SECOND FIVE-YEAR REVIEW REPORT FOR

LIBBY ASBESTOS SUPERFUND SITE LINCOLN COUNTY, MONTANA

Prepared by

U.S. Environmental Protection Agency Region 8

Denver, Colorado

--------------------------------- ----------------------------------- Betsy Smidinger Date Director Superfund and Emergency Management Division

2

Table of Contents LIST OF ABBREVIATIONS AND ACRONYMS ...................................................................................................4 I. INTRODUCTION...................................................................................................................................................5

Site Background .....................................................................................................................................................5 FIVE-YEAR REVIEW SUMMARY FORM ......................................................................................................10

II. RESPONSE ACTION SUMMARY ....................................................................................................................10 Basis for Taking Action .......................................................................................................................................10 Response Actions .................................................................................................................................................11 Status of Implementation .....................................................................................................................................17 Systems Operations/Operation and Maintenance (O&M .....................................................................................23

III. PROGRESS SINCE THE PREVIOUS REVIEW ..............................................................................................25 IV. FIVE-YEAR REVIEW PROCESS ....................................................................................................................25

Community Notification, Community Involvement and Site Interviews ............................................................25 Data Review .........................................................................................................................................................26 Site Inspection ......................................................................................................................................................26

V. TECHNICAL ASSESSMENT ............................................................................................................................27 QUESTION A: Is the remedy functioning as intended by the decision documents? .........................................27 QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels and RAOs used at the time of the remedy selection still valid? .................................................................................................................................28 QUESTION C: Has any other information come to light that could call into question the protectiveness of the remedy? ................................................................................................................................................................28

VI. ISSUES/RECOMMENDATIONS .....................................................................................................................29 OTHER FINDINGS .............................................................................................................................................29

VII. PROTECTIVENESS STATEMENT ................................................................................................................29 VIII. NEXT REVIEW ..............................................................................................................................................30 APPENDIX A – REFERENCE LIST ................................................................................................................... A-1 APPENDIX B – SITE CHRONOLOGY ...............................................................................................................B-1 APPENDIX C – SITE MAPS ................................................................................................................................C-1 APPENDIX D – PRESS NOTICE ........................................................................................................................ D-1 APPENDIX E – INTERVIEW FORMS ................................................................................................................ E-1 APPENDIX F – SITE INSPECTION CHECKLISTS ........................................................................................... F-1 APPENDIX G – SITE INSPECTION PHOTOS .................................................................................................. G-1 APPENDIX H – REMEDIAL GOALS AND CLEANUP CRITERIA ................................................................ H-1 APPENDIX I – EXPANDED SITE BACKGROUND ........................................................................................... I-1

Tables Table 1: OU Descriptions ...........................................................................................................................................5 Table 2: OU Historical and Current Use and Reuse Status ........................................................................................8 Table 3: OU4 and OU7 Property Status Summary ...................................................................................................18 Table 4: Summary of Planned and/or Implemented Institutional Controls (ICs) .....................................................22 Table 5: Protectiveness Determinations/Statements from the 2015 FYR Report ....................................................25

3

Table B-1: Site Chronology ....................................................................................................................................B-1 Table H-1: LA RALs for Contaminated Surface Soil, by Land-Use Type and Use Frequency............................ H-1 Table H-2: LA RALs for Contaminated Building Materials, by Accessibility ..................................................... H-1 Table H-3: LA Remedial Clearance Criteria for Subsurface Soil, by Land-Use Type ......................................... H-1 Table H-4: LA Remedial Clearance Criteria for Contaminated Building Material .............................................. H-2 Table I-1: Summary of Response Action Removals at OU1 ................................................................................... I-2 Table I-2: Summary of Response Action Removals at OU2 ................................................................................... I-3 Table I-3: Summary of Investigations and Removal Activities at OUs 4, 5, 6, 7 and 8 ......................................... I-5

Figures Figure 1: Site Vicinity Map ........................................................................................................................................7 Figure 2: OU Map ......................................................................................................................................................9 Figure 3: Removal and Remedial Activities 1999 - 2015 .......................................................................................12 Figure C-1: OU1 Site Map .....................................................................................................................................C-1 Figure C-2: OU1 Areas 1, 2, 3 ...............................................................................................................................C-2 Figure C-3: OU1 Locations of Residual Contamination ........................................................................................C-3 Figure C-4: OU1 Remedial Components ...............................................................................................................C-4 Figure C-5: OU2 Site Map .....................................................................................................................................C-5 Figure C-6: OU2 Site Layout .................................................................................................................................C-6 Figure C-7: OU2 Remedy Components .................................................................................................................C-7 Figure C-8: OU2 Locations of Residual Contamination ........................................................................................C-8 Figure C-9: OU4 Geographic Removal Zone (GRZ) Areas and Removal Zones ..................................................C-9 Figure C-10: OU5 Ownership and Land Use ....................................................................................................... C-28 Figure C-11: OU5 Surface Soil LA and Visible Vermiculite Areas .................................................................... C-29 Figure C-12: OU5 Subsurface Soil LA and Visible Vermiculite Areas ............................................................... C-30 Figure C-13: OU5 Subsurface Soil LA and Visible Vermiculite Insets ............................................................... C-31 Figure C-14: OU6 Response Action Zones and LA in Surface Soil at BNSF Libby Railroad ............................ C-32 Figure C-15: OU6 LA and Visible Vermiculite in Surface Soil with Right-of-Way ........................................... C-33 Figure C-16: OU7 GRZ Areas and Removal Zones ............................................................................................. C-34 Figure C-17: OU8 LA in Surface Soil .................................................................................................................. C-35 Figure C-18: OU8 Visible Vermiculite in Surface Soil ....................................................................................... C-36

4

LIST OF ABBREVIATIONS AND ACRONYMS ABS Activity-Based Sampling ACM Asbestos-Containing Material AHERA Asbestos Hazard Emergency Response Act ARP Asbestos Resource Program bgs below ground surface BOH Board of Health BNSF Burlington Northern Santa Fe CBM Contaminated Building Material CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations CIC Community Involvement Coordinator COC Contaminant of Concern cy cubic yards EPA United States Environmental Protection Agency ESD Explanation of Significant Differences FS Feasibility Study FYR Five-Year Review GRZ Geographic Removal Zone HHRA Human Health Risk Assessment HI Hazard Index HQ Hazard Quotient IC Institutional Control ICIAP Institutional Control Implementation Assurance Plan LA Libby Amphibole LCPA Lincoln County Port Authority MCA Montana Code Annotated MDEQ Montana Department of Environmental Quality MDT Montana Department of Transportation NCP National Contingency Plan NOEC Notice of Environmental Condition NOPEC Notice of Potential Environmental Condition NPL National Priorities List O&F Operational and Functional O&M Operation and Maintenance OU Operable Unit PEN Property Evaluation Notification PRP Potentially Responsible Party RAL Remedial Action Limit RAO Remedial Action Objective RAWP Response Action Work Plan RI Remedial Investigation ROD Record of Decision ROW Right-of-Way RPM Remedial Project Manager s/cc structures per cubic centimeters TEM Transmission Electron Microscopy USACE United States Army Corps of Engineers UU/UE Unlimited Use/Unrestricted Exposure

5

I. INTRODUCTION The purpose of a five-year review (FYR) is to evaluate the implementation and performance of a remedy to determine if the remedy is and will continue to be protective of human health and the environment. The methods, findings and conclusions of reviews are documented in FYR reports such as this one. In addition, FYR reports identify issues found during the review, if any, and document recommendations to address them. The U.S. Environmental Protection Agency (EPA) is preparing this FYR pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section 121, consistent with the National Contingency Plan (NCP) (40 Code of Federal Regulations (CFR) Section 300.430(f)(4)(ii)), and considering EPA policy. This is the second FYR for the Libby Asbestos Superfund site (the Site). The triggering action for this statutory review is the completion date of the previous FYR. The FYR has been prepared because hazardous substances, pollutants or contaminants remain at the Site above levels that allow for unlimited use and unrestricted exposure (UU/UE). The Site consists of eight operable units (OUs) (Table 1). This FYR addresses seven of the eight OUs . The FYR does not address OU3 as a Record of Decision (ROD) has not been issued and remedy construction has not yet started. Table 1: OU Descriptions

OU Description

1 Former Export Plant 2 Former Screening Plant 3 Former Libby Vermiculite Mine (the mine) 4 Libby Residential/Commercial Area 5 Former Stimson Lumber Company 6 Burlington Northern Santa Fe (BNSF) Railroad 7 Town of Troy Residential/Commercial Area 8 Roadways

EPA remedial project managers (RPMs) Dania Zinner and Mike Cirian led the FYR. Participants included EPA Community Involvement Coordinators (CICs) Katherine Jenkins and Beth Archer, Montana Department of Environmental Quality (MDEQ) project managers Lisa Dewitt and Jason Rappe, and Ryan Burdge and Alison Cattani from EPA FYR support contractor Skeo. The review began on 7/25/2019.

The cleanups at OUs 1, 2, 4, 5, 6, 7 and 8 of the Libby Asbestos Superfund site are currently protective of human health and the environment. Institutional controls in the form of U-Dig and the Board of Health Asbestos Resource Program have been implemented and apply to all OUs. Encroachment permits are also in place in OU8. Additional institutional controls have also been implemented for OU4, OU7 and OU8. To ensure long-term protectiveness, the remaining institutional control at OU5 should be finalized.

Site Background The Site is in and around the city of Libby and the nearby town of Troy in northwest Montana, 35 miles east of Idaho and 65 miles south of Canada (Figure 1). The Site lies in a valley carved by the Kootenai River. Gold miners discovered vermiculite in Libby in 1881. In the 1920s, the Zonolite Company formed and began mining the vermiculite in a large, open-pit mine located about five miles northeast of Libby. In 1963, W.R. Grace bought the Zonolite mining operations. The mine closed in 1990. While in operation, the Libby mine (OU3) produced up to 80% of the world’s supply of vermiculite. Vermiculite

6

has been used in building insulation and as a soil conditioner. The vermiculite from the Libby mine was contaminated with a toxic and highly friable form of asbestos called Libby Amphibole asbestos (LA). Historic mining, milling, and processing of vermiculite at the Site are known to have caused releases of vermiculite and LA to the environment, the city of Libby and the town of Troy. In addition, vermiculite products and wastes containing LA were used in thousands of homes, businesses and public buildings across the Site. Vermiculite insulation, both commercially purchased and obtained otherwise, was used at a high rate in Libby buildings. Libby, the county seat for Lincoln County, Montana, has a population of approximately 2,700. Troy, located 20 miles west of Libby, has a population of about 950. Areas of the Site outside the towns are generally lightly-populated, mountainous woodlands. The Site is divided into eight OUs shown in Figure 2 and described in Table 1. From 1963 to 1990, W.R. Grace used the former riverside Export Plant (OU1) for exfoliating, stockpiling and distributing vermiculate concentrate. Concentrated ore was then transported downstream to the Screening Plant (OU2). At the Screening Plant, vermiculite ore was sorted by size and loaded for transport by rail or truck to processing facilities in Libby and nationwide. Within the Libby processing plants, located within OU1 and OU5, ore was exfoliated by rapid heating and then sent to market on the Burlington Northern Santa Fe (BNSF) railway or on the roadways and highways (OU6 and OU8, respectively). Over the course of W.R. Grace's operation in Libby, nearly 10 billion pounds of vermiculite were shipped from Libby. LA-containing vermiculite was used in homes, businesses and public properties in the city of Libby (OU4) and the town of Troy (OU7) as insulation and soil and concrete additives, and it was also unintentionally transported via mine workers on clothing and cars into businesses and homes in OU4 and OU7. More detailed maps for each OU are provided in Appendix C. Appendix I provides a more comprehensive description of each of the OUs. Table 2 provides a brief description of each OU’s remedy and current status.

7

Figure 1: Site Vicinity Map

Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informational purposes only regarding EPA’s response actions at the Site.

8

Table 2: OU Historical and Current Use and Reuse Status Operable Unit Historical Use Current Use/Reuse Status

OU1 Former Export Plant, consists of three areas: Area 1, Former Export Plant; Area 2, Riverfront Park; and Area 3, Highway 37 Embankments

Riverfront Park and David Thompson Search and Rescue.

OU2 Former Screening Plant, consists of four subareas: Subarea 1, Former Screening Plant; Subarea 2, Flyway property; Subarea 3, Private Property; and Subarea 4, Rainy Creek Road Frontage

Riverside property and an undeveloped parcel owned by the Kootenai Development Corporation.

OU3 Property in and around the former mine impacted by LA asbestos

Not currently in use. Remedial investigation completed in 2016. Feasibility study is in progress.

OU4 Residential, commercial, industrial (not associated with former W.R. Grace operations) and public properties, including schools and parks in and around Libby, or those areas that have received material from the mine not associated with W.R. Grace operations.

Continued use as residential, commercial, industrial and public properties.

OU5 Former Stimson Lumber Company property owned and managed by the Lincoln County Port Authority.

The area is currently occupied by various vacant buildings as well as several operating businesses.

OU6 BNSF railroad, including 42 miles of rail line, rights-of-way and rail yards.

Continued use as a railroad.

OU7 All residential, commercial and public properties in and around the city of Troy, Montana.

Continued use as residential, commercial, and public properties.

OU8 United States and Montana state highway transportation corridors, including 30 miles of U.S. Highway 2, Montana Highway 37, and Farm to Market and River Roads.

Continued use as roadways.

Appendix A provides a list of documents reviewed as part of this FYR Report. Appendix B provides a chronology of site-related activities.

9

Figure 2: OU Map

Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informational purposes only regarding EPA’s response actions at the Sit

10

FIVE-YEAR REVIEW SUMMARY FORM

II. RESPONSE ACTION SUMMARY Basis for Taking Action LA is the only contaminant of concern (COC) at the Site. During remedial investigations, LA was observed in all media sampled: air (indoor, outdoor ambient and outdoor near disturbed soil), vermiculite insulation and bulk materials, indoor dust, soil (surface and subsurface), water, and tree bark and tissue. A sitewide human health risk assessment was conducted in 2015. The primary exposure route of concern for LA is inhalation. The exposure scenarios are different for each OU but generally include: residential or commercial exposure via disturbance of surface or subsurface soils with LA contamation or indoor exposure during active source disturbance activities, outdoor worker exposures during disturbance of subsurface soils with LA contamination and forest worker or firefighter exposure near the mine (OU3). Several individual exposure scenarios do not result in unacceptable risk but they have the potential to be important contributors to cumulative risk.

SITE IDENTIFICATION

Site Name: Libby Asbestos Site

EPA ID: MT0009083840

Region: 8 State: Montana City/County: Libby/Lincoln

SITE STATUS

NPL Status: Final

Multiple OUs? Yes

Has the Site achieved construction completion? No

REVIEW STATUS

Lead agency: EPA

Author name: Dania Zinner with contractor support provided by Skeo

Author affiliation: EPA Region 8 and Skeo

Review period: 7/25/2019 – 6/22/2020

Date of site inspection: 8/22/2019

Type of review: Statutory

Review number: 2

Triggering action date: 6/22/2015

Due date (five years after triggering action date): 6/22/2020

11

Following completion of the OU1 remedial action, the EPA conducted a post-construction risk assessment of OU1. The resulting cancer and non-cancer risks were less than a level of potential concern for city workers, recreational visitors, and search and rescue workers/volunteers at the David Thompson Search and Rescue building. Following completion of the OU2 remedial action, EPA conducted a post-construction risk assessment of OU2. The resulting cancer and non-cancer risks were less than a level of potential concern for both Montana Department of Transportation (MDT) workers and recreational visitors and trespassers. In 2015, the EPA conducted an HHRA for OU4 and OU7. The risk assessment showed that all past removals remain protective. The Lincoln County Port Authority (LCPA/the Port) owns a majority of OU5 and its continued use will be for industrial and commercial purposes. As shown in Figure C-10 in Appendix C, areas within OU5 that are owned by entities other than LCPA include the motocross track owned by the Millpond Motocross Association, the property owned by the International Paper Company, and an electrical substation owned by the Flathead Electric Cooperative. Some commercial entities currently operate within OU5; these business operations have been evaluated against the exposure scenarios presented in the sitewide HHRA. The soil exposure scenario at these businesses is most consistent with the OU5 (industrial) outdoor worker soil exposure scenario in the HHRA given the minimal soil disturbance associated with these business operations. All buildings have been evaluated or remediated to the RAL for interior exposure. The commercial entities within OU5 are therefore compared to the RAL for interior exposure inside these buildings and the industrial RAL for soil exposure outside these buildings. Should land use change in the future, soil exposures associated with a more conservative (i.e., commercial) exposure scenario will be reevaluated and any changes documented as appropriate. In addition, areas of OU5 will continue to be used for some limited recreational uses as they relate to exposure scenarios (e.g., fishing pond, motocross track, walking path), which are included in the parks/schools land-use category. Response Actions In response to local concerns and news articles, an EPA Response Team conducted an initial investigation in November 1999. This initial investigation consisted of inspection of the mine and processing facilities; interviews with local officials and some members of impacted families; an interview with a pulmonologist in Spokane, Washington, who specializes in the treatment of asbestos-related diseases; and collection of a small set of environmental samples. The initial investigation revealed many asbestos-related diseases centered in and around Libby. In 1999, a pulmonologist in Spokane was treating more than 200 cases of asbestos-related diseases among people who had either lived in Libby or worked at the mine and had provided care to dozens more who had already died. The EPA’s first priority at Libby was to reduce risk as quickly as possible. Beginning in 1999, early removal activities focused on understanding the sources of contamination and removing those source areas that presented the highest potential risk. These actions are discussed below. In 1999, the EPA opened the EPA Information Center in Libby. In 2002, to support the removal actions, a special cell was constructed in the Libby Class II Landfill for disposal of asbestos waste. In 2002, the EPA also began the Human Health Risk Assessment process, initiated sampling and inspection of residential and commercial properties, and began removal actions in Libby homes and businesses. In a January 2002 letter to the EPA officials, Montana’s governor officially asked the EPA to add Libby’s asbestos contamination to the Superfund program’s National Priorities List (NPL) on the basis of the threat presented to human health and the environment. The Site was added to the NPL in October 2002. Figure 3 shows an overview of the removal and remedial activities conducted at the Site up to 2020.

12

Figure 3: Removal and Remedial Activities 1999 - 2020

13

Removal Actions Prior to the issuances of their respective RODs, the EPA performed emergency response action removals (removal actions) in all OUs with the exception of OU3. A summary of these removal actions is presented below by OU and in Appendix I, Tables I-1 through I-3. The RODs and respective remedial investigations (RIs) include a full description of the removal actions conducted for each OU. OU1 OU1, the former Export Plant, consists of three areas (Figure C-1 and C-2 in Appendix C). Area 1 is the former Export Plant, Area 2 is Riverside Park and Area 3 is the Highway 37 embankments. The EPA conducted various investigation sampling events at all three areas. Based on the sampling results, removal events were conducted as needed and contaminated material disposed of offsite. Following each removal event, confirmation soil samples were collected from the floor of the excavation to ensure samples met the removal clearance criteria of less than 1% LA. OU1 response action removals were conducted in Areas 1 and 2 (former Export Plant and Riverside Park, respectively) (Table I-1 in Appendix I). In Area 1, W.R. Grace conducted the removal actions from July 2000 to December 2002. Vermiculite, contaminated soil, dust and building debris were removed. Historic buildings were demolished, and additional contaminated soil was removed. In Area 2, the EPA conducted the removal actions from October 2003 through July 2008. The EPA removed contaminated soil in Riverside Park to a depth of 12 inches below ground surface (bgs) except on the riverbank and embankment on the northeast side of City Service Road (6 inches bgs). The EPA placed rock cover in areas of observed vermiculite. Orange fencing was placed at depth to indicate the presence of vermiculite. In 2008, the EPA conducted a quick response removal event to assist the city of Libby with construction of the new pavilion. Two areas were excavated to prepare the area for the placement of the pavilion footers and provide an access ramp. Based on investigation activities at Area 3 (Highway 37 embankments), no removal actions were conducted. OU2 OU2, the former Screening Plant, consists of Subareas 1 through 4 (Former Screening Plant, Flyway, Private Property, Rainy Creek Road Frontages, respectively) (Figure C-5 and C-6 in Appendix C). The EPA conducted various investigation sampling events at all areas. Based on the sampling results, removal events were conducted. Following each removal event, confirmation soil samples were collected from the floor of the excavation to ensure samples met the removal clearance criteria of less than 1% LA. The EPA, and in some instances, W.R. Grace, conducted removal actions at the four subareas of OU2 (Table I-2 in Appendix I). Removal actions were conducted seasonally from August 2000 through August 2006. In Subarea 1, the former Screening Plant, a majority of the buildings were demolished, and the EPA removed the building demolition materials, vermiculite-contaminated soil, vegetative material and debris. In subareas 2, 3 and 4 (Flyway, Private Property and Rainy Creek Road Frontage, respectively), the following removal actions were conducted:

• Subarea 2: Excavation and disposal of vermiculite-contaminated soil in 2001 and 2004, and excavation within the Highway 37 right-of-way (ROW) adjacent to Subarea 2 with disposal at the former mine in 2005.

• Subarea 3: Excavation within the Highway 37 ROW adjacent to Subarea 2 with disposal at the former mine in 2005.

• Subarea 4: Excavation along the North and South frontages in 2004 and excavation to locate and repair a damaged water line in 2005 with disposal at the former mine.

OUs 4, 5, 6, 7 and 8 Table I-3 provides an overview of the investigations and removal actions at OUs 4 through 8. A full description of the removal actions is provided in the 2016 ROD. Removal actions are summarized below for OUs 4 through 8.

14

OU4 There are about 6,635 properties in OU4. Prior to the signing of the 2016 ROD, between 2001 and 2015, removals were completed at about 2,100 commercial and residential properties. A Class IV asbestos cell at the Libby Class II Landfill was also constructed during this time for disposal purposes. The EPA subdivided OU4 into 24 geographic removal zones (GRZs) (Figure C-9 in Appendix C). GRZs are geographic groups developed to subdivide OU4 into strategic areas. OU5 The former Stimson Lumber Mill is a large property (over 400 acres) (Figure C-10 in Appendix C). Based on interviews and investigation activities, the EPA was aware of vermiculite and LA-containing soil present in surface areas at OU5 in the following areas: former Expansion Plant, railroad spur and former tree nursery. Between 1999 and 2013, contaminated media was removed, and historic buildings were demolished, at various parts of the former Stimson Lumber Company property (Table I-3 in Appendix I). Contaminated media was disposed of at the former mine or the asbestos cell at the Libby Class II Landfill. OU6 In August 2003, visibly contaminated soil was removed from the BNSF Libby Railyard (Figure C-14 and C-15 in Appendix C). LA asbestos was detected in all soil samples collected from the removal area. In fall 2004, the EPA contractor conducted a removal of about 15,000 feet of railroad track and 8,000 railroad ties to access underlying LA-contaminated soil for removal and disposal of potential asbestos-containing material (ACM) of the BNSF scale house and foundation. Clearance soil sampling was conducted until clearance levels were achieved. In 2005, two remaining areas with previously identified LA-contaminated soil were excavated, and confirmation samples indicated no detection of LA asbestos. In 2010 and 2011, about four cubic yards of solid waste containing visible vermiculite was removed from an abandoned concrete structure east of the mainline in the Town of Troy, and the structure was filled with concrete and covered with steel plates to prevent unauthorized access. Additional work was conducted in 2018 to further secure this structure from potential access by trespassers. OU7 There are 1,477 properties in OU7 and seven GRZs (Figure C-16 in Appendix C). From 2008 to 2015, LA-contaminated material was removed at about 100 commercial and residential properties. OU8 LA-containing vermiculite and soil are known to exist on the surface along the ROW of United States, state, and local highways within OU8. A majority of the surface soil samples were non-detect, with the stretch of Highway 37 between Libby and Rainey Creek Road having the greatest concentration of samples with results of trace or less than 1%. The areas with samples with visible vermiculite were confined to areas east of Rainey Creek Road along Highway 37. These areas were addressed under response actions for other OUs. Remedial Actions The EPA selected the final remedies in 2010 for OU1 and OU2 and in 2016 for OUs 4 through 8. For each OU, the bulk of the work was conducted during the prior removal actions. The RODs established the final remedial action objectives and cleanup goals and identified any remaining areas of contamination. OU1 and OU2 The EPA issued the OU1 ROD and OU2 ROD in May 2010. The remedial action objectives (RAOs) for OU1 and OU2 are as follows:

• Break the exposure pathways for inhalation of LA fibers that would result in unacceptable cancer risk or non-cancer hazard.

• Control erosion of contaminated soil by wind and water from source locations to prevent exposures and the spread of contamination to unimpacted locations.

15

• Implement controls to prevent uses of the Site that could pose unacceptable risks to human health or the environment or compromise the remedy.

The selected remedy for OU1 is as follows:

• Containment via soil covers on about nine acres with a visible marker layer at the bottom of the cover to denote the extent of cleanup.

• Removal and off-site disposal of contaminated materials in the proposed utility corridor (about 22,000 cubic yards over 10% of Areas 1 and 2).

• Institutional controls in the form of land-use restrictions to restrict use of areas containing contaminated soil, including subsurface soil covered under previous response actions and subsurface contamination remaining below excavated areas.

The selected remedy for OU2 pertained to two areas of remaining contamination in the upper 18 inches of soil. The first area was a single contaminated sample location in Subarea 2 (Flyway Property Subarea). The 2010 OU2 ROD specifies that this area will be excavated and the contaminated material disposed of offsite. A visible marker was required to denote the extent of cleanup. The second area is along the embankment of Highway 37. The area could not previously be excavated due to concerns that excavation would damage the structural integrity of the highway. The OU2 ROD specified that further evaluation will be conducted to determine if excavation is possible. If it was determined not to be possible, the OU2 ROD required a cover to be placed in this area. Institutional controls will provide assurance that the remedy will remain protective. OUs 4, 5, 6, 7 and 8 The EPA issued a combined ROD for OUs 4 through 8 in February 2016. A majority of areas within these OUs were remediated during removal actions (see above). However, at the time of the issuance of the 2016 ROD, there were remaining commercial and residential properties associated with OU4 and OU7 that were not yet remediated. The 2016 ROD called for remediation of these remaining properties and required institutional controls at all five OUs. The overall RAOs for OUs 4 through 8 were as follows:

• Minimize the inhalation of LA during disturbances of soil contaminated with LA such that the resulting exposures result in cumulative cancer risks that are within or below the EPA’s acceptable risk range of 1x10-6 to 1x10-4 and cumulative non-cancer hazard index (HI) that are at or below 1.

• Minimize the inhalation of LA during disturbances of building materials contaminated with LA such that the resulting exposures result in cumulative cancer risks that are within or below the EPA’s acceptable risk range of 1x10-6 to 1x10-4 and cumulative non-cancer HIs that are at or below 1.

The selected remedy for the commercial and residential properties in OUs 4 and 7 is divided by media: contaminated soil and contaminated building materials. To guide the remedial actions at OU4 and OU7, two criteria types were used. Remedial action levels (RALs) were used to define the condition when remedial action was needed due to LA contamination in soil or building material. The remedial clearance criteria were the condition that must be met in order to deem a remedial action complete. The site-specific RALs and remedial clearance criteria were based on the type of contaminated media (building materials versus soil), land-use categories, depth of contaminated soil or accessibility of contaminated building material, use frequency of contaminated soil, and the identification of boundary conditions. Boundary conditions are defined as features or conditions that limit the ability to further remediate LA contamination due to physical or technical constraints and the related lack of accessibility these boundary conditions present. Appendix H, tables H-1 through H-4 provide a list of all RALs and clearance criteria. The selected remedy for contaminated soil includes the following components for residential and commercial properties:

• Contaminated soils at a property exceeding RALs for the land-use category will be excavated until remedial clearance criteria for surface soil and subsurface soil are met for the land-use category, or a boundary condition is reached.

16

• If contaminated soil is left in place due to a boundary condition, a visibly distinct marker layer will beinstalled at the bottom of the excavation.

• Clean backfill is installed to replace the excavated material. Backfill will be revegetated or otherwiserestored to match the previous surface conditions.

• Excavated contaminated soil will be disposed of properly at a facility authorized for LA.• Access controls such as temporary fencing and signage will be implemented during construction to warn

of dangers or exclude access to areas being remediated. Post construction, access controls may beappropriate in public use areas where disturbance of backfill could occur.

• The remedy components will be monitored, maintained and adjusted as necessary so exposure tocontaminated soil does not occur and backfill remains effective for eliminating migration of LA to thesurface or other media.

The selected remedy includes the following components for parks and schools, transportation corridors, and industrial parks where removal actions had previously been conducted:

• The remedy components will be monitored, maintained and adjusted as necessary so unacceptableexposures to contaminated soil do not occur and previously placed backfill remains effective foreliminating migration of LA to the surface or other media.

The selected remedy for contaminated residential and commercial building materials includes the following components:

• Accessible contaminated building materials exceeding RALs will be removed until remedial clearancecriteria for indoor non-living space or indoor living space are met.

• Removed building materials, primarily attic insulation, will be restored as needed to a functionalcondition.

• Contaminated building materials to remain in place will be addressed through encapsulation consisting ofin-place sealing and covering.

• Interior cleaning, when required, will be performed using vacuum extraction to remove LA fiberspreviously released within buildings.

• Removed contaminated building materials will be disposed of properly.• Access controls will be implemented during construction to warn of dangers or exclude access to areas

being remediated. Post-construction access controls may be appropriate in public use areas wheredisturbance of encapsulated areas could occur.

• The remedy components will be monitored, maintained and adjusted as necessary to mitigate exposure toor migration of LA to areas where they could become accessible.

The selected remedy includes the following components in parks and schools, transportation corridors, and industrial parks where contaminated building materials had previously been removed:

• The remedy components will be monitored, maintained and adjusted as necessary to mitigate exposure toor migration of LA to areas where they could become accessible.

The selected remedy calls for institutional controls for all land use types. Institutional controls, including legal controls and risk communication controls, will be implemented site wide and will be tailored to land uses as necessary to reduce exposure risks during and post construction. The ROD noted that while the objectives for the institutional controls identified in the ROD were unlikely to change, the specific institutional controls had yet to be formally identified. The ROD indicated EPA and DEQ will work with the community to develop an Institutional Control Implementation and Assurance Plan (ICIAP) to help clarify the tools that will be used to implement the institutional controls. The EPA would then prepare an Explanation of Significant Differences (ESD) that would reference the ICIAP and identify the specific institutional controls.

17

Status of Implementation

OU1 The EPA completed the remedial design and Response Action Work Plan (RAWP) in May 2010 and Remedial Action Design Drawings in September 2011. The OU1 remedial action began in August 2011 and finished in June 2012. In most areas of OU1, remediation consisted of removing contaminated soil and installing an 18-inch-thick soil cover using clean soil. Confirmation samples were collected from the floor of the excavation, with each sample representing a maximum of 2,500 square feet. Samples were analyzed for LA content. Eight of the 241 confirmation samples collected indicated LA concentration greater than or equal to 1%. In areas represented by these eight samples, an additional 18 inches of soil depth was excavated. Areas not capped with 18-inch-thick soil cover included:

• Road embankments, where 6 inches of soil was excavated.• Roads, where paving was removed and replaced with road base.• Riverbank areas that were capped with riprap.

Figure C-3 shows remaining areas of contamination and Figure C-4 shows the remediated areas and capping treatment. Excavated soils were disposed of at the mine (OU3).

Excavated areas were backfilled with clean soils. The OU1 Final Remedial Action Report was approved in July 2013. This OU was deleted from the NPL on May 26, 2020.

OU2 The OU2 remedial design consisted of the RAWP, completed in May 2010, and evaluation of the seasonally flooded portion of the Flyway property investigated during the RI. Evaluation of the seasonally flooded portion of the Flyway property was completed in July 2010 and consisted of visual inspection for vermiculite, collection of samples from activity-based sampling (ABS) activities, and analysis of the samples for LA. Based on this evaluation, it was concluded that remedial measures were not required in this portion of the Flyway property. OU2 remedial action began on September 27, 2010, and was completed on November 3, 2010. Remedial action consisted of excavation and backfill in an isolated portion of the Highway 37 ROW (depth of 6 inches) and the area surrounding a sample in the Flyway property (depth to 12 inches). The OU2 remedy components are shown in Figure C-7 in Appendix C. Four confirmation soil samples were collected from the bottom of excavation at the Flyway property. All these samples were non-detect for LA. One confirmation soil sample was collected from each of the areas in the ROW. Samples contained less than 1% LA, which means that residual contamination will remain in these areas below the cap (Figure C-8 in Appendix C). All other ROW areas were non-detect for LA. Excavated soils were disposed of at the former mine.

Excavated areas were backfilled with clean soils imported from outside the Libby Valley. Imported soils were tested to verify they met the requirements of the OU2 remedial action work plan. Following backfill, excavated areas were hydroseeded. The OU2 final remedial action report was approved on May 15, 2012. The EPA declared OU2 operational and functional on August 1, 2013.

This OU was deleted from the NPL on April 10, 2019.

OU4 and OU7 As previously discussed, many response actions have been performed at OU4 and OU7 both prior to and following finalization of the 2016 ROD. Construction activities were conducted in accordance with the OU4/OU7 RAWP. The O4 and OU7 final remedial action report was approved on June 30, 2020.

OU4 and OU7 consist of 8,112 properties (6,635 properties within OU4 and 1,477 properties within OU7). Table 3 provides a summary of the removal and remedial actions (together referred to as response actions). From 1999 to 2018, an EPA contractor conducted investigation and response activities in OU4 and OU7. The EPA finalized the OU4 and OU7 Remedial Action Completion Report in November 2019. An overview of the various removal zones is shown in Figure C-9 in Appendix C for OU4 and Figure C-16 for OU7.

18

Table 3: OU4 and OU7 Property Status Summary Status OU4 OU7 Property Count

Response Not Required (RALs not exceeded)

3,758 1,208 4,966

Response Completed Indoor 291 62 353 Response Completed Indoor/Outdoor 767 42 809 Response Completed Outdoor 1,368 98 1,466 Investigation Not Requireda 291 3 294 Investigation Required – Access Refused 155 62 217 Response Required – Access Grantedb 1 0 1 Response Required – Access Refused 4 2 6

Totals 6,635 1,477 8,112 Notes: Source: Final Remedial Action Completion Report, November 2019 a = includes undeveloped government owned lands, timber industry lands, borrow sources/fill pits and roadways not associated with OU8. b = response action on hold due to property owner’s medical issue; property owner will contact MDEQ when ready for response action.

Contaminated Soil An EPA contractor excavated contaminated soil that exceeded action levels until the clearance criteria for surface soil and subsurface soil was met. Trucks with covered beds transported the majority of excavated soil to the mine (OU3) for disposal. In some cases, the EPA directed soils to be disposed of at the Class IV Asbestos Cell at the Libby Class II Landfill. To mitigate technical issues and limitations, the clearance criteria included boundary conditions (building foundations, utilities, tree roots) that did not require complete removal of contaminated soil. The maximum excavation depth was established at 3 feet bgs. A delineation marker was used at the bottom of the excavation to mark areas where contaminated soil was left in place. Each property was backfilled and regraded after excavation activities in accordance with resumption of the current use of the property. In general, common fill overlain by 4 inches of topsoil was used to restore yard areas, topsoil was used to restore gardens and flowerbeds, and structural fill was used to restore driving/parking surfaces.

Contaminated Building Materials Accessible contaminated building materials (CBMs) were removed using pneumatic or mechanical means and disposed of in the Class IV Asbestos Cell at the Libby Class II Landfill. Encapsulation was used when CBMs were inaccessible. Encapsulation included in-place sealing and/or covering with a high-performance coating to prevent release of LA fibers into indoor air. Typical inaccessible CBMs included insulation in some portions of attics or openings such as outlets and light fixtures. An EPA contractor conducted indoor cleaning when needed to remove LA fibers previously released within a building.

Response actions at OU4 and OU7, both pre- and post-ROD, met the performance goals for both contaminated soil and CBMs for residential/commercial and park/school land-use categories. The EPA conducted final inspections following the completion of restoration activities for each response action. For fund-financed remedies, the EPA and MDEQ conducted a joint inspection following construction to determine that the remedy had been constructed properly. The operational and functional (O&F) period began upon the EPA’s letter to MDEQ signifying the start of the O&F period. The O&F period started on April 1, 2019. Due to the complexity and large number of properties, the EPA and MDEQ conducted the joint inspection at randomly selected properties. A total of 33 properties were evaluated during the joint inspection. No issues were found.

OU5 Based on the investigation and removal activities performed prior to the ROD and documented in the 2013 RI Report, OU5 had already met the requirements of the ROD. The EPA reviewed the documentation of interior and

19

exterior response actions and analytical data and determined actions at OU5 met the appropriate RALs. No design and construction activities were conducted.

Figure C-11 in Appendix C shows the LA and visible vermiculite present at the ground surface following completion of investigation and removal activities. Figure C-12 and C-13 in Appendix C show LA and visible vermiculite in subsurface soils from subsurface investigation and confirmation sampling at the floor of excavation. In the 2015 HHRA, exposures to outdoor workers and recreational users in OU5 were within the EPA’s acceptable risk range for cancer (1x10-6 to 1x10-4) and a non-cancer HQ less than 1.

OU6 In 2016, during the Amtrak Depot renovation, asbestos-containing material and contaminated building material were removed and disposed of at the Lincoln County Landfill. Figure C-14 in Appendix C shows the response action zones and Figure C-15 shows the tested areas in the right of way. As reported in the 2015 HHRA, all results of the ABS activities resulted in no detection of LA asbestos. In 2016, a surface soil sampling effort was completed, and results were consistent with previous sampling results in 2016. In 2017, a test pit investigation was completed at the Stimson Spur to determine LA concentrations in surface and subsurface soils that may be disturbed by routine track installation activities. The track installation was completed in late 2017. In 2018, asbestos exposure monitoring was conducted. Fifty-nine personal air samples and 52 stationary air samples were collected during soil disturbing activities during a signal upgrade project. With the exception of a single sample, all results were not detected. The one personal air sample was two orders of magnitude below the Permissible Exposure Limit. On May 18, 2018, the EPA conducted the final inspection and walkthrough. BNSF has submitted preliminary drafts of the Remedial Action Report and the O&M Plan for OU6 to the EPA and DEQ.

OU8 As previously discussed, response actions were performed for other (non-OU8) OUs that addressed contamination within the highway ROWs that are part of OU8. Those actions have been discussed in the Remedial Action Report for the OU in which the action was performed (OU1, OU2, OU4/7 Remedial Action Reports). Figures C-17 and C-18 in Appendix C show the sample results in surface and subsurface soil for OU8. In the 2015 HHRA, exposures from driving on roads in Libby and Troy, soil disturbance activities along the ROW and recreation usage all resulted in estimated cancer risk within the EPA’s acceptable risk range and a non-cancer HQ less than 1.

Institutional Control (IC) Review

Institutional controls are required for OUs 1, 2, 4, 5, 6, 7 and 8, as indicated in their respective RODs. There are two informational instruments that currently apply to all of these OUs: U-Dig and the Lincoln County Board of Health (BOH) Asbestos Resource Program (ARP) (Table 4).

U-Dig is a Montana utility locate service. Montana state law (Montana Code Annotated [MCA] Section 69-4-503)requires that all parties planning to excavate, drill, or perform other subsurface activities notify the designated U-Dig (one-call) notification center prior to starting these activities.

BOH-ARP is a program currently staffed in Lincoln County, Montana, and currently funded by the EPA. BOH-ARP was developed as a program to educate the public regarding the remaining risks of LA exposure, provide resources to manage the risks associated with LA exposure, and implement initiatives to reduce or prevent the risk of LA exposure. The BOH-ARP is notified by the U-Dig call center for all activities planned within the site boundaries. The BOH-ARP has access to all property sampling information and cleanup history. Assistance in managing contamination may include providing resource materials and best management practices, making contractor referrals, and/or removing LA (or sources of LA) contamination. Resource material is provided via the office and via a hotline. Homeowners and residents can call the hotline prior to remodeling their homes or if vermiculite is encountered on their property. The BOH-ARP can provide information on contamination present at the property, risk reduction and information on renovation and demolition requirements. BOH-ARP is available for any persons interested in information regarding LA and/or resources available to minimize risks associated with LA in Lincoln County.

20

OU1 The EPA issued the OU1 ICIAP in August 2015 and revised it in July 2019. As required in the 2010 OU1 ROD, institutional controls are used to ensure that any future encounters with residual contamination are managed appropriately.

The following are the main objectives of the institutional controls in place at OU1: 1. Notify future landowners of the presence of subsurface contamination and institutional requirements.2. Mitigate the potential for inhalation exposures to LA fibers that would result in excess cancer risks that

exceed the EPA’s acceptable cancer risk range of 1x10-6 to 1x10-4 (one in one million to one in tenthousand) or non-cancer HQ greater than 1.

3. Control dispersion/erosion of contaminated soil by wind and water from source locations to prevent thespread of contamination to unimpacted locations and media.

4. Implement controls to prevent uses of the Site that could pose unacceptable risks to human health or theenvironment or compromise the remedy.

5. Implement controls to prevent uses of the Site that could spread contamination to unimpacted orpreviously remediated locations and media.

The institutional controls in place at OU1 include U-Dig, BOH-ARP, environmental covenant, encroachment documents, including an MDT encroachment application, a Riverfront Park excavation application, and a City of Libby permit.

• All individuals and organizations intending to perform work within the right-of-way (ROW) of MontanaHighway 37 must apply for an encroachment permit with MDT. Any application for the OU1 ROW alongHighway 37 is accompanied by an addendum, which notifies the permittee to take precautions to guardagainst potential exposure to LA contamination.

• The Riverfront Park excavation application is a document used by the City of Libby to evaluate anyexcavation work anticipated to be performed within OU1. All individuals and organizations performingexcavations are required to complete the application.

• The Fred Brown Pavilion rental agreement is an acting permit issued by the City of Libby for users of thepavilion area who reserve the area for commercial, non-profit or private use. Some activities at the Sitemay be prohibited, as listed in the rental agreement, to ensure remedies at the Site remain intact.

• DEQ has implemented an environmental covenant on the Riverfront Park property pursuant to MCA 75-10-727 intended to notify future landowners of previous remedial action completed at the Site, the knownLA contamination within soil at the Site.

OU2 The EPA finalized the OU2 ICIAP in March 2018. As required by the OU2 ROD, institutional controls are used to ensure that any future encounters with residual contamination are managed appropriately. The main objectives for institutional controls at OU2 are the same as those listed above for OU1.

Institutional controls for OU2 include U-Dig, BOH-ARP and an environmental covenant. Under MCA Section 75-10-727, MDEQ has implemented an environmental covenant intended to notify future landowners of previousresponse actions completed at the Site, the potential presence of contamination within soils, and institutionalcontrol requirements within the Flyway (Subarea 2). Under MCA Section 75-10-727, the EPA and/or MDEQ arethird-party beneficiaries of the environmental covenant, with enforcement rights. In addition, U-Dig and theBOH-ARP program apply to OU2.

OU4 and OU7 EPA finalized the OU4 and OU7 ICIAP in March 2020. As required by the 2016 ROD, the institutional control objectives for OU4 and OU7 are as follows:

1. Prevent LA fibers that may remain in soil within OUs 4 and 7 after meeting remedial criteria for the land-

21

use category from becoming a future source of unacceptable risk. 2. Prevent LA fibers that remain in inaccessible building materials from becoming a future source of

unacceptable exposure.3. Track changes in land use and develop a notification system to ensure that property owners, prospective

property owners and workers are aware of remaining or potential LA, which could become a futuresource of unacceptable exposure.

Institutional controls for OUs 4 and 7 include government controls and informational devices. As indicated above, U-Dig and BOH-ARP are in place for OU4 and OU7. Below is the list of the other institutional controls currentlyin place.

• Property Evaluation Notification (PEN) regulation: Adopted in March 2020, this regulation is focused onproviding LA property information, data, education and evaluations to protect the public whileperforming applicable activities defined as excavation, grading, and landscaping; interior or exteriordemolition, repair, modification, disturbance of material, or remodeling to permanent or temporarystructures; and development of subdivisions or previously undeveloped land. Prior to performing anyApplicable Activities at a property within the above-defined jurisdiction, a person is required to notifyBOH-ARP of the proposed Applicable Activities through the PEN process.

• MDT encroachment permit application and addendum: All individuals and organizations intending toperform work within the ROW in OUs 4 and 7 of the OU8 corridor must apply for an encroachmentpermit with MDT.

• Notice of Environmental Condition (NOEC) and Notice of Potential Environmental Condition (NOPEC):NOECs and NOPECs are filed with the Lincoln County Clerk and Recorders Office for any propertywhose owner has refused to complete investigation and/or cleanup efforts. The NOECs and NOPECs areintended to provide notice concerning the presence (NOEC) or potential presence (NOPEC) ofcontamination at a specific property and to caution interested parties against using the property in anymanner that may increase the risk of exposure to the contamination and result in an imminent andsubstantial endangerment to public health, welfare or the environment. For a notice to be withdrawn,submission to the EPA and MDEQ of investigation data and/or proof of remediation, as applicable, arerequired and are the responsibility of the property owner.

Per the ROD, these specific institutional control instruments will be documented in the decision document via an ESD.

OU5 EPA finalized the OU5 ICIAP in August 2016. The institutional control objectives for OU5 are the same as for OU4 and OU7. Institutional controls for OU5 include government controls and informational devices. As indicated above, U-Dig and BOH-ARP are in place for OU5.

For OU5, an MDEQ-approved institutional control, under MCA Section 75-10-727, shall be instituted to restrict the property, as necessary, to mitigate the risk to public health by way of an environmental covenant. This institutional control will also notify future landowners/users of previous response actions completed at OU5 and of known or potential LA contamination within the soils or buildings at the Site. In the event any such instrument receives final approval by MDEQ, it will be included within the ICIAP as an appendix. The landowner must agree to place this institutional control on the property.

Per the ROD, these specific institutional control instruments will be documented in the decision document via an ESD.

OU6 BNSF’s contractor sent a preliminary draft ICIAP for OU6 to EPA and MDEQ. The institutional control objectives are as follows:

22

1. Prevent LA fibers that may remain in soil after meeting remedial criteria for transportation corridors frombecoming a future source of unacceptable exposure.

2. Track changes in land use and develop a notification system to ensure that property owners, prospectiveproperty owners, users, and workers are aware of remaining or potential LA, which could become a futuresource of unacceptable exposure and institutional control requirements.

Institutional controls include U-Dig and BOH-ARP, described in detail above. A restrictive covenant is in place limiting land/resource use and protecting remedy portions of the Libby Railyard. This institutional control mitigates potential risk to public health and notifies future landowners/users of previous response actions completed at the Libby Railyard and of known or potential LA impacts within the boundary of the restrictive covenant.

Per the ROD, these specific institutional control instruments will be documented in the decision document via an ESD.

OU8 The EPA finalized the OU8 ICIAP in September 2017. As required by the 2016 ROD, the institutional control objectives for OU8 are as follows:

1. Prevent LA fibers that may remain in soil within OU8 after meeting remedial criteria for the land-usecategory from becoming a future source of unacceptable risk.

2. Track changes in land use and develop a notification system to ensure that property owners, prospectiveproperty owners and workers are aware of remaining or potential LA, which could become a futuresource of unacceptable exposure.

Institutional controls for OU8 include U-Dig and BOH-ARP, described in detail above. An ESD is under development to specify the institutional control instruments and will be issued in the summer of 2020.

Table 4: Summary of Planned and/or Implemented Institutional Controls (ICs) Media, Engineered Controls, and Areas

That Do Not Support UU/UE

Based on Current Conditions

ICs Needed

ICs Called for in the Decision

Documents

Impacted Parcel(s)

IC Objective

Title of IC Instrument Implemented and Date

(or planned)

Soil Yes Yes

OUs 1, 2, 4, 5, 6, 7, 8

Prevent LA fibers that may remain in soil from becoming a future source of

unacceptable risk, track changes in land

use, and develop a notification system to ensure that property owners, prospective property owners and workers are aware of remaining or potential

LA, which could become a future

source of unacceptable exposure.

U-Dig

BOH-ARP

OU 8 Encroachment permits

OUs 4, 7 PEN regulation NOEC and NOPEC

23

Media, Engineered Controls, and Areas

That Do Not Support UU/UE

Based on Current Conditions

ICs Needed

ICs Called for in the Decision

Documents

Impacted Parcel(s)

IC Objective

Title of IC Instrument Implemented and Date

(or planned)

OU 6 Restrictive covenant (December 19, 2017)

OU5 Environmental covenant (planned)

CBM Yes Yes

OUs 4, 5, 7 Prevent LA fibers that remain in inaccessible

building materials from becoming a future source of

unacceptable exposure.

BOH-ARP

OUs 4, 7 PEN regulation NOEC and NOPEC

OU5 Environmental covenant (planned)

Systems Operations/Operation and Maintenance (O&M)

The EPA has finalized the O&M plans for OU1, OU2, OU4, OU5, OU7 and OU8. That state led annual O&M inspections at OU1 and OU2 in June 2018 and September 2019. The first state led annual O&M inspection at OU5 and OU8 were completed in September 2019.

The EPA finalized the O&M plan for OU4 and OU7 in April 2020. The anticipated end of the O&F period and start of O&M is July 1, 2020.

OU1 and OU2 The EPA approved the final OU1 O&M Plan in July 2019 and the final OU2 O&M Plan in August 2015. O&M at OU1 and OU2 consists of annual inspections conducted by MDEQ. Annual inspection activities include visual inspections, remedy repair and maintenance, sampling and analysis, evaluation of institutional controls, and reporting. General property maintenance and management is the responsibility of the property owner as guided by the BOH-ARP. The O&M objectives for OU1 and OU2 are as follows:

• Maintain the integrity of the physical remedy and engineered controls.• Monitor, evaluate and update institutional controls to ensure protectiveness.• Ensure that the protection of human health is maintained.• Prevent unrestricted use of OU1 and OU2.

O&M OU1 site inspections occurred in June 2018 and September 2019. The 2018 inspection results indicate minor areas of erosion associated with runoff from City Service Road as well as soil disturbance from vehicles driving off the designated road area near the entrance to the overflow parking area, overpass bridge, and along the main road between the pavilion and overflow parking area. The City of Libby repaired the erosion on the embankments and along City Service Road, as well as the area where vehicles created a disturbance. Riprap was also replaced in areas along the Kootenai Riverbank and the underpass. Minor areas of erosion associated with runoff were observed from the City Service Road on the west side of MT Highway 37 during the 2019 inspection. During the annual inspections, the institutional controls were reviewed. From 2017 through 2019, U-Dig was used five times and about 90 rental permits were issued for the pavilion. During the 2018 annual inspection, MDT

24

reported no encroachment permits. MDT was contacted for the 2019 annual inspection; however, no response was received. The OU2 annual O&M inspection was conducted in 2018 and 2019 at the Former Screening Plant and surrounding areas. Subareas 1 and 3 were not accessed. However, observations were made from publicly accessible areas. During the inspections, covers appeared intact and no erosion concerns were identified. Institutional controls were reviewed, and no U-Dig calls or encroachment permits were sought from 2017 to 2018. MDT was contacted for the 2019 annual inspection; however, no response was received. OU4 and OU7 The EPA approved the final OU4 and OU7 O&M Plan in April 2020. Long-term O&M will be performed by MDEQ to maintain the integrity of the remedy components. The O&M objectives for OU4 and OU7 are as follows:

• Observe and maintain the integrity of the remedies and controls. • Monitor, evaluate, and update institutional controls to ensure protectiveness.

O&M activities will include nonintrusive visual inspections, performed at least annually, sampling, monitoring and analysis following activities such as land-use change, and physical remedy maintenance during activities such as planned renovations, new construction, demolition and land-use change. The first annual O&M inspection is planned for Spring 2021. OU5 MDEQ conducted the first annual inspection at OU5 in September 2019 in accordance with the 2018 O&M Plan. Annual inspection activities include visual inspections, remedy repair and maintenance, sampling and analysis, evaluation of institutional controls, and reporting. General property maintenance and management is the responsibility of the property owner as guided by the BOH-ARP. The O&M objectives at OU5 include:

• Maintain the integrity of the physical remedy and engineered controls. • Monitor, evaluate and update institutional controls to ensure protectiveness.

Specifically, visual observations were made to:

• Note any damage to the remedies in the Central Maintenance Building. • Observe the integrity of the fishing pond and soil/gravel cap on the adjacent bark pile. • Verify building removal of the fire-destroyed Plywood Plant and Finger Jointer Buildings. • Observe the integrity of the streambank along Libby Creek. • Note any changes to the site conditions from the August 2017 EPA site walkthrough.

During the 2019 annual inspection, the following was noted:

• Spray foam was observed in encapsulated areas of the Central Maintenance Building and although intact, there was no barrier to prevent deterioration.

• Soils with identified vermiculite were removed by LCPA from the collapsed portion of the Truck Barn Building, and the area currently consists of bare ground with no barrier or vegetation.

• The section of Libby Creek streambank has eroded, and rip rap has washed away, causing potential for erosion during high flows. LCPA requested that the EPA take corrective action; however, the EPA has determined that no further action will be taken.

• Encapsulated bark piles adjacent to the fishing pond are capped with a gravel area; however, the slopes are not capped, and deer were observed in the area.

In 2018, there were six U-dig calls in OU5. MDEQ determined that there are no anticipated future land-use changes and, with the exception of the Libby Creek streambank, covers are intact, and no erosion is occurring.

25

MDEQ recommended additional monitoring and maintenance based on the results of the first annual inspection and LCPA is implementing the Draft OU5 Property Management Plan. LCPA completes property activity evaluations and land-use reviews as part of the plan. In 2017, there were five property activity evaluations and one in 2018. OU8 MDEQ conducted the first annual inspection at OU8 in 2019 in accordance with the 2018 O&M Plan. Annual inspection activities include visual inspections, remedy repair and maintenance, sampling and analysis, evaluation of institutional controls, and reporting. General property maintenance and management is the responsibility of the property owner as guided by the BOH-ARP. O&M objectives at OU8 include:

• Maintain the integrity of the physical remedy and engineered controls. • Monitor, evaluate and update institutional controls to ensure protectiveness.

In 2018, there were 17 U-dig calls in OU8. Overall, no exposures to residual contamination were identified, and the remedy is functioning as designed. The only findings were minor areas of erosion associated with runoff from the City Service Road on the west side of MT Highway 37 (see inspection results for OU1). III. PROGRESS SINCE THE PREVIOUS REVIEW This section includes the protectiveness determinations and statements from the last FYR Report. There were no issues and recommendations in the 2015 FYR Report.

Table 5: Protectiveness Determinations/Statements from the 2015 FYR Report

OU # Protectiveness Determination Protectiveness Statement

1 Protective The remedy at OU1 is protective of human health and the

environment; exposure pathways that could result in unacceptable risks are being controlled.

2 Protective The remedy at OU2 is protective of human health and the

environment; exposure pathways that could result in unacceptable risks are being controlled.

IV. FIVE-YEAR REVIEW PROCESS Community Notification, Community Involvement and Site Interviews

A public notice was made available by a newspaper posting on 8/12/2019 (Appendix D). It stated that the FYR was underway and invited the public to submit any comments to the EPA. The results of the review and the report will be made available at the Site’s information repositories and Lincoln County Libraries in Libby and Troy. The Libby Library is located at 220 West Sixth Street in Libby, Montana, and the Troy Library is located at 3rd and Kalispell in Troy, Montana. During the FYR process, interviews were conducted to document any perceived problems or successes with the remedy implemented to date. The interviews are summarized below and provided in Appendix E. Jerry Bennett, Lincoln County Commissioner, expressed an overall positive impression of remedial activities at the Site. He noted some operational changes in remedy implementation over the years and questioned some things that have been left in place. He expressed some concern with the restoration of specific properties such as over-compaction of septic drain fields. Mr. Bennett also expressed concern with the transition from O&F (EPA) to

26

O&M (MDEQ and Lincoln County). Mr. Bennett indicated some local residents are unsure how to proceed if they need to remodel their homes or businesses or if land use needs to change. Brent Teske, Mayor of Libby, is pleased with how the remedial activities are proceeding, especially toward the end of the project. Mr. Teske expressed concern about the transition of O&M responsibilities to Lincoln County and feels uncertain about what that outcome will look like in the future. Mr. Teske would like to see OU1 deleted. LCPA representatives Tina Oliphant and Brett McCully are concerned about the remaining contamination that was left in place and how that will impact the ability to change land-use designations. They are also concerned about the transition from the EPA to MDEQ and Lincoln County for long-term O&M responsibilities and feel that the EPA has not managed that transition well to date. Ms. Oliphant and Mr. McCully are not satisfied with the O&M Plan for OU5. They feel it is too vague and will not be useful going forward. Lisa Dewitt, MDEQ project manager, has a positive impression of the project overall. Ms. Dewitt observed that the community is ready to move past being a Superfund site but the transition to the O&M phase may be difficult. She believes that there was a huge effort to communicate risks during the cleanup, but that it was and is difficult to get it into simple language. Ms. Dewitt also indicated that the EPA needs to communicate with MDEQ and Lincoln County about how the transition into the O&M phase will proceed. Virginia Kocieda implements the BOH-ARP. Ms. Kocieda expressed similar concerns as other interviewees about the transition to the O&M phase, how land-use changes will be managed going forward, and how best to communicate risk in simple language. In her capacity implementing the BOH-ARP, some community members have complained about property damage or issues with cleanup (both too much and not enough). She believes the focus going forward should be on how people can maintain the remedy on their properties. Dallas Carr, Mayor of Troy, feels the cleanup in Troy has been professional. Some community members have not been satisfied with the fill material used to restore their properties. Overall, he feels the EPA did a good job with the cleanup and restoration. WR Grace provided responses specifically related to OU 2 and OU4. Responses indicate WR Grace considers the remedies for OU2 and OU4 to be adequate and noted no significant issues with implementation or maintenance. Data Review The EPA has collected soil and contaminated building material data to support the pre-ROD removal actions and remedy implementation at OUs 4, 5, 6, 7 and 8 during this FYR period. These data are discussed in the Response Action and Status of Implementation sections of this FYR Report. No other data have been collected at the Site during this FYR period. Site Inspection The site inspection took place from August 20, 2019 through August 22, 2019. Participants included EPA RPMs Dania Zinner and Mike Cirian, EPA CIC Katherine Jenkins, and Alison Cattani and Ryan Burdge from EPA FYR support contractor Skeo. The purpose of the inspection was to assess the protectiveness of the remedies selected and implemented at OUs 1, 2, 4, 5, 6, 7 and 8. The EPA led a site tour on August 20, 2019, during which site inspection participants observed the current status of OUs 1, 2, 4, 5, 6 and 8. At OU1, site inspection participants observed the remediated areas, which include the Riverfront Park property, David Thompson Search and Rescue, and embankments along roadways. Site inspection participants observed the protective covers present on OU1 properties; the covers were in good condition and well vegetated. At OU2, site inspection participants observed the associated subareas where covers were employed. Several subareas owned by private parties were not accessible, but the remedy could be observed from the roadways. All subareas appeared to be in good condition with covers intact.

27

Site inspection participants drove around the town of Libby to observe several properties that were part of the OU4 cleanup activities. The properties generally seem to be well maintained and there was no indication of issues with the implemented remedy. At OU5, site inspection participants observed the Former Stimson Lumber property, which is currently owned by LCPA. OU5 currently consists of various vacant structures and buildings as well as multiple businesses. During the inspection, there was no indication of issues with the implemented remedy. Site inspection participants observed the BNSF railroad (OU6) and the highways and ROWs (OU8). They did not observe any issues with the implemented remedy. On August 22, 2019, site inspection participants travelled to Troy, Montana, to observe the remedy status and implementation for OU7. During the inspection, participants observed an active remediation of a home in Troy. Several other remediated properties were also observed. For each OU, a checklist was completed (Appendix F) and photos were taken (Appendix G). V. TECHNICAL ASSESSMENT QUESTION A: Is the remedy functioning as intended by the decision documents? Overall, the remedies at OUs 1, 2, 4, 5, 6, 7 and 8 are functioning as intended by their respective decision documents. Where access was granted or for soils and buildings requiring remediation, LA-contaminated soil and building materials were remediated to meet site-specific RALs and remedial clearance criteria. The site-specific RALs and remedial clearance criteria were based on the type of contaminated media (building materials versus soil), land-use categories, depth of contaminated soil or accessibility of contaminated building material, use frequency of contaminated soil, and the identification of boundary conditions. A sitewide HHRA in 2015 indicated that previous removal actions and the RALs and clearance criteria are protective. The remedial actions have been completed at OU1, OU2 and OU4 through OU8. OU1, OU2, OU5 and OU8 have transitioned into the O&M phase. OU2 has been in the O&M phase since 2015, and there are no issues indicating the remedy is not functioning effectively. During the FYR site inspection, there were no issues observed that affect the protectiveness of the remedy. The annual inspection at OU5 identified several potential issues with the remedy including exposed spray foam in an encapsulated area, an area with no barrier where LCPA removed vermiculite soils, and uncapped slopes near the fishing pond potentially accessible by wildlife. The EPA finalized the O&M plan for OU4 and OU7 in April 2020 after a 30-day public comment period and with a responsiveness summary. The end of O&F and start of O&M in OUs 4 and 7 is July 1, 2020 at which time O&M responsibilities will transfer from EPA to MDEQ. During this FYR several people associated with OU4 and OU7, including county commissioners and property owners, voiced concerns about the transition of O&M responsibilities to MDEQ and Lincoln County. The OUs 4 and 7 O&M plan contains information on the funding mechanisms and the procedures for implementing additional remedial actions that may be required. The next FYR will evaluate the effectiveness of the O&M plan at OUs 4 and 7. The first annual inspection of OUs 4 and 7 will occur in 2021. Property owners at OU5 expressed concern about how land-use change could impact the need for future remedial action and how effective the O&M plan will be for tracking the remedy effectiveness. The effectiveness of the O&M procedures and the impacts of land-use change will continue to be evaluated as part of the annual inspection and as part of the FYR process. Institutional controls in the form of U-Dig and the BOH-ARP have been implemented and apply to all OUs. Encroachment permits are also in place in OU8. Additional institutional controls are in place for OU4 and OU7,

28

including the Property Evaluation Notification regulation and the notices of environmental conditions. A draft environmental covenant has not yet been filed for OU5. Efforts are underway to implement the environmental covenant. In addition, the OU 4-8 ROD indicated that EPA would complete an ESD documenting the ICIAP and the specific institutional control instruments for these OUs. The ESD for OU8 is underway and should be completed in the summer of 2020. And ESD documenting the ICs for OUs 4-7 will be completed by the next FYR. QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels and RAOs used at the time of the remedy selection still valid? The exposure assumptions, cleanup levels and RAOs used at the time of the remedy selection are still valid. EPA conducted an HHRA for the Site in 2015. The exposure assumptions have not changed and remain to be inhalation and ingestion exposure routes under the current and expected future land-use scenarios (non-OU3 areas): residential/commercial, industrial, transportation corridors and parks/schools. The RALs and clearance criteria are site-specific and based on land use (soil) and accessibility (building materials). The RAOs minimize exposure to LA-contaminated soil and building materials such that the resulting potential exposure results in cumulative cancer risks that are within or below the EPA’s acceptable risk range of 1x10-6 to 1x10-4 and cumulative non-cancer HIs that are at or below 1. The site-specific RALs and clearance criteria selected in the RODs attain the RAOs for the current and future anticipated land uses for non-OU3 areas of the Site. Since the EPA issued the RODs and the HHRA, there have not been any updates to toxicity or risk assessment methods for LA asbestos that affect the remedy implemented at the Site. EPA expects that the selected remedy will address ecological risk, because it completely cuts off all exposure pathways. An ecological risk assessment is being developed for the mine site (OU3). EPA will build upon the information gathered during that ecological risk assessment to identify potential pathways and receptors to evaluate ecological risk at other OUs. While general exposure scenarios remain valid, there are community concerns that land-use changes will occur that require additional removal actions in certain areas of the Site. This is especially relevant in OU5, which consists of several commercial and industrial operations and areas that are available for development. Several areas of OU5 have LA-contaminated soil remaining in place that will need to be addressed if further development occurs or if current operations change. Although more unlikely due to terrain, non-use areas might be considered for redevelopment in the future as well. QUESTION C: Has any other information come to light that could call into question the protectiveness of the remedy? No other information has come to light that could call into question the protectiveness of the remedy.

29

VI. ISSUES/RECOMMENDATIONS

Issues/Recommendations

OU(s) without Issues/Recommendations Identified in the FYR:

1,2,4,6,7,8

Issues and Recommendations Identified in the FYR:

OU(s): 5 Issue Category: Institutional Controls

Issue: An environmental covenant has not yet been filed for OU5.

Recommendation: Finalize and implement remaining institutional control at OU5.

Affect Current Protectiveness

Affect Future Protectiveness

Party Responsible

Oversight Party Milestone Date

No Yes EPA/State

EPA 6/30/2022

OTHER FINDINGS Additional recommendations were identified during the FYR. These recommendations do not affect current and/or future protectiveness.

• Once all institutional controls are finalized, conduct outreach with community and local government to ensure all are aware of the measures in place to ensure no unacceptable exposures.

• The annual inspection at OU5 identified several potential issues with the remedy including exposed spray foam in an encapsulated area, an area with no barrier where LCPA removed vermiculite soils, and uncapped slopes near the fishing pond potentially accessible by wildlife. The covers and barriers will be monitored and maintained to prevent exposures.

• EPA will issue ESDs to document institutional controls for OUs 4-8.

VII. PROTECTIVENESS STATEMENT

Protectiveness Statement(s)

Operable Unit: 1

Protectiveness Determination: Protective

Protectiveness Statement: The remedy at OU1 is protective of human health and the environment.

Protectiveness Statement(s)

Operable Unit: 2

Protectiveness Determination: Protective

Protectiveness Statement: The remedy at OU2 is protective of human health and the environment.

30

Protectiveness Statement(s)

Operable Unit: 4

Protectiveness Determination: Protective

Protectiveness Statement: The remedy at OU4 is protective of human health and the environment.

Protectiveness Statement(s)

Operable Unit: 5

Protectiveness Determination: Short-term Protective

Protectiveness Statement: The remedy at OU5 currently protects human health and the environment because remedial actions have been completed, LA-contaminated soil and building materials were remediated to meet site-specific RALs and remedial clearance criteria, and some institutional controls have been implemented to protect the remedy. However, for the remedy to be protective in the long-term, the remaining institutional control, an environmental covenant, should be finalized.

Protectiveness Statement(s)

Operable Unit: 6

Protectiveness Determination: Protective

Protectiveness Statement: The remedy at OU6 is protective of human health and the environment.

Protectiveness Statement(s)

Operable Unit: 7

Protectiveness Determination: Protective

Protectiveness Statement: The remedy at OU7 is protective of human health and the environment.

Protectiveness Statement(s)

Operable Unit: 8

Protectiveness Determination: Protective

Protectiveness Statement: The remedy at OU8 is protective of human health and the environment.

VIII. NEXT REVIEW The next FYR Report for the Libby Asbestos Site Superfund site is required five years from the completion date of this review.

A-1

APPENDIX A – REFERENCE LIST Annual O&M Report, Former Screening Plant and Surrounding Properties, Operable Unit 2, Fall 2014, Libby Asbestos Superfund Site, Libby, Montana. Prepared by USACE. December 2014. Annual Operation & Maintenance Report, Former Export Plant/Riverfront Park, Operable Unit 1, Fall 2014, Libby Asbestos Superfund Site, Libby, Montana. Prepared by USACE. November 2014. Annual Operation & Maintenance Report, Libby Asbestos Superfund Site, OU1 Former Export Plant, Libby, Montana. Prepared by Weston Solutions. August 2018. Community Involvement Plan, Libby Asbestos Superfund Site, Libby, Montana. EPA. August 2016. Draft Final Institutional Control Implementation and Assurance Plan, Libby Asbestos Superfund Site, Libby Montana. EPA. October 2019. Final Feasibility Study Report, OU 4, 5, 6, 7 and 8, Libby Asbestos Superfund Site, Lincoln County, Montana. Prepared by CDM. May 2015. Final Operations and Maintenance Plan, Revision 0, OUs 4 and 7, Libby Asbestos Superfund Site, Lincoln County, Montana. Prepared by CDM. April 2020. Final Operations and Maintenance Plan, OU5 Former Stimson Lumber Mill, Libby Asbestos Superfund Site, Lincoln County, Montana. Prepared by CDM. February 2018. Final Operations and Maintenance Plan, OU8 Highways and Roadways, Libby Asbestos Superfund Site, Lincoln County, Montana. Prepared by CDM. August 2018. Final Post-Construction Human Health Risk Assessment, OU1 Former Export Plan. Prepared by CDM. October 2015. Final Remedial Action Report, Libby Asbestos Superfund Site Former Export Plant Site, Operable Unit 1, Lincoln County, Montana. Prepared by USACE. July 8, 2013. Final Remedial Action Report, Libby Asbestos Superfund Site, Former Screening Plant and Surrounding Properties, Operable Unit 2, Lincoln County, Montana. Prepared by USACE. April 20, 2012. Final Remedial Action Report, OU5 Former Stimson Lumber Mill, Libby Asbestos Superfund Site, Lincoln County, Montana. Prepared by USACE. September 2016. Final Remedial Action Report, OU8 Highways and Roadways, Libby Asbestos Superfund Site, Lincoln County, Montana. Prepared by CDM. September 2017. Institutional Control Implementation and Assurance Plan Revision 2, OU1 Former Export Plant. Prepared by CDM. July 2019. Institutional Control Implementation and Assurance Plan, The Former Export Plant, Operable Unit 1, Libby Asbestos Superfund Site, Libby, Montana. Prepared by CDM. February 2014. Institutional Control Implementation and Assurance Plan, OU5 Former Stimson Lumber Mill, Libby Asbestos Superfund Site, Lincoln County, Montana. EPA. August 2016.

A-2

Institutional Control Implementation and Assurance Plan, OU8 Highways and Roadways, Libby Asbestos Superfund Site, Lincoln County, Montana. EPA. August 2017. Institutional Control Implementation and Assurance Plan, Revision 1, Former Screening Plant and Nearby Areas, Operable Unit 2, Libby Asbestos Superfund Site, Libby, Montana. EPA. February 2014. Operable Units 4 and 7, Institutional Control Implementation and Assurance Plan, Libby Asbestos Superfund Site, Libby, Montana. EPA. March 2020. Operation and Maintenance Plan Revision 2, OU1 Former Export Plant. Prepared by CDM. July 2019. Operations and Maintenance Plan, Libby Asbestos Superfund Site Former Export Plant Site, Operable Unit 1, Lincoln County, Montana. Prepared by CDM. July 15, 2013. Operations and Maintenance Plan, Libby Asbestos Superfund Site Former Screening Plant and Surrounding Properties, Operable Unit 2, Lincoln County, Montana. Prepared by CDM. July 15, 2013. Preliminary Draft Institutional Control Implementation and Assurance Plan, OU 6, Libby Asbestos Superfund Site, Libby, Montana. Prepared by Kennedy Jenks. April 26, 2019. Preliminary Draft Remedial Action Report, OU 6, Libby Asbestos Superfund Site, Libby, Montana. Prepared by Kennedy Jenks. April 26, 2019. Record of Decision for Libby Asbestos Superfund Site, Former Export Plant, Operable Unit 1, Lincoln County, Montana. EPA. May 2010. Record of Decision for Libby Asbestos Superfund Site, Libby and Troy Residential and Commercial Properties, Parks and Schools, Transportation Corridors, and Industrial Park, OUs 4 through 8, Lincoln County, Montana. EPA Region 8. February 2016. Record of Decision for Libby Asbestos Superfund Site, Operable Unit 2 - Former Screening Plant and Surrounding Properties, Lincoln County, Montana. EPA. May 2010. Response Action Work Plan, Libby Asbestos Site, Libby, Montana. EPA. May 2010. Site-wide Baseline Ecological Risk Assessment for Exposure to Asbestos, Part 2 (Non-OU3), Libby Asbestos Superfund Site, Libby, Montana. Prepared by CDM. January 2015. Site-wide Human Health Risk Assessment, Libby Asbestos Superfund Site, Libby, Montana. Prepared by CDM. November 2015.

B-1

APPENDIX B – SITE CHRONOLOGY

Table B-1: Site Chronology

Event Date Hard rock mining began in Libby area 1880s Prospector located vermiculite deposits 1900s Zonolite Company began vermiculite mining on Rainy Creek claims 1919 W.R. Grace bought the Zonolite Company, including the mine and associated facilities, and operated until 1990

1963-1990

The Former Export Plant (OU1) was used for exfoliating, stockpiling and distributing vermiculite concentrate Concentrated ore produced by milling was transported to a screening plant (Former Screening Plant – OU2) OU2 was operated as a nursery 1993-2000 Ownership of OU1 was transferred to the City of Libby Mid-1990s The EPA opened Information Center in Libby 1999 The EPA completed studies and investigations at OU2 1998-2008 The EPA completed studies and investigations at OU1 1999-2007 Early OU1 and OU2 response actions conducted 2000-2008 Removal of LA-contaminated media in OU4 2001-2019 Millwork West Company buildings on OU1 demolished by W.R. Grace 2001 The EPA built a special cell in the Libby Class II Landfill for disposal of asbestos waste 2002 David Thompson Search and Rescue erected a building on the northwest portion of OU1 2004 The EPA conducted response action and supplemental response action at OU6 2004 and 2005 Removal of LA-contaminated media in OU7 2008-2019 The EPA completed the OU1 remedial investigation/feasibility study (RI/FS) report August 2009 The EPA completed the OU2 RI/FS report August 2009 The EPA completed the OU1 ROD May 10, 2010 The EPA completed the OU2 ROD May 10, 2010 The EPA completed the OU2 remedial design September 2010 The EPA completed the OU1 remedial design August 2011 The EPA completed the OU2 Remedial Action Report April 20, 2012 The EPA completed the OU5 RI Report June 2013 The EPA completed the OU1 Remedial Action Report July 8, 2013 The EPA issued the ICIAP for OU2 November 2013 The EPA issued the ICIAP for OU1 and updated the ICIAP for OU2 February 2014 The EPA completed the OU6 RI Report April 30, 2014 The EPA completed the OU4 RI Report June 25, 2014 The EPA issued the FS Report for OUs 4 through 8 May 2015 The EPA signed first FYR for OU1 and OU2 June 22, 2015 The EPA updated the ICIAP for OU1 and OU2 August 2015 The EPA completed the OU1 HHRA October 2015 The EPA completed the sitewide HHRA November 2015 The EPA completed the OU4, OU5, OU6, OU7, OU8 ROD February 8, 2016 The EPA issued the ICIAP for OU5 August 2016 The EPA completed the OU5 Remedial Action Report September 28, 2016 The EPA completed the OU8 Remedial Action Report September 27, 2017 The EPA issued the ICIAP for OU8 September 2017 The EPA updated the ICIAP for OU2 January 2018 The EPA updated the ICIAP for OU2 March 2018 The EPA updated the ICIAP for OU1 July 2019 The EPA completed the OU4 and OU7 Draft Remedial Action Completion Report November 2019 The EPA deleted OU2 from the NPL April 10, 2019 The EPA deleted OU1 from the NPL May 26, 2020 The EPA completed the OU4/OU7 Remedial Action Report June 30, 2020

C-1

APPENDIX C – SITE MAPS Figure C-1: OU1 Site Map1

1 Source: OU1 Remedial Action Report 2013

C-2

Figure C-2: OU1 Areas 1, 2, 32

2 Source: OU1 Remedial Action Report 2013

C-3

Figure C-3: OU1 Locations of Residual Contamination3

3 Source: OU1 Remedial Action Report 2013

C-4

Figure C-4: OU1 Remedial Components4

4 Source: 2015 FYR

C-5

Figure C-5: OU2 Site Map5

5 Source: OU2 O&M Plan 2015

C-6

Figure C-6: OU2 Site Layout6

6 Source: OU2 O&M Plan 2015

C-7

Figure C-7: OU2 Remedy Components7

7 Source: OU2 O&M Plan 2015

C-8

Figure C-8: OU2 Locations of Residual Contamination8

8 Source: OU2 O&M Plan 2015

C-9

Figure C-9: OU4 Geographic Removal Zone (GRZ) Areas and Removal Zones9

9 Source: 2016 OUs 4 through 8 ROD

C-10

C-11

C-12

C-13

C-14

C-15

C-16

C-17

C-18

C-19

C-20

C-21

C-22

C-23

C-24

C-25

C-26

C-27

C-28

Figure C-10: OU5 Ownership and Land Use10

10 Source: OU5 Remedial Action Report 2016

C-29

Figure C-11: OU5 Surface Soil LA and Visible Vermiculite Areas11

11 Source: OU5 Remedial Action Report 2016

C-30

Figure C-12: OU5 Subsurface Soil LA and Visible Vermiculite Areas12

12 Source: OU5 Remedial Action Report 2016

C-31

Figure C-13: OU5 Subsurface Soil LA and Visible Vermiculite Insets13

13 Source: OU5 Remedial Action Report 2016

C-32

Figure C-14: OU6 Response Action Zones and LA in Surface Soil at BNSF Libby Railroad14

14 Source: 2016 OUs 4 through 8 ROD

C-33

Figure C-15: OU6 LA and Visible Vermiculite in Surface Soil with Right-of-Way15

15 Source: 2016 OUs 4 through 8 ROD

C-34

Figure C-16: OU7 GRZ Areas and Removal Zones16

16 Source: 2016 OUs 4 through 8 ROD

C-35

Figure C-17: OU8 LA in Surface Soil17

17 Source: 2016 OUs 4 through 8 ROD

C-36

Figure C-18: OU8 Visible Vermiculite in Surface Soil18

18 Source: 2016 OUs 4 through 8 ROD

D-1

APPENDIX D – PRESS NOTICE

The U.S. Environmental Protection Agency, Region 8 Announces the Second Five-Year Review for the Libby Asbestos Superfund Site, Libby, Montana

The U.S. Environmental Protection Agency (EPA), in cooperation with the Montana Department of Environmental Quality (DEQ), is conducting the second five-year review of the Libby Asbestos Superfund site (the Site) in Libby, Montana. The purpose of the five-year review (FYR) is to make sure that the cleanup actions completed to date are adequately protecting human health and the environment. The five-year review is scheduled to be completed by June 2020. The Site encompasses and surrounds the cities of Libby and Troy, Montana. EPA added the Site to the National Priorities List (NPL) in 2002. Historic mining, milling, and processing of vermiculite in Libby are known to have caused releases of vermiculite and tremolite-actinolite series asbestos to the environment. As of August 2019, EPA has implemented cleanup plans for all portions of the site except for the former mine site and forested areas that make up Operable Unit (OU) 3. The 2015 FYR assessed OU1 (former export plant) and OU2 (former screening plant) and determined the removals, land use controls and site monitoring implemented at these OUs were protective of human health and the environment. The 2020 FYR will assess the status and protectiveness of all OUs except for OU3. We want to hear from you! Community members are always encouraged to share information that may help EPA make determinations regarding the protectiveness and effectiveness of the remedies at the site. On August 21st from 3:00-4:00, EPA staff will be hosting in-person interviews at the EPA Information Center (108 E 9th St, Libby, MT 59923). You may also contact EPA if you would like to send your comments: Katherine Jenkins, EPA Community Involvement Coordinator Phone: 303-312-6351 Email: jenkins.katherine@epa.gov Mailing Address: U.S. EPA Region 8 (EPR-SR) 1595 Wynkoop Street, Denver, CO 80202-1129 Additional site information is available at: Lincoln County Library – Libby 220 W. Sixth Street Libby, MT 59923 (406) 293-2778 Lincoln County Library – Troy 3rd and Kalispell Troy, MT 59935 (406) 295-4040 EPA Superfund Records Center 1595 Wynkoop Street Denver, CO 80202-1129 303-312-7273 Or online at: www.epa.gov/superfund/libby-asbestos

E-1

APPENDIX E – INTERVIEW FORMS Libby Asbestos Site Superfund Site Five-Year Review Interview Form Site Name: Libby Asbestos Site EPA ID No.: MT0009083840

Interviewer Name: Katherine Jenkins Affiliation: EPA Subject Name: Jerry Bennett Affiliation: Lincoln County

Commissioner Subject Contact Information: Time: 9:00 a.m. Date: 08/21/2019 Interview Location: EPA Information Center

Interview Format (circle one): In Person Phone Mail Other:

Interview Category: Local Government 1. What is your overall impression of the remedial activities at the Site?

I think it has been good, but there have been some things over the years that I’ve questioned. I saw a change in how EPA operated and didn’t appreciate it.

2. What is your overall impression of the project, including cleanup, maintenance and reuse activities (as appropriate)? Well, overall, I think EPA has done a lot of good work. I question some things that have been left. I have heard comments from local residents indicating some things haven’t been addressed. One example, I used to own a septic tank company and had a customer who had a system that was backing up. I talked to EPA, and EPA over-compacted the soil, which creates issues for a drain field. EPA did not agree, and the resident needed a new system. CDM was good about notifying me if they thought there was an issue. When the U.S. Army Corps of Engineers (USACE) took over, they never called. He thinks things likely broke and weren’t addressed.

a) Can you think of anything EPA could have done during the cleanup to better communicate if there were any risks associated with the site (as appropriate, if individual was present during cleanup)? Not really. I think they were good at informing the local people about the risk at the Site. There have been questions in the past about fencing being used to communicate risk (when there is an airborne contaminant). I think EPA could have gone further with explaining that process.

b) How do you learn about what’s happening at the Site now? Since EPA isn’t present, I don’t know much about what is happening. There is no contract in place for the transition of O&M responsibilities from EPA to Lincoln County. The county wants to help but doesn’t have a contract in place to do that.

c) Do you feel like EPA does a good job explaining the difference between whether there are risks to people and whether the cleanup is working well? Yes, EPA has done a good job explaining the remedy. A lot of folks have a problem with the remedy and are just not sure what to do if they need to remodel their house or commercial properties (the Port) where maybe the remedy wasn’t sufficient. The levy at the Port had a one-year warranty but it washed out within three to four years. This left the county with a large bill to fix it.

E-2

3. What is your assessment of the current performance of the remedy in place at the Site?

It depends on the use and area. I have 40 acres, and EPA has inspected it. Folks have run into issues where a land-use change has caused issues with the bank. Either the property is clean, or it is not. There are some potential future issues with land-use restrictions.

4. Are you aware of any complaints or inquiries regarding environmental issues or the remedial action from

residents since implementation of the cleanup? I used to live near the Screening Plant and Riverfront Park. Now, I live somewhere else and had used soil from the Screening Plant. EPA stopped 4 feet short of the edge of my garden because they said there was no visible LA. It feels like they weren’t listening and did not remove material that I knew contained ore. I’m concerned that this could be a sign of missed ore material at other properties.

5. Have there been any problems with unusual or unexpected activities at the Site, such as emergency response,

vandalism or trespassing? It is a big site; without 24-hour security there are going to be issues. There is nothing that I can pinpoint.

6. Do you feel the community is well-informed regarding the Site’s activities and remedial progress? If not, how

might EPA convey site-related information in the future? It is a two-edged sword. EPA could make a lot of effort, and people aren’t interested unless they are directly affected. I think there’s been a lot of communication and numerous meetings. Each individual is different.

7. Do you have any comments, suggestions or recommendations regarding any aspects of the project? As a commissioner, I am really concerned with the issue with the levy and folks having issues on their properties. Funding needs to be secured. If some of these issues can’t be resolved, the county is concerned it will be left holding the bag. It is important that EPA gets this settled to get contracts in place for long-term maintenance of the Site. Every day something is going to come up (remodeling houses, digging water lines, etc.). Libby is struggling economically. Land-use restrictions need to get figured out. Do properties need to get retested for a change in use? Are properties that have been cleaned up cleared for all uses? I feel that EPA generally did a good job, but a lot of money was wasted in the cleanup of Rainy Creek. I felt that a lot of EPA contractors weren’t paying the local contractors on time.

E-3

Libby Asbestos Site Superfund Site Five-Year Review Interview Form Site Name: Libby Asbestos Site EPA ID No.: MT0009083840

Interviewer Name: Katherine Jenkins Affiliation: EPA Subject Name: Brent Tenske Affiliation: City of Libby Mayor Subject Contact Information: Time: 1:30 p.m. Date: 08/21/2019 Interview Location: City Hall

Interview Format (circle one): In Person Phone Mail Other:

Interview Category: Local Government 1. What is your overall impression of the remedial activities at the Site?

Overall, I’m happy with how things have been going lately. In the past, there was a lot of uncertainty with cleanup techniques. Toward the end, I think EPA was doing good work with fewer issues.

2. What is your overall impression of the project, including cleanup, maintenance and reuse activities (as appropriate)? For maintenance, once the financing issues are resolved and there’s a plan going forward, it will be a big boost. From the city’s perspective, I am not sure how it will look in the future for the city to do the work needed to maintain the remedy. People are conscientious of it and ARP is getting a lot of calls through U-Dig. Reuse is going fine; the port is a huge piece of property that is available for use. For individual homeowner reuse, there haven’t been any major complaints.

a) Can you think of anything EPA could have done during the cleanup to better communicate if there were any risks associated with the Site (as appropriate, if individual was present during cleanup)? There were a lot of unknowns; a lot of things that were discussed and changed, and that made people doubt EPA. EPA had a lot of meetings and used to fill auditoriums; now no one shows up to the meetings.

b) How do you learn about what’s happening at the Site now? Emails, information from BOH, and public meetings work for me personally. The public is only interested when people are directly affected.

c) Do you feel like EPA does a good job explaining the difference between whether there are risks to people and whether the cleanup is working well? They’ve done a good job from EPA’s perspective, but it still wasn’t clear enough for the layperson. Folks don’t understand that there is risk and things aren’t going to be 100% clean or gone. I am not sure there is another way to communicate it more effectively. EPA may have been able to make it more accessible or understandable to the layperson.

3. What is your assessment of the current performance of the remedy in place at the Site? I think it is working. I haven’t heard of any major exposure or avenue of exposure. The city is installing service lines, which was easy in the past because they had CDM, but I am not sure how that will look in the future. A new person may not know about the procedures. Are people following it? I am not sure if people are

E-4

following it when remodeling their homes. A long-term issue going forward is getting people to adhere to the process.

4. Are you aware of any complaints or inquiries regarding environmental issues or the remedial action from residents since implementation of the cleanup? The chief complaint was why some material was left, some was encapsulated and some was removed. Residents had complaints about the compacted soil used as backfill. Some people complained that EPA cleaned up vermiculite that wasn’t LA, which made the EPA look incompetent.

5. Have there been any problems with unusual or unexpected activities at the Site, such as emergency response,

vandalism or trespassing? Not that I’m aware of. At Riverfront Park, it’s almost impossible to get below the cap. There was structural vandalism on the port property that didn’t pertain to the Site.

6. Do you feel the community is well-informed regarding the Site’s activities and remedial progress? If not, how

might EPA convey site-related information in the future? People are well informed, but they may not have taken it all in or may have lost interest. The information is out there. EPA did a good enough job. I am not sure if the people have trust in it.

7. Do you have any comments, suggestions or recommendations regarding any aspects of the project? I would like to get OU1 delisted. All digs have gone according to plans. They need to tie up loose ends with the Site. Personally, everyone I’ve worked with has been good.

E-5

Libby Asbestos Site Superfund Site Five-Year Review Interview Form Site Name: Libby Asbestos Site EPA ID No.: MT0009083840

Interviewer Name: Katherine Jenkins Affiliation: EPA Subject Name: Tina Oliphant and Brett Affiliation: Lincoln County Port

McCully Authority Subject Contact Information: Time: 2:00 p.m. Date: 08/21/2019 Interview Location: Port Authority Main Office

Interview Format (circle one): In Person Phone Mail Other:

Interview Category: Local Government 1. What is your overall impression of the remedial activities at the Site?

The Site is 400 acres, a large area; how would anyone test it all? We don’t know what the future will hold. A couple of things during the process were alarming. We had to request additional sampling because of land-use classification changes. Since then, we have found out that part of the remediation was not up to snuff. A portion of the remedy failed on the bank of the river. We had to prove at our cost that it was a failure of the remedy. It was very expensive; we had to hire an engineer and prove that EPA made a mistake. This bank had been stable for 30 years, and the replacement bank failed. EPA will not take responsibility. This was a reflection of how EPA does work. We feel that it was inadequate. That has brought in some anxiety about the future of the remaining portions of the remedy. We want to attract outside investors but don’t have confidence in the remedy.

2. What is your overall impression of the project, including cleanup, maintenance and reuse activities (as appropriate)? We recognize that this was a tricky project and EPA kept changing its actions in response. We have had a personal experience at OU4. We are shocked with EPA’s transition out of town. After spending $600 million, EPA couldn’t figure out how to make a careful, methodical transition and make sure ARP was fully prepared for the transition. It was not the county’s job to figure it out. That was EPA’s job and it didn’t follow through. In OU4, property owners were caught up in that with a lot of finger pointing. In general, the transition went badly. In OU5, we have a pretty good plan of attack for reuse. There is a pocket of LA in a low-use area that is now in a higher-use area. EPA put it back and covered it and said it wasn’t worth going after. We don’t understand why EPA wouldn’t take it out. This is reflective of the EPA culture. It feels like EPA is trying to get out of spending money to fully remediate. OU5 was a little ahead of the game. We created a land evaluation form that is now used by ARD. Land-use change is a big concern. If you live in this area and purchase a home, you are going to want to do something to it. In terms of the O&M process, OU5 is ahead of everyone. We provided revisions and comments on a draft O&M plan. We were disappointed in the content of the draft O&M Plan. Documents were signed before all our questions were answered, and we felt like our comments weren’t being heard or addressed. The current OU5 O&M plan is ambiguous. We don’t feel like the document will ever be changed or used going forward. The property owners are trying to get outside investors, and the O&M Plan is not clear, which will affect how the property is seen to potential investors. Our main questions are what is allowed, what isn’t allowed, and what is more of a gray area.

a) Can you think of anything EPA could have done during the cleanup to better communicate if there were any risks associated with the Site (as appropriate, if individual was present during cleanup)?

E-6

We feel well aware of the risk and don’t think there is anything more EPA could have done.

b) How do you learn about what’s happening at the Site now? We are on the OU4 Institutional Control Steering Committee so we are well aware of establishing guiding principles. We would like to see the task force communicating better. We recommend advertising in advance and making sure it reaches people. There used to be an email list that went to people in the town. The Department of Tourism does a good job with an email list. It should be a regular email that goes out.

c) Do you feel like EPA does a good job explaining the difference between whether there are risks to people and whether the cleanup is working well?

EPA was good about explaining the risks. EPA has a lot of half-truths on whether the cleanup is working well. There should be proactive discussion on land use and cleanups. Instead, there was a lot of defensive behavior. We feel that EPA felt it did a good job but if the cleanup isn’t complete, it isn’t complete.

3. What is your assessment of the current performance of the remedy in place at the Site?

The remedy has not been tested but is about to be tested because people want to do stuff to their property and that procedure isn’t in place. Removal and encapsulation are fine, but there is no process or path forward for improving an asset. The remedy overall is pretty well done but the future is unclear. The OU5 remedy is generally working well, but there are areas of remaining contamination. EPA’s hesitation to say let us come back and deal with this, or we have the money to give you for you to deal with it, is a concern. EPA is unwilling to set that up. We feel unsupported by the process. We feel like we have to fight for everything. It is already a risk to come to little Libby; it is naïve and problematic to expect private business or homeowners to move to Libby and deal with it.

4. Are you aware of any complaints or inquiries regarding environmental issues or the remedial action from residents since implementation of the cleanup?

More contamination will continue to be found due to land-use change. We were impressed personally with residential remediation in OU4/OU7.

5. Have there been any problems with unusual or unexpected activities at the Site, such as emergency response, vandalism or trespassing? We have that in general in OU5, but nothing related to the Superfund site.

6. Do you feel the community is well-informed regarding the Site’s activities and remedial progress? If not, how might EPA convey site-related information in the future? There’s a lot of burnout in this town. Until someone has a need or encounters something, there is not much interest.

7. Do you have any comments, suggestions or recommendations regarding any aspects of the project? No other comments.

E-7

Libby Asbestos Site Superfund Site Five-Year Review Interview Form Site Name: Libby Asbestos Site EPA ID No.: MT0009083840

Interviewer Name: Katherine Jenkins Affiliation: EPA Subject Name: Lisa Dewitt Affiliation: MDEQ Subject Contact Information: Time: 4:00 p.m. Date: 08/21/2019 Interview Location: EPA Information Center

Interview Format (circle one): In Person Phone Mail Other:

Interview Category: MDEQ 1. What is your overall impression of the remedial activities at the Site?

It has gone forward and done what it intended to do. OU2 has been delisted and OU1 is on its way to delisting. The challenges ahead is getting institutional controls in place to move ahead to the O&M phase for all OUs.

2. What is your overall impression of the project, including cleanup, maintenance and reuse activities (as appropriate)? I believe it has been positive. OU1 reuse is a widely used public park that is beneficial to the community. OU5 needs an environmental covenant and then EPA can delist it, which may assist in attracting businesses. The community wants to move past being a Superfund site, but it may be a difficult transition to the O&M phase since EPA will not be available.

a) Can you think of anything EPA could have done during the cleanup to better communicate if there were any risks associated with the Site (as appropriate, if individual was present during cleanup)?

There was a huge effort to communicate risk, but it is difficult to explain remaining risk for the Site. Getting into lay language is difficult but everything that could be done was done.

b) How do you learn about what’s happening at the Site now?

It is my job to oversee O&M activities and that is part of my daily work.

c) Do you feel like EPA does a good job explaining the difference between whether there are risks to people and whether the cleanup is working well?

There can be improvement on this. For a while, people on the street thought one fiber of asbestos could kill you. Dealing with the community, some members think more can be done and some think too much has been done. Going forward, EPA and MDEQ will need to keep sharing information with the community about risk.

3. What is your assessment of the current performance of the remedy in place at the Site?

The remedy appears to be performing correctly. Without doing additional activity-based sampling, it is difficult to know for sure, but it has met the remedial goals in the ROD. The challenge going forward is getting the institutional controls in place.

E-8

4. Has your office conducted any site-related activities or communications in the past five years? If so, please describe the purpose and results of these activities. MDEQ has been actively involved in all activities at the Site, performing its responsibilities as the supporting agency.

5. Are you aware of any complaints or inquiries regarding environmental issues or the remedial action from residents since implementation of the cleanup? Yes, a variety of residents have not been satisfied with cleanup. In some instances, there was additional action warranted and some were not remedy specific.

6. Have there been any problems with unusual or unexpected activities at the Site, such as emergency response, vandalism or trespassing? Not that I’m aware of.

7. Do you feel the community is well-informed regarding the Site’s activities and remedial progress? If not, how might EPA convey site-related information in the future? I think EPA does a great job in relaying the information, although more can always be done. More information is needed going forward about what being in the O&M phase means. EPA needs to communicate how the O&M transition to MDEQ and Lincoln County will happen.

8. Do you have any comments, suggestions or recommendations regarding any aspects of the project? A lot of good work has been done, and we just need to maintain what has been done.

E-9

Libby Asbestos Site Superfund Site Five-Year Review Interview Form Site Name: Libby Asbestos Site EPA ID No.: MT0009083840

Interviewer Name: Katherine Jenkins Affiliation: EPA Subject Name: Virginia P. Kocieda Affiliation: Lincoln County ARP Subject Contact Information: Time: Date: 08/21/2019 Interview Location: EPA Information Center

Interview Format (circle one): In Person Phone Mail Other:

Interview Category: Local Government 1. What is your overall impression of the remedial activities at the Site?

My focus is OU4 and OU7. I have been involved with ARP and working with EPA to make sure the last of the quick responses have been completed. ARP is trying to serve the community to get them the resources while there is still a cooperative agreement. Nothing has come up at the other OUs. Some city maintenance has been done at OU1. ARP goes out to OU1 and makes sure they are aware of the process. Early in the year, ARP was trying to figure out how they would deal with the process of bringing business to OU5 and how ARP would organize a response to prospective businesses.

2. What is your overall impression of the project, including cleanup, maintenance and reuse activities (as appropriate)? I was here at the end of the cleanup. I took a closer look at property files, and it seemed like it was a fast pace to get cleanup done. I think EPA, CDM and USACE did the best they could do with a massive cleanup issue. As the situation was understood more fully, the process changed accordingly. Maintenance is just starting, which has also been fast-paced due to government shutdown and other issues. I want to make sure all the details are reviewed, and the county’s questions are answered, with guidance on how to answer questions from the community and process for maintenance going forward. What can Lincoln County do in the O&M phase? What are the responsibilities of the homeowner? What are the responsibilities of the county? I think land-use change is a very interesting conversation that is going on. When is additional sampling needed? I want to see those questions answered definitively. The future of Libby and Troy is land-use changes.

a) Can you think of anything EPA could have done during the cleanup to better communicate if there were any risks associated with the Site (as appropriate, if individual was present during cleanup)?

Risk assessment came after the cleanup and ROD. I don’t really have an answer for that. Going forward, it will be relevant to go back to the HHRA in the ROD to adapt to how things will change with future land-use changes.

b) How do you learn about what’s happening at the Site now?

It is my job to know. I refer to EPA webpages and site documents. ARP posts a warning to its website and to newspapers. The library has an administrative record that ARP explores occasionally. I figured EPA would be the main site for answering any questions. I have a science background, so I can understand risk and exposure.

c) Do you feel like EPA does a good job explaining the difference between whether there are risks to people and whether the cleanup is working well?

E-10

I think there is a level of understanding within the community about the difference between these two things. Explaining the difference is a difficult job. I have heard of risk assessors coming in to explain it. It is hard to make sense of it and translate it to laypeople.

3. What is your assessment of the current performance of the remedy in place at the Site?

It is hard to maintain the remedy, and ARP’s job is to make it clear to residents how to maintain the remedy on individual properties. It is a big challenge for the Site.

4. Are you aware of any complaints or inquiries regarding environmental issues or the remedial action from residents since implementation of the cleanup? There are always people who are complaining and unhappy. There are general complaints about property damage or about how there is not enough cleanup or too much cleanup. I go into the property records and can see that it is usually all historical commentary. ARP is a county program to serve the community to help maintain remedies at their properties. Through September 30, ARP has funds to help homeowners, but after that it will change.

5. Have there been any problems with unusual or unexpected activities at the Site, such as emergency response, vandalism or trespassing? There has been some trespassing at OU3, but not at other OUs.

6. Do you feel the community is well-informed regarding the Site’s activities and remedial progress? If not, how might EPA convey site-related information in the future? For remedial work, yes. Right now, for O&M, I can’t give out certain information while it is still being negotiated, which is hard to work around. ARP gives updates to BOH, O&M groups and the Institutional Control Steering Committee. All of these updates are open to the public.

7. Do you have any comments, suggestions or recommendations regarding any aspects of the project? This is a hard project. It is hard to understand the limits and how far EPA can go to remove contamination. What’s done is done, and I think it is important for people to know how to maintain the remedy on their properties and that it may involve limitations. It shouldn’t be a burden anymore, and it is time to move on. The ordinance is not yet passed. The ordinance will be a county ordinance about a notification process. When people start doing work, they don’t realize there may be LA on their property. If a resident applies for a building permit or something to alter a property, this notification ordnance will help communicate how to move forward. The other part will be for new subdivisions (new land use). If land use changes for an area, the county needs to make sure the remedy is still protective. A county planner will be involved in review to assess for LA and provide information on additional sampling or potential reimbursement. It is still in discussion.

E-11

Libby Asbestos Site Superfund Site Five-Year Review Interview Form Site Name: Libby Asbestos Site EPA ID No.: MT0009083840

Interviewer Name: Ryan Burdge Affiliation: Skeo Subject Name: Dallas Carr Affiliation: Mayor of Troy Subject Contact Information: Time: 9:30 a.m. Date: 08/22/2019 Interview Location: City of Troy Office

Interview Format (circle one): In Person Phone Mail Other:

Interview Category: Local Government 1. What is your overall impression of the remedial activities at the Site (OU7)?

Overall, it’s been professional. Not many complaints, but sometimes individual properties have some minor issues with the remediation contractor hitting something, but they are usually good at fixing any issues.

2. What is your overall impression of the project, including cleanup, maintenance and reuse activities (as appropriate)? It’s OK. Everyone complains about the material that has been used, and it is poor. Doesn’t grow much. Usually the property looks pretty good after the cleanup.

a) Can you think of anything EPA could have done during the cleanup to better communicate if

there were any risks associated with the Site (as appropriate, if individual was present during cleanup)?

That’s up to the professionals. The average person doesn’t know about it. It should be up to the on-site person to be clear with the owner. Some of the properties were already bad and people’s homes were in bad shape. People did understand why it was happening.

b) How do you learn about what’s happening at the Site now?

It’s a small town, so by watching/being local. We see the remediation contractor come in, but do not get involved with any scheduling, and that’s fine. It is up to EPA to schedule, and it has worked well.

c) Do you feel like EPA does a good job explaining the difference between whether there are risks to people and whether the cleanup is working well?

Sometimes I questioned why EPA did things the way they did. I know from older citizens that some things were not done right. I would say something if I saw something not done right. The cleanup here was necessary.

3. What is your assessment of the current performance of the remedy in place at the Site?

I do not know how to judge it, but I trust the professionals and that cleanups were done well. See EPA at a property for a week, and they seem to spend a good amount of time at a cleanup. Sometimes I question why one thing was done versus another.

4. Are you aware of any complaints or inquiries regarding environmental issues or the remedial action from

residents since implementation of the cleanup?

E-12

The main complaints would be if there were any damage or they didn’t fix something. Some sewer damage, etc. The communication could have been better letting people know if something was damaged during the cleanup.

5. Have there been any problems with unusual or unexpected activities at the Site, such as emergency response,

vandalism or trespassing?

No, people generally know to avoid the areas.

6. Do you feel the community is well-informed regarding the Site’s activities and remedial progress? If not, how might EPA convey site-related information in the future? I think that privacy is important. At first, EPA went house to house and let people know some initial findings and explained the prioritization of where they were on the scale. General sources of information include newspapers such as Western News and Montanan, and the Troy city website gets a lot of use.

7. Do you have any comments, suggestions or recommendations regarding any aspects of the project? EPA helped the town and the EPA property rental helped. We got the space that EPA previously occupied rented again to a couple that is going to do a feed/grain retail business along with some other services.

E-13

E-14

F-1

APPENDIX F – SITE INSPECTION CHECKLIST OU1 and OU2

FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST

I. SITE INFORMATION

Site Name: Libby Asbestos Site Date of Inspection: 8/20/2019

Location and Region: Libby, Montana, 8 EPA ID: MT0009083840 Agency, Office or Company Leading the Five-Year Review: EPA Weather/Temperature: 80s, sunny

Remedy Includes: (Check all that apply) Landfill cover/containment Monitored natural attenuation Access controls Groundwater containment Institutional controls Vertical barrier walls Groundwater pump and treatment Surface water collection and treatment Other: Excavation, removal

Attachments: Inspection team roster attached Site map attached

II. INTERVIEWS (check all that apply) 1. O&M Site Manager

Name Title

Date

Interviewed at site at office by phone Phone: Problems, suggestions Report attached:

2. O&M Staff Name

Title

Date

Interviewed at site at office by phone Phone: Problems/suggestions Report attached:

3. Local Regulatory Authorities and Response Agencies (i.e., state and tribal offices, emergency response office, police department, office of public health or environmental health, zoning office, recorder of deeds, or other city and county offices). Fill in all that apply.

Agency MDEQ Contact Lisa Dewitt

Name MDEQ Project Manager Title

8/21/2019 Date

Phone No.

Problems/suggestions Report attached: Agency Lincoln County Contact Virginia P. Kocieda

Name BOH-ARP Title

8/21/2019 Date

Phone No.

Problems/suggestions Report attached: Agency Contact

Name Title

Date

Phone No.

Problems/suggestions Report attached: Agency Contact

Name Title

Date

Phone No.

F-2

Problems/suggestions Report attached: Agency Contact

Name Title

Date

Phone No.

Problems/suggestions Report attached:

4. Other Interviews (optional) Report attached:

III. ON-SITE DOCUMENTS AND RECORDS VERIFIED (check all that apply)

1. O&M Documents

O&M manual Readily available Up to date N/A

As-built drawings Readily available Up to date N/A

Maintenance logs Readily available Up to date N/A

Remarks:

2. Site-Specific Health and Safety Plan Readily available Up to date N/A

Contingency plan/emergency response plan

Readily available Up to date N/A

Remarks:

3. O&M and OSHA Training Records Readily available Up to date N/A

Remarks:

4. Permits and Service Agreements

Air discharge permit Readily available Up to date N/A

Effluent discharge Readily available Up to date N/A

Waste disposal, POTW Readily available Up to date N/A

Other permits: Readily available Up to date N/A

Remarks:

5. Gas Generation Records Readily available Up to date N/A

Remarks:

6. Settlement Monument Records Readily available Up to date N/A

Remarks:

7. Groundwater Monitoring Records Readily available Up to date N/A

Remarks:

8. Leachate Extraction Records Readily available Up to date N/A

Remarks:

9. Discharge Compliance Records

Air Readily available Up to date N/A

Water (effluent) Readily available Up to date N/A

F-3

Remarks:

10. Daily Access/Security Logs Readily available Up to date N/A

Remarks:

IV. O&M COSTS

1. O&M Organization

State in-house Contractor for state

PRP in-house Contractor for PRP

Federal facility in-house Contractor for Federal facility

2. O&M Cost Records

Readily available Up to date

Funding mechanism/agreement in place Unavailable

Original O&M cost estimate: Breakdown attached

Total annual cost by year for review period if available

From: Date

To: Date

Total cost

Breakdown attached

From: Date

To: Date

Total cost

Breakdown attached

From: Date

To: Date

Total cost

Breakdown attached

From: Date

To: Date

Total cost

Breakdown attached

From: Date

To: Date

Total cost

Breakdown attached

3. Unanticipated or Unusually High O&M Costs during Review Period Describe costs and reasons:

V. ACCESS AND INSTITUTIONAL CONTROLS Applicable N/A

A. Fencing

1. Fencing Damaged Location shown on site map Gates secured N/A Remarks:

B. Other Access Restrictions

1. Signs and Other Security Measures Location shown on site map N/A

Remarks:

C. Institutional Controls (ICs)

F-4

1. Implementation and Enforcement Site conditions imply ICs not properly implemented Yes No N/A

Site conditions imply ICs not being fully enforced Yes No N/A

Type of monitoring (e.g., self-reporting, drive by): Self-reporting Frequency: Annual Responsible party/agency: MDEQ

Contact

Name Title Date Phone no.

Reporting is up to date Yes No N/A

Reports are verified by the lead agency Yes No N/A

Specific requirements in deed or decision documents have been met Yes No N/A

Violations have been reported Yes No N/A

Other problems or suggestions: Report attached

2. Adequacy ICs are adequate ICs are inadequate N/A Remarks:

D. General

1. Vandalism/Trespassing Location shown on site map No vandalism evident Remarks:

2. Land-Use Changes On Site N/A

Remarks:

3. Land-Use Changes Off Site N/A

Remarks:

VI. GENERAL SITE CONDITIONS

A. Roads Applicable N/A

1. Roads Damaged Location shown on site map Roads adequate N/A Remarks:

B. Other Site Conditions

Remarks:

VII. LANDFILL COVERS Applicable N/A

A. Landfill Surface

1. Settlement (low spots) Location shown on site map Settlement not evident

Area extent: Depth:

Remarks:

2. Cracks Location shown on site map Cracking not evident

Lengths: Widths: Depths:

Remarks:

F-5

3. Erosion Location shown on site map Erosion not evident

Area extent: Depth:

Remarks:

4. Holes Location shown on site map Holes not evident

Area extent: Depth:

Remarks:

5. Vegetative Cover Grass Cover properly established

No signs of stress Trees/shrubs (indicate size and locations on a diagram)

Remarks:

6. Alternative Cover (e.g., armored rock, concrete) N/A

Remarks: Riprap in good condition in OU1

7. Bulges Location shown on site map Bulges not evident

Area extent: Height:

Remarks:

8. Wet Areas/Water Damage

Wet areas/water damage not evident

Wet areas Location shown on site map Area extent: Small area in parking lot

Ponding Location shown on site map Area extent: Small area in parking lot

Seeps Location shown on site map Area extent:

Soft subgrade Location shown on site map Area extent:

Remarks:

9. Slope Instability Slides Location shown on site map

No evidence of slope instability

Area extent:

Remarks:

B. Benches Applicable N/A (Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined channel.)

1. Flows Bypass Bench Location shown on site map N/A or okay

Remarks:

2. Bench Breached Location shown on site map N/A or okay

Remarks:

3. Bench Overtopped Location shown on site map N/A or okay

Remarks:

C. Letdown Channels Applicable N/A

F-6

(Channel lined with erosion control mats, riprap, grout bags or gabions that descend down the steep side slope of the cover and will allow the runoff water collected by the benches to move off of the landfill cover without creating erosion gullies.)

1. Settlement (Low spots) Location shown on site map No evidence of settlement

Area extent: Depth:

Remarks:

2. Material Degradation Location shown on site map No evidence of degradation

Material type: Area extent:

Remarks:

3. Erosion Location shown on site map No evidence of erosion

Area extent: Depth:

Remarks:

4. Undercutting Location shown on site map No evidence of undercutting

Area extent: Depth:

Remarks:

5. Obstructions Type: No obstructions

Location shown on site map Area extent:

Size:

Remarks:

6. Excessive Vegetative Growth Type:

No evidence of excessive growth

Vegetation in channels does not obstruct flow

Location shown on site map Area extent:

Remarks:

D. Cover Penetrations Applicable N/A

1. Gas Vents Active Passive

Properly secured/locked Functioning Routinely sampled Good condition

Evidence of leakage at penetration Needs maintenance N/A

Remarks:

2. Gas Monitoring Probes

Properly secured/locked Functioning Routinely sampled Good condition

Evidence of leakage at penetration Needs maintenance N/A

Remarks:

3. Monitoring Wells (within surface area of landfill)

Properly secured/locked Functioning Routinely sampled Good condition

Evidence of leakage at penetration Needs maintenance N/A

Remarks:

F-7

4. Extraction Wells Leachate

Properly secured/locked Functioning Routinely sampled Good condition

Evidence of leakage at penetration Needs maintenance N/A

Remarks:

5. Settlement Monuments Located Routinely surveyed N/A

Remarks:

E. Gas Collection and Treatment Applicable N/A

1. Gas Treatment Facilities

Flaring Thermal destruction Collection for reuse

Good condition Needs maintenance

Remarks:

2. Gas Collection Wells, Manifolds and Piping

Good condition Needs maintenance

Remarks:

3. Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)

Good condition Needs maintenance N/A

Remarks:

F. Cover Drainage Layer Applicable N/A

1. Outlet Pipes Inspected Functioning N/A

Remarks:

2. Outlet Rock Inspected Functioning N/A

Remarks:

G. Detention/Sedimentation Ponds Applicable N/A

1. Siltation Area extent: Depth: N/A

Siltation not evident

Remarks:

2. Erosion Area extent: Depth:

Erosion not evident

Remarks:

3. Outlet Works Functioning N/A

Remarks:

4. Dam Functioning N/A

Remarks:

H. Retaining Walls Applicable N/A

1. Deformations Location shown on site map Deformation not evident

Horizontal displacement: Vertical displacement:

F-8

Rotational displacement:

Remarks:

2. Degradation Location shown on site map Degradation not evident

Remarks:

I. Perimeter Ditches/Off-Site Discharge Applicable N/A

1. Siltation Location shown on site map Siltation not evident

Area extent: Depth:

Remarks:

2. Vegetative Growth Location shown on site map N/A

Vegetation does not impede flow

Area extent: Type:

Remarks:

3. Erosion Location shown on site map Erosion not evident

Area extent: Depth:

Remarks:

4. Discharge Structure Functioning N/A

Remarks:

VIII. VERTICAL BARRIER WALLS Applicable N/A

1. Settlement Location shown on site map Settlement not evident

Area extent: Depth:

Remarks:

2. Performance Monitoring Type of monitoring:

Performance not monitored

Frequency: Evidence of breaching

Head differential:

Remarks:

IX. GROUNDWATER/SURFACE WATER REMEDIES Applicable N/A

A. Groundwater Extraction Wells, Pumps and Pipelines Applicable N/A

1. Pumps, Wellhead Plumbing and Electrical

Good condition All required wells properly operating Needs maintenance N/A

Remarks:

2. Extraction System Pipelines, Valves, Valve Boxes and Other Appurtenances

Good condition Needs maintenance

Remarks:

3. Spare Parts and Equipment

Readily available Good condition Requires upgrade Needs to be provided

F-9

Remarks:

B. Surface Water Collection Structures, Pumps and Pipelines Applicable N/A

1. Collection Structures, Pumps and Electrical

Good condition Needs maintenance

Remarks:

2. Surface Water Collection System Pipelines, Valves, Valve Boxes and Other Appurtenances

Good condition Needs maintenance

Remarks:

3. Spare Parts and Equipment

Readily available Good condition Requires upgrade Needs to be provided

Remarks:

C. Treatment System Applicable N/A

1. Treatment Train (check components that apply)

Metals removal Oil/water separation Bioremediation

Air stripping Carbon adsorbers

Filters:

Additive (e.g., chelation agent, flocculent):

Others:

Good condition Needs maintenance

Sampling ports properly marked and functional

Sampling/maintenance log displayed and up to date

Equipment properly identified

Quantity of groundwater treated annually:

Quantity of surface water treated annually:

Remarks:

2. Electrical Enclosures and Panels (properly rated and functional)

N/A Good condition Needs maintenance

Remarks:

3. Tanks, Vaults, Storage Vessels

N/A Good condition Proper secondary containment Needs maintenance

Remarks:

4. Discharge Structure and Appurtenances

N/A Good condition Needs maintenance

Remarks:

5. Treatment Building(s)

N/A Good condition (esp. roof and doorways) Needs repair

F-10

Chemicals and equipment properly stored

Remarks:

6. Monitoring Wells (pump and treatment remedy)

Properly secured/locked Functioning Routinely sampled Good condition

All required wells located Needs maintenance N/A

Remarks:

D. Monitoring Data

1. Monitoring Data

Is routinely submitted on time Is of acceptable quality

2. Monitoring Data Suggests:

Groundwater plume is effectively contained Contaminant concentrations are declining

E. Monitored Natural Attenuation 1. Monitoring Wells (natural attenuation remedy)

Properly secured/locked Functioning Routinely sampled Good condition

All required wells located Needs maintenance N/A

Remarks:

X. OTHER REMEDIES If there are remedies applied at the site and not covered above, attach an inspection sheet describing the physical nature and condition of any facility associated with the remedy. An example would be soil vapor extraction.

XI. OVERALL OBSERVATIONS A. Implementation of the Remedy

Describe issues and observations relating to whether the remedy is effective and functioning as designed. Begin with a brief statement of what the remedy is designed to accomplish (e.g., to contain contaminant plume, minimize infiltration and gas emissions). The remedy consists of containment with soil covers, removal and institutional controls. The implemented remedies at OU1 and OU2 appear to be effective and functioning as designed with no apparent disturbance of the cover or land-use changes that would impact the remedy.

B. Adequacy of O&M Describe issues and observations related to the implementation and scope of O&M procedures. In particular, discuss their relationship to the current and long-term protectiveness of the remedy. O&M is conducted annually and issues are addressed in an appropriate time frame. O&M procedures appear to be effective in maintaining the remedy.

C. Early Indicators of Potential Remedy Problems Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high frequency of unscheduled repairs that suggest that the protectiveness of the remedy may be compromised in the future. No early indicators of potential remedy problems were observed.

D. Opportunities for Optimization Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy. None at this time.

F-11

OU4 and OU7

FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST

I. SITE INFORMATION

Site Name: Libby Asbestos Site Date of Inspection: 8/20/2019

Location and Region: Libby, Montana, 8 EPA ID: MT0009083840 Agency, Office or Company Leading the Five-Year Review: EPA Weather/Temperature: 80s, sunny

Remedy Includes: (Check all that apply) Landfill cover/containment Monitored natural attenuation Access controls Groundwater containment Institutional controls Vertical barrier walls Groundwater pump and treatment Surface water collection and treatment Other: Excavation of contaminated soil or removal of building materials with off-site disposal,

encapsulation of contaminated building material

Attachments: Inspection team roster attached Site map attached

II. INTERVIEWS (check all that apply) 1. O&M Site Manager

Name Title

Date

Interviewed at site at office by phone Phone: Problems, suggestions Report attached:

2. O&M Staff Name

Title

Date

Interviewed at site at office by phone Phone: Problems/suggestions Report attached:

3. Local Regulatory Authorities and Response Agencies (i.e., state and tribal offices, emergency response office, police department, office of public health or environmental health, zoning office, recorder of deeds, or other city and county offices). Fill in all that apply.

Agency Lincoln County Contact Jerry Bennett

Name Commissioner Title

8/21/2019 Date

Phone No.

Problems/suggestions Report attached: Agency City of Libby Contact Brent Tenske

Name Mayor Title

8/21/2019 Date

Phone No.

Problems/suggestions Report attached: Agency MDEQ Contact Lisa Dewitt

Name Project Manager Title

8/21/2019 Date

Phone No.

Problems/suggestions Report attached: Agency Lincoln County Contact Virginia P. Kocieda

Name BOH-ARP Title

8/21/2019 Date

Phone No.

Problems/suggestions Report attached:

F-12

Agency City of Troy Contact Dallas Carr

Name Mayor Title

8/22/2019 Date

Phone No.

Problems/suggestions Report attached:

4. Other Interviews (optional) Report attached:

III. ON-SITE DOCUMENTS AND RECORDS VERIFIED (check all that apply)

1. O&M Documents

O&M manual Readily available Up to date N/A

As-built drawings Readily available Up to date N/A

Maintenance logs Readily available Up to date N/A

Remarks: O&M Manual not yet complete for OU4 and OU7.

2. Site-Specific Health and Safety Plan Readily available Up to date N/A

Contingency plan/emergency response plan

Readily available Up to date N/A

Remarks:

3. O&M and OSHA Training Records Readily available Up to date N/A

Remarks:

4. Permits and Service Agreements

Air discharge permit Readily available Up to date N/A

Effluent discharge Readily available Up to date N/A

Waste disposal, POTW Readily available Up to date N/A

Other permits: Readily available Up to date N/A

Remarks:

5. Gas Generation Records Readily available Up to date N/A

Remarks:

6. Settlement Monument Records Readily available Up to date N/A

Remarks:

7. Groundwater Monitoring Records Readily available Up to date N/A

Remarks:

8. Leachate Extraction Records Readily available Up to date N/A

Remarks:

9. Discharge Compliance Records

Air Readily available Up to date N/A

Water (effluent) Readily available Up to date N/A

Remarks:

F-13

10. Daily Access/Security Logs Readily available Up to date N/A

Remarks:

IV. O&M COSTS

1. O&M Organization

State in-house Contractor for state

PRP in-house Contractor for PRP

Federal facility in-house Contractor for Federal facility

2. O&M Cost Records

Readily available Up to date

Funding mechanism/agreement in place Unavailable

Original O&M cost estimate: Breakdown attached

Total annual cost by year for review period if available

From: Date

To: Date

Total cost

Breakdown attached

From: Date

To: Date

Total cost

Breakdown attached

From: Date

To: Date

Total cost

Breakdown attached

From: Date

To: Date

Total cost

Breakdown attached

From: Date

To: Date

Total cost

Breakdown attached

3. Unanticipated or Unusually High O&M Costs during Review Period Describe costs and reasons:

V. ACCESS AND INSTITUTIONAL CONTROLS Applicable N/A

A. Fencing

1. Fencing Damaged Location shown on site map Gates secured N/A Remarks:

B. Other Access Restrictions

1. Signs and Other Security Measures Location shown on site map N/A Remarks:

C. Institutional Controls (ICs)

F-14

1. Implementation and Enforcement Site conditions imply ICs not properly implemented Yes No N/A

Site conditions imply ICs not being fully enforced Yes No N/A

Type of monitoring (e.g., self-reporting, drive by): Self-reporting Frequency: Responsible party/agency:

Contact

Name Title Date Phone no.

Reporting is up to date Yes No N/A

Reports are verified by the lead agency Yes No N/A

Specific requirements in deed or decision documents have been met Yes No N/A

Violations have been reported Yes No N/A

Other problems or suggestions: Report attached

2. Adequacy ICs are adequate ICs are inadequate N/A Remarks: All ICs are in place as of March 2020.

D. General

1. Vandalism/Trespassing Location shown on site map No vandalism evident Remarks:

2. Land-Use Changes On Site N/A

Remarks:

3. Land-Use Changes Off Site N/A

Remarks:

VI. GENERAL SITE CONDITIONS

A. Roads Applicable N/A

1. Roads Damaged Location shown on site map Roads adequate N/A Remarks:

B. Other Site Conditions

Remarks:

VII. LANDFILL COVERS Applicable N/A

A. Landfill Surface

1. Settlement (low spots) Location shown on site map Settlement not evident

Area extent: Depth:

Remarks:

2. Cracks Location shown on site map Cracking not evident

Lengths: Widths: Depths:

Remarks:

F-15

3. Erosion Location shown on site map Erosion not evident

Area extent: Depth:

Remarks:

4. Holes Location shown on site map Holes not evident

Area extent: Depth:

Remarks:

5. Vegetative Cover Grass Cover properly established

No signs of stress Trees/shrubs (indicate size and locations on a diagram)

Remarks:

6. Alternative Cover (e.g., armored rock, concrete) N/A

Remarks:

7. Bulges Location shown on site map Bulges not evident

Area extent: Height:

Remarks:

8. Wet Areas/Water Damage

Wet areas/water damage not evident

Wet areas Location shown on site map Area extent:

Ponding Location shown on site map Area extent:

Seeps Location shown on site map Area extent:

Soft subgrade Location shown on site map Area extent:

Remarks:

9. Slope Instability Slides Location shown on site map

No evidence of slope instability

Area extent:

Remarks:

B. Benches Applicable N/A

(Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined channel.)

1. Flows Bypass Bench Location shown on site map N/A or okay

Remarks:

2. Bench Breached Location shown on site map N/A or okay

Remarks:

3. Bench Overtopped Location shown on site map N/A or okay

Remarks:

C. Letdown Channels Applicable N/A

(Channel lined with erosion control mats, riprap, grout bags or gabions that descend down the steep side slope of the cover and will allow the runoff water collected by the benches to move off of the landfill

F-16

cover without creating erosion gullies.)

1. Settlement (Low spots) Location shown on site map No evidence of settlement

Area extent: Depth:

Remarks:

2. Material Degradation Location shown on site map No evidence of degradation

Material type: Area extent:

Remarks:

3. Erosion Location shown on site map No evidence of erosion

Area extent: Depth:

Remarks:

4. Undercutting Location shown on site map No evidence of undercutting

Area extent: Depth:

Remarks:

5. Obstructions Type: No obstructions

Location shown on site map Area extent:

Size:

Remarks:

6. Excessive Vegetative Growth Type:

No evidence of excessive growth

Vegetation in channels does not obstruct flow

Location shown on site map Area extent:

Remarks:

D. Cover Penetrations Applicable N/A

1. Gas Vents Active Passive

Properly secured/locked Functioning Routinely sampled Good condition

Evidence of leakage at penetration Needs maintenance N/A

Remarks:

2. Gas Monitoring Probes

Properly secured/locked Functioning Routinely sampled Good condition

Evidence of leakage at penetration Needs maintenance N/A

Remarks:

3. Monitoring Wells (within surface area of landfill)

Properly secured/locked Functioning Routinely sampled Good condition

Evidence of leakage at penetration Needs maintenance N/A

Remarks:

4. Extraction Wells Leachate

F-17

Properly secured/locked Functioning Routinely sampled Good condition

Evidence of leakage at penetration Needs maintenance N/A

Remarks:

5. Settlement Monuments Located Routinely surveyed N/A

Remarks:

E. Gas Collection and Treatment Applicable N/A

1. Gas Treatment Facilities

Flaring Thermal destruction Collection for reuse

Good condition Needs maintenance

Remarks:

2. Gas Collection Wells, Manifolds and Piping

Good condition Needs maintenance

Remarks:

3. Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)

Good condition Needs maintenance N/A

Remarks:

F. Cover Drainage Layer Applicable N/A

1. Outlet Pipes Inspected Functioning N/A

Remarks:

2. Outlet Rock Inspected Functioning N/A

Remarks:

G. Detention/Sedimentation Ponds Applicable N/A

1. Siltation Area extent: Depth: N/A

Siltation not evident

Remarks:

2. Erosion Area extent: Depth:

Erosion not evident

Remarks:

3. Outlet Works Functioning N/A

Remarks:

4. Dam Functioning N/A

Remarks:

H. Retaining Walls Applicable N/A

1. Deformations Location shown on site map Deformation not evident

Horizontal displacement: Vertical displacement:

Rotational displacement:

F-18

Remarks:

2. Degradation Location shown on site map Degradation not evident

Remarks:

I. Perimeter Ditches/Off-Site Discharge Applicable N/A

1. Siltation Location shown on site map Siltation not evident

Area extent: Depth:

Remarks:

2. Vegetative Growth Location shown on site map N/A

Vegetation does not impede flow

Area extent: Type:

Remarks:

3. Erosion Location shown on site map Erosion not evident

Area extent: Depth:

Remarks:

4. Discharge Structure Functioning N/A

Remarks:

VIII. VERTICAL BARRIER WALLS Applicable N/A

1. Settlement Location shown on site map Settlement not evident

Area extent: Depth:

Remarks:

2. Performance Monitoring Type of monitoring:

Performance not monitored

Frequency: Evidence of breaching

Head differential:

Remarks:

IX. GROUNDWATER/SURFACE WATER REMEDIES Applicable N/A

A. Groundwater Extraction Wells, Pumps and Pipelines Applicable N/A

1. Pumps, Wellhead Plumbing and Electrical

Good condition All required wells properly operating Needs maintenance N/A

Remarks:

2. Extraction System Pipelines, Valves, Valve Boxes and Other Appurtenances

Good condition Needs maintenance

Remarks:

3. Spare Parts and Equipment

Readily available Good condition Requires upgrade Needs to be provided

Remarks:

F-19

B. Surface Water Collection Structures, Pumps and Pipelines Applicable N/A

1. Collection Structures, Pumps and Electrical

Good condition Needs maintenance

Remarks:

2. Surface Water Collection System Pipelines, Valves, Valve Boxes and Other Appurtenances

Good condition Needs maintenance

Remarks:

3. Spare Parts and Equipment

Readily available Good condition Requires upgrade Needs to be provided

Remarks:

C. Treatment System Applicable N/A

1. Treatment Train (check components that apply)

Metals removal Oil/water separation Bioremediation

Air stripping Carbon adsorbers

Filters:

Additive (e.g., chelation agent, flocculent):

Others:

Good condition Needs maintenance

Sampling ports properly marked and functional

Sampling/maintenance log displayed and up to date

Equipment properly identified

Quantity of groundwater treated annually:

Quantity of surface water treated annually:

Remarks:

2. Electrical Enclosures and Panels (properly rated and functional)

N/A Good condition Needs maintenance

Remarks:

3. Tanks, Vaults, Storage Vessels

N/A Good condition Proper secondary containment Needs maintenance

Remarks:

4. Discharge Structure and Appurtenances

N/A Good condition Needs maintenance

Remarks:

5. Treatment Building(s)

N/A Good condition (esp. roof and doorways) Needs repair

Chemicals and equipment properly stored

F-20

Remarks:

6. Monitoring Wells (pump and treatment remedy)

Properly secured/locked Functioning Routinely sampled Good condition

All required wells located Needs maintenance N/A

Remarks:

D. Monitoring Data

1. Monitoring Data

Is routinely submitted on time Is of acceptable quality

2. Monitoring Data Suggests:

Groundwater plume is effectively contained Contaminant concentrations are declining

E. Monitored Natural Attenuation 1. Monitoring Wells (natural attenuation remedy)

Properly secured/locked Functioning Routinely sampled Good condition

All required wells located Needs maintenance N/A

Remarks:

X. OTHER REMEDIES If there are remedies applied at the site and not covered above, attach an inspection sheet describing the physical nature and condition of any facility associated with the remedy. An example would be soil vapor extraction.

XI. OVERALL OBSERVATIONS A. Implementation of the Remedy

Describe issues and observations relating to whether the remedy is effective and functioning as designed. Begin with a brief statement of what the remedy is designed to accomplish (e.g., to contain contaminant plume, minimize infiltration and gas emissions). The remedy consists of excavation and off-site disposal of contaminated soil, encapsulation of contaminated building materials, and institutional controls. The implemented remedies at OU4 and OU7 appear to be effective and functioning as designed with no apparent issues that would impact the remedy. Within OU4, property owners are utilizing the U-Dig and ARP prior to performing work on their properties.

B. Adequacy of O&M Describe issues and observations related to the implementation and scope of O&M procedures. In particular, discuss their relationship to the current and long-term protectiveness of the remedy. An O&M plan has not been completed for OU4 or OU7. The adequacy of O&M will be evaluated in the next FYR.

C. Early Indicators of Potential Remedy Problems Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high frequency of unscheduled repairs that suggest that the protectiveness of the remedy may be compromised in the future. No early indicators of potential remedy problems were observed.

D. Opportunities for Optimization Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy. None at this time.

F-21

OU5

FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST

I. SITE INFORMATION

Site Name: Libby Asbestos Site Date of Inspection: 8/21/2019

Location and Region: Libby, Montana, 8 EPA ID: MT0009083840 Agency, Office or Company Leading the Five-Year Review: EPA Weather/Temperature: 80s, sunny

Remedy Includes: (Check all that apply) Landfill cover/containment Monitored natural attenuation Access controls Groundwater containment Institutional controls Vertical barrier walls Groundwater pump and treatment Surface water collection and treatment Other: Excavation and off-site disposal, encapsulation

Attachments: Inspection team roster attached Site map attached

II. INTERVIEWS (check all that apply) 1. O&M Site Manager

Name Title

Date

Interviewed at site at office by phone Phone: Problems, suggestions Report attached:

2. O&M Staff Name

Title

Date

Interviewed at site at office by phone Phone: Problems/suggestions Report attached:

3. Local Regulatory Authorities and Response Agencies (i.e., state and tribal offices, emergency response office, police department, office of public health or environmental health, zoning office, recorder of deeds, or other city and county offices). Fill in all that apply.

Agency Lincoln County Port Authority Contact Tina Oliphant and Brett

McCully Name

Title

8/21/2019 Date

Phone No.

Problems/suggestions Report attached: Agency MDEQ Contact Lisa Dewitt

Name Project Manager Title

8/21/2019 Date

Phone No.

Problems/suggestions Report attached: Agency Contact

Name Title

Date

Phone No.

Problems/suggestions Report attached: Agency Contact

Name Title

Date

Phone No.

Problems/suggestions Report attached:

F-22

Agency Contact

Name Title

Date

Phone No.

Problems/suggestions Report attached:

4. Other Interviews (optional) Report attached:

III. ON-SITE DOCUMENTS AND RECORDS VERIFIED (check all that apply)

1. O&M Documents

O&M manual Readily available Up to date N/A

As-built drawings Readily available Up to date N/A

Maintenance logs Readily available Up to date N/A

Remarks:

2. Site-Specific Health and Safety Plan Readily available Up to date N/A

Contingency plan/emergency response plan

Readily available Up to date N/A

Remarks:

3. O&M and OSHA Training Records Readily available Up to date N/A

Remarks:

4. Permits and Service Agreements

Air discharge permit Readily available Up to date N/A

Effluent discharge Readily available Up to date N/A

Waste disposal, POTW Readily available Up to date N/A

Other permits: Readily available Up to date N/A

Remarks:

5. Gas Generation Records Readily available Up to date N/A

Remarks:

6. Settlement Monument Records Readily available Up to date N/A

Remarks:

7. Groundwater Monitoring Records Readily available Up to date N/A

Remarks:

8. Leachate Extraction Records Readily available Up to date N/A

Remarks:

9. Discharge Compliance Records

Air Readily available Up to date N/A

Water (effluent) Readily available Up to date N/A

Remarks:

F-23

10. Daily Access/Security Logs Readily available Up to date N/A

Remarks:

IV. O&M COSTS

1. O&M Organization

State in-house Contractor for state

PRP in-house Contractor for PRP

Federal facility in-house Contractor for Federal facility

2. O&M Cost Records

Readily available Up to date

Funding mechanism/agreement in place Unavailable

Original O&M cost estimate: Breakdown attached

Total annual cost by year for review period if available

From: Date

To: Date

Total cost

Breakdown attached

From: Date

To: Date

Total cost

Breakdown attached

From: Date

To: Date

Total cost

Breakdown attached

From: Date

To: Date

Total cost

Breakdown attached

From: Date

To: Date

Total cost

Breakdown attached

3. Unanticipated or Unusually High O&M Costs during Review Period Describe costs and reasons:

V. ACCESS AND INSTITUTIONAL CONTROLS Applicable N/A

A. Fencing

1. Fencing Damaged Location shown on site map Gates secured N/A Remarks:

B. Other Access Restrictions

1. Signs and Other Security Measures Location shown on site map N/A Remarks:

C. Institutional Controls (ICs)

F-24

1. Implementation and Enforcement Site conditions imply ICs not properly implemented Yes No N/A

Site conditions imply ICs not being fully enforced Yes No N/A

Type of monitoring (e.g., self-reporting, drive by): Self-reporting Frequency: Annual Responsible party/agency: MDEQ

Contact

Name Title Date Phone no.

Reporting is up to date Yes No N/A

Reports are verified by the lead agency Yes No N/A

Specific requirements in deed or decision documents have been met Yes No N/A

Violations have been reported Yes No N/A

Other problems or suggestions: Report attached

2. Adequacy ICs are adequate ICs are inadequate N/A Remarks: The information devices are in place and appear to be adequate. Other institutional controls including county ordinances and environmental covenant are not yet in place. In addition, funding for response actions resulting from the use of the information institutional controls is not yet in place and may affect the future effectiveness of the institutional controls.

D. General

1. Vandalism/Trespassing Location shown on site map No vandalism evident

Remarks:

2. Land-Use Changes On Site N/A Remarks:

3. Land-Use Changes Off Site N/A Remarks:

VI. GENERAL SITE CONDITIONS

A. Roads Applicable N/A

1. Roads Damaged Location shown on site map Roads adequate N/A

Remarks:

B. Other Site Conditions

Remarks:

VII. LANDFILL COVERS Applicable N/A

A. Landfill Surface

1. Settlement (low spots) Location shown on site map Settlement not evident

Area extent: Depth:

Remarks:

2. Cracks Location shown on site map Cracking not evident

F-25

Lengths: Widths: Depths:

Remarks:

3. Erosion Location shown on site map Erosion not evident

Area extent: Depth:

Remarks:

4. Holes Location shown on site map Holes not evident

Area extent: Depth:

Remarks:

5. Vegetative Cover Grass Cover properly established

No signs of stress Trees/shrubs (indicate size and locations on a diagram)

Remarks:

6. Alternative Cover (e.g., armored rock, concrete) N/A

Remarks:

7. Bulges Location shown on site map Bulges not evident

Area extent: Height:

Remarks:

8. Wet Areas/Water Damage

Wet areas/water damage not evident

Wet areas Location shown on site map Area extent:

Ponding Location shown on site map Area extent:

Seeps Location shown on site map Area extent:

Soft subgrade Location shown on site map Area extent:

Remarks:

9. Slope Instability Slides Location shown on site map

No evidence of slope instability

Area extent:

Remarks:

B. Benches Applicable N/A

(Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined channel.)

1. Flows Bypass Bench Location shown on site map N/A or okay

Remarks:

2. Bench Breached Location shown on site map N/A or okay

Remarks:

3. Bench Overtopped Location shown on site map N/A or okay

Remarks:

F-26

C. Letdown Channels Applicable N/A (Channel lined with erosion control mats, riprap, grout bags or gabions that descend down the steep side slope of the cover and will allow the runoff water collected by the benches to move off of the landfill cover without creating erosion gullies.)

1. Settlement (Low spots) Location shown on site map No evidence of settlement

Area extent: Depth:

Remarks:

2. Material Degradation Location shown on site map No evidence of degradation

Material type: Area extent:

Remarks:

3. Erosion Location shown on site map No evidence of erosion

Area extent: Depth:

Remarks:

4. Undercutting Location shown on site map No evidence of undercutting

Area extent: Depth:

Remarks:

5. Obstructions Type: No obstructions

Location shown on site map Area extent:

Size:

Remarks:

6. Excessive Vegetative Growth Type:

No evidence of excessive growth

Vegetation in channels does not obstruct flow

Location shown on site map Area extent:

Remarks:

D. Cover Penetrations Applicable N/A

1. Gas Vents Active Passive

Properly secured/locked Functioning Routinely sampled Good condition

Evidence of leakage at penetration Needs maintenance N/A

Remarks:

2. Gas Monitoring Probes

Properly secured/locked Functioning Routinely sampled Good condition

Evidence of leakage at penetration Needs maintenance N/A

Remarks:

3. Monitoring Wells (within surface area of landfill)

Properly secured/locked Functioning Routinely sampled Good condition

Evidence of leakage at penetration Needs maintenance N/A

F-27

Remarks:

4. Extraction Wells Leachate

Properly secured/locked Functioning Routinely sampled Good condition

Evidence of leakage at penetration Needs maintenance N/A

Remarks:

5. Settlement Monuments Located Routinely surveyed N/A

Remarks:

E. Gas Collection and Treatment Applicable N/A

1. Gas Treatment Facilities

Flaring Thermal destruction Collection for reuse

Good condition Needs maintenance

Remarks:

2. Gas Collection Wells, Manifolds and Piping

Good condition Needs maintenance

Remarks:

3. Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)

Good condition Needs maintenance N/A

Remarks:

F. Cover Drainage Layer Applicable N/A

1. Outlet Pipes Inspected Functioning N/A

Remarks:

2. Outlet Rock Inspected Functioning N/A

Remarks:

G. Detention/Sedimentation Ponds Applicable N/A

1. Siltation Area extent: Depth: N/A

Siltation not evident

Remarks:

2. Erosion Area extent: Depth:

Erosion not evident

Remarks:

3. Outlet Works Functioning N/A

Remarks:

4. Dam Functioning N/A

Remarks:

H. Retaining Walls Applicable N/A

1. Deformations Location shown on site map Deformation not evident

F-28

Horizontal displacement: Vertical displacement:

Rotational displacement:

Remarks:

2. Degradation Location shown on site map Degradation not evident

Remarks:

I. Perimeter Ditches/Off-Site Discharge Applicable N/A

1. Siltation Location shown on site map Siltation not evident

Area extent: Depth:

Remarks:

2. Vegetative Growth Location shown on site map N/A

Vegetation does not impede flow

Area extent: Type:

Remarks:

3. Erosion Location shown on site map Erosion not evident

Area extent: Depth:

Remarks:

4. Discharge Structure Functioning N/A

Remarks:

VIII. VERTICAL BARRIER WALLS Applicable N/A

1. Settlement Location shown on site map Settlement not evident

Area extent: Depth:

Remarks:

2. Performance Monitoring Type of monitoring:

Performance not monitored

Frequency: Evidence of breaching

Head differential:

Remarks:

IX. GROUNDWATER/SURFACE WATER REMEDIES Applicable N/A

A. Groundwater Extraction Wells, Pumps and Pipelines Applicable N/A

1. Pumps, Wellhead Plumbing and Electrical

Good condition All required wells properly operating Needs maintenance N/A

Remarks:

2. Extraction System Pipelines, Valves, Valve Boxes and Other Appurtenances

Good condition Needs maintenance

Remarks:

3. Spare Parts and Equipment

F-29

Readily available Good condition Requires upgrade Needs to be provided

Remarks:

B. Surface Water Collection Structures, Pumps and Pipelines Applicable N/A

1. Collection Structures, Pumps and Electrical

Good condition Needs maintenance

Remarks:

2. Surface Water Collection System Pipelines, Valves, Valve Boxes and Other Appurtenances

Good condition Needs maintenance

Remarks:

3. Spare Parts and Equipment

Readily available Good condition Requires upgrade Needs to be provided

Remarks:

C. Treatment System Applicable N/A

1. Treatment Train (check components that apply)

Metals removal Oil/water separation Bioremediation

Air stripping Carbon adsorbers

Filters:

Additive (e.g., chelation agent, flocculent):

Others:

Good condition Needs maintenance

Sampling ports properly marked and functional

Sampling/maintenance log displayed and up to date

Equipment properly identified

Quantity of groundwater treated annually:

Quantity of surface water treated annually:

Remarks:

2. Electrical Enclosures and Panels (properly rated and functional)

N/A Good condition Needs maintenance

Remarks:

3. Tanks, Vaults, Storage Vessels

N/A Good condition Proper secondary containment Needs maintenance

Remarks:

4. Discharge Structure and Appurtenances

N/A Good condition Needs maintenance

Remarks:

5. Treatment Building(s)

F-30

N/A Good condition (esp. roof and doorways) Needs repair

Chemicals and equipment properly stored

Remarks:

6. Monitoring Wells (pump and treatment remedy)

Properly secured/locked Functioning Routinely sampled Good condition

All required wells located Needs maintenance N/A

Remarks:

D. Monitoring Data

1. Monitoring Data

Is routinely submitted on time Is of acceptable quality

2. Monitoring Data Suggests:

Groundwater plume is effectively contained Contaminant concentrations are declining

E. Monitored Natural Attenuation 1. Monitoring Wells (natural attenuation remedy)

Properly secured/locked Functioning Routinely sampled Good condition

All required wells located Needs maintenance N/A

Remarks:

X. OTHER REMEDIES If there are remedies applied at the site and not covered above, attach an inspection sheet describing the physical nature and condition of any facility associated with the remedy. An example would be soil vapor extraction.

XI. OVERALL OBSERVATIONS A. Implementation of the Remedy

Describe issues and observations relating to whether the remedy is effective and functioning as designed. Begin with a brief statement of what the remedy is designed to accomplish (e.g., to contain contaminant plume, minimize infiltration and gas emissions). The remedy consists of excavation and off-site disposal of contaminated soil, encapsulation of contaminated building materials, and institutional controls. The implemented remedy at OU5 appears to be effective and functioning as designed with no apparent issues that would impact the remedy.

B. Adequacy of O&M Describe issues and observations related to the implementation and scope of O&M procedures. In particular, discuss their relationship to the current and long-term protectiveness of the remedy. MDEQ will conduct annual inspections at OU5 in accordance with the 2018 O&M Plan.

C. Early Indicators of Potential Remedy Problems Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high frequency of unscheduled repairs that suggest that the protectiveness of the remedy may be compromised in the future. None at this time.

D. Opportunities for Optimization Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy. None at this time.

F-31

OU6

FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST

I. SITE INFORMATION

Site Name: Libby Asbestos Site Date of Inspection: 8/20/2019

Location and Region: Libby, Montana, 8 EPA ID: MT0009083840 Agency, Office or Company Leading the Five-Year Review: EPA Weather/Temperature: 80s, sunny

Remedy Includes: (Check all that apply) Landfill cover/containment Monitored natural attenuation Access controls Groundwater containment Institutional controls Vertical barrier walls Groundwater pump and treatment Surface water collection and treatment Other: Excavation of contaminated soil with off-site disposal

Attachments: Inspection team roster attached Site map attached

II. INTERVIEWS (check all that apply) 1. O&M Site Manager

Name Title

Date

Interviewed at site at office by phone Phone: Problems, suggestions Report attached:

2. O&M Staff Name

Title

Date

Interviewed at site at office by phone Phone: Problems/suggestions Report attached:

3. Local Regulatory Authorities and Response Agencies (i.e., state and tribal offices, emergency response office, police department, office of public health or environmental health, zoning office, recorder of deeds, or other city and county offices). Fill in all that apply.

Agency MDEQ Contact Lisa Dewitt

Name Project Manager Title

8/21/2019 Date

Phone No.

Problems/suggestions Report attached: Agency Contact Name

Title Date

Phone No.

Problems/suggestions Report attached: Agency Contact

Name Title

Date

Phone No.

Problems/suggestions Report attached: Agency Contact

Name Title

Date

Phone No.

Problems/suggestions Report attached: Agency

F-32

Contact Name

Title

Date

Phone No.

Problems/suggestions Report attached:

4. Other Interviews (optional) Report attached:

III. ON-SITE DOCUMENTS AND RECORDS VERIFIED (check all that apply)

1. O&M Documents

O&M manual Readily available Up to date N/A

As-built drawings Readily available Up to date N/A

Maintenance logs Readily available Up to date N/A

Remarks:

2. Site-Specific Health and Safety Plan Readily available Up to date N/A

Contingency plan/emergency response plan

Readily available Up to date N/A

Remarks:

3. O&M and OSHA Training Records Readily available Up to date N/A

Remarks:

4. Permits and Service Agreements

Air discharge permit Readily available Up to date N/A

Effluent discharge Readily available Up to date N/A

Waste disposal, POTW Readily available Up to date N/A

Other permits: Readily available Up to date N/A

Remarks:

5. Gas Generation Records Readily available Up to date N/A

Remarks:

6. Settlement Monument Records Readily available Up to date N/A

Remarks:

7. Groundwater Monitoring Records Readily available Up to date N/A

Remarks:

8. Leachate Extraction Records Readily available Up to date N/A

Remarks:

9. Discharge Compliance Records

Air Readily available Up to date N/A

Water (effluent) Readily available Up to date N/A

Remarks:

10. Daily Access/Security Logs Readily available Up to date N/A

F-33

Remarks:

IV. O&M COSTS

1. O&M Organization

State in-house Contractor for state

PRP in-house Contractor for PRP

Federal facility in-house Contractor for Federal facility

2. O&M Cost Records

Readily available Up to date

Funding mechanism/agreement in place Unavailable

Original O&M cost estimate: Breakdown attached

Total annual cost by year for review period if available

From: Date

To: Date

Total cost

Breakdown attached

From: Date

To: Date

Total cost

Breakdown attached

From: Date

To: Date

Total cost

Breakdown attached

From: Date

To: Date

Total cost

Breakdown attached

From: Date

To: Date

Total cost

Breakdown attached

3. Unanticipated or Unusually High O&M Costs during Review Period Describe costs and reasons:

V. ACCESS AND INSTITUTIONAL CONTROLS Applicable N/A

A. Fencing

1. Fencing Damaged Location shown on site map Gates secured N/A Remarks:

B. Other Access Restrictions

1. Signs and Other Security Measures Location shown on site map N/A

Remarks:

C. Institutional Controls (ICs)

F-34

1. Implementation and Enforcement Site conditions imply ICs not properly implemented Yes No N/A

Site conditions imply ICs not being fully enforced Yes No N/A

Type of monitoring (e.g., self-reporting, drive by): Self-reporting Frequency: Responsible party/agency:

Contact

Name Title Date Phone no.

Reporting is up to date Yes No N/A

Reports are verified by the lead agency Yes No N/A

Specific requirements in deed or decision documents have been met Yes No N/A

Violations have been reported Yes No N/A

Other problems or suggestions: Report attached

2. Adequacy ICs are adequate ICs are inadequate N/A Remarks: An ICIAP has not been issued yet for OU6.

D. General

1. Vandalism/Trespassing Location shown on site map No vandalism evident Remarks:

2. Land-Use Changes On Site N/A

Remarks:

3. Land-Use Changes Off Site N/A

Remarks:

VI. GENERAL SITE CONDITIONS

A. Roads Applicable N/A

1. Roads Damaged Location shown on site map Roads adequate N/A Remarks:

B. Other Site Conditions

Remarks:

VII. LANDFILL COVERS Applicable N/A

A. Landfill Surface

1. Settlement (low spots) Location shown on site map Settlement not evident

Area extent: Depth:

Remarks:

2. Cracks Location shown on site map Cracking not evident

Lengths: Widths: Depths:

Remarks:

F-35

3. Erosion Location shown on site map Erosion not evident

Area extent: Depth:

Remarks:

4. Holes Location shown on site map Holes not evident

Area extent: Depth:

Remarks:

5. Vegetative Cover Grass Cover properly established

No signs of stress Trees/shrubs (indicate size and locations on a diagram)

Remarks:

6. Alternative Cover (e.g., armored rock, concrete) N/A

Remarks:

7. Bulges Location shown on site map Bulges not evident

Area extent: Height:

Remarks:

8. Wet Areas/Water Damage

Wet areas/water damage not evident

Wet areas Location shown on site map Area extent:

Ponding Location shown on site map Area extent:

Seeps Location shown on site map Area extent:

Soft subgrade Location shown on site map Area extent:

Remarks:

9. Slope Instability Slides Location shown on site map

No evidence of slope instability

Area extent:

Remarks:

B. Benches Applicable N/A

(Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined channel.)

1. Flows Bypass Bench Location shown on site map N/A or okay

Remarks:

2. Bench Breached Location shown on site map N/A or okay

Remarks:

3. Bench Overtopped Location shown on site map N/A or okay

Remarks:

C. Letdown Channels Applicable N/A

(Channel lined with erosion control mats, riprap, grout bags or gabions that descend down the steep side slope of the cover and will allow the runoff water collected by the benches to move off of the landfill

F-36

cover without creating erosion gullies.)

1. Settlement (Low spots) Location shown on site map No evidence of settlement

Area extent: Depth:

Remarks:

2. Material Degradation Location shown on site map No evidence of degradation

Material type: Area extent:

Remarks:

3. Erosion Location shown on site map No evidence of erosion

Area extent: Depth:

Remarks:

4. Undercutting Location shown on site map No evidence of undercutting

Area extent: Depth:

Remarks:

5. Obstructions Type: No obstructions

Location shown on site map Area extent:

Size:

Remarks:

6. Excessive Vegetative Growth Type:

No evidence of excessive growth

Vegetation in channels does not obstruct flow

Location shown on site map Area extent:

Remarks:

D. Cover Penetrations Applicable N/A

1. Gas Vents Active Passive

Properly secured/locked Functioning Routinely sampled Good condition

Evidence of leakage at penetration Needs maintenance N/A

Remarks:

2. Gas Monitoring Probes

Properly secured/locked Functioning Routinely sampled Good condition

Evidence of leakage at penetration Needs maintenance N/A

Remarks:

3. Monitoring Wells (within surface area of landfill)

Properly secured/locked Functioning Routinely sampled Good condition

Evidence of leakage at penetration Needs maintenance N/A

Remarks:

4. Extraction Wells Leachate

F-37

Properly secured/locked Functioning Routinely sampled Good condition

Evidence of leakage at penetration Needs maintenance N/A

Remarks:

5. Settlement Monuments Located Routinely surveyed N/A

Remarks:

E. Gas Collection and Treatment Applicable N/A

1. Gas Treatment Facilities

Flaring Thermal destruction Collection for reuse

Good condition Needs maintenance

Remarks:

2. Gas Collection Wells, Manifolds and Piping

Good condition Needs maintenance

Remarks:

3. Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)

Good condition Needs maintenance N/A

Remarks:

F. Cover Drainage Layer Applicable N/A

1. Outlet Pipes Inspected Functioning N/A

Remarks:

2. Outlet Rock Inspected Functioning N/A

Remarks:

G. Detention/Sedimentation Ponds Applicable N/A

1. Siltation Area extent: Depth: N/A

Siltation not evident

Remarks:

2. Erosion Area extent: Depth:

Erosion not evident

Remarks:

3. Outlet Works Functioning N/A

Remarks:

4. Dam Functioning N/A

Remarks:

H. Retaining Walls Applicable N/A

1. Deformations Location shown on site map Deformation not evident

Horizontal displacement: Vertical displacement:

Rotational displacement:

F-38

Remarks:

2. Degradation Location shown on site map Degradation not evident

Remarks:

I. Perimeter Ditches/Off-Site Discharge Applicable N/A

1. Siltation Location shown on site map Siltation not evident

Area extent: Depth:

Remarks:

2. Vegetative Growth Location shown on site map N/A

Vegetation does not impede flow

Area extent: Type:

Remarks:

3. Erosion Location shown on site map Erosion not evident

Area extent: Depth:

Remarks:

4. Discharge Structure Functioning N/A

Remarks:

VIII. VERTICAL BARRIER WALLS Applicable N/A

1. Settlement Location shown on site map Settlement not evident

Area extent: Depth:

Remarks:

2. Performance Monitoring Type of monitoring:

Performance not monitored

Frequency: Evidence of breaching

Head differential:

Remarks:

IX. GROUNDWATER/SURFACE WATER REMEDIES Applicable N/A

A. Groundwater Extraction Wells, Pumps and Pipelines Applicable N/A

1. Pumps, Wellhead Plumbing and Electrical

Good condition All required wells properly operating Needs maintenance N/A

Remarks:

2. Extraction System Pipelines, Valves, Valve Boxes and Other Appurtenances

Good condition Needs maintenance

Remarks:

3. Spare Parts and Equipment

Readily available Good condition Requires upgrade Needs to be provided

Remarks:

F-39

B. Surface Water Collection Structures, Pumps and Pipelines Applicable N/A

1. Collection Structures, Pumps and Electrical

Good condition Needs maintenance

Remarks:

2. Surface Water Collection System Pipelines, Valves, Valve Boxes and Other Appurtenances

Good condition Needs maintenance

Remarks:

3. Spare Parts and Equipment

Readily available Good condition Requires upgrade Needs to be provided

Remarks:

C. Treatment System Applicable N/A

1. Treatment Train (check components that apply)

Metals removal Oil/water separation Bioremediation

Air stripping Carbon adsorbers

Filters:

Additive (e.g., chelation agent, flocculent):

Others:

Good condition Needs maintenance

Sampling ports properly marked and functional

Sampling/maintenance log displayed and up to date

Equipment properly identified

Quantity of groundwater treated annually:

Quantity of surface water treated annually:

Remarks:

2. Electrical Enclosures and Panels (properly rated and functional)

N/A Good condition Needs maintenance

Remarks:

3. Tanks, Vaults, Storage Vessels

N/A Good condition Proper secondary containment Needs maintenance

Remarks:

4. Discharge Structure and Appurtenances

N/A Good condition Needs maintenance

Remarks:

5. Treatment Building(s)

N/A Good condition (esp. roof and doorways) Needs repair

Chemicals and equipment properly stored

F-40

Remarks:

6. Monitoring Wells (pump and treatment remedy)

Properly secured/locked Functioning Routinely sampled Good condition

All required wells located Needs maintenance N/A

Remarks:

D. Monitoring Data

1. Monitoring Data

Is routinely submitted on time Is of acceptable quality

2. Monitoring Data Suggests:

Groundwater plume is effectively contained Contaminant concentrations are declining

E. Monitored Natural Attenuation 1. Monitoring Wells (natural attenuation remedy)

Properly secured/locked Functioning Routinely sampled Good condition

All required wells located Needs maintenance N/A

Remarks:

X. OTHER REMEDIES If there are remedies applied at the site and not covered above, attach an inspection sheet describing the physical nature and condition of any facility associated with the remedy. An example would be soil vapor extraction.

XI. OVERALL OBSERVATIONS A. Implementation of the Remedy

Describe issues and observations relating to whether the remedy is effective and functioning as designed. Begin with a brief statement of what the remedy is designed to accomplish (e.g., to contain contaminant plume, minimize infiltration and gas emissions). The remedy consists of excavation and off-site disposal of contaminated soil along the BNSF railways and institutional controls. The implemented remedy at OU8 appears to be effective and functioning as designed with no apparent issues that would impact the remedy.

B. Adequacy of O&M Describe issues and observations related to the implementation and scope of O&M procedures. In particular, discuss their relationship to the current and long-term protectiveness of the remedy. An O&M plan has not been finalized.

C. Early Indicators of Potential Remedy Problems Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high frequency of unscheduled repairs that suggest that the protectiveness of the remedy may be compromised in the future. No early indicators of potential remedy problems were observed.

D. Opportunities for Optimization Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy. None at this time.

F-41

OU8

FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST

I. SITE INFORMATION

Site Name: Libby Asbestos Site Date of Inspection: 8/20/2019

Location and Region: Libby, Montana, 8 EPA ID: MT0009083840 Agency, Office or Company Leading the Five-Year Review: EPA Weather/Temperature: 80s, sunny

Remedy Includes: (Check all that apply) Landfill cover/containment Monitored natural attenuation Access controls Groundwater containment Institutional controls Vertical barrier walls Groundwater pump and treatment Surface water collection and treatment Other: Excavation of contaminated soil with off-site disposal

Attachments: Inspection team roster attached Site map attached

II. INTERVIEWS (check all that apply) 1. O&M Site Manager

Name Title

Date

Interviewed at site at office by phone Phone: Problems, suggestions Report attached:

2. O&M Staff Name

Title

Date

Interviewed at site at office by phone Phone: Problems/suggestions Report attached:

3. Local Regulatory Authorities and Response Agencies (i.e., state and tribal offices, emergency response office, police department, office of public health or environmental health, zoning office, recorder of deeds, or other city and county offices). Fill in all that apply.

Agency MDEQ Contact Lisa Dewitt

Name Project Manager Title

8/21/2019 Date

Phone No.

Problems/suggestions Report attached: Agency Contact Name

Title Date

Phone No.

Problems/suggestions Report attached: Agency Contact

Name Title

Date

Phone No.

Problems/suggestions Report attached: Agency Contact

Name Title

Date

Phone No.

Problems/suggestions Report attached: Agency

F-42

Contact Name

Title

Date

Phone No.

Problems/suggestions Report attached:

4. Other Interviews (optional) Report attached:

III. ON-SITE DOCUMENTS AND RECORDS VERIFIED (check all that apply)

1. O&M Documents

O&M manual Readily available Up to date N/A

As-built drawings Readily available Up to date N/A

Maintenance logs Readily available Up to date N/A

Remarks:

2. Site-Specific Health and Safety Plan Readily available Up to date N/A

Contingency plan/emergency response plan

Readily available Up to date N/A

Remarks:

3. O&M and OSHA Training Records Readily available Up to date N/A

Remarks:

4. Permits and Service Agreements

Air discharge permit Readily available Up to date N/A

Effluent discharge Readily available Up to date N/A

Waste disposal, POTW Readily available Up to date N/A

Other permits: Readily available Up to date N/A

Remarks:

5. Gas Generation Records Readily available Up to date N/A

Remarks:

6. Settlement Monument Records Readily available Up to date N/A

Remarks:

7. Groundwater Monitoring Records Readily available Up to date N/A

Remarks:

8. Leachate Extraction Records Readily available Up to date N/A

Remarks:

9. Discharge Compliance Records

Air Readily available Up to date N/A

Water (effluent) Readily available Up to date N/A

Remarks:

10. Daily Access/Security Logs Readily available Up to date N/A

F-43

Remarks:

IV. O&M COSTS

1. O&M Organization

State in-house Contractor for state

PRP in-house Contractor for PRP

Federal facility in-house Contractor for Federal facility

2. O&M Cost Records

Readily available Up to date

Funding mechanism/agreement in place Unavailable

Original O&M cost estimate: Breakdown attached

Total annual cost by year for review period if available

From: Date

To: Date

Total cost

Breakdown attached

From: Date

To: Date

Total cost

Breakdown attached

From: Date

To: Date

Total cost

Breakdown attached

From: Date

To: Date

Total cost

Breakdown attached

From: Date

To: Date

Total cost

Breakdown attached

3. Unanticipated or Unusually High O&M Costs during Review Period Describe costs and reasons:

V. ACCESS AND INSTITUTIONAL CONTROLS Applicable N/A

A. Fencing

1. Fencing Damaged Location shown on site map Gates secured N/A Remarks:

B. Other Access Restrictions

1. Signs and Other Security Measures Location shown on site map N/A

Remarks:

C. Institutional Controls (ICs)

F-44

1. Implementation and Enforcement Site conditions imply ICs not properly implemented Yes No N/A

Site conditions imply ICs not being fully enforced Yes No N/A

Type of monitoring (e.g., self-reporting, drive by): Self-reporting Frequency: Responsible party/agency:

Contact

Name Title Date Phone no.

Reporting is up to date Yes No N/A

Reports are verified by the lead agency Yes No N/A

Specific requirements in deed or decision documents have been met Yes No N/A

Violations have been reported Yes No N/A

Other problems or suggestions: Report attached

2. Adequacy ICs are adequate ICs are inadequate N/A Remarks:

D. General

1. Vandalism/Trespassing Location shown on site map No vandalism evident Remarks:

2. Land-Use Changes On Site N/A

Remarks:

3. Land-Use Changes Off Site N/A

Remarks:

VI. GENERAL SITE CONDITIONS

A. Roads Applicable N/A

1. Roads Damaged Location shown on site map Roads adequate N/A Remarks:

B. Other Site Conditions

Remarks:

VII. LANDFILL COVERS Applicable N/A

A. Landfill Surface

1. Settlement (low spots) Location shown on site map Settlement not evident

Area extent: Depth:

Remarks:

2. Cracks Location shown on site map Cracking not evident

Lengths: Widths: Depths:

Remarks:

F-45

3. Erosion Location shown on site map Erosion not evident

Area extent: Depth:

Remarks:

4. Holes Location shown on site map Holes not evident

Area extent: Depth:

Remarks:

5. Vegetative Cover Grass Cover properly established

No signs of stress Trees/shrubs (indicate size and locations on a diagram)

Remarks:

6. Alternative Cover (e.g., armored rock, concrete) N/A

Remarks:

7. Bulges Location shown on site map Bulges not evident

Area extent: Height:

Remarks:

8. Wet Areas/Water Damage

Wet areas/water damage not evident

Wet areas Location shown on site map Area extent:

Ponding Location shown on site map Area extent:

Seeps Location shown on site map Area extent:

Soft subgrade Location shown on site map Area extent:

Remarks:

9. Slope Instability Slides Location shown on site map

No evidence of slope instability

Area extent:

Remarks:

B. Benches Applicable N/A

(Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined channel.)

1. Flows Bypass Bench Location shown on site map N/A or okay

Remarks:

2. Bench Breached Location shown on site map N/A or okay

Remarks:

3. Bench Overtopped Location shown on site map N/A or okay

Remarks:

C. Letdown Channels Applicable N/A

(Channel lined with erosion control mats, riprap, grout bags or gabions that descend down the steep side slope of the cover and will allow the runoff water collected by the benches to move off of the landfill

F-46

cover without creating erosion gullies.)

1. Settlement (Low spots) Location shown on site map No evidence of settlement

Area extent: Depth:

Remarks:

2. Material Degradation Location shown on site map No evidence of degradation

Material type: Area extent:

Remarks:

3. Erosion Location shown on site map No evidence of erosion

Area extent: Depth:

Remarks:

4. Undercutting Location shown on site map No evidence of undercutting

Area extent: Depth:

Remarks:

5. Obstructions Type: No obstructions

Location shown on site map Area extent:

Size:

Remarks:

6. Excessive Vegetative Growth Type:

No evidence of excessive growth

Vegetation in channels does not obstruct flow

Location shown on site map Area extent:

Remarks:

D. Cover Penetrations Applicable N/A

1. Gas Vents Active Passive

Properly secured/locked Functioning Routinely sampled Good condition

Evidence of leakage at penetration Needs maintenance N/A

Remarks:

2. Gas Monitoring Probes

Properly secured/locked Functioning Routinely sampled Good condition

Evidence of leakage at penetration Needs maintenance N/A

Remarks:

3. Monitoring Wells (within surface area of landfill)

Properly secured/locked Functioning Routinely sampled Good condition

Evidence of leakage at penetration Needs maintenance N/A

Remarks:

4. Extraction Wells Leachate

F-47

Properly secured/locked Functioning Routinely sampled Good condition

Evidence of leakage at penetration Needs maintenance N/A

Remarks:

5. Settlement Monuments Located Routinely surveyed N/A

Remarks:

E. Gas Collection and Treatment Applicable N/A

1. Gas Treatment Facilities

Flaring Thermal destruction Collection for reuse

Good condition Needs maintenance

Remarks:

2. Gas Collection Wells, Manifolds and Piping

Good condition Needs maintenance

Remarks:

3. Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)

Good condition Needs maintenance N/A

Remarks:

F. Cover Drainage Layer Applicable N/A

1. Outlet Pipes Inspected Functioning N/A

Remarks:

2. Outlet Rock Inspected Functioning N/A

Remarks:

G. Detention/Sedimentation Ponds Applicable N/A

1. Siltation Area extent: Depth: N/A

Siltation not evident

Remarks:

2. Erosion Area extent: Depth:

Erosion not evident

Remarks:

3. Outlet Works Functioning N/A

Remarks:

4. Dam Functioning N/A

Remarks:

H. Retaining Walls Applicable N/A

1. Deformations Location shown on site map Deformation not evident

Horizontal displacement: Vertical displacement:

Rotational displacement:

F-48

Remarks:

2. Degradation Location shown on site map Degradation not evident

Remarks:

I. Perimeter Ditches/Off-Site Discharge Applicable N/A

1. Siltation Location shown on site map Siltation not evident

Area extent: Depth:

Remarks:

2. Vegetative Growth Location shown on site map N/A

Vegetation does not impede flow

Area extent: Type:

Remarks:

3. Erosion Location shown on site map Erosion not evident

Area extent: Depth:

Remarks:

4. Discharge Structure Functioning N/A

Remarks:

VIII. VERTICAL BARRIER WALLS Applicable N/A

1. Settlement Location shown on site map Settlement not evident

Area extent: Depth:

Remarks:

2. Performance Monitoring Type of monitoring:

Performance not monitored

Frequency: Evidence of breaching

Head differential:

Remarks:

IX. GROUNDWATER/SURFACE WATER REMEDIES Applicable N/A

A. Groundwater Extraction Wells, Pumps and Pipelines Applicable N/A

1. Pumps, Wellhead Plumbing and Electrical

Good condition All required wells properly operating Needs maintenance N/A

Remarks:

2. Extraction System Pipelines, Valves, Valve Boxes and Other Appurtenances

Good condition Needs maintenance

Remarks:

3. Spare Parts and Equipment

Readily available Good condition Requires upgrade Needs to be provided

Remarks:

F-49

B. Surface Water Collection Structures, Pumps and Pipelines Applicable N/A

1. Collection Structures, Pumps and Electrical

Good condition Needs maintenance

Remarks:

2. Surface Water Collection System Pipelines, Valves, Valve Boxes and Other Appurtenances

Good condition Needs maintenance

Remarks:

3. Spare Parts and Equipment

Readily available Good condition Requires upgrade Needs to be provided

Remarks:

C. Treatment System Applicable N/A

1. Treatment Train (check components that apply)

Metals removal Oil/water separation Bioremediation

Air stripping Carbon adsorbers

Filters:

Additive (e.g., chelation agent, flocculent):

Others:

Good condition Needs maintenance

Sampling ports properly marked and functional

Sampling/maintenance log displayed and up to date

Equipment properly identified

Quantity of groundwater treated annually:

Quantity of surface water treated annually:

Remarks:

2. Electrical Enclosures and Panels (properly rated and functional)

N/A Good condition Needs maintenance

Remarks:

3. Tanks, Vaults, Storage Vessels

N/A Good condition Proper secondary containment Needs maintenance

Remarks:

4. Discharge Structure and Appurtenances

N/A Good condition Needs maintenance

Remarks:

5. Treatment Building(s)

N/A Good condition (esp. roof and doorways) Needs repair

Chemicals and equipment properly stored

F-50

Remarks:

6. Monitoring Wells (pump and treatment remedy)

Properly secured/locked Functioning Routinely sampled Good condition

All required wells located Needs maintenance N/A

Remarks:

D. Monitoring Data

1. Monitoring Data

Is routinely submitted on time Is of acceptable quality

2. Monitoring Data Suggests:

Groundwater plume is effectively contained Contaminant concentrations are declining

E. Monitored Natural Attenuation 1. Monitoring Wells (natural attenuation remedy)

Properly secured/locked Functioning Routinely sampled Good condition

All required wells located Needs maintenance N/A

Remarks:

X. OTHER REMEDIES If there are remedies applied at the site and not covered above, attach an inspection sheet describing the physical nature and condition of any facility associated with the remedy. An example would be soil vapor extraction.

XI. OVERALL OBSERVATIONS A. Implementation of the Remedy

Describe issues and observations relating to whether the remedy is effective and functioning as designed. Begin with a brief statement of what the remedy is designed to accomplish (e.g., to contain contaminant plume, minimize infiltration and gas emissions). The remedy consists of excavation and off-site disposal of contaminated soil along roadways in OU1, OU2 and OU4/OU7 and institutional controls. The implemented remedy at OU8 appears to be effective and functioning as designed with no apparent issues that would impact the remedy.

B. Adequacy of O&M Describe issues and observations related to the implementation and scope of O&M procedures. In particular, discuss their relationship to the current and long-term protectiveness of the remedy. An O&M plan was issued in 2018. The first O&M report was not available to review for this FYR. During the site inspection, O&M appeared to be adequate.

C. Early Indicators of Potential Remedy Problems Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high frequency of unscheduled repairs that suggest that the protectiveness of the remedy may be compromised in the future. No early indicators of potential remedy problems were observed.

D. Opportunities for Optimization Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy. None at this time.

G-1

APPENDIX G – SITE INSPECTION PHOTOS

OU1

Pavilion and parking area at Riverfront Park

Remediated embankment off City Service Road

G-2

Low area in soil cover in the Riverfront Park parking lot

Soil cover and the David Thompson Search and Rescue facility

G-3

OU2

Undeveloped remediated property

Private property

G-4

OU4

Remediated home

Libby Elementary School

G-5

OU5

Fishing pond located in OU5

Remediated area with vacant and occupied buildings in background

G-6

Encapsulated building

OU6

Railroad depot

G-7

Rail line

OU7

Remediation in progress

H-1

APPENDIX H – REMEDIAL GOALS AND CLEANUP CRITERIA Table H-1: LA RALs for Contaminated Surface Soil, by Land-Use Type and Use Frequency

Land-Use Type Use Frequency RAL

Residential/Commercial Frequent

LA present at levels greater than or equal to 0.2% (regardless of spatial extent).

LA present at levels less than 0.2% if area is more than 25% of total soil exposure area at the property.

Infrequent LA present at levels greater than or equal to 0.2%.

Industrial NA LA present at levels greater than or equal to 1%.

Transportation Corridors NA LA present at levels greater than or equal to 1%.

Parks/Schools NA LA present at greater than or equal to 0.2%.

Notes: Source: 2016 ROD NA = not applicable for land-use type

Table H-2: LA RALs for Contaminated Building Materials, by Accessibility

Land-Use Type Accessibility RAL

All Accessible

Presence of accessible LA-containing vermiculite insulation in any quantity in living spaces, non-living spaces and/or secondary structures. Presence of accessible friable and/or deteriorated building materials containing greater than or equal to 0.25% LA.

Notes: Source: 2016 ROD

Table H-3: LA Remedial Clearance Criteria for Subsurface Soil, by Land-Use Type

Land-Use Type RAL

Residential/Commercial

Parks/Schools

LA is not present or is present at levels less than 0.2% unless boundary conditions are reached.

Industrial

Transportation Corridors

LA is not present or is present at levels less than 1% unless boundary conditions are reached.

Notes: Boundary conditions are defined as features or conditions that limit the ability to further remediate LA contamination due to physical or technical constraints and the related lack of accessibility these boundary conditions present.

H-2

Table H-4: LA Remedial Clearance Criteria for Contaminated Building Material

Space Type RAL

Indoor Non-living Space

No accessible vermiculite remaining.

Five clearance air samples, collected following leaf blower disturbances in the non-living space after remedial actions are complete, that have an average total LA air concentration less than 0.005 s/cc when analyzed by TEM using Asbestos Hazard Emergency Response Act (AHERA) counting rules (achieved analytical sensitivity of 0.005 per cubic centimeter of air [cc-1]).

Indoor Living Space

No accessible vermiculite remaining.

Five clearance air samples, collected following leaf blower disturbances in the living space after remedial actions are complete, that have total LA air concentrations that are non-detect when analyzed by TEM using AHERA counting rules (achieved analytical sensitivity of 0.005 cc-1).

Notes: Source: 2016 ROD s/cc = structures per cubic centimeters TEM = transmission electron microscopy

I-1

APPENDIX I – EXPANDED SITE BACKGROUND OU Descriptions

• OU1 – Former Export Plant: Defined geographically by the parcel of land that included the former Export Plant and the Highway 37 embankments and is situated on the south side of the Kootenai River, just north of the downtown area of the City of Libby. The property is bound by the Kootenai River on the north, the BNSF railroad thoroughfare on the south, and residential properties on the east and west.

• OU2 – Former Screening Plant: Areas impacted by contamination released from the former Screening Plant. These areas include the former Screening Plant, the Flyway property, the Highway 37 ROW adjacent to the former Screening Plant and/or Rainy Creek Road, and privately-owned properties. The Kootenai Bluff Subdivision area (the former W.R. Grace railroad loading station area), located directly across the Kootenai River from the former Screening Plant, was removed from OU2 and is now part of OU4.

• OU3 – Former Libby Vermiculite Mine (the mine): The property in and around the Zonolite Mine owned

by W.R. Grace or W.R. Grace-owned subsidiaries (excluding OU2) and any area (including any structure, soil, air, water, sediment or receptor) impacted by the release and subsequent migration of hazardous substances and/or pollutants or contaminants from such property, including but not limited to the mine property, the Kootenai River and sediments therein, Rainy Creek, Rainy Creek Road, and areas in which tree bark is contaminated with such hazardous substances and/or pollutants and contaminants.

• OU4 – Libby Residential/Commercial Area: The residential, commercial, industrial (not associated with W.R. Grace mining operations) and public properties, including schools and parks, in and around the City of Libby.

• OU5 – Former Stimson Lumber Company: Defined geographically by the parcel of land that included the former Stimson Lumber Company. OU5 is bounded by the high bank of Libby Creek to the east, the BNSF railroad to the north, and properties within OU4 to the south and west. This OU is currently occupied by various vacant structures/buildings as well as several operating businesses (e.g., lumber processing, log storage, an excavation contractor). The Libby Groundwater Superfund site is located within the OU5 boundary. That site is not associated with the Libby Asbestos Superfund site and is not discussed in this FYR Report.

• OU6 – BNSF Railroad: This OU is owned and operated by the BNSF railroad. OU6 is defined geographically by the BNSF property boundaries from the eastern boundary of OU4 to the western boundary of OU7 and the extent of contamination associated with the Libby and Troy railyards.

• OU7 – Town of Troy: The residential, commercial, and public properties in and around the town of Troy, Montana, located 20 miles west of downtown Libby.

• OU8 – Roadways: This OU comprises the United States and Montana state highways and ROWs within the boundaries of OU4 and OU7.

OU1 and OU2 were previously addressed in separate response actions, and RODs were published for both OUs in May 2010. OU3 will be addressed separately in the future. Thus, extent and risks from LA contamination in these OUs and remedial alternatives for contaminated media such as soils and building materials within these OUs were not evaluated in the feasibility study (FS). When referring to OUs 4, 5, 6, 7 and 8, the term “non-OU3 areas” is often used. While OUs have been used at the Site to organize investigations and subsequent response actions, the EPA has determined that categories related to current and future land use are more consistent with the risk management

I-2

approach for the non-OU3 areas of the Site evaluated within the FS. Thus, the non-OU3 areas of the Site have been organized in four separate land-use categories:

• Residential/commercial • Industrial • Transportation corridors • Parks/schools

While these land-use categories were primarily identified to categorize existing land uses for properties on site, they also form the framework in which to evaluate land uses when a property owner changes the land use in the future. Thus, the definitions of the land-use categories may contemplate uses that do not currently exist. Pre-ROD Response Actions Table I-1: Summary of Response Action Removals at OU1

Year Material Removed Summary of Response Action

Area 1 – Former Export Plant July 2000 – January 2001 Vermiculite and contaminated dust,

soil and debris Cleaned five on-site historic buildings and the building’s contents, excavated and disposed of vermiculite and LA‐contaminated soil and debris, and restored the property. Contaminated materials were disposed of at the former mine.

September – October 2001 Contaminated soil and building debris Grace conducted a cleanup action to address residual LA contamination in site buildings and soil. Ultimately, four of the five buildings (all but the planar shop) were demolished and additional soil was excavated from the Site. The contaminated soil and debris were disposed of at the former mine.

October – December 2002 Contaminated soil and building debris Grace began removing the remaining building material and debris from Area 1. Contaminated soil from the footprint of the demolished planar shop and from an area near the BNSF railroad tracks was also removed. Contaminated soil and building materials were disposed of at the former mine.

Area 2 – Riverfront Park October – November 2003 Vermiculite and contaminated soil Within Riverfront Park, soil was

excavated to a depth of 12 inches bgs throughout the park area, with the exception of the Kootenai riverbank and the northeast side of City Service Road where soils were excavated to a depth of 6 inches bgs. Excavation of the embankment on the southeast side of City Service Road was not conducted. Additionally, where visible vermiculite was observed or where elevated LA analytical results were

I-3

detected above the EPA’s removal clearance criteria, additional 6‐inch lifts were removed, iteratively, to a maximum depth of 3 feet bgs. However, along the riverbank and City Service Road embankment, maximum excavation depths were 12 inches bgs.

July 2007 Vermiculite and contaminated soil Subsurface vermiculite was brought to the surface during the installation of cable by a phone company from a depth of approximately two feet bgs. The excavated soils were disposed of at the former mine. The area was covered with four to six inches of rock.

May 2008 Contaminated soil Soils were excavated to place foundation footings and a full concrete slab in the construction of a new City pavilion. The footings area was excavated to an approximate depth of 57 inches bgs. The excavated soils were disposed of at the former mine. The second area was excavated to provide a construction access ramp to the bottom of the city pavilion excavation.

July 2008 Vermiculite and contaminated soil Several small areas containing medium to high amounts of vermiculite as well as what appeared to be raw LA were found. The type of vermiculite observed was apparently not from a local source, but was suspected as an import. No vermiculite was observed in these areas after the removal was completed.

Area 3 – Highway 37 Embankments

None

Table I-2: Summary of Response Action Removals at OU2

Year Material Removed Summary of Response Action

Subarea 1 - Former Screening Plant August – October 2000 Building demolition materials,

vermiculite-contaminated soil and debris

Contaminated soil was removed from the northern portion following the removal, disposal, and/or relocation of all stored items and demolition of all buildings (except the long shed). Soil was excavated to 4 feet bgs to mitigate exposure risk and stockpiled in and around the long shed. The remaining contaminated soil was covered with geotextile and fill.

August – November 2001 Building demolition materials, vermiculite-contaminated soil and debris

Stockpiled soils were removed and disposed of at the mine, the long shed was demolished, and the concrete slab

I-4

was abandoned and covered. Additional excavation was conducted along the northern portion of the area adjacent to the river and covered with rip-rap and geotextile.

August – October 2002 Vermiculite-contaminated soil, debris, trees and vegetative material

Removal of decontamination pad and surrounding soil. Excavation along the banks of Rainy Creek, including removal of trees and vegetation and disposal of contaminated soil at the former vermiculite mine.

October 2002 – April 2003 Vermiculite-contaminated soil, granular pad

Removal of vermiculite-contaminated soil and granular pad during installation of potable water well.

September 2003 – August 2004 Vermiculite-contaminated soil Excavation within the Highway 37 ROW and disposal of contaminated soil at the former vermiculite mine.

July 2005 – May 2006 Vermiculite-contaminated soil Removal of vermiculite-contaminated soil and granular pad during installation of potable water well.

Subarea 2 - Flyway September 2001 Contaminated soil Excavation and disposal of

vermiculite-contaminated soil at the former mine.

July – November 2004 Contaminated soil Contaminated soil was excavated from the northern portion of the Flyway and the Kootenai riverbank along the southern portion of the Flyway. Iterative removals in lifts were conducted, with a maximum depth of 4 feet bgs. Grids in the riverbank slope were excavated to water.

June 2005 Contaminated soil Contaminated soils in the ROW were excavated to 12 inches bgs. A stockpile of contaminated soil was removed. Two confirmation samples had elevated results that could not be addressed through further excavation. Sample lR-30927 (2% LA) was on a steep embankment of the ROW. Due to the slope, the area could not be excavated to a depth greater than 4 inches bgs. Sample lR-30960 (3% LA) was in the footprint of the stockpile that had been removed and was very near the highway. This area was not excavated further than 12 inches bgs due to concerns about impacting the highway's integrity.

Subarea 3 - Private Property

June 2005 Contaminated soil

The EPA determined that soil in this subarea required removal to a depth of 12 inches throughout. Confirmation soil samples were collected from the excavation bottom to depths between 2 and 14 inches bgs.

I-5

Subarea 4 - Rainy Creek Road Frontage

August through October 2004 Contaminated soil

Removal activities consisted of an approximately 2-foot excavation on residential property. The excavation was backfilled using 18 inches of common fill and 6 inches of topsoil.

August 2006 Contaminated soil

While excavating to repair a damaged water line at the north frontage, a contractor observed vermiculite. The contaminated soil (40 cubic yards) was excavated, and the damaged water line was repaired.

Table I-3: Summary of Investigations and Removal Activities at OUs 4, 5, 6, 7 and 8

OU Investigation Removal/Construction

OU4 • Investigations completed at approximately 5,800 commercial and residential properties.

• Specialty investigations conducted at schools and unique properties such as Cabinet View Country Club and the former landfill.

• LA nature and extent investigation. • ABS investigations, including multiple-year

residential (five scenarios), schools, limited use area, background and borrow, woodstove ash, and comparative exposure.

• Removals completed at approximately 2,100 commercial and residential properties.

• Construction of Class IV asbestos cell at the Libby Class II Landfill.

OU5 • Site interview in 2001 indicated three areas of interest: the former Expansion Plant, the railroad spur and the former tree nursery.

• Soil sampling and characterization of several areas within the OU.

• Summer 2005: Central Maintenance Building removal action. The removal action conducted at the Central Maintenance Building consisted of removal of vermiculite insulation, a full interior cleaning in the former mobile shop, removal of vermiculite-containing building materials, and a limited soil removal. The volume of CBM removed and disposed of at the Libby Class II Landfill amounted to approximately 468 cubic yards (cy). The volume of contaminated soil removed and disposed of at the mine amounted to approximately 10 cy.

• May 2009: OU5 redevelopment area. The April 2009 investigation of the redevelopment area identified three areas requiring response action for LA-impacted soil. The LA contaminated soil was excavated and disposed of, and the excavations were backfilled with structural fill. The volume of contaminated soil removed and disposed of at the former mine amounted to approximately 2,075 cy.

• August 2009: Libby Creek (OU4 action with possible encroachment on OU5). Libby Creek is part of OU4 as it traverses OU5. However, a portion of the response action may have encroached onto OU5 on the east bank of the creek. The Specialty Property Investigations in October 2008 identified LA-contaminated materials in a riprap section of bank along Libby Creek. Removal of the riprap and soil beneath it followed by replacement with clean fill and riprap took place in 2009. The volume of excavated

I-6

material disposed of at the mine amounted to approximately 499 cy of soil and 950 cy of riprap (95 truckloads).

• September 2009: Central Maintenance Building. The removal action removed demolition debris from the north wall and excavated soil in the surrounding area. Material removed and disposed of at the Libby Class II Landfill amounted to approximately 55 cy of CBMs. The volume of contaminated soil removed and disposed of at the mine amounted to approximately 93 cy.

• October 2009: Quick response at Central Maintenance Building. The removal action removed approximately 1 cy of vermiculite-containing insulation, disposing of it at the Libby Class II Landfill.

• January 2010: Central Maintenance Building. The removal action consisted of removal of vermiculite-containing insulation and interior cleaning in the east end of the Central Maintenance Building where extension of a door access occurred. Vermiculite-containing insulation remains throughout the interior and exterior walls of the building. Additional action included bagging and disposal of contaminated debris from the tenant-performed door removal. The volume of material removed and disposed of at the Libby Class II Landfill amounted to approximately 5.1 cy of CBMs.

• August – September 2010: Soil removed along the trenched area north of the former veneer dryer and removal of vermiculite-containing building materials (mortar and bricks) along the former veneer dryers. The volume of materials removed and disposed of at the mine amounted to approximately 7 cy of contaminated soil, bricks and mortar.

• August – September 2010: Quick response at valve house at Finger Jointer building. The removal action consisted of soil removal from the ground area surrounding the valve house and from the valve house floor. Soil removal occurred to the required depth, but contamination remains beneath. The volume of soil removed and disposed of at the mine amounted to approximately 40 cy. Action at the valve house removed vermiculite containing insulation and building materials from the attic space, walls, door, and ceiling. The volume of material removed and disposed of at the Libby Class II Landfill amounted to approximately 20.8 cy of CBMs.

• August – November 2011: Quick response at former popping plant. The removal action consisted of soil removal from the area used for parking near Libby City Hall. Contaminated soil removal occurred to the required depth, but contamination remains beneath. The volume of contaminated soil removed and disposed of at the mine amounted to approximately 7778 cy.

I-7

• November 2011 and February 2012: Central Maintenance Building. As follow up to the roof maintenance at the Central Maintenance Building performed between October 2010 and September 2011, interior cleaning, debris removal, and spot cleaning of the areas impacted by landowner removal of LA-containing roof materials took place. A single completion form documented the November and February actions. Collectively, the volume of CBMs removed and disposed of at the Libby Class II Landfill amounted to approximately 2.8 cy.

• April – May 2012: Quick response at Port Authority Building. The removal action consisted of soil removal from a portion of the yard northwest of the building to create re-vegetation demonstration plots. The volume of soil removed and disposed of at the mine amounted to approximately 160 cy. Note: soil removal took place to develop the demonstration plots, not because soil exceeded the action level at the time.

• June – July 2012: Former tree nursery. The removal action consisted of soil removal from the area previously known as the tree nursery and demolition of a small shed. Soil removal occurred to the required depth, but LA contamination remains beneath. The volume of CBMs removed and disposed of at the Libby Class II Landfill amounted to approximately 1.6 cy. The volume of contaminated soils removed and disposed of at the mine amounted to approximately 1430 cy.

• October 2012: Central Maintenance Building. The removal action consisted of removing vermiculite-containing insulation and interior cleaning after someone accidentally punched a hole through an exterior wall containing the insulation. The volume of CBMs removed and disposed of at the Libby Class II Landfill amounted to approximately 20 cy.

• April 2013: Removal of contaminated soil in several areas, including an area of the former tree nursery in preparation for construction of a fishing pond, which opened in August 2015.

• October 2013: International Paper lean-to. The removal action consisted of soil removal from under the lean-to at 231 Port Boulevard (International Paper). The volume of soil removed and disposed of at the former mine amounted to approximately 30 cy.

• October – November 2013: Central Maintenance Building. The removal action consisted of wall paneling and vermiculite-containing insulation removal, as well as interior cleaning after a contractor encountered vermiculite insulation during wall panel demolition. The volume of CBMs removed and disposed of at the Libby Class II Landfill amounted to approximately 5.9 cy.

I-8

OU6 • Sampling began in 2001 and focused on characterization in and around the BNSF Libby Railyard.

• Sampling efforts after response actions were completed focused on receptor exposure during railroad maintenance activities along the tracks and are considered representative of areas outside the BNSF Libby Railyard.

• August 2003: Soil containing visible vermiculite was removed from the BNSF Libby Railyard using high efficiency particulate air filtered vacuum trucks and a small excavator.

• 2004: Following characterization of LA asbestos within the BNSF Libby Railyard, 14,091 feet of railroad track and 8,000 railroad ties were removed to access the underlying, vermiculite-impacted soils. All track materials were removed, decontaminated, and either disposed of or recycled. The BNSF scale house and associated concrete foundation were also removed during the demolition phase and disposed of at the Lincoln County Landfill as potential asbestos-containing material.

OU7 • Investigations completed at approximately 1,300 commercial and residential properties.

• Removals completed at approximately 100 commercial and residential properties.

OU8 • Systematic soil sampling was performed in support of the RI Report along the ROW.

• Residential and Commercial Encroachment (OU4/OU7): For residential and commercial properties abutting the state and federal highway corridors, investigation and response actions were performed based on the residential and/or commercial use of the property, which sometimes included the highway ROW.

• OU1. The OU1 RA included excavation and backfill of the MT Highway 37 embankments, which are part of the MT Highway 37 ROW and included in OU8.

• OU2. The OU2 RA included excavation and backfill of the MT Highway 37 ROW, which is part of OU8.