Environmental Performance

Environmental Compliance Index

Measurement of environmental performance is becoming increasingly important due to mounting pressure on most manufacturing operations to develop and implement ISO 14001, or equivalent, environmental management systems (EMS). Bethlehem is currently reviewing the list of available metrics to supplement its Corporate Environmental Compliance Index (ECI), particularly leading indicators, which are in-process measures of performance rather than lagging indicators.

Bethlehem's ECI is the number of exceedances/incidents reported to or cited by government agencies in a month. In 1998, Bethlehem reduced its ECI by 73 percent compared to 1997. Since 1994, the ECI has been reduced by 85 percent. For the first six months of 1999, the total number of exceedances/incidents is 10 percent lower compared to the same period in 1998.

Individual business divisions all showed significant reductions in their ECI in 1998 compared to 1997: Burns Harbor (48 percent); PST (65 percent); Sparrows Point (40 percent); and the former Bethlehem Plant operations (84 percent). For the first six months of 1999, all business divisions improved their performance except Sparrows Point, which showed a slight increase in its ECI. Over the long term, however, Sparrows Point has decreased its ECI by 47 percent since 1994 despite the recent upward trend. A comparison for Bethlehem Lukens Plate cannot be made since the division was created in May 1998 with the acquisition of Lukens Steel Company.

Fines and Penalties

Bethlehem paid $913,000 in fines and penalties in 1998 compared to $833,000 in 1997, an increase of 10 percent. Of the 1998 total, 97 percent was incurred at two facilities: (1) the former Bethlehem Coke Works, for air emissions and water discharges that occurred primarily in 1997 (the batteries were shut down in March 1998); and (2) Burns Harbor, to resolve a 1994 problem related to water seepage from blast furnace quench basins. Fines and penalties paid during the first half of 1999 totaled almost $48,000; for the year, they are expected to be well below those paid in 1997 and 1998.

Audits

Corporate environmental audits were completed at Sparrows Point and Bethlehem Lukens Plate Divisions during 1998. Audits of PST and Lackawanna Coke are scheduled in 1999.

Support from Research

Bethlehem is also actively involved in the auditing of outside environmental laboratories that provide services to Bethlehem. Audits are conducted by a small group of multi-talented chemists in Bethlehem's research department who provide analytical chemistry and laboratory services. The group's responsibilities range from analyzing the content of various steel products to monitoring the quality of purchased goods.

The group also serves as the technical interface with outside environmental labs, on behalf of the corporate safety, health and environment department.

EPA's Toxic Release Inventory

Bethlehem has been reporting toxic chemical release inventory data to the EPA since the requirement was established in 1986 by the Emergency Planning and Community Right to Know Act. This law was designed to help protect public health, safety and the environment from chemical hazards through the leadership of State Emergency Response Commissions and Local Emergency Planning Committees. Since 1987, Bethlehem has reduced its releases by more than 15 million pounds per year, or 72 percent (75 percent excluding Lukens).

Toxic chemical release reports were submitted to EPA for calendar year 1998 by 10 different facilities on or before July 1, 1999. A total of 6 million pounds of toxic chemical releases were reported for 43 different listed chemicals, an apparent increase of approximately 13 percent over the releases reported for 1997. It should be noted that the increase is due to the addition of four new reporting facilities as part of the acquisition of Lukens Steel Company in May 1998. Excluding the former Lukens facilities, Bethlehem's other six reporting facilities reported an aggregate of 5.1 million pounds, or a decrease of almost four percent from the 5.3 million pounds reported in 1997.

With the shutdown of the Bethlehem Coke Works in March 1998 and the divestiture of two of the four former Lukens facilities in 1999, toxic chemical releases should decrease to approximately 5 million pounds during the next reporting cycle.

Superfund Sites

As of December 31, 1998, Bethlehem was involved in 26 Superfund sites for which EPA or a state regulatory agency has advised that the corporation may be considered a "potentially responsible party" for site remediation. EPA may impose liability for site remediation on waste generators, owners and operators, both past and present, regardless of fault or the legality of the original disposal activities. Based on its experience regarding site remediation and its knowledge of and extent of involvement in such sites, Bethlehem expects that its share of the costs for remediation of these sites will not be material.

1998/99 Environmental Report Table of Contents