Background
Since 1994, the 100-plus acre Emergency Response Training Center (ERTC) at Lake Superior College (LSC) has trained over 5,000 students to become first responders. This critical work prepares the region and the state’s fire departments as well as other agencies like Homeland Security to save lives, property, and the environment from disasters.
The ERTC was sold to Lake Superior College after being developed by Independent School District 709 with grants from the Federal Aviation Administration (FAA). Like other training sites across the nation developed with grants from the FAA, Lake Superior College used firefighting foam or Aqueous Film Forming Foam (AFFF).
Since the 1960’s, AFFF foam included per- and polyfluoroalkyl substances (PFAS) sometimes referred to as “forever chemicals.” This foam is very effective in fighting flammable liquid fires, but the emerging data suggest these PFAS chemical compounds may increase the risk of serious health problems, including cancer. Between 1994 and 2014, various AFFF foams were used in dozens of annual ERTC training exercises.
Aviation firefighting training at the ERTC’s six-acre burn site ended in 2011. Currently, the ERTC burns only Class A materials (wood, straw) in old shipping containers (conex boxes) for general firefighting training, in compliance with National Fire Protection Agency guidelines. LSC is committed to following current laws and industry best practices in its firefighting training.
Compliance Actions
In 2024, the US EPA finalized a rule that designates certain PFAS as hazardous substances.
Prior to that designation, in 2023, the Minnesota Pollution Control Agency (MPCA) invited LSC to become a part of the Cooperative Responsible Party program, which is part of state superfund program.
LSC retained Barr Engineering Co. (Barr), a Minnesota-based engineering and environmental consulting firm with expertise in PFAS, to assess site conditions and ultimately recommend corrective measures. This MPCA webpage includes the ERTC site’s PFAS testing data, maps, our future workplan, and more.
Control Measures Thus Far
Since entering into the agreement, Lake Superior College has installed interim control measures to collect, hold and filter water used in water-only training exercises. The PFAS filtered water is being released into the City of Duluth’s sanitary system, which is part of the Western Lakes Sewer and Sanitary District.
Project Findings and Recommendations
A 2024 investigation conducted by Barr identified ERTC areas with concentrations above MPCA industrial reference values (SRVs) for soil samples. It found concentrations above EPA maximum contaminant levels (MCLs) and/or Minnesota Department of Health groundwater (GW) values for water samples collected from perched water.
Primary recommendations from the report include:
- Conducting supplemental onsite hydrogeologic investigation activities to support the identification, sampling, and evaluation of a contiguous groundwater unit
- Constructing monitoring wells at deeper intervals than the initial investigation; use methods to prevent cross-contamination among hydrogeologic units
- Screening multiple wells in a contiguous groundwater unit for groundwater evaluation to learn about off-site site migration
- Evaluating the extent of soil impacts north and east of the equalization basin to delineate soils with concentrations exceeding SRVs; soil sampling is also recommended west of MW-1
- Evaluating surface water discharge frequency and flow rates to inform the presumed future remedial feasibility studies focused on mitigation of offsite PFAS migration
Costs
Total costs are unknown but are expected to be extensive and persist for years to come. As of May 2025, Lake Superior College has spent over $750,000 of its reserve resources to fund testing and containment efforts. LSC is partnering with elected officials, the MPCA, and other government leaders to identify funding sources that will exceed the college’s capacity to pay.
At some point in the future, it’s likely that the college will need to find a temporary home for its firefighting and truck driving program during site clean-up. If you know of a possible location for either or both programs, please contact Linda Kingston.
Next Steps
Continued testing of the soil and water will become necessary to ensure the site follows current law and science standards. The college is committed to the collaborative cleanup effort while continuing its vital work of training fire fighters.
Because the ERTC is not a critical worksite for active-duty firefighters (like a fire station), it is an ideal location for researchers to learn about effective PFAS mitigation efforts. The knowledge generated from these efforts will be shared with state and other agencies that also face PFAS cleanup work.
For additional information on this topic, please contact David Kline, vice president of Advancement and External Relations.
