Site Background

The former Bethlehem Steel Corporation (BSC) property was used for iron and steel production since the beginning of the 20th century. 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.

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. Based on the RFI results, 42 locations on the western 489-acre portion (CMS Area) of the former Bethlehem Steel property were identified as needing remediation or further assessment. Tecumseh Redevelopment, Inc. conducted further investigation and assessment of remedial alternatives that resulted in a Corrective Measures Study (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. Investigation reports are available for review in the site document repository.

Contaminants of Concern

A “contaminant of concern” is a contaminant that is sufficiently present in frequency and concentration in the environment to require evaluation for remedial actions.

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 specifically include metals (such as arsenic, cadmium, lead, and mercury), volatile organic compounds (VOCs), semi volatile organic compounds (SVOCs), polychlorinated biphenyls (PCBs), and per- and polyfluoroalkyl substances (PFAS). Based on the detections, these compounds will continue to be evaluated as contaminants of concern throughout the investigation and remedial actions.

*Note*: Further discussion on health-related questions associated with the contaminants of concern found at the site are located under the section “Health Related Questions” further below. General information on the contaminants of concern is included in the following subsections, and additional site-specific information is included in the Proposed Statement of Basis document for the site (see the NYSDEC website: Please note that not all the uses for the contaminants of concern described below occurred on the former Bethlehem Steel site.

Arsenic, Cadmium, Lead, and Mercury

Arsenic, cadmium, lead, and mercury are natural elements in the earth’s crust and can be found in soils, rocks, groundwater and surface water. Most anthropogenic arsenic is produced as a by-product of copper and lead refining or by heating the mineral arsenopyrite causing the arsenic to sublime (change directly from a solid to a gas) and leave behind iron sulfide. Commercially, arsenic has been used in the production of agricultural products (pesticides, herbicides and insecticides); treatment for wood products (wood preservatives); veterinary drugs; and to make special glass. Arsenic is sometimes alloyed with lead to form a harder, more durable metal for use in things like car batteries and bullets.

Soils and rocks, including coal and mineral fertilizers, contain some cadmium. Most cadmium used in the United States is extracted during the production of other metals like zinc, lead, and copper. Cadmium does not corrode easily and has many uses, including batteries, metal coatings, and plastics. Cadmium has also been used in pigments as a coloring agent which can produce a range of brilliant shades of yellow, orange, red and maroon. Cadmium pigments have been used in plastics, ceramics, glasses, and special paints.

Although lead is a naturally occurring heavy metal that can be found in soil and dust, the majority of lead present in the environment is due to human activity. It was once widely used as an additive in gasoline and paint, and is commonly used in the production of automotive batteries, ammunition, metal products, ceramic products, caulking, and shields against x-rays. Lead was also historically released from mining lead (extracted from ores dug from underground mines) and other metals, and from factories that make or use lead, lead alloys and lead compounds. Lead was also commonly used in glass such as television picture tubes, computer video display terminals and the inner portion of the common lightbulb.

Mercury is naturally occurring in some rock, including in coal deposits. It has historically been used in thermometers, fluorescent light bulbs and electrical switches, as well as many consumer and medicinal products. Mercury can combine with other elements to form inorganic salts. Inorganic mercury salts can be found in water and in soil, and dusts containing these inorganic salts may become airborne during mining of ore deposits that contain mercury. Emissions of both elemental and inorganic mercury can occur from coal-fired power plants, burning of waste, and from industrial uses of mercury.

Volatile organic compounds (VOCs)

Volatile organic compounds are compounds that have a high vapor pressure (readily evaporate) and low water solubility. Many VOCs are human-made chemicals that are used and produced in the manufacture of paints, pharmaceuticals, and refrigerants. VOCs typically are industrial solvents, such as trichloroethylene; fuel oxygenates, such as methyl tert-butyl ether (MTBE); or by-products produced by chlorination in water treatment, such as chloroform. VOCs are often components of petroleum fuels, hydraulic fluids, paint thinners, and dry-cleaning agents. VOCs are common ground-water contaminants.

VOCs are emitted as gases from certain solids or liquids. VOCs include a variety of chemicals, some of which may have short- and long-term adverse health effects. VOCs are emitted by a wide array of household products. Examples include: paints and lacquers, paint strippers, cleaning supplies, pesticides, building materials and furnishings, office equipment such as copiers and printers, correction fluids and carbonless copy paper, graphics and craft materials including glues and adhesives, permanent markers, and photographic solutions.

Semi-volatile compounds (SVOCs) and polycyclic aromatic hydrocarbons (PAHs)

Semi-volatile compounds are a subgroup of volatile organic compounds with higher boiling points and a lower potential to volatilize (evaporate into air) compared to VOCs. Polycyclic aromatic hydrocarbons (PAHs) are a subgroup of SVOC compounds that occur naturally in coal, crude oil, and gasoline. They are also produced by incomplete combustion when coal, oil, gas, wood, garbage, and tobacco are burned. PAHs generally occur as complex mixtures (as part of combustion byproducts such as soot/ash residue), not as single compounds.

Polychlorinated biphenyls (PCBs)

Polychlorinated biphenyls are a group of man-made organic chemicals consisting of carbon, hydrogen, and chlorine atoms. The number of chlorine atoms and their location in a PCB molecule determine many of its physical and chemical properties.

PCBs belong to a broad family of man-made organic chemicals known as chlorinated hydrocarbons. PCBs were domestically manufactured from 1929 until manufacturing was banned in 1979. They have a range of toxicity and vary in consistency from thin, light-colored liquids to yellow or black waxy solids. Due to their non-flammability, chemical stability, high boiling point and electrical insulating properties, PCBs were used in hundreds of industrial and commercial applications including:

  • Electrical, heat transfer and hydraulic equipment
  • Plasticizers in paints, plastics, and rubber products
  • Pigments, dyes, and carbonless copy paper
  • Other industrial applications

Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS)

PFAS stands for a broad group of perfluoroalkyl and polyfluoroalkyl substances. The group contains several categories and classes of durable chemicals and materials with properties that include oil, water, temperature, chemical and fire resistance, as well as electrical insulating properties. Such characteristics are critical for use in important product applications across many industries (such as stain- and water-resistant fabrics and carpeting, cleaning products, paints, and fire-fighting foams).

Site Investigation

Who is the responsible party for the investigation and cleanup?

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 Cleveland-Cliffs Steel LLC (formerly known as ArcelorMittal USA LLC) ., completed and submitted the final RCRA Facility Investigation (RFI) report in 2005.

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 the Remedy Implementation Consent Order (as discussed and defined below) entered pursuant to this regulatory program, Tecumseh Redevelopment Inc. is responsible for implementing Corrective Action to address releases to the environment from solid waste management units (SWMUs) and areas of concern (e.g., watercourses) impacted by Bethlehem Steel operations. On June 30, 2009 the Department and Tecumseh signed an Order on Consent (the “CMS Order”) to complete a Corrective Measures Study (CMS) for the facility. The CMS 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 the Department, Tecumseh, and ArcelorMittal USA LLC signed an Order on Consent (the “Remedy Implementation 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 property is also a site listed on the Department’s Registry of Inactive Hazardous Waste Disposal Sites (Site No. 915009 – Former Bethlehem Steel) and is currently classified as a Class 2 site as defined in the associated 6NYCRR Part 375 regulations. Portions of the larger former Bethlehem Steel complex that are adjoining the CMS Area (i.e., Steel Winds wind turbine development along the Lake Erie shoreline) are participating in the Brownfield Cleanup Program (BCP) administered by the Department, with remediation performed by Tecumseh Redevelopment; however, the Order and these documents pertain only to the approximately 489-acre CMS Area.

What kinds of environmental samples have been collected to date?

Soils, sediments, groundwater, surface water and waste materials have been sampled at the site to determine the nature and extent of contamination.

What is the purpose of pre-design investigation (PDI) sampling?

A PDI Work Plan will be developed, and approved by the Department, to ensure that adequate information is available to implement the remedial design program. The Work Plan will include, but is not limited to, investigations that will:

  • Ensure that sufficient geotechnical samples and data are collected to support the Remedial Design and supplement the Subsurface Exploration, Geotechnical Engineering Evaluation and Shoreline Protection System Design Report (2013) completed by GEI Consultants;
  • Allow for additional soil sampling to determine the extent of areas where the upper one foot of exposed surface soil exceeds industrial/commercial soil cleanup objectives (SCOs) and therefore a site cover may be required for industrial/commercial use of the site;
  • Provide for radiation surveys and/or sampling to identify slag materials exhibiting elevated gamma (radiological) readings and thus inform remedial design decisions regarding disposition of excavated materials and site cover needs; and
  • Undertake additional sampling/testing to determine if waste/fill exhibits hazardous waste characteristics (e.g., lead readings >5 mg/L) which may require wastes to undergo solidification/stabilization.

What are soil cleanup objectives (SCOs)?

Soil cleanup objectives are contaminant-specific soil concentrations allowable in soils that are protective of public health and the environment for specified uses of a property (e.g., residential, commercial). SCOs are used, along with other considerations, to guide decisions about the need to reduce exposure to environmental contaminants. The SCOs are contained in NYSDEC’s Environmental Remediation Program regulations (see SCOs will be used to set cleanup levels at the former Bethlehem Steel site, with different SCOs used as appropriate for the proposed future uses of different areas of the site (e.g. commercial SCOs will be used as cleanup levels for areas that may be proposed to have future passive recreational uses).

Remedial Actions

What is an Interim Corrective Measure (ICM)?

An ICM (sometimes referred to as Interim Remedial Measure) is a discrete set of planned actions that can be conducted without the extensive investigation and evaluation of a full Resource Conservation and Recovery Act (RCRA) Facility Investigation (Remedial Investigation) and Corrective Measures Study (Feasibility Study). Given their versatility and the relative speed with which they are applied, ICMs accelerate clean-up (remedial) projects by removing or isolating source materials found during investigatory stages and eliminating the threat the material poses to human health or the environment. Sometimes, an ICM achieves the remedial goal for a site and no further action is required, however most often, and as used at the former BSC site, they were undertaken to address limited or discrete pockets of contamination or impacted infrastructure. The sooner sites are remediated, the sooner the public and the environment are protected.

What is the remedial design process?

A remedial design program will be implemented to provide the details necessary for the construction, operation, optimization, maintenance, and monitoring of the selected remedial program. Proposed Remedies are protective of human health and the environment while simultaneously aimed restoring the former Bethlehem Steel property in a sustainable manner. They must be cost-effective, comply with other statutory requirements, and utilize permanent solutions, alternative technologies, or resource recovery technologies to the maximum extent practicable while attaining all remedial action objectives identified for the site. Sustainable restoration will advance the goals of preserving, restoring, and connecting the natural resources and resiliency features of New York’s Lake Erie Shoreline and increases waterfront access to Lake Erie, a key economic development strategy.

The remedial design program begins once the Corrective Measures Study (CMS) is approved (accepted August 2019) and a consent order signed (September 2020). At that point a Proposed Statement of Basis (SB) and Proposed Remedial Action Plan (PRAP) are developed and published for public comment (information and details are shared via a Public Information Meeting, mailed newsletters, the NYSDEC website, etc.). The SB/PRAP will include details about the pre-design investigation, design of the remedy, restoration plan, climate resiliency plan, disposal, and treatment of waste at the site, monitoring requirements, financial assurances, institutional and engineering controls, site management plan, and so on.

NYSDEC will consider public comments as it finalizes the remedy design for the site. The selected remedy will be described in a document called a "Record of Decision" (under the Inactive Hazardous Waste Disposal Sites program, also known as the “State Superfund Program”) and Proposed Statement of Basis (under the RCRA corrective action program) that will explain why the remedy was selected and respond to public comments. A detailed design of the selected remedy will then be prepared, and the cleanup will be performed.

Will NYSDEC provide oversight?

Yes. During investigation and remediation NYSDEC inspectors will be onsite to observe activities associated with the remedial program. NYSDEC personnel or a NYSDEC-contracted inspector will oversee implementation of the health and safety plan, review planned activities, and respond to community questions through a dedicated telephone number. Additional dedicated third-party personnel will be in place if needed during specific work activities to support NYSDEC with providing noise or vibration monitoring, air monitoring, and independent oversight inspections.

What is the purpose of Tecumseh Redevelopment Inc.’s proposed shoreline revetment?

To provide slope stabilization a shoreline revetment (fortification) along the western slag bluff consisting of large armor stone or concrete at the toe of the slag bluff is proposed. Additional rip rap would be installed above the shoreline revetment. The slag bluffs would be graded to achieve, at a maximum, a 1.5-horizontal to 1 vertical slope. A geotechnical analysis was submitted by Tecumseh Redevelopment Inc. to support this proposal. During design, slope stabilization and the goal of softening the shoreline along Lake Erie will need to be evaluated and balanced to provide the best overall approach.

What kind of development can take place at the site once it is cleaned up?

Deed Restrictions limiting the use of the property are already in place. After the cleanup an Environmental Easement will limit the end use of the property to commercial and industrial uses. Any proposed end-use development will be required to account for the current and future uses of the site. Currently the site includes areas of outdoor uses including on-site slag reclamation, coal handling facilities, and wood recycling facilities.

Will the cleanup of the site include restoration of the environment?

Regulatory requirements for environmental restoration of a site encourages the collaboration between developing end uses of the site with restoring, preserving, and connecting natural resources to the site (specifically, Part 375 defines a "Remedial Program" to include restoration of the environment, and also speaks to groundwater quality restoration, stating restoration of groundwater shall be evaluated to determine the feasibility of measures to restore groundwater quality to meet applicable standards and guidance). Based on its location along the Lake Erie Shoreline, natural feature restoration and resiliency of the shoreline will be evaluated an incorporated as part of the remedial design.

In signing the Remedy Implementation Order Tecumseh committed to a public/private collaboration between themselves, DEC, and other public entities (the “Collaborators”) to evaluate the feasibility, location(s) of, and designs for: on-site areas of habitat creation, restoration and enhancement that will include; structural, environmental and ecological enhancements to the on-site shoreline and surrounding area that will restore the Lackawanna lakeshore to a more natural state, soften the shoreline and provide stability of the slag-cliff face where needed. The development of such enhancements will be compatible with all final remedies and the Collaborators’ shared vision for the planned future use of the Site.

To begin the discussion about site restoration NYSDEC will work collaboratively with Tecumseh to develop a Sustainable Restoration Plan which includes among other things:

  1. Habitat creation, restoration, and enhancement, including but not limited to pollinator gardens, common tern, bank swallow, gull habitat and nesting areas, and elevated nesting for raptors; and,
  2. Improvement of the habitat for fish and wildlife with respect to the Smokes Creek Shoals Significant Coastal Fish & Wildlife Habitat.

Based on the priorities identified in these plans and programs, specific ideas to consider for the nearshore, coastal, and riparian areas within the site may 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, in areas where the slag stacks are steep.
  • 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.
  • 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.
  • NYSDEC intends to work with Tecumseh Redevelopment Inc. to provide conceptual renderings of remedial and restoration activities to help the public visualize what work at the site may look like.

Will the public be able to access the site?

In signing the Remedy Implementation Order Tecumseh agreed to allow public access to private/publicly funded and private/publicly owned improvements in certain areas of the site including portions along Smokes Creek and the Lake Erie waterfront. The locations, designs, and purposes of these improvements will be developed over time in collaboration with Tecumseh, DEC, and other public entities (the “Collaborators”). These improvements must be consistent and compatible with all final remedies and the protection of public health and the environment. The development of all such access and improvements shall be subject to the Collaborators review and approval regarding final locations, uses, conditions, parameters, scope, management, construction plans, and other details. Tecumseh has agreed to assist, as reasonably necessary, efforts to acquire public and/or private funding (from third parties) for such improvements.

What type of institutional and engineering controls are being considered?

"Institutional Controls" (ICs) are any non-physical means of enforcing a restriction on the use of real property that limits human or environmental exposure, restricts the use of groundwater, provides notice to potential owners, operators, or members of the public, or prevents actions that would interfere with the effectiveness of a remedial program or with the effectiveness and/or integrity of site management activities at or pertaining to a remedial site (i.e. environmental easements, deed restrictions, discharge permits, site security, zoning restrictions, etc.).

"Engineering Controls" (ECs) include any physical barrier or method employed to actively or passively contain, stabilize, or monitor contamination, restrict the movement of contamination to ensure the long-term effectiveness of a remedial program, or eliminate potential exposure pathways to contamination. Engineering controls include, but are not limited to, pavement, caps, covers, subsurface barriers, vapor barriers, slurry walls, building ventilation systems, fences, and access controls.

At this site, environmental easements will be placed on the property. The placement of an environmental easement, an example of an institutional control, provides an effective and enforceable means of encouraging the reuse of a site at a level that has been determined to be safe, while ensuring the ongoing performance of operation, maintenance, and/or monitoring requirements. The CAMUs (Corrective Action Management Unit areas), cover system, inspection and maintenance requirements, and enhanced groundwater extraction and treatment are examples of engineering controls required for this remedial project. A Site Management Plan will be issued once the remedy is completed (an Interim Site Management Plan will be in place throughout the remedy). These documents will include an Institutional and Engineering Control Plan which will identify all use restrictions and engineering controls for the site and detail, steps, and media-specific requirements necessary to ensure all institutional and engineering controls remain in place and are effective (i.e. an excavation plan, provisions for future remediation and investigation, specific controls for areas dedicated to passive recreation use, provisions of remedial system optimizations, and so on). These documents will also include a Monitoring Plan (to assess the performance and effectiveness of the remedy) and an Operation and Maintenance Plan (to ensure continued operation, maintenance, optimization, monitoring, inspection, and reporting of any mechanical or physical components of the remedy).

See under “Other Questions” more discussion on Site Management Plans and how they work.

Public Outreach

How will the community be kept informed?

Information about the cleanup is provided through NYSDEC’s project-specific website: and on the Public Availability Website for the site ( Investigation and cleanup progress, work locations, traffic changes, and anticipated activities will be posted to keep the community informed. A virtual public meeting will be held prior to the selection of any final remedies, and periodic newsletters will be published to keep residents updated. NYSDEC has developed a Community Liaison Plan which describes all public outreach plans and details to keep the public informed (a copy is provided on the NYSDEC’s project-specific website mentioned above).

Will portions of the site be available for passive recreational use?

NYSDEC and Tecumseh have committed to collaborate with the City of Lackawanna, Erie County, and potentially other public entities to develop a Sustainable Restoration Plan. This plan will consider opportunities for public recreation and public access to Lake Erie.

The Sustainable Restoration Plan will evaluate the feasibility, location(s) of and designs for on-site areas of habitat creation, restoration, and structural/ecological/environmental enhancements. To this effect, Tecumseh Redevelopment Inc. has agreed to allow public access to private/publicly funded and private/publicly owned improvements in certain areas of the site including portions along Smokes Creek and the Lake Erie waterfront. The plan also requires consideration for the design, implementation, and maintenance in perpetuity of:

  1. on-site public access to Lake Erie (with the goal of preserving, restoring, and connecting the natural resources and resiliency features of NY’s Lake Erie shoreline);
  2. areas of habitat creation and restoration of the shoreline and surrounding area; and
  3. restoration consistent with the Great Lakes Restoration Initiative or other regional master plans.

Health Related Questions

What is exposure?

Exposure is physical contact with a chemical or substance. Without exposure, you cannot be harmed by a substance. There are three main routes of exposure including inhalation, direct contact, and ingestion.

  • Inhalation – breathing in dust or vapors from remediation areas
  • Direct Contact – getting contaminated soil, groundwater, surface water or sediment on your skin or in your eyes
  • Ingestion – eating or drinking something that has contaminated soil, groundwater, surface water or sediment on it

One or more of these physical contacts must occur before a chemical has the potential to cause a health problem. Exposure does not necessarily mean that a health effect will occur. Access to the site is currently restricted which prevents exposure to site related impacts in soil and groundwater. Additionally, the site and surrounding community receive drinking water from public water supply that is not affected by this contamination.

How are dust and particulates being controlled?

NYSDEC and NYSDOH will approve a Community Air Monitoring Plan (CAMP) that requires continuous upwind and downwind air monitoring during all excavation, soil handling and backfilling activities. This will ensure no additional dust, particulates or VOCs are released beyond the work zone to the environment or surrounding community during the cleanup activities. The air monitoring stations check for dust particulates and VOCs using real-time monitoring equipment. Results are compared to the airborne action level standards. The equipment employs an audible alarm to indicate exceedance of the action level so corrective measures (such as wetting down the area) can be taken immediately. The CAMP requires no visual dust moving outside the work area, and wetting down dry materials as necessary. The air monitoring equipment is sensitive and will detect very low levels of dust or VOCs particles in the air, typically before you can see them with your eyes. If dust is observed, either by the personnel at the site, or if it is detected above action levels with the air monitoring equipment, the work will be stopped, and corrective actions will be taken. Additional controls require trucks to be covered to properly secure all excavated material during transport across the site or for disposal off-site at a permitted facility.

What health effects can be caused by exposure to arsenic, cadmium, lead, or mercury?

All chemicals can cause health effects. The risk for adverse health effects from exposure to any chemical depends on the chemical's toxicity, the amount of the chemical to which a person is exposed, and how long and how often the exposure occurs. Exposure to a chemical does not necessarily mean that a health effect will occur. Below is some general information about the kinds of health effects that are associated with arsenic, cadmium, lead, and mercury.

Arsenic: Arsenic is classified as a human carcinogen based on evidence from a large number of scientific studies that show an increased risk for skin, lung, and bladder cancer among people who have been exposed to high levels of arsenic in drinking water. Exposure to high levels of arsenic also can cause non-carcinogenic health effects such as stomach irritation, and effects on the nervous system, heart, blood vessels, and skin.

Cadmium: There is some evidence that cadmium causes cancer, which has been demonstrated in rats exposed to high levels in their drinking water over their lifetime. Some people exposed to large amounts of cadmium experience kidney and bone damage. Exposure to high levels of cadmium damages the kidneys, blood, liver, heart, and the immune and nervous systems of laboratory animals. High exposure also damages the unborn offspring of laboratory animals exposed during pregnancy.

Lead: Ingestion of lead can increase blood lead levels. Numerous scientific studies show that elevated blood lead levels in children (before or after birth) cause or are associated with adverse effects on the developing nervous system. These include reductions in several measures of cognitive ability, which is an indicator of a child's ability to learn.

Mercury: The nervous system is very sensitive to all forms of mercury. Methylmercury and metallic mercury vapors are more harmful than other forms, because more mercury in these forms reaches the brain. Exposure to high levels of metallic, inorganic, or organic mercury can permanently damage the brain, kidneys, and developing fetus. Effects on brain functioning may result in irritability, shyness, tremors, changes in vision or hearing, and memory problems. Short-term exposure to high levels of metallic mercury vapors may cause effects including lung damage, nausea, vomiting, diarrhea, increases in blood pressure or heart rate, skin rashes, and eye irritation.

What health effects can be caused by exposure to PCBs?

The most commonly observed health effects in people exposed to large amounts of PCBs are skin conditions such as acne and rashes. Studies in exposed workers have shown changes in blood and urine that may indicate liver damage. PCB exposures in the general population are not likely to result in skin and liver effects. Most of the studies of health effects of PCBs in the general population examined children of mothers who were exposed to PCBs. Animals that ate food containing large amounts of PCBs for short periods of time had mild liver damage and some died. Animals that ate smaller amounts of PCBs in food over several weeks or months developed various kinds of health effects, including anemia; acne-like skin conditions; and liver, stomach, and thyroid gland injuries. Other effects of PCBs in animals include changes in the immune system, behavioral alterations, and impaired reproduction. PCBs are not known to cause birth defects.

What health effects can be caused by exposure to VOCs?

Short-term exposure to high levels of some VOCs can cause headaches, dizziness, light-headedness, drowsiness, nausea, and eye and respiratory irritation. These effects usually go away after the exposure stops. In laboratory animals, long-term exposure to high levels of some VOCs has caused cancer and affected the liver, kidney, and nervous system.

What health effects can be caused by exposure to PAHs?

Mice that were fed high levels of one PAH during pregnancy had difficulty reproducing and so did their offspring. These offspring also had higher rates of birth defects and lower body weights. It is not known whether these effects occur in people. Animal studies have also shown that PAHs can cause harmful effects on the skin, body fluids, and ability to fight disease after both short- and long-term exposure. But these effects have not been seen in people.

What health effects can be caused by exposure to PFAS?

A large number of studies have examined possible relationships between levels of PFAS in blood and harmful health effects in people. However, most of these studies analyzed only a small number of chemicals, and not all PFAS have the same health effects. Research suggests that high levels of certain PFAS may: increase cholesterol levels; decrease how well the body responds to vaccines; increase the risk of thyroid disease; decrease fertility in women; increase the risk of serious conditions like high blood pressure or pre-eclampsia in pregnant women; lower infant birth weights; however, the decrease in birth weight is small and may not affect the infant’s health. At this time, scientists are still learning about the health effects of exposures to mixtures of PFAS.

Other Questions

What is an operable unit (OU)?

An operable unit 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.

What is a solid waste management unit (SWMU)?

All facilities that treat, store, or dispose of hazardous waste must investigate and clean up all known or likely releases (i.e., spills) of hazardous wastes or materials with hazardous constituents. These requirements were established under the federal Hazardous and Solid Waste Amendments of 1984 (HSWA). State law was similarly amended and New York State received authorization from the EPA to implement the Corrective Action program. Corrective Action activities are focused on solid waste management units (SWMUs). A SWMU is any unit at a facility where solid and/or hazardous waste is or was managed at facilities that are or have ever been subject to Part 373 permitting (through Part 373 permits, DEC ensures that environmentally protective design and operational standards are maintained at treatment, storage, and disposal facilities).

What is the Resource Conservation and Recovery Act (RCRA)?

The Resource Conservation and Recovery Act (RCRA) is the Federal law which creates the framework for the proper management of hazardous and non-hazardous solid waste. The term “RCRA” is also used to describe the waste management program itself. The RCRA Act, mandated by Congress, gave the EPA and delegated States such as New York authority to develop the RCRA program. The term RCRA is also used interchangeably to refer to the law, regulations and policy and guidance.

Will financial assurance be required for the site?

Yes. Financial assurance is an important component of hazardous waste cleanups. The primary purpose of financial assurance is to ensure that adequate funds will be available when needed to conduct necessary corrective action measures and to maintain the site in the future. The intent of the Resource Conservation and Recovery Act (RCRA) financial responsibility requirements is, in part, to reduce the number of facilities that are insolvent or abandoned by their owners and operators, leaving the costs of corrective action to be borne by the public.

Tecumseh Redevelopment Inc., must post financial assurance using one or more of the financial instruments in 6 NYCRR 373-2.8 in the amount of the cost projection for the remedy selected in any Proposed Statement of Basis(s). Financial assurance must include all remedial activities as well as cover closure and post-closure care for the site.

What is a corrective action management unit (CAMU)?

Corrective action management units are engineered units provided for under the Resource Conservation and Recovery Act (RCRA) regulations to facilitate treatment, storage, and disposal of hazardous wastes. A CAMU is used only for managing CAMU-eligible wastes (sediments and/or soils which exceed either the Class A (Smokes Creek and South Return Trench) or Class C (Ship Canal) sediment guidance values or the protection of ecological resource soil cleanup objectives as the final corrective measure), at the facility being remediated.

A CAMU must be located within the property where the wastes to be managed in the CAMU originated. There are several ways this on-site disposal option facilitates the implementation of a reliable, effective, protective, and cost effective remedy:

  1. Disposal areas will be protected with a liner. The requirement for a liner would be predicated on the concentrations and leachability of the waste going into the CAMU.
  2. Soil testing and concentration limit control. Previous testing has indicated that the arsenic-contaminated soil does not have the propensity to leach arsenic or other contaminants into the groundwater. In addition, a maximum soil concentration would be set for on-site disposal. The CAMU will be designed to incorporate proven and innovative treatment technologies (such as soil washing, stabilization, or solidification) to significantly reduce the toxicity and mobility of remediation waste prior to placement into the on-site cell.
  3. Successful construction and effective maintenance of the CAMU cap. A well-built cap would prevent runoff from being contaminated and prevent soil from eroding. A properly built and maintained CAMU would be very effective and reliable at containing and isolating the waste long-term.
  4. Design provisions to reduce infiltration through the berms and roads by extending cap membranes up berm slopes. Prior to performing a detailed remedial design, a pre-design investigation will be performed to verify that uncovered surfaces are suitable for passive recreational use and minimize the potential for water to percolate through waste materials.

What is climate resiliency?

Remedies at contaminated sites may be vulnerable to the implications of climate change and extreme weather events. The New York State Superfund program developed an approach that raises awareness of these vulnerabilities and applies climate change and weather science as a standard operating practice in cleanup projects. The approach involves periodic screening of remedy vulnerabilities, prioritizing the NYS Superfund program's steps to adapt to a changing climate and identifying adaptation measures to assure climate resilience of NYS Superfund sites such as the former Bethlehem Steel site.

What is meant by hazardous waste?

The term hazardous waste is a regulatory designation. In New York State, hazardous wastes are defined by U.S. Environmental Protection Agency (EPA) and NYSDEC regulations (see Simply defined, a hazardous waste is a waste with properties that make it dangerous or capable of having a harmful effect on human health or the environment. Hazardous waste is generated from many sources, including industrial manufacturing processes, and may come in many forms, including liquids, solids gases, and sludges.

The treatment, storage and disposal of hazardous waste are regulated under the federal RCRA of 1976. Hazardous wastes are defined under RCRA in 40 CFR 261 where they are divided into two major categories: characteristic wastes and listed wastes. Characteristic hazardous wastes are materials that are known or tested to exhibit one or more of the following four hazardous traits: ignitibility, reactivity, corrosivity, or toxicity. Listed wastes are wastes from common manufacturing and industrial processes, or specific industries and can be generated from discarded commercial products.

What is the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)?

CERCLA, also known as Superfund, is the Federal enforcement program whose goals are to identify and characterize suspected inactive hazardous waste disposal sites and to ensure that those sites which pose a significant threat to public health or the environment are properly addressed.

What are solidification and stabilization?

Solidification and stabilization refer to a group of cleanup methods that prevent or slow the release of harmful chemicals from wastes, such as contaminated soil, sediment, and sludge. These methods usually do not destroy the contaminants. Instead, they keep them from “leaching” into the surrounding environment. Leaching occurs when water from rain or other sources dissolves contaminants and carries them downward into groundwater or over land into lakes and streams.

Solidification binds the waste in a solid block of material and traps it in place. This block is also less permeable to water than the waste. Stabilization causes a chemical reaction that makes contaminants less likely to be leached into the environment. They are often used together to prevent people and wildlife from being exposed to contaminants, particularly metals and radioactive contaminants. However, certain types of organic contaminants, such as PCBs and pesticides, can also be solidified.

What is capping?

Capping involves placing a cover over contaminated material such as landfill waste or contaminated soil. Such covers are called “caps.” Caps do not destroy or remove contaminants. Instead, they isolate them and keep them in place to avoid the spread of contamination. Caps prevent people and wildlife from coming in contact with contaminants. Today caps can be planted with wildlife friendly plants that encourage ecological activity while still isolating contaminants.

What is pump and treat?

Pump and treat is a common method for cleaning up groundwater contaminated with dissolved chemicals, including industrial solvents, metals, and fuel oil. Groundwater is pumped from wells to an above-ground treatment system that removes the contaminants from the water. Pump and treat systems are also used to “contain” a contaminant plume by pumping contaminated water toward the wells. This pumping helps keep contaminants from moving and reaching drinking water wells, wetlands, streams, and other natural resources.

What is monitored natural attenuation?

Natural attenuation relies on natural processes to decrease or “attenuate” concentrations of contaminants in soil and groundwater. These conditions are monitored to make sure natural attenuation is continuing to degrade contaminants. Monitoring typically involves collecting soil and groundwater samples to analyze them for the presence of contaminants and other site characteristics. The entire process is called “monitored natural attenuation” or “MNA.” Natural attenuation occurs at most contaminated sites. However, the right conditions must exist underground to clean sites properly and quickly enough. Regular monitoring must be conducted to ensure that MNA continues to work.

How will traffic control be addressed?

Tecumseh Redevelopment Inc.’s contractors will provide adequate traffic controls including flaggers and traffic control devices such as cones, signs and barriers to ensure safe access to and from the site for remediation as necessary. Truck traffic patterns will be designed to minimize congestion on local roads and maintain safety in the community. These traffic control details (including truck traffic frequency, times of activity, etc.) will be described in the Remedial Action Work Plan (RAWP), which will be issued prior to implementation.

What is a Site Management Plan and how does it work?

A Site Management Plan defines how a site is to be managed and monitored once the remedy is completed to ensure the effectiveness of the remedy is maintained. The document includes an Institutional and Engineering Control Plan (which will identify all use restrictions and engineering controls for the site and details, steps, and media-specific requirements necessary to ensure all institutional and engineering controls remain in place and are effective), a Monitoring Plan (to assess the performance and effectiveness of the remedy), and an Operation and Maintenance Plan (to ensure continued operation, maintenance, optimization, monitoring, inspection, and reporting of any mechanical or physical components of the remedy).

  • Who Writes the Plan: Tecumseh Redevelopment, Inc.
  • Who Approves the Plan: NYSDEC & NYSDOH
  • Plan Highlights:
    • Identify all use restrictions (for example, areas of the site proposed for passive recreational use and areas restricted for commercial use).
    • Outline of institutional and engineering controls (for example, soil cover) and maintenance requirements thereof.
    • Include provisions to establish and maintain access agreements where it’s necessary to inspect and/or perform future work.
    • Include a Soils Management Plan, outlining requirements if the property owner intends to disturb soils beneath the established cover system.
    • Require periodic inspections to ensure the remedy remains in place and continues to be effective in the protection of public health and the environment.
    • Outline steps necessary to track property ownership changes to ensure new owners get notifications and reminders.
    • Provide contact information for NYSDEC, NYSDOH, and Tecumseh Redevelopment, Inc.

The following link includes a template for a Site Management Plan which would be used as a starting point to develop a specific plan for the former Bethlehem Steel Site:

For More Information

Where can I find more information?

Project documents are available at the following locations to help the public stay informed:

  • Lackawanna Public Library
    560 Ridge Road
    Lackawanna, NY 14218
    Call 716-823-0630
    Region 9 Office Headquarters
    270 Michigan Avenue
    Buffalo, NY 14203
    Call ahead for an appointment
    716-851-7220, Mr. Stanley Radon

Additional information regarding the Bethlehem Steel site may be obtained by:

  1. Contacting NYSDEC's Buffalo Office at 716-851-7220 or NYSDEC's Albany Office at 518-402-9814.
  2. Accessing the DECinfo Locator (, an interactive map that lets you access NYSDEC documents and public data about the environmental quality of specific sites in New York State.
  3. Information on the New York State Superfund Program (Site Number for this site is 915009) at the following link:
  4. Information about the site, as well as an online form, email address ([email protected]), and toll-free hotline (833-578-2019) for submitting inquiries are located on the public availability webpage at the following link:

The NYSDEC maintains a web page with additional information specific to this site:

For project remedy selection-related questions, contact the DEC:

Stanley Radon
NYS Department of Environmental Conservation
Division of Environmental Remediation
270 Michigan Avenue
Buffalo, NY 14203-2915
[email protected]

For project investigation-related questions for additional areas, please contact the NYSDEC Project Managers:

Andrew Zwack, NYSDEC, Division of Environmental Remediation
Project Manager for Operable Unit 05 Slag Fill Zone 2
270 Michigan Avenue, Buffalo, NY 14203-2915; (716) 851-7220; [email protected]

Matthew Dunham, NYSDEC, Division of Environmental Remediation
Project Manager for Operable Unit 06 Tank Farm Sub-Area
625 Broadway, Albany, NY 12233-7017; (518) 402-9813; [email protected]

Ben Rung, NYSDEC, Division of Environmental Remediation
Project Manager for Operable Unit 07 Coal, Coke and Ore Handling & Storage Sub-Area, and Coke Plant & By-Products Facility Sub-Area
625 Broadway, Albany, NY 12233-7017; (518) 402-9813; [email protected]

Steve Moeller, NYSDEC, Division of Environmental Remediation
Project Manager for Operable Unit 08: Slag Fill Area - Zones 4 & 5 SWMU/AOC Group
270 Michigan Avenue, Buffalo, NY 14203-2915; (716) 851-7220; [email protected]

Brianna Scharf, NYSDEC, Division of Environmental Remediation
Project Manager Operable Unit 09 Waterbodies
625 Broadway, Albany, NY 12233-7017; (518) 402-5987; [email protected]

Jenelle Gaylord, NYSDEC, Division of Environmental Remediation
Project Manager for Operable Unit 10 Site Wide Groundwater
625 Broadway, Albany, NY 12233-7017; (518) 402-9813; [email protected]

For project related health questions, please contact NYSDOH Project Manager:

Sara Bogardus, NYSDOH, Bureau of Environmental Exposure Investigation
Project Manager
Empire State Plaza - Corning Tower Room #1787; Albany, NY 12237; (518) 402-7860
[email protected]

How do I stay informed?

NYSDEC and NYSDOH will continue to keep the public informed as this work progresses and as development of cleanup plans are finalized.

Using the DEC info Locator (, an interactive map that lets you access NYSDEC documents and public data about the environmental quality of specific sites in New York State.

Sign up for the contaminated sites county email listserv to receive site-related information and announcements for all contaminated sites in the county. Sign up for the listserv is available at the following web page:

List of Acryonyms

BSC Bethlehem Steel Corporation
CAMP Community Air Monitoring Plan
CAMU Corrective Action Management Unit
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CMS Corrective Measures Study (Feasibility Study)
EPA U.S. Environmental Protection Agency
ICM Interim Corrective Measures (Interim Remedial Measure)
MNA Monitored Natural Attenuation
MTBE Methyl Tert-Butyl Ether
NORM Naturally Occurring Radioactive Material
NYSDEC New York State Department of Environmental Conservation
NYSDOH New York State Department of Health
PAH Polycyclic Aromatic Hydrocarbons
PCB Polychlorinated Biphenyl
PDI Pre-Design Investigation
PFAS Perfluoroalkyl and Polyfluoroalkyl Substance
RAWP Remedial Action Work Plan
RCRA Resource Conservation and Recovery Act
RFI RCRA Facility Investigation (Remedial Investigation)
SCO Soil Cleanup Objectives
SVOC Semi-volatile Organic Compound
SWMU Solid Waste Management Unit
VOC Volatile Organic Compound