Community Involvement Plan Carpenter Snow Creek Mining District Superfund Site July 2014

ADMINISTRATIVE RECORD 1549403 - R8 SDMS

United States Environmental Protection Agency Region 8 Table of Contents 1. PURPOSE ...... 1 1.1 Superfund Law and Cleanup Program ...... 1 1.2 Document Organization ...... 2 2. SITE BACKGROUND ...... 4 2.1 Location ...... 4 2.2 Site History ...... 4 2.3 Nature and Extent of Contamination ...... 5 2.4 Summary of Community Involvement Activities ...... 7 3. SITE BACKGROUND AND CONCERNS ...... 9 3.1 Population and Demographics ...... 9 3.2 Government and Services ...... 9 3.3 Community Concerns, Comments, and Issues ...... 9 4. COMMUNITY INVOLVEMENT PLAN OBJECTIVES AND STRATEGIES ...... 11 4.1 Proactive Approach ...... 11 4.2 Define and Communicate Roles ...... 11 4.3 Formally Involve Local Officials and Other Community Representatives ...... 12 4.4 Comply with CERCLA/SARA Requirements ...... 12 5. COMMUNITY INVOLVEMENT ACTIVITIES ...... 13 5.1 Activities...... 13 5.2 Site-Specific Support Activities ...... 13 6. REFERENCES ...... 16

List of Figures 1 Site Location Map 2 Site Layout Map 3 Primary Waste Areas

List of Appendices A Contacts B Information Repositories C Public Meeting Locations D Local Media E Elected Officials F Community Interview Questionnaire List of Acronyms CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CSCMD Site Carpenter Snow Creek Mining District National Priorities List Site DEQ Montana Department of Environmental Quality EPA U.S. Environmental Protection Agency mg/kg milligrams per kilogram NCP National Oil and Hazardous Substances Pollution Contingency Plan SARA Superfund Amendments and Reauthorization Act

1. PURPOSE This Community Involvement Plan for the Carpenter Snow Creek Mining District National Priorities List Site (CSCMD Site), Cascade County, Montana, is an update to the CSCMD Site Community Involvement Plan dated August 2011 (USEPA 2011). The focus of this updated Community Involvement Plan is to guide community engagement activities through investigation, remedy selection, remedial design, remedial action, and the initial stages of operations and maintenance for the entire CSCMD Site (Figures 1 and 2). The previous Community Involvement Plan focused on the community of Neihart. The CSCMD Site includes the town of Neihart (Operable Unit 1) and the slopes to the east and west of Neihart and the Carpenter and Snow Creeks drainages (Operable Units 2 and 3). Operable Units are established by the U.S. Environmental Protection Agency (EPA) to assist with better management and remediation of large sites. Operable Unit boundaries may change as a site progresses through the cleanup process, as they have at the CSCMD Site. This Community Involvement Plan has been prepared in accordance with the Superfund Community Involvement Handbook (USEPA 2005) and the Community Engagement Initiative program endorsed by the EPA Office of Solid Waste and Emergency Response. The Handbook outlines the community involvement requirements stipulated in the National Oil and Hazardous Substances Pollution Contingency Plan (the NCP), which are the regulations that govern Superfund. In addition, implementation of the Community Involvement Plan will follow EPA’s Community Engagement Initiative, an EPA policy which is designed to help interested community members more effectively participate in the EPA decision-making processes. The Community Involvement Plan guides the EPA’s communications and interactions with the affected community and stakeholders as part of the Superfund process. The Community Involvement Plan serves as a basis for identifying community concerns and planning two-way communications so that the public gets questions answered and concerns publically addressed. Community Involvement staff members or contract employees strive to anticipate, identify, and acknowledge areas of conflict so that decisions can be made with full understanding of community views. The EPA conducts community interviews and, based on these interviews, prepares a Community Involvement Plan that includes a description of the site background, history of community involvement at the site (including major community concerns), community relations objectives, and a list of affected and interested groups and individuals. The community interviews form the foundation for developing a plan for keeping the community engaged throughout the Superfund process. It is important to emphasize that the Community Involvement Plan often presents opinions of residents and other interviewees. The information obtained in these interviews and summarized in the Community Involvement Plan reflects interviewees' responses, regardless of whether those responses are factually accurate. The interview questions and responses are discussed further in Section 3.4. 1.1 Superfund Law and Cleanup Program Superfund is the federal program to clean up uncontrolled or abandoned hazardous waste sites. The Superfund law, officially known as the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), was passed by Congress in 1980 and amended in 1986 by the Superfund Amendments and Reauthorization Act (SARA). The Federal regulation that guides the Superfund program is the NCP, first developed in 1968 and revised to incorporate the Superfund process after enactment of CERCLA in 1980.

CSCMD CIP July 2014 Page 1 of 16 Superfund’s basic provisions:  Give the EPA the authority to mitigate or prevent the releases or potential releases of hazardous substances;  Enable the EPA to compel those responsible for site contamination to pay for cleanup; and  Depending on annual appropriations from Congress, provide funding for cleanup when money from responsible parties is not available (fund-lead). The NCP requires the EPA to develop and manage community involvement programs at both fund- lead and enforcement-lead sites. At fund-lead sites, cleanup is paid for with money appropriated by Congress and money provided by the State where the site exists. At enforcement-lead sites, potentially responsible parties pay for cleanup with oversight by EPA and the state. At either type of site, community involvement remains the responsibility of the EPA or the State when the State is the lead agency. The Superfund community involvement effort promotes two-way communication between members of the public and the government agencies responsible for investigation and cleanup actions. Under the Superfund program, the EPA investigates hazardous waste sites and is authorized to conduct two types of response actions:  Removal Actions - short-term actions designed to stabilize or clean up incidents involving hazardous substances that may present an imminent threat to human health or the environment. Time-critical removal actions can last no longer than 12 months or cost no more than $2 million. Non-time critical removal actions also may be authorized and generally cost more and take longer to complete.  Remedial Actions - long-term cleanup actions that reduce threats to human health or the environment due to releases or potential releases of hazardous substances. The overall objectives of Superfund community involvement are as follows (EPA 2005):  Keep the public well informed of ongoing and planned activities;  Encourage and enable the public to get involved;  Listen carefully to what the public is saying;  Change planned actions where public comments or concerns have merit and fit within the Superfund law and NCP; and  Explain to the public how EPA considered their comments; what EPA plans to do; and why EPA reached its decision. The EPA’s community involvement activities also address environmental justice issues. Environmental justice is, among other things, the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies. The EPA has this goal for all communities and persons across this nation. It will be achieved when everyone enjoys the same degree of protection from environmental and health hazards and equal access to the decision- making process to have a healthy environment in which to live, learn, and work. 1.2 Document Organization The EPA has prepared this updated Community Involvement Plan based upon information from interviews with Neihart and surrounding community members and local and county officials in 2011

CSCMD CIP July 2014 Page 2 of 16 and 2012. The updated Community Involvement Plan describes the concerns and comments and outlines community involvement activities planned for the CSCMD Site. The EPA is committed to fully involving potentially affected interests in CSCMD Site activities and decisions. These activities and opportunities for community involvement are explained in the pages that follow. The EPA office located in Helena, Montana (Appendix A) will be responsible for implementing the community engagement program outlined in this Community Involvement Plan. The Community Involvement Plan will be modified if necessary, to meet changing needs as activities progress. The remaining updated Community Involvement Plan sections are as follows: 2.0 Site Background: This section identifies the location, history as a Superfund site, nature and extent of contamination as currently known, and community involvement activities to date at the CSCMD Site. 3.0 Community Background and Concerns: This section describes the town of Neihart and the Carpenter and Snow Creek watersheds, and summarizes the responses from the interviews. 4.0 Objectives of the Community Involvement Program: This section provides the basis for, and clarifies the goals of, the Community Involvement Program. 5.0 Community Involvement Activities: This section describes the activities tailored to meet specific community needs and planned to promote effective community involvement at the CSCMD Site. 6.0 References: This section contains a list of references used in the Community Involvement Plan.

CSCMD CIP July 2014 Page 3 of 16 2. SITE BACKGROUND 2.1 Location The CSCMD Site consists of the Carpenter Creek and Snow Creek drainages, portions of the incorporated town of Neihart, and the portion of Belt Creek that flows through the town to its confluence with Carpenter Creek. The CSCMD Site lies in the Little Belt Mountains of southern Cascade County, approximately 55 miles south of Great Falls, Montana (Figure 1). The EPA has divided the CSCMD Site into three Operable Units, to address the Carpenter Creek and Snow Creek watersheds independently of the town of Neihart. Neihart Community Soils Area Operable Unit 1 is primarily comprised of the properties located within the community of Neihart but also includes residential properties located in the surrounding area. The Carpenter-Snow Creek Mines and Watershed Operable Unit 2 and the Silver Dyke Mining Complex Operable Unit 3 comprise the remainder of the CSCMD. The CSCMD Site encompasses approximately 9,000 acres. Neihart is a small historic mining community with approximately 100 vacation cabins and fewer than 50 full-time residents. At approximately 5,500 feet above sea level, it is surrounded by mountains and forested areas. The mountains east of town are spotted with mines and Belt Creek flows from south to north through Neihart. Montana Highway 89 transects Neihart, generally following Belt Creek. Carpenter-Snow Creek Mines and Watershed Operable Unit 2 is characterized by ore that has low base metal content and higher gold content. It also includes the lower Carpenter Creek basin below the confluence with Snow Creek as well as the abandoned mine sites, mill sites, and associated wastes at the base of the Neihart slope that are not easily accessible to the public. Belt Creek flows from south to north through Neihart and the named tributaries of Belt Creek within the Neihart slope where known historic mining operations occurred include Broadwater, Compromise, and Rock Creek. Operable Unit 2 also contains the abandoned mines and mills within Lucy Creek, MacKay Creek, and Burg Creek in the Upper Carpenter Creek basin. Carpenter Creek enters Belt Creek north of Neihart. The Silver Dyke Mining Complex Operable Unit 3 is located in the drainage in the Upper Carpenter Creek basin above the confluence with Snow Creek. The Silver Dyke Mining Complex includes the Silver Dyke adit, mill, and tailings piles. All tailings depositions above Snow Creek are included in OU3. EPA is currently undergoing a planning process which may result in some changes to the OU definitions above. 2.2 Site History The Carpenter Snow Creek Mining District was divided into three distinct units based on differences in the type and occurrence of the ore. The first is the Carpenter Creek area which is characterized by lower grade ore that contains a high proportion of copper. The second is the upper Snow Creek basin, which is characterized by ore that has low base metal content and higher gold content. The third is on the Neihart slope, which is characterized by richer surface ore that decreases in silver and lead content with depth. Mining began in the Carpenter Snow Creek Mining District when prospectors from the Barker/Hughesville Mining District discovered silver deposits near the town of Neihart in 1881. The Carpenter Snow Creek Mining District mines primarily yielded silver, lead, and zinc ores. After 1883, only those mines with high grade silver ore continued to operate. Later, during the period from 1915 to 1919, the use of the flotation process allowed the mining of lower grade silver ore. During the 1940s,

CSCMD CIP July 2014 Page 4 of 16 lead and zinc were produced in large quantities for World War II. Between 1882 and 1929, the Carpenter Snow Creek Mining District produced about 16 million dollars in silver and was the primary silver producer in Cascade County. In the Carpenter Creek basin, the Silver Dyke Mining Complex is farthest upstream. The Silver Dyke Mining Complex, largest mining operation at the CSCMD Site, included active mining and concentration of ore between 1923 and 1929. The operations at the Silver Dyke Mining Complex resulted in several tailings deposits at the CSCMD Site. A tailings dam, co- located next to the Silver Dyke Mill, was damaged by an earthquake in 1925 releasing a flood of tailings into the valley below, now known as the Silver Dyke Tailings. In 1926, the Silver Dyke Mining Company developed two impoundments (upper and lower tailings) for collection of mine tailings. These tailings are now known as the Carpenter Creek Tailings and were placed into the impoundments by slurry from the upstream Silver Dyke Mill (Figure 3). Although some mines have reported development work and sporadic production, the Carpenter Snow Creek Mining District has been largely inactive since the 1960s. Further information on characteristics, mining history, and regulatory actions for the CSCMD Site can be found in the Remedial Investigation Report, Neihart Operable Unit, Carpenter-Snow Creek Mining District NPL Site (EPA/CDM 2005). 2.3 Nature and Extent of Contamination Since 1991, government agencies and private companies have conducted several investigations of waste rock, tailings, sediment, surface water, and groundwater from historic mines in the area. The State of Montana’s Abandoned Mine Bureau identified, inventoried, and sampled inactive mines in the Carpenter-Snow Creek drainages in the early 1990’s. Based on the high levels of arsenic and metals found in mine waste, surface water, sediment, and groundwater, the EPA proposed and then listed the areas consisting of the Carpenter Creek and Snow Creek drainages, the Neihart slope, and the Town of Neihart on the National Priorities List in September of 2001. It was determined that some exploration and minimal mining activity had occurred at the CSCMD Site after September 1, 1977, which made the Site ineligible for funding from the State of Montana Abandoned Mine Reclamation Fund. OPERABLE UNIT 1 Beginning in 2002, the EPA started to sample residential, commercial, and public properties and roadways in the town of Neihart. The EPA performed a time-critical removal action in 2004 and completed the Remedial Investigation Report for the Neihart Community Soils Area of Operable Unit 1 in 2005. Subsequently, a Feasibility Study produced in 2006 lead to the publication of a Proposed Plan later in 2006, both for the Neihart Operable Unit 1. Comments and changes to the selected remedy required the EPA to publish a second Proposed Plan in late 2008. A Record of Decision (USEPA 2009) for the Neihart Community Soils Area of Operable Unit 1 was issued by EPA in 2009. The full nature and extent of contamination of Operable Unit 1 is not known at this time; therefore additional sampling is necessary to complete the remedial design (this is the phase of Superfund cleanup that follows the issuance of a Record of Decision). Additional sampling efforts will include residential parcels outside of Neihart; groundwater, surface water, sediment, and streamside tailings on the Neihart slope and Belt Creek; and waste rock and adit discharge from the mines on the Neihart slope. It is known that elevated levels of lead and arsenic are found in both surface and subsurface soils in and around the community of Neihart. The Neihart Operable Unit 1 Record of Decision summarized the known nature and extent as follows:

CSCMD CIP July 2014 Page 5 of 16  The contaminants of concern are primarily lead and arsenic in soil.  Lead concentrations ranged from less than 50 milligrams per kilogram (mg/kg) to over 3,600 mg/kg in surface soil, and from non-detect to 3,094 mg/kg in soil to a depth of 18 inches.  Arsenic concentrations ranged from 10 to 154 mg/kg in surface soil and from non-detect to 120 mg/kg in soil to a depth of 18 inches.  No significant areas of groundwater contamination were identified, based on limited sampling.  Slight exceedances in surface water quality standards were noted in the wetlands near the Monarch/Neihart Senior Center; however, the water quality in Belt Creek as it flows through the CSCMD Site generally meets water quality standards.  The aquatic habitat is generally good in Belt Creek as it flows through the CSCMD Site, but limited ecological risk evaluation suggested the need for additional sampling of wetlands in town. OPERABLE UNITS 2 AND 3 The United States Forest Service, Region 1 collected environmental data to characterize mine wastes present on National Forest land (the upper Carpenter Creek Tailings impoundment) and to identify potential impacts to National Forest land from abandoned mine properties located on private lands. The EPA completed a Screening-Level Ecological Risk Assessment for the CSCMD Site to provide initial information on the potential for adverse effects (risks) to ecological receptors due to environmental releases of toxic chemicals from historical mining activities associated with the Site. Surface water, sediment, and aquatic community and tissue samples have been collected at the CSCMD Site since 2009 to fill many of the data gaps identified in the Risk Assessment. The pace of studies of the Carpenter and Snow Creek watersheds (water quality, sediment and waste volume estimates, and ecological risk assessment) has increased since 2009. To date, the EPA has:  Surveyed over two dozen abandoned mine and mills that have been identified in previous investigations;  Performed laboratory toxicity testing on rainbow trout and aquatic insect larvae using surface water and sediment collected from select sampling stations at the CSCMD Site;  Conducted in-situ toxicity tests on Westslope cutthroat trout at select sampling stations;  Made a preliminary Determination of National Register Eligibility for 14 properties over 50 years of age within the CSCMD Site pursuant to 36 CFR § 800.4 that are located in Operable Unit 2 and Operable Unit 3; and  Conducted a habitat assessment in accordance with the Rapid Bioassessment Protocols for Use in Streams and Wadeable Rivers. The full nature and extent of contamination in Operable Units 2 and 3 is not known at this time; therefore additional sampling is necessary to complete the remedial investigation. Additional sampling efforts will include:  The nature and extent of metals in the creek-side mine waste;  The volume of tailings and waste rock in the Carpenter Creek, Snow Creek, and Neihart slope drainages;  The concentration of target metals in the roads and all-terrain vehicle (ATV) trails;  Potential residential exposure on the Neihart slope properties;  On-site chemical or physical hazards that pose a threat to human health;  The extent of contaminant concentrations in groundwater;

CSCMD CIP July 2014 Page 6 of 16  Data to support water balance studies at the Silver Dyke Mine Adit and Broadwater Mine Adit;  Additional mine waste characterization as identified during the 2012 field season;  An evaluation of water draining from the upper and lower tailings ponds; and  Additional Mackay Gulch repository site geotechnical characterization data. A site wide remedial investigation report and risk assessments will be released in the next 6 to twelve months. A repository location RI/FS will be completed in 2014. 2.4 Summary of Community Involvement Activities The following is a brief summary of community involvement activities that have occurred to date at the CSCMD Site. Details of future EPA community involvement activities are described further in Sections 4.0 and 5.0. COMMUNITY INTERVIEWS In March 2004, the EPA conducted approximately 11 community interviews with individuals either living in, owning property in, or otherwise involved with the CSCMD Site. For the Community Involvement Plan update in 2011, the EPA interviewed 16 persons, including, local officials and residents. For this update to the Site-wide Community Involvement Plan, the EPA interviewed an additional person. The objectives of the most recent interviews were to: 1) find out how much the interviewees know of and are impacted by the EPA’s activities at the CSCMD Site; 2) identify concerns about the CSCMD Site; and 3) determine the best methods for communication between the EPA and the local residents/leaders and property owners. While these interviews were for the formal purpose of this Community Involvement Plan, the EPA will continue to have open and frequent communication with the public and stakeholders. INFORMATION REPOSITORIES The EPA established an information repository at the Great Falls Public Library and the Belt Creek Ranger Station. Important site documents and informational fact sheets are placed in the repositories to allow the public easy access to site information. In addition, general Superfund information is available in the repositories. The full Administrative Record and site file is located at the EPA Montana Office in Helena. The Administrative Record contains certain important documents leading up to and relied on by EPA in reaching a remedial (cleanup) decision. The site file contains other records that are not necessarily related directly to the cleanup decision. Details for each of these locations can be found in Appendix B. As characterization and cleanup progresses, EPA will continue to update the repositories and the Administrative Record. An Administrative Record will also be placed in a local repository for future remedial decisions. PUBLIC MEETINGS The EPA has held formal public meetings at the Monarch/Neihart Senior Center, the Belt Creek Ranger Station, and the Great Falls Public Library in 2003, 2009, and 2012. In addition, the EPA held public hearings following publication of the Proposed Plan for the Record of Decision at the Monarch/Neihart Senior Center and the Cascade County Courthouse Annex in 2006 and 2009. The meetings were well attended and consisted of presentations of the EPA's activities, sampling results, and future plans, and also provided a question and answer period. The hearings included a presentation and an opportunity for individuals to provide recorded statements regarding the Proposed Plan. Appendix C has details for potential locations to hold future public meetings. It is anticipated that future communication with the public will occur through small group meeting as described below.

CSCMD CIP July 2014 Page 7 of 16 However, if appropriate and as required, additional formal public meetings will be held as needed to inform the community about new information, upcoming Proposed Plan/Record of Decision for repository siting, and Operable Units 2 and 3, or changes to the cleanup approach identified in the Record of Decision for Operable Unit 1. SMALL GROUP MEETINGS Throughout the CSCMD Site progression, EPA and Montana Department of Environmental Quality (DEQ) representatives have met with individuals, local and county officials, city-county health department personnel, Montana State Historic Preservation Office personnel, and Forest Service personnel, and have attended a numerous weekly dinners at the Monarch/Neihart Senior Center and Neihart Town Council meetings. The EPA and the DEQ will continue to communicate regularly with interested parties at the CSCMD Site through small, informal group meetings. INFORMATIONAL MAILINGS The EPA, in consultation with the DEQ, has prepared and distributed ten informational fact sheets for the CSCMD Site. The facts sheets can be found on the internet at: http://www.epa.gov/region8/superfund/mt/carpenter_snow_creek/index.html. Future fact sheets will include information on sampling, design, and remedial actions. MASS MEDIA The EPA has provided press releases and advertisements to both the print media (primarily the Great Falls Tribune) and television (KRTV and KFBB). The press releases announced the start of sampling in 2002, public meetings in 2003, community interviews in 2004, the Proposed Plans in 2006 and 2009, the Record of Decision in 2009, and the public meeting in 2012. The EPA will continue to provide press releases and advertisements to announce milestones and formal public meetings. Contact information for the local media can be found in Appendix D of this Community Involvement Plan. INFORMATION ON THE INTERNET The EPA maintains a webpage specific to the CMSD Site at: http://www.epa.gov/region8/superfund/mt/carpenter_snow_creek/index.html.

CSCMD CIP July 2014 Page 8 of 16 3. SITE BACKGROUND AND CONCERNS 3.1 Population and Demographics According to the 2010 census, Neihart has a year round population of 51 persons, with over 90% of those being Caucasian. The median age is 53 years and household income is $22,402. Sixty-three percent of the population is families. There are no year round residents in the watershed area, but there are 41 residents in the area extending to the northwest along Belt Creek. The EPA estimates approximately 10 recreational and part-time cabins within the Carpenter and Snow Creek watersheds. 3.2 Government and Services Cascade County is managed by three elected commissioners who guide the operations of the county’s eleven departments and offices. Neihart is governed by an elected mayor and city council members. Local, state, and federal government contacts are in Appendix E. Neihart has a municipal water supply system and a volunteer fire department. The Monarch/Neihart Senior Center provides meeting space and supports community dinners and events. There is a combination restaurant/hotel/laundromat/gas station and one general store in town. Outlying properties in the CSCMD Site are primarily recreation cabins with individual power, water, and sewage systems. Most services, including Cascade County government offices, are available in Great Falls, approximately 58 miles to the northwest. 3.3 Community Concerns, Comments, and Issues To develop a Community Involvement Plan that accurately reflects community interests and concerns, the EPA depends heavily upon information obtained during "Community Interviews." In June, 2011, the EPA conducted interviews with area residents, community leaders, city-county health department personnel, and elected officials. The EPA interviewed an additional person to produce this Site-wide Community Involvement Plan update. Given the proximity of the two interview periods and the applicability of the previous interviews to the entire CSCMD Site, the interview questions and responses from both the 2011 and 2012 are included in this section. The interview questions are contained in Appendix F. The responses from these interviews are grouped below according to similar themes. The EPA has made every effort to include all the responses from the interviews as well as information from residents, government officials, and other stakeholders that have been shared subsequent to the interviews. It is important to emphasize that this section presents the opinions and concerns of residents and other interviewees rather than those of the EPA, the state, or any other official governing body. The information obtained in the interviews and subsequent conversations is summarized in this section and reflects interviewees' responses and concerns; regardless of whether they are factually accurate. The following general areas of concerns, comments, and issues have been identified from the community interviews and other sources:  Health Risks  Degree of Contamination  Repository Location  Property Values  Communication  Timeframe

CSCMD CIP July 2014 Page 9 of 16 When interviewees were asked about their knowledge of Superfund in general and the CSCMD Site in particular, there were a variety of responses. Some elected officials had a broad knowledge of the Superfund process, while community members were more familiar with the Superfund process as it pertained directly to the CSCMD Site. All were aware that there had been ongoing work and were curious as to where the process currently stands. One of the largest issues of concern raised by the interviewees was the location of the repository. The location of the temporary repository used for time critical removal cleanup in 2004 was an area of concern, and many individuals were wondering when this repository would be taken out. Most of the people interviewed explained they would prefer a permanent repository be established up Carpenter Creek, and if possible, at the Silver Dyke glory hole at the top of the Carpenter watershed. There was concern regarding how much waste the Evening Star Mine could hold, as well as whether soils placed at the Evening Star Mine may have a potential to run down the hill, onto the highway, and into the creek. The opinion was presented that a permanent repository would be preferred, instead of another temporary repository. As noted above, EPA plans a separate RI/FS and Record of Decision process for repository location siting and construction in the near future. The interviewees helped to identify additional places where waste rock may be found, as well as provided information on where children play in Neihart. Through the interviews, the EPA was able to identify the pond near the Monarch/Neihart Senior Center, unpaved streets, area beaver dams, and the ball fields south of town as potential areas where children play. The EPA will confirm that these locations either have been sampled or will be sampled in the near future. Those interviewed identified new ways of contacting both resident and non-resident property owners in addition to providing information through the town of Neihart. In addition to communicating with the town council, specific unofficial community leaders were identified as contacts. Suggestions for distributing information to residents included: providing information with water bills, and posting information in local meeting places such as the Post Office, Monarch/Neihart Senior Center, Inconvenience Store, and Bob’s Bar, Motel and Restaurant. Several other methods of communication were mentioned including:  KGPR Public Radio announcements  Aging Services Newsletter announcements or articles  Other Utility Mailings  Community Dinners In the past, former EPA Remedial Project Managers have been contacted with questions. Interviewees indicated they would continue to contact the EPA for information, as well as the mayor and other community leaders. Another topic discussed was public and community health. No major health concerns were mentioned by those interviewed. There was some concern regarding children’s exposure to lead and arsenic, but no health issues have presented themselves. Interview discussions confirmed that for health information, the City-County Health Department in Great Falls is the primary contact. Additional questions that were raised during the interviews are as follows:  When is the cleanup going to take place?  What affect will this have on property values?  How much soil needs to be taken out?  Where will the fill soil come from?

CSCMD CIP July 2014 Page 10 of 16 4. COMMUNITY INVOLVEMENT PLAN OBJECTIVES AND STRATEGIES Based upon interviews with local community members and interested parties as well as other relevant information, the EPA has developed the following list of objectives for community involvement and meaningful communications for the CSCMD Site:  Use proactive approach.  Define and communicate roles.  Formally involve local officials and other community representatives.  Comply with CERCLA/SARA public involvement requirements. A discussion of each of these objectives and the strategies the EPA will use to implement the objectives follows. 4.1 Proactive Approach The EPA’s objective is to use a proactive approach to sharing information with the public. The EPA will try to provide information to as many people as possible, listen to their concerns, and answer their questions. To achieve this objective, the EPA will ensure that public health and safety issues and opportunities for public participation in Site decisions are well publicized. One example of the EPA’s proactive approach to listening and responding to the community is the Pre-Remedial Assistance for Property Owners Soil Management (POSM) Program discussed under Section 5.2 below. The EPA will provide information on the Superfund process that is relevant to decisions at the Site. The EPA will make certain that periodic, easy-to-read information regarding the status of Site activities is provided to the community at regular intervals. The information will enable the community to keep up- to-date and be well-informed and involved with Site activities. The EPA will use various techniques, including communication strategies suggested by the community, to provide Site information to the public. One effective way to share information with both full time residents and non-resident property owners is direct mailing and the EPA’s website. For the local residents, posting signs and holding community dinners are effective means to distribute information. Sending information with the water bills appears to be one of the most effective ways to reach residents of Neihart. Many non-resident property owners in Neihart are from the Great Falls area, so the EPA will also share information through the Great Falls Tribune and the public radio station. The EPA will continue to produce fact sheets and flyers when appropriate and distribute this information through direct mail and postings in community meeting places. The EPA will hold public meetings and periodically attend established community organization meetings, such as the community dinners. The EPA will maintain a webpage dedicated to the CSCMD Site to update people on activities, decisions, and issues regarding the Site. This webpage will also provide contact information so community members can communicate issues and concerns back to the EPA. One interviewee recommended posting the specific water quality results on the internet. 4.2 Define and Communicate Roles The EPA’s objective is to clearly define and communicate plans, schedules, responsibilities, costs, and relationships with other agencies. The EPA wants to be clear about the roles of various groups involved in CSCMD Site activities. It is important that the EPA clearly explain the role and authority of each agency and how their activities are coordinated. Coordination with the DEQ and the Forest Service is especially important because they are the EPA’s primary governmental agency partners. This will be done by adding this information to the efforts described above.

CSCMD CIP July 2014 Page 11 of 16 4.3 Formally Involve Local Officials and Other Community Representatives The EPA’s objective is to formally involve local officials and other community representatives in the Superfund process and maintain ongoing, two-way communication with the community. Community leaders and local government organizations have expressed an interest in the EPA communicating regularly with them, either through meetings or email, informing them in advance of major decisions or events, and formally inviting them to public meetings and other public activities. To accomplish this objective, the EPA will make an effort to formalize communication of the EPA Site activities. The EPA will continue to offer the community opportunities to participate and learn of activities on the CSCMD Site. 4.4 Comply with CERCLA/SARA Requirements The EPA will also comply with the CERCLA/SARA requirements for community involvement. In addition to the above activities, other activities will be planned specifically to meet the community involvement requirements under CERCLA/SARA. A detailed description of these activities is found in the Section 5.0 of this Community Involvement Plan.

CSCMD CIP July 2014 Page 12 of 16 5. COMMUNITY INVOLVEMENT ACTIVITIES This section describes the community involvement activities that the EPA plans to conduct during the course of the Superfund cleanup actions. These activities are designed to provide information to community members and provide opportunities for them to be involved in the remedial design, cleanup, and long-term maintenance at the CSCMD Site. The EPA is currently the lead government agency in the remediation of the CSCMD Site. As such, the EPA will ensure full public participation in the Superfund cleanup process. Many of the activities listed below have been implemented prior to the publication of this updated Community Involvement Plan. These activities include those required by CERCLA/SARA. In addition, other Site-specific support activities are important tools for keeping the community informed and involved. These Site-specific activities will be implemented in response to community input and requests. 5.1 Activities DESIGNATE A SPOKESPERSON Mr. Tillman McAdams, an EPA Remedial Project Manager, is the designated spokesperson for all actions regarding Operable Unit 1. Mr. Roger Hoogerheide, an EPA Remedial Project Manager, is the designated spokesperson for all actions regarding Operable Units 2 and 3. NOTIFY AFFECTED CITIZENS Mr. McAdams and Mr. Hoogerheide will, in a timely manner, inform the community, state, and local officials of plans, decision-making processes, and actions taken. They will respond to inquiries and provide information concerning the CSCMD Site. Their contact information is located in Appendix A of this Community Involvement Plan. ESTABLISH INFORMATION REPOSITORY The EPA has established three Information Repositories for the CSCMD Site. They are the Great Falls Public Library, the Belt Creek Ranger Station, and the EPA office in Helena. Details for each of these locations, including contact information and hours of availability can be found in Appendix B of this Community Involvement Plan. CONDUCT COMMUNITY INTERVIEWS Initially, the EPA interviewed the residents and local officials in March 2004. For this updated Community Involvement Plan, the EPA conducted interviews in June 2011 and March 2012. The results of the most recent interviews are presented in Section 3.4. The EPA will continue to conduct community interviews as needed to support updates to this Community Involvement Plan. PREPARE AND REVISE THE COMMUNITY INVOLVEMENT PLAN This Community Involvement Plan update is developed for public use by the community, and may be updated and revised as investigations and cleanup progress at the CSCMD Site. 5.2 Site-Specific Support Activities In addition to the community involvement activities described above, the EPA considers the following community involvement activities important in helping the public provide meaningful input to the ongoing Site activities.

CSCMD CIP July 2014 Page 13 of 16 PREPARE FACT SHEETS AND SITE ACTIVITY UPDATES The EPA will produce a variety of fact sheets for publication and distribution. These fact sheets may vary from an informal paragraph for a water bill, to a multi-page summary of a specific topic. In all cases, the EPA and other stakeholders will benefit from having a thorough review of the fact sheets for accuracy, readability, and visual appeal. The EPA may, at times, ask community members to review fact sheets to ensure they are clear and convey relevant information. The EPA is open to suggestions from potentially affected interests on topics to write about, based on their relevancy to the CSCMD Site activities and their importance to the general public. These materials will be distributed to those on the mailing list and will also be available to the general public through the information repositories, the EPA’s website, and by request.

ISSUE PRESS RELEASES AND OTHER INFORMATIONAL ADS TO NEWS OUTLETS The EPA will issue press releases to make official statements at milestones in the Superfund process, such as key project dates, investigation schedules, or completion of cleanup actions. Appendix D contains contact information for potential media outlets. It is the EPA’s policy not to negotiate the timing or content of a press release. However, in an effort to communicate openly with affected stakeholders, the EPA will send all press releases related to the CSCMD Site to interested parties at the same time it sends the release to the press. The EPA will try to alert community members about current events that may generate media interest and/or a press release. Anyone whose name is given to the press about any issue will be notified immediately. The EPA will, at times, provide notices of events in the form of a display ad in the Great Falls Tribune. COORDINATE WORKSHOPS, SMALL GROUP MEETINGS, LARGE PUBLIC MEETINGS, AND MEETINGS WITH INDIVIDUALS Meetings with the community provide a forum for presentation and exchange of information. The EPA will make an effort to present materials in a non-technical format and provide opportunities for interaction with meeting attendees to ensure that the information is understood. Such meetings also could be used to present a wide variety of information updates or to give slide shows or videotape presentations on Site activities. Appendix C includes details regarding potential meeting locations for the CSCMD Site. If necessary, specialized information such as sampling or sample results, cleanup status etc., will be presented in workshops, small group meetings, and large public meetings. Meetings make it possible for the EPA to get immediate feedback from the public on Site-specific issues. The EPA staff remains available for interested parties to discuss their concerns on a person-to-person basis. When possible, the EPA will share information directly with residents at their homes, particularly during field work such as sampling, design, or cleanup. BRIEF LOCAL OFFICIALS The EPA will inform local officials of key events and activities. Formal notification of key events and activities and advance information on decisions and events are important to local officials. The EPA's continued efforts in this regard have been effective and will be continued. This is especially important as the Site progresses to long-term stewardship and the direct involvement of the local officials becomes increasingly important. Appendix E is a list of the state and local elected officials, including their contact information.

CSCMD CIP July 2014 Page 14 of 16 MAINTAIN AN ACCURATE MAILING LIST The EPA will continuously look for ways to build its mailing list of people interested in receiving information on the investigation and cleanup of the area affected by the CSCMD Site and related information. The EPA will also maintain a list of e-mail addresses for those that prefer to be notified by electronic mail. EPA PRE-REMEDIAL ASSISTANCE FOR PROPERTY OWNER’S SOIL MANAGEMENT (POSM) As a consequence of the lack of a permanent repository site, the Remedial Action for Operable Unit 1 has been delayed. The residents of the CSCMD Site have expressed the subsequent impact on property improvements and other dirt-moving activities on individual properties. In response to the community input and concerns, the EPA developed the POSM program. The program provides for post-excavation soil management and approved backfill materials for these property improvements and other dirt- moving activities. Further, the EPA coordinated with the Cascade County Health Department in 2012 to provide HAZWOPER Training for local contractors in support of anticipated POSM activities. The implementation of the POSM program was delayed in 2013 due to unresolved property boundary issues: legal ownership of properties must be established prior to EPA involvement and if more than one owner is involved, resolution by multiple party agreements is required to proceed with POSM. EPA intends to conduct POSM activities, as Congressional funding allows, beginning in 2014 and will be contacting citizens within the community that have expressed interest in the program. Additional information regarding the POSM program is available at the Cascade City-County Health Department.

CSCMD CIP July 2014 Page 15 of 16 6. REFERENCES Camp Dresser and McKee (CDM) and United States Environmental Protection Agency (USEPA). 2005. Remedial Investigation, Neihart Residential Area Operable Unit, Carpenter-Snow Creek Mining District NPL Site, Neihart, Montana. Prepared for EPA. August. USEPA. 2005. Superfund Community Involvement Handbook. April. USEPA. 2009. Record of Decision, Neihart Community Soils Area, Neihart Operable Unit 1, Carpenter-Snow Creek Mining District NPL Site, Cascade County, Montana. March. USEPA. 2011. Community Involvement Plan, Carpenter Snow Creek Mining District Superfund Site. June.

CSCMD CIP July 2014 Page 16 of 16 Figures

k e SILVER DYKE GLORY HOLE !. e r 89 LOCATION OF LARGER MAP

C ¤£ t l e B

AD RO K EE C R ER T N E P R A C

S SILVER DYKE MILL i h

- m !.

C k r SILVER DYKE e e e e H !. r k TAILINGS NEIHART a C y y s a

Topographic Map Source: National Geographic Society, i-cubed a k c c a

k M C r e e k reek r C te Bur en g L rp C u a r c C e e y k

k C r e e e r e k C t l e UPPER TAILINGS PILE B k ree t C ec Prosp D A LOWER TAILINGS PILE O R K E E R C R E T N E P R A eek C S now Cr

H W Y k e 8 re 9 C ley Har CARPENTER-SNOW CREEK MINING DISTRICT NATIONAL PRIORITIES LIST SITE Aerial Imagery Source: Esri, DigitalGlobe, GeoEye, i-cubed, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, and the GIS User Community

LEGEND FIGURE 3 STREAM PRIMARY MINE WASTE AREAS ROAD p 0 1,000 2,000 3,000 Feet GIS MAP BY DOUG HEROLD TTEMI-HELENA - Community_Involvement_Plan.mxd

Appendices

Appendix A Community Involvement Plan CSCMD Site, Montana: Contacts

Contact Name/ Phone Number/ Contact Title Mailing Address Fax Number Email Address Tillman McAdams Remedial Project Manager US EPA Region 8 406 457 5015 Community Involvement Coordinator 10 W. 15th St., Suite 3200 [email protected] (fax) 406 457 5056 Operable Unit 1 Helena, MT 59626 US Environmental Protection Agency Roger Hoogerheide Remedial Project Manager US EPA Region 8 406 457 5031 Community Involvement Coordinator 10 W. 15th St., Suite 3200 [email protected] (fax) 406 457 5056 Operable Units 2 and 3 Helena, MT 59626 US Environmental Protection Agency Keith Large Montana DEQ 406 841 5039 State Project Officer Remediation Division [email protected] Montana Department of Environmental PO Box 200901 (fax) 406 841 5050 Quality Helena, MT 59620 Dan Strausbaugh, MPH ATSDR/DCHI/DRO/Region 8 [email protected] Capt., U.S. Public Health Service 406 457 5007 10 W. 15th St., Suite 3200 or Agency for Toxic Substances and Disease (cell) 303 7171 2952 Helena, Mt 59626 [email protected] Registry Scott Sudweeks, MS ATSDR/DCHI/Region 8 [email protected] Region 8 Toxicologist 303-312-6580 1595 Wynkoop Street or Agency for Toxic Substances and Disease (cell) 303-656-5615 Denver, CO 80202-1129 Registry [email protected] Steve Helgerson, MD, MPH MT DPHHS 406 444 1286 State Medical Officer 1400 Broadway [email protected] (fax) 406 444 6943 MT Dept of Public Health and Human Services Helena, MT 59620 Carol Ballew, PhD MT DPHHS 406 444 6988 Senior Public Health Epidemiologist 1400 Broadway, [email protected] (fax) 406 444 7465 MT Dept of Public Health and Human Services Helena, MT 59620 Sandy Johnson 115 4th Street South Sanitarian 406 454 6950 [email protected] Great Falls, MT 59401 Cascade City-County Health Department Alicia Thompson 115 4th Street South Health Officer 406 454 6950 [email protected] Great Falls, MT 59401 Cascade City-County Health Department Beth Ihle On-Scene Coordinator 4234 US Highway 89 North 406 495 3863 [email protected] United States Forest Service Neihart, MT 59465 Belt Ranger Station

Appendix B Community Involvement Plan CSCMD Site, Montana: Information Repositories

Information Repository Street Address Contact Name Phone Number Hours of Operation EPA Montana Office, Superfund Records Center 406 457 5046 Monday through Friday U.S. EPA Records Center 10 West 15th Street Lori Hallauer or 8:00 a.m. to 4:00 p.m. EPA Montana Office Suite 3200 406 457 5000 (excluding holidays) Helena, MT 59626 4234 US Highway 89 North Monday through Friday US Forest Service Neihart, MT 59465 406 236 5511 8:00 a.m. to 4:30 p.m. Belt Creek Ranger Station (4 miles north of Neihart) Generally open weekends in the summer Monday, Friday and Saturday 301 2nd Avenue North 10:00 a.m. to 6:00 p.m. Great Falls Public Library Reference Librarian 406 453 0349 Great Falls, MT 59401 Tuesday, Wednesday, and Thursday 10:00 a.m. to 8:00 p.m.

Appendix C Community Involvement Plan CSCMD Site, Montana: Public Meeting Locations

Accommodations/Availability/ Facility Address Phone ADA Compliance Main room holds 60 Monarch/Neihart Senior 200 S Main Street 406 236 5998 Availability is flexible Center Neihart, MT 59465 Building is ADA compliant 4234 US Highway 89 Basement meeting room holds 20 US Forest Service North 406 236 5511 Available during regular business hours Belt Creek Ranger Station Neihart, MT 59465 Building is ADA compliant (4 miles north of Neihart) Small meeting room holds 6 301 2nd Avenue North Cordingly Room holds 120 Great Falls Public Library 406 453 0349 Great Falls, MT 59401 Available when library is open Both are ADA compliant

Appendix D Community Involvement Plan CSCMD Site, Montana: Local Media

Phone Number/ Name Mailing Address Media Type Fax Number 205 River Drive South Switchboard (8am-5pm): 406 791 1444 Great Falls Tribune Great Falls, MT 59405 or (800) 438 6600 Daily Newspaper http://www.greatfallstribune.com/ Newsroom Fax: 406 791 1431 3200 Old Havre Highway Local Television KFBB TV 5 Black Eagle, MT 59414 406 453 4377 ABC Affiliate http://www.kfbb.com/ PO Box 2989 Local Television KRTV TV 3 Great Falls, MT 59403 406 791 5400 CBS Affiliate http://www.krtv.com/home/ 2100 16th Avenue South 406 268 3739 KGPR Great Falls, MT 59405 Montana Public Radio 406 268 3736 http://kgpr.org/

Appendix E Community Involvement Plan CSCMD Site, Montana: Elected Officials

Association or Contact Name/ Phone Number/ Contact Category Mailing Address Email Address Department Contact Title Fax Number 724 Hart Senate Office http://www.tester.senate.gov/?p=e 202 224 2644 Building mail_senator Jon Tester/ U.S. Congress Washington, DC 20510 U.S. Senator 119 First Avenue North 406 452 9585 Suite 102 [email protected] (fax) 406 452 9586 Great Falls, MT 59401 511 Hart Senate Office http://www.walsh.senate.gov/conta Building Federal Government John Walsh/ ct.cfm U.S. Congress Washington, DC 20510 202 224 2651 U.S. Senator 113 3rd Street North 406 761 1574 [email protected] Great Falls, MT 59401 206 Cannon House Office https://daines.house.gov/contact/e 202 225 3211 Steve Daines Building mail-me U.S. Congress U.S. Representative Washington, DC 20515 104 2nd St. S, Suite 103 406 315 3860 http://www.stevedaines.com/ Great Falls, MT 59401 (fax) 406 315 3862

Appendix E (continued) Community Involvement Plan CSCMD Site, Montana: Elected Officials

Association or Contact Name/ Phone Number/ Contact Category Mailing Address Email Address Department Contact Title Fax Number Montana State Capitol Governor of Steve Bullock Building 406 444 3111 http://governor.mt.gov/contact/defa Montana Governor Post Office Box 200801 (fax) 406 444 5529 ult.htm Helena, MT 59620-0801 Montana State Bradly Maxon Hamlett State Government Post Office Box 49 406 799 5885 [email protected] Senate State Senate District 10 Cascade, MT 59421-0049 Montana State Roger Hagan 117 Gerber Road 406 459 0773 [email protected] Congress State House District 19 Great Falls, MT 59405-8107 Bill Salina, Chair Cascade County 325 2nd Ave. North, #111 County Commission 406 454 6816 [email protected] Commissioners Great Falls, MT 59401 District Two Joe Briggs Cascade County 325 2nd Ave. North, #111 County Government County Commissioner 406 454 6815 [email protected] Commissioners Great Falls, MT 59401 District One Jane Weber Cascade County 325 2nd Ave. North, #111 County Commissioner 406 454 6814 [email protected] Commissioners Great Falls, MT 59401 District Three PO Box 36 406 868 1544 Mayor of Neihart Steve Taylor [email protected] Neihart, MT 59465 406 236 5323 PO Box 3 Council Member Robert (Bill) Black 406 236 5551 [email protected] City Neihart, MT 59465 Government PO Box 132 Council Member Jackie Buskirk 406 236 5376 [email protected] Neihart, MT 59465 PO Box 91 Council Member Joyce Korin 406 236 5380 [email protected] Neihart, MT 59465

Appendix F Community Involvement Plan CSCMD Site, Montana: Community Interview Questionnaire

Carpenter-Snow Creek Mining District Community Interviews

Date: Interviewers:

1. Are you familiar with the Superfund process and the Carpenter-Snow Creek NPL Site? What do you know about them?

2. Do you have any questions or concerns regarding the upcoming cleanup actions and repository siting? Is there any information we can provide to you regarding the Superfund process or the Neihart site?

3. Are you aware of any locations of mine waste or tailings in town?

4. Where do children play in Neihart?

5. What do you think is the best way to get information to community members and property owners (both local and remote)?

 Fact sheets/direct mail  Great Falls Tribune  Meetings  Other?

6. How do you get important information regarding community activities? Who always seems to know what is going on?

7. Have you ever contacted anyone about the Superfund site activities? If yes, who and how?

8. Where do you go for questions about public or community health?

9. Who are the formal and informal community leaders? Who else should we talk to?

10. Do you want future information? May we add you to the mailing list