Voicing frustration and lacking options, Missoula County on Thursday sent a letter to the U.S. Environmental Protection Agency, the state's congressional delegation and the governor, citing concerns over the lack of progress and adequate testing at the former Smurfit-Stone Container Mill.

After what's proven to be a protracted process that has taken years, the county remains concerned that the risk to human and ecological health has not been adequately addressed in the EPA's assessment of former pulp and paper mill.

“That risk assessment has to be completed before the remedial investigation is finalized and you can move on to discussing the feasibility studies and what the options are for remedy,” said Travis Ross. “It's a critical point where these risk assessments will define what the actual risk on the ground is to ecological receptors and to humans.”

Ross, an environmental health specialist with the county, cited four lingering concerns over the EPA's current risk assessment, which covers much of the abandoned site, including the former industrial core, the sludge ponds and the Clark Fork River floodplain.

The county believes the EPA's approach to testing, which involved a grid, doesn't work in evaluating the true level of contamination since the system results in averages. The county also said the risk assessment failed to consider the river's channel migration.

“One risk that still hasn't been addressed despite repeated correspondence is the risk of channel movement, with the Clark Fork reoccupying the site, which it did in 1955,” Ross said.

The county reiterated that concern in its letter to the EPA, saying that “the berms surrounding the Smurfit Stone site are masking a huge liability and risk to the ecosystem and to people. Catastrophic failure is a real threat, and that risk should be evaluated.”

The county also believes the EPA failed to include the results of a 2018 study on tissue samples taken from fish downstream of the mill to Noxon. After those tests, the state deemed the fish unsafe for human consumption.

Add it up and the county feels the EPA is not in a position to offer a true risk assessment. But it's also concerned that by requesting more data, the process will continue to drag on, perhaps lasting several more years.

However, commissioners believe more data and more time may be the best approach.

“If the future cleanup is going to be based on what the risks actually are, it's super important that we get these details right, even if it takes longer,” said Commissioner Josh Slotnick. “Then we'll get the cleanup that actually gets things cleaned up. If we work off inaccurate data, we'll get an incomplete cleanup. The delay would actually be worth it.”

Ross agrees with commissioners.

“The site is complicated enough and has discharged so much over so many years, it's difficult to assess the risks, and to feel confident that the risks are assessed in such a way that they're going to lead to cleanup,” he said.