EPA trashing sound CFAC cleanup strategies
EPA’s (Environmental Protection Agency) trash can is full of discarded cleanup strategies marked as “Too Costly,” “Too Risky,” “Good, But Not Top Rated,” “Why Do More, When Less is, OK?”
After months of study, the Coalition for a Clean CFAC is calling out the absolute lack of a sound factual basis for trashing many of these ideas. Instead, we are pointing out that these ideas were already studied and ranked by EPA as meeting its Threshold Criteria for Protection of Human Health and the Environment.
Many were ranked as more effective and permanent than current recommendations by studies EPA and Glencore have already done. That’s why in a recent letter to Gov. Gianforte and other elected officials, as well as EPA, the Coalition for a Clean CFAC is calling for reconsideration of many of these “trashed” ideas.
We believe these currently dismissed, existing tools and strategies need to be given priority in a revised cleanup plan, and that they hold the key to achieving a cleanup of the CFAC site that is timely, effective, and permanent.
For example, EPA trashed the idea of using active cleanup treatment of the toxic plume of groundwater on site now, despite their own consultant pointing out that if they treated the ground water plume now it could be cleaned up in 6 to 9 years, as opposed to the option EPA and Glencore chose that will take toxic waste in the plume 35-to 60 years to breakdown, if even then.
For another trashed solution, it was argued that soil caps (which only provide short-to-long term containment not treatment) were equally as effective as active treatment and stabilization, even though the latter has been used at hundreds of Superfund sites across the Country. (“Solidification/ Stabilization (S/S) transforms potentially hazardous liquid or solid contaminants of concern (COCs) present in soil or sediment into environmentally innocuous materials of considerably reduced mobility, thus preventing the hazardous waste from reaching receptors [like the Flathead River].” https://frtr.gov/matrix/Solidification-and-Stabilization/).
This treatment method is one of the top five treatment methods used at Superfund sites across the country and has been used successfully and safely to clean up cyanide.
We concur with recent concerns raised in a letter to EPA from the Confederated Salish and Kootenai Tribes about the toxic contaminants that Glencore plans to leave in the ground at the site, and how the cyanide, fluoride, and heavy metals impact the Flathead River and native trout.
And guess what we found in EPA’s and Glencore’s trash can?
Sample data that, while collected, was trashed and not included in a food chain model used to supposedly understand potential harm to aquatics and fish and potential harm to humans from fish consumption!
Equally important is what we didn’t find anywhere, including no analysis or data of future residential child cancer risks, given that the majority of this site is now proposed to be sold for residential development.
While there are more examples we could cite, we encourage you to go to the following link to read our more detailed letter to Gov. Gianforte, other elected officials, and EPA, and the CSKT Tribe’s letter to EPA. https://www.flatheadcitizens.org/recent-alters/.
Please ask EPA to revise the proposed cleanup plan so that the CFAC Superfund site cleanup plan can provide greater long-term, permanent protection of the Columbia Falls’ local economy, future redevelopment of the CFAC site, human health, and the Region’s clean water, healthy rivers, and fisheries.
The Board of the Coalition for a Clean CFAC, Shirley Folkwein, Phil Matson, Del Phipps, Laura Damon, Mayre Flowers, and Peter Metca