
_
-
-
_
Lt Lt
mw-%
F,-
_
Pnr >or -e-ve
r~ it
H-1&3
_
~
ilF'1
_ir rt,
m^rr.^3
. I! ' -!
Beraoibifluoranttwric
S.51E-GT
.....
h1
Certrasoe
i
"» J*fl
-
_
F ,
pgSw'3
riA
-
MA
Difcerzsa t)enthra cere
U8&3I
r
-
-
rL 1 1
WB.^'3
_
fi-<
lnrenst
- -1: if
i iM
-
-
-
-
^ A
f *>
M*tiiyfcyclofc«can«
1.40E-Q2
TiV3
-
-
-
-
pgJtsm
f *
K-
Naphshatara
1.22E-01
Tl'll
lf-| «
K t*
i f I .
ii n j-
PCS- ftoocFt-lfte Congener TE
- -- -
i'ciki
_
_
-
_
J~
m F i J
rrat-'I
1 ¦ t
Tct« PCS*
2 03C'Q1
. 5* t
-
-
-
'"£<-2
r *
Aluminum
1.19E+D4
"T13-1-3
-
-
"E ¦
noEt >
Antimony
1 Hg-Hl<
rrfN.,
-
_
-
SH . 1
' r-
W
Araesyc
11
S 3i* ,
_
_
_
_
2ZL> •>
P&W3
' fE i 1
rarYj
\ i
Barium
t 74E-02
Till*-?
-
-
-
,i i
-I c ! .
'1 He- -
Cftdmium
i ii-a
"
-
_
J. ¦ '
ii jn • ,
Orcrnwi l«
7.33E+01
-
_
-
TF'
f.A
Oron-um VI
2.2FE+0O
j
«
-
u®n?^
t> in '
si ! r
CtiUA
S &8E»0ft
_
_
_
-
-
i L >»j>
' ilH
d an '
u r t
Copper
I.47E+02
T 4l.q
_
~
-
k.
H4f^3
f
t -
Cyanide
906-01
' At
1
iron
6 3l£*D<
• >a
-
-
_
-
¦'I ' 1
MS!An^3
? >-
f'l.ffl
L«d
" nPr-O
It Ihd
»
-
~
r>-
HA
Mangeneie
111E*02
i ,~ ?
-
-
-
-
>, • , -
u i i
n .VP .
0.001'
Mercury
2.02E+QG
TiH
-
-
-
Slf- ¦ 1
IF!
¦mgrt-r^S
2. If
Nickel
\ ^e--i
1 i'l. i
-
Ml 1 ¦>
|i. "7 "
'r, f i
i « H
Thallium
4 i I
i.jfc,
_
-
-
-
~
t "r,"
M^3
? A
t '
Vanadium
J--4E- 1!
1 JM
-
-
-
-
ti °
1 t 1
mg,iWft3
C00CO4?
Zinc
"i E« .
1 Ihl
...
......
f M'
1
M
f*a
;**taiion Tote!
Il
ۥ22
Total T Depc< Street
- 1 -
1
Note*
-ntake hickMles an assumed relate t»i»v.'k.(aiw!ify (RPIA) of *1%
BTfineering, toe.
KM • RAGS te«e ? . SamME
Appendix B - Tables P a g e | 127
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TABUS G-21 (RMS)
CALCULATION OF COPC CANCER RISKS AND NONCANCBt HAZARDS - AQBADJUSTEO RESIDENT - AGGREGATE SOIL EXPOSURE
KEDOY MILL SUPEBFUND SITE
WINDHAM, MAINE
5X V. 1 *\ ilh
N.jr ' ill'
f -'tl'Vl 1 <1
it M,
Route
Potential Concern
Va*je
Hn t
r. >. - ^
«l K't [ MHI
f m 1 '111 if I
w
mnr6
v i,u-
I it
Vatoe
Units
i Kh
-'
! I!1-
l> jIuc
1
l-l t "l.t
3o«t
tjl t 4=tkH *
7 Oepc* Street
Ingestion
1,3-Dicrvorctw;t:ene
3.70C-01
11 ?M
fru'
2.3 7.8-TCDD TEQ
' 4i
5 IK 1
•w»_
nX^C-oay
1.3E+0S
ir j'»i, Je /i
11 r i'
2-Methv»n3ptMh8lene
4-.256+0&
1 if ,
t u- j
WA
....
*i>
......
.......
Benzo(BHH)fttrBcene
o 97E--3I
1 SH.J
kS you
1 .r t h »>
4^ '1
.....
U . x-.l «• -
S S3? 01
1 >K
Mutagenic h
«, » «,T,
- I' Hi
Eterizofbifiuoranthene
.It: .J
1 lttl
Milt a ft "
1 < ~ >ar *u«i
1 '
C>,rba^fi-
11
• Jt-:
;«.r
-
'1A
....
....
Kb«pj®!«..h)8fil(hfacene
1.7S&01
* m
». Jou«nir
Ovtt VTii !J1
I 'fc !l
-
Irajene^l >:d»y-«n&
3 31c-01
< i+j
s-t 4-'|V|
11- I,
....
Met^c-^ior.exarw
1.40E-32
tjVo
" r=
rTiR.Tt«-ciay
Mi'.
N-a
Nep^'haler-e
-$.226-01
i 31-5
i . = T"
mg.'kg-day
MA
¦ • •: .7- •- -
T5V3
T.5
M, IV
1
- .i.U
ms*9-m
8.0&6S
tngAjHlay
? i
mrnit
_ i 'E+ 1
' *>i
^ v
™j/ko rtsy
1 5S*00
ii ,!*' j„,t"
J !L I-
t?4E*Q2
r*M
' ~ '
m*a-m
NA-
Cktmm
t.SSE+OO
i
l n
mo.'k^ilay
HA
'JA
0teomim HI
?SJE*01
ri ,* l
rtfe Ottij
f,~
-
J'
Cnrowum VI
227&m
1 3W
i( k ft* fl »t
r »r ii
Cobsar
« ik-,
! 1Z-
no vq-jSj,
WA
_
n..
Coppa
t.4?g +02
it jk;
„
nx^s-any
NA
Cyanide
7.90€«<31
i ik,
t «:
alcc .
l\!A
IfW
6311=404
. it (
1 r u
mc - r ^.
HA
iwl
2?4E+02
• J*'J
11 ~ «
mg.'kg-cSsy
fJA.
M»ns»ra?s»
5iie*o?
m ihiS
rv ir i- ^
Mercury
2 02EtOO
'A
£ ),
ng.'Kg-cSBY
MA
-
-
NicKel
1
> -'U
i - >«
ng.'V.g-flfty
m
Thaiitum
4.11E-01
lUkCJ
-1" s
B^k^day
NA
-
v/anedum
454E«01
< ifcq
B .&=:-«&
m<s-dsy
MA
HA
i t- i<
i iV
} 1 - i
>« ^<1 ,
•r.
NA
-
1 i Total
2 4E-D4
BTfineering, toe.
KM • RAGS te«e ? . SamiWE 6rt*2«1&
Appendix B - Tables
Page | 128
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TABUS G-21 (RMS)
CALCULATION OF COPC CANCER RISKS AND NONCANCBt HAZARDS - AQBADJUSTEO RESIDENT - AGGREGATE SOIL EXPOSURE
KEDOY MILL SUPEBFUND SITE
WINDHAM. MAINE
5
M f ,- > 1, »¦ , .'I IT
CSftUfl* R$sk
Cerwer
Risk
inlske^F>po5urf* Concentral'ar^
RCi^RfC
> H-
Urtfe
»• af - ~*
Ui.,h
WJ-.e-
Units
Valus
""" Umfe
0«ot«nt
Soil
Aggregsts Sod
7 Depot Street
Dermal
1,3-DicMorobeMene
2.3-?,8-TCOD Tgflt
2-Methylnaphthalene
3.70E-01
5.44E-OS
Hi lt< 1
>atuj
«
MA
1.3E+06
NA
(noAg-dBy)'*-1
m
u tl -il,
-it.
-
S.97E-01
t vk,
Mocfcoffetiort
1 t t
_
—
BwizoMipp-ew
L H z Jt
ril-t
bf ii it' Mode ct > t
1 -«q
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-
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CSber>ata.h)an8hrac«ne
1.?8£-Qt
i S^q
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Z vL-J-
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H
me^s^isy
IMA
I'
-
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PCS OtacM** CoRgwer T6
?.17£-04
t 5k.j
-r-H
tt0k*dfty
I
1 b >
_
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"
-
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Tefal P€m
2 03E-01
r> **
l 1 i-
wc/Kfrdiv
2.0E*00
~ E 1c
Alurrtmur"*
i >> 1
WA
If
.....
-
_
_
Antjfrony
5 5&E+01
rzlj
V
MA
-
fii
_
AtS»«
?
' »»i
f" '
msfcfrdsy
4 !5- 1!
-
Barium
i ;'4F»a?
r »1ui
\a
~~
M*
_
-
_
_
CecJnium
t 89E+Q0
?.$3E+01
i i*„
T
4)A
NA
WA
I
J*-
U
I
I
—
Chrom^m VI
227E+00
i :jiut
K' i' f ii "o " i*t •* 'i n
J
_
_
Cottt
saet'OO
i jM
V
J»
Cofiw
t 4TE+02
1 ik>
MA
-
-
_
Cy»r»icfc
?,90£-01
U.- '
mgfcg
tu* a
t J*..
f,*
KA
MA
NA,
-
J 6
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-
_
Mang»ne*e
< lij
NA
J
-
Mercury
2.&2E+00-
i m
HA
-
I
-
-
MftKei
1.36E-02
.1 1*4
m
-
I
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Thallium
4.H£-0t
1 uKq
m
-
-
-
.....
-
Vanadium
A54E+01
r 5^
m\
„
r
-
-
~
One
¦J* J
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TABLE G-21 (RMS)
CALCULATION OF COPC CANCER RISKS AND NONCANCER HAZARDS - AGE-ADJUSTED RESIDENT - AGGREGATE SOIL EXPOSURE
KEDOY MILL SUPERFUND SITE
WINDHAM, MAINE
nmefr#ne. future
Aga AoailAChilci
f Medium
rv i-ii ^
Kf,. e Voirrt
e
Chemical of
h
t ,
" V '1 i u
„
Ncr- C^ncor Hazard Calct-'ations
Route
PoUtrti*l Concern
( <
11 r r»
> k " , > . I U < 1 'Mil
i ,i* >, .
trrtske.'ExposiiiTe Conconlraliors
RfDJRfC
nazero
Qgot;ent
1
i 1 J*
i',! "
...fflir *¦;.
rw«h
1
Units
Value
Units
Soil
Aggregate Sod
Air ad
nhsteiior
1 .J-DtcKiorctKtfzene
3.70E-Q1
i x»l«g
i I 1
Mh
NA
-
7 Depot Street
2.3-7,8-TCOCTEQ
2-Meth^naphthal«n«
4 25E*00
»i*a
> a'M
- f " a,A
~-n
3 8E-0?
I\ A
ro.
...
—
Betvoteirilhracere
4 1
1 jk 1
*1 » .Ml
0 *€05
_
-
-
-
BcnzotA^ymw
5 r- '1
1
Mutagens ft,
r -<¦ nt a- '),«
1 7*" i
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B«!-iz«;bii!uofafJiene
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4 L J
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Kfa«aii8jh)BRthf80»e
t.'8£-01
! ak.i
t <
N » ,
1 !E-11
-
_
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3.81E-JJ1
i o-k i
Kg « # in
tooe of Afflim
,.r .
_
„
Mettycyelohwcan*
4.40E-02
T3>a
'i
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_
_
Naptehaiene
: e 1
i j'V-j
-*¦ u
3-.4S-0S
3 2£-08
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PCS Oloxi-i-ift® Ccrgerwr TE
7.1?E-0^
T lVr
i r- -
^ m '
3 SE+OI
iydnlf-'
5.0E-OG
-
-
-
"
TdW PC3s
2.0'3EJ01
I ikl
1 4E-.C
JC>c "
5.7E-04
78E-06
-
-
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Aluminum
! 1 jE*
-rskq
4>*= v
^ m !
NA
»
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' ,«&- 11
' ak J
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¦
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?17F»01
i ikn
. 3E-r
-ir*:
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3 SE-03
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Barium
I.74E-02
( «
,K^'
'HA
*th
-
-
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-
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Cftcniuw
1.69E«00
t
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't T)r"
((jg/miyM
1 2E 1 r
-
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.....
-
_
Cfcrcnv.jm Hi
7.33EtQ1
fl J+3
_ /£ ..
h-H/.
—
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~
—
_
-
_
Chremiism VI
2.27E+00
tjIq
Mutagenic f\
'OOt'-.'lTi
2.0€-08
_
Cobait
s.a-gE+oo
T J*i
1"" r
J. ft
3 4E-09
_
-
-
-
-
CopfKSf
i 4 l-T 1
i iKy
-tz-
a. i'
fcjfi
m
-
—
~
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—
Cyanide
- trz"!
rjk (
1 '
it.
fm
-
hA
_
_
-
-
Iron
S.31E^W
r iVq
ni, H
HA
-
HA
_
-
-
-
-
Le&d
_ nt*«:
vj'
( iky
1 ,k
*
_
( *
-
_
_
_
ifdiatelian T
m
1 3£-06
r i,rr.
3 >JE>04
_
Ar*r>ie ing««nori incudes an assumed relative tsoavwiawiity (R&A.icftKW.
KM - RAGS Te©le 7 - Soil-RME
Appendix B - Tables
Nobis Engineering, toe.
mmuw
P a «c I 130
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
Table G-22 (RW1E)
CALCULATION OF COPC CANCER RISKS AND NQNCANCER HAZARDS - COMMERCIAL/INDUSTRIAL WORKER - AGGREGATE SOIL EXPOSURE
KEDDY MILL SUPERFUND SITE
WINDHAM, MAINE
Ejerterio Timeframe: Fakir g
Receptor ^opulslion: Comry»rciel/;ndustri6l Worker
(Receptor Ago: Adult
1 Medium
Medium
Exposure Past
E c (rc.
P u«-e
v. he ih
f nt ficerrs
EPC
Canc« Risk Calculations
tJlf! '"ill
"Ha^ani "jl
flUf!
Value
Units
Intsfe'eSxposufe Concentration
GSF7 InF 1 b
i nnr-
" k
nt-V'l 4'. i fp'
in ari r-if >*
l-t
tic-nt
Value
Units
Value
Units
1 il.i"
Urncs
alti'
UhjIs
Sal
Aggregate So >
7 Depot Street
In qe r
1 i hh m-
3.70E-01
n. \q
1.0E-0?
mq huf t
r -
j#
• i
n (Qr* Li-lja^
J^
Nn
2,3.7 S-TCDD TEQ
at < 'i
f»**3
1.5E-11
mg.'kg-dsy
1 uCf
-raVa-dB,!
1 'I lb
t r 11
mq *q d ,
7.0E-1G
irng.'Vg-CBy)
VM 9 s i thi"n«
a 2&EHW
1.2E-08
mg.'Vg-dsy
UA.
_
N'
, ih
mq.'lsq-day
^.0E-03
imcAg-CBy-
b - an hr L»r
6.97E-01
rioVq
1.9E-07
mg/kg-day
1 -C-E-01
rraVo-da, i'
1 U=- iu
1= i
mq ^ q d ,
JM
ri.ft
Berwoiaipyren*
S.$SE-01
H'-fcfl
1JE-0?
mg/kg-dsy
1.0E+00
rsjVq-dB,i
t h i
4 1
mq »q d «
j he n
imgAg-CEry)
E>- 2 Diflu ran h re
6.51E-01
rn&Va
1.8E-07
mq'hqu i
ma* >da /i' "
1 uE iu
0 JE-1?
m ~ q d
NA
u-
rt rla
4t id
™jt»S
4.5E-08
mc Sigos
ISA
-
IA
mq q d",
...
UA
L hh z a nthr ne
"iiE<-1
iicVg
4.9E-00
--
i1
'i. Jc-iJu
1 1E- >-
mo "q J ,
MA
NA
1-dMn i1 up/ «ne
3.S1E-01
n^Vg
9.9E-S8
mq^Q if:.
I rEul
naVo-de.t'
'1 'f - iu
«' i=-1
mq > q d s
NA.
...
P vt * th " jni.
i }iEO
maAtj
3.9E-*35
nnjlqii't
i\A.
_
JA
p= iu
n q >q dif
NA
...
N phfh it-n«
t.22E-
"
Tjtl F 5
E"ji
=
rrql-q d
" i*
maV >ds,i'
1 IE-J5
I =E-iC
mq ¦ q d"1
. ¦
inc^o i a'
7
—J< r i u-r"
1 t.E'.4
mn,lo
3.3E-03
fii >
['¦•¦A
j &
UZE i.
ng«q ih
1 rc+.v-i
irp Ki t ,i
.
« 1 .
": --
mcAq
1.5E-05
mg/kg-dsy
h-A
_
fvji,
4 i E- iG
rnq t q d *
4 HE-OA
(rng/kg-dayj
.Arsenic
¦ E-
rri'jKq
3.6E-05
UM i /
1.SE+0C?
ir i I'V )
•S -E- 'b
1 OH-15
lug "J ii ¦?
nF n-
(mc/KQ-Oi'sy)
B urn
1 "lE-tv.
ron> q
4.8E-05
mymg-day
KA
-
JA
1 JE J1
rug »-g U -
.PE Hi
(mg^Kg-cSay)
"
~ IT!! m
t ~-E-' JH
4.8E-0T
rriQt'KQ day
K..»i
JA
1: e- m
irii] KH in,
1 ill i
fm^KQ^iay)
r m II
"•EtJt
m-">o
2.0E--05
rna.'Ha-osy
KA
JA
- E *
(ng n
i 11< v} y
rng.'KQ
S.0E-D1
frt "J"k ) fli yi
1E- '~
1 ~E in
lilQ *0 i!
HI i
in kp .»
Cobaii
S.SSE400
mc> B
Z.7&08
maftSHJw
F.A
- ,=-JU
mgi'u '1 ?
J.0E04
(m^Ag-cuy)
Copper
1.47E+02
in <>u
4 0E-O5
mg.'kg-(is.y
i\f\
llS
1 IE 14
nil) *Q ii
J HI i
Cyanide
7.90E-O1
m 4 b
i> I t
NA
I. 1E j"
nig Kg m.
~-lit i -1
ir \
I'v.ll
6 3"E*04
iiuiu
l-.;A
J'
4^ U
IllQ'",!] l1 ,
ill hi
1! I, lirin i
L «J
- "AE* '2
maVa
! 1
J^
-1 1- >4
mgn /
NA
P Ml Hie 1
5 1*E-*02
m Kij
imtQu-j
-
1 -i- 14
mq "g d
-i i
n hi i h.i
f "If E
: ^-E-f' 'fi
to v> a
¦
hA
J^
1 E in
rrg n i| (11,
!)[ 1 M
mi ki ,,i
N 1-
1 36E-*02
in i j
mo ltt3 e-,f
KA,
-
r n' a
II 1
ii Vi t ,,
Thaiiium
4 t E"!
hi > i
K/'.
J1"
„E
lilQ *a n
I III I!
"'-••J' ¦>
1 1 JDl
4.54E-*01
tn*U}
mq Vq--^
hA
-
Jft
1 S I'l
mqSq a ,
5.GE-G3
in )qi s,i
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
T«Me 8-22 (RUE?
CALCULATION OF CO PC CANCER RISKS AND NONCANCER HAZARDS - COMMStCIAUMDUSTItlAL WORKER - AOOWKSATK SOIL EXPOSURE
KEOOY MILL SUPERFUND SITE
WINDHAM. MAINE
Seeoano Timeframe: Future
Receptor PepulMiofi: €.Mmercial.ftaduslri&; Worker
-<*cepecr agb: ftefust
Medium
Medium
Esposyr® Pant
Exposure
R elite
Ch«erica) dt
PexeoMrf Concern
h
Cartes
'Jf ' . >1.'.,
v»li»
" ll
>1 1. >h>i^S . 1
CSWUint Risk
i fFi h
1,1
nlske/FxposufP ConcenJralian
RSWIC
Hazard
¦ r
itn ,
vaiu«
Units
Vafes
Units
«
U, ,
Sal
? HflC lift- < V
7 Depot -Street
Dwmai
1,3-Oichlcobenzene
... [
rnqJkq
h-A
NA
NA
„
NA
j-mmcdo tec
S.4A&SS-
in lJ
t 9E-15
mgftg-day
1
•
,•>
mc^chdfiy
7
2-i.tehytn^tha^r
4.25E+00
I Is' 1
6 3E-0?
rc k < i ,
ifji
1 "r Hi
IHI, MVJ t
-1 3E-03
0 00044
6.97601
i"*va
1 0E-07
mg/kg-tiay
i ~»r)V j ,i ,fi' "
1 i ii
f
r!Ht if i1 r
NA
Beric* a jpyrerve
5S3E-01
11 ^
1 8E-08
i ikj-dan
~ 1
1 ii'iHj,
if- M
irrg^g-day)
0 00082
Ber«*0)fiuor#r«hfrne
6.516-01
p» m
f e 1
mg/kg-day
' f '!
1 -iqn 1 '1 ,1 4
. v.
n
< ,
-
NA
c*rte»(e
V64E-01
'•JA
v,
hfc
NA
Bo*»*i.n)vtfhr»«j»e
m§.%
2 7E-08
mg/kg-day
* M-K 1
,-J<.
-5 -V
mm?."1 JsP
j^'
~
MA
in&enai ,2.3*ojipyrefw
3.61E-01
mg/te
5 *E-06
mg^kp-day
r
1 51 i
manq-dj,
r,A
— yCt^^CX 8D5-
iJ'Zi,
I .cfcc
\A
-
fvA
—
f<-
Napftlhsiso s
1 22E-01
ms/kg
E- '
m-3 J>q-r-« f
„
V
mo- u-dk.
2.QE-Q2
.1,1
1 1 "H TC~"
PCS DioKfvlike Congener TS
7 17E-M
mgfltg
.
»: -
.:»• 5
TT3l»a-di,i "
- ^
h r 1
ma-o-dE,
7.0E-1Q
i TQ^q-ca,'
11 i
Too; pom
2 0J£'01
i'U ^ J
3.3E-06
rrwka-oiiv
_ Ul*f
I Off J J?
h - F
' 1!
niu'o J£
: " ""
! >» ti >
-
mmmm
' ft if
n_ * .5
*
_
N/4
_
1 ,OE»CO
itq'ltq-CI '
Antimony
S S3F«01
n M
r 4 Kl! • i l
r,«
emm
&.8SE+00
n-* j
' '
NA
3.0&DW
lijKji .i
HA
Copper
f4?E*02
rrh
r v
NA
.....
A 0E-02
1 T l, k 1 • 1,1
C'ywloc
7 90E-01
r i * «
¦\a,
A
U*
NA
-
S.&&SM
in)KP. .
iron
'V E- H
m- ,
r.i a.
m
HA
-
7 0E-01
I < .j'T-v, ¦ i,t
Lewd
2 74E+02
Mil!
\,A
-
M
HA
-
NA
Mensanese
5\*E*Q2
1 1\ ^ 11
r a
m
HA
&6E-W
O'.ki ^ i
fi >
Meicwry
2OSE«00
. X* ,
KA
-
NA
_
2.1 &0S
I i VM ' «• 1
r>
taM
t 35E-»02
109*9
\A
N.A
-
NA
NA
e.a&w
i i ii kij c »,!
ti
Thallium
4.11£41
" M
r-, a
m
NA
-
1 DP-1>5
1 S •' fcl1 1 "* 1
ti \
tfanafl-um
'1
> O i
f A
.....
m
NA
-
1
1 ' ^ 1 U 1 , 1
-,«r»r
rosfa
-
m
NA
'
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
T«Me 8-22 (RUE?
CALCULATION OF CO PC CANCER RISKS AND NONCANCER HAZARDS - COMMStCIAUMDUSTItlAL WORKER - AOOWKSATK SOIL EXPOSURE
KEOOY MILL SUPERFUND SITE
WtNDHAM. MAINE
Seeoano Timeframe: Future
Receptor PepulMiofi: €.Mmercial.ftaduslri&; Worker
-<*cepecr agb: ftefust
Medium
Medium
Esposyr® Pant
Exposure
R elite
Ch«erica) dt
PexeoMrf Concern
h
C„„
Ri
I'tli
'card CatafeiaBws
Vslue
" il
>1 1. >h>i^S . 1
.i-1
, Nhh
i r>ri »¦
nlske/Fxposufp ConcenJralian
RSWIC
Hazard
Ojotient
Ufi ,
. ii 'i
Unit^
il t
Ml
Vnl.!«
0^5
Sal
Aggregate Soil
"r 1
fcnhalatiori
1.3-Dichio'cOtnzenc
,C,M
f r ' 1
• «
n«
- 1 >
! "
UA
I i- > t irt"-
2.3.? 5-TCDO TEG
s4<»e-06
fn > ¦;
2.IE-OS
3 8E*-0t
'
»F »'
' . F i
J 1
4.0E-06
f> -V'- 'H "
S0-* H.
n, - j
$Atm
NA
Nw
1 -r .
W,
fiM
BertfataWtfhracerre
«3»e-ot
. |
1 2E-05
m^
6.0E-05
jq r . -1
<1 u
•2L>i
.J,
ii'
Benzo^pyrene
5.93E-01
n-M
* ^
hit
t >C( J
2'h .
1 jb >i"
^0.W'3
ib »
i.^iM (
Beri-3«o.iflu«af>lhcric
6 51E-01
S IE-OS
'Q'U , k 1
I
i »
MS#n*3
MA
Ctfeuore
i 3E-03
NA
Nrt
^ hf i
PS^'3
¦"J A
TO.
Obenio n)an{hrace-»6
1 78E-01
mglkg
1-«E-09
y0m^
IE r»
a^i ¦ 1
4E
¦* >E |
vr>
NA
ioaenwi 2.3<4W«?ie
- ~ r r t
M * I
2 8E-0S
umK'i
S..0E-O5
jgfiiJ -
1 L- .
»ith
ysyfrvs
NA
t,»
Mstrv/cycian** sne
1 40E-C-2
miV:;
1 1E-1G
ayfrri^
feA
-
h-
"'E"
J, T*
ht«
Naphlhaiene
V22E-01
« 3
+- >4
umr^
3 *E 05
" " t
»• -| i 4
vJ
3 oe 03
^ 11
PCS Dioxifviike Conjjarwr IE
7.1TE-04
2 7E-68
2
3 8E«-G f
jq'rrj
1 >Ei b
nRCi
4.0E-l)S
c.jc
Total PCBs
2 03D01
fn ' j
2.8E-03
I-.I'J'IM
5.7E-04
j " t
1 "E iM.
' E i,_
g-Jr "•
NA
Alurmuim
i-SE+04
ric^a
.« E •-
NA
n
Tf- "1
5iJE-0Q
..
Anliricny
->-E» n
4 &mi
iJ&rrt'-Z
K-A
N ^
1 *
in r "
NA
NA
1 « i!
mgAg
1 7E-07
pigftnA2>
5 :e- i:
jq"Tj
-4r "
>1 E > "
vi..'"'-' ¦¦¦•
1 5E-05
Barium
! "4E- >;
H tq
1 4E-06
f.A
< ti "
5.0E-SM
"
Ciamijm
T69E*0G
I'K^U
1 3fc-08
iij j - ¦»
„ IE 11
J Mu
11JBXJS
Chromium HI
. -J > IS
mgAg
5 8E-07
ugAnA3
NA
II -
• ?F i<
ugftw*3
HA
MA
Cnrcrnium VI
227E+00
mgM9
1 ae-os
4WS
1
i./n . *
1 'b ' '«
•> rt .p
t 0C-CM
. , i 'i i 1 n
Cotm*
9&SEV3C
M Mf
7 SE-08
ygrtn"3
&.OE-03
JQT -i
~ C ii
.d1 1
J- r
6 0E-06
Copper
M7E+02
n-1 a
1 2E-06
NA
t^
i i(_ „
jjgAt^S
NA
Cyanic*
7.S0E-O1
i . >y
1 if m
h'\
N
' ! 1 >
jigW^S
8 r>F-fM
. .i
inn
6.3 tE *M
P \i\
5 OE-04
u&m'-z
f.A
M
' Af
Lead
""!F» L
rn^fkg
2.2E-0&
!\ A,
' 1L i'
jl r "
HA
!mi
Wferi<}«r>e%e
$,'l*E*-02
|i b|
4 0E-O6
r,-.A
n*.
•il- •
50-E-0S
i Nt lU
Mercury
2ME'*m
r. Va
4 3E-03
r,A
rn.
1- >
P9.*r»*3
3 0E (M
i' .i
N-cktf
1,33E*02
><» *<
1 mm
u&'m'-l
' H '14
ufn '
"F i'
, I ..
sog-«
Thallium
4 11 f--01
" 1 I
3 2E-0S
iip'm'2
h A
fife
' E
M5^
f»
Var-atlum
¦ S4E" i!
3.§&t>?
umA3
!V.A
If-,
:<[ <
1 ,0E-i>5
. Hi j
rrr»q
5 6E OS
.
IV A
' i F | *•
r*ai-3»ion Total
- IS".
1 -
lores 7 Oepel Stfeel
5 9E4J5
•>
.Af-^.s^'igssfWiunteha include', an assumed reiative bt
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
Table G-23 {RME)
CALCULATION OF COPC CANCER RISKS AND NONCAI^ER HAZARDS - CONSTRUCTION/EXCAVATION WORKER - AGGREGATE SOIL EXPOSURE
KEDOY IVSLL SUPERFUND SITE
WINDHAM. MAINE
Scenario Timeframe; fuMr*
rpcr r-ipi iMnn: CoV>
lh
~ia"' >3! j*
a-rEl
Benioia.ianihraeere
6.97E-C1
mgAg
- . <•
1 0£-i f 'Y
i oe-01
J Ml >! /«¦"
r r~
q rz-n-
11 ! 1W
MA
*JA
€®fa azote
t, i: 1
- p -
nybg-day
MA
'}k
. pAg-day
U-
Dtberute.ftarifirBcene
1 76E-C1
mgA-g
MgiVg day
i
' T "
M 1 It r
'in
"Jh
lndenoi'1 2..3-cd!pvr#r>p
3.61E-C1
ma,h3
ill.
1 4.t»i3 it,, ,1 1
~ tE i'
"I 1^4 1 ' t
MA
' * € T
mg.'Xg
frvgftg-day
m
: ie .r
' J
?.IA
-I*
NaohSha cnc
1.22E-0!
frq si
>. i E ->
~nF gc' ,
m
1 *U- r
frvO'ko-dsy
2.'>E-02
cm^ff-4ay)
PCB D owr>4iKe C»s»er TE.
7.17E-04
f !M
jsp/kg-Oay
1 3E*ft5
; L'»
1 1L
p>g&§~dfiy
¦» 1»
Cmg.^g "
<~a'sq aa,
f -
-
U'
c[ IK
fnijfVi 9-day
-'EM
(mg/Hg-day;
, .
I I
1 S&MO
< I'l
" ~1
•^G'*Q dj,
MA
„
')
1,1,
-"Q 0-div
1 OE-03
(mgAo-d«y5
| r ruin II
f.JM
X
™r,< o fW
btf\
1 1- <>
-ia"'D ik,
1.5E+-G0
rcl-o -'t,
! i nun n
237E*«J
•UfJ
4 ~
S.ClE-01
> vi d,"%,i
, ' llr,
3.SE-Cf3.
n-'T-q ~ .
\1 \
' .
S 86E+00
InJ * 1
1 "
1 ¦ it
MA
'1"
1 1- II !
Mr 4 I',
¦"C r
¦ n .
! "
1 47H*m
0 j*»j
•> S~
c
N'\
I*"
' 1 1
rr»g*<$-day
4.0E-C2
(mgikg-deyj
' I
j-,31133
7.9GE-C1
ma s j
r"
Ni'"\
1 _L nt.
mgfcg-iiisy
. ? i
(moiVy«d»y}
• > t •!
1 Si * 1
u,
mfs&g-dey
MA,
•lh
»[ U„
ill' S 1 ,
. ' t u
(m^Q-ciey)
'
]Lf
2-74E*02
»-3
i,' t ,
MA
'Ja
IE 'Ik
Ml M 1 *,
•f
j j L i.
rq
IS. ,
mg&f-day
NA
jii
rI 1
sr^p-day
2.4E-02
(m^V^KtBy)
. ¦*
jK'- - r,
2 02E*D0
rnt f 3
' -
ij'* n "•«
UA
'JA
i: ,11,
(>}'« )H-.
ru*j
i na
NA
i r ii »
u 1 t* 1
(mg,%o-day5
»1 I
4 tlE-Ct
i.au
. .H
W nji,
N'<\
i r£ ir
w^gflcfiNday
1' r i
IKVtJ
?--J
j rn il»ir
•» 1 !P - <1
mi» I
< _•
mfliVg-tlay
NA
N-
h I"
'0'3d\
5.0E-C3
{m9»V8-
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
Table G-23 {RME)
CALCULATION OF COPC CANCER RISKS AND NONCAI^ER HAZARDS - CONSTRUCTION/EXCAVATION WORKER - AGGREGATE SOIL EXPOSURE
KEDOY IVSLL SUPERFUND SITE
WINDHAM. MAINE
Scenario Timeframe; fuMr*
rpcr r-ipi iMnn: Co
If ak^L'^u^iJ f
-*•" r-r rdh -
RfCXRC
k^a'd
value
U*«»
v«iue
Uir
"!|U'
i'i'it
J 1st-
1 n> :
Seal
Aggregate Soil
7 Depal Street
Qarmst
wa
UA
(j.*
1,^
NA
IA
2.3.?,e-TCOO TEQ
S.ME-05
mgfrg
4.3E-M
< '
1.SE+35
" tlk J tj<> /! 1
- j
¦ b M
(m9%8-d8V)
j» i I
2-Meltiyi'WiS*vih aiene
* 25C«00
msflcg
1.5E-C45
. Vt.H,
NA
11 tll
>0"!^
^ • i ,
Benzora'.anthracere
6 975-01
rrig.d t
Ben2o;aipyrene
S93G-C1
>mMg
2.0E-O9
if '<<3 tia
1 0E*CJ0
• >i:. -
1 w II
>' ¦> '-s
. L i -
!'! H
Benaojfatfluorarifhene
6 S1E-0I
mgMg
2.2E-09
-o'?nsjr
1.C&01
-n-a "i
e i'
11 * ii
-laNad^,
NA
Ca--t>azoi©
1.ME-G1
mg/kg
MA
MA
r, *
"J *
1",
DfcsrufcJDarftracene
t 76E^t
mgMg
S.1E-10
! € in
-
K »b ''
t ii
n^^-day
N-
....
a-
lndenoi'1,2,3-cii')pyrBf3®
3.S1E-OI
mg*y
i,S£^9
V* » i.
10^-01
' lj M| i)nlv
» .b 1'
"E 'i
w.
htethylcyc'ofcaxans
1 40E-C2
mgMg
NA
-
MA.
—
fcja
MA
w,
Naphthalene
1.22E-01
mg/kg
4.2S-10
•nflfcgday
WA
'I'
-E i
«'«3^fc!ay
".hi1
i k »ir
PCB D cKir.-Skc Congener TEO
7.17E-C4
mgAg
5.7E-IS
r>g,Vg-day
1 IE*05
~ 4E r
i E 1 i
r*g.4}» j
mgAg
?.5E-oa
>iA
mg^s-day
2M* 00
" if»1- 1a i" i
t ' h i ~
H
r»
l
i r i'i
t OE*-00
*mg/1«g-£tey)
r -Vn
1
1 1(1 1 X!
S-4- '1
i"
( .J.V 3
1.*E-OS
mg-Vg-day
i 11
1' i 1j/
' h i
1 - n
iu' >i i
.pi
(mgAg-dey)
. . j,
j( Hfl 11*1
t U • '
1
NA
-
-
'JA
NA.
i t i 1
(mgMtyMft
! sdi" iun
! L j! «
n^a
4,5E-ti
rig^g-clay
3.1E-C9
IIs J u~f
. F i .
(rng'Ve-diyj
r * n
! t mm ll
?35E-01
"1* i
*A
_
NA
CiA.
1 i |- 1
1 t -Iffll. A
!
TT K
, , -1 <
rti^i i
r > i f 4
KA
NA
_
% j * >-du, r 1
NA
NA
HA
HA
rb I j
fi: T
Coopw
1 41 - >
I-1A1
m
_
NA
HA
-
- Ei2
>n 1>q to,
1 ,HP1
? me-ci
I'M.* j
MA
-
NA
MA
-
L !
r .1 3 321
U
in..
6 3?E>04
fll J.f 1
MA
-
m
MA
, > Li
11 '"d e >
•i\
!i< >1
??4S*OS
HUM
m
„
MA
_
m
MA
N-J
1 ig ir i
1 t~ i
" !•* i
m
MA,
m
HA
«
11 C i -
(m»Ka~^y5
i' \
r. .
i 'hw t1
1 '}•' 1
NA
-
HA
-
NA
NA
; ic i .
(m&.V9-day;
Hnk
»j.b-V
rrtgftg
m
HA
NA
HA
t r T4
irti^Va-^nyj
The'lium
1 1 V
n,j,* |
NA
NA
-
MA
HA
-
""EM
n Vo i,
unaaur
f IE- '1
- r*r
nvj.*:}
m i,» i
KA
MA
.....
NA
NA
HA
NA
h4A
NA
1 F I
. P r
¦;fn^«sfey)
1A
Dermal Test
df
2.6E-0?
Itohis BTfineering, toe.
KM • RAGS te«e ? • SamME 6rt*2«1&
Appendix B - Tables
Page | 135
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
Table G-23 {RME)
CALCULATION OF COPC CANCER RISKS AND NONCAI^ER HAZARDS - CONSTRUCTION/EXCAVATION WORKER - AGGREGATE SOIL EXPOSURE
KEDOY IVSLL SUPERFUND SITE
WINDHAM. MAINE
Scenario Timeframe; fuMr*
Rccep*or Population: Corwlm«io?il>Excavatta Wads.Br
fo8p:a Age: Muk
Medium
Exposure Medium
Expire Pant
Exposure
Route
OWfftlCsl Cf
Pcrtwital Concern
'..an;
H < Mj| ijli , ,
Ncn-Cance
HazErd Cel&i
dBtions
V8iu«
in >»
3H* L pi 1. S.
onc*ntr3fion
. -1 n i Fufr
(ir'C
Ir ikPlL'y.H/1'J f
¦v rr rdh -
Rf£>RC
1 V2"1
L in' r
Value
»)\N
v«iue
'ii-
"!|U'
, 1
units
Sol)
Soft
Air it
inhaielson
1 ^Otch!orot)«a?e:h«Sene
425£*00
!'¦ Ji" J
1
'L* t 1 '
NA
'J-
M Ii 1
\&
Benzofatapthracsne
6 9?e-C5
m ir
8.0S-05
U '111 1
fi E 1
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-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TABLE G-24 (RME)
CALCULATTON OFCOPC CANCER RISKS AND NONCANCER HAZARDS - CHILD RECREATIONAL AMBLER - FISH EXPOSURE
KEDDY MILL SUPERFUND SITE
WMDHAM, MAINE
M 1 II I III i!
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Nobis Enoii-eann
KM - RAGS Table 1 - Fish-^ME ift/s;
Appendix B - Tables
Page | 137
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TABLE G-25 (RME)
CALCULATION OF COPC CANCER RISKS AND NQNCANCER HAZARDS - ADULT RECREATKJNAL ANQLER . FISH EXPOSURE
KEDDY MILL SUPERFUND SITE
WINDHAM, IMME
-.1 I i il f r 1
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Nobis Enoii-eann
KM - RAGS Table 1 - Fish-^ME ift/s;
Appendix B - Tables P a g e | 138
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TABLE G-28 (RME)
CALCULATION OF COPC CANCER BISKS AMD NONCAHCER HAZARDS - LIFETIME RECREATIONAL AMBLER • PISH EXPOSURE
KEDDY MILL SUPERFUND SITE
WNOttAM, MAINE
-n i i In >
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Nobis Enois-eann
KM - RAGS Table 1 - Fish-^ME ift/s;
Appendix B - Tables
Page | 139
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TABLE G-2? (RME)
CALCULATION OF CHCMfCAL CANCER RISKS AMU NON-CANCER HAZARDS - CHILD RESIDENT • GROUNDWATER AS TAP WATER EXPOSURE
KEDDY MILL SUPERFUND SITE
WINOHAM, MAINE
•urn lift r in II
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No:
m - RAGS Table ? - C3W-RME
Appendix B - Tables P a g e | 140
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TABLE G-2? (RME)
CALCULATION OF CHCMfCAL CANCER RISKS AMU NON-CANCER HAZARDS - CHILD RESIDENT • GROUNDWATER AS TAP WATER EXPOSURE
KEDDY MILL SUPERFUND SITE
WINOHAM, MAINE
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No:
m - RAGS Table ? - C3W-RME
Appendix B - Tables
P a g e | 141
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TABLE G-2? (RME)
CALCULATION OF CHEMCAL CANCER RISKS AND MON-CANCER HAZARDS - CHILD RESIDENT ¦ UROUNDWATCR « TOP WATER EXPOSURE
KEDDY MILL SUPERFUND SITE
WINDHAM. MANE
•urn lift r in II
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5 Table ? - C3W-RME
Appendix B - Tables
P a g c | 142
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TABLE G-28 (RME)
CALCULATION OP CHEMICAL CANCER RISKS AMD NON-CANCER HAZARDS • ADULT RESIDENT - GROUNDWATER AS TAP WATER EXPOSURE
KEDDY MILL SUPERFUND SITE
WINDHAM, MAINS
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rgtat PC Bs
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; II.;
sjg/L
:
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:
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1 II II
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—
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3 OE-03
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1 ii "i i i
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2 9 3-E ~ Q 0
2 97E*00
-
-
-
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8 8fc-05
8 9E-05
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s.oE-m
mg-f^g-day
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iron
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yg.1
I
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4 4E-0*
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e- oe-o~
7 0E-04
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—
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2 4E-02
1 1
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i
7 i
T Diet ~ap w
mr
......
7.1
5 Table ? - (SW-RME
Appendix B - Tables
P a g e | 143
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TABLE G-28 (RME)
CALCULATION OP CHEMICAL CANCER RISKS AMD NON-CANCER HAZARDS • ADULT RESIDENT - GROUNDWATER AS TAP WATER EXPOSURE
KEDDY MILL SUPERFUND SITE
=========_11111_ WINDHAM, MAINS
Ill ~l i'i*h j i i- F ill
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i) 00078
No:
m - RAGS Table ? - C3W-RME
Appendix B - Tables
P a g e | 144
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TABLE G-28 (RME)
CALCULATION OP CHEMICAL CANCER RISKS AMD NON-CANCER HAZARDS • ADULT RESIDENT - GROUNDWATER AS TAP WATER EXPOSURE
KEDDY MILL SUPERFUND SITE
=========_11111_ WINDHAM, MAINS
Ill ~l i'i*h j i i- F ill
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-
29
5 Table ? - C3W-RME
Appendix B - Tables
P a g c | 145
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TABLE G-29 (RME)
CALCULATION OP CHEMICAL CAKCER RISKS ABO NON-CANCER HAZARDS - ABE-ADJUSTED RESIDENT • OROUNOWATER EXPOSURE
KEDDY MILL SUPBRFUNO SITE
WINDHAM, MAINE
llnll i
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5 Table ? - C3W-RME
Appendix B - Tables
Page | 146
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TABLE G-29 (RME)
CALCULATION OP CHEMICAL CAKCER RISKS ABO NON-CANCER HAZARDS • ABE-ADJUSTED RESIDENT • OROUNOWATER EXPOSURE
KEDDY MILL SUPERFUND SITE
WINDHAM. MAINE
111! 1 I I l|'
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r
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No:
m - RAGS Table ? - C3W-RME
Appendix B - Tables P a g e | 147
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TABLE G-29 (RME)
CALCULATION OP CHEMICAL CAKCER RISKS ABO NON-CANCER HAZARDS • ABE-ADJUSTED RESIDENT • OROUNOWATER EXPOSURE
KEDDY MILL SUPERFUND SITE
WINDHAM. MAINE
r i >1i ii
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5 Table ? - C3W-RME
Appendix B - Tables P a g e | 148
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
TABLE <3-30 fRME)
CALCULATION OF CHEMICAL CANCER RISKS AND NON-CANCER HAZARDS - CONSTRUCTION/EXCAVATION WORKER • 6 ROUND WATER AND TRENCH AIR EXPOSURE
KEDDY MILL SUPERFUND SITE
WINDHAM. MAINE
I'll
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p .. r.< __ _ i|
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value
Urnf:=
CSF/Urif Risk
im2«feirip^sUE»-
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'Value
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Value
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5 20E-03
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rng/kg-'day
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1,40E+00
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idwater k--at
L
Page 1
Appendix B - Tables
Page | 149
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
Table G-31
Refined Chemicals of Potential Ecological Concern
Koddy Mill Superfund Site
Windham, Maine
Page 1 of 2
Anafyte
Terrestrial (soil}
Aquatic
Target Reach
lower Reach
Direct Contact
BR
Food Chain Modeling
Direct Contact
BR
Food Chain Modeiinq
DC 1 FCM
SW I SO
SW | 3D | Fish
SW [ 3D
SW 1 SD 1 Fish
VOCs
Acetone
1
Benzaldehyde
V
Cdfbori
SVOCs
Bi*(2-eth)Hhe\yl >phthalate
V
CaproEactam
Dibenzufurrn
s
Di N-Butyljihthaiate
\
V
isoph'Tfore
V
PAHs
Low (ViOfecufar p4Hs
J-Methviuaphthaiene
T
Ar^naphthen*
i
Acenaphthyiene
V
Anthracene
\
Caria azote
\
Fluomf-hene
\
Fluorene
N
Naphthalene
N
Phenanthrtrrtfc
Htqh Molecular Wetqfrf PAHs
Denzc" 3 )anthiaeene
V
Benzcnajpyrene
X
Bh". i*wb)fluoMr;Uit-nftsh)
"V
2 3,7 8-TCDDTEQ.mammal1
V
N
Pesticides
4 4-DDT
V
DDT and MPtaboM^s
4
Aldrm
V
<
aipha-BHC
<
delta-RHC
V
bieidnn
*
Endosulfan Sulfate
Enarin
V
Endnn Aldehyde
V
Appendix B - Tables
P a g e | 150
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
Table G-31
Refined Chemicals of Potential Ecological Concern
Koddy Mill Superfund Site
Windham, Maine
Pag# 2 of 2
Analyte
Tarrestrial (soil!
Aquatic
Target Reach
lower Reach
Direct Contact
BR
Food Chain Modeling
Direct Contact
BR
Food Chain Modeling
DC
FCM I SW
SD
SW
SD
SW
SD
SW
SD
Fish
Eridrin Ketone
3 1
Heptachior
Heptachter Epoxide
V
|
trans-Chiordane
V
\ |
PCBs
___ | - | ; I V | ^ | V 1 V I V I ; 1 | | | | |
PCBs - Dioxin/Furan TEQs
PCB Dloxin-like Congener TEQ (bird)
V
V
V
\f
v
PCB Dioxin-like Congener TEQ {fish)
V
v1
PCB DicSin-ISe C'Saaier TEQ '(mammal}
V
\
¦v
V
v
V
V
Inorganics
Aluminum
V
V
V '
V
V
V
V
s'
'¥
Antlmor
V
\
Arsiriic
Barium
Cadmium
r
Chromium
V
Cobalt
Cooper
V
V
V
V
V
V
Cyanirif
i
Lead
V
%
V
i
fvlantjan^^e
V
V
\
Metfiii*
y
Nickel
V
V
h'ilfNiium
V
Thallium
V
7
s
Varwrfium
Zinc
V
V
\
;
i
V
BR = Bnd\ o*;ioue
DC = Dnod conta.t,
SD = Sedith^ni
= Surfsf Aat«*,
Appendix B - Tables
Page | 151
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
Table G M
Summary of Ecological Risk Assessment Refined Screening Evaluation
Keddy Mill Superfund Site
Windham, Maine
Exposure Area
Receptor
Assessment Endpoint
Measure of Effect
Terrestrial Plarfs
Support of a functioning plant
community
HQ5 baser an COT EC so*' concentration companion w ith
literati re baseu phytotovicrty values
Soil Invertebrates
Support of a functioning soil
invertebrate community
HQs baser on COPEC soil concentration comparison with
literati re-basec effect valies
Mill Complex
Property
Invert ivorous Birds
Support of a functioning invertivorous
bird community
HQs based on dietary intake of COPECs by the American robin
usinp site-specif ic soil ana earthworm concentrations
comparer with literature-baser effect valuer
Invertivorous Mammals
Support of a functioning invertivorous
mammal community
1 ids baser' on dietary intake of COPEls by the short tailec
shrew using site specific soil arc earthworm concentrations
comparer with liteiatuie baser effect voltes
Aquatic Lommi r sty
(including fish)1
Support of a functioning aquatic
community
HQs based on CGPEC surface water concentration comparison
with literati, re-based ac i.atic toxioty values
Herptile Lonmnirrty"
Support of a functioning herptile
community
HQs basee on COPEC surface watni concentration comparison
with literature based herptile toxicity values.
Beirthr. Invertebrate
Community
Support ot i functioning benthic
invertebrate community
HQs based on COPEC sediment corro.ntratior comparison with
literature based bemhic invertebrate toxicity values
Presuropscot River
(Target Reach and
Lower Reach)
Fish
Support of a functioringfish
community
HQs based on COPEC fish tissue concentration comparison
wirh literature-based fish tissue toxicity values
Piscivorous Birds
Support of a functioning piscivorous
bird community
HQs based on dietary intake of COPECs by the kingfisher using
site-specific semment, surface water, and fish concentrations
compares with literature-baser effect values
Piscivorous Mammals
Support of o functioning piscivorous
momma! community
HQ'; baseo on dietary intake of COPECs by the mink using site
specificsecnmcnt, surface water, arc fish concentrations
comparee with literature baser, effect values
Motes
{I* - No COPECs identified in the Lower Rp-tr c dtnn was not completed.
Appendix B - Tables
Page 1 of 1
Page | 152
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
Table K-1"1
Comparative Analysts Summary
Keddy Mill Superfund Site?
Windham, Masm®
Threshold Criteria
Balancing Criteria
Protection of
Human Health
&
Environment
Compliance
with ARARs
Long-Term
Effectiveness
Reduction
through
Treatment
Short-Term
Effectiveness
Implement-
ator Hty
Cost
Capital | O&M. UTM&FYR* [ Total NPV
Soil Alternatives.
50-1
Nu Aufiuri
n
n
n
o J n
SO
$0
SO
CO-*.
EvzdVatmn Off-Site Disposal On-Ste
Cuin'h'Jdiun Capping and k>
¦
¦
• •
•
»•
§•
$9 71^000
$1.087,000
$10 BO3.Q0CI
so->
Evca\ ahnn and Off-Site Disposal
N
¦
• ••
*
•••
••
1 13 00c
to
S14 113,one
Groundwater Alternatives
GVV-1
Nd Actmn
a
Q
a
o
a
SO
$0
JO
GW-2
Monrtcrod Natural Attenuate i'MN'Y'
and ICs
»
•
• •
a
••
S&i 770
JtOO M
5714,000
GW-3
In-Situ Treatment. Basdine and Post-
Treatment Monitoring and ICs
m
m
• ••
•
••
St 5^3,000
S2 035-000
Sediment Alternatives
NoAdmn
a
Q
B
a
a
SO
SO
SO
f Ip-fiannl E j a^tm On-t tp
Ccn i iidilun ai?rf \>~ -
m
m
• •
•
#• »«
5627 000
$10? O'O
S735 000
tED "B
f lp-hanir'3 E*ra -=){< n and o»f filt
Cm -pi s\
•
i
• ••
•
*•
S769 000
Ia1 ODD
sseaooo
Page | 153
Falls threshold and/or balancing criterion
Meets threshold and/or balancing criterion
Appendix B - Tables
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
Table L-l
Cleanup Levels
Redely FvIrM Super ruind >=s r
vV indium, fc/kilno
CortfanufVJPt
I Selected PRG
Br'^S.'S
Soil
Bf;rizo(a|pyrene
I 1,1 rng/kg
ilcr =
Di berizfa, lijanth racene
| 1,1 mg/kg
ItCR s 10',Ki
2,3,7,8-TCDOTEQ
1 0,000048 mg/kg
ILCR = 10,:'ra
Total PCBs
1 mg/kg
EPA Guidance (Human Health!1'
j 1-8 mg/kg
EqP-derived (Ecological]
Aritiimony
1 31 mg/kg
Hi 1
Arsenic
| 18 mg/kg
BTV (Human Heaithj
I 68 nig/kg
Toxicitf-based {Ecological}
Iror
I.. . , .. _
i-i - !
(iroirmfWfrtinr
i,4»Kctiloraberuene
I 75MB/L
MCL
Chloroform
J toU he/l
MCL
Trichloroethene
5 Hg/L
MCL
Vinyl chloride
I 2 PS/l
MCL
8enzo(a}pyrene
1 0,2 |ig/L
MCL
Bis(2-ethvlhexvl)phthalate
J 6 |ig/L
MCL
2-MethyInaphthalene
36 n&*L
HI -1
Naphthalene p!
j .2,75 ng/l
!LCR ~ 10'S
Perilachlorophenol
1 Hg/l
MCL
Dioxin TED
0.00003 jlg/L
MCL
T.
I o S n, /L
Ml L
finfnir
J io Mg/L
MCL
Cy*
| 200 ne/L
HI - i
1 14,000 wg/L
HI = 1
vi .mhh"'1
j,. « J:.f| f.1->
SffJiiuent
: ¦ -.mi/k-
r;
Fish 7'ivsiie'''
i i>t,a i r uo.i
] 0,125 mg/kg WW
ILCR - 10"
Nk>tes:
,1 than p ic-,ti b irr scfiocts CF rmrsrcuv rt nccniur tu attain bitom c cf van a* iitc rni,tftK
* n tot, !>• f] i m -_r!*mtfhn vm i.iT»or ».*it+ feasibility v-mU i pimA • oooI, ,i*
p, 5 Jf ('l Lv or " to I i< r' on uit •'< TrOtIS It M pt ft"! T> NTf Itll f \ B 1 u"'ft'trlif.111 )I
U ^ C! * h hlintuir No ^ S11. «i t *• h»-t t 'iiif iMMn
!' >-»igi pi m8 -*Um unt^ivnar t tf it p j,ps isi to cor^iii itiu *rur»-r tAppsi r>- to ts~"Tb ¦'uu 11 ^ =»tvr and trench vapors
14) U ^ i tinhn^vwit' ¦ f ".ilth ddvts> », t,ii mit £.iiu» itP i PJ* fi ,<4 UU 1 Jt ut * J0u4l
?si--sh >k *',^11^ i'nv ",p-ntu 4
Dicier TEQ 2 - "*,? totsnd Imcx 'bt'.To p diw - i2 1," £ "TCODi Tiwierty £t > nt
£k F En itib u in f iiliti[;i-1r s «. ». n
Hi - Hazard Index
I ICR Iruonp Mt.il Lit tin • ^ir.i1 Ri L
Mi L Mci>imiim i onfj'fl -irt »» !d t il F ninny Di hiM >r, uVJtfM Rcii Mfoi -,
i <*'!. OEM lit' I
II ,vM iiiilh(*i om» pu I
iPlVkt*' inillir.n'ii1" u^i I'lui ifTi wcir/t wci^rt
iXP. flnl\,shlm injtnJ b ph -
'„.ii.rtitL lipjuit hLdior S» |'»',+ r> Di.i'iur fP'-. Fivninr 4 Or^irat]v i< bli I c. NKiiin^i t!int->
or^ Is^t iipchtcd Mjich I
TEu Toxintv Equivalent
Appendix B - Tables
Page | 154
-------
Keddv Mill Superfund Site
Record of Decision
September 2023
Appendix C - Figures
Figure 1:
Site Locus Map
Figure 2:
Site Plan
Figure 3:
Site Topography
Figure 4:
Bedrock Surface Topography
Figure 5:
Overburden Potentiometric Surface
Figure 6:
Bedrock Potentiometric Surface
Figure 7:
Runoff Drainage
Figure 8:
Fate and Transport Conceptual Site Model
Figure 9A: Estimated Shallow Soil Contaminated Areas
Figure 9B: Estimated Aggregate Soil Contaminated Areas
Figure 10
Groundwater Contaminant Extents
Figure 11
Total PCBs in Sediment
Figure 12
Metals in Sediment
Figure 13
Conceptual Construction Layout - Soil Remedy
Figure 14
Conceptual In Situ Treatment Locations - Groundwater Remedy
Figure 15
Conceptual Construction Layout - Sediment Remedy
Appendix C - Figures P a g e | 155
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Keddy Mill Superfund Site
Record of Decision
September 2023
Wlttf
South N. c>m
Windhanry/
SITE LOCATION
¦r'vAnJrw
Little
Falls.'.,
STATS
Robi«
Sch'
Map Location
f^r\
USGS Topographic Map
Gorham, Maine
Revised 1975
FIGURE 1
nobis
Nob Is Group Ste«t
Low«il, MAO 1 - (9 re) 083-OS91
imjmw nobls-oroup com
SITE LOCUS MAP
KEDDY MILL SUPERFUND SITE
WINDHAM, MAINE
PREPARED BY: JTS
PROJECT NO. D00006.00D
CHECKED BY-KKN
DATE: DECEMBER 2021
Appendix C - Figures
Page | 156
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
FORMER
CONCRETE PAD
KEDDY MILL
NPLSITE
RESIDENTIAL COMPLEX
APPROXIMATE
) FENCELINE
DYNAMO ROOM
FORMER FORGE SHOP I
// APPROXIMATE LOCATION
/ J OF FORMER 10,000
y AND 15,000 GALASTS
FORMER OLD
BOILER HOUSE
APPROXIMATE
| PROPERTY
.BOUNDARY
LITTLE FALLS LANDING
APARTMENT COMPLEX1
.OLD CONCRETE PAD;
I LOADING DOCK
STORAGEAND
MANUFACTURING
HYDRO
PROPERTY
'OVERHEAD HOIST
GENERATOR ROOM
(BASEMENT)
MANUFACTURING,
AND OFFICE
MELT BUILDING
HYDRO
POWER PLANT
PRESS BUILDING|
APPROXIMATE LOCATION OF
TWO FORMER 1,000-GAL I
ASTS
Legend
0 I FORMER GARAGE
Existing Structure
Former Structure
TRANSMISSION LINI
PROPERV
SAPPI Hydroplant
! Mill Complex Property
I Parcels subdivided from original
mill complex property
Hawkes Way
Fenceline
1. Keddy Mill Property boundary is from Doucet Survey,
December 2016.
2. Current and Former Structures from S.W. Cole, 1997,
Consla, 1993, and H S and Nobis, 2013. Parcels from Maine
Office of GIS, revised May 2016. Aerial photo from Maine
Geolibrary, 2018.
3. Locations of site features depicted hereon are approximate
and given for illustrative purposes only.
Feet
1 inch = 150 feet
nobis
Nobis Group® - 585 Middlesex Street
Lowell, MA01851 - (978) 683-0891
www.no bis- gro up. co m
riouRn £.
SITE PLAN
KEDDY MILL SUPERFUND SITE
REMEDIAL INVESTIGATION
WINDHAM, MAINE
OLD SUBSTATION
I AND EXTERIOR AND
TRANSFORMER PAD
Appendix C - Figures
P a g e | 157
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
Legend
Mill Complex Property
10 Foot Contour
2 Foot Contour
Existing Structure
Former Structure
Hydroplant
Parcels
Fen celine
1. Ground surface contours and property boundary from
Doucet Survey. December 2016.
2. Parcels from Maine Office of GIS, revised May 2016.
Aerial photo from Maine Office Of GIS, 2012, and Google
Earth. 2016.
3. Locations of site features depicted hereon are approximate
and given for illustrative purposes only.
FIGURE 3
SITE TOPOGRAPHY
KEDDY MILL SUPERFUND SITE
WINDHAM, MAINE
nobis
Nobis Group® - 585 Middlesex Street
Lowell, MA01851 - (978) 683-0891
www.nobis-group.com
CHECKED BY: GH
PROJECT NO. DQQ0Q6.QQ0
DATE: APRIL 2023
Appendix C - Figures
P a g e | 158
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Keddy Mill Superfund Site
Record of Decision
September 2023
Appendix C - Figures
P a g e | 159
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
.MW03D;
IMV^08
,97 .13i
[MV^u2j
pWjlOpSi
pjgaiTos]
Legend
Overburden Monitoring Well with
Groundwater Elevation (11/08/16)
Surface Water Elevation
(11/11/16)
Overburden Groundwater
Contour (11/08/16)
Groundwater Flow Line
Inferred Overburden Groundwater
Contour (11/08/16)
Inferred Groundwater Flow Line
Approx. Parcel Boundaries
Current Parcels
1. Groundwater elevations from November 8, 2016. Surface
water elevations from November 11, 2016. Elevations of
MW-10D/S and MW-09D/S are averages of the S and D wells.
2. Mill Complex Property is from Doucet Survey. December
2015. Parcels are from Maine Office of GIS, revised 2016; aerial
photo from Maine Office of GIS, 2012 and Google Earth. 2016.
3, Locations of site features depicted hereon are approximate
and given for illustrative purposes only.
FIGURE 5
OVERBURDEN POTENTIOMETRIC SURFACE
- NOVEMBER 2016
KEDDY MILL SUPERFUND SITE
WINDHAM, MAINE
nobis
Nobis Group3 - 585 Middlesex Street
Lowell. MA 01851 - (978) 683-0891
www.nobis-group.com
PROJECT NO. D0006.000
DATE: SEPTEMBER 2021
Appendix C - Figures
P a g e | 160
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
Legend
Bedrock Monitoring Well with
Groundwater Elevation (11/08/16)
Bedrock Groundwater
Contour (11/08/16)
Inferred Groundwater
Contour (11/08/16)
Groundwater Flow Line
Mill Complex Property
Current Parcels
Notes:
1. Groundwater elevations from November 8,2016.
2. Mill Complex Property is from Doucet Survey, December 2015.
Parcels are from Maine Office of GIS, revised 2016; aerial photo
from Maine Office of GIS, 2012 and Google Earth, 2016.
3. Locations of site features depicted hereon are approximate and
given for illustrative purposes only.
FIGURE 6
BEDROCK POTENTIOMETRIC SURFACE
NOVEMBER 2016
KEDDY MILL SUPERFUND SITE
WINDHAM, MAINE
nobis
Nobis Group® - 585 Middlesex Street
Lowell, MA 01851 - (978) 683-0891
www.nobis-group.com
CHECKED BY: LC
PREPARED BY: JH
PROJECT NO. 80107
DATE: JANUARY 2018
Appendix C - Figures
P a g e | 161
-------
Keddy Mill Superfund Site Record of Decision September 2023
Appendix C - Figures
P a g e | 162
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
Figure 8
Fate and Transport Conceptual Site Model
Keddy Mill Superfund Site
SOURCES of
RELEASES
PRIMARY
RELEASE/
TRANSPORT
MECHANISMS
PRIMARY
RECEIVING
MEDIUM/
SOURCE
SECONDARY
RELEASE/
TRANSPORT
MECHANISMS
SECONDARY
RECEIVING
MEDIA
TERTIARY
RELEASE/
TRANSPORT
MECHANISMS
RECEIVING
MEDIA
FATE AND TRANSPORT SCREENING
SUMMARY
o
w
Groundwater
<
%
3
~
Surface Water
Sediment
Fish Tissue
VOCs
~
y
SVOCs
y/
~
y
•/
PCBs
V
~
Dioxins
and
Furans
V
~
V
Metals
V
~
Legend:
w Indicates a transport pathway of interest
Contaminants of interest represent chemicals
detected in environmental media at concentrations
exceeding initial screening. More detailed
evaluations in the HHRA and ERA identify potential
Contaminants of Concern that pose risks to human
health and the environment.
Appendix C - Figures
P a g e | 163
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
0-0.S ft:
Aroclor, Total 22,400 ug/kg
Dioxin-like PCBTEQ 288 ng/k
SB41
\t ,0-0.5 ft:
SB40 \ jAroel or, Total 3,200 ug/kg
\/,Dioxin-likePCBTEQ184ng/l<
10-0.5 ft:
|pioxin-like PCBTEQ 173 ng/kg,
l0-0.5ft:
^Aroclor, Total 1,200 ug/kg[
0-0.5 ft:
Arsanic 20.9 mg/kg
Dioxin-lika PCB TEQ 88.4 ng/kg
Iron 143,000 mg/kg
Total PCB Homologues 3,200 ug/kgf
0-0.5ft: I
Total PCB Homologues 1,100 ug/kgt
, Dioxin-like PCBTEQ 68.1 ng/kg|
SB14
JSB53
10-0.5 ft:
IDioxin-like PCBTEQ 287 ng/kg
Iron 117,000 mg/kg
fTotal PCB Homologuas 13,000 ug/kg
SB04
0-0.5 ft:
Dioxin-like PCB TEQ 147 ng/kg
Total PCB Homologues8,800 ug/kg
I0-0.5 ft
Arodor, Total 13,000 ug/kg
Dioxin-lika PCBTEQ 294 ng/k
10-0.5 ft: j
IDioxin-like PCBTEQ 316 ng/kg
|Total PCB Homologues 15,000 ug/kg|
PCB TEQ 53.9 ng/kg
SB47
10-0.5 ft:
[iron 65,400
Ism 8
10-0.5 ft:
I Aroclor, Total 3,800 ug/kg
[pioxin-like PCBTEQ 142 ng/k
Legend
ISB23
lo-0.5 ft:
IDioxin-like PCBTEQ 278 ng/kg
Sample Exceeds Residential PRGs?
Estimated Contamination Area
It-BANK-1 J
I0-0.5 ft: [
)atocI or, Total 1,970 ug/kg|
>10 mg/kg Total PCBs
1 to
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
SB42
10-15 ft:
Benzo(a)pyrene 1,300 ug/kg|
0.5-7 ft:
Dioxin-like PCBTEQ:
Iron 243,000 mg/kg
Total PCB Homologu
10-15 ft:
^Arsenic 28.6 mg/kg
2-3 ft: |
Aroclor, Total 9,000 ug/kg I
Dioxin-like PCBTEQ 149 ng/kg,
SB41.
1.58-2.58 ft:
Aroclor, Total 9,600 ug/kg
Dioxin-lika PCBTEQ 112 ng/kg,
, SB40Q
0.5-5 ft:
Iron 148,000 mg/kg
Total PCB Homologues 3,600 ug/kg
14-15 ft:
Dioxin-like PCBTEQ 213 ng/kg
Total PCB Homologues 24,000 ug/kgf
1-2 ft:
JAroclor, Total 9,700 ug/kg
, Dioxin-like PCBTEQ 100 ng/kg|
|SS-13
*|0-2ft:
'• jAroclor, Total 5,900 ug/kg
i/Benzo(a)pyrene 1,400 ug/kg
r^lron 94,300 mg/kg
i. |SS-14
I 0-2 ft:
\ jAroclor, Total 1,900 ug/kg
^Arsenic 44.7 mg/kg
//I Benzo(a)pyrene 3,600 ug/kg
J1-2 ft:
,Aroclor, Total 2,900 ug/kg|
1.92-2.92 ft: r
Aroclor, Total 2,200 ug/kg
Dioxin-like PCBTEQ84.5 ng/kg
SS-06 1
0-2 ft:
I Bsnzo(a)pyrene1,400 ug/kg|
1.25-2.25 ft:
Aroclor, Total 1,800 ug/kg|
10.5-8 ft:
[Arsenic40.9 mg/kg|
[SBT8]
ISS-22
jo-2 ft:
tArsenic 92.6 mg/kg|
SS-07 1
0-2 ft:
Arsenic 23.9 mg/kg|
"^H-GP-3
Oh-gp-1
Jo.5-10 ft:
[Benzo(a)pyrene1,500 ug/k
115-17 ft:
[Arsenic 22.7 mg/kg
|5-8 ft:
lAntimony 622 mg/kg
|Arsenic 68.5 mg/kg
[o.5-10 ft: i
lArsem'c 21.6 mg/kg
jDioxin-like PCBTEQ4,400 ng/kg
|Total PCB Homologues 350,000 ug/kg|
|SS-19
lo-2 ft:
[iron 60,600 mg/kg
0-2 ft:
Arsenic 23.1 mg/kg
Benzo(a)pyrene 1,400 ug/kgl
[Iron 124,000 mg/kg
|sS-23
lo-2 ft:
|Benzo(a)pyrene 2,200 ug/kg[
Legend
Sample Exceeds Residential PRGs?
l5-8 ft:
|Arsenic 32,6 mg/kg|
Estimated Contamination Areas
>10 mg/kg Total PCBs
1 to
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
2-Methyl naphthalene 390 ug/L
Arsenic 44 ug/L
Benzo(a)pyrene 1S ug/L
Bis(2-ethylhexyQphthalate 7 ug/L
Cyanide 1.4 ug/L
Iron 40,000 ug/L
Manganese 2,080 ug/L
Naphthalene 140 ug/L [
MW-01: I
Arsenic 12.9 ug/L
Cyanide 0.75 ug/L
Iron 30,900 ug/L
Manganese 3,180 ug/L
Maphthalerie 4.2 ug/L
Legend
fli Bedrock Well Locations
Overburden Wells
Sample does not exceed PRGs
+ Sample does exceed PRGs
j Mill Complex Property
Approx. Arsenic > PRG
—- Approx. TCE > PRG
Approx. Manganese Extent > PRG
—— Approx. Napthalene Extent > PRG
1. Boundary is from Doucet Survey, December 2015. Parcels are
from Maine Office of GIS, revised 2016; Aerial photo from Maine
Geolibrary, 2018.
2. The groundwater PRG values can be found in Table 2-5.
3. Locations of site features depicted hereon are approximate and
given for illustrative purposes only.
Feet
1 inch = 100 feet
nobis
Nobis Group0 - 585 Middlesex Street
Lowell, MA 01851 - (978) 683-0891
www.nobIs-group.com
nounc i u
GROUNDWATER
CONTAMINANT EXTENT
KEDDY MILL SUPERFUND SITE
FEASIBILITY STUDY
WINDHAM, MAINE
Appendix C - Figures
P a g e | 166
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
From RSL Res to
< ME RAGs Res
SED-01
Gambo Dam - approxfl.S miles,up:
1- Rnalf^s main man
\ \ ^ SED-30
Legend
A Rl Sediment Sample Locations
I 1 Mill Complex Property
1 I Current Parcels
CD, Town Line
. v' -^tnurfii'Eium
Total PCBs 53 J ug/kg
"-Li i"" '~ :
Notes:
1. Remedial Investigation (Rl) sediment sample depths are 1-2 inches
bgs. PCBs reported are sum of Homologues. Samples collected
November 2016. EB = analyte identified in Equipment Blank; J = result
is estimated; U = analyte not detected above sample detection limit.
2. Boundary is from Doucet Survey, December 2015. Parcels are from
Maine Office of GIS, revised 2016; aerial photo from Maine Geolibrary,
2018.
3, Locations of site features depicted hereon are approximate and
given for illustrative purposes only.
Polychlorinated
Biphenyls
(PCBs) (Mg/Kg)
Criteria or Standard
Result Color Code
None Detected
[Regional Screening Level (RSL)
Residential (Res) Soil
I Maine (ME) Remedial Action
Guidelines (RAGs) - Res Soil
|ME RAGs- Recreational (Rec)
[Sediment
From ME RAGs Res to
< ME RAGs Rec
From ME RAGs Rec to
< 10x ME RAGs Rec
10x ME RAGs Rec Sediment
FIGURE 11
TOTAL PCBs IN SEDIMENT
KEDDY MILL SUPERFUND SITE
WINDHAM, MAINE
nobis
Nobis Group® - 586 Middlesex Street
Lowell, MA 01851 • (978) 683-0891
www.nob is-group .com
PREPARED BY: JH
CHECKED BY: LC
PROJECT NO. 80107
DATE: MARCH 2020
Appendix C - Figures
P a g e | 167
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
9.2 J mg/kg
390 mg/kg
5.1 J mg/kg
6.3 J mg/kg
225 mg/kg
2.1 J mg/kg
4 J mg/kg \
From RSL Res to
< ME RAGs Res
From ME RAGs Res to
< ME RAGsRec
Gatribo Dam - apgro^1.5 miles upstream
• jHRsametscaleias'-main map \
it ' 1
24.5 mg/kg
| As 13.6Jmg/kgj
97.7 mg/kg|
9.5 mg/kg
Legend
Rl Sediment
^ Sample Locations
I I Mill Complex Property
. I I Current Parcels
[C3 Town Line
\ f v*
98.3 mg/kg
12.8 mg/kg
18.5 EB mg/kg
1. Remedial Investigation (Rl) sediment samples are from 1-2 inches
bgs. Samples collected November 2016. EB = analyte identified in
Equipment Blank; J = result is estimated; U = analyte not detected
above sample detection limit.
2. Boundary is from Doucet Survey, December 2015. Parcels are from
Maine Office of GIS, revised 2016; aerial photo from Maine
Geolibrary, 2018.
3. Locations of site features depicted hereon are approximate and
given for illustrative purposes only.
Arsenic
(As)
Cobalt
(Co)
Lead
(Pb)
Criteria or Standard (mg/Kg)
Result Color Code
Criteria (mg/Kg)
Result Color Code
None Detected
None Detected
Regional Screening Level (RSL)
Residential (Res) Soil
ME RAGs Res
< ME RAGs Res
Maine (ME) Remedial Action
Guidelines (RAGs) - Res Soil
ME RAGs Rec
ME RAGs - Recreational (Rec)
Sediment
From ME RAGs Res to
< ME RAGs Rec
From ME RAGs Rec to
< RSL Res
From ME RAGs Rec to
<10x ME RAGs Rec
From RSL Res to
<10x RSL Res
10x ME RAGs Rec Sediment
FIGURE 12
METALS IN SEDIMENT
KEDDY MILL SUPERFUND SITE
WINDHAM, MAINE
nobis
Nobis Group* - 585 Middlesex Street
Lowell, MA 01851 - (978) 683-0891
www.nobis-group.oom
PREPARED BY: JH
CHECKED BY: LC
PROJECT NO. 80107
DATE: MARCH 2020
Appendix C - Figures
P a g e | 168
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
Legend
2 Foot Contour
10 Foot Contour
Proposed Temporary Fence
Proposed Construction Road
Equipment/Materials Staging Area
Potential Equipment/Materials Staging Area
Soil Staging and Ex-Situ Soil Treatment Area
Estimated Soil Excavation Areas
Existing Structure
Former Structure
SAPPI Hydroplant
Mill Complex Property
Parcels
Town Line
Notes:
¦ 1. Ground surface contours and property boundary from Doucet Survey. December 2016.
2. Parcels from Maine Office of GIS, revised May 2016. Aerial photo from Maine Office Of GIS,
2012. and Google Earth, 2016.
3. The Mill building will be removed prior to the remedial action.
4 The Access/Haul Road locations will likely be adjusted as needed during the remedial
action.
5. The Equipment/Materials staging area in the center of the Site, will likely be moved to the
Potential staging area along Depot Street once the impacted soils have been removed and the
area backfilled. This will allow for access to other impacted areas during remaining soil
excavation and construction of the consolidation cell.
6. The soil staging area will be adjusted as necessary based on soil staging and ex-situ soil
treatment needs during the design phase.
7. Locations of site features depicted hereon are approximate and given for illustrative
purposes only.
8. Contaminated soil on Transmission Line Property will not be addressed underthe RA.
Hawkes Way
Feet
1 inch = 100 feet
nobis
Nobis Group® - 585 Middlesex Street
Lowell, MA01851 - (978) 683-0891
www.no bis- gro up. co m
nourvc i o
CONCEPTUAL CONSTRUCTION LAYOUT
SOIL REMEDY
KEDDY MILL SUPERFUND SITE
WINDHAM, MAINE
Appendix C - Figures
P a g e | 169
-------
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
Legend
Sediment Excavation Areas
Current Parcels
Mill Complex Property
Sediment Staging and Dewatering Area
Temporary Coffer Dam
1. Boundary is from Doucet Survey, December 2015. Parcels arc
from Maine Office of 6IS, revised 2016; Aerial photo from Maine
Geolibrary, 2018.
2 Areas estimated to exceed PCB PRG may be adjusted pending
PDI testing post building demolition.
3 Locations of site features depicted hereon are approximate
and given for illustrative purposes only.
4 Proposed Construction Roads, Consolidation Cell Grading and
Footprint, and Temporary Fencing for SO-2 and SED-3A are
shown on Figure 5-1.
5. Temporary coffer dams with a maximum height of 7 feet to be
used along with pumps to de-water sediment excavation areas
prior to excavation.
FIGURE 15
CONCEPTUAL CONSTRUCTION LAYOUT
SEDIMENT REMEDY
KEDDY MILL SUPERFUND SITE
WINDHAM, MAINE
nobis
Nobis Group3 - 585 Middlesex Street
Lowell, MA 01851 - (978) 683-0891
www.nobis-group.com
PREPARED BY: TF
PROJECT NO. DQ0006.0Q0
DATE: SEPTEMBER 2022
Appendix C - Figures
P a g e | 171
-------
Kcddv Mill Superfund Site
Record of Decision
September 2023
Appendix D - ARARs Tables
Table D-l: Evaluation of Chemical-Specific Applicable or Relevant and Appropriate
Requirements and To Be Considered Criteria for Soil Alternatives
Table D-2: Evaluation of Location-Specific Applicable or Relevant and Appropriate Requirements and
To Be Considered Criteria for Soil Alternatives
Table D-3: Evaluation of Action-Specific Applicable or Relevant and Appropriate Requirements and To
Be Considered Criteria for Soil Alternatives
Table D-4: Evaluation of Chemical-Specific Applicable or Relevant and Appropriate Requirements and
To Be Considered Criteria for Groundwater Alternatives
Table D-5: Evaluation of Location-Specific Applicable or Relevant and Appropriate Requirements and
To Be Considered Criteria for Groundwater Alternatives
Table D-6: Evaluation of Action-Specific Applicable or Relevant and Appropriate Requirements and To
Be Considered Criteria for Groundwater Alternatives
Table D-7: Evaluation of Chemical-Specific Applicable or Relevant and Appropriate Requirements and
To Be Considered Criteria for Sediment Alternatives
Table D-8: Evaluation of Location-Specific Applicable or Relevant and Appropriate Requirements and
To Be Considered Criteria for Sediment Alternatives
Table D-9: Evaluation of Action-Specific Applicable or Relevant and Appropriate Requirements and To
Be Considered Criteria for Sediment Alternatives
Appendix D - ARARs Tables
Pasc I 172
-------
Keddy Mill Superfund Site
Record of Decision September 2023
Applicable or Relevant and Appropriate Requirements and To Be Considered Criteria
Table D-l
Evaluation of Chemical-Specific ARARs arid JSC for Soil Alternatives
Keddy Mill Superfund Site
Windham, Mains
Authority
Requirement
Citation
Requirement Synopsis
Status
Action to be Taken to Achieve ARAR
SO-1: No Action
SO-2: Excavation, Off-Site Disposal, On-Site
Consolidation, Capping and Institutional Controls
5Q-3: Excavation and Off-Site Disposal *
F ederal
EPA Risk Reference Doses (RIDs)
>A for use in
sets of
To Be Considered
Tt-e! A i i iM rut) ill not achieve
ricrt r in f mi r t. L 1 cleanup standards
de 1 ff i l r I i i i.-e.
"Hie combination of excavation/of!-site disposal,
capping of remaining contaminated soils and
institutional controls will prevent exposure to
contaminated soil exceeding non-carcinogenic risk-
based standards developed using this guidance.
E>. a\ . i n and -s*t >, « ®s posal will prevent
ayn irii" tan imt«H soil exceeding
d standards developed
Federal
Cancer Slope Factors (CSFsj
uunanre va ue irei f> r-valuatethe potential
exposureto
To Be Consi;
h T A n It rnafae 1 t hieve
r opener 5 b e 1 v f t rlardsdev ) 1
using this guidance,
fi 1" t cf i r f 1
capping of remaining contaminated soils and
institutional controls will prevent exposure to
contaminated soil exceeding carcinogenic risk- based
standards developed using this guidance.
Excavation and off-site disposal will prevent
exposure to contaminated soil exceeding
j using
litis >u.iic.i,irc.e.
Federal
EPA Carcinogenic Assessment Group
Potency Factors
These guidelines provide guidance for calculating
the incremental cancer risk from contaminant
Miiod.'JC.'C;.
T Be Considered
The K mi lion tiller native will riot achieve
car 11 j 'cine msk liased cleanup standards dev 1
The combination of excavation/off-site disposal,
capping of remaining contaminated soils and
i- based
suniuiii i;s ueveiopfcu using itus yuioance.
i using
Federal
Supplemental Guidance for Assessing
Susceptibility from Early-Life Exposure to
Carcinogens
EPA/630/R-03/0
03F 2005
This provides guidance on assessing risk to
children from carcinogens.
To Be Considered
The No Action alternative will not achieve
carcinogenic risk in children based cleanup sta
developed using this guidance.
The combination: of excavation/ off-site disposal,
capping of remaining contaminated soils and
institutional controls will prevent exposure to
rents nins'plrTl-1 ip ""irpc n ncpcnic ' >k-based
standards for children developed using this
Excavalio t dn I til t ii to dl i prevent
exposure sding
carcmogs or children
deveiope
federal
Guidelines for Carcinogenic Risk
Assessment
EPA/630/
01B 2005
n conducting
risk assessment involving carcinogens,
To Be Consk
"U <-1 r lien i e H not achieve
c r i cur Viae cl nup standards dev | rd
u r tl s ct
ft n I
j using
Federal
EPA Guidance off tor
S uperfund Sites v. ration,
I
5
EPA Guidance for developing risk-based
remediation standards for risks posed by PCBs at
unci
To Be Consk
The No Action alternative will not achieve risk based
cleanup standards for KB exposure developed using
Ihis'fiLtklinn.*
The combination of excavation/off-site disposal,
sretil Utional controls will prevent exposure to PCBs
in soil exceeding risk based cleanup standards
developed us inc. this guidance.
Federal
PCBs: Cancer Dose Response Assessment
and Application irt Environmental Mixtures
EfA/600/P-
96/00ir- (EPA,
1995}
Guidance describing EPA's reassessment
regatding the carcinoe,wi icily of PCBs.
To Be Considered
The No Action alternative will not achieve risk
cleanup standards for PCB exposure developed
this guidance.
Thecombination of excavation/oft-site disposal,
capping of remaining contaminated soils and
institutional controls will prevent exposureto PCBs
ii .I'l-irindi cr;
de ei ^1 ! i
Excavation/ofi-site disposal, wiH prevent exposure to
PCBs in soil exceeding risk based cleanup standards
developed using this guidance.
Federal
axicity
Polychkmrtated Dioxins, Furans, and
rent.
S
(
This framework describes a methodology for
assessing risks associated with exposure to
complex mixtures ofdioxins and dtoxin-llke PCBs,
it describes how to apply a specific toot, the
toxicity equivalence methodology, within the
broader context of an ecological risk assessment
To Be Considered
IT 1! not achieve ecological
rt< i for PCBs developed
" "
* Indicates EPA's selected alternative.
Page 1 of 2
Appendix D - ARARs Tables
P age | 173
-------
Keddy Mill Superfund Site
Record of Decision September 2023
Applicable or Relevant and Appropriate Requirements and To Be Considered Criteria
Table D-l
Evaluation of Chemical-Specific ARARs arid JSC for Soil Alternatives
Keddy Mill Superfund Site
Windham, Mains
Authority
Requirement
Citation
Requirement Synopsis
Status
Action to be Taken to Achieve ARAR
SO-1: No Action
SO-2: Excavation, Off-Site Disposal, On-Site
Consolidation, Capping and Institutional Controls
SO-3: Excavation and Off-Site Disposal *
Federal
EPA Ecological Risk Assessment Guidance
for Superfund: Process for Designing and
Conducting Ecological Risk Assessments.
EPA 540-R-97-
006, QSWER
1W7.
Primary source of guidance used in developing
Assessment Forum (Framework for Ecological
Risk Assessment (EPA. 1992) and Guidelines for
Ecological Risk Assessment fEPA, 1998), Provides
i * v ir.1xor»Jjtlirj. jf
te hi ill M ' 1 " t k,J alrivk
uil'- fr li d i r n.
T i Be Consid <
rf N & 1 1 native will not ach e * 1
k L 1' u). standards develop 1 t U
guidance.
The combination of excavat ion/off-site disposal,
capp ing of remaining contaminated soils and
institutional controls will prevent exposureof
ecological receptor to soil contaminants t hat exceed
risk based cleanup standards developed using this
fiuioance.
ecotogfcal receptor to soil contaminants that exceed
risk based cleanup standards developed using t his
Be Considered
The No Action alternative will not, ach
risk based cleanup standards develop
guidance.
capping of remaining contaminated soils and
institutional controls will prevent exposure of
ecological receptor to soil contaminants that exceed
n khs fdiknn l^ndaa' dcv-lcp* in inj hits
Etni-wm.e.
federal
bk Assessment,
iruro,
EPA/630/R-
95/0Q2F :
The Guidelines expand upon and replace the
previously published EPA report Framework for
Ecological Risk Assessment (EPA/630/R-92/001,
February 1992), This proposed principles and
let mitroiogy for the ecological risk assessment
process. Provides guidance on the developing an
ecological risk assessment.
T i Be Considered
"""t f> ¦ 1 o i ilti native will not achieve ecol al
it t La ed It- iU(- standards developed using h
i,u iir e
Thecombination of excavalion/off-site disposal,
c (t» 1 " t s-i
institutional controls will prevent exposure of
ecological receptor tosoil contaminants that exceed
risk based cleanup standards developed using this
puidciritt*.
1 will prevent exposure of
:ontaminantsthal exceed
ds developed using this
Federal
Guidance for Developing Ecological Soil
Screening Levels-
C
5
f
Guidance describing the process used to derive a
set of risk-based ecological soil sc reening, levels
(Eco-SSls) for many of the soil contaminants that
are frequently of ecological concern for plants
and animals at hazardous waste sites and
1 Be Considered
Tf e 1 i A t c n ah emative will not achieve ecol< ral
risk t, pd lK»nuy standards developed using 1 s
gi
The combination of excavation/off-site disposal,
capping of remaining contaminated soils and
institutional contr ols will prevent exposure of
ecological receptor to soil contaminants that exceed
risk based cleanup standards developed using this
iiuidaiKK
t ia ~*.
State
Maine Solid Waste Rale-,. Lead
Management Regulations
06-095 C,
Chapter 4.:
-------
Keddy Mill Superfund Site
Record of Decision September 2023
Applicable or Relevant and Appropriate Requirements and To Be Considered Criteria
Table D-2
Evaluation of Location-Specific ARARs and TBC for Soil Alternatives
Keddy Mill Superfund Site
Windham, Maine
Authority
Requirement
Citation
Requirement Synopsis
Status
Action to be Taken to Achieve ARAR
SO-1: No Action
SO-2: Excavation, Off-Site Disposal, On-Site
Consolidation, Capping and Institutional Controls
SO-3: Excavation and Off-Site Disposal *
Federal
National Historic- Preservation Act (NBPAS
54 U.S.C. §
300101efssq.
its a«Mltes nay cause Separable toss oe
destruction of sfenilfcant scientific, historical, or
archeotofjiea! data, such agency shall consult with
if t t I ! T III
d 1 i < it 1 i 1
Applicable
N/A
EPA performed an Archaeological Phase 0
Assessment and Architectural Assessment for I he
project, area. The assessment concluded that no
historic properties (architectural or archaeolofikai!
would be affected by EPA's future ground disrupting
activities, However, should additional reflated
features be identified in the course of implement!tip,
the alternative, these requirements will be complied
wish.
EPA perform t At 1 tcct ilFfiseO
Assessment and Architectural Assessment for the
project area. The assessment concluded that no
historic properties (architectural or archaeological)
would be affected by EPA's future ground disrupting
activities. However, should additional regulated
features be identified in the course of implementing
the alternative, these requirements will be complied
Fioodplain
and
Wetlands
federal
Fioodplain Management and Protection of
Wet lands
4d CFR 9
IE r ri it * lit- >
t - e i i « 1 te t tl e i 1
1 e F «• t i. <• lrll n. I r
Manaeement) and Executive Order 11990
(Protection of Wetlands), Prohibits, activities that
adversely affect a federally- regulated wetland
unless there is no practicablealternativeand the
proposed action includes ail practicable measures
to minimize harm to wetlands !hat may result
from such use. Requires the avoidance of impacts
associated with the occupancy and modification
of federally-designated 100-year and500- year
fioodplain and to avoid develop went within
If * t M | L >-
alternative. An assessment of impacts to
500-year ftoodplain is required for critical actions
1 i t t t % til
(including pipelines? in a fioodplain. Requires
public notice when proposing any action in or
affecting fioodplain or wetlands.
protected wetland
and fioodplain resources, EPA will solicit public
comment in the Proposed Plan on the proposed
measures to be taken to protect wetland and
:
Wet lands
and
Waterways
State
Maine Natural Resources Protec tion Act
{NRPA) Permit by Rule Standards
38 MRSA 4:
B. C, D, 0'
CMR Chapter
305
P lilt ill 1 t 1 1 i. t *f)Kf
i ¦> . e. i ' n t r )l re l< j i luiiii( sru
Ihtut m! *ct !« i) ludt r t u t n
!>•(. i r all r-it r t <, x 1 tru «u t
Activities n-i\ n r it •>« irwoinll >il
erosion or 1
icable
N/A
To the extent that the installation, operation and
maintenance of the consolidation cell and any
temporary impacts from the soil excavation and
backfilling will impact protected State-protected
resources or their 75-foot buffer ^one, practicable
means will be used to prevent impacts to protected
wHIilViiJ
To the extent that any temporary impacts from the
soil excavation and backfilling will impact
State-protected resources or their 75-foot buffer
ione, available practicable means will be used to
prevent impacts to protected wetland resources.
* Indicates EPA's selected alternative.
Page lot 2
Appendix D - ARARs Tables P a g e | 175
-------
Keddy Mill Superfund Site
Record of Decision September 2023
Applicable or Relevant and Appropriate Requirements and To Be Considered Criteria
Table D-2
Evaluation of Location-Specific ARARs and TBC for Soil Alternatives
Keddy Mill Superfund Site
Windham, Maine
Authority
Requirement
—
Requirement Synopsis
Status
Action to be Taken to Achieve ARAR
SO-1: No Action
SO-2: Excavation, Off-Site Disposal, On-Site
Consolidation, Capping and Institutional Controls
SO-3: Excavation and Off-Site Disposal *
Wetlands
and
Waterways
State
Ma ne Natural resources Protect ion Act
if .lands and Waterways
Pirteftioi Pules
38 MESA 4
B, C. D, Oi
CMR 310
1 i b ' .1 ; f jY «_h u(J i \ p n
li re 3 n^ble imp 'rn t-ste jurj^ Jirt ~>ra
wfhrd m p p *r fviti r f*ie *-fr
rr r ninrwM t pi e m
ips i rr f I f t m if- utt-t'nt ilrei Hons
t pi o*vrts-d i?f r Irp oir eq b° n ->sr d v iere
pis pp iJtfit j e-no ti tfi thit
1 ti iltt- )l sf n ibettnp i ipFis in?
f h low It i il f jniL i i Hi i- ir t
in im 7«J t the>,|p, t-1
exf*-! f i M 1 e f r( e- i ii is i hi E t >
1 1 1 id f IStl M i!fc r d If S Art-II ! Cb
h J ei rf, ti— a rt iiulinl' !*vit nrpy
v S! Here^jhl !V t-^uie es li prittMthe
«»*« as i i.'ten n t urit
Applicable
N/A
To the extent that the installation, operation and
maintenance of the consolidation cell and any
temporary impacts from the soil excavation and
backfilling wtli impact State- jurisdictionaf wetlands
or I heir 75-fool buffer zone, practicable means will
be used to prevent impacts to protected wetland
T i e c*tpr t|- ^rytfip " ntho
soil excavation and backfilling will impact State-
jurisdictional wetlands ortheir 75-Foot buffer ione,
available practicable means will be used to prevent
impacts to protected wetland resources.
Waterway
State
Maine WaterClassification program,
Presumpscot Rivet Basin
38 MRSA
Section Mr,
it f r 1 1 i 1
classifies!ion of Maine's water. The Presurnpscot
River adjacent to the Site is classified as Class 8.
Activities in a water body cannot lower water
1 IX O t It ] rit ¦>
Applicable
N/A L , <7 ' t ' ,'w IMte
Temporary impacts from the soil excavation and
backfilling will be implemented in a manner that
does not degrade the chemical, physical, or
biological integrity of Itie adjacent Presurnpscot
* indicates EPA's selected alternative.
Page 2 of 2
Appendix D - ARARs Tables P a g e | 176
-------
Keddy Mill Superfund Site
Record of Decision September 2023
Applicable or Relevant and Appropriate Requirements and To Be Considered Criteria
Table D-3
Evaluation of Action-Specific ARARs and TBC for Soil Alternatives
Keddy Mil! Superfund Site
Windham, Mains
Action to be Taken to Achieve ARAR
Authority
Requirement
Citation
Requirement Synopsis
Status
SO-l: No Action
SO-2: Excavation, Off-Site Disposal, On-Site
Consolidation, Capping and Institutional Controls
SO-3: Excavation and Off-Site Disposal *
D rt r t
Federal
Clean Waler Ad (CWA}, National Pollution
Discharge Elimination System fMPDES)
33 U.S.C, 11343,
40 C.F.R Part
122.22 -125,
131
Regulates direct discharges lo waters of the
United States,
Applicable
N/A
l( decontaminat ion water, runoSf and any water
If decontamination water, runoff and any waler
generated from this soil remedial alternative is to be
discharged to the River, the water wilt undergo
treatment and analysis toensure the water meets
the substantive dischargestandards of this
Ok HI
Federal
CWA; General Prefrfiatmerst Regulations
for existing and New Sources of Pollution
40C.F.R, P.irf
403
It -st li i r (.r il it «¦> ( It r i
f i IP ft f j» if « S1 i i t
pollutants which pass through or interfere with
treatment processes in Publicly Owned
Tf r nt tl. POT r Ahi 1 m ,
t t lit t V !f-f i V
Applicable
N/A
If decontamination water, runoff and any water
generated from thissoi! remedial alternative is to be
discharged to the a POTW, the water will undergo
treatment and analysis to ensure the water meets
the substantive discharge standards of th is
re-KDi.uton
If decontaminat ion wafer, runoff and any water
generated from this soil remedial alternative is to be
discharged to a POTW, the water will undergo
treatment and analysis toensurethe water meets
the substantive discharge standards of this
Discharge to
Groundwater
Federal
Safe Drinking Water Act (SDWA), Part C;
Underground injection Control Program
42 U.S.C. 300f
el set}.; 40CFR
144-148
nd
This program has beer, delegated to the state and
Relevant and
Appropriate
N/A
If decontamination water, runoff and any water
generated from this soil remedial alternative is to be
discharged to groundwater, the water will undergo
treatment and analysis to ensure the water meets
the substantive discharge standards of th is
^Rubuon
if decontamination water, runoff and any water
generated from this soil remedial alternative is to be
discharged to ground water, the water will undergo
treatment and analysis foensuret he water meets
She substantive dischargestandards of this
i >.:[J!.iI:iUoiv
Stormwater
Discharge
Federal
CWA, National Pollution NPDES
Stormwater Regulations
40CFR
122,26(t:)|'ii}(C)
pollutants in stormwater discharges during and
Applicable
N/A
BMPs wit! be used to manage stormwater runoff
during excavation and soil management activities.
Currently best management practices include
erosion controls instated along the perimeter ol She
work area and around workareas within the Site
perimeter, (e.g., deton facilities, staging area,
excavations}; useof sloped land with sumps to
collect water in thedecon pad and staging areas;
and lining, covering of stockpiles. In addition, the
on-site consolidation area will he designee with
permanent stormwater controls.
BMPs will be used to manage stormwater runoff
during excavation and soil management activities.
Currently best management practices include
erosion controls installed along the perimeter of the
work area and around work areas within the Site
perimeter, (egdecon facilities, staging area,
excavations); useof sloped land with sumps to
collect water in the decon pad and staging areas;
and lining, covering of stockpiles.
Surface
Water
Monitoring
federal
National Recommended Water Quality
Criteria
EP
47
Of
Of
an
IN
Nt» CS dl \ t jUdl 1 El f ill III) I
p eel 1" r i hi-vj it r q t ۥ
I nnedi e ? r | ateo •- o ME s
water quality regulations. The Criterion
I nt "ib i j f- ltra (f l ^ (¦* t fi a c j(
tf-et- |pt cr rr^r i M ^t r i rlace
water to which an aquatic community can be
t j. Hi ! itd( t i t ) re t t 1
t. -W t> lp»rA t t, rtb tHl it/L,
To Be Considered
N/A
Surface water monitoring will beconduct.ed during
ensure-short-term remedial activities do not impact
water quality in the River. Will be used as iong-term
water quality monitoring standards to assess the
piotectiveness of the consolidation area component
of the all.em.)five.
Sutracr «« ip», Jn no' n^pa i
* Indicates EPA's selected alternative.
Page 1 of i>
Appendix D - ARARs Tables r a g e | 177
-------
Keddy Mill Superfund Site
Record of Decision September 2023
Applicable or Relevant and Appropriate Requirements and To Be Considered Criteria
Table D-3
Evaluation of Action-Specific ARARs and TBC for Soil Alternatives
Keddy Mil! Superfund Site
Windham, Mains
Authority
Requirement
—
Requirement Synopsis
Status
Action to be Taken to Achieve ARAR
SO-1: No Action
SO-2: Excavation, Off-Site Disposal, On-Site
Consolidation, Capping and Institutional Controls
SO-3: Excavation and Off-Site Disposal *
Groundwater
Monitoring
Federal
Sale Drinking Water Act (SWDA)
Maximum Contaminant Levels (MCLs)
40CrSU41
141.66
Thcl,lb(« M puLf r ir ate
f f Ik s P ) J i 6 ii 0
Relevant and
Appropriate
N/A
Established groundwater monitoring standards for
N/A
Groundwater
Monitoring
Federal
S;
IV
(Mail'; I
40CrR 141
142.55
fvKt. jrt- s >1 1 rf ibi st » I i Mr
d i )• •• i«i ii u ft (ft i if ioMC
i Ml bit t s Jfit tihr si I\lt- a. viftl
1 1 edtoil f/Cib sre h si it- el i vhK h ( o
kf o J »c I iiih ipjtcf >d\< r t rttv<1 i n ti m
Is ilt i v it t ir j I > wi *Js qui!"- r is oi
safety.
Non-Zero MCLGs
are Relevant and
Appropriate Zero
MCLGs,"ire To Be
Considered
K A
Established groundwater monitoring standards for
the consolidation area! required even after
groundwater cleanup standards have been met
remedy).
N/A
Groundwater
Monitoring
Federal
EPA Health Advisories for Groundwater
H rfl i A1 "! LIn aqtr r on icbnd
to a Ic a the e 5ur 11 r t lI*-
r u trf r i ^ f j ttf-dlt*- fp
environment. Written approval tar the proposed
risk-based cleanup must be obtained from the
L) r "tor ecf tt- n ediatmn and
Ru L if ft C 1
icahle
Tf^ril t? t n r nar»-n n f PC8
rt p ei c! det d h and
hi a rnt p ib Jlr;=u"
p r n r ton n t | to spd t CB S pt for
The sampling, excavation, arid management of PCB
contaminated soil/debris, including air monitoring
during remedial activities, will not result in an
unreasonable risk of injury to health or the
environment. EPA will provide a draft TSCA
determination on its proposed PCB sail remedy for
the Site for public comment in the Proposed Pla n.
Orredi.-t ion
federal
TSCA; PCBSlorage for Disposal
40CF.R.
?S1.65faJ,
and (c)
Ftsljiili r •auifi-m it t u mp »r at y to i^e
0 r< t r*n diatm walv > ith r t
concentrations of PCBs equal or greater than 50
( 1 5 b h nor si ii r it 1 tin iti n < ti the
st i j r 1.1 i 'is ) (t J t- t it Ii h <¦ jge
1 irt p.}i irrn-nt '-ert ti i )t ,s letti*** He
i !i ih Tier f iff or tii i t tu
e i U Sl^l de tHte tie eqnfimt«t fir oils
stockpiles.
Applicable
N/A
POP In tp f i n , r r it. * ions
oi PCBs equal or greater than 50mg/kg will be
mar pin c nre- tMhoierep. '•ments
pri
(tons
of PCBs equal or greater than 50 nig/kg will be
managed in accordance with these requirements
flll'.ll 10 0!l,'All.v":.HSijnVlj.
* indicates EPA's selected alternative.
Page 2 ofS
Appendix D - ARARs Tables
P age | 178
-------
Keddy Mill Superfund Site
Record of Decision September 2023
Applicable or Relevant and Appropriate Requirements and To Be Considered Criteria
Table D-3
Evaluation of Action-Specific ARARs and TBC for Soil Alternatives
Keddy Mil! Superfund Site
Windham, Mains
Authority
Requirement
—
Requirement Synopsis
Status
Action to be Taken to Achieve ARAR
SO-l: No Action
SO-2: Excavation, Off-Site Disposal, On-site
Consolidation, Capping and Institutional Controls
SO-3: Excavation and Off-Site Disposal *
In Situ
Treatment
Federal
Art
(RCRAK Interim Status Treatment,
f i r S ^ rds,
l. b) re I b I
T
4C
26
i
L I t if t j t
1. h it t t
a i t it soil
t f n *r i 1 ([ 1 c it
Ml I t< fl III®
t
Relevant and
Appropriate
N/A
N/A
ln"tu il treat nttt* will ti*-•mpleir1 tiled in
COfllUllil*! c Altil UcicVtrfik'jfd
[>
Federal
Generation of investigation Derived
II f i \ ct
Publication
93453-03 PS
(January 1992)
Vvctsie Ov-i'danc e uit the ui
Met -i «i L)hi eJ sA a fe f L>if nai i r
t' i e »u i rc.it i < h iiwr ts Ui 4i u he
h-ivjrh-iit: trill.
To Be Cons idered
M/A
IDWgenerated as part of this remedial action will be
managed based on guidance standards.
IDWgenerated ss part of this remedial action will be
managed based on guidance standards.
Air
federal
Clean Air Act {CAA} arid Regulations
Chapter 85,
§7411 & 7412:
40 C.F.R, Part
f«l.
Tl < 11 ontlF CAA t
regulations require establish standards to protect
tf- | t n tvp > *¦ > t e
jt i s ,i-k ti j lo
human health.
Applicable
uci < A i j? il r if mtr t jt *flof
N/A {suppression. Anair qua ity management an ^ ^
During excavation and soil management, dust
controls (i.e., water sprays and mist s) will be used
for dust and odor suppression, An air quality
)r di i nt> p-1 11 n < to be-
discharged to the River, the water will undergo
iMtii'-n r1 idcnulw-. 3 en-, ire th'- t meets
the substantive discharge standards of this
regulation.
If decontar h
generated r *1 c f M It*- t »to be
e tl b 1 rder^o
sets
the substantive discharge standards of this
Discharge to
3 Publicly-
Owned
Treatment
Works
(P0TW)
State
Pretreatment Program teg illations
06-096 CMR ch.
528
SI
Os ay
Applicable
N/A
If decontamination water, runoff and any water
generated tram this soil remedial alternative is to be
discharged to the a POTW, the water will undergo
treatment and analysis to ensure the water meets
the substantive discharge standards of th is
If decontamination water, runoff and any water
generated from this soil remedial alternative is to be
discharged to a POTW. the water wiii undergo
treatment and analysis toensurethe water meets
the substantive discharge standards of this
regulation.
Discharge to
Groundwater
State
Rules to Control the Subsurface Discharge
of Poltuta r»tv
06-096 CMR ch.
543
State regulatory requirements for subsurface
wastewater discharges.
Applicable
jgenerated from this soil remedial alternative is to be
N/A j 'SC 3FgS . 0,8r0ULw3er,tlew^erw! un e!¥°
Hdt v 'dpnndfion fto'Li rum.ltirr' r n\ w. ier
f-tn^dtpd rnm'h c rem»Jaialtv r'urMl e vdi'-nneels
ubsi rrtivrr^ bar,_ = L-n1?rCi i 'his
* Indicates EPA's selected alternative.
Page 3 of i>
Appendix D - ARARs Tables P a g e | 179
-------
Keddy Mill Superfund Site
Record of Decision September 2023
Applicable or Relevant and Appropriate Requirements and To Be Considered Criteria
Table D-3
Evaluation of Action-Specific ARARs and TBC for Soil Alternatives
Keddy Mil! Superfund Site
Windham, Mains
Requirement Synopsis
SO-1: No Action
Action to be Taken to Achieve ARAR
SO-2: Excavation, Off-Site Disposal, On-Site
Consolidation, Capping and Institutional Controls
SO-3: Excavation and Off-Site Disposal *
Slormwater Management Act;
Storm water Management Roles
38 MRSA 420-0:
06-096 CMR 500
Stormwater regulationsapplyto, among things,;
project that disturbs one acre or more of land
BMPs will be used to managestormwater rtinofi
during excavation and soil management activstie
Currently best management practices include
erosion controls installed along the perimeter of
work area and a round work areas within the Sit«
perimeter, (e.g., decon facilities, staging area,
excavat ions): useof sloped land with sumps to
collect water in the decon pad and staging areas
and lining, covering of stockpiles In addition, th>
on-site consolidation area will be designed with
permanent storntwatet controls.
BMPs will be used to manage stormwater runol
during excavation and sod management activiti
Currently best management practices include
erosion controls installed aiong the perimeter o
perimeter, {e.g., decon facilities, staging area,
excavations}; use of .sloped land with sumps to
collect water in the decon pad and staging area
and lining, covering of stockpiles.
Surface
Water
Monitoring
Maine Surface Water Quality Criteria for
Toxic Pollutants
06-096 CMR c.
ambient water quality
lutarits in the surface waters
ion and on- site soil management activity to
short-term remedial activities do not impact
uality in the River. Will be used as long-term
iveness of the consolidation area component
jring
tyto
rspac.t
Groundwater
Monitoring
Maine Drinking Water Rules
10-144ACMR
Chapter
231-233
Relevant and
Appropriate
Established groundwater monitoring standards for
the consolidation area (required even after
Erosion and
Sedimentatio
A person who conducts, or causes to be
nducted, an activity that involves filling,
iplacing, or exposing soi! or other eartlw
materials shall take measures to prevent
.¦.iiiOit/niK- !¦:rovon o- ;
ito a i
Erosion and Sedimentation Control Act
e before the a
tequ;
emporary and permanent st
isl betaken arid the site m
prevent unreasonable wo:
if the site is
and timely
BRi
se<
BMPs will be used to establish and manage
edimentation and erosion controls during
>xcavatiori and soil management activities. Cut
)esl management practices include erosion co
retailed along the perimeter of the work area.
nthe
rte pe
Htshl
loped land with s'umps to collect water in the deco
'ad and staging areas; and lining, covering of
s UH.Kfnft;;..
Solid/
Hazardous
Waste
;eand
i Waste Management Act (see
applicable regulations under the Act,
¦iowi
38 MRSA § 1301
el seq.
ioils/oebris excavated from the S
lay he either
¦lid waste far
it iiuuiyjicwj nocuous waMeuiiposui
the
Ma
-site to an author!*
facility.
* Indicates EPA's selected alternative.
Page 4 of s
Appendix D - ARARs Tables
P as
I 180
-------
Keddy Mill Superfund Site
Record of Decision September 2023
Applicable or Relevant and Appropriate Requirements and To Be Considered Criteria
Table D-3
Evaluation of Action-Specific ARARs and TBC for Soil Alternatives
Keddy Mil! Superfund Site
Windham, Mains
Authority
Requirement
—
Requirement Synopsis
Status
Action to be Taken to Achieve ARAR
SO-l: No Action
SO-2: Excavation, Off-Site Disposal, On-Site
Consolidation, Capping and Institutional Controls
SO-3: Excavation and Off-Site Disposal *
Hazardous
Waste
Stale
Maine Identification of Hazardous Wastes
06-096 CMR ch,
850
State regulations for the identification of
hazardous waste.
Applicable
N/A
While no hazardous wastes have been identified on
the Site to date, any wastes generated by the
excavation will be analyzed tinder these standards to
determine whether they meet characteristic
hazardous waste standards. If identified, any
hazardous wastes generated will fee managed
hazardous materia Is will be disposed appropriately.
While no hazardous wastes have been identified on
the Site to date, any wastes generated by the
excavation will be analyzed under these standards to
determine whether they meet characteristic
hazardous waste standards, Ifidemified.ariy
hazardous wastes generated will be managed
disposed of off-site at a licensed facility, Non-
hazardous materials will be disposed appropriately.
Hazardous
waste
Stole
Maine Standards for Generators of
Hazardous Waste
06-0% CMR ch.
851
This rule establishes standards and requirements
for persons who generate hazardous waste,
Applicable
N/A
Ifi\ i s the mt r H n
M i* Ul Si l 1 €l ibllSl ^ Tit «-! I
in Titm tnbifc t
r rt- i t 1 a dr< t si r 11 id si h I at f e
I i it f J i i fi u*-pw d i r tl e
(.1 lit tit S i 1 1 ! «-
icable
n/a i .
Oi
cc ised
fo
es ted
di don
Air Emissions
State
MEDEP Air Emissions. Visible Emissions
Recusation
38 MRSA §585;
06-096 CMR
Part 101
These regulations establish emission standards
ge
ponunuv M.sruxvciv.
icabie
I of
N/A . ( e n d f est v m n m t a n
Di
cc ised
fo
ted
tion
* indicates EPA's selected aiternative.
Page 5> of i>
Appendix D - ARARs Tables P a g e | 181
-------
Keddy Mill Superfund Site
Record of Decision September 2023
Applicable or Relevant and Appropriate Requirements and To Be Considered Criteria
Table D-4
Evaluation of Chemical-Specific ARARs and TSt for Groundwater Alternatives
Keddy Mill Superfund Site
Windham, Maine
Action to fee Taken to Achieve ARAR
Medium
Authority
Requirement
Citation
Requirement Synopsis
Status
GW-1: No Action
GW-2: Monitored Natural Attenuation and
Institutional Controls
6W-3: In Situ Treatment, Baseline and Post-
Treatment Monitoring and Institutional Controls *
Groundwater
federal
Safe Drinking Water Act (SWDA)
Maximum Contaminant levels (MCls)
40 CfR 141.61
-141.06
Relevant and
Appropriate
Tis l\( /v j r 1\> mat ive will not achieve
VK i. 1 > i J lei W! standards.
Natural and ongoing abiotic and biotic processes
expected togradually diminish groundwater
contaminant concentrations. If is estimated that
MCLs will be achieved in approximately 30 years, its
will prevent consumption of drinking water and
exposure to soil vapors in excavations until MCls are
acmeven.
fcf c \H
^GCs,
PAHsi or st,3 bilked ite, fe, Mrs). Groundwater
after completion of in-situ t reatroent. ICs will
prevent consumption of dt inking waterand
* t- ! ip b r n I is are
1
Groundwater
Federal
Srim stHy n
ICs will prevent consumption of drinking water and
i ei % filers ir sva'rr irlilMCl s
are achieved.
Because active in-situ treatment will occur,
groundwater contaminants will be destroyed fvocs,
PAHsl or stabilized {As, Fe, Mn). Groundwater
quality is likely to attain MCLGs within 5 to 10 years
after completion of to sifts treatment. ICs will
prevent consumption of drinking water and
exposure to soil vapors in excavations until MCLGs
rt hi t-j
Groundwater
federal
EPA Health Advisories for Groundwater
Health Advisories p ublfched by £ PA are used to
assess non-cancer health affects tor different
ranges of exposure and used for those
components in drinking water that have neither
MCls nor MCLGs:. EPA's healt li advisories are
non-enforceable and non-regulatory and provide
technical information to state agencies and
other' public health officials on health effects,
analytical methodologies and treatment
technologies associated with drinking wafer
aiiKiirilfdtiDn,
T-> ne Considered
The No Action alternative will not achieve risk-h
manganese clean op standard developed using t
Advisory.
Healt h advisories were used to develop groundwater
cleanup standards formangane.se. Natural and
ongoing abiotic and biotic processes expected to
gradually diminish groundwater contaminant
concentrations. It is estimated that the manganese
cleanup standard will be achieved in approximately
30 years. ICs wiii prevent consumption of drinking
water until the manganese risk-based cleanup
st;j
Health advisories were used to develop groundwat er
lira treatment will occur, groundwater
contaminants will he stabilized (As, Fe, Mnj.
Groundwater quality is likely to attain risk-based
«& i
This euidance was used to devefoo non-carcino r
The guidance was used to develop groundwater
Groundwater
Federal
EPA Risk Reference Doses fRfDs)
F jed by EPA for use in
e *ertic effects of
To Be Considered
The No Action alternative will not achieve
non-carcinogenic risk based cleanup standards
developed usingthis guidance,
* Indicates EPA's selected alternative.
Page lot 2
Appendix D - ARARs Tables P a g e | 182
-------
Keddy Mill Superfund Site
Record of Decision September 2023
Applicable or Relevant and Appropriate Requirements and To Be Considered Criteria
Table D-4
Evaluation of Chemical-Specific ARARs and TSt for Groundwater Alternatives
Keddy Mill Superfund Site
Windham, Maine
Medium
Authority
Requirement
Citation
Requirement Synopsis
Status
Action to fee Taken to Achieve ARAR
GW-1: No Action
GW-2: Monitored Natural Attenuation and
Institutional Controls
GW-3: in Situ Treatment, Baseline and Post-
Treatment Monitoring and Institutional Controls *
Groundwater
Federal
Cancer Slope Factors (CSFs)
G .ed to evaluate the potential
c aused by exposure to
To Be Consrd
si i isli I } t-d 1" jf -ir nrcls
This guidance was used to develop carcinogenic
risk-based cleanup standards carcinogenic
risk-based cleanup s? andards to address
consumption and vapor risks. Natural and ongoing
abiotic and biotic processes expected to address
consumption and vapor risks. To gradually diminish
groundwater contaminant concentrations, if is
estimated that cleanup standards will be achieved in
approximately ;i0 years. ICs will prevent
consumption of drinking water and exposure to
Soil
Federal
EPA Carcinogenic Assessment Group
Potency Factors
T idaoce tor calculating
i from contaminant
e tsk-based
To Be Consid
(.iHllit -ft| iskl i r* ^ if-l'IU? s tr Jirds
This guidance was used to develop carcinogenic
risk-based cleanup standards to address
consumption and vapor risks. Natural and ongoing
t 1 d t pi v ex|_P Pi j
diminish groundwater contaminant concentrations,
!t is estimated t hat cleanup standards will be
achieved in approximately 30 years (Cs will prevent
consumption of drinking water and exposure to
vapor intrenches until risk-based cleanup standards
The guidance was used to develop groundwater
carcinogenic cleanup standards to address
consumption and vapor' risks. Because active its siUi
treatment will occur, groundwater contaminants
will be destroyed (VOCs, PAHs) and contaminants
will be subilued (As, Fe, Mn). Groundwater quality
is likely to attain risk-based standards within 5 to 10
years after completion ol in situ treatment, ICs will
prevent tonsil mption of drinking water and
exposure to vapor intrenches until risk-based
deanupstandards are achieved.
Soil
Federal
Supplemental k to
children tram carcinogens.
To Be Consid
T'if hdAUwr .}'*< "st.'1 ivp v ill not achieve
ia cuwitr nsl> in - nldrpn hasedcleanup
-.tindflsri'- rWFl-ni-il nsmt *'mi; guidance.
This guidance was used to develop carcinogenic
risk-based cleanup standards to address
consumption and vapoi risks. Natural and ongoing
abiotic and biotic processes expected to gradually
diminish ftroundwater contaminant concent radons,
li is estimated t hat cleanup standards will be
achieved in approximately 30 years. ICs will prevent
consumption of drinking water and exposure to
vapor in trenches until risk-based cleanup standards
an-! M.J'IIWKl.
The guidance was used to develop groundwater
rare inogenic cleanup standards to address
consumption and vapor risks, Because active in situ
treatment will occur, groundwater contaminants
will be destroyed (VOCs, PAHs land contaminants
II1 - sNh 1 e * f V J t ui j\nM tut i y
is likely to attain risk-based standards within 5 to 10
,,,,,,
prevent consu mption of drinking water and
exposure to vapor in trenches until risk-based
Groundwater
Federal
Guidelines for Carcinogenic Risk
Assessment
SPA/eO/P-tB/O
01B2Q0S
These guidelines provide guidance on conducting
risk assessment invoking carcinogens.
To Be Consid
(if t nit «*-*->i !c i it it iiEdS
This guidance was used to develop carcinogenic
risk-based clean Lip standards to address
consumption and vapor risks, Natural and ongoing
abiotic and biotic processes expected to gradually
St is estimated that cleanup standards will be
achieved in approximately 30 years ICs wi II prevent
consumption of drinking water and exposure to
vapor in trenches until risk-based cleanup standards
carcinogenic cleanup standards to address
consumption and vapor risks. Because active in situ
treatment will occur, groundwater contaminants
ine it | P H la i t n
will be stabilized (As, Fe, Mn>, Groundwater quality
is likely to attain risk-based standards within 5 la 10
years alter completion of in situ treatment. ICs will
prevent consumption of drinking water and
exposure 10 vapor intrenches until risk-based
cleanup standards are achieved.
* Indicates EPA's selected alternative.
Page 2 of 2
Appendix D - ARARs Tables
P age | 183
-------
Keddy Mill Superfund Site
Record of Decision September 2023
Applicable or Relevant and Appropriate Requirements and To Be Considered Criteria
Table D-S
Evaluation of Location-Specific ARARs and T8C for Groundwater Alternatives
Keddy Mil! Superfund Site
Windham, Maine
Requirement Synopsis
GW-i: No Action
Action to be Taken to Achieve ARAR
GW-2: Monitored Natural Attenuation and
Institutional Controls
GW-3: In Situ Treatment, Baseline and Post-
Treatment Monitoring and Institutional Controls *
American
Artifacts and
National Historic Preservation Act (NMPA)
:>i u.s.c §
300101 et seq.
Should additional regulated features be identified in
the course of installing or maintaining monitoring
wells, these requirements will be complied with.
Should additional regulated features be identified ir
rourse of installing or maintaining monitoring
wells or treatment infrastructure, these
requirements will be complied with,
Floodplain
and
Wetlands
FEN1.A regulations that set forth the
procedure and responsibilities to imi
enforce Executive Order 13.988 (Plot
Management} and Executive Order;
[Protection of Wetlands). Prohibits £
adversely aSfecl a federally regulate
unless there is no pratt fcableaiteriu
proposed action includes all practice
to minimise harm to wetlands that n
floodplain Management and Protection of
Wetlands
¦ the
aled a
rant and
opriale
»f federally-designated 100-year an
ioodplain and to avoid develop mer
ioodplasn wherever there is a pract
iftemative, An assessment of impac
>00-year floodplain is required for c
which includes siting waste treatn
including pipelines} in a floodplain.
sublic notice when proposing any a.
affecting floodplain or wetlands.
0 the extent that the installation and mainte
if monitoring wells impact adjacent federal
jrisdictior.al wetlands or take place within th
-00-year floodplain available practicable mea
© used to reduce impacts to protected weti«
loodplain resources. EPA will solicit public co
1 the Proposed Plan on the proposed measui
«taken to protect wetland and floodplain
title t r th r all n n a it in r
ire w
ict adjacent federal jurisdictional wetlands
la » ^thTfct- ( lo d r =1
icticable means will be used to reduce impac
>tected wetland and floodplain resources. Ef
icit public comment in the Proposed Plan on
-oposed m
idfloodpfe
taken
=ct wetla
* Indicates EPA's selected alternative.
Page lot 2
Appendix D - ARARs Tables P a g e | 184
-------
Keddy Mill Superfund Site
Record of Decision September 2023
Applicable or Relevant and Appropriate Requirements and To Be Considered Criteria
Table D-S
Evaluation of Location-Specific ARARs and T8C for Groundwater Alternatives
Keddy Mil! Superfund Site
Windham, Maine
Authority
Requirement
—
Requirement Synopsis
Status
action to be Taken to Achieve ARAR
GW-i: Mo Action
GW-2: Monitored Natural Attenuation and
Institutional Controls
GW-3: In Situ Treatment, Baseline and Post-
Treatment Monitoring and Institutional Controls *
Wetlands
arid
Waterways
State
M t F> jrilP >urces Protection Act
•NPEVO ! hn t- U tlsnds and Waterways
r,i I i sBjIi
>MvirSA4 J A
B, C, D, 06-096
CMR 310
P l t E r |j t
1 Stf (.at t j r 1 t
wetlands. Applies to alteration of freshwater
wetlands or rivers, among other protected
resources. The standards require that alterations
to protected natural resources be avoided where
S I It I j t i t >
( t Ite it x 1 tl f t i 1 nt
must show that the amount of the resource
ffc- c 1 if- 1 tit t
" ff r i i f tI 1 P -v) t i i) t f
t I ir l if 3 v tl K
J f- t k r» j r rnt rr pi t t > > c t « ->
we
Tf
buffer zone. available practicable means wilt he used
Waterway
State
Maine Water Classification Program,
Presurnpscot River Basin
38 MRSA
Section 467(95
Its tl! «. sf i ltd!, (or the
1 J a II t jc 1 tr j l ,0t
P ( odj t- t o If te tria U? B.
A t U « I *- t r
li > L 1 d s j «. o t
Applicable
N/A
ins eiis
wi!
d» iical
sol
N
lb
* Indicates CPA's selected alternative.
Page 2 of 2
Appendix D - ARARs Tables P a g e | 185
-------
Keddy Mill Superfund Site
Record of Decision September 2023
Applicable or Relevant and Appropriate Requirements and To Be Considered Criteria
Table D-6
Evaluation of Action-Specific ARARs and "FBC for Groundwater Alternatives
Keddy Mill Superfund Site
Windham, Mains
Authority
Requirement
Citation
Requirement Synopsis
Status
Action to be Taken to Achieve ARAR
SW-i: No Action
GW-2: Monitored Natural Attenuation and
Institutional Controls
GW-3: In Situ Treatment, Baseline and Post-
Treatment Monitoring and Institutional Controls *
Slormwater
Federal
CWA, National Pollution NPDES
Slormwater Regulations
40 CFR
122.2f,ic)(;
C la *";o nrr v atpr ^ i at°d tb
-> n c n t t p r o ef 1 f re
required to implement measures, including best
it t ^ vl t 1
pollutants in stormwater discharges during and
after construction activities.
Applicable
N/A
BMPs wtii be used to manage stormwater runoff
during installation and maintenance of monitoring
welb,
BMP?/ willt ater runoff
during inst >i tnonitorina
wells and it
PCB
Remediation
Waste
Federal
Toxir Substances Control Act (TSCA); PCB
Remediation Waste Regulations
15 U.S.C 2'
el see?.; 40
CFR. 751.<
This section of the TSCA regulations provides
risk-based cleanup and disposal options for PCS
remediation waste based on the risks posed by
PCB concentrations found in soil/debris on the
Sitr i ft n th ne utcsHk wllr ult
if t i> 3 >i \ n 1. ut us r 11 ii ilt'i ( Hse
m\ t n nt-Wntte i ?ppt nlf the p ipr eri
fi Inv-d If inu( i) Mi btiireif i the
Dirt t r "> f f t fMt r rrt Jiifii (ii 1
P riiir I EP* toi 1
Applicable
N/A
T^ r (ilit nJnnut """r' >cFCe< f ni 'fd
of injury to health ortheenvironment PCBs wilt
attenuation processes approximately 30 yeans, EPA
proposed PCB groundwater remedy for the Site for
. , . . ,
groundwater will not result in an unreasonable risk
of injury to health or the environment, PCBs will
achieve cleanup standards through in situ treatment
within approximately .12 years. EPA will provide a
draft TSCA determination on its proposed PCB
groundwater remedy for the Site for public comment
in Ult: PitJiiOSw.1
in Situ
Treatment
federal
Underground injection Control Program
40 CFR 144,
146,147
(Subpart EE!
Re
tind" *- oundnie uill poi Hid met- drirkmg
w; nt,
wi
stanoaros.
Applicable
N/A
N/A
hi situ groundwater treatment will be implemented
in compliance with these standards.
to Silu
Treatment
Federal
c i tr t rd Rt v fy 1
l^t it in Th huh
Mc t< mitt ^ ->i lit ai iv
1 « ! rh\si j} i Jfni L il
Tit ji «i
40C.F.R. Part
265 Subpart Q
S a 1 1 1 | t l 1 i ( 1 ")! i
f 1 in I l i i t
proper handling of reagents, system
maintenance, and closure procedures, in-situ soil
i 1 i {f i e it
If?.] f.1 1 tl
Relevant and
Appropriate
H/A
N/A
In situ groundwater treatment wilt be implemented
in compliance with these standards,
Investigation-
Derived
Waste
Federal
Generation of investigation Derived ^
Publication
9345.3-03 FS
('January 1992)
Vi 1 t i- s c-
1 11 [ fr i !(• n r
t a f ^ 11 di 1 he
To Be Considered
N/A
IDW t'eiiK > ilt"1 s 'fi "i fn remedial t« "ut will be
mat i,eJ brt-,eu ti|»jicl<«i t sUrit- id
ID si action will be
m is.
Mori itored
Natural
Attenuation
Federal
Use of Monitored Natural Attenuation at
Superfund, RCRA Corrective Action, arid
Underground Storage Ta nk Sites
OSWER
Publication
920G.4-17P
Th
PC
At
grwrntwou'ir.
To Be Cons idered
N/A
MNA modelling following these guidance standards
achieve groundwater d«mup standards within 3
reasons b!e period (30 years) compared to the SW-3
treatment alternative (12 years}.
Isi/A
* Indicates EPA's selected alternative.
Page 1 of 3
Appendix D - ARARs Tables P a g e | 186
-------
Keddy Mill Superfund Site
Record of Decision September 2023
Applicable or Relevant and Appropriate Requirements and To Be Considered Criteria
Table D-6
Evaluation of Action-Specific ARARs and "FBC for Groundwater Alternatives
Keddy Mill Superfund Site
Windham, Mains
Authority
Requirement
Citation
Requirement Synopsis
Status
Action to be Taken to Achieve ARAR
GW-i: No Action
GW-2: Monitored Natural Attenuation and
Institutional Controls
GW-3: In Situ Treatment, Baseline and Post-
Treatment Monitoring and Institutional Controls *
Vapor
Federal
irTTf 1 n . i o A ^
PI * t i t V i tr j P ! n J
i s 1 IK pis t . r
OSWER
Publication
9200.2-154
(June 2015)
BP va|»r intrusion
To Be Considered
M/A
Institutional controls pertaining to vapor exposure to
HI! If llltll IF Uu- »- | LIS i tf f I d U till
sure to
workers in trendies will be implemented and
until
such time as it is determined Ihey are no longer
i'li^ciwl.
Air
federal
Clean Air Act (CAA) and Regulations
42 U.S.C.
c i iprt-r
§7411 & 7412;
40 CJ.R, Part
61,
Tf s>dir tL* s i iu i thfcLAM »i u a
i»-l u«-« i is rriw « e i «1''< fi i>rJitd l > pro>e«
th'-iutU on -xp tirt l Jiuoine
llilflllsllt I1 't tit !• 11.W lite'HcttdOi la
human health.
Applicable
H/A
Duririj; (retaliation and maintenance of monitoring
wells dust controls [i.e „ water sprays and mists) will
be used for dust and odot suppression, if needed. An
air quality management and monitoring program will
be established, and air monitoring will be conducted
during well installation-and maintenance activities, if
IIKKUTfll,
Dunne installation and maintenance of monitoring
wells and treatment infrastructure dust controls
H.e „ water sprays and mists) will be used for dust
arid odor suppression, if needed. An air quality
management and monitor ing program will be
established, and air monitoring will be conducted
during well installation and maintenance activities
and in-situ injection of c hemical treatment reagents,
Stormwater
State
St.ormwater Management Art;
Star mwater Management Rules
3S
06
Hcrrm alDr regulations apply lo, among things, a
5 (-rt *1 it disturbs one acre or more of land
Applicable for
Relevant and
Appropriate for
under 1 acre
bilk
BMP' i' ,1' be used to manage stormwater runoff
riuiine e l— -sSfation and maintenance or monitoring
Atli-
BMPs will be used to manage stormwater runoff
during installation and maintenance of monitoring
wells and treatment infrastructure. Currently best
management practices include erosion controls
installed along the perimeter of the work areas.
In Situ
Treatment
State
Rules to Control Subsurface Discharge of
Pollutants
06-096 CMR rh.
543
Requirements for subsurface wastewater
discharges.
Applicable
fc/A
N/A
In srf ¦ sroupt wfer tre Trent will be implemented
in (onplsanre with the,e '.fandards,
Erosion and
Sediment at io
n Control
State
Erosion and Sedimentation Cont rot Act
38 MRSA 4
*>Mii \h(norrt'u t t r i ii t- '<> I -
,lu ted ». t i (tin r v\ K"> iilln r
d ! 1 Klllt I H/p») i ), >0 I [ J | f I - ,f f n
nil'MUil s>hi 1! 'opi t_nl
u ire i ru' k- * t m i on t r t S u i1 s "id
i' - s io|t( i 5 le i r j um Mlur a
( i Ll Vl t If lit t MIS ll dlilt < 1 >USt
rrrmirtlu' i 'un icnal i ntiUt t !*> i
f «-i >i r ibil /<• i Ad« j n»< i id in -l\
t« n|ir i ir\ md p< 'ii -nrnt at at Ii wtu i iifri1- ires
f i'li l iktn nc.lf»
-------
Keddy Mill Superfund Site
Record of Decision September 2023
Applicable or Relevant and Appropriate Requirements and To Be Considered Criteria
Table D-6
Evaluation of Action-Specific ARARs and "FBC for Groundwater Alternatives
Keddy Mill Superfund Site
Windham, Mains
Authority
Requirement
—
Requirement Synopsis
Status
Action to be Taken to Achieve ARAR
SW-i: No Action
GW-2: Monitored Natural Attenuation and
Institutional Controls
GW-3: In Situ Treatment, Baseline and Post-
Treatment Monitoring arid Institutional Controls *
Solid/
Hazardous
Waste
State
s1 Mfc H s s i j
alternative will tie analyzed under these standards to
hazardous materials wit be disposed appropriately.
I 1 1
- a
i
'
State
>r Generators of
h > >ni ii i t
0(1-096 CMRch.
851
This rule establishes standards and requirements
Applicable
N/A
If id* n n,i an, 1 . >r > » ^ It i i i jt S will be
me
IrcfMiswi '.aniuv.
If
m
licniswS ii.4t.ilHv.
Solid Waste
Slate
Maine Solid Waste Management Rules
06-096 CMR ch,
400
State regulations for the management of solid
waste.
Applicable
N/A
A«i> soi J viasles generated will be managed on-site
iisuosed of off-meat a licensed facility or
Any solid wastes generated will be managed on-site
ar
Air Emissions
State
MEDEP Ambient Air Quality Standards. Air
Rules
38 MRSA I
06-096 CM
This regulation establishes ambient air quality
standards that are maximum levels of a particular
pollutant that are permitted in the ambient air.
I 1 1 i bl >- [ c 1
! it t \t. Tit
t r 1 j i i \
f 7 rcj it t- i
I* s,f 1 i
icable
N/A
Duriita installation and maintenance of the
mc ;t controls f/.e.. water sprays
an ;ed, if nerved, for dust and odor
SU|
Durina installation and maintenance of the
m dust
cc used,
if
Air Emissions.
Slate
MEDEP Air Emissions. Visible Emissions
Regulation
38 MRSA §:
06-096 CMK
Part 101
'hMsete ub'k i e 'a^ls * emtss >nsUnJiris
it >.ltj Jir „ i p Kit, nuts '- (1 ii out imir mi ou <- tuu jUi
tpnk i iruaix.ii i tM«- « ii » i ii
pollutant standards.
icable
N/A
11{3 rstiliai ir «nd maintenance of the
t> t-vn v el ^t controls f/.ewater spra
i j n st ii i used, if needed, for dust and 1
upi-ie 1
">l 'r ' tailat'-in n " ia'nt«-i «• f '1 e
i rn ^ e>l| i i iprt r fr=i ir rt p r
i c 1 | ^ I n i J
"-drtj f i s M J 1 ppie i
* Indicates EPA's selected alternative.
Page 3 of 3
Appendix D - ARARs Tables P a g e | 188
-------
Keddy Mill Superfund Site
Record of Decision September 2023
Applicable or Relevant and Appropriate Requirements and To Be Considered Criteria
Table D-7
Evaluation of Chemical-Specific ARARs and TBC for Sediment Alternatives
Keddy Mil! Superfund Site
Windham, Maine
Authority
Requirement
Citation
Requirement Synopsis
Status
Action to be taken to Achieve ARAR
SED-1: No Action
SED-3A: Mechanical fcxeavaoon. Or-Site
Consolidation and Institutional Controls
s£D-iS: Mechanical fcxcavation and Off-Site
Disposal *
Federal
PCBs: Cancer Dos« Response Asses smeru
a rid Application in Environmental Mixtures
EPA./GGQ/P-96/0
OIF (EPA, 1996S
Guidance describing EPA's reassessment
regarding the car dnogenicsty of PCBs.
To Be Considered
The No Action alternative will not achieve risk
cleanup standards for PCB exposure develope-s
this guidance.
The combination of excavation, with both on-site
consolidation on shore and off-site disposal, and
in tkutiori 4 r-,rt!rpi (( kir«ver W ci i iifik i
until risk-based Fish tissue standards are achieved
\ illp «\fnt <\po i *5»irif h rts i it <-od
human consumption risk-based standards developed
usnnri.hr; Pi.iu.Mnrf*.
Fxc ft *< n if U Oi f >Sil u j ii titut wi'
controls to prevent Fish consumption until risk-based
fish tissue standards are achieved will prevent
- , lireU> rf P ii h 1 m, ittM - ir hu itj
< i urn ti'ti i I h J t mu ml developed using
Federal
Framework for Application of the Toxicity
Equivalence Methodology (or
Pl\ 'iIcijh Ht i D vxifs r r j c
Biphenyls in ecological Risk Assessment.
Risk Assessment Forum USEPA,
EPA/100/ S (
)4, 6/1/2 i
This framework describes a methodology for
assessing risks associated with exposure to
complex mixtures of dioxins and dioxin-like PCBs.
it describes how to apply a specific tool, the
toxicity equivalence methodology, within the
broader context of an ecological risk assessment.
To Be Consic
lie IWA u< n rtliet tdtK«- aiR not achieveecol tl
n k bas-d cleanup «-iafidd d> for PCBs develop d
'h . Mn f nee
The combinat ion of excavation of PCB-contaminated
sediments and off-site disposal/ consolidation of less
PCB-contaminated sediments on shore will prevent
contaminants that exceed risk based cleanup
standards for PCBs developed using this guidance.
Excavation and off-site disposal of
PCB-contaminated sediments-will prevent exposure
ol ecological receptor to soil contaminants that
exceed risk based cleanup standards for PCBs
developed using this guidance.
Federal
EPA Erologif.il Risk Assessment Guidance
for Superfund: Process for Designing and
Conducting Ecological Risk Assessments.
EPA
54G-R-97-006,
OSWER
199?
Primary source o( guidance used in developing
Screening Level Ecological Risk Assessment
|S LERA). The guidance describes a progressive
—
incorporating fundamental approach to
performing ERA'S as outlined by EPA's Risk
Assessment Forum (Framework lor Ecological
Risk Assessment (EPA, 1392) and Guidelines lot
Ecological Risk Assessment {EPA, 1938}, Provides
guidance on the designing and conducting of
technically defensible ecological risk assessments
tor the Superfund program.
T Be Considered
i fi tor 1 native will not arh <=> e o cif
1 I sea lc uj. standards develops j i ft"
t> -> ldn e
PCB-contaminated sediments on shore wili prevent
Excavation and off-site disposal of
B C tilt srflimH-fr Villi frpipnt-\pc urh
of ecological receptor to soil contaminants that
exceed risk based cleanup standards for PCBs
Federal
E PA Region 4 Ecologic.il Risk Assessment
Supplemental Guidance, March 2018
Update.
The purpose of this supplemental guidance is to
provide regional direction for implementation oi
thi- UbfTAE>.">l'y! ,IPi h se i Mtnf-mino
To Be Considered
The No Action alternative wili not acl
risk based cleanup standards developed u rum.
E
«
The Guidelines expand upon and replace the
previously published EPA report Framework for
Ecological Risk Assessment (EPA/630/R-S2/001,
February 1992J. This proposed principles ami
I r «- r t d L j i ce 1 *u
T Be Considered
The No Action alternative will not achieve ecological
risk based cleanup standards developed using this
guidance.
sou K It 1 ped'i ir, tl is utdartce. J ^ b
* Indicates EPA's selected alternative.
Page 1 of 1
Appendix D - ARARs Tables P a g e | 189
-------
Keddy Mill Superfund Site
Record of Decision September 2023
Applicable or Relevant and Appropriate Requirements and To Be Considered Criteria
Table D-8
Evaluation of location-Specific ARARs andTBC for Sediment Alternatives
Keddy Mill Superfund Site
Windham, Maine
Medium
Authority
Requirement
Citation
Requirement Synopsis
Status
Action to be Taken to Achieve ARAB
SED-1: No Action
SF0 ®A M chankil Excav tion On «sjtr
Cofssoifdstron and Institutional Controls
SFD 3B Mctb tint Excavation wfl OH
site Disposal *
Fish ar.d
Wild life
l-labim
Feeerai
Fish and Wildlife Coordination Act of
1934
existence* of any listed species or rest-!? in the
Applicable
NJA
This alternative will result in modifications to
restoration of the riverbank. Temporary erosion
controls will be installed around work area to
prevent sediment transport oi.t of the work zones
and protect sensitive areas. CPAwillconsult with
the USFWS regard ins the selectee remedial action
arc its impacts. Adverse project related impacts
to fish and wildlife resources will be mitigated and
restoration will occur if necessary.
1 it i it rut
t «'( =tr e n tP ^t =i i.
i o it cftf n j h 1 T ic> iv in
lit s ill be tillc o 3 lie t^
prevent seeiment transport out of the work zones
| o U ? 1 1 1 iltwtf
the USFWS regarding the selected remedial action
iH t n nrr V e r r t iter rp r
r ~ 1 i *, I 1 ci 1 in ir i s d
restoration will occur if necessary,
Wetlands
Feceral
Clean Water Act, Section 404: Section
4i h(l If f erf
Disposal Sites for Dredged or Fill
Matem!.
33U.S.C.§
044; 40 CF.fi.
Part 230, 231
and 33 C.F.R.
Parts 320-323
Under this res uirement, no activity that
adversely affects a wetland shall be permitted
if a practicable alternative with lesser effects is
available, Sctsstordarcsfor restoration ard
mitigation recuircd as result of unavoidable
imp,icts to acuatic resources. CPA must
determine whcli alternative is the "Least
Environmentally Damaging Practicable
aquatic resources. EPA will solicit public
comment in the Proposed Plan on its draft
pplicable
N/A
Temporary impacts from the oewatenng of the
riverbed and sediment excavation, anc backfilling
onfecera! jurisdictional wetlancs. irducing within
1 p e v II be th [¦ it op ' p
inrtisation and restoration measures.
Temporary impacts from the dewaterir-g of the
riverbed and sediment excavation, and backfilling
on federal jurisdictional wetlands, including with in
the river, will be addressed through appropriate
mitigation ano restoration measures. EPA has
cetcrminec that this alternative is the "least
Environmentally Damaging Practicable
Alternative" {LEDPA). as required uncerthese
Floodplair
and
Wetlands
Federal
Fioodplain Managerrsentand Protertior
of Wetlarcs
44 CFR 9
FEMA regulations thatset forth the policy,
procedure ,ird responsibilities to implement
and enforce Executive Ore er 11988 [Floor;plain
Management) and Executive Order 11990
(Protection of Wetlands). Prohibits activities
that adversely affect a federally-regulated
wetlanc unless there is no practicable
alternative and the proposed action includes
wetlarcs that may result from such use.
with the occupancy arc mocrficaiion of
federally-designated 100- yesrand 500-year
fioodplair and to avoid development within
floodplair wherever there is a practicable
alternative. An assessment of impacts to
50G'yearfloodpl3in is reouired for critical
actions - which includes siting waste
treatment facilities (inducing pipelines] in a
floodplair. Secures public notice when
proposing any action in or affectir.gflooc plain
f levant and
propria te
M/A
Tempore ry imparts from the dewaterirg of the
riverbed arc! sediment excavation, anc backfilling
on fee era 1 jurisdictional wetlancr. or floodplain
u p te a .590-year flood evert! will he addressee
throuf-h appropriate mitigation and restoration
measures roeuce impacts to protected wetland
arc flood plain resources. EPA will solicit public
comment in the Proposed Plan on the proposes
measures to be taken to protect wetland and
Tioocrnsm niMHce::,,
Temporary impacts from the dewaterirgof the
riverbed and sediment excavation, and backfilling
on federal juriscictional wetlarcs orfloocplain
{including prevent any release of contamination in
up to ft 500-year flood event] will be acoressed
through appropriate mitigation measures reduce
impacts to protected wetland and flood plain
resources EPA will solicit public commert in the
Proposed Plan on the proposed measures to be
taken to protect wetland and floodpiam
* Indicates EPA's selected alternative.
Appendix D - ARARs Tables P a g c | 190
-------
Keddy Mill Superfund Site
Record of Decision September 2023
Applicable or Relevant and Appropriate Requirements and To Be Considered Criteria
Table D-8
Evaluation of location-Specific ARARs andTBC for Sediment Alternatives
Keddy Mill Superfund Site
Windham, Maine
Action to be Taken to Achieve ARAB
1M.M,
Authority
Requirement
Citation
Requirement Synopsis
Status
SED-1: No Action
5ED-3A: Mechanical Excavation, On-Sitc
Consolidation and Institutional Controls
SED-3B: Mechanical Excavation and Off-
Site Disposal *
Wet lards
and
Waterways
Stale
Prohibits activities which would have an
unreasonable impact or State jurisdictional
wetlarcs. Applies to alteration of freshwater
wetlands or rivers, among other protectee,
resources The standards recuire that
alterations to protectee natural resources be
avoided where possible,and if it can be
demonstrated that no practicable alternative
exists, thee the applicant must show that the
amount of the resource affected has beef
mirimized to the greatest extent practicable.
Projects in or adjacent to (within 75 feet of]
State jurisdictional wetlaro.s and rivers,
streams, are brooks need to comply with the
regulatory retirements to protect the
Applicable
N/A
To thn ertertthat tirmnnrarv irrmaefs from
the shoreline access sec sediment management
development, river bed dnwatcrirg, sncimert
excavation, and backfOiirgwill impact
State-jiirisdictiarial wetlands ortheir 75-foot
buffer zore, practicable means will be used to
prevent impacts to protectee wet lane resources
; - —»
Waterways
State
Ma ire Water Classification Progra m,
Prcsumpscot River Basin
3R MRSA
Section 467(9!
classified 35 Class 8. Activities in s water boey
Applicable
m
pni pttn t 1 1
arc sediment management development, river
bed dewstering, seciment excavation, arc!
backfilling will be implemented in a manner that
f rh c tt h 1 In
biological integrity of the adjacent Prcsumpscot
and seetment mar agement development, river
b i it at r ent e t 1
backfilling will be implemented in a mamerthat
t t tf i ol 3h i
t ( hpc 1 tec t ctth m t
River.
* Indicates FPA's selected alternative.
Page 2 of 2
Appendix D - ARARs Tables P a g e | 191
-------
Keddy Mill Superfund Site
Record of Decision September 2023
Applicable or Relevant and Appropriate Requirements and To Be Considered Criteria
Table D-9
Evaluation of Action-Specific ARARs and TBC fsr Sediment Alternatives
Keddy Mil! Superfund Site
Windham, Maine
Medium
Authority
Requirement
Citation
Requirement Synopsis
Status
Action t3 be Taken to Achieve ARAR
„ . { SLb-.iA: Mechanical Excavation. On-Srte
5ED-1: No Action
| Consolidation and in ti utionai Controls
SED-3B: Mechanical Excavation and Off-Si®
Disposal *
> t
Federal
Cnvni' i-m.i n.Yf-u, ' i.'ihUliOn
0 i)
Regulates. direct discbarges to waters of the
United States.
Applicable
Hi A
it decontamination water, runoff and any water
generated from this sediment remediai alternative is
to be discharged to the River,, the water mil undergo
treat merit, and analysis to ensure the water meets
the substantive discharge standards of this
generated from this sediment remedial alternative is
to be discharged to the River, the water will undergo
treatment and analysis to ensure the water meets
the substantive disc harge standards of this
t ' if 1 c Tr I v I it c
re i ti e 1 m e rw
\t I t t •- 1 t t nl i I
rsRulatiort.
Discharge to
Groundwater
Federal
Safe Drinking Water Art {SDWA}, Part C;
Underground injection Control Program
42U.S.C 3'
etneq.; 40 u k
144-148
These regulations outline minimum program and
performance standards (or underground
injection wells and prohibit any inject ion that
i il * j. I* J k t
t ht J 4 FP I to
1 t I 1 J
li. I t tl fel 1 p }
1 t jl
>ant and
opriate
N/A
If decontamination water, runoff and any water
to '» Ji i ntfl ~i -r itv v ill
meets t he substant ive discharge standards of t his
rpj>i!iar.iffli.
If decontamination water, runoff and arty water
generated from this sediment remedial alternative is
tobe discharged to groundwater, the water will
undergo treatment and analysis to ensure the water
meets the substantive discharge standards of this
(PfiUWKOh.
Stormwater
Federal
CWA, National Foilution fsPDES
Stormwater Regulations
40CFR
122.26fc>(it)(C)
Discharges, of stormwater associated with
construction activities of over an acre are
ffct* i *d K imril^tr* r>t rn<~a ue in h<=>st
r erf pi t t iP 5 tr L >nt >i
pollutants in stormwater discharges during and
Applicable
N/A
BMPswili be used to manage stormwater runoff
during sediment management activities. Currently
best management practices include erosion controls
installed along the perimeter of the work area and
around work areas within the Site perimeter, (e.g
decon facilities, staging area); use of sloped land
with sumps to collect water in the decon pad and
staging areas; and lining, covering of stockpiles.
Stormwater controls for the consolidation area are
to be addressed as part of the soil component of the
rwm-dv.
BMPs will he used to manage stormwater runoff
during sediment management activities, Currently
best management practices Include erosion controls
installed along the perimeter of the work area and
around work areas within the Site perimeter, (e.g
decon facilities, staging area); use of sloped land
with sumps to collect water in the decon pad and
staging a reas; and lining, covering of stockpiles.
Surface
Water
Monitoring
Federal
National Recommended Water Qua lit v
Criteria
EPA-822-R-02-0
47, USEPA,
Office of Water.
Office of Science
and Technology
(Nov. 20021
F fr are q DIt rt all kI 11
1 «v 1 n heith a c } at Ife
(p in n ei Je e a k r[ ite itn Ml
at r u It) e iat nr leL ter «
Lrnf b" l ettra n \C <_ e t n »if
fn i fe c t- t c 1 tr s fice
i^rpr nt, h rh in nq t n nfr ? u
p->se nde n el 1 t v It c i
i r )le Ter! 1 t 1PU 4 > /L,
To Be Considered
H/A
Surface water monitoring will be conducted during
excavation and on- site sediment management
activity to ensure short-term remedial activities do
not impact water quality in the River.
Surface wa
excavation
activity toi
not impact
* Indicates EPA's selected alternative.
Page 1 of 4
Appendix D - ARARs Tables P a g e | 192
-------
Keddy Mill Superfund Site
Record of Decision September 2023
Applicable or Relevant and Appropriate Requirements and To Be Considered Criteria
Table D-9
Evaluation of Action-Specific ARARs and TBC fsr Sediment Alternatives
Keddy Mil! Superfund Site
Windham, Maine
Medium
Authority
Requirement
Otation
Requirement Synopsis
Status
Action to be Taken to Achieve ARAR
. I SED-3A: Mechanical Excavation, Ors-Site
SED-1: No Action }
j Consolidation and Institutional Controls
SED-3B: Mechanical Excavation and Off-Si®
Disposal *
PCB
Remediation
Waste
Federal
Toxic Substances Contra! Act (TSCAtr PCB
Remediation Waste Regulations
15U.S.C 2
et secf.;40
C.r.R, 761.<
1 rftl Ca e t | o es
risk-based cleanup and disposal options for PCB
remediation waste based or* iheiisks posed by
PCB concentrations found In soil/debris on the
i p 1 t- lie 11 ! It
He k f s t 11 1i Ie
\r - pf 1 t n ( tl
I H e He I t-if o 1
C -»f t- f r r i
rt c u ET«.rv
icable
N/A
PCB
contaminated sediment including air monitoring
i Plan,
Tf r PCB
cc irig
di
d< j? for
th Ian,
PCB
Remediation
Waste
federal
TSCA; PCB Storage for Disposal
40 CJ.R.
761.65(a), (b),
and (c)
Establishes requirements for temporary storage
of PCB remediation waste with in stiu
concentrations of PCBs equal or greater than 50
rng/kg, Subsection (a) identifies limitation on the
storage oi waste, Section (b) establishes storage
.( ts i jr if 1
f- ( ! i i>- thf r r n rt f r oils
H *-
Applicable
N/A
PC ions
of
ma ts
pri
PC" " " jncentrations
of Igwiflbe
m quiremerits
Pf
Federal
Generation of investigation Derived Waste
USEPAOSWER
Publication
9345,3- 03 FS
(January 1992)
Wa 1 i
Investigation Derived Waste (IDWjina manner
that ensures protection of human health and the
To Be Considered
rv/A
!OW generated as part, of this remedial action will be
managed based on guidance standards.
IDW generated as part of this remedial action wiii be
managed based on guidance standards.
Air
Federal
Clears Air Act JCAA} and Regulations
42U.S.C,
Chapter 85,
§7411 & 7412;
aoc.r.R. Part
C:i :t.
The air toxics provision r>r the i, Aa b® hazardous to
1 jnurtleiHh
Applicable
tSi/A
During excavation and sediment management dust
controls (I.e., water sprays and mists) will be used
for dust and odor suppi essiort, as needed. An air
quality management and monitoring program will be
established, and air monitoring will be conducted
during excavation, stockpiling, and transportation
controls (re., water sprays and mists > will be used
for dust arid odor suppression, as needed. An air
quality management and monitoring program will he
established, and air monitoring will be conducted
during excavation, stockpiling, and transportation
¦>Cl.ivit>.'<,.
Surface
Water
Discharge
State
Surface Water Discharge Standards
06-096 CMR ch.
520-525
State standards for point source discharges So
surface waters,
Applicable
N/A
If decontamination water, runoff and any water
generated !rom this sediment remedial alternative is
to be discharged to the River, the water will undergo
treatment' and analysis to ensure the water meets
the substantive discharge standards of this
^decontamination water, runoff and any water
generated from this sediment remedial alternative is
to be disc harged to the River, the water will undergo
treatment and analysis to ensure t fie water meets
the substantive discharge standards oi this
Discharge to
FuMul
Ov\ iej
Trci mcit
lrH7 \
State
Presentment Program regulations
06-096 CM
528
state v ast>-v iter prehuman* ta ) ia ds+n
c-it i p II + w nrh pi sth rsiph ~r
ir rtne/ 1 he In *nt (.no ir S jhlr 1,
(_h i ®1Trea n n* *\orl- iPufV" ' jrwh n nay
c-it m rite s-v» ipe -,1 die-
Applicable
M/A
If decontamination water, runoff and any water
generated from this sediment remedial alternative is
to be discharged to a POTW, tire water will undergo
treatment and analysis to ensure lite water meets
the substantive discharge standards of th is
Oil.
If decontamination water, runoff and arty water
l *• i rtt~d r m h **<. men rt n * i i It rr H s
to be discharged to a POTW, the water wit! undergo
treatment and analysis lo ensure the water meets
the substantive discharge standards of this
* Indicates EPA's selected alternative.
Page 2 of 4
Appendix D - ARARs Tables P a g e | 193
-------
Keddy Mill Superfund Site
Record of Decision September 2023
Applicable or Relevant and Appropriate Requirements and To Be Considered Criteria
Table D-9
Evaluation of Action-Specific ARARs and TBC fsr Sediment Alternatives
Keddy Mil! Superfund Site
Windham, Maine
Medium
Authority
Requirement
Citation
Requirement Synopsis
Status
Action to be Taken to Achieve ARAR
„ . I SLD iA Mechanical Excavation, On-Site
SFD-1 • No Action f
I Consolidation and institutional Controls
SED-3B: Mechanical Excavation and Off-Si®
Disposal *
Discharge to
Groundwater
State
Rules to Control the Subsurface Discharge
of Pollutant5
06-096 CMR ch.
543
State regulatory requirements for subsurface
wastewater discharges.
Applicable
life
Ik®
n'a l vr
{meets the substantive discharge standards of this
Slormwater
State
Storm water Management Act;
Stermwater Management Rules
38 MRSA 420-D:
06-096 CMR 500
Stormwaler regulationsapply to, among thiols, a
project that, disturbs one acre or more of land
Applicable
N/A
i-Mf litre used to i ! ff
during sediment management activities. Currently
best management practices inciudeerosion controls
installed along the perimeter of the work area and
around work areas within the Site perimeter, ie.g
decon facilities, staging area); use of sloped land
with sumps lo collect water in the decon pad and
staging areas; and lining, covering of stockpiles,
Stormwaler controls lor the consolidation area are
to be addressed as part of the soil component of rhe
KMr i 1 b^isKU-nvna,- 'err at-r l ol>
decon facilities, staging area); use of sloped land
M?rnt™na
State
Maine Surface Water Quality Criteria (or
Toxic Pollutants
06-096 CMI'i
584
1 !> ru fa'ill < <=• ambient, water quality
n ter t"it xi pT lutants in the surface waters
r t*f t tn
Applicable
N/A
Su ring
ad ; do
Si ducted during
e> agement
ac 1 activities do
Erosion and
Sedimentatio
n Control
Stale
Erosion and Sedimentation Control Act
38 MRSA 4.
A s_e p lo d ch
od J a a fa o j II t
d ph k po [5ii 1 rl
materials shall take measures to prevent
unreasonable erosion of soil or sediment beyond
the project site or into a protected natural
to ft
p i t\ e ns Mf s e t
Mi lit
[. "3 ! II -d t- 1 j
Uf e 1
must be taken and the site must be maintained
it-able
N/A
BMPs will be used ro establish and manage
sedimentation and erosion controls during
excavation and sediment management activities.
Currently best management practices include
erosion controls installed along the perimeter of the
'¦mi e ¦'ii i a onnJ« r£ eir nh nhe f*-
perimete?, ie gdecors facilities, staging area,
excavations}; useof sloped land with sumps to
and fining, covering of stockpiles. Sediment and
erosion controls for the consolidation area are to be
addressed by the soil component of the remedy.
BMPs will be used to establish and manage
sedimentation and erosion controls during
excavation and sediment management activities..
Currently best management practices include
erosion controls installed along the perimeter of the
work area and around work areas within the Site
perimeter, {e.g., decon facilities, staging area,
excavations); use of sloped land with sumps to
collet t water in the decon pad and staging areas;
and lining, covering of stockpiles.
<^l
Ml i o
V * tp
State
f 1 tH) i s * i It- V| I e 1 d
s ! t\ tin it it h u -e
a L ltrrc|_L -H U L
oelowi
38 MRSA §1301
et set?.
M
Re \}
th
prwimiii.wxs (.maw a.
Applicable
HJA
Sediments excavated from the Site will hp
characterized as either solid or hazardous waste.
Solid waste may be either disposed oit-sSte at an
authorized solid waste facility or relocated to the
consolidation area. Hazardous waste will be sent
off-site to an authorized hazardous waste disposal
Sediment excavated from the Site will be
characterised as either solid or hazardous waste.
Solid waste will be disposed off- site at an authorised
solid waste facility, Hazardous waste will be sent
off-site to an authorised hazardous waste disposal
ucitay-
* Indicates EPA's selected alternative.
Page 3 of 4
Appendix D - ARARs Tables P a g e | 194
-------
Keddy Mill Superfund Site
Record of Decision September 2023
Applicable or Relevant and Appropriate Requirements and To Be Considered Criteria
Table D-9
Evaluation of Action-Specific ARARs and TBC fsr Sediment Alternatives
Keddy Mil! Superfund Site
Windham, Maine
Medium
Authority
Requirement
Citation
Requirement Synopsis
Status
Action to be Taken to Achieve ARAR
5ED-1: No Action
SED-3A; Mechanical Excavation, On-Site
Consolidation and institutional Controls
SED-3B: Mechanical Excavation and Off-Si®
Disposal *
Hazardous
Waste
State
Maine Identification of Hazardous Wastes
06-096 CMRch.
850
State regulations (or the identification of
hazardous waste.
Applicable
R/A
While no hazardous wastes have been identified on
the Site to date, any wastes generated by the
excaval ion will be analyzed under these standards to
determine whether they meet characteristic
hazardous waste standards, If identified, any
hazardous wastes generated will be managed
disposed of off-site at. a licensed facility. Non-
hazardous materials wilt be disposed appropriately,
While no hazardous wastes have been identified on
the Site to date, any wastes generated by the
excavation will be analysed under these standards to
determine whether they meet characteristic
hazardous waste standards. If identified, any
hazardous wastes generated will be managed
disposed of off-site at a licensed facility, Non-
hazardous materials will be disposed appropriately.
Hazardous
Waste
State
Maine Standards for Generators of
Hazardous Waste
06-096 CMR di.
851
This ruie esia S ht siarc i rfs and requirements
t r persons \ 1 e-r eM e >" azardous waste,
Applicable
U/A
managed on-site and disposed of off-site at. a
fia.'iisctl iiicilh.v.
Solid Waits
Slate
Maine Solid Waste Management Rules
06 1 f\ cMRth
40il
'•late regulations for the management of solid
A35te
Applicable
N/A
Any soiid wastes generated will be managed on-site
and either disposed oi off-site at a licensed facility or
on site in the consolidation area.
Arty solid wastes generated will be managed on-site
and disposed of off-site at a licensed facility.
Air Emissions
State
MEDEP Ambient Air Quality Standards. Air
Rules
38
oe
Th te th i r Hi lit* » oieril i m ji! t
t nr ci h -i ( i muri 11 I-a 1 f 11 K hr
t Hut it' th it ii (.) ntir-u itHe » u it i
!l i e ihi » ri iili he rt rl
Increments which define the maximum ambient
in tt i t il
ths il fit. KUt it re
iratble
HfA
During excavation arid sedimf t t i
quality rranaj'ement and monitoring program will be
during excavation, stockpiling, transportation, and
During excavation iMid sediment management. dust
controls (i.e., water spsays and mistsjwiii be used
lot dust and odor suppression as needed. An air
established, and air monitoring will becoriducted
during excavation, stockpiling, transportation, and
Air Emissions
State
MEDEP Air Emissions. Visible Emissions
Regulation
38 MRSA §585;
06-096 CMR
Part 101
These regulations establish emission standards
i i f. t i e I
-i tore Id o a it
f ll t t 1 t a dh (t il •)
Applicable
M/A
Dunny excavation and sediment management dust
controls (i.e., water sprays and mists) will be used
for dust and odor suppression, as needed. An air
quality management and monitoring program will be
established, and sir monitoring will be conducted
during excavation, stockpiling, transportation, and
conwrn-iai ion wTiwihws.
'Ji r I 'I * ~ JtM
II 1* S i j is I U j J
f I d 1 J sU| P -| ec«- A a f
fni i t-d r*a n ->rt \ II1 f r i Jl te
h 1 t t c i- I r j i. L i i
n it t 1 e
* indicates EPA's selected alternative.
Page 4 of 4
Appendix D - ARARs Tables P a g e | 195
-------
Keddv Mill Superfund Site
Record of Decision
September 2023
Appendix E - Acronyms and Abbreviations
2,3,7,8-TCDD 2,3,7,8-Tetrachlorodibenzo-p- Dioxin
ACM asbestos containing material
ADD average daily dose
AOC Administrative Settlement Agreement and Order on Consent
ALM adult lead methodology
ARAR Applicable or Relevant and Appropriate Requirement
AST above-ground storage tank
AVS/SEM acid volatile sulfide/simultaneously extracted metals
BLL blood lead level
bgs below ground surface
BHHRA Baseline Human Health Risk Assessment
BMP Best Management Practices
BSAF biota sediment accumulation factor
BTV background threshold value
CBR critical body residue
CERCLA Comprehensive Environmental Response. Compensation, and Liability Act
CERCLIS Comprehensive Environmental Response. Compensation, and Liability Information System
CFR Code of Federal Regulations
CIP Community Involvement Plan
COC contaminant of concern / chemical of concern
CO PC contaminant of potential concern
COPEC contaminant of potential ecological concern
CSM conceptual site model
CSF cancer slope factor
cfs cubic feet per second
CTE central tendency exposure
CWA Clean Water Act
DAF dilution attenuation factor
EE/CA Engineering Evaluation and Cost Analysis
EPA United States Environmental Protection Agency
EPC exposure point concentration
ESD Explanation of Significant Differences
FS Feasibility Study
FSP Field Sampling Plan
Fl fraction ingested
GD Shoreland General Development
HI hazard index
HQ hazard quotient
HRS Hazard Ranking System
IEBUK Integrated Exposure Uptake Biokinetic
ILCR incremental lifetime cancer risk
LADD lifetime average daily dose
LEDPA Least Environmentally Damaging Practicable Alternative
LOAEL lowest observed adverse effect level
MCL Maximum Contaminant Level
MEDEP Maine Department of Environmental Protection
mg/kg milligrams per kilogram
Appendix E - Acronyms and Abbreviations
Page | 196
-------
Kcddv Mill Superfund Site
Record of Decision
September 2023
mg/kg-day
milligrams per kilogram per day
Hg/dL
micrograms per deciliter
M'g/L
micrograms per liter
MNA
monitored natural attenuation
NCP
National Oil and Hazardous Substances Pollution Contingency Plan
ng/L
nanograms per liter
NOAEL
no observed adverse effect level
NPL
National Priorities List
NRPA
Natural Resources Protection Act
NTCRA
Non-Time-Critical Removal Action
O&M
Operations and Maintenance
OU
Operable Unit
PAH
polyaromatic hydrocarbons
PCB
polychlorinated biphenyl
PDI
pre-design investigation(s)
PFAS
per- and polyfluorinated alkyl substances
PEL
Probable Effect Level
PFHxA
perfluorohexanoic acid
PFOS
perfluorooctane sulfonate
PRC
preliminary remediation goal
PRP
potentially responsible party
PWD
Portland Water District
QAPP
quality assurance project plan
RAGS
EPA Risk Assessment Guidance for Superfund
RAO
remedial action objective
RfC
reference concentration
RfD
reference dose
RI
Remedial Investigation
RME
reasonable maximum exposure
ROD
Record of Decision
RSV
Refinement Screening Value
SEMD
Superfund and Emergency Management Division
SHPO
state historic preservation officer
SLERA
Screening Level Ecological Risk Assessment
SSL
soil screening level
SVOC
semi-volatile organic compound
TBC
To-Be-Considered
TCE
trichloroethene
TEQ
toxicity equivalence quotient
THPO
tribal historic preservation officers
TSCA
Toxic Substances Control Act
TRY
Toxicity Reference Values
UCL
upper confidence level
UST
underground storage tank
VISL
EPA Vapor Intrusion Screening Level
vc
Village Commercial
VLF
Village at Little Falls Contract Zone
voc
volatile organic compound
VRAP
Voluntary Response Action Program
Appendix E - Acronyms and Abbreviations
Page | 197
-------
Keddv Mill Superfund Site
Appendix F - TSCA Determination
Record of Decision
September 2023
Appendix F - TSCA Determination
Page | 198
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
Keddy Mill Superfund Site
TSCA 40 CFR § 761.61(c) Risk-Based Disposal Determination
ThisToxic Substances Control Act (TSCA) Risk-Based Disposal Determination ("Determination") is
included in EPA's Record of Decision ("ROD") to address contamination within portions of the
Keddy Mill Superfund Site (the "Site") located in the Little Falls area of Windham, Maine. EPA has
determined that Polychlorinated Biphenyl (PCB) contaminated soil within the Mill Complex
Property of the Site14 at total PCB concentrations of greater than (>) 1 milligrams per kilogram
(mg/kg), sediments within the Target Reach of the Presumpscot River15 at concentrations of
greater than or equal to (>) 0.7 mg/kg, and PCBs at 0.5 micrograms per liter (|ig/L) in Site
groundwater meet the definition of a PCB Remediation Waste as defined under 40 CFR § 761.3.
Therefore, these PCB-contaminated soils, sediments, and groundwater are regulated for cleanup
and disposal under 40 CFR § 761 (Polychlorinated Biphenyls Manufacturing, Processing,
Distribution in Commerce, and Use Prohibitions). Under 40 CFR § 761.61(c), EPA may authorize
disposal of PCBs in a manner not otherwise prescribed provided that EPA determines that the
disposal will not pose an unreasonable risk of injury to health or the environment.
EPA's administrative record, available for public review (www.epa.gov/syperfund/keddv).
includes extensive information on the nature of the contamination, location and extent of the
contamination, the procedures used relative to sampling, and Human Health and Ecological Risk
Assessments. Consistent with 40 CFR § 761.61(c) of the TSCA, EPA has determined that the
implementation of the remedy outlined in the Record of Decision will not pose an unreasonable
risk of injury to health or the environment as long as the following conditions are met:
• PCB contaminated soil in excess of the human health risk-based cleanup level of less than
or equal to (<) 1 mg/kg within the Mill Complex Property will be excavated for off-site
disposal. Terrestrial portions of an adjoining property (referred to as the Transmission
Line Property [i.e., upland and riverbank soil exclusive of Presumpscot River sediments])
are outside of the Site and are being remediated under State authority.
Soil excavation consistent with the human health risk-based cleanup level will be
protective of potential ecological receptors (i.e., the soil cleanup level for ecological
receptors is higher at 1.8 mg/kg). Site soils with in situ total PCB concentrations equal to
or greater than 50 mg/kg will be excavated, appropriately managed per 40 CFR §
761.65(c)(9) outside the 500-year flood plain, and disposed of off-site at an approved TSCA
or hazardous waste disposal facility in accordance with 40 CFR § 761.61(a)(5)(i)(B)(2)(iii).
Soils with in situ total PCB concentrations > 1 mg/kg and less than (<) 50 mg/kg will be
excavated and disposed of off-site at a facility licensed to accept such soil material in
14 As referenced herein, the Mill Complex Property includes the 7 Depot Street parcel (Map 38, Lot 7) as defined by
the final National Priorities List (NPL) listing on May 12, 2014.
15 The Target Reach of the Presumpscot River represents the reach of the river between the downstream side of
the Little Falls dam and the upstream side of the Mallison Falls dam.
Appendix F - TSCA Determination
Page | 199
-------
Keddv Mill Superfund Site
Record of Decision
September 2023
accordance with 40 CFR § 761.61(a)(5)(i)(B)(2)(ii). The soil excavation activities include
potential PCB contamination comingled with the presence of petroleum product in soil/at
the water table within northern portion of the Site. Stormwater will be appropriately
managed per 40 CFR § 761.60 and § 761.79, environmental monitoring (e.g., dust
monitoring and control) will be implemented (as needed), and equipment and vehicles
will undergo appropriate decontamination.
• Water from excavation dewatering, as well as other potential remedial activities (e.g.,
groundwater remedy implementation, sediment management, groundwater monitoring,
etc.) will be treated to remove PCBs, as needed, prior to being appropriately discharged
under applicable PCB discharge levels (e.g., to the Presumpscot River, to a municipal
sewer system or to groundwater) or sent to an off-site disposal facility. Water will be
treated to meet the TSCA surface water discharge level of 0.5 parts per billion (ppb) in
accordance with 40 CFR § 761.79(b)(l)(iii) and applicable surface water discharge criteria,
publicly-owned treatment works (POTW) wastewater discharge permit requirements or
State groundwater discharge criteria (depending on the selected discharge method).
Filters or other media generated from the treatment process will be characterized and
disposed of at an off-site disposal facility appropriately licensed to accept the PCB-
contaminated waste.
• Focused in situ treatment will be used to address localized areas of groundwater
contamination throughout the Site, with Institutional Controls (ICs) to limit potential
exposure until cleanup levels are achieved. Groundwater treatment activities will be
implemented based on the Site-specific conditions present following the soil source
control action and placement of amendments during backfilling activities to supplement
the improvement of groundwater conditions. Treatment technologies will be assessed
and selected based on Site-specific conditions as part of the remedial design and may vary
to adequately address on-site localized groundwater contamination. Notably, comingling
of petroleum with other contaminants in the northern portion of the Site has resulted in an
increased degree of mobilization of select contaminants including PCBs. The soil remedy is
anticipated to address residual petroleum-based product and oil, as well as PCBs, present
in the subsurface. The physical removal of soil source material, followed by in situ treatment
of residual petroleum contamination in groundwater, will mitigate the mobilization of PCBs
to the shallow groundwater. The selected in situ treatment technology is anticipated to
further address residual PCBs in groundwater in excess of the 0.5 |ig/L cleanup level.
• PCB-contaminated river sediments throughout the Site will be excavated from targeted
areas within the Target Reach of the Presumpscot River to meet EPA's ecological cleanup
level (0.7 mg/kg). Excavated material will be dewatered and transported off-site for
disposal. Sediments with in situ total PCB concentrations > 0.7 mg/kg and < 50 mg/kg will
be excavated and disposed of off-site at a facility licensed to accept such soil material
accordance with 40 CFR § 761.61(a)(5)(i)(B)(2)(ii). Sediments with in situ total PCB
concentrations > 50 mg/kg (none anticipated) will be excavated and disposed of off-site
Appendix F - TSCA Determination
Page | 200
-------
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-------
Keddv Mill Superfund Site Record of Decision
Appendix G - Administrative Record Index and Guidance Documents
Appendix G - Administrative Record Index and Guidance Documents
September 2023
Page I 202
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
Keddy Mill
NPL Site Administrative Record
Record of Decision (ROD)
Index
ROD Dated; September, 28 2023
Released: October 2023
Prepared by
EPA New England
Superfund & Emergency Management Division
Appendix G - Administrative Record Index and Guidance Documents
Page | 203
-------
Keddv Mill Superfund Site
Record of Decision
September 2023
Introduction to the Collection
This is the administrative record file for the Keddy Mill Superfund Site, Windham, ME, Record of
Decision (ROD), dated September 28, 2023. The file contains site-specific documents and a list
of guidance documents used by EPA staff in selecting a response action at the site.
This Administrative Record replaces the ROD Proposed Plan Administrative Record file release
in June 2023. This Administrative Record Index includes, by reference, the Administrative
Record for the Non-Time Critical Removal Action, issued September 2018. Documents listed as
bibliographic sources in individual reports might not be listed separately in the index.
The administrative record file is available for review at:
Online: https://go.usa.gov/xtpZe (case sensitive)
Additional information about the site is also available at www.epa.gov/superfund/keddv
SEMS Records & Information Center
U.S. EPA Region 1 - New England
5 Post Office Square, Suite 100 (mail code: 02-3)
Boston, MA 02109-3912
(617) 918-1440 (phone)
Rl.Records-SEMS@epa.gov (email)
Windham Public Library
217 Windham Center Road
Windham, Maine 04062
Phone (207) 892-1908
Fax(207) 892-1915
www.windham.lib.me.us
An administrative record is required by the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act (SARA).
Questions about this administrative record should be directed to the EPA New England
remedial project manager, Jeffry Saunders, (617) 918-1352, saunders.ieffry@epa.gov
Appendix G - Administrative Record Index and Guidance Documents
Page
-------
Keddy Mill Superfund Site Record of Decision September 2023
AR 67421 Keddy Mill Record of Decision (ROD) Administrative Record September
2023
Document
ID
677537
Title
RECORD OF DECISION (ROD)
Document
Date
09/28/2023
Page Count
208
Resource Type
Program Information
Author
Addressee
Access Control
URL
RPT / Report
053-REMEDIAL/0531-Remedy
Characterization/05.04-RECORD OF DECISION
(ROD)
R01: (US EPA REGION 1)
UCTL( Uncontrolled)
https://semsDub,eDa.gov/src/document/01/677537
677538
RESPONSIVENESS SUMMARY FOR RECORD OF DECISION
(ROD)
09/28/2023
16
RPT / Report
053-REMEDIAL/0531-Remedy
Characterization/05.03-RESPONSIVENESS
SUMMARIES
R01: (US EPA REGION 1)
UCTL( Uncontrolled)
https://semsDub.eDa.gov/src/document/01/677538
677539
LETTER REGARDING STATE CONCURRENCE FOR RECORD
OF DECISION (ROD)
09/28/2023
2
LTR / Letter
053-REMEDIAL/0531-Remedy
Characterization/O5.01-CORRESPONDENCE (ROD)
R01: Hodgkins, Nicholas J. (ME DEPT
OF ENVIRONMENTAL PROTECTION)
R01: Keefe, Daniel (US
EPA REGION 1)
UCTL( Uncontrolled)
httDs://sems Dub.eDa.gov/src/document/01/677539
100026989
EMAIL REGARDING PUBLIC COMMENT ON PROPOSED
PLAN
07/27/2023
1
EML/ Email
053-REMEDIAL/0531-Remedy
Characterization/05.03-RESPONSIVENESS
SUMMARIES
R01: Favreau, Anthony (WINDHAM
(ME) RESIDENT), R01: Favreau, Linda
(WINDHAM (ME) RESIDENT)
R01: Saunders, Jeffry
(US EPA REGION 1)
UCTL( Uncontrolled)
httDs://sems Dub.eDa.gov/src/document/Ql/lQQQ269S9
677518
REDACTED EMAIL REGARDING PUBLIC COMMENT ON
PROPOSED PLAN
07/27/2023
1
EML/ Email
053-REMEDIAL/0531-Remedy
Characterization/05.03-RESPONSIVENESS
SUMMARIES
R01: Diblasi, Tony (WINDHAM (ME)
RESIDENT)
R01: Saunders, Jeffry
(US EPA REGION 1)
UCTL( Uncontrolled)
httDs://sems Dub.eDa.gov/src/document/01/677518
677517
REDACTED EMAIL REGARDING PUBLIC COMMENT ON
PROPOSED PLAN
07/26/2023
1
EML/ Email
053-REMEDIAL/0531-Remedy
Characterization/05.03-RESPONSIVENESS
SUMMARIES
R01: Adams, Joshua (WINDHAM
(ME) RESIDENT)
R01: Saunders, Jeffry
(US EPA REGION 1)
UCTL( Uncontrolled)
httDs://sems Dub.eDa.gov/src/document/01/677517
677519
REDACTED EMAIL REGARDING PUBLIC COMMENT ON
PROPOSED PLAN (07/25/2023 EMAIL RESPONSE AND
TRANSMITTAL ATTACHED)
07/23/2023
2
EML/ Email
053-REMEDIAL/0531-Remedy
Characterization/05.03-RESPONSIVENESS
SUMMARIES
R01: Dickinson Amidon, Holly
(WINDHAM (ME) RESIDENT)
R01: Gray, Charlotte
(US EPA REGION 1)
UCTL( Uncontrolled)
httDs://sems Dub.eDa.gov/src/document/Ql/677519
100025992
PRESENTATION SLIDES FOR PUBLIC HEARING
07/18/2023
9
MTG / Meeting
Document
051-COMMUNITY INVOLVEMENT/0511-
Community Involvement Activities/13.04-PUBLIC
MEETINGS/HEARINGS
R01: (US EPA REGION 1)
UCTL( Uncontrolled)
httDs://sems Dub.eDa.gov/src/document/Ql/lQQQ25992
100026990
PROPOSED PLAN PUBLIC HEARING TRANSCRIPT
07/18/2023
10
MTG / Meeting
Document
051-COMMUNITY INVOLVEMENT/0511-
Community Involvement Activities/13.04-PUBLIC
MEETINGS/HEARINGS
R01: Bishop, Lisa (BISHOP
REPORTING INC)
UCTL( Uncontrolled)
httDs://sems Dub.eDa.gov/src/document/Ql/lQQQ2699Q
100025861
PUBLIC NOTICE AS APPEARING IN WINDHAM EAGLE: EPA
PROPOSES CLEANUP PLAN FOR THE KEDDY MILL
SUPERFUND SITE
07/14/2023
1
PUB/
Publication
051-COMMUNITY INVOLVEMENT/0511-
Community Involvement Activities/13.03-NEWS
CUPPINGS/PRESS RELEASES
R01: (US EPA REGION 1), R01:
(WINDHAM EAGLE)
UCTL( Uncontrolled)
httDs://sems Dub.eDa.gov/src/document/Ql/lQQQ25861
100025862
PUBLIC NOTICE AS APPEARING IN PORTLAND PRESS
HERALD: EPA PROPOSES CLEANUP PLAN FOR THE KEDDY
MILL SUPERFUND SITE
07/14/2023
1
PUB/
Publication
051-COMMUNITY INVOLVEMENT/0511-
Community Involvement Activities/13.03-NEWS
CUPPINGS/PRESS RELEASES
R01: (US EPA REGION 1), R01:
(PORTLAND PRESS HERALD)
UCTL( Uncontrolled)
httDs://sems Dub.eDa.gov/src/document/Ql/lQQQ25862
100025863
POSTCARD: ANNOUNCEMENT OF PUBLIC COMMENT
PERIOD ON PROPOSED PLAN, 06/28/2023 THROUGH
07/28/2023, AND PUBLIC HEARING ON 07/18/2023
06/28/2023
1
ROC / Record
of
Communication
051-COMMUNITY INVOLVEMENT/0511-
Community Involvement Activities/13.01-
CORRESPONDENCE (COMMUNITY RELATIONS)
R01: (US EPA REGION 1)
UCTL( Uncontrolled)
httDs://sems Dub.eDa.gov/src/document/Ql/lQQQ25863
Appendix G - Administrative Record Index and Guidance Documents
205
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
100025657
PRESENTATION: PUBLIC INFORMATION MEETING,
PROPOSED CLEANUP PLAN
06/27/2023
31
MTG / Meeting
Document
051-COMMUNITY INVOLVEMENT/0511-
Community Involvement Activities/13.04-PUBLIC
MEETINGS/HEARINGS
R01: (US EPA REGION 1)
UCTL( Uncontrolled)
https://semspub.epa.gOv/s rc/document/01/100025657
673685
NEWS RELEASE: EPA PROPOSES CLEANUP PLAN FOR
KEDDY MILL SUPERFUND SITE IN WINDHAM, ME
06/26/2023
2
PUB/
Publication
051-COMMUNITY INVOLVEMENT/0511-
Community Involvement Activities/13.03-NEWS
CUPPINGS/PRESS RELEASES
R01: (US EPA REGION 1)
UCTL( Uncontrolled)
https://semspub.epa.gOv/s rc/document/01/673685
100025423
DRAFT FINAL REMEDIAL INVESTIGATION (Rl) REPORT,
VOLUME 3 OF 3, FINAL ECOLOGICAL RISK ASSESSEMENT
(ERA)
06/20/2022
1015
RPT / Report
053-REMEDIAL/0531-Remedy
Characterization/03.06 - REMEDIAL
INVESTIGATION REPORTS
R01: (NOBIS GROUP)
R01: (US EPA REGION
1)
UCTL( Uncontrolled)
https://semspub.epa.gOv/s rc/document/01/100025423
673670
FLYER ANNOUNCING 06/27/2023 PUBLIC MEETING
06/19/2023
3
MTG / Meeting
Document
051-COMMUNITY INVOLVEMENT/0511-
Community Involvement Activities/13.04-PUBLIC
MEETINGS/HEARINGS
R01: (US EPA REGION 1)
UCTL( Uncontrolled)
https://semspub.epa.gOv/s rc/document/01/673670
673684
PROPOSED PLAN
06/01/2023
35
PUB/
Publication
053-REMEDIAL/0531-Remedy
Characterization/04.09 - PROPOSED PLANS FOR
SELECTED REMDIAL ACTION
R01: (US EPA REGION 1)
UCTL( Uncontrolled)
https://semspub.epa.gOv/s rc/document/01/673684
100025424
DRAFT FINAL FEASIBILITY STUDY (FS)
06/01/2022
565
RPT / Report
053-REMEDIAL/0531-Remedy
Characterization/03.06 - REMEDIAL
INVESTIGATION REPORTS
R01: (NOBIS GROUP)
R01: (US EPA REGION
1)
UCTL( Uncontrolled)
https://semspub.epa.gOv/s rc/document/01/100025424
100025422
DRAFT FINAL REMEDIAL INVESTIGATION (Rl) REPORT,
VOLUME 2 OF 3, FINAL HUMAN HEALTH RISK
ASSESSEMENT (HHRA)
06/01/2022
897
RPT / Report
053-REMEDIAL/0531-Remedy
Characterization/03.06 - REMEDIAL
INVESTIGATION REPORTS
R01: (NOBIS GROUP)
R01: (US EPA REGION
1)
UCTL( Uncontrolled)
https://semspub,epa,gov/s rc/document/01/100025422
673668
TSCA 40 CFR 761.61(C) RISK-BASED DISPOSAL
DETERMINATION, DRAFT
06/01/2023
6
RPT / Report
053-REMEDIAL/0531-Remedy
Characterization/05.04-RECORD OF DECISION
(ROD)
R01: (US EPA REGION 1)
UCTL(Uncontrolled)
https://semspub,epa,gov/s rc/document/01/673668
100023151
PAMPHLET: Q& A WITH THE EPA (LITTLE FALLS LANDING
HOUSING COMPLEX MEETING ANNOUNCEMENT)
11/30/2022
1
MTG / Meeting
Document
051-COMMUNITY INVOLVEMENT/0511-
Community Involvement Activities/13.04-PUBLIC
MEETINGS/HEARINGS
R01: (LITTLE FALLS LANDING )
UCTL( Uncontrolled)
https://semspub.epa.gOv/s rc/document/01/100023151
100022571
LETTER REGARDING COMMENTS ON DRAFT FEASIBILITY
STUDY (FS) REPORT
11/04/2022
2
LTR / Letter
053-REMEDIAL/0531-Remedy
Characterization/04.06-FEASIBILITY STUDY
REPORTS
R01: Swiecanski, Tess K (ME DEPT OF
ENVIRONMENTAL PROTECTION)
R01: Saunders, Jeffry
(US EPA REGION 1)
UCTL( Uncontrolled)
https://semspub,epa,gov/s rc/document/01/100022571
100023701
TECHNICAL MEMO REGARDING EVALUATION OFTOTAL
PCBS IN SMALLMOUTH BASS AND WHITE SUCKER IN THE
TARGET AND UPPER REACHES OF THE PRESUMPSCOT
RIVER
11/01/2022
142
MEMO/
Memorandum
053-REMEDIAL/0531-Remedy
Characterization/03.04 - INTERIM DELIVERABLES
(Rl)
R01: (NOBIS GROUP)
UCTL( Uncontrolled)
https://semspub,epa,gov/s rc/document/01/100023701
100021691
LETTER REGARDING COMMENTS ON DRAFT FEASIBILITY
STUDY (FS) REPORT
08/16/2022
2
LTR / Letter
053-REMEDIAL/0531-Remedy
Characterization/04.06-FEASIBILITY STUDY
REPORTS
R01: Swiecanski, Tess K (ME DEPT OF
ENVIRONMENTAL PROTECTION)
R01: Saunders, Jeffry
(US EPA REGION 1)
UCTL( Uncontrolled)
https://semspub.epa.gOv/s rc/doc ument/01/100021691
100023486
FACT SHEET: 08/2022 SITE UPDATE & FAQ [SPANISH
VERSION]
08/01/2022
4
PUB/
Publication
051-COMMUNITY INVOLVEMENT/0511-
Community Involvement Activities/13.05-FACT
SHEETS/INFORMATION UPDATES
R01: (US EPA REGION 1)
UCTL(Uncontrolled)
https://semspub.epa.gOv/s rc/doc ument/01/100023486
100021276
TECHNICAL MEMORANDUM: BIOTA SEDIMENT
ACCUMULATION CALCULATION
05/19/2022
34
RPT / Report
053-REMEDIAL/0531-Remedy
Characterization/03.04-1 NTERIM DELIVERABLES
(Rl)
R01: (NOBIS GROUP)
R01: (US EPA REGION
1)
UCTL( Uncontrolled)
https://semspub,epa,gov/s rc/document/01/100021276
Appendix G - Administrative Record Index and Guidance Documents
206
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
100020731
PHOTOGRAPH: SITE VISIT-SITE FIRE DOCUMENTATION
05/11/2022
45
PHT/
Photograph
053-REMEDIAL/0531-Remedy
Characterization/03.04-1 NTERIM DELIVERABLES
(Rl)
R01: (US EPA REGION 1)
UCTL( Uncontrolled)
https://semspub.epa.gOv/s rc/document/01/100020731
100020272
TOWN OF WINDHAM -TOWN COUNCIL MEETING
AGENDA
03/23/2022
4
MTG / Meeting
Document
051-COMMUNITY INVOLVEMENT/0511-
Community Involvement Activities/13.04-PUBLIC
MEETINGS/HEARINGS
R01: (TOWN OF WINDHAM, ME)
UCTL( Uncontrolled)
https://semspub.epa.gov/src/document/01/100020272
100020275
REMEDIAL INVESTIGATION/FEASIBILITY STUDY (RI/FS)
FACT SHEET
03/21/2022
3
PUB/
Publication
051-COMMUNITY INVOLVEMENT/0511-
Community Involvement Activities/13.05-FACT
SHEETS/INFORMATION UPDATES
R01: (US EPA REGION 1)
UCTL( Uncontrolled)
https://semspub.epa.gOv/s rc/document/01/100020275
100023485
FACT SHEET: REMEDIAL INVESTIGATION FEASIBILITY
STUDY (RI/FS) UPDATE [SPANISH VERSION]
03/01/2022
3
PUB/
Publication
051-COMMUNITY INVOLVEMENT/0511-
Community Involvement Activities/13.05-FACT
SHEETS/INFORMATION UPDATES
R01: (US EPA REGION 1)
UCTL( Uncontrolled)
https://semspub.epa.gOv/s rc/document/01/100023485
673671
DRAFT FINAL REMEDIAL INVESTIGATION (Rl) REPORT,
VOLUME 1 OF 3
11/01/2021
3064
RPT / Report
053-REMEDIAL/0531-Remedy
Characterization/03.06 - REMEDIAL
INVESTIGATION REPORTS
R01: (NOBIS GROUP)
R01: (US EPA REGION
1)
UCTL( Uncontrolled)
https://semspub.epa.gOv/s rc/document/01/673671
100017087
LETTER PROVIDING MEMO REGARDING STORMWATER
OBSERVATIONS FROM 05/27/2017 EVENT
12/17/2019
4
LTR / Letter
053-REMEDIAL/0531-Remedy
Characterization/O3.01-CORRESPONDENCE (Rl)
R01: Chu, Liyang (NOBIS
ENGINEERING)
R01: Mcvickar, Leslie
(US EPA REGION 1)
UCTL( Uncontrolled)
https://semspub.epa.gOv/s rc/document/01/100017087
100017118
FINAL REUSE ASSESSMENT
05/01/2018
13
RPT / Report
053-REMEDIAL/0531-Remedy
Characterization/03.04 - INTERIM DELIVERABLES
(Rl)
R01: (US EPA REGION 1)
UCTL(Uncontrolled)
https://semspub,epa,gov/s rc/document/01/100017118
100017152
LETTER REGARDING NO HISTORIC PROPERTIES AFFECTED
BY SITE BEING ADDED TO THE NATIONAL PRIORITIES LIST
(NPL)
07/27/2017
1
LTR / Letter
053-REMEDIAL/0531-Remedy
Characterization/16.01-CORRESPONDENCE
(NATURAL RESOURCE TRUSTEE)
R01: Mohney, Kirk F (ME HISTORIC
PRESERVATION COMMISSION)
R01: Cyr, Rosemary A
(UNIVERSITY OF
MAINE AT
FARMINGTON)
UCTL( Uncontrolled)
https://semspub.epa.gOv/s rc/document/01/100017152
100017085
FACT SHEET-SITE UPDATE
02/01/2016
2
PUB/
Publication
051-COMMUNITY INVOLVEMENT/0511-
Community Involvement Activities/13.05-FACT
SHEETS/INFORMATION UPDATES
R01: (US EPA REGION 1)
UCTL(Uncontrolled)
https://semspub,epa,gov/s rc/document/01/100017085
594988
NEWS RELEASE: EPA TO BEGIN SITE INVESTIGATION AT
SUPERFUND SITE IN WINDHAM, ME
10/26/2015
1
PUB/
Publication
051-COMMUNITY INVOLVEMENT/0511-
Community Involvement Activities/13.03-NEWS
CUPPINGS/PRESS RELEASES
R01: (US EPA REGION 1)
UCTL(Uncontrolled)
https://semspub.epa.gOv/s rc/document/01/594988
100022081
PUBLIC HEALTH ASSESSMENT
08/18/2015
33
RPT / Report
053-REMEDIAL/0531-Remedy
Characterization/03.09-HEALTH ASSESSMENTS
R01: (US DEPT OF HEALTH AND
HUMAN SERVICES - AGENCY FOR
TOXIC SUBSTANCES AND DISEASE
REGISTRY (ATSDR))
UCTL( Uncontrolled)
https://semspub.epa.gOv/s rc/document/01/100022081
574628
SITE DESCRIPTION ACCOMPANYING NATURAL
RESOURCE TRUSTEE NOTIFICATION LETTERS
04/22/2015
6
RPT / Report
053-REMEDIAL/0531-Remedy
Characterization/16.01-CORRESPONDENCE
(NATURAL RESOURCE TRUSTEE)
R01: (US EPA REGION 1)
UCTL(Uncontrolled)
https://semspub.epa.gOv/s rc/document/01/574628
574629
NATURAL RESOURCE TRUSTEE NOTIFICATION OF
NATIONAL PRIORITIES LISTING (NPL) - PENOBSCOT
INDIAN NATION
04/22/2015
1
LTR / Letter
053-REMEDIAL/0531-Remedy
Characterization/16.01-CORRESPONDENCE
(NATURAL RESOURCE TRUSTEE)
R01: Mcvickar, Leslie (US EPA
REGION 1)
R01: Sockalexis, Chris
(PENOBSCOT INDIAN
NATION)
UCTL( Uncontrolled)
https://semspub.epa.gOv/s rc/doc ument/01/574629
574630
NATURAL RESOURCE TRUSTEE NOTIFICATION OF
NATIONAL PRIORITIES LISTING (NPL) - HOULTON BAND
OF MALISEET INDIANS
04/22/2015
1
LTR / Letter
053-REMEDIAL/0531-Remedy
Characterization/16.01-CORRESPONDENCE
(NATURAL RESOURCE TRUSTEE)
R01: Mcvickar, Leslie (US EPA
REGION 1)
R01: Venno, Sharri
(HOULTON BAND OF
MALISEET INDIANS)
UCTL( Uncontrolled)
https://semspub.epa.gOv/s rc/document/01/574630
Appendix G - Administrative Record Index and Guidance Documents
207
-------
Keddy Mill Superfund Site
Record of Decision
September 2023
574631
NATURAL RESOURCE TRUSTEE NOTIFICATION OF
NATIONAL PRIORITIES LISTING (NPL) -
PASSAMAQUODDYTRIBE OF INDIANS
04/22/2015
1
LTR / Letter
053-REMEDIAL/0531-Remedy
Characterization/16.01-CORRESPONDENCE
(NATURAL RESOURCE TRUSTEE)
R01: Mcvickar, Leslie (US EPA
REGION 1)
R01: Soctomah,
Donald
(PASSAMAQUODDY
INDIAN TRIBE, INDIAN
TOWNSHIP
RESERVATION)
UCTL( Uncontrolled)
https://semspub.epa.gOv/s rc/document/01/574631
574632
NATURAL RESOURCE TRUSTEE NOTIFICATION OF
NATIONAL PRIORITIES LISTING (NPL) - AROOSTOOK
BAND OF MICMACS
04/22/2015
1
LTR / Letter
053-REMEDIAL/0531-Remedy
Characterization/16.01-CORRESPONDENCE
(NATURAL RESOURCE TRUSTEE)
R01: Mcvickar, Leslie (US EPA
REGION 1)
R01: Pictou, Jennifer
(AROOSTOOK BAND
OF MICMACS)
UCTL( Uncontrolled)
https://semspub.epa.gOv/s rc/document/01/574632
574633
NATURAL RESOURCE TRUSTEE NOTIFICATION OF
NATIONAL PRIORITIES LISTING (NPL) - ME HISTORIC
PRESERVATION COMMISSION
04/22/2015
1
LTR / Letter
053-REMEDIAL/0531-Remedy
Characterization/16.01-CORRESPONDENCE
(NATURAL RESOURCE TRUSTEE)
R01: Mcvickar, Leslie (US EPA
REGION 1)
R01: Shettleworth,
EarleG (ME HISTORIC
PRESERVATION
COMMISSION)
UCTL( Uncontrolled)
https://semspub.epa.gOv/s rc/document/01/574633
574634
NATURAL RESOURCE TRUSTEE NOTIFICATION OF
REMEDIAL INVESTIGATION/FEASIBILITY STUDY (RI/FS)
START - US NATIONAL OCEANIC AND ATMOSPHERIC
ASSOCIATION (NOAA)
04/22/2015
1
LTR / Letter
053-REMEDIAL/0531-Remedy
Characterization/16.01-CORRESPONDENCE
(NATURAL RESOURCE TRUSTEE)
R01: Mcvickar, Leslie (US EPA
REGION 1)
R01: Finkelstein,
Kenneth (US
NATIONAL OCEANIC
ANDATMOSPHERIC
ADMINISTRATION)
UCTL( Uncontrolled)
https://semspub.epa.gOv/s rc/document/01/574634
574635
NATURAL RESOURCE TRUSTEE NOTIFICATION OF
REMEDIAL INVESTIGATION/FEASIBILITY STUDY (RI/FS)
START - US DEPTOFTHE INTERIOR (DOI)
04/22/2015
1
LTR / Letter
053-REMEDIAL/0531-Remedy
Characterization/16.01-CORRESPONDENCE
(NATURAL RESOURCE TRUSTEE)
R01: Mcvickar, Leslie (US EPA
REGION 1)
R01: Raddant, Andrew
(US DEPTOF
INTERIOR)
UCTL( Uncontrolled)
https://semspub,epa,gov/s rc/doc ument/01/574635
75001041
STATE/TRIBAL CORRESPONDENCE REGARDING STATE OF
MAINE CONCURRENCE WITH THE LISTING OF THE KEDDY
MILL SITE ON THE NATIONAL PRIORITIES LIST (NPL)
07/01/2013
1
LTR / Letter
055-SITE EVALUATION/O551-Pre-Remedial Site
Evaluation/01.05-CORRESPONDENCE (SITE
ASSESSMENT)
R01: Lepage, Paul R (ME GOVERNOR)
R01: Perciasepe,
Robert (US EPA)
UCTL(Uncontrolled)
https://semspub.epa.gOv/s rc/doc ument/01/7501041
538512
NEWS ADVISORY: PUBLIC MEETING ON 05/30/2013 FOR
KEDDY MILL SITE IN WINDHAM, MAINE AT WINDHAM
TOWN COUNCIL CHAMBERS
05/22/2013
1
PUB/
Publication
051-COMMUNITY INVOLVEMENT/0511-
Community Involvement Activities/13.03-NEWS
CUPPINGS/PRESS RELEASES
R01: (US EPA REGION 1)
UCTL(Uncontrolled)
https://semspub,epa,gov/s rc/doc ument/01/538512
534236
MEMO REGARDING WETLANDS DELINEATION ACTIVITIES
08/01/2012
3
MEMO/
Memorandum
053-REMEDIAL/0531-Remedy
Characterization/03.04 - INTERIM DELIVERABLES
(Rl)
R01: Mcgrath, Denis F (NOBIS
ENGINEERING INC)
R01: Bosworth,
Martha (US EPA
REGION 1)
UCTL(Uncontrolled)
https://semspub,epa,gov/s rc/doc ument/01/534236
534237
MEMO REGARDING WETLANDS DELINEATION ACTIVITIES
- APPENDIX A
08/01/2012
6
MEMO/
Memorandum
053-REMEDIAL/0531-Remedy
Characterization/03.04 - INTERIM DELIVERABLES
(Rl)
R01: Mcgrath, Denis F (NOBIS
ENGINEERING INC)
R01: Bosworth,
Martha (US EPA
REGION 1)
UCTL(Uncontrolled)
https://semspub.epa.gOv/s rc/doc ument/01/534237
534238
MEMO REGARDING WETLANDS DELINEATION ACTIVITIES
-APPENDIX B - FIGURES
08/01/2012
5
MEMO/
Memorandum
053-REMEDIAL/0531-Remedy
Characterization/03.04 - INTERIM DELIVERABLES
(Rl)
R01: Mcgrath, Denis F (NOBIS
ENGINEERING INC)
R01: Bosworth,
Martha (US EPA
REGION 1)
UCTL(Uncontrolled)
https://semspub,epa,gov/s rc/doc ument/01/534238
534239
MEMO REGARDING WETLANDS DELINEATION ACTIVITIES
- APPENDIX C - EPA MAPPED WETLAND FRONTAGE
ALONG THE PRESUMPSCOT RIVER BETWEEN LITTLE
FALLS AND MALLISON FALLS
08/01/2012
2
MEMO/
Memorandum
053-REMEDIAL/0531-Remedy
Characterization/03.04 - INTERIM DELIVERABLES
(Rl)
R01: Mcgrath, Denis F (NOBIS
ENGINEERING INC)
R01: Bosworth,
Martha (US EPA
REGION 1)
UCTL(Uncontrolled)
https://semspub.epa.gOv/s rc/doc ument/01/534239
534240
MEMO REGARDING WETLANDS DELINEATION ACTIVITIES
-APPENDIX D - PHOTOLOG
08/01/2012
4
MEMO/
Memorandum
053-REMEDIAL/0531-Remedy
Characterization/03.04 - INTERIM DELIVERABLES
(Rl)
R01: Mcgrath, Denis F (NOBIS
ENGINEERING INC)
R01: Bosworth,
Martha (US EPA
REGION 1)
UCTL(Uncontrolled)
https://semspub,epa,gov/s rc/doc ument/01/534240
Appendix G - Administrative Record Index and Guidance Documents
208
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