Digital Commons @ Montana Tech

Rott, Emma

Montana Tech Library 
Digital Commons @ Montana Tech 
Silver Bow Creek/Butte Area Superfund Site Montana Superfund 
Summer 8-22-2025 
Re: Approval Letter for Butte Priority Soils Operable Unit (BPSOU) 
Superfund Operation and Maintenance (O&M) Request for 
Maintenance – Kelley Stormwater Channels (revised on July 23, 
2025) 
Emma Rott 
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 
Rott, Emma, "Re: Approval Letter for Butte Priority Soils Operable Unit (BPSOU) Superfund Operation and 
Maintenance (O&M) Request for Maintenance – Kelley Stormwater Channels (revised on July 23, 2025)" 
(2025). Silver Bow Creek/Butte Area Superfund Site. 1436. 
https://digitalcommons.mtech.edu/superfund_silverbowbutte/1436 
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. 
 
 
August 22, 2025 
 
 
Mr. Josh Bryson 
Liability Manager 
Atlantic Richfield Company 
317 Anaconda Road 
Butte, Montana 59701 
 
Re: Approval Letter for Butte Priority Soils Operable Unit (BPSOU) Superfund Operation and 
Maintenance (O&M) Request for Maintenance – Kelley Stormwater Channels (revised on July 
23, 2025) 
 
Dear Mr. Bryson: 
 
The U. S. Environmental Protection Agency (EPA) in consultation with the Montana Department of 
Environmental Quality (DEQ) is approving the Butte Priority Soils Operable Unit (BPSOU) Superfund 
Operation and Maintenance (O&M) Request for Maintenance – Kelley Stormwater Channels (revised on 
July 23, 2025). Please attach the signed request for maintenance and distribute as final.  
If you have any questions or concerns, please call me at (406) 438-0823.  
 
      Sincerely,  
 
 
 
Emma Rott, P.E. 
Remedial Project Manager 
 
 
 
ENCLOSURE: 
1. Signed Superfund Operation and Maintenance (O&M) Request for Maintenance – Kelley 
Stormwater Channels  
 
 
 
 
 
2 
 
Cc (by 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 
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  
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 
Todd Church / 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 
Carolina Balliew / EPA  
Molly Roby / EPA  
Katherine Jenkins / EPA  
Charlie Partridge / EPA 
 


Re: Approval Letter for Butte Priority Soils Operable Unit (BPSOU) Superfund Operation and Maintenance (O&M) Request for Maintenance – Kelley Stormwater Channels (revised on July 23, 2025)

Roby, Molly

Montana Tech Library 
Digital Commons @ Montana Tech 
Silver Bow Creek/Butte Area Superfund Site Montana Superfund 
Summer 7-11-2025 
Re: Comment Letter for 2024 Annual Operations and Maintenance 
Report Butte Reclamation Evaluation System (BRES) Annual 
Summary Report for Work Completed in Quadrant 4 (dated May 1, 
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 2024 Annual Operations and Maintenance Report Butte Reclamation 
Evaluation System (BRES) Annual Summary Report for Work Completed in Quadrant 4 (dated May 1, 
2025)" (2025). Silver Bow Creek/Butte Area Superfund Site. 1437. 
https://digitalcommons.mtech.edu/superfund_silverbowbutte/1437 
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 11, 2025 
Ms. Abigail Peltomaa 
Data and Outreach Manager 
Reclamation and Environmental Services Dept. 
The City-County of Butte-Silver Bow  
600 Gilman Ave. 
Butte, MT 59701 
Mr. Brandon Warner 
Operations Manager 
Reclamation and Environmental Services Dept. 
The City-County of Butte-Silver Bow  
600 Gilman Ave. 
Butte, MT 59701 
 
Re: Comment Letter for 2024 Annual Operations and Maintenance Report Butte Reclamation Evaluation 
System (BRES) Annual Summary Report for Work Completed in Quadrant 4 (dated May 1, 2025) 
 
Dear Ms. Peltomaa and Mr. Warner: 
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 2024 Annual Operations and 
Maintenance Report Butte Reclamation Evaluation System (BRES) Annual Summary Report for Work Completed 
in Quadrant 4 (the Annual Report) dated May 1, 2025. Please incorporate these comments and submit a revised 
version. 
General Comments: 
1. EPA requests that weed management be conducted every year in spring and fall to preserve the integrity 
of the wastes capped in place. The twice a year schedule should be maintained until such time that weed 
conditions at individual sites demonstrate improvements, where weed control activities can be reduced. 
2. Appendix B is not included in the table of contents of the Annual Report. Please review all references to 
Appendix B throughout the text of the Annual Report and correct the reference where necessary. For 
example in the text of the Annual Report under the Site Summary for Site 120 – Bonanza Dump,  the 
Corrective Action Plan subsection references Appendix B while the Corrective Action Plans are included in 
Appendix A.  
• The current Appendix B includes information that is not necessarily relevant to the Annual Report, 
specifically work performed on stormwater features. For future reports please consider revising what 
is included within Appendix B to specific or relevant information to the quadrant evaluated. 
3. Due to construction taking place outside of the normal evaluation schedule, the comprehensive BRES site 
evaluation is not being fully achieved and is anticipated to have an effect on evaluation results. The 
Agencies are requesting that a concerted effort is made to complete the quadrant activities in the 
appropriate construction season. 
4. EPA requests a meeting agenda item at an upcoming technical working group meeting to define the 
Insufficiently Reclaimed and Reclamation Improvement categories and to accurately document which of 
these corrective actions will be implemented based on results of the BRES field inspections. 
5. Please provide an update as to when the Agencies should expect to see the Field Sampling Plans for the 
following IR Sites: Site 135 Washoe Sampling Works, Site 136 Ophir Dump, Site 154 Clark Mill Tailings NE, 
Site 156 Timber Butte Mill. 
Brandon Warner and Abigail Peltomaa 
July 11, 2025 
Page 2 of 4 
6. As indicated in the Annual Report, Field Sampling Plans were submitted for the Dexter Mill (Site 133) 
(August 15, 2022) and for Star West (Site 134) (July 25, 2023). Please provide an update as to when the 
Site Evaluation Summary Report for these sites will be presented. If possible, please update the Annual 
Report to reflect the results of the sampling.   
Specific Comments: 
1. List of Acronyms: Please add the following to the list of Acronyms. 
ATV – all terrain vehicle 
EA – Engineering Assessment 
FRESOW – Further Remedial Elements Scope of Work 
FSP – Field Sampling Plan 
M – monitor 
NE – northeast 
RI – Reclamation Improvement 
VI – Vegetation Improvement 
Please remove the following from the list of Acronyms: 
QA/QC – Quality Assurance and Quality Control 
RMAP – Residential Metals Abatement Program 
Please define BPSOU and QAPP in the text before using it as an acronym; recommend doing this in the 
Introduction section. 
2. Introduction, Second Paragraph. Please update the reference at the end of the sentence to (EPA, 2006a).  
3. Introduction, BRES O&M Implementation, Page 5. This section currently describes the BRES field 
inspection tool and process, not the operation and maintenance process. Please insert the following from 
the Butte Reclaimed Areas Monitoring and Maintenance Plan and add a reference to this document:  
The annual report provides a summary of all corrective actions completed to address deficiencies and 
trigger items identified during field evaluations and describes conventional maintenance tasks 
implemented on a site. Work completion summaries will typically include documentation of the 
materials used, their source, quantity and final site condition. 
4. Introduction, Evaluation Sites, Figure 2, Page 7. The map presented as Figure 2. BRES Quadrant 4 Site 
Locations is a map of Quadrant 1. Please update. 
5. Introduction, Evaluation Sites, Table 2.1, Page 8. Quadrant 4 Sites: Bonanza Dump East (120E) indicates a 
vegetation improvement plan, while Appendix A indicates this site will be investigated under the 
Insufficiently Reclaimed Sites QAPP. Please verify and update. 
6. Introduction, Evaluation Summary, Table 2.4. BRES Evaluation Summary, Page 9. Please include all 
Quadrant 4 Sites in the table; if evaluation form was not completed (as for Dexter Mill) please list in the 
table with N/A. This allows for consistency with site designation and evaluation. 
7. Site 120E – Bonanza Dump East, Proposed Corrective Action, Page 11. 
• Site Edges; last sentence: Add “seeded” after “interstitially”. 
8. Site 132 – Emma Dump, Page 13. 
• Field Evaluation Summary; first sentence: the Corrective Actions report indicates that the adjusted live 
score for this site was 50, not 40. Please verify and update accordingly. 
• Proposed Corrective Action, Administrative: Removal and repair of broken fencing is listed in this 
section, but is not listed in Appendix A or Appendix B. Please verify and update if this corrective action 
was performed. 
Brandon Warner and Abigail Peltomaa 
July 11, 2025 
Page 3 of 4 
• Summary of Corrective Actions; Seventh sentence: “Twelve cubic yards of exposed waste removed 
and disposed of at the MWR using the excavator and dump trucks.” Sentence appears to be repetitive 
to another sentence earlier in the paragraph. Please verify and update accordingly. 
9. Site 142 – Charlie Judd Park, Page 16. Appendix B references repair of a gully and broken curbing using 
asphalt millings, but that information is not included in the Annual Report as a corrective action. Please 
update the Annual Report to reflect this work. 
10. Site 150 – Colorado Smelter, Page 17. Appendix B references the repair of a gully (addition of soil) and the 
repair of barren areas but is not included in the Annual Report as a corrective action. Please update the 
Annual Report to reflect this work. Please verify/update the Summary of Corrective Actions subsection 
and, if necessary, Appendix B as to whether the following Proposed Corrective Actions identified in the 
Annual Report were preformed: 
i. Mow or weed whack to address weedy species on site. 
ii. Interstitially seed site edges. 
iii. Land slump will be investigated and repaired. 
11. Site 150N – Colorado Smelter North, Page 18. Please update the Summary of Corrective Actions with the 
raking of plant litter and broadcast seeding, as cited in Appendix B. Additionally, please verify and update 
the Summary of the Corrective Actions subsection and, if necessary, the appendices describing the 
application of chemical weed control was completed as described in the Proposed Corrective Actions 
subsection. 
12. Site 152 – Montana St. & I-90, Page 19. The Summary of Corrective Actions subsection identified the 
removal of 46 cubic yards of waste. Please describe any excavation was below ground surface and any 
cover materials placed onsite. 
13. Site 155 – Clark Mill Tailings, Page 20. The text indicates that the Agencies never approved the corrective 
actions. Please provide a copy of the proposed Corrective Action Plan to the Agencies for approval. 
14. Site 1796 – Kaw at Casey, Page 23. In the Field Evaluation Summary, please include the adjusted live score. 
15. Site 2310 – Silver Bow Creek, Page 24. Please add “Seeding of sparsely vegetated area with EPA approved 
seed mix” to the Summary of Corrective Actions as cited in Appendix B. 
16. Site CB08 – Catch Basin 08, Page 26. Please add “Removal of sediment from ditch and disposed of at [mine 
waste repository]” and “Repair of barren areas identified during site evaluation using EPA approved soil” 
in the Summary of Corrective Actions as cited in Appendix B. 
17. Site CB09 – Catch Basin 09, Page 27. Please include in the Summary of Corrective Actions the type of 
material (i.e., sediment) that was removed from the ditch at this site. 
18. Appendix B – Monthly Operations and Maintenance Reports. 
• Please include this Appendix as an attachment to the 2024 Annual Operations and Maintenance 
Report. 
• Each Operations and Maintenance report in Appendix B references photographs that have not been 
attached. Please either attach the photos referenced or remove the photograph reference all 
together. 
• The Appendix Report does not include the following work currently presented in the Summary of 
Corrective Actions for Site 132-Emma Dump; please update Appendix B: 
i. Installation of 12 cy limerock, 100 cy of fill, and 32 cy of cover soil over excavated area. 
ii. Repair of barren area using 3 cy of cover soil. 
 
 
Brandon Warner and Abigail Peltomaa 
July 11, 2025 
Page 4 of 4 
Please let me know if you have any questions. 
 
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  
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 2024 Annual Operations and Maintenance Report Butte Reclamation Evaluation System (BRES) Annual Summary Report for Work Completed in Quadrant 4 (dated May 1, 2025)

Thompson, Mark

Griffis, Dave

Re: BUTTE MINE FLOODING SITE CD, CV 02-35 Bu-RFC, 2025 Second Quarter Report

Montana Tech Library 
Digital Commons @ Montana Tech 
Silver Bow Creek/Butte Area Superfund Site Montana Superfund 
Summer 6-27-2025 
Re: Comment letter for the Butte Priority Soils Operable Unit 
(BPSOU) Insufficiently Reclaimed Sites Josephine Shaft (IR-37) 
Remedial Action Work Plan (RAWP) (dated February 6, 2025) 
Molly Roby 
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 
 
 
June 27, 2025 
Mr. Mike McAnulty 
Liability Manager 
Atlantic Richfield Company 
317 Anaconda Road 
Butte, Montana 59701 
 
Re: Comment letter for the Butte Priority Soils Operable Unit (BPSOU) Insufficiently Reclaimed 
Sites Josephine Shaft (IR-37) Remedial Action Work Plan (RAWP) (dated February 6, 2025) 
 
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 Butte Priority Soils Operable Unit (BPSOU) 
Insufficiently Reclaimed Sites Josephine Shaft (IR-37) Remedial Action Work Plan (RAWP) (dated 
February 6, 2025). Please address the comments below and resubmit the document for agency review. 
General Comments 
1. Please include the sample results table within this report for quick reference. 
2. Take into consideration that the sized channel be over excavated to accommodate the riprap, so 
not to lose flow area. Section 4.2.3 states it will be layered atop the shaped and compacted 
native subgrade. Losing one foot of flow area along the channel bottom, while also increasing 
Manning’s roughness, will impact conveyance.  
Specific Comments 
3. Section 1.0 Introduction; 3rd sentence: Please remove this sentence; the “soil sampling” did not 
determine the reclamation requirements; the next sentence accurately references the Butte Hill 
Revegetation Specifications. 
4. Section 1.0 Introduction; 4th sentence: The CD does not address this claim (reclamation being 
conducted prior to establishment of BHRS). Update the reference to the Consent Decree (CD) to 
specifically reference Appendix D of the CD – the BPSOU Statement of Work. In addition, in order 
for a BRES site to qualify for IR designation, it must fail its vegetation requirements for two 
evaluation cycles in a row, not just once. Please revise this sentence to include specific years 
where the evaluation was failed. 
5.  Section 2.0 Background; 3rd paragraph; 1st sentence: It appears that this sentence may be missing 
information; please revise. 
6.  Section 2.1 Site Location and Work Plan; 1st sentence: This site is not between Dunn Street and 
East Clark Street. Please revise. 
Mike McAnulty 
June 27, 2025 
Page 2 of 3 
7. Section 2.1 Site Location and Work Plan; 2nd sentence: Atlantic Richfield owns most of the site
but a small piece in the southwest corner of the site is owned by the City of Walkerville. Please
ensure this is included, the City of Walkerville is aware of RA activities, and all proper permits
have been filed.
8. Section 2.1 Site Location and Work Plan; last sentence: Please explain if previous RA activities
were conducted under BRES or if this is referring to the historic remedial action that took place
prior to BHRS? Please revise for clarity.
9. Section 4.0 Description of Work: The topics discussed in this paragraph are addressed in
individual subsections below this section except for site regrading. Please include a subsection
detailing the excavation and site regrading that is expected to take place at this site. Include
information related to waste disposal as well.
10. Section 4.2.1 Vegetative Caps; 3rd sentence: Please indicate the pH value that would require the
addition of 2” of limestone and clarify whether this pH data will be collected during the
reclamation project or if it is already existing data collected during the prior field sampling.
11. Section 4.2.1 Vegetative Caps: Please ensure that the reference to the Butte Hill Revegetation
Specifications is the latest approved version; please provide a separate update to the Agencies
regarding the proposed updates to the BHRS drafted in 2024.
12. Section 4.2.2 Vegetative Improvement: Please revise “(PAL, 2020)” to “(Pal Mixture, 2020)”.
13. Section 4.2.2 Vegetative Improvement: The text states, “The vegetative improvement will be
performed at the direction of a revegetation consultant.” EPA is concerned that the results of the
IR investigation in areas designated for Vegetation Improvement (VI) are not being considered in
the RAWP. Dr. Pal made his recommendations in 2021 and the IR investigation was conducted in
2022. Multiple results in the designated VI area (Sheet G-5) fail chemical and textural
requirements contained in the BHRS. Additionally, cap thickness is not discussed and could be
another potential issue that needs to be considered.  Please provide the details of VI in the RAWP
after consultation with Dr. Pal (or the revegetation consultant). Update this RAWP or provide a VI
plan under separate cover for EPA approval.
14. Section 5.1 A-Minus (A-) Material: Reference the specific document as either 2022a or 2022b.
15. Section 5.4 Seed: Circle S Seeds in Three Forks does not appear to be certified weed free. Please
verify and correct as necessary.
16. Section 5.5 Riprap Material: Please share how AR will communicate with the Agencies regarding
material source. What documentation will be used?
17. Section 8.0 Post-Construction Operation and Maintenance: Please indicate the program to which
AR will release the site to under BSB’s care (i.e., BRES). 
18. Section 9.0 References: Please include a reference in the text to the first document identified or
remove it from the references.
18. Appendix A – Construction Drawings; G-3 Existing Site Conditions: The existing underground
telephone line located at the southeast corner of the site appears to end at the site boundary.
Please confirm and revise as necessary.
19. Appendix C Site Hydrology Design Report; Figure 3: Please include color coding in the legend.
Mike McAnulty 
June 27, 2025 
Page 3 of 3 
If you have any questions or concerns, please call me at (406) 457-5021. 
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 
cc: continued 
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  
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 the Butte Priority Soils Operable Unit (BPSOU) Insufficiently Reclaimed Sites Josephine Shaft (IR-37) Remedial Action Work Plan (RAWP) (dated February 6, 2025)

Rampart Solutions

On-Site Water Management Field Sampling Plan (FSP), 2025 Update

Montana Tech Library 
Digital Commons @ Montana Tech 
Silver Bow Creek/Butte Area Superfund Site Montana Superfund 
Summer 6-18-2025 
Re: Approval letter for the Butte Priority Soils Operable Unit 
(BPSOU) Revised Draft Final Unreclaimed Sites (UR-05) Remedial 
Action Work Plan (RAWP) (dated June 10, 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: Approval letter for the Butte Priority Soils Operable Unit (BPSOU) Revised Draft Final 
Unreclaimed Sites (UR-05) Remedial Action Work Plan (RAWP) (dated June 10, 2025)" (2025). Silver Bow 
Creek/Butte Area Superfund Site. 1485. 
https://digitalcommons.mtech.edu/superfund_silverbowbutte/1485 
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. 
 
 
June 18, 2025 
 
Mr. Mike McAnulty 
Liability Manager 
Atlantic Richfield Company 
317 Anaconda Road 
Butte, Montana 59701 
 
Re: Approval letter for the Butte Priority Soils Operable Unit (BPSOU) Revised Draft Final 
Unreclaimed Sites (UR-05) Remedial Action Work Plan (RAWP) (dated June 10, 2025) 
  
Dear Mr. McAnulty: 
 
The U. S. Environmental Protection Agency (EPA), in consultation with the Montana Department of 
Environmental Quality (DEQ), is approving the Butte Priority Soils Operable Unit (BPSOU) Revised Draft 
Final Unreclaimed (IR) Sites (UR-05) Remedial Action Work Plan (RAWP) (dated June 10, 2025). Please 
distribute this RAWP as final. If you have any questions, please call me at (406) 457-5021.  
 
      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  
Mike McAnulty 
June 18, 2025 
Page 2 of 2 
 
cc: continued  
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 
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: Approval letter for the Butte Priority Soils Operable Unit (BPSOU) Revised Draft Final Unreclaimed Sites (UR-05) Remedial Action Work Plan (RAWP) (dated June 10, 2025)

Pioneer Technical Services, Inc.

Final 2025 Residential Metals Abatement Program (RMAP) Butte KOA Playground Soil Remedial Action Work Plan (RAWP)

McAnulty, Mike

RE: Butte Priority Soil Operable Unit (BPSOU) Final Insufficiently Reclaimed Sites Field Sampling Plan (FSP): BRES No. 91 – Robert Emmett Dump

RE: Butte Priority Soil Operable Unit (BPSOU) Final BRES No.94 – Rialto Dump Reclamation Improvement (RI) Field Sampling Plan (FSP)

English

2025 Final Butte Reduction Works (BRW) Smelter Area Mine Waste Remediation and Contaminated Groundwater Hydraulic Control Site Phase III Quality Assurance Project Plan (QAPP)

Montana Tech of the University of Montana

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