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an aerial photo of water, land, and a small island
Aerial photo of the U.S. Steel site taken last year during sediment remediation, with Spirit Island in the foreground. (1854 Treaty Authority)

Trustees Seek Public Comment on a Draft Natural Resource Damage Assessment Plan for the U.S. Steel Site in Duluth, Minnesota

February 6, 2023

NOAA and other federal, state, and tribal natural resource Trustees have released a Draft Damage Assessment Plan (PDF, 67 pages) for the U.S. Steel site in Duluth, Minnesota, and are soliciting public comments. 

The draft plan describes studies and data analysis the trustees may conduct to determine the nature and scale of injuries to natural resources from releases of hazardous wastes at the site. 

Additionally, the plan provides:

  • the history of operations and pollution releases at the site
  • the types of natural resources that may have been and may continue to be injured as a result of the contamination
  • the types of recreational and tribal cultural uses of natural resources that may have been or continue to be affected

Damage assessment planning is one step in determining the types and amounts of natural resource restoration needed to compensate for ecological harm caused by pollution and the loss of human uses of natural resources.

Site History and Remedial Cleanup

Historical waste discharges from the site have contaminated natural resources including surface water and sediment, soils, biological resources (fish, aquatic invertebrates, and terrestrial wildlife), and groundwater resources. Elevated concentrations of hazardous substances released from the Site have been found in these resources at concentrations sufficient to potentially cause injury.

Investigation at and cleanup of the U.S. Steel site has taken place over many years. Most recently, the U.S. Environmental Protection Agency, under the Great Lakes Legacy Act, partnered with U.S. Steel on the cleanup of sediments in Spirit Lake and other contaminated aquatic areas at the site. 

Cleanup is largely complete as of 2023; cleanup of remaining land areas of the site remains under the oversight of the Minnesota Pollution Control Agency.

Natural Resource Damages

Natural resource damage assessment, or NRDA, is separate from and in addition to the cleanup of hazardous waste sites. In conducting NRDA, Trustee agencies seek to restore injured natural resources, compensate for lost ecological services they would have provided had there not been contaminant releases, and compensate the public for lost or diminished human uses of natural resources as well. 

Natural resources include many parts of the natural environment including water, sediment, fish, birds, and mammals. Human uses include the loss or impairment of recreational opportunities, such as boating; and adverse effects on natural resource-based tribal cultural uses. 

In this geography, cultural losses impact the Anishinaabe (Ojibway) tribe. Spirit Lake and Spirit Island in particular are central to the Anishinaabe (Ojibway) migration story. Spirit Island is a culturally significant location where ceremonies and other traditions are practiced to this day.

Recent Developments

In 2020 the Natural Resource Trustees completed a Pre-Assessment Screen, necessary for determining if a natural resource damage assessment is needed; U.S. Steel agreed to cooperate with the Trustees on the NRDA assessment. Before the site sediment was cleaned up, the Trustees were able to complete a study on the toxicity of the site sediment to invertebrate biota by collecting and analyzing contaminated sediment. The sediment toxicity study report will be available on NOAA's website for this case by mid-February 2023.

Additional potential NRDA analyses and studies are described in the Draft Natural Resource Damage Assessment Plan, which is available for public review and comment through March 23 2023. Upon the close of the public comment period, the Trustees will consider comments and issue a final Assessment Plan, including responses to comments received.

How to Submit Comments

To submit comments on the draft assessment plan electronically:

  • Email them to Ms. Reena Bowman at
  • Or mail them to:

    Ms. Reena Bowman
    U.S. Fish & Wildlife Service
    3815 American Blvd. East
    Bloomington, MN 55425

All comments should be submitted to the email or mailing address above before the March 23, 2023 comment deadline.