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(Usa) Form Confidential REPORT Site Assessment and Risk Evaluation Based on 2010 and 2011 Field Sampling Investigation of Soil and Sediment In Areas Potentially Impacted by The Cass Lake Biological Testing Site For Zinc Cadmium Sulfide Compound Cass Lake, MN Leech Lake Band of Ojibwe DRAFT Prepared By: IECIS Group Stillwater, MN For: Brandy Toft, Project Officer Division of Resource Management Leech Lake Band of Ojibwe Cass Lake, MN February 2012 Version 2 Executive Summary Zinc Cadmium Sulfide Dispersion Tests were conducted in 1964 on the Leech Lake Indian Reservation, Minnesota, by the U.S. Army Chemical Corps as part of the United States Biological Warfare (BW) program established in 1942. This report provides the final confirmation sampling results aimed at measuring Zinc and Cadmium levels within areas of concern within the Leech Lake Indian Reservation, MN. Zinc and Cadmium in soils and wetland areas were investigated in several areas, including areas that are culturally sensitive. Samples were collected by Leech Lake Band of Ojibwe (LLBO) staff following the approved Quality Assurance Project Plan and chemical analyses were conducted by Test America, the LLBO contracting laboratory. Overall, a summary of the validation and audit of Test America analytical results is provided for all soil and sediment samples collected as part of Site Screening Investigation of Cass Lake Biological Testing Site, Cass Lake, MN in 2010 and 2011. The samples were collected from designated areas and shipped to Test of America Laboratories for testing. The chain of custody of each sample is documented and the samples were received in good conditions. The samples were prepared and analyzed in four different batches. Cadmium and Zinc were determined using ICPMS, moisture, percent solid and pH of each sample was also determined. A separate report was issued for each batch by Test America Laboratories. The results of the analysis show: 1. No cadmium detected above the screening level 1 mg/kg for soil. The results ranged from 0.012 to 0.3 mg/kg. All samples analyzed were below the screening level for 1 mg/kg for soil. 2. The amount of Zinc detected varied from one sample to another and the results ranged between 12 and 86 mg/kg which were above the screening level of zinc in soil of 10 mg/kg, but within background conditions and findings by the Minnesota Geological Survey in a till geochemistry and indicator minerals study for the entire State of Minnesota. 3. The pH of the samples varied between acidic pH 2.3 for sample S13 to slightly basic pH 8.0 as for sample S07. The moisture content varied from one sample to another (73-86 %). 4. No correlation was found between the pH values and the metal content of the samples. Based on the 2010 and 2011 field investigations, no further sampling is recommended. Several Band/community Members have expressed their wish to avoid hunting and gathering in the area of the Site and intent to make sure their children are aware of the location. The technical study did not clear their minds given the fact that the U.S. Army’s Zinc Cadmium Sulfide Dispersion Tests could have also involved simultaneous exposures to other dispersants such as biologic stimulants, e.g. Serratia marcescens or Bacillus globigii. There are rumors of other biological stimulants being used, such as tularemia being released during this testing. Evaluation of other biological agents was not within the scope of this evaluation. Based on comments collected during the initial scoping for risk evaluation of Zinc Cadmium Sulfide there is reason to be concerned about public perception of this evaluation method. Several Band members reported their concern of the use of other biological compounds in addition while practicing traditional activities observed signs of tulerima in the project area. For the purposes of the Zinc Cadmium Sulfide releases this report indicates there are no elevated residual levels of Zinc or cadmium in the project area. However, without access to the completed reports and deliverables from the entire project by the government, which includes comprehensive evaluation of its test results, follow up testing, and final conclusions on the potential risks as outlined in Technical Report February 2012 Version-2 IECIS Group Page 2 of 22 the government test objectives, it is impossible for the Band members and leadership to conclude there are no lingering risks to the Leech Lake community or their natural resources. We will attempt to address the Band members’ concerns with community meetings and the Tribe will conduct extensive outreach as part of future mitigation efforts to address cultural impacts attribute to the Cass Lake Biological ZnCdS Testing Site. Based on information we have today with the technical and best available science for zinc cadmium sulfide deposition, this report indicates there are no residual impacts to the natural resources from the Zinc Cadmium Sulfide compound. Without the completed reports from the project by the government and complete evaluation and potential risks outlined, the Band cannot state that health risk and environmental impacts associated with this project have been fully evaluated. As such, the Band reserves the right to revisit the Site if further information regarding the Site presents itself. Technical Report February 2012 Version-2 IECIS Group Page 3 of 22 1.0 INTRODUCTION 1.1 Background Because of concern over the possible use of biological warfare (BW) by a foreign power against the United States and its allies, President Roosevelt in 1942 established the U.S. Biological Warfare Program. From January through August 1964, , the U.S. Army Biological Warfare Center in Fort Detrick, Maryland, contracted with Litton Industries to conduct an experimental monitoring station for airborne releases of zinc cadmium sulfide (ZnCdS) powder. The test was designed to determine the potential effects of a biological or nuclear attack on U.S. cities by measuring the movement of airborne particles released in urban and rural environments, and to determine the munitions requirement (the quantity of material required to achieve a particular military objective). In light of today’s homeland security preemptive measures, such an experiment may help identify the potential ecological and health impact associated with a terror act conducted using elements similar to those utilized by the experiment. The ZnCdS compound used in the Cass Lake Biological Testing Site 1964 experiment was not considered to be a biological warfare agent. It was viewed as a desirable non-biologic stimulant of bacterial particles for the following reasons: it fluoresces under ultraviolet (UV) light and therefore can be easily detected; its particle diameter (2-3µm) and mass, and thus its behavior in air, are similar to those of BW agents; and it is economically feasible to use. At the time, ZnCdS was thought to be nontoxic to humans, animals and plants, and relatively stable in the atmosphere to conduct the tracer experiment (hours to days). 1.2 Site Location The site is on LLBO Reservation and within Chippewa National Forest in North Central Minnesota, approximately 350 km north of Minneapolis-St. Paul, 5-6 km from main roads, 8-10 km southeast of nearest town of Cass Lake (population 1,500), 32 km southeast of Bemidji (population 10,000). It is situated along U.S. Forest Road 133, approximately 3 ¼ miles from the junction of Forest Road 133 and U.S. Highway 2 (Figures 1a and 1b). The legal description for this area is SE ¼ Section 33 and SW ¼ Section 34, Township 145 North, Range 30 West, and the NE ¼ Section 4, Township 144 North, Range 30 West. (Figure 1) Technical Report February 2012 Version-2 IECIS Group Page 4 of 22 Figure 1: Site Location The Cass Lake Biological Testing Site was selected for many reasons. It was to provide: non- marshy terrain with uniform and dense coverage of hardwood or deciduous forest conditions; continuous site at least 3 miles upwind; a minimum of hills, streams, lakes, built-up areas for several miles; presence (but not excessive) of snow in winter; accessibility by road; access to manpower, supplies, and facilities; reasonable convenience of aircraft facilities; and access to meteorological data for previous years. Two series of 12 tests were then conducted during the winter and summer of 1964. To simulate a line source, about 700 pounds of zinc cadmium sulfide were released by an Army Piper Apache aircraft flying at 150 mph ground speed along a line of 16 km within the boundaries of the Leech Lake Reservation. In addition, individual bomblets were exploded to simulate point sources (See Figure 2, a general historic data map located at the U.S. Forest Service). Technical Report February 2012 Version-2 IECIS Group Page 5 of 22 Figure 2: Historic Release Map - Tower System (NW-SE) and Release Lines (SW-NE) Upon learning of the dispersion tests in the early 1990s, the Leech Lake Band of Ojibwe (LLBO) became very concerned about possible health effects of exposures to ZnCdS by people in its community, and expressed outrage about being exposed to chemicals by the government without being informed. After some information on the test became public, it was believed that the LLBO tribal lands may have been potentially at risk, which lead to a Cooperative Agreement between the Leech Lake Band of Ojibwe and the U.S. Department of Defense (DOD) to conduct a screening investigation of environmental impacts associated with secret testing conducted on the Reservation. The Department of Defense, through the Native American Lands Environmental Mitigation Program (NALEMP), began funding the screening study of environmental impacts and preliminary environmental mitigation program management activities at the formerly used defense site known as the Cass Lake Biological Testing Site located near Cass Lake, MN, FUDS #E05MN1062.
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