East Mission Flats Waste Repository
Frequently Asked Questions

September 2009

vvEPA

What is
Covered in this
Fact Sheet?

People are asking questions about the East Mission Flats Repository (EMF),
west of Cataldo, Idaho. Below are some of those questions with answers from
the Environmental Protection Agency (EPA) and the Idaho Department of
Environmental Quality (DEQ).

The design for the repository is final. For a copy of the site's 90% Design
Report, contact Andy Mork, Idaho Department of Environmental Quality, at
208-373-0141, or andv.mork@dea.idaho.gov. Or, find the report's briefer
Executive Summary at: www.basincommission.com or

http://vosemite.epa.aov/R10/CLEANUP.NSF/sites/east mission flats repository

Note from the
Agencies

EPA and DEQ understand why some people have concerns about the EMF
Repository. Some people may not have all the information or facts about what
the agencies are doing. Others may not agree with the agencies' decisions and
actions related to the Superfund cleanup. This fact sheet helps to set the
record straight.

Current Status
of East Mission
Flats

Repository

We, as federal and state environmental agencies, are obligated to make sound
scientific decisions. We are dedicated to our mission to protect public health
and the environment, even if our actions are unpopular. If we are missing
something or have made a technical error, we want to know and will listen to
all comments. However, there are times that we don't agree with the input we
receive and don't feel that we should change our decisions. For all of our
cleanup work, we recognize the importance of explaining our rationale and will
continue to look for ways to improve our public involvement. This fact sheet is
another opportunity for us to share timely information with the public.

What activities are currently underway at EMF?

Site preparation at the EMF repository is under way. The site has been cleared
of vegetation, and a safe, convenient access for vehicles and equipment is
being constructed close to Exit 39. Trees removed from the site have been
donated to the Kellogg School District to fuel the Middle School boiler. Clean
soil, known as structural fill, is being brought in to construct a temporary ramp
for heavy equipment access. Starting in September, primary access to the
repository will be temporarily closed to build the access bridge, which involves
pile driving and bridge-deck placement. The primary access is estimated to be
closed through September.

The site began to receive contaminated residential waste soil in late August.
This soil is being used to build a pad that will support the decontamination
facility. About 14,000 cubic yards will be used to build the pad. The pad needs
to be built now to allow enough time for the material to settle before concrete


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is placed on top of the pad. The settling time is about 4-5 months. Then it will
take another few months for the decontamination facility to be built. With this
timeline, the repository will be fully operational in the 2010 construction
season. Before winter closure in November, soil placed in the EMF repository
will be stabilized to resist winter erosion and spring rain, snowmelt, and
flooding.

Office of
Inspector
General
Review

Complete

What is the status of the Office of Inspector General review?

The EPA Office of Inspector General (OIG) reviewed the agencies' community
involvement work for the repository siting and design. It also reviewed
technical issues related to flooding at EMF. The OIG endorsed the agencies'
community involvement efforts. The OIG also made recommendations for
more technical review of the potential for metals to leach from the repository
during flood events. The agencies did careful and thorough work to respond to
the OIG recommendations, seeking two independent technical reviews. Both
independent reviews concluded that the design was adequate and made no
recommendations for design changes.

On August 12, 2009, the EPA Office of Inspector General (OIG) accepted EPA
Region 10's action plan for the East Mission Flats Repository. The OIG stated
that the "planned corrective actions address the remainder of our concerns."
The plan is to do enhanced monitoring at the repository to address technical
uncertainties identified by the OIG, such as improving the understanding of
moisture conditions within the waste soil mass. The goal of this additional step
is to provide a performance check to see if conditions at the repository are as
anticipated in the design studies. The OIG did not require any changes to the
repository design. The OIG did not request a moratorium on the repository
construction.

Agencies Will
Seek Public
Input on
Enhanced
Monitoring
Plan

Will there be public review of the draft Enhanced Monitoring Plan?

Yes. DEQ will prepare the Enhanced Monitoring Plan with input from EPA and
the public. That input for the plan will incorporate any comments from the
independent Region 10 hydrogeologist who reviewed the repository design
based on the OIG's request. DEQ expects to provide a draft monitoring plan for
public review in October. DEQ will complete the plan for submittal to the OIG
by November 2, 2009.

No Moratorium Why didn't you stop work on the repository until the OIG investigation
Requested by was completed?

OIG	The OIG did not say the East Mission Flats repository location was

inappropriate. They did not recommend that work at EMF stop. The OIG
recommended that an independent technical review be performed to assess the
assumptions and conclusions of the site geochemical and physical conditions
presented in the 90% Design Report. That verification was completed and sent
to the OIG on July 23, 2009. The technical review concluded that the site has
little to no potential for leaching metals to groundwater and that the review
effectively completed the tasks necessary to address the OIG recommendation.
Therefore, EPA and DEQ had full confidence that the OIG concerns could be
addressed while site preparation occurred. The August 12 OIG response
confirmed the agencies' position and approved the corrective action plan to
develop an enhanced monitoring program.

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Will EMF be affected by EPA Headquarters' decisions?

EPA Administrator Jackson received a number of inquiries about the Bunker Hill
Superfund site and, specifically, EMF. Some people asked the Administrator to
review the Region's decision-making, some asked for a moratorium at EMF, and
some expressed support for moving forward with repository construction.

Administrator Jackson asked Mathy Stanislaus, Assistant Administrator for
EPA's Office of Solid Waste and Emergency Response (OSWER), to visit the site
and directly assess the situation. The national Superfund program resides in
OSWER.

Mr. Stanislaus visited the Bunker Hill site on August 18 and 19 to meet with
stakeholders and see the cleanup, including EMF. As part of his review, the
Assistant Administrator may reconsider the work being done at EMF. This could
include stopping development of the repository. As this review is completed,
one of Mr. Stanislaus' main considerations will be to ensure that EPA is fulfilling
its mandate to protect public health and the environment. This includes
assessing the implications of delaying development of EMF. A delay would slow
the residential cleanup and cost contractor jobs, including the new jobs created
with American Recovery and Reinvestment Act (i.e., stimulus) funds. The
Assistant Administrator plans to make his decision soon.

Protecting	Why are the agencies placing a repository at East Mission Flats?

Human Health ^ jS true that, at first take, East Mission Flats does not look like a good place to
put a repository. It floods. It's near a historic landmark in a culturally
significant area. There are wetlands nearby. There is clean groundwater under
the site. Because we share these concerns and have a mandate to protect
human health and the environment, we took great care in selecting this site.
Technical studies show that we can engineer this site to withstand floods,
protect groundwater, and protect nearby wetlands. We coordinate with the
Tribe and the State Historic Preservation Office to ensure sensitivity about
cultural resources. We changed the planned height of the repository so it won't
be easily seen from the Mission.

The agencies are cleaning up properties as part of a Superfund project to
protect the health of people and the environment. Cleanup started over 20
years ago due to a public health crisis. Hundreds of children and families had
elevated blood lead levels. Because of the cleanup, there have been major
reductions in blood lead levels. Part of the cleanup involves disposing of
contaminated materials, mostly from cleanup of residents' yards and
community areas. Repositories are designed and managed to contain those
contaminated materials safely, which reduces exposures for people and
animals. EPA and DEQ searched for other sites for the repository, but East
Mission Flats was found to be the most viable location in the lower Basin.

Repositories make good sense. There is contamination all over the place. The
cleanup primarily consists of scraping up contamination from all over the Coeur
d'Alene River Basin and putting it into repositories. Here, the contaminants are
managed and secured in place. When the repositories are full, they are capped
over with clean material. Repositories reduce the footprint of contamination.
They protect people and wildlife.

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EPA Assistant

Administrator's

Visit


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Location and Will the repository affect the Old Mission or its grounds? Will it be
Appearance of visible?

Repository	The repository is not located at the Old Mission. The repository is located

across Interstate 90, about 0.35 mile away, as measured from the steps of the
Old Mission to the closest point of the repository. The repository footprint is
roughly triangular and covers about 14 acres. No waste will be brought to the
Mission or its grounds. The repository will not be easily visible from the
Mission. In fact, it may not be visible at all. A screen of trees and vegetation
will be in place. The site will be vegetated with a native seed mix as it reaches
full design height, to blend in with the natural surroundings. It will not look like
a cube, a block, or steps.

Criteria Used What criteria were used to select EMF? Are there other more suitable
to Select EMF sites nearby?

Starting in 2002, DEQ and EPA surveyed possible sites in the Coeur d'Alene
Basin for a new repository. The agencies identified a list of over 250 sites in
the Upper and Lower Basin. Many of the sites were found to be unsuitable
because they were in a flood way. A floodway is an active channel for fast-
moving flood waters. Sites were also found to be unsuitable because they were
existing wetlands, or not easy to reach from Interstate 90. These sites were
removed from the list, as were sites in the Upper Basin, which were too far
away to effectively serve the Lower Basin cleanup.

After this first screening, a second more detailed screening was done. This
second screening looked at whether the site was relatively flat; how near the
site was to wetlands; whether the area around the site was previously
contaminated by mine waste; how close the site was to Lower Basin cleanup
areas; how big the site was and how much waste it could hold; whether the site
was outside the floodway; how easy it was to access the site; what were
adjacent land uses; and possible impacts on neighbors.

East Mission Flats remained a potential site after the second screening. The
property owner was willing to sell, and the agencies began studies in 2004 to
find out if the site was suitable for a repository. (See Q&A below on the timing
of public involvement.) The site was purchased by the State in August 2006.
Since then, extensive technical studies have confirmed EMF is a suitable, safe
place to contain contaminated soils. Studies show the area under EMF's
footprint has at least three feet of contaminated soils already. EPA and DEQ
prefer to place contaminated soils in areas already contaminated. No clean
land will be used for this repository.

Consequences
of Delaying a
New Lower
Basin

Repository

What if there was no new repository in the Lower Basin? Or the siting
was delayed?

Residential property cleanup is key to protecting people from exposure to lead
and other harmful contaminants, particularly high-risk groups like young
children. If EPA and DEQ delayed placing a new repository in the Lower Basin
for two or three more years, the Superfund cleanup would have to slow down.
Some workers would be laid off. Fewer yards in the Lower Basin would get
cleaned up. This is because the agencies currently have limited places to put
the waste soils from the cleanups. For example, the existing Big Creek
Repository is being used mainly to take residential waste soils from Upper Basin
communities. Big Creek is the only other Basin Superfund repository, and it's
expected to be filled by mid-summer next year.	

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Siting	Why are DEQ and EPA placing the repository in a floodplain?

Repository in a EPA and DEQ would not build a repository that spreads contamination. EPA and

Floodplain	q^q concluded that the repository can be safely built and managed in this

location. The agencies have done extensive studies and public outreach to get
input. Flood concerns were addressed early in the design. The repository is
being engineered to prevent metals from getting into the groundwater under
the site. The repository is also designed to prevent sediments from eroding
during floods. The sides will be armored. Plus, the soil will be very tightly
compacted so that most water will just run off the sloped repository sides. That
means, even in a flood, the soils in the repository will remain dry except around
the outer edges. Water will not be flowing through the repository picking up
contaminants.

The site is mostly flat and shielded from fast-flowing water during floods. It is
protected by 1-90 to the south, Canyon Road to the north, and the Dredge
Road to the west. During flooding, water will fill the site gradually like a
reservoir, instead of flowing quickly through the site. Erosion controls will help
ensure that materials do not get eroded by rain or snowmelt. For extra
protection, the lower slopes of the repository will be armored with rock or
vegetation to make it stable during floods.

The native soil under the site also reduces the chance of metals leaching. DEQ
studies find the soil can selectively remove metals from water percolating
through the waste soil. This is called "sorption." DEQ expects that piling waste
soil on top of the native soil will not stop this naturally-protective process.

Protecting
Groundwater,
Drinking Water

The groundwater under EMF currently meets safe drinking water
standards. Could the repository contaminate it?

The groundwater currently meets safe drinking water standards and needs to
be protected. Although the water is not being used as a drinking water source,
nearby groundwater is used by residents in the area for drinking water.
Monitoring at EMF will continue, to confirm that groundwater remains clean. If
the groundwater monitoring data indicate that metals are entering groundwater
due to operations at EMF we will find the cause of the problem and make sure it
will not impact drinking water supply wells. Much of the groundwater within
the Bunker Hill Superfund site is very contaminated and cannot be used safely
for drinking water. The agencies are spending lots of resources to clean up
contaminated water and provide safe drinking water to people living in the
area. We would not build a repository that contaminates clean water.

We are confident the underground water will not be contaminated by the
repository. The technical studies indicate that groundwater won't rise up into
the repository soil. As noted above, native soils and engineering features
included in the design will reduce the chance that contaminants will leach into
groundwater. Also, EPA and DEQ's well system monitors EMF groundwater and
will reveal potential problems should they arise.

Repository
Placement -

When did DEQ take comments on whether to site the repository at East
Mission Flats?


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Opportunities
for Public
Input

There were a number of opportunities for public input over the last few years.
In 2005, the agencies prepared a Frequently Asked Questions document and
went door-to-door to discuss East Mission Flats with some people living close to
EMF. Also in 2005, the agencies held a public meeting about East Mission Flats
at the Mission. The Autumn 2005 edition of the EPA newsletter, the Basin
Bulletin, solicited ideas for repository locations. In 2006, another public
meeting was held at Canyon School about East Mission Flats. After making
several presentations to the Basin Commission and its committees, DEQ
purchased the site in August 2006. In 2007, the public raised many questions
and concerns. The agencies held more community meetings, hosted a site
tour, gave presentations, mailed updates, made media announcements, and
participated in other outreach efforts. To provide the public an opportunity to
give input on the repository design, DEQ made the 30% and 60% Design
Reports available to the public. Written responses to public input on the 30%
and 60% Design Reports were issued in September 2007 and October 2008,
respectively.

The OIG endorsed the agencies' public involvement efforts. At the same time,
some citizens do not believe they were adequately informed nor had enough
chance to comment on the site selection. Not everyone got a knock on the
door, or received a mailing, or read the papers, or attended a meeting. The
agencies are listening. We believe we could have done a better job, and are
working hard to improve our communications.

Repository
Shape and Size

Cultural
Resources

How much waste will go into the repository?

The repository will cover about 14 acres of the 23-acre property. It is about
650 feet long on the northwest side, 1,650 feet long on the southwest side, and
1,350 feet long on the northeast side. EPA and DEQ estimate that, when full,
the repository will hold about 445,000 cubic yards (cy) of material. Of the
445,000 cy of material, 30,000 cy will be the clean cover.

How are DEQ and EPA addressing concerns about protecting sacred
cultural resources?

Protecting sacred cultural resources is very important to both EPA and DEQ.
The agencies recognize the historic importance of this area. To date, DEQ has
consulted with the Coeur d'Alene Tribe, State Historic Preservation Office
(SHPO), and local sources about the site's cultural significance. An
archaeological evaluation was completed for the site under the National Historic
Preservation Act. The evaluation did not turn up any artifacts in the repository
area. SHPO approved the project, with the condition that an archaeological
expert will monitor excavation activities described in the evaluation. If the
archaeologist detects the presence of cultural resources, work will be halted
until a thorough evaluation can be done.

Protecting
People and
Wildlife

Will the repository pose a risk to people and wildlife when it's finished?

DEQ and EPA have carefully engineered the repository to reduce the risk to
people and wildlife. Similar to the residential cleanup, the risks will not be
completely eliminated because wastes will remain in place. However, the site
will be capped with clean soil and re-vegetated to offer a clean and safe surface
for wildlife. The contents will be stable and monitored by DEQ for the long	


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term, which is required by Superfund law when contaminants remain in place.
Moreover, the risk to the health of people and wildlife is greatly reduced when
contaminated soils are removed from the places people live and put in secure
repositories.

Dust Controls What will be done to keep dust from blowing off the repository?

DEQ will monitor dust levels at the repository. When EMF is active, the interior
roads will be watered or treated to control dust. Measures also will be taken to
ensure that dust does not blow off work vehicles carrying materials to the site.
During the inactive portion of the year, the exposed soil surfaces will be
stabilized to prevent wind and water erosion and creating a dust hazard. After
the repository is full, it will be covered with clean soil and reseeded with a
native seed mix to minimize the chance for wind erosion. DEQ will monitor the
site long after the site is full to ensure that contaminated materials placed in
the repository stay in the repository.

Dust is common in this area due to large areas of bare ground west of the
Dredge Road where people commonly drive recreational vehicles. The property
west of Dredge Road is not owned by EPA or DEQ, but has "No Trespassing"
and "Health Warning" signs, posted by the property owner. If dust from the
property west of Dredge Road is a problem, the public is encouraged to contact
the Panhandle Health District at 208-783-0707.

Wetlands	Will the repository harm wetlands?

No. The repository design has been adjusted to protect the nearby wetlands.
At first, the property owner had offered to sell 90 acres. DEQ eventually
purchased a total of 23 in two parcels after studying where the wetlands are
and how they might be affected. The study was used to develop a repository
"footprint" which will not fill in any designated wetlands.

EMF, like the other repositories, will be closely managed to keep contaminated
soil out of waterways. Soil placed on the repository will be compacted to make
it hard for water to wash it off the repository. The side slopes of EMF will be
sloped to prevent erosion. Water channels on EMF will be lined with clean rock
to prevent contact with the underlying contaminated soil. Silt fences and other
erosion controls will be placed around the disturbed ground to catch fine
material in water running off the repository. There will be regular inspections
and maintenance to check up on these erosion control measures. If any part of
EMF is found to be eroding, the erosion will be stopped.

Site Studies Are all the required studies for this site complete?

Yes. All technical and administrative analyses are now complete, with the
exception of the enhanced monitoring plan, described above, being completed
as part of the agencies' corrective action plan. The public will have an
opportunity to give input on the monitoring plan. The plan will improve the
agencies' understanding of the site's vertical groundwater gradients and
monitor moisture conditions inside the repository. DEQ expects the plan to be
completed by November 2, 2009.

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Protecting	Will heavy trucks carrying materials to the repository tear up the local

Roads	roads and the old Highway 10 bridge?

No. The contractors hired by DEQ for the yard cleanup program will not be
allowed to use the Old Cataldo Bridge on Canyon Road for heavy loads. All
contractors hauling materials to the site are required to comply with highway
weight limits. All work will be performed in coordination with the Institutional
Controls Program as described in the Record of Decision.

The trucks operated by the DEQ yard cleanup contractors will continue to meet
local weight and speed limit restrictions. The trucks are owned by local
contractors that pay the Idaho State fuel tax when purchasing fuel, just the
same as other heavy trucks, such as those involved in construction, logging and
mining activities.

A new bridge is being built at Exit 39 this summer to minimize truck traffic on
Dredge Road and Canyon Road. Once bridge construction is complete, the
majority of heavy truck traffic will enter the EMF site on the southwest side,
immediately off 1-90 Exit 39. However, some limited truck traffic on Canyon
Road and Dredge Road will be necessary when cleanup starts on properties
near Tamarack Ridge Road, South River Road, and several other smaller source
areas.

DEQ and EPA do not control traffic patterns of individual ICP users. Although
highway signs will direct ICP users to Exit 39, undoubtedly some ICP users will
cross the Old Bridge.

Get Involved How can I become more involved in the cleanup?

You are invited to participate in the Citizens Coordinating Council, or CCC. The
CCC is a forum for citizens interested in the Coeur d'Alene Basin Superfund
cleanup project. You can learn about issues, share your concerns and
comments, and provide advice to the Basin Environmental Improvement
Project Commission. To learn more, contact Jerry Boyd, CCC Chair, at 509-
455-6000 or go to www.basincommission.com/ccc.asp

More

Information

Where can I find out more about the cleanup?

In addition to the CCC discussed above, we encourage you to sign up to get
EPA's free Basin Bulletin. This newsletter provides regular updates on cleanup
activities in the Basin and opportunities to get involved. To be added to the
mailing list, contact Andrea Lindsay or Debra Sherbina (contact information
below). Information is also available at the listed websites and at local
libraries. For more information, contact Terry Harwood, Basin Commission
Executive Director, at terrv.harwood@dea.idaho.gov or 208-783-2528.

Contacts

Andy Mork, DEQ Project Manager
208-373-0141 or
andv.mork@dea.idahol.gov

Ed Moreen, EPA Project Manager
208-664-4588 or moreen.ed@epa.oov


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Tina Elayer, DEQ Community
Involvement Coordinator
208-373-0563 or

tina.elaver@dea.idaho.aov	

Andrea Lindsay, EPA Community
Involvement Coordinator
206-553-1896 or 800-424-4372, xl896
lindsav.andrea@eDa.aov

Debra Sherbina, EPA Community
Involvement Coordinator
206-553-0247 or 800-424-4372, 0247
sherbina .debra@eDa.gov

Websites for Basin Environmental Improvement Project Commission:

Documents	www.basincommission.com

and

Information U.S. Environmental Protection Agency:

http://yosemite.epa.gov/R10/CLEANUP.NSF/sites/east_mission_flats_repository
Alternative formats are available. For reasonable accommodation, please call Debra
Sherbina. TTY users, call the Federal Relay Service at 800-877-8339.

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