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UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION III
FINAL DECISION AND RESPONSE TO COMMENTS
SANDS BETHWORKS GAMING, LLC
(A PORTION OF THE FORMER BETHLEHEM STEEL CORPORATION)
The United States Environmental Protection Agency (EPA) is issuing this Final Decision and
Response to Comments (FDRTC or Final Decision) selecting the Final Remedy for a 56.27-acre
parcel of the Former Bethlehem Stcci Corporation - Bethlehem Structural Products located in
Bethlehem, PA (hereinafter referred to as the Parcel). The Final Decision is issued pursuant to
the Solid Waste Disposal Act, as amended by the Resource Conservation and Recovery Act
(RCRA) of 1976, and the Hazardous and Solid Waste Amendments (HSWA) of 1984, 42 U.S.C.
Sections 6901, et seq. EPA issued a Statement of Basis (SB) in which it described the
information gathered during environmental investigations at the Parcel and proposed a Final
Remedy for the Parcel. The SB is hereby incorporated into this Final Decision by reference and
made a part hereof as Attachment A.
This FDRTC selects the remedy that CPA evaluated under the SB. Consistent with the public
participation provisions under RCRA. EPA solicited public comment on its proposed Final
Remedy. On March 24, 2017, notice of the SB was published on the EPA website:
[https://www.epa.gov/pa/epa-public-notices-pennsylvania] and in The Express-Times newspaper.
The thirty (30) day comment period ended on April 24, 2017.
Since EPA did not receive any comments on the SB. the remedy proposed in the SB is the Final
Remedy selected by EPA for the Facility.
BETHLEHEM, PA
PAD 99 082 4161
PURPOSE
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FINAL REMEDY
EPAs 1 ¦inal Remedy for the Puree! includes the following:
* I he Pared property shall not he used for residential purposes unless there is a prior
demonstration to PADPP and 11 PA that such use will not pose a threat to human health or
the environment:
* Groundwater shall not be used for any potable purpose and no wells shall he installed,
unless authorized by PADKP or Id'A and used lor monitoring or remediating:
* If any asphalt, concrete, soil or other groundcover is excavated or removed, remaining
soil or other materials in that area shall either 1 ) he demonstrated to meet Penns\ Ivania
Medium-Speeille Concentrations, or 2) be covered with material that eliminate pathuavs
of exposure to the underlying soil: and
* Hie Puree! will not he used in a way that will adversely affect or interfere with the
integrity and protectiveness of the final remedy .
l-.PA's final Remedy will be implemented by compliance with existing use and activity
restrictions lor the Parcel. I hese restrictions are already in place and include a PADhP-siiined
filiform lai\ironmental Covenant, recorded May tW. 2D I." with the Northampton County
Recorded of Deeds, and an exisitng City of Bethlehem ordinance restricting groundwater use.
DECLARATION
Based on the Administrative Record compiled lor the corrective action at the Sands Bethworks
Gaming. l.i.C parcel ol the former Bethlehem Steel facility. 1 have determined that the remedv
selected in this f inal Decision and Response to Comments, which incorporates the March 21.
2017 Statement of Basis, is protectiv e of human health and the environment.
Date:_ " 1 ¦ . ; _____ i-
Martha Nhimkin. Acting Director
Land and Chemicals Division
I'.S. I.nv ironmental Protection Agency, Region lil
Attachment A: Statement of Basis (March 21. 2017)
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ATTACHMENT A
STATEMENT OF BASIS
Sands Beth works Gaming, LLC
(A Portion of Former Bethlehem Steel Corporation)
Bethlehem, PA
PAD 99 082 4161
March 21, 2017
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UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION III
STATEMENT OE BASIS EOR PROPOSED REMEDY
Sands Bethworks Gaming, LLC
(A Portion of Former Bethlehem Steel Corporation)
BETHLEHEM, PENNSYLVANIA
PAD990824I61
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I, Introduction
The United States Environmental Protection Agency (EPA) has prepared this Statement of Basts
(SB) to solicit public comment on its proposed remedy for a 56.27-acre parcel (Parcel) located
on die property formerly owned ami operated by Bethlehem Steel Corporation - Bethlehem
Structural Products (BSC) (hereinafter referred to as the BSC Facility or Site), located in the Cit\
of Bethlehem. Northampton County. Pennsylvania. This SB applies to the portion of the Facility
currently owned by Sands Bellnvorks Gaming I EC. who acquired the proper!v in 2007.
EPA's proposed remedy consists of compliance with and maintenance of institutional controls
(ICs) and operation and maintenance of engineering controls (EC's) that are already in-plaee and
approved by Pennsylvania Department of Environmental Protection (PA13EP), This SB
highlights key information relied upon by EPA in developing this proposed remedy.
I he former Bethlehem Steel Corporation - Bethlehem Structural Products property is subject to
EPA's Corrective Action Program under the Solid Waste Disposal Act. as amended In the
Resource Conservation and Recovery Act (RCRA) of 1976. and the Hazardous and Solid Waste
Amendments (1ISWA) of 1984, 42 II.S.C. §§ 6901 et seq. {Corrective Action Program). The
Corrective Action Program is designed to ensure that certain facilities subject to RCRA haw
investigated and cleaned up any releases of hazardous waste and hazardous constituents that
have occurred at their property. The Commonwealth of Pennsylvania (Commonwealth) is not
authorized for the Corrective Action Program under Section 3006 of RCRA. Therefore. EPA
retains primary authority in the Commonwealth lor the Corrective Action Program.
1 he Administrative Record (AR) for the Parcel contains all documents, including data and
quality assurance information, on which EPA's proposed remedy is based. An index to the
Administrative Record is included at the end of this SB. See Section IX, I'tih/ic Participation.
for information on how you may review the AR.
IE Facility Background
The BSC Facility had been a fully integrated steel mill consisting of approximately 1600 acres
on the hanks of the Lehigh River in Bethlehem. PA {Figure 1 >. All manufacturing operations
ceased in the 1990s. The Facility was divided into various parcels to ease environmental
investigation and eventual redevelopment. The Bethlehem Works Parcel consists of 160 acres
on the western-most edge ot the Facility, with numerous structures such as buildings, parking
lots. I he Bethlehem Works Parcel is bounded to the east and west by industrial properties once
owned by Bethlehem Steel. Third Street to the south and railroad tracks to the north. Just
beyond the rail tracks to the north is the l.ehigh River.
Currently the Bethlehem Works Parcel is being redeveloped and has been divided into 27 smaller
parcels as jihoun in figure 2. 1 he Sands Bethworks Gaming EEC parcel (parcel I 7). is the
subject of this SB. The environmental investigation discussed in the documents in the AR was
conducted across the entire Bethlehem Works Parcel and reviewed by both PADEP and EPA.
Section III below - Summary of Environmental Historv- is applicable to the entire i 60-acre
Bethlehem \\ orks Parcel. The proposed remedy discussed in remainder of this SB pertains only
to the Sands Bethworks Gaming EEC parcel which comprises >6.27 acres. EPA plans to issue a
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separate SB fur [lie Sands Bethworks Retail Parcels (Parcels 1.2.5-10. 12-16. and 21-27). The
Redevelopment Authority of Bethlehem owns Parcel I I which will also receive a final decision
by I-PA. Parcels 3,4,19, and 20 have already received a final decision from HP A.
flf. Summary of Fnvironmcntal History
A. Soils
{.Note: The investigations referenced in this section were conducted under the PADFP/FPA
One Cleanup Program. Soil investigation results were compared to both F.PA non-
residential screening levels (RSI.s) and PADKP non-residential state-wide health standards
(or media specific standards - MSCs). The reports generated by (lie investigations
typically used the MSC nomenclature. For non-residential use, PADF.P and KPA
standards are Imtli protective. The MSC nomenclature is used in this SB to aid the reader
in using tlie references found in the Administrative Record)
Numerous sampling events were completed between 19()5 and IWX for the soils investigation at
areas identified in the RCRA Facility investigation (RFA) and other areas identified as
potentially having contact with hazardous waste at the Bethlehem Works Parcel. More than 200
.soil samples from over 120 locations were collected to meet both Act 2 and Corrective Action
guidelines for site investigation and cleanup. Samples were analyzed for priority pollutant
metals and organic constituents. The sampling results were compared to non-residential .soil
MSCs for direct contact and soil-to-groundwater pathways.
Concurrent with the investigation, demolition of certain buildings and. remoutl of debris were
completed under the redevelopment plan. The soils beneath the building foundations, were not
investigated. I-PA does not anticipate .significant contamination beneath former structures.
Nonetheless, am changes to these features will require the then-owner to re-evaluate the current
conditions and exposure pathways. This requirement is specified in the Hnviroiimeitta! Covenant
for each parcel on the Bethlehetn Works property.
To simplify the site-wide investigation during Phase II, the site was divided into various
production areas which had similar potential hazardous constituents. Fach of these areas
contained a number of tanks, degreasers. storage areas, and other areas of concern. A list of the
Solid Waste Management Units, grouped by production area investigated, is provided in Table
I A. The investigation also included a number of Areas recognized lor potential contamination.
Areas that required remedial activities are listed in "fable IB, Detailed descriptions of all areas
investigated and the applicable sampling results are presented in the Remedial Investigation,
Risk Assessment and Cleanup Plan (RI/RA/CP) and supplemental information submitted in 1998
and in the two Final Reports for Soils submitted in 2000 and 2002.
BSC removed soils and other materials from live distinct areas on the Bethlehem Works
Properly. These soils and other materials were determined to contain regulated substances at
concentrations above non-residential MSCs for soils. Post removal samples of underlying soils
were collected to ensure that remediation was adequate.
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Iran Foundry Sam! Pile (Sands Belinrorks Rvlai!IAX
A stockpile of primarily foundry sand was located between ihe Iron Foundry Building and the
Iron Casting, Cleaning and Shipping Building in the central portion of Bethlehem Works, This
foundry sand was produced by using sand as the mold material in easting molten iron. The
footprint of the pile was approximately 1600 square feet. The pile was sampled, characterized,
and excavated in April 199K, Lead and cadmium were found at levels above direct contact
MSCs. Approximately K3 cubic sards (123 tons) of sand was removed. Following remov al, soil
samples were collected from within the former footprint of the pile. These confirmatory samples
did not detect any lead or cadmium above their MSCs of 1000 mg kg for lead and 1400 me kg
for cadmium.
Sails Near BF-S' (Sands Retail Belinrorks l,l.(')
Soils with coal tines and tar-like material was removed from the area of monitoring well BF-S, in
the northwest section of the Facility. This material was found during installation of BF-S in
1995. Sampling showed PA lis above direct contact health standards (for benzo(a)p\ rene and
diben/.ola.h (anthracene). Approximately 125 cubic uirds of material was removed in 1998, Post
excavation sampling from within the footprint showed detected concentrations below direct
contact MSCs (11 mg'kg) for both constituents,
Tar 'Pitch Tank Pad (Sands Retail Belinrorks LI A'/
Also in the northwest .section of the Bethlehem Works Parcel, a tar pitch tank pad was
discovered south of monitoring well BF-8. Coal tar was found imbedded in a portion of the
concrete pad and in two sumps. Affected concrete and surrounding soils were excavated; 21
cubic yards (18 tons}. Samples taken of the area after excavation show attainment of the Act 2
statewide health standards for direct contact in soils for PAlIs. which ore the primary
constituents in coal tar.
Sintering Plant (Saihls Bethworks (ianting /./,('/
The soils near the Sintering Plant electrostatic precipitators indicated the presence of arsenic and
lead, lixeavation of approximately 200 cubic vards was completed in 1999, Post excavation
sampling showed two samples above the lead direct contact standard of 1000 mg 'kg I at 2800
mg 'kg and 7360 mg 'kg). However. 75% of the samples were below the 1000 mg kg standard
and the 95% upper confidence limit calculated for the lead data set is below the 1000 mg'kg
standard. Thus, this area meets the non-residential MSC for lead.
Arsenic was not found above Act 2 MSCs.
Car Tipper Area f Sands Bvtltuorks LI A ")
Soil sampling showed PA1 fs above remedial standards in the Car Upper area. In 2002, 2.4 cubic
yards of soil was excavated. Sampling of the soils below the excavation showed no PA1 Is above
Act 2 nonresidential standards.
B, (iniuiuhvakr
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i here are three aquifers beneath the Bethlehem Works site area. The site is immediately
underlain by an unconsolidated aquifer consisting of alluvium and (III material. Groundwater
upgrauient of the site Hows toward the site in a carbonate aquifer directly beneath the
unconsolidated aquifer. A granite gneiss aquifer, deepest of all. remains mostly upgradieni of
the site. Groundwater Hows from south to north across the site. At the Bethlehem Works Parcel,
contaminants have been found only in the shallowest, unconsolidated alluvium unit.
Sixteen new monitoring wells and three existing wells were installed across the site and along
the perimeter of the site. Well placement was based on historical operations and land usage in
addition to groundwater How patterns. These 19 wells, were used to evaluate groundwater
quality and to determine potential pathways and risks to the Lehigh River.
These monitoring wells were sampled once in 1995 and quarterly in 1997 and 1998. fifty four
samples were analyzed for organic and inorganic constituents. Additionally, groundwater
samples were collected % ia direct push technology at locations of suspected releases of
irichioroeihene t'lCT l and 1.1 .l-trichloroelhane (TCA). used in five degreasers located in
buildings on the site.
l ive of the sixteen wells were constructed in bedrock; the remaining 11 are completed in the
overburden. Total depth of these sixteen wells ranges from 30 to 122 feet. The three existing
wells were original!) used to supply production water to the plant. The Spring Pit. a shallow
pond-like well located near the Kleetric Furnace Melt building remained in operation until 1998.
The Drop Forge Well, several hundred feet deep, stopped pumping in 1987 and was
decommissioned in 1998. The Blue Mountain Well, also several hundred feet deep, was pumped
until 2000. at which time it was decommissioned.
Groundwater samples were analyzed for organic and inorganic compounds, and were compared
to the Aet 2 Medium-Speeillc Concentrations (MSCs) for Non-Residential Used .Aquifers.
Detected concentrations were generally below the applicable MSC. however concentrations of
volatile organic compounds (VOCs) downgradient of the Kleetric Repair Building (LRB)
exceeded MSCs for TCA, TCL. and 1,2-dichloroethene (l)CI'). The maximum detected
concentration of TCA was 7S(K)ug/|, 120ug/l for TCli, and 2S0ug/i for IXT. The MSCs for
these constituents are 2(K)ug I. 5ug. 1 and 7ug 1 respectively. It is important to note that this
contamination was only found in the overburden aquifer. The carbonate and gneiss aquifers are
not affected by past releases in the \icinily of the Bethlehem Works Parcel.
Although the VOC presence appeared to be localized, HI'A determined that additional
information was needed lo verify that the contamination was not impacting lower aquifers or the
Lehigh River. During 1999 and 2000, BSC conducted a Verification Monitoring Program to
provide this information. Three additional wells were installed along the most likely migration
route between the ERB and Lehigh River. These wells sampled over lour quarters for VOCs
and polyarotnatie hydrocarbons {['Alls).
HI
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Results lrom the Verification Monitoring Program indicated that the VOC contamination is
localized near the F.RB and has been attenuating. Contaminate levels in the uppermost aquifer
actually meet drinking water standards before discharging to the Lehigh River. The final
sampling event at the source area showed IX A concentration at 2 !k assessment)
With respect lo ecological receptors on the site, other than the Lehigh River, no sensitive
habitats, such as wetlands or endangered species exist on the site. The site currently has. and
will have in the future, ground cover of buildings, parking lots and roads that eliminate direct
contact exposure pathway for ecological receptors.
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I). Soil Cas
Soil gas samples were located neat* or down gradient of potential sources for VOCs. Thirteen
areas were targeted, where 158 samples were collected using direct push technology, at depths of
(1-2 and 2 to 1 5 feci below ground surface. Samples were initially screened using I'll) or FID.
Samples with screening reading.-, of over Klppin weic then analyzed using a Held portable ga-,
chroniatograph. These samples were analyzed for vinyl chloride, DCH. TCA. TCE, PCI:,
toluene, and ethyl benzene. Samples were compared to criteria for worker exposure to
substances in air: NIOSI I. ACGIll. and OSIIA. Only one sample exceeded a criterion, for vinyl
chloride. This sample result is questionable as it was the lone exceedatiee, and found at the 0-2
foot depth. Vinyl chloride is highly volatile and it is unusual for it to be found at a shallow
depth. Other shallow and deeper samples in the vicinity did not detect vinyl chloride, 'flic
icsnlls of the soil ga^ survey indicate that VOCs arc not being released from soils or
groundwater.
In addition to soil gas sampling, indoor air samples were also collected to evaluate the potential
of VOCs to migrate into buildings. Indoor air samples were collected from the ERR, Carpenter
and Pattern Shop. Machine Shop 2 and Central 'fool Annex. These locations were selected as
they once contained vapor degrcasing units or were located above groundwater in which VOCs
have been detected at levels above applicable MSCs. Two sampling pumps were placed in each
building, within 10 to 20 feet of the former vapor degreaser locations. The air samples were
collected after approximately 8 hours. l aboratory results showed no substances were detected,
which indicates VOCs are not migrating into buildings at measurable concentrations. The results
of indoor air sampling support the findings from the soil gas samples; VOCs arc not present in
soil gas at concentrations that pose a risk. In addition, the findings show the former degreascis
do not pose an inhalation risk in the buildings.
E, Risk Assessments
On March 31, 1998. the Facility submitted a Notice of Intent to Remediate to PADIiP pursuant
to Act 2. A combination of the Act 2 Non-residential Statewide Health Standards (SMS) and Site-
Speeilie Standards (SSSs) were chosen as the cleanup goals to be aehicsed.
BSC presented the May 28. 199X Rl/RA/CP as the first formal submission under the Act 2
process. The Risk Assessment, contained within, describes potential exposures to regulated
substances at the site. A combination of pathway elimination and transport modeling was used
to assess potential exposures and to determine site-specific standards. Additional analytical data
for groundwater was collected in 1999 and 2000. The evaluation of this data was, in part
presented as a quasi-supplcment to the Risk Assessment, to bolster the presented evaluation.
This evaluation is found in the January 11. 1999 memo from BSC to IT'A. This document can
be found in the Administrative Record for this SB.
The following assumptions on future use were used to develop the Risk Assessment and were
discussed with the stakeholders, including City of Bethlehem officials;
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• The Bethlehem Works property will he restricted to non-residential uses;
• The future use of groundwater for any (potable or non-potable) purpose will be
prohibited, other than tor potential environmental monitoring,
• An existing public water system supplies drinking water in the area. (hound water use is
prohibited by local ordinances and'or other institutional controls.
• Current ground cover (i.e. pads, roadways, etc.) will remain in place.
• Future redevelopment plans indicate unpaved areas will be covered by asphalt, concrete,
clean fill. etc. eliminating direct contact pathways.
The Risk Assessment evaluated exposures to current or future outdoor worker, indoor worker,
and recreational visitor (potential receptors) from groundwater and surface water from identified
constituents of interest, Expostites and cleanup levels were based on comparison of the
maximum delected analytical groundwater results to PADHP medium specific concentrations
(MSCs) and PADHP Water Quality Criteria (WQC) for surface water protection.
EPA has reviewed the risk assessment and the resulting calculated standards (Fables A and 2B).
HPA has determined that the risk assessment was conducted in accordance with HPA guidance
and that the groundwater and soil standards are protective of human health and the environment
for non-residential land use,
IV. Corrective Action Objectives
1, Soils
hPA's Corrective Action Objective for the Parcel soils is to prevent residential-level exposure to
hazardous constituents remaining in the soils. This proposed remedy requires continued
compliance with land use restrictions imposed by PADHP in the form of an Environmental
Covenant. The Parcel meets Pennsylvania's Non-Residential Statewide I leallh Standards
(NRSI IS) for soils. HPA has determined that these standards are protective of human health and
the environment for individual contaminants at the Parcel. The Non-Residential SI ISs meet or
are more conservative than HPA's acceptable risk range for non-residential use.
2. Groundwater
HPA's Corrective Action Objective for groundwater is to prevent potable use of the uppermost
aquifer by requiring the compliance with and maintenance of groundwater use restrictions at the
Parcel. 1 he former Bethlehem Steel originally implemented these as deed restrictions in IW.
Beth works-Sands converted these restrictions to an Environmental Covenant in 2013, (The Cit\
of Bethlehem already prohibits the use of groundwater for consumptive purposes anywhere
within the City limits.)
Based on groundwater data collected from this parcel, contaminate levels in the uppermost
aquifer attenuate to drinking water standards (or were not detected) by the point at which the
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groundwater discharges to the Lehigh River. A groundwater model was used to ealeulale
potential effects on surface water. The model was run using the highest levels of contaminates
found during the investigation and assumed these levels were present in the groundwater
immediately prior to discharge to the Lehigh River. The model result showed that the Lehigh
River will not he impacted by groundwater discharging from the site. Those calculated levels
can be found in Table 2A.
HPA is not requiring periodic monitoring of groundwater for the Parcel, as is generally done with
attenuation remedies. There is no exposure risk and two independent prohibitions are in place to
prevent groundwater use. The property has been redeveloped into a commercial and
entertainment complex, so the long term use of the property will be non-residential. PADIP and
HP A approved closing of all monitoring wells on the Parcel as part the redevelopment activities.
3. Vapors
I:PA's Corrective Action Objective for the Parcel vapors is to control exposure to this hazard h\
requiring the compliance with and maintenance of land use restrictions at the Parcel as provided
for in the environmental covenants applicable to this property.
5. Surface Water and Sediment
HPA has determined that the cleanup standards calculated for groundwater in Table A and the
groundwater MSC's are protective of human health and the environment for individual
contaminants at this Parcel, as groundwater discharges to the Lehigh River. Therefore, I'PA's
Corrective Action Objective for .surface water and sediments is to control migration to the
Lehigh River with a combination of engineering and institutional controls.
V. Proposed Remedy
HPA has determined that the existing ground cover and construction of new structures and
parking areas are protective of human health and the environment by control ling exposure to
environmental media at this Parcel.
1 'se and acli\ it> restrictions are already in place and include a PADHP appro\cd registered
Uniform Environmental Co\enant and an existing City of Iknhlehem ordinance restricting
groundwater use. Below" are pertinent sections of the Covenant:
(A) If any asphalt, concrete, soil or other ground cover is excavated or
removed remaining soil or other materials in that area shall either (1) be demonstrated to
meet Pennsylvania MSCs. or (2) be covered with material that eliminate pathway's of
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evposiire tn ihe underhtng soil. '1 his cover material ma> consist of (a) new asphalt, (h>
new eoncrele. (e| nol less than twelve (12) inches of clean soil, or (d) an alternative cover
that is capable of phvsieallv supporting the intended use of the area and that provides
protection to eliminate pathwavs of exposure to and from the underlying soil
(II) C iroundwater shall not he used for any purpose and no wells shall he
installed, unless authorized by the Department. However, monitoring welis and treatment
wells may he installed so I eh for the purpose of monitoring and remediating.
(C) I he Parcel property shall not be used for residential purposes unless it is
demonstrated to PA 1)1'.P. in consultation with HPA. that such use will not pose a threat to
human health or the environment or adversely affect or interfere with the selected remedy
and PADHP. in consultation with HPA. provides prior written approval for such use:
(D) The Property will not he used in a way that will adversely affect or
interfere with the integrity and protect iveness of the final remedy:
VI. Evaluation of l,PA\s Proposed Remedy
1 his section provides a description of the criteria HPA used to evaluate the proposed remedy
consistent with HPA guidance. The criteria arc applied iti two phases. In the first phase, HPA
evaluates three remedy threshold criteria as general goals. In the second phase, for those
remedies which meet the threshold criteria, HPA then evaluates seven balancing criteria to
determine which proposed remedy alternative provides the best relative combination of
attributes.
A, i hreshold Criteria
1. Protect Human Health and the Environment
BSC has remediated on-site soils to protect human health and the environment for industrial use.
using current ground cover. Since current and anticipated land use is industrial, controls will be
implemented a! the Parcel to restrict future property uses to ensure that human health and the
environment remain protected,
On May S. 2013. Sands Rethvvorks (taming. LLC recorded an environmental covenant which
imposes land and groundwater use restrictions and conditions regarding the use of the Parcel
property and groundwater. Under the covenant. Parcel proper!}' may only be used for non-
residential purposes and groundwater beneath the properly ma)' not be used for any purpose.
These conditions are enforceable and provide long-term assurance that the exposure assumptions
used in developing HPA's proposed remedy are not changed without approval.
2. Achieve Media Cleanup Objectives
The Parcel has achieved the appropriate cleanup standards for soils, groundwater, and surface
water, These standards meet HPA risk guidelines for human health and the environment at the
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Fared. KPA's proposed remedy requires compliance with the implementation and maintenance
of institutional controls to ensure that Parcel property is not used for residential purposes, current
ground cover remains in place and groundwater beneath Parcel propertv is not used for any
purpose,
3, Remediating the Source of Releases
In all proposed decisions, i •PA seeks to eliminate or reduce further releases of hazardous wastes
or hazardous constituents that ma> pose a threat to human health and the environment.
As described in the Summary of Environmental History section above, the Parcel has remediated
the sources of releases. There are no remaining large, discrete sources of waste from which
constituents would be released to the environment. Therefore, I:PA has determined that this
criterion has been met.
B, Balancing/Evaluation Criteria
1. Long-Term Kffcctivcness
The proposed use of institutional controls will maintain protection of human health and the
environment over time by controlling exposure to the hazardous constituents remaining at the
Parcel. EPA's proposed remedy requires the compliance with and maintenance of land use and
groundwater use restrictions at the Parcel. The land use and groundwater use restrictions have
already been implemented through an environmental covenant recorded in the chain of title of
the deed for the Parcel property. The environmental covenant runs with the land and as such will
be enforceable against future land owners.
2. Reduction of Toxicity, Mobility, or Volume of the Hazardous Constituents
The reduction of toxicity and volume of hazardous constituents at the Parcel has already been
achieved by decommissioning the Parcel structures and soil excavation as described in the
Summary of Environmental IUstory section above
3. Short-Term Effectiveness
EPA's proposed remedy does not involve any additional activities, such as construction or
excav ation that would pose short-term risks to workers, residents, and the environment. In
addition, the land use and groundwater use restrictions have already been implemented through
an environmental covenant recorded in the chain of title of the deed for the Parcel property.
4. Im|)lemcntabi)ity
I-PA's proposed remedy is readily implementahle. An environmental covenant has already been
recorded and the engineering and institutional controls are in place. Therefore, EPA does not
anticipate any regulatory constraints in implementing its proposed remedy.
5, Cost
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An environmental covenant has already been recorded in the chain of title of the deed to the
Parcel property. Therefore, there should be no additional costs associated with the proposed
remedy.
6. Community Acceptance
KPA will evaluate Community acceptance of the proposed remedy during the public comment
period and will be described in the final Decision and Response to Comments (FDRTC).
7. State/Support Agency Acceptance
Environmental cleanup at this Parcel has been overseen by PADKP as part of Pennsylvania's Act
2 Program since 1998. PADf.P approved the Act 2 Final Report for remedial activities on
November 3. 2010. HPA will evaluate further State acceptance based on any comments received
from PADKP during the public comment period and will be described in the FDRTC.
¥11, (environmental Indicators
HPA sets national goals to measure progress toward meeting the nation's major environmental
goals, for Corrective Action, KPA evaluates two key environmental indicators for each facility:
(1) current human exposures under control and (2) migration of contaminated groundwater under
control. The EPA has determined that the Parcel met these indicators on April 19, 1996 and
April 02. 1999.
VII i. Financial Assurance
KPA has evaluated whether financial assurance for corrective action is necessary to implement
KPA's proposed remedy at the Parcel, (liven that Kl'A's proposed remedy does not require any
further engineering actions to remediate soil contamination at this time and gi\en that the costs
of implementing institutional controls at the Parcel will be minimal. KPA is proposing that no
llnancial assurance he required.
IX, Public Participation
Before KPA makes a final decision on its proposal for the Parcel, the public ma> participate in
the remedy selection piocess by reviewing this SB and documents contained in the
Administrative Record (AR) for the Parcel. The AR contains all information considered by RPA
in reaching this proposed remedy. It is available for public review during normal business hours
at:
U.S. HPA Region 111
1650 Arch Street
Philadelphia. PA 14103
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Contact: Ms. I.in
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INDKX TO ADMINIS'I KAT1VK. KKCORI)
Gmundw afcr
Draft 1U'KA Hacilin Assessment. Bethlehem Steel Corporation. September 28. ] Wn. CDM for
EPA
Groundwater Flow Study Report of Findings. Bethlehem Plant, June 1995; GT1 for BSC, 1
binder
Remedial Investigation. Risk. Assessment, and Cleanup Plan, Bethlehem Works Site, May 28,
1998; SAIC for BSC, 6 binders (on CD)
SugfikiffiaaiiJaim^ Plan
Report, Bethlehem Works Site, August 27, 1998; SAIC for BSC to PADEP, 71 pgs, (on CD)
I;PA Comments to Remedial Investigation, Risk Assessment, and Cleanup Plan, Bethlehem
Works Site, December 22, 1998; EPA to BSC, 8 pgs.
Summary Document for Sut'lieient Characterization, January 11, 1999; BSC to I-PA. 14 pg.s.
Verification Requirements for Beth Works Groundwater. March 03, 1999; HPA to BSC, 4 pgs.
Letter of Aet 2 Liability Protection for Groundwater at Beth Works Site, April 05, 1999: PADI'P
to BSC, Ipg.
Approval of Soils and Groundw ater Remediation, April 2, 1999; HPA to PADL11. 6 pgs.
Approval of Soils and Groundw ater Remediation, May 06. 1999; HPA to I'ADI J\ 6 pgs.
Results for Verification Monitoring- Bethlehem Works_Site. Sept IC>. 1909; BSC to l l'A. K l p-s
Bethlehem Works Site Verification Monitoring Program Results. May 5. 2000; BSC to HPA, 4
pgs,
Bethlehem Works Site Groundwater Approval, January 22, 2001; HPA to BSC. I pg.
Soils
DrafiJCRA Facility Assessment, Bethlehem Sleel Corporation. September 28, 1990; CDM for
HPA
Remedial Investigation. Risk Assessment, and Cleanup Plan. Bethlehem Works Site, May 28,
199S: SAIC for BSC. 6 binders (on CD)
[13]
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Supplemental Information In I lie Remedial Investigation. Risk Assessment. and Cleanup Plan
Report. Bethlehem Works Silo. August 27. 1998; SAIC tor BSC to PADHP, 71 pgs. (on ( 1)1
Silc-Spccitic Standards for Soils tor the Bethlehem Works Site, January 26, 1999; SAIC to
padhp. 5 pys.
Residual Materials as Construction Mil, March 12, 1999; PADHP to BSC, 2 pgs.
Approval of Soils and Groundwater Remediation. April 2. 1999; HP A to PADEP. 6 pgs.
Approval of Soils and Groundwater Remediation. May 06. 1999: FPA to PADHP. 6 pgs,
An Hvaluation ol the Potential for .Acute Health Hlfccts on Children Hxposed to Iron ill Surface
Soi!s_andJ)ther Materials. October ll'9lJ: SAIC for BSC. 5 I pgs. (on CD)
final Report for Soils Phase 1 Area. Bethlehem Works Site. April 2000; SAIC for BSC. 219 pgs.
(on CD)
Pinal Report for Soils Phase 1 Area, Bethlehem Works Site, April 14. 2000: Cover letter. Act 2
transmittal sheet, final report summary, checklist and proof of public notice, 42 pgs.
Bethlehem Works Posl-Charaeterization Supplemental Soils Sampling, June 5, 2000; BSC to
PADHP. .1 pgs.
Amendment to Final Report for Soils Phase 1 Area, Bethlehem Works Site. August 10, 2000;
BSC to PADHP, 5 pgs.
fetter of Act 2 liability Protection for Phase I Soils Area at Bethlehem Works Site. September
14. 2000: PADHP to BSC. 2 pgs.
final Report for Soils Phase 11 Area. Bethlehem Works Site. November 2002; SAIC for BSC.
138 pgs. {on CD)
Replacement page to Final Report for Soils Phase II Area. Bethlehem Works Site, January 31,
2003: SAIC to PADHP. 2 pgs.
I etter of Act 2 Hiability Protection for Phase II Soils Area at Bethlehem Works Site. February
i9. 2003; PADHP to BSC. 2 pgs
Demolition Cleanup Process, February 23, 2006 Hmail: I iDR to HPA, 2 pgs.
[14]
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Ownership/Kitvironmental Cm cmints
Bethlehem Works Phase I Area. October 12, 2001; recorded by BSC
Bethlehem Works Phase II Area. September 13, 2004; recorded In Tecumseh Redevelopment
inc.
Map of Sands Betlnvorks Properties. August 04. 2011
Hnvironniental Covenant, Condominium I'nit 1. May 08. 2013. recorded by Sands Beth Works
(iaminy. LI.C
Public Participation
Press Release- October 14. 1')<)S; Morning Call article- October 14. 1998; Morning Call article
October 14, 199S: 5 pgs.
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Table 1 A: Solid Waste Manure nit* lit I'nits Identified in UFA
Solid Waste Management
Unit {as identified in UFA)
20 Blast Furnace
Waste Description
Waste
nestination
Release noted
in UFA?
Kcmcdiatio
n |
[ )orr Clari Tiers
Non-hazardous iron
fines and carbon
Sinter Plant,
RWL
No release
Vacuum Filters
Nun-ha/auious iron
lines and carbon
Sinter Plant,
RWL
No release
Cast Mouse Baghnuses
Non-hazardous iron
oxide
RWL
No release
Flue Dust Catchers
Non-hazardous iron
tines and carbon
Sinter Plant.
RW1
No release
M21 Sinter Plant
1
Precipitators
D006/D008 1 On-site piles.
Cadmium. Lead, then off-site
Arsenic i
Release to soils
Fxcavation
in 1999,
(200 yd.l)
C\ clones
'
1)0061)008
Cadmium. Lead.
Arsenic
D006/D008
Cadmium. Lead,
Arsenic
On-site piles,
then off-site
Release to soils
See above
Cold Transfer Baghouse
I lot Transfer Bughouse
On-site piles,
then off-site
Release to soils [ See above
D006/D008
Cadmium. I cad.
Arsenic
On-site piles,
then off-site
Release in soils
See above
40 h'leelrte Arc Furnace i Non-hazardous dust
Banhouse svsteni
Re-u>e in No tcleave
?
Sinter Plant !
.
50 Llectroslag Remeit Shop
Dust Diums 1 ;,lo
Casting Lmi.ssions
Baghouse
D006/D008
Chromium. Lead
()ff-site
No release
Cutting Unit Baghouse
D006/D008
Chromium. Lead
Off-site
No release
Furnace Baghouse
DU0CVD008
Chromium. Lead
D006/D008 =
Chromium. Lead
Off-site
No release
I loffman System
Baghouse
Off-site
" ()IY-si te _~
No release
Sand Miser Baghouse ' D006'D(K)8
1 Chromium. Lead
No release
I
[16]
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I lot Blast Bauihou.se
1)006/1)008
1 Off-site
No release I
Chromium, Lead
i
I
61 Iron Foundry
Shakeout Baghouses
Non-hazardous
RWI
No release 1
sand and iron lines
Chipper Baghouse
Non-hazardous
, RWI.
No release
sand and iron lines
11'- di'oblnst Scrubber &
Noti-ha/ardous
j RWI.
No release
! Settling Tank
sand and iron fines
1
Shot blast Baghouse
Non-hazardous
RU 1
No release
sand and iron lines
7o Ccntial 1 oo| 1 (T Drum
I t I-1CL
Off-site
No release
Storaee
|
i
71 Lehigh Llectric Repair
lll-PCH
Off-site
No release
CA\ rclea>e
, Shop- TCI- Drum
|
- additional
Storage
monitorum ,
72 No. 2 Machine Shop-
1 1 1-TCL
Off-site
No release
1
TCL* Drum Storage
, SO Drop Forge
No release
Oil Collection Sump
Non-hazardous oil
Reeve led for
No release
and grease
fuel at plant
Soil Removal Sump
Non-ha/ardous oil
Reeve led lor
Nii release
and urease
fuel at plant
Shoiblast Baghouse
Non-ha/ardous dust
RWI. ]
No release
and lines
j
litch Room
Muriatic acid
Neutralized, j
No release
Neutralization Pit
then NPDFS !
outfall 008 1
SI Press Forge
1
Collection Pits
Non-ha/ardous oil
Recycled for
No release
and glease
fuel at plant
Collection Box
Non-ha/ardous oil
Recycled for
No release
and mease
fuel at plant j
Clari tier
Non-hazardous oil
Reeve led for i
No release
it
.. i
and grease
fuel at plant :
Burning Emission
Non-hazardous dust
RWI. j
No release
Baghouse
!
92 Lehigh Powerhouse Oil
Non-ha/ardous oil
Ree\eled for
No release i
Separation Tank
and water
fuel at plant
i
NA not applicable, no release
Sampling results compared to non-residential MSCs for Direct Contact.
Residual Waste Landfill (RAVI.) was operated as a non-hazardous solid waste landfill for
disposal of v arious plant wastes. This 500-aere landfill is located along the eastern border of the
Former Bethlehem Steel Facility, not on the Bethlehem Works Parcel, nor the Pared which is the
subject of this Remedy Decision Proposal.
171
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_T_:iI>lc_lIJ: Areas Requiring Remediation (Not Identified in UFA)
Area
Soil/Soil (, as
j Results
Northwest Section- Soils near PAHs
| nr-s_ _ _ J_
1 Sand Pile near Iron Pound-v . Cadmium, lead
Remedial Action
Kxcavalion in 199X. (125 \\I3(
Hxcavalion in 1998-remove foundry sand
pile (123tons''83\'d5)
Northwest Section- Tar Pitch
Pad
PA Ms (coal iar)
"
1
Pxcavatiun in (27 ul?)
Car T ipper Area
PA lis
Pxcavation in 2002. (2.4 yd?)
Sampling results compared to non-residential MSCs for Direct Contr
act.
J able 2A: Groundwater SSS s compared to PADPP MSC and Pareel highest concentrations lor
constituents exceed is lu MSCs
Constituent Sample
Highest
MSC
SSS
("vLinide
2200
200
12.500
I. I -Dichloroethene
280
|~7~~
535
Indenoi 1.2.3-ed}pviene
12
0,029
27
Methlvene chloride
9
5
44,560
P\ rene
100
13
1000
1 etruchioroelhenc
48
5
6238
1,1, i -Trichluroethane (TCAi
7800
200
1,512,500
! richloroelhene (TCP)
120
26.736
All concentrations in im/L
Table 2IJ:
Constituent Sample
i iron
Soil SSS's compared to PAPPP MSC for constituents exceed in*; MSCs
T1 ( 1*1 I l ' ^ I / I CW «
MSC
190.0(H) mu ke
SSS _
850,(10!! mu'ki;
[18]
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re 1 - Location Map
3C»u: IN Ftxt
[19]
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Figure 2 - Bethlehem Works Parcel Layout
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