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Site Type: Proposed NPL
Updated May 2015
EPA conducted a Preliminary Assessment/Site Inspection at the Smurfit-Stone Mill site in 2011 and 2012 that identified environmental contamination at the site. As a result of this limited investigation, EPA is pursuing a thorough environmental investigation of the site, known as a Remedial Investigation, to determine the nature and extent of contamination.
EPA has identified and notified parties potentially responsible for the environmental contamination. EPA is working with these parties to develop a plan for the comprehensive Remedial Investigation, the first step toward cleaning up the site.
The Smurfit-Stone Mill was a large integrated pulp and paper mill that operated from late 1957 through early 2010. The former mill is located on the eastern bank of the Clark Fork River, 11 miles northwest of the city of Missoula, in Missoula County, Montana. It covers approximately 3,200 acres. The mill is located approximately three miles south of the town of Frenchtown and has often been referred to as the Frenchtown Mill.
The core industrial footprint of the mill site covers approximately 100 acres. Over 900 acres of the site consist of a series of unlined ponds used to store both treated and untreated wastewater effluent from the mill as well as primary sludge recovered from treated wastewater. Some ponds, which were initially used to store wastewater, were subsequently drained and used for the land-filling of various solid wastes produced at the mill. The site includes landfills used to dispose of solid wastes, including general mill refuse, boiler fly ash, lime kiln grits, ragger wire and asbestos.
The site began operation as a pulp mill in the fall of 1957. Later expansions and improvements allowed the facility to produce paper, primarily rolls of kraft linerboard, which is used in the production of corrugated containers (i.e., the outside layers of cardboard boxes). Linerboard produced at the mill was shipped to box plants, where it was used to make a variety of corrugated containers. The mill ceased operations in January 2010.
Various hazardous chemicals were used or produced on-site, including high pH (alkaline) fluids, which were used as part of the pulping process, and bleaching agents.
The use of chlorine for the bleaching of pulp produces chlorinated organic compounds, including dioxins and furans, through the reaction of chlorine with residual lignin. Dioxins and furans are the short names for a family of toxic substances that all share a similar chemical structure and health effects. Studies have shown that exposure to dioxins at high enough levels may cause a number of adverse health effects, including cancer. Dioxins and furans are the short names for a family of toxic substances that all share a similar chemical structure and health effects. Studies have shown that exposure to dioxins at high enough levels may cause a number of adverse health effects, including cancer.
|Media Affected||Contaminants||Source of Contamination|
|surface soils (former sludge, wastewater and emergency spill ponds)||dioxins, furans, various metals including arsenic, cadmium, lead and manganese; semi-volatile organic compounds such as methylphenol, di-n-butyl phthalate, phenanthrene and naphthalene||direct contact with primary sludge, wastewater|
|surface water||dissolved manganese||primary sludge and wastewater ponds|
|river sediments||dioxin, furans||primary sludge and wastewater ponds|
|groundwater||dioxins, furans, various metals including manganese, arsenic, chromium and lead||leaching from primary sludge and waste water ponds|
An Analytical Results Report for a Combined Site Inspection and Removal Assessment was completed for the Smurfit-Stone Mill site in August 2012. Results from that report are summarized here. The full report for this investigation, as well as other investigations, is available in Site Documents below.
Soil Exposure Pathway – Soil samples were collected from sludge ponds, wastewater holding ponds and an emergency spill pond at the site. Samples were not collected from landfills at the site. Multiple congeners of dioxin were detected at levels greater than background concentrations. Metals and other inorganics, such as arsenic and manganese, were detected above background concentrations in two sludge ponds. Sludge ponds 3 and 17, and emergency spill pond 8, had the highest concentrations of contaminants of the locations sampled on the site. It should be noted that only a subset of ponds at the site were sampled.
Groundwater Migration Pathway – Shallow groundwater at the site had detections of multiple dioxin congeners (related substances) and manganese. Arsenic was also present in the shallow groundwater at levels exceeding federal drinking water standards. Nearby down-gradient and cross-gradient domestic wells draw water from a deeper aquifer, and the wells that were sampled did not show any indication that they are currently impacted by the site.
Surface Water Migration Pathway – Sediments from the Clark Fork River had detections of multiple dioxin and furan compounds at higher than background concentrations. Additionally, dissolved manganese in the surface water was detected at higher than background concentrations. This stretch of the Clark Fork River is used by anglers. Fish tissue samples were not collected as part of the site assessment. With the limited amount of data captured as part of this sampling event, it is unknown if bioaccumulation of these contaminants is a concern.
Air Migration Pathway – Air samples were not collected as part of this sampling event. It has been reported to MDEQ and Missoula County Health Department that fugitive dust emissions have occurred since operation at the site has ceased and the ponds have dried up. These dusts may contain similar compounds as those detected in other surface soil samples from the site.
EPA proposed the Smurfit-Stone Mill site to the National Priorities List (NPL) in 2013. EPA continues to review public comments received on the proposal. In regard to ongoing work, EPA is currently pursuing a thorough environmental investigation of the site, known as a Remedial Investigation. The Remedial Investigation will determine the nature and extent of contamination, delineate the contamination source areas and determine how contaminants may impact human health and the environment. The results of the Remedial Investigation are used to justify cleanup decisions at the site. EPA has identified and notified parties potentially responsible for the environmental contamination and will be working with these parties to develop a plan for a comprehensive Remedial Investigation in an efficient manner. Throughout, EPA and the community will work collaboratively to determine a path forward to ensure that the site is fully characterized and any necessary cleanup occurs in a timely manner.
You will need Adobe Reader to view some of the files on this page. See EPA's PDF page to learn more.
Federal Register notice of National Priorities List, Proposed Rule No. 59 (PDF), December 12, 2013(9 pp, 254 K)
Federal Register notice of National Priorities List, Proposed Rule No. 58 (PDF), May 24, 2013(8 pp, 226 K)
Letters supporting NPL proposal from Montana Governor Schweitzer, the Confederated Salish and Kootenai Tribes Tribal Council, Missoula County Commissioners, Missoula County Board of Health and the Missoula County Water Quality Advisory Council, November–December 2012
Public Presentation: Overview of EPA Activities, November 8, 2012
Results Fact Sheet, November 8, 2012
- 1. How did the EPA learn about the site?
After the Smurfit-Stone Mill closed in 2010 and sat vacant for most of a year, the Montana Department of Environmental Quality (MDEQ) requested that EPA conduct a preliminary assessment (PA) and site inspection (SI) to determine environmental impacts from the former operation.
- 2. What is the EPA doing?
EPA completed a preliminary assessment and site investigation in 2011 and 2012, respectively, at the request of MDEQ. A site inspection includes environmental sampling to determine what contaminants are present at the site and if the contamination is migrating off-site. EPA collected samples from the surface soils and subsurface soils at the site. EPA also collected samples from the groundwater, nearby domestic wells and surface water and sediment samples from the Clark Fork River, which flows by the western edge of the site.
While the site was proposed for listing in spring 2013, EPA has not yet made a final decision on the proposal to place the site on the NPL. EPA is still responding to the comments received on the proposal. Simultaneously, regional staff is working with the PRPs to begin the RI/FS process.
- 3. What contaminants have been found at the site?
The data that EPA has collected indicates that there are multiple contaminants present above background conditions in the surface and subsurface soils at the site. Various dioxin and furan compounds were detected in the sludge ponds soils, emergency spill pond soils, and the wastewater storage pond soils. Manganese was also detected at the site in the sludge pond soils and emergency spill pond soils.
- 4. What contaminants have been found in the groundwater and Clark Fork River?
Sediments from the Clark Fork River had detections of dioxin congeners (related chemicals) and manganese. This stretch of the Clark Fork River may be used by anglers. With the limited amount of data captured as part of the sampling event, bioaccumulation of these contaminants may be a concern.
- 5. Does an emergency situation exist?
No. While documented releases to the Clark Fork River exist, sampling data does not indicate that an emergency situation currently exists.
- 6. Is drinking water in the area safe?
At this time EPA is not aware of any people who are drinking contaminated water. Nearby drinking water wells were sampled and did not show any evidence of impact from the site. Missoula’s water supply comes from upstream sources and Frenchtown’s water supply is a groundwater source.
- 7. Are the fish and crayfish in the area and down river safe to eat?
No fish or crayfish studies were conducted during EPA's site assessment. A full risk assessment, including the evaluation of human food chain concerns, could be conducted as part of a more comprehensive remedial investigation.
The state conducted a fish study near the site on the Clark Fork River. Based on the study, Missoula County issued an advisory about the number of fish that would be safe to eat from this portion of the river. For more information see the Montana Fish, Wildlife & Parks news release.
- 8. What would happen if the site flooded?
While flooding is a possibility and concern, EPA has yet to fully characterize the site and thus cannot speculate what would happen in the event of a flood. Flooding hazards would be evaluated as part of a more comprehensive remedial investigation.
- 9. Is this a Superfund Site?
This site is not on the NPL. EPA has proposed the site to the NPL, but has not yet made a final decision.
- 10. Does the site qualify for addition to the National Priorities List under the Comprehensive Environmental Response, Compensation and Liability Act (also known as CERLCA or Superfund)?
Yes. Based on contaminants present at the site and documented impacts to the Clark Fork River, the site does qualify for the NPL.
- 11. Why hasn’t the site been finalized to the NPL?
While comments on the listing package are being addressed, EPA regional staff is focused on the work that should occur on the ground. We know there are contaminants at the site that need to be investigated and potentially remediated. The community has asked for an efficient process to investigate and remediate the site, and EPA believes trying to work with the PRP group to complete this effort can be an effective path forward.
- 12. Does the site need to be finalized for cleanup to more forward?
EPA has the authority and ability to complete the necessary investigation without the need to finalize the site at this time.
- 13. What is a remedial investigation and feasibility study (RI/FS)?
The RI/FS process is the beginning of analyzing a site and understanding different cleanup options. A remedial investigation is a more comprehensive sampling effort that determines the nature and extent of contamination at a site. A feasibility study then evaluates potential cleanup alternatives.
- 14. Will EPA withdraw the proposed listing in order to support redevelopment of the site?
Any redevelopment is predicated on an adequate assessment and a durable commitment to address risks identified by the assessment. Furthermore, withdrawing the site at this point would be inconsistent with EPA guidance.
- 15. Can EPA oversee and ensure that cleanup occurs outside of the NPL process?
Yes, particularly when there is a viable party responsible for the contamination at a site. EPA can reach a legally-enforceable agreement with this party or parties to conduct a remedial investigation and cleanup.
- 16. What are the benefits of the NPL?
NPL listing ensures that a site will be addressed, regardless of whether there is a responsible party to pay for it. In other words, a site that is listed on the NPL is eligible to receive money from the Superfund to facilitate cleanup. NPL listing also ensures resources for communities to help them better understand the technical issues and guarantees the citizens will have the opportunity to provide input in the process and comment on decisions before they are made. Community involvement is ongoing throughout the investigation and cleanup.
- 17. Who decides how an NPL site is cleaned up?
EPA and the states have the authority under the Superfund law to make the final clean up decisions. However, the Superfund law also requires that the community be given opportunities to have meaningful input on how the cleanup is completed. EPA is committed to involving any interested citizens or groups along with state and local government throughout the decision process.
- 18. How long will it take to clean up under Superfund?
The length of the cleanup will be dependent on many factors, including the types of contaminants found and the extent of contamination, etc. These factors have not been fully defined, which further work would accomplish.
- 19. How much will cleanup cost?
At this point we have no way of knowing as we only have limited site data. Full site characterization is necessary prior to considering cleanup options and associated costs.
- 20. Who will be responsible for paying for any work at this site?
EPA adheres to the polluter-pays principal. EPA looks for PRPs to assist or pay for the investigation and cleanup of the environmental problems they have caused.
- 21. Can private investment and redevelopment occur if the site is placed on the NPL?
Yes. In fact, the EPA Superfund Redevelopment Initiative was developed for just this purpose and has been highly successful. Available tools and resources, as well as several case studies, can be viewed on the Superfund Redevelopment page.
- 22. Can the property be transferred or leased during the cleanup?
The Superfund program has many examples where property is transferred or leased during investigation and cleanup. It is important that this is done thoughtfully so that new owners/renters do not inadvertently become liable for contamination that they did not cause.
- 23. Can the existing buildings on site be used?
Existing buildings are often able to be used. Consideration needs to be given to worker health and safety due to potential contamination exposures as well as the structural soundness of the building. Knowing that there is interest in reuse of the buildings can help guide and prioritize cleanup related activities.
- 24. What redevelopment options are available during cleanup?
This is a site-specific issue. Knowing that redevelopment is important to the local government, the Site team can begin working with stakeholders early in the process to see how and what redevelopment can be safely started while investigation and cleanup are occurring. We have many examples of sites where this has been successfully done.
- 25. What can EPA do to help communities facilitate reuse/redevelopment at Superfund sites?
Under the Superfund Redevelopment Initiative (SRI), EPA can fund activities that facilitate reuse, as long as those activities are designed to project the future land use. Anticipating the probable future use of a Superfund site after it has been cleaned up is of key importance in selecting and designing a remedy that will be consistent with that use. Activities that are appropriate for funding under the SRI include the following:
- Community needs assessments that identify major issues, needs and desires of the local officials and the community related to the anticipated future use;
- Analyses that identify area market conditions and trends to provide a realistic understanding of the uses and activities that could occur on-site;
- Physical site evaluation to determine assets and constraints of the site and available infrastructure (e.g., transportation, utilities);
- Stakeholder and community outreach on reuse options; and
- Preparation of reports documenting the results of the analyses and describing anticipated future uses, and coordination of the reuse planning activities with the Superfund response process.
- 26. When can the community become involved in reuse/redevelopment decisions?
This is a site-specific issue. A Reuse Assessment is part of the RI/FS process. This is typically the time when communities provide input into the potential reuse/redevelopment options.
- 27. Can portions of the property be immediately excluded from the site? (Excluded after sampling.)
If, based on sampling and analysis done under EPA oversight, we can document that an area is free from contamination.
- 28. Would local contractors be used as part of the cleanup efforts?
EPA typically uses a pre-placed contract for the investigation efforts and then advertises and awards a contract for the cleanup work. Even if a non-local firm is awarded the cleanup contract, the firm frequently hires local workers, and this can be encouraged.
An additional option if the cleanup is going to use a larger number of workers is the Superfund Job Training Initiative, which is an environmental remediation job readiness program that provides free training and employment opportunities for citizens living in communities affected by Superfund sites. This option can be explored further once the likely cleanup needed is known.
- 29. Can someone buy contaminated property without becoming CERCLA/Superfund liable?
Yes. As of January 11, 2002, a bona fide prospective purchaser (BFPP) may buy property with knowledge of contamination and maintain its protection from liability provided it conducts All Appropriate Inquiries (AAI), complies with continuing obligations and can demonstrate no affiliation with a liable party. For more information, see Landowner Liability Protections.
- 30. What does All Appropriate Inquiries mean?
All Appropriate Inquiries, or AAI is the process of conducting due diligence or a Phase I Environmental Site Assessment to determine prior uses and ownership of a property and assess conditions at the property that may be indicative of releases or threatened releases of hazardous substances. For liability purposes, a purchaser must conduct AAI prior to acquisition. For more information see, All Appropriate Enquires.
- 31. What are Continuing Obligations?
In order to maintain their protection from liability, a new owner of a contaminated property must comply with the following continuing obligations: (1) comply with any land use restrictions and institutional controls; (2) take reasonable steps with respect to hazardous substance releases; (3) provide full cooperation, assistance, and access to persons that are authorized to conduct response actions or natural resource restoration; (4) comply with information requests and administrative subpoenas; and (5) provide legally required notices.
- 32. Will National Priority List (NPL) listing affect my property values?
In the short-term, possibly, but not necessarily. In the long-term, studies have shown that a Superfund cleanup has a beneficial impact on the community, including rebounding property values.
- 33. How quickly can you start, what has to happen next?
EPA has identified and notified potentially responsible parties for the contamination at the site. EPA is working with these parties to develop an initial scope to conduct a comprehensive remedial investigation, the first step toward cleaning up the site.
- 34. What voice does the community have?
EPA works very closely with communities and states throughout a site investigation and cleanup. Some communities choose to be very involved and form a Community Advisory Group, others do not. EPA welcomes input and involvement from all stakeholders.
- 35. How are the site boundaries determined in the National Priority List (NPL) process?
Superfund designation includes the source, or release, of the contamination and wherever contamination may have spread and is a threat to human health and the environment. When a site is proposed, a basic area is described in the listing package, a report prepared and sent to EPA headquarters supporting why the site qualifies for placement on the National Priorities List (NPL). Boundaries are not determined until after the nature and extent of contamination is determined through the RI/FS process. If more contamination is found later in the cleanup process, the boundaries may be changed to include the new area. If less contamination is found than suspected, the boundaries may be changed to reflect the smaller size.
- 36. What is a 104(e) letter and why were the letters sent out?
Issuing information request letters is a basic component of nearly all potentially responsible party (PRP) searches. The request letters are used for information gathering purposes. Under section 104(e)(2) of CERCLA, EPA may require any person who has or may have information relevant to any of the following to furnish, upon reasonable notice, information or documentation relating to such matter, including:
- The identification, nature, and quantity of materials which have been or are generated, treated, stored, or disposed of at a vessel or facility or transported to a vessel or facility.
- The nature or extent of a release or threatened release of a hazardous substance or pollutant or contaminant at or from a vessel or facility.
- Information relating to the ability of a person to pay for or to perform a cleanup.
- 37. Who received 104(e) letters?
EPA sent letters to BNSF Railway, the Rock Tenn Company, International Paper Company, M2Green Redevelopment, Montana Rail Link and Missoula County.
- 38. Why did Missoula County receive a 104(e) letter?
Through EPA’s PRP Search Report, it discovered that, in the past, Missoula County owned some property at the site. Therefore, Missoula County may have information about hazardous substances or releases of hazardous substances at the site.
- 39. Does this mean that Missoula County is a Responsible Party?
EPA has sent Missoula County a general notice letter which states that the county may be a potentially responsibly party.
- 40. What are general notice letters, and were they sent to all the PRPs?
General notice letters inform recipients that they are identified as PRPs at Superfund sites; that they may be liable for cleanup costs at the site; and explains the process for negotiating the cleanup with EPA.
The letter also includes information on Superfund, the site, and may include a request for additional information.
Yes, general notice letters have been sent to BNSF Railway, the Rock Tenn Company, International Paper Company, M2Green Redevelopment, Montana Rail Link and Missoula County.
- 41. What are special notice letters, and were they sent to the PRPs?
EPA sends out a special notice letter when it is ready to negotiate with PRPs to clean up a site. A special notice letter gives PRPs information on why EPA thinks they are liable and the EPA’s plans for the cleanup of the site.
The letter also invites parties to participate in negotiations with EPA to conduct future cleanup work and pay the EPA for any site-related costs already incurred.
The special notice letter triggers the start of a "negotiation moratorium," which means that EPA agrees, for a certain period of time, not to unilaterally order the PRP to conduct the cleanup. This moratorium period is intended to encourage the PRPs to negotiate a settlement agreement promptly.
Yes, special notice letters have been sent to BNSF Railway, the Rock Tenn Company, International Paper Company, M2Green Redevelopment, Montana Rail Link and Missoula County.
Site Assessment Manager
U.S. Environmental Protection Agency, Region 8
1595 Wynkoop Street (EPR-B)
Denver, CO 80202-1129
800-227-8917 ext. 312-6664 (toll free Region 8 only)
Remedial Project Manager
U.S. Environmental Protection Agency, Region 8
400 North Main Street, Room 339
Butte, MT 59701
Community Involvement Coordinator
U.S. Environmental Protection Agency, Region 8
1595 Wynkoop Street (OC)
Denver, Colorado 80202-1129
800-227-8917 ext. 312-6879 (toll free Region 8 only)