After reading long-awaited federal reports on the Smurfit-Stone Mill Site, Missoula County leaders are concerned that insufficient sampling now could mean less cleanup in the future.
On Tuesday afternoon, the Missoula County Commission and employees met with representatives of the Environmental Protection Agency and the Montana Department of Environmental Quality to raise questions about two recently published EPA documents on the Smurfit site.
One report is the Baseline Ecological Risk Assessment for two of the three regions on the site where industrial activities took place before the mill closed in 2009, and where the waste settling ponds and dumps were located. An assessment for the surrounding agricultural lands was published in 2017.
According to EPA documents, an ecological risk assessment is supposed to be an evaluation of the likelihood that chemicals on the site could affect the environment. EPA managers then use the assessment to help decide what cleanup actions are required.
The other report is an addendum to the plan to monitor possible contaminants in the groundwater below the site. Because groundwater can seep into the Clark Fork River or possibly create well problems later, such information is important.
Missoula County hydrogeologist Elena Evans said she’s been discussing the reports with EPA project manager Allie Archer but hasn’t been comfortable with Archer’s response.
“We’re about to turn a corner in the process. We have a lot of concerns about the baseline ecological risk assessment, and essentially, those still haven’t really been addressed,” Evans said. “We’ve continually commented that we want more sampling and that composite sampling across the site with this degree of complexity on the site inherently underestimates risk.”
Evans said the EPA published the groundwater sampling plan addendum this fall with no opportunity to provide public comment. The EPA is pulling back sampling frequency to once a year in the fall.
Archer said the EPA is comfortable that the sampling it has carried out is sufficient to inform what the EPA and the landowners – the potentially responsible parties – will need to do to clean up the site.
Archer re-emphasized that the EPA is only required to do enough cleanup to deal with elevated risk from chemicals, and that risk is measured at the community level and is not intended to protect every individual.
Commissioner Dave Strohmaier voiced concern about 55-gallon drums of chemicals buried in the dumps. They might not be leaking now, but if they start, a hot spot could develop, Strohmaier said.
But because it isn’t reflected in the EPA sampling, it wouldn’t be cleaned up.
“Based on how risk is being defined, if there’s low risk, could we still come out with an option that would say ‘remove all the material in the dump’?” Strohmaier said. “It’s that disconnect between what we’d like to see – get the doggone dump completely cleaned up – versus what’s being detected in the testing.”
Archer encouraged the county to wait until the EPA publishes the remedial investigation report and feasibility study – which will take at least another year, according to the project schedule. At that time, she said, the county and others can comment if they feel the remedial actions don’t go far enough.
“We don’t have site-specific cleanup levels developed yet,” Archer said. “If we decide somewhere on site is posing excess risk or is causing potential exposure now or in the future, then we can go in and delineate an area by collecting more discrete samples.”
To fill in the data gaps in the EPA sampling, Montana Resources Damage Program is proposing four additional studies to look at how far downstream contaminants have spread in the Clark Fork River.
Evans said the potential responsible parties don’t have to pay for the studies now, but could be required to pay after the fact. She suggested that the county commissioners write a letter of support for the studies.
“My hope would be that our community concern and strong interest in this might help get this done,” Evans said. “I think it would also be great if this understanding would be incorporated into the EPA risk side of things.”
However, the county is also concerned about the stability of the earthen berms that separate the mill site from the Clark Fork River.
In 2018, the spring runoff in the Clark Fork River flooded parts of Missoula and threatened to scour away segments of the berm. The high water caused groundwater to percolate to the surface in several locations.
Concerned, the county recently paid for river channel mitigation modeling that showed the river poses a threat to the site where several side channels and oxbows once crisscrossed the floodplain.
Missoula County environmental health specialist Todd Seib wondered what would happen if the mill site flooded after an EPA operation where the cleanup was insufficient. Would floodwaters expose more contaminants and wash them into the Clark Fork River?
“The flood piece really sets the stage in the risk assessments, because if there’s no risk identified, there’s no need (for the EPA) to clean it up,” Seib said. “Both risk assessments state at the beginning that those berms provide flood protection. That’s a really misleading and untrue statement.”
Archer said she wasn’t going to comment about the berms, because they’ll be dealt with later in the EPA process with the remedial investigation. But if the berms were to blow out, the EPA has a contingency team that would take over.
“We’re not going to decide in a risk assessment to remove them. This isn’t the point where we say they must be removed,” Archer said. “They also don’t rise to the level of an EPA removal action either – there’s not an imminent threat to human health or the environment because of the berms. I think where it’s tough right now is I can’t give you the answer you want to hear.”
Contact reporter Laura Lundquist at firstname.lastname@example.org.