Site Location and Features
Location - The Former Bethlehem Steel Site is located in an urban area along the eastern shores of Lake Erie in the Cities of Buffalo and Lackawanna, Erie County. The remediation encompasses the approximately 489-acre “Corrective Measures Study (CMS) Area” portion of the former Bethlehem Steel Corporation-Lackawanna facility (which is over 1,000 acres and includes property now under the Brownfield Cleanup Program and on the east side of Route 5).
Site Features - The site is an irregular parcel which extends from south of Smokes Creek to the Buffalo Outer Harbor on the north, and from the east end of Lake Erie to the Gateway Metroport Ship Canal (Ship Canal). The site consists of approximately 489 acres and has approximately 2-miles of shoreline along Lake Erie. Smokes Creek passes westward across the site where it discharges to Lake Erie. The Ship Canal, located towards the northern end of the site, extends approximately 3,000 feet southward into the site from the Buffalo Harbor. The western portion of the site was created by the placement of slag-fill materials from iron and steel-making within an area that was formerly within the boundaries of Lake Erie. The site is mostly undeveloped, especially the western slag fill portion.
Current Zoning and Land Use - This site is currently zoned for industrial use and is currently used for slag reclamation, coal handling facilities, wood recycling facilities, and the site groundwater treatment plants. Renewable energy facilities were built under the New York State Brownfield Cleanup Program (BCP) on portions of the former Bethlehem Steel plant, consisting of 14 wind turbines located along the shoreline and 2 large solar panel arrays present in the center of the site. The majority of the land is vacant/undeveloped.
Site Geology and Hydrogeology - The predominant site feature is the wedge-shaped slag-fill area that extends into Lake Erie. This area extends from the former lake shore an average of 1,300 feet westward, and now forms the eastern shoreline of Lake Erie. The site geology beneath the slag-fill layer consists of lake and glacial sediments overlying shale or limestone bedrock. In order beneath the slag-fill, there is a sand layer with occasional peat deposits, lake clay/silt deposits, and glacial till overlying shale or limestone bedrock.
The depth to groundwater is variable and depends upon the topography, and can vary in depths ranging from about 10- to over 60-feet below ground surface. Groundwater generally flows toward Lake Erie, Smokes Creek, or the Ship Canal. Groundwater occurs within the fill and sand layers in the overburden and in the bedrock beneath the site.
Originally developed by Seneca Steel in 1902, the former 1,000-acre+ Bethlehem Steel Lackawanna Plant complex has had a long history of iron and steel production. The property changed ownership to Bethlehem Steel in 1922 and quickly became the third largest steel plant in the USA. At its peak, the property stretched over 2.5 miles of Lake Erie shoreline, from Woodlawn Beach to the Buffalo Inner Harbor and reached one mile inland (encompassing the Site and an additional 500+ acres of land). Slag, a byproduct of the steel production process (in addition to iron, steel, and coke), was in such excess that it was used to extend the shoreline into Lake Erie up to one-half mile and in some areas is over 90 feet thick.
In 1988 the National Enforcement Investigations Center (NEIC) was requested by the EPA to conduct a thorough site inspection of the Bethlehem Steel Lackawanna Plant to determine the type(s) of waste generated; identify active and inactive waste management areas; and assist EPA in identifying, characterizing, and remediating releases. A Resource Conservation and Recovery Act (RCRA) Facility Investigation (RFI) was initiated by Bethlehem Steel Corporation (BSC) in 1990 and site investigations were conducted primarily by BSC. Based on the RFI results, areas of the former Bethlehem Steel property were identified as needing remediation or further assessment.
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 NYS Route 5 had been demolished. In September 2001, BSC’s coke oven operation was terminated leaving only a Galvanized Products Division operating on the east side of NYS Route 5. BSC filed for bankruptcy in 2001 and certain BSC’s assets, including the Site and approximately 500 acres of adjacent land in Lackawanna, were acquired by the International Steel Group (ISG) in 2003. ISG formed Tecumseh Redevelopment Inc. (“Tecumseh”) to own and manage the Lackawanna, NY property that was acquired from Bethlehem Steel. Later ISG (and its subsidiary Tecumseh) was purchased by Mittal Steel who then merged with Arcelor in 2006 to become ArcelorMittal S.A., the world’s largest steel company. In December 2020 Cleveland-Cliffs Steel LLC acquired ArcelorMittal USA, the US subsidiary of ArcelorMittal S.A. Tecumseh, as a wholly-owned subsidiary of Cleveland-Cliffs Steel, has retained ownership of the CMS Area and other portions of the former Bethlehem Steel property to the present time.
Summary of Site Operable Units
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.
To date, the following OUs have been designated for the Former Bethlehem Steel Site:
OU-01 (Site-Wide Remedial Progream)
Consists of approximately 486 acres on the western portion of the Bethlehem Steel Corporation Lackawanna Facility. This unit encompasses 44 SWMUs and nine areas of concern (AOCs). Several SWMUs and AOCs have been addressed as separate OUs under NYSDEC approved Interim or Expedited Corrective Measures. Under a CMS, extensive groundwater, surface water, soil, sediment, and waste characterizations has been completed.
OU-02 (Tar Decanter Pit, Blast Furnace Hot & Cold Wells, and Lime and Kish Landfill)
Consists of SWMUs P-9 (Tar Decanter Pit), P-18A & P-18B (Blast Furnace Hot & Cold Wells), P-76 (Coke Oven Gas Line), and two AOCs (B & C) within S-18 (Lime and Kish Landfill R). Wastes from these SWMUs/AOCs were excavated, treated, and consolidated within the OU-03 containment unit.
- The Tar Decanter Pit is located near the coke oven area just west of the Ship Canal and was used to separate tar sludge from weak ammonia flushing liquor used to quench coke oven gases (decommissioned and backfilled in 1960).
- The Blast Furnace Hot & Cold Wells were located at the southwest corner of the Ship Canal. The wells were operated from 1978 to 1983 and used to cool and recycle blast furnace scrubber water.
- The Lime and Kish Landfill comprises approximately 2 acres located in the northwest portion of the site. The landfill contained wastes generated from the Basic Oxygen Furnace (BOF) process consisting of lime dust and baghouse dust from iron transfer points called Kish. AOCs B & C were found to be impacted primarily with elevated levels of benzene and lead.
OU-03 (Acid Tar Pit)
OU-03 is approximately 6-acres and consists of SWMUs S-11, S-21, S-22, and S-24 known as the Acid Tar Pit Group. S-11, S-21, and S-22 are located south of Smokes Creek in the southeast corner of the CMS Area. These SWMUs were found to be impacted with elevated levels of metals and various organic compounds.
- SWMU S-11 consists of various wastes generated from steel and coke making operations, including drums containing petroleum wastes and solvents, open-hearth precipitator dust from exhaust gas treatment, and baghouse lime dust from the BOF process.
- SWMU S-21 consists of a pile of scrap melter precipitator dust, mostly consisting of iron oxides, and was generated during the movement of scrap metal used in the BOF process.
- SWMU S-22 consists of spent carbonate solution, also called vacuum carbonate blowdown (the solution was used in the coking process to treat off-gas from the coke ovens prior to re-use as fuel).
- SWMU S-24 is located just north of Smokes Creek west of the intersection of Site Highways #9 and #11. SWMU S-24 is believed to have been used for the disposal of agitator sludge, also known as acid tar sludge. Sulfuric acid used to wash and separate impurities from benzene processing of coke oven off-gas was neutralized with caustic solution generating the agitator sludge.
OU-04 (Coke Oven Area, Groundwater)
Consists of groundwater associated with an approximately 27-acre area along the western side of the Gateway Metroport Ship Canal. OU-04 is not intended to address soil, soil vapor, or other environmental issues associated with the former Coke Oven Area (these other media will be addressed through a separate remedy decision(s) under proposed statement of basis for the operable unit as appropriate). This area contains portions of the former coke oven area and SWMUs P-11 (former Benzol Plant) and P-11A (“old” former Benzol Plant). The Benzol Plants were used for the treatment and processing of liquid coke gas by-products. These SWMUs were found to be impacted with various organic compounds.
OU-05 (Slag Fill Area Zone 2, The Impoundments)
OU-05 is approximately 74.4-acres and encompasses Slag Fill Area Zone 2 (SFA-2), consisting of steep slag bluffs located along the eastern shores of Lake Erie and the south shore of Smokes Creek. OU-05 is comprised of the SWMUs commonly referred to as The Impoundments (S-1, S-2, S-3, S-4, S-5, S-6, S-7/20, S-8, and S-27). The Impoundment SWMUs comprise approximately 21-acres and are primarily located in the western portion of OU-05. Disposal in the Impoundment SWMUs consisted of Water Quality Control Station sludges and dredge spoils from Smokes Creek. Areas outside the SWMUs are comprised of slag fill, access roads, and the aforementioned OU-03. OU-05 does not address groundwater (addressed under OU-10).
OU-06 (Former Petroleum Bulk Storage Sub-Area)
OU-06 is approximately 116-acres located just north of Smokes Creek and encompasses SWMUs:
- P-8 Waste Oil Storage Tanks;
- S-10 Slag Quench Area J;
- P-74 (A, B, C, & D) Solid Fuel Mix Storage Piles;
- P-75 Tank Storage Area for No. 6 Fuel Oil and Petroleum Tar; and
- Tar Impacted Slag AOC-H and AOC-I.
U-07 (Coal/Coke/Ore Storage & Handling/Coke Plant, By-Products Processing, & Benzol Yard)
OU-07 is approximately 178-acres located just west of the Metroport Ship Canal and encompasses SWMUs:
- P-1 North Quench Water Pit;
- P-2 Arctic Quench Water Pit;
- P-3 Central Quench Water Pit;
- P-4 A Quench Water Pit;
- P-5 B Quench Water Pit;
- P-6 Lime Sludge Settling Basin;
- P-7 Lime Sludge Settling Basin;
- P-10 Contaminated Soil Near Ball Mill;
- P-11 Benzol Plant Tank Storage Area;
- P-11A Old Benzol Plant Tank Storage Area;
- P-12 Spill Cleanup Storage Area;
- S-19 Murphy’s Mountain Landfill;
- S-25 Impoundment Under Coal Pile; and
- S-26 Fill Area Near Coke Battery No. 8.
OU-08 (Slag Fill Area Zones 4 & 5 SWMU/AOC Group)
OU-08 is approximately 113-acres located in the northwest portion of the site along Lake Erie and encompasses nine SWMUs:
- S-12 Asbestos Landfill L;
- S-13 Tar Sludge Surface Impoundment (HWMU 1A);
- S-14 General Rubble Landfill N;
- S-15 General Rubble Landfill O;
- S-16 Lime Stabilized Spent Pickle Liquor (SPL) Sludge Landfill (HWMU 1B);
- S-17 Vacuum Carbonate Blowdown Landfill Q;
- S-18 Lime Dust and Kish Landfill R;
- S-23 Tar Pit Adjacent to Lime Stabilized SPL Sludge Landfill; and
- S-28 Drum Landfill.
In addition, seven AOCs are also included within OU-08, tar and/or lead impacted areas in SWMUs S-14, S-18, S-23, the Iron City Slag Reclamation Area, and the Steel Winds II Wind Turbine 9 (WT-9) area.
OU-09 (Water Courses)
OU-09 is comprised of four waterbodies, including Smokes Creek, the North Return Water Trench (NRWT), the South Return Water Trench (SRWT), and the Metroport Ship Canal. Approximately 8,500 feet of the eastern shoreline of Lake Erie borders the Site and a primary focus of any proposed remedial work is to reduce contaminant loading into Lake Erie.
- The portions of Smokes Creek and Lake Erie that are included within the site are both classified as Class C Fresh Waterbodies. The portion of Smokes Creek that runs through the site is divided into two parts: the Upper Reach which extends from State Route 5 to the bridge on Site Highway 9; and the Lower Reach from the Highway 9 Bridge to Lake Erie. Smokes Creek and Lake Erie are located within the EPA Niagara River Area of Concern. The focus of the AOC with respect to OU-09 begins at the mouth of Smokes Creek and extends into Lake Erie, which includes the Buffalo Outer Harbor.
- The North and South Return Water Trenches are man-made channels. The NRWT previously flowed from south to north discharging to the Buffalo Outer Harbor whereas the SRWT flows north to south discharging to Smokes Creek, with its discharge point identified as a SPDES Outfall (with monthly flow monitoring requirements at the weir near the confluence of Smokes Creek and SRWT).
- The Metroport Ship Canal is located in the northeast portion of the site and opens to the Buffalo Outer Harbor.
The NYS Department of Environmental Conservation (DEC) maintains a web page with additional information and documents specific to this site and the different OUs:
Contaminants of Concern
A "contaminant of concern" (COC) is a hazardous waste that is sufficiently present in frequency and concentration in the environment to require evaluation for remedial action (not all contaminants identified on the property are contaminants of concern). COCs are evaluated and compared to State standards and guidance values (i.e., Part 375 Soil Cleanup Objectives, TOGs 1.1.1, Class C Sediment Guidance Values) dependent on allowable land use (mainly industrial but select areas for passive recreation).
The contaminants of concern at the site are a result of past industrial activities and/or the past treatment, storage, or disposal of hazardous wastes and historical releases of contamination. Contaminated lands can pose a variety of health and environmental hazards. The site must be carefully managed through containment or cleanup to prevent contaminants of concern from causing harm to humans, wildlife, or ecological systems, both on- and offsite (while these are found on-site as a result of Bethlehem Steel Industrial operations, and are considered contaminants in this setting, they are also used today in the manufacturing of common everyday products as explained below).
The contaminants of concern at the site specifically include:
- metals (such as arsenic, cadmium, lead, and mercury);
- volatile organic compounds (VOCs, such as benzene, ethylbenzene, toluene, xylene, trichloroethene [TCE]));
- semi volatile organic compounds (SVOCs, such as Phenolic Compounds, Polycyclic aromatic hydrocarbons [PAHs]); and,
- polychlorinated biphenyls (PCBs).
Based on the detections, these compounds will continue to be evaluated as contaminants of concern throughout the investigation and remedial actions.
A Resource Conservation and Recovery Act (RCRA) Facility Investigation (RFI) was initiated by Bethlehem Steel in 1990 and subsequently completed by the new owner of the property Tecumseh Redevelopment, Inc. (the Remedial Party) in January 2005. The investigation was intended to identify the nature (or type) of contamination which may be present at the site and the extent of that contamination in the environment on the site or leaving the site.
The investigation gathered data to determine if wastes containing hazardous substances were disposed at the site, and if the soil, groundwater, soil vapor, indoor air, surface water or sediments may have been contaminated.
Investigation reports are available for review in the site document repository and DEC website:
Monitoring wells are installed to investigate the depth and quality of groundwater. These wells are screened across the interface between the saturated and unsaturated zones (i.e., water table) or at a specific depth to target areas of contamination. Groundwater is evaluated by collecting samples in monitoring wells. Monitoring wells located across a site can help define the nature and extent of groundwater plumes.
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 taken into account after the public comment period.
Based on the Proposed Statement of Basis (SB), also known as the Proposed Remedial Action Plan (PRAP), for the site-wide remedial elements, groundwater, and water courses, DEC is proposing Alternative 4 – construction of a solid waste Corrective Action Management Unit (CAMU), groundwater treatment and monitoring, and removal of sediments/soils in waterways exceeding environmental standards as a site-wide remedy, since this remedial option will achieve the two main criteria and achieves the best balance among the remaining criteria when compared to the other evaluated remedial options. Based on the SB for OU-05 (Slag Fill Zone 2) and OU08 (Slag Fill Area - Zones 4 & 5 SWMU/AOC Group), DEC is proposing excavation, solidification/stabilization, consolidation and/or off-site disposal, along with closure in-place of SWMUs S-1, S-2, S-3, S-4, S-5, and S-6, S-16, S-23, and AOC-D, and includes shoreline revetment and slope stabilization and a cover system. Based on the SB for OU-06 (Former Petroleum Bulk Storage Sub-Area) and OU-07 (Coal, Coke and Ore Handling & Storage Sub-Area, and Coke Plant & By-Products Facility Sub-Area), DEC is proposing demolition of buildings, excavation/consolidation and excavation/off-site disposal, as well as cover in place in SWMU S-10 (in OU-6). In this SB DEC also proposes residual solids removal and backfill to grade with material meeting commercial cover requirements, or characterization, excavation and disposal of materials followed by backfill to grade with material meeting commercial cover requirements, or a vegetated soil cover depending on the subarea in OU-7.
Prior to the Proposed Statement of Basis, Tecumseh’s proposed on-site disposal option consists of constructing an engineered consolidation area known as a Corrective Action Management Unit (CAMU) to receive the remedial materials for permanent disposal with conditions to ensure protectiveness of human health and the environment. A CAMU Application was submitted by Bethlehem Steel on November 16, 2000. DEC is evaluating transport and disposition options, including both on-site and off-site disposal options.
Interim and Final Corrective Measures
The interim corrective measure (ICM) is conducted at a site when a source of contamination or exposure pathway can be effectively addressed before issuance of the Decision Document.
The OUs and Solid Waste Management Units (SWMUs) that have final corrective measures or ongoing OM&M of interim corrective measures are as follows:
- The Acid Tar Pits SWMU Group (OU-03), for SWMUs S-11, S-21, S-22 and S-24. Memorialized in Corrective Action Order on Consent File No. 10-09, effective date May 10, 2010;
- The Acid Tar Pits SWMU Group consolidation (OU-02), for SWMUs S-18 sub-areas B&C, P-9, P-18, and P-76, and AOCs: B, C, F, G, H and I. Memorialized in the Acid Tar Pits SWMU Group, Amendment No. 1, Corrective Action Order on Consent File No. 10-09, effective date 7/27/2015, and in the Former Coke Oven Gas Lines Order on Consent File No. 14-23, effective date June 29, 2015;
- The Coke Oven Area Groundwater (OU-04), including SWMUs P-11 and P-11A. Memorialized in the Coke Oven Area Groundwater Expedited Corrective Action Order on Consent File No. 16-55, effective date September 11, 2017;
- The Benzol Plant Source Area Control, for SWMU P-11. Memorialized in the Benzol Yard Source Control Interim Corrective Measure Order on Consent File No. 18-23, effective date November 14, 2018; and
- Hazardous Waste Management Unit (HWMU) 1A.
No further corrective measures (remedial actions) are contemplated for the following SWMUs and AOCs, many of which were addressed as part of the Acid Tar Pits (“ATP”) SWMU Group consolidation/OU-2/OU-3 described above:
- S-24 Tar Pit North of Lime Plant (Post-Closure Care required) -- addressed as part of the ATP SWMU Group consolidation/OU-2/OU-3
- AOC-B Lead-impacted hazardous waste/fill within SWMU S-18 addressed as part of the ATP SWMU Group consolidation/OU-2/OU-3
- AOC-C Lead-impacted hazardous waste/fill within SWMU S-18 -- addressed as part of the ATP SWMU Group consolidation/OU-2/OU-3
- AOC-E Tar-impacted solid waste slag/fill identified during Steel Winds I utility excavation -- contamination was excavated and disposed of off-Site
- AOC-F Tar-impacted solid waste slag/fill identified during slag reclamation activities -- addressed as part of the ATP SWMU Group consolidation/OU-2/OU-3
- AOC-G Tar-impacted solid waste slag/fill identified during Steel Winds II Wind Turbine 9 foundation excavation -- addressed as part of the ATP SWMU Group consolidation/OU-2/OU-3
- AOC-H Tar-impacted solid waste slag/fill identified during installation of Steel Winds II electric transmission poles -- addressed as part of the ATP SWMU Group consolidation/OU-2/OU-3
- AOC-I Tar-impacted solid waste slag/fill identified during installation of Steel Winds II electric transmission poles -- addressed as part of the ATP SWMU Group consolidation/OU-2/OU-3