oEPA
(
www.epa.gov/aml/revital
Out of the Dust: Recreational Reuse After Vermiculite Mining
The libby Asbestos Superfund Site in Libby, Montana
Introduction
Libby is a small town in the northwest corner of Montana, 35 miles east of Idaho
and 65 miles south of Canada. The town lies in a picturesque valley carved by
the Kootenai River and framed by the Cabinet Mountains to the south.
Sometimes, the value of a place goes far beyond trees, picnic
tables and open space. In Libby, Montana, Riverfront Park has
come to symbolize the community's resilience, healing and
recovery from environmental tragedy. The park, dedicated in
August 2013, points the way to a brighter future, while honoring
the memory of those who have suffered or died from asbestos-
related disease.
For decades, a mine near Libby run by W.R. Grace and Company
(Grace) was the source of more than 70 percent of all vermiculite
sold in the United States. Vermiculite is a remarkably versatile
mineral used to insulate homes, improve garden soils and
make shipping materials. Unfortunately, vermiculite from the
Libby mine was contaminated with a toxic form of naturally
occurring asbestos. Many residents and workers exposed to the
contamination developed asbestos-related disease. To date, about
400 people have died. Another 2,000 people have been diagnosed
with some form of the disease.
Part of the Libby Asbestos Superfund site was the former Export
Plant area, where Grace stored mined vermiculite before shipping
it nationwide. Located on the south side of the Kootenai River,
just north of downtown, the 17-acre area was mostly a fenced-
off. overgrown eyesore for years. The City of Libby came
together with EPA, the Montana Department of Environmental
Quality (MDEQ), Lincoln County and community organizations
to develop a coordinated approach to the area's cleanup and
redevelopment.
In August 2013, after several years of planning, cleanup and
restoration, the City of Libby officially opened Riverfront Park.
The multi-use recreation facility includes river access, pavilions,
a memorial, parking and picnic tables. People put in boats to
experience one of the area's many renowned fisheries. At dusk,
others take a quiet moment to sit and enjoy the park's mountain
views and watch the water flow past. Groups come together
for community gatherings and celebrations. Libby's annual
Riverfront Blues Festival recently attracted more than 900 people
to the park.
This case study explores the partnerships and tools that have led
to the successful cleanup and reuse of the former Export Plant
area at the Libby Asbestos Superfund site. In the following
pages, the case study discusses how local planning efforts and
community coordination with EPA and MDEQ made Riverfront
Park possible. The case study provides detailed information and
lessons learned for parties interested in Superfund site and mine
land reuse, local government leadership and recreational reuse of
contaminated lands.
Cleanup, tree plantings and the official opening of Libby's Riverfront Park in August 2013.
U.S. Environmental Protection Agency
Abandoned Mine Lands Team

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Site History, Contamination and Remediation
While many hard rock mines have operated in the Libby area
since the 1880s, the dominant impact to human health and
the environment in Libby lias been from vermiculite mining
and processing. Prospectors first located vermiculite deposits
on Rainy Creek northeast of Libby. In 1919. Edward Alley, a
local rancher, bought the Rainy Creek claims and started the
vermiculite mining operation called the "Zonolite Company."
Over time, vermiculite became a product used in insulation
feed additives, fertilizer and soil amendments, construction
materials, absorbents and packing materials. Many people
used vermiculite products for insulation in their houses in
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The vermiculite mine near Libby operated for more than 70 years.
and around the site and
as soil additives in their
gardens. Grace bought the
mine and its processing
facilities in 1963 and
operated them until 1990.
Vermiculite mining and
processing activities led to
widespread contamination
in and around Libby.
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1940s advertisement for
vermiculite insulation from Libby.
The former Export Plant
- referred to by EPA as
operable unit 1 (OU1) - is
located on the south side
of the Kootenai River,
just north of downtown
Libby. Grace owned and
used the 17-acre area
for stockpiling, staging and distributing vermiculite and
vermiculite concentrate to vermiculite processing areas and
insulation distributors outside of Libby. EPA's work in Libby
began when the Agency sent an Emergency Response Team
to investigate local concerns about asbestos-contaminated
vermiculite in 1999. Since then, EPA has been working
closely with the community to clean up contamination and
reduce risks to human health. EPA listed the site on the
National Priorities List (NPL). the Agency's list of top-
priority Superfund sites, in October 2002.
This map shows the eight areas, or OUs, where
cleanup activities are ongoing in and around
Libby. The former Export Plant, the focus of
this case study, is 0U1.
OU 3
OU 7
OU 4
Jroy
OUs 3,6
and 8 """
OU 2
Kootenai
Falls
OU 1
ou 5'
ou
OU
2

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year of restoration activities, the ribbon-cutting ceremony
for Riverfront Park took place on August 3, 2013.
Cleanup of the rest of the site's operable units is ongoing.
While remaining cleanup will take years, major progress
has been made. Sitewide, as of fall 2013, EPA and MDEQ
have cleaned up 1,861 properties and removed and
replaced more than 1 million cubic yards of impacted soil,
significantly reducing risks to area families. EPA has also
conducted response actions to reduce nsks at other former
processing facilities, schoolyards and various abandoned
waste piles.
EPA and MDEQ remove asbestos from about 150 properties each year.
Beginning in 1999, EPA started a series of short-term
cleanups called removals to protect human health and
the enviromnent in and around Libby. These efforts
have included soil and debris excavation, attic and yard
cleanups, and building demolition. In 2009, for the first
time in the history of the Agency, EPA declared a Public
Health Emergency in Libby, to provide federal health care
assistance for victims of asbestos-related disease. In 2010,
EPA selected the long-term remedy for the former Export
Plant. Cleanup started in 2011 and finished in August 2012,
removing 25,656 cubic yards of contaminated soil. After a
Throughout all planning and cleanup activities, EPA
Region 8 and MDEQ staff meet regularly with community
stakeholders to share information and updates and to
incorporate community feedback into the Superfund
process. EPA maintains an information center in Libby.
EPA uses various outreach tools, maintains a website
(www.epa.gov/libby) and holds public meetings to keep
the community informed. EPA also provides support to the
Libby Community Advisory Group (C AG), which serves as
a focal point for the exchange of information, and funds a
Technical Assistance Grant (TAG) to allow a local group to
hire independent consultants to review technical documents
and offer input into Agency decisions.
What is Libby Asbestos (LA)?
The venniculite mine near Libby contains a distinct
form of naturally occurring amphibole asbestos.
This form of amphibole asbestos, often called Libby
asbestos, or LA, refers to amphibole materials from the
Libby venniculite deposit that can fonn durable, long
tlun structures. They are generally respirable and can
reasonably be expected to cause disease. Accordingly,
they are the contaminant of concern at the site.
3
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David Thompson
Search and Rescue Building
Pumphouse
,'Areaซ1i- Former Export'Plantl
freaBB Em b an k m ent s*
Downtown
Libby
Legend
tZ23 Area 1 - Former Export Plant I
lorn Area 2 - Riverside Park
EZ2 Area 3 - Embankments
Aerial view of the former Export Plant area during cleanup.

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Project History
Mid-1990s - 2003:
New Beginnings
After Grace transferred ownership of the former Export
Plant area to the City of Libby in the mid-1990s, the
community thought it knew what should happen next.
"The area had been used for industrial purposes for
decades," recalled Libby Mayor Doug Roll. "It made
sense to keep it that way." The City leased some of the
area to a lumberyard. The community continued to use two
ballfields on part of the site. Even after EPA's emergency
response activities began in 1999, Grace's short-term
cleanup actions in 2001 and 2002 focused on making
the area safe for industrial users. The $2 million cleanup
demolished several structures and took away contaminated
soils, backfilling with gravel at the City's request.
More broadly, the community saw the 17-acre area as a
functional space for municipal purposes, according to City
Administrator Jim Hammons. A city service road extended
across the land, connecting to the city's wastewater plant
and an equipment storage facility. The BNSF Railway
rail line and Montana State Route 37 hemmed in the area
to the east and south, with a rail spur located on site. "It
was mostly a mess," said Libby Councilwoman Vicky
Lawrence. "Most of [the former Export Plant area] was
full of weeds and debris, and surrounded by orange hazard
fencing. It was a constant reminder to the community of
the questionable safety of living here."
EPA had been working closely with the community since
1999 on short-term cleanups in and around Libby. In 2003,
the community first began coordinating with EPA regarding
the future use of the former Export Plant area. With the
David Thompson Search and Rescue organization working
on a new facility, the City developed plans for a new boat
ramp on site for its operations. During construction, the
City discovered a 2-inch-thick layer of venniculite along
the boat ramp. EPA led a short-term cleanup to remove
venniculite and contaminated soils, and cover the riverbank
with protective riprap.
"The community has been through so much, from the
urgent health issues to a cleanup that has come into
people's homes, schools and workplaces," said long-time
EPA project manager Rebecca Thomas. "But people have
refused to give up. The gradual reuse of OU1 has been a
bright spot for everyone involved. Early cleanup activities
Aerial view of the area in 2002, after initial cleanup
activities by Grace.
The Export Plant area, 1968.
View of the ballfields at the Export Plant area. Leagues
would sometimes postpone games due to thick clouds of
dust from the loading of boxcars on site.

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like the riverbank work have led to a long and productive
partnership between site agencies and the community."
According to Mayor Roll, the new boat ramp was an
important first step toward the community seeing the former
Export Plant area in a new light. "The ramp led to more traffic
down there, for recreation," he noted. "Outfitters were using
it to take people fishing. People were going out boating." The
City put in picnic tables. A local bank donated money for new
trees. The City, EPA and MDEQ agreed to coordinate as long-
term cleanup plans for the former Export Plant area came
together. The seeds had been planted.
2003 - 2009:
Taking Steps, Developing Plans
Over the next few years, several events spurred further
change in community perspectives. In 2005, a group called
the Community Asbestos Memorial Project met with Libby's
City Council, proposing to build a pavilion next to the river,
as part of a memorial to asbestos victims. "When the pavilion
was built [in 2006], we were reminded that the riverside there
could be a beautiful place," recalled Vicky Lawrence. "It
wasn't just about cleanup orbringing in industry at that point."
A proposal to build a second, much larger community
pavilion next to the river in 2008 met with broad community
support. According to the City, funding for the $250,000
project, led by the local Amish community, came almost
entirely through a loan repayment and community donations
of time and supplies. Prior to its construction, EPA excavated
vermiculite and contaminated soil from the area, enabling
placement of foundation footings and a full concrete slab
for the new pavilion. The community dedicated the Fred
Brown pavilion, named for the long-time mayor of Libby,
in November 2008.
Around the same time, the City of Libby and Lincoln County's
long-term economic development efforts were starting to
pay off after a long period of post-mining economic decline.
As part of a regional economic development strategy, the
localities had been working for several years to transform
the nearby Stimson Lumber Mill into the Kootenai Business
Park Industrial District. Stimson Lumber Company had
donated the property to the Lincoln County Port Authority
after lumber production stopped in 2003. The 400-acre area,
located on the northwest edge of Libby, is also part of the
Libby Asbestos Superfund site.
"By 2008, it was clear the proposed business park was a
much better fit for industrial uses. It was a larger property,
with better access and infrastructure," said Lincoln
County Planning Director Kristin Smith. Plans became
The riverside Community Asbestos Memorial Project
pavilion, built on site in 2006.
The Fred Brown pavilion, built on site in 2008.
reality in 2009 - the industrial district received several
million dollars in state and federal grants and loans, and
a bridge manufacturer agreed to locate there. The park's
development was a major achievement for the community,
representing another milestone on its journey back from
years of economic hardship and environmental tragedy.
As a result, in 2009, the community decided to focus on
turning the entire former Export Plant area into a park.
Following a public meeting with near-unanimous support
for the area's recreational reuse, Libby City Council
commissioned a conceptual plan for a riverfront park.
Working with landscape architect Bruce Lutz during a series
of community meetings, initial interest in maintaining an
industrial presence along the site's rail spur faded. "The
main focus became how to realign the city service road to
maximize park space and connect all of the recreation areas,"
5

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Lutz recalled. In addition to the boat ramp and pavilions,
community priorities included trails, environmental
education, boat and trailer parking, restrooms, a gazebo and
a fishing platform.
" Alot of people had arrived on the same page. They were using
the pavilions and the boat ramp and wanted to see everything
else become a park as well," said Vicky Lawrence. "Now we
were asking new questions. The main one was, 'how are we
going to make this happen?"'
New partnerships and opportunities for collaboration lay
ahead. Over the next two years, the City of Libby would
work closely with EPA and MDEQ to integrate the site's
remedy and reuse.
In 2009, while the riverside area was in reuse, much of
the former Export Plant area remained idle.
Boat Area
-Typical Park Pathway
— Boater's
Picnic Area
Future Road
Connection
Bike/Ped	\
Walkway	\
•••tyluki-purpose Park Area
Boat/Raft
Trailer
Parking
Renovated
Existing
. Scale: 1 "=60' <ฎ 24x36" Sheet Size
Existing Approach Alternative
Riverfront Pgrk
Libby, Montana
G R ~ U R
Revised: 4-20-11
The final conceptual plan for Riverfront Park. The final plan followed almost two years of community review and detailed discussions with EPA and MDEQ.
Pedestrian fnderpass
Re-align City Service Road
Asbestos Memorial Pavilion
& Memorial Garden
Park Restrooms
"t,
Ox
Fishing Platform i ^
Fred Brown
Riverfront Pavilion
Ramp 1
Park Restrooms
Service Lane
Ramp 2

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Timeline of Events
Early 1900s: Vermiculite deposits first discovered near Libby
1919:	Zonolite Company operations begin
1963-1990: Grace acquires and operates the vermiculite mine
1960s-1990: Former Export Plant area used for vermiculite
storage and shipping
1977-1997: Part of the area used for ballfields
1987-2000: Other industrial businesses operate on site, including
lumberyard, metal scrap dealer and larch tree gum
manufacturer
Mid-1990s: Grace transfers ownership of former Export Plant
area to City of Libby
1999-2010: EPA conducts investigations and short-term cleanups
2001-2002: Grace conducts short-term cleanups at former Export
Plant area
Oct. 2002: EPA places site on NPL
2003-2004: City installs new boat ramp, David Thompson Search
and Rescue facility built
2006:	Asbestos memorial pavilion built
2008:	Fred Brown community pavilion built
Mar. 2008: EPA negotiates largest cash settlement in Superfund
history ($250 million) to recover cleanup costs from Grace
2009:	City commissions conceptual plan for Riverfront Park
Jun. 2009: EPA declares Public Health Emergency in Libby
2010:	EPA selects final long-term remedy for former Export
Plant area
2010-2011: Remedy design process integrates remedy and reuse
2011:	EPA releases draft Libby Amphibole asbestos-specific
toxicity values for public comment, review by
Science Advisory Board
Apr. 2011: City finalizes engineered park design
Aug. 2011 - Final cleanup of former Export Plant area
Aug. 2012:
Jul. 2012 - Site restoration, plantings and park preparation activities
Aug. 2013:
Aug. 2013: Riverfront Park ribbon-cutting ceremony
2009-2011:
Working on the Details
By 2009, EPA project managers Rebecca Thomas
and Mike Cirian had been working with the
community on cleanup issues for more than five
years. "Those relationships set the stage for the
work that was to come," recalled Mike Cirian.
"Integrating reuse as part of the area's long-term
remedy was a big next step."
Helping the community understand EPA's
responsibilities was key. Under federal law,
EPA can use Superfund monies only for actions
that are necessary for a protective remedy or to
enhance protectiveness. "Our mission is to protect
human health and the environment," said Rebecca
Thomas. "But we were also looking to incorporate
the community's priorities as part of the cleanup
process."
"EPA and MDEQ were not there to build us a
park," said Vicky Lawrence. "But we also knew
we couldn't afford to go back in afterward to put
in the infrastructure. The City was willing to do
its part, to find ways to fund what we needed to
do."
For its part, EPA faced an additional complexity.
Cleanup criteria for levels of concern and the
basis for those levels are typically included
in site cleanup plans. While the Agency did a
human health risk assessment for the area, LA-
specific toxicity values were not yet available.
"The proposed remedy was fairly straightforward
- removing waste and replacing it with clean
fill," noted EPA project manager Mike Cirian.
"Even without final toxicity values, removing
the contaminated soil and replacing with clean
fill broke the exposure pathway."
The Agency also agreed to conduct a post-
construction risk assessment with activity-based
sampling to show the effectiveness of the remedy.
If the assessment identifies any health risks, EPA
will undertake additional cleanup as needed.
After community and City Council meetings
and outreach activities, EPA issued the Record
of Decision for the former Export Plant area in
May 2010. The document provided the flexibility

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needed for site agencies and the City of Libby to work
together on designing the site's remedy. EPA would:
•	Put in soil covers to contain some areas of surface
contamination.
•	Remove contaminated materials in proposed utility
corridor areas and dispose of them off site.
•	Place a visible marker layer at the bottom of the
cover to show the extent of cleanup.
•	Use clean fill for excavated areas and soil covers
from outside the Libby valley.
EPA also added an additional option to the remedy, retaining
flexibility to remove other areas of contamination as needed
due to land use issues. For example, as the ROD states,
"future land use might include construction of a structure
that would necessitate excavation for a foundation. In that
event, it would be important to have a remedial option that
allows for at-depth removal in selected areas rather than just
in utility corridors." The ROD also included a statement
explicitly recognizing the importance of integrating remedy
and reuse: "EPA will also work closely with the City of
EPA and Reuse
Since the start of the Superfund program, EPA has been building on its expertise in conducting site characterization
and cleanup to make sure contamination is not a barrier to the reuse of property. Today, consideration of future use is
an integral part of EPA's cleanup programs from initial site investigations and remedy selection through to the design,
implementation, and operation and maintenance of a site's remedy.
"At older sites, EPA did not focus on taking reuse considerations into account early in the cleanup process," reflected
EPA's Matthew Mankowski, a former project manager at Superfund sites. "Today, that has changed. Superfund cleanups
can be very creative and flexible in allowing for future site uses, but that information needs to be plugged in early to be
as effective as possible."
At the former Export Plant area, future land use considerations were able to inform EPA Region 8's selection of the
remedy, which enabled the area's reuse for recreational purposes. The integrated cleanup and redevelopment of the area
meant that the City of Libby could coordinate infrastructure installation with the cleanup of the site.
Thanks to lessons learned at Superfund sites across the country, EPA has developed additional tools to ensure an integrated
approach to the cleanup and redevelopment of contaminated lands. For example, EPA has developed a partial deletions
guidance. Partial deletions allow EPA to remove the cleaned and uncontaminated portions of a Superfund site from the
NPL, expediting the reuse of those properties.
EPA also works with site stakeholders to consider how future land use considerations can inform the implementation and long-
term stewardship of site remedies as well as cleanup planning. At some sites, for example, reuse considerations can inform the
location of ground water monitoring wells and other equipment that might inadvertently hinder redevelopment efforts.
Downtown Libby.
Libby during design so that the remedy can complement any
planned future uses."
For detailed cleanup planning to move forward, the
community's conceptual plan for Riverfront Park now needed
to turn into detailed engineering drawings. The City of Libby
issued a Request for Proposals for engineering assistance in fall
2010, and selected a trio of local and regional Anns - WGM
Group, 48 North Engineering and Sitescape Associates - for

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Libby is also known as the "City of Eagles," on account of the eagles who live along the Kootenai River, as well as the avian artwork found
throughout the community.
the job. "The pieces were in place [for the engineering work]
to move quickly," recalled Melissa Matassa-Stone, Project
Manager/Engineer with WGM Group. "The community was
on board with the park plan, and the City had been working
with EPA and MDEQ. We were able to focus quickly on what
was needed - plans for grading, drainage, utility corridors,
access and road design."
From there, a new process began, according to Nick Raines.
Now with Lincoln County, Raines at the time was an engineer
for CDM Smith, EPA's cleanup contractor. "It was a back-and-
forth process," he explained. "Multiple phases of the cleanup
design were key to figuring out exactly how the cleanup and
Riverfront Park plans were going to work together. That
back-and-forth continued right through the cleanup. We were
on site regularly, making minor adjustments to surface water
drainage and other features as needed."
To address specific cleanup and reuse responsibilities, EPA
and the City of Libby reached a cooperative agreement in
early 2011 EPA agreed to reimburse the City $59,600 for
engineering and irrigation costs, planting activities and
road removal. The City agreed to take the lead on all site
infrastructure related to reuse.
To help meet its commitments, the City reached out to a
diverse network of organizations. "The response was
remarkable," said Libby Mayor Doug Roll. "From Lincoln
County to local businesses and community organizations,
everyone stepped up to the plate."
By August 2011, site preparation activities were underway.
Within a year, the site's remedy would be in place. A year
later, after site restoration, the City of Libby officially
dedicated Riverfront Park in August 2013.
City of Libby Responsibilities
EPA Responsibilities
Construction of new sanitary sewer line and all other
utilities.
Site cleanup (capping, excavation and disposal
of contaminated materials, creation of utility
corridors, backfilling with clean fill).
Trees and other plantings for the park.
Site grading and grass seeding.
Road paving and striping.
Road removal, gravel base installation,
boat ramp reconstruction.
Engineering and site irrigation.
Partial funding for the City's engineering,
site irrigation and road paving costs.
All reuse-related infrastructure (street lighting,
restrooms, signage, trails, gazebo, fishing pier).
Stormwater management (detention ponds, swales).
9

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The Former Export Plant Area: The Story in Pictures
ฆ* - —
Site Cleanup (August 2011 — August 2012)
Soil excavation	Road removal
Backfilling and site grading
Revegetation, stormwater management, roadbed installation

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Road and parking lot paving
Riverbank cieanup (before arid after)
Embankment cleanup (before and after)
"The important thing is that EPA didn't have to do this. They could have scrapped 18 inches of soil and left it an
open field. It's so pretty down there and it's a great place for a park. I call it an example of our rebirth in Libby."
- Libby Mayor Doug Roll, July 2012 article in the Flathead Beacon newspaper

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Site Restoration (July 2012 - August 2013)
Community tree plantings
Following cleanup. Riverside Park unofficially opened to the
community in July 2012. Families hosted weddings in the large pavilion.
The community's Riverfront Blues Festival attracted hundreds of
concertgoers. Over the next year, made possible by the City of Libby's
pursuit of grants and donations, the City and its community partners
worked to light the new roadway, install restrooms, put in new picnic
tables and plant trees.
The U.S. Forest Service provided 170 tree seedlings and the
Montana Department of Natural Resources and Conservation
and the Society of American Foresters provided $10,000 in
grant money for purchasing trees.
The Flathead Electric Cooperative's Roundup for Safety
program helped fund roadway lighting.
BNSF Railway, the Plum Creek Foundation and the Libby
Parks Board funded new restroom facilities.
Lincoln County provided equipment and workers, and helped
pave the new roadways, with additional resources provided by
the county's David Thompson Search and Rescue organization.
Community volunteers planted several hundred trees.
In total, the City of Libby estimates that park grants and donations came to
$296,000, covering almost half of the park's $612,000 cost. "Conserving
taxpayer dollars was a priority," noted Libby Councilwoman Vicky
Lawrence. EPA's cleanup, funded by the Agency's 2008 settlement with
Grace, cost $2.6 million.
Project Partners
Local Governments
City of Libby
Lincoln County
Site Agencies
EPA (cleanup lead)
MDEQ (cleanup support)
U S. Army Corps of Engineers (contract
management)
Community Organizations
Amish Community
Avid Gardeners of Libby
Boy Scout Troop #1971
Community Asbestos Memorial Project
Community Volunteers
Girl Scout Troop #3443
Libby Community Advisory Group
Libby Middle School
Libby Park District
Libby Tree Board
Lincoln County Foundation
Lincoln County Veterans Memorial Project
Site Design and Engineering
48 North Engineering
Sitescape Associates
WGM Group
Grant Resources and In-Kind Services
BNSF Railway
David Thompson Search and Rescue
Flathead Electric Cooperative
Montana Department of Natural Resources and
Conservation
Plum Creek Foundation
Society of American Foresters
Strom Electric
U.S. Forest Service
Cleanup Contractors
CDM Smith
Environmental Restoration LLC
Project Resources, Inc.

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The Riverfront Blues Festival,
August 2012
Park boat ramps in use on the
Kootenai River
Riverside Park Dedication (August 2013)
The City of Libby's official dedication of Riverfront Park on August 3, 2013,
brought the community together with all of the project's partners. "Riverfront Park
represents our future," said Libby Mayor Doug Roll. "We look back and recognize
our history, and appreciate our steady recovery from environmental tragedy."
^ivertrnntjuues Festivj
Fred Brown
Riverfront Pavilion
Mayor of Libby Montana 1973 - 1997
Made possible through the generosity of
City of Libby
Libby Park District
TBC Timber
Mark and June McMahon
Mary Johnson In Memory of Jim Johnson
Dick, Tom, Trudie and Topper Wood
The EPA Libby Project Team
Plum Creek Foundation
Lincoln County Foundation
Roundup For Safety

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Conclusions: 2013
Building on the Past, Looking to the Future
Riverfront Park is now a highly valued community
resource. In addition to many unreserved gatherings,
people have rented the large park pavilion several dozen
times over the past year, for occasions as varied as
weddings, class reunions, memorial services and family
celebrations, according to the City of Libby's Utility
Billing Office. The fifth annual Riverfront Blues Festival
in August 2013 brought more than 900 people to Riverfront
Park. "Everything feels well established," said Libby
Councilwoman Vicky Lawrence. "The grass has grown, the
trees are in. It is a beautiful park."
Riverfront Park also remains a work in progress. Future
additions include a veteran's memorial. Trails, more trees,
historical signage, and a pedestrian overpass to connect the
park with downtown Libby are also under consideration. With
the park's new utilities and expanded infrastructure, the City
is optimistic that its location and popularity may also attract
new businesses to the area. "Providing support services to
park visitors makes a lot of sense," said City Administrator
Jim Hammons. "For outfitters, restaurants, breweries, other
businesses. The park makes a big difference in local quality
of life, for our economy as well as recreation."
With so much accomplished over the past decade, the City
of Libby, EPA and MDEQ are now working together to
transition into new roles and responsibilities. "Appropriate
institutional controls are critically important," said EPA
project manager Rebecca Thomas. "They help us prevent
and limit exposure to hazardous materials left in place,
making sure the remedy remains protective over the long
term. The City of Libby has been great to work with on ICs."
The City has put in place a rental agreement required
for users of the Riverfront Park pavilion. It defines how
renters may use the area, limiting usage so as to not
disturb ground that would cause potential exposures to
LA contamination below the protective cap. Any work on
embankment areas requires an Encroachment Permit from
the Montana Department of Transportation. An agreement
with Montana's one-call utility locator service, called
U-Dig, puts EPA in touch with anyone excavating in the
area. EPA's remedial contractor currently fields U-Dig
calls and requests for site information. EPA evaluates and
updates the area's institutional controls annually, and has
Institutional Controls (ICs): A Brief Overview
ICs are legal and administrative tools used to maintain
protection of human health and the environment at sites.
They do not involve construction or physical changes
to a site.
•	ICs play an important role when a cleanup is
conducted and when it is too difficult or too
costly to remove all contamination from a site.
•	ICs are designed to lower the potential for
people and the enviromnent to be exposed to
contamination.
•	There are four types of ICs: govermnent
controls (local laws or permits), proprietary
controls (private property use restrictions),
enforcement tools (consent decrees, unilateral
orders), and informational devices (deed
notices, public advisories).
•	ICs are usually most effective when layered
(i.e., multiple ICs of different types working
together) to improve protectiveness.
•	Seeking community input and involvement
can maximize the effectiveness of ICs.
•	Most cleanups will need to use a combination
of engineered remedies and ICs. ICs provide
an additional level of safety and help to make
sure a site's remedy remains securely in place.
(Information adapted from EPA's Citizen's Guide to
Understanding Institutional Controls)
also provided best management practices for contractors
and tradespeople working in Libby on Region 8's website.
"MDEQ will remain responsible for monitoring and
ensuring the protectiveness of the site's remedy," said
MDEQ project manager Carolyn Rutland. "The community
is carrying forward the responsibility to use Riverfront
Park appropriately." As project partners continue to work
together on the cleanup of the rest of the Libby Asbestos
site. Riverfront Park serves as a shining example of what
is possible. "This park is a symbol of healing for our
community," said Vicky Lawrence. "Libby is a special
place. We are resilient, and we are ready to move on."
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V
The large park pavilion under construction in 2008.
Observations
Participants agree that a combination of significant factors
have contributed to the cleanup of the former Export Plant
area and the successful development of Riverfront Park.
•	The area's size, location and proximity to the
Kootenai River meant it was well suited to
provide multiple recreational amenities.
•	The City of Libby energetically pursued the
site's cleanup and redevelopment over the long
term, putting in place the needed resources,
partnerships and infrastructure.
•	EPA and MDEQ were engaged partners who
understood the community's redevelopment
priorities in the context of the site's cleanup and
restoration, enabling the development of decision
documents that reflected remedy, restoration and
redevelopment considerations.
•	The community enthusiastically supported the
development of Riverfront Park, donating time,
materials and money to make it a reality.
•	Early and sustained coordination of site
plans meant that remediation, restoration and
redevelopment could each move forward as part
of a linked, phased approach.
•	All parties involved were patient and flexible,
recognizing that site cleanup and park planning
was a complex process reliant on seasonal
conditions, available resources, multiple parties
and other factors.
•	EPA selected a remedy that would be consistent with
the area's reasonably anticipated future land uses.
Lessons Learned
While these factors created an ideal climate for the
successful reuse of the former Export Plant area, there are
also a range of broader lessons learned that can help guide
similar projects at contaminated lands across the country.
EPA works with communities, site owners and other
stakeholders to support reuse outcomes that are
compatible with site cleanups.
The Agency places a high priority on supporting the return
of contaminated sites to productive and beneficial uses.
In Libby, the community was able to work with EPA and
MDEQ to develop plans for Riverfront Park that reflected
site conditions and cleanup plans. In turn, the community's
reuse plans were able to inform EPA's selected remedy for
the site.
While EPA provides tools and resources to support
Superfund reuse, communities and public and private
sector organizations make it happen.
EPA'smissionistoprotecthumanhealthandtheenvironment.
EPA relies on engaged community stakeholders to bring
their future land use goals and priorities to the table so that
this information can be incorporated as part of the remedial
process, linking cleanup and redevelopment.
Mining areas include processing facilities and other
infrastructure often located in communities.
While many mines are in remote or rural locations, these
support facilities are often well-wired and well-suited for
a wide range of reuse opportunities, including recreation.
Local governments can play a unique leadership role in
Superfund redevelopment.
As the organizations responsible for their communities' general
welfare, local governments are particularly well positioned to
host redevelopment projects, bring together diverse stakeholders

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to discuss site reuse opportunities, and use planning tools and
incentives to foster positive site outcomes.
Think long term.
It can take many years to remediate contamination that
has accumulated over decades of site activities. However,
this lengthy process also provides a time window for site
stakeholders to build partnerships and identify resources,
coordinate with EPA and state agencies, and develop a
strategy for returning a site to use while protecting future
users. In Libby, short-term cleanups at the former Export
Plant area led to a gradual expansion of recreational
resources and built a strong foundation for the reuse
partnerships and coordination with site agencies needed
over time.
Avoid business as usual. Site characteristics and
community priorities change over time.
The former Export Plant area had been an industrial hub
for decades. However, the area's size, riverside location
and proximity to downtown were also ideal for recreation.
With industrial growth planned for the Kootenai Business
Park Industrial District, the City of Libby headed in a
new direction and found the resources needed to make
Riverfront Park a reality.
Plan for multiple uses as well as reuse.
The City of Libby enhanced infrastructure in the area's
utility corridors to support surrounding land uses as well
as meet the park's needs. "We were thinking long term,"
said Libby Mayor Doug Roll. "We didn't want to have to
dig [the corridors] up in several years' time."
Projects at contaminated lands can be complex
undertakings that require diverse expertise.
The project required significant legal and technical
expertise. The City worked with an attorney with extensive
Superfund experience to provide guidance throughout
the process and relied on a landscape architect and an
engineering group to ensure that plans for Riverfront Park
would be compatible with site conditions and the remedy.
Access site-related information and recognize
opportunities provided by the Superfund program.
Superfund sites are among the most comprehensively
documented and evaluated areas of land in the United
States. At most sites, a completed remedial investigation/
feasibility study, draft proposed plan, or Ready for Reuse
(RfR) Determination will provide interested parties with
extensive site information.
Use a variety of outreach tools to reach different parts
of the community.
EPA and the City of Libby both used websites, social
media, newspaper articles, fact sheets, and other tools to
keep the community updated and engaged. "We learned
that different generations get their information in different
ways," said City Councilwoman Vicky Lawrence. "Older
people might rely on the newspaper or check a website.
Younger folks are big with social media."
Build on past experience.
Today, thanks to the bona fide prospective purchase
(BFPP) provisions of the 2001 Brownfields Revitalization
Act, environmental insurance and EPA tools like RfR
Determinations, established resources are available to
address stigma and other Superfund site issues. Prospective
purchasers can contact EPA site teams to learn more,
or see the Resources section on page 17 for additional
information.
Libby Vision Statement - Libby 2030
"Libby is a safe, healthy, friendly and attractive
community that fosters a sense of belonging and
pride. Libby is committed to advancing commerce,
tourism and recreation, and to supporting high quality
and continuing education...New development and
redevelopment is encouraged in areas where public
services can be provided and the historic and cultural
heritage of the city can be preserved and enhanced. The
integrity of natural and scenic resources are maintained
and enhanced to protect and maintain Libby's high
quality of life..."
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Sources and Resources
Sources
Images and maps for this case study were provided by EPA Region 8, the City of Libby, Lincoln County, CDM Smith, Sitescape
Associates and WGM Group.
Resources
EPA site profile:
cfpub2.epa.gov/supercpad/cursites/csitinfo.ciin?id=0801744
EPA Region 8 Superfund Program and project Web page:
www.epa.gov/region8/superfund and www2.epa. gov/region8/libbv-asbestos
EPA Recommendations for Best Management Practices in Libby:
www2.epa.gov/region8/libbv-communitv-involvement-doeuments
EPA Abandoned Mine Lands Team:
www, epa. gov/aml
City of Libby:
www.citvollibbv.com
Libby Riverfront Blues Festival:
www.riverfrontbluesfestival.com
Lincoln County:
www.lincolncountvmt.us
Montana Department of Environmental Quality, site Web page:
www.deq, mt. gov/libbv
Aerial view of Libby.
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Out of the Dust: Recreational Reuse After Vermiculite Mining
THE LIBBY ASBESTOS SUPERFUND SITE IN LIBBY, MONTANA
&EPA
United States
Environmental Protection
Agency
Office of Superfund Remediation and Technology Innovation (OSRTI)
Abandoned Minelands Team
www.epa.gov/aml
May 2014

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