UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION III
FINAL DECISION AND RESPONSE TO COMMENTS
SANDS BETHWORKS RETAIL, LLC
{A PORTION OF THE FORMER BETHLEHEM STEEL CORPORATION)
BETHLEHEM, PA
PAD 99 082 4161
PURPOSE
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 twenty (20)
parcels totaling 62.11 acres of the Former Bethlehem Steel Corporation - Bethlehem Structural
Products located in Bethlehem, PA (hereinafter referred to as the Parcels). The Final Decision is
issued pursuant to the Solid Waste Disposal Act, as amended by the Resource Conservation and
Recovery Act (RCRA) ofl976, 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 Parcels and
proposed a Final Remedy for the Parcels. 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 EPA evaluated under the SB. Consistent with the public
participation provisions under RCRA. KPA solicited public comment on its proposed Final
Remedy. On May 19. 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 June 19. 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 Parcels, with one correction. The SB inadvertently had
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Pureel :'¦* 1 5 on figure 2 listed as subject to that SB.
and is not subject to this Final Decision.
Parcel #15 will be included in a future SB
FINAL REMEDY
I-.PA's Final Remedy for the Parcels includes the following:
• fhc Parcels property shall not be used for residential purposes unless there is a prior
demonstration to PADI-P and HP A that such use will not pose a threat to human health or the
environment:
• (uoundwater shall not be used for any potable purpose and no wells shall he installed,
unless authorized by PADLP or FPA and used for monitoring or remediating:
• If" any asphalt, concrete, soil or other groundcover is e\ca\ated or removed, remaining
soii or other materials in (hat area shall either 1 ) be demonstrated to meet Pennsylvania
Medium-Specific Concentrations, or 2) be covered with material that eliminate pathways
of exposure to the underlying soil: and
• "fhc Parcels will not be used in a way that will adversely affect or interfere with the
integrity and proteetiveness of the final remedy,
FPA's Final Remedy will be implemented hy compliance with existing use and aetivitv
restrictions for the Parcels. These restrictions are already in place and include a PADLP-signed
I niform Fnv ironmenlal Covenant, recorded May l)1). 2013 with the Northampton County
Recorder of Deeds, and an existing City of Bethlehem ordinance restricting groundwater use.
DECLARATION
Based on the Administrative Record compiled for the corrective action at the Sands Rethworks
Retail. LLC parcels /-5-10. 12-14. 16. IS. 21-27 of the former Bethlehem Steel Facility, [ have
determined that the remedy selected in this Final Decision and Response to Comments, which
incorporates the May 15. 2017 Statement of Basis, is protective of human health and the
env ironmenl.
/ / /
Martha Shimkin,1 Acting Director
Land and Chemicals Div ision
I '.S. Fnv ironmenlal Protection Auenev. Reuion lit
Attachment A: Statement of Basis (May 1 5. 20 I 7)
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ATTACHMENT V
ST AT EM FAT OF BASIS
Sands Befhworks Retail, FI.C
(A Portion of Former Bethlehem Steel Corporation)
Bethlehem, I'A
PAD 99 082 4161
Mil) 15,2017
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UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION III
STATEMENT OF BASIS FOR PROPOSED REMEDY
Sands Bethworks Retail, LLC
(A Portion of Former Bethlehem Steel Corporation)
BETHLEHEM, PENNSYLVANIA
PAD990824I6I
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I. Introduction
I he United States Hnvironmental Protection Agency (LPA) has prepared this Statement of Basis
(SB) to solicit public comment on its proposed remedy for twenty-one (21) parcels totaling 64,2?
acres (Parcels) located on the property formerly owned and operated by Bethlehem Steel
Corporation - Bethlehem Structural Products (BSC) (hereinafter referred to as the BSC Facility
or Site), located in the city of Bethlehem. Northampton County. Pennsylvania. This SB applies
to the portion of the Facility currently owned by Sands fiethworks Retail LLC. who acquired the
property in 2007.
BPA's proposed remedy consists of compliance with and maintenance of institutional controls
(K's) and operation and maintenance of engineering controls (PCs) that are already in-place and
approved by Pennsylvania Department of Environmental Protection (PADLP). This SB
highlights key information relied upon by EPA in developing this proposed remedy.
The tormer Bethlehem Steel Corporation - Bethlehem Structural Products property is subject to
f.PA s Corrective Action Program under the Solid Waste Disposal Act. as amended by the
Resource Conservation and Recovery Act (RCRA) of 1976. and the I la/ardous and Solid Waste
Amendments (I ISWA) of 1984. 42 I'.S.C. §§ 6901 et sci]. (Corrective Action Program). The
Corrective Action Program is designed to ensure that certain facilities subject to RCRA hav e
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. LPA
retains primary authority in the Commonwealth for the Corrective Action Program.
'Hie Administrative Record (AR) for the Parcels contains all documents, including data and
quality assurance information, on which I'PA's proposed remedy is based. An index to the
Administrative Record is included at the end ol this SB. See Section /X, Public I'urticifhninn.
for information on how you may rev iew the AR.
If. Facility Background
1 he BSC Facility had been a full) integrated steel mill consisting of approximately 1600 acres
on the banks ot 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 of the Facility, with numerous structures such as buildings, and
parking lots, The 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 Lehigh River.
Currently the Bethlehem Works Parcel is being redeveloped and has been divided into 27 smaller
parcels as shown in Figure 2. The Sands Bethworks Retail LLC parcels (parcels 12-16.
18, 21-27). are the subject of this SB. "I he environmental investigation discussed in the
documents in the AR was conducted across the entire Bethlehem Works Parcel and reviewed by
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both PADHP and EPA. Section III below - Summary of Environmental J listory- is applicable to
the entire HiO-acrc Bethlehem Works Parcel. The proposed remedy discussed in the remainder of
this SB pertains only to the Sands Bethworks Retail LLC parcels v%hich comprises 64,27 acres.
l.PA has recent!) issued a separate SB lor the Sands Betimorks (iaming parcel (••'17). I he
Redevelopment Authority of Bethlehem owns Parcel 1 I and will receive a separate SB and final
Decision by I-PA. Parcels 3.4.19. and 2(1 have already received a iinat decision from I-PA.
III. Summary of Environmental History
A. Soils
(Note: The investigations referenced in this section were conducted under the PADEP/EI'A
One Cleanup Program. Soil investigation results were compared to both EPA non-
residential screening levels (USLs) and PADEP non-residential state-wide health standards
(or media .specific standards - MSCs), The reports generated by the investigations
typically used the MSC nomenclature. For non-residential use, PAIMT and EPA
standards arc both protective. The MSC nomenclature is used in this SB to aid the reader
in using the references found in the Administrate e Record)
Numerous sampling events were completed between 1995 and 1998 for the soils investigation at
areas identified in the Rt'RA 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 oxer 120 locations were collected to meet both Act 2 and Correcti\c .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-tu-groundwater pathways,
Concurrent with the investigation, demolition of certain buildings and removal of debris were
completed under the redevelopment plan. The soils beneath the building foundations, were not
investigated. LPA does not anticipate significant contamination beneath former structures.
Nonetheless, any change* to these features will require the then-owner to re-e\aluate the current
conditions and exposure pathways. This requirement is specified in the Environmental Covenant
for each parcel on the Bethlehem Works property.
lo simplify the site-wide investigation during Phase II. the site was divided into various
production areas which had similar potential hazardous constituents. Each 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
1 A. "flic investigation also included a number of Areas recognized for potential contamination.
Areas that icquued remedial aetiv ities are listed in I able 1 B. Detailed descriptions of all areas
investigated and the applicable sampling results are presented in the Remedial Investigation.
Risk Assessment and Cleanup Plan (RI'R.VCP) and supplemental information submitted in 199S
and in the two Einal Reports for Soils submitted in 2000 and 2002.
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BSC removed soils and oilier 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.
Iron Loitndn Sand Pile (Sands Bethworks Retail /./.( j A stockpile of primarily foundry sand
was located between the Iron Foundrv Building and (he Iron Casting, (.'leaning 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 approximate!)
1600 square feet. The pile was sampled, characterized, and excavated in April 1998, Lead and
cadmium were found at levels above direct contact MSCs. Approximated S> cubic vards (12 i
tons) ot sand was removed, following removal, soil samples were collected from within the
tormer footprint ol the pile. I hese confirmatory samples did not detect any lead or cadmium
above their MSCs of 1000 mg'kg for lead and 1400 mg/kg for cadmium.
Soil!, At*£«• (Sands Retail Bethworks LLC V
Soils with coal lines and tar-like material was removed from the area of monitoring well BF-8, in
the northwest section of the Facility, This material was found during installation of BF-8 in
1995, Sampling showed I'AI Is above direct contact health standards (tor ben/o(a)pyrcne and
di benzol a.h)an(hraeene). Approximately 125 cubic yards of material was removed in 199 N. Post
excavation sampling from within the footprint showed detected concentrations below direct
contact MSCs (11 mg/kg) for both constituents.
Tar. /'itch Tank Pad (Sands Retail Betlmorks LLC)
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 excav ated; 27
cubic yards (18 tons). Samples taken of the area after excavation show attainment of the Act 2
statewide health standards (or direct contact in soils for PA! Is. which are the primary
constituents in coal tar.
Sintering Plant (Sands Bethworks Retail /./.( V
fhe soils near the Sintering Plant electrostatic precipitators indicated the presence of arsenic and
lead. I 'xeavation of approximately 200 cubic yards was completed in 1999. Post excavation
sampling showed two samples above the lead direct contact standard of 1000 mg/kg (at 2800
mglg and 7360 mg kg). I low ever. 75".. of the samples wcic below the 1000 mg kg standard
and the 45"« 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.
('a/' Tipper Area (Sands Bethworks LLC)
Soil sampling showed PA I Is above remedial standards in the Car Tipper area. In 2002. 2.4 cubic
yards ol soil was excavated. Sampling of the soils below the excavation showed no PA Us above
Act 2 nonresidential standards.
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B, Groundwater
! here are three aquifers beneath the Bethlehem Works site area. '['Ik- .site is immediate!}
underlain by an unconsolidated aquifer consisting of alluvium and fill material. Groundwater
upgradicnt 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 upgradicnt of
the site. Groundwater (lows 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 peri meter of the site. Well placement was based on historical operations and land usage in
addition In groundwater How patterns. These 19 wells, were used to evaluate groundwater
quality and to determine potential pathways and risks to the Lehigh River.
1 hese monitoring wells were .sampled once m 1995 and quarterly in 1997 and 1998, Fifty-four
samples were analyzed for organic and inorganic constituents. Additionally, groundwater
samples were collected via direct push technology at locations of suspected releases of
triehloroethene (TCF-) and 1.1.1-triehloroethane (TC'A). used in five degreasers located in
buildings on the site.
Five ol'the sixteen wells were constructed in bedrock: the remaining 11 are completed in the
merhurden. Total depth of these sixteen wells ranges from ?() to 122 feet. The three existing
wells were originally used to supply production water to the plant. 1 he Spring Fit. a shallow
pond-like well located near the Electric 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. 'I'lic 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 Act 2 Medium-Specific Concentrations (MSCs) tor Non-Residential Used Aquifers.
Detected ciuiccnirations were generally below the applicable MSC. however concentrations of
volatile organic compounds (VOCs} downgradient of the Fleetrie Repair Building (ERB)
exceeded MSCs for TCA. TCE, and 1,2-dichloroethene (DCF). The maximum detected
concentration of I'CA was 78(SOug 'L 12dug'l for I CF, and 280ug I for DCF. I he MSCs for
these constituents are 2(i0ug'i. 5ug I 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 In past releases in the vicinity of the Bethlehem Works Parcel.
Although the VOC presence appeared to be localized, EPA determined that additional
information was needed to 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 F'RB and Fehigh River. These wells sampled over four quarters for VOCs
and polyaromatic hydrocarbons (PAlls).
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Results from the Verification Monitoring Program indicated that the VOC contamination is
localized near the ERB and has been attenuating. Contaminate levels in the uppermost aquifer
actually meet drinking water standards before discharging to the Lehigh Ri\cr. The final
sampling event at the source area showed TCA concentration at 2100ugi (73% decrease). 1 CL
concentration declining to 35ug/l (70% decrease), and DCL concentration at 2.3»g/i. which is
below the MSC . No oilier \ OC s or PAi Is were louiui to be abo\e MSC> timing the sampling
period.
The verification program required the installation of two wells at the top of bedrock down
gradient ot the source area in order to evaluate whether a dense non-aqueous phase liquid
(lA'APL) was present in groundwater at the KRB. Site conditions slum YOCs in soil are below
2mg kg. Maximum concentrations of YOCs in groundwater were less than 0.5% of solubility
and VOCs in soil gas is less than 200ppni. Characterization data does not support the potential
for a i)NAPI„
The Verification Monitoring Program also confirmed groundwater How'- is northward, toward the
Lehigh River, and the Lehigh is a gaining stream (groundwater Hows into the Lehigh). This
result was consistent with results previously reported in all earlier studies.
Groundwater at the site is not being used for potable purposes, and future uses will be restricted
by environmental cov enants. LPA met with city of Bethlehem officials in 20(W regarding
potential use of the groundwater beneath the site. City officials explained that city ordinance
prohibits use ot groundwater within the city limits and requires hookup to the municipal supply
system. 1 hey further explained that the overburden groundwater (where the contamination was
found) would never be used for supply purposes based on yield and other factors. Both current
and future direct contact exposure pathways to groundwater have been eliminated for both
human and ecological receptors.
C. Surface Water
An evaluation of potential impacts from groundwater discharges to water quality in the Lehigh
River was considered in the risk assessment. This ev aluation was based on mass balance
modeling to determine whether the concentrations detected in groundwater discharging to the
Lehigh River would result in in-slream concentrations that exceed the Pennsylvania Water
Quality Criteria. To demonstrate that detected YOC concentrations are protective of surface
water quality, maximum concentrations from all groundwater samples (including direct push)
were evaluated. Hie risk assessment shows that surface water criteria for aquatic life and human
health are not exceeded, including for maximum detected concentrations in groundwater. This
indicates that existing groundwater concentrations are protective of surface water quality. (See
Section I ILL below for more information on the risk assessment)
With respect to 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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D, Soil Gas
Soil gas .samples were located near or down gradient of potential sources for VOCs. Thirteen
areas were large ted. where 158 samples were collected using, direct push technology, at depths of
0-2 and 2 lo 15 feet below ground surface. Samples were initialiv screened using IMP or I 11).
Samples with screening readings of over lOppm were then analv/ed using a Held portable gas
chromalngraph. fhese samples were anah/.ed for vinyl chloride. IX'f. TCA, TCH, PC I
toluene, and ethyl hen/ene. Samples were compared to criteria for worker exposure to
substances in air: NIOS1I. ACGI1I. and OSIIA. Only one sample exceeded a criterion, lor \in\l
chloride. This sample result is questionable as it was the lone exceedanee. and found at the 0-2
foot depth. Vinyl chloride is highly volatile and it is unusual for it to he found at a shallow
depth. Other shallow and deeper samples in the vicinity did not detect vinyl chloride. The
results of the soil gas survey indicate that VOCs are not being released from soils or
groundwater.
In addition to soil gas sampling, indoor air samples were also collected to evaluate the potential
of V< it's to migiaie into buildings. Indoor air samples were collected from the 1KB. Carpenter
and Pattern Shop, Machine Shop 2 and Central Tool .Annex. These locations were selected as
llicv once contained \apor degreasing units or were located above groundwater in which VOCs
have been detected at levels above applicable MSCs. 1 wo sampling pumps were placed in each
building, within 10 lo 20 feet of the former vapor degrcascr locations. The air samples were
collected after approximately 8 hours. Laboratory 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: VOC.s are not present in
soil gas at concentrations that pose a risk. In addition, the findings show the former degreasers
do not pose an inhalation risk in the buildings.
E, Risk Assessments
On March 31. 1998. the Faeilit) submitted a Notice of Intent lo Remediate to PADf'P pursuant
to Act 2. A combination of the Act 2 Non-residential Statewide I lealth Standards (SI IS) and Site-
Specific Standards (SSSs) were chosen as the cleanup goals to be achieved.
BSC presented the Mav 2X. I99N R| 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, 1 he evaluation of this data was, in part
presented as a quasi-supplement to the Risk Assessment, to bolster the presented evaluation.
This evaluation is found in the January 11. 1999 memo from BSC to I-PA. This document can
be found in the Administrative Record for this SB.
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The following assumptions on future use were used to develop the Risk Assessment and were
discussed with the stakeholders, including city of Bethlehem officials:
• The Bethlehem Works property will be restricted to non-residential uses;
• The future use of groundwater for any (potable or non-potable) purpose will be
prohibited, other than for potential environmental monitoring.
• An existing public water system supplies drinking water in the area. Groundwater use is
prohibited by local ordinances and or other institutional controls,
• Current ground cover (i.e. pads, roadways, etc,) will remain in place.
• I'mure redevelopment plans indicate unpaved areas will be covered by asphalt, concrete,
clean 1111, 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, hxposures and cleanup levels were based on comparison of the
maximum detected analytical groundwater results to PADEP medium specific concentrations
(MSCs) and PADLP Water Quality Criteria IWQC) for surface water protection.
F.PA lias reviewed the risk assessment and the resulting calculated standards (Tables A and 2B).
I'PA has determined that the risk assessment was conducted in accordance with I-PA 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
LPA's Corrective Action ()hjecti\e for the Parcels 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 PAI3HP in the form of Hnvironniental
Covenants. The Parcels meets Pennsylvania's Non-Residential Statewide I Icalth Standards
(NRSHS) for soils. F.PA has determined that these standards are protective of human health and
the environment for individual contaminants at the Parcels. The Non-Residential SlISs meet or
are more conser\nli\e than FP.Vs acceptable risk range for non-residential use.
2. Groundwater
LiPA'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
Parcels. '1 he former Bethlehem Steel originally implemented these as deed restrictions in 19W,
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Beth works-Sands convened these restrictions to Lnvironmental Covenants in 2til~v ( ! he citv of
Bethlehem already prohibits the use of groundwater for consumptive purposes anywhere within
thecii> limits.)
Based on groundwater data collected from these parcels, contaminant lex eh in the uppermost
aquifer attenuate to drinking water standards (or were not detected) h\ the point at which the
groundwater discharges to the Lehigh River. A groundwater model was used to calculate
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
immediate!) prior It) discharge to the i ehigh River. 1 he model result showed that the Lehigh
River will not he impacted by groundwater discharging from the site. Those calculated levels
can he found in 'fable 2A.
HPA is not requiring periodic monitoring of groundwater for these Parcels, 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. I'ADLP and
LP A approved closing of all monitoring wells on the Parcels as part the redevelopment activities.
3. Vapors
L.l'A's Corrective Action Objective for the Parcels vapors is to control exposure to this hazard by
requiring (he compliance with and maintenance of land use restrictions at the Parcels as provided
for in the environmental covenants applicable to this properly.
4, Surface Water an
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(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 MSC's. or (2) he covered with material that eliminate pathways of
exposure to the underlying soil. This cover material may consist of (a) new asphalt, (b)
new concrete, (c) not less than twelve (12) inches of clean soil, or (d) an alternative cover
that is capable of physically supporting the intended use of the area and that pro\ ides
protection to eliminate pathways of exposure to and from the underlying soil
(B) Groundwater shall not be used for any purpose and no wells shall be
installed, unless authorized by the Department. However, monitoring wells and treatment
wells may be installed solely for the purpose of monitoring and remediating.
(C) The 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 nil! not pose a threat to
human health or the environment or adversely affect or interfere with the selected remedy
and PADIiP. in consultation with MP A. provides prior written approval for such use:
(D) The Proper!}' will not be used in a way that will adversely affect or
interfere with the integrity and protect! veness of the final remedy;
VI. r.\a [nation of LJ'A's Proposed Rcnieih
This section provides a description of the criteria KPA used to e\aluate the proposed remedy
consistent with IT'A guidance. The criteria are applied in two phases. In the first phase. MP A
evaluates three remedy threshold criteria as general goals. In the second phase, for those
remedies which meet the threshold criteria, HPA then evaluates sewn balancing criteria to
determine which proposed remedy alternative provides the best relative combination of
attributes.
A. I lucshoki Criteria
I. Protect Human Health ami the Kin ironmcnt
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 at the Parcels to restrict future property uses to ensure that human health and the
environment remain protected.
On May (W, 2013, Sands Bethworks Retail. LLC recorded environmental covenants which
impose land and groundwater use restrictions and conditions regarding the use of the Parcels
property and groundwater. Under the cov enants. Parcels property may only be used for non-
residential purposes and groundwater beneath the property may not be used for any purpose.
1 hese conditions are enforceable and provide long-term assurance that the exposure assumptions
used in developing HPA's proposed remedy are not changed without approval.
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2. Achicvc Media Cleanup Objectives
The Parcels have achieved the appropriate cleanup standards lor soils, groundwater, and surface
water. These standards meet LP A risk guidelines for human health and the environment a( the
Parcels. l-PA's proposed reined) requires compliance with the implementation and maintenance
of institutional controls to ensure that Parcels property is not used for residential purposes,
current ground cover remains in place and groundwater beneath Parcels property is not used for
any purpose.
3. Remediatin« the Source of Releases
In all proposed decisions, HP A seeks to eliminate or reduce further releases of hazardous wastes
or hazardous constituents that may pose a threat to human health and the environment.
As described in the Summary of Environmental History section above, the Parcels have had
sources of releases remediated. 1 here are no remaining large, discrete sources of waste from
which constituents would he released to the environment. Therefore, IT'A has determined that
this criterion has been met.
B. Balaneing/l Evaluation Criteria
1. Long-Term Kffectiveness
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
Parcels. KPA's proposed remedy requires the compliance with and maintenance of land use and
groundwater use restrictions at the Parcels. The land use and groundwater use restrictions have
already been implemented through environmental covenants recorded in the chain of title of the
deeds for the Parcels property. The environmental covenants run 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 Parcels has already been
achieved by decommissioning the Parcels structures and soil excavation as described in the
Summary of linvironmental History section above,
3. Short-Term Kffcetivcncss
I-P.Vs proposed remedy does not involve any additional activities, such as construction or
excavation 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
environmental covenants recorded in the chain of title of the deeds for the Parcels property.
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4.
(m piemen lability
HPA's proposed remedy is readily implementahle. Environmental covenants haw* already been
recorded and the engineering and institutional controls are in place. Therefore, EPA dues not
anticipate am regulatorv constraints in implementing its proposed remedy.
5. Cost
Hnvironmental covenants have already been recorded in the chain of title of the deeds to the
Parcels properly. Therefore, there should he no additional costs associated with the proposed
remedy.
6. Community Acceptance
HPA will evaluate Comiminiu acceptance of the proposed remedy during the public comment
period and will he described in the Final Decision and Response to Comments (FDRTC).
7. State/Support Agenc} Acceptance
Hnvironmental cleanup at these Parcels lias been overseen by PADFP as part of Pennsylvania's
Act 2 Program since 1998. PADHP appnned the Act 2 Final Report for remedial activities on
November 3. 2010. id'A will evaluate lurthcr State acceptance based on an\ comments received
from PADHP during the public comment period and will be described in the FDRTC.
VII, Environmental Indicators
I .PA sets national goals to measure progress toward meeting the nation's major environmental
glials. For Corrective Action. KPA evaluates two key environmental indicators for each facility:
(I) current human exposures under control and (2) migration of contaminated groundwater under
control. The HPA has determined that the Parcels met these indicators on April 19. 1996 and
April 02. 1999.
VIII. Financial Assurance
HPA has evaluated whether financial assurance for corrective action is necessary to implement
1PA s proposed remedy at the Parcels. Given that HPA's proposed remedy does not require any
further engineering actions to remediate soil contamination at this time and given that the costs
ot implementing institutional controls at the Parcels will be minimal. HPA is proposing that no
financial assurance be required.
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IX. Public Participation
Be lore KPA makes a final decision on its proposal lor the Parcels, the public may participate in
the rcmedv selection process by reviewing (his SB and documents contained in the
Administrative Record {AR) for the Parcels. The AR contains all information considered by
HP A in reaching this proposed remedy, it is available for public reviewduring norma! business
hours at:
U.S. LI!A Region III
1650 Arch Street
Philadelphia, PA 19103
Contact: Ms. I .inda Matyskieia (3LC30)
Phone:(215)814-3420
Fax: (215) SI4 - 3113
Lmail: MaU skiela.Linda a cpa.uov
Interested parties arc encouraged to review the AR and comment on KIWs proposed remedy,
The public comment period will last thirty (30) calendar daws from the date that notice is
published in a local newspaper. You may submit comments by mail, fa.v or e-mail to
Ms. l.inda Matyskieia. LPA will hold a public meeting to discuss this proposed remedy upon
request. Requests for a public meeting should be made to Ms. Linda Matyskieia.
LP A will respond to all releuuH comments received during the comment period. If KPA
determines that new information warrant a modification to the proposed remedy. KPA will
modi IV the proposed remedy or select other alternatives based on such new information and'or
public comments. KPA will announce its iinal decision and explain the rationale for any changes
in a document entitled the Final Decision and Response to Comments. All persons who
comment on this proposed remedy will recei\e a copy of the FDRTC. Others may obtain a copy
bv contacting Ms. Linda Matyskieia at the address listed aho\e.
Date: ^ ~" 11 -L'idLlAlciJLJLL^ }.<_ 1(1^
Catherine A. 1 ,ibert/
Acting Director
Land and Chemicals Division
I IS KPA. Ronton III
Tables 1A and 1B
l ables 2A and 2B
Figure 1 - Location Map
Figure 2 Bethlehem Works Parcel Layout
1121
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INDI A TO ADMIMS 1 UATIVK RKCORD
Gronnthv ntiT
Draft RCRA Facility Assessment. Bethlehem Steel Corporation- September 28. I WO; t'DM for
EPA
Groundwater Flow Study Report of Findings. Bethlehem Plant June 1995; (ill for BSC, I
binder
Remedial Investigation, Risk Assessment, and Cleanup Plan, Bethlehem. Works Site, May 2E,
199S; SAIC for BSC, 6 binders (on CD)
Information tp jfce fov^jgatfon, KM* Assessment, and clew ?im
Report, Bethlehem Works Site, August 27,1998; SAIC for BSC lo PADEP, 71 pgs, (on CD)
LPA Comments to Remedial Investigation, Risk Assessment, and Cleanup Plan, Bethlehem
Works Site, December 22, 1998; EPA to BSC, 8 pgs.
Summary Document for Sufficient Characterization. January 11,1999; BSC to I*PA, 14 pgs.
Verification Requirements for Beth Works Groundwater, March 03, I'M1); LPA to BSC, 4 pgs.
Letter of Act 2 Liability Protection for Groundwater at Beth Works Site, April 05. I1)1)1); PADLP
to BSC, Ipg.
Approval of Soils and Groundwater Remediation. April 2. 1999; LPA to PADLP. 6 pgs.
Approval of Soils and Groundwater Remediation. May 06, 1999; LPA to PADLP. ft pgs.
Results for Verification Monitoring, Bethlehem Works_Sjte, Sept 16, 1999; BSC to LPA. 84 pgs.
Bethlehem Works Site Verification Monitoring Program Results. Ma> 5. 2001); BSC tu LPA, 4
pgs.
Bethlehem Works Site Groundwater Approval, Junuar\ 22, 2001; LPA to BSC. 1 pi!.
Soils
DraflRCRA Facility Assessment, Bethlehem Steel Corporation. September 28, 1990; COM for
EPA
Remedial Investigation. Risk Assessment, and Cleanup Plan, Bethlehem Works Site, May 28,
1998; SAIC for BSC. 6 binders (on CD)
I13|
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Supp!emenUiI Informatio.ii lo the Remedial Investiuation. Risk Assessment. and Cleanup Plan
Report. Bethlehem Works Site. August 27. 1998: SAIC lor BSC to PAD!-,!5. 7i pgs. (on CD)
Sitc-Spccillc Standards for Soils for the Bethlehem Works Site. January 26, 1999; SAIC to
PADEP, 5 pgs.
Residual Materials as Construction Fill, March 12. 1099: PADEP to BSC. 2 pgs.
Approval of Soils mid Groundwater Remediation. April 2, 1999; EPA to PADEP, 6 pgs.
Approval of Soils and Groundwater Remediation. May 06. 1909: HPA to PADEP. 6 pus.
An E\ a I nation ol the Potential for Acute I leaith Ellects on Children Exposed to I roti in Surface
Soils and Other Materials. October 1999; SAIC for BSC, 51 pgs. (on CDs
final Report lor Soils Phase 1 Area. Bethleheni Works Site. April 2000: SAIC lor BSC. 219 pgs.
¦(on CD)
final Report lor Soils Phase I Area. Bethlehem Works Site. April 14. 2000: Cover letter. Act 2
transmittal sheet, final report summary, checklist and proof of public notice. 42 pus.
Bethlehem Works P0st-Chara.cteri2al.i0n Supplemental Soils Sampling. June 5. 2000; BSC to
PADEP, 3 pgs.
Amendment to Final Report for Soils Phase i Area, Bethlehem Works Site. August 10. 2000:
BSC to PADEP. 5 pgs.
fetter of .Act 2 Liability Protection for Phase I Soils Area at Bethlehem Works Site. September
14. 2000: PADI-P to BSC. 2 pgs.
Final Report for Soils Phase II Area. Bethlehem Works Site. November 2002: SAIC for BSC,
138 pgs. (on CD)
Replacement page to f inal Report for Soils Phase II Area. Bethlehem Works Site. January 31,
2003: SAIC to PADEP. 2 pgs.
Letter of Act 2 Eiahility Protection for Phase II Soils Area at Bethlehem Works Site. February
19. 200.3; PADEP to BSC, 2 pgs.
Demolition Cleanup Process, February 23, 2006 Ismail; HDR to EPA. 2 pgs.
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Q\t nership/Fnv'iromncntnl Covenants
Bethlehem Works Phase I Area,, October 12. 2001; recorded by BSC
Bethlehem Works Phase 1! Area. September 13, 2004: recorded by Iceumseh Redevelopment
Inc.
Map of Sands Bethworks Properties. August 04, 2011
Environmental Covenant, Condominium Unit 2. Mas 09, 2013. reeorded by Sands Bethworks
Retail, LLC
Environmental Covenant - Sands Bethworks Retail, LLC, May 09, 2013, recorded by Sands
Bethworks Retail, LLC
Public Participation
Press Release- October 14, 1(J9S: Morning Call article- October 14, 1WS: Murninu Call article
October 14. LMK: 5 pus.
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Table I A: Solid Waste Management I nits identified in RFA
Solid Waste Management j Waste Description s Waste
Unit (as identified in RFA) i [ Destination
20 Blast Furnace j
Dorr Clariliers Non-hazardous iron
fines and carbon
Release noted | Remediation
in RFA?
Vacuum Fillers
C 'ast I louse Baghouses
Flue Dust Catchers
N21 Sinter Plan!
Precipitators
Cyclones
Cold 'I ransler Baghouse
Hot l ransler Bathhouse
Noil-hazardous iron
fines and carhon
Non-hazardous iron
oxide
Non-hazardous iron
fines and carbon
On-siie piles,
then oil-site
-10 Flectric Are Furnace
Baghouse system
30 I'ieetroslag Remelt Shop
Dust Drums
F.SR Bachouse System
60 Brass Foundry
Multi Clones
Dust Drums
( astinc l:.missions
Bauhouse
DOOfy'DOOK
Cadmium. Lead,
Arsenic
D006/D008 " On-site piles,
Cadmium. Lead. tlicn off-site
Arsenic
DU06;D008 On-site piles,
Cadmium. Lead, then off-site
Arsenic
IXK)6'DfMlX ()ii-sile"piles"
Cadmium, Lead. then off-site
Arsenic _ _
Non-hazardous dust j Re-use in
¦ Sinter Plant
Sinter Plant,
RVVL
Sinter Plant,
RWL
RWl7
No release
i No release
1 No release
Sinter Plant,
RWL
No release
Release to soils
Release to soils
Release to soils
Lxcavation
in 1999. (200
yd?)
See above
See above
Release to soils 1 See above
No release
' 1)007 Chromium
! 1)007 Chromium
! D006/EXK)ST
' Chi^'inhmi. Lead
| I)006d)0();S
, Chromium. I cad
| 0006^)0(18
I Chromium. Lead
. Off-site
j Ol'l-site
I Off-site
1 Off-site'
j Off-site
No release
j No release
! No release
i No release
No release
Cullin«z Unit Bayhouse | 1XK)6-'D008
Furnace Bayhouse
1 loffman System
Bachouse
Sand Mi\er Bachouse
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; Chromium. Lead
! 1)0061)0(18
j Chromium, Lead
D006/D008
' Chromium. Lead
H>0061)008
| Off-site
I Off-site
Off-site
i Off-site
No release
[ No release
No release
: No release
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Chromium. Lead
1 lot Blast Bauhouse
D006/D008
Off-site
No release
Chromium, Lead
fil Iron Foundrv
Shakeout Baghouses
Non-hazardous
sand and iron tines
RWL
No release
Chipper Baghouse
Non-hazardous
sand and iron lines
RWL
No iclease
; liydroblasl Scrubber &
Non-hazardous
RWL
No release
Settling Tank
sand and iron lines
i Shotblast Raidiouse
Non-hazardous
RWL
No release
sand and iron lines
I 70 Central Tool TCli Drum
1 1 l-TCh
Off-site
No release
Storage
71 i ehigh Lleetrie Repair
111-fCE
< )lf-site
No release
CiW release -
Shop- TCIi Drum
additional
Storage
monitoring
72 No. 2 Machine Shop-
! 11 -TCE
Off-site
No release
i 1 C1-. Drum Storuue
; SO Drop forge
No release
Oil Collection Sump
Non-ha/ardous oil
Reeve led for
No release
and urease
fuel at plant
Soil Removal Sump
Non-ha/ardous oil
and grease
Recycled for
fuel at plant
No release
Shotblast Baghouse
Non-ha/ardous dust
RWL
No release
and lines
L-teh Room
Muriatic acid
Neutralized,
No release
Neutralization Pit
then NPDLS
outfall 008
«S 1 Press forge
Collection Pits
Non-ha/aidous oil
Rec\cled for
No release
and grease
fuel at plant
Collection Box
Non-ha/ardous oil
and grease
Recycled for
fuel at plant
No release
Clariller
Non-hazardous oil
Reeve led for
No release
and grease
fuel at plant
iiurniiiLL Hmission
Non-hazardous dust
RWL
No release
Bughouse
l)2 Lehiuh Powerhouse Oil
Non-hazardous oil
Reeve led for
No release
Separation lank
and water
fuel at plant
NA not applicable, no release
Sampling vesulls compared U> non-residential MSCs for Direct Contact.
Residual Waste Landfill (RWL) was operated as a luui-ha/ardous solid waste landfill for
disposal of various plant wastes. This 500-aere landfill is located along the eastern border of the
[17]
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Funner Bethlehem Steel Facility. no I on the Bethlehem Works Parcel, nor the Parcels which are
the .subject of this Remedy Decision Ptoposnl.
I aide 1 it: Areas Requiring Remediation (Not Identified in RFA)
Area
Northwest Section- Soils near
R1--S
Sand Pile near Iron Foundry
Soil/Soil (J as
Results
PAILs
Cadmium, lead
Northwest Section- "Far Pilch - PAIIs (coal tar)
Pad
Car Upper Area
I1 AI Is
Remedial Action
Fxeavation in i 99S. (125 yd3)
; Fxeavation in 1998-remove foundry sand
! pi Ie (1231ons'83yd3)
j Fxeavation in 1999. {27 vd3)
Fxeavation in 2002. {2.4 yd?)
Sampling results compared to non-residential MSCs for Direct Contact.
Table 2A: Groundwater SSS's compared to P.ADEP MSC and Parcel highest concentrations for
constituents exceeding MSCs
Constituent Sample
Highest
MSC
SSS
Cvanide
2200
200
12.500
1.1 -Diehloioethene
280
7
535
Indcnoi 1,2.3-cd)pyrene
12
0.029
27
Methvleue chloride
9
5
44.560
Pvrene
|lM
13
1000
Tetrachloroeihene
48
5
623 S
1,1,1 -Trichloroethane (1C A)
7800
200
1.512,500
frichloroethene (TCF.)
120
>
26,736
All concentrations in utz/L
"Fahle 2H: Soil SSS's compared to PADFP MSC" for constituents execedmjj MSCs
Constituent Sample
iron
MSC
T90.0()CTnYp/ku'
sss
850.0(H) tnu'kn
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Figure I - Location Map
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