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Summary
Between 1994 and 2013, firefighting training at Lake Superior College’s Emergency Response Training Center (ERTC) included the use of aqueous film-forming foam (AFFF), which contains PFAS. A class of chemicals once widely used for their oil- and water-resistant properties, PFAS (per- and polyfluoroalkyl substances) do not break down naturally in the environment. Scientific understanding of PFAS has evolved, and today, these compounds are associated with environmental and health risks.
In 2023, the Minnesota Pollution Control Agency (MPCA) invited Lake Superior College (LSC), a member of the Minnesota State Colleges and Universities System (MinnState) to participate in the state’s Cooperative Responsible Party program due to ERTC’s prior use of PFAS-containing AFFF. LSC retained Barr Engineering Co. to investigate PFAS at the site and recommend appropriate actions.
An initial site investigation in 2024 found PFAS in soil and water at concentrations above applicable regulatory criteria. LSC has since taken interim measures to collect and treat PFAS-containing water before it is discharged to Duluth’s sanitary sewer system.
Additional investigations in 2026 will advance understanding of PFAS in groundwater, soil, and surface water. The results will help determine next steps for continued investigation and cleanup.
LSC has announced plans to suspend firefighter training programs at the ERTC while the investigation and cleanup efforts are underway. The college remains committed to supporting workforce and student needs and is moving some programmming that has traditionally operated at ERTC, such as Emergency Medical Technician (EMT) training, to alternative locations.
After joining the MPCA state Superfund program as a Cooperative Responsible Party, LSC conducted a 2024 investigation that identified ERTC areas with PFAS concentrations above MPCA industrial reference values for soil samples. The 2024 investigation also found concentrations above EPA maximum contaminant levels (MCLs) and/or Minnesota Department of Health groundwater values for water samples collected from perched water and stormwater on-site at the ERTC.
A: Rain and snow contact PFAS in soil and some PFAS travels with water
B: Water with some PFAS can travel in streams and rivers
C: Water with some PFAS can soak into the ground. Water in the ground can be monitored with wells or pumped for use.
In 2025, MPCA approved LSC’s plans for additional investigation work at the ERTC. This effort began in early 2026 and includes:
- Conducting supplemental, on-site hydrogeologic investigations to support the identification, sampling, and evaluation of the groundwater beneath the ERTC. This work will help clarify groundwater flow directions and related PFAS concentrations.
- Evaluating the extent of PFAS in the soil, both vertically and horizontally, in the three identified source areas.
- Investigating surface-water discharge frequency and flow rates to inform any future studies focused on off-site PFAS migration.
Measures in Place Today
LSC joined the MPCA’s Superfund program in 2023 and has engaged in site investigation and interim actions as a Cooperative Responsible Party since that time. During this timeframe, LSC and MinnState retained Barr Engineering Co., an international expert on PFAS, as its environmental consultant.
Since entering into the 2023 agreement, LSC has performed interim control measures to collect, hold, and treat PFAS-containing water used during firefighting water-based training exercises. The water is treated to remove PFAS before being released into the City of Duluth’s sanitary sewer system, and subsequently to Resource Renew, the public sanitary sewage treatment facility for the area.
Future Activities
After the 2026 investigation activities are completed, a summary report will be developed in early 2027. That report will include an evaluation of collected data and propose additional actions. Recommendations may include additional investigation locations, as well as remediation activities that focus on the most significant PFAS migration pathways, with consideration of potential downstream receptors. Additional investigation considerations will be based on data collected to determine the extent and magnitude of PFAS associated with historical firefighting training activities.
LSC and MinnState have committed to moving forward with PFAS investigation and cleanup activities, with review and approval of work plans and summary reports at each major step by the MPCA. Because long-term environmental site remediation projects do not proceed directly from start to finish, LSC may adjust its approach to investigation and cleanup as new information emerges during the process.
