Digital Commons @ Montana Tech

Rott, Emma

Montana Tech Library 
Digital Commons @ Montana Tech 
Silver Bow Creek/Butte Area Superfund Site Montana Superfund 
Spring 5-7-2025 
Re: Comment Letter for the 2023 Butte Priority Soils Operable Unit 
(BPSOU) Groundwater Compliance Evaluation (dated March 10, 
2025) 
Emma Rott 
Follow this and additional works at: https://digitalcommons.mtech.edu/superfund_silverbowbutte 
 Part of the Environmental Health and Protection Commons, Environmental Indicators and Impact 
Assessment Commons, and the Environmental Monitoring Commons 
 
 
May 7, 2025 
 
Mr. Josh Bryson 
Liability Manager 
Atlantic Richfield Company 
317 Anaconda Road 
Butte, Montana 59701 
 
Re: Comment Letter for the 2023 Butte Priority Soils Operable Unit (BPSOU) Groundwater 
Compliance Evaluation (dated March 10, 2025) 
 
Dear Mr. Bryson: 
 
The U. S. Environmental Protection Agency (EPA), in consultation with the Montana Department of 
Environmental Quality (DEQ), is providing comments on the 2023 Butte Priority Soils Operable Unit 
(BPSOU) Groundwater Compliance Evaluation, dated March 10, 2025. This report is required per 
Section 2.2.1.1 of Attachment B.1 to Appendix D of the BPSOU Partial Remedial Design/Remedial 
Action and Operation and Maintenance Consent Decree. Please address the comments below and 
submit revised versions of the subject documents for EPA and DEQ review and approval.  
General Comments 
1. Please review Agency comments from previous Groundwater Compliance Reports (i.e. 2020 
Groundwater Compliance Memo). All comments submitted by the Agencies at that time are 
relevant to this report and should be applied accordingly. 
2. The Data Quality Objective in the 2022 Interim Groundwater QAPP (as well as previously 
provided comments on the 2020 Groundwater Compliance Report) states the components of this 
2023 Butte Priority Soils Operable Unit (BPSOU) Groundwater Compliance Evaluation “must 
include an assessment of groundwater quality trends (spatially and temporally), as well as 
groundwater/surface water elevation relationships that can be used to evaluate groundwater 
capture.” Although this data has been collected, it has not been presented temporally in this 
document. Please present POC well concentrations as a function of time so trends can be 
observed. 
• It is currently not possible to compare the POC compliance data (both the most-recent 
sample data, as well as trends at POC wells) and discuss how the data meet the objectives 
of groundwater monitoring as described in Appendix E (BPSOU Revised Interim Ground 
Water Monitoring Plan) of the 2011 UAO and answer the questions posed in Section 2.4.1, 
Step 2 of the 2022 Interim Groundwater QAPP. 
Specific Comments 
 
2 
 
3. Section 1, Introduction, 4th sentence: Please revise “Groundwater Monitoring Quality Assurance 
Plan” to “Groundwater Monitoring Quality Assurance Project Plan”. 
4. Section 2.1, Methodology: There is a discrepancy between the 2023 GW QAPP and the 2023 
BPSOU Groundwater Compliance Evaluation in reference to the number of wells to be included in 
sampling. Please update this section to reflect the current groundwater well monitoring array for 
the appropriate sampling year by excluding abandoned/excluded wells (and manholes) and 
adjusting well counts based on monitoring frequency (semi-annually vs. every 5 years). The 2023 
GW QAPP states: 
o 117 wells in the Water Quality Monitoring Network for 2023 
o BPSOU Subdrain Manholes were to be removed in 2023 
o 106 wells sampled semiannually 
o 11 wells sampled every 5 years 
 Additionally, please specify the year of the Groundwater QAPP and provide an in-text citation. 
5. Section 2.2, Performance Standards, Table 1: Groundwater Quality Performance Standards may 
be based of the DEQ-7 standards, but the ruling document is the 2006 ROD and should be used as 
the column header. 
6. Section 2.3, Points of Compliance, Table 2 – Point of Compliance Groundwater Wells: Please 
remove the “1” superscript from the BPS07-05A Well ID or define what the superscript is for. 
7. Section 2.3, Points of Compliance, Table 2 – Point of Compliance Groundwater Wells: The 
screened interval reported for the following wells is not consistent to what is listed in the 2023 
GW QAPP. Please clarify for the following wells. 
o AMW-13B 
o BPS07-05A 
o BPS07-16A 
8. Section 4, Compliance Comparison Results: Please include Table 3 in the last sentence. 
9. Tables 5 & 6: COC Concentrations for several constituents (e.g., HgDis, PbDis, and others) appear 
to be non-detect values, revise and update the table to accurately reflect the data results. 
10. Table 6:  The dates reported appear to be copied and pasted from the spring sampling event. 
Please report the correct fall date(s) of sample collection. 
11. Section 7, Attachments: Please revise the title indicated here to match the title of the indicated 
on Figure 1. 
12. Figure 1: Please indicate the nature of the data reported on this groundwater map, for example, 
are the data averages of water levels or measurements taken on a specific date? 
If you have any questions or concerns, please call me at (406) 438-0823.  
 
      Sincerely,  
 
 
 
Emma Rott 
Remedial Project Manager 
 
3 
 
 
 
cc (email only) 
Butte File  
Chris Greco / Atlantic Richfield  
Mike Mcanulty / Atlantic Richfield  
Loren Burmeister / Atlantic Richfield  
Dave Griffis / Atlantic Richfield  
Tim Hilmo / Atlantic Richfield 
Jean Martin / Atlantic Richfield  
Irene Montero / Atlantic Richfield  
David A. Gratson / Environmental Standards  
Mave Gasaway / DGS  
Adam Cohen / DGS  
Brianne McClafferty / Holland & Hart  
Daryl Reed / DEQ  
Logan Dudding / DEQ  
Jacob Wheeling/ DEQ 
Jon Morgan / DEQ  
Kevin Stone / DEQ  
Amy Steinmetz / DEQ  
Katie Garcin-Forba / DEQ  
Doug Martin / NRDP  
Jim Ford / NRDP  
Pat Cunneen / NRDP  
Katherine Hausrath / NRDP  
Ted Duaime / MBMG  
Gary Icopini / MBMG  
Becky Summerville / MR  
John DeJong / UP  
Robert Bylsma / UP  
John Gilmour / Kelley Drye  
Leo Berry / BNSF  
Robert Lowry / BNSF  
Brooke Kuhl / BNSF  
Lauren Knickrehm / BNSF  
Doug Brannan / Kennedy Jenks  
Matthew Mavrinac / RARUS  
Harrison Roughton / RARUS  
Mark Neary / BSB  
Eric Hassler / BSB  
Chad Anderson / BSB  
Brandon Warner / BSB  
Abigail Peltomaa / BSB  
Sean Peterson/BSB  
Josh Vincent / WET  
Scott Bradshaw / W&C  
Emily Evans / W&C  
Pat Sampson / Pioneer  
Karen Helfrich / Pioneer  
Randa Colling / Pioneer  
Scott Sampson / Pioneer  
Jesse Schwarzrock / Pioneer 
Mark Meyer / Pioneer 
Ramzi Khuri / Jacobs 
Cord Harris / Jacobs  
Brent Lucyk / Stantec 
Rich Keeland / Aspect Engineering 
Andy White / Aspect Engineering 
Ian Magruder/ CTEC  
CTEC of Butte  
Scott Juskiewicz / Montana Tech  
David Shanight / CDM Smith  
Curt Coover / CDM Smith  
Chapin Storrar / CDM Smith  
Erin Agee / EPA  
Will Lindsey / EPA  
Ben Mathieu / EPA 
Jamie Miller / EPA  
Carolina Balliew / EPA  
Molly Roby / EPA  
Katherine Jenkins / EPA  
Charlie Partridge / EPA 
 


Re: Comment Letter for the 2023 Butte Priority Soils Operable Unit (BPSOU) Groundwater Compliance Evaluation (dated March 10, 2025)

Pioneer Technical Services, Inc.

Final Quarterly Operations and Maintenance Report Butte Treatment Lagoon System – Third Quarter 2023

McAnulty, Mike

RE: Butte Priority Soils Operable Unit (BPSOU) Final Insufficiently Reclaimed Sites Field Sampling and Investigation Plan (FSP) for UR-19 – Butte, Anaconda & Pacific Railway from Montana Street to South Arizona Avenue – Montana Street Adjacent Parcel

Woodard & Curran

September 16, 2025 
 
Emma Rott 
Remedial Project Manager 
US EPA Region 8 Montana Office,  
Federal Bldg., 10 W. 15th St., Suite 3200 
Helena, Montana 59626 
 
Daryl Reed 
DEQ, Project Officer  
P.O. Box 200901 
Helena, Montana 59620-0901 
 
 
Erin Agee, Senior Assistant Regional Counsel 
Mail Code 8 ORC_LE_C 
Office of Regional Counsel - CERCLA 
1595 Wynkoop Street 
Denver, Colorado 80202 
 
Jonathan Morgan, Esq. 
DEQ, Legal Counsel 
P.O. Box 200901 
Helena, Montana 59620-0901 
 
RE: Butte Priority Soils Operable Unit Clark Tailings Consolidated Waste Management Area 
Site Investigation Quality Assurance Project Plan Revision 0 (2025 Update) and Response to 
EPA Comment Letter dated July 31, 2025 
 
Agency Representatives: 
On behalf of Atlantic Richfield Company, I am submitting the Butte Priority Soils Operable Unit 
(BPSOU) Clark Tailings Consolidated Waste Management Area Site Investigation Quality Assurance 
Project Plan (QAPP) Revision 0 (2025 Update) for review and approval by EPA, in consultation with 
MDEQ.  
This QAPP update was prepared to identify completed tasks and changes made to data review, 
quality control, laboratory methods and analytes, or field procedures since the original QAPP 
submittal. Comments provided by the EPA in the crosswalk have been addressed and responses 
are provided in the crosswalk. Completed, ongoing, and planned tasks have been identified in Table 
1 of the QAPP and are reiterated below.  
Completed Tasks:  APS Investigation & GeoProbe Soil Sampling 
Cap Infiltration Testing 
Ground Penetrating Radar Survey 
Topographic Survey 
Ongoing Tasks:  Quarterly Surface Water, Groundwater, & Seep Monitoring 
Planned Tasks:  CCTV Storm Drain Investigation (September 29 – October 3, 2025) 
If you have any questions or comments, please call me at (406) 723-1834. 
 
Regards, 
 
Josh Bryson, PE, PMP 
Liability Manager 
Remediation Management Services Company 
An affiliate of Atlantic Richfield Company  
Cc: Chris Greco / Atlantic Richfield  
Josh Bryson / Atlantic Richfield  
Mike McAnulty / Atlantic Richfield  
Tim Hilmo / Atlantic Richfield  
Loren Burmeister / Atlantic Richfield  
Jean Martin / Atlantic Richfield  
Irene Montero / Atlantic Richfield  
David A. Gratson / Environmental Standards  
Mave Gasaway / DGS  
Adam Cohen / DGS  
Lucas Satterlee / DGS   
Brianne McClafferty / Holland & Hart   
Carolina Balliew / EPA   
Molly Roby / EPA   
David Shanight / CDM   
Curt Coover / CDM   
James Freeman / DOJ  
Alyxandra Ruzevich/ DEQ  
Amy Steinmetz / DEQ   
Logan Dudding / DEQ   
Katie Garcin-Forba / DEQ  
Doug Martin / NRDP   
Jim Ford / NRDP   
Katherine Hausrath / NRDP   
Ted Duaime / MBMG   
Gary Icopini / MBMG   
Becky Summerville / MR   
John DeJong / UP   
Robert Bylsma / UP   
John Gilmour / Kelley Drye   
Leo Berry / BNSF   
Robert Lowry / BNSF   
Brooke Kuhl / BNSF   
Lauren Knickrehm / BNSF   
Doug Brannan / Kennedy Jenks   
Matthew Mavrinac / RARUS   
Harrison Roughton / RARUS   
Brad Gordon / RARUS   
Mark Neary / BSB   
Eric Hassler / BSB   
Brandon Warner / BSB   
Abigail Peltomaa / BSB   
Aaron Rains / BSB   
Sean Peterson/BSB   
Josh Vincent / WET   
Kevin Bethke / W&C   
Scott Bradshaw / W&C   
Emily Evans / W&C   
Paddy Stoy / W&C   
Joe McElroy / Pioneer   
Mark Meyer / Pioneer   
Pat Sampson / Pioneer   
Troy Colvin / Pioneer   
Karen Helfrich / Pioneer   
Randa Colling / Pioneer   
Todd Church / Pioneer 
Rich Keeland / Aspect   
Andy White / Aspect   
Ian Magruder/ CTEC   
CTEC of Butte   
Scott Juskiewicz / Montana Tech   
  
  
File: RMO – upload   
BPSOU SharePoint – upload   
 


Butte Priority Soils Operable Unit Clark Tailings Consolidated Waste Management Area Site Investigation Quality Assurance Project Plan (QAPP) Revision 0

Roby, Molly

Montana Tech Library 
Digital Commons @ Montana Tech 
Silver Bow Creek/Butte Area Superfund Site Montana Superfund 
Spring 5-16-2025 
Re: Comment Letter for Draft Final BPSOU Unreclaimed Site 
Anderson Shaft Remedial Action Work Plan (RAWP) (dated June 
14, 2024) 
Molly Roby 
Environmental Protection Agency 
Follow this and additional works at: https://digitalcommons.mtech.edu/superfund_silverbowbutte 
 Part of the Environmental Health and Protection Commons, Environmental Indicators and Impact 
Assessment Commons, and the Environmental Monitoring Commons 
Recommended Citation 
Roby, Molly, "Re: Comment Letter for Draft Final BPSOU Unreclaimed Site Anderson Shaft Remedial Action 
Work Plan (RAWP) (dated June 14, 2024)" (2025). Silver Bow Creek/Butte Area Superfund Site. 1426. 
https://digitalcommons.mtech.edu/superfund_silverbowbutte/1426 
This Government Report is brought to you for free and open access by the Montana Superfund at Digital Commons 
@ Montana Tech. It has been accepted for inclusion in Silver Bow Creek/Butte Area Superfund Site by an 
authorized administrator of Digital Commons @ Montana Tech. For more information, please contact 
sjuskiewicz@mtech.edu. 
 
 
May 16, 2025 
Mr. Mike McAnulty 
Liability Manager 
Atlantic Richfield Company 
317 Anaconda Road 
Butte, MT 
59701 
Re: Comment Letter for Draft Final BPSOU Unreclaimed Site Anderson Shaft Remedial Action 
Work Plan (RAWP) (dated June 14, 2024) 
 
Dear Mr. McAnulty: 
The U. S. Environmental Protection Agency (EPA), in consultation with the Montana Department of 
Environmental Quality (DEQ), is providing comments on the Draft Final BPSOU Unreclaimed Site 
Anderson Shaft Remedial Action Work Plan (RAWP) (dated June 14, 2024). Please incorporate these 
comments and submit a revised version for Agency review. 
General Comments: 
1. Please include the UR identification in the title throughout the RAWP and construction drawings. 
2. Please detail the extent of the project boundary. Maps such as 94ARCO68 show that the area 
east of the roundhouse building should be included in the project site boundary. Please include 
the Butte-Silver Bow (BSB) property to the south in the project boundary, including the area east 
of the roundhouse or specify why the BSB property was excluded. Note, this area includes at least 
one storm drain and spoil piles of dirt and debris should be characterized. EPA also suggests 
working with BSB to backfill the areas of subsidence (e.g., collapsed utility raceways, etc.) on the 
east side of the roundhouse as part of this effort from a safety standpoint.  
 
Photo looking west from South Warren Avenue. 
Spoils Piles 
Storm Drain 
Mike McAnulty 
May 16, 2025 
Page 2 of 6 
 
3. Please consider either using beehive type manhole grate, raising the inlet elevation of the CB-1 
grate structure, or other BMPs to allow sediments and debris to drop out prior to the manhole.  
4. Please update references to the schedule from 2024 and update any features that have changed 
since the development of this RAWP (i.e., security fencing alignments, current land use). 
5. Please consider further actions to protect the existing trees such as adding cover to the tree areas 
and removing dead trees. 
6. When available, please provide an approved A+ material that will be used onsite. 
7. There is a disconnect between the language used in the text and the labeling that is presented on 
the construction drawings. For example, in Section 4.3.3, a feature called the “curb cut channel” 
is discussed but the construction drawings are labeled “curb outlet channel”. Please align text 
and construction drawings for consistency. 
8. The construction drawings state that there will be reclamation completed by another party on 
the property that belongs to BNSF. Will this reclamation be taking place at the same time as this 
one? Please provide additional detail and the include communication and coordination with BNSF 
on reclamation to be completed as a part of the RAWP. 
9. The naming of the catch basins may be problematic in the future. Naming the catch basins simply 
“catch basin-1” and “catch basin-2” may cause confusion; there are other catch basins within the 
BPSOU that already have these designations. Consider re-naming these features for ease of 
interpretation in the future. 
Specific Comments: 
1. Title Page: Please include the UR identification of this site in the title (UR-08). 
2. 2.0 Background 
• First paragraph, second sentence: Please include a citation to a reference document. 
• First paragraph, third and fourth sentences – Please modify these sentences to read:  
“…Scope of Work (FRESOW) (EPA, 2020). The work conducted at the Site is intended to 
address human health and environmental concerns and focuses on mitigating erosion of 
sediment onto surrounding properties and to downgradient surface water by implementing 
storm water infrastructure on the Site.” 
• Second paragraph, second sentence: Please include a citation to a reference document. 
• Second paragraph, third sentence: Please attach a site map that details the stormwater 
connection route between UR-08 and Silver Bow Creek, for reference. 
3. 2.1 Site Location and Work Plan 
• Second paragraph, fifth sentence: Please specify to which catch basins the stormwater flows 
will be directed. 
4. 3.2 Safety Considerations: Please add “Working with contaminated mine waste” to the bulleted 
list. 
5. 4.3 Remedial Cap 
• Second Paragraph, first sentence: The correct reference here is Appendix B.3 of Attachment A 
to Appendix B – Technical Specifications and Approved Borrow Sources. 
Mike McAnulty 
May 16, 2025 
Page 3 of 6 
 
• Second Paragraph, fourth sentence: Please clarify the order of tasks that will occur; at present 
this sentence reads as thought the Site regrading will take place before cover soil placement 
but after limestone placement. 
• Second to last sentence: Please confirm whether BSB plans to continue to store equipment 
and supplies for their Metro Storm Department. 
6. 4.3.2 Storm Water Piping and Inlet Installation 
• Second paragraph, first sentence: Revise; the location of proposed CB-2 is nearly directly 
north, not northeast. 
• Second paragraph, Second sentence: The “new subsurface 8-inch SDR 35 PVC piping” location 
has not been depicted on Sheet G-5 Project Overview. Please include. 
7. 4.3.4 Snow Storage Area 
• First sentence: The construction drawings show that the entirety of Madison Street will be 
used for snow storage in the future. Is it BSB’s plan to shut down Madison Street to traffic 
during the winter months to store snow? How will remnants (possibly contaminated) be 
managed so that impacts to the new reclamation and drainage structures downgradient are 
minimized? Please describe the snow storage plan in more detail, including the impacts of the 
snow percolating through waste material. 
8. 5.2 A+ Material 
• Last sentence: A+ material is not mentioned past the construction drawings in this document, 
appendices, and attachments. Please specifically state where the “approval documentation of 
A+ material development” can be found in Appendix B. Is it referring to the BPSOU Reclaimed 
Areas M&M SMP-4 – Organic Amendment, Appendix B.1 to the Butte Reclaimed Areas 
Maintenance and Monitoring Plan in Accordance with BRES which is Attachment A to the 
2023 BPSOU Helehan Borrow Submittal #1 located in Appendix B of this document? 
9. 5.4 1 ½ -Inch Minus (Base course) Material: 
• Last sentence: Please include the borrow submittal in the appendix for reference as well. 
10. 5.5 Seed: 
• First sentence: The document cited in this sentence is not included in the references section. 
Additionally, there is not a second Atlantic Richfield Company document from 2022, so please 
revise the reference to “Atlantic Richfield Company, 2022”. 
11. 6.0 Management of Change Review: Please add “Working with contaminated mine waste” to the 
bulleted list. 
12. 8.0 Post-Construction Operations and Maintenance: Please indicate the program through which 
monitoring and “as-needed” maintenance will be conducted (i.e., BRES program). Please describe 
the timeframe for this transfer. 
13. 9.0 References: Please add the Atlantic Richfield 2022 document that is cited in Section 5.5. 
14. Sheet G-3 Existing Conditions: 
Mike McAnulty 
May 16, 2025 
Page 4 of 6 
 
• Section 4.3.2 states that the Site currently contains two catch basin type inlets that collect 
and deliver water to a third catch basin inlet. This drawing does not mention catch basins. Is 
section 4.3.2 referring to the “existing storm drain inlets”? To avoid confusion, please ensure 
that the text matches the terms used in the site construction drawings. 
• Please label the BSB roundhouse building. 
• Please label the existing brick storm drain manhole near South Warren Avenue that is 
described in section 4.3.2. 
• Please indicate where BSB has been utilizing this site for snow storage. 
15. Sheet G-5 Project Overview: 
• Add “Construct Curb Outlet Channel” to this drawing. 
• Please indicate the location of the 8-inch SDR 35 PVC piping that is described in section 4.2.3. 
• Add “Curb Cut Channel” to this drawing. 
• Please add the blue to the legend. 
16. Sheet C-1 Site Grading Plan: 
• Please revise “curb outlet channel” to “curb cut channel” to be consistent with Section 4.3.3. 
• Please include a legend on this sheet. 
• In the SW corner of this drawing, there is an area that is marked for removal. This removal 
action has not been discussed in the text portion of this document. Please update and provide 
clarification for what is being removed and where it will be relocated/disposed. 
17. Sheet C-6 Volume Tables: 
• The box in the lower left hand corner states “Limestone quantity is based on a 2” thickness, 
field verified pH testing will determine actual thickness to be placed.” The BHRS requires a 
minimum 2” thickness. Suggest the wording should be revised to: “…field verified pH testing  
will determine the actual areal extent of subgrade soil with a pH of less than 5.5 SU and the 
quantity of limestone required will be adjusted accordingly.” 
18. Sheet C-7 Cover Plan 
• Please revise “curb outlet channel” to “curb cut channel” to be consistent with Section 4.3.3. 
• On the west end of the site, the topographical lines do not match up between the reclaimed 
area and the non-reclaimed area indicating that there will be a difference in elevation 
between the two. Please revise as this would be an unacceptable way to leave the site post-
reclamation.  
• Please add the thin white lines (located at the southeast portion of the site) and the red lines 
(western portion of the site) to the legend. 
19. Sheet C-13 Curb and Gutter Plan and Profile: Please add “channel” to the end of “curb cut” on the 
drawing. 
20. Sheet D-2 Curb and Asphalt Surfacing Details, Drawing 3: Revise “Cutter” to “Gutter” 
21. Appendix B: Please break this appendix into labeled subsections with title pages to allow for easy 
referencing and navigation. 
Mike McAnulty 
May 16, 2025 
Page 5 of 6 
 
22. Appendix C – Anderson Shaft Hydrology Design Report, Section 3.1 – Hydrology, 8th sentence: 
This sentence specifies six different drainage areas; however, Figure 2 (and Table 1) only has five 
drainage areas. It appears that the Southwest and Southeast Site Areas have been combined into 
the South Site Area on Figure 2. Please revise for clarity and consistency. 
23. Section 3.2 – Hydraulics, Last sentence: This sentence cites an Attachment D, which is not 
included. Please revise. 
24. Section 3.2.4 – Storm Drain: 
• Please provide a narrative regarding the existing 24-in Storm Drain that is shown in the 
Channel Report. 
• Please label Attachments A, B, and C with titles describing what is contained within. 
25. Hydrograph Report: 
• Hydrograph #8: the reported drainage area on this hydrograph is 0.190 ac but is reported as 
0.22 ac on Figure 2. Please confirm the acreage and recalculate as necessary. 
• Please move the Hydroflow Table of Contents to the beginning of the Hydroflow tables. 
 
If you have any questions or concerns, please feel free to set up a meeting to discuss.  
 
      Sincerely,  
 
 
 
Molly Roby 
Remedial Project Manager 
 
cc: (email only) 
Butte File  
Chris Greco / Atlantic Richfield  
Josh Bryson / Atlantic Richfield  
Loren Burmeister / Atlantic Richfield  
Dave Griffis / Atlantic Richfield  
Tim Hilmo / Atlantic Richfield 
Jean Martin / Atlantic Richfield  
Irene Montero / Atlantic Richfield  
David A. Gratson / Environmental Standards  
Mave Gasaway / DGS  
Adam Cohen / DGS  
Brianne McClafferty / Holland & Hart  
Daryl Reed / DEQ  
Logan Dudding / DEQ  
Jacob Wheeling/ DEQ 
Alyxandra Ruzevich / DEQ 
Jon Morgan / DEQ  
Kevin Stone / DEQ  
Amy Steinmetz / DEQ  
Katie Garcin-Forba / DEQ  
Doug Martin / NRDP  
Jim Ford / NRDP  
Katherine Hausrath / NRDP  
Ted Duaime / MBMG  
Gary Icopini / MBMG  
Becky Summerville / MR  
John DeJong / UP  
Robert Bylsma / UP  
John Gilmour / Kelley Drye  
Leo Berry / BNSF  
Robert Lowry / BNSF  
Brooke Kuhl / BNSF  
Lauren Knickrehm / BNSF  
Doug Brannan / Kennedy Jenks  
Mike McAnulty 
May 16, 2025 
Page 6 of 6 
 
Matthew Mavrinac / RARUS  
Harrison Roughton / RARUS  
Mark Neary / BSB  
Eric Hassler / BSB  
Chad Anderson / BSB  
Brandon Warner / BSB  
Abigail Peltomaa / BSB  
Sean Peterson/BSB  
Josh Vincent / WET  
Scott Bradshaw / W&C  
Emily Evans / W&C  
Pat Sampson / Pioneer  
Karen Helfrich / Pioneer  
Randa Colling / Pioneer  
Scott Sampson / Pioneer  
Jesse Schwarzrock / Pioneer 
Mark Meyer / Pioneer 
Brent Lucyk / Stantec 
Rich Keeland / Aspect Engineering 
Andy White / Aspect Engineering 
Ian Magruder/ CTEC  
CTEC of Butte  
Scott Juskiewicz / Montana Tech  
David Shanight / CDM Smith  
Curt Coover / CDM Smith  
Chapin Storrar / CDM Smith  
Erin Agee / EPA  
Will Lindsey / EPA  
Ben Mathieu / EPA 
Hannah Woolsey / EPA 
Jamie Miller / EPA  
Carolina Balliew / EPA  
Emma Rott / EPA  
Katherine Jenkins / EPA  
Charlie Partridge / EPA
 
 


Re: Comment Letter for Draft Final BPSOU Unreclaimed Site Anderson Shaft Remedial Action Work Plan (RAWP) (dated June 14, 2024)

Montana Tech Library 
Digital Commons @ Montana Tech 
Silver Bow Creek/Butte Area Superfund Site Montana Superfund 
Summer 7-25-2025 
Re: Comment Letter for BPSOU Uncontrolled Surface Flow Areas 
Drainage C 30% Design RAWP (dated June 23, 2025) 
Molly Roby 
Environmental Protection Agency 
Follow this and additional works at: https://digitalcommons.mtech.edu/superfund_silverbowbutte 
 Part of the Environmental Health and Protection Commons, Environmental Indicators and Impact 
Assessment Commons, and the Environmental Monitoring Commons 
Recommended Citation 
Roby, Molly, "Re: Comment Letter for BPSOU Uncontrolled Surface Flow Areas Drainage C 30% Design 
RAWP (dated June 23, 2025)" (2025). Silver Bow Creek/Butte Area Superfund Site. 1445. 
https://digitalcommons.mtech.edu/superfund_silverbowbutte/1445 
This Government Report is brought to you for free and open access by the Montana Superfund at Digital Commons 
@ Montana Tech. It has been accepted for inclusion in Silver Bow Creek/Butte Area Superfund Site by an 
authorized administrator of Digital Commons @ Montana Tech. For more information, please contact 
sjuskiewicz@mtech.edu. 
July 25, 2025 
Mr. Mike McAnulty 
Liability Manager 
Atlantic Richfield Company 
317 Anaconda Road 
Butte, Montana 59701 
Re: Comment Letter for BPSOU Uncontrolled Surface Flow Areas Drainage C 30% Design 
RAWP (dated June 23, 2025) 
Dear Mr. McAnulty: 
The U. S. Environmental Protection Agency (EPA) in consultation with the Montana Department of 
Environmental Quality (DEQ) has reviewed and is providing comments on the BPSOU Uncontrolled 
Surface Flow Areas Drainage C 30% Design RAWP (dated June 23, 2025). Please incorporate these 
comments into the next design package. 
Comments: 
1. With the next submittal, please confirm that Butte Silver Bow County (BSB) and Northwestern
Energy have had the opportunity to review and provide input on the remedial design. For
subsequent drainage design packages, the Agencies will expect that coordination with BSB (and
where required, Northwestern Energy) will occur prior to the submittal of the 30% design
package submittal to ensure that BSB is in alignment. As discussed in the design meeting on July
22, 2025, the documentation of this coordination can simply be summarized in the design report.
o Please confirm that AR has consulted with Northwestern Energy about the depth to
pipelines, precise alignments, and how to evaluate the length and width of construction
disturbance.
o Please confirm that AR has consulted with BSB, especially regarding the operation and
maintenance activities and design considerations for the project.
2. Please coordinate with BSB regarding design features that will support operation and
maintenance activities, to the extent possible. Please evaluate the potential extension of the
service road between the sedimentation basin and the infiltration basin, as well as around the
north side of the infiltration basin to enhance operational and maintenance accessibility. The
Agencies want to ensure that maintenance crews have adequate area to drive maintenance
equipment safely and efficiently, especially where berms are proposed above current conditions.
Mike McAnulty 
July 25, 2025 
Page 2 of 4 
3. To prevent erosion and any damage from water cutting into the existing cover soil cap at this
Butte Reclamation Evaluation System (BRES) site, please include a vegetative pilot channel to
direct surface flow to best management practices (BMPs) features, specifically:
o from the emergency overflow spillway to the culvert underneath the interstate, to the
extent possible considering easements and right-of way; and
o downgradient of the culvert passing under the proposed access road to the existing
stone channel at the eastern edge of the property.
4. The Agencies request the replacement of the existing culverts under West Greenwood Avenue be
included in the next remedial design submittal.
For the culvert located on the southwest side of the project area:
o Please extend the project area south to include the replacement of the rusted, 24-inch
corrugated metal culvert (CMP) under West Greenwood Avenue, with a new 24-inch
reinforced concrete pipe (RCP) and appropriate backfill and bedding material.
o Install Class 1 riprap at new culvert inlet and outlet for inlet embankment scour
protection and outlet flowline scour protection.
o Install culvert aprons on inlet and outlet.
o Install a trash screen on the inlet side to prevent debris from entering the culvert.
For the culvert located on the southeast side of the project area: 
o Please extend the project area south to include the replacement of the existing, 18-inch
CMP culvert under West Greenwood Avenue (currently discharging into the existing
rock channel along the east edge of the property), with a new 24-inch RCP and
appropriate backfill and bedding material.
o Install Class 1 riprap at new culvert inlet and outlet for inlet embankment scour
protection and outlet flowline scour protection.
o Install culvert aprons on inlet and outlet.
o Install a trash screen on the inlet side to prevent debris from entering the culvert.
5. DSR Section 2.2 Field Testing: The text states the remaining infiltration tests will be performed in
2025. Please provide an update to the results obtained in 2025.
6. Att A – Design Report; Section 1.2.3: There is a concern of sediment resuspension in the
sedimentation basin during high flow, stormwater events. It is shallow (1.5 feet deep); therefore,
resuspended sediment could easily escape to the infiltration basin. Please confirm that AR has
evaluated the settling velocities for incoming sediment to verify proper fallout time and provide
the expected sediment settling in the next iteration of the design package.
7. Att A – Design Report; Section 3.4.6: Please update the design report to include information
regarding the sediment removal frequency. Please also provide a preliminary schedule that is
expected for maintenance activities and cleanout of sediments.
8. Att A – Design Report; Section 4.3.1.2: The vegetated swale is sized to convey the 10-year 24-
hour peak flow. Please provide the basis for this design parameter.
Mike McAnulty 
July 25, 2025 
Page 3 of 4 
9. Att A – Design Report; Section 4.3.1.2: To prevent erosion and any cutting into the existing cover
soil cap at this Butte Reclamation Evaluation System (BRES) site, please include a vegetative pilot
channel to direct surface flow to best management practices (BMPs) features, specifically:
o from the emergency overflow spillway to the culvert underneath the interstate, to the
extent possible considering easements and right-of way; and
o downgradient of the culvert passing under the proposed access road to the existing
stone channel at the eastern edge of the property.
10. Att A – Design Report; Figure 2: In the overland flow area downstream of the 24” RCP culvert,
there is concern about erosion and additional sediment losses, even with the riprap energy
dissipator. Please confirm the erosion from this structure has been evaluated and taken into
consideration in the remedial design. See also Comment 4 above.
11. Att A-B-Calculation Briefs: USFA-C-004 Weir Sizing.pdf: Please provide weir flow equations and
calculations leading to the weir dimensions selected.  
If you have any questions or concerns, please call me at (406) 438-0826. 
Sincerely, 
Molly Roby 
Remedial Project Manager 
cc: (email only)
Butte File 
Chris Greco / Atlantic Richfield  
Josh Bryson / Atlantic Richfield  
Loren Burmeister / Atlantic Richfield  
Dave Griffis / Atlantic Richfield  
Tim Hilmo / Atlantic Richfield 
Jean Martin / Atlantic Richfield  
Irene Montero / Atlantic Richfield  
David A. Gratson / Environmental Standards 
Mave Gasaway / DGS  
Adam Cohen / DGS  
Brianne McClafferty / Holland & Hart  
Daryl Reed / DEQ  
Logan Dudding / DEQ  
Jacob Wheeling/ DEQ 
Alyxandra Ruzevich / DEQ 
Jon Morgan / DEQ  
Kevin Stone / DEQ  
Amy Steinmetz / DEQ  
Katie Garcin-Forba / DEQ 
Doug Martin / NRDP  
Jim Ford / NRDP  
Katherine Hausrath / NRDP  
Ted Duaime / MBMG  
Gary Icopini / MBMG  
Becky Summerville / MR  
John DeJong / UP  
Robert Bylsma / UP  
John Gilmour / Kelley Drye  
Leo Berry / BNSF  
Robert Lowry / BNSF  
Brooke Kuhl / BNSF 
Lauren Knickrehm / BNSF  
Doug Brannan / Kennedy Jenks 
Matthew Mavrinac / RARUS  
Harrison Roughton / RARUS 
Mark Neary / BSB 
Eric Hassler / BSB 
Chad Anderson / BSB  
Brandon Warner / BSB 
Abigail Peltomaa / BSB 
Sean Peterson / BSB 
Mike McAnulty 
July 25, 2025 
Page 4 of 4 
cc: continued 
Josh Vincent / WET  
Scott Bradshaw / W&C  
Emily Evans / W&C  
Paddy Stoy / W&C
Pat Sampson / Pioneer  
Karen Helfrich / Pioneer  
Randa Colling / Pioneer  
Scott Sampson / Pioneer  
Jesse Schwarzrock / Pioneer 
Mark Meyer / Pioneer 
Brent Lucyk / Stantec 
Rich Keeland / Aspect Engineering 
Andy White / Aspect Engineering 
Ian Magruder/ CTEC  
CTEC of Butte  
Scott Juskiewicz / Montana Tech  
David Shanight / CDM Smith   
Curt Coover / CDM Smith
Chapin Storrar / CDM Smith  
Erin Agee / EPA  
Will Lindsey / EPA  
Ben Mathieu / EPA 
Hannah Woolsey / EPA 
Jamie Miller / EPA  
Carolina Balliew / EPA  
Emma Rott / EPA  
Katherine Jenkins / EPA  
Charlie Partridge / EPA 


Re: Comment Letter for BPSOU Uncontrolled Surface Flow Areas Drainage C 30% Design RAWP (dated June 23, 2025)

Thompson, Mark

Griffis, Dave

Re: Butte Mine Flooding Operable Unit Berkeley Pit and Discharge Pilot Project – August 2025 Monthly Discharge Monitoring Report

Re: Butte Mine Flooding Operable Unit Berkeley Pit and Discharge Pilot Project – May 2025 Monthly Discharge Monitoring Report

DISCHARGE SYSTEM FIELD SAMPLING PLAN, 2025 UPDATE SILVER BOW CREEK/BUTTE AREA NPL SITE BUTTE MINE FLOODING OPERABLE UNIT | BUTTE, MONTANA

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