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E-M:/ More on EPA bust of National Steel on Zug Island and in Ecorse

Enviro-Mich message from "Alex J. Sagady & Associates" <ajs@sagady.com>

Here is a more detailed blurb, obviously written by lawyers 
rather than the EPA's PR people, on the National Steel 
bust......   tells you more about all of the violations they were
caught on....

Taken from EPA's Region 5 Office of Legal Counsel web site....


EPA secures $53,942 penalty, two SEPs costing $416,000, and two compliance
               orders against National Steel Corporation / Ecorse and River
Rouge, Michigan

               On April 17, 1998, a fully executed Consent Agreement and
Consent Order ("CACO")
               was filed in the administrative proceeding captioned In the
Matter of National Steel
               Corporation, Docket No. 5-MM-97-001. The CACO resolves a
               enforcement action charging the Respondent, National Steel
Corporation ("NSC"),
               with violations of the Clean Air Act ("CAA"), the
Comprehensive Emergency
               Response, Compensation and Liability Act ("CERCLA"), the
Resource Conservation
               and Recovery Act ("RCRA") and the Toxic Substances Control
Act ("TSCA").
               Pursuant to the CACO, NSC must pay a civil penalty of
$53,942, complete two
               supplemental environmental projects ("SEPs") expected to cost
more than $416,000
               and comply with the terms of two compliance orders issued
pursuant to RCRA. In the
               CACO, NSC certified that, to the best of its knowledge after
reasonable inquiry, the
               facility at issue is presently in compliance with the
requirements alleged to have been

               Between April 22, 1996, and May 3, 1996, inspectors from U.S.
EPA's National
               Enforcement Investigations Center conducted a multi-media
compliance inspection at
               NSC's integrated steel mill facility (commonly known as
"Great Lakes Steel") located
               at Ecorse and River Rouge, Wayne County, Michigan. On
September 24, 1997, U.S.
               EPA issued a 31-count Complaint alleging that Respondent
violated various
               requirements of the CAA, CERCLA, RCRA and TSCA. In
particular, the Complaint
               alleged that NSC violated (1) the CAA by failing to comply
with the requirements of
               the National Emission Standard for Hazardous Air Pollutants
("NESHAPs") for
               equipment leaks and for benzene emissions from coke
by-product recovery plants, as
               set forth respectively at 40 C.F.R. Part 61, Subparts V and L
(4 counts); (2) CERCLA
               by failing to notify U.S. EPA timely of the release of two
hazardous substances
               (2 counts); (3) various RCRA requirements governing several
hazardous wastes
               generated at the facility (9 counts); (4) various RCRA
requirements governing the
               underground storage tanks ("USTs") at the facility (3
counts); and (5) TSCA by failing
               to comply with the requirements of the polychlorinated
biphenyl ("PCB") regulations
               at 40 C.F.R. Part 761 (13 counts). For the violations alleged
in the Complaint,
               Complainant proposed that NSC be assessed a $270,423 civil
penalty and that
               compliance orders be issued for all RCRA violations.

               The parties have negotiated this settlement prior to the
filing of an Answer to the
               Complaint. In settlement, NSC will pay the $53,942 civil
penalty and complete two
               SEPs consisting of (1) the removal, disposal and replacement
of PCB equipment
               containing at least 5,300 gallons of PCBs ($375,000), and (2)
the purchase of
               electronic infrastructure upgrades that will enhance the
emergency reporting to, and
               the sharing of information by, emergency response agencies in
and around Wayne
               County, Michigan ($41,000). In addition, NSC will be bound by
the requirements of a
               RCRA Hazardous Waste Compliance Order and a RCRA UST
Compliance Order,
               both incorporated as part of the CACO, that include
conditions assuring NSC's long
               term compliance with the RCRA requirements alleged to have
been violated in this

               This case is the largest multi-media administrative
enforcement action ever brought
               by Region 5.

               Case Contact: Tim Chapman, Multi-Media Branch I, (312) 886-6829


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Alex J. Sagady & Associates        Email:  ajs@sagady.com
Environmental Consulting and Database Systems
PO Box 39  East Lansing, MI  48826-0039  
(517) 332-6971 (voice); (517) 332-8987 (fax)

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