£EPA
United States
Environmental Protection
Agency
Share your opinions
EPA invites your comments on this
proposed cleanup plan. A public
comment period runs from June 22 to
July 21,2011 and statements can be
submitted in these ways:
• Fill out and return the enclosed
comment sheet.
• Orally or in writing at the
public hearing.
• By the Internet at
www.epa.gov/region5/cleanup/
publiccomment/stregis-
pubcomment.htm.
• Fax to Tim Drexler at
312-353-1263.
Public meeting/hearing
Thursday, June 23, 2011, 6:30 p.m.
Cass Lake-Bena Elementary School
154thSt.,N.W.
Cass Lake
After a brief presentation, EPA will
hold a public hearing to accept
comments on the proposed plan. A
court reporter will record all public
comments.
Contact information
Don de Blasio
Community Involvement Coordinator
312-886-4360
deblasio .don@epa.gov
Tim Drexler
Remedial Project Manager
312-353-4367
drexler.timothy@epa.gov
EPA Region 5 toll-free
800-621-8431
8:30 a.m. - 4:30 p.m., weekdays
Soil Cleanup Plan Includes
Removal of Contaminated Soil
St. Regis Paper Co. Superfund Site
Leech Lake Reservation
Cass County, Minnesota
June 2011
To clean up soil contamination at the St. Regis Paper Co. site, the U.S.
Environmental Protection Agency is proposing the following steps as part of a
cleanup plan1:
• Remove up to two feet of contaminated soil from affected residential
areas and replace it with clean soil or apply a clean soil cover.
• Cover contaminated soil on industrial/commercial properties owned
by the responsible parties with one foot of clean soil and maintain the
cover.
• Pave commercial/industrial work areas where heavy equipment is in
use and pave residential and commercial unpaved roads.
• Remove contaminated soil from a former work area because of
ecological risks.
• Dispose of all contaminated soil at an off-site facility.
• Monitor surface water in the nearby forested wetland.
• Place institutional controls on property where some hazardous
materials remain.
EPA arrived at this recommendation after extensive study of the site, and after
considering a number of cleanup alternatives in a document called a
Feasibility Study. The steps listed represent Alternative 4A (see Page 4),
which is EPA's recommended option. It protects people and the environment,
meets the applicable regulations, is cost-effective and will be effective in the
long term.
Before making a final decision, EPA is holding a public meeting and
comment period (see box, left). After considering public comments and
consulting with the Leech Lake Band of Ojibwe and the Minnesota Pollution
Control Agency, EPA may alter its proposed plan or even choose a new one.
Your opinion is important. The final cleanup plan will be presented in an EPA
document called the "record of decision" and announced in local newspaper
notices.
You are also encouraged to review supporting documents - as well as a
detailed version of the proposed plan - at any of the information repositories
listed on the back page. EPA is also announcing that the Final Feasibility
Study Report is available for your review.
'Section 117 (a) of the Comprehensive Environmental Response, Compensation, and
Liability Act (CERLCA, known as the Superfund law) requires the publication of a
notice announcing the proposed plan. It also requires a public hearing and public
comment period. This fact sheet summarizes the technically written proposed plan
and other site-related environmental reports that can be viewed at the information
repositories listed in the box on the backpage and the EPA Region 5 office in
Chicago.
-------
St. Regis Paper Company Site
out
History and background
The St. Regis site is in Cass Lake within the boundaries
of the Leech Lake Band's reservation. The former
operations area of the site is on about 125 acres south of
the BNSF Railway Co. tracks, and east of Highway 371.
It was used as a wood treatment facility from about 1958
until 1985. The site includes any areas where
contamination from the wood treatment facility has
migrated. The St. Regis site was listed on the National
Priorities List in 1984, making it eligible for cleanup
under EPA's Superfund program.
The site has four primary sections divided into operable
units (see figure above):
• OUI is between South 3rd Street and the BNSF
Railway tracks, and consists of a north former
operations area currently owned by the responsible
parties: International Paper Co., City of Cass Lake,
BNSF Railway and Cass Forest Products.
• OU2 is the former operations area southwest of
OUI and the location of an on-site contaminated
soil vault.
• OU3 is the portion of the former Cass Lake dump
that accepted site waste.
• OU7 is the residential area adjacent to the site.
MPCA was the lead cleanup agency at the site until
1994. During the late 1980s, MPCA required then-owner
Champion International Corporation to conduct the
following cleanup actions:
• Connect nearby residents to city water.
• Remove visibly contaminated soil and sludge.
• Create a vault for the contaminated soil and sludge
removed from the site.
• Create a ground water extraction system with
monitoring wells to contain and treat contaminated
underground water plumes in the former
operations and former city dump areas.
In 1994, EPA became the lead agency for the cleanup at
the request of the Leech Lake Band. Soil sampling was
conducted under EPA oversight in 2001 and 2003 and
found dioxin concentrations in shallow soil that were
higher than EPA's 1998 dioxin policy of 1,000 parts per
trillion in residential areas. Based on those samples, a
total of about 3,995 tons of contaminated soil was
removed from the site on city-owned and BNSF Railway
property in 2004, 2005 and 2006. Other areas were
covered or fenced to reduce contact with the
contaminants.
Also in 2004, EPA ordered International Paper Company
(IP), a successor to Champion International, to conduct a
human health and ecological risk assessment. IP sampled
for contaminated dust in residences as a part of the risk
assessment. The results showed an increased risk to
residents near the site. In response, IP cleaned up
contaminated dust in nearby residences in 2006 and
placed a 3-inch cover on the yards at these homes. IP will
continue to periodically clean dust from residences until
-------
a final soil remedy is implemented.
In August 2008, the human health risk assessment
concluded that there were still unacceptable risks to
residents, workers, and the environment at the site. Based
on these results, IP and BNSF Railway agreed in
September 2008 to perform a feasibility study to evaluate
cleanup options for addressing the remaining site risks.
EPA approved the feasibility study in June 2011. It is
now available to the public.
Summary of site risks
The main way people in and around the St. Regis site are
exposed to potentially harmful pollutants is by direct
contact with contaminated soil. Utility workers could
also be exposed to contaminated ground water when
digging in either a portion of the former operations area
or in the pit area near the former city dump.
The contaminants of concern include dioxin;
pentachlorophenol, or PCP; and polycyclic aromatic
hydrocarbons, or PAHs. PCP was used as a part of the
wood treatment process at the site. PCP is a
manufactured chemical used for wood preservation and
as an insecticide. PCP can cause liver effects, damage to
the immune system, reproductive effects and
developmental effects.
Dioxin was an impurity in the PCP that was used at the
site. Dioxin causes effects on the skin, has been shown to
be very toxic in animal studies and probably causes
cancer.
PAHs are a group of chemicals formed during the
incomplete burning of coal, oil, gasoline, wood, garbage,
or any plant or animal material and are also found in
cigarette smoke, soot and creosote. Breathing or long
periods of skin contact to mixtures that contain PAHs can
cause cancer. Animal studies have shown some PAHs
caused birth defects and decreased body weight. EPA's
evaluations further identified high molecular weight
PAHs, or HPAHs and benzo(a)pyrene equivalent B(a)PE,
which are groups of PAHs. HPAHs are a useful
combination of PAHs for determining ecological risk.
B(a)PE is a useful group of PAHs to determine human
health risk.
Based on the results of the risk assessment, EPA
considers 63 parts per trillion for dioxin and the
background level of 1.6 parts per million for B(a)PE in
soil to be protective of human health in OU7. For OU1,
OU2 and OU3, the cleanup levels considered to be
protective of workers are 380 ppt for dioxin and 4.1 ppm
for B(a)PE. These values represent the middle of EPA's
acceptable range of protectiveness against excess cancer
risk. The higher level of protection is based on a
consideration of Leech Lake Band tribal life ways and
uncertainties identified in the risk assessment, including
dioxin cancer risks.
In 2000, the Leech Lake Band enacted the Hazardous
Substances Control Act (HSCA) which establishes
contamination cleanup levels within the reservation. The
HSCA establishes a 10 ppt cleanup level for dioxin in
soil, which represents the high end (most protective) of
EPA's acceptable risk range. The estimated background
concentration of dioxin in the area is about 7 ppt. EPA
proposes that those residential and industrial/commercial
areas with surface contamination above the HSCA
cleanup value be covered with one-foot of clean soil to
protect workers and residents from the residual
contamination levels.
For protection of the ecological risk area, EPA proposes
a cleanup level of 31 ppm for PCP and 18 ppm for PAHs
in soil. The HSCA requires a cleanup level of 2 parts per
billion for PCP in soil. For that reason, EPA proposes a
one-foot soil cover over those portions of the ecological
risk area that remain above the HSCA cleanup level.
Cleanup alternatives Considered
EPA considered eight alternatives for cleaning up the St.
Regis site, each of which was evaluated against seven of
the nine criteria required by the Superfund law (see box,
Page 5).
Alternative 1 - No action: EPA always includes a no-
action alternative as a comparison point for other options.
Under this option, EPA would do nothing to clean up the
contaminated property, which means there would be no
effect on potential health risks. Cost: $0
Alternative 2A - Under this alternative:
• Contaminated soil on OU7 above 63 ppt dioxin and
the site background concentration of 1.6 ppm for
B(a)PE will be removed to a maximum depth of 2
feet. EPA anticipates that they will only have to dig
down about 1 foot to get to the clean soil. If soil
remains contaminated above cleanup levels at the
two-foot depth, marker material would be placed in
the dug up area before clean soil is placed on the
yard to return the yard to its original surface. If in
the future the yard had to be dug up again past two-
feet deep, the marker material would indicate that
contaminated soil still existed and additional
precautions or steps would need to be taken.
• Institutional controls such as deed notices or a
registry of contamination at depth will be sought
for residential properties that have remaining
-------
contamination below the two-foot depth.
• At OU1, OU2 and OU3 a one-foot layer of clean fill
and top soil followed by vegetation would be placed
in all areas with surface contamination above 380
ppt for dioxin and 4.1 ppm for B(a)PE.
• Institutional controls, which consist of non-
engineered requirements relating to property use,
would then be implemented for these areas to
monitor and protect the cover and prevent exposures
to contaminated soil and ground water.
• Additionally, the heavy machinery areas owned by
Cass Forest Products and all unpaved commercial
and residential streets in the site area would be
paved.
• Contaminated soil would also be removed from the
ecological risk area in OU2 to a PCP concentration
of 31 ppm and a HP AH concentration of 18 ppm.
• Institutional controls and warning signs would be
placed in OU1 and OU3 by the responsible parties
to prevent potential worker exposure to
contaminated groundwater if they were digging in
the area.
• Finally, the forested wetland area east of the former
operations area would be monitored for any surface
water contamination above acceptable levels. Cost:
$22.5 million
Alternative 2B is identical to Alternative 2A, except that
excavated soil under this alternative will be placed in an
on-site cell and covered. Cost: $20.3 million
Alternatives 3A - This alternative includes all of the
elements of Alternative 2A except that the one-foot clean
soil cover in OU1, OU2 and OU3 would be extended to
include all areas with surface contamination of dioxin
above 63 ppt and B(a)PE concentrations above 1.6 ppm.
Cost: $29.8 million
Alternative 3B is identical to Alternative 3A, except that
excavated soil under this alternative will be placed in an
on-site cell and covered. Cost: $27.7 million
Alternative 4A (EPA's Recommended Alternative) -
This alternative includes all of the elements of
Alternative 2A except that the one-foot clean soil cover
and marker material on OU1, OU2 and OU3 would be
extended to include any areas within these operable units
and OU7 with surface dioxin soil contamination above
10 ppt. In addition, a one-foot soil cover would be placed
over surface contamination above the HSCA clean up
value of 2 ppb for PCP in the ecological risk area of OU2
that is not already addressed by excavation. Cost:
$45.8 million
Alternative 4B is identical to Alternative 4A, except that
excavated soil under this alternative will be placed in an
on-site cell and covered. Cost: $44 million
Alternative 5A - This alternative includes all of the
elements of Alternative 3A, but instead of cover on OU1,
OU2 and OU3, all site areas with soil contamination
above 63 ppt for dioxin and background concentrations
for B(a)PE would be removed, regardless of depth. The
removed soil would be transported to an off-site landfill
and replaced with clean fill and topsoil. Cost: $103
million
Alternative SB is identical to Alternative 5A, except that
excavated soil under this alternative will be placed in an
on-site cell and covered. Cost: $45 million
Alternative 6A - This alternative is similar to
Alternative 5 A except that the removal of contaminated
soil in all site areas would be performed on soil that is
above 10 ppt for dioxin and excavation in the area of
ecological risk would be to the HSCA value of 2 ppb for
PCP. Cost: $201 million
Alternative 6B is identical to Alternative 6A, except that
excavated soil under this alternative will be placed in an
on-site cell and covered. Cost: $82 million
Alternative 7A - This alternative is similar to
Alternative 2A except it would remove soil in OU7 that
is above 190 ppt for dioxin in surface soil and 8.1 ppm
for B(a)PE in surface soil. A cover would be applied in
the OU1, OU2 and OU3 to surface soil that is above
2,000 ppt for dioxin and 41 ppm for B(a)PE. This level
of protection is within EPA's risk ranges, but is less
protective than those achieved in Alternatives 2-6. Cost:
$12.4 million
Alternative 7B is identical to Alternative 7A, except that
excavated soil under this alternative will be placed in an
on-site cell and covered. Cost: $10.5 million
Alternative 8A - This alternative is like Alternative 7A
except that a cover in OU1, OU2 and OU3 would be
applied to all areas with surface contamination above 190
ppt for dioxin. Cost: $22 million
Alternative 8B is identical to Alternative 8A, except that
excavated soil under this alternative will be placed in an
on-Site cell and covered. Cost: $19.9 million
-------
Evaluation criteria
EPA uses nine criteria to compare cleanup options:
1. Overall protection of human health and the environment addresses whether an alternative adequately
protects both human health and the environment. The cleanup plan can meet this criterion by reducing or
eliminating contaminants or by reducing exposures to them.
2. Compliance with applicable or relevant and appropriate requirements assures that each project complies
with federal, tribal, state and local laws and regulations.
3. Long-term effectiveness and permanence evaluates how well an option will work in the long term, including
how safely remaining contaminants can be managed.
4. Reduction of toxicity, mobility or volume through treatment addresses how well the option reduces the
toxicity (the chemical makeup of a contaminant that makes it dangerous), movement and amount of
contaminants.
5. Short-term effectiveness is how quickly the project achieves protection, as well as its potential to be harmful
to human health and the environment while it's being constructed
6. Implementability evaluates the technical feasibility of the cleanup plan, and whether materials and services
are available to carry out the project.
7. Cost includes estimated capital or startup costs, such as the cost of buildings, treatment systems and
monitoring wells. The criterion also considers costs to implement the plan, and operate and maintain it over
time. Examples include laboratory analysis and personnel to operate equipment.
8. State and tribal acceptance is whether the state environmental agency, in this case the Minnesota Pollution
Control Agency, and the tribal government, the Leech Lake Band of Ojibwe, agree or disagree with EPA's
recommended alternative.
9. Community acceptance evaluates how well the community near the site accepts the option. EPA evaluates
community acceptance after it receives and evaluates public comments on its recommended alternative.
EPA's recommended alternative
EPA recommends Alternative 4A because the Agency
believes this option is the best balance of the evaluation
criteria.
Alternative 4A protects people and the environment, and
it meets applicable rules and regulations by removing
contaminated soil and putting in clean dirt in portions of
OU7 and covering those portions of OU7 with residual
soil contamination above the HSCA level of 10 ppt. In
addition, marker material and a cover would be placed in
areas of OU1, OU2 and OU3 that exceed the HSCA-
based cleanup levels. Soil above ecological health-based
limits in OU2 would be removed. Residual soil
contamination above HSCA cleanup levels in OU2 that is
not removed would be covered. Institutional controls will
monitor and maintain the soil cover and will ensure that
any future planned disturbance of these covered areas at
depth requires adequate sampling and proper disposal of
contaminated soil and that the cover is then restored.
Institutional and engineering controls will also prevent
future ground water exposures to workers or others
digging in the ground water plume areas of OU1 and
OU3.
Alternative 4A provides long-term and permanent
protection against exposure to site-related contaminants
by the combination of soil excavation and cover, coupled
with appropriate institutional controls. Off-site disposal
of excavated soil allows for less long-term maintenance
and better addresses preliminary concerns expressed by
the Leech Lake Band and the city of Cass Lake that
excavated contaminated soil not be stored on-site.
Alternative 4A does not reduce toxicity, mobility or
volume of the contamination because effective
alternative treatment technologies or resource recovery
technologies are not practical for large quantities of soil
containing low levels of contamination.
Alternative 4A also provides short-term effectiveness
when proper health and safety measures are taken.
Alternative 4A is implementable. Finally, Alternative 4A
meets the evaluation criteria at a much lower cost than
Alternative 6 (the only other alternative that meets the
HSCA cleanup level), and is therefore cost-effective.
Continuing ground water study
This proposed plan addresses only the risks from
contaminants in soils. Ground water contamination
continues to be addressed by the ground water pump-
and-treatment system previously installed and currently
operated by IP.
Next steps
Before it makes its decision final, EPA, in consultation
with both the Leech Lake Band and MPCA, will review
comments received during the public comment period
and at the public meeting. Based on new information
presented in the comments, EPA may modify its
recommended alternative or choose another.
-------
EPA encourages you to review and comment on the
proposed cleanup plan. Much more detail on the cleanup
options is available in the Proposed Plan and other
official documents on file at the information repositories
(see back page) or EPA's website at
www.epa.gov/region5/cleanup/stregis.
EPA will respond to the comments in a document called
a "Responsiveness Summary." This will be part of
another document called the "Record of Decision" that
describes the final cleanup plan. The Agency will
announce the selected cleanup plan in a local newspaper
and will place a copy in the information repositories and
post it on EPA's website.
Chart comparing cleanup options with the nine Superfund remedy selection criteria
Altl
Alt 2A/B
Alt 3A/B
Alt 4A/B
Alt 5A/B
Alt 6A/B
Alt 7A/B
Alt 8A/B
Evaluation Criterion
Overall Protection of
Human Health and the
Environment
Compliance with
ARARs
Long-term
Effectiveness and
Permanence
Reduction of Toxicity,
Mobility, or Volume
through Treatment
Short-term
Effectiveness
Implementability
Alternative A Cost
($ millions)
Alternative B Cost
($ millions)
Tribal and State
Acceptance
Community
Acceptance
O
O
O
O
N/A
N/A
$0
$0
•
O
•
O
•
•
$25.5
$20.3
•
O
•
O
•
•
$29.8
$27.7
•
•
•
O
•
•
$45.8
$44
•
O
•
O
•
•
$103
$45
•
•
•
O
•
•
$201
$82
•
O
•
O
•
•
$12.4
$10.5
•
O
•
O
•
•
$22
$19.9
LLBO currently prefers Alternative 6 A. State of Minnesota has not endorsed any Alternative at this
time.
Will be evaluated after the public comment period
Fully meets criterion
O Does not meet criterion
-------
Information repositories
To find more detailed information about the site and to view technical documents, visit one of the information
repositories below.
Leech Lake Band of Ojibwe
Division of Resource Management
6530 Highway 2 N.W.
Cass Lake
Cass Lake City Clerk
332 Second St. N.W.
Cass Lake
Cass Lake Library
223 Cedar Ave.
Cass Lake
Bemidji State University Library
1501 Birchmont Drive, N.E.
Bemidji
Leech Lake Tribal College
6945 Little Wolf Road
Cass Lake
Attend a public meeting to find out more about the selected cleanup plan.
Thursday, June 23, 6:30 p.m.
Cass Lake-Bena Elementary School
15 4th St., N.W.
Cass Lake
»^ w
uB|d dnueaio nos sasodojd Vd3 :31IS -00 N3dVd SI93U IS
069£-«)909'll'°6eo!MO
•pA|g uos>per 'M LL
punjjsdng
|B)U9UJUOJIAU3
S91EJS
------- |