National Steel is monitoring the system to ensure that no
future releases occur. Clean-up activities are expected to
be completed in the near future. In the meantime, nature
has taken over. The areas that once contained hazardous
waste are developing the characteristics of natural dunes,
with the potential forthe threatened Pitcher's thistle species
to return to the area.
  For more information, you may write to:
  U.S. EPA Region 5,
  Office of Public Affairs P-19J
  77 West Jackson Boulevard
  Chicago, Illinois 60604

  or call: (800) 621-8431
  830a.m. - 4:30p.m. Central
                                                          United States
                                                          Environmental Protection
                                                          Agency
                                                          Region 5	
                              EPA/905/F-94/004
                              Revised
                              October 1994
                                                          Off ice of RCRA
                                                 &EPA A Hazardous
                                                          Waste  Cleanup
                                                          In  The  Dunes:
                                                          A Success
                                                          Story
Overview
The U.S. Environmental Protection Agency (EPA) has
served as the public's advocate for a livable environment
throughout its 23-year history. The EPA is divided into 10
regions. Region 5 consists of six of the Great Lakes states,
including Indiana. With its Northwest Indiana Initiative,
Region 5 has focused on the environmental impact of the
steel-making industry on the shores of Lake Michigan
because 40 percent of the Nation's steel making capacity
is located there. Steel operations generate hazardous and
non-hazardous wastes.  The past  hazardous waste
management practices of the steel industry have adversely
affected the environment. However, cooperation between
the Agency, the Indiana Department of Environment
Management (IDEM), the public, and industry partners
like National Steel Corporation's Midwest Division have
resulted in positive, tangible benefits to the environment.

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Environmental Perspective
The dunes' unique ecology began in the Ice Age when
diverse species deposited their seeds. This resulted in the
unique combination of arctic and desert plants which
exists on the dunes today. Sandy beaches were created
when Lake Michigan was formed by a glacier.  Dunes
were formed  by wind and waves.

Sand accumulates against rocks, trees, and other stationary
objects to create miniature dunes. As a dune increases in
size, plants establish roots,and serve as natural barriers to
the wind and waves, preventing erosion,and maintaining
the shape of the dune.

However, wind not only helps create and shape a dune,
but can destroy one as well. Blowout areas begin as small
channels or gaps created by wind in a preexisting dune.
The gap enlarges until it looks like an amphitheater. This
rapid removal of sand eventually strips the dune of most
of its vegetation.
  Dunes develop in sequence, with each sequence of dunes
  exhibiting distinct types of plant and animal life. As plants
  grow and die on a dune, they influence the other forms of life
  in that area. This process is called "succession." As a result,
  a  location's plants and  animals  are often  replaced by
  completely different species.

  The fragile dune ecosystem can be adversely affected by the
  forces of nature and the actions of humans.  The activities of
  humans who trample the dunes and deposit wastes,adversely
  affect dune vegetation and animal life.

  The dunes serve as home for many rare, threatened, and
  endangered species of plants  and animals.  Twenty-six
  percent of the endangered or threatened plants in Indiana are
  found at the dunes.  For example, the threatened plant
  species Pitcher's thistle grows in some blowout areas of the
  dunes and the  endangered Karner blue butterfly  can be
^ spotted in some of the wooded dunes.

  The Endangered Karner  Blue  Butterfly
  The geographic area in which the Karner blue butterfly lives
  generally follows the growth of the wild lupine plant because
 ,the wild lupine is the sole known  source of food  for the
  larvae.  The Karner blue butterfly's habitat in the Midwest
  includes Black Oak Savanna and Jack Pine stands. Females
  lay their eggs on the wild lupine plants twice a year, during
  the spring and during the summer. The larva hatch and feed
  on the surfaces of the lupine plants until they are mature.
  Adult butterflies have an average life span of five to seven
  days.

  At this time, the Karner blue butterfly is believed to be
  extirpated in Illinois, and extinct in Ohio, Massachusetts,
  Pennsylvania, and Ontario.  The species is endangered in
  New York, New  Hampshire, Wisconsin, Minnesota,
  Michigan, and Indiana. Over the past 100 years, the Karner
  blue butterfly's population has decreased drastically by
  99% (90% of this decrease occurring within the past 10 to
  15 years). Because of industrial, residential, and commercial
  activity, the butterfly's habitat is  declining.  In addition,
  buildings and other man-made structures act as effective
  barriers to the migration of the butterfly.

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Historical Perspective
By 1900, the United States led the world in the production
of iron and steel. In 1901, Inland Steel Corporation became
the first of many steel facilities to bring its operations to the
southern shores of Lake Michigan. The American steel
industry developed in this area for three important reasons:
     • The Great Lakes provided ideal transportation
      routes;
     • Michigan, Minnesota, and Wisconsin contained
      vast supplies of iron ore deposits; and
     • The American railroads expanded westward

Steel Finishing
Two types of steel plants are commonly  operated: steel-
production  facilities and steel-finishing plants.   Steel-
finishing facilities like National Steel's Midwest Division
treat coils of sheet steel with hydrochloric acid to remove
surface imperfections from manufacturing, a process called
"pickling."  After the steel sheets have been treated with
acid, they are "galvanized" with a protective coating of tin,
chrome, or zinc to prevent corrosion.

Pickling operations  generate hazardous  wastewater.
Generally, wastewater contains hazardous constituents like
metals. In the past, hazardous wastewater was discharged
into large, unlined pits called "lagoons." In the lagoons,
the heavier particles in the wastewater  settled to the
bottom and the liquids either evaporated or leached into
the ground over a period of several months, creating
sludge.  Sludge generated at National  Steel's Midwest
Division  is classified as a hazardous waste because  it
contains a high concentration of metals.  When the sludge
was dry, it was excavated from the lagoons and disposed
of in the onsite hazardous waste landfill. Years later, the
adverse effects on  the environment from  this  waste
management practice became evident.

Citizens concerned about the effect of industrial activity
near the  dunes  and  the surrounding fragile ecosystem
organized conservation  groups.  One such organization
was the Save the Dunes Council. As a result of its efforts,
and the efforts of Indiana Senator Paul Howard Douglas,
Federal laws were passed which created the Indiana Dunes
National Lakeshore and authorized the  purchase  of
additional land.

What  are the  Closure and  Corrective
Action Programs?
In an effort to promote the protection of human health and
the environment, and  to conserve valuable natural
resources, Congress passed laws enforcing the management
of •solid and hazardous wastes.

Congress passed the Resource Conservation and Recovery
Act (RCRA) in 1976, establishing a national hazardous
waste management program for companies that generate,
store, treat, dispose of, or transport hazardous waste. The
program provides  for appropriate hazardous  waste
management practices from the time a waste is generated
|o the time it is disposed.  This is known as "cradle-to-
grave" management.

Since 1976, RCRA has been amended several times, most
significantly by the  Hazardous and  Solid Waste
Amendments (HS WA) of 1984. HS WA created a program
to identify and contain or clean up uncontrolled chemical
releases from facilities,  including releases which extend
beyond the facility's boundaries. This process is known as
RCRA Corrective Action.

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The RCRA Corrective Action program has the following
objectives:
  • Determining whether a release of hazardous
   waste or hazardous constituents has occurred;
  • Evaluating the nature, rate, and extent of any
   releases;
  • Developing methods to remediate or contain
   releases; and
  • Designing, building, and monitoring cleanup
   methods or containment devices and preventing
   future releases.

HSWA also established minimum design requirements
for hazardous waste management units to prevent releases
of hazardous waste to the environment. Facilities were
required, as of November 8,1988, to either redesign land
disposal units to meet the minimum requirements or close
the units according to the existing standards.

The RCRA Closure and Corrective Action programs are
cooperative efforts between  EPA, IDEM, and  industry.
EPA and IDEM help industry select and design the most
appropriate method to clean up the environment and close
a unit. Implementation of the remediation process is a
joint activity. Industry performs the remediation while
EPA and IDEM oversee the operation.

National Steel's Midwest Division, EPA, and IDEM are
trying to achieve the goals  of the RCRA Corrective
Action and Closure programs.
A Hazardous Waste Cleanup Success Story
In 1960, National Steel's Midwest Division facility bej
operating  as a finishing plant for rolls of sheet st
manufactured at steel-production factories. National Steel's
Midwest Division is located in Portage, Indiana.

Until 1988, National Steel discharged its treated wastewater
to five "lagoons" to concentrate the waste into sludge. The
dried  sludge was then  removed from the lagoons and
transferred to an onsite hazardous waste landfill.  In  1988,
the facility decided to stop using the lagoons instead
retrofitting them with the minimum required technology tc
prevent releases.  Since then, National Steel has used
mechanical device that dries the sludge more quickly and
efficiently than the lagoons.  National Steel is working with
EPA and IDEM to close  three of the five lagoons.

On November 7,1988, EPA issued National Steel a RCJ
land-disposal operating permit for its onsite hazardous waste
landfill. EPA included RCRA Corrective Action provisions
which required  the facility to determine  the  extent of
contamination at the other two lagoons and develop a method
to clean up the dune environment. EPA determined that a
release of hazardous constituents had likely occurred into
the surrounding dune environment from the unlined lagoons.
To clean up the area, National Steel removed almost 400,000
cubic yards of sludge and underlying contaminated soil from
four of the five lagoons and placed it in the onsite landfill.

The sludge almost filled the onsite landfill.  In order to
complete clean-up activities, National Steel had to apply to
EPA and IDEM for a permit to expand  the onsite landfill.
EPA  and  the  U.S. Fish and Wildlife Service (USFWS)
determined that the planned landfill expansion threatened a
habitat of the endangered Karner blue butterfly.   EPA,
IDEM, USFWS  and National Steel, in cooperation with
local  community groups, worked out an arrangement to
create a conservation area for the butterfly.

In early 1993, the facility relocated wild lupine plants from
the landfill-expansion area to a 45-acre site on the west side
of the facility, next to National Park Service land. By the end
of  1993,  a population  of  Karner blue butterflies was
documented in the conservation area.

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