U.S. Environmental
           Protection Agency
           Region 5
           Indiana Department of
           Environmental
           Management
EPA905-R-96-013
August 1996
&EPA
Northwest Indiana
Environmental Initiative
Action Plan

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            A Message from Valdas Adamkus and Michael O'Connor

Since 1992, the Indiana Department of Environmental Management (IDEM) and the
United States Environmental Protection Agency (U.S. EPA) have been joined together
in a geographic initiative to address the complex environmental challenges confronting
Northwest Indiana.  During this time, we have strengthened and built upon our
partnership.  We reassessed our strategies, conferred with the public, and have now
updated our original 1992 Northwest Indiana Initiative Action Plan (Action Plan).

This document is the result of much hard work between IDEM and U.S. EPA Region
5. It reflects the strategies that we, in concert with the public, agree to use in the
coming years to effect real environmental improvements,  and  to decrease
environmental  risks that threaten the health and vitality of the  community.  The Action
Plan establishes land and groundwater remediation, sediments, pollution prevention, air
quality, the Remedial Action Plan, and compliance and enforcement, as areas of
priority focus for our joint actions.

This plan does not  address all activities currently engaged in by both agencies, but
rather those that U.S. EPA and IDEM agree are conducive to collaboration or in need
of strong coordination to bring about long term restoration and environmental
protection, stronger communications,  and more effective use of resources.  It also does
not focus on the extensive environmental work being done by  others outside the
Agencies. We recognize the valuable contributions made by local governments,
citizens, and industry, and believe that the partnerships already formed between these
groups and our agencies will continue to gain strenth and  multiply.

As a result of public meetings held during the development of the Action Plan, we
expanded the initiative area to include portions of northern Porter and LaPorte
Counties,  in addition to northern Lake County.  We included non-traditional issues such
as sustainable development, which is the concept of doing economic development in an
environmentally sound way. Finally, this plan continues  to emphasize public
involvement in developing a locally suitable and effective environmental approach for
the  region.     ,

Both IDEM and U.S. EPA have recognized the importance of focusing dedicated staff
on environmental issues in Northwest Indiana.  In addition to work done by the

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Northwest Indiana Regional Office, several teams of IDEM staff focus on air, water,
non-point source reduction, natural resources, solid waste, sediments, and data
management issues in Northwest Indiana.  In addition, U.S. EPA has recognized this
initiative by establishing a team, with a full time manager and members from each of
the Region's environmental programs. This team is charged with finding and
implementing environmental solutions for Northwest Indiana by involving the local
community as an integral element of those solutions.

Public involvement will be vital to the success of Action Plan implementation and
achieving environmental results in Northwest Indiana. Already, the work of
environmental groups, industry, and communities in the  area, has made a significant
impact on environmental quality. Staff involved with these activities will identify,
pursue,  and welcome opportunities for meaningful public involvement that actively
create a dialogue among all stakeholders.  A recently conducted survey of community,
industrial, and environmental leaders regarding implementation of this plan is an
excellent starting point  for enhancing public involvement.  We want to make certain
that listening to and addressing the concerns of the public are an integral part of our
work.

Northwest Indiana offers tremendous challenges in environmental protection,
stewardship, and restoration.  This Action Plan offers a framework for furthering our
progress hi meeting these challenges.
    7/          y
Valdas V. Adamkus                         Michael O'Connor
Regional Administrator                      Commissioner
Region 5                                   IDEM
August, 1996

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           Northwest Indiana Environmental Initiative
                                 Action Plan
1.    Background and Vision of the Northwest Indiana

      Environmental Initiative

      Northwest Indiana has suffered the effects of severe pollution through a century of
      industrial activity. As a consequence, contamination threatens the health and vitality of
      communities and surrounding ecosystems.  The air quality of Lake and Porter counties
      does not meet Federal standards.  Five to ten million cubic yards of contaminated
      sediments cover the bottom of the Grand Calumet River and Indiana Harbor Ship
      Canal, of which 150,000 cubic yards enter Lake Michigan each year.  Millions of
      gallons of petroleum float atop the ground water in certain portions of Northern Lake
      County. Hundreds of sites require clean up, including seven Superfund sites and
      numerous leaking underground storage tank sites. The extent of these and other
      environmental challenges require special governmental action. During the last several
      years, EPA and IDEM have worked together to prevent further degradation and have
      begun developing long term solutions to restore ecological balance in the region.

      Starting with the 1992 Northwest Indiana Action Plan, EPA and IDEM joined in the
      Northwest Indiana Environmental "Initiative," designed to direct significant federal and
      state resources to the region. We have pursued certain short term strategies to relieve
      immediate threats to the environment and provide the ground work for longer term,
      more comprehensive solutions for the region.  The heightened enforcement strategy  of
      EPA and IDEM sends an important signal to the affected communities that future
      abuses will not be tolerated and past wrongs will be remediated.

      With the current Northwest Indiana "Action Plan," we intend to continue our
      geographic focus on Northwest Indiana.  It reflects our agencies' continued
      commitment to work cooperatively to address some of the most environmentally
      challenging problems in the nation.  Both agencies seek to clean up major waterways
      and contaminated lands, reduce the use of toxic substances, restore and protect strained
      ecosystems, and foster practices among industry and citizens that are sustainable  for the
      long term health of the environment and people of Northwest Indiana.  To that end,  we
      have established a collaborative management arrangement involving teams from both
      agencies to craft strategies and work with the community to achieve the objectives of
      this Action Plan. By sharing information and strategically focusing our joint resources,
      we can use the limited resources each have to maximize governmental efforts in the

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       area. Together, U.S. EPA and IDEM have already enhanced our communications and
       coordination in Northwest Indiana. Our evolving relationship allows us to continue
       collaborative strategies, maximize our resources, and bring about better environmental
       results for everyone in Northwest Indiana.

II.    Major Environmental Goals and Key Principles of the Northwest
       Indiana Environmental Initiative:

       EPA and IDEM seek environmental restoration of the region and elimination of serious
       environmental stresses now threatening Lake Michigan.  Several strategies, many
       initiated through the  1992 Northwest Indiana Action Plan, will be pursued under the
       Action Plan, including: improving the area's air quality; cleaning up contaminated
       sediments in the Indiana Harbor Ship  Canal and Grand Calumet River;  remediating  and
       restoring contaminated lands and ground water; using pollution prevention as a tool to
       develop an overall environmental strategy with local industry and citizens; attaining
       high compliance with state and federal environmental laws; and continuing to develop
       and implement the Remedial  Action Plan (RAP) for the Grand Calumet River, Indiana
       Harbor Ship Canal and Nearshore Lake Michigan Area of Concern and the Lake
       Michigan Lakewide Management Plan (LaMP).

       Several key principles will guide our efforts.  Success will be measured through:

             •achieving tangible environmental improvements;

             •developing creative  solutions and non-traditional ways of
             dealing with environmental problems that foster cooperation
             among affected groups;

             •closely coordinating strategies and action with other federal and
             state agencies and local governments;

             •encouraging involvement by  affected groups such as industry,
             environmental groups, and citizens; and

             •using integrated, multi-media approaches consistent with long
             term environmental goals.

       The Initiative  is based on a collaborative effort between EPA and IDEM.  We have
       agreed to work together, sharing resources and information, and engaging in informed
       decision-making by involving all those who hold a stake in the process.

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III.   Scope of the Northwest Indiana Environmental Initiative

      This Initiative focuses on the most industrialized and developed portions of Northwest
      Indiana. Its geographic boundary approximates a crescent along the
      shore of Lake Michigan. In Lake County, the Action Plan addresses the area
      north of Route 30; in Porter County, the area north of Route 30 west of Valparaiso
      and north of Route 2 to the east of Valparaiso; and in LaPorte County, the area north
      of Route 2.

      This "Initiative" complements other major environmental planning efforts underway in
      Northwest Indiana, though their geographic boundaries differ. The RAP, which is lead
      by IDEM, designates the northern portion of Lake County as its area of concern.  Both
      the LaMP, which is lead by EPA, and the Coastal Zone Management Program
      (CZMP), which is lead by DNR, address the drainage basin of Lake Michigan,
      although the boundaries for the CZMP have not been finalized.  A number of
      watershed management planning efforts focus on drainage areas for specific
      waterbodies, including the Trail Creek Watershed in LaPorte County and the
      watersheds for George and Wolf Lakes in Hammond.  IDEM's Northwest Regional
      Office augments these planning processes, and supports traditional regulator activities
      by providing services to the counties of Lake, Porter, and LaPorte.

      The objectives of this Action Plan represent strategies that EPA and IDEM have
      identified as critical to the long term restoration and protection of the region.  NOTE:
      SPECIFIC ACTIVITIES UNDER EACH OBJECTIVE DO NOT REPRESENT
      ALL THE ACTIVITIES ENGAGED IN BY THE TWO AGENCIES, NOR DO
      THE OBJECTIVES THEMSELVES INDICATE ALL MATTERS OF CONCERN.
      RATHER, THEY REPRESENT THOSE ACTIVITIES THAT BOTH AGENCEES
      HAVE AGREED ARE CONDUCIVE TO JOINT COLLABORATION OR IN
      NEED OF STRONG COORDINATION TO SUPPORT LONG TERM
      RESTORATION AND PROTECTION EFFORTS.  Activities not jointly undertaken
      by EPA and IDEM will still be coordinated through the Initiative and be consistent
      with major Initiative strategies.  The result of such cooperation will bring about
      stronger communications, more effective use of resources, and a better environment.

FV.   Relationship of the Northwest Indiana Action Plan with Other
      Planning  Processes

      The effectiveness  of this Action Plan depends greatly on maintaining close coordination
      and frequent communications with other major planning processes  underway  in the
      region. The activities under the Action Plan will further mutual goals shared by these
      longer term planning processes, and augment ongoing regional regulatory activities
      required by state and federal laws. Efforts will be made to strengthen communications

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       and coordination among federal, state, and local units of government and agencies, as
       well as with private groups working within Northwest Indiana.  Such coordination will
       ensure that the Initiative promotes broadly shared environmental priorities and the
       cooperative use of government and private resources to address regional problems.
V.    Public Involvement in the Northwest Indiana Environmental
       Initiative

       EPA and IDEM are committed to providing citizens of Northwest Indiana with
       opportunities for input into the decision making process.  We recognize that public
       involvement is important to our success.  Consequently, our process to revise
       the 1992 Northwest Indiana Action Plan began with several "roundtable" meetings held
       among agency representatives and community leaders in Northwest Indiana.  The
       comments of more than 60 individuals, representing industry, environmentalist, labor,
       and local government, helped guide the preparation of this Action Plan.  In addition,
       the final draft of this Action Plan was widely circulated for public review and comment
       before final adoption.  Our Action Plan seeks to create wide spread understanding of
       environmental challenges in Northwest Indiana and foster development of opportunities
       for the public and industry to cooperatively address environmental problems.  To
       achieve this goal, IDEM and EPA will:  (1) enhance public access to information
       concerning environmental problems (including consent decrees, technical documents
       and reports); (2) provide the public with opportunities for input and interaction; (3)
       identify  and communicate both challenges and milestones; and (4) maintain flexibility
       to allow for implementation of new and different communication strategies to meet the
       public's changing priorities and needs.

VI.   Environmental Justice

       Protecting the public health and the environment for everyone in Northwest Indiana is
       central to our mission.  Yet because of the level  of past environmental degradation, the
       historic concentration of industry in the region, the environmental issues presented by
       industry located there, and the presence of ethnic and socio-economic minorities within
       certain communities, the environmental challenges of Northwest Indiana raise unique
       concerns. Although our geographic initiative has allowed us to focus resources and
       efforts on Northwest Indiana, with this current Action Plan we have made emerging
       environmental justice issues an important consideration for our agencies.

       As society at large struggles with environmental justice concerns, EPA and IDEM are
       focusing on this issue.  We are committed to working with the public to develop a
       mutual understanding of environmental justice and a direction for our work. By
       involving minority communities  in our outreach  efforts and exploring ways that we can

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       be responsive to their concerns, we will further our efforts to protect everyone in
       Northwest Indiana, regardless of ethnic background or financial resources.  As we
       identify and define environmental justice issues, we will undertake appropriate
       responses to them.
VII. Sustainable Development

       In the December 1993 roundtable meetings, several commenters suggested that
       "Sustainable Development" should be included in the Action Plan. EPA and IDEM
       agree that the concept and practice of sustainable development should be one of the
       guiding principles of how we accomplish our goals in Northwest Indiana.  Indeed,
       President Clinton, announcing his Executive Order creating the President's Council on
       Sustainable Development,  stated the following: "to grow the economy and preserve the
       environment for our children and our children's children, bringing together some of the
       most innovative people from business, from government, from the environmental
       movement, the  civil rights movement, and the labor movement...! am asking [the
       Council] to find new ways to combine economic growth and environmental protection;
       to promote our  best interests in the world community; to bring our people together to
       meet the needs  of the present without jeopardizing the future."

       But sustainable  development as a global vision for the Northwest Indiana  area is not so
       clearly defined. EPA and IDEM recognize that the agencies need to begin working
       with the communities of the area to come to some common understandings of what
       sustainable development is, what the desired outcomes of work should be, who the
       interested parties are, and what roles parties can and should play. The agencies will
       work together with the public to open up avenues for dialogue on these issues.  For
       example, currently there is a significant movement toward redeveloping abandoned and
       unused urban sites.  EPA and IDEM both recognize the importance of this
       "Brownfields" concept.  EPA sees its role as one of removing  impediments to
       redeveloping these Brownfield sites, providing the market with clear signals of EPA's
       interests, sharing information, and testing ideas.  IDEM has an active role in cleaning
       up  these sites through various state programs including the state's Voluntary Clean Up
       program.  In addition, both agencies are engaged in transportation planning activities
       aimed at promoting growth patterns consistent with our environmental goals. These
       activities will be continued, and other activities will be explored, as we cooperate with
       communities in Northwest Indiana in the development of a shared vision of sustainable
       development for their region.

VIII. Implementation and  Future Review of the NWIAP

       The Action Plan, with its six major strategies - Air Quality, Compliance and

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       Enforcement, Land and Ground Water Remediation, Pollution Prevention, Remedial
       Action and Lakewide Management Plans, and Sediments - will be implemented jointly
       by EPA and  IDEM. This Action Plan is not inflexible.  It will be assessed
       continuously for progress by the agencies, and periodically reviewed by the public for
       major shifts in strategies and changing environmental priorities.  Joint agency
       committees have been charged with implementation for strategies not already
       coordinated and implemented through base program work.  Our agencies will work
       cooperatively with the public to ensure that the goals of this Initiative are achieved.
       Indicators of progress based on tangible environmental improvements will be developed
       and reported to the public. Our six strategies follow, with a brief explanation of our
       goals and objectives and the major activities that will guide our efforts over the next
       several years.
                                AIR QUALITY

Goal:

       The air quality in Northwest Indiana will not interfere with the citizens' enjoyment of
       their region or threaten their health.
Objective:
       To improve the area's air quality by: ensuring compliance with the new Clean Air Act
       Amendment requirements for the area; taking all steps needed to achieve and maintain
       health-based air quality standards; involving the public and improving their awareness
       of what we all can do to lessen air pollution;  and initiating targeted efforts through
       enforcement, rule development, and public awareness.
Definitions:
       Criteria Pollutants:    Pollutants identified in Title I of the Clean Air Act that include
       carbon monoxide, lead, nitrogen oxides, ozone, paniculate matter, and sulfur dioxide.

       VQC:  Volatile organic compounds, active hi formation of ozone/smog.

       PM-10: Fine paniculate matter (measured as PM-10).

       Title III:  Portion of Clean Ah* Act Amendments of 1990 that outlines hazardous air
       pollutant control  program.

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       Title V: Portion of Clean Air Act Amendments of 1990 that outlines new state
       operating permit program.

Background:

       Lake County has the poorest overall air quality of any area within Indiana. Over the
       years, portions of this county have not met state and federal health standards for most
       'of the criteria air pollutants. The smog problem persists in Porter County and possibly
       LaPorte County. Northwest Indiana,  and Lake County in particular, also have high air
       emissions of hazardous air pollutants.

       EPA and IDEM have spent considerable time and effort developing new rules and
       programs and enforcing existing laws  to improve air quality in this region. These
       efforts have resulted in substantial improvement in air quality, especially for particulate
       matter, sulfur dioxide and carbon monoxide.  However, problems still persist for ozone
       and other hazardous air pollutants.

       New control plans for particulate matter and sulfur dioxide have been established and
       are being implemented.  The State of Indiana is working with Illinois, Wisconsin, and
       Michigan on a new smog/ozone control program aimed at eliminating the health threat
       from ozone before 2007. IDEM is also launching the Title III (Air Toxics) program
       that will lead to substantial reduction in emissions of hazardous air pollutants to reduce
       risk to public health.  EPA is participating in developing these new programs and in
       guaranteeing their success.

Major Activities:

       1.     IDEM and EPA will develop a targeted compliance and enforcement strategy
             aimed at addressing the area's  major air quality problems (ozone, PM-10 and
             toxic substance exposure).  IDEM will work to reduce major nuisance problems
             related to odor, dust, and other air quality problems.

       2.     IDEM will prepare a state wide air toxic substances control program with an
             emphasis on activities in Northwest Indiana that will both evaluate the extent of
             excessive risk and address major problems with rules, compliance and outreach
             efforts. EPA will actively support IDEM through technical assistance and other
             means.  The state air toxic substances program will incorporate all mandatory
             elements of the hazardous pollutant provisions of the Clean Air Act
             Amendments.

       3.     IDEM will work with the Clean Air Act Advisory Council - Northwest Indiana
             Committee to focus on their concerns relative  to ah" quality in Northwest

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              Indiana.

       4.      IDEM and EPA will continue to coordinate and cooperate in the Lake Michigan
              Ozone Project, and develop control measures to reduce ozone and smog.

       5.      IDEM and EPA will continue to coordinate closely on all significant regulations
              and programs required as part of the Clean Air Act Ozone State Implementation
              Plan to assure that the state rules and programs meet the federal requirements
              and to assure that EPA's review process supports the state's actions.

       6.      IDEM will collect and evaluate  air quality monitoring data in the area to track
              improvements, and will increase sampling for hazardous air pollutants as part of
              the air toxic substances program.

       7.      IDEM and EPA will promote pollution prevention approaches during
              compliance and enforcement activities, public outreach efforts and, whenever
              practical, rulemaking.

       8.      IDEM will work to secure approval from EPA  on the state's Fine Paniculate
              Matter Implementation Plan and then closely  coordinate state and federal
              compliance activities in the area.

       9.      IDEM will pilot an odor control program for the area, working with EPA
              wherever there is federal authority for effective air pollution reduction.

       10.     IDEM will implement an effective enhanced vehicle emission testing program
              with assistance from EPA that will provide better service to the motorists and
              more emission reductions.

       11.     IDEM will incorporate air quality consideration into transportation planning
              decisions and identifying effective mobile source control measures.

       12.     IDEM will prioritize implementation of the Clean Air Act's new Title V
              operating permits for major sources in Lake and Porter counties. IDEM's
              Small Business and Technical Assistance Program will work to assure
              compliance with Clean Ah- Act requirements  for small businesses hi the area.

Opportunities for Public Involvement:

       IDEM and EPA will meet regularly to discuss progress and coordination on joint
       efforts in Northwest Indiana. The IDEM/EPA Northwest Indiana Air Committee is
       responsible for communicating on all matters involving or affecting the other agency to

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       assure proper coordination and effective actions.

       The public, industry and local government can participate in meeting these objectives
       through IDEM's Clean Air Act Advisory Committee, public meetings and hearings,
       and other public processes associated with regulatory activity.
              COMPLIANCE AND ENFORCEMENT

Goal:

       Reduce the quantities of conventional and toxic pollutants existing within and entering
       the environment in Northwest Indiana.

Objective:

       Use enforcement actions and other statutory authorities to achieve a high level of
       compliance with all federal and state environmental laws and to remediate contaminated
       sites.

Definitions:

       Supplemental Environmental Project (SEP): A project carried out by a polluter which
       has direct environmental benefits and is not otherwise required by law. Such projects
       can be used to offset a portion of the cash penalty.

       RCRA: Resource Conservation and Recovery Act of 1976; the law established rules to
       monitor hazardous substances from the time of production to disposal.  It requires that
       safe procedures be used in treating, handling, using and disposing of hazardous
       substances.

Background:

       Many of EPA's and IDEM's joint efforts under the Action Plan focus on remediation
       and restoration of Northwest Indiana because of the environmental degradation that has
       occurred over many decades.  But the long term benefits to the environment and to the
       citizens in Northwest Indiana, as well as the success of the Initiative, depend on
       whether ongoing regulated activities comply with federal and state environmental laws
       and regulations,  now and in the future.  Therefore, it is critical that IDEM and EPA
       continue our joint efforts in determining the compliance status of the industries and
       other regulated facilities operating in Northwest Indiana, and when appropriate,

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       vigorously enforce against those not in compliance.

       Northwest Indiana presents difficult challenges with regard to compliance and
       enforcement for several reasons.  First, many industries located in Northwest Indiana
       were established decades prior to modern environmental laws and regulations.  Their
       processes and equipment were not designed to control or limit pollution into the
       environment. Some of these facilities have had difficulty adapting their processes and
       equipment to meet current environmental standards.  As a result, many have
       experienced chronic compliance problems.  In addition, and unfortunately, there have
       been some who have chosen to locate in Northwest Indiana who have not taken their
       environmental responsibilities and obligations seriously. Regulating such facilities
       requires vigilance and aggressiveness.  Finally,  because of the past significant
       degradation of all the environmental media - air, water and land - compliance and
       enforcement strategies must take into account that pollution can be shifted from one
       medium to another. As a result, IDEM and EPA will continue to focus on
       environmental improvement through a multi-media approach to compliance and
       enforcement, and  by actively seeking through enforcement actions remediation of past
       contamination.

Major Activities:

       1.      Coordinate state and federal enforcement actions through the Compliance and
              Enforcement Committee (CEC) to ensure efficient use of state and federal
              resources.

       2.      Prioritize and target inspections and enforcement to ensure compliance.

       3.      Research the legal/judicial facets of sediment remediation, the remediation of
              contaminated ground water and the development of natural resource damage
              claims to enable state and federal enforcement personnel to bring cases which, if
              successful, will compel the remediation of past damages to the environment.
              Evaluate cases to determine the applicability of additional statutory authorities.

       4.      Consistent with Number 1, both agencies will pursue civil litigation and seek
              voluntary actions to remediate contaminated  sites, including contaminated
              sediments  in the Grand Calumet River/Indiana Harbor Ship  Canal, and compel
              responsible parties to undertake clean up at contaminated sites to  remove
              hazardous, toxic and solid wastes and to clean up leaking underground storage
              tanks.

       5.      EPA will follow its Supplemental Environmental Project Policy to facilitate
              inclusion of environmental and pollution prevention projects in its enforcement
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             settlements.  IDEM will complete its Supplemental Environmental Project
             Policy in order to do the same.

      6.     Work with local governments to identify their authorities and use them more
             effectively to address violators, including open dumpers, air pollution sources,
             and industrial dischargers to municipal sewage treatment plants.

      7.     At permitted and closing RCRA sites, prioritize and complete closure and/or
             corrective action.

      8.     Implement a compliance and enforcement strategy which increases inspection
             surveillance of and enforcement against sources of Volatile Organic Compounds
             (VOCs), Particulate Matter (PM-10), and toxic sources.

      9.     Continue to implement the Great Lakes Enforcement Strategy dated
             9-15-93 for reducing toxic discharges to Grand Calumet River/Indiana Harbor
             Ship Canal.
Opportunities for Public Involvement:

      The citizens of Northwest Indiana have the opportunity and responsibility to be aware
      of problems and call them to the attention of their city and/or county officials, or
      contact IDEM or EPA about them. Additionally, citizen suit provisions exist in many
      state and federal laws, as another means to bring about compliance with the law.
       LAND AND GROUND WATER REMEDIATION

Goal:
      Protect Northwest Indiana from the release of hazardous substances, petroleum or
      petroleum-related substances and clean up of contaminated lands and ground water.

Objective:

      Prevent the release of hazardous substances, petroleum or petroleum-related substances
      to the land or ground water; if releases occur, ensure the immediate containment and
      clean up; and use all applicable Federal and State authorities and programs to address

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       the containment, removal and/or treatment of hazardous substances, petroleum or
       petroleum-related substances currently contaminating land or ground water of
       Northwest Indiana.
Definitions:
       Northwest Indiana Brownfields Redevelopment Project:  A local initiative of East
       Chicago, Gary, and Hammond and IDEM to identify properties unused because of
       potential environmental contamination, and to encourage their remediation and reuse.

       Superfund:  The Comprehensive Environmental Response, Compensation and Liability
       Act of 1980; the federal law which established a mechanism for identification and
       remediation of the worst hazardous substance contaminated sites in the U.S.

       Voluntary Remediation Program:  A cooperative initiative between the state and private
       parties in which contaminated sites are remediated with state oversight and, upon
       successful completion of the remediation, a Covenant Not To Sue is issued to the
       property.
Background:
       Northwest Indiana has been the site of substantial industrial activity for over 100 years.
       Past industrial practices in Northwest Indiana often did not consider their future impact
       upon the environment and have resulted in significant contamination of the soils and
       ground water. This historical contamination has not only resulted in potential threats to
       human health and the environment but is now impacting the local economies through
       the real or perceived threat of environmental liability on properties within Northwest
       Indiana.

       IDEM and EPA have many  different programs within their authority over the
       prevention and correction of pollution of the land and ground water.  Northwest
       Indiana, because of its size and density, presents a major challenge to all  involved.
       Through this  Action Plan, EPA and IDEM will work to coordinate, and where
       possible, accelerate addressing land and ground water contamination.
Major Activities:

       1.      Continue to coordinate and aggressively pursue targeted actions to protect and
              remediate contaminated land and ground water through federal and state
              Superfund emergency and remedial programs, petroleum clean ups, corrective

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       actions, closures and non-traditional efforts.

2.     Improve coordination with other units of government to enhance protection and
       achieve clean up where no one agency or department has complete authority,
       and foster partnerships with other major stakeholders.

       Efforts will continue to work with state and federal agencies, such as the
       Indiana Department of Natural Resources, Indiana Department of Commerce,
       U.S. Army Corps of Engineers, U.S. Fish and Wildlife Service, the National
       Biological survey, and local units of government. Through such efforts EPA
       and IDEM can effectively extend their programs and resources to  address
       egregious  problems over which neither agency has complete authority.
3.     Identify and encourage the use of both innovative approaches and  innovative
       technologies for land and ground water remediation.

       The August 1994, execution of a voluntary Memorandum of Cooperation
       (MOC) by IDEM and EPA with local industries  is an example of an innovative
       approach to a vexing problem. The MOC describes a way to prevent future
       releases of petroleum to the Indiana Harbor Ship Canal from the ground water
       beneath the properties of the signatories.  Several companies have agreed to
       voluntarily take measures to prevent the migration of petroleum to the canal
       which may be currently occurring.  EPA and IDEM will also continue to
       research and use, where appropriate, new technologies to enhance the
       effectiveness of clean up actions.

4.     Continue efforts to map, locate, and define the extent and thickness of
       petroleum-related products on or within, the soils and ground water.

       The continuing mapping efforts will provide the location of pockets of "floating
       oil" on the ground water; assist in prioritizing clean ups and assist in evaluating
       the impacts on the environment.

5.     Continue to assist and coordinate with the Northwest Indiana Brownfields
       Redevelopment  Project through the identification of potential sites and through
       the innovative use of Indiana's Voluntary Remediation Program. IDEM and
       EPA will also seek out further opportunities to work with local units of
       government and industry for further "Brownfield" redevelopment  opportunities
       throughout the entire geographic initiative area.

       The implementation of the  "Brownfields" approach will not only provide
       enhanced clean up and the protection of green fields outside the metropolitan
       areas but has  the potential to result  in positive economic impacts.
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       6.     Identify and resolve regulatory barriers to achieving remediation of
             contaminated sites.

             The purpose of this activity is to clearly define the authorities and tools state
             and federal staff may use to prevent and/or address spills, releases or existing
             contamination in the most effective manner. IDEM and EPA will review and
             develop a "tool box" of mechanisms which may be employed to obtain
             compliance under  state and federal hazardous substance and oil pollution
             legislation.

Opportunities for Public Involvement:

       IDEM and EPA rely on the public to help identify suspected locations of contamination
       in the soil and/or ground  water. We will keep the public current on activities
       associated with clean ups  and continue to encourage their participation in formal
       comment periods used to  gather input on site specific projects. Throughout the
       implementation of this element of the Action Plan, EPA and IDEM will continue to
       look for and provide opportunities for further cooperation with the public, government
       agencies and industry.
                     POLLUTION PREVENTION

Goal:

      Integrate pollution prevention and environmental stewardship into industry practices
      and public behavior in Northwest Indiana.

Objective:

      IDEM and EPA will engage in a consistent effort promoting pollution prevention and
      environmental stewardship in Northwest Indiana. In general, IDEM will take the lead
      on pollution prevention in the region.  Through this consistent effort by the agencies,
      industry and the public in Northwest Indiana can adopt pollution prevention and
      environmental stewardship practices.  Success will  be measured by integration of
      pollution prevention measures into other Action Plan activities.  When this objective is
      met, the pollution prevention and environmental stewardship committee should no
      longer be necessary.

Definitions:
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       Environmental Waste:  All environmental pollutants, wastes, discharges or emissions,
       regardless of whether or how they are regulated, and regardless of whether they are
       released to the general environment or the workplace environment.

       CFR:  Code of Federal Regulations.
       Toxic Materials:  For purposes of this Action Plan, toxic materials are substances on
       the CERCLA Hazardous Substance list (40 CFR Part 302), and they also include toxic
       chemicals as defined by 40 CFR Part 372.
Background:
       Pollution prevention and, in the broader sense, environmental stewardship, are the
       primary mechanisms for positive change for IDEM and EPA activities in Northwest
       Indiana.  Each agency has committed resources to the issues and will continue to
       emphasize pollution prevention as a priority. These efforts will be aggressively
       incorporated into the agencies' activities whenever possible.

       Indiana's program seeks a dramatic shift in perspective to pollution prevention, rather
       than incremental shifts towards this best approach. These incremental shifts  from
       disposal to treatment to recycling, and then finally prevention, delay the time when the
       economic and environmental benefits of prevention can be realized. To promote this
       shift, Indiana has a strong definition of pollution prevention that is unique in the United
       States.

       EPA and IDEM believe it is  important to recognize that while there are differences
       between state and federal pollution prevention legislation, EPA and IDEM are
       committed to working as partners in Northwest Indiana to achieve reductions in the
       generation of pollution and/or its release to the environment.

       Pollution prevention means the use of practices that reduce  or eliminate the industrial
       use of toxic materials or the hazards associated with an environmental waste  without
       diluting or concentrating the  waste before the release, handling, storage, transport,
       treatment, or disposal of the  waste.

       Pollution prevention consists of activities that directly impact the production  of a
       product or the providing of a service.  It includes product reformulation, production
       process redesign, housekeeping, environmental and process training,  inventory control,
       preventive maintenance, energy conservation by the energy producer, and on-site
       closed-loop recycling. It does not include waste burning, waste exchanges, most
       recycling, or environmental remediation activities.

       Environmental stewardship includes pollution prevention, but is a broader concept. It


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       means activities that protect the environment either directly or indirectly.  Some
       examples of activities that are not pollution prevention but are environmental
       stewardship include:  energy conservation (unless activity is by energy producer), waste
       minimization, environmental education, household hazardous waste collection, and
       sediment remediation.

       IDEM and EPA have active pollution prevention and environmental stewardship efforts
       in the region.  For the most part, IDEM has taken the lead in implementing these
       efforts, with financial and/or technical support from EPA. The exceptions to this are
       the Steel Industry Pollution Prevention effort, which is entirely state funded, and
       EPA's Hazardous Waste Minimization Assessments, which were entirely  federally
       funded.  Other efforts include the Enviromobile, Hazardous Waste Minimization
       Studies, and the Grand  Calumet River District Pollution Prevention Effort.  In general,
       IDEM has taken the lead on these efforts with support from EPA.

Major  Activities:
       1.    The Pollution Prevention Implementation Committee will aggressively integrate
             pollution prevention objectives into the other components of this Action Plan
             over the next  two years. IDEM will facilitate  integration by assigning a
             representative of the Office of Pollution Prevention and Technical  Assistance to
             work on each of the objectives that address preventing future pollution. EPA
             will work with its staff to ensure that pollution prevention is an integral part of
             the Action Plan and the agency's efforts.

       2.    The EPA,  with IDEM support, will continue to assist companies in their efforts
             to identify and evaluate pollution prevention, waste minimization,  and
             environmental stewardship opportunities.  In the  future, assessment results will
             distinguish between pollution prevention, waste minimization, and
             environmental stewardship.

       3.    IDEM, with the support of EPA, has developed a measure of pollution
             prevention progress among manufacturers in the  region.  This committee will
             work with the citizens to get the information out  in a format that is
             understandable.

       4.    This committee  will promote opportunities within this Initiative for public and
             industry awareness of and participation hi pollution prevention and
             environmental stewardship activities.

Opportunities  for Public Involvement:

       The public, industry  and local government are already working toward pollution


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      prevention and environmental stewardship by participating in household hazardous
      waste collection, and environmental education, including the Enviromobile, teacher
      education, and continuing public forums on pollution prevention and environmental
      stewardship.
                 REMEDIAL ACTION PLAN AND
               LAKEWIDE MANAGEMENT PLAN
Goal:
      Eliminate pollution that impairs beneficial uses in Lake Michigan and the Grand
      Calumet Area of Concern and restore those beneficial uses.
Objective:
      Implement Annex 2 (see definition below) of the Great Lakes Water Quality Agreement
      (GLWQA) through the use of an ecosystem approach to address the environmental
      problems which impair beneficial uses of Lake Michigan and the Grand Calumet
      Indiana Harbor Ship Canal Area of Concern.
Definitions:
      Annex 2: A section within the GLWQA that requires any Great Lakes State with an
      area of concern to prepare a Remedial Action Plan (RAP).  Annex 2 also requires the
      United States and Canada prepare Lakewide Management Plans (LaMP's) for each of
      the five Great Lakes.

      Area of Concern (AGO: A geographic area that fails to meet the objectives of the
      GLWQA and where such failure has caused or is likely to cause impairment of
      beneficial uses. There are 43 AOCs' surrounding the Great Lakes, one of which is in
      Indiana.  The Grand Calumet Indiana Harbor Ship  Canal Area of Concern is bounded
      by the State of Illinois on the west, Porter County on the east, Interstate 80/94 on the
      south, and the Indiana portion of Lake Michigan on the north.

      Ecosystem: The interacting components of air, land, water, and living organisms,
      including humans.

      Great Lakes Water Quality Agreement  : A product of the 1909 Boundary Waters

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       Treaty between the United States and Canada.  The agreement, last amended in 1987,
       was negotiated and signed by both countries to protect and restore the water quality of
       the five Great Lakes and the waterways which connect them.

       Impairment to beneficial use: A change in the chemical, physical, or biological
       integrity of the Great Lakes System sufficient to cause any of the following: restrictions
       on fish and wildlife consumption; tainting of fish and  wildlife flavor;  degradation of
       fish and wildlife populations; fish tumors or other deformities; bird or animal
       deformities or reproduction problems; degradation of benthos; restrictions on dredging
       activities; eutrophication or undesirable algae; restrictions on drinking water
       consumption, or taste and odor problems; beach closings; degradation of aesthetics;
       added costs to agriculture or industry; degradation of phytoplankton and zooplankton
       populations; and loss of fish and wildlife habitat.

       International Joint Commission: The Boundary Waters Treaty of 1909 between the
       United States and Canada established a six-member commission which oversees water
       quality matters with regards to the Great Lakes and advises both countries. The
       commission reviews Lakewide Management Plans and Remedial Action Plans.

       Combined Sewer Overflow:  A combined sewer system is a  sewer system owned by a
       state or municipality that collects waste water and storm water through a single-pipe
       system and conveys it to a publicly owned treatment works  plant.  A combined sewer
       overflow is a structural device which discharges from the combined sewer system at a
       point prior to the publicly owned treatment works plant.

       Lakewide Management Plans: A comprehensive effort to identify the  critical pollutants
       within a Great Lake and determine what steps need to be taken to eliminate lakewide
       problems caused by both conventional and toxic pollutants.

       Remedial Action Plan: The identification of the causes of use impairments within a
       harbor, bay or tributary to a Great Lake, and the development of an implementation
       plan and schedule to address the problems which caused the impairments using an
       ecosystem approach.
Background:
       Annex 2 of the GLWQA requires Indiana to prepare a RAP for the Grand
       Calumet/Indiana Harbor Ship Canal AOC.  In addition, Annex 2 requires the United
       States Government to lead the development of a lakewide management plan for Lake
       Michigan.  Close collaboration between the federal government and the state of Indiana
       on both planning efforts is essential to their ultimate success and the long term
       protection and restoration of the AOC. While IDEM is charged with developing the
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       process to produce a RAP, the comprehensive nature of the problems facing Northwest
       Indiana will require the continued involvement of many stakeholders, public and
       private, as long-term ecosystem approaches are pursued. EPA provides a uniquely
       supportive role of the State's RAP efforts, offering financial, technical and capacity
       building resources. Moreover, Indiana's contribution to the Lake Michigan LaMP will
       rely heavily on the remedial strategies developed through the RAP.  The LaMP, in
       turn, will assist the development of the RAP by assessing the environmental impacts of
       current loadings to Lake Michigan and helping identify how future loadings can be
       reduced.

       Stage 1 of the RAP, an assessment of beneficial use impairments, was completed in
       January 1991.  The development of key strategies to address  such impairments during
       Stage II, which is the implementation phase of the RAP process, will be completed in
       1995. The long term protection and restoration of the AOC is the chief aim of the
       tasks targeted initially for implementation or subsequently selected in bi-partisan
       fashion.

       Considerable progress has been made through IDEM and EPA's cooperation on AOC
       activities.  Enforcement actions taken against polluters located within the AOC has
       prevented hundreds of thousands of pounds of pollutants from entering the
       environment.  A household hazardous waste collection program, funded by EPA and
       implemented by IDEM, resulted  in the proper disposal of many harmful substances
       which might have ended up in the sewers, landfills or waterways. Another joint
       project between the agencies resulted in the Grand Calumet Sanitary Districts Toxic
       Pollution Prevention Project. This voluntary, collaborative project works with cities
       and industries to reduce discharges of chemicals to sewage treatment plants and,
       ultimately, the Grand Calumet River.  Future efforts will include identifying further
       opportunities, and working with local communities, to minimize the adverse impacts of
       combined sewer overflows which have historically resulted in annual discharges of up
       to 7.3 billion gallons of untreated sewage and storm water in the Grand Calumet and
       Indiana Harbor Ship Canal.
Major Activities:

       1.     Identify persistent toxic substances and the sources from which they are being
             released into, and are affecting the ecosystem health of, Lake
             Michigan from the Grand Calumet River and Indiana Harbor Ship Canal
             through the review of existing data and information.

       2.     Estimate, on a gross scale, total pollutant loadings from the Grand Calumet
             River and Indiana Harbor Ship Canal into Lake Michigan through the review of
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              all existing information systems, such as the Toxic Release Inventory, data
              bases, and sediment transport information generated by the U.S. Army Corps of
              Engineers.

       3.     For future reduction activities, develop critical pollutant load estimates for
              individual sources where data exists, and develop monitoring plans to gather
              data where none currently exist.

       4.     Identify and implement short-term and long-term pollution prevention and
              environmental stewardship activities to  further reduce critical pollutant loads to
              Lake Michigan.

       5.     Complete the revisions to the Stage I RAP called for by the International Joint
              Commission in its review of the document.  Establish a firm schedule to
              complete  all remaining components of the Stage II RAP.

       6.     Implement watershed management plans for both Wolf and George Lakes and
              for the Grand Calumet River Lagoons at Marquette Park.  Support the
              restoration of natural areas, especially wetlands, to continue the ecosystem
              restoration required by Annex 2.

       7.     Develop greater public involvement in pollution control, ecosystem protection,
              and the responsibilities of municipal government through
              workshops, open houses, and other events as may be determined by the
              agencies and the public and by facilitating open house events.

       8.     Support and provide special assistance to the LaMP/RAP Toxic Pollution
              Prevention Project as it expands in scope, providing limited technical assistance
              to dischargers to the Grand Calumet River and Indiana Harbor Ship Canal to
              reduce these dischargers' toxic pollutant loads on a voluntary cooperative basis.
Opportunities for Public Involvement:

       Annex 2 requires that the public be extensively involved in the development of every
       facet of both the RAP and LaMP.  To meet this requirement the State of Indiana has
       established the Citizens Advisory for the Remediation of the Environment (CARE).
       CARE is an advisory group to the state composed of citizen members representing a
       broad array of backgrounds and interests.  EPA and the four Great Lakes States rely on
       citizen input from groups such as the LaMP public forum.  Additionally,  both IDEM
       and EPA have held, and will continue to host, public workshops on specific issues
       brought forward by the public.  The Action Plan was initiated to address several of the
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       most difficult immediate environmental problems facing Northwest Indiana; the RAP
       process, however, is designed to protect and restore the environment in the Grand
       Calumet Area of Concern through the development of long term remedial and
       preventive strategies. That environment is shaped  by the citizens of the area and the
       RAP must reflect their views of the future and what must be done to create that future.
                                   SEDIMENTS


Goal:

       To reduce the adverse impacts of contaminated sediments flowing into Lake Michigan
       from the Indiana Harbor Ship Canal and the Grand Calumet River and to restore these
       waterbodies for uses including fishing and wildlife habitat.

Objective:

       EPA and IDEM will support the development of and implementation of the RAP for
       the Area of Concern to protect Lake Michigan from toxic sediments and restore the
       Grand Calumet River-Indiana Harbor Ship Canal ecosystem. These efforts will control
       contaminated sediments by means including dredging, in-place treatment and disposal.

Background:

       More than twenty-five percent of the nation's steel making capacity is located in
       Northwest Indiana, along with several major petroleum facilities and other
       manufacturing plants. Largely as a result of past industrial pollution, substantial
       deposits of contaminated sediments have formed in the area's various waterbodies.
       The U.S.  Army Corps of Engineers estimates that the Grand Calumet River and the
       Indiana Harbor and Ship Canal alone contain five to ten million cubic yards of
       contaminated sediments.  This accumulation is due in large part to the suspension of
       maintenance dredging since 1972 because of the contaminated sediments. This in turn
       has led to approximately 150,000 cubic yards of these sediments carried into southern
       Lake Michigan annually.  Therefore, IDEM and EPA have developed and will continue
       to develop strategies, not only to remediate existing contaminated sediment deposits,
       but to prevent future sediment contamination.  Development of sediment disposal
       facilities,  with public participation, is central to the resolution of this problem.
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Major Activities:

       Because of the extent and variability of sediment contamination, EPA and IDEM have
       divided their activities into two categories.  Category I consists of on-going or planned
       projects in the  Indiana Harbor Ship Canal and Grand Calumet River aimed primarily at
       protecting Lake Michigan from the effects of contaminated sediments and improving
       quality.  Category II activities involve development of further actions, using a basin or
       ecosystem wide approach.  These activities will proceed, to the extent possible,  as a
       joint venture between EPA and IDEM. Other long-range control  and prevention
       strategies, such as ground water characterization, source controls, and ground water
       remediation, will eventually be developed as part of the RAP for the  Area of Concern.

       Category I activities will:
             •pursue the dredging and disposal of contaminated sediments from the
             navigable portion of the Indiana Harbor Ship Canal — the Federal Navigation
             Channel — by cooperating with the U.S.  Army Corps of Engineers.  Such
             dredging will create a trap to reduce the  flow of contaminated sediments into
             Lake Michigan. For other areas of the Indiana Harbor Ship Canal, IDEM and
             EPA will use all available tools, including the Inland Steel and LTV Steel
             Consent Decrees, to control as much sediment as possible;

             •focus  on controlling contaminated sediments in the East Branch of the Grand
             Calumet River using all appropriate tools, including the implementation of the
             USX and Gary Consent Decrees;

             •pursue contaminated sediment control for the West Branch of the Grand
             Calumet River.

             •define appropriate measures for remediation and disposal of sediments
             addressed by the foregoing actions.

             •continue study of environmental conditions in the Indiana Harbor Ship Canal
             Grand Calumet River ecosystem and organize data to support site-specific
             actions, as well as analysis of basin-wide impacts of various sediment clean up
             or control alternatives.
       Category II activities will:

              •begin development of a comprehensive treatment/storage/disposal strategy for
              sediments removed  from the Indiana Harbor Ship Canal and Grand Calumet
              River.
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             •continue to identify and evaluate available mechanisms including enforcement,
             corrective action, and voluntary projects, to address non-remediated areas of the
             Indiana Harbor Ship Canal and Grand Calumet River;

             •continue the development of individual strategies targeting specific polluters
             and broad strategies bringing together "responsible parties" to address key
             geographic areas.
Opportunities for Public Involvement:

      The successful completion of this strategy requires significant public outreach by EPA
      and IDEM, and other involved agencies, on all aspects of this sediments strategy. The
      agencies will seek out opportunities for education and dialogue with the public
      regarding sediment control and remediation, and encourage their participation and
      comment on future sediments work.
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Co-Chairpersons
USEPA

* Sally Swanson
 Northwest Indiana Team Manager

 JoLynn Traub, Director
 Water Division

 Norm Niedergang, Director
 Waste, Pesticides & Toxics Division

 William E. Muno, Director
 Superfund Division

*Gail Ginsberg
 Regional Counsel

 Gary Gulezian, Acting Director
 Great Lakes National Program

*Elissa Speizman, Director
 Office of Public  Affairs

 Robert Springer, Director
 Resources Management Division

*Anne Rowan
 Indiana State Coordinator
      Sediments:
      Compliance & Enforcement:
      Land & Groundwater
      Remediation

      Pollution Prevention:
     Remedial Action Plan/
     Lakewide Management Plan:

     Air Quality:


* Steering Committee Members
Northwest Indiana Action Plan
    Executive Committee

              Jodi Pen-as, Deputy Commissioner
              Indiana Department of Environmental Management
              Office of Legal Affairs

              David Ullrich, Deputy Regional Administrator
              Environmental Protection Agency, Region 5

              IDEM

             *Beth Admire
              Office of Legal Counsel

              Tim Method, Deputy Commissioner
              Off. of Environmental and Reg. Affairs

              David Wersan, Assistant Commissioner
              Office of Solid and Hazardous Waste

              John Rose, Assistant Commissioner
              Office of Environmental Response

              Tom Neltner, Assistant Commissioner
              Office of Pollution Prevention

              Pat Carroll, Director
              Offfice of Enforcement

              *Kay Nelson, Director
               Northwest Indiana Regional Office

              *Kim Robinson, Director
              Office of Community Relations

             *Jan Henley, Assistant Commissioner
              Office of Water Management

  Implementation Committee

          Bonnie Eleder, USEPA
          Dave Wersan, IDEM

          Mike Smith, USEPA
          Pat Carroll, IDEM

          Tom Geishecker, USEPA
          John Rose, IDEM

          Dan O'Riordan, USEPA
          Tom Neltner, IDEM

          Stacy Greendlinger, USEPA
          Adriane Esparza, IDEM

          Cheryl Newton, USEPA
           Felicia George, IDEM

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