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United States
Environmental Prol8cllon
Agency
Office of
Emergency and
Remedial Response
EPAIROD/R08-861006
September 1988
3EPA
Superfund
Record of Decision:
~B~7 -I g &J ~7 '-I
:ollection
:e Center
107
Libby Ground Water, MT
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U.S. Environmental Protection Agency
Region III Information RGSOlAfca
Center (3PM52) ,
841 Chestnut Street "/ ,"
Philadelphia, fA 1910l ~~
/
EPA Report Collection
Information Resource Center
US EPA Region 3
Philadelphia. PA 19107
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TECHNICAL REPORT DATA
(Pltut rnd '''tlfUCl/O''t 0" lht rtvtf!t bt{fNt co,""lttl"lI
1. PlI,OIllT NO. 12. 3. AECIPIENT'S ACCESSION NO.
EPA/ROD/R08-86/006
.. TITI.& ANa SU.TITI.! 5. AE"OAT OATE
SUPERFUND RECORD OF DECISION - ?j:; , aCj:;
Libby Ground Water, MT e. PEAflOAMING OAGANIZATION COOE
7. AUTMOIIIIS) 8. PEAflOAMING ORGANIZATION REPOAT NO
8. PI!III"OIllMINQ OIllGANIZATION NAME ANa AOOIIII!$$ 10. PAOGAAM EI..EMENT NO.
". CONTRACT/GRANT NO.
12. SPONSOIIIING AGENCY NAME ANa AOOAESS 13. TYPE 01' REPOAT ANO PERIOO COliEFlEO
U.S. Environmental Protection Agency ""-~, t)"n
401 M Street, S.W. 16. SPONSORING AGENCY COOE
.-.
Washington, D.C. 20460 800/00
115. SUP'I.EMINTAIIIY NOTES
Ie. ABSTRACT
The Libby Ground Water Contamination site, in the northwest corner of Montana,
consists of Champion International corporation's active lumber and plywood mill, the
City of Libby, and surrounding developed but unincorporated areas. The Champion lumber
and plywood mill was owned and operated by the J. Nells Lumber Company from 1946-1957,
and by St. Regis Company from 1957-1985. Abandoned wood treating operations on the mill
property are the source of ground water contamination. getween 1946 and 1969, wood
treating fluids were disposed of and spilled at several different mill locations: waste
water, formed as vapor in the retorts, ',.,as placed in onsite waste pits: and tank bottom
sludges from wood treating fluid tanks were periodically removed and hauled to the wastE
pits. In addition, spills of treating fluid occurred onsite. In 1979, shortly after
installation of private wells, some homeowners detected the presence of a creosote odor
and EPA monitoring in 1981 confirmed ground water contamination. Based on 1984 well
sample results, Champion implemented the Buy Water Plan. Under this program,
individuals with contaminated ground water wells agree to cease using their well and us~
water from the public water system operated by the City of Libby. Champion, providing
monetary compensation to the wellowners to pay for this metered water, also caps anrj
locks the previously operating wells. The program, indefinite in term, would be
terminated upon the elimination of the threat of contamination, if the well owner
(~I'I'" A~+-",~h",~ ~hp".r)
1 7. KEY WOAOS ANO OOCUMENT ANAI.."'SIS
a. OISCIilIPTOIIIS b.IOENTIFIEI'ISiOPEN ENOEa TEI'IMS c. COSA TI Flelc1:Group
. .
Record of Decision
Libby Ground Water, MT
Contaminated Media: sw, soil
Key contaminants: VOCs, organics,
PARs
18. OISTRIBUTION STATEMENT 19. SECURITY CI..ASS I nlls R,po,r/ 21. NO. OF i>AOES
20. SECuAITY ~a iTllls PO,'I 22. i>""ce 81
I'. 11- 2220-1 (R... 4-771
II,.CV'OUt &0'1'10'" It 0810l.&1'C
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EPA/ROD/R08-86/006
Libby Ground Water, MT
16.
ABSTRACT (continued)
provides a written termination notice, or if other alternatives become
available. The primary contaminants of concern include: VOCs; PAHs, PCP,
organics, inorganics, heavy metals, and creosote.
The selected remedial action for this first operable unit includes the
continuation and expansion of ~he Buy Water Plan sponsored by Champion and
the enactment of an ordinance which prohibits installation of new wells for
human consumption and irrigation, but would allow well installation for use
in closed systems. The estimated capital cost for this remedy is $152,000
with annual o&M costs of $64,000, both to be paid by Champion. Federal
funds will be required for oversight of Champion's actions at an estimated
annual cost of $20,000.
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RECORD OF DECISION
ROO ISSUES ABSTRACT
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
COMMUNITY RELATIONS ~ESPONSIVENESS SUMMARY
ADMINMISTRATIVE :ORDER ON CONSENT, DOCKET NO. CERCLA-VIII-83-03
FIRST OPERABLE UNiT
LIBBY GROUND WATER CONTAMINATION SITE
LI BBY, MONTANA
SEPTEMBER 19, 1986
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RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION FOR FIRST OPERABLE UNIT
SITE
Libby Ground ~ater Contamination Site
Libby, Montana
DOCUMENTS REVIEWED
I am basing ~y de~ision primarily on the following documents describing
the analysis of the cost and effectiveness of the remedial alternatives for
the first ooerable unit of the Libby, Montana Ground ~ater Contamination Site:
o
Phase IV Remedial Investigation Report, Libby, Montana Ground Water
Contamination Site. dated July 1986 and preoared by Wood','iard-Clyde
Consultants for ~~ampion International Corporation
o
Feasibility Study for the First Operable Unit Libby, Montana Ground
Water Contamination Site, dated July 1986 and prepared by
Woodward-Clyde Consultants for Chamcion International Corporation
a
Summary of Remedial Alternative Selection
o
Responsiveness Summary
o
Staff Briefing'Paper
Administrative Order on Consent, Docket No. CERCL~ VIII-83-03,
October 18, 1983
DESCRIPTION OF SELECTED REMEDY FOR FIRST OPERABLE UNIT
a
The remedy sele~ted for the first operable unit will reduce human exposure
to contaminated ground ~ater. It consists oT 2 parts: (1) the continuation
and the expansion of the Buy !,jater Plan instituted by Champion International
in 1985 to eliminate exposure to existing contaminated wells; and (2) passage
by the City oT Libby oT a local ground water well installation ordinance.
The Buy Water Plan is an agreement whereby individuals with detectable
contaminants in their ground water wells agree to cease using their well, and
instead use water from the public water syste~ ooerated by the City of Libby.
The '.'iell O\,,"er also allows Champion to cao and locK the 'Nell. Chamoion
provides monetary compensation to the well owners to oay for costs incurred by
using metered public water instead of well water. The source or the public'
water suppiy is uncontaminated surface water from an upstream reservoir on
Flower Creek. .
The local ordinance is in the form of a city-wide well permit system. The
permit system precludes the installation of new wells for human consumption
and irrigation. Violation or the ordinance is punishable by fine up to
$500.00 and imprisonment up to 6 months.
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On July 21, 1986, the City passed the above ordinance on a 90-day
emergency basis. This allowed the ordinance to take effect during the 1986
irrigation season. The City has begun the procedural steDs necessary to ~ake
this a per~anent ordinance.
The primary reason for installation of new ~ells by Libby residents has
been to avoid the increasing casts of city water. Water use is highest in the
summer lawn and garden irrigation season. In order to provide an incentive
for Libby residents to comply ~ith the new ordinance, Chamoion has entered
into an agreement with the City to provide free irrigation ~ater to Libby
residents. Champion pays the City directly for a fixed amount of irriaation
water cer household. -
In order to achieve effective i~elementation, the following conditions
must also be part of the~emedy:
( 1 )
If it becomes necessary, Chamoion must take stees to insure that
sufficient water to meet the demands of the Buy Water Plan and the
free irrigation water agreement is available until the final remedy
is effective; .
( 2)
The city water system must be tested for all contaminants of concern
to demonstrate. that it is not contaminated from some other source;
(3 )
Champion must continue to monitor wells within and outside of the
city limits (including in West Libby) for changes or movement of the
plume boundary. If additional '."ells become contaminated, the
recommended remedy should be extended to the owners of those wells;
(4)
Chamoion must establish a part-per-trillion (pot) monitoring program
for PAH in wells on the fringes of the current plume boundary. ~
detection limit of 2 oat or less '."ould be sufficient to demonstrate
whether PAHwater qua~ity was below the lxlO-6 carcinogenic risk
level of the Ambient Water Quality Criteria for PAH. If additional
w~lls are found to be contaminated above the lxlO-6 risk level, the
recommended r~~edy must be extended to these well owners;
(5)
Without prior written approval from EPA, Chameion must not consent to
a change in its written agreement with the City to provide free
irrigation water to Libby water users;
(6 )
Until the final site remedy is cJmplete and effective, for those w~ll
.Qwner$ who decline or discontinue participation in the 3uy Water Plan
Agreement, Champion must notify the well owner by certified mail that
he/she has been offered the agreement, but has declined to .
participate. A copy of the notification must be sent to EPA;
Until the final site remedy is complete and effective, Champion must
demonstrate annually that all new residents who purchase properties
with contaminated wells have been offered the Buy Water Plan
agreement in accordance with condition (6) above;
(7)
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(8)
By matching available public records (such as water service
connections and land ownership records), Champion must demonstrate
that all residents who do not have water service connections have
been offered the Buy Water agreement in accordance with condition (6)
above;
The recommended alternative provides an interim remedy, and its
approval assumes that the final remedy will adequately restore ground
water quality. If such restoration is determined not to be possible,
the first operable unit remedy must undergo substantial improvement
or modification before EPA could approve it as a final remedy.
Under the selected remedy, no Federal funds will be requested for
operation and maintenance requirements, as Chamoion will undertake the
remedy. However, Federal funds will be necessary to provide for oversight of
Champion's activities un.tjl the final remedy is effective.
(9)
DECL~RATIONS
Consistent with the Comprehensive Environmental Response, Compensation,
and Liability Act of 1980 (CERCLA), and the National Contingency Plan (40 CFR
Part 300), I have determined that, as a first ooerab1e unit, the Buy Water
Plan With Ordinance at the Libby, Montana Ground Water Contamination Site is a
cost-effective remedy, is consistent with a permanent remedy, and as a first
operable unit provides protection of public health, welfare, and the
env; ronment.
The State of Montana has been consulted and agrees with the approved
remedy.
I have determined that the selected remedy is only an interim remedy.
have also determined that the action being taken is a cost-effective
alternative when compared to the other remedial options reviewed.
Champion recognizes that further remedial action may be required, and is
currently undertaking additional remedial investigation and feasibility
studies to evaluate alternatives for final site remediation involving control
of contaminant migration and contaminant removal. If additional remedial
actions are determined to be necessary, a Record of Decision will be prepared
for approval of the future remedial action(s) for remaining operable unit(s).
~ 02'1 / I?'
Date
~"-. .t-. 4. ~~
John G. Welles ~
Regional Administrator
Attachments:
ROO Issues Abstract
Summary of Remedial Alternative Selection
Community Relations Responsiveness Summary
Administrative Order on Consent
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:S AND RESOLUTION
.he City of Libby also considered prohibiting the use of existinq wells,
Jut counsel for the City advised against such action based upon concerns
)f inverse condemnation and other taking issues. The "Buy Water"
!qreement affords adequat~ protection to those well owners who sign the
!greement. Well owners have been informed many times individually and via
Jub1ic meetings, mass mai1inqs, and the media of the existence of
:ontamination, and have been advised by EPA, Chamoion, the City, and the
:ounty sanitarian not to use the ground water. Therefore, it is
reasonable to assume that any well owners who do not sign the agreement
will have made an informed decision.
Key Words':
Water rig~:s, Inverse condemnation
Due to limited city and county resources, enforcement is not expected to
playa large part in compliance with the city ordinance restricting well
installation. However, the "free irrigation water" incentive is expected
to result in a high level of voluntary compliance, as the cost of city
'Hater is .the primary reason Libby residents have installed wells.
Key Words:
Institutional controls
This remedy provides an interim remedy, and simply breaks the exposure
link between Libby residents and contaminated qround water. It is
anticioated that this remedy will no longer be needed when final
remediation is complete and effective. Champion is currently conducting
the RI studies necessary to suoport an FS for aquifer restoration and soil
cleanup to complete the site response.
Key Words:
Alternate water supply, Temporary remedial alternative,
Operable unit, Ground water, Carcinogenic comoounds, PAH
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
CONTENTS
. Site Location and Description................................. 1
Site Hi story. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 1
Current Site Status........................................... 4
Enforcement Anal ys is. . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . .11
A 1 terna t i ves E val ua t ion. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
Cost. . . . . . . . .. .. . . . . . . . . . . . . . . . . . .. . . . .. . . . . . . .. . . . . . . . . .24
InstitutionaJ Considerations.............................24
R e 1 i a b i 1 i t;{.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
Effectiveness............................................27
Adverse Impacts.......................................... 27
COlT1T1un i ty Re 1 at ions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .28
Consistency With Other Environmental Requirements.............28
Recommended A 1 ternat i ve. . . .. .. . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . .29
. Operation and Maintenance.....................................31
S c h ed u 1 e. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
Futur~ Actions................................................~31
Fiqures
1.
2.
3.
4.
S.
6.
Tables
1.
Exhibits
1.
2.
3.
Location Map........................................ 2
L ; bby 5; te Mac...................................... 3
Mac Showinq Shallow Aquifer PCP and PAH Plume....... 7
Extent of Volatile Organics Contamination........... 8
Well Locations with Metals Above Backqround......... 9
Map Showing Deeper Aquifer Zone Plumes.............. 10
Contaminants Detected in Private Ground
Water We 11 s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 6
2.
3.
4.
5.
Health Effects of PAH Compounds Detected in Off-site
We 11 s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 2
6.
7.
Acute and Chronic Toxicity Summary for Contaminants.14
SUlT1T1ary of Basel; ne Hea 1 th Risk s . . . . . . . . . . . . . . . . . . . .15
Comparison of Standards to Exposure Point
Concentrations...................................... 16 .
Estimated Costs of Alternatives.....................25
Summary of Institutional Contro1s...................26
Champion's 1985 Buy Water Agreement.................18
City Ordinance......................................20
Free Irrigation Water Aqreement.....................22
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
LIBBY MONTANA GROUND WATER CONTAMINATION SITE
SITE LOCATION AND DESCRIPTION
The Libby Ground Water Contamination Site ;s located in and near the city
of Libby in the northwest corner of Montana (See Figure 1). The site is
located in a glacial valley at an elevation of 2100 feet MSL, surrounded by
mountains rising to elevations of over 4500 feet.
The site is bounded on the north by the Kootenai River, on the east by
Libby Creek, and on the west by Flower Creek. The site consists of Champion
International Corporation's lumber and plywood mill, the City of Libby, and
surrounding developed but unincorporated areas (See Fiqure 2). The Chamoion
mill property, the only known source of the contamination, borders the City of
Libby on, the east and southeast.
The City of Libby had~,a 1980 census population of 2748, and the
surrounding unincorporated areas had a population of 8212. The entire city is
contained within a 1.75 mile radius of the on-plant source areas.
The City obtains its public water supply from a reservoir on Flower Creek,
about 3 miles upstream from the site. Ground water is contained within the
alluvial 'material of the Kootenai River, and Libby and Flower Creeks.
SITE HISTORY
Champion presently operates an active lumber and plywood mill on the
site. The mill was owned and operated by the J. Neils Lumber Company from
1946-1957, by St. Regis Company from 1957-1985, and is currently owned by,
Champion International Corporation.
Abandoned wood treating operations on the mill property are the source of
,the qround water contamination. The wood treating operations beqan in 1946
and ceased in 1969. Wood treatinq fluids are known to have been disposed of
and spilled at several different locations at the mill during the early
operation of the plant. Waste water, formed as vapor in the retorts, was
placed in on-site waste pits. The waste water was estimated to be 95 percent
water, 3 percent light oil fractions and 2 percent creosote. Tank bottom
sludqes from wood treating fluid tanks were periodically removed and hauled to
the waste pits. In addition to the waste pit operations, spills of treatinq
fluid are known to have occurred in the tank farm area and the butt dip tank.
Each of these areas was located near the wood treating retort plant. The
retort plant and related facilities were removed shortly after termination of
wood treating operations in 1969, and the areas were backfilled and graded.
In 1979, installation of private wells and consumptive use of ground water
'increased, due in part to a rate increase for the town water supply. The
primary purpose of the new wells was for lawn/garden irrigation and heat pump
uses. Although most well owners are also connected to the city water system
and purchase metered water from the city, some well owners are not connected,
and derive all their water from their well.
Shortly after installation, some homeowners detected a creosote odor from
their wells. Subsequent field monitoring by the EPA in June 1981
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and preliminary sampling of domestic wells by the FIT contractor (Fred C. Hart
and Associates), confirmed that ground water contamination had occurred. The
consultant team of Alsid-Carr was retained by St. Regis to further study the
extent and concentrations of contaminants. An initial investigation (Phase I)
commenced in spring 1983, focusing on inventory and sampling of domestic
wells.
In December 1982, EPA proposed adding the Libby Ground Water site to the
National Priorities List (NPL), and in September 1983, the Libby site was
finalized on the NPL.
Following signing of an Administrative Order on Consent by the St. Regis
Corporation and EPA on October 18, 1983, a formal RIfFS program began. Phase
II consisted of the plan for further field work, and Phase III the field work
and report. Monitoring 'NeJls were installed and water quality samples were
collected from these and selected existing homeowner wells in January, April,
July, and October of 1984. The Phase III RI report was submitted in June 1985.
Champion purchased St. Regis in early 1985 and retained Woodward-Clyde
Consultants to conduct and prepare the Phase IV RIfFS and Endangerment
Assessment. Phase IV field operations were conducted from May 1985 to
February 1986, and included expanded well installation and sampling, soil and
geotechnical investigations, and samoling of surface water and sediments. The
Phase IV RI report, and. the Feasibility Study for the First Operable Unit were
submitted in July 1986.
During the course of the Phase IV RI, Champion discovered that heavy oil
contamination had occurred to a greater depth and areal extent than previously
observed. It became apparent that final remediation of the site required
further RI studies to determine the extent of the heavy oil contamination. In
order to provide for protection of public health in the interim, consideration
was given to dividing the site into operable units. In accordance with
Section 300.68(c)(3), it was determined that the operable unit approach would
be cost effective and consistent with the final remedy. Therefore, the site
was divided into operable units.
The first operable unit, and the subject of this ROD, addresses public
exposure to contaminated ground water. Field studies are currently being
conducted for subsequent operable units which will address aquifer restoration
and source cleanup.
CURRENT SITE STATUS
Abandoned wood treating operations on the mill property are the source of
the ground water contamination. The wood treating operations began in 1946
and ceased in 1969.
Four basic types of wood treating fluids were used at Libby: creosote,
pentachlorophenol (PCP), salt treatment, and fire retardant.
-..----. --.-..--- -~_. "..-'---- -_. -- ,. - ..
z
;:,
/
-------
-5-
Technical grade pentachlorophenol used for wood treating contains 85-95
percent PCP, 5-15 percent other chlorOPhenols, and 0.1 percent
dioxins/furans. (The oils and contaminated soils at this site were found to
contain all isomers of the chlorinated ~ioxins and furans, except the tetra
isomer. No dioxin or furan isomers ~ere detected in private well samples.)
The light solvent used with PCP in the wood treatment process was a mixture of
mineral spirits, polyethylene glycol, and wax.
Creosote is a complex mixture of over 200
aooroximately 85 percent polynuclear aromatic
phenolic compounds and 3 percent heterocyclic
compounds.
orqanic compounds and contains
compounds (PAH), 12 perce~t
nitrogen, oxyqen and sulfur
The ingredients of salt treatinq fluids were fluoride, chrome, arsenic and
dinitrophenol. The fire ~etardant was composed of zinc chloride, chrome,
boric acid and ammonium sulfate.
Ground water contamination has been observed in wells located both on the
mill property and on private properties in the City of Libby. Sampling and
analysis of 67 private off-site qround water wells was conducted at least once
per well ~n 1985, and most were sampled 3 times (March, June, and September).
A total of 32 of these wells are known or suspected (some data are not
entirely conclusive or consistent) to be contaminated with PCP, creosote
chemicals (PAH), some vOlatile organic compounds, and some metals. No
chlorinated dioxins or furans have been detected in private well samples. A
summary of these 1985 data is provided in Table 1. Althouqh private wells
both within and outside the city limits have been monitored for contamination,
only wells within the city limits were found to be contaminated.
Based on 1984 sampling data, Champion offered Buy Water agreements (an
aqreement to supply alternate water, described on paqe 6 of this document) to
the 15 owners of contaminated wells in 1985. Eleven of the 15 siqned. (After
beinq informed of the possible hazards of using the contaminated water, 4
owners still wished to retain the use of their wells.) Based on 1985 data, a
total of 32 wells were identified as beinq within the contaminant plume. This
apparent increase in number of contaminated wells is not due to the migration
rate of the contaminant plume. Rather, all private wells had not yet been
identified for the 1984 samp1inq, and some additional wells were installed
between samplings. Champion plans to extend Buy Water aqreements in 1986 to
the 17 additional identified well owners plus the 4 who did not sign in 198~.
Fiqure 3 shows the extent of contamination of PCP and PAH compounds in the
shallow ground water aquifer (less than 70 feet) based on the location of
known and suspected contamination in shallow water wells. Similar analyses
delineated plumes for volatile organic and halogenated organic compounds
(Figure 4) and metals (Figure 5) in shallow ground water aquifer. The
contaminant data for the deeper water bearing units (lOQ to 170 feet) are more
limited. Figure 6 shows the estimated areal extent of heavy oil and of PCP
and PAH compounds in the deeper aquifer.
----"...' ."_0__.._.-..--"
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- n -.-..------..... -_.. --
-------
-6-
:;,
T.;mz 1
CONTAMINANTS DETECTED IN PRIVATE GROUND wA TER WELLS
(ALL PAH COMPOUNDS INCLUDED)
No. of
Safiioles
GSiJmet:-ic ,;lbove
Chemical Rar.ce C;c/1) Me:.n ('~a/1) ::: Dete::~on
.Arser1ic 5 5 --':) Z
:inc 2CO 1,(!OO 5: 1. 73 7
Coooe: 23 160 ~2. 53 6
Chromium 6 10 7.33 (!
Lead --. 30 30 --{Z) 1
Nickel 7 29 14.25 2
Pentachlorophenol 2.3 - 3,200 89.49 20
Naohthalene 2 SuO 33.23 18
Acenaohthylene 1 :00 13.95 13
Acenaohther1e 3 100 2a..i7 ~?
,-
Fluore!ie 0.75 118 8.39 23
Phenanthrene 0.82 212 8.63 17
,A,nthracer1e 0.11 1 - 1.07 13
_:J
Fluoranthene 0.12 93 0.:5 9
Pyrene 0.111 114 0.62 6
Chrysene 0.067 5 0.117 a.
Benzo ( a) anthracene 0.093 1 0.30 2
Benzo (k) fluoranchene
Benzo (b) fluoranthene
8enzo (a). pyrene
Indeno (123, cd) pyrene
Oibenzo (an) anchracene
8enzc (ghi) ;:erylene
1-ii1e:hyl nao'Chaler.e 7.4 250 50.1 9
2-;ne':hyl naohthalene 1.1 43 9.87 4
8enzene 2 20 5.98 9
Toluene 1.2 51 5.12 7
Tota 1 Xylene 2 109 17.55 18
2-8utanone
(Me1:hyl Ethyl Ketone) 1? 1 280 103.75 ~
--. .
1,1,1 Trichloroethane 0.6 a5 - O? j 1
O.J- .1.-
E':hylbenzene 1 19 5.62 ..
J
Carcinogen PAH's 0.067 93 0.52 21
(1) Only values measured above detection were used
geometric mean.
in
calculating the
(%) No geometric mean concentration is estimated since the compound was
either detected in only one well or only one time during the 1985
sampling program.
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EXTElIT OF VOLA 111.£
ORGANIC COMPOUND AND
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ORGANICS CONTAMINI\ TlON
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..~~<~.:~ ~:-:, -'.".... i,i,/...'. "":":'~~ .:,'::," ":"...;"'':',. ,"...::- 8; '86004,' ,,-- 'f.,"", .;:-~,~.~.:.._.~._---.,. ...::::.t/~" U,ol'-"
, ) --...,:, ' ",,' <;' 'J.t ;,' (' ""'. -: '',; ..' (" :,;."/ ~ oCHI"---.'Q{)l _Io{).~ I ~ I' i ,: '~-~:co::-' 0' "', "
// / ''''')'' j)' ~x , ..'::. ~)~:, 31 r:~C' :,i~~":"~:"I"">:~'",,/' -';~" ~ ,-~o:-;"" <},'" ;;::::; '~,11 11 ~ ;i9~~I;=""':';""'.':"'.""";-:-"\" ":~,
~/ /( !' f/// ",# ' , i,,~r.;. )'':t~,)''''<''j., :":'<.' '~/, t/~;, '"', I 1~""@_1'9~L_J)A;<"Ln N
. ,-:.0 .~i ,0/..: Q~ I r: li1. "."~I.,",,:-','~. -....' ;". 'f", ,'. -.'-~. I '.06~. . .I'-~I" . oi-:"'Ir:::.--;'-~"),,!:;' ~(: "\
...' ,," )11, () / " ,:;" ", r ." ~.,..' ,'," '.' '..00.. -' - I 11 ("" I, I 0.00 oor. '0;(0'
' , ~: . :' it , ":,; /.)f::~', ~ ", ,; ~':o--' ,/ .: 'cJ C'":'" , 'I,. "J~"='L JI~,,1,,: ",r 1,,_, ;~.\;~ ',~ '(EET -
:"1)~W:lf/ ' ) / :""" - '~ " ", -:~ :,',::r'~~~~':,(:./,<, ;~-:. .."~>, <~~ !"':~:~~f~d"C":\';''''' ,_u .o{)::~~=II'[i:~JO- ' ,lr~-J;")';':"i;,,'l
// ! rJ / '/». "', ',;' ~:..,I "~~~,f'.'::/':'i:;/( '/'~:'" ~~;. »'., ,if' ':~, " , r, ,,/-" j(. I;';;'~ '.'.~' .
,/ I. ",' ' ",,;,';', '')'(\!" '" " :, :.', -,' ,10,)1.: KH& .1Q9~ ,- L,' ( ,'" "',
/ 0,// ::~ ,', "'.". "l"::':':":';:.' .I~':,'.:~';'~,.J:":" /1' ,'~,O~. ::' "C-~'~f'~"l'~"/",,::
',> ,1 f~!. ,':; :l~:../;'''(~ l')~(' '/~~:~~/ :://:.~,Jt/7;U~ ,~ "fl.,'1 '{\~;6)~a.-,'!! /; JfW,ii!';, I.... l [ G [ NO,
~ ,r/ ;' 'I , ,', '-::,;.'~, ,j' ''"<,:;OJ;' /, '..::::--// I "'" "",",- ' , "'" ' ',,',',',',: /,/ . MOAlS (As: Zn, CII, C", Ph,
'==;:." V~~~'>2 ;'01:.;} ,:,;_l_',/I -:..:~-- y ('~' '" /;;I/:'<~i£zJ Ii < ,;:" r J'li j II J);! Fif" :)~~~ WELlS IIIIHf MElPlS HEASUP£O
,.. " ,,,,',' '" , ....---- ' ", _J "~I :r~1!... :' ':"1'('" ,[L 'J-- r'=~!!........,-"'- ii,',:",: J "',,'- AT OR ULlU~1 UACKGROUlIO,
,< , Q f ,,' n, ' ',' ,'/ 1('1006"'''-'' l ' I,' $ ('-.[\\,',' ,',,' ,-- ""
~: , "', :'L/-, ,---:~' I";, '-:",' ,,(~ql ~":' :' "1012"'- I (:" \", :,",',":
.'~ . . . . . "'. .' . I .. -....:,. . .,019 c... . . .: .. -- '- - ;..' .
/~"q ',.-!, , p" UI' ,'"~,,,,',' , (.-:on ''-..:: ,~: ''''':..! ''-'', ':-~,\,..",
~:/ V",' ," r 'II ~' , f-Y' l\v'~,~h,) ("~o\' C/iE '''-','fio,~ 1, I ,,/
/. CIJ" '.4:,.. J. ...' £", / -----:---.1../1 ( .'
' ~ I -'.~'=- 'I <, 1 -.)" 't.------ k=""I'=', :<-.~""
',,<".. ;' :- ~o~;j:.z;) '''>;--'~;~~~,:;;:/,i'l /-" '. ' , -"::.')''-''-'''''''''J ,'= '.. ll~:,:,,?.-~?~
, .. ",' .. '/ L;", IL--')/IT~IC..!.._.:"', (" ,,' - I" '.',
' ,," , // '1:""-',"'. ~,'.. ,",=, J' ,"-' -- ,p-'.""~.J' vE
, ", ""-" , , " :/ ,ti 1'.,:, "
c... 21 Z6/So;
I
-0
I
FIGUI
-------
pu~'~."~.
......""'1: ............ 1-
,"""'~,I...~. .....to
..--...~. ,
-
.... .
~J.J
." ~..
... .. J ..&
.. . J
......:............. ~'~.~J ~- ...
, "
~ ."'-
...._~ .
-
....
),~,.hs'~,'''" t, ",' '.',t\,\,~\, J A\", '(,'k""',.'::,:,i~_\~~,;<;:'~)~'-~}.~,~~",.;,;S,'E!~
,~\. '\\, \'" \) 1 II,: --', ~,": ' ,,' ,~jj~~ ~"'-'" , ' , \ '-, ~' ,,' ".,."
:~.. \ ~' '.. '" , II f-~' /' - , J'
::"~ ':', \,' ; , {1' \ 1 "', ,- \' '~IIJ --~', '" ',' '1," '-",' , f "',
'.S",:, , "\: , ': .. \!"- ' 11/' ";, , ~ ,,-' ::1' , , " ,),.. ,_:~ ,~, , ~
" \ l..." ", '" ' ~"", ~'~'",', " \ ( /''- " t
l~ "\ "",',,,\.~~5""'7"':,' "r'\'I\'" '!;~~':-'~:::"~/'~;'~:I"l"" ..-.' ",~',t:IHh,' i c /:';;;j.;,> ',' '(",~;), 1
.:.~\\\ /.r-'. ~L ,i ,;, '",t:.. .'I , .1"", , ~ ' l"!ff. }I . - . I' \i ),1 . ,.' I.
: lj' / ~( "'~){1\'~'~: ///" ;"'Y'I~'t~ ~¥}~~j '~~:~~':~{; , , " 'L.:"-j
~,/\\.:,... ' i,}.l1{ \/:: : ~""~=~",, '..': ~: <\F, "\, I, , ~'- A:!I.~, ,,' : ~', L
'\ '..... " ~ ,:' '. " " ',I ,/' '/ ,.;': f, ", ~. "-' . ')014 ,. "
j( '/.~)' 'il '1,(" _0'., - ","~, -~-'-~, ~1 ~~' ':' ),. ~ ,': ~~ ~~ . ,~ : ~ , c~~~:~~'O"~L ',' ~:, -,.'
/" '? (J 'X::.." " /' ,,:r-=~6I '.' /-::;~~"'. ~,~" " ij, ~:; '., ~I L~', rr~;~l~iI(t::-,C
( j ,,, ,'I ,', " , ',',.., ' 00 '. I..""" -"'-~
' " II '\', !.~, ',',.' ,,' /1, IOU' " , :,". ': ., :.,"" ", -' " .. ~-- ,~~.::::~-,':;:-:.,;
II 'I, ' " ,// ,'.' "'.""'-'"" ,;.. , "-' ", ~.' --,-- .,
//! , ) ,",; ~~/ ,,' Il; .,:.. ( ",'. /,' ','," "'-:,;:;,,'~6;t.'~:
~~- /' J ~9' (, Zi:.~ , ' ::' ': ~_: ,l;:'!,'~~:L~~):('~:::,;'~:"
/1 //'~J~~)i' 'd,~;t~, ::'--.,t::i;'~:':1/~:""', ':'~" ~" t )~', :,,;'~' ",' . ;,' -~}!,-- _I~ ", '~,,~Jf \,/t,'~,r>l::::;;>"~ '~ 0,' -",' ",
,~.:..; ~j((.l 0\'0; ;:"'l/",,-'t'~~/':~.),' ',; " "", /' ,"'.- ',:,;;,; !,,..' " ',,,,!L~j,~,,/. f ,', ;;' - m'lj ("£A" 0") '''''"''''
1j' ',J e... , j'" 'J .',":':':' I~ '. '," ;: ,0059 ", ,I<~ 1/'-' ': 1016 .. I: IY - 'C" ":".. .. jj.J;fjj
~' A' ,I ',' "'<,'1 :" ',:, .' ":-,"" 'o/;;"::--'-J1: ",_~.1O~4 II ,.: io"--", .."i!;;'I!ii,(\~
,; iJ . i~~;, ~i ''J''';!lr''1~( <','~"/( }\JtJ,"--\'t ,~, .~,n. t J:~;~:,I : Ii J": ,j );,'i;i',<} ~' ~'\J ARfAL EXTfNT Of DffpfR AQUIfER,
.... 1/ ' , " , I{ '" ,./j """, '" /,' ~- " " , 'r... I '" ,,',,? t'o." 't 10HE (,no. '" n, IN orp""
~//)'i " "K>6o---- I' .;}' , "':, ,: ,.". ' -'.:-"':(ii.J-/l,,!):".JI."Il)ZO-,- ";. -~ :1 " :/ 'll','i!,/,{.,:,~ pCP AND PAil CONTAMINANT PLUM£'
'~f!/h ,;/~lj.~{':) :<:j.--(,,~~~JI:..z,,-j~'~~5//("<;C-:~'~'':
, . ", 1,'1rLY- ' fI':"Z,,---\, !,~lil~i"'.,fo:'i !~ \..:,::
"I' zi,,,,, '01" ;",;,,~i "",,"~!~:;L~"i:'~_:h~;,); ) """" 'iT':::-
~ ~,,:,,~ ',,'1",.11, ::f5,J',:..J" .j'). '\/~~ /~':~~,-,:,
v' " I 'J", '':>' -," -- ..-,
"'" ;', r'~~) L"" "_:~~,// ii' j , , ,,' -r '-- ---'! .. ,;> '.. lI,;".~,~,~!~
' " " I ,~', C-=1)/~l,:.1 ::- --..- ~ '\ \:, -,J:; ".,w.. 0,' J R D
'ti" ',:" C - : ~ II :'f' I 1 '-d' ) , I C.,. ZfB/66
C
I
FIGURE 6
MAP SHOWING DEEPER
AQUIFER ZONE
CONTAMINANT PLUMES
1'...
..,
-"~-,~'-r
'u=m~-;.'t.iQ:!l:'
'.!W~~-"ill.~
\:~-;-~'\~~ ~'?:..:' I~;'" }.x':m;m;'iA:F,'" I]:~ .-~i
~~~
-------
-11-
Each of the contaminants migrates at a different rate in the ground water
depending 1arqe1y on its solubility in water, soil adsorptive properties and
rate of deqradation. In general, contaminant concentrations in ground water
decrease with distance from the source area due to disperSion in the ground
water and because of the factors mentioned above. Thus, private wells located
closest to the mill site property are generally those with the highest
observed concentrations of-contaminants. This generalization is complicated
by the highly variable hydrogeology of the site, resu1tinq in apparent qround
water channels of hiqher permeability and higher contamination, as generally
exhibited by the northwest contaminant plume arm shown on Figures 3 through 5.
Certain of the contaminants detected in the private wells are known or
suspected, carcinogens, and others have. known toxic effects on humans. Table 2
summarizes the carcinogenic properties of PAH (the major constituents of
creosote). Table 3 summa~izes the known acute and chronic toxic effects of
contaminants found.
A baseline risk assessment (no action alternative) ,indicates that an
elevated carcinogenic risk currently exists at the site (See Table 4). The
qreatest risks of contracting cancer for individual routes of eXPosure result
from: drinking contaminated water (chance of 1.8 in 10,000); inqestion of
contaminated soil by children (chance of 6.8 in 10,000) (soil contaminated by
contact with contaminated water, such as lawn and garden watering); ingestion
of vegetables irrigated with contaminated water (chance of 3.7 in 10,000 to
6.1 in 1000). Other less significant routes of exposure included dermal
absorption and inhalation while bathing or showering. Total carcinogenic risk
was estimated to range from 1 chance in 1000 to 6 chances in 1000.
, .
No Maximum Contaminant Levels (MCL) as established by the Montana Water
Quality Act (State equivalent of the Safe Drinking Water Act) were exceeded
for drinking water in any of the wells measured. However, some water quality
criteria, proposed Federal MCL1s, proposed Federal Recommended MCLs (RMCL),
and drinking water health advisories were exceeded (See Table 5).
The only chronic or acute toxic hazard found was posed by PC? by the
drinking water route of exposure (see Table 4).
ENFORCEMENT ANALYSIS
In October 1983, .the St. Regis Paper Comcany accepted responsibility for
the contamination found in the Libby wells, and signed a CERCLA 106 .
Administrative Order on Consent with EPA for both RI/FS and RD/RA activities.
Champion International Corporation purchased the St. Regis Company in early
1985, and thus inherited St. Regis' responsibilities under the Order.
Champion first began to implement the Buy Water Plan (see Exhibit 1)
during the summer of 1985, based on the results of the 1984 well sample
results. With the identification of additional contaminated wells in 1985,
Champion has already begun to offer the Buy Water Plan to these new owners,
and will re-offer the plan to those who did not sign in 1985.
",----- -_. _.~. - -
--_.._._-~------_._-------_.~ _. --.._.- .'.-..-.. - -
-------
-12-
CO)
Vo.BLE 2
HEALTH EFFECTS OF PAH CCMPOUNDS DETEC7EJ IN OFF-SITE WELLS
Chemical
Acenapthene
Acenacncnyle!"le
At~t:-:r-ac:~e
Y:2!"1z~(a)anchracene
'3.,..
*Chrysene
"'~luorant:-:e!"le
Flucre!"le
i-methyl naothale!"le
2-iitethy 1 Matha 1 ene .
Na;::hale!"le
Pher.anthre!"le
"'Pyrene
**Senzo(k) fluoranthene
**8enzo(b) fluoranthene
**2e!"lzo(a) ~yre!"le
**Indeno(123,cd) pyrene
**O;benzo(ah)anthracene
.--.- - -- ..-- -
. ... - -_.... - -. . . - -
He:.lth
';:':c,--
- I I - '- ..
mutagen i c':ZJ
skin car::~noaen,~:) ii1U~~.-c:~;c !Z)
.. '----. ' ,
. car::inogenic ora1 s~:.ldies~:
animal earcinoaen,(:J mutaaen and
car::inoaen,.:Z) anima1 carcinocenic
evidenca,:Z) positive oral carcinoge!"l wit:,
other pas i t i ve -da tal:)
positive carcinogenic data and co-carcinogenic
data no~ tes~ed orally':)
ri e.; ~ : ~ '~. e
e.J-carci noge!,,!i:)
(with pyrene)
i nh i b i tor,z1
inhibitor'"
inhibitor,rz) negative carc~nogenic studi2S::)
several negative carcinogenic and mutagenic
studies (not tested orally)(:)
animal carc~nogen,(t) co-carcinoae!"l (,....ith
f1 ucranchene) and mutagen ic ,.:Z) co-caic i no,:e!"!
or initiator with ne~a~ive carcinocen or ~r.
vivo mucage!"l(:) - -
Ne~ative carc~nogen in singie carcinogenic
stud:;::)
Positive carcinogenic and co-carcinogenic
data, not tested orally,(e) animal
carcinogenic e'lidence'Z)
Positive oral carcinogen and other ~osi::ve
data,(:) animal carcinogen and susper::ed
human carci nogen,L)
Co-carcinogen or initiator with negativ~
carci nogens or ; n v; vo mutagen, (4)
Positive oral carcinogen with other positive
data,(4) animal carcinogen and tumoriaen,(l)
anima 1 carci nogenic eV1dence(J) ..
-. .'- - - .-..-. - ---
-------
-13-
TJo.BLE 2
(Continued)
*"'Ser1Zo(ghi) peryle!'1e -
Pasitive carcinocrer1ic or co-carc;ngenic da:~,
n",/> -:s-:,.; a"'ally.'~)
....,... 1.-.. '--~ I
... Detected
ofr-s i t;'C:--oand de':er:i1i i1ed
to be carcinogenic ar.d the tnal
is
referred to total carcinogenic PAH campounds.
...... Not det;c:ed in off-sit; ground water ~eil samples.
(:)
Health Eff~::s of RiSk-Ass:ss~e!'1t Cdte~ories, C.~.
8rookr.aver1 National Laboratory, October 1983.
C:"c.mer
et d 1.,
( Z)
Woad
P1"'eservative
Pesticides,
Cre'Jsote.
Per1tachloroone!'1ol
~ashingtan, D.C., P9S2-229956, ~arch 1982.
r..,orcanic A.rS.:"ica 1 s
('..Jood Uses)
Positior:
Qoc~me'1t 2/3,
and
U.S.
-1.=
'...1-
;:! .,
-. ~,
(: )
Four.th ~nr:ual Re~ort en Carcincce!'1s, Draft,
and Human Services, P9 85-134633, 1985.
u. S. Oepar::i1ern:
of He:l:h
(: )
An
Excosure
and
Risk
Assessme:'1t
for . 8e~za (a) :Jvre~e
c.~d
o:~c~
PolYCyclic ArO~d:ic Hvcr"~c!rbons, Volume
1. Summary,
E?~-~40/~-2:-:2J,
July 1982.
. -.... ..- - ----.-----.--- --------. --- -
-------
-"
-14-
TABLE 3
ACUTE AND CHRONIC TOXICITY SUMMARY FOR MEASURED CONTAMINANTS
Chemical
Potential Health Effect
Arsenic
Interferes with certain metabolic
processes.
Zinc
Human nutritional element.
Copper
,~.
Human nutritional element, but
excessive ingestion can result in
liver, brain and kidney damaqe.
Lead
Fatigue, sleep disturbance, colic,
neuritis, anemia, heart and kidney
damaqe.
Nickel
Deqenerative changes in heart muscle
and seminiferous tubules of testes with
chronic ingestion.
Benzene
Headache, dizziness, nausea,
convulsions, coma, death, birth
defects, certain forms of leukemia,
various blood disorders, nervous system
depression, liver and kidney damage.
Toluene
Nervous system depression, liver and
kidney damage.
2-Butanone (methyl ethyl ketone)
Nervous system depression, narcosis,
and liver damage with high acute
doses. Teratogenic in rats.
l,l,l-Trichloroethane
Nervous system depression, narcosis,
liver and kidney damage, and death with
chronic inhalation.
Ethylbenzene
Slight to moderate effects on liver,
kidney, testes, and body weight in .
animals with chronic inhalation.
Pentachlorophenol
Teratogenic.
Source:
Feasibility Study for the First Operable Unit, Libby Montana Ground
Water Site, prepared for Ch~mpion International by Woodward-Clyde
Consultants, July 1986, Appendix C. .
-------
-15-
TABLE 4
SUMMARY OF BASELINE HEALTH RISKS
Route of Exposure
Drinking water
Ingestion of soil
by children
Ingest i on of vegetab 1 es .~_.
irrigated with contaminated
qround 'Hater
Inhalation of 1,1,1-TCA(3)
\vhi1e showerinq
Inhalation of 1,1,1-TCA(3)
whi 1e bathin:;
Inhalation of benzene
while showering
Inhalation of benzene
while bathing
Dermal absorption of
benzene while bathing
Hazard Index (1) Carcinoqenic
Acute Chronic Risk (2)
0.36 0.27 1.8 in 10,00
3.1(Teratogenic effect of ?CP)
6.8 in 10,000
3.7 in 10,000
to 6. 1 in 1000
3.2x10-9 8.4x10-10
3.6x10-7 9.6x10-8
1.5 in 10 billion
1.8 in 100 billion
6.7x10-6 8.2x10-6 2.7 in 1 billion
The hazard indices above provide numerical indications of whether a significant
probability exists for acute or chronic health effects to occur from all
contaminants acting through the route indicated. The index accounts for the
measured concentrations, the route of exposure, and the threshold above whic!, the
health effect begins to manifest itself. A hazard index greater than 1.0 is taken
to mean that a significant probability exists for the contaminants to produce a
health effect through the route indicated.
2 Carcinogenic risk provides a numerical indication of the risk or chance of persons
exposed by the route indicated to contract "additiona 1" cancers. lifetime (70
years or more) exposure to the measured concentration is assumed. "Additi ona 1"
cancers are those that might be contracted over and above those that might be
contracted from other routes of exposure, such as smoking, diet, occupational
exposure, etc. "1.8 in 10,000" means a person exposed by the route indicated has
1.8 chances out of 10,000 of contracting an additional cancer.
3
1,1,1-trich1oroethane
-.--. ------------- -----. --._-----"--- ..---.- ----- .---- ..- -- --
-------
'l'Am.E 5
COMPAII/S(JtI Of SlAIUJA/mS 10 [xPOSUI~( PO flIT COtler tI/ltA IIOIIS*
Standardl
Value of .Standard r xposllre Point Cr iter ion
Chemical S t anda !:~L£!=_L~ ~El ~-'~ 1~!_Ue!J~~~9Lll -~Q~~~':; 11~!"!!!l on -(~9 ill'~) fxceeded
8enzo(a)anthracene No c r I LeI' I on seL for O.flO) 0.)0 (LTC) X
lh1s PAil CO/llJHHlrll1.
for to lill Cilrc inogcnic
PAil. the [PA !-lilLer Qllell i ty
Cr iter Iii is IIsed
(IncrelJl(~nLj)1 canCer ;,
ri sk of 10 ").
Chrysene No criterion set for 0.00] 0.47 ( l lC) X
this PAil COlJlpOCIIHI.
for to lil I carT inogenlc
PAil. the t:PA './iller Qua lily I
Criteria is IIsed t-'
0\
( I ncrelllenL a 1 cancer I
risk of HI").
Oenzene Proposed NCt. 5.0 5.9B (LTC) X
'./ater (Jllalily crilerion 0.G7 !1.9B (LTC) X
ill! ju sLed for drinking wilLer only
( i ncrelUcnL iI I cilncer
risk of 10 ").
[PA Drinking '.IL,Ler Ilea Ill! n.)!) ~j. 9B (UC) X
Advisories
Acenaphthene './a ter Qua liLy (.' i LeI' ion 20 Ion (SlC) X
Adjusted fol' IIrinking Waler Only
(organoleplic c I I e cl s on I y ) HI
fluorant hene './ill e r QII ill i Ly Crilerion IBfJ ~] (STC)
Nickel '.1 ill e r QII a 1 i L y Cr i ler iOIl 15.1) ;>1) (STC) X
Alljusled /(11' IIrillldn9 '.IaLer Ollly
-------
Chemical
Total Carcinogenic
PAil Compounds
Pentach loropheno 1
'I'AIU.E 5
((o"l inlled)
-- Stan~!~~:~U~~~g~!.:"!!!!!-
Vii 111e of S Lilndl1rd
-~ !j-~~ r i ()~~{ !~~JUl
Hater QUillity CriLerion
AdjusLed for /II' illk in9 Iialer On ly
(i ncrcmenL ill Cilncer
risk of 10 I.)
u . 00 ) 1
Proposed UNCI.
220
Hater Qual ity Cr iLer ion
I\djusted f or 1)1' i Ilk in~ Ua ter Only
1,010
II) Appl teab le drink in9 \'Iiller stc1/ulc1rds c1S determined hy the fPl\
[xpw;lIre Po i nt
~OI~~~I! ~!' ,! UQ.~~.t!!9Ln
11.52
(Ll()
Standard/
Cri Lerion
Exceedetl
x
x
x
12) (STC) II Short TerUl Conc.entratlon is lIIilXllIIlIUI concenlrl1tlon rucc1sIJrecl In any off-site we11 in 1905
(Ue) = long Term CUllu!ntraLlolI Is geolllcLric mean ilhove detecLion of IIICilSlln!Ulenls in il1l off-slLe wells
In 1905 .
I
.-
-J
I
).1.110
(STC)
f'
).200
(S Te)
IJ) Well 1001 was the only well indlcilLill1j the presence of c1l'senlc at 5 pph, the detecLlon 1 imlt.
term concentl"ilL ion hilS he en t!~L imiILet!.
.1
(4) Taste aod Odor
*Only contaminants which exceeded standards or criteri.a have ueen included.
No 1009
-------
-18-
EXHIBIT 1
-'
~ ~!:n~~~.~~~na. C~roo'alion
OW1PION'S 1985 BUY WMER ~
!~ coo?e:a:~~c ~i:h che ti~col~ C~~nc'l Heal:h De?a:::e~c a~e c~e U. S.
E~vi:on:en:al ::~:ec:i~~ Agency, ChG:?~o~ !::e~acicnal C=:?o:a:ion is
con=i:ui~g :~ i~ves:~ga:! che ex:!n: of gr~~~e~ace: con:~~a:~o~. ~cer-
l:i~g :~a ti:~y &=~a, a~c :~e ?cssi=i:i:ias :c~ =e:e:~a;:~~.
Sc::e lC"oo' le':!l c::::a:.::.~:~::: :.as :ee::. ::1t.:..-:c ~:: \,i.:!:, sa:?les :ak.e::. - --- :'C~:
~ell or f:e= -ells i: yo~= ~e=~a:e vic~::.i:1. Al:ho~3h i: is ~o: c~::e::.:l:
k:c~n ~Qe:he: or ~oc cne use of your ~ell ~a:e: for lA.~ a:: gar:e::. i:~iga-
cion is ha~i'~, ~c~l fdr:her in:or--&:ion is available, Cha:?lOa :eq~es:s
yo~: assis:ance by disc~ncinui~3 :he.use of chis .ell :0 ensure chac you an:
yo~: f~ly co ::.oe diree:ly CO~~e ?ossi~ly con:a=i~aced .ace:.
In re:~:~ :0: you: assis:~nce ane Co c:=?ensace you fo: :~e cas: 0: usi~S =:re
Qe:e:ed '.'acer, ChA:;1ion .g:ees co ~ay you :~e i::.e:ea.sed c~s: 0: yo~: :eCe:e:
~a:e: asage :0: A?ri~ ~h:ough Sepce::e: over ar.: above you: :i::i:~ :or.:hly
bil:i:g or $ZQO.OO. -hicheve: is grea:!:, ~.o h~~~reci collars .ill be ?aic
on July 1 of eve:j year,and any a:ou~: over $200,00 ~ill be ?aid on Deee::e: 1.
'!ou agree no: co use. or ?e~: anyone else co use, che '.:aar '.:ell locaced. or.
you:: ?t'o?e:":y and :toe co d=:.ll any :l~-' ~.i:!r \Jells on ;:ou: ?ro.pe:c::, Io be
Su::e roo ac:::':en:~l U$e of i:~Q ~a:er .ell occ~=s. C:~?i:n ::e~~!s:s your ?er-
Qiss::'o~ :0 ir.s:all . loc~~~g device or. :~e wellhead. ~e :ay. f:~ ::.:e :0
C~=e. :a~. sa~pl~s :==: c~e \Jell :ot' :esi:~ng ?u:?oses, af:!:" giving you
rea30naQl~ 4QV4~:e ~o::'c:e.
~~~s ag:ee::e:: :ay be ce~r.ai:ed ~~ i: is dece~:led :~ac r.o :h~la~ of ::n-
c~ir.a:::'or. :0 you: \Jell e~s:s, oc~e: al:e:r.acives bec::e aVail~:le. 0:: af:e:
60 days :::= reC:el?: 0: a \J:i::er. :eq~es: ::oa you :0 :e~i::.a:e c~e as=e~e~:.
r: you :i::.: ::~s agre~!r.c ac:!~caole. ?lezse so ind:.ca:e
s?ace(S)belc'J. A. check ~i.ll oe ser.: :0 you 0:1 July L
. . . . .
~y Sl~~; :~ :~e
~~?ioc a?~t'eciates' you: coope:a:ion aad ~she$ co ch4~k you for yo~:
assiscance wi:~ chis progra=.
Si~~I!=ely,
Doug Iilner
DB:: g1:0
ACC::::?TI:J:
Date:
Dace:
-------
u
-19-
A local ordinance prohibiting the installation of new ground water wells
for irrigation or human consumption has been enacted. The ordinance was
passed by the City Commission on July 21, 1986 in a temporary, 90-day
emergency form (see Exhibit 2). The city is currently taking the procedural
steps to enact the ordinance on a permanent basis.
On July 21, 1986, Champion and the City also signed the agreement to
provide free irrigation water to Libby water users as an incentive to comply
with the new qround water ordinance (see Exhibit 3).
ALTERNATIVES EVALUATION
The o,bjective of the first operable unit is to significantly reduce or
eliminate human exposure to contaminated ground water. Therefore, the first
operable unit FS consider'~'on1y alternatives that limit or eliminate this
exposure. Environmental objectives (e.Q., aquifer restoration) were not
within the scope of this operable unit, but will be within the scope of
subsequent operable units. .
In accordance with section 300.68(f) of the MC?, the following remedial
alternatives were developed:
Alternative Develooed:
Alternative Como1ies ~ith:
1. No action
300.68(f)(1)(v)
300.68(f)(1)(ii) and (iii):
Alternatives that attain or exceed
applicable or relevant and
appropriate requirements (ARARs)
Alternate water supplies:
2. Buy Water Plan with Ordinance,
using existing public water
supply as the source of
a lternate water
3. Buy Water plan without Ordinance,
using existing public water
supply as the source of
alternate water
4. Alternate water from the Kootenai
River
5. Alternate water from the Kootenai
River- Alluvium
6. Alternate water from Libby Creek
Ground water treatment systems:
7. Granulated activated carbon (GAC)
8. Membrane filters
300.68(f)(1)(iv):
Alternatives that do not attain
ARARs, but reduce the likelihood
of present or future threats.
9. Oxidation processes
. -------'--.----'--'- -------------_u- --- ---------- ----
.------ -
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-20-
-
E:
-------
-21-
E:OO:BIT 2
(cant 'd)
or excavated pursua~t to a permit gra~ted hereu~der must be
equipped with adequate shut-off valves or co~trol valves for t~e
purpose of controllin; the flow of water from the water well and
for the protection of the C:ty water system in the event of
pollutio~ or other ha:ards.
Sectio~ 5 -- Mar~i~2. The issua~ce of a water well permit
may be conditioned on markin~ the ~ater well in a manner to be
designated by the City of Libby, or its designated representative
or agent, for the purposes of ide~tification, location, and f~r
i~spection by the City of Libby, or its desi~nated representative
of a;e~t, at reaso~able times and as may be requi~ed.
Sectio~ 6 Violations And ?e~alties. Any person,
whe~her as principal, agent, employee or otherwise, ~ho violates
any. of the provisions of this Chapter shall be subject to a fine
not to exceed Fiv~_.Hundred Dollars ($500.00) and imprisonmenc not
in excess of six (6) months in jail.
. Ci t Y
PASSED BY THE CITY COUNCI~~~pproved
0' Libby 'hi. ~/-<' day 0' y~ 986.
~,lc.a
~la vo"r' \
~ I ,-....
by che Mayor of the
ATTEST:
-I,v..~
City Clerk
me. ..tJ~
EMERGE~CY ORDINANCE EFF~C7!V~ U?ON PASSAGE FOR A PERIOD NOT
TO EXCEED HINETY (90) DAYS.
. ---_..__.-.- ...
----'-"---.-. -.-..---------- -- --'-"'---..--- ----..--- .-..
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:>
-22-
CITY OF LIBSY
UNCOI..H COUNTY. MONTANA
~OST 0"'''''<::1: IIOX :
LISSY, MONTANA :992.3
July 21, 1986
Champion In terna tion~l Corpora tion
P.o.. Box V-IO
Libby, Mon tana
59923
At tn :
Doug Kilne!:'
Caa :"
Doug:
This letter sets :crt~
of Libby, Montana,"-and
coo pE'!t"a tion in aba ting
the Ci ty of Libby.
and confirms the agreement of t~e City
Cham9ion In terna tional Coq:ora tion for
the g:"oundl.la te= con tamina t:..on l.Ii thin
The city has determined that it is in the best inte::-ests 0:
the ):\ealth and l.Ielfare 0: the citizens of Libby to p::-ohihit
the ins ta lla tion 0': any nel.l l.Ia ta:- l.Iells l.Ii thir\ the Ci ty ....hic~
could provide ~ater for eithe!:' direct or indirect huma~ cor.-
sump::ion, '!'he C~t:; shall immediately proceed to im;;:l.e;.:en:.
said prosc=iption by an eme::-gency ordinance" The City shall.
also use its best efforts to restrict or prohibit the use 0:
existing ~ells located l.Iithin the City limits of Libby,
To amerliora te the inc:"eased financial burden on the ci tizens
of Libby I.Ihich l.Iill result f=om said ordinance, Champion shall
pay to the City of Libby the amount of $30,000.00 per yea:".
Said payment shall be a9plied to the City to prol,.ide Cit,;'
'..rate:- to each resident 0: the City of Libby. Said 9aY:':lents
shall be made on or before the 1st day of October 0: each yea::-
for a pe:-iod of te::1 years commencir\g cctober 1, 1986.
This agreement shall be subject to change upon
consent. of both the City of Libby and Champion.
the
m u t ua 1
If the above provisions and conditions meet with
approval, please endorse this le t ter and re tu:,,:'1 it to the
of LU:.by.
V~UIY yours,
F~~~c?-
Mayor of the City of Libby
you:,
City
READ AND APPROVED BY:
Champion In terna tional
EXHIBIT 3
FF!:E: IRRIGrlXICN WA1'ER 1l.GP.EEMENT
BY~,:DO~JtJL-
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-23-
Since offsite shipment of site wastes such as ground water, soils, or
sludges is not within the objective of this operable unit, development of an
alternative for offsite treatment or disposal (300.68(f)(1)(i)) is not
appropriate.
ARARs for this operable ~nit are defined in the section of this document
titled ~Consistency With Other Environmental Requirements.~
The Buy Water Plan isa program whereby individuals with contaminated
ground water wells agree to cease using their well, and instead use water from
the public water system operated by the City of Libby. The well owner also
allows Champion to cap and lock the well. Champion provides monetary
compensation to the well owners to pay for costs incurred by using metered
publ ic water instead of wetl water. The compensation offered is $200 per year
or the actual cost of additional metered water, whichever is more. Well
owners who are not currently connected to the city water system would be
hooked up and receive all their water free of charge under the agreement. The
agreement is indefinite in term, and would be terminated only if the threat of
contamination no longer exists, if the well owner provides written notice that
he/she wishes to terminate the agreement, or-if other alternatives become
available. See Exhibit 1.
The local ordinance is in the form of a city-wide well permit system. The
permit system precludes the installation of new wells for human consumption
and irrigation, but would allow well installation for use in closed systems,
such as heat pumps and swamp coolers. Annual inspection of the well is a
condition of the well permit. Violation of the ordinance is punishable by
fine up to $500.00 and imprisonment up to 6 months. Enforcement is conducted
by the County sheriff, but due to limited resources, enforcement is not
expected to playa large part in the level of compliance. Voluntary
compliance with the ordinance is expected to be high due to the ~free
irrigation water~ incentive provided by Champion. As the cost of summer
irrigation water is the primary reason residents have installed wells, the
prospect of free irrigation water should remove any other monetary incentive
for installing new wells. The "free irrigation water" agreement signed by
Champion and the City of Libby has a term of 10 years. See Exhibits 2 and 3.
In accordance with section 300.68(g) of the NCP, the identified
alternatives were subjected to an initial screening to narrow the list of
potential remedial actions for the further detailed analysis.
Oxidation processes and membrane filters (alternatives 8 and 9) were
eliminated based on considerations of technological reliability,
effectiveness, and cost considerations. These systems were found to have
costs which far exceeded costs of other alternatives, did not provide
substantially greater public health protection, were of poorer reliability,
and would not be more effective than the GAC filter system.
In evaluating alternate water supplies, Libby Creek (alternative 6) was
eliminated because of the potential adverse impact of upstream septic tank
effluents on water quality. This alternative was therefore deemed to have
significant adverse effects, and would not effectively contribute to
protection of public hea1th compared to the other available sources.
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::>
-24-
In accordance with 300.68(h) of the NCP, a detailed evaluation of the
remaining alternatives waS conducted. Each 'alternative was evaluated for
cost, reliability, effectiveness io achieving the desired human health
protect ion, i nst i tut iona 1 'tons iderat ions, and adverse impactS.
Table 6 contains the estimated present value costs of each of the
remaining alternatives. The 8uy Water Plan Without Ordinance is the least
costly altecnative, but because it does not provide protection from future
threats (installation of ne~,wel1s), it is not the most cost effective
alternative. .
cost
-
Institutional considerations
Tab 1 e 7. summari zes the insti tut iona 1 controls needed .,i th each
alternative, and the advantages and disadvantages of each. In summary, all
alternatives (except no action) either require or would substantially benefit
from an institutional control (ordinance).
Montana water law was evaluated, and it was determined that both authority
and precedent existed for restricting accesS to ground water when public
health is a concern. The City of Libby determined that it had authority under
Sections 7.-1-4123 and 7.-13-4401 of the Montana Codes ~nnotated (MC~) to
control ground water use within the city limits (see Exhibit 2).
Note in Table 7 that the "Libby 8uy Water Plan" (simil~ to but not the
same as Champion's 8uy Water Pl an) and the "Libby Low summer 'Hater Rates Pl an"
are listed seoaratelY, These plans do not constitute separate alternativeS,
but rather are two possible ways to provide LibbY residents a financial
incentive to comply with the well installation ordinance. Both would provide
free irrigation water to LibbY residents. ~s a practical matter, the "LibbY
8uy water Plan," under which Champion comoensateS the city directly, was the
method selected. I""lementation of the "Libby Low Summer ~ater Rates Plan"
was impractiCal due to the need for approval of water rate adjustments by the
~ontana Public Service Commission.
R e 1 i ab i1 i tY.
The reliability of alternative water supplies has been demonstrated at
other sites where an alternate water suoply waS selected as the remedial
alternative. Engineering reliability is not usually an insurmountable issue
with such remedial alternatives, and is not an issue with the alternate water
sources considered for Libby.
Reliability is, however, an issue with installation of individual well
filters. G~C filters under intermittent use are subject to clogging via
biOlogical growth. This growth may also cause human health problemS. 8ecause
ground water use rates, contaminant loading, individual filter performance,
and personal habits vary so greatly, individual G~C filters have practical
problems which seriously hamper their reliability. In addition, the use of
individual filters on a scale sufficient to protect the health of a large
number of people has not been proven.
-------
'I'Am.E 6
fSTIHAHO COSTS or ALHRIIAlIV(S ($ \ ,ODD)
fiuy \~ill e r Guy \.llll er Supp 1 (~lIIen l ill Supplemental
P litn (1-1 i lhout Plan (Hilh Individual Hiller Hdter
~rd ina~s~)- Or~i~~~!lce} r i Hers {~.L!~~ ~~!I~L {~oolena I R1ver~
-----
1st Year Cost 122 152 \ ,005 725 835
City of
Libby Annual Cost 311 M 607 75 125
fl
Present Villue Cost* 310 521 11 , 50 I . I , I !J J 1 ,555
!
1st Year C05t 935 950 1,602
West I
Libby Annual Cost 60 75 980 N
VI
I
Present Value Cost* 1,281 1,3B2 7,326
C Hy of 1st Year Cost 1,057 1,102 2,687 1,762 2,172
Libby
and Annual Cost 94 1)9 1,557 100 150
West Libby
Present Value Cost* 1,590 1,903 11 ,027 7., DB 3,036
* Computed based on 10 year life at 10 percent discount rale.
-------
Alternat Ive
No Act Ion
Cont Inue Challp lon' 5
Existing Buy Waler
Plan
1.llIby Buy Water
Plan
Libby low Su_el'
Water R.tes l'ldn
InstAllation 01
Individual Well
f I It en
'j'ABLE 7
SUMMARY OF INSTITUTIONAL CONTROLS NEEDED 10
IMPLEMENT VARIOUS REMEDIAL ACTION ALTERNATIVES
Inst Hut iO!!dl Controls
Hone required
Hone required. llowever, progrilll would be
IIOre effective wilit sUJlllort 01 loe41
ordinance.
Heed local ordinance pdssed prohlbillng
use 01 ground W
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-27-
Effectiveness
A numerical projection of the reduction in human health risk brought about
by implementation of any of the alternatives has not been made. This is due
to the variability in response to the institutional-type controls proposed,
and to the unproven effectiveness of the individual GAC filters. Instead,
qualitative estimates must be, and have been, made.
The effectiveness of individual GAC
reasons that hamper their reliability.
addition, GAC filters are generally not
contaminants which were identified.
filters is questionable for the same
These are discussed above. In
effective in removing the metal
The effectiveness of the Buy Water agreement in protecting the health of
the owner of a contaminated well is dependent upon whether the owner wishes to
sign the agreement. If he/she does sign, protection is complete, as exposure
to contaminated ground water ceases. If he/she does not sign, exposure
continues. .
Based upon concerns about inverse condemnation and other taking issues,
the Libby city attorney advised the Libby City Commission not to prohibit the
use of existing wells. Libby residents have been informed several times via
several media of the potential for and actual existence of ground water
contamination (see attached Community Relations Responsiveness Summary). In
addition, Champion approaches well owners individually to si9n the buy water
agreement, and at the same time informs the well owner of the results of
h.is/her well sampling. It is therefore reasonable to assume that well owners
who choose not to sign the Buy Water agreement will have made an informed
decision.
The effectiveness of the city ordinance is dependent on the levels of
enforcement and voluntary compliance. The City relies upon the limited
resources of the county sheriff to enforce city ordinances, and therefore
enforcement is not expected to playa larqe part in the effectiveness of the
ground water ordinance. However, the level of voluntary compliance is
exoected to be high in liqht of the "free irrigation water" incentive provided
by Champion and the City.
Adverse Impacts
Adver$e impacts that could result from implementation of the GAC filter
alternative occur during the operation and maintenance phases. Under
conditions of poor GAC filter operation and maintenance, exposure to the
contaminants of concern would not improve, and may actually worsen if the
filters are not replaced prior to breakthrough. In addition, bacterial growth
may provide exposure to a previously unant~cipated health problem.
The FS evaluated the possibility of demand exceeding the capacity of the
Flower Creek public water supply system. After examining 20 years of
historical data, it concluded that the Flower Creek system can meet the new
demand even during periods of low flow.
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'"
-28-
The FS did not evaluate the impact of the new demand on the Flower Creek
biota, or on the surface water supplies downstream of the reservoir. .
Historical data show that Flower Creek- flows have varied from well over 66
million gallons per day (MGO) to a recorded low of 2.1 MGD. A minimum flow of
6.8 MGO can be anticipated every 2 years, and a minimum flow of 3.6 MGD can be
anticipated every 10 years. The projected total demand of 0.2 MGO would
reduce the lowest recorded flow by less than 10%, the 2-year minimum by less
than 3%, and the 10-year minimum by less than 6%. Flower Creek is a sport
fishery for cutthroat, rainbow, and brook trout. The Montana Department of
Fish, Wildlife, and Parks indicated that the projected demand would not
significantly affect the quality of the fishery. Any effect which might occur
would be f~r less than the effects which already occur due to operation of the
ex i st i ng dam, and to natun'l changes in runoff.
Currently, no homes are known to draw their water supply from Flower Creek
below the reservoir.
COMMUNITY .RELATIONS
The Community Relations Responsiveness Summary (attached) describes the
responses and concerns of the community regarding the alternatives evaluated
in the feasibility study~ No negative responses were received regarding the
recommended alternative. Although no significant changes to the recommended
alternative were required by the comments received, some comments resulted in
the attachment of conditions. These conditions are described in the
Recommended Alternative section of this document.
CONSISTENCY WITH OTHER ENVIRONMENTAL REQUIREMENTS
MCL standards promulgated by the State of Montana under the Montana Water
Quality Act, and the need for disposal of the spent GAC filter media to comply
with the requirements of the Montana Hazardous Waste Management Act
(equivalent of RCRA) constitute the ARARs for this operable unit.
All 3 of the sources for the alternate water supply have been analyzed at
least partially for compliance with State MCL standards. The recommended
source - the existing Flower Creek system - has been completely tested.
Testing of the Kootenai River by the USGS since 1969, and testing of the
Kootenai alluvium during a 1978 ground water resources study, indicates that
both of these sources meet most of the State's MCL standards. The Flower.
Creek public water system has been tested since 1976, and has consistently met
all State MCL standards.
The GAC filter alternative includes shipment of the spent filter media to
the nearest permitted incinerator capable of charcoal regeneration.
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-29-
RECOMMENDED ALTERNATIVE
The remedy recommended is the Buy Water Plan with Ordinance, using the
existing Flower Creek water system as the source of alternate
water (alternative 2). Cost, technology, reliability, administrative and
other considerations, and their effect on the public health, welfare, and
environment were evaluated in selecting this alternative from among those that
provide adequate protection of public health.
In accordance with section 300.68(i)(1) of the NCP, this alternative
effectively mitigates and minimizes threats to and provides adequate
protectio"' of public health.-
The least costly alternative, the Buy Water Plan Without Ordinance
(alternative 3), protects those owners of existing contaminated wells who sign
the buy water agreement, but does not adequately address protection of future
public health (i.e., from installation of new wells which may be or may become
contaminated), unless all future well owners sign the agreement. The
enactment 'of an ordinance which prohibits installation of new wells with a
monetary incentive for compliance is viewed as a more effective way to
accomolish this objective.
--,
The Buy Water Plan with Ordinance is the second least costly alternative,
and provides protection from future public health threats as well as existinq
threats.
All other alternatives are much more costly, and provide either less or
no better protection of public health. They therefore do not constitute
cost-effective alternatives.
Capital and O&M costs to Champion for the recommended alternative follow:
1. Provide annual payments to City of Libby
to offset summer water irrigation costs
(Estimated by City of Libby) $ 30,000
2. Connect 10 houses to the existing water
distribution system, with approximately
250 feet per house of line required for
2,500 feet total at $35/foot $ 88,000
3. Purchase water at $200 per year for each
of approximately 170 wells (annual cost) $ 34,000
Total First Year Cost $152,000
Annual Cost $ 64,000
. . .-. ._-_.._..-.__.._~._._--~---_._----_..._---_._-_.._._----.---.--'----- .- .... -- _0..
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:;,
-30-
To insure the effective implementation, the following conditions should be
attached to the recommended alternative:
( 1 )
If it becomes necessary, Champion must take steps to insure that
sufficient water to.meet the demands of the Buy Water Plan and the
free irrigation water agreement is available until the final remedy
is effective;
( 2)
The city water system must be tested for all contaminants of concern
to demonstrate that it is not contaminated from some other source;
(3)
Champion must continue to monitor wells within and outside of the
. city limits (incl~ding in West Libby) for changes or movement of the
plume boundary...... If additional wells become contaminated, the
recommended remedy should be extended to the owners of those wells;
Champion must establish a part-per-trillion (PDt) monitoring program
for PAH in wells on the fringes of the current plume boundary. A
detection limit of 2 Dot or less would be sufficient to demonstrate
whether PAH water quality was below the lxlO-6 carcinogenic risk
level of the Ambient Water Quality Criteria for PAH. If additional
wells are found to be contaminated above the lxlO-6 risk level, the
recommended remedy must be extended to these well owners;
(4)
( 5 )
Without prior written approval from EPA, Champion must not consent to
a change in its written agreement with the City to provide free
irrigation water to Libby water users;
Until the final site remedy is complete and effective, for those well
owners who decline or discontinue participation in the Buy Water Plan
Agreement, Champion must notify the well owner by certified mail that
he/she has been offered the agreement, but has declined to
participate. A copy of the notification must be sent to EPA;
(6 )
(7)
Until the final site remedy is complete and effective, Champion must
demonstrate annually that all new residents who purchase properties
with contaminated wells have been offered the Buy Water Plan
agreement in accordance with condition (6) above;
(8)
By matching available oublic records (such as water service
connections and land ownership records), Champion must demonstrate
. .that all residents who do not have water service connections have
been offered the Buy Water agreement in accordance with condition (6)
above; .
(9)
The recommended alternative provides an interim remedy, and its
approval assumes that the final remedy will adequately restore grot.;.
water quality. If such restoration is determined not to be possible,
the first operable unit remedy must undergo substantial improvement
or modification before EPA could approve it as a final remedy.
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-31-
OPERATION AND MAINTENANCE (O&M)
There are no EPA or State funds projected for O&M costs for the first operable
unit remedy, except for federal funds needed for oversite of Champion's
actions. These oversight costs are estimated to be about $20,000 per year.
O&M costs to Champion are listed above.
SCHEDULE
The following schedule reflects the fact that Champion and the City of
Libby have already begun to implement the recommended alternative.
Milestone Start Date End Date
a Enact Emergency Ordinance Ju 1 y 21, 1986 Ju 1 Y 21, 1986
a Enact Permanent Ordinance July 22, 1986 *
o Sign "Free Irrigation Water" NA July 21, 1986
Agreement
a Approve Remedy (sign ROO) NA Sept. 30, 1986
a Extend Buy Water Plan Already begun **
a Cap Existing Wells Already begun **
o Complete Public Water Already begun **
Supply Connections
0 Provide Free Irrigation Completed with enactment of
Water emergency ordinance and signing
of free irrigation water
agreement
*
A period of 90 days and 2 public readings of the proposed ordinance
are required to enact a permanent ordinance within the City of Libby.
**
The time" necessary to sign all owners of contaminated wells, cap t~e
w~lls and provide public water system connections depends on the
individual well owners' willingness to sign. Most, but not all, are
expected to sign the agreement. Champion anticipates implementation
of the remedy to be complete for those willing to sign by
approximately September 30, 1986.
FUTURE ACTIONS
A subsequent feasibility study which addresses aquifer restoration and
source cleanup is required to complete site response. Champion is currently
conducting the RI studies necessary to support such a feasibility study (FS),
and the FS report is anticipated in early 1987.
. . -~-------_._-_.~--_._.--- "----..-.-----.----- ---- ---- ----- ----
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- ._. --'. . ~ -- <---. -. -
COMMUNITY RELATIONS RESPONSIVENESS SUMMARY
CONTENTS
Background on Community Involvement....................... 1
Summary of Major Comments Received and Responses.......... 3
Remedial Aiternative Preferences..................... 4
Concerns About Health and the Environemnt............ 5
Cost Issues............;............................. 7
Technical Questions.................................. 8
Community Relations Issues...........................10
Remaining Concerns........................................'l
Attachment A,
Community Relations Activities Conducted
At the Libby Ground Water Site.......................13
- --. ..---....--.. ----..-.--------.--,.
-~.- ......-
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RESPONSIVENESS SUMMARY
LIBBY GROUND VATER SITE
LI!!Y; MONTANA
September 1986
This community relations
Enforcement Decision Document
Ground Vater Superfund site.
the following sections: .
Responsiveness Summary is a part of the
for the first operable unit of the Libby
The Responsiveness Summary is divided into
--,
Section I.
Background on Community Involvement. This section provides
a brief history of community interest and concerns raised
during the remedial planning activities at the Libby Ground
Vater site.
Section II.
Summary of Hajor Comments Received.and the Environmental
Protection Agency's (EPA) Responses. This section
categorizes written and oral comments by relevant topics and
provides a general indication of the sou~ce of the comments
in each category. Responses to these comments are a1so
provided.
Section III.
Remaining Concerns. This section describes remaining
concerns that EPA is aware of regarding remedial design and
remedial action at the Libby Ground Vater site and EPA's
plans for addressing these concerns.
In addition to the above sections, Attachment A, included as part of
this Responsiveness Summary, identifies the community relations activities
conducted thus far by EPA during remedial response activities at the Libby
Ground Vater site.
I.
BACKGROUND ON COMMUNITY INVOLVEMENT
Community interest in the Libby Ground Vater site has generally'been
low. Over the years, many Libby residents have worked for Champion
International, or its predecessor, the St. Regis Company. Most residents
take their water from the public water system which comes from a reservoi:~
-1-
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on Flower Creek three miles upstream from the site. The Libby-area
population directly affected by the ground water contamination is a small
percentage of the population. Champion International is conducting the
remedial investigation and feasiDil!ty study (RIfFS) at the site. The
public has been informed of RIfFS progress and potential health effects of
creosote and pentachlorophenol through articles in the local papers and
mass mailings sponsored by EPA and Champion International. Early in the
Superfund process, the Lincoln County sanitarian was established as a key
conta,ct person to maintain two-way communication between EPA and the
community.
--.
Copies of completed portions of the RIfFS have been placed in the
information repositories located in the Lincoln County sanitarian's office
and the Montana office of the EPA.
Thus far, EPA has held three public meetings at the site, all in
conjunction with regularly-scheduled meetings of the County Board of
Health. The first meeting, in October 1983, attracted about ten area
residents in addition to the federal and local officials and company
representatives. The purpose of the meeting was to discuss results of
studies conducted as of that time ahd to urge residents not to use their
wells if another source of water was available. A second meeting was held
in July 1985. In addition to County Board of Health members, the meeting
attracted one interested citizen. EPA updated residents on site activities
and again urged residents not to use well water or drill new wells.
The third meeting was held on July 15, 1986, at the beginning of the
public comment period on the first operable unit. EPA and Champion
International provided the local media with press releases regarding the
meeti.n"g and the proposed corrective measures. Before the public mee.ting,
each of the local papers carried at least two news stories on the planned
meeting and the proposed alternatives. In addition, EPA prepared a fact
sheet on the site, with particular emphasis on the first operable unit.
This fact sheet was distributed as an insert in a local newspaper that is
-2-
"--." -,.- --.--...-.--.------ ..."-
-------
delivered to 3,600 homes. Further, Champion International wrote letters to
homeowners who had responded to a site-related survey the company had taken
earlier. This letter notified them of thp. time, place, and purpose of the
meeting.
This public meeting opened the three-week public comment period held
from July 15 through August 8, 1986. The purpose of the meeting was to
describe Champion International's proposed actions, inform people about
overa~l site activities and the Superfund program, receive questions and
comments, and answer questions on the Feasibility Study on the First
Operable Unit (FS report) for the Libby Ground Yater site. EPA placed the
draft report in the information repository located in the county
sanitarian's office. The turnout at the meeting included fifteen local
citizens plus an additional ten representatives of the Lincoln County and
City of Libby governments.
II.
SUMMARY OF MAJOR COMMENTS RECEIVED AND RESPONSES
Although no one at the public meeting on the FS report made a formal
written statement, the majority of public questions. and comments on the
draft FS report were made at this meeting. Other comments were later made
in writing to EPA or to the Lincoln County sanitarian, or by telephone to
EPA in Helena.
The atmosphere at the meeting was generally amicable, with citizens
raising questions that clearly concerned them. No one voiced opposition to
Champion International's preferred alternative (see the full Enforcement
Decision Document). As requested in the preferred alternative, an
ordinance restricting the drilling of new wells passed unanimously without
opposition at the City Council meeting the following week.
The majority of the comments made and questions and concerns raised
came from local officials and area residents. The Montana Solid and
-3-
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Hazardous Vaste Bureau (SHVB) also made several comments. These comments,
questions, and concerns are summarized and grouped into the following five
categories:
o
Remedial alternative preferences;
o
Concerns about health and the environment;
o
Cost issues;
o
Technical questions; and
o
Community relations issues.
--.
The comments, questions, and concerns are summarized below and each is
followed by a summary of the responses. Some responses at the public
meet,ing were provided by Champion International or its consultants. These
responses are identified; otherwise, the responses were made by EPA.
Remedial Alternative Preferences
1.
Comment: The Montana SHVB concurred with the preferred
alternative. It recommended planning ahead, however, in case
future demands are greater than the capacity of the system.
citizens supported this comment as well.
Other
Response: In its study of the proposed remedial alternatives,
Champion International analyzed historical water flow and demand,
and found that Flower Creek at its lowest flow would be adequate
to meet the demands. Champion International also examined the
possibility of using the Kootenai River and the Kootenai shallow
ground water as municipal water sources. The cost to do this
would be very high, however, and EPA is not aware of any plans to
develop these or other water resources. Another possible source
of increased water supply might come from alterations to the
existing water distribution system, which currently appears to
lose a major portion of its water, probably through leakage.
-4-
. .-------.-
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Champion International has informed the City of Libby of this
problem, and the City may be exploring ways to improve the
situation.
2.
The Montana SHVB recommended that the ten residences
Commen t :
within the contaminated area that are not on the city supply
system should be connected to that system.
Response: EPA agrees with this recommendation, with the note that
the cost of connecting these residences to the public water system
has already~een included in the "buy water plan with ordinance,"
which is being implemented.
3.
Comment: The SHVB recommended that monitoring and sampling by
Champion International should be continued, especially in the Vest
Libby area and Flower Creek.
Response:
remedy.
EPA agrees, and has included this as part of the
4.
Comment: SHVB recommended that observations of the ground water
and contaminant plume movement as a result of decreased ground
water use should be made.
Response: A significant change in the
contaminant movement is not expected.
continue to monitor both ground water
however.
rate or direction of
Champion International will
levels and plume movement,
Concerns Abou t Heal th and tbe Environmen t
1.
Several citizens were concerned about the extent of the
Commen t :
con tamina tion.
They wanted to know how deeply the ground water is
-5-
..- ------.--.-----.----------.-- . ---
-------
... -- -. - ...-..--...-.
contaminated, whether use of wells outside the contaminated area
will draw the contamination in the direction of such wells, and
how the spread of the ~ontamination can be halted.
Response: The EPA and Champion International representatives
answered that the contamination is at all levels of the ground
water; there is no known safe level from which citizens might draw
their water. Vhile wells outside the contaminated area may tend
to draw contamination toward themselves, individual wells are not
a significaat factor in the overall spread of the contamination.
2.
Commen t :
One citizen wanted to know if the contamination tends to
bioaccumulate, that is, collect and concentrate in living tissue.
Response: The consultant for "Champion International answered that
the information collected thus far does not show bioaccumulation.
Plants do take up the contamination, but they do not concentrate
it. A bigger risk comes from watering the lawn; the creosote
tends to stick to the soil and in that way concentrates it. Few
tests have been done on animals, but indications thus far are that
they tend to shed the creosote easily.
3.
Comment: One citizen asked what is being done to protect
residents of Libby Flats, south of Libby.
Response: The consultant for Champion International responded
that the ground water flows away from that area; thus, action need
not be taken in that area now.
4.
Comment: One citizen asked if there has been any evidence of
increased cancer in Libby.
-6-
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Cost Issues
Response:
in Libby.
EPA does not know of any increased incidence of cancer
Cancer as a result of long-term exposure, however, is
hard to pin to a single cause.
1.
Comment: One resident asked how Champion International's payment
to the City of Libby for extra water use in the summer will affect
the individuals"already subscribing to the "buy water" plan.
Response: the Champion International representative answered that
residents subscribing to the "buy water" plan will save additional
money during the summer months.
2.
A resident asked how much the installation of an
Commen t :
activated charcoal filter on a well would cost.
Response: The Champion International consultant responded that
the installation cost is $3,000 plus the operational costs.
3.
Comment: One resident asKed whether the "buy water" plan is a
year-to-year agreement, or extends for ten years.
Response: The Champion International representative answered that
it is a year-to-year agreement. The agreement is reviewed
annually to determine if a threat to the well owners still exists,
and if other suitable alternatives have become available.
It is EPA's position that the "buy water" agreements are written
with an indefinite term. They may be terminated when a
contaminant thceat to the well no longer exists, when other
alternatives become available, or when the well owner requests
termination in writing. The payment of compensation is made on ""
yearly basis.
-7-
... - . -------.---.-----...- . -..
---- -.. .--- - -- ._-- ----.-.- --_._----- _._-------- -. - -- -- -.
-------
"
4.
Comment: A citizen asked how the Champion International payment
to the City will affect. individual sewer rates.
Response: The Hayor of Libby responded that the sewer rates will
not be affected.
5.
Comment: A Libby resident expressed concern that his well
become contaminated in the future, which could cost him as
$150 to $25~per year, an expense he cannot afford.
might
much as
EPA Response: If any wells become contaminated in the future,
Champion International will offer the "buy water" plan to the well
owner, which will cover any additional costs the well owner might
encounter.
6.
Comment: A citizen asked if the proposed options will be funded
indefinitely, or if the costs will revert to the responsibility of
the water users.
Response: EPA is not aware of any plans to make the water users
bear costs that are now being borne by Champion International for
the "buy water" or the "free irrigation water" plans.
Technical Questions
1.
Comment: One resident suggested that EPA consider drilling down
to the contaminated area of the ground water, inserting a devi~e
similar to a big wick and burning the oil off as it rises to the
surface.
-8-
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Response: A Champion International consultant responded that his
company is now investigating a similar treatment in pumping ground
water from the contaminated area and drawing off the 011 for
disposal.
2.
A resident asked if the site is expected to increase in
Commen t :
size.
\
Response: As technology makes it possible to detect contamination
in smaller amounts, the boundary of the site may become broader to
include areas. contaminated by more minute quantities of chemicals.
3.
Comment: A.local couple asked whether sufficient water pressure
would be available to each house so that irrigation and domestic
usage can go on simultaneously.
Response: . This question is actually part of a broader question of
whether water pressure was considered when the "free irrigation
water" plan was proposed. The answer to the broader question is
that potential water pressure problems were considered, but not
completely resolved. It appears that if any pressure problems
develop, they might be due to the problems inherent in the water
distribution system rather than to the additional demand. It
appears that the water distribution system loses a major portion
of its water, probably through leakage.
4.
Comment: In Harch 1985, a party with an interest in the county's
plan to drill a well in Libby asked if it would be safe to drill
that well.
Response: EPA responded in Hay 1985 that it would be best to
postpone the drilling of this well pending results of new tests in
-9-
-------
the area. In July 1986, EPA advised
of Libby had restricted the drilling
limi ts.
the same party that the City
of new wells inside the city
Community Relations Issues
1.
Comment: Several citizens asked why the fact sheets were not
printed sooner and delivered to area residents, particularly those
who are participating in the "buy water" plan.
--,
Response: The fact sheets were printed as soon as the information
became available, and were sent to all subscribers of the Western
News as an insert to the July 16, 1986 edition.
2.
Comment: One person asked whether there will be another public
meeting at, the end of the July-August, 1986 comment period.
Response: Another public meeting at the end of the public comment
period is not now planned. At the end of this public comment
period, EPA will study all the relevant information, including
public comments, and then select a remedy.
3.
Commen t :
One citizen asked if EPA will consider individual
citizens' suggestions for correcting the problems at Libby.
Response:
there are
EPA will consider any suggestions submitted., Since
many other considerations, however, there are no
that any individual suggestion will be adopted without
guarantees
change.
..J10-
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III.
REMAINING CONCERNS
There were two questions raised during the public comment period on
the FS report that EPA was unable to answer fully during remedial planning
activities.
1.
A resident asked how the contamination can finally be
Commen t :
cleaned up.
Response: The EPA and Champion International representatives
---
answered that there has not been a complete answer to that
question anywhere yet.
2.
Comment: Several commenters focused on the question of providing
water to area residents who live outside the city limits of Libby.
SHVB recommended that a plan to supply water to ~est Libby
residents not on the city water system but who may in the future
be identified as living within the contaminant plume area should
be considered. The county sanitarian asked what remedy, if any,
would be extended to those Libby-area residents that live within
the plume boundary, but not within the city limits. A non-Libby
resident who takes his water from the Libby system and whose home
is within the contaminant plume boundary expressed the opinion
that Champion International should buy water for all residents,
including those outside the city limits. And one citizen asked
whether a city ordinance or similar legislation would apply to a
property owner outside both the city limits and the plume
boundaries.
Response: Currently, no contamination has been found in wells
outside of the city limits. Individuals who already have wells
that may later become contaminated would be protected by the "buy
water" plan, provided they notify Champion International of the
existence of their well. This applies to well owners whether they
-11-
-..-...-..-.-. -..---...-.--.---___...n -------------.----- ---
-------
are inside or outside of the city limits. At such time as
contaminated wells are discovered outside of the city limits, EPA
believes it would then be appropriate for EPA, Champion
International and Lincoln County to discuss some county action to
preclude the use of ground water in the area.
EPA advises all property owners in the broader Libby area,
including those outside the plume boundary as it is now drawn, not
to drill wells, as there is a possibility that the wells could be
contaminated. . The possibility is greater for those within the
plume boundaty, but the boundary of the plume is approximate, and
it is not possible to say whether even those outside the boundary
would be guaranteed to have clean water.
'"
-12-
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ATTACHMENT A
COMMUNITY RELATIONS ACTIVITIES CONDUCTED
AT THE LIBBY GROUND VATER SITE
o
EPA established Lincoln County sanitarian as key contact person
(1979).
o
EPA issued news releases and fact sheets when the Libby Ground
Vater site was placed on the National Priorities List (January
1983).
o
Results of da~a collection from Phase I of the RIfFS York Plan were
sent by Certified Mail to each homeowner whose well was tested
(October 1983).
o
Three-week comment period with public meeting held on Phase I
results and the CERCLA 106 Administrative Order on Consent with St.
Regis Company, Champion International's predecessor (October 1983).
o
Information-repositories were established in the Lincoln County
sanitarian's office and the Montana EPA office (1983).
o
Through the cooperation of the Lincoln County sanitarian, EPA,
Champion International, and the City of Libby, a fact sheet
recommending that residents limit well installation and use was
sent to area residents (April 1984).
o
EPA prepared a community relations plan (October 1984).
o
EPA responded to occasional telephone queries from Libby residents
(ongoing throughout RIfFS).
o
A fact sheet advising residents to avoid using contaminated ground
water and to refrain from drilling wells in Libby was mailed to
Libby area residents (May 1985).
o
EPA held a public meeting in Libby to inform the public of
information gained from studies at the site (July 1985). The
meeting was announced by a press release.
o
Champion International surveyed homeowners to determine the extent
of public contact with contaminated ground water (February 1986).
o
Feasibility Study on the on First Operable Unit report released for
public review and comment (July 1986).
o
EPA issued a press release announcing the public meeting and FS
public comment period (July 1986).
-13-
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tSi';~.
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o
EPA held a public meeting at the Lincoln County Annex in Libby to
discuss the FS report and answer questions from the public (July
1986). A summary of this meeting is available in the EPA Montana
office.
o
EPA held a three-week public comment period from July 15 to
August 8, 1986.
-14-
... '"
" , .,
r"/~'!J!'
-------
ADMINISTRATIVE ORDER ON CONSENT,
DOCKET NO.
CERCLA -VIII-83-03
CONTENTS
Findings
and
S t ; p ti'1' at; 0 n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Report; nq. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Force Majeure............................................
Opportunity to Confer/Modifications......................
Resolution of Disputes...................................
Confidentiality..........................................
Pub 1; c; ty. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Incorporation of Documents...............................
Compliance with Applicable Laws..........................
2
......4
4
4
5
5
5
6
6
6
6
7
7
8
8
9
9
End a n q e rme n t . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 9
Re 1 ease from L ; abi 1; ty a.e ..... . . . .. . . . . .. . . . . . . . . . . . . . . . .. 9
En fore ernen t . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
......................
o rd e r . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Remedial Investigation and Action........................
Coordinators............................................ .
Qua 1; ty Assurance........................................
No t ; c e. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Site Acces 5 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Information Exchanqe.....................................
Preservatio~ of Information....
Coordination with Other Government Agencies..............10
Applicability of Order...................................10
R; qhts Reserved.......................................... 11
Other Claims........................".....................11
L ; ab i 1 ; t; es. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
Termi nat i on. . .... .... . ... .. .. . . . .. . . . . . .. . . .. .. . .. . . .. . . .12
Exhi bit A[[[ 13
-------
, .
UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION VIII
Docket No.
CERCLA VIII 83-03
In the Matter of:
51'. REGIS CORPORATION
)
)
)
)
)
)
)
)
)
)
)
ADMINISTRATIVE ORDER
ON CONSENT
Proceeding under Section 106
of the Comprehensive Environ-
mental Response, Compensation,
and Liability Act (CERCLA) I
42 a. S . C . 9606-. (19 8 0 )
ADMINISTRATIVE ORDER ON CONSENT
This Administrative Order on Consent (Order) is issued to
St. Regis Corpora"tion (St. Regis) upon consent of the parties by
the United States Environmental Protection Agency (EPA) pursuant
to Section l06(a) of the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), 42 a.s.c. 9606(a).
Notice of this Order has been provided to the Montana Department
of Health and Environmental Sciences (State) pursuant to Section
l06(a) of CERCLA, 42 C.S.C. 9606(a).
This Order is issued without trial or final adjudication on
any issue of law or fact.
Neither St. Regis' consent to this
Order, nor anything in this document shall constitute an
admission by St. Regis with respect to any factual or legal
matter except as otherwise stipulated herein.
---- _._--- ---.--- -----" -. - - --.--.. --.- . - --.----:-."-.-'- ---~-~-
--." .-.-----. --.-.--. --
-------
FINDINGS AND STIPULATIONS
1.
A preliminary field investigation of the groundwater in
Libby, Montana, completed by EPA in October 1981, identified
pentachlorophenol and polynuclear aromatic hydrocarbons
associated with creosote in samples taken from three domestic
irrigation wells within the Libby city limits.
2.
Pentachorophenol and polynuclear aromatic hydrocarbons
are hazardous substances, as defined by Section 101(14) of
CERCLA, and are characteristic constituents of wood treating,
among other, operations.
3.
In September 1983, EPA included the area of groundwater
contamination within Libby on the National Priorities List,
pursuant to Section 105(8) (8) of CERCLA.
(Libby Groundwater
5 i te . )
4.
St. Regis, formerly known as St. Regis Paper Company, a
New York Corporation authorized to conduct business in Montana,
owns and operates a lumber and plywood mill in Libby, Montana,
which previously included a wood treating operation.
Waste
water from the former wood treating operation, containing
pentachlorophenol and polynuclear aromatic hydrocarbons, was
placed by former owners and operators, and by St. Regis .into
evaporation ponds at the mill beginning in the early 1940's.
5. . .
St. Regis discontinued the wood treating operation in
the late 1960's, filled the ponds with earth, and incorporated
them into a log deck storage
ar ea.
St. Regis believes that
- 2 -
. .
- - ...-- -----------_._-------~----_. .-: _.--
-------
these ponds, which remain in St. Regis' ownership, were clay
lined and designed to reduce release to the environment.
6.
Neither the State nor EPA has definitely determined
that hazardous substances have migrated from the St. Regis
f ac il i ty.
However, based on the age of the evaporation ponds at
the St. Regis facility and their proximity to the three
contaminated wells, EPA believes that these evaporation ponds
may present a threat of release of hazardous substances into the
groundwater in the' Libby Groundwater Site, and that these
conditions may present an imminent and substantial endangerment
to public health, welfare, or the environment within the meaning
of Section l06(a) of CERCLA, 42 U.S.C. 9606(a).
7.
Since the spring of 1982, St. Regis, in consultation
with EPA and the State, has been investigating the extent and
sources of contamination of the groundwater at the Libby
Gro~ndwater Site and developing a plan to evaluate and implement
remedial action as necessary.
The Remedial Investigation/Action
Plan set forth herein in Exhibit A is the culmination of St.
Regis' proposal, which the parties now seek to implement through
this Order.
8.
EPA has jurisdiction to issue this Order under Section
106(a) of CERCLA, 42 U.S.C. 9606, based on its findings as
stipulated in paragraph 6, above.
9.
St. Regis consents to the issuance of this Order, but
does not admit that conditions at the Libby Groundwater Site
- 3 -
-------
constitute an imminent and substantial endangerment, within the
meaning of Section 106 of CERCLA.
St. Regis retains the right
to contest allegations concer~ing imminent and substantial
endangerment in any _other proceeding brought by EPA or any other
~rson, and enters into this Order for the purpose of expediting
an investigation of the Libby Groundwater Site in cooperation
with EPA and the State.
-.
ORDER
Based on the foregoing, it is hereby agreed and ORDERED:
10.
Remedial Investiqation and Action
Upon issuance of this Order, St. Regis shall implement
the remedial investigation, feasibility study, and remedial
action programs as set forth in Exhibit A, entitled Remedial
Investiaation/Action Plan.
St. Regis or a qualified independent consultant(s),
retained by St. Regis shall prepare all proposals, studies, and
reports required by this Order to be conducted or submitted by
St. Regis.
11.
Coordinators
Within fifteen days of entry of this Order, EPA and St.
Regis shall name coordinators who shall be responsible for the
administration of their respective responsibilities pursuant to
this Order and receive all written materials required by this
Order, and shall submit the names of those coordinators to each
other.
- 4 -
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12.
guality Assurance
St. Regis shall use sampling, quality assurance,
quality control, and chain-of-custody procedures acceptable to
EPA throughout all activities 90nducted pursuant to this Order.
St. Regis shall con~ult the EPA in planning for sampling and
analysi s.
13.
Noti ce
St. Regis shall provide advance notice to EPA and the
State of any excav~!ing, drilling, or sampling to be conducted
pursuant to the Order at least five working days in advance of
the da~e of such activity and, upon request in advance, shall
provide EPA and/or the State with a split of any sample taken
pursuant to this Order.
14.
Site access
-
St. Regis shall permit EPA, the State, and their
contractors and consultants to have access t,o St. Regis'
property and to monitor any activity conducted pursuant to this
st udy .
EPA will provide five days prior notification for access
whenever possible, consistent with its responsibilities.
Persons other than those bound by this Order presently
own portions of the Libby Groundwater Site.
The Parties to this
agreement shall use best efforts to obtain voluntary site accesS
agreem~nts from the present owners necessary to fulfill the
Parties' respective responsibilities under this Order.
"In the
event St. Regis is unable to obtain the necessary access, it
shall notify EPA.
- 5 -
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15.
Information exchange
St. Regis, EPA, and their respective contractors and
consultants shall cooperate and make available to the others in
a timely manner, the results of sampling, testing, or other data
generated by any of them or on their behalf, and any relevant
-
information in their possession regarding the actions called for
by this Order, except as exempt or protected by law from such
d i s c 1 os ur e .
16.
Preservation of information
.........
The parties shall preserve, during the pendency of this
Order ~nd for three (3) years after its termination, all records
and documents in their possession, or the possession of their
employees or agents, which relate to the Libby Groundwater Site.
17.
Reporting
St. Regis shall report to EPA in accordance with the
Plans submitted pursuant to this Order.
St. Regis shall
promptly notify EPA of any failure to meet any date in an
approved schedule, or any other significant delays, including in
such report, a statement of the causes of such delays, the date
by which the delayed activities will be completed, and their
effects on St. Regis' ability to meet the remaining schedule for
compl etion.
18~. Force Majeure
Any failure by St. Regis to comply with the terms of
this Order shall be excused, and the times for St. Regis'
- 6 -
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.. -- ----- -.
performance extended to the extent St. Regis demonstrates such
failure is caused by circumstances beyond its control.
St.
Regis shall notify EPA of any such delay as provided in
paragraph 17, above.
19.
Opoortunit~ to Confer/Modification
At any time in the course of implementation of the
Remedial Investigation/Action Program, St. Regis or its
consultants may confer with EPA concerning the program.
St.
Regis may request EPA approval of a program modification based
--.
on new information or changed circumstances.
Such
modification
shall ba implemented upon its approval.
EPA shall provide
appro~al or disapproval of requested modifi~ations.
20.
Resolution of Disputes
In the event that EPA does not approve any recommended
course of action, or part thereof, as submitted by St. Regis,
the disapproval shall be in writing, shall state reasons for the
disapproval, and may include requests for amendments or
revisions.
Within thirty days after receipt of any notice of
disapproval of any required recommendation or proposed action,
St. Regis shall submit a revised recommendation or shall state
in writing the reasons why the recommendation, as originally
submitted, should be approved.
If within the thirty days, (1)
St. Regis has not submitted a revised recommendation and the
disapproval has not been withdrawn, or (2) St. Regis has
- 7 -
-~. - -... -.. ---~ -~- -"---~--'---_.' -.__.~_..- -------.--.-'---------'---' -...
-------
submitted a revised recommendation which has not been approved,
EPA retains the right to require such further action as it deems
necessary, by issuing further administrative orders or seeking
judicial recourse, pursuant ~o its authority under Section 106
of CERCLA, 42 U.S.C~ 9606, or any other relevant provision of
law.
Nothing in this Order shall be construed to limit St.
Regis' right to contest any such further orders or judicial
action brought by EPA, or to require St. Regis to undertake any
action not set for~~in the Order submitted by St. Regis in its
recommendation or revised recommendation.
21.
Conf i denti al i ty
St. Regis may, if it desires, assert a business
confidentiality claim covering part or all of the information
requested by this Order in the manner described by 40 C.F.R.
Part 2, Subpart B.
If no such claim accompanies the information
when it is received by EPA, EPA may make it available to the
public without further notice to St. Regis.
22.
PUblicity
Each Party shall inform the other Party to this Order
in advance of any formal press release made relating to this
Order and the work conducted thereunder.
Either Party may
respond to inquiries about the
Order without consultation with
the other Party when such inquiries are made in a manner that
precludes prior notice.
Any Party may promptly release
technical data as necessary to protect public health, provided
- 8 -
. - . no- "-'-----.- - ,
-------
however, that, if possible, the Parties will be given an
opportunity to review such information and provide comments on
the information's technicai accuracy.
Any release of such
-
information shall insure that the public is informed in a
responsible manner.
23.
Incorporation of Documents
-
Any reports, plans, specifications, and schedules
required by the terms of this Order are, upon approval of EPA,
incorporated into this Order.
-.
24.
Compliance with Applicable Laws
All action required pursuant to this Order shall be
undertaken in accordance with the requirements of all applicable
local, state, and federal laws and regulations.
25.
Endangerment
In the event that activities implementing this Order,
an emergency situation, or a release or threat of release not
addressed in this Order is creating an imminent and substantial
endangerment to the public health, welfare, or the environment,
EPA and/or St. Regis may take whatever additional action may be
necessary to prevent or abate the endangerment.
,
26.
Release From Liability
Full performance by St. Regis of all commitments made
in this Order, including implementation of an approved course of
remedial action, shall constitute a full and final disposition
of this and any other civil proceeding which may have been
- 9 -
-------
brought by EPA against St. Regis with respect to groundwater
contamination in the Study Area.
However, as provided herein,
in the event of final disapproval of any course of action
proposed by St. Regis, EPA ~etains the right to seek judicial
enforcement of this-Order or require further action under
-
Section 106 of CERCLA or any other relevant provision of law,
and St. Regis retains the right to raise any and all defenses,
except as stipulated herein.
27.
Enforcement
I
Compliance with the terms of this Order shall be
enforr.eable by EPA pursuant to Section 106(b) of CERCLA, 42
U.S.C,. 9606(b).
Nothing herein shall prevent EPA from taking whatever
action may be necessary to prevent or abate any imminent and
substantial endangerment to health and the environment.
28.
Coordination with Other Government Agencies
EPA and St. Regis shall make all reasonable efforts to
coordinate all actions taken under this Order with other
appropriate government agencies, including provision of notice
and duplicate samples, upon request.
29.
Applicability of Order
This Order shall apply to and be binding on St. Regis
and its employees, agents, and contractors acting with respect
to the Libby Groundwater Site, and to successors and ass'igns of
St. Regis' said Lumber and Plywood Mill.
- 10 -
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30.
Riqhts Reserved
EPA retains the right to conduct such other
investigations and activities at the Libby Groundwater Site,
consistent with the commitments or activities required by this
Order, and further ~etains all rights against third parties
which may arise out of the facts on which this Order is based.
31.
Other Claims
Nothing in this Order is intended to release any
claims, causes of aetion or demands in law or equity of any
party against any entity not a signatory to this document for
any liability it may have arising out of or relating in any way
to the'Libby Groundwater Site.
32.
Li a bili ti es
The United States shall not be liable for any injuries
or damages to persons or property resulting from acts or
omissions by St. Regis or its agents or contractors in carrying
out activities pursuant to this Order, nor shall the United
States be held as a party to any contract entered into by St.
Regis or its agents or contractors in carrying out activities
pursuant to this Order.
The St. Regis Corporation shall not be liable for any
injuries or damages to persons or property resulting from acts'
or omissions by the United States or its agents or contrac~ors
in carrying out activities pursuant to this Order, nor shall the
St. Regis Corporation be held as a party to any contract entered
- 11 -
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into by the United States or its agents or contractors in
carrying out activities pursuant to this Order.
33.
Termination
-
The provisions of,tbis Order shall terminate Upon St.
Regis' receipt of written notice from EPA that St. Regis has
-
demonstrated, to the satisfaction of the Agency, that all of the
terms of the Remedial Investigation/Action Plan have been
compl et ed.
';:!...
I t is so agreed:
St. Regis Corporation
by Michael Flannery,
ce President
/01;k.r
Date /
It is so Ordered:
/~~,~
Eff ec v ate
- 12 -
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1.
EXHIBIT A - REMEDIAL INVESTIGATION/ACTION PLAN
Pur pose
The purposes of this study are to develop facts and
data to:
a.
Characterize the physical and chemical groundwater
conditions ~hat exist in the .Study Area-, as defined
below, through sound, well managed scientific
in vesti gations.
b.
Evaluate, to the extent possible, the degree of
suspected groundwater contamination in the Study Area.
Identify, to the extent possible, the source or sources
of suspected groundwater contamination.
c.
--.
d.
Notify, when and where appropriate, public health
officials of potential public health implications
. associated with the Study Area.
e.,
Evaluate remedial action alternatives, recommend
alternative(s) as appropriate, and implement any final
approved remedial action(s) to address any identified
threats ~o health and the environment from release of
hazardous substances in the Study Area.
II.
Obj ecti ves
The objectives of the Study are:
a.
Describe the geology.and hydrology of the Study Area
through the compilation and evaluation of well data.
b.
Utilize well data to estimate the water-bearing
characteristics of materials underlying the Study Area,
to estimate the rate and direction of groundwater flow,
and to develop a water table map for the Study Area.
Sample and analyze groundwater from wells to determine
the presence and concentration of Target Substances, as
defined in Appendix I of this exibit, in the Study Area.
c.
d.
Utilize the above data to evaluate, develop, and
recommend remedial action alternatives to address any
identified threats to health and the environment' from
release of hazardous substances in the Study Area.
-l~-
-------
III.
Study Area
The Study Area consists of Sites A and B as described
on Map 1:
a.
Site A is a portion of the property owned cy St. Regi~
where the St. Regis Libby Lumber and Plywood Facility
operates. Study Site A is defined as follows:
1.
The Southern Boundary runs from a point just south
of an irrigation well and near a mill log yard
road at the intersection with the Western
Boundary, east to the intersection with the
Eastern Boundary.
The Eastern Boundary runs along the eastern
high-W4ter mark of Libby Creek, from an
intersection with the Southern Boundary, north to
. the intersection with the Fifth Street Extension,
which crosses Libby Creek approximately 1,000 feet
from the so~thernbank of the Koot:enai River.
2.
3.
The Northern Boundary follows the Fifth Street
Extension from the east side of Libby Creek, to an
intersection with the St. Regis property line at
the plywood plant.
4.
The Western Boundary runs from an intersection
with the Northern Boundary, south following the
St. Regis property line until it connects with U.
S. Hi ghway Number 2, then par.all eling U. S.
Highway Number 2 to an intersection with the
Southern BoundlUY.
b.
Site B is a section of residential property, located to
the west of Site A. Site B is defined as follows:
1.
The Southern Boundary runs west from the western
boundlUY of U. S. Highway Number 2 down the
northern right-of-way of Maple Street to the
western high-water mark of Flower Creek.
2.
The Eastern Boundary runs along the western
right-of-way of U. S. Highway Number 2, where U.
S. Highway Number 2 runs north and south within
the town of Libby, from an intersection with the
Southern Boundary north to an intersection with
Minnesota Avenue.
-14-
. ~."- on__._.. -.__. - . ..- .-.._- ---... --~ - '--......... ---.-.--.--..------ -
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3.
The Northern Boundary is the southern right-of-way
of U. S. Highway Number 2, where the U. S. Highway
Number 2 runs east and west through the town of
Libby, running from the intersection of Minnesota
Avenue west to the western high-water mar k of
Flower Cr eek.
4.
The Western Boundary is the western high-water
mark of.Flower Creek, running north from an
intersection with the Southern Boundary to an
intersection with the Northern Boundary.
A.
IV. STUDY PLAN
PHASE I - Field Investioation
1.
Within ten .days after the effective date of this Order,
St. Reg is'--. shall obtain avail abl e well log dat a on all
existing wells located on Map I of this Exhibit. Data
collected shall include well construction information
(e.g., depth, diameter, elevation, screened intervals,
and casing type), and hydrogeologic information (e.g.,
lithologies, water bearing characteristics and
evaluations, and identity of water bearing zone).
2.
Within ten days after the effective date of this Order,
St. Regis shall measure well depths and static water
levels on the wells identified in pa'ragraph 1 above,
where possible.
3.
Within fifteen days after the effective date of this
Order, St. Regis shall submit to EPA for approval a
plan for sampling and analysis of all existing wells t9
evaluate the extent of contamination and describe
contamination plumes in the Libby Groundwater Site.
Samples will be analyzed for the Target substances
listed in Appendix I.
4.
Within seven days of EPA's approval, St. regis shall
implement the sampling and analysis Plan submitted
pursuant to paragraph 3, above, as approved by EPA.
Within fifteen days after the effective date of this
Order, St. Regis shall evaluate existing stream fl.ow
data from Libby and Flower Creeks to determine the
relationship between surface and groundwater in , the
area.
s.
6.
Within thirty days of completion of the activities in
Phase I, St. Regis shall submit a report including date:
-15-
-------
B.
c.
D.
1..
collected, sampling results, and an evaluation of the
need for further field investigation to characterize
adequately the extent and pathway of contamination at.
the Libby Groundwater Site.
PHASE II - Field Investiaation
1.
Within thirty days of submittal of the Phase I report,
St. Regis shall develop and submit to EPA a plan,
including a schedule for implementation, for continuing
the sampling, analysis, and other data gathering
necessary to evaluate the extent and pathways of
groundwater contamination at the Libby Groundwater Site.
The plan will include, inter alia, the
installatlon of additional groundwater
wells, and quarterly well sampling for
ye ar .
desi gn and
monitoring
a period of one
2.
Within thirty days of submittal of the Phase I report,
EPA will evaluate alternatives and develop a plan for
interim remedial measures to protect public health and
the environment as appropriate, including restrictions
on use of: c:ontaminat ed groundwater, if any.
PHASE III - Field Investigation
1.
Within fifteen days of EPA's approval, St. Regis shall
implement the Plan submitted in Phase II for continued
field investigations and interim remedial measures, as
approved by EPA.
2.
Within sixteen months after initiating the additional
field investigation, St. Regis shall submit to EPA a
draft and final field investigation report including
the data gathered during Phase III and an evaluation of
the extent and the pathways of any groundwater
contamination in the study area.
PHASE IV - Feasibility Study
Within 15 days after submittal of the Phase III Report,
St. Regis shall submit to EPA for approval a proposal
for studying alternative remedial measures to mitigate
and control the release and past release of hazardous
substances at the Libby Groundwater Site. The pr0P<"~ ,
shall provi de for any addi tional dSita gather ing t hi:d
may be necessary to evaluate alternatives. The Stuu~
-16-
-------
E.
shall be conducted in accordance with the National 011
and Hazardous Substances Contingency Plan, 40 C.P.R.
300.68. The proposal shall identify alternative
measures, including ~ource control and off-site action,
necessary to provide a permanent remedy to prevent
effectively o-r minimize to the greatest extent feasible
the migration of a release of hazardous substances into
the environment.
The alternative measures proposed for study will
include among others, containment, on-site treatment,
removal, management alternatives such as continued
monitoring, and may include no action.
2.
Within si'~ty days of EPA's approval of the feasi.bility
proposal, St. Regis shall complete the study of
remedial alternatives, ~ecommend a preferred
alternati ve (s) for remedial action, and submit a final
report to EPA for approval.
PHASE V - Remedial Action
1.
Within thirty days of EPA's approval of remedial
measures proposed pursuant to paragraph D.2., above,
St. Regis shall submit to EPA for approval detailed
plans which include specifications for and operation,
maintenance, and monitoring of remedial measures, and a
proposed implementation schedule.
Within fourteen days of EPA's approval of the remedial
action plans, specifications, and schedules, St. Regis
shall initiate the approved remedial actions.
2.
3.
St. Regis shall operate, maintain, and monitor
quarterly the performance of the remedial actions in
accordance with the approved plan.
-17-
_. ."'--"'-.-- ---..---..--------' ..---'..---. -'
-------
F.
Mil estones
Milestone
Phase I
Initiate Phase I
Submit samplin9 and analysis
plan
Complete Phase I data
collection
Phase II
Submit Phase I Report
Submit plan for
supplemental field investiation
,~.
Evaluate and develop plan for
interim remedial measures'
Phase III Initiate supplemental
field investigation and interim
remedial measures
Phase IV
Submit Phase III repo~t
Submit proposal for
feasibility study
Submit feasibility study
report
Phase V Submit plans, specffications,
implementation schedule for
approved remedial alternative (s)
Implement remedial alternative(s)
-18-
Date
-
Compl eted
Completed
Completed
Sept. 15, 1983
Oct. 1 5, 19 83
Oct. 15, 1983
Nov. 15, 1983
March 15, 1985
March 30, 1985
June 15, 1985
July 30, 1985
as scheduled
-------
APPENDI X I - PROTOCOL
I.
Sampling
Groundwater elevation measurements and well sampling will be
performed in accordance with th~ following procedures:
a.
Log boo k
All the field observations noted
evaluations shall be recorded in a Field
used for well studies. The Field Sample
kept at St. Regis offices in Libby.
during the well
Sample Log Book
Log Sook shall be
b.
Ground water elevation measurements
Ground water elevations shall be determined by
sounding the water depth with an electronic sounder that
will measure the level to a reference point on top of the
welJ. This reference point will be surveyed to the nearest
0.01 foot elevation. The elevations will be recorded on the
"Wa~er Well Information Form," Figure 1.
c.
Sample Protocol
(l) Water" sample bottles will be obtained from Laucks
Lab and will contain all the necessary preservatives as
outlined in Table II, 44 Fed. Reg. 69464 (December 3, 1979) r
and Laucks Laboratory Manual, Attachment 1. No residual
chlorine is anticipated in the well water and therefore
additives will not be necessary for these water samples.
The sample bottles, specific preservatives, and holding
times to be used with each target compound are listed in the
t a bl e be low:
PARAMETER CONTAINER PRESERVATIVE HOLDING TIME
Pentachlorophenol amber Cool to 4 C 7 days to extact
glass bot tl e 30 days to analysis
PAH/Compounds amber Cool to 4 C 7 days to extract
glass bottle 30 days to analysis
Total Phenols glass CuS04 28 days
bot tl e H3P04
The bottles shall be assembled into specific well packets,
containing the bottles required for the water analyses at ea~h
well. The well packets shall be shipped ,in storage and shipw< .
cooler boxes to St. Regis Co., Libby, by common carrier for .;'!i""J.'
sample series.
-19-
. --------------..-----------..--- --~-- --...-
-------
(2) Prior to well sampling, the static water level of
the well will be measured.
(3) Each well will be purged according to the
instructions found on the .~ater Well Information Form,.
F i gur e I.
(4) Each purge will consist of discharging between 3
to 5 well volumes as determined in the well elevation
study. Any well having insufficient water for the specified
purge shall be discharged until a stable pH, temperatut'e,
and conductivity is obtained.
( 5)
pur ging.
Labels on each bottle will be completed during the
The s~ple label is shown in Figure 2.
(6) After purging, all the sample bottles in the well
packets shall be filled to the top with water using a bailer
or submersible pump, either of' which must be stainless
steel. .The bottles shall not be flushed or allowed to run
over as preservatives have been pre-added to each bottle.
(7) The chain-of-custody record, Figure 3, shall be
completed and a seal attached to the top of each bottle and
signed by the sample collector.
(8) The filled water bottles shall be placed in the
cooler box containing ice for storage.
(9) The Field Sample Log Book shall be completed,
including, but not limited to, the following data: date;
time; well name; location; samples taken; sampling team;
well owner; sample splits taken; on-site water analysis
results, if completed; water physical characteristics; and
remar ks.
(10) One additional sample shall be taken by St. Regis
for a random field replica and a field blank will be carried
with all samples.
(11) After all the wells are sampled, the cooler boxes
will be checked for ice and prepared for shipment to Lau~ks
Lab. in Seat tl e.
(12) Two copies of the Field Sample Log Book will be
placed in a water tight plastic bag and accompany the
samples.
-20-
-------
(13 )
Laucks, a
in one of
by common
bo'x shall
si gned by
If the samples are to be hand delivered'to
copy of the chain-of-custody form will be placed
the containers. If the samples are to be shipped
carrier, the chain-of-custody form for each cooler
be attached to the top inside of the box and'
t he common carr i er .
(14) The cooler boxes will be sealed and shipped to
Laucks Lab, Seattle, within 48 hours of collection.
(15) The Field Sample Log Books will be placed in a
secure location at St. Regis plant at Libby.
II. Analysis
a.
Target Substances
Unless otherwise approved by !PA, all samples will be
analyzed for the following Target Substances:
Total phenols
Pentachlorophenol
Napthalene
Penathrene
Anthracene
Total polynuclear aromatic
hydrocar bons (PAR) as
identified by Method 610
b.
Field Analysis
Field analyses will follow "Standard Methods for Evaluating
Water and Waste Water," 15th Edition 1980, or manufacturers
recommendations as approved by EPA. Each instrument will be
calibrated or internally calibrated at least every morning,
noon, and after the last sample of the day. The calibration
results will be recorded prior to adjusting the instrument. The
results of each well sampled shall be noted on the "Field
Chemical Analysis Form," Figure 4.
c.
Laboratory Analysis
Upon receipt of the samples, the boxes will be examined for
broken seals. The boxes will be opened, the chain-of-custody
record signed, and any broken seals on the boxes or bottles
noted. A laboratory number will be assigned and the bottles
placed in storage for preparation and analysis. The methods
used for the analyses of the targeted compounds are outlined in
40 C.F.R. 136.3, Tables lS and C, as specified below:
-21-
-------
Descr i ption of Methods and Comments
1. Pentachlorophenol Solvent extraction
of sample followed by methylation of
extract. GC analysis will be performed
using packed column methodology and ECD
detector.
2. PAH/Specific compounds. Solvent
extraction of sample followed by HPLC
analysis of extract. Specific
compounds quantified by reference to
a calibrated curve. Compounds include,
but are not limited to Napthalene,
Phenanthrene an~.Anthracene.
3.
Total PAl!
4. Total Phenols. Automated distillation
colorimetric 4-aminoantipyrine
Reference
8Methods for .Organlc
Chemical Analysis of
Municipal and
Industrial Wastewater
U.S. EPA, July, 1982.
Method 604, or EPA- .
approved equivalent.
8Methods for Organic
Chemical Analysis of
Municipal and
Industrial Wastewater,
U . S . EP A , J ul y, 198 2 ,
Method 610, or EPA-
approved equivalent
"Methods for Organic
Chemical Analysis of
Muni ci pal and
Industrial Wastewater,
U.S. EPA, July, 1982.
Method 610, or EPA-
approved equivalent
"Methods for Chemi~ .
Analysis of Water and
Wastes," U.S. EPA,
March, 1983.
Method 420.2, or EPA-
approved equivalent,
Surrogate compounds will be added to samples prior to
extraction in the pentachlorophenol and PAR analysis. One
each duplicate, spike, field blank and field replicate will
be analyzed for all parameters. Reagent blanks will be
processed for all determinations.
III.
Quality Assurance/Ouality Control (OA/QC)
QA/OC procedures shall be in accordance with EPA document SW
846, "Test Methods for Evaluating Solid Waste,. Section 10,
Second Edition, July 1982. .
-22-
.
-------
IV.
Training and Safety
Before the sampling is started and before the first sample
of the day, training on the correct sampling procedures and'
QA/QC will be provided by the person in charge of the sampling
team.
No chemicals hazardous to the level warranting special
equipment have been getected and therefore no special safety
requirements are necessary at this time.
-~.
-23-
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--.
COMMUNITY RELATIONS RESPONSIVENESS SUMMARY
CONTENTS
Background on Community Involvement....................... 1
Summary of Majo~ Comments Received and Responses.......... 3
Remedial Alternative Preferences..................... 4
Concerns About Health and the Environemnt............ 5
Cost I s sues. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 7
Technical Questions.................................. 8
Community Relations Issues...........................10
Rema in i ng Concerns........................................ 11
Attachment A,
Community Relations Activities Conducted
At the Libby Ground Water Site....................... 13
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RESPONSIVENESS SUMMARY
LIBBY GROVND VATER SITE
LIBBY, MONTANA
September 1986
This community relations
Enforcement Decision Document
Ground Vater Superfund site.
the following sectio~.:
Responsiveness Summary is a part of the
for the first operable unit of the Libby
The Responsiveness Summary is divided into
Section I.
Background on Community Involvement. This section provides
a brief history of community interest and concerns raised
during the remedial planning activities at the Libby Ground
Vater site.
Section II.
Summary of Major Comments Received ,and the Environmental
Protection Agency's (EPA) Responses. This section
categorizes written and oral comments by relevant topics and
provides a general indication of the source of the comments
in each category. Responses to these comments are also
provided.
Section III.
Remaining Concerns. This section describes remaining
concerns that EPA is aware of regarding remedial design and
remedial action at the Libby Ground Vater site and EPA's
plans for addressing these concerns.
In addition to the above sections, Attachment A, included as part of
this Responsiveness Summary, identifies the community relations activities
conducted thus far by EPA during remedial response activities at the Libby
Ground Vater site.
I.
BACKGROUND ON COMMUNITY INVOLVEMENT
Community interest in the Libby Ground Vater site has
low. Over the years, many Libby residents have worked for
International, or its predecessor, the St. Regis Company.
take their water from the public water system which comes
generally been
Champion
Most residents
from a reservoh~
-1-
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on Flower Creek three miles upstream from the site. The Libby-area
population directly affected by the ground water contamination is a small
percentage of the population. Champion International is conducting the
remedial investigation _and-feasibility study (RIfFS) at the site. The
public has been informed of RIfFS progress and potential health effects of
creosote and pentachlorophenol through articles in the local papers and
mass mailings sponsored by EPA and Champion International. Early in the
Superfund process, the Lincoln County sanitarian was established as a key
contact person to maintain two-way communication between EPA and the
communi ty. -~.
Copies of completed portions of the RIfFS have been placed in the
information repositories located in the Lincoln County sanitarian's office
and the Montana office of the EPA.
Thus far, EPA has held three public meetings at the site, all in
conjunction with regularly-scheduled meetings of the County Board of
Health. The first meeting, in October 1983, attracted about ten area
residents in addition to the federal and local officials and company
representatives. The purpose of the meeting was to discuss results of
studies conducted as of that time and to urge residents not to use their
wells if another source of water was available. A second meeting was held
in July 1985. In addition to County Board of Health members, the meeting
attracted one interested citizen. EPA updated residents on site activities
and again urged residents not to use well water or drill new wells.
The third meeting was held on July 15, 1986, at the beginning of the
public comment period on the first operable unit. EPA and Champion
International provided the local media with press releases regarding the
meeting and the proposed corrective measures. Before the public meeting,
each of the local papers carried at least two news stories on the planned
meeting and the proposed alternatives. In addition, EPA prepared a fact
sheet on the site, with particular emphasis on the first operable unit.
This fact sheet was distributed as an insert in a local newspaper that is
-2-
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delivered to 3,600 homes. Further, Champion International wro.te letters to
homeowners who had responded to a site-related survey the company had taken
earlier. This letter notified them ~f the time, place, and purpose of the
meeting.
This public meeting opened the three-week public comment period held
from July 15 through August 8, 1986. The purpose of the meeting was to
describe Champion International's proposed actions, inform people about
overall site activities and the Superfund program, receive questions and
comments, and answer ~~estions on the Feasibility Study on the First
Operable Unit (FS report) for the Libby Ground Vater site. EPA placed the
draft report in the information repository located in the county
sanitarian's office. The turnout at the meeting included fifteen local
citizens plus an additional ten representatives of the Lincoln County and
City of Libby governments.
II.
SUMMARY OF MAJOR COMMENTS RECEIVED AND RESPONSES
Although no one at the public meeting on the FS report made a formal
written statement, the majority of public questions and comments on the
draft FS report were made at this meeting. Other comments were later made
in writing to EPA or to the Lincoln County sanitarian, or by telephone to
EPA in .Helena.
The atmosphere at the meeting was generally amicable, with citizens
raising questions that clearly concerned them. No one voiced opposition to
Champion International's preferred alternative (see the full Enforcement
Decision Document). As requested in the preferred alternative, an
ordinance restricting the drilling of new wells passed unanimously without
opposition at the City Council meeting the following week.
The majority of the comments made and questions and concerns raised
came from local officials and area residents. The Montana Solid and
. -3-
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Hazardous Vaste Bureau (SHVB) also made several comments. These comments,
questions, and concerns are summarized and grouped into the following five
categories:
o
Remedial alternative preferences;
o
Concerns about health and the environment;
o
Cost issues;
o
Technical questions; and
o
'~.
Community relations issues.
The comments, questions, and concerns are summarized below and each is
followed by a summary of the responses. Some responses at the public
meeting were provided by Champion International or its consultants. These
responses are identified; otherwise, the responses were made by EPA.
Remedial Alternative Preferences
1.
Comment: The Montana SHVB concurred with the preferred
alternative. It recommended planning ahead, however, in case
future demands are greater than the capacity of the system.
citizens supported this comment as well.
Other
Response: In its study of the proposed remedial alternatives,
Champion International analyzed historical water flow and demand,
and found that Flower Creek at its lowest flow would be adequate
to meet the demands. Champion International also examined the
possibility of using the Kootenai River and the Kootenai shallow
ground water as municipal water sources. The cost to do this
would be very high, however, and EPA is not aware of any plans to
develop these or other water resources. Another possible source
of increased vater supply might come from Glterations to the
existing water distribution system, which currently appears to
lose a major portion of its vater, probably through leakage.
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Champion International has informed the City of Libby of this
problem, and the City may be exploring ways to improve the
situation.
2.
Commen t :
The Montana SHVB recommended that the ten residences
within the contaminated area that are not on the city supply
system should be connected to that system.-
Response: EPA agrees with this recommendation, with the note that
the cost o~~connecting these residences to the public water system
has already been included in the "buy water plan with ordinance,"
which is being implemented.
,3.
Comment: The SHVB recommended that monitoring and sampling by
Champion International should be continued, especially in the Vest
Libby area: and Flower Creek.
Response:
remedy.
EPA agrees, an~ has included this as part of the
4.
Comment: SHVB recommended that observations of the ground water
and contaminant plume movement as a result of decreased ground
water use should be. made.
Response: A significant change in the
contaminant movement is not expected.
continue to monitor both ground water
however.
rate or direction of
Champion International will
levels and plume movement,
Concerns About Health and the Environment
1.
Commen t :
Several citizens were concerned about the extent of :h:
contamination.
They wanted to know how deeply the ground water ;s
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..
contaminated, vhether use of wells outside the contaminated area
will draw the contamination in the direction of such wells, and
how the spread of the coritamination can be halted.
Response: The EPA and Champion International representatives
answered that the contamination is at all levels of the ground
vater; there is no known safe level from which citizens might draw
their water. Vhile wells outside the contaminated area may tend
to drav contamination toward themselves, individual wells are not
a significant factor in the overall spread of the contamination.
2.
Comment:
One citizen wanted to know if the contamination tends to
bioaccumulate, that is, collect and concentrate in living tissue.
Response:. The consultant for Champion International answered that
the information collected thus far does not show bioaccumulation.
Plants do take up the contamination, but they do not concentrate
it. A bigger risk comes from watering the lawn; the creosote
tends to stick to the soil and in that way concentrates it. Few
tests have been done on animals, but indications thus far are that
they tend to shed the creosote easily.
J.
Comment: One citizen asked what is being done to protect
residents of Libby Flats, south of Libby.
Response: The consultant for Champion International responded
that the ground water flows away from that area; thus, action need
not be taken in that area now.
4.
Comment:
One citizen asked if there has been any evidence of
increased cancer in Libby.
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-- --- ---
Response: EPA does not know of any increased incidence of cancer
in Libby. Cancer as a result of long-term exposure, however, is
hard to pin to a single ~ause.
Cos tIssues
1.
Comment: One resident asked how Champion International's payment
to the City of Libby for extra water use in the summer will affect
the individuals already subscribing to the "buy water" plan.
--.
Response: The Champion International representative answered that
residents subscribing to the "buy water" plan will save additional
money during the summer months.
2.
Commen t :
A resident asked how much the installation of an
activated charcoal filter on a well would. cost.
Response: The Champion International consultant responded that
the installation cost is $3,000 plus the operational costs.
3.
One resident asked whether the "buy water" plan is a
Comment:
year-to-year agreement, or extends for ten years.
Response: The Champion International representative answered that
it is a year-to-year agreement. The agreement is reviewed
annually to determine if a threat to the well owners still exists,
and if other suitable alternatives have become available.
It is EPA's position that the "buy water" agreements are written
with an indefinite term. They may be terminated when a
contaminant threat to the well no longer exists, when other
alternatives become available, or when the well owner requests
termination in writing. The payment of compensation is made on a
yearly basis.
-7-
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4.
Comment: A citizen asked how the Champion International payment
to the City will affect -individual sewer rates.
Response: The Hayor of Libby responded that the sewer rates will
not be affected.
5.
Comment: A Libby resident expressed concern that his well
become contaminated in the future, which could cost him as
$150 to $250~'per year, an expense he cannot afford.
might
much as
EPA Response: If any wells
Champion International'will
owner, which will cover any
encounter. -
become contaminated in the future,
offer the "buy water" plan to the well
additional costs the well owner might
6.
Comment: A citizen asked if the proposed options will be funded
indefinitely, or if the costs will revert to the responsibility of
the water users.
Response: EPA is not aware of any plans to make the water users
bear costs that are now being borne by Champion International for
the "buy water" or the "free irrigation water" plans.
Technical Questions
1.
Comment: One resident suggested that EPA consider drilling down
to the contaminated area of the ground water, inserting a device
similar to a big wick and burning the oil off as it rises to the
surface.
-8-
-------
Response:
company is
water from
A Champion International consultant responded that his
now investigating a similar treatment in pumping ground
the contaminated area and drawing off the oil for
disposal.
2.
Commen t :
size.
A resident asked if the site is expected to increase in
Response: As technology makes it possible to detect contamination
in smaller amounts, the boundary of the site may become broader to
include areas contaminated by more minute quantities of chemicals.
3.
Comment: A local couple asked whether sufficient water pressur~
would be available to each house so that irrigation and domestic
usage can go on simultaneously.
Response: This question is actually part of a broader question of
whether water pressure was considered when the "free irrigation
water" plan was proposed. The answer to the broader question is
that potential water pressure problems were considered, but not
completely resolved. It appears that if any pressure problems
develop, they might be due to the problems inherent in the water
distribution system rather than to the additional demand. It
appears that the water distribution system loses a major portion
of its water, probably through leakage.
4.
Comment: In Harch 1985, a party with an interest in the county's
plan to drill a well in Libby asked if it would be safe to drill
that well.
Response: EPA responded in Hay 1985 that it would be best to
postpone the drilling of this well pending results of new tests in
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~"-_."---'. -_._._---- ...-
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the area. In July 1986, EPA advised the same party that the City.
of Libby had restricted the drilling of new wells insid~ the city
limi ts .
Coamunity Relations Issues
1.
Comment: Several citizens asked why the fact sheets were not
printed sooner and delivered to area residents, particularly those
who are participating in the "buy water" plan.
--.
Response: The fact sheets were printed as soon as the information
became available, and were sent to all subscribers of the Vestern
News as an insert to the July 16, 1986 edition.
2.
Comment: One person asked whe'ther there will be another public
meeting at the end of the July-August, 1986 comment period.
Response: Another public meeting at the end of the public comment
period is not now planned. At the end of this public comment
period, EPA will study all the relevant information, including
public comments, and then select a remedy.
3.
Comment: One citizen asked if EPA will consider individual
citizens' suggestions for correcting the problems at Libby.
Response:
EPA will consider any suggestions submitted.
Since
there are many other considerations, however, there are no
guarantees that any individual suggestion will be adopted without
change.
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III.
REMAINING CONCERNS
There were two questions raised during the public comment period on
the FS report that EPA~as-unable to answer fully during remedial planning
activities.
1.
Commen t :
A resident asked how the contamination can finally be
cleaned up.
question
The EPA and Champion International representatives
that there has not been a complete answer to that
anywhere ye t .
Response:
answered
'2.
Comment: Several commenters focused on the question of providing
water to area residents who live outside the city limits of Libby.
SHVB recommended that a plan to supply water to ~est Libby
residents not on the city water system but who may in the future
be identified as living within the contaminant plume area should
be considered. The county sanitarian asked what remedy, if any,
would be extended to those Libby-area residents that live within
the plume boundary, but not within the city limits. A non-Libby
resident who takes his water from the Libby system and whose home
is within the contaminant plume boundary expressed the opinion
that Champion International should buy water for all residents,
including those outside the city limits. And one citizen asked
whether a city ordinance or similar legislation would apply to a
property owner outside both the city limits and the plume
boundaries.
Response: Currently, no contamination has been found in wells
outside of the city limits. Individuals who already have wells
that may later become contaminated would be protected by the "buy
water" plan, provided they notify Champion International of the
existence of their well. This applies to well owners whether they
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are inside or outside of the city limits. At such time as
contaminated wells are discovered outside of the city l'imits, EPA
believes it would then be appropriate for EPA, Champion
International-and Lincoln County to discuss some county action to
preclude the use of ground water in the area.
EPA advises all property owners in the broader Libby area,
including those outside the plume boundary as it is now drawn, not
to drill wells, as there is a possibility that the wells could be
.~.
contaminated. The possibility is greater for those within the
plume boundary, but the boundary of the plume is approximate, and
it is not possible to say whether even those outside the boundary
would be guaranteed to have clean water.
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ATTACHHENT A
COHHUNITY RELATIONS ACTIVITIES CONDUCTED
AT THE LIBBY GROUND YATER SITE
o
EPA established Lincoln County sanitarian as key contact person
(1979).
o
EPA issued news releases and fact sheets when the Libby Ground
Yater site was placed on the National Priorities List (January
1983).
--.
o
Results of data collection from Phase I of the RIfFS York Plan were
sent by Certified Hail to each homeowner whose well was tested
(October 1983).
o
Three-week comment period with public meeting held on Phase I
results and the CERCLA 106 Administrative Order on Consent with St.
Regis Company, Champion International's predecessor (October 1983).
o
Information repositories were established in the Lincoln County
sanitarian's office and the Montana EPA office (1983).
o
Through the cooperation of the Lincoln County sanitarian, EPA,
Champion International, and the City of Libby, a fact sheet
recommending that residents limit well installation and use was
sent to area residents (April 1984).
o
EPA prepared a community relations plan (October 1984).
o
EPA responded to occasional telephone queries from Libby residents
(ongoing throughout RIfFS).
o
A fact sheet advising residents to avoid using contaminated ground
water and to refrain from drilling wells in Libby was mailed to
Libby area residents (Hay 1985).
o EPA held a public meeting in Libby to inform the public of
information gained from studies at the site (July 1985). The
.. meeting was announced by a press release.
o
Champion International surveyed homeowners to determine the extent
of public contact. with contaminated ground water (February 1986).
Feasibility Study on the on First Operable Unit report released for
public review and comment (July 1986).
o
o
EPA issued a press release announcing the public meeting and FS
public comment period (July 1986).
-13-
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-14-
o
EPA held a public meeting at the Lincoln County Annex in Libby to
discuss the FS report and answer questions from the public (July
1986). A summary of this meeting is available in the EPA Hontana
office. .
o
EPA held a three-week public comment period from July 15 to
August 8, 1986.
-.
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ADMINISTRATIVE ORDER ON CONSENT,
DOCKET NO.
CERCLA -VIII-83-03
CONTENTS
"".'
Incorporation
Compliance with Applicable Laws..............
2
4
..........4
..........4
..............5
......................5
5
6
6
6
6
7
7
8
8
............9
............9
9
9
E n fore erne n t . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 0
Coordination with Other Government Agencies....... ..10
Applicability of Order...................................10
R; qhts Reserved.......................................... 11
Other C 1 a; ms . . . . . . . . . . . . . . . . . . . . ~ . . . . . . . . . . . . . . . . . . . . . . . . , 1
L ; ab; 1 ; t; es . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 ,
Term; n at ; on . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 .
and Action..............
Findings
and Stipulations.........
........... ......... ..... ...
Order. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Remedial Investigation
Coord i nators. . . . . . . . . . . . . . . . . . . . . . . . . . .
Quality Assurance.....................r....
No t ; c e . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
S; te Acces s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Information
Preservation of
Exchanqe. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
I nf orma t; on. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Report; nq. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Force Majeure............................................
Opportunity to Confer/Modifications......................
Resolution of Disputes...................................
Confidentiality..........................................
Publ ;c;ty................................................
of Documents...................
End a n q e rme n t . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Release from Liability...................................
Exhfbit
Appendix
A[[[ .13
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UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION VIII
Docket No.
CERCLA VIII 83-03
In the Matter of: -
ST. REGIS CORPORATION
)
)
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)
)
)
)
)
)
)
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ADMINISTRATIVE ORDER
ON CON SENT
Proceeding under Section 106
of the Comprehensive Environ-
mental Response, <;_ompensation,"
and Liability Act (CERCLA),
42 a.s.c. 9606 (1980)
ADMINISTRATIVE ORDER ON CONSENT
This Administrative O;der on Consent (Order) is issued to
St. Regis Corporation (St. Regis) upon consent of the parties by
the anited States Environmental Protection Agency (EPA) pursuant
to Section l06(a) of the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), 42 a.s.c. 9606(a).
Notice of this Order has been provided to the Montana Department
of Health and Environmental Sciences (State) pursuant to Section
106(a) of CERCLA, 42 a.S.c. 9606(a).
This Order is issued without trial or final adjudication on
any issue of law or fact.
Neither St. Regis' consent to this
Order, nor anything in this document shall constitute an"
admission by St. Regis with respect to any factual or legal
matter except as otherwise stipulat~d herein.
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FINDINGS AND STIPULATIONS
1.
A preliminary field investigation of the groundwater' in
Libby, Montana, completed by EPA in October 1981, identified
pentachlorophenol and polynuclear aromatic hydrocarbons
associated with creosote in samples taken from three domestic
irrigation wells within the Libby city limits.
2.
Pentachorophenol and polynuclear aromatic hydrocarbons
are hazardous substances, as defined by Section 101{14) of
CERCLA, and are ch-a:racteristic constituents of wood treating,
among other, operations.
3.
In September 1983, EPA included the area of groundwater
contamination within Libby on the National Priorities List,
pursuant to Section 105(8) (B) of CERCLA.
Site. )
(Libby Groundwater
4.
St. Regis, formerly known as St. Regis Paper Company, a
New York Corporation authorized to conduct business in Montana,
owns and operates a lumber and plywood mill in Libby, Montana,
which previously included a wood treating operation.
Waste
water from the former wood treating operation, containing
pentachlorophenol and pOlynuclear aromatic hydrocarbons, was
placed by former owners and operators, and by St. Regis into
evaporation ponds at the mill beginning in the early 1940's.
5.
St. Regis discontinued the wood treating operatl'on in
the late 1960's, filled the ponds with earth, and incorporated
them into a log deck storage area.
St. Regis believes that
- 2 -
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these ponds, which remain in St. Regis' ownership, were clay
lined and designed to reduce release to the environment.
6.
Neither the State nor EPA has definitely determined
that hazardous substances have migrated from the St. Regis
facility.
However, based on the age of the evaporation ponds at
the St. Regis facility and their proximity to the three
contaminated wells, EPA believes that these evaporation ponds
may present a threat of release of hazardous substances into the
--.
groundwater in the Libby Groundwater Site, and that these
conditions may present an imminent and substantial endangerment
to public health, welfare, or the environment within the meaning
of Section 106(a) of CERCLA, 42 U.S.C. 9606(a).
7.
Since the spring of 1982, St. Regis, in consultation
with EPA and the State, has been investigating the extent and
sources of contamination of the groundwater at the Libby
Groundwater Site and developing a plan to evaluate and implement
remedial action as necessary.
The Remedial Investigation/Action
Plan set forth herein in Exhibit A is the culmination of St.
Regis' proposal, which the parties now seek to implement through
this Order.
8.
EPA has jurisdiction to issue this Order under Section
106(a) of CERCLA, 42 U.S.C. 9606, based on its findings as
stipulated in.paragraph 6, above.
9.
St. Regis consents to the issuance of this Order, but
does not admit that conditions at the Libby Groundwater Site
- 3 -
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constitute an imminent and substantial endangerment, within the
meaning of Section 106 of CERCLA.
St. Regis retains the right
to contest allegations concerning imminent and substantial
endangerment in any ~ther proceeding brought by EPA or any other
~rson, and enters into this Order for the purpose of expediting
an investigation of the Libby Groundwater Site in cooperation
with EPA and the State.
--.
ORDER
Based on the foregoing, it is hereby agreed and ORDERED:
10'.
Remedial Investiqation and Action
Upon issuance of this Order, St. Regis shall implement
the remedial investigation, feasibility study, and remedial
action programs as set forth in Exhibit A, entitled Remedial
Investiqation/Action Plan.
,St. Regis or a qualified independent consultant(s),
retained by St. Regis shall prepare all proposals, studies, and
reports required by this Order to be conducted or submitted by
St. Regis.
11.
Coordinators
Within fifteen days of entry of this Order, EPA and St.
Regis shall name coordinators who shall be responsible for the
administration of their respective responsibilities pursuant to
this Order and receive all written materials required by this
Order, and shall submit the names of those coordinators to each
other.
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12.
Quality Assurance
St. Regis shall use sampling, quality assurance,
quality control, and chain-of-custody procedures acceptable to
EPA throughout all activities conducted pursuant to this Order.
St. Regis shall consult the EPA in planning for sampling and
analysi s.
13.
Noti ce
st. Regis shall provide advance notice to EPA and the
State of any excavating, drilling, or sampling to be conducted
pursuant to the Order at least five working days in advance of
the datoe of such activity and, upon request in advance, shall
provide EPA and/or the state with a split of any sample taken
pursuant to this Order.
14.
site access
St. Regis shall permit EPA, the State, and their
contractors and consultants to have access to St. Regis'
property and to monitor any activity conducted pursuant to this
study. .
EPA will provide five days prior notification for access
whenever possible, consistent with its responsibilities.
Persons other than those bound by this Order presently
own portions of the Libby Groundwater Site.
The Parties to this
agreement shall use best efforts to obtain voluntary site ~ccess
agreements from the present owners necessary to fulfill the
Parties' respective responsibilities under this Order.
In the
event St. Regis is unable to obtain the necessary access, it
shall notify £FA.
- 5 -
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15.
Information exchange
St. Regis, BFA, and their respective contractors and
consultants shall cooperate and make available to the. others in
a timely manner, the results of sampling, testing, or other data
generated by any of them or on their behalf, and any relevant
- .
information in their possession regarding the actions called for
by this Order, except as exempt or protected by law from such
d i s c 1 os ur e .
--.
16.
Preservation of information
The .parties shall preserve, during the pendency of this
Order .::nd for three (3) years after its termination, all records
and documents in their possession, or the possession of their
employees or agents, which relate to the Libby Groundwater Site.
17.
Reporting
St. Regis shall report to EPA in accordance with the
Plans submitted pursuant to this Order.
St. Regis shall
promptly notify EPA of any failure to meet any date in an
approved schedule, or any other significant delays, including in
such report, a statement of the causes of such delays, the date
by which the delayed activities will be completed, and their
effects on St. Regis' ability to meet the remaining schedule for
com pI etion.
18.
Force Majeure
Any failure by St. Regis to comply with the terms of
this Order shall be excused, and the times for St. Regis'
- 6 -
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performance extended to the extent St. Regis demonstrates such
failure is caused by circumstances beyond its control.
St.
Regis shall notify EPA of any such delay as provided in
paragraph 17, above.
19.
Opportunity. to Confer/Modification
At any time in the course of implementation of the
Remedial Investigation/Action Program, St. Regis or its
consultants may confer with EPA concerning the program.
St.
Regis may request BFA approval of a program modification based
on new information or changed circumstances.
Such
modification
shall b.a implemented upon its approval. - EPA shall provide
approval or disapproval of requested modifications.
20.
Resolution of Disputes
In the event that EPA does not approve any recommended
course of action, or part thereof, as submitted by St. Regis,
the disapproval shall be in writing, shall state reasons for the
disapproval, and may include requests for amendments or
revisions.
Within thirty days after receipt of any notice of
disapproval of any required recommendation or proposed action,
St. Regis shall submit a revised recommendation or shall state
in writing the reasons why the recommendation, as originall¥
submitted, should be approved.
If within the thirty days, (1)
St. Regis has not submitted a revised recommendation and the
disapproval has not been withdrawn, or (2) St. Regis has
- 7 -
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submitted a revised recommendation which has not been approved,
EPA retains the right to require such further action as it deems
necessary, by issuing further administrative orders or seeking
judicial recourse, pursuant to' its authority under Section 106
of CERCLA, 42 U.S.C.- 9606, or any other relevant provision of
law.
Nothing in this Order shall be construed to limit St.
Regis' right to contest any such further orders or judicial
action brought by EPA, or to require St. Regis to undertake any
action not set fortil. in the Order submi tted by St. Regi s in its
recommendation or revised recommendation.
21.
Conf i denti al i ty
St. Regis may, if it desires, assert a business
confidentiality claim covering part or all of the information
requested by this Order in the manner described by 40 C.F.R.
Part 2, Subpart B.
If no such claim accompanies the information
when it is received by EPA, EPA may make it available to the
public without further notice to St. Regis.
22.
Publicity
Each Party shall inform the other Party to this Order
in advance of any formal press release made relating to this
Order and the work conducted thereunder.
Either Party may
respond to inquiries about the
Order without consultation with
the oth~r Party when such inquiries are made in a manner that
precludes prior notice.
Any Party may promptly release
technical data as necessary to protect public health, provided
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. -... '-'--'---'.'. ._._-.--._-----~---
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however, that, if possible, the Parties will be given an
opportunity to review such information and provide comments on
the information's technical accuracy.
Any release of such
-
information shall insure that ,the public is informed in a
responsible manner.-
23.
Incorporation of Documents
Any reports, plans, specifications, and schedules
required by the terms of this Order are, upon approval of EPA,
incorporated into ~~is Order.
24.
Compliance with Applicable Laws
All action required pursuant to this Order shall be
undertaken in accordance with the requirements of all applicable
local, state, and ,federal laws and regulations.
25.
Endangerment
In the event that activities implementing this Order,
an emergency situation, or a release or threat of release not
addressed in this Order is creating an imminent and substantial
endangerment to the public health, welfare, or the environment,
EPA and/or St. Regis may take whatever additional action may be
necessary to prevent or abate the endangerment.
26.
Release From Liability
Full performance by St. Regis of all commitments made
in this Order, including implementation of an approved course of
remedial action, shall constitute a full and final disposition
of this and any other civil proceeding which may have been
- 9 -
.-----.---- -- ...---.--.---..- ----.-.- - -.----. .. ----..'" -
-------
brought by EPA against St. Regis with respect to groundwater
contamination in the Study Area.
However, as provided herein,
in the event of final disapproval of any course of action
-
proposed by St. Regis, EPA retains the right to seek judicial
enforcement of this Order or require further action under
-
Section 106 of CERCLA or any other relevant provision of law,
and St. Regis retains the right to raise any and all defenses,
except as stipulated herein.
27.
Enforcemerli:
Compliance with the terms of this Order shall be
enforr.eable by EPA pursuant to Section 106(b) of CERCLA, 42
U.S.C.9606(b).
Nothing berein shall prevent EPA from taking whatever
action may be necessary to prevent or abate any imminent and
substantial endangerment to health and the environment.
28.
Coordination with Other Government Agencies.
EPA and St. Regis shall make all reasonable efforts to
coordinate all actions taken under this Order with other
appropriate government agencies, including provision of notice
and duplicate samples, upon request.
29.
Applicability of Order
This Order shall apply to and be binding on St. Regis
and its employees, agents, and contractors acting with respect
to the Libby Groundwater Site, and to successors and assigns of
St. Regis' said Lumber and Plywood Mill.
- 10 -
'.,"" ..... ,., ... .,.-.. -," ......,.." .~"~_.. 'I.';"",~'" .,"
-------
30.
Right s Reserved
EPA retains the right to conduct such other
investigations and activities at the Libby Groundwater Site,
consistent with the commitments or activities required by this
Order, and further retains all rights against third parties
which may arise out of the facts on which this Order is based.
31.
Other Claims
Nothing in this Order is intended to release any
claims, causes of action or demands in law or equity of any
party against any entity not a signatory to this document for
any liability it may have arising out of or relating in any way
to the Libby Groundwater Site.
32.
Liabilities
The United States shall not be liable for any injuries
or damages to persons or property resulting from acts or
omissions by St. Regis or its agents or contractors in carrying
out activities pursuant to this Order, nor shall the United
States be held as a party to any contract entered into by St.
Regis or its agents or contractors in carrying out activities
pursuant to this Order.
The St. Regis Corporation shall not be liable for any
injuries or damages to persons or property resulting from acts.
or omissions by the United States or its agents or contractors
in carrying out activities pursuant to this Order, nor shall the
St. Regis Corporation be held as a party to any contract entered
- 11 -
------ -.-____n
- 0" U._--'--"-
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into by the United States or its agents or contractors in
carrying out activities pursuant to this .Order.
33.
Termination
-
The provisions of ,this Order shall terminate upon St.
Regis' receipt of written notice from EPA that St. Regis has
demonstrated, to the satisfaction of the Agency, that all of the
terms of the Remedial Investigation/Action Plan have been
completed.
--.
I tis so a g r e e d :
St. Regis Corporation
by Michael Flannery,
ce President
lo~k~
Date /
It is so Ordered:
Eff~R:P
- 12 -
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I.
EXHIBIT A - REMEDIAL INVESTIGATION/ACTION PLAN
pur pose
The purposes of this study are to develop facts and
data to:
a.
Characterize the physical and chemical groundwater
conditions that exist in the "Study Area", as defined
, below, through sound, well managed scientif ic
investigations.
b.
Evaluate, to the extent possible, the degree of
suspected groundwater contamination in the Study Area.
Identify, to the extent possible, the source or sources
of suspected groundwater contamination.
c.
d.
Notify, when and where appropriate, public health
officials of potential public health implications
associated with the Study Area.
e.
Evaluate remedial action alternatives, recommend
alternative(s) as appropriate, and implement any final
approved remedial action(s) to address any identified
threats to health and the environment from release of
hazardous substances in the Study Area.
Obj ecti ves
II.
a.
The objectives of the Study are:
Describe the geology and hydrology of the Study Area
through the compilation and evaluation of well data.
b.
Utilize well data to estimate the water-bearing
characteristics of materials underlying the Study Area,
to estimate the rate and direction of groundwater flow,
and to develop a water table map for the Study Area.
Sample and analyze groundwater from wells to determine
the presence and concentration of Target Substances, as
defined in Appendix I of this exibit, in the Study Area.
c.
d.' .
Utilize the above data to evaluate, develop, and
recommend remedial action alternatives to address any
identified threats to health and the environment from
release of hazardous substances in the Study Area.
-13.-
-. _0.. ,.." ...,.....~.... "'. .''''''''
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III.
Study Area
The Study Area consists of Sites A and B as described
on Map 1:
a.
Site A is a portion of, the property owned oy St. Regis
where the St. Regis Libby Lumber and Plywood Facility
operates. Study Site A is defined as follows:
1.
The Southern Boundary runs from a point just south
of an irrigation well and near a mill log yard
road at the intersection with the Western
Boundary, east to the intersection with the
Eastern Boundary.
2.
The Eastern Boundary runs along the eastern
high-water mark of Libby Creek, from an
intersection with the Southern Boundary, north to
. the intersection with the Fifth Street Extension,
which crosses Libby Creek approximately 1,000 feet
from the so~thernbank of the K09tenai River..
3.
The Northern Boundary follows the Fifth Street
Extension from the east side of Libby Creek, to an
intersection with the St. Regis property line at
the plywood plant.
b.
The Western Boundary runs from an intersection
with the Northern Boundary, south following the
St. Regis property line until it connects with Uo
S. Highway Number 2, then paralleling U. S.
Highway Number 2 to an intersection with the
Southern Boundary.
Site B is a section of residential property, located to
the west of Site A. Site B is defined as follows:
4.
1..
The Southern Boundary runs west from the western
boundary of U. S. Highway Number 2 down the
northern right-of-way of Maple Street to the
western high-water mark of Flower Creek.
The Eastern Boundary runs along the western
right-of-way of U. S. Highway Number 2, where U.
S. Highway Number 2 runs north and south within
the town of Libby, from an intersection with the
Southern Boundary north to an intersection with
Minnesota Avenue.
2.
-14-
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3.
The Northern Boundary is the southern right-of-way
of U. S. Highway Number 2, where the U. S. Highway
Number 2 runs east and west through the town of
Libby, running from the intersection of Minnesota
Avenue west to the western high-water mar k of
Flower Creek.
4.
The Western Boundary is the western high-water
mar k .of Flower Creek, running north f rom an
intersection with the Southern Boundary to an
intersection with the Northern Boundary.
IV. STUDY PLAN
A.
PHASE I - Field Investioation
3.
1.
Within t~ days after the effective date of this Order,
St. Regis shall obtain available well log data on all
existing wells located on Map I of this Exhibit. Data
collected shall include well construction information
(e.g., depth, diameter, elevation, screened intervals,
and casing type), and hydrogeologic information (e.g.,
lithologies, water bearing characteristics and
evaluations, and identity of water bearing zone).
2.
Within ,t'en days after the effective date of this Order q
St. Regis shall measure well depths and static water
levels on the wells identified in paragraph 1 above,
where possible.
4.
Within fifteen days after the effective date of this
Order, St. Regis shall submit to EPA for approval a
plan for sampling and analysis of all existing wells to
evaluate the extent of contamination and describe
contamination plumes in the Libby Groundwater Site.
Samples will be analyzed for the Target substances
listed in Appendi~ I.
Within seven days of EPA's approval, St. regis shall
implement the sampling and analysis Plan submitted
pursuant to paragraph 3, above, as approved by EPA.
5.
Within fifteen days after the effective date of t~is
Order, St. Regis shall evaluate existing stream flow
data from Libby and Flower Creeks to determine the
relationship between surface and groundwater in the
area.
6.
Within thirty days of completion of the activities in
Phase I, St. Reg is shall submit a report incl uding dati~
-15-
..- .------.---.-. .-.- . -. -'-' ---~--- -+. - --.----- "-- ---.. - -
-------
- - ~..- .-
collected, sampling results, and an evaluation of the
need for further field investigation to characterize
adequately the extent and pathway of contamination at.
the Libby Groundwater Site.
B.
PEASE II - Field Investigation
1.
2.
Within thirty days of submittal of the Phase I report,
St. Regis shall develop and submit to EPA a plan,
including a schedule for implementation, for continuing
the sampling, analysis, and other data gathering
necessary to evaluate the extent and pathways of
groundwater contamination at the Libby Groundwater Site.
The plan w.ill include, inter alia, the
installatlon of additional groundwater
wells, and quarterly well sampling for
ye ar .
desi gn and
monitoring
a period of one
Within thirty days of submittal of the Phase I report,
EPA will evaluate alternatives and develop a plan for
interim remedial measures to protect public health and
the environment as appropriate, including restrictions
on use of contaminated groundwater, if any.
c.
PHASE III - Field Investigation
1.
2.
D.
1. .
Within fifteen days of EPA's approval, St. Regis shall
implement the Plan submitted in Phase II for continued
field investigations and interim remedial measures, as
approved by EPA.
Within sixteen months after initiating the additional
field investigation, St. Regis shall submit to EPA a
draft and final field investigation report including
the data gathered during Phase III and an evaluation of
the extent and the pathways of any groundwater
contamination in the study area.
PEASE IV - Feasibility Study
Within 15 days after submittal of the Phase III Report,
St. Regis shall submit to EPA for approval a proposal
for studying alternative remedial measures to mitigate
and control the release and past release of hazardous
substances at the Libby Groundwater Site. The propo~,"1l
shall provide for any additional data gathering that
may be necessary to evaluate alternatives. The Study
-16-
- . -- ---... -.. -, .-. -' ~"-.'," ,,~"..,..... -,"
.- ..-------. .--~,.
--.--- ..-- ----- .'---~-'_.' ----... -... _.~ .
-------
shall be conducted in accordance with the National 011
and Hazardous Substances Contingency Plan, 40 C.F.R.
300.68. The proposal shall identify alternative
measures, including-source control and off-site action,
necessary to provide a permanent remedy to prevent
effectively- or minimize to the greatest extent feasible
the migration of a release of hazardous substances into
the environment.
The alternative measures proposed for study will
include among others, containment, on-site treatment,
removal, management alternatives such as continued
monitoring, and may include no action.
---
2.
Within sixty days of EPA's approval of the feasibility
proposal, St. Regis shall complete the study of
remedial alternatives, ~ecommend a preferred
alternative(s) for remedi-al action, and submit a final
report to EPA for approval. - -
E.
PHASE V - Remedial Action
1.
Within thirty days of EPA's approval-of remedial
measures proposed pursuant to paragraph D.2., above,
St. Regis shall submit to EPA for approval detailed
plans which include specifications for and operation,
maintenance, and monitoring of remedial measures, and a
proposea implementation schedule.
2.
Within fourteen days of EPA's approval of the remedial
action plans, specifications, and schedules, St. Regis
shall initiate the approved remedial actions.
3.
St. Regis shall operate, maintain, and monitor
quarterly the performance of the remedial actions in
accordance with the approved plan.
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. -. ..~....-.....
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F.
Mil es tones
Phase I
Phase II
Milestone
Initiate Phase I
Submit sampling and analysis
plan -
Complete Phase I data
collection
Submit Phase I Report
Submit plan for
supplemental field investiation
Evaluate and develop plan for
interim remedial measures
Phase III Initiate supplemental
field investigation and interim
remedial measures
Phase IV
Submit Phase III report
Submit proposal for
feasibility study
Submit feasibility study
report
Phase V Submit plans, specifications,
implementation schedule for
approved remedial alternative (s)
Implement remedial alternative(s)
-18-
Date
Completed
Completed
Compl et ed
Sept. 15, 1983
Oct. 15 , 19 83
Oct. 15, 1983
Nov. 15, 1983
March 15, 1985
March 30, 1985
June 15, 1985
July 30, 1985
as scheduled
". _. ..- ._'.~ ~~..'-.-.~' ..-'''''',.. "....
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APPENDI X I - PROTOCOL
1.
Sampling
Groundwater elevation measurements and well sampling will be
performed in accordance with the following procedures:
a.
Log book.
All the field observations noted
evaluations shall be recorded in a Field
used for well studies. The Field Sample
kept at St. Regis offices in Libby.
during the well
Sample Log Book
Log Book shall be
b.
Ground wat.er elevation measurements
Ground water elevations shall be determined by
sounding the water depth with an electronic sounder that
will measure the level to a reference point on top of the
welJ. This reference point will be surveyed to the nearest
0.01 foot elevation. The elevations will be recorded on the
NWater Well Information Form,N Figure 1.
--.
c.
Sample Protocol
(1) Water sample bottles will be obtained from Laucks
Lab ana will contain all the necessary preservatives as
outlined in Table II, 44 Fed. Reg. 69464 (December 3, 1979) g
and Laucks Laboratory Manual, Attachment 1. No residual
chlorine is anticipated in the well water and therefore
additives will not be necessary for these water samples.
The sample bottles, specific preservatives, and holding
times to be used with each target compound are listed in the
tabl e belcrw:
PARAMETER CONTAINER PRESERVATIVE HOLDING TIME
Pentachlorophenol amber Cool to 4 C 7 days to extact
glass bot tl e 30 days to analysis
PAR/Compounds amber Cool to 4 C 7 days to extract
gl as s bottle 30 days to analysis
Tota.l Phenols glass CuS04 28 days
bottle H3P04
The bottles shall be assembled into specific- well packets,
containing the bottles required for the water analyses at P'C!r.~r'
well. The well packets shall be shipped in storage and sh).)':' r"
cooler boxes to St. Regis Co., Libby, by common carrier fot' r:':~")}
s am pI e s e r i e s .
-19-
-'-",' .-'-"" .,.,"'. -',," ----...~~
-------
(2) Prior to well sampling, the static water level of
the well will be measured.
(3) Each well will be purged according to the
instructions found on th~ .~ater Well Information Form,.
Figure 1.
(4) Each purge will consist of discharging between 3
to 5 well volumes as determined in the well elevation
study. Any well having insufficient water for the specified
purge shall be discharged until a stable pH, temperature,
and conductivity is obtained.
( 5)
purging.
Labels on each bottle will be completed during the
The sample label is shown in Figure 2.
(6) After purging, all the sample bottles in the well
packets shall be filled to the top with water using a bailer
or submersible pump, either of which must be stainless
steel. The bottles shall not be flushed or allowed to run
over as pr eservati ves have been pre-added to each bottle.
(7) The chain-of-custody record, Figure 3, shall be
completed and .a seal attached to the top of each bottle and
signed by the sample collector.
(8) The filled water bottles shall be placed in the
cooler box containing ice for storage.
(9) The Field Sample Log Book shall be completed,
including, but not limited to, the following data: date;
time; well name; location; samples taken; sampling team;
well owner; sample splits taken; on-site water analysis
results, if completed; water physical characteristics; and
remar ks.
(10) One additional sample shall be taken by St. Regis
for a random field replica and a field blank will be carried
with all samples.
(11) After all the wells are sampled, the cooler boxes
will be checked for ice and prepared for shipment to Laucks
Lab "in Seattle.
(12) Two copies of the Field Sample Log Book will be
placed in a water. ti ght plastic bag and accompany the
samples.
-20-
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;.,
(13)
Laucks, a
in one of
by common
box shall
si gned by
If the samples are to be hand delivered to
copy of the chain-of-custody form will be placed
the containers. If the samples are to be shipped
carrier, the chain-of-custody form for each cooler
be attached to the top inside of the box and.
the common carrier.
(14) The cooler boxes will be sealed and shipped to
Laucks Lab, Seattle, within 48 hours of collection.
(15) The Field Sample Log Books will be placed in a
secure location at St. Regis plant at Libby.
II. Analysis
a.
Tar get Substanc~s
Unless otherwise approved by EPA, all samples will be
analyzed for the following Target Substances:
Total phenols
pentachlorophenol
Napthalene
penathrene
Anthracene
Total polynuclear aromatic
hydrocarbons (PAR) as
identified by Method 610
b.
Field Analysis
Field analyses will follow "Standard Methods for Evaluating
Water and Waste Water," 15th Edition 1980, or manufacturers
recommendations as approved by EPA. Each instrument will be
calibrated or internally calibrated at least every morning,
noon, and after the last sample of the day. The calibration
results will be recorded prior to adjusting the instrument. The
results of each well sampled shall be noted on the "Field
Chemical Analysis Form," Figure 4.
c.
Laboratory Analysis
Upon receipt of the samples, the boxes will be examined for
broken seals. The boxes will be opened, the chain-of-custody
record signed, and any broken seals on the boxes or bottles
noted. A laboratory number will be assigned and the bottles
placed in storage for preparation and analysis. The methods
used for the analyses of the targeted compounds are outlined in
40 C.F.R. 136.3, Tables lB and C, as specified below:
-21-
. - '.-.'"
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Description of Methods and Comments
1. Pentachlorophenol Solvent extraction
of sample followed by methylation of
extract. GC analysis will be performed
using packed column methodology and ECD
detector.
2. PAH/Specific compounds. Solvent
extraction of sample followed by HPLC
analysis of extract. Specific
compounds quantified by reference to
a calibrated curve-. Compounds include,
but are not limi~ed to Napthalene,
Phenanthrene and Anthracene.
3.
Total PAH
4. Total Phenols. Automated distillation
colorimetric 4-aminoantipyrine
'j
Reference
8Methods for 'Organic
Chemical Analysis of
Mun i"ci pal and
Industrial Wastewater,
U.S. EPA, July, 1982.
Method 604, or EPA-
approved equivalent.
8Methods for Organic
Chemical Analysis of
Municipal and
Industrial Wastewater,
U . 5 . EP A , J ul y, 1982.
Method 610, or EPA-
approved equivalent
8Methods for Organic
Chemical Analysis of
M uni ci pal and
Industrial Wastewater,
u.S. EPA, July, 1982.
Method 610, or EPA-
approved equivalent
-Methods for Chemical
Analysis of Water and
Wastes,8 U.S. EPA,
March, 1983.
Method 420.2, or EPA~
approved equivalent.
Surrogate compounds will be added to samples prior to
extraction in the pentachlorophenol and PAR analysis. One
each duplicate, spike, field blank and field replicate will
be analyzed for all parameters. Reagent blanks will be
processed for all determinations.
III.
Quality Assurance/Quality Control (QA/QC)
QA/QC procedures shall be in accordance with EPA document SW
846, -Test Methods for Evaluating Solid Waste,- Section la,
Second Edition, July 1982.
-22-
-------
,-
:,)
IV.
Training and Safety
Before the sampling is started and before the first sample,
of the day, training on the correct sampling procedures and
QA/OC will be provided by the person in charge of the sampling
team.
No chemicals hazardous to the level warranting special
equipment have been detected and therefore no special safety
requirements are necessary at this time.
.-.
-23-
. ......, . ''''.."
-------
LOCATION MAP \
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INVESTIGATION OF GROUND WATER. QUALITY
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SCALE: '..eoo.
-24-
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LIBBY ,M:JNT ANA
FIELD CH£MICAL ANALYSIS fORM
: I
\:.Ie 11 Owner
Address
Ci tj/State
location T
We 11 P ro j ec t No.
Date
Time
1/4
1/4. See
N. R
~
C:):.;rl~y
Quad
--.
Sa~~l i"9 DHa
Sa:;.?' e tal:.en fr:)m:
Pur:':~ operated
Sa~p'e is markc1:
minutes before samp1ing.
Fie!1 Chemical knalysis
~.."alyst lli:7:e i Qa:~ I
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;- + -i
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3 .' I I I I
I
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4 I I I
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5 t
6 --1 1
.
T IJ ta 1
Co~1uctance Hardness
i.1 cro mno$icm I as Ca CO
I
I
I
Dissolved Iron
I ph I Oxygen I (Total mg/l 1:-
I I I I
-~ I. I
Schedul ed by
J.R. Carr/Associate~
-i7~~ 4
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