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2-26-2024 Clean CFAC Coalition to EPA_ 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 signatures1 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 1 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.org, 406-755-4521, Flathead County Resident Shirley Folkwein, upperflatheadna@gmail.com , 406-890-1659, Columbia Falls Resident Phil Matson, flbsphil@gmail.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: • 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 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 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