Libby Environmental Health Update

Monday, March 20, 2000

The Department of Environmental Quality (DEQ) is involved in the Libby investigations on several levels. The department is directly responsible for a request to release the final bond at the former mine site under the Montana Metal Mine Reclamation Act (MCA 82-4-101 et seq) (MMRA). Additionally, the DEQ is responsible for enforcing federally delegated air quality, water quality, public water supply, and hazardous waste disposal laws. The department also is responsible for working cooperatively with local, state and federal agencies to ensure the people of Libby have a clean and healthful place to live.

Vermiculite was discovered in 1881 at Vermiculite Mountain, approximately six miles northeast of Libby, in the Rainy Creek drainage, by miners hoping to discover gold. Its unique properties were recognized by Edward Alley in 1919, and in the 1920s the Zonolite Company was formed and began mining vermiculite. In 1963, W.R. Grace bought the mine and operated a mill until 1990, when the mine closed and reclamation began.

At times during the operation, the vermiculite mine produced up to 80% of the world's supply of vermiculite. It has been used in building insulation and as a soil conditioner. Unfortunately, the vermiculite ore from the Libby mine contained an associated waste rock that included a particularly toxic form of naturally occurring asbestos referred to as tremolite.

Passed in 1971, the MMRA acknowledges that mineral mining in Montana is a basic and essential activity that makes an important contribution to the state's economy, but at the same time, proper reclamation of mined land and former exploration areas is necessary to prevent undesirable land and surface water conditions that would be detrimental to the general welfare, health, safety, ecology and property rights of the citizens of the state. At the time the act was passed, almost 320 acres of land at the vermiculite mine were already disturbed and mine tailings were being discharged down the slopes of the mountain into the Rainy Creek Drainage.

DEQ has been involved at the mine site since the early 1970s when the Clean Air Act of Montana was passed. A series of 10 air quality permits were issued to W. R. Grace over the years for various pieces of air pollution control equipment and operations, including milling, concentration, drying, screening, storage, loadout, and bagging. The permits regulated primarily particulate emission and opacity limitations. Asbestos is a particulate, but was not regulated separately from total particulate probably because there was, and still is, no federal or state ambient air quality standard for asbestos. The permits were revoked in 1992 after completion of operations. A file review of air quality inspections of the operation indicated general compliance with the exception of one minor opacity violation at the dryer stack.

W. R. Grace applied for a permit to discharge wastewater to Rainy Creek in February 1971. In 1973, the company changed from dry beneficiation of the ore to a wet process with a subsequent increase in the discharge of process water. It received a permit in March 1971, which was extended in November 1971. The permit expired in January 1972. At that time the company had completed construction of the tailings impoundment, which the department considered a no discharge facility and no longer required a Montana Pollutant Discharge Elimination System (discharge) permit.

The impoundment does have an underdrain, which has been sampled. The level of pollutants is within water quality standards so a permit is not needed for the underdrain.

The impoundment has a spillway that discharges asbestiform fibers during high flows. The discharge over the spillway may require a discharge permit, but state Water Quality Bulletin-7 (WQB-7) limits for asbestos fibers may or may not apply. Sampling and health risk assessments in 2000 will evaluate the need for a permit and whether Rainy Creek needs to be diverted around the impoundment during high flows to prevent a discharge of asbestiform fibers.

The following is a brief summary of the mine's permitting, bonding and bond release history under the MMRA:

  • W. R. Grace applied for an operating permit from the former Department of State Lands (DSL) in November 1971. Bond was set at $100/acre on the original 320 acres of disturbance. Operating Permit 00010 was approved in January 1972.
  • In July 1977, December 1978, August 1979, July 1986 and September 1992, the operating permit was amended. The bond eventually increased to $472,000 for 1,004 acres of disturbance in the 1,200-acre permit boundary.

As areas were mined out, concurrent reclamation commenced.

  • After a legal notice was published requesting public comment, a partial bond release was approved on 14 acres in August 1988 and the bond was reduced to $467,242 for 990 acres of disturbance in the 1,200-acre permit boundary.
  • Mining ceased in September 1990, and final reclamation commenced. A final closure plan for the impoundment area was approved in September 1992 after a legal notice and environmental assessment were published and a public meeting was held in Libby.
  • After a legal notice was published, a second partial bond release was approved in September 1994. Reclamation of the entire mine site, according to the approved plan, was completed. The bond was reduced from $467,242 to $66,700 for 740 acres of disturbance in the 1,025-acre permit boundary. The bond was held for maintenance of the reclaimed areas. The bond was no longer needed on the 160 acres released from Operating Permit 00010 for the tailings impoundment. These acres are now regulated under a Montana Department of Natural Resources and Conservation (DNRC) Dam Safety Section operating permit (Application No. 1470A) which was approved December 1994.
  • In December 1994, the Kootenai Development Corporation (KDC) purchased the property and assumed the operating permits and bond. KDC has continued to maintain the site since 1994.
  • After the public notice process was completed, a third bond release was approved in September 1997 reducing the bonded acreage in the permit area to 125 acres because vegetation on reclaimed areas continued to improve. The bond for maintenance of the reclaimed acreage remained the same on the 125 acres at $66,700.

DEQ's involvement in Libby continued through June 1999 when the current owners of the former vermiculite mine, KDC, requested a final bond release for the property. The department agreed to publish the bond release request, and after a public comment period, decide on whether the bond release was appropriate or whether more work and monitoring were needed. A new public notice process was approved by the legislature in 1999 requiring a legal notice be published throughout the area and a press release for statewide media coverage. As a result, a request for public hearing from Lincoln County Commissioners was received. DEQ immediately agreed to conduct the hearing and coordinated all phases of the hearing with the local officials.

The DEQ held a public hearing in Libby to record comments on the proposed bond release on December 1, 1999. The department announced it would accept written comments to January 1, 2000.

The DEQ responded on March 2, 2000, to individuals who raised concerns. The responses address the entire 1,200-acre mine site, not just the 125 acres in the bond release request. The responses also address other possible health related issues resulting from vermiculite ore that left the mine site and was processed in Libby, as well as in other locations throughout the country. A decision on the bond release will not be made until a thorough site review is completed by the department later this year.

While focused on the MMRA, the department's review will also ensure that the entire mine site, access roads and streams in the Rainy Creek drainage are in compliance with state environmental health laws. This review will be coordinated with local, state and federal plans and include:

  • Air, water and soil sampling will be done at the mine this spring.

An air quality monitoring program will document the level of dust and fibers blowing off the entire site.

A detailed sampling plan involving sampling tailings, soil and waste rock will document the extent of contamination at the mine site. DEQ knows the tailings and/or soil contain at least an average of 5-7% tremolite, based on a Montana Department of Commerce publication from 1990. Water from several creeks and ground water in the mine area will be sampled to identify the level of asbestiform fibers. Based on the results of the sampling, decisions will be made on the amount of reclamation still needed at the mine.

  • Data collected in the early 1990s and again in 1999 indicate that asbestos levels in road materials in parts of the Rainy Creek Road were elevated. Although there is no air quality standard for asbestos fibers along the road, new information indicates that dust on the Rainy Creek Road may produce a continuing health hazard. Dust sampling by Lincoln County officials and W. R. Grace in 1991 and 1992 indicated that dust levels along Rainy Creek Road did not exceed standards based on the sampling method used at the time. Rainy Creek Road is a county road that passes through U.S. Forest Service (USFS) land and some land now owned by KDC. The DEQ will reevaluate sampling conducted along Rainy Creek Road in the early 1990s and review the new data. Only a small portion of the road was within the old mine permit boundary. If there is a health risk, DEQ will coordinate with local and federal officials to address the road issue.
  • The former Department of Health and Environmental Sciences (DHES) and W.R. Grace set up a water quality monitoring program in the early 1990s. Concerns were expressed again in 1999 about levels of milling reagents (diesel, fluoride) in the water in the impoundment, as well as asbestiform mineral fibers in the impoundment water. The DEQ re-sampled some sites again in September 1999. The only exceedance of any water quality standard at any sampling station was asbestiform mineral fibers in the tailing impoundment. The department plans to re-sample Rainy Creek and its tributaries during high runoff in the spring when the spillway from the impoundment is flowing. If the level of fibers is above acceptable levels (the ambient water quality standard for drinking water is 7 million fibers per liter in WQB-7), the DEQ will work with the DNRC Dam Safety Program and local and federal officials to address the issue.
  • The Rainy Creek drainage historically has been impacted by mine waste products since the 1920s. Rainy Creek downstream from the water intake for the former mine/mill (lower Rainy Creek) was classified as an impaired (C-1) stream in 1971. Upstream from that point it is classified A-1. The other waters in the Rainy Creek watershed and the Kootenai River are classified B-1. A-1 (ARM 17.30.622) waters are suitable for drinking and cooking after conventional treatment for removal of "naturally present impurities." While B-1 waters "are suitable for drinking, culinary and food processing purposes, after conventional treatment; . . ." (ARM 17.30.623), C-1 waters are not suitable for drinking and should not be used for that purpose (ARM 17.30.626). As a result, no one uses the water in Rainy Creek or its tributaries for drinking water. The impoundment was constructed in 1971 to contain the mine wastes. Rainy Creek water quality is probably better today than it has been for more than 50 years. Risks from old tailings in the drainage below the impoundment will also be evaluated in 2000.
  • W. R. Grace and KDC were given permission to dispose of certain solid wastes on site in a landfill. This is allowed under the MMRA as long as the disposal meets Montana solid waste regulations. Materials that were allowed to be buried on site included inert wastes such as concrete. W. R. Grace was also allowed to bury steel and asbestos shingles. Concerns have been expressed about how deep it is to ground water and if that ground water is contaminated by anything that may have been dumped illegally. DEQ plans to sample an abandoned well on the site to address this issue. The depth to water in the well is more than 200 feet deep. More wells will be installed if the old well is not located in an appropriate monitoring location. Reclamation of the disposal site will be reevaluated.
  • Concerns have been expressed about future development of the mine site. The concern is that new development will introduce more asbestiform mineral fibers in the air and water. DEQ will coordinate with Lincoln County and federal officials to identify controls needed on the old mine site to limit potential problems with future development proposals.
  • Concerns have been expressed that because the bond has been released on the majority of the site and because the land has been sold to KDC, that W. R. Grace is not responsible if air or water quality problems are identified. W. R. Grace has been cooperating with local, state and federal officials to address the issue. Any necessary cleanup will be conducted under the MMRA, Clean Air Act, Water Quality Act, Comprehensive Environmental Cleanup and Responsibility Act (state Superfund) and Comprehensive Environmental Response, Compensation, and Liability Act (federal Superfund), as needed.

In response to the widespread concerns of possible asbestos contamination in Libby, the DEQ sampled five public and private wells to check for ground water contamination from asbestos. The samples revealed no contamination. The sites included mobile home courts and a plant nursery operating in a former vermiculite screening facility.

City personnel had previously sampled Libby's public water system and found no asbestos contamination. However, DEQ decided to sample the system again to verify the initial findings. The city gets its drinking water from Flower Creek, which is geographically in a different drainage from the vermiculite mine. No asbestos contamination has been reported in that drainage.

In February, the DEQ announced the sample results revealed there was no asbestos in the samples taken from the city's water supply.  One sample was taken from untreated water entering the treatment plant. A second sample was taken from the finished (filtered) water leaving the plant.  Copies of the results were sent to the City of Libby, the Lincoln County Sanitarians Office, and the EPA Office in Libby.

Time and cooperation are the keys to answering the many environmental and public health questions in the Libby area.

Time is an important factor because it took time for the situation in Libby to develop and it will take time to identify and address any environmental and public health problems. Time is also a factor in determining the current investigation's impact on Libby's economy, tourism, business community and its citizens. If testing reveals environmental exposures still exist, it will take time to clean up or stabilize those sites. The result, however, will be an environment safe for people, in addition to being attractive for economic development, existing businesses and people visiting the area.

As for cooperation, when it became apparent that asbestos concerns ranged far beyond those associated with the request to release the bond at the mine, DEQ formed a group of department employees to work on the proposed bond release and asbestos investigation. The group includes: the person in charge of reviewing the proposal to release the bond, a project coordinator to work with EPA on the environmental health investigation, the DEQ's media manager and a project coordinator from the Director's Office to work with EPA and local, state, and federal public health officials. Additionally, these DEQ persons are drawing on the expertise of a number of persons throughout the department.

The DEQ and EPA investigation of possible asbestos contamination in the Libby area began with sampling in December 1999. The team collected air, soil (yard, garden and driveway samples), dust and vermiculite insulation samples. Samples were taken at 32 residences, as well as several potential areas of concern due to historic vermiculite-related activities.

To date, the state and federal team's investigation includes:

  • Approximately 73 air sample results from 32 residences, two businesses, and two former processing areas were received and reviewed. Transmission electron microscopy analysis was used to count asbestos fibers (10-grid system count looking for fibers 5 microns [: =one-millionth of a meter] or greater).
  • Results from the December air sampling event were released on January 31, 2000. Preliminary results indicate that two potential areas have relatively elevated levels of asbestos related fibers in the 5-10 micron range.
    • Two homes have elevated levels of asbestos fibers. Chrysotile (serpentine asbestos) was detected in one home and tremolite-actinolite fibers were detected in the other home. (The chrysotile is not related to the old vermiculite mine.)
    • The two former processing areas with elevated levels of tremolite-actinolite asbestos fibers present are the lumber facility at the former export plant and the plant nursery (Parker business and residence) at the former screening facility.
    • Of the remaining homes, 24 have trace levels of tremolite fibers. However, to make sure nothing was missed, these same samples were sent back to the laboratory to be re-tested with a more stringent analysis (lower detection limit) looking at fibers from 5 – 10 microns in length using a 30 grid count system.
  • Results from the second sampling were received in early March. After evaluating the data the EPA determined that approximately 1/3 of the homes have elevated levels of fibers excluded from the specific indicator length fibers. For example, fibers which were detected to have a (less than) <5:1 ratio, a length <0.5: (microns) or a diameter of (greater than) >0.5: are not considered to be a health risk to residents. These shorter fibers have not been determined, at this point, to be dangerous. The health experts are still debating the dangers of these fibers.

When evaluating the data for those fibers that fall within the specific fiber ranges, the following is evident: (1) 7 homes have detectable fibers of tremolite/actinolite ranging from 1 fiber to 2 fibers per 30 grid opening counts; (2) 6 homes have detectable fibers of chrysotile fibers ranging from 1 fiber to 7 fibers per 30 grid opening counts; (3) one residential home has elevated levels of both forms of fibers; and (4) air samples collected from the Railroad Loading Facility (Screening Plant) and the Export Facility have elevated levels of tremolite/actinolite fibers.

The EPA has converted the individual fiber counts to actual concentrations. When these values are compared to the data results, only the Railroad Loading Facility (Screening Plant), the Export Facility and one residential home have elevated levels of tremolite/actinolite fibers. One home has been identified to have elevated levels of chrysolite.

  • Surface dust samples were collected from the same residential homes used to collect indoor air samples. The March sampling results revealed 11 homes had detectable levels of actinolite/tremolite fibers present in the dust samples. The highest fiber count was 2 fibers per 10 grid opening count. These numbers have not been converted to concentrations at this point, but it is suspected that these levels do not pose a threat. In addition, these fibers are of the shorter length (0.5: - <5: ) and are not considered a human health risk. The longer fibers are considered a risk.

Of interest in these samples is that more than half of the samples collected showed elevated levels of chrysotile fibers. The majority of the fibers detected were of the length 0.5 to <5: and at this point are not considered a human health risk.

  • Surface dust sampling results were collected from five local schools. Only one sample contained a detectable fiber count of 1 fiber per 10 grid opening count. Of interest in these samples is that over 1/3 of the samples collected showed elevated levels of chrysotile fibers. The majority of the fibers detected were of the length 0.5 to <5: and at this point are not considered to be a human health risk.
  • The current owners of the former screening plant (now a plant nursery) are in the process of negotiating with the EPA, DEQ and W.R. Grace on various ways to undertake remedial actions. At this point the owners have decided to end business operations, and are discussing whether they will sell the property back to W.R. Grace.

The remedial work for the screening plant is expected to begin in May and will focus on the entire property and will include either total demolition of the property and buildings, or staged operations that will save the buildings. EPA's preferred remedial action is to scrape away the surface contamination from the entire property and haul the material to the mine site for disposal. W.R. Grace, at this point, seems to prefer a method of removing the identified "hot spots" from the property. No specific pattern exists which shows a single area or location that contains the highest concentration of contaminated soil. Instead, the data indicates that the asbestos contamination is spread throughout the property, with "hot spots" occurring in certain areas. In addition, the northern part of the property has not been sampled. EPA plans on collecting soil samples from the northern part of the property in the near future. The property encompasses roughly 21 acres.

When the screening plant was purchased, the current owners covered much of the land with several feet of tree bark and peat moss or paved selected areas with asphalt. According to the owners, they did not remove any soil prior to covering the land with bark or asphalt. Therefore, it can be assumed that the soil beneath these areas is potentially contaminated with asbestos fibers. Two concerns arise from this information. The subsurface soil samples were only taken to a depth of 2 feet. Therefore, the contamination may be below that level. Second, a large percentage of the property surface area is covered with asphalt (the exact surface area is unknown). Contamination may exist below the asphalt as well.

When actual remedial work begins, these areas will need to be scraped away. This will create a large volume of asbestos contaminated material (ACM) and possibly contaminated soil. If it is determined the former vermiculite mine is the best disposal site, the DEQ would be involved in determining a proper location and disposal method for the large amounts of ACM and contaminated soil.

Lastly, the property borders the Kootenai River. At this point, it is not known if contaminated material lies along the banks of the river. DEQ suggested to the EPA that more samples be collected when remedial work begins to determine how close cleanup must be done in proximity to the river. In addition, DEQ suggested that the EPA determine if the property is in the 100-year flood plain for the Kootenai River.

  • Soil sample results from the export plant indicate that removal of some areas is needed. At this point, it appears that "hotspot" removal may be the best option. The soil samples collected from around the baseball fields came back indicating no detection of contamination. As sample locations moved closer to the buildings, contamination concentrations increased, especially directly adjacent to the buildings. The highest concentration detected was >5% and was collected from the southern edge of the eastern baseball field or across from the former popping plant building.

W.R. Grace will fund the cleanup work based on the work plan approved by EPA and commented upon by DEQ.

  • A total of 29 residential home insulation samples were collected and analyzed. Two problems arose from the collection. First, the samples were taken as "grab" samples. For example, the sampler reached his/her hand into a crawl space or attic and grabbed one handful of insulation. Since this is not a composite of several locations within the home, this cannot be considered a true representation of the insulation. Second, the polarized light microscopy (PLM) (PLM microscopes determine minerals through interpretation of traditional optical properties) method has flaws when analyzing bulk matrix samples such as soils and insulation. The insulation has a large amount of non-asbestos fibers present. This creates an interference with the readings and can indicate a false positive or false negative in the data results.
  • A total of 58 soil samples were collected along Rainy Creek Road. Composite samples (5-point sampling - taking five samples near each other, then putting them together into a single, composite sample) were taken from the junction of Rainy Creek Road and Highway 37 up to the mine site. Samples were analyzed using PLM, with the same uncertainty occurring as previously mentioned.
  • A total of 27 soil samples were collected along the Conveyer Unloading Station. This site is located west of the Screening Facility across the Kootenai River. Composite (5-point) samples were taken from visible areas thought to be the location of the former conveyer and railroad loading area. Samples were analyzed using PLM, again, uncertainty arises from the data since the soil sample data has a large amount of non-asbestos fibers present, creating an interference with the readings.
  • A total of 194 soil samples were collected from 32 different residences. Composite (5-point) sample points ranging from 2 – 8 per home were taken from various locations in both the front and back of yards and gardens; not all homes had gardens. Samples included surface and subsurface soil samples. Samples were analyzed using PLM, with uncertainty occurring as previously stated. Of interest in this data set is the presence of non-fibrous amphibole asbestos fibers.
  • The federal Agency for Toxic Substances and Disease Registry (ATSDR) has taken the lead for the health screening project in Libby. ATSDR will work closely with the EPA and the Department of Public Health and Human Services (DPHHS) on developing an exposure assessment and a medical monitoring program, now called the Community Health Test (CHT). Screening of Libby residents will encompass those individuals living within a 2.5 mile radius of the mine and the former operating facilities in town. Approximately 5,000 residents are determined to be within this area. The order of who will be screened first is based on seven risk factors developed by ATSDR, EPA and DPHHS.
  • ATSDR, EPA and DPHHS are in the processes of purchasing the appropriate medical equipment. A large trailer will house the equipment and be used as the station for screening. The trailer will be installed as part of St. John’s Hospital in town.

    • A draft medical plan has been developed and commented on by the EPA and health experts involved in this project. A revised version of the report will be finished soon and will go out to the community for comment within a few weeks. Dr. Mike Spence and Dr. Todd Damrow, DPHHS, have been involved with this issue from the beginning and are keeping DEQ informed as the work proceeds.

Recent field work by EPA:

A. The EPA discovered that the property east of the former Screening Plant was owned and used by W.R. Grace as a possible storage and stockpile area. The property is currently owned by the KDC, the same group that currently owns the mine. The EPA has taken several surface and subsurface soil samples from the area. Data from the area will be available by the end of March.

B. The EPA collected several surface and subsurface soil samples in the forest around the mine for the USFS. The USFS wants to develop several helicopter landing areas in the Kootenai Forest. A few of these areas are located near the mine, therefore the USFS requested that the EPA collect soil samples from logged areas adjacent to the mine.

C. The EPA collected indoor air samples and dust samples from 42 additional homes in Libby. The sampling team is in Libby and has approximately 100 more homes to sample. Data will be available by the end of March.

D. The EPA is in the process of writing individual data reports for residents whose homes were sampled. The report, which DEQ will receive prior to mailing, will contain data results for air, soil, dust and insulation samples and an explanation of what the data means.

  • EPA opened a field office (the Storefront, 501 Mineral) in Libby. The office is being shared with DEQ and other state and federal agencies. The office is open from 8:30 a.m. to 5 p.m. every day except Tuesday. Tuesday it is open from 12 noon to 8 p.m.

Upcoming issues:

  1. The health screening team is in the process of determining which residents will be screened and which screening tests will be used
  2. A public meeting discussing this information will be held on Wednesday, March 22, 2000.
  3. The next Community Advisory Group meeting will be held on Thursday, March 23, 2000.
  4. The EPA will send out a press release on Monday, March 20, 2000.
  5. The DEQ will be meeting with the local press on Monday, March 20, 2000.
  6. EPA is having a meeting with W.R. Grace on Monday, March 20, 2000. EPA is planning on "just listening" to W.R. Grace voice its concerns on sampling and analysis work. DEQ will join the conference call with the EPA and W.R. Grace.
  7. The 20/20 showing of the Libby issue may air next week.