Fines and Penalties

Consistent with our environmental policy and objectives, in 1995 Bethlehem Steel resolved a number of historic environmental compliance cases from the early and mid-1980s. Discussions with regulatory agencies suggest that we have resolved most of our environmental legacy issues and will be involved in fewer cases in the future.

Fines and penalties totaling $5.9 million in 1995 included the following:

• Burns Harbor Division: Resolution of waste management and a corrective action lawsuit with EPA regarding the application of Resource Conservation and Recovery Act (RCRA) corrective action requirements and the management of certain sludges as hazardous wastes. ($3.4 million)
• BethShip-Sabine Yard: Agreement with EPA and the Texas Natural Resources Commission to resolve a case alleging the discharge of pollutants without a National Pollutant Discharge Elimination System (NPDES) permit. ($1.5 million)
• Lackawanna Coke Division: Resolution of alleged violations of charging, pushing, lids, doors, waste heat stacks and desulfurization requirements through a consent order with the New York Department of Environmental Conservation. ($0.8 million)
• Sparrows Point Division: Settlement of citations from the U.S. Coast Guard for oil spills. ($0.1 million)
• Miscellaneous. ($0.1 million)

Environmental Compliance Index

Bethlehem Steel measures its environmental performance with an environmental compliance index (ECI), which is defined as the number of exceedances/incidents reported to or cited by government agencies during a reporting month. The index components are air exceedances, water discharge exceedances, spills and notices of violation. The sum of these four components creates the ECI. Overall, we reduced the ECI by more than 50 percent from 1994 to 1995.

The number of environmental exceedances in 1995 (43 spills, 134 water, 250 air) were less than goal for the year. Notices of violation are included in appropriate categories.

We also monitor our environmental performance through a comprehensive environmental auditing process. To promote improved effectiveness, we want the audit to take us beyond simply "identifying and fixing problems" to searching for underlying or "root causes" and eliminating them by managing the process better. During 1995, we conducted environmental audits at seventeen Bethlehem facilities.

Another measure of environmental performance is our progress in reducing the number of underground storage tanks, thereby avoiding the application of stringent regulations and potential future liability. From 1985 to 1995, we removed, closed in place or sold more than 97 percent of our underground storage tanks containing petroleum.

We registered 398 tanks in 1985 and since then have either transferred them with property sales, closed them in place or removed them. Today, only 10 regulated underground tanks remain at our facilities.

Safety, Health and Environment Department
1170 Eighth Avenue, Martin Tower; 12th Floor, Bethlehem, PA 18016-7699
For further information about this report, send mail to [email protected]

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