COMMUNITY INVOLVEMENT PLAN St. Regis Paper Company Superfund Site St. Regis Paper Company Superfund Leech Lake Reservation Cass Lake,Cass Minnesota 2016

St. Regis Paper Company Superfund Site CONTENTS Section Page 1.0 INTRODUCTION...... 1 1.1 Community Engagement is Essential to the Success of Superfund Cleanups...... 1 1.2 Purpose of this CIP...... 2 1.3 CIP Overview...... 2

2.0 COMMUNITY ENGAGEMENT AND THE SUPERFUND PROCESS...... 3

3.0 ST. REGIS PAPER CO. SUPERFUND SITE BACKGROUND...... 7 3.1 Site Location...... 7 3.2 Site History...... 8 3.3 Known Contaminants...... 11

4.0 COMMUNITY BACKGROUND...... 13 4.1 Cass Lake Community Profile...... 13 4.2 Leech Lake Reservation Profile...... 15 4.3 Community Demographics...... 15 4.4 Past Community Involvement Efforts...... 16

5.0 DETAILED SUMMARY OF COMMUNITY INTERVIEWS...... 17

6.0 COMMUNITY CONCERNS AND QUESTIONS...... 21 6.1 Potential Health Effects...... 21 6.2 Potential Impact on Property Values...... 21 6.3 Communication with Local Residents and Officials...... 21 6.4 Summary of Comments, Concerns and Questions Raised at the August 2016 Meeting...... 22

7.0 COMMUNITY INVOLVEMENT GOALS AND ACTIVITIES...... 27 7.1 Specific Community Involvement Activities...... 27 7.2 Timeframe for Conducting Community Involvement Activities...... 30 Figures Exhibit 1: Superfund Process Steps...... 4 Exhibit 2: Community involvement opportunities during the Superfund process...... 5 Figure 1: Site Location Map...... 7 Tables Table 1: Site History...... 8 Table 2: Schedule of Community Involvement Activities...... 30 Appendices

A GLOSSARY – INITIALS - ACRONYMS

B INFORMATION REPOSITORIES WITH ADMINISTRATIVE RECORDS, WEBSITE AND PUBLIC MEETING LOCATIONS

C LIST OF CONTACTS

Community Involvement Plan iii St. Regis Paper Company Superfund Site

iv Community Involvement Plan St. Regis Paper Company Superfund Site 1.0 INTRODUCTION The U.S. Environmental Protection Agency continues and comments are received from prepared this Community Involvement Plan the community. It is intended to be flexible, for the St. Regis Paper Co. Superfund site in adaptable and used as a guideline for EPA’s Cass Lake, Minnesota, on the Leech Lake Indian communication with the St. Regis community. Reservation adjacent to the Chippewa National Forest. EPA’s community involvement effort 1.1 Community Engagement is is committed to promoting communication between community members and the Agency. Essential to the Success of EPA wants to make sure the community’s Superfund Cleanups current concerns and information needs are Ongoing comment and involvement by the considered as site activities progress. (Words in community is essential to EPA’s efforts to boldface are defined in the Glossary – Initials – provide effectivecommunity engagement. Acronyms Appendix A.) EPA has learned that its decision-making ability is enhanced by actively seeking comments and This CIP was updated to support environmental information from the community. Community and cleanup activities at the St. Regis site. EPA members need to be involved in all phases used several information sources to update this of the cleanup so that the contamination is plan, including research, community interviews addressed in a way that protects people and the and public meetings. The interviews were environment – now and in the future. conducted with residents, business owners and local officials in July 2012 and the information Residents, former employees and local gathered from July 2012 and August 2016 public government officials may be able to provide meetings gave EPA an insight into the concerns valuable information about a hazardous site that and information needs of the community. This can help EPA determine the best way to clean it CIP describes EPA’s plan for addressing concerns up. Information can help determine the location and keeping residents informed and involved of contamination, how people may be exposed in the site cleanup activities. It also provides to the contamination and perhaps sources of information on the Superfund process, site the contamination. background information and a profile of Cass Lake. The CIP is a working document that will evolve as the investigation and cleanup process

Goals of EPA’s community involvement efforts: • Assist the public in understanding the decision-making process during project design and cleanup and the community’s role in that process.

• Give the public accessible, accurate, timely and understandable information about the project as it moves forward.

• Ensure adequate time and opportunity for the public to provide informed and meaningful comment and for that comment to be considered.

• Reflect community concerns, questions and information needs.

• Respect and fully consider public comment throughout the process as the project moves forward.

Community Involvement Plan 1 St. Regis Paper Company Superfund Site

1.2 Purpose of this CIP • Section 4 – Cass Lake Community Background: Profiles the economic and The EPA will use this document as a guide ethnic makeup of the community and to involve and communicate with residents, summarizes the community’s history and businesses and local government in the Cass past involvement at the site. Lake area. In a separate process, EPA works in partnership with the Leech Lake Band of • Section 5 – Detailed Summary of Ojibwe tribal government and with the state Community Interviews: Provides a of Minnesota to provide those governments a summary of what interviewees told EPA meaningful role in decisions for the St. Regis site. about the St. Regis site and how they would Those relationships are not the subject of this like to receive information from EPA about CIP. the site.

If you are interested in submitting comments or • Section 6 – Community Concerns and have questions or suggestions concerning the Questions: Presents the concerns and other CIP, please contact: information gathered during the community interviews and public meetings. Heriberto León Community Involvement Coordinator • Section 7 – Community Involvement EPA Region 5 (SI-7J) Goals: Describes EPA’s plan and timeline for 77 W. Jackson Blvd. conducting site-specific activities to keep Chicago, IL 60604-3507 residents and local officials informed and Phone: 312-886-6163 or toll free at 800-621- involved during the cleanup process. 8431, ext. 66163 [email protected] • Appendix A – Glossary – Initials - Acronyms: Provides the definition of For more information on the St. Regis Paper key words in bold found throughout the Co. Superfund site, visit: http://www.epa.gov/ document. superfund/st-regis-paper or request information 1.0 INTRODUCTION by contacting EPA’s CIC, Heriberto León. • Appendix B – Information Repository, Administrative Record and Public Meeting 1.3 CIP Overview Locations: Identifies places where people can find more information about the St. This CIP contains the following sections: Regis site.

• Section 1 – Introduction: Describes the • Appendix C – List of Contacts: Provides a purpose and intended uses of this CIP. list of federal, tribal, state and local agencies. • Section 2 – Community Engagement and the Superfund Process: Provides an overview of the step-by-step process the EPA follows to determine the best way to clean up a contaminated site and opportunities for community involvement throughout the process.

• Section 3 – St. Regis Paper Co. Superfund site Background: Provides background information about the site’s location and history.

2 Community Involvement Plan St. Regis Paper Company Superfund Site 2.0 COMMUNITY ENGAGEMENT AND THE SUPERFUND PROCESS

Superfund is an environmental cleanup program a step-by-step enabled by a federal law enacted in 1980 process (see known as the Comprehensive Environmental Exhibit 1 on the Response, Compensation, and Liability Act, next page) to or CERCLA. In 1986, another law, the Superfund determine the Amendments and Reauthorization Act (SARA) best way to clean reauthorized CERCLA to continue Superfund up the site and cleanup activities. The CERCLA law gives EPA the protect human authority to require those parties responsible health and the for creating hazardous waste sites to clean up environment. those sites or to reimburse the government if EPA cleans up the site. EPA compels responsible The Superfund program encourages active parties to clean up hazardous waste sites dialogue between communities affected by through administrative orders, consent decrees the release of hazardous substances and and other legal settlements. EPA is authorized all of the agencies responsible for carrying to enforce the Superfund laws within Indian out or overseeing cleanup actions. EPA reservations, in all 50 states and in U.S. territories. considers community involvement to be an Superfund site identification, monitoring and important part of the Superfund program and response activities are coordinated with state, opportunities for community involvement tribal and territorial environmental protection or occur throughout the process. At each step in waste management agencies. the process, there are opportunities for various levels of community involvement (see Exhibit 2 There are several steps involved in cleaning up on Page 5). a contaminated site. Once EPA has been made aware of a contaminated site from a person, local, tribal or state agency, or others, EPA follows

Visit these EPA websites for more information on the Superfund process. Superfund www.epa.gov/superfund

Cleanup Process: www.epa.gov/superfund/cleaning-superfund-sites

Community Involvement www.epa.gov/superfund/superfund-community-involvement

Community Involvement Plan 3 St. Regis Paper Company Superfund Site

Exhibit 1: Superfund Process Steps

Legend PA/SI Preliminary Assessment/Site Although “reuse” is shown as the last step in Investigation the remedial process, it is important to note that potential future uses of a Superfund site NPL Listing National Priorities Listing helps to guide the entire process. In addition, RI/FS Remedial Investigation/ many Superfund sites are redeveloped prior Feasibility Study to being deleted from the National Priorities ROD Record of Decision List. Redevelopment of the St. Regis site is a significant concern among the residents of the RD/RA Remedial Design/Remedial Cass Lake area, and EPA believes the remedial Action process does not need to be a barrier to reuse. NPL Deletion National Priorities List Deletion

4 Community Involvement Plan St. Regis Paper Company Superfund Site

Superfund Community Involvement Process Steps Opportunities • Gather historical site condition information to • Provide any information you have about the site determine if further investigation is needed Preliminary to the EPA • Use Hazard Ranking System to evaluate risks Assessment/Site Inspection

• Publish notice in Federal Register and local media • Read information about EPA’s proposal to list the site announcing proposed listing and public comment National • Contact EPA for questions or additional information period Priorities List • If concerned, submit comments during the Public • Once listed, EPA publishes notice in Federal Register Process Comment period and responds to comments

• Determines the nature and extent of contamination, Remedial • Consider forming a Community Advisory Group and evaluates human health and ecological risk applying for a Technical Assistance Grant Investigation/ • Participate in public meetings Feasibility Study • Contact community involvement coordinator with questions

• Presents the cleanup alternatives and is issued for • Read proposed plan a 30-day public comment period St. Regis Proposed • Participate in public meetings • Visit Information Repository soil Plan

• Contains the selected remedy for a site and the • Read the ROD for site cleanup Responsiveness Summary which provides • Participate in public events or visit the information responses to all comments received during the Record of Decision repository public comment period • Contact site CIC with questions

• Includes preparing for and doing the bulk of the • Learn about the final design cleanup at the site Remedial Design/ • Work through your CAG, TAG, or Technical Assistance • Final design is developed Services for Communities provider for information Remedial Action • Attend meetings and site visits • Contact CIC with questions

• Any necessary physical construction has been • Attend meetings and site visits completed (even though final cleanup levels may Construction • Contact CIC with questions not have been reached) Completion

• Ensures that Superfund cleanups provide • Work through your CAG, TAG, or TASC provider for long-term protection of human health and Post-Construction information environment St. Regis • Visit the site or arrange a site tour through EPA • Monitoring continues Completion • Contact CIC with questions ground water

• All site work completed • Read EPA’s proposal and Responsiveness Summary • EPA requests comments on upcoming deletion of NPL • Read the final deletion report site from NPL list • Plan a community event to celebrate deletion Deletion from NPL

After site is clean: • Work with EPA and neighbors to plan the • EPA works with community to help return site to redevelopment productive use Reuse • Explore EPA’s tools and resources • EPA will ensure that any land use restrictions • Be supportive of redevelopment plans once they’ve continue to be met been agreed upon

Exhibit 2: Community involvement opportunities during the Superfund process

Community Involvement Plan 5 St. Regis Paper Company Superfund Site

6 Community Involvement Plan St. Regis Paper Company Superfund Site 3.0 ST. REGIS PAPER CO. SUPERFUND SITE BACKGROUND

This section describes the St. Regis site and • The southwest operational area north of summarizes the history of activities at the site. Fox Creek, east of the Tribal Fishery, south of South 3rd Street and west of County Road 3.1 Site Location 147. The St. Regis Paper Co. Superfund site occupies • A portion of the City of Cass Lake city dump 125 acres on the Leech Lake Indian Reservation north of Fox Creek, east of County Road 147, between Pike Bay and Cass Lake in Minnesota. south of Chippewa National Forest and west The site is adjacent to Chippewa National Forest. of Pike Bay. The site is composed of four general areas: • Residential parcels east of Minnesota • The former operations area bounded by the Highway 371, west of Pike Bay, and south of Burlington Northern Santa Fe railroad to the the BNSF railroad tracks. north, Pike Bay and the channel between Pike Bay and Cass Lake to the east, South 3rd Street to the south, and Minnesota Highway 371 to the west.

Figure 1: Site Location Map

Community Involvement Plan 7 St. Regis Paper Company Superfund Site

3.2 Site History Champion International Corp. bought St. Regis in 1985 and merged with International Paper The St. Regis Corp. operated as a wood in 2000. The site was initially cleaned up by treatment facility from about 1958 until 1985. then-owner Champion International under the During this time, the land was leased from authority of the Minnesota Pollution Control Great Northern Railroad, which became part of Agency from 1986 to 1988. International Paper, Burlington Northern Railroad (now the BNSF the current owner, continues to maintain a Railway) in a merger. The site expanded through ground water treatment facility on the site. land purchased south of the leased property. Residents were hooked up to city water in 1986 Lumber was pressure treated with creosote because private wells were in danger of being and chemicals including pentachlorophenol, contaminated. In 1995, EPA took over from the or PCP; polycyclic aromatic hydrocarbons, state as lead agency on the site. or PAHs; and copper chromium arsenate. These substances generated the PAHs, dioxin EPA’s later reviews of the site remedy concluded and arsenic pollution. Wastewater from these that additional sampling and a risk assessment processes went into several disposal ponds on were needed to fully understand contamination the site. Sludge from these ponds was hauled at the site. Below is a table providing a timeline to a nearby dump and burned. On September of events at the site. 21, 1984, the site was added to EPA’s National Priorities List, which made it eligible for cleanup under the Superfund program. Table 1: Site History

Date Event

1981-1982 St. Regis Paper Co. conducted a ground-water investigation under MPCA oversight and found PCP, PAHs and some heavy metals in ground water, as well as sludge-contaminated soil, at the site.

1984 Site placed on National Priorities List

January 1985 Champion International Corp. assumed ownership of the site when it acquired and merged with St. Regis Corp.

April 1985 Champion submits a Remedial Investigation/Alternatives Report summarizing contamination at the site and proposing several cleanup alternatives.

September 1985 Operations stopped at the site.

March 1986 MPCA signed two Minnesota Enforcement Decisions Documents requiring Champion to excavate sludge and contaminated soil and place it in an on-site vault and pump and treat contaminated ground water.

1986-1987 Champion excavated contaminated sludge pits and visibly contaminated soil from operations areas and the Cass Lake city dump; waste was put in a Resource Conservation and Recovery Act, or RCRA-compliant vault constructed at the former southwest operations area. An extraction system was constructed to remove ground-water contamination for the former operations and city dump areas; contaminated water began to be treated with activated carbon to remove contamination and discharged to the nearby channel connecting Cass Lake with Pike Bay.

8 Community Involvement Plan St. Regis Paper Company Superfund Site

1988 Champion deeded a large part of the north storage area to the city of Cass Lake; a portion of the southwest area was transferred to the Leech Lake Reservation Business Committee to expand fish hatchery facilities.

1995 MPCA completed a five-year review of the cleanup actions carried out at the site; review showed some of the cleanup actions may not have been adequate and further action was needed to ensure protection of human health and the environment. EPA becomes the lead oversight agency for the site.

2000 International Paper acquired Champion Paper and became the responsible party for the St. Regis site. EPA completed a second five-year review of the site and concluded that additional soil sampling and other testing were needed to determine if cleanup actions were protective of human health and the environment.

2001 EPA conducted additional sampling; results showed contamination was still present in soil and a more detailed evaluation was needed.

2003 EPA issued IP a Unilateral Administrative Order to conduct additional detailed sampling in the former operations area. The samples confirmed that high levels of contamination in the soil still existed.

2004 EPA issued IP a UAO to conduct a human health and ecological risk assessment. IP took more than 300 samples from the site and related areas, including indoor dust from selected nearby homes, fish, river and lake sediment, grasses, wild rice, native plants, clams, worms, grubs and crayfish. Risk information would later help EPA determine what additional work may be needed at the site.

2004-2005 EPA issued IP a UAO to remove heavily contaminated soil in several properties near the former operations area. IP removed 3,394 tons of contaminated soil from the site.

2005 EPA conducted the third five-year review and determined more information was needed to know if the ground water cleanup plan was still protecting people and the environment.

2006 IP conducted a voluntary removal action at two commercial parcels owned and operated by Cass Forest Products; a geotextile fabric was put on one parcel to eliminate the potential from exposure and a fence was put around the other parcel to limit trespassing. Under an Administrative Order on Consent, BNSF Railway removed an additional 680 tons of contaminated soil from its property area. Based on results from indoor dust sampling, EPA ordered IP to reduce the levels of dust within homes near the site. IP completed the initial housecleaning where access was granted; applied dust suppressant on unpaved roads and placed clean dirt and grass seed on the yards. IP drilled additional wells and borings to improve the ground water monitoring system. Monitoring requirements were updated and include more frequent sampling and testing for additional contaminants. Under EPA oversight, IP completed a system-wide pumping test of 72 monitoring wells and all 13 extraction wells. IP conducted additional sediment sampling under EPA oversight.

Community Involvement Plan 9 St. Regis Paper Company Superfund Site

2008 EPA reached agreement with IP and BNSF Railway and signed a consent order for the companies to conduct a feasibility study of site cleanup alternatives. EPA approved the potentially responsible parties’ human health portion of the site risk assessment.

2009 IP tested the ground water to test the connection between the lower and upper aquifers and the variability of this connection near the LLBO Fish Hatchery property.

2010 EPA conducted the fourth five-year review and concluded that the extraction well system does not completely capture the contaminant plume in the operable unit 1 area and possibly in the OU3 area.

2011 EPA approved the PRPs’ ecological risk portion of the site risk assessment. EPA issued a Proposed Plan for cleanup of contaminated soil for public review and comment.

2012 IP collected additional soil samples at depth to enhance review of cleanup alternatives. IP took ground water samples in the area southeast of the former operations area to investigate capture of the ground water plume in OU1.

2013 IP collected additional soil samples. IP Soil Sampling for Feasibility Study Report is finalized incorporating the results of the 2012 and 2013 soil sampling.

April 2014 The Minnesota Department of Health and the Leech Lake Band of Ojlbwe Division of Resource Management issue a Letter Health Consultation for Surface Soil Contamination Data Gaps for Residentially-Zoned Areas (Potential Current Dioxin Exposure).

Aug. 2014 Leech Lake Reservation Business Committee issues Resolution No. 2015-27 to approve, as a matter of tribal law and policy, the MDH and LLBO-DRM Letter Health Consultation dated April 18, 2014, and adopt the soil sampling recommendation as tribal requirements to be implemented as applicable or relevant and appropriate requirements within the exterior boundaries of the Leech Lake Reservation.

January 2015 IP publishes the Final Supplemental Feasibility Study Report for soil cleanup.

July 2015 EPA signs the Fifth Five-Year Review Report for the site.

April 2016 EPA issues a Proposed Plan for cleanup of contaminated soil in OU7 for public review and comment.

10 Community Involvement Plan St. Regis Paper Company Superfund Site

3.3 Known Contaminants are likely to cause cancer. The ecological effects from PAHs include poisoning of The wood treating process at the St. Regis aquatic life and birds causing tumors and site resulted in the introduction or creation reproductive effects. of contaminants that are hazardous or potentially hazardous to human health and • Metals, including arsenic and copper have the environment. These contaminants include been identified in the soil and sediment of dioxin, pentachlorophenol, commonly called the St. Regis site. Potential ecological effects PCP, polycyclic aromatic hydrocarbons, referred from copper contamination include death in to as PAHs, and metals including arsenic and amphibians, poisoning of aquatic organisms, copper. Much of the contamination was removed reduced growth and developmental from the site during the MPCA-directed remedial abnormalities in birds and liver damage and actions. However, during subsequent sampling, kidney and brain damage in mammals. EPA found remaining elevated levels of these contaminants at the site.

• Dioxin has been identified in soil samples in the former operations areas of the site in concentrations that may pose a risk to human health and the environment. Dioxin has been characterized by EPA as likely to be cancer causing in people. Effects specifically observed in people include changes in markers of early development and hormone levels. At much higher doses, dioxins can The driller collects a soil core. cause a serious skin disease in people called chloracne. The ecological impacts of dioxin contamination include death, cancer and reproductive effects. Dioxin can result in fish, earthworm, bird, amphibian and mammalian death. Dioxin can also cause reproductive impairment, organ damage and retarded growth in mammals.

• PCPs have been identified in the groundwater of the St. Regis site in concentrations that may pose a risk to human health and the environment. Workers make observations of the soil core before collecting Impacts on people caused by exposure to soil to send to the laboratory for analysis. PCP include damage to the central nervous system, cardiovascular system, respiratory system, liver and kidneys. The ecological effects from PCP include death, reproductive impairment, organ damage and retarded growth in mammals.

• PAHs have been identified in the soil of the St. Regis site in concentrations that may pose a risk to human health and the environment. Impacts to people caused by exposure to PAHs include developmental and behavioral effects. PAHs may also cause red blood cell damage, suppressed immune systems and

Community Involvement Plan 11 St. Regis Paper Company Superfund Site

12 Community Involvement Plan St. Regis Paper Company Superfund Site 4.0 COMMUNITY BACKGROUND This section describes the Cass Lake community and summarizes the history of community involvement with the site.

4.1 Cass Lake Community Profile Cass Lake is in northern Minnesota near Bemidji in Pike Bay Township, Cass County, Minnesota, on the Leech Lake Band of Ojibwe Reservation. The city has a land area of 1.1 square miles. The city government is composed of a mayor and four elected council members. The Cass Lake City Council meets the 2nd Wednesday of each month at 5:30 p.m. The council meetings are held at the Cass Lake Municipal Center and are open to the public. The current council members are listed in Appendix C.

The Cass Lake Settlement grew and, in 1898, the village was established with the construction of the Great North Railway. When the post office was originally established in December 1898, the town was called “Tuller,” named after the

Cass Lake Municipal Center. Cass Lake is notable as the headquarters of the Minnesota Chippewa Tribe and Leech Lake Band of Ojibwe, as well as the Chippewa National Forest. The city is located on the shore of its namesake Cass Lake, named in honor of Michigan Governor Lewis Cass.

Until the early 1850s, the area was covered with dense forests of pine, poplar, oak, cedar, maple, birch and spruce. After Cass County was organized in 1851, lumbermen swarmed in and General view of Cass Lake Minnesota, 1900. logging camps and saw mills sprang up. (Photo courtesy of the Minnesota Historical Society)

Community Involvement Plan 13 St. Regis Paper Company Superfund Site brother-in-law of the first postmaster. When With a major railroad yard in town, railroad this became known, residents quickly lodged operations and businesses supporting the protests with the Postmaster General and by the railroad were very important to the local end of March 1899 it was renamed “Cass Lake.” economy. Historically, lumbering and forest The coming of the Minneapolis, St. Paul and Sault products were also important parts of the local Ste. Marie Railroad (Soo Line) in 1900 was also economy. an important factor in the development of the community. (Source: https://en.wikipedia.org/wiki/Cass_Lake_ (Minnesota)

Tourism, which is highly seasonal because of the cold winters, is also an important part of the local economy. Resorts, recreational facilities and scenic beauty attract many visitors to Cass Lake. Some of the major employers in the area include

Employer Products/Services Employees Leech Lake Band of Ojibwe Gambling Industries 350 US Indian Health Service Nursing Care Facilities 125 Cass Lake School District 115 Elementary & Secondary 100 Schools Minnesota Chippewa Tribe Other Community Housing 75 Services. Cass Forest Products Sawmills & Wood Preservation 60 Teal’s Supervalu Grocery Stores 50 U.S. Forest Service Support Activities for Forestry 40 (Source: http://www.lakesnwoods.com/CassLake.htm)

14 Community Involvement Plan St. Regis Paper Company Superfund Site

4.2 Leech Lake Reservation Profile The federally recognized Leech Lake Band of Ojibwe is one of six member bands of the Minnesota Chippewa Tribe and is governed by a Constitution, which the band members wrote. The Leech Lake Tribe holds the smallest percentage of its reservation of any tribe in the state. County, state and federal governments owned well over half of the original land. Of the original 864,158 acres, nearly 300,000 acres are surface area of the three big lakes and the 4.3 Community Demographics National Chippewa Forest has the largest portion of the land. Seventy-five percent of the National Based on 2010 U.S. Census data, Cass Lake has Forest is within the reservation, which leaves a population of 770. This reflects a population less than 5 percent of land owned by the band decrease of 10.5 percent from the 2000 census. (http://www.llojibwe.com/subnav/demographic. During the summer months, the population in the html). The reservation lies within parts of area increases dramatically when summer residents Beltrami, Cass, Hubbard and Itasca counties. return to the area around Pike Bay and Cass Lake. According to www.city-data.com, the population of Cass Lake is predominantly American Indian alone (66.8 percent), White alone (24.2 percent), two or more races (5.8 percent), Hispanic of any race (2.2 percent), Asian alone (.8 percent) and Black alone (.3 percent).

The median resident age in Cass Lake is 31.8 years compared to a median age in Minnesota of 43.1 years. About 71 percent of the population 25 years and over in Cass Lake have a high school education or higher and about 7 percent of those have attained a bachelor’s degree or higher. Leech Lake Ojibwe delegation to Washington in 1899. (Source: http://en.wikipedia.org/wiki/Cass_Lake,_Minnesota) The 2009 median household income was $28,536. This compares to the median The Leech Lake Band of Ojibwe operates three household income for the state of Minnesota of casinos, a hotel, two convenience stores, a gift $55,616 in 2009. As of March 2012, the cost of store and an events center, as well as a fish hatchery and a wild rice processing and distribution warehouse. American Indian alone The Leech Lake Reservation White alone Business Committee or Tribal Council is the governing body two or more races with its offices in Cass Lake. The members of the tribal council Hispanic are listed in Appendix C. Asian alone (Information is from the Leech Lake Band of Ojibwe website: Black alone www.llojibwe.com.)

Community Involvement Plan 15 St. Regis Paper Company Superfund Site living index in Cass Lake was 86.7, which is considered 2011 and 2012. On April 9, 2016, EPA held a less than average (the U.S. average is 100). In August public meeting and public hearing on a proposed of 2012, unemployment in Cass Lake was reported to cleanup plan for soil at the site. The meeting was be 7.6 percent compared to the state average of 5.6 announced in the local paper, through a mass percent for the same time period. The unemployment mailing and EPA’s website. EPA transcribed the rate has steadily declined since 2009, when it reached meeting proceedings. A 60-day public comment its peak of 11 percent. period was held on the proposed cleanup from March 28 to May 27, 2016. On August 10, 2016, EPA As of April 14, 2011, Leech Lake Reservation held another public meeting and public hearing population is 10,456, with 4,132 enrolled in the on the proposed cleanup for soil associated with tribe as Tribal members. The American Indian the site and the comment period on the proposed population is reported to be 4,488. soil cleanup was extended until September 2, 2016. The comment period extension and the August 4.4 Past Community Involvement meeting were announced through various local Efforts media, mass mailings to two distribution lists and EPA’s website. The meeting proceedings have been EPA’s community involvement efforts have transcribed. included meeting with individual residents, hosting numerous public meetings and availability Fact sheets providing updates about site activities sessions throughout the years and publishing were mailed to community members and made numerous fact sheets. EPA has sent press releases available on the EPA website in 2004, 2005, 2008, to local media and arranged for numerous 2009 and 2010. Two fact sheets explaining the media interviews, especially with the Cass Lake proposed cleanup plan were also produced in 2016. newspaper, the local radio station and the band’s EPA produced a newsletters entitled “Woods and newsletter. EPA also has, through a grant to the Water” updating the community on ongoing activities Leech Lake Band Division of Natural Resources, at the St. Regis Superfund site. Newsletters were interviewed band members, and has met with produced in April 2012, March 2014, September 2014 band local district communities. EPA also has met and March 2015. with the Reservation Tribal Council and the Cass Several information repositories have been Lake City Council to provide briefings and answer established for the site (see Appendix B for the questions about site progress or proposed actions. locations). Each repository contains the same EPA has held several meetings throughout the site-related documents such as technical reports, years to provide opportunities for the community sampling results, enforcement documents, to get an update on activities and to ask general information about EPA and the questions. In 2001, EPA provided a “Superfund Superfund program and other information. 101” community involvement workshop to help Documents in each repository are available community members understand the Superfund for public review during each location’s hours remedial process and how to become involved of operation. Site-related information can also and be heard. A public meeting was held in 2003 be found on EPA’s website (www.epa.gov/ to update the community on sampling results superfund/st-regis-paper). and cleanup activities in and around the site. In In November 2005 a CIP update was prepared 2005, a public meeting and public hearing was and made available on EPA’s website and at held to give the community an opportunity to the information repositories. Community comment on a proposed short-term cleanup plan interviews conducted in July 2012 represent for contaminated dust in residents. Less formal EPA’s continuing efforts to keep the community informational sessions were also held to answer informed and solicit comment. These interviews questions from the community. Also in 2005, EPA as well as meetings held in July 2012 and April facilitated meetings in the community, using a and August of 2016 were used in updating this professional planning consultant, to develop a CIP. More detail on these interviews is in Section site reuse plan. Additional meetings to give site 5. Additional planned community involvement updates were held in 2006, 2008, 2009, 2010, activities are discussed in Section 7.

16 Community Involvement Plan St. Regis Paper Company Superfund Site 5.0 DETAILED SUMMARY OF COMMUNITY INTERVIEWS During July 2012, EPA conducted in-person 2. What do you know about the St. Regis interviews with 15 people with interest in site? the St. Regis site. Post cards were mailed to everyone on the St. Regis mailing list and to all Everyone interviewed knew about the postal customers and box holders informing site and said that they knew the company them that EPA was conducting interviews and [St. Regis] made wood products and that asked people who were interested to call to railroad ties were treated with creosote. One schedule an appointment. The interviews were resident said he saw creosote pits on the conducted in a discussion format and each site and that he had brothers who worked interviewee was asked questions from a list and there. Some of the people interviewed follow-up questions were suggested by the said they were not aware that the site is a discussions. The site Remedial Project Manager Superfund site. One homeowner said when and Community Involvement Coordinator she bought her house, she did not know it participated in the interviews. EPA’s contractor was on a Superfund site. Another resident provided note taking support during the said he knows it is a Superfund site and interviews. Below are the specific that people complain about it questions the EPA asked and a but it doesn’t really affect summary of the answers that Note him. One resident said were provided during the that she believed that community interviews. to the reader: the MPCA started to investigate 1. Do you live or work This section is intended to faithfully record the site and that on or near the and reflect the issues and concerns expressed to the Minnesota site? If no, are you EPA by residents, officials and others interviewed Department affiliated with any during the community interviews. By necessity of Health had organization that conducted a this is a collection and summary of thoughts, has an interest in health study that observations and opinions. Please note that the the site? How long was not used. have you been a statements contained in this section may or may resident of the area? not be factual and that some opinions and 3. How long have concerns may not be based on accurate you been aware of Four people have lived the environmental information. in the area all their lives concerns at the site? and several are summer residents, most of whom have Most of the residents said been coming to the area for more than they had been aware of the 50 years. Of the three people interviewed environmental concerns for many years, who do not live in Cass Lake, two work for some since it became a Superfund site. A Cass Forest Products and one works for the couple of the “summer residents” said they Cass County Economic Development Corp. did not know about the issues until the last few years because they live away from the site.

Community Involvement Plan 17 St. Regis Paper Company Superfund Site

4. What concerns do you have about the 7. How do you normally get information site? about the site?

See Section 6.0 on Page 21 for a complete Everyone interviewed said they normally summary of answers to this question. get information from the EPA mailings, word of mouth and city council meetings. One 5. Has any site work been performed on resident said that people think that “what your property? If so, what and when? If comes from EPA is sanitized – not getting work was performed on your property, the full story.” One resident thought the do you feel comfortable that it was done language should be simplified a little more properly? in fact sheets that are sent. Another resident Three homeowners said that their soil was said he usually throws out the EPA mailings replaced sometime in 2007 and black dirt because he believes it is just a repetition of was put in. They all said the black dirt that what they have heard before. was used was terrible and that it turned 8. How would you like to be informed into weeds and that the soil was more clay concerning future site activities (mail, soil whereas it used to be sandy soil. One e-mail, telephone, newspapers, television, homeowner said that his basement has radio)? flooded since they put the new soil in. No one has had any problems on their property. Everyone interviewed agreed that getting A couple of city workers said that they will updates and information in the mail is the usually get calls from residents asking if best way. Some people also wanted to there are problems they need to be worried be updated by e-mails. A couple people about after there has been information in the suggested that posting information on the newspaper about the site. They also received city’s website is a good way to keep the calls after the postcard was sent out asking community informed. people to call to schedule an interview. 9. Have you had any contact with local Cass 6. Is your home on the schedule to receive Lake, tribal, state or federal agencies monthly or quarterly cleaning by the about the site? PRPs? If so, do you have any concerns about how that is being done? Three people said they had gotten updates from State Representative John Persell, who Three residents have had a monthly service. is also an employee of the band. One resident said he had it done in his house but chose not to have it done in the 10. When EPA has a public meeting or apartment he owns. He said that they came availability session, what day and time in and vacuumed the carpets so he refused would be most convenient for you? Do to have it continued because he “can vacuum you normally attend the public meetings? himself.” One resident said it only takes the If not, what obstacles are there that keep cleaners 45 minutes to clean the entire house you from attending? and she thinks they are saying that it takes Almost all of the people interviewed said them longer. She asked the cleaning lady for they would attend a meeting and that a copy of the paperwork, but the cleaning having the meetings at the school or the city lady wouldn’t give it to her. The third resident council office are good places. The majority said all that gets done is vacuuming. of people said the meetings should be on a Two of the residents said that the only time Tuesday, Wednesday or Thursday, early in the the dust suppression gets done on the roads evening. is right before EPA comes to town. Another resident said she “thinks workers work because everyone is in town.”

18 Community Involvement Plan St. Regis Paper Company Superfund Site

11. Do you feel that you have been 14. Do you have any questions? adequately informed about the site? The following are comments and questions About half the people said they believe they asked by the people interviewed: have been kept informed about the site. One resident said he is being kept informed • How long before anything happens? but that the information given “is not saying • Why is the US Forest Service not listed as a anything different than from 25 years ago.” partner? People are furious with the Forest He also asked why there has not been Service because of wanting to triple fees. information given about health concerns. He filled out forms but hasn’t heard anything • I would like to be involved in the further. One resident said he doesn’t get redevelopment of the area. information from EPA and that he believes the newspaper is more colorful. He said the • When will sampling be started? key is who has credibility. Three residents • Who is supposed to watch if mowing is said they need more information about the being done? water and there is misinformation: one group says the water is okay and another says it • The dust suppression and mowing schedule is not. For example, there is dioxin in fish is an issue. I know when International Paper eggs in Pike Bay, but Cass Lake is okay. “That or EPA is going to be in town because that is doesn’t make sense.” One resident said that when the mowing and dust suppression get the fishing guides say not to eat white fish done. from Pike Bay. • Why is IP buying properties? 12. Site information is posted on the EPA’s website. Have you used the EPA web site • Need to make sure public meetings are www.epa.gov/superfund/st-regis-paper? more organized; the last meeting was “short of fire fights” and people were not Information repositories exist at the Cass courteous. Lake Public Library, City Hall, Leech Lake Band Division of Resource Management • I realize EPA is doing your job but am tired Offices, Leech Lake Tribal College and of hearing the same story. In regards to the Bemidji State University Library. Have you cleaning, the carpet was replaced (all houses ever used the information about the site held got the same carpet, there was no choice on at one of these places? the color); the walls and drawers were not cleaned. Maintenance is doing a good job A couple people said they had reviewed mowing. information posted on the website, but the majority have not visited any of the information repositories.

13. Are there any other people or groups you think we should talk to about the St. Regis site either because they have unique information or would like to know more from EPA?

Some additional names were provided as possible resources.

Community Involvement Plan 19 St. Regis Paper Company Superfund Site

20 Community Involvement Plan St. Regis Paper Company Superfund Site 6.0 COMMUNITY CONCERNS AND QUESTIONS We learned about concerns, questions and informational needs related to the St. Regis Superfund site, by conducting interviews with residents, local officials and other interested community members in July 2012. We also heard people’s concerns at public meetings held in 2012 and 2016. Several days before the July 2012 community interviews, storms passed through the area and caused a lot of damage. Many trees were torn down. Some of the discussion from residents focused on the downed trees and residents asked if dirt could be trucked in where holes were made from trees being uprooted. Also, some of the summer residents said that many people were afraid to express concerns too much or go to meetings because the U.S. Forest Service will throw them out of their cabins.

Overall, residents expressed concerns about health issues and property values. City officials and developers want the site cleaned up so the area can become prosperous again.

6.1 Potential Health Effects Many people had health concerns citing family members and others they know who have various illnesses, including cancer. One resident said there have been a high number of people the bank using their property as collateral, that who live in the cabins [across the lake] who they won’t even do an appraisal. City officials have died from many illnesses. Residents raised are concerned that the area is not marketable concern that the dust is contaminated. Others because digging is not allowed and as a result, mentioned concern about the dioxin in fish and no construction is being permitted. They also asked if it was okay to eat the white fish as there voiced worries that Cass Lake will always have seems to be conflicting information provided. the stigma of being a Superfund site.

6.2 Potential Impact on Property 6.3 Communication with Local Values Residents and Officials Some residents are concerned that being a Almost everyone interviewed said they were Superfund site is negatively affecting their satisfied with the information that has been property values. Many people said that the provided about the site, either from EPA or fences are an eyesore and they don’t understand from the city. One interviewee said information why they were put up where they are. A few he was receiving at the interview was the first residents said they could not get loans from he could understand and thought EPA has

Community Involvement Plan 21 St. Regis Paper Company Superfund Site not done a good job of communication. The interviewees also said they want to receive communications from EPA such as fact sheets Note to the reader: and postcards through regular mail as opposed to e-mail. Many people also said they also This section is intended to faithfully would like to receive information by e-mail record and reflect the issues and concerns and provided their e-mail addresses. Another expressed to EPA by attendees to the August 2016 meeting. This is a collection suggestion for a communication route is to use and summary of thoughts, observations and the city’s website. Having meetings at the Cass opinions. Please note that the statements Lake-Bena Elementary School is a convenient contained in this section may or may not be location for the Cass Lake community; however, factual and that some opinions and concerns the acoustics are very poor and at least one may not be based on accurate information. community member said that it was difficult to EPA’s response to public comments will hear what was being said. Having the meetings be summarized in a document called a in the early evening during the week (avoiding responsiveness summary, which will be Mondays and Fridays) would be the best time. placed in the site information repository and made available on EPA’s website. 6.4 Summary of Comments, Concerns and Questions Raised at the August 2016 Time Numerous people said that the contamination Public Meeting should have been cleaned up a long time ago. EPA held a meeting on August 10, 2016 to They expressed frustration that it has taken so get input from the community on a cleanup long. One said that they had been promised that plan being proposed for a portion of the St. the site would get cleaned up for over 20 years Regis Superfund site. At that meeting, people while people were “dropping over every day”. expressed the following comments and concerns about the site: EPA representation Several people questioned who EPA was Unique community representing in making its decision about the Many people expressed concern that they did cleanup. One person said that it sounded like EPA not want this site to be “treated like every other was negotiating with a Fortune 500 company, site”. They talked about how the site was on a who had the money to clean the site up, to keep reservation making it unique and said that EPA the contaminated soil in the community. She should follow tribal laws and cleanup levels. said, “Represent us, you know. Just represent One person said, “The difference between us us.” She added, “You represent the Federal and a lot of other communities is that we have a government, United States of America, best treaty with the government; and it’s a treaty that country in the whole world, they say. Take care of kept our territory, and this is what remains of it.” us, please.” Another spoke about how, as a Native American, her ancestors had lived in the area for thousands Cost of years living off the land. Yet another said, “You Several people expressed concern that EPA was can’t move a reservation. It’s here. It’s tied to this using cost as a factor in deciding the cleanup land and this environment. And the interest of at the site when the PRP is a “Fortune 500 the Anishinabe people to keep it that way.” Company”.

22 Community Involvement Plan St. Regis Paper Company Superfund Site

Health concerns “I think good minds [are] connected to one Several people at the meeting expressed another, good things can come of it. And if concern about cancer and other illnesses in the people never stop saying, ‘We want a better area and wondered if the contamination could life. We want a better life for our children,’ have been the cause. A woman who identified then it’s going to happen. But it’s not going herself as a former health professional said that to happen unless people like you and me and due to health concerns she was asked to tell you and everybody here stand up and say, children to stay indoors with the windows shut ‘Hey. EPA, pay attention. This is our land; this and felt that the health of the community had is our family; these are our children, and they been compromised. Another person spoke of deserve better than you’re giving them now.” compensating people for their health problems. Local resident There were also comments about exposure to site contamination from dust blowing, people tracking soil into homes and children walking Potential recontamination through the pole yard going to and from school. Several people expressed concern about recontamination of the soil in areas that were Who will do the work already cleaned up. One man questioned Some people had questions about who would why the cleanup was only dealing with the do the cleanup and the testing. They asked residential area. He expressed concern that about the roles and responsibilities of the EPA, the contamination from the industrial areas the state, the Leech Lake Band and the PRP would simply blow back into the residential as far as doing, monitoring or overseeing the area and re-contaminate it after it had been excavation. cleaned up. Others asked if soil monitoring or sampling would be a part of the cleanup. Still Additional issues and concerns another person expressed concern that during • Property values. prior excavation, the PRPs could have brought contamination to the surface and contaminated • Potential of tree damage during soil previously clean soil. removal activities.

Lack of credibility • So-called “hot spot” near Cass Several people questioned how, as one put it, Elementary School. EPA intended to “restore its credibility with the community”. One questioned how credibility • Exposure to potential contaminants in could be restored when the cleanup process had Pike Bay. been taking so long. Another said that people in the community don’t have any faith in the process. Burying of contamination Several expressed concern about how the contamination would be buried. Some concerns included:

• the potential for contamination to leach into the groundwater. • that the onsite containment would create a second “dump” in the community and this was unacceptable. • that taking the contamination elsewhere would “keep the cycle going on and on”.

Community Involvement Plan 23 St. Regis Paper Company Superfund Site

Questions community members 11. How does the soil get contained? Is it in a asked EPA container? Or are you just literally digging a hole and pushing it in. At the August 2016 public meeting, people asked many questions about various issues On-site vs. off-site containment related to the site. This section lists some of 12. If you bury the contamination on the site, those questions. EPA will periodically respond to would it be in a vault? Or, would it be just these and similar issues, questions and concerns buried in the ground and covered? And, by publishing information on its website, fact how do you know that it’s not going to be sheets, and newsletters. leaching into the groundwater in the future?

Contaminants of concern 13. Do you plan on leaving both dumps in this community? 1. Can you elaborate on the mix of chemicals that contaminate the site? 14. Where exactly is the contamination going? To which community? I don’t want to drop 2. What is considered low and high level toxins it off somewhere else and keep the cycle in the eyes of the EPA? going. Proposed Plan 15. Why would the responsible party want to put 3. Why are you only discussing the residential contaminated soil on their property? properties and not the entire contaminated 16. How do you mark the buried contamination area? so that in 30 years somebody doesn’t dig it 4. If you clean up a residential area, but you up? haven’t touched the industrial sites, how are 17. What does putting the contamination on you going to prevent the dust from blowing the site do for the value of the property? back into the area you’ve cleaned up? And what does that do if you want to build 5. I’m wondering why in your proposed plan a home or community garden or a park over you’re not planning to do soil monitoring at there? the completion of this project. Wouldn’t you 18. If you were to move the contamination off- want to make sure that you were successful site -- you were talking about how trucks in getting rid of the toxins in the soil? would be difficult, and that was part of your 6. Would there be any soil monitoring to make reasoning for wanting it to be on-site. Have sure that there isn’t any recontamination of you thought of using trains? the soil after the excavation? Prior cleanup 7. Has the EPA ever looked at a natural remedy? 19. The responsible party has purchased 8. After you clean up this initial area, will the residential properties, knocked down houses, cancer-causing particulates keep blowing and excavated to level the property. This has around the community? caused mixing of the soil. Could that mixing have brought contamination to the surface? 9. How exactly is the EPA going to restore integrity when the Agency’s proposal would Health leave the waste in the community? 20. This contaminated dirt has been blowing all 10. How deep are you going to dig and how will over for years. People were carrying it home you decide how deep to go? Are you still from work on the bottom of their shoes. Kids going to go down two feet? played on it. What effect has the contamination already had on us breathing it in, ingesting it over the years?

24 Community Involvement Plan St. Regis Paper Company Superfund Site

21. What will be the effect on our community 32. How does the fact that this community is with two vaults with toxins in them here? wedged in between the toxic activities of And what’s the life of those toxins? What are two corporations that don’t seem to want we supposed to do? to clean up their mess weigh into your decision? How is that weighed and factored 22. Could contamination from this site be linked in to your “bang for the buck”? to cancer in the area? Tribal standards CERCLA 33. How are you going to deal with this 23. What more do we need to do to make sure community differently since we are not like no one else has to deal with this in twenty or every other site? (The site is on a reservation thirty years? and there are tribal laws and treaties.) 24. Why wasn’t action taken a long time ago? Disclosure 25. What is to prevent International Paper from 34. Are the land owners legally required to declaring bankruptcy and walking away? disclose the contamination? 26. What are the laws that authorize EPA to do Other these cleanups? Explain the relationship between the sampling step and choosing a 35. What are the different ways to incinerate? particular cleanup option in the Superfund process. 36. Is there a hot spot by the Cass Lake Elementary School? And, if so, why aren’t 27. Who does all the testing? Is it EPA or outside you doing something about it? And, if it was agencies? cleaned up, what was done? 28. What are the responsible party’s legal obligations for the project? Does the responsible party oversee the cleanup? The actual excavation process? Or, is that EPA? And, do the Leech Lake Band and the state have the opportunity to continue to monitor the excavation process?

29. We talked about federal and tribal standards. Where are the standards when you consider the health issues the people have had for 50 years? Everybody has lost somebody to cancer, and you ask us to have faith in the government and tribal standards?

30. How did a Superfund site come to be on a reservation? Superfund process 31. Why is there a discussion about getting more “bang for the buck” with a Fortune 500 company that is continuing to poison a poor community? Why is bang for the buck even a discussion in the EPA?

Community Involvement Plan 25 St. Regis Paper Company Superfund Site

26 Community Involvement Plan St. Regis Paper Company Superfund Site 7.0 COMMUNITY INVOLVEMENT GOALS AND ACTIVITIES When establishing the objectives for a site-specific EPA has implemented, or will implement, the community involvement program, EPA considers activities described below to meaningfully and several factors, including federal requirements actively engage the community in decisions and EPA policy that assess the nature and extent regarding the cleanup of the St. Regis site. of known or perceived site contaminants and The following plan is intended to provide known community concerns and requests. opportunities for communication between the community and EPA and to address key To be effective, the community involvement concerns and questions raised during the program must be designed to meet the various community interviews and meetings. community’s need to know, give information in a timely manner and accommodate the community’s interests and its willingness to 7.1 Specific Community participate in decision-making processes. EPA Involvement Activities must also provide information in language the To address community concerns and public can understand. questions described in Sections 5 and 6, EPA has conducted (or will conduct) the activities EPA has set the following objectives for described below. Through these activities, it is community involvement efforts in order to EPA’s goal to inform, involve and engage the meet the needs of the community, respond to community during site cleanup decisions and information obtained during the interviews and efforts. meetings, and meet federal requirements: • Maintain point of contact. Heriberto León is • Enlist the support and involvement of local the primary liaison between EPA and the Cass officials and community leaders Lake community. Mr. León serves as the point • Monitor community interest in the site and of contact for community members and fields respond accordingly general questions about the site. For technical site issues, Mr. León coordinates with EPA’s • Keep the community well informed of remedial project manager for the site, Leslie ongoing and planned site activities Patterson. • Provide follow-up explanations about The EPA has designated two people as primary technical site activities and findings site contacts for local residents:

• Provide opportunities for public comment on Heriberto León, CIC key decisions 312-886-6163 [email protected] • Change planned activities, when warranted, based on community comment Leslie Patterson, RPM 312-886-4904 • Establish a website that provides updates [email protected]

• Hold meetings, when necessary, within They can both also be reached toll-free at 800- the community to give all residents an 621-8431, weekdays 8:30 a.m. to 4:30 p.m. opportunity to attend

Community Involvement Plan 27 St. Regis Paper Company Superfund Site

EPA will include current contact information • Update and maintain the site mailing list. on all written and electronic information and A mailing list that includes local residents, will notify the community of any contact organizations, businesses and officials has information changes. been established for the site. This list will be used for mailing fact sheets, site updates, • Establish a toll-free number for residents invitations to public meetings and events and to ask questions and receive information. other site-related information mailed to the Both Mr. León (ext. 66163) and Ms. Patterson community. The list will be updated regularly (ext. 64904) can be reached at 800-621- to reflect address changes and changes 8431, weekdays from 8:30 a.m. to 4:30 in elected officials and to add new people p.m. Ask for them by name or use the interested in site activities. In addition to the telephone extensions listed in the section site mailing list, EPA sends approximately above. Residents can call this number as 2,600 copies of documents addressed to Box questions or concerns arise. EPA provides Holders and Postal Customers to the Cass Lake this toll-free number in the local newspapers Post Office. The Post Office then distributes advertisements and includes the toll-free the pieces of mail to those receptacles. EPA number in all fact sheets and all other EPA will also establish an e-mail list and provide communications with the public. regular updates as appropriate.

• Prepare and distribute a community EPA uses the site mailing list and Box Holder newsletter 1-2 times per year. EPA will and Postal Customer distribution to send publish a newsletter with articles about site- written information such as fact sheets related issues and persons. The newsletter and meeting notifications. This is a way to will be written in non-technical language ensure that those who do not have access describing upcoming activities, answering to the Internet or other information sources common questions or explaining ongoing site still have a way to receive information work or decisions. The newsletter is distributed directly about the site and be notified about to those on the site mailing and e-mail lists. In important meetings. Community members addition, newsletters are also placed in several interested in being placed on either mailing community locations, including the City Clerk’s list may contact Heriberto León, CIC. Office, Teal’s Supervalu and the Leech Lake Band DRM Office. Copies will be placed in the • Prepare and distribute fact sheets and information repository and posted on EPA’s site updates: Fact sheets, letters and site website: www.epa.gov/superfund/st-regis- updates summarizing current information paper. about the site and describing upcoming activities may be prepared and distributed • Maintain communication with local officials, to those on the site mailing and e-mail agencies and community residents. EPA has lists. These documents are written in non- heard from local officials and residents from the technical language and typically done to city of Cass Lake in addition to other interested coincide with important site activities. people, and we’ll continue to maintain communication with everyone throughout the EPA uses these types of documents to Superfund cleanup process. The Cass Lake City provide the community with detailed Clerk receives electronic copies of all releasable information in a relatively quick, simple and site documents. easy-to-understand manner. In addition to being distributed to individuals on the site • Provide site information on the Internet mailing lists, fact sheets and site updates are EPA has established a website for the St. also placed in the information repository Regis site that is updated as events occur: and posted on EPA’s website: www.epa.gov/ www.epa.gov/superfund/st-regis-paper. superfund/st-regis-paper.

28 Community Involvement Plan St. Regis Paper Company Superfund Site

• Maintain five site-specific information A public hearing is a formal meeting where repositories. EPA has set up four local EPA officials hear the public’s views and information repositories (see Appendix B for concerns about an EPA action or proposal. locations) and maintains one at the Chicago There are specific regulations about when Regional Office Superfund Records Center. EPA is required to consider such comments The repository is a reference collection of when evaluating its actions. Public hearings site information available to the public for are recorded by a professional transcriber reading and photocopying. Documents and become part of the administrative include fact sheets, technical reports, the CIP, record. The comments are also posted on general Superfund information and other the EPA website. documents. EPA adds new documents about the site as they become available. Information EPA has held public meetings and repositories provide residents with local availability sessions (see Table 1: Site access to site information in forms that can be History on Pages 8-10) to present site- easily read and photocopied for future use. specific information and ask for community comments. Additional meetings and/ • Maintain the administrative record. A or information sessions will be held as copy of the Administrative Record for warranted throughout the various steps of the St. Regis site will be found at the the cleanup process. information repositories and at the EPA Region 5 Superfund Record Center in • Write and distribute news releases and Chicago (see Appendix B). EPA will update public notices: EPA will prepare and release the Administrative Record as necessary. The announcements to local newspapers such Administrative Record provides residents as the Cass Lake Times, Daily Pioneer or the with a paper trail of all documents EPA relied DiBahjiMon to provide information about on, or considered, to reach decisions about events such as significant site investigation the Superfund site cleanup. findings, completion of major milestones, significant scheduling information and other • Conduct public meetings, hearings and pertinent site-related information. information sessions: A public meeting provides an opportunity for EPA to present News releases allow EPA to reach large specific information and a proposed course audiences quickly. They will also be posted of action. EPA staff is available to provide on EPA’s website, www.epa.gov/superfund/ information and answer questions. A public st-regis-paper. EPA typically publishes news meeting is not a formal public hearing releases and public notices to announce where testimony is received. Generally it major events such as comment periods, is a meeting to exchange information or public meetings and major milestones such comments. In addition, EPA may hold an as the selection of a cleanup plan. informal open-house style meeting, called EPA will issue news releases and public availability sessions, where residents can notices as site activities progress. Copies meet EPA experts one-on-one to discuss of the news releases and public notices the activities at the site. Either type of will also be available in the Information meeting provides community members with Repositories and on the EPA website. an opportunity to express their concerns and ask questions of EPA, state or local • Solicit community comment during government officials. Public meetings or public comment periods. EPA holds availability sessions can be held at various public comment periods to give community times throughout the investigation and members an opportunity to review and cleanup process. A meeting is typically comment on key decisions. Before EPA scheduled when there are technical selects a final cleanup plan for the St. Regis milestones or the community has expressed site, the Agency will hold a public comment an interest in having a meeting. period to allow interested residents an

Community Involvement Plan 29 St. Regis Paper Company Superfund Site

opportunity to review and comment on help the Agency set the objectives for our its proposed plan. EPA will consider the community involvement program and community’s comment before selecting a activities going forward. EPA recognizes final cleanup plan. Comments made during that changes in areas such as community this period may affect EPA’s decision in the perceptions, information needs and final plan. EPA’s response to public comments population demographics can occur over will be summarized in a document called a time and that such changes may necessitate responsiveness summary, which will be a revised approach to conducting placed in the site information repository and community involvement activities. For this made available on EPA’s website. reason as well as to determine whether the activities in this plan are achieving their • Evaluate community involvement and intended objectives, periodic reviews will outreach efforts and make adjustments be done to determine whether additional as warranted. This CIP was designed to activities are warranted or whether changes consider site- and community-specific to current methods of implementing the factors as well as to comply with federal activities outlined in this plan are necessary. requirements. The information and the list of community concerns gathered during our 2012 and 2016 interviews and public meetings with the public and officials

7.2 Timeframe for Conducting Community Involvement Activities The following table presents the general timeframe for the activities described in Section 7.1.

Table 2: Schedule of Community Involvement Activities Community Involvement Activities Timeframe Maintain point of contact Complete Establish a toll-free number Complete; published in site written materials Maintain communication with local officials, Ongoing as needed agencies, and community residents Share site information on the Internet Completed; update as needed

Update and maintain the site mailing list Completed; update as needed

Prepare and distribute fact sheets and site Ongoing as needed updates Establish and maintain a site-specific information Completed; update as needed repository Establish and maintain the administrative record Completed; update as needed Conduct public meetings, hearings and Ongoing as needed information sessions Write and distribute news releases and public Ongoing as needed notices Solicit community input during public When proposed cleanup plan is completed comment periods Evaluate community involvement and outreach Periodically throughout the cleanup process efforts and make adjustments as warranted

30 Community Involvement Plan St. Regis Paper Company Superfund Site APPENDIX A Glossary – Initials - Acronyms

Administrative Record. The body of documents Community Engagement. The process of that forms the basis for the selection of a involving communities in all phases of the particular response at a site. For example, the cleanup process. Communities are asked to Administrative Record for remedy selection provide comment on how the cleanup will be includes all documents that were considered conducted and how it may affect community or relied on to select the remedy through the plans and goals. See also Community record of decision. Involvement.

Administrative Order on Consent. A legal Community Involvement. The term used by agreement signed by EPA and an individual, the EPA to identify its process for engaging in business, or other entity through which the dialogue and collaboration with communities violator agrees to pay for correction of violations, affected by Superfund sites. The EPA community take the required corrective or cleanup actions, involvement approach is founded in the belief or refrain from an activity. It describes the actions that people have a right to know what the to be taken, may be subject to a comment Agency is doing in their community and to period, applies... to civil actions, and can be have a say in it. Its purpose is to give people the enforced in court. Unlike a consent decree, an opportunity to become involved in the Agency’s administrative order on consent does not have to activities and to help shape the decisions that be approved by a judge. are made.

Arsenic. Arsenic is an element and a naturally Community Involvement Coordinator. occurring mineral found widely in the The EPA official whose lead responsibility is environment. Prolonged arsenic exposure causes to involve and inform the public about the skin and lung cancer and may cause other Superfund process and response actions in internal cancers as well. accordance with the interactive community involvement requirements set forth in the CERCLA. See Comprehensive Environmental National Oil and Hazardous Substances Response, Compensation and Liability Act. Pollution Contingency Plan.

CIC. See Community Involvement Coordinator. Community Involvement Plan. A plan that outlines specific community involvement CIP. See Community Involvement Plan. activities that occur during the investigation and cleanup at the site. The CIP outlines how EPA Cleanup. Actions taken to deal with a release or will keep the public informed of work at the site threat of release of a hazardous substance that and the ways in which residents can review and could affect humans and/or the environment. comment on decisions that may affect the final The term “cleanup” is sometimes used actions at the site. The document is available in interchangeably with the terms “remedial action,” the site’s information repository maintained by “remediation,” “removal action,” “response action” the EPA. The CIP may be modified as necessary or “corrective action.” to respond to changes in community concerns, information needs and activities. Community. An interacting population of various types of individuals (or species) in a common location; a neighborhood or specific area where people live.

Community Involvement Plan A-1 St. Regis Paper Company Superfund Site

Comprehensive Environmental Response, Information Repository. A file containing Compensation, and Liability Act. A federal current information, technical reports and law passed in 1980 and modified in 1986 by the reference documents regarding a site. The Superfund Amendments and Reauthorization information repository usually is located in a Act. Commonly known as Superfund, CERCLA public building convenient for local residents is intended to protect people’s health and the such as a public school, town hall or library. environment by investigating and cleaning up abandoned or uncontrolled hazardous waste National Priorities List. The EPA’s list of serious sites. Under the program, the EPA can either: uncontrolled or abandoned hazardous waste sites identified for possible long-term cleanup • Pay for site cleanup when parties responsible under Superfund. The list is based primarily on for the contamination cannot be located or the score a site receives from the Hazard Ranking are unwilling or unable to do the work; or System. The EPA is required to update the NPL at least once a year. • Take legal action to force parties responsible for site contamination to clean up the site or NPL. See National Priorities List. pay back the federal government for the cost of the cleanup. Operable Unit. Term for each of a number of separate activities undertaken as part of a Contaminant. Any physical, chemical, biological Superfund site cleanup. or radiological substance or matter that has an adverse effect on air, water, or soil. OU. See Operable Unit.

Contamination. Introduction into water, air and PA/SI. See Preliminary Assessment and Site soil of microorganisms, chemicals, toxic substances, Investigation. wastes or wastewater in a concentration that makes the medium unfit for its next intended use. PAHs, or polycyclic aromatic hydrocarbons. Also applies to surfaces of objects, buildings and PAHs are a group of organic contaminants various household use products. that form from the incomplete combustion of hydrocarbons, such as coal and gasoline. PAHs Dioxin. A group of harmful chemical compounds generally occur as complex mixtures and not as that are released into the air from combustion single compounds. PAHs are an environmental processes such as commercial or municipal concern because they do not break down easily, waste incineration and from burning fuels such are toxic to aquatic life and build up in humans as wood, coal, or oil. and animals. Several PAHs are suspected to cause cancer in humans. Hazardous Substance. Any material that poses a threat to human health and/or the environment. PCP, or pentachlorophenol. Harmful chemical Typical hazardous substances are toxic, corrosive, that can damage the central nervous system, ignitable, explosive or chemically reactive. Any cardiovascular system, respiratory system, liver substance designated by the EPA to be reported and kidneys and may cause death, reproductive if a designated quantity of the substance is impairment, organ damage and retarded growth spilled in the waters of the United States or is in mammals. otherwise released into the environment. Pentachlorophenol. See PCP Hazardous Waste. Byproducts that can pose a substantial or potential hazard to human health Polycyclic Aromatic Hydrocarbons. See PAHs. or the environment when improperly managed. Hazardous wastes usually possess at least one of four characteristics (ignitability, corrosivity, reactivity or toxicity) or appear on special EPA lists.

A-2 Community Involvement Plan St. Regis Paper Company Superfund Site

Potentially Responsible Party. An entity, RD/RA. See Remedial Design/Remedial Action. individual or company (e.g., an owner, operator, transporter, or generator of hazardous Remedial Design/Remedial Action. Remedial waste) that is potentially responsible for the design is a phase in the CERCLA response contamination problems at a Superfund site. process in which technical drawings are Whenever possible, EPA requires PRPs to clean up developed for the chosen remedy, costs for hazardous waste sites they have contaminated. implementing the remedy are estimated, and roles and responsibilities of EPA, states, and Preliminary Assessment and Site Investigation. contractors are determined. During the remedial The PA/SI is the process of collecting and action phase, the remedy is implemented reviewing available information about a known or generally by a contractor, with oversight and suspected hazardous waste site or release. The PA/ inspection conducted by EPA or the state (or SI usually includes a visit to the site. both).

Proposed Plan. A plan for a site cleanup that is Remedial Investigation/Feasibility Study. A available to the public for comment. study designed to collect the data necessary to determine the nature and extent of PRP. See Potentially Responsible Party. contamination at a site. The second part of a two-part study called an RI/FS. The feasibility Public Comment Period. A formal opportunity study involves identifying and evaluating for community members to review and the most appropriate technical approaches contribute written comments on various EPA to addressing contamination problems at documents or actions. a site. Alternatives are evaluated for their effectiveness in protecting human health and Public Hearing. A public hearing is a special the environment. type of public meeting. The sole purpose of a public hearing is to provide an opportunity for Remedial Project Manager. The EPA official the public to make comments on a proposed who is the technical lead on a project. agency decision. A court reporter records all remarks made during the hearing and prepares Resource Conservation and Recovery Act. an official transcript of the proceeding. It is not a This law was passed in 1976 and is the principal question and answer session. Federal law governing the disposal of solid and hazardous waste. Public Meeting. Formal public sessions that are characterized by a presentation to the public Responsiveness Summary. A summary of followed by a question-and-answer session. oral and/or written public comments received by EPA during a comment period on key EPA Public. The community or people in general documents and EPA’s responses to those or a part or section of the community grouped comments. because of a common interest or activity. RI/FS. See Remedial Investigation/Feasibility RCRA. See Resource Conservation and Recovery Act. Study.

Record of Decision. A ROD is a legal, technical, ROD. See Record of Decision. and public document that explains which cleanup alternative will be used at a Superfund NPL site. The ROD is based on information and technical analysis generated during the remedial investigation and feasibility study (RI/ FS) and consideration of public comments and community concerns.

Community Involvement Plan A-3 St. Regis Paper Company Superfund Site

Superfund. The program operated under the legislative authority of CERCLA that funds and carries out EPA solid waste emergency and long-term removal and remedial activities. These activities include establishing the NPL, investigating sites for inclusion on the list, determining their priority and conducting and/or supervising cleanup and other remedial actions. See also CERCLA.

UAO. See Unilateral Administrative Order.

Unilateral Administrative Order. A legal document issued by EPA directing a potentially responsible party to perform site cleanup. A UAO sets forth the liabilty of the party for the cleanup, describes actions to be taken, and subjects the recipient to penalties and damages for noncompliance. Unilateral orders may be enforced in court. A UAO is EPA’s most potent enforcement tool and a powerful settlement incentive. EPA usually only issues them to parties that are the largest contributors of waste to a site, are financially viable, and against whom there is strong evidence of liability.

A-4 Community Involvement Plan St. Regis Paper Company Superfund Site APPENDIX B COMMUNITY RESOURCES Information Repositories with Administrative Records, Website and Public Meeting Locations

Local Information Repository Leech Lake Band of Ojibwe Division of Resource Management 6350 Highway 2 NW Cass Lake, MN

Cass Lake City Clerk’s office 330 2nd St. NW Cass Lake, MN

Cass Lake Library 223 Cedar Ave. Cass Lake, MN

Leech Lake Tribal College 113 Balsam Ave. Cass Lake, MN Official Information Repository EPA Region 5 Superfund Record Center Room 711, 7th Floor Ralph Metcalfe Federal Building 77 W. Jackson Blvd. Chicago, IL 60604

EPA Site Web Page www.epa.gov/superfund/st-regis-paper Possible Meeting Locations Cass Lake-Bena Elementary School 15 4th Street NW Cass Lake, MN 56633 218-335-2201 Note: The elementary school has poor acoustics, but no other appropriate rooms of sufficient size have been identified.

Community Involvement Plan B-1 St. Regis Paper Company Superfund Site

B-2 Community Involvement Plan St. Regis Paper Company Superfund Site APPENDIX C LIST OF CONTACTS (Current as of September 2016)

U.S. EPA Region 5 Project Contacts

Heriberto León Leslie Patterson Community Involvement Coordinator Remedial Project Manager Superfund Division (SI-7J) Superfund Division (SR-6J) 77 W. Jackson Blvd. 77 W. Jackson Blvd. Chicago, IL 60604-3590 Chicago, IL 60604-3590 312-886-6163 312-886-4904 800-621-8431, ext. 66163 800-621-8431, ext. 64904 [email protected] [email protected]

Agency for Toxic Substances and Disease Registry

Mark Johnson ATSDR 77 West Jackson Blvd. (ATSDR-4J) 312-353-3436 [email protected]

Federal Elected Officials

Senator Al Franken Senator Amy Klobuchar 60 East Plato Blvd., Suite 220 121 4th Street South Saint Paul, MN 55107 Moorhead, MN 56560 651-221-1016 218-287-2219

309 Hart Senate Office Building 302 Hart Senate Office Building Washington, D.C. 20510 Washington, D.C. 20510 202-224-5641 202-224-3244 www.franken.senate.gov/?p=contact www.klobuchar.senate.gov/public/contact-amy

Representative Rick Nolan 8th Congressional District Duluth Technology Village 11 E. Superior Street #125 Duluth, MN 55802 218-464-5095

2447 Rayburn House Office Building Washington, DC 20515 202-225-6211 https://nolan.house.gov

Community Involvement Plan C-1 St. Regis Paper Company Superfund Site

Leech Lake Band of Ojibwe

Administration Office Division of Resource Management 115 Sixth Street NW (Physical Address) 15756 State 371 NW Cass Lake, MN 56633 Cass Lake, MN 56633 218-335-8200 Rich Robinson 800-442-3909 Director http://www.llojibwe.com/ 218-335-7410 Levi Brown 190 Sailstar Drive Environmental Protection Department Director Cass Lake, MN 56633 (Mailing Address) 218-335-7417 John Persell Superfund Program Director 218-335-7412

LLBO Tribal Council Members Faron Jackson, Sr. Tribal Chairman Arthur LaRose Secretary/Treasurer Penny DeVault District I Representative Steve White District II Representative LeRoy Staples Fairbanks III District III Representative

State Elected Officials

Governor Mark Dayton State Senator Tom Saxhaug Office of the Governor District 05 130 State Capitol 95 University Ave. W 75 Rev. Dr. Martin Luther King Jr. Blvd. Minnesota Senate Building, Room 2111 St. Paul, MN 55155 St. Paul, MN 55155 651-201-3400 651-296-4136 http://mn.gov/governor/contact-us/form/ [email protected]

State Representative John Persell District: 05A 2435 Staghorn Lane Bemidji, MN 56601 218-751-2770

359 State Office Building 100 Rev. Dr. Martin Luther King Jr. Blvd. St. Paul, MN 55155 651-296-5516 [email protected]

C-2 Community Involvement Plan St. Regis Paper Company Superfund Site

Local Officials

City of Cass Lake 330 2nd Street NW Cass Lake, MN 56633 218-335-2238

Wayne LaDuke Sue Uhrinak Mayor Clerk - Treasurer

City of New Carlisle Council Members

Wayne Bohn George Donnell Lenny Fineday Scott Reimer

State Agencies

Minnesota Pollution Control Agency Minnesota Department of Health 525 S. Lake Avenue, Suite 400 PO Box 64975 Duluth, MN 55802 St. Paul, MN 55164-0975 218-723-4660 651-201-5000 888-345-0823 Kevin Mustonen, Project Leader 218-725-7762 Rita Messing [email protected] 651-201-4096

Mark Elliott, Hydrogeologist Daniel Peña 218-302-6649 651-201-4920 [email protected] Ginny Yingling [email protected]

Bemidji Office 705 5th Street NW, Suite A Bemidji, MN 56601 218-308-2100

Community Involvement Plan C-3 St. Regis Paper Company Superfund Site

Newspapers

Bemidji Pioneer DeBahJiMon PO Box 445 115 Sixth Street NW, Suite E Bemidji, MN 56619 Cass Lake, MN 56633 218-333-9200 218-335-8225 http://www.bemidjipioneer.com/ [email protected] http://www.llojibwe.com/news/news.html

The Cass Lake Times PO Box 398 Cass Lake, MN 56633 218-335-2290 http://www.lakeandpine.com/

Radio Stations

Strongest AM radio stations in Cass Lake: • KKBJ (1360 AM; 5 kW; BEMIDJI, MN; Owner: R.P. BROADCASTING) • KPRM (870 AM; 25 kW; PARK RAPIDS, MN; Owner: DE LA HUNT BROADCASTING CORP.) • WEBC (560 AM; 50 kW; DULUTH, MN) • WWNL (1080 AM; 50 kW; PITTSBURGH, PA; Owner: STEEL CITY RADIO, INC.) • KBUN (1450 AM; 1 kW; BEMIDJI, MN; Owner: PAUL BUNYAN BROADCASTING CO.) • WNMT (650 AM; 10 kW; NASHWAUK, MN; Owner: MIDWEST RADIO NETWORK, L.L.C.) • WCCO (830 AM; 50 kW; MINNEAPOLIS, MN; Owner: INFINITY MEDIA CORPORATION) • KAKK (1570 AM; 1 kW; WALKER, MN) • WCTS (1030 AM; 50 kW; MAPLEWOOD, MN; Owner: CNTL. BAPT. THEO/AL SEMIMINNEAPOLIS) • KOZY (1320 AM; 5 kW; GRAND RAPIDS, MN; Owner: ITASCA BROADCASTING, INC.) • KKCQ (1480 AM; 5 kW; FOSSTON, MN; Owner: PINE TO PRAIRIE BROADCASTING, INC.) • KFAN (1130 AM; 50 kW; MINNEAPOLIS, MN; Owner: AMFM RADIO LICENSES, L.L.C.) • KSTP (1500 AM; 50 kW; ST. PAUL, MN; Owner: KSTP-AM, LLC (DELAWARE))

Strongest FM radio stations in Cass Lake: • KOJB (90.1 FM, The Eagle; OWNER: LEECH LAKE RESERVATION) • KKZY (95.5 FM; BEMIDJI, MN; Owner: BG BROADCASTING INC.) • KBHP (101.1 FM; BEMIDJI, MN; Owner: PAUL BUNYAN BROADCASTING CO.) • KCRB-FM (88.5 FM; BEMIDJI, MN; Owner: MINNESOTA PUBLIC RADIO) • KNBJ (91.3 FM; BEMIDJI, MN; Owner: MINNESOTA PUBLIC RADIO) • WBJI (98.3 FM; BLACKDUCK, MN; Owner: R.P. BROADCASTING, INC.) • KKBJ-FM (103.7 FM; BEMIDJI, MN; Owner: R.P. BROADCASTING, INC.) • KBLB (93.3 FM; NISSWA, MN; Owner: BL BROADCASTING, INC.) • KLLZ-FM (99.1 FM; WALKER, MN; Owner: BG BROADCASTING, INC.) • KQKK (101.9 FM; WALKER, MN; Owner: CAROL J. DELAHUNT)

Source: http://www.city-data.com/city/Cass-Lake-Minnesota.html

C-4 Community Involvement Plan St. Regis Paper Company Superfund Site

Television Stations

TV broadcast stations around Cass Lake: • KAWE (Channel 9; BEMIDJI, MN; Owner: NORTHERN MINN. PUBLIC TELEVISION, INC.) • K28DD (Channel 28; BEMIDJI, MN; Owner: , INC.) • K30DK (Channel 30; BEMIDJI, MN; Owner: FOX TELEVISION STATIONS, INC.) • KFTC (Channel 26; BEMIDJI, MN; Owner: FOX TELEVISION STATIONS, INC.) • KCCW-TV (Channel 12; WALKER, MN; Owner: CBS BROADCASTING INC.) • K65DT (Channel 65; WALKER, MN; Owner: LEECH LAKE TV CORPORATION) • K67BZ (Channel 67; WALKER, MN; Owner: LEECH LAKE TV CORP.) • K69CP (Channel 69; WALKER, MN; Owner: LEECH LAKE TV CORP.) • K32FY (Channel 32; PARK RAPIDS, MN; Owner: HUBBARD BROADCASTING, INC.) • K49CU (Channel 49; WALKER, MN; Owner: FOX TELEVISION STATIONS, INC.) • K78AK (Channel 78; CASS LAKE, MN; Owner: BLUE GRASS TELEVISION, INC.)

Source: http://www.city-data.com/city/Cass-Lake-Minnesota.html

Community Involvement Plan C-5