Agenda

• Remedial Investigation Update

• Risk Assessments

• OU2/OU3 draft Baseline Ecological Risk Assessment

• OU2 and OU3 draft Human Health Risk Assessments

• Groundwater

• Conceptual Site Model next steps

• Schedule

2

1/26/2021 U.S. Environmental Protection Agency 3

Questions the Remedial Investigation Should Answer

1/26/2021 U.S. Environmental Protection Agency

What are the Contaminants Of Concern (COCs)?

How much contamination is

present?

What are the risks from the

contamination?

Where is the extent of contamination?

Does it migrate, if so how, where, and

under what conditions?

What is the regulatory framework

that applies to the cleanup of this contamination?

5

Ecological Risk Assessment

OU1 Ecological Risk Assessment: March 2017

OU2/OU3 Screening Level Ecological Risk

Assessment (SLERA): October 2017

OU2/OU3 Baseline Ecological Risk Assessment

(BERA) Workplan: August 2018

Draft OU2/OU3 BERA: November 2020

6

Receptors of Concern – OU2

Feeding Guild Avian Mammalian

Terrestrial

Invertivore

American robin, Gray

catbird

Vagrant shrew

Aerial

Insectivore

Tree swallow Bat

Herbivore Blue grouse White-tailed deer,

Montane vole

Carnivore American kestrel Red fox

Omnivore Mallard, Northern flicker,

Clark’s nutcracker

Deer mouse

7

Receptors of Concern – OU3

Feeding Guild Avian Mammalian

Terrestrial

Invertivore

American robin, Gray

catbird

Vagrant shrew

Aerial

Insectivore

Tree swallow

Aquatic

Insectivore

American dipper

Herbivore Blue grouse White-tailed deer,

Montane vole

Carnivore American kestrel Red fox, American

mink

Piscivore Belted kingfisher, Osprey River otter

Omnivore Mallard, Northern flicker,

Clark’s nutcracker

Deer mouse

8

Receptors of Concern

Terrestrial (OU2, OU3)• Plants• Soil invertebrates

Aquatic (O’Keefe and Lavalle Creeks, Ponds,

Clark Fork River)• Aquatic Insects• Benthic Organisms• Aquatic Plants• Amphibians• Fish

9

Data

Surface Water – 2015, 2018• Clark Fork River

• O’Keefe and Lavalle Creeks

• 12 On-Site Ponds

Pore Water – 2018• 12 On-Site Ponds

Sediment – 2015, 2018• Clark Fork River

• O’Keefe and Lavalle Creeks

• 12 On-Site Ponds

Soil – 2014, 2015, 2017• OU2

• OU3 Upland

• OU3 Floodplain

Tissue – 2018, 2019• Trout, Pike, Dace from CFR

• Aquatic Inverts from Creeks,

Ponds

• Small Mammals from

OU1/OU2/OU3

10

Risk Characterization – Plants

OU2• Low risk for barium, copper, mercury,

selenium, zinc

OU3 Upland• Low risk for barium, copper, mercury,

selenium, zinc

OU3 Floodplain• Low risk for barium, copper, mercury, zinc

11

Risk Characterization – Soil Invertebrates

OU2• Low risk for barium, copper, mercury, zinc

OU3 Upland• Low risk for barium, copper, zinc

• Potential high risk for mercury

OU3 Floodplain• Low risk for barium, copper, zinc

• Potential high risk for mercury

12

Risk Characterization – Aquatic, CFR

Surface Water• Low risk for manganese

Sediment• Minimal risk for TEQ

• Low risk for mercury

Fish Tissue• Minimal risk for TEQ (D/F/PCBs) in pike and

trout

• Minimal risk for mercury in dace

13

Risk Characterization – Aquatic, Creeks

Surface Water• Minimal risk for manganese

Sediment• Low risk for TEQ and mercury

14

Risk Characterization – Aquatic, Ponds

Surface Water• Moderate risk for barium and manganese

Pore Water• Low risk for selenium

• Moderate risk for barium and manganese

Sediment• Low risk for arsenic, copper, selenium, silver

and zinc

• Moderate risk for cadmium, manganese,

mercury, and TEQ

15

Risk Characterization – Wildlife, CFR

Kingfisher, Osprey, Otter, Mink

• Low risk for mercury, methylmercury for

kingfisher and osprey

• Similar risk upstream vs downstream

• Low risk for aluminum for otter, mink

• Similar risk upstream vs downstream

16

American Dipper, Tree Swallow, Mallard

• Low – moderate risk for aluminum, barium,

copper, mercury, methylmercury, and

vanadium

Risk Characterization – Birds, Creeks & Ponds

17

Grouse, Kestrel, Flicker, Nutcracker, Robin, Catbird

• Low – moderate risk for TEQ, copper,

aluminum, mercury, and vanadium

• Potential high risk for mercury for robin

Risk Characterization – Birds, Terrestrial

18

Bat, Fox, Deer, Shrew, Vole, Mouse

• Moderate – high risk for aluminum

• Low risk for mercury

• Low – moderate risk for TEQ

Small Mammal Tissue

• Potential risk for TEQ

Risk Characterization – Mammals, Terrestrial

19

Conclusions

Aquatic

• Low risk to aquatic receptors using CFR

• Risks to piscivores using the CFR are low

• Risks to fish based on tissue concentrations are low

• Risks to aquatic receptors using Ponds may occur

• Risks to birds using Creeks may occur

20

Conclusions

Terrestrial

• Potential adverse effects to plants/soil invertebrates

• Aluminum may be posing risk to wildlife

• Risks to large home range receptors are low

• Risks to medium home range receptors are low

• Risks to small home range receptors may occur

OU2/OU3 HHRA Update

• Evaluate potential risks to current and future users based on

existing conditions

– HHRA assumes individuals do not take actions to mitigate exposures

– Use conservative assumptions such that the possibility of adverse

effects are not expected with a reasonable degree of certainty

– Exceeding a level of concern does not necessarily mean adverse

effects should be expected, but theoretically possible if maximally

exposed and sensitive

• Intended to inform risk management decisions and the RI

– Evaluates potential site-related contaminants

– HHRAs do not evaluate source attribution


Risk Assessment Basics

• Risk = Exposure x Toxicity

• Exposure: Concentration in Media x Intake Factor

– Central Tendency Estimate (CTE), Reasonable Maximum Exposure (RME)

• Toxicity: Threshold dose for the most sensitive effect (mg/kg bw-d)

– Measured from animal or epidemiological studies

– Divided by uncertainty factors to ensure protectiveness

• Non-cancer vs. cancer effects

– Hazard Quotient (HQ), Hazard Index (HI) >1.0

– Added cancer risk > EPA risk management range (1 in 1,000,000 = 1x10-6,

1 in 100,000 = 1x10-5, 1 in 10,000 = 1x10-4)


HHRA Exposure Scenarios

OU2 – Core Industrial Footprint

• Hypothetical Future Residents

• Hypothetical Future Commercial/Industrial Workers

• Hypothetical Future Construction Workers


OU3 – Peripheral WasteTreatment Areas• Hypothetical Future

Residents• Hypothetical Future

Commercial/Industrial Workers

• Hypothetical Future Construction Workers

• Recreators• Hiker• Camper• Recreational Fisher• Tribal Fisher

OU2/OU3 Exposure Media by Receptor


• OU2/OU3 Future Resident

• Groundwater

• OU2 Soil

• OU3 Upland Soil

• OU2/OU3 Commercial/Industrial Worker

• Groundwater

• OU2 Soil

• OU3 Upland Soil

• OU2/OU3 Future Construction Worker

• OU2 Surface/Subsurface Soil

• OU3 Upland Soil

• OU3 Hiker

• Surface Water

• Upland Soil

• Floodplain Soil

• OU3 Camper

• Surface Water

• Upland Soil

• Floodplain Soil

• OU3 Recreational Fisher

• Surface Water

• Floodplain Soil

• Sediment

• Fish

• OU3 Tribal Fisher

• Surface Water

• Floodplain Soil

• Sediment

• Fish

Media and Analytes Sampled

OU2 – Core Industrial Footprint• Media Sampled

– Surface & Subsurface Soil (Figures

3-2 & 3-3)

– Groundwater (Figures 3-4 & 3-5)

• Contaminants Analyzed

– Dioxins/Furans (Toxic Equivalency,

TEQ)

– Polychlorinated Biphenyls (PCBs, as

Aroclors)

– Metals

– Volatile Organics (VOCs)

– Semi-volatile organics (SVOCs)


OU3 – Peripheral WasteTreatment Areas• Media Sampled

• Upland Surface & Subsurface Soil

(Figures 3-4 & 3-6)

• Floodplain Surface Soil (Figure 3-5)

• Groundwater (Figure 3-2)

• Sediment & Surface Water (Figures

3-7 through 3-9)

• Fish Tissue (Figure 3-10)

• Contaminants Analyzed

• Dioxins/Furans (TEQ)

• Polychlorinated Biphenyls (PCBs) as

Aroclors

• Metals

• Volatile Organics (VOCs)

• Semi-volatile organics (SVOCs)

COPC Screening Process


Contaminants of Potential Concern (COPC) Screen

• OU2 Soil

– TEQ, Aroclor 1254

• OU2 Groundwater

– TEQ

– Co, Fe, Mn


• OU3 Upland Soil

• TEQ, Sb, Cd, Mn

• OU3 Floodplain Soil

• TEQ, Ba, Hg

• OU3 Groundwater

• TEQ, Al, As, Cr, Co, Fe, Mn, Ni, V

• OU3 CFK Surface Water

• None

• OU3 Creek Surface Water

• None

• OU3 CFK Sediment

• None

• OU3 Creek Sediment

• None

• OU3 Fish Tissue

• TEQ*, total PCBs

OU2 Risk Characterization

• Future Resident (Tables 5-1, 5-4, 5-6)

– Soil risks do not exceed levels of concern

– GW risks exceed levels of concern for 4 shallow (Unit 1) wells

• Mn, Fe, Co

• Risks below levels of concern at deep (Unit 3) wells

• Future Commercial/Industrial Worker (Tables 5-2, 5-5, 5-6)

– Soil risks below levels of concern

– GW risks exceed a level of concern for a single shallow GW well

• Log Chipper Well (Co)*

• Future Construction Worker (Table 5-3)

– Soil risks do not exceed a level of concern


OU3 Risk Characterization


• Future Resident (Tables 5-1, 5-3, 5-4, 5-6)

– Soil risks exceed a level of concern near Settling Pond 17 (Grid 74): TEQ

– GW risks exceed a level of concern for 18 shallow wells (Mn, As, Co)

• Future Commercial/Industrial Worker (Tables 5-1, 5-5, 5-7)

– Soil risks do not exceed levels of concern

– GW risks exceed a level of concern for 18 shallow wells (Mn, As, Co)

• Future Construction Worker (Table 5-1)

– Surface soil / subsurface soil do not exceed a level of concern

• Hiker/Camper/Fisher (Table 5-2)

– Risks from upland soil & floodplain soil do not exceed a levels of concern

OU3 Risk Characterization (continued)

• Recreational Fisher (Table 5-8)

– Risks from fish consumption exceed a level of concern for some exposure scenarios

– Northern pike fillet: RME non-cancer (PCB TEQ & D/F/PCB TEQ) and RME cancer risks (total PCBs)

– Rainbow trout fillet: recreational consumption does not exceed levels of concern

– D/F TEQ does not exceed a level of concern for recreational consumption of northern pike or rainbow trout fillets

• Risks driven by PCB TEQ and total PCBs


OU3 Risk Characterization (continued)

• Tribal Fisher (Table 5-9)

– Risks from fish consumption exceed a level of concern

– Northern pike and rainbow trout fillet RME non-cancer risks (PCB TEQ, D/F/PCB TEQ) and RME cancer risks (total PCBs)

– Northern pike whole body CTE & RME non-cancer risks (PCB TEQ, D/F/PCB TEQ) and CTE & RME cancer risks (total PCBs)

– Rainbow trout whole body RME non-cancer risks (PCB TEQ, D/F/PCB TEQ) and RME cancer risks (total PCBs)

– D/F TEQ does not exceed a level of concern for tribal consumption of northern pike or rainbow trout (fillet & whole body)

• Risks driven by PCB TEQ and total PCBs


Risk Characterization and Uncertainty

• Figures 6-1 through 6-4 offer visual depictions of fish

consumption risks by location

– D/F TEQ vs PCB TEQ vs D/F/PCB TEQ

• Tables 6-1 through 6-3 examine potential effects on risk

estimates using higher tribal consumption rates

– RME D/F TEQ risks exceed a level of concern when higher fish

consumption rates are considered

– Uncertainty Section contains detailed discussion


HHRA Next Steps

• HHRA presentation during February 4th CAG

meeting

• OU2/OU3 HHRA Comments due February

19th

• You may contact me with questions or to

request additional information at

[email protected]


Smurfit Groundwater CSM

Process:

• Iterative draft development with MDEQ and EPA input

• Concurrent review with public stakeholders for version 3

Schedule

Document Dates

Draft Risk Assessments • OU2/OU3 Baseline Ecological Risk Assessment• OU2 Human Health Risk Assessment• OU3 Human Health Risk Assessment

comments due by February 19th

at 5 pm

Groundwater Conceptual Site Model, version 4 March 2021

Draft RI Report TBD

Additional Handouts As needed, to support site-related activities


Meetings Date/Time/Location

Frenchtown Community Advisory Group February 4th, 6 pm, Zoom call

2021 Quarterly Teleconferences

• January 26

• April 27

• July 27

• October 26


Environmental Protection Agency Montana Department of Environmental

Quality

Allie Archer: Remedial Project Manager

406-438-6255

[email protected]

Keith Large: State Project Officer

406-444-6569

[email protected]

Jennifer Chergo: Community Involvement Coordinator

303-312-6601

[email protected]

Katie Morris: Human Health and Ecological Risk

Assessor

406-541-9017

[email protected]

Will Folland: Human Health Toxicologist

303-312-6365

[email protected]

Sara Edinberg: Hydrogeologist

406-444-6797

[email protected]

Brian Sanchez: Ecological Toxicologist

303-312-6659

[email protected]

How to access EPA online documents:

EPA Smurfit Reports & Documents

https://cumulis.epa.gov/supercpad/SiteProfiles/index.c

fm?fuseaction=second.docdata&id=0802850Sarah Teschner: Hydrogeologist

303-312-7056

[email protected]

Region 8 Community Update Winter 2021 Smurfit-Stone Mill Site, Frenchtown, MT

SITE UPDATE The 3,200-acre Smurfit-Stone Mill Site is located 11 miles northwest of Missoula, Montana. A pulp mill

operated on site from 1957 to 2010. In 2013, EPA proposed the Site as a national priority under EPA’s

Superfund program. In 2015, the potentially responsible parties for the Site, WestRock; International

Paper; and M2Green Redevelopment, agreed to investigate the Site. The remedial investigation (RI) is

ongoing to characterize the contamination; assess potential risks to human health and the

environment; and inform what clean up actions are required. EPA works with DEQ to oversee the

investigation.

The Site is currently organized into three operable units (OUs):

• OU1 covers approximately 1,200 acres; largely agricultural lands.

• OU2 is approximately 255 acres and encompasses the core industrial footprint of the mill.

• OU3 includes approximately 1,700 acres of the settling ponds and parts of the Clark Fork River

floodplain.

Summary of Risk Characterizations:

The primary purpose of the baseline risk assessment is to provide risk managers with an understanding

of the actual and potential risks to human health and the environment posed by the site and any

uncertainties associated with the assessment. This information may be useful in determining whether a

current or potential threat to human health or the environment exists that warrants future remedial

action.

Documents are available for public review & comment on the EPA Smurfit-Stone website until 5 pm on

February 19, 2021:

• Draft OU2 Human Health Risk Assessment


• Draft OU2 and OU3 Baseline Ecological Risk Assessment

OU1 Human Health and Ecological Risk Assessments

EPA completed risk assessments for OU1 in 2017 with the objective to identify any impacts from

airborne deposition of COPCs to surface soils. No elevated levels of any contaminants of potential

concern, including dioxins, were found, and EPA determined OU1 does not pose a potential human

health concern. Ecological risk in OU1 is limited to selenium in soils, which poses a low risk to mammals

and plants.


OU2 & OU3 Human Health Risk Assessment

EPA’s draft human health risk assessment is the process to estimate the nature and potential for

adverse health effects in humans who may be exposed to chemicals in contaminated environmental

media, now or in the future.

OU2 Human Health Risk Assessment

• As described in the draft HHRA, risks to potential human receptors from exposures to OU2 soils

do not appear to exceed USEPA’s health guidelines.

• Total risks (exposure to soil and groundwater) are driven by exposures to groundwater; risks

from exposures to OU2 soils do not contribute significantly to total risk.

OU3 Human Health Risk Assessment

Risks to Hypothetical Future Residents

• As described in the draft HHRA, risks to potential future residential receptors from exposures to

OU3 soils within the upland areas do not appear to exceed USEPA’s health guidelines anywhere

except within the area of former settling pond 17 (grid 74).

• Elevated levels of manganese and arsenic, and to a lesser extent cobalt and iron, in groundwater

may contribute to risks above a level of concern for hypothetical future residents who consume

Site groundwater as drinking water.

Risks to Hypothetical Future Workers

• Risks to potential commercial/industrial and/or construction workers from exposures to OU3

soils do not appear to exceed USEPA’s health guidelines

Risks to Tribal Fishers and Recreational Visitors

• Risks to recreational visitors (hikers, campers or fishers) from exposures to OU3 soils do not

appear to exceed USEPA’s health guidelines. Exposure to sediments and surface waters from on

Site creeks or the CFR appear to be influenced significantly by either naturally occurring

concentrations or other anthropogenic sources as evidenced by statistical tests that found

concentration distributions between Site and upstream samples to be equivalent.

• Recreational fishers may potentially experience elevated non-cancer hazards from consuming

the fillets of northern pike, while non-cancer hazards and cancer risks for recreational fishers

consuming rainbow trout fillets did not exceed a level of concern.

• Tribal fishers who consume their catch from the CFR adjacent to and downstream of the Site

potentially have a higher risk of adverse effects than a recreational fisher based on a higher

assumed ingestion rate. Consumption of rainbow trout or northern pike fillets appear to be

associated with non-cancer hazards above USEPA’s health guideline (HQ˂1E+00) for a tribal

fisher.

OU2 & OU3 Baseline Ecological Risk Assessment

Aquatic Setting

• Risks to aquatic receptors, including fish, from direct contact exposures with Site-related

Contaminants of Potential Ecological Concern (COPECs) in the CFR appear to be low.

• Risks to aquatic receptors from direct contact exposures with Site-related COPECs in O’Keefe

and LaValle Creeks appear to be minimal.


• Risks to aquatic receptors in on-Site ponds may occur.

• Risks to aquatic-dependent wildlife are generally low.

Terrestrial Setting

• Metal contamination in Site soils may be causing adverse effects to plants and soil invertebrates.

• Aluminum concentrations in Site soils may be contributing to adverse effects in wildlife.

• Risks to large home range wildlife receptors are low (excluding risks associated with ingestion of

aluminum).

• Risks to medium home range wildlife receptors are low to moderate. Exposures to mercury as

inorganic mercury in soils and as methyl mercury in prey items may result in adverse effects.

Groundwater Conceptual Site Model

EPA and DEQ are finalizing response-to-comments.

Documents

Site Related Documents are available at: www.epa.gov/superfund/smurfit-stone

Recently Available



• Draft OU2 and OU3 Baseline Ecological Risk Assessment

• Monthly Progress Reports

Upcoming Documents

• Site-specific Handouts

• Groundwater Conceptual Site Model, V4

• Draft Reuse Assessment

Upcoming Meetings

DATE MEETING TOPIC LOCATION

FEBRUARY 4 CAG Meeting Zoom Call

APRIL 27 Spring Quarterly Teleconference Teams Meeting

JULY 27 Summer Quarterly Teleconference Teams Meeting

OCTOBER 26 Fall Quarterly Teleconference Teams Meeting

Community Advisory Group (CAG) Meeting

A Community Advisory Group has formed for the site and their mission is to serve as a trusted liaison

between the community and EPA/DEQ by becoming informed, sharing this information with the public,

and engaging in the Superfund process to ensure the restoration of the Smurfit-Stone Mill site to a

healthy ecological state for future generations. The group meets on the first Thursday of the month at 6

p.m. at the Frenchtown Fire Hall, 16875 Marion Street, Frenchtown, Montana.


Spring Quarterly Teleconference

EPA is hosting quarterly teleconferences to update the community and interested stakeholders on Site

progress, activities, and future steps. Contact Allie Archer or Jennifer Chergo if you are interested in

attending the call.

SSSSMURFIT STONE AGENCY CONTACTSMURFIT STONE AGENCY CONTACTSMURFIT STONE AGENCY CONTACTSMURFIT STONE AGENCY CONTACTS • Allie Archer, EPA Remedial Project Manager: 406-438-6255; [email protected]

• Jennifer Chergo, EPA Community Involvement Coordinator: 303-312-6601;

[email protected]

• Will Folland, EPA Human Health Toxicologist: 303-312-6365; [email protected]

• Brian Sanchez, EPA Ecological Toxicologist: 303-312-6659; [email protected]

• Sarah Teschner, EPA Hydrogeologist: 303-312-7056; [email protected]

• Keith Large, DEQ State Project Officer, Montana DEQ: 406-444-6569; [email protected]

• Katie Morris, DEQ Human Health and Ecological Risk Assessor: 406-541-9017;

[email protected]

• Sara Edinberg, DEQ Hydrogeologist: 406-444-6797; [email protected]

smurfit-stone/frenchtown mill site

Documents