Clean CFAC letter to Council re Columbia Falls Aluminum Superfund Sitek! COALITION for a
- C L E A N
CFAC
To: Carolina Balliew,
Montana Remedial Section C 'Supervisor, -Region 8,
US Environmental Protection Agency (EPA)
10 West 15th Street, Helena, MT 59626
To: Christopher Dorrington,
Director, Montana Department of Environmental Quality (DEQ)
P.O. Box 200901, Helena MT 59620-0901
Feb. 26, 2024
Dear Ms. Balliew and Mr. Dorrington,
We are writing you to share that we have surpassed over 1000 signatures' from local residents asking
you to pause your record of decision on the Columbia Falls Aluminum Company Superfund site for the
reasons we set forth in our previous letter to you on January 18, 2024. Additionally, the following
organizations have joined the call for this timeout including, American Rivers, Flathead Lake Protection
Association, Flathead Rivers Alliance, Flathead Lakers, Swan View Coalition, and West Glacier Community
Preservation Association, with a number of others considering joining pending approval of their boards.
These organizations collectively with the Coalition for a Clean CFAC represent over 10,000 individuals.
These petition signatures/names were primarily gathered by citizen volunteers who reached out to their
friends and neighbors about the proposed plan to leave the highly toxic waste buried at the former
aluminum plant and their concerns about the implications for our water and our community, as well as
for future use and economic redevelopment of the site.
The hours and hours of time such grassroots outreach takes demonstrates the depth of concern that
exists in our community about the proposed plan. We are not done. We plan to come back to you over
the next month with another 1000 names and then another and another. This is so important to
residents of the Flathead as they begin to understand what is at stake if a comprehensive cleanup of
CFAF is not fairly analyzed and implemented. While gathering these signatures, a common refrain from
our fellow residents was their overwhelming frustration that they had not been kept better informed
' These individuals signed a petition that states "To: The Environmental Protection Agency (EPA) and the MT Department of
Environmental Quality (DEQ)— I signed this petition to respectfully request that your agencies pause the decision -making
process to fully and fairly evaluate the cost -benefits of removing not leaving) the toxic waste at the CFAC Superfund
site. No cost analysis was done by CFAC when they wrote the cleanup plan. CFAC simply dismissed this option as too costly,
even though they acknowledged it would likely be a permanent and effective solution. We ask the EPA and DEQ to require
an independent cost analysis be done to evaluate the permanence and long-term effectiveness of off -site removal. This is
necessary to ensure the cleanup truly protects our water, our health, our community, and our economy. CFAC and ARCO,
and early on Anaconda Co., made many millions of dollars operating this aluminum smelter from 1955-2009 and provided
good jobs. But the citizens of the Flathead watershed shouldn't be left with their toxic mess. The site must be fully cleaned
up and restored for future beneficial uses. "
about opportunities for public input and that more town halls and public information sessions were not
consistently held to engage and inform the public in a genuine and meaningful way.
Having been asked so many times why there was not more extensive public outreach, we recently went
to the EPA web site to try to find a list of community public information sessions and townhall style
meetings where the public might have missed opportunities. What we found was an aspirational
Community Involvement Plan (CIP) at a broken link that was written in 2017. When we finally got to read
this plan, once one of us brought the broken link to EPA's attention, it did not list any such broad -based
public meetings that really reached out and tried to engage the larger community. It did reference the
CFAC Community Liaison Panel, which consisted of CFAC hand-picked community representatives only,
and was run, we are told by members selected, by a public relations firm out of Denver, Colorado that
CFAC hired. We can find no record of public notice of the meetings, certainly not the kind of
informational, questions and answer, townhall style meetings that we heard over and over again from
those who signed the petition they had wanted to see.
One of us then emailed to Missy Haniewicz with EPA and asked for a list of the public out -reach
meetings that EPA has held since 2017. Her email response did not provide any. Instead, she wrote,
"...As far as a report on the community engagement efforts outlined in the CIP, there isn't anything
formal. The CIP is meant to be guidance for community engagement efforts, which are described in the
Record of Decision. Once the ROD is released, the Agency conducts additional community interviews to
help inform an update to the CIP. The original was written in 2017 so it would make sense to do this
update now, as is the practice." We hope we are not the only ones who sees the gross irony in updating
a community engagement report after the most important decision in the entire Superfund process is
made and the public's ability to meaningfully inform that plan is over.
To say that the we, and the public we have been interacting with, are frustrated would be an
understatement. To say that we are even more frustrated than when we last wrote you on January 18,
2024 (we have not received any response to that letter) would also be an understatement. In that letter
we formally requested that the EPA order a time-out to the proposed issuing of a Final Record of
Decision on the CFAC Superfund Site scheduled for an estimated time frame in March of 2024. We
requested in that letter that EPA and Montana DEQ not go forward with a Record of Decision based on
its proposed waste -in -place plan outlined in the 2021 Feasibility Study and the 2023 proposed cleanup
plan for the Columbia Falls Superfund site. (Please see that 1/18/24 letter attached again for the details
we raised.)
Additionally, to help address the public's frustration, the Coalition For A Clean CFAC is applying for the
EPA's Technical Assistance Grant (TAG) program to better help us and community members have
additional opportunities to gain the information needed to meaningfully participate in decision making
and to help the community as a whole better understand what is at stake at the Columbia Falls
Aluminum Plant Superfund site. There are many technical issues at this site that are hard for people to
understand. The grant will help provide money for a technical advisor to meet with community members
to explain site reports, discuss how the site contaminants affect the soil and water, and to evaluate any
health issues related to the site.
Once again, we urge you to hold off on a final decision until a complete feasibility study evaluating the
actual costs and benefits for removal of the highly toxic waste, as well as other missing data and costs for
other clean-up activities discussed in our original letter. Residents and businesses of Columbia Falls and
the Flathead want and deserve this information before any proposed cleanup plan can receive
community acceptance. Furthermore, we believe this missing information is essential to crafting a
future vision for the redevelopment of this site that is good for the community, the economy, the
environment, and for future generations. Without this information the public and EPA cannot really
know if the proposed solution would meet the EPA's goals for solutions that offer long term
effectiveness and permanence, as well as community acceptance.
In closing, we want to offer to drive to Helena to meet with you soon so we can deliver these petitions
directly and share what we hear from our community outreach about the desire for a hard pause in the
decision -making process prior to issuing a final Record of Decision. One of us will follow up directly with
you soon to try to arrange a meeting. We appreciate the important work you do to create a clean and
healthful environment, and recognize that you have many demanding issues you must deal with. We
look forward to meeting with you and working together to ensure the cleanup of the former Columbia
Falls Aluminum plant site leads to a healthier and more prosperous future for our community and the
environment.
Sincerely,
Mayre Flowers, Shirley Folkwein, Phil Matson, and Peter Metcalf on behalf of the Coalition for a Clean
CFAC, PO Box 2198, Kalispell, MT 59903
Mayre Flowers, Mayre@Flatheadcitizens.ore, 406-755-4521, Flathead County Resident
Shirley Folkwein, upperflatheadna@gmail.com , 406-890-1659, Columbia Falls Resident
Phil Matson, flbsphil@email.com, 406-249-2529, Columbia Falls Resident
Peter Metcalf, peterwmetcalf@hotmail.com, 406-531-5098, Columbia Falls Resident
Nicole Bond, Columbia Falls Resident
Becca Wheeler, Columbia Falls Resident
Jim and Heather Peacock, Columbia Falls Residents
Larry D. Williams, Columbia Falls Resident
Rebecca R. (Becky) Williams, Columbia Falls Resident
Attached:
Cc
• The Clean CFAC Coalition's letter of January 18, 2024
• City of Columbia Falls City Council letters to EPA and DEQ in opposition to a waste -in -place
solution,4/6/2015 and 3/25/2022.
• Senator Jon Tester's 5/3/2022 Letter to EPA Administrator, Michael Regan
• KC Becker, Regional Administrator for EPA's Region 8
• Matthew Dorrington, Remedial Project Manager, U.S. EPA Region 8
• Columbia Falls City Council, Mayor Don Barnhart,
• Whitefish City Council, Mayor John Mulfield,
• Kalispell City Council, Mayor Mark Johnson
• Flathead County Commissioners: Brad Abell, Randy Brodehl, and Pam Holmquist
• US Senator Jon Tester, c/o Erik Nylund, Regional Director Butte, and Chad Cambell, Regional
Director, Kalispell
• US Senator Steve Daines, c/o Katie Devlin, Natural Resource Liaison
• Confederated Salish and Kootenai Tribal Council, Tom McDonald, Chair
• The Confederated Salish & Kootenai Tribes: Richard Janssen, Head of CSKT Natural Resources Dept
• The Montana Natural Resource Damage Program: Doug Martin and Katherine Hausrath
• Montana DEQ Project Manager, Richard Sloan
• Flathead City -County Health Department: Jennifer Rankosky
• Flathead Lake Biological Station, UM, James Elser, Director and Tom Bansak, Associate Director
• Western Montana Conservation Commission, Casey Lewis, Executive Director
• Flathead Conservation District, Pete Woll, Board Chair, and Samantha Tappenbeck, Resource
Conservationist
COALITION for a
.. , CLEAN
C FAC
To: Carolina Balliew,
Montana Remedial Section C Supervisor, Region 8,
US Environmental Protection Agency (EPA)
10 West 15th Street, Helena, MT 59626
To: Christopher Dorrington,
Director, Montana Department of Environmental Quality (DEQ)
P.O. Box 200901, Helena MT 59620-0901
January 18, 2024
Dear Ms. Balliew and Mr. Dorrington,
Citizens for a Better Flathead is a citizen -based advocacy organization representing more than 3000
residents of Flathead County. We, along with the Columbia Falls -based Upper Flathead Neighborhood
Association representing some 200 residents in the Columbia Falls area, and a rapidly growing number of
city and county residents throughout the Flathead including a number of former Columbia Falls
Aluminum Company (CFAC) employees and other local organizations, have come together to form the
Coalition for a Clean CFAC. Our mission is to secure the comprehensive cleanup of the Columbia Falls
Aluminum Company (CFAC) Superfund site for the health, enjoyment, and economic benefit of the local
community and the protection of the Flathead watershed.
We are writing now to formally request that the EPA order a time-out to the proposed issuing of a
Final Record of Decision on the CFAC Superfund Site scheduled for an estimated time frame in March
of 2024. We Request that EPA and Montana DEQ not go forward with a Record of Decision based on its
proposed waste -in -place plan outlined in the 2021 Feasibility Study and the 2023 proposed Cleanup plan
for the Columbia Falls smelter site.
While the public record will show that the option of off -site removal of highly toxic waste has all along
been called for and supported by the local community and the Columbia Falls City Council, the
Feasibility Study Report never seriously considered this as a viable option and instead it was deemed,
and early on dismissed, as too expensive. An actual cost estimate was never produced. (See discussion
of "Relative Cost' beginning on page 69 of the 2021 Feasibility Study Report and page 10 of the 2023
Proposed Plan for Cleanup Columbia Falls Aluminum Company Superfund Site.)
We request that EPA and DEQ take a time-out to produce a focused feasibility study evaluating
realistic costs for removal of acute and extremely hazardous wastes including the Spent Pot Liner and
Wet Scrubber Pond Wastes to an offsite hazardous waste disposal facility. This will require
investigation not previously completed during the remedial investigation, including waste volumes,
amount of waste intermingling, and volumes of contaminated soils beneath the existing waste dumps.
This focused feasibility study should include consideration of use of the existing rail lines at the CFAC site
which were used for many years after 1990 to remove highly toxic Spent Pot Liners (SPL) and other
hazardous waste. Not only does the CFAC smelter after 1990 have a history of successfully using the
existing rail lines at CFAC to ship highly toxic waste like SPLs to a federally certified hazardous waste
landfill out of state', other smelters in the northwest like the Alcoa Smelter in Vancouver, Washington
have done so as well.
Our reservation regarding the proposed action calling for leaving toxic waste in place at the CFAC site is
validated and heighten by the recent conclusion of the Montana Natural Resource Damage Program,
acting on behalf of Gov. Greg Gianforte, who was joined by the Confederated Salish and Kootenai Tribes
(CSKT) as well as two federal natural resource trustees, the U.S. Departments of Interior and Agriculture,
to issue a notice of intent to perform a natural resource damage assessment at the CFAC site. Most
telling is the conclusion of their detailed 34-page pre -assessment screen which states regarding the
proposed CFAC cleanup plan that, "EPA has issued a proposed plan for a final cleanup in 2023; the preferred
alternative, however, will not return the Site to baseline. Rehabilitation, restoration, or replacement of
natural resources is required to reduce future injuries and compensate the public for interim losses of natural
resources and the services they provide."2 These findings are one more reason we believe a time out is
warranted to ensure more effective cleanup solutions are considered and adopted.
Actual cost estimates and investigation of additional alternatives should be done as well on treatment
of other potential remaining wastes at the site including their consolidation into a "high and dry" lined
and capped landfill meeting state -of -art design and containment standards for toxic wastes. This and
the removal of the most toxic wastes should be reviewed as a cost-effective alternative to the very
expensive proposed slurry wall containment structure. The proposed use of a slurry wall at this site faces
unique site -specific challenges of high ground water that fluctuates significantly during the year by as
much as 25 feet and the inability of these proposed slurry walls to reach to the depth of a suitable
impermeable layer needed to prevent ongoing contact between groundwater and the buried waste
proposed currently to be left in place. Cost estimates and alternatives should also be reviewed for some
low-level wastes not contaminated with cyanide and fluoride or other such highly toxic wastes, which
could perhaps be sent to the Flathead County landfill, if justified, in limited quantities, as this is a lined
facility that sits some 300 feet above groundwater.
This requested time-out should also provide time to facilitate the missing consideration of an
assessment of climate vulnerability for this superfund site including consideration of long-term impacts
from flooding (climate change) and seismic activity. This assessment is now being done all around the
country and for the Smurfit Mill site in Missoula.
Another important reason and need for EPA and DEQ to take a time-out before issuing a final Record
of Decision (ROD) is a missed step under the Superfund Redevelopment Initiative (SRI) process
established in 1999 to help communities return Superfund sites to productive use3. As this directive
sets forth, "Regions should review the Superfund Land Use Directive and ensure that reasonable future
land use assumptions are incorporated into the development, evaluation and selection of response
actions, where appropriate."
CV 18-131-M-DWM, FINDINGS OF FACT AND CONCLUSIONS OF LAW, CFACLLC vs Atlantic Richfield, 8/25/21
2 Montana Begins Natural Resource Damage Assessment at CFAC Superfund Site, Flathead Beacon 1/16/2024
3 https•//www emgov/superfund-redevelopment/superfLmd-redevelopment-policy-guidance-and-resources and
https://www.epa.gov/superfund-redevelopment/superfund-reuse-planning-support-technical-assistance
For whatever reason or set of reasons, be it the disbandment of the G le nco re-created Community
Liaison Panel once CFAC was designated as a superfund site in 2016, the time wait for site analysis that
followed this, or the chaos of the covid years where no one wanted to gather, a stakeholder process has
never been held to engage the community in imagining potential reuses and future development at the
CFAC 900+ acre site. In our recent outreach in the community, this lack of a future vision for
redevelopment is one that the community wants to see happen so that it can be considered prior to the
final selection of cleanup and remedial processes. Indeed, the EPA has a program to facilitate such
community visioning known as Regional Seeds. 'The purpose of Regional Seeds is to provide site teams
with technical assistance to facilitate redevelopment, remove barriers to productive reuse, and ensure
future use is well aligned with the cleanup and removal/remedial process."
The 2023 proposed Cleanup plan for the Columbia Falls smelter site states on page 4 that "Local
authorities have not adopted a future land use plan for the site." But the plan fails to call for or identify
the benefits to the community of having such a plan in place. Instead, it simply repeatedly states that the
recommended cleanup strategies in this plan are sound given the "current and reasonably expected
future uses" of this CFAC site. But this is not the consensus of the public.
As noted in a front-page story in the Hungry Horse News earlier this month referring to the over 750
pages of comment the EPA received in August on this proposal, "Community members were almost
universally opposed to leaving the waste in place, slurry walls or not. "Leaving the waste in place next to
the Flathead River is a recipe for disaster," one person commented."
The proposed waste -in -place plan would indeed impose severe restrictions on future land uses at the
site with the need for deed restrictions limiting available land uses near the waste dumps, a
groundwater control area banning drinking water wells, and access control points such as fencing and
warning signs; not the vision of a cleaned -up, economically revitalized property that the community so
desires and deserves. A waste -in -place solution fails to provide the assurances the community deserves
that there will not be on -going and worsening leaking of these toxic wastes to ground water and surface
waters. as the waste plume grows and moves.
Removal of the most contaminated wastes including spent pot liners and wet scrubber pond waste, and
consolidation of less contaminated materials in lined and capped and high -and dry landfills on site will
reduce the burdensome restrictions that leaving the waste in place would cause. This will allow a
broader range of land uses benefitting the community in the future.
The smelter produced aluminum, good jobs and taxes for about 54 years, yet the wastes from that
process have remained on site limiting the available uses of the land for 15 years since the smelter
closed. We do not support leaving the waste in place and restricting the use of this land in perpetuity,
just to save some money on cleanup today. The community deserves better than this.
We urge you to call for a time-out to provide Columbia Falls and Flathead residents and businesses a
focused feasibility report evaluating realistic costs for removal of the highly toxic waste on site, as well as
other missing data and costs for other clean-up activities discussed above. We believe this missing
information is essential to be able to a craft future vision for the redevelopment of this site that is
good for the community, the economy, the environment, and for future generations. Without this
information the public and EPA cannot really know if the proposed solution would meet the EPA's
goals for solutions that offer long term effectiveness and permanence, as well as community
acceptance.
Sincerely,
Mayre Flowers, Shirley Folkwein Phil Matson, and Peter Metcalf on behalf of the Coalition for a Clean
CFAC, PO Box 2198, Kalispell, MT 59903
Mayre Flowers, Mayre Flatheadcitizens.org, 406-755-4521, Flathead County Resident
Shirley Folkwein, upperflatheadna@gmail.com , 406-890-1659, Columbia Falls Resident
Phil Matson, flbsphil@email.com, 406-249-2529, Columbia Falls Resident
Peter Metcalf, peterwmetcaif@hotmail.com, 406-531-5098, Columbia Falls Resident
Nicole Bond, Columbia Falls Resident
Becca Wheeler, Columbia Falls Resident
Jim and Heather Peacock, Columbia Falls Residents
Larry D. Williams, Columbia Falls Resident
Rebecca R. (Becky) Williams, Columbia Falls Resident
Attached:
• City of Columbia Falls City Council letters to EPA and DEQ in opposition to a waste -in -place
solution,4/6/2015 and 3/25/2022.
• Senator Jon Tester's 5/3/2022 Letter to EPA Administrator, Michael Regan
Cc
• KC Becker, Regional Administrator for EPA's Region 8
• Matthew Dorrington, Remedial Project Manager, U.S. EPA Region 8
• Columbia Falls City Council, Mayor Don Barnhart
• Whitefish City Council, Mayor John Mulfield
• Kalispell City Council, Mayor Mark Johnson
• Flathead County Commissioners: Brad Abell, Randy Brodehl, and Pam Holmquist
• US Senator Jon Tester, c/o Eric Erik Nylund, Regional Director and Natural Resources Liaison
Butte, and Chad Cambell, Regional Director, Kalispell
• US Senator Steve Daines, c/o Bret Slaughter, Natural Resource Liaison
• Confederated Salish and Kootenai Tribal Council, Tom McDonald, Chair
• The Confederated Salish & Kootenai Tribes: Richard Janssen, Head of CSKT Natural Resources Dept
• The Montana Natural Resource Damage Program: Doug Martin and Katherine Hausrath
• Montana DEQ Project Manager, Richard Sloan
• Flathead City -County Health Department: Jennifer Rankosky
• Flathead Lake Biological Station, UM, James Elser, Director and Tom Bansak, Associate Director
• Western Montana Conservation Commission, Casey Lewis, Executive Director
• Flathead Conservation District, Pete Woll, Board Chair, and Samantha Tappenbeck, Resource
Conservationist
130 6TH STREET WEST
ROOM A
COLUMBIA FALLS, MT 59912
April 6, 2015
Docket Coordinator, Headquarters
U.S. Environmental Protection Agency
CERCLA Docket Office (Mail Code — 5350T)
1200 Pennsylvania Avenue, NW
Washington, DC 20460
RE: FDMS Docket ## EPA-HQ-SFUND-2015-0139
PHONE (406) 892-4391
FAX (406) 892-4413
RECI<IVED
APR 14 2015
EPA DOCKET CENTER
The Columbia Falls City Council supports the listing of the Columbia Falls Aluminum Company Plant
(CFAC) on the National Priorities List. The Council recognizes the importance of the process, particularly
the completion of the Remedial Investigation/Feasibility Study. As the owner of the property elected to
end negotiations with MT DEO, DEQ and EPA must ensure that remediation and cleanup will occur in a
timely manner.
The City Council, on be of the community, express their desire to see the site cleaned up, preventing
the sftead of grouridwater contaminants. Providing clean, safe drinking Water is important to the
Council and to that end, the City has made significant investments in providing safe drinking water to
the citizens of Columbia,Falls. While the testing of the City's well have not revealed that the known
contaminants from the CFAC site have made their way into the City's drinking Ginter supply as of now,
the City would not like to see cleanup and remedial action delayed until the -City is faced with costly
emergency measures to protect the City's water supply.
Also important, is the redevelopment of the CFAC site to provide long-term, sustainable employment
and development in the community.
Please record the City Council's unanimous support of the listing of the CFAC site on the National
Priorities List.
Sincerely,
?r,. Councilman
Julie Plevel, Counc' an
1ich
id Petersen, C Gilman
ael Shepard Councilman POSTMARKED
APR 0.7 ZB'5
EPA DOCKET CENTER
130 6TH STREET WEST
R0010 A
COLUMBIA FALLS. KliT 59912
March 25, 2021
US EPA — Region 8
Attn. Ken Champagne
10 West 151" Street
Helena, MT 59626
Sent Via Email: Champagne.l<enneth@epa.gov
RE: Columbia Falls Aluminum Company Site Feasibility Study
Dear Ken:
PHONE (406) 892-4391
FAX (406) 892-4413
The Columbia Falls City Council would like to express concerns over the initial draft feasibility study for the
cleanup of the former Columbia Falls Aluminum Company site which proposed leaving some hazardous
materials on the property. The EPA and Glencore hosted a virtual meeting on February 11, 2021 whereby the
draft plan was discussed. We understand that the EPA will prepare the draft plan for public comment later this
spring but we wish to submit our comments at this time.
The City Council, on behalf of the community, continues to express their desire to see the site cleaned up with
the contaminants removed from the site and not covered up or left in place to prevent the spread of
groundwater contaminants. Providing clean, safe drinking water is important to the Council and to that end, the
City has made significant investments in providing safe drinking water to the citizens of Columbia Falls. While
testing of the City's wells have not revealed that the known contaminants from the CFAC site have made their
way into the City's drinking water supply as of now, the City would not like to see cleanup and remedial action
delayed until the City is faced with costly emergency measures to protect the City's water supply.
History has shown that contaminants can surface many years later. Respectfully, we do not want to have a
repeat of the Opportunity/Anaconda site issues with groundwater contamination appearing years after "clean
up." Leaving contaminants on site should not be an option.
Please consider the City's paramount concern of providing safe, clean drinking water to our community while
preparing the cleanup plan as well as the impacts in the residential areas just outside the City, such as Aluminum
City. The ecological well-being of the Flathead River is of utmost significance to our community.
Sinc ly,
Donald W. arnhart, Mayor
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Darin Fisher, Councilman
John Piper, Councilman
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Michael Shepard, Counci man
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INDIAN AFFAIRS
VFTE RANS' AFFAIRS
May 3, 2022
The Honorable Michael Regan
Administrator
Environmental Protection Agency
1200 Pennsylvania Avenue, N.W.
Washington, D.C. 20460
Dear Administrator Regan:
Su.-TE RANT 8
Smw 311
WA'; INGTOn, DC 20510
202- 224 -2644
tester .agnate-g oviconwct
I am writing to highlight growing concerns from communities in Montana about the
EPA's use of waste -in -place remedies at Superfund sites, and the importance of outreach from
EPA staff to communities navigating the Superfund process. EPA has a critical responsibility to
ensure communities are well-informed so that they can provide meaningful input into cleanup
decisions, and that remedies the agency supports are protective of human health and the
environment.
I am troubled by the EPA's reliance on waste -in -place remedies at multiple sites in
Montana. Communities are rightfully skeptical about the risks posed by leaving toxic waste on
site where it could migrate into groundwater or surface water. There are multiple waste -in -place
remedies that are either already in place or under consideration that are mere feet away from
rivers in Butte, Anaconda, Frenchtown, and Columbia Falls. In 2017, flooding at the Smurfit
Stone site damaged the berm separating the site from the Clark Fork River, and also sent a plume
of material into the river. Modeling from the Montana Bureau of Mines indicated that waste
from tailings at the Butte -Silver Bow site would migrate much more quickly than EPA
suggested, and present an imminent risk to groundwater and surface water. Despite EPA
assurances about the extent and mobility of contamination, there has been subsequent testing by
state entities raising serious questions about assumptions made during the investigation. At
Columbia Falls, community leaders have told me that their repeated concerns about the risks a
potential waste -in -place remedy poses to headwaters have seemingly fallen on deaf ears. At a
minimum, this creates a public trust and confidence issue at other sites. Worse, a remedy that
isn't effective poses a direct threat to human health and water quality.
The EPA needs to do more to ensure that planned remediation actions are actually
protective of the sites in question, and that the public is well-informed of the inherent risks
associated with waste -in -place remedies. EPA should work with affected communities to ensure
that controversial waste -in -place remedies receive significant additional scrutiny, either through
direct analysis from EPA staff or in concert with hydrology experts from other
agencies. Objective experts should clearly demonstrate to the public, based on real -world
monitoring from the site and surrounding waters, that their proposed remedy keeps waste where
it should be. Input from outside experts, especially those with additional monitoring data, should
be welcomed, and responses to that input should be included in the EPA's analysis of the site and
its outreach to the affected community. If an affected community calls for an alternative remedy,
EPA should give serious consideration to developing an alternative cleanup solution and, if those
BILLINGS BOZEMAN BUTTE MISSOULA GREAT FALLS HELENA KALISPELL
(406) 252-0550 (406) 586-4450 1400 723-3277 (406) 728-3003 t4W 452-9585 1406) 449-5401 (406) 257-3360
alternatives aren't feasible, provide detailed explanations in public meetings and online why
those remedies are not possible.
In addition to bolstering its scientific analysis of waste -in -place remedies, EPA also
needs to improve its outreach to affected communities. The public needs a clear understanding
of the procedural and scientific steps involved with cleaning up a Superf ind site, and much
earlier in the process than has occurred, so that their input can be considered in feasibility studies
remediation investigations. I have spoken directly with many community leaders from across
Montana who have attended EPA briefings on their site, and left without a clear understanding of
what steps remained before remediation could begin, when and how the public could comment
on proposed remedies, and how EPA was verifying that a proposed remedy was protective. In
many cases, briefings that contain digestible information came long after critical steps were
complete. When local elected officials, leaders of community groups, and business owners don't
have this information in plain English, it is supremely difficult for them to effectively advocate
for the remediation that actually works for the community during those critical early portions of
the process.
For community leaders to be better informed, the Community Involvement Coordinators
for Montana's sites need to ensure public meetings are sufficiently noticed. Information
presented at those meetings must be comprehensible to members of the public who are not
subject matter experts, and local stakeholders need to be informed about the scientific
justification for specific remedies well before milestones are reached. Montana communities
also need to be informed about their options to secure direct financial support for technical
assistance through EPA's Technical Assistance Grants and Technical Assistance Services for
Communities. Online information needs to be presented clearly, informatively, and as
objectively as possible. The website for Columbia Falls includes a misspelling in the first few
sentences explaining the site, and links through to the potentially responsible party's non -
government website to explain the Superfund process and remedial investigation. This does not
inspire confidence that EPA is treating this site with a high attention to detail and providing
objective information to the public. I encourage you to revisit your online presentation of
information, and promptly schedule in -person public meetings within your ongoing COVID
safety guidelines to more clearly explain proposed remedies and the Superfund cleanup process
with Montana's Superfund communities.
Thank you for your work to engage with Montana's Superfund communities, and to
ensure remedy options are substantially protective of human health and the environment. EPA
has an important role to play in our daily lives and has an opportunity to improve public
perception across its programs.
Sincerely,
Jon Tester
Flathead Comity
Board Of Commissioners
(406) 758-5503
Brad W. Abell
Randy L. Brodehl
Pamela J. Holmquist
February 12, 2024
Missy Haniewicz
U.S. EPA, Region 8
1595 Wynkoop Street
Denver, Colorado 80202-1 129
Subj: Columbia Falls Aluminum Company Superfund Site
The Flathead County Board of Commissioners is urging the EPA to postpone its final
determination on the cleanup of the Columbia Falls Aluminum Superfund site until a
comprehensive evaluation is conducted. This evaluation must thoroughly assess the potential
impacts on the pristine waters of the Flathead River, Lakes, and the Columbia River headwaters
that could result from the retention of a million cubic yards of hazardous waste on -site.
Additionally, it should entail a thorough cost analysis comparing the removal of waste versus
capping and lining in place, with a focus on the implications for the next century and beyond.
Given the proximity of this project to the vibrant and expanding community of Columbia Falls,
Montana, the EPA should also actively seek public input from residents regarding the potential
impact on adjacent neighborhoods and the future growth prospects of Columbia Falls.
Please include these comments in the Administrative Record for the Superfund Site.
Sincerely,
BOARD OF COMMISSIONERS
FLATHEAD COUNTY, MONTANA
Randy L. Brodehl, Chairman
Not Available for Signature
/P:am�da-V'Holm u' mber
Jie
Br '. Abell, Memb
800 South Main, Room 302 ** Kalispell, MT 59901 ** Fax (406) 758-5861