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Non-time Critical Removal Action Adjacent to OU3 (Mitchell-Jackson)

Background

Operable Unit 3 (OU3) of the Libby Asbestos Superfund Site includes a former vermiculite mine and surrounding area contaminated with Libby Amphibole asbestos which is present in forest-related source media (tree bark, duff, and soil). Since 1999, the Environmental Protection Agency (EPA) has conducted response actions within the entire Libby Asbestos Superfund Site to address the unprecedented human health impacts associated with widespread contamination in and near the cities of Libby and Troy, Montana. In 2002, EPA listed the Libby Asbestos Superfund Site on the National Priorities List.

EPA studies show that the asbestos concentrates in the ash of burned material. Further defined by the EPA is a human health risk for firefighters doing activities such as dry mop-up within OU3. Additionally, OU3 is one of the remaining Libby Asbestos Superfund Site OUs to be cleaned up by the EPA and is an estimated two years out from a Record of Decision. In 2017, the EPA and USDA Forest Service issued a joint fire preparedness action for in and around OU3. This action focused on use of a prioritized helicopter, dedicated equipment, and specially trained and equipped firefighters for aggressive initial attack. The fire preparedness action was necessary to help reduce the potential risk of asbestos exposure to firefighters during mop-up by helping to keep fires small.

Non-time Critical Removal Action

Forest Service policy is to respond to threats of release under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). The presence of asbestos contamination in the forest-related source media within OU3 constitutes a threat of release of a hazardous substance, pollutant, or contaminant into the environment and subsequent human health risk to firefighters during certain activities.

This effort is a Non-time Critical Removal Action to reduce fuels adjacent to OU3 to reduce the potential of wildfires moving into OU3. The general objective of a removal action is to abate, prevent, minimize, stabilize, mitigate, or eliminate the release or threat of release of hazardous substances or pollutants or contaminants into the environment. This action works to reduce the release or threat of release of asbestos by reducing the number and size of wildfires that move into OU3.

Adjacent lands to OU3 are heavily forested and within steep terrain. Additionally, Northwestern Montana experiences multiple wildfires during the summer months and, in recent years, the size and scale of wildfires has increased. This action focuses on the need to reduce the potential for and intensity of a wildland fire through reducing fuels within the removal action area.

Reducing fuels such that the risk is low for large scale wildfires to move into OU3 is one method to help reduce the release of asbestos. Through vegetation management treatments, forest composition, structure, and pattern move towards landscape diversity and resiliency to disturbances such as fire and climate change. Another method to reduce the release of asbestos is to use the road system for more efficient fire suppression response as well as conduct fuels and forest management. The road system can also be used as control lines. Additional considerations under CERCLA include minimizing potential environmental effects to the landscape such as watershed health and grizzly bear habitat management.

The National Environmental Policy Act (NEPA) does not apply to CERCLA response actions. However, Forest Service response actions must be consistent with the National Oil and Hazardous Substances Pollution Contingency Plan (National Contingency Plan, FSM 2164.03) which serves the function of agency compliance with NEPA. The National Contingency Plan requires community relations as well as environmental review of proposed removal actions in an Engineering Evaluation/Cost Analysis report, referred to as an EE/CA.

Location Summary

 

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OU3-Jackson Location Map showing proximity to Highway 37 North on the southern edge of the project boundary and removal action areas surrounding the Operable Unit 3 boundary in the center

Vicinity of OU3 and Removal Action Area in relation to Libby, Montana

Located east-northeast of Libby, Montana, and along Montana Highway 37 , the project area encircles the former Zonolite Mine and OU3. The eastern boundary generally follows National Forest System Road 228, locally known as the FDR, from Highway 37 north to Jackson Creek. The western and northern boundaries include Tubb Gulch, Mitchell Creek, the headwaters of Doak and Rainy creeks, and tributaries to Jackson Creek. This area consists of lands in all or portions of Townships 30, 31, and 32 North, Ranges 29, 30, and 31 West P.M.M. in Lincoln County, Montana.

Process and Information

The purpose of this project web page is to inform the public about the planned removal action. The Forest Service is performing the removal action, which will be conducted in accordance with the final EE/CA provisions. CERCLA law requires a 30-day comment period to allow the public an opportunity to review and comment on the proposed removal action.

The draft EE/CA and associated documentation will be made available on this website for review. Notifications of the availability of this document and the forthcoming comment period will be made to the public and interested parties who have request notification of updates to this action. Details on how to comment will be posted below prior to the start of the comment period.

Implementation of this removal action is expected to begin in the spring of 2025. The decision was signed October 2024.

Please contact District Ranger Nathan Gassmann at the Canoe Gulch Ranger Station, (406) 283-7598, for additional information.

EE/CA & Comment Period

The scope of the EE/CA includes vegetation and transportation management activities. Two removal action alternatives are identified, and both include regeneration harvest that would create openings exceeding 40 acres in size. The final EE/CA is now available.

Public comments on the Draft EE/CA were accepted for thirty (30) days starting May 29, 2024, until June 28, 2024.

Signed Action Memo

Final EE/CA 

Draft EE/CA & Related Documents

Public Meeting

The Libby Ranger District of the Kootenai National Forest hosted a public meeting on May 29th from 5:30 to 7:00 pm to discuss the draft Engineering Evaluation/Cost Analysis. The meeting was held at the Kootenai National Forest Supervisor’s Office at 31374 US Highway 2, Libby, MT. There was a brief presentation followed by a question-and-answer session.

A public meeting was held on September 18, 2023, at the Kootenai National Forest Supervisor's Office. The purpose of that public meeting was to discuss potential Forest Service fuels and forest management activities on lands adjacent to the Libby Asbestos Superfund Site Operable Unit 3 (OU3). The Forest Service sought to share information about the project, gather input to inform agency decision-making, and answer questions and respond to concerns from attendees.

Meeting Materials & Maps

Quick References and Notifications

Last updated April 21st, 2025

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