Libby Community Advisory Group
March 10, 2005
Gerald Mueller and members of the Libby Community Advisory Group (CAG) introduced themselves. A list of the members in attendance is attached below as Appendix 1.
The CAG agreed to the following agenda for this meeting:
- US Attorney's Office Presentation
- CARD Clinic
- ARD Net
- Mesothelioma Applied Research Foundation Petition
- Presentation by Gary Swenson
US Attorney's Office Presentation
Sheryl Nordahl, who has been the victim/witness coordinator with the US Attorney's Office for 17 years, reported on the indictment of W.R. Grace employees, the court hearing date, and the implications for Libby people of the "Justice for All Act". The Federal Grand Jury handed down an indictment of WR Grace officials on February 7, 2005. The text of the indictment, which is only a charging document, is available at www.mtd.uscourts.gov. The presiding judge, US District Judge Donald W. Molloy, recently set the trial date for May 15, 2006 in Missoula. The US Attorney is seeking to provide a closed circuit broadcast of the trial to Libby, so that Libby residents can view it without traveling to Missoula. The federal statute entitled the "Justice for All Act" sets forth the rights of victims of criminal acts. The victims have the right to attend all of the court proceedings, to talk with prosecutors, and to be kept informed about trial developments. Ms. Nordahl passed out request for notification forms to CAG members and the audience. She invited anyone wishing to do so to complete the form and return it so that they can be added to the victim data base for this trial. She stated that one does not have to be diagnosed with asbestos-related disease to be a victim. Anyone who feels that they were a victim of the indicted crimes will be added to the victim data base. The goal of the US Attorney in this case is to obtain a conviction and both sentence those convicted and require them to make restitution to the victims in the data base. In the event of a conviction, victims will be asked to complete a victim impact statement which will specify how the crime affected them. These impact statements will provide the basis for restitution. People with questions can contact Ms. Nordahl at 406-542-8851 X3328. Ms. Nordahl also introduced two EPA investigators working on this case, Daniel Horgan and Susan Zazzali.
Audience Member Question - If W.R. Grace is bankrupt, how can each defendant afford three lawyers?
Answer - I don't know. It is important that you know, however, that bankruptcy cannot be used as a shield against fines levied as a result of a criminal conviction or of the requirement to payment restitution to victims.
Audience Member Question - How much restitution could be required?
Answer - Fines could amount to $1 million per count of the conviction. The restitution amount would be set by the judge.
Audience Member Question - Does the prosecution team include the best people from your office?
Answer - Yes. The lead prosecutor is Kris McLean. Mr. McLean is the top environmental prosecuting attorney in the country. He has prosecuted more environmental crimes than anyone else. He will be assisted by another Department of Justice Attorney who specializes in environmental crimes, Kevin Cassidy, and by two EPA attorneys, Linda Kato and Eric Nelson.
Audience Member Comment - In addition to those afflicted by disease, businessmen in Libby also suffered losses as a result of the asbestos contamination. In fact, every person in the valley was a victim of these crimes.
Response - The Justice for All Act ensures that all victims will be considered.
Audience Member Question - What charges were filed against Alan Stringer? Did they result from acts committed before or after the mine closure?
Answer - I do not know the specifics of each count of the indictment; however, the conspiracy count covers the period 1976 through now.
Response by Daniel Horgan - A conspiracy happens when two or more people enter into an agreement to commit a crime. People can enter and leave a conspiracy. The criminal investigation did not end with the indictments or with the arraignments. We are continuing to interview people here in Libby.
CAG Member Question - WR Grace attorneys have asked for a change of venue, have they not?
Answer - Yes. Judge Molloy will hear arguments about the motion to change the venue in September. Judge Molloy has stated his desire to keep the case in Montana because of the hardship to the victims if it is moved outside the state.
CAG Member Question - What about a WR Grace attempt to replace Judge Molloy?
Response - Replacing the judge will have a higher burden than moving the trial location.
CAG Member Question - On a scale of 1 to 10, how would you rate the alleged crimes here in Libby?
Answer - In terms of the people affected and the damage to the community, the events here are one of the largest environmental crimes in the country.
CAG Member Comment - How can there be enough money to provide for restitution for the loss of life and life span suffered by the people of Libby? How can you set a value on a human life?
Audience Member Question - Can residents of Troy be victims in this case?
Answer - Yes. We are trying to get the word out so that people in the area including Troy and Eureka can sign up to be included in the victim data base.
Audience Member Question - What about residents in other locations around the country that had exfoliation plants or shipment locations?
Answer - The alleged crimes in this indictment relate to actions at Libby. Other US Attorneys may decide to file for crimes committed in their districts.
CAG Member Question - Can the city, county, or the community as a whole be considered a victim?
Answer - I am not sure. I know that in cases of a bank fraud, the bank as well as individuals have been victims. I will look into this question.
CAG Member Question - Can EPA seek restitution for its cleanup expenditures?
Answer - No. EPA must seek cost recovery through a civil suit.
CAG Member Question - What court would hear any WR Grace appeal?
Answer - The appeal would first be heard by the Ninth Circuit Court of Appeals and then by the US Supreme Court.
Audience Member Question - Given the length of time required, some people will die before they can receive restitution. Can a victim's heirs receive restitution?
Answer - Beneficiary trusts may be eligible for restitution. Because this is a criminal case, penalties arising from a conviction will not be subject to a statute of limitations.
Audience Member Comment - We had better all sign up as victims.
Response - I agree. Enrolling in the victim data base will ensure that your voice is heard by the court.
Wendy Thomi reported on behalf of EPA on the following topics.
Residential Cleanups - Cleanup work resumed on February 21. Five properties have been cleaned so far this year, bringing the cumulative total cleanups to date to 358. Task orders have been issued for 33 properties, and the pre-task order walk through has been conducted at an additional 40 properties. Cleanup costs continue to drop. A budget of $17 million has been approved for this year. EPA's goal is at least 170 residences to be finished by the end of this construction season.
Supplemental Sampling Plan - A sampling plan aimed at filling in some gaps in existing sampling is being drafted and will be available soon in the EPA Information Center. This supplemental plan will address a variety of exposure paths and areas such as carpets that we need more information about. This plan will support the record of decision which is targeted for the end of this year.
Demolition - One of Mark Epperson's buildings will be demolished. Because it is structurally unsound, the asbestos contaminated materials cannot be removed, so the building will be dropped and the rubble transported for appropriate disposal. The perimeter of the demolition will be monitored extensively to ensure that contamination is not escaping from the site. It is downtown and may involve temporary road closures. EPA will provide information to the public as the work unfolds.
New EPA Team Member - EPA will be adding a new remedial project manager who will be full time in Libby. The remainder of the team will be unchanged.
Clarification of Topics from Denver Technical Meeting - EPA wanted to respond to questions raised about the material presented at the Denver technical meeting, such as toxicology and the Superfund process. EPA asked Aubrey Miller, EPA's toxicologist to present information at this month's CAG meeting. EPA is also providing an Information Sheet about its Superfund response authority and the upcoming Record of Decision. A copy of the information will be
available at the EPA Information Center and is attached below as Appendix 2.
CAG Member Question - The TAG requested that two issues be addressed regarding carpets: sampling at a distance immediately above a carpet and during removal of a carpet. Will this sampling be addressed in the supplemental sampling plan?
Answer by Wendy Thomi - Yes.
CAG Member Question - How will the monitoring of the demolition of the Epperson building be different than your normal sampling?
Answer by Dr. Aubrey Miller - The amount of monitoring will be increased to ensure that the demolition does not result in contamination leaving the site. Two or three rings with six to eight monitors each will be established around the site. The monitoring rings will be set about 100 feet apart. If contamination is detected leaving the site, then the surrounding areas will be evaluated and if contaminated will also be cleaned as appropriate.
CAG Member Question - Will the results of the sampling be published?
Answer by Dr. Aubrey Miller - The sampling results will be provided to the community. We have not yet determined what format the results will be in for dissemination to the public.
CAG Member Question - You are also planning a demolition at the Loomis property, correct? Answer by Dr. Aubrey Miller - Yes.
CAG Member Question - Will there be a plan for the two demolitions published for review before they are carried out?
Answer by Dr. Aubrey Miller - Yes. There will be an overall plan with site specific considerations.
CAG Member Question - These demolitions will use an experimental wet method?
Answer by Dr. Aubrey Miller - Yes. The buildings will be dropped in place and water will be used to suppress dust.
CAG Member Question - What will be the source of the water and how will contaminated water be addressed?
Answer by Dr. Aubrey Miller - I don't know at this point; these issues will be addressed in the site specific plan.
CAG Member Question - Does EPA have a standard model to follow for building demolitions?
Answer by Dr. Aubrey Miller - No, we will be employing strategies that have been tried at other locations in the country and we will be learning as we go. The two other so-called "wet demolitions" that were mentioned by the CAG Member (Ft Worth, Texas and the St. Louis Airport) have received much media attention. These were not EPA demolition projects. EPA scientists had commented on the proposed plans at the Ft. Worth site and this demolition was subsequently stopped. Except for structurally unsound buildings, wet demolitions of have stopped at the St. Louis Airport at this time.
Audience Member Question - If the Epperson building is relatively small, why not wrap it in plastic sheeting to prevent dust escaping?
Answer by Dr. Aubrey Miller - Wrapping the building while demolishing it is not technically feasible.
Audience Member Question - Do the residential cleanups include removing asbestos from attics?
Answer by Wendy Thomi - In attics with accessible vermiculite insulation, the vermiculite is being removed if it is possible to do so safely.
Audience Member Question - Could you please discuss how EPA is addressing the relative toxicology of different asbestos types?
Answer by Dr. Aubrey Miller - The EPA Libby team has attempted to use the best available science to address the situation here. Chris Weis, my predecessor as the Region 8 toxicologist, forced EPA's hand to use tools in the risk assessment that would allow for the consideration of newer and more health oriented views of asbestos. Since 1986, EPA had used the IRIS model in risk assessment. This model is similar to the one used by OSHA. The IRIS model was based on historical studies of asbestos exposure and lung cancer and mesothelioma in workers in various industries (e.g., textiles, mining, and friction industries). The IRIS model did not isolate the effects of different asbestos types or fiber sizes. EPA Region 9 in California developed a newer model, the Berman-Crump model. Although it was based on the same studies as before, it did examine toxicity as a function of both asbestos fiber type and size. When applied to the Libby site, the Berman-Crump model predicts that amphibole asbestos is no more than an order of magnitude more toxic than predicted by the IRIS model. We continue to use the IRIS model and the Berman-Crump model to help us consider the appropriate cleanup actions in Libby. EPA regulatory actions at the national level continue to be primarily based on the IRIS model, though a number of Superfund sites have recently been using both models similar to Libby. We do not assume that any level of asbestos exposure is safe. The levels at which EPA generally takes action is 1 excess cancer death in a population of 10,000.
Audience Member Comment - You should use the Berman-Crump model and keep politics out.
Response by Dr. Aubrey Miller - EPA is continuing to move forward, but changes to the IRIS model may not occur for some time. Region 8 science is helping to drive national activities in new ways to analyze air and soils. The Libby TAG should continue to be our collaborative partner in this effort to understand and challenge our application of the science.
CAG Member Question - Did I understand you to say in the development of the IRIS model, the studies did not differentiate amphibole and chrysotile asbestos so that this model likely overstates the toxicity of chrysotile and understates the toxicity of amphibole?
Answer by Dr. Aubrey Miller - Yes. The risk of mesothelioma appears to be much greater for amphiboles than chrysotile, The IRIS model combines these together to produce a composite risk factor. To use the Berman-Crump model, we need to use analytical techniques that differentiate between fiber types. Certain optical techniques such as Phase-Contrast Microscopy (PCM) does not do so. Transmission electron microscopy (TEM) does.
CAG Member Question - Assume your workers are working in a 2,000 square foot house with two ceiling fans, forced air heating, and 7,500,000 asbestos fibers. Would you require the workers to "suit up", i.e. wear special protective clothing? These are the conditions in my house after it was cleaned.
Response by Dr. Aubrey Miller - Exposure risk is determined by how many asbestos structures become airborne. The interim cleanup trigger for dust is 5,000 structures. Our policy since coming to Libby has been to clean up the most contaminated sites first.
Audience Member Comment - I have been working on cleanups in Libby for four years. We get better each year. It is rare for monitoring to detect asbestos in perimeter sampling or in personal samplers. I have confidence in the engineering controls used to prevent the cleanups from causing off-site or worker exposures.
CAG Member Question - Wendy said that the authorized cleanup budget amount for this year is $17 million. Was this the amount Jim Christiansen requested?
Answer by Wendy Thomi - Headquarters committed to $17 M last year. I believe that Jim requested $19 million.
CAG Member Question - Will the supplementary sampling be funded out of this budget?
Answer by Wendy Thomi - Yes.
CAG Member Question - Jim Christiansen has told us in the past that he wants to conduct animal studies to determine asbestos dose-response relationships. Is money available to for these studies?
Response by Dr. Aubrey Miller - No, money is not currently available. Jim is still searching for funding for these studies.
Audience Member Question - You have said that this year's cleanup budget total is $17 million, and that the target for residential cleanups is 170 homes. Can you provide us a breakdown of how the $17 million will be spent?
Answer by Wendy Thomi - Jim Christiansen has been working on a budget breakdown. We will soon be able to share more information about it.
CAG Member Question - Has a date been established for the "Denver-Lite" conference discussed at the last CAG meeting?
Answer by Wendy Thomi - A specific date has not been set, but it is likely to be in the summer, perhaps in June.
Catherine LeCours reported on behalf of the Montana DEQ. She recently conducted interviews with of community leaders, representatives of local businesses and professional associations and general citizens of Troy to identify their needs and expectations regarding the pending cleanup. These interviews will be used to develop a community involvement plan. The state is hoping that funding from EPA will be available to begin the Troy cleanup next year. Pending the availability of funding, cleanup at the high school will occur this summer. The study area boundary has been set, and copies of its map are available. The area includes the valley from the intersection of Highway 56 with Highway 2 to the Yaak Flats area 5.5 miles north of Troy. Please contact Ms. LeCours if you have information about structures that were moved from the mine to the Bull Lake/Savage Lake area.
CAG Member Question - Will you be developing a work plan for the Troy cleanup?
Answer - Yes. A draft of the containment screening work plan should be prepared by this fall.
CAG Member Question - Will the TAG be permitted to review and comment on the plan?
Answer - Yes.
CAG Member Question - Could we add a member from Troy to the TAG?
Answer - Yes. I have discussed this opportunity with the Troy City Council.
CAG Member Question - Will the cleanup have an oversight contractor?
Answer - Yes.
CAG Member Question - Will you develop criteria and issue a request for bids to choose the oversight contractor?
Answer - The state has different contracting procedures than the federal government. I can pick a contractor from an existing state list without issuing bids.
CAG Member Question - Will the state be paying for the Troy cleanup?
Answer - EPA funds will pay for the cleanup.
CAG Member Question - Would the money for Troy come out of the funds for cleaning the 170 Libby properties?
Answer by Wendy Thomi - No, funding for Troy will not reduce this year's budget for Libby residential cleanups. This budget does not include funds for Troy. I don't know about next year's budget.
CAG Member Question - Who will carry out the contaminant screening study in Troy?
Answer - The study will be conducted by a contractor that has not yet been selected.
Gayla Benefield reported on behalf of the TAG. Some of the TAG's questions were answered at the Denver meeting, and some were not. The TAG is compiling a document setting out the issues not fully addressed in Denver and will be providing it to Jim Christiansen. In addition to its regular meeting on Tuesday the week of the CAG meeting, the TAG will meet on Tuesday, March 22 at 5:30 p.m. at the College to complete its work on this document.
CARD Clinic Report
Mr. Giesey reported on behalf of the CARD Clinic. The Clinic is presently remodeling the building formerly occupied by Dr. Patrick and intends to move into this building in mid-April. We are using funds provided by the City to develop the infrastructure for the data base. You may have read press reports that Senator Baucus is seeking $250 million from WR Grace to support screening, health care, and research in Libby. The CARD Board is expanding its membership by two individuals.
Audience Member Question - How are you recruiting these new board members?
Answer - We have already tendered invitations to new potential board members.
Gayla Benefield reported that the Asbestos Related Disease Network (ARD Net) held the asbestos health fair last weekend. Some 144 people registered at the fair. It was busy from 10:00 a.m. to 4:00 p.m. The attendees included more young people than last year. The fair organizers judged it to be a success.
LeRoy Thom provided an answer to the question posed to him at the last CAG meeting about how much LAMP funding has been provided to the CARD Clinic. To date, the recipients of LAMP funds have been:
CARD Clinic $44,934
St. John's Lutheran Hospital $110,000
Northwest Imaging $5,500
Local pharmacies $5,850
Local care givers $36,000
Mesothelioma Applied Research Foundation Petition
Because Dr. Black had to leave tonight's meeting prior to this agenda item, Gerald Mueller summarized and passed to the CAG members and the audience a petition sponsored by the Mesothelioma Applied Research Foundation (MARF), a non-profit group. Dr. Brad Black referred MARF's Assistant Director, Jill Wayne, to Mr. Mueller. Ms. Wayne requested that the CAG and any others be given the opportunity to sign the petition, the purpose of which is to support federal funding of research to improve treatments for, and ultimately cure, mesothelioma. Tanis Hernandez reported that MARF has awarded a grant to the CARD Clinic to participate with other researchers in search of a blood marker that would provide early detection of mesothelioma. The CARD will be soliciting blood samples from people in the Libby community to further this research.
Audience Member Question - Will this research be subject to an institutional review board (IRB)?
Answer by Tanis Hernandez - Yes, this research will subject to IRB review to ensure that it protects participants and meets ethical and legal standards.
Presentation by Gary Swenson
A meeting to plan for a permanent memorial for asbestos victims will be held next Tuesday at 5:30 p.m.
There was no further public comment.
The next CAG meeting was scheduled for 7:00 to 9:00 p.m. on Thursday, April 14, 2005 in the Ponderosa Room of Libby City Hall. The agenda will include viewing a short documentary produced by Libby students entitled, "A Breath of Life".
CAG Member & Guest Attendance List
March 10, 2005
Members Group/Organization Represented
K.W. Maki Libby Schools
Mike Giesey CARD Clinic
Clinton Maynard Area Asbestos Research Group
Gordon Sullivan TAG
Aubrey Miller EPA
LeRoy Thom Former Grace Employee
Ken Hays Senior Citizens
David Latham The Montanian Newspaper
Wendy Thomi EPA Community Involvement Coordinator
Sheryl Nordahl US Attorney's Office
John Wardell EPA
Catherine LeCours DEQ
Gary D. Swenson Libby Volunteer Fire Department
Gayla Benefield LCAVRO
Eileen Carney TAG and ARD Net
Norita Skramstad Asbestos Victim
Brad Black CARD/Lincoln County Health Officer
Jeanie Gentry St. John's Lutheran Hospital
3/10/05 Information Sheet Regarding EPA's Response Authority and the Upcoming Record of Decision
This information sheet is intended to address basic questions regarding EPA's cleanup authority under CERCLA ("Superfund") and how EPA is using that authority to conduct investigation and cleanup in Libby. Many Libby residents have expressed concern regarding EPA's limitations on response and question why we can't clean up everything immediately. Few fully understand the important limitations and structure of CERCLA which EPA must work within. These factors are particularly important now as we approach the first Record of Decision (ROD) for Libby in late 2005. The ROD will have important implications to cleanup in Libby, both immediate and long-term, and it is vitally important that Libby residents understand the cleanup process and the structure of the CERCLA law. EPA will be undertaking a broad community outreach campaign in 2005 to ensure the community understands how to participate in the decision-making process and to help educate the community on the technical issues involved in cleanup.
CERCLA provides two basic authorities for investigation and cleanup: Removal Actions and Remedial Actions. Removal Actions are intended to address time-sensitive risks and situations. Removal Actions can be initiated quickly. While a Removal Action may completely eliminate a health risk or environmental problem, it also may be used to mitigate only certain aspects of the problem, while other parts are looked at in more detail to determine the appropriate type and level of cleanup. Removal Actions are generally limited to 12 months in duration and $2 million in expenditures, but are extended in certain situations. One such situation is an "emergency." If EPA determines that an environmental situation constitutes an "emergency" and is an immediate risk to public health, we can extend the duration and cost of a Removal Action beyond the limitations. The magnitude and prevalence of asbestos contamination, multiple exposure pathways present in town, and past exposures to residents were all important factors in EPA's determination that such an emergency situation exists in Libby. To date, all cleanups in Libby have been conducted as Removal Actions, but there are important limitations to the cleanup that can be done as a Removal Action. Remedial Actions, on the other hand, can be used to address health risks which are not necessarily sufficient to warrant a Removal Action. Remedial Actions are not limited in duration or expenditures. It takes a longer time to initiate Remedial Actions, often years or even decades, and there are numerous procedural, planning, and community involvement requirements that must be met prior to initiating cleanup.
At large, complex sites such as Libby, EPA often uses both Removal Actions and Remedial Actions to ensure the cleanup is conducted in the most protective and efficient manner. Immediate risks, or contamination that may migrate or be released if not dealt with immediately, are addressed quickly using Removal Actions. Less immediate risks are studied more extensively before cleanup is conducted using Remedial Actions. We are taking this basic approach in Libby.
Libby is particularly complex. There were, and still are, many situations and conditions that EPA has determined constitute immediate health risks and warrant emergency response. The scope of these situations is very large - ranging from the former vermiculite processing plants and contaminated public areas to some residential and commercial properties in Libby. Conversely, many situations in Libby present lesser health risks that are more chronic in nature. Often, both situations are present at a particular property, which makes response challenging. And, unlike some sites, the solutions to the problems at Libby are often complex, expensive, and require innovative approaches. The science of asbestos is quickly evolving. The challenge is trying to address the immediate health risks quickly, while still ensuring the cleanup is done efficiently and in a scientifically and technically sound manner.
We know Libby residents want the cleanup to be protective, efficient, and as timely as possible. EPA shares those goals. To try to meet them on this complex site, EPA has tried to be creative and proactive in our use of CERCLA authority. Here are some creative and proactive steps we've taken:
- We've prioritized cleanups. Large, public areas with high concentrations of asbestos were addressed first. In this way, we addressed the highest risks first. We continue to employ this basic strategy. For instance, some properties that do not meet the criteria for a Removal Action may meet future criteria established for Remedial Action.
Rather than staging them sequentially, we are concurrently conducting Removal Action cleanups and the additional investigation, research, and planning that is a necessary precursor to Remedial Actions. In fact, much of the important data and information we need for long-term planning has been collected during actual cleanups. The results of our efforts will be set forth in the upcoming Record of Decision. This approach accelerates the overall completion of cleanup, allows us to learn from our investigations and cleanups quickly and concurrently, and maximizes the use of resources to accomplish both tasks simultaneously. We've tried to be creative in how we balance available resources to accomplish both tasks with a limited budget.
At many properties in Libby, there are both immediate health risks and health risks of a lesser or more chronic nature. In most situations, once we start a cleanup to address an immediate health risk, EPA has elected to address all conditions that are present so that properties only have to be cleaned up once. To accomplish this, we've used the best science available to set cleanup standards and methodologies. This approach is protective, cost-effective, and makes good common sense - it would be extremely expensive to clean up sites twice and residents want assurance that their home is safe for the long-term. However, in certain situations, we must limit Removal Actions at particular properties. For instance, certain areas around the screening plant and export plant were not cleaned up immediately because conditions were such that they did not meet criteria for a Removal Action. These and other situations that may warrant cleanup, but do not warrant Removal Action, may be addressed by future Remedial Actions.
We've designed a Removal Action cleanup plan that we believe is reasonable and will be consistent with any future Remedial Actions: immediate risks or easily accessible contaminated source materials are dealt with aggressively (e.g. by removing them), whereas lesser risks or less accessible contaminated materials are dealt with through less aggressive measures such as containment. This limits the scope of the Removal Action by ensuring the right level of response for the situation but also leaves future options open.
We continually monitor and evaluate our cleanup approach and use that experience and information to make the cleanups more protective and efficient. Learning from our actual experience while doing the time-critical cleanups is the best way to ensure the cleanups are protective and efficient in the long-term.
Instead of waiting until cleanup is nearly complete, we are proactively planning for Libby's future through establishment of an Operations and Management (O&M) Workgroup. The O&M Workgroup is beginning to discuss long-term management issues, such as future asbestos landfill availability, institutional controls such as local ordinances, and community education. The work and discussions of the group will be used in the Record of Decision planning process to help us shape a long-term cleanup program that is protective and efficient.
Overall, EPA has sought to balance available resources and the limitations of CERCLA to both efficiently address immediate health risks and plan for the long-term. We've used Removal Actions to quickly address the multitude of immediate health risks in Libby, while simultaneously conducting the investigation, research, and planning necessary for a protective and efficient cleanup. We've learned and adjusted our cleanup approach quickly. Soon, we will pull this all together and present our "Proposed Plan" for Remedial Action in Libby. The public will have extensive opportunity to comment on the Plan, and we will consider those comments before we publish the Record of Decision.