Environmental Clean-up At Former Bethlehem Steel Site

City of Lackawanna, Erie County

NYSDEC Project ID 915009

On June 30, 2009, DEC and Tecumseh Redevelopment Inc. signed an Order on Consent (the "Order") to complete a Corrective Measures Section (CMS) for the facility. The Order also required that Tecumseh Redevelopment Inc. (Tecumseh henceforth) provide financial assurance for completing Resource Conservation and Recovery Act closure, post-closure, and corrective action requirements for the site.

Cleanup Goals and Objectives

DEC is committed to supervising a careful and thorough cleanup of the Former Bethlehem Steel Site. This investigation and cleanup will be completed to address potential exposure to contaminants above the NYS commercial/industrial soil clean up objectives (primarily arsenic, cadmium, mercury, lead, and semi-volatile organic compounds). Goals of the cleanup will be protective of human health and the environment, and allow for commercial/industrial development. As part of the cleanup, the DEC is committed to work with the community and Tecumseh to allow public access to areas near the Lake Erie Shoreline.

The site is currently partially fenced, gated, and has signage, which restricts public access. However, persons who enter the site could contact contaminants in the soil by walking on the site, digging or otherwise disturbing the soil. There are several surface water areas where persons may come in contact with contaminants on-site. People are not coming into contact with the contaminated groundwater because the area is served by a public water supply that is not affected by this contamination. Volatile organic compounds in the groundwater may move into the soil vapor (air spaces within the soil), which in turn may move into overlying buildings and affect the indoor air quality. This process, which is similar to the movement of radon gas from the subsurface into the indoor air of buildings, is referred to as soil vapor intrusion. Because the site is undeveloped or unused for outdoor industrial purposes, the inhalation of site-related contaminants due to soil vapor intrusion does not represent a current concern. Find out more about exposure (leaves DEC's website).

Site Description

Historical Operations

The former Bethlehem Steel Corporation (BSC) property was used for iron and steel production since the beginning of the 20th century (iron and steel production by Seneca Steel began in 1902, and in 1922 it was purchased by Bethlehem Steel). Iron and steel-making operations were discontinued by the end of 1983, and by the mid-1990s, most of the steel-making facilities on the west side of Hamburg Turnpike (NYS Route 5) had been demolished.

In September 2001, BSC's coke production was terminated. While some buildings remain, most structures have been razed. The western portion, also referred to as the CMS Area that includes roughly two miles of Lake Erie waterfront, consists of approximately 489 acres of manmade land where iron, steel-making slag, and other manufacturing wastes from the production plant were deposited.

Buffalo Southern R.R. dumping slag (October 1943).

Past Investigation and Actions

An RFI was initiated by BSC in 1990. Site investigations were conducted primarily by BSC before that company filed for bankruptcy in 2001. The final site investigation report was subsequently completed by Tecumseh and submitted in January 2005. Based on the RFI results, areas of the former Bethlehem Steel property were identified as requiring remediation or further assessment. Tecumseh conducted further investigation and assessment of remedial alternatives in a CMS Report (2019). A supplemental Comprehensive Groundwater Quality Report (2019) was also prepared that summarized and assessed the groundwater data collected during both the RFI and CMS. The investigation identified approximately 40 areas on the Site that exhibited soil, fill, groundwater, sediment, and surface water contamination. Most of the Tecumseh property outside the CMS Area has been thoroughly investigated and remediated under the New York State Brownfield Cleanup Program (BCP) and sold to other private and public parties (e.g., Buffalo and Erie County Industrial Land Development Corporation [ILDC]) for redevelopment.

Site Layout

The site is divided into multiple operable units (OU). An OU represents a portion of a remedial program site that for technical or administrative reasons can be addressed separately to investigate, eliminate, or mitigate a release, threat of release or exposure pathway resulting from the site contamination. A number of Solid Waste Management Units (SWMUs), Areas of Concern (AOCs), and two Hazardous Waste Management units (HWMUs) in the CMS area have been designated as OUs due to their proximity to each other, the similar composition of waste material, and/or similarity of remedy selection.

Site figure showing Operable Unit areas.

Current Project Status and Remedy Selection for 2021

DEC evaluates potential remedial options against several criteria, the most critical of which are the remedy's ability to provide protection for human health and the environment and the remedy's compliance with environmental laws and standards. For remedies that meet these first two criteria, DEC also evaluates several "balancing criteria" in order to determine the best remedy, including the short- and long-term effectiveness and impacts of the remedy, the remedy's ability to reduce the presence of wastes, the implementability of the remedy, its cost, and the current and future land uses of a site under the selected remedy. The local community's acceptance of the remedy is also considered after the public comment period on the Proposed Statement of Basis (SB), also known as the Proposed Remedial Action Plan (PRAP).

Investigation Activities

Site investigations were conducted primarily by Bethlehem Steel Corporation before that company filed for bankruptcy in 2001. Tecumseh Redevelopment Inc., a wholly owned subsidiary of ArcelorMittal USA, Inc., completed and submitted the final RFI report. Tecumseh conducted further investigation and assessment of remedial alternatives in a CMS Report. A supplemental Comprehensive Groundwater Quality Report was also prepared that summarized and assessed the groundwater data collected during both the RFI and CMS.

The Former Bethlehem Steel Site is subject to hazardous waste treatment, storage, and disposal facility (TSDF) permitting requirements under New York State (NYS) hazardous waste regulations (6 NYCRR Part 373) and has RCRA EPA ID No. NYD002134880. Under this regulatory program, Tecumseh Redevelopment Inc. is responsible for implementing Corrective Action to address releases to the environment from SWMUs and AOCs (e.g., watercourses).

• On June 30, 2009, DEC and Tecumseh signed an Order on Consent (the "Order") to complete a CMS for the facility. The Order also required that Tecumseh provide financial assurance for completing RCRA closure, post-closure, and corrective action requirements for the site.
• On September 24, 2020, DEC, Tecumseh, and ArcelorMittal USA LLC signed an Order on Consent (the "Order") to complete comprehensive investigation; evaluation; and implementation of Corrective Measures/Remedial Actions, Closure and Post-Closure Care requirements of the Site to protect public health and the environment and to allow, when and where appropriate, the continued use of the Site and its redevelopment by Tecumseh and/or third parties.

The final OU-4 groundwater remedy consists of two independent groundwater collection, conveyance and treatment systems:

• The south system consists of 25 groundwater collection wells and treatment units.
• The north system consists of 27 groundwater collection wells and treatment units. The treatment units are housed in a single new building.

The combined treated effluent flows to infiltration galleries to recharge groundwater. The construction of OU-4 groundwater remediation facilities was substantially completed and began operation on March 13, 2019.

Based upon remedial systems performance documented during the first year of operation (2019-2020) of the OU-4 groundwater remediation system, additional investigations and engineering evaluations were performed to address identified issues and deficiencies. Recommendations were made in early 2021 to make modifications to the treatment system and to install 5 additional recovery wells and 2 additional monitoring wells (which could be converted to recovery wells in the future, if needed). It is anticipated that these treatment system modifications and well installations will be completed by late 2021.

How Restoration Might Look after Remediation

DEC supports restoration which helps achieve the goal of preserving and connecting the natural resources and resiliency features of NY's Lake Erie shoreline. Increasing waterfront access to Lake Erie is a key component of a sustainable economic development strategy.

Following the remedy selection process, the remedial design will inform the ultimate restoration of the site. However, DEC will require the development of a Sustainable Restoration Plan which considers the following:

• Reconfiguration of the on-site shoreline with approaches to soften the lakeshore impacted by past operations of the facility and prevent the migration of contaminated materials to nearby waterbodies;
• Opportunities for public recreation;
• Habitat creation, restoration and enhancement; and
• Improvement of the habitat for fish and wildlife.

Based on the priorities identified in these plans and programs, specific ideas to consider for the nearshore, coastal and riparian areas within the site include:

• Expansion of nearshore cobble areas suitable for walleye and other native fish species such as white sucker and northern pike. This valuable fishery habitat is very close to the shoreline, where the slag stacks very steeply;
• Enhancement of the coastal transition zone habitat, possibly terracing portions of the existing slag bluff and shoreline, combined with soil augmentation and re-vegetation appropriate for bank swallow and chimney swift habitat; and
• Enhancement of the Smokes Creek riparian zone through the former Bethlehem Steel property with bank clean-up and stabilization for greater aquatic connectivity into the creek's headwaters.

Development of a Climate Resiliency Plan would also be required which includes at the minimum the following:

• Climate change vulnerability analyses and adaptation planning leading to increased remedy resilience;
• Identifying potential hazards posed by climate change;
• Characterizing the remedy(s) exposure and sensitivity to the hazards;
• Considering factors that may exacerbate remedy(s) exposure and sensitivity, such as the size of upstream water;
• Catchment, the size of adjacent floodplains, and land use in the floodplains;
• Identifying measures that potentially apply to the vulnerabilities in a range of weather/climate scenarios; and
• Selecting and implementing priority adaptation measures for the given remedy.

Public Involvement

Community Updates

DEC has issued a community update describing the current status of the site and activities planned for 2021:

• Fact Sheet - Spring 2021 Community Update (PDF)

Public Meetings

DEC held public meetings and availability sessions about the project in June 2006 and July 2009. Additional public meetings will be held at later stages of the project as necessary and will be announced here and on the DEC public availability webpage.

For any materials from previous community events, refer to DEC Region 9's DER webpage.

Receive Fact Sheets by Email!
DEC invites you to sign up with one or more contaminated sites email listservs.

It's quick, it's free, and it will help keep you better informed. As a listserv member, you will periodically receive site-related information and announcements for all contaminated sites in the county(ies) you select.

NYSDEC prepared the following Community Liaison Plan to further assist the public to stay informed: Bethlehem Steel Community Liaison Plan - April 2021 (PDF)

Document Access Information

Information regarding access to other pertinent documents not linked to this page is provided below.

NYSDEC Fact Sheets:

The links below provide access to Fact Sheets prepared by DEC:

• Fact Sheet - Spring 2021 Community Update (PDF)
• Fact Sheet - February 2017 Community Update (PDF)
• Fact Sheet - May 2015 Community Update (PDF)

Final Decision Documents, Work Plans, and Other Documents:

The links below provide access to Work Plans and other main Documents related to the site (the complete documents, and additional reports such as annual monitoring reports and superseded/interim documents, can be found here.

2021

• 2021 PRAP/SB OU-1 Site Wide Remedial Elements, OU-9 Water Courses, and OU-10 Site-Wide Groundwater - May 2021 (PDF, 10 MB)
• 2021 PRAP/SB OU-6 Former Petroleum Bulk Storage, and OU-7 By-Products Processing - May 2021 (PDF, 6.5 MB)
• 2021 PRAP/SB OU-5 and OU-08 Slag Fill Area Zones - May 2021 (PDF, 10 MB)

2020

• Consent Order Tecumseh Redevelopment Inc - September 2020
• 2020 Interim EC-IC Plan for CMS Area - May 2020

2019

• Tecumseh Redevelopment Inc Corrective Measures Study Report - May 2019

Complete copies of the documents listed on this web page and other documents pertaining to the Former Bethlehem Steel Site are available in hard copy for public review at the following locations:

• Lackawanna Public Library
  560 Ridge Road
  Lackawanna, NY 14218
  Call 716-823-0630
• NYSDEC Region 9 Office Headquarters
  700 Delaware Avenue
  Buffalo, NY 14209
  Call ahead for an appointment
  716-851-7220, Mr. Stanley Radon

Related Program Sites

Tecumseh Redevelopment, Inc. - SteelWinds Brownfield Cleanup Program Site No. C915205

The Tecumseh Redevelopment, Inc. - SteelWinds Site is an approximately 29-acre parcel of property located west of Route 5 in the City of Lackawanna, Erie County. The narrow parcel is approximately 240 feet wide by 4800 feet long and extends north-south along the western edge of the former Bethlehem Steel Corporation (BSC) property, adjacent to Lake Erie. Currently the site is a gently-graded and vegetated parcel, vacant except for the addition of eight 2.5 megawatt wind turbines. In December of 2007, the remedial construction was deemed complete, an Environmental Easement was executed, and a Final Engineering Report and Site Management Plan were accepted. A Certificate of Completion was issued on December 18, 2007. The site is leased to Niagara Wind Power, LLC who currently operates and maintains the wind turbines and remedial components. Steel Winds IA Brownfield Cleanup Program Site No. C915216 and Steel Winds II Brownfield Cleanup Program Site No. C915217

A Brownfield Cleanup Program (BCP) application was submitted to investigate, remediate, and redevelop the Steel Winds IA site and was denied. Subsequently, a BCP application was submitted for the Steel Winds II site and was approved; the Brownfield Cleanup Agreement was executed on March 27, 2008. Due to failure to show progress the Brownfield Cleanup Agreement was terminated effective October 16, 2009. The Steel Winds II site has been addressed under the Tecumseh Phase III Business Park Brownfield Cleanup Program Site No. C915199 (see below). Additional site information can be found at the links below:

• Steel Winds IA
• Steel Winds II

Tecumseh Phase I Business Park Brownfield Cleanup Program Site Nos. C915197 and C915197B through C915197K

The approximate 103-acre Tecumseh Phase I Business Park site is comprised of the following 11 sub-parcels located at 2303 Hamburg Turnpike in the City of Lackawanna, Erie County. The Phase I Business Park site is located on the former BSC property and bounded on the east by Route 5, on the north and west by Gateway Metroport, and on the south by Tecumseh Phase II Business Park. The site is zoned Commercial/Industrial and is currently vacant. Interim Remedial Measures (IRMs) consisting of excavation followed by off-site disposal or on-site treatment were completed on the Phase I Business Park to address petroleum-, tar-, and metals-impacted soil/fill. Remedial actions have successfully achieved soil cleanup objectives for commercial use via installation of a 1-foot cover system on sites I-1, I-3, I-5, I-7, I-9, I-10, and I-11. Residual contamination in the soil and groundwater for these sites is managed under a Site Management Plan. Decision Documents, outlining the required remedial actions (installation of a 1-foot cover) for the remaining Phase I sites were issued in February of 2012. The Buffalo & Erie County Industrial Land Development Corporation currently owns and maintains the Tecumseh Phase I Business Park site sub-parcels.

Tecumseh Phase IA Business Park Brownfield Cleanup Program Site No. C915218

The Tecumseh Phase IA Business Park site is an approximately 12-acre site located on the former BSC property in an industrial area at 1951 Hamburg Turnpike in the City of Lackawanna, Erie County. The site is bounded on the east by the Tecumseh Phase I Business Park, on the west and north by the Gateway Metroport, and on the south by the Tecumseh Phase II Business Park. The site contains three existing buildings historically used for support operations in the steel making process. The Site was recently purchased by Sucro Real Estate NY, LLC for redevelopment consisting of raw material import and future sugar refining. A Decision Document was released in March of 2021 outlining the required remedial actions prior to redevelopment.

Tecumseh Phase II Business Park Brownfield Cleanup Program Site Nos. C915918J and C915198B through C9151968L

The approximate 142-acreTecumseh Phase II Business Park site is comprised of the following 12 sub-parcels located at 2303 Hamburg Turnpike and 6 Dona Street in the City of Lackawanna, Erie County. The Tecumseh Phase II Business Park is located on the former BSC property and is bounded on the east by Route 5, on the north by Tecumseh Phase I Business Park, on the west by Tecumseh Phase III Business Park and on the south by the South Buffalo Rail Road Company. Smokes Creek bisects the Tecumseh Phase II Business Park. IRMs consisting of excavation followed by off-site disposal or on-site treatment were completed on the Phase II Business Park to address petroleum-, tar-, and metals-impacted soil/fill. Remedial actions have successfully achieved soil cleanup objectives for commercial use via installation of a 1-foot cover system on sites II-9, II-10, and II-12. Residual contamination in the soil and groundwater for these sites is managed under a Site Management Plan. Decision Documents, outlining the required remedial actions (installation of a 1-foot cover) for the remaining Phase II sites, with the exception of II-4, were issued in 2016 and 2017. A remedial investigation and alternatives analysis report for Site II-4 is under review. Sites II-9 and II-10 are developed with a 280,000 square foot manufacturing facility and attached 8,000 square foot office building that comprise the Time Release Sciences, Inc. development.

Tecumseh Phase III Business Park Brownfield Cleanup Program Site Nos. C915199 and C915199B through C915199J

The approximate 149-acre Tecumseh Phase III Business Park site is comprised of the following 10 sub-parcels located at 2303 Hamburg Turnpike and 2 Dona Street in the City of Lackawanna, Erie County. The Tecumseh Phase III Business Park is located on the former BSC property and is bounded on the east by Tecumseh Phase II Business Park, on the north by the Gateway Metroport, on the west by the former BSC site, and on the south by the South Buffalo Rail Road Company. Smokes Creek bisects the Tecumseh Phase II Business Park. Remedial actions have successfully achieved soil cleanup objectives for commercial use by the removal of impacted materials and installation of a 1-foot cover system on the Tecumseh Phase II Business Park sites, with the exception of site III-10. Residual contamination in the soil and groundwater for these sites is managed under a Site Management Plan. A Decision Document, outlining the required remedial actions (installation of a 1-foot cover) for the III-10 site was issued in August of 2015. Sites III-2, III-3, III-4, III-5, III-6, and III-9 are developed with solar energy farms. Sites III-7 and III-8 are part of the Welded Tube USA manufacturing facility and site III-1 is developed with a lumber transfer facility.

Bethlehem Shoreline Trail Brownfield Cleanup Program Site No. C915197L

The Bethlehem Shoreline Trail site is an approximately 6.7-acre site located in an industrial area at 2303 Hamburg Turnpike in the City of Lackawanna, Erie County. The site is one of 12 parcels comprising the Tecumseh Phase I Business Park, which is in turn part of a larger property that included the Bethlehem Steel Company. The site is bound to the east by Route 5, to the west by the Tecumseh Phase I and II Business Parks, to the north by the Gateway Metroport, and to the south by the South Buffalo Rail Road Company. In October 2018, nearly one mile of the Erie County Shoreline Trail was opened to the public, which sits east of the former Bethlehem Steel site and is a symbol that marks the redevelopment in the Lackawanna region. It connects the public to the Outer Harbor Shoreline, Woodlawn Beach, Tift Nature Preserve and Gallagher Beach. Specifically, designed signage and remaining infrastructure at the site provides the passing public a glimpse into steel-making process. The 10-foot wide asphalt bike path covers the length of the site, and areas not covered by the bike path consist of one foot of soil cover meeting requirements for cover material as per 6 NYCRR Part 375-6.7(d). Surrounding parcels include vacant former industrial land and shipping, storage and transport facilities. The site was formerly part of Bethlehem Steel Company's steel making operations (steel production at the site was discontinued in 1983). The site is mostly filled land with between two to eight feet of steel and iron-making slag and other fill material. Remediation at the site has been completed. Remedial actions have successfully achieved soil cleanup objectives for commercial use, and residual contamination in the soil and groundwater for these sites is managed under a Site Management Plan.