Region 3 GPRA Baseline RCRA Corrective Action Facility


Bethlehem Steel Corporation -

Bethlehem Works and

Bethlehem Commerce Center

1805 East 4th Street
Bethlehem, PA 18016-7699
Congressional District 15
EPA ID #: PAD990824161
Latest Update 12/28/2005


Current Progress at the Site


EPA, PADEP and Bethlehem Steel Corporation-Bethlehem Plant (BSC) formed a team in 1998 to
proceed with the clean-up of the facility. The facility is subject to RCRA corrective action, however,
BSC's redevelopment plans hinged on obtaining a release from liability which is available for
remediation performed under the Pennsylvania Act 2 Land Recycling Program. The redevelopment
plan is designed to revitalize South Bethlehem, which has been in an economic slump since BSC started
downsizing in the 1970's.

In May 2003, this Bethlehem Steel site was sold to an International Steel Group (ISG) subsidiary,
Tecumseh Redevelopment Corp., as part of the Bethlehem Steel bankruptcy proceedings. In May
2004, Tecumseh Redevelopment sold 1000 acres to Lehigh Valley Industrial Park, Inc. (LVIP), a local
redevelopment firm and owner of several industrial parks. In July 2004, LVIP sold 32 acres in the
Saucon area to United States Cold Storage, for refrigeration warehousing. In 2004, Tecumseh sold
the Bethlehem Works property to BethWorks Now, however, Tecumseh continued to own the 450-
Acre area.  In 2004, a Dutch steelmaker, Mittal Steel, purchased ISG, including Tecumseh and the
450-Acre area.

The facility has been divided into 2 different areas for redevelopment; Bethlehem Works and Bethlehem
Commerce Center, which includes the Coke Works, Saucon, Conectiv, East Lehigh, Easton Road
Frontage, Commerce Center Boulevard, and the Greenway.

Bethlehem Works
At the  163-acre Bethlehem Works area, on the western side of the site, demolition of buildings and
removal of some soil has been completed.  EPA, PADEP, and BSC agreed on the remediation work
completed. PADEP and EPA have approved the soil remediation and the groundwater investigation

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under the Act 2 and federal corrective action programs respectively. Current studies indicate that the
small amount of residual VOC contamination in the alluvial aquifer does not impact the Lehigh River.

Building demolition and the soil investigation happened concurrently.  At that time, degreasers, which
may have been sources of contamination, were excavated and other soil contamination was removed
(down to 2 feet) when it was found and backfilled with clean fill. The redevelopment plan calls for most
of Bethlehem Works to be paved over, which will eliminate any avenue of exposure from soil
contamination left on-site.

Bethlehem Works, currently owned by BethWorks Now, is to become the Riverfront Renaissance
District. This is a $879 million redevelopment project, expected to include a multiplex movie theater,
ice skating center, swimming pool facilities and  other entertainment and retail establishments. A major
piece of Bethlehem Works is the establishment of the National Museum of Industrial History, an annex
to the Smithsonian Institution. The museum is expected to be housed in one of the former production
buildings.  Construction of a new roof for the museum was started in 2005.

Bethlehem Commerce Center

Coke Works
The Coke Works phase of investigation and remediation encompasses the 390 acres at the southern
end of the facility where the former Coke Plant was located.  The Coke Works consists of two areas,
Coal Chemical, where the Coke Plant was located - the most contaminated  portion of Coke Works;
and the new Bethlntermodal, just south of Coal Chemical. Investigation of the soils and groundwater
beneath the Coke Works began in March 1999.

Coal Chemical
The primary contaminants of concern at Coal Chemical are BTEX (benzene, toluene, ethyl benzene
and xylene) and naphthalene, which are all common contaminants of the historic coke operations and
by-product chemical production.  Several waste  disposal areas have been found, as well as widespread
soil contamination. The underlying groundwater is also contaminated. Currently, the characterization
investigation is focusing on soil gas studies, which will help identify risks from vapors emanating from the
soils, and a groundwater computer model which will aide in visualizing long-term remedial strategies.

EPA, PADEP and Bethlehem Steel jointly developed a plan for increasing airflow in the soils, with the
expectation of increasing microbial activity and the degradation of the organic contaminants.  The
"passive bio-venting"  strategy uses standard technologies in an innovative way.  The system will
consume very little energy and has low maintenance requirements, lending  itself well to the facility's
redevelopment vision. Currently, design of the system is on-hold.

EPA, PADEP, and BSC discussed the regulatory expectations for remediation of Coal Chemical,
consistent with its intended redevelopment with  light and heavy industrial activities. The workgroup is
developing proposals to eliminate the exposure threats posed by the soils and groundwater.

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Bethlntermodal
A new $14 million intermodal terminal is almost complete on 100 acres in the Coke Works area, just
south of Coal Chemical. Bethlntermodal is a six-track transfer station for rail-to-truck and vice-
versa shipping.  This short line railroad, managed by Lehigh Valley Rail Management, has direct access
to a major Norfolk Southern railroad and is expected to move more than 80,000 containers annually.
Currently, 20 people work locally for Lehigh Valley Rail Management with additional work intermodal
handled by contractors.

The old intermodal terminal is located on the 450-Acre Area (in East Lehigh) which has been
proposed for warehousing development (see description under 450-Acre Area below).  Operations at
the old terminal will cease when the new Bethlntermodal opens, which is anticipated for mid-2006.

Commerce Center Boulevard
Commerce Center Boulevard is a $13 million,  4,200-foot road linking Rte. 412 with the new
Bethlntermodal and  the 450-Acre Area in East Lehigh. Construction started in mid-2004, and when
complete will provide access to the eastern third of Bethlehem Commerce Center. Part of the
Boulevard crosses the Coal Chemical area. BSC studied the risks the Coal Chemical area posed to
road construction workers as well as those using the road, and submitted a risk evaluation to EPA and
PADEP.  EPA and PADEP approved construction of the road in July 2001. At this time, the road is
expected to be finished in early  2006.

East Lehigh
Conectiv Bethlehem  Generation
A 53.3-acre area along Apple Butter Road in the northeastern most portion of the site is home to a
1100-watt natural gas fired power plant.  BSC  submitted a soils characterization report, "Final Report
of Soils, Conectiv Mid-Merit, Inc., Project Area", which EPA and PADEP approved in October
2001. The contaminants in the soil are below Pennsylvania Act 2 state-wide health-based levels.
PADEP granted liability protection for soils pursuant to the Act 2 program. Conectiv bought the
property and began construction of the plant shortly thereafter.  The plant went "on line" in early 2003.
Total investment in this project  is expected to be $600M.

450-Acre Area
An additional 450 acres in the East Lehigh area has been proposed for a warehousing and distribution
center. ISG is currently in negotiations with a real estate developer based in California. Some industrial
activity was formerly located on the site.  A soils characterization has been completed and is under
evaluation. A groundwater investigation is expected to commence in mid-2007.

Easton Road Frontage Properties
Half of the 100 acres of property along Easton Road (paralleling Rte 412) is being eyed for immediate
redevelopment in 2006 and 2007.  Environmental investigation of the former mineral wool area of
Bethlehem Steel began in 2005, and is expected to be completed in mid-2006.  Two prospective
buyers have shown interest in the acreage.

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Saucon
Investigation and clean-up of this 265-acre tract began in early 2004 and is expected to last until 2008.
Saucon is slated for redevelopment and has been divided into sections for both investigation and resale.
In July 2004, 31 acres was sold to United States Cold Storage for refrigerated storage and
warehousing.  The business began operation in mid-2005 and employs 50 workers. In December
2005, Primo Produce, Inc. purchased 30.7 acres for a food warehousing enterprise.  At this time, at
least two other prospective buyers are interested in sections of the Saucon tract.

Greenway
The Greenway is currently owned by LVIP, purchased in May from ISG. LVIP is looking into
creating a public environmental or educational area on these 110 acres along the easternmost property
boundary.  LVIP will coordinate with state and local groups to determine the best use of this property.
Site Description
Located on the south side of Bethlehem, PA, Bethlehem Steel's Bethlehem Plant has been in operation
since the 1880s. BSC closed its last operations in March, 1998. The site, part of which borders then
Lehigh River, consists of approximately 1800 acres, on which are a coke production plant, steel iron
making operations, finishing and forging operations, and a chemical plant. In May 2003, Bethlehem
Steel Corporation went into bankruptcy and this Bethlehem Steel site was sold to an International Steel
Group subsidiary, Tecumseh Redevelopment Corp.  In May 2004, the Coke Works, Saucon, East
Lehigh, and Greenway parcels were sold to Lehigh Valley Industrial Park, Inc, a local redevelopment
firm and owners of several industrial parks. In 2004, Tecumseh Redevelopment sold Bethlehem Works
to BethWorks Now.  Tecumseh continued to own the 450 -Acre area.  In 2004, a Dutch steelmaker,
Mittal Steel, purchased ISG, including Tecumseh and the 450-Acre area.


Contaminants
The main contaminants in the groundwater are PAHs (poly aromatic hydrocarbons), and solvents, such
as TCE and tetrachloroethane, The primary contaminants in the soil are solvents, PAHs,  and heavy
metals, such as arsenic and lead.
Community Interaction
From the out-set, BSC worked closely with the city of Bethlehem on the redevelopment project. BSC
issued all public notices of "Intent to Remediate" and "Remedial Investigation Report" required under
the Act 2 program. Bethlehem Steel held a public meeting October 21, 1998 to keep the public up-to-
date on the investigation to that point,  as well as future investigations and resale plans for the property.
PADEP and EPA were in attendance.

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Institutional Controls
The groundwater under the site will not be used for drinking water.  The Bethlehem Commerce Center
property will be used for non-residential purposes only.

Government  Contacts
EPA Project Manager
Ms. Linda Matyskiela - 3WC22
U.S. Environmental Protection Agency - Region III
1650 Arch Street
Philadelphia, PA 19103-2029
Phone: (215) 814-3420
Email: matyskiela.linda@epa.gov

PADEP Project Manager
Mr. Randy Roush
Pennsylvania Department of Environmental Protection
Bureau of Land Recycling and Waste Management
Rachel Carson State Office Building
400 Market Street
Harrisburg, PA 17105
Phone: (717)787-7816
Email: raroush@state.pa.us

For more information about EPA's corrective action webpage, including Environmental Indicators,
please visit our site at: www.epa.gov/reg3wcmd/correctiveaction.htm

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