phase i environmental site assessment fpl energy

PHASE I ENVIRONMENTAL SITE ASSESSMENT FPL ENERGY MAINE HYDRO, LLC PARCEL

MAP 71, LOT 8 LACONIA STREET, BIDDEFORD, MAINE

Prepared for:

City of Biddeford P.O. Box 586

Biddeford, Maine

Prepared by:

Ransom Consultants, Inc. 400 Commercial Street, Suite 404

Portland, Maine 04101 (207) 772-2891

Project 111.06115 October 31, 2011

Ransom Project 111.061165 Page 1 of 2 P:\2011\111.06115\Phase I ESA\Final Text.doc October 31, 2011

EXECUTIVE SUMMARY

The following report presents the findings of a Phase I Environmental Site Assessment (ESA) performed by Ransom Consultants, Inc. (Ransom) for the FPL Energy Maine Hydro, LLC Parcel located on Laconia Street in Biddeford, York County, Maine and referenced by the City of Biddeford Assessors Office as Map 71, Lot 8 (the Site). This Phase I ESA was performed in general accordance with the requirements of the American Society for Testing and Materials (ASTM) International Designation: E 1527-05, Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process, which meets the requirements of the United States Environmental Protection Agency (EPA) All Appropriate Inquiry (AAI), 40 CFR Part 312 . The purpose of this Phase I ESA was to document the environmental history of the Site, evaluate the likelihood that a release of oil and/or hazardous material (OHM) has occurred or has the potential to impact the Site, and to provide our professional opinion regarding evidence of Recognized Environmental Conditions (RECs) in connection with the Site.

The Site, located on the western bank of the Saco River, is currently vacant. It is abutted on the remaining three sides by former mill buildings, which have or are currently being redeveloped as mixed-use commercial/residential space. Based on available information, the Site was formerly utilized as part of the River Dam Mill. From the late 1800s until the mid/late 1900s, the Site was developed with mill structures and may have been used for storage, production, or transportation of goods. A machine shop was also formerly located in the southern portion of the Site. According to City personnel, in the late 1900s, the Site may have been used by Central Maine Power (CMP) to store electrical transformers. The Subject Area has been used for industrial purposes, since its development in the 1800s. Area buildings are connected to municipal water and sewer, provided by the City of Biddeford.

As part of Ransoms assessment of the Site, Environmental Data Resources, Inc. (EDR) conducted an environmental database search. Ransom also reviewed the Maine Department of Environmental Protection (MEDEP) online databases. The Site was not identified in the EDR Report; nor was it identified in any MEDEP online databases.

The three adjacent properties located west, north, and south of the Site have historically been industrial/mill sites: the former River Dam Mill (up and side-gradient), former WestPoint Stevens Mill Building 11 (up and side-gradient), and North Dam Mill, formerly part of the WestPoint Stevens Mill complex (side-gradient). Although remediation activities in accordance with the MEDEP Voluntary Response Action Program (VRAP) are in various stages for these three properties; the historic use, storage, and possible releases of oil and/or hazardous materials at the up-gradient River Dam Mill and WestPoint Stevens Mill properties may have had the potential to adversely impact the Site. Subsurface investigations completed at the River Dam Mill have revealed heavy metals, semi-volatile organic compounds (SVOCs), benzo(a)pyrene, and diesel range organics (DRO) in surficial and subsurface soil samples at concentrations above applicable MEDEP Remedial Action Guidelines and/or Cleanup Goals. Historic environmental investigations at the WestPoint Stevens Mill have previously documented the use and/or release of several chemicals including DRO, volatile organic compounds, chlorinated solvents (trichloroethylene and its degradation products), polycyclic aromatic hydrocarbons (PAHs), and metals.

We have performed a Phase I ESA in general conformance with the scope and limitations of ASTM Practice E 1527-05 and Ransoms Scope of Work, dated August 31, 2011, for the property identified by the City of Biddeford Assessors Office as Tax Map 71, Lot 8, located on Laconia Street in the City of Biddeford, York County, Maine. Any exceptions to, or deletions from, this practice are

Ransom Project 111.061165 Page 2 of 2 P:\2011\111.06115\Phase I ESA\Final Text.doc October 31, 2011

described in Section 1.4 of this report. Based on the information obtained during this Phase I ESA, Ransom has identified the following RECs in connection with the Site:

1. Prior environmental investigations completed at adjacent and up-gradient properties (former River Dam Mill and WestPoint Stevens Mill) identified heavy metals, VOCs, SVOCs, DRO, PAHs, and DRO in surficial and subsurface soils at concentrations which exceed applicable MEDEP Remedial Action Guidelines and/or Cleanup Goals. Due to the fact that these investigations were completed directly up-gradient and in close proximity from the Site, it is likely that the surficial and/or subsurface conditions found at the River Dam and WestPoint Stevens properties are consistent with those found at the Site.

2. City and FPL personnel indicated that CMP may have formerly stored electrical transformers on-Site. FPL indicated that an environmental report documenting potential environmental conditions, as a result of this activity may exist; however, FPL representatives were unable to locate a copy of the report for review as part of this assessment. Improperly stored transformers may represent the threat of release of polychlorinated biphenyls (PCBs) onto the surface or into the subsurface.

3. Stormwater discharge pipes were observed in the central portion of the property. City personnel indicated that the stormwater from the adjacent mill complex(es) was collected and discharged onto the Site through this subsurface collection system. There is the potential that historic and existing spills, releases, and poor housekeeping practices at the adjacent mill facilities have allowed pollutants to be discharged through the stormwater collection system and onto the Site.

Based on the information obtained during this assessment, Ransom concludes that additional investigation is warranted. Specifically, Ransom recommends the following:

1. A limited subsurface and/or surface soil investigation should be performed to determine whether the Site has been impacted from historic industrial operations conducted on the site, historic industrial operations conducted on adjacent and up-gradient properties, the potential for releases associated with electrical transformers, which may have been historically stored on-Site, and the potential for releases associated with the stormwater discharge points on-Site.

2. Prior to any site redevelopment activities, Ransom recommends the development of a Soil Management Plan to address necessary actions in the event contaminated soil is encountered during Site redevelopment.

3. Depending on the results of the recommended limited subsurface and/or surficial soil investigation noted above, a deed restriction may need to be developed, requiring that certain site use conditions/covenants be imposed on the property, such as prohibiting/managing the excavation of on-Site soils and/or prohibiting groundwater extraction.

4. The Site should be entered into the MEDEP VRAP. The VRAP would allow for MEDEP review and approval of the assessment actions performed, and assuming the MEDEP concurs with the actions conducted at the site, would provide for liability protection under 38 M.R.S.A. 342 (15) and 343-E. Upon submission of a Site Closure Report, and subsequent approval of the VRAP Application, the MEDEP would issue a No Further Action letter to the applicant.

TABLE OF CONTENTS

1.0 INTRODUCTION ......................................................................................................................... 1 1.1 Purpose ............................................................................................................................... 1 1.2 Scope of Work .................................................................................................................... 1 1.3 Significant Assumptions ..................................................................................................... 2 1.4 Limitations, Exceptions, and Deviations ............................................................................ 2 1.5 Special Terms and Conditions ............................................................................................ 3 1.6 User Reliance...................................................................................................................... 3

2.0 PROJECT LOCATION/DESCRIPTION ................................................................................... 4 2.1 Location and Legal Description.......................................................................................... 4 2.2 Site and Vicinity Characteristics......................................................................................... 4 2.3 Current Use of the Property ................................................................................................ 4 2.4 Description of Structures, Roads, Other Improvements on the Property............................ 4 2.5 Physical Setting................................................................................................................... 4

3.0 USER PROVIDED INFORMATION.......................................................................................... 6 3.1 Title Records....................................................................................................................... 6 3.2 Environmental Liens or Activity and Use Limitations (AULs).......................................... 6 3.3 Specialized Knowledge....................................................................................................... 6 3.4 Commonly Known or Reasonably Ascertainable Information........................................... 6 3.5 Valuation Reduction for Environmental Issues .................................................................. 6 3.6 Owner, Property Manager, and Occupant Information....................................................... 6 3.7 Reason for Performing Phase I ESA................................................................................... 6 3.8 Previous Environmental Reports ........................................................................................ 6

4.0 SITE HISTORY............................................................................................................................. 7

5.0 ADJOINING PROPERTIES ........................................................................................................ 8 5.1 Historical Use Information for Adjoining Properties ......................................................... 8 5.2 Current Adjoining Properties and Potential Environmental Impact ................................... 8

6.0 RECORDS REVIEW .................................................................................................................. 11 6.1 Standard Environmental Record Sources ......................................................................... 11 6.2 Additional Environmental Record Sources ...................................................................... 16 6.3 Chain of Title .................................................................................................................... 17

7.0 SITE RECONNAISSANCE........................................................................................................ 18 7.1 Methodology and Limiting Conditions............................................................................. 18 7.2 General Site Setting and Observations ............................................................................. 18 7.3 Exterior Observations ....................................................................................................... 19

8.0 INTERVIEWS ............................................................................................................................. 20 8.1 Past and Present Site Owners............................................................................................ 20 8.2 Local Government Officials ............................................................................................. 20

9.0 SUMMARY OF KEY FINDINGS ............................................................................................. 21

10.0 DATA GAPS ................................................................................................................................ 22

11.0 CONCLUSIONS AND OPINIONS............................................................................................ 23

12.0 RECOMMENDATIONS............................................................................................................. 24

13.0 ADDITIONAL SERVICES AND NON-SCOPE CONSIDERATIONS ................................. 25 13.1 Additional Services........................................................................................................... 25 13.2 Non-Scope Considerations ............................................................................................... 25

14.0 REFERENCES............................................................................................................................. 26

15.0 SIGNATURE(S) OF ENVIRONMENTAL PROFESSIONAL(S) .......................................... 27 FIGURES

Figure 1: Site Location Map Figure 2: Site Plan

APPENDICES

Appendix A: Photograph Log Appendix B: EDR Radius Map with GeoCheck Report Appendix C: Historical Topographic Maps, Sanborn Maps, and Aerial Photographs Appendix D: Supplemental Documentation Appendix E: Qualifications

Ransom Project 111.06115 Page 1 P:\2011\111.06115\Phase I ESA\Final Text.doc October 31, 2011

1.0 INTRODUCTION

The following report presents the findings of a Phase I Environmental Site Assessment (ESA) performed by Ransom Consultants, Inc. (Ransom) for the FPL Energy Maine Hydro, LLC (FPL) Parcel, located on Laconia Street in the City of Biddeford, York County, Maine and referenced by City Assessors Office as Map 71, Lot 8 (the Site). The Phase I ESA was prepared for the City of Biddeford. Refer to the appended Figure 1, Site Location Map, to view the general location of the Site on a 7.5-minute topographic quadrangle.

1.1 PURPOSE

The purpose of this Phase I ESA was to assess the environmental condition of the Site by performing all appropriate inquiry into the previous ownership and uses of the Site consistent with good commercial or customary practice, taking into account commonly known and reasonably ascertainable information. The goal of the assessment was to identify recognized environmental conditions (RECs) in connection with the Site. The term REC is defined as:

The presence or likely presence of any hazardous substances or petroleum products on a property under conditions that indicate an existing release, a past release, or a material threat of a release of any hazardous substances or petroleum products into structures on the property or into the ground, ground water, or surface water of the property. The term includes hazardous substances or petroleum products even under conditions in compliance with laws. The term is not intended to include de minimis conditions that generally do not present a threat to human health or the environment and that generally would not be the subject of an enforcement action if brought to the attention of appropriate governmental agencies.

By performing a Phase I ESA of a parcel of real estate with respect to the range of contaminants within the scope of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) (42 U.S.C. 9601) and petroleum products, a user satisfies one of the requirements to qualify for the innocent landowner, contiguous property owner, or bona fide prospective purchaser limitations on CERCLA liability.

1.2 SCOPE OF WORK

This Phase I ESA was performed in general accordance with the requirements of the American Society for Testing and Materials International Designation: E 1527-05, Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process, 2005 (ASTM Standard Practice), United States Environmental Protection Agency (EPA) All Appropriate Inquiry (AAI), 40 CFR Part 312, and Ransoms Scope of Work with the City of Biddeford, executed August 31, 2011, and included the completion of the following tasks:

Review municipal records and search state and federal environmental databases for sites or conditions of environmental concern;

Review historical land use records to evaluate past use of the Site and adjoining properties;


Perform a site reconnaissance to visually and/or physically observe current conditions of the Site and the general land use of surrounding properties; and

Conduct interviews with readily available past and present owners, operators, and occupants of the Site.

1.3 SIGNIFICANT ASSUMPTIONS

No significant assumptions were made during the performance of this Phase I ESA.

1.4 LIMITATIONS, EXCEPTIONS, AND DEVIATIONS

Along with the limitations set forth in various sections of the ASTM Standard Practice E 1527-05 protocol, the accuracy and completeness of this report is limited by the following:

Access LimitationsImmediately prior to the Site reconnaissance, there was a significant storm event which caused the Saco River to rise above the concrete walls which comprised the eastern edge (retaining wall) of the Site. This flooding undermined underground utilities on-Site, and left exposed pipes, structures and unstable ground surfaces; as such, the northern-most extent of the property was not observed. This portion of the Site was observed from a safe location in the central portion of the property. Based on the history of the Site, and the observations made from the central portion of the Site, we do not anticipate this access limitation represents a significant concern warranting additional investigation.

Physical Obstructions to ObservationsNone

Outstanding Information RequestsBased on conversations with City of Biddeford and FPL personnel, it is our understanding that Central Maine Power (CMP) may have formerly stored electrical transformers on the Site. FPL indicated that an environmental report documenting potential environmental conditions, as a result of this activity may exist; however, FPL representatives were unable to locate a copy of the report for review as part of this assessment. This potential environmental concern has been discussed in pertinent sections of this report, and a conclusion/recommendation has been made to perform additional environmental investigation regarding this matter.

Historical Data Source Failure Reasonably ascertainable historical information sources allowed uses of the Site to be traced from the present back to 1893, at which time the area surrounding the Site was shown on a topographic map to be developed (it is unclear what type of structure may have been located at the Site, but it was likely mill or mill-related). This 1893 topographic map post-dates the propertys obvious first developed use and constitutes historical data failure per ASTM Standard Practice E 1527-05 8.3.2.3. However, based on the identified nature of development and use at the time and since the area has a long history of use as a mill district, the historical data failure/data gap does not appear to represent a significant concern, above and beyond the known environmental concerns for the Mill district, warranting additional investigation beyond those recommendations provided herein.

Exceptions or DeviationsNone

OtherNone


The findings provided by Ransom in this report are based solely on the information reported in this document. Should additional information become available in the future, this information can be reviewed by Ransom and the findings presented herein may be modified as a result of the review. It should be noted that information obtained from state and local agencies is not necessarily all-inclusive and that files may have been reviewed and purged by officials prior to review by the public.

1.5 SPECIAL TERMS AND CONDITIONS

This Phase I ESA was conducted in accordance with our executed Scope of Work, executed August 31, 2011. Authorization to perform this Phase I ESA was provided by the City of Biddeford.

1.6 USER RELIANCE

The services and the contents of any project reports and associated documents provided to the client by Ransom are solely for the benefit of the City of Biddeford, their affiliates and subsidiaries and their successors, assigns, and grantees. Reliance or any use of this report by anyone other than the City of Biddeford, for whom it was prepared, is prohibited. Reliance or use by any such third party without explicit authorization in the report does not make said third party a third party beneficiary to Ransoms contract with the City of Biddeford. Any such unauthorized reliance on or use of this report, including any of its information or conclusions, will be at the third party's risk. For the same reasons, no warranties or representations, expressed or implied in this report, are made to any such third party.


2.0 PROJECT LOCATION/DESCRIPTION

2.1 LOCATION AND LEGAL DESCRIPTION

The Site is located on Laconia Street in the City of Biddeford, York County, Maine. The Site is identified by the City of Biddeford Assessors Office as Lot 8 on Tax Map 71. A Site Location Map and Site Detail Plan are included as Figure 1 and Figure 2, respectively.

2.2 SITE AND VICINITY CHARACTERISTICS

The Site is located within the Mill Distinct in the City of Biddeford (High Density/Mixed Use Zone- MSRD3), on the western banks of the Saco River. Land use in the vicinity of the Site is primarily commercial and industrial, and the Site is abutted on three sides by mills: River Dam Mill to the north and west, WestPoint Stevens Mill to the south and west, and North Dam Mill to the south. Land located west and southwest of the Site is located within the Citys General Business zone (B1). Land located south of the Site is located within the Citys Commercial Core zone (MSRD1). Land along the riverbank northeast of the Site is zoned General Development (GD).

A Site Plan and photograph log are included as Figure 2 and Appendix A (Photograph Log), respectively.

2.3 CURRENT USE OF THE PROPERTY

The Site is currently vacant. Please refer to the appended Site Figure (Figure 2) and Photograph Log (Appendix A) for the location of key site features.

2.4 DESCRIPTION OF STRUCTURES, ROADS, OTHER IMPROVEMENTS ON THE PROPERTY

The Site is currently vacant. The eastern boundary of the property is defined by a concrete wall, which is part of a dam structure in the Saco River. There is a concrete pad in the southern portion of the property, which was likely the location of former mill structures. There are no structures, roads or other improvements on the Site.

2.5 PHYSICAL SETTING

2.5.1 Topography

The topography of the Site is generally flat and sloping downward to the east and northeast toward the Saco River. Based on the Biddeford, Maine USGS Quadrangle and data reported by EDR, the general elevation of the Site is 34 feet above the National Geodetic Vertical Datum. The general topography of properties located near the Site is generally sloping downward to the east or northeast toward the Saco River. The Site is immediately down-gradient from both the WestPoint Stevens Mill and the River Dam Mill.

2.5.2 Soils/Geology

According to information provided in the EDR Report, soils in the vicinity of the Site are identified by the U.S. Department of Agriculture Soil Conservation Service as urban land. The soils are characterized as moderately well drained. Depth to the water table is generally greater than ten feet below grade.


As mapped by the Maine Geological Survey (MGS), surficial geology in the vicinity of the Site consists of glaciomarine deposits, comprised of silt, clay, sand, and minor amounts of gravel, as well as till, a mixture of sand, silt, clay, and stones (possibly boulders).

According to previous environmental investigations at adjacent properties, the surficial materials in the Site area consisted predominantly of fill. Bedrock was encountered at approximately 11 to 12 feet below ground surface.

The EDR report states the depth to bedrock in the vicinity of the Site can be as shallow as surface grade. The bedrock stratigraphic unit underlying the Site and vicinity, as detailed in the EDR Report, is categorized as Eugeosynclinal deposits of the Paleozoic Era. Bedrock in the vicinity of the Site is mapped by MGS as calcareous feldspathic sandstone of the Berwick formation. Bedrock outcrops were observed in the river bed adjacent to the Site and have historically been observed withing the basement areas of several adjacent former mill buildings.

2.5.3 Surface Water Bodies/Floodplains

The closest surface water body to the Site is the Saco River located adjacent and east of the Site. Based on York County, Maine flood zone data provided by the Federal Emergency Management Agency (FEMA), areas along the riverbank are located within 100-year and 500-year flood zones.

2.5.4 Hydrogeology

Based on site observations, Site topography, and information provided in the EDR Report, regional groundwater at the Site is inferred to flow generally east-northeast toward the Saco River.


3.0 USER PROVIDED INFORMATION

3.1 TITLE RECORDS

No title records in connection with the Site were provided by The City of Biddeford. No environmental liens or activity/use restrictions regarding the Site were obtained by Ransom.

3.2 ENVIRONMENTAL LIENS OR ACTIVITY AND USE LIMITATIONS (AULS)

No environmental liens or activity/use restrictions in connection with the Site were identified by the City of Biddeford.

3.3 SPECIALIZED KNOWLEDGE

No specialized knowledge in connection with the Site was provided by the City of Biddeford.

3.4 COMMONLY KNOWN OR REASONABLY ASCERTAINABLE INFORMATION

No commonly known or reasonably ascertainable information about the Site that is material to RECs in connection with the Site was provided by the City of Biddeford.

3.5 VALUATION REDUCTION FOR ENVIRONMENTAL ISSUES

The City of Biddeford did not identify a reduction in the purchase price, as compared to the fair market value, that was due to the Site being impacted by hazardous substances or petroleum products.

3.6 OWNER, PROPERTY MANAGER, AND OCCUPANT INFORMATION

It is our understanding that the City has provided Ransom with available information pertinent to RECs in connection with the Site.

3.7 REASON FOR PERFORMING PHASE I ESA

This Phase I ESA was performed to support The City of Biddefords environmental due diligence of the Site.

3.8 PREVIOUS ENVIRONMENTAL REPORTS

No previous environmental reports for the Site were provided or discovered during this Phase I ESA; however, based on discussions with City and FPL personnel, there is the potential that an environmental report/investigation may have been performed at the Site by CMP to address the potential for environmental contamination caused by the potential storage of electrical transformers on-Site. However, FPL representatives were unable to locate a copy of the report for review as part of this assessment.

Abutting properties, including the up-gradient River Dam Mill, the up-gradient WestPoint Stevens Mill, and the down/side-gradient North Dam Mill have been the subject of numerous environmental investigations, subsurface investigations, and remedial action planning. These reports were reviewed, and pertinent information has been included throughout this report.


4.0 SITE HISTORY

The history of the Site was researched to ascertain past use from the present back to the propertys first developed use, or back to 1940, whichever was earlier. Reasonably ascertainable historical information sources researched in this assessment allowed uses of the Site to be traced from the present back to 1893, at which time the area surrounding the Site was shown on a topographic map to be developed (it is unclear what type of structure may have been located at the Site, but it likely was mill-related). This 1893 topographic map post-dates the propertys obvious first developed use and constitutes historical data failure per ASTM Standard Practice E 1527-05 8.3.2.3. The following standard historical sources were reviewed by Ransom:

Environmental reports and remedial action plans prepared for the adjacent and up-gradient properties, including the River Dam Mill, WestPoint Stevens Mill, and North Dam Mill;

Historical topographic maps dated 1893, 1944, 1956, and 1970 (Appendix C);

Aerial photographs dated 1960, 1975, 1986, 1991, 1998, and 2006 (Appendix C);

Sanborn Fire Insurance Maps dated 1932, 1947, and 1976 (Appendix C);

Information reviewed at the City of Biddeford Municipal Offices.

The following table presents a summary of the historical use of the Site over time.

Year(s) Property Use and Observed Details Reference Source

1840 A dam was constructed on the Saco River, defining the limits of the river and Site. The dam underwent major renovations in 1937-1938. Historic Tax Card

1932 to 1947

The Site is improved with several structures as part of the River Dam Mill. These structures are labeled: Building No. 14-B, Storage No. 33,

Building No. 15, and a wheel house. It appears that these buildings may have extended over the Saco River.

Sanborn Maps

1976 The Site is improved with a single building, labeled 14-B. This

building is connected to the River Dam Mill, and appears to extend over the Saco River.

Sanborn Maps

Unknown

A landscape plan prepared in 2009 by Archetype Architects shows an old machine shop in the southern portion of the Site. It is unclear based on this plan when this structure was constructed or removed.

The concrete pad observed during the Site Reconnaissance is generally located in the same location as this old machine shop. See Appendix

D for a copy of this plan.

Landscape Plan, 2009


5.0 ADJOINING PROPERTIES

5.1 HISTORICAL USE INFORMATION FOR ADJOINING PROPERTIES

Historical uses of the adjoining properties to the Site were identified in the standard historical sources listed above.

5.2 CURRENT ADJOINING PROPERTIES AND POTENTIAL ENVIRONMENTAL IMPACT

As part of Ransoms reconnaissance, observations were made of adjoining properties from the Site or public right-of-ways. Observations included current use of adjoining properties and potential visible evidence of environmental impacts.

East: The Site is bordered to the east the Saco River.

West: The Site is bordered to the west by the Mill at Saco Falls (formerly a portion of the River Dam Mill, and further, by the former River Dam and WestPoint Stevens Mills.

North: The Site is bordered to the north by the Mill at Saco Falls (formerly a portion of the River Dam Mill.

South: The Site is bordered to the south by the former WestPoint Stevens Mill, and further, by the North Dam Mill.

The three adjacent properties located west, north, and south of the Site have historically been industrial/mill sites: the Mill at Saco Falls (formerly a portion of the River Dam Mill), up and side-gradient; former WestPoint Stevens Mill, up and side-gradient; and North Dam Mill, side-gradient. Although remediation activities in accordance with the Maine Department of Environmental Protection (MEDEP) Voluntary Response Action Program (VRAP) are in various stages for the River Dam Mill, North Dam Mill, and former WestPoint Stevens Mill properties; the historic use, storage, and possible releases of oil and/or hazardous materials at the up-gradient River Dam Mill and WestPoint Stevens Mill properties may have had the potential to adversely impact the Site. The following paragraphs present a summary of environmental conditions at these properties.

Mill at Saco Falls (formerly a portion of the River Dam Mill): The Mill at Saco Falls was formerly a portion of the River Dam Mill and has been redeveloped as mixed-use. The River Dam Mill was used for cotton textile manufacturing from the mid-1800s until the early 1920s, at which time it was used for electronics manufacturing, storage, valve manufacturing and auto machine shops. In the 1970s, manufacturing ceased and the building was used as storage space. Former site assessments identified RECs in connection with the property, including: several MEDEP spill reports documented for the property; former and improperly-removed USTs; an up-gradient municipal solid waste facility (Maine Energy Recovery Company) with 25 associated MEDEP spill reports; and the potential presence of lead-based paint and asbestos-containing building materials.


The River Dam Mill site was identified by EDR as a UST site, a LUST site, a Brownfields site, and a VCP site. Four USTs were formerly maintained on the River Dam Mill site, including two 10,000-gallon No. 4 fuel oil USTs that were installed in 1977 and removed in 2000; one 6,000-gallon No. 4 fuel oil UST that was installed in 1969 and removed in 1997; and one 1,000-gallon No. 2 fuel oil UST that was installed in 1977 and removed in 1997. According to MEDEP Spill Report P-116-1997, observations of waste drums at the River Dam property were reported in March 1997. Approximately 21 unlabeled drums were identified in the lower basement of the mill building. The drums were in poor condition and had reportedly been moved to the basement in 1993.

Subsurface investigations completed in the northeastern portion of the property have revealed concentrations of heavy metals, benzo(a)pyrene, and diesel range organics (DRO) above applicable MEDEP Cleanup Goals. There have also been subsurface investigations on the portion of the mill which directly abuts the Site to the west. Soil borings completed in this location have concentrations of heavy metals, semi-volatile organic compounds (SVOCs) and DRO which exceed background concentrations and applicable MEDEP Cleanup Goals. Due to the fact that these borings were completed directly up-gradient and in close proximity from the Site, it is likely that the subsurface conditions found at the River Dam Mill property are consistent with those found at the Site.

WestPoint Stevens Mill: The WestPoint Stevens Mill has been used for industrial manufacturing since prior to 1875. The WestPoint Stevens mill has been shut down since August 2009. Select hazardous waste storage areas are currently maintained on the Site by the remaining personnel. An oil and waste oil storage area is located within a concrete berm on the first floor (the basement) of Building 9 (west and up-gradient of the Site). EDR identified the property as a UST site, a LUST site, an AST site, a LAST site, a Resource Conservation and Recovery Act conditionally exempt small quantity generator (RCRA-CESQG) of hazardous waste, and a state hazardous waste site (SHWS). Five USTs were formerly maintained at the property, including two 50,000-gallon No. 6 fuel oil USTs that were installed in 1937 and abandoned-in-place in 1991; one 10,000-gallon No. 2 fuel oil UST that was installed in 1979 and removed in 1992; one 2,000-gallon No. 2 fuel oil UST that was installed in 1954 and removed in 1987; and one 7,500-gallon solvent UST that was installed in 1968 and abandoned-in-place in 1985. Historic releases from the two 50,000-gallon No. 6 fuel oil USTs were identified in 1991 during tank closure activities. Approximately 300 cubic yards of accessible contaminated soil was excavated and disposed offsite at that time. Residual petroleum contamination was observed extending beyond the accessible areas of contamination (i.e. near building foundations).

Several MEDEP spill events were reported at the property that may have had the potential to adversely impact subsurface conditions. Spill Report P-911-2003 documents the release of hydraulic oil in Building 10 (west and up-gradient of the Site); P-1089-2003 documents releases from a 6,000-gallon adhesive tank located in the basement of Building 10; P-517-1997, P-529-1999, P-911-2003, and P-1088-2003 document releases of oil into the underground canals formerly located at the property (west and up-gradient of the Site); P-517-1997 documents a release of heavy fuel oil in the upper canal on the property (west and up-gradient of the Site); P-529-1999 documents a release of 100 to 150 gallons of hydraulic oil on the first floor of Building 10; and P-911-2003 documents free product floating in the upper canal.


A Phase I ESA conducted for the property in June of 2010 identified the following RECs: the presence of residual petroleum contamination in the vicinity of two abandoned 50,000-gallon No. 6 oil USTs located southwest of the Steam Plant (south and down-gradient from the Site); the unknown location of a former 2,000-gallon No. 2 fuel oil UST; the presence of an abandoned 7,500-gallon solvent UST east of Building 11 (west and up-gradient from the Site); the former presence of a 10,000-gallon No. 2 fuel oil UST west of Building 9 (southwest and side-gradient); areas of significant oil throughout the Site buildings which may contain PCBs; the fact that DRO, volatile organic compounds, chlorinated solvents (trichloroethylene and its degradation products), polycyclic aromatic hydrocarbons (PAHs), and metals have been previously detected in sediment samples collected from the canals; the fact that historical environmental investigations at other properties in the Biddeford Mill District have identified fill materials and soil contaminated with low levels of PAHs and metals; and lead-paint, PCBs and ACM in property buildings.


6.0 RECORDS REVIEW

6.1 STANDARD ENVIRONMENTAL RECORD SOURCES

Ransom utilized EDR to conduct a search of Federal and State databases containing known and suspected sites of environmental contamination. The number of listed sites identified within the approximate minimum search distance (AMSD) from the Federal and State environmental records database listings specified in ASTM Standard Practice E 1527-05 are summarized in the following table. Detailed information for sites identified within the AMSDs is provided in Section 4.1.1, along with an opinion about the significance of the listing to the analysis of RECs in connection with the Site. A copy of the EDR research data and descriptions of the databases is included in Appendix B of this report.

DATABASE RECORD AMSD (Miles)

Total Sites

Found

On Subject

Property

On Adjoining Property

Federal NPL 1.0 0 No No Federal Delisted NPL 0.5 0 No No Federal CERCLIS 0.5 0 No No Federal CERC-NFRAP 0.5 2 No No Federal RCRA CORRACTS Facilities 1.0 0 No No

Federal RCRA Non-CORRACTS TSD 0.5 0 No No

Federal RCRA Generators Property/Adjoining 2 No Yes Federal Institutional/Engineering Controls Registries 0.5 0 No No

Federal ERNS Property Only 0 No No State-Equivalent NPL/CERCLIS/SHWS 1.0 3 No Yes

State Landfill/Solid Waste Disposal Site 0.5 1 No No

State Leaking AST 0.5 54 No Yes State Registered AST Property/Adjoining 0 No No State Leaking UST 0.5 43 No Yes State Registered UST Property/Adjoining 3 No Yes State Institutional/Engineering Controls Property Only 0 No No

State Voluntary Cleanup Sites 0.5 15 No Yes State Brownfield Sites 0.5 6 No Yes


6.1.1 Site

The Site was not identified in any of the databases searched by EDR.

6.1.2 Discussion of Database Findings

Federal NPL Sites

No Federal National Priority List (NPL) or proposed NPL sites were identified by EDR within one mile of the Site.

Federal Delisted NPL Sites

No Federal Delisted NPL sites were identified by EDR within 1.0 mile of the Site.

Federal CERCLIS Sites

No Federal Comprehensive Environmental Response Compensation and Liability Information System (CERCLIS) sites were identified by EDR within 0.5 mile of the Site.

Federal CERCLIS-NFRAP Sites

Two Federal CERCLIS No Further Remedial Action Planned (NFRAP) sites were identified by EDR within 0.5 mile of the Site, including the NKL Tanning Company Warehouse located at 72 Main Street on Factory Island, approximately 0.2 miles east and hydraulically isolated from the Site, and the Whites Wharf Site located on Water Street, approximately 0.25 miles southeast and side-gradient of the Site. Given these two sites are located in positions perceived to be hydraulically isolated or side-gradient from the Site, they do not appear to represent environmental concerns to the Site.

A third CERCLIS-NFRAP site, the Rotary Park Site, was identified by EDR as an Orphan Site. The Rotary Park Site is located on Main Street, in a perceived up-gradient position to the Site. According to the EDR Site Report for this property, the site has been assessed, and no further remedial action is planned; therefore, this site does not appear to represent an environmental concern to the Site.

Federal RCRA CORRACTS Facilities

No Federal Resource Conservation and Recovery Act (RCRA) Corrective Action (CORRACTS) facilities were identified by EDR within one mile of the Site.

Federal RCRA Non-CORRACTS TSD Facilities

No Federal RCRA Non-CORRACTS Treatment, Storage and Disposal (TSD) facilities were identified by EDR within 0.5 mile of the Site.


Federal RCRA Generators

Two Federal RCRA hazardous waste generator facilities were identified by EDR on or adjoining the Site. The WestPoint Stevens Mill was identified as a RCRA-CESQG. Refer to section 5.2 for details pertaining to the Site. The Biddeford Textile Company (currently referred to as North Dam Mill) located at 2 Main Street, adjacent to the southeast of the Site, was also identified as a RCRA-CESQG. The hazardous wastes generated at this property were classified as ignitable wastes, and no violations were identified. Given that no violations were identified, and that this property is hydraulically down-gradient from the Site, the generator status of this adjacent property does not appear to represent an environmental concern to the Site.

Federal Institutional Control/Engineering Control Registries

No Federal Institutional/Engineering Control sites were identified by EDR within 0.5 miles of the Site.

Federal ERNS List

No Federal Emergency Response and Notification System (ERNS) sites were identified by EDR on the Site.

State and Tribal Equivalent CERCLIS/NPL/Hazardous Waste Sites

Three State Hazardous Waste Sites (SHWS) were identified by EDR within 0.5 mile of the Site, including the West Point Pepperell Site (WestPoint Stevens Mill), located adjacent and up-gradient to the Site, the NKL Tanning Company Warehouse located at 72 Main Street on Factory Island, approximately 0.23 miles east-northeast and hydraulically isolated from the Site, and the Whites Wharf Site located on Water Street, approximately 0.25 miles southeast and presumed side-gradient of the Site. As stated previously, historic operations at the WestPoint Stevens Mill have the potential to have advesely impacted environmental conditions at the Site. However, the facility status listed for both the NKL Tanning Company Warehouse and the Whites Wharf Site is no further action. Given these two sites are located in positions perceived to be hydraulically isolated or side-gradient from the Site, they do not appear to represent environmental concerns to the Site.

State and Tribal Landfill and/or Solid Waste Disposal Sites

One solid waste facility (SWF) was identified by EDR within 0.5 mile of the Site. The facility is identified by the licensee name of Casella Waste Systems Inc. and is located at 3 Lincoln Street, approximately 0.2 miles west-northwest and presumed side-gradient of the Site. The facility includes an incinerator and is known as the Maine Energy Recovery Company (MERC). Given MERCs perceived side-gradient position to the Site, this site does not appear to represent an environmental concern to the Site.

State and Tribal Registered UST Sites

Three abutting properties were identified by EDR as State registered UST sites, including the WestPoint Stevens Mill, the Biddeford Textile Co. (North Dam Mill), and the Gamache Enterprises property (the River Dam Mill).


The Gamache Enterprises property (River Dam Mill) is located adjacent to the north and west, and in a perceived up-gradient position to the Site. According to the EDR Site Report, this facility formerly maintained four USTs under Facility ID 10007: two 10,000-gallon No. 4 fuel oil USTs that were installed in 1977 and removed in 2000; one 6,000-gallon No. 4 fuel oil UST that was installed in 1969 and removed in 1997; and one 1,000-gallon No. 2 fuel oil UST that was installed in 1977 and removed in 1997.

The WestPoint Stevens Mill, located adjacent to the west and south and up-gradient of the Site, formerly maintained five USTs under Facility ID 886: two 50,000-gallon No. 6 fuel oil USTs that were installed in 1937 and abandoned-in-place in 1991; one 10,000-gallon No. 2 fuel oil UST that was installed in 1979 and removed in 1992; one 2,000-gallon No. 2 fuel oil UST that was installed in 1954 and removed in 1987; and one 7,500-gallon UST registered as containing an unknown substance that was installed in 1968 and abandoned-in-place in 1985.

The Biddeford Textile Company property (the North Dam Mill site) located adjacent and down-gradient to the Site, formerly maintained one UST under Facility ID 15941: a 12,000-gallon No. 2 fuel oil UST that was installed in 1969 and removed in 1988.

The North Dam Mill is located down-gradient from the Site; as such, it is not anticipated to represent an environmental risk to the Site. However, both the WestPoint Stevens Mill and the River Dam Mill are located up-gradient of the Site, and as such, have the potential to have adversely impacted the Site. Refer to Section 5.2 for details pertaining to these properties.

State and Tribal LUST Sites

A total of 43 State LUST sites were identified by EDR within 0.5 mile of the Site. Of these 43 LUST sites, only the adjacent, up-gradient Sites are anticipated to represent an environmental threat. The remaining properties are either at relatively large distances from, or located in positions perceived to be hydraulically side-gradient, up-gradient, or hydraulically isolated from the Site, and as such, do no appear to represent environmental concerns to the Site.

The River Dam Millyard Warehouse, adjacent to the north and west and in a perceived up-gradient position to the Site, was identified as a LUST site. MEDEP Spill Report P-116-1997 documents the discovery of 21 waste drums at this property; P-125-1997 and P-29-1998 document the discovery and subsequent removal of two USTs; and P-132-2000 documents the discovery and subsequent removal of two additional USTs.

The WestPoint Stevens Mill, adjacent to the west and south and in a perceived up-gradient position to the Site, was also identified as a LUST site. Historic releases from the two 50,000-gallon No. 6 fuel oil USTs were identified in 1991 during tank closure activities. According to MEDEP Spill Report P-600-1991, evidence of historic releases of No. 6 oil was observed in test pits excavated in the vicinity of the USTs. Approximately 300 cubic yards of accessible contaminated soil was excavated and disposed offsite.


State and Tribal LAST Sites

A total of 54 State LAST sites were identified by EDR within 0.5 mile of the Site. Of these 54 LUST sites, only those located adjacent and up-gradient are thought to represent an environmental concern. The remaining properties are either at relatively large distances from, or located in positions perceived to be hydraulically side-gradient, up-gradient, or hydraulically isolated from the Site, and as such, do no appear to represent environmental concerns to the Site..

The WestPoint Stevens Mill maintained several ASTs for storage of chemicals utilized within the manufacturing process. MEDEP Spill Report P-911-2003 documents a hydraulic oil release in Building 10. Cleanup activities were reported for the spill, and no further response actions were required by the MEDEP at that time. According to MEDEP Spill Report P-1089-2003, releases from a 6,000-gallon adhesive tank located in the basement of Building 10 were identified. The MEDEP determined that the adhesive was a non-hazardous chemical, and no cleanup activities were necessary.

State and Tribal Institutional Control/Engineering Control Registries

No State or Tribal Institutional/Engineering Control sites were identified by EDR on the Site.

State and Tribal Voluntary Cleanup Sites

A total of 15 State Voluntary Cleanup (VCP) sites were identified by EDR within 0.5 mile of the Site. Two of these VCP sites are adjacent to the Site and include the River Dam Mill and the North Dam Mill. These sites have been entered into the MEDEP Voluntary Response Action Program (VRAP), and cleanup activities are in various stages for these three sites. Given that these adjacent properties are planned to be remediated under the guidance of the MEDEP VRAP, their VCP status does not appear to represent an environmental concern to the Site.

The remaining VCP sites identified by EDR within 0.5 mile of the Site are located in positions considered to be hydraulically isolated or side-gradient and do no appear to represent an environmental concern to the Site.

State and Tribal Brownfield Sites

Six State Brownfields sites were identified by EDR within 0.5 mile of the Site. Two of these Brownfield sites are adjacent to the Site and include the River Dam Mill and the North Dam Mill. These sites have been entered into the MEDEP VRAP, and cleanup activities are in various stages for these properties. The remaining sites are not anticipated to represent an environmental concern due to either their relatively large distance from the Site, their relative hydraulic location to the Site, or the fact that remedial activities have been completed to the satisfaction of the MEDEP.

Orphan Sites

EDR orphan site designation indicates insufficient address information for the site to be plotted. Ransom reviewed the 23 Orphan Sites identified by EDR and determined that many of these Orphan Sites are located in positions considered to be side-gradient, down-gradient, or hydrologically isolated from the Site, or are beyond the applicable ASTM search parameters. Therefore, these particular Orphan Sites are unlikely to impact the Site.


One of the Orphan Sites was identified as located within the applicable ASTM search parameters: the Rotary Park site was identified by EDR as an Orphan CERCLIS-NFRAP site, and is discussed in the pertinent sections above.

6.1.3 Maine Department of Environmental Protection

Ransom also reviewed the following MEDEP online databases for information pertaining to Site and/or properties in the vicinity of the Site with known and/or suspected environmental contamination and their potential to adversely impact environmental conditions at the Site.

Division of Remediation Sites List (MEDEP Sites List) online database;

Non-Conforming Tanks online database;

Registered Underground Oil Storage Tanks online database;

Active and Out of Service Underground Oil Storage Tanks Including Tanks That Have Not Been Properly Abandoned online database; and

Hazardous and Oil Spill online database.

The Site was not identified on any MEDEP online databases.

6.2 ADDITIONAL ENVIRONMENTAL RECORD SOURCES

6.2.1 City of Biddeford Municipal Offices

Assessors Office

Information provided by the City of Biddeford Assessors Office included a current property card (included in Appendix D) and one historic property card. Information provided by the Assessors Office regarding the Site history coincided with information discussed in Section 4 of this report. The property cards did not include information pertaining to underground or aboveground storage tanks, hazardous waste storage, and/or adverse environmental conditions at the Site.

Code Enforcement

The City of Biddeford Code Enforcement Office did not maintain a file for the Site. However, Ransom reviewed files related to the adjacent, up-gradient River Dam Mill and found a landscape plan which showed an old machine shop at the Site. A copy of this plan has been included in Appendix D.

6.2.2 Previous Investigations/Assessments

No previous environmental reports in connection with the Site were discovered or reviewed as part of Ransoms assessment. As stated previously, the City has made reference to an environmental report/investigation which may have been completed by CMP to address potential contamination from electrical transformers that were formerly stored on-Site. A copy of this report was not able to be obtained.


The Biddeford Mill District, and adjacent properties (including the up-gradient River Dam Mill and WestPoint Stevens Mill), have been the subject of many environmental and subsurface investigations. These reports were reviewed and pertinent information has been included throughout this report.

6.3 CHAIN OF TITLE

According to the City of Biddeford Assessors Office, the Site is currently owned by FPL (Florida Power and Light) Energy Maine Hydro, LLC, who obtained the property from Central Maine Power (CMP) in 1999. The following ownership history was derived from Municipal Records.

Owner Date Book/Page FPL Energy Maine Hydro, LLC 4/8/1999 9404/12 Central Maine Power Unknown Unknown


7.0 SITE RECONNAISSANCE

On September 15, 2011, Ransom conducted a reconnaissance of the Site. Ms. Jennie Franceschi, a municipal employee, provided Ransom with access to the Site and provided an explanation of the Site and facilities to be assessed. A photograph log is included in Appendix A.

7.1 METHODOLOGY AND LIMITING CONDITIONS

The Site reconnaissance included observations of the property grounds for evidence of releases, or potential releases of oil and/or hazardous materials (OHM), or a material threat of releases of OHM. Weather conditions at the time of the reconnaissance were rainy with temperatures around 70F.

7.2 GENERAL SITE SETTING AND OBSERVATIONS

The Site is currently vacant. It is located in the Mill District, and is surrounded on three sides by mills. The property is abutted to the east by the Saco River. A concrete wall separates the river from the Site. A concrete pad was observed in the southern portion of the Site.

7.2.1 Hazardous Substances and Petroleum Products

No petroleum or OHM was observed at the Site during our reconnaissance.

7.2.2 Storage Tanks

Ransom did not observe evidence of USTs (i.e., fill and vent pipes) currently in use and/or abandoned at the Site during our reconnaissance. Ransom did not observe any aboveground storage tanks (ASTs) during our reconnaissance.

7.2.3 Odors

No strong, pungent, or noxious odors were noted at the Site during our reconnaissance.

7.2.4 Pools of Liquid

Ransom did not observe areas of standing water and/or pools of liquid, indicative of a release of OHM, at the Site during our reconnaissance.

7.2.5 Drums

No drums containing petroleum, OHM or unknown substances were observed at the Site during our reconnaissance.


7.2.6 Unidentified Substance Containers

No unidentified substance containers were observed at the Site during our reconnaissance.

7.2.7 Polychlorinated Biphenyls (PCBs)

Ransom did not observe pole-mounted or pad-mounted electrical transformers at the Site which were leaking, or which had the potential to impact environmental conditions on-Site.

7.3 EXTERIOR OBSERVATIONS

7.3.1 Pits, Ponds or Lagoons

No pits, ponds, or lagoons reported to have been utilized for waste disposal or waste treatment purposes were observed on the Site during our reconnaissance.

7.3.2 Stained Soil or Pavement

No stained soil and/or pavement were observed at the Site, indicative of a release of petroleum or OHM.

7.3.3 Stressed Vegetation

No stressed vegetation was observed at the Site.

7.3.4 Solid Waste

No fill material was observed at the Site during our reconnaissance; however, based on historic environmental reports for adjacent properties, the area (and likely the Site) is comprised of urban fill materials.

No dumpsters were observed on-Site during our reconnaissance.

7.3.5 Waste Water As previously stated, area properties are connected to the municipal sewer system. No evidence of septic systems/cesspools was observed at the Site during our reconnaissance.

7.3.6 Wells

Ransom did not observe any wells on the Site including groundwater monitoring, water supply, dry wells, irrigation wells, injection wells, etc. No wells are reportedly located at the Site.

7.3.7 Drains

Catch basins were observed in the central portion of the Site. Additionally, stormwater discharge lines were observed to discharge along the concrete retaining wall on the eastern property boundary. City personnel indicated that stormwater runoff from the adjacent, up-gradient mill complex discharged through the observed outfall.


8.0 INTERVIEWS

Ransom interviewed the following entities/individuals in an effort to obtain information indicating potential RECs in connection with the Site.

8.1 PAST AND PRESENT SITE OWNERS

Ransom interviewed Mr. Matthew LeBlanc of FPL, representative for the current Site owner on September 15, 2011, during the Site reconnaissance visit. Mr. LeBlanc provided information that has been included throughout the pertinent sections of this report Site Manager/ Occupants

Information provided by Ms. Franceschi has been included in pertinent sections of this report.

8.2 LOCAL GOVERNMENT OFFICIALS

On October 27, 2011, Ransom interviewed Mr. Brian Phinney of the City of Biddeford Code Enforcement office and a clerk in the City of Biddefords Assessors Office for information pertaining to environmental incidents or concerns pertaining to the Site. Information from these interviews are included throughout the pertinent sections of this report. In addition, Mr. Phinney completed an ASTM Transaction Screen Questionnaire, which is included as Supplemental Documentation in Appendix D.


9.0 SUMMARY OF KEY FINDINGS

The Site, located on the western bank of the Saco River, is currently vacant. It is abutted on the remaining three sides by mills. Based on available information, the Site was formerly utilized as part of the River Dam Mill. From the late 1800s until the mid/late 1900s, the site was developed with mill structures and may have been used for storage, production or transportation of goods. A machine shop was also formerly located in the southern portion of the Site. According to City personnel, in the late 1900s, the Site may have been used by Central Maine Power to store electrical transformers. The Subject Area has been used for industrial purposes since its development in the 1800s. Area buildings are connected to municipal water and sewer, provided by the City of Biddeford.

As part of Ransoms assessment of the Site, EDR conducted an environmental database search. Ransom also reviewed the MEDEP online databases. The Site was not identified in the EDR Report; nor was it identified in any MEDEP online databases.

The three adjacent properties located west, north, and south of the Site have historically been industrial/mill sites: the River Dam Mill (up and side-gradient), former WestPoint Stevens Mill (up and side-gradient), and North Dam Mill (side-gradient). Although remediation activities in accordance with the MEDEP VRAP are in various stages for these three properties; the historic use, storage, and possible releases of oil and/or hazardous materials at the up-gradient River Dam Mill and WestPoint Stevens Mill properties may have had the potential to adversely impact the Site. Subsurface investigations completed at the River Dam Mill have revealed concentrations of heavy metals, SVOCs, benzo(a)pyrene, and DRO above applicable MEDEP Cleanup Goals. Historic environmental investigations at the WestPoint Stevens Mill have documented DRO, volatile organic compounds, chlorinated solvents (trichloroethylene and its degradation products), PAHs, and metals on-Site.


10.0 DATA GAPS

Based on conversations with City of Biddeford personnel, it is our understanding that CMP may have formerly stored electrical transformers on the Site. FPL indicated that an environmental report documenting potential environmental conditions, as a result of this activity may exist; however, FPL representatives were unable to locate a copy of the report for review as part of this assessment. This potential environmental concern has been discussed in pertinent sections of this report, and a conclusion/recommendation has been made to perform additional environmental investigation regarding this matter.

Reasonably ascertainable historical information sources allowed uses of the Site to be traced from the present back to 1893, at which time the area surrounding the Site was shown on a topographic map to be developed (it is unclear what type of structure may have been located at the Site, but it was likely mill or mill-related). This 1893 topographic map post-dates the propertys obvious first developed use and constitutes historical data failure per ASTM Standard Practice E 1527-05 8.3.2.3. However, because the area has historically been used as a mill, it is unlikely that this historical data failure/data gap represents an additional environmental concern, above and beyond the known environmental concerns associated with the Mill District. The conclusions and recommendations presented in this report will address potential environmental concerns associated with the historic Site and adjacent property use.

No other significant data gaps were identified in the information collected for this assessment that affect the ability to identify conditions indicative of releases or threatened releases of OHM or that would materially affect our conclusions and opinions relative to recognized environmental conditions in connection with the Site.


11.0 CONCLUSIONS AND OPINIONS

Based on the information obtained during this Phase I ESA, Ransom has identified the following RECs in connection with the Site:

1. Prior environmental investigations completed at adjacent and up-gradient properties (former River Dam Mill and WestPoint Stevens Mill) identified heavy metals, VOCs, SVOCs, DRO, PAHs, and DRO in surficial and subsurface soils at concentrations which exceed applicable MEDEP Remedial Action Guidelines and/or Cleanup Goals. Due to the fact that these investigations were completed directly up-gradient and in close proximity from the Site, it is likely that the surficial and/or subsurface conditions found at the River Dam and WestPoint Stevens properties are consistent with those found at the Site.

2. City and FPL personnel indicated that CMP may have formerly stored electrical transformers on-Site. FPL indicated that an environmental report documenting potential environmental conditions, as a result of this activity may exist; however, FPL representatives were unable to locate a copy of the report for review as part of this assessment. Improperly stored transformers may represent the threat of release of PCBs onto the surface or into the subsurface.

3. Stormwater discharge pipes were observed in the central portion of the property. City personnel indicated that the stormwater from the adjacent mill complex(es) was collected and discharged onto the Site through this subsurface collection system. There is the potential that historic and existing spills, releases, and poor housekeeping practices at the adjacent mill facilities have allowed pollutants to be discharged through the stormwater collection system and onto the Site.

Therefore, we have revealed conditions indicative of a release(s) or threatened release(s) of oil and/or hazardous material substances on the Site and additional investigation is recommended to address the identified recognized environmental conditions at the Site (please refer to the following section for our recommendations).


12.0 RECOMMENDATIONS

Based on the information obtained during this assessment, Ransom concludes that additional investigation is warranted. Specifically, Ransom recommends the following:

1. A limited subsurface and/or surface soil investigation should be performed to determine whether the Site has been impacted from historic industrial operations conducted on the site, historic industrial operations conducted on adjacent and up-gradient properties, the potential for releases associated with electrical transformers, which may have been historically stored on-Site, and the potential for releases associated with the stormwater discharge points on-Site.

2. Prior to any site redevelopment activities, Ransom recommends the development of a Soil Management Plan to address necessary actions in the event contaminated soil is encountered during Site redevelopment.

3. Depending on the results of the recommended limited subsurface and/or surficial soil investigation noted above, a deed restriction may need to be developed, requiring that certain site use conditions/covenants be imposed on the property, such as prohibiting/managing the excavation of on-Site soils and/or prohibiting groundwater extraction.

4. The Site should be entered into the MEDEP VRAP. The VRAP would allow for MEDEP review and approval of the assessment actions performed, and assuming the MEDEP concurs with the actions conducted at the site, would provide for liability protection under 38 M.R.S.A. 342 (15) and 343-E. Upon submission of a Site Closure Report, and subsequent approval of the VRAP Application, the MEDEP would issue a No Further Action letter to the applicant.


13.0 ADDITIONAL SERVICES AND NON-SCOPE CONSIDERATIONS

13.1 ADDITIONAL SERVICES

The following environmental issues are outside the scope (non-scope considerations) of the standard practice defined by ASTM Standard Practice E 1527-05. This Phase I ESA does not identify or evaluate these non-scope considerations.

Radon;

Lead in Drinking Water;

Wetlands;

Regulatory Compliance;

Cultural and Historic Resources;

Industrial Hygiene;

Health and Safety;

Ecological Resources;

Endangered Species;

Indoor Air Quality;

High Voltage Power Lines; or

Biological Agents.

13.2 NON-SCOPE CONSIDERATIONS

No additional services beyond the standard scope of services prescribed by ASTM Standard Practice E 1527-05 were requested by the client.


14.0 REFERENCES

1. City of Biddeford Municipal Offices, Ransom File Review.

2. Maine Department of Environmental Protection Online Database Review, http://www.maine.gov/dep/rwm/data/index.htm, September 2011.

3. MEDEP Online Fortis Portal, https://fortisportal.maine.gov/fortisportal/DisplayQueryPrompts.aspx?Database=OfficeDocs&Query=DEP_Spills&QuerySet=Portal_Queries&User=Portal.DEP&Password=DEPPortal1, September 2011

4. FEMA Map Service Center, http://msc.fema.gov/webapp/wcs/stores/servlet/FemaWelcomeView?storeId=10001&catalogId=10001&langId=-1, September 2011

5. U.S. Geological Survey, Topographic 7.5-Minute Series Biddeford East, Maine, USGS Quadrangle, 1989.

6. Bedrock Geologic Map of Maine, Maine Geological Survey, Department of Conservation, Anderson, Walter A., 1985.

7. Surficial Geologic Map of Maine, Maine Geological Survey, Department of Conservation, Anderson, Walter A., 2004.

8. Environmental Data Resources (EDR) Radius Map Report, September 8, 2011.


15.0 SIGNATURE(S) OF ENVIRONMENTAL PROFESSIONAL(S)

Environmental Professional

We declare that, to the best of our professional knowledge and belief, we meet the definition of an Environmental Professional as defined in 312.10 of 40 CFR Part 312. We have the specific qualifications based on education, training, and experience to assess a property of the nature, history, and setting of the Site. We have developed and performed the all appropriate inquiries in conformance with the standards and practices set forth in 40 CFR Part 312.

Jaime L. Madore, P.E. Project Engineer/Primary Author

Peter J. Sherr, P.E. Senior Project Manager/Primary Reviewer Nicholas O. Sabatine, P.G. Vice President/Office Manager

G:\Data\ME\Project\111_06115\Maps\MXD\Figure_1.mxd

Site Location

City of BiddefordPO Box 586Biddeford, Maine

Figure 1

[

FPL ParcelMap 71, Lot 8Laconia StreetBiddeford, Maine

0 2,0001,000

1 inch = 2,000 feet

Scale and Orientation

Prepared For

Site Address

Regional Locator Map

111.06115 Oct 2011

Notes

1. Data Source: USGS National Map Seamless Server, 24K DRG, 1/3" NED

2. USGS Quad Name: Biddeford

3. Latitude: 43 29' 39.19" N Longitude: 70 27' 9.7" W UTM Northing: 4816724.43 mN UTM Easting: 382547.72 mE

Biddeford

SITE LOCATION

G:\Data\ME\Project\111_06115\Maps\MXD\Figure_2.mxd

Approximate Property Boundary

(Former Westpoint Stevens Mill: Building 11)

(Former Riverdam Mill)

Saco River

Map 71Lot 8

PEPPERELL MILLS

MILL AT SACO FALLSNORTH DAM MILL Site Plan

City of BiddefordPO Box 586Biddeford, Maine

Figure 2

[

FPL ParcelMap 71, Lot 8Laconia StreetBiddeford, Maine

0 4020

1 inch = 40 feet

Scale and Orientation

Prepared For

Site Address

Legend

111.06115 Oct 2011

Notes

1. Site Plan based on 2007 Orthophotography

2. Some features are approximate in location and scale

3. This plan has been prepared for The City of Biddeford. All other uses are not authorized unless written permission is obtained from Ransom Environmental Consultants, Inc.

Site Boundary

Ransom Environmental Consultants, Inc. Project 111.06115

APPENDIX A

Photograph Log

Phase I Environmental Site Assessment FPL Energy Maine Hydro, LLC Parcel

Map 71, Lot 8 Laconia Street, Biddeford, Maine

Photograph Log

Ransom Project 111.06115 Page 1 of 2 P:\2011\111.06115\Phase I ESA\Appendix A - Photolog.doc October 31, 2011

Subject Property. View is to the north.

Concrete wall comprising the edge of property. View is to

the east.

Southern portion of the Site. View is to the southeast.

Southern portion of the Site. View is to the south.

Subject Property. View is to the south.

Catch basin located centrally on Site.

Photograph Log

Ransom Project 111.06115 Page 2 of 2 P:\2011\111.06115\Phase I ESA\Appendix A - Photolog.doc October 31, 2011

Subject Property. View is to the north.

Northern portion of Site. View is to the north.

View is to the northwest.

Ransom Environmental Consultants, Inc. Project 111.06115

APPENDIX B

The EDR Radius Map with GeoCheck Report

Phase I Environmental Site Assessment FPL Energy Maine Hydro, LLC Parcel

Map 71, Lot 8 Laconia Street, Biddeford, Maine

FORM-NULL-DXG

kcehCoeG htiw tropeR paM suidaR RDE ehT

440 Wheelers Farms RoadMilford, CT 06461Toll Free: 800.352.0050www.edrnet.com

FPL Parcel1-99 LACONIA STBiddeford, ME 04005

Inquiry Number: 3162603.1sSeptember 08, 2011

SECTION PAGE

Executive Summary ES1

Overview Map 2

Detail Map 3

Map Findings Summary 4

Map Findings 7

Orphan Summary 661

Government Records Searched/Data Currency Tracking GR-1

GEOCHECK ADDENDUM

Physical Setting Source Addendum A-1

Physical Setting Source Summary A-2

Physical Setting SSURGO Soil Map A-5

Physical Setting Source Map A-8

Physical Setting Source Map Findings A-10

Physical Setting Source Records Searched A-13

TC3162603.1s Page 1

Thank you for your business.Please contact EDR at 1-800-352-0050

with any questions or comments.

Disclaimer - Copyright and Trademark Notice

This Report contains certain information obtained from a variety of public and other sources reasonably available to Environmental DataResources, Inc. It cannot be concluded from this Report that coverage information for the target and surrounding properties does not exist fromother sources. NO WARRANTY EXPRESSED OR IMPLIED, IS MADE WHATSOEVER IN CONNECTION WITH THIS REPORT. ENVIRONMENTALDATA RESOURCES, INC. SPECIFICALLY DISCLAIMS THE MAKING OF ANY SUCH WARRANTIES, INCLUDING WITHOUT LIMITATION,MERCHANTABILITY OR FITNESS FOR A PARTICULAR USE OR PURPOSE. ALL RISK IS ASSUMED BY THE USER. IN NO EVENT SHALLENVIRONMENTAL DATA RESOURCES, INC. BE LIABLE TO ANYONE, WHETHER ARISING OUT OF ERRORS OR OMISSIONS, NEGLIGENCE,ACCIDENT OR ANY OTHER CAUSE, FOR ANY LOSS OF DAMAGE, INCLUDING, WITHOUT LIMITATION, SPECIAL, INCIDENTAL,CONSEQUENTIAL, OR EXEMPLARY DAMAGES. ANY LIABILITY ON THE PART OF ENVIRONMENTAL DATA RESOURCES, INC. IS STRICTLYLIMITED TO A REFUND OF THE AMOUNT PAID FOR THIS REPORT. Purchaser accepts this Report "AS IS". Any analyses, estimates, ratings,environmental risk levels or risk codes provided in this Report are provided for illustrative purposes only, and are not intended to provide, norshould they be interpreted as providing any facts regarding, or prediction or forecast of, any environmental risk for any property. Only a Phase IEnvironmental Site Assessment performed by an environmental professional can provide information regarding the environmental risk for anyproperty. Additionally, the information provided in this Report is not to be construed as legal advice.

Copyright 2011 by Environmental Data Resources, Inc. All rights reserved. Reproduction in any media or format, in wholeor in part, of any report or map of Environmental Data Resources, Inc., or its affiliates, is prohibited without prior written permission.

EDR and its logos (including Sanborn and Sanborn Map) are trademarks of Environmental Data Resources, Inc. or its affiliates. All othertrademarks used herein are the property of their respective owners.

TABLE OF CONTENTS

EXECUTIVE SUMMARY

TC3162603.1s EXECUTIVE SUMMARY 1

A search of available environmental records was conducted by Environmental Data Resources, Inc (EDR).The report was designed to assist parties seeking to meet the search requirements of EPAs Standardsand Practices for All Appropriate Inquiries (40 CFR Part 312), the ASTM Standard Practice forEnvironmental Site Assessments (E 1527-05) or custom requirements developed for the evaluation ofenvironmental risk associated with a parcel of real estate.

TARGET PROPERTY INFORMATION

ADDRESS

1-99 LACONIA STBIDDEFORD, ME 04005

COORDINATES

43.494200 - 43 29 39.1Latitude (North): 70.452800 - 70 27 10.1Longitude (West): Zone 19Universal Tranverse Mercator: 382534.1UTM X (Meters): 4816507.0UTM Y (Meters): 34 ft. above sea levelElevation:

USGS TOPOGRAPHIC MAP ASSOCIATED WITH TARGET PROPERTY

43070-D4 BIDDEFORD, METarget Property Map:1975Most Recent Revision:

43070-E4 OLD ORCHARD BEACH, MENorth Map:1975Most Recent Revision:

AERIAL PHOTOGRAPHY IN THIS REPORT

2006, 2007Portions of Photo from:USDASource:

TARGET PROPERTY SEARCH RESULTS

The target property was not listed in any of the databases searched by EDR.

DATABASES WITH NO MAPPED SITES

No mapped sites were found in EDRs search of available ("reasonably ascertainable ") governmentrecords either on the target property or within the search radius around the target property for thefollowing databases:

STANDARD ENVIRONMENTAL RECORDS

Federal NPL site list

NPL National Priority List

EXECUTIVE SUMMARY


Proposed NPL Proposed National Priority List SitesNPL LIENS Federal Superfund Liens

Federal Delisted NPL site list

Delisted NPL National Priority List Deletions

Federal CERCLIS list

CERCLIS Comprehensive Environmental Response, Compensation, and Liability Information SystemFEDERAL FACILITY Federal Facility Site Information listing

Federal RCRA CORRACTS facilities list

CORRACTS Corrective Action Report

Federal RCRA non-CORRACTS TSD facilities list

RCRA-TSDF RCRA - Treatment, Storage and Disposal

Federal RCRA generators list

RCRA-LQG RCRA - Large Quantity Generators

Federal institutional controls / engineering controls registries

US ENG CONTROLS Engineering Controls Sites ListUS INST CONTROL Sites with Institutional Controls

Federal ERNS list

ERNS Emergency Response Notification System

State and tribal landfill and/or solid waste disposal site lists

LCP Municipal Landfill Closure Database

State and tribal leaking storage tank lists

INDIAN LUST Leaking Underground Storage Tanks on Indian Land

State and tribal registered storage tank lists

INDIAN UST Underground Storage Tanks on Indian LandFEMA UST Underground Storage Tank Listing

State and tribal voluntary cleanup sites

INDIAN VCP Voluntary Cleanup Priority Listing

ADDITIONAL ENVIRONMENTAL RECORDS

Local Lists of Landfill / Solid Waste Disposal Sites

ODI Open Dump Inventory

EXECUTIVE SUMMARY


DEBRIS REGION 9 Torres Martinez Reservation Illegal Dump Site LocationsSWRCY Recycling FacilitiesINDIAN ODI Report on the Status of Open Dumps on Indian Lands

Local Lists of Hazardous waste / Contaminated Sites

US CDL Clandestine Drug LabsDEL SHWS Sites Removed from the Uncontrolled Sites ListUS HIST CDL National Clandestine Laboratory Register

Local Land Records

LIENS 2 CERCLA Lien InformationLUCIS Land Use Control Information SystemLIENS Environmental Liens Information Listing

Records of Emergency Release Reports

HMIRS Hazardous Materials Information Reporting SystemSPILLS Hazardous Material and Oil Spill System Database

Other Ascertainable Records

DOT OPS Incident and Accident DataDOD Department of Defense SitesFUDS Formerly Used Defense SitesCONSENT Superfund (CERCLA) Consent DecreesROD Records Of DecisionUMTRA Uranium Mill Tailings SitesMINES Mines Master Index FileTRIS Toxic Chemical Release Inventory SystemTSCA Toxic Substances Control ActFTTS FIFRA/ TSCA Tracking System - FIFRA (Federal Insecticide, Fungicide, & Rodenticide Act)/TSCA (Toxic Substances Control Act)HIST FTTS FIFRA/TSCA Tracking System Administrative Case ListingSSTS Section 7 Tracking SystemsICIS Integrated Compliance Information SystemPADS PCB Activity Database SystemMLTS Material Licensing Tracking SystemRADINFO Radiation Information DatabaseFINDS Facility Index System/Facility Registry SystemRAATS RCRA Administrative Action Tracking SystemUIC Underground Injection ControlNPDES Wastewater Facilities ListingDRYCLEANERS Drycleaner FacilitiesAIRS Emissions Inventory DataTIER 2 Tier 2 Information ListingINDIAN RESERV Indian ReservationsSCRD DRYCLEANERS State Coalition for Remediation of Drycleaners ListingPCB TRANSFORMER PCB Transformer Registration DatabaseCOAL ASH EPA Coal Combustion Residues Surface Impoundments ListCOAL ASH DOE Sleam-Electric Plan Operation Data

SURROUNDING SITES: SEARCH RESULTS

Surrounding sites were identified in the following databases.

EXECUTIVE SUMMARY


Elevations have been determined from the USGS Digital Elevation Model and should be evaluated ona relative (not an absolute) basis. Relative elevation information between sites of close proximityshould be field verified. Sites with an elevation equal to or higher than the target property have beendifferentiated below from sites with an elevation lower than the target property.Page numbers and map identification numbers refer to the EDR Radius Map report where detaileddata on individual sites can be reviewed.

Sites listed in bold italics are in multiple databases.

Unmappable (orphan) sites are not considered in the foregoing analysis.

STANDARD ENVIRONMENTAL RECORDS

Federal CERCLIS NFRAP site List

CERC-NFRAP: Archived sites are sites that have been removed and archived from the inventory of CERCLISsites. Archived status indicates that, to the best of EPAs knowledge, assessment at a site has been completedand that EPA has determined no further steps will be taken to list this site on the National Priorities List(NPL), unless information indicates this decision was not appropriate or other considerations require arecommendation for listing at a later time. This decision does not necessarily mean that there is no hazardassociated with a given site; it only means that, based upon available information, the location is not judgedto be a potential NPL site.

A review of the CERC-NFRAP list, as provided by EDR, and dated 02/25/2011 has revealed that there are 2 CERC-NFRAP sites within approximately 0.5 miles of the target property.

PageMap IDDirection / Distance Address Lower Elevation ____________________ ________ ___________________ _____ _____

NKL TANNING COMPANY WHSE. 72 MAIN ST. (FACTORY IS E 1/8 - 1/4 (0.209 mi.) 61 205 WHITES WHARF SITE WATER STREET SE 1/8 - 1/4 (0.245 mi.) O100 334

Federal RCRA generators list

RCRA-SQG: RCRAInfo is EPAs comprehensive information system, providing access to data supportingthe Resource Conservation and Recovery Act (RCRA) of 1976 and the Hazardous and Solid Waste Amendments (HSWA)of 1984. The database includes selective information on sites which generate, transport, store, treat and/ordispose of hazardous waste as defined by the Resource Conservation and Recovery Act (RCRA). Small quantitygenerators (SQGs) generate between 100 kg and 1,000 kg of hazardous waste per month.

A review of the RCRA-SQG list, as provided by EDR, and dated 06/15/2011 has revealed that there are 5 RCRA-SQG sites within approximately 0.25 miles of the target property.

PageMap IDDirection / Distance Address Equal/Higher Elevation ____________________ ________ ___________________ _____ _____

CHEMLAN CO 24 SMITH ST WNW 0 - 1/8 (0.074 mi.) A2 7 BIDDEFORD INDUSTRIES SMITH ST NW 0 - 1/8 (0.097 mi.) A4 10 GWN CO 8 LINCOLN ST. WNW 1/8 - 1/4 (0.180 mi.) I48 153 PRECISION SCREW MACHINE PRODUC GOOCH ST NW 1/8 - 1/4 (0.212 mi.) M63 211 CARQUEST #1539 81 ELM STREET WNW 1/8 - 1/4 (0.215 mi.) L66 217

EXECUTIVE SUMMARY


RCRA-CESQG: RCRAInfo is EPAs comprehensive information system, providing access to data supportingthe Resource Conservation and Recovery Act (RCRA) of 1976 and the Hazardous and Solid Waste Amendments (HSWA)of 1984. The database includes selective information on sites which generate, transport, store, treat and/ordispose of hazardous waste as defined by the Resource Conservation and Recovery Act (RCRA). Conditionallyexempt small quantity generators (CESQGs) generate less than 100 kg of hazardous waste, or less than 1 kg ofacutely hazardous waste per month.

A review of the RCRA-CESQG list, as provided by EDR, and dated 06/15/2011 has revealed that there are 4 RCRA-CESQG sites within approximately 0.25 miles of the target property.

PageMap IDDirection / Distance Address Equal/Higher Elevation ____________________ ________ ___________________ _____ _____

WESTPOINT STEVENS MILL 1 YORK STREET WSW 1/8 - 1/4 (0.128 mi.) C17 37 STANDARD AUTO SUPPLY INC 81 ELM ST WNW 1/8 - 1/4 (0.215 mi.) L67 218 7 ELEVEN 32540 66 ALFRED ST SSW 1/8 - 1/4 (0.222 mi.) N73 232

PageMap IDDirection / Distance Address Lower Elevation ____________________ ________ ___________________ _____ _____

BIDDEFORD TEXTILE CO 2 MAIN STREET ESE 1/8 - 1/4 (0.166 mi.) H29 75

State- and tribal - equivalent CERCLIS

SHWS: The State Hazardous Waste Sites records are the states equivalent to CERCLIS. These sitesmay or may not already be l

phase i environmental site assessment fpl energy

Documents