Bethlehem City Council formally approved a negotiated settlement with the Pennsylvania Department of Environmental Protection on Tuesday to address recurring violations at the city’s wastewater treatment plant, including a one-time civil penalty of $26,900.
The Consent Order and Agreement, approved unanimously by council, settles violations of Pennsylvania’s Clean Streams Law that occurred primarily between August 2021 and October 2025. The agreement outlines a roadmap of infrastructure improvements the city must complete by 2030.
COAs document “recurring violations of our permit,” explained Edward Boscola, Bethlehem’s director of water and sewer resources.
“They issue penalties and they provide a roadmap and a schedule to return the system to compliance,” he said. “It’s a public document. It gets everything out in the open.”
The settlement follows approximately two years of negotiations between city officials and the state agency.
The violations included repeated exceedances of ammonia-nitrogen, fecal coliform and suspended solids limits in water discharged from the Bethlehem Wastewater Treatment Plant into the Lehigh River.
State regulators also documented nearly 20 sanitary sewer overflows — or SSOs — during the period, caused by grease blockages, rags and equipment failures. One overflow in March 2025 at East Third Street and Founders Way released between 1,500 and 2,000 gallons of waste. Another, in March 2022, backed up untreated sewage into a home due to a sewer main blocked with grease.
The department found the city failed to provide required notifications for several incidents within mandated timeframes.
Boscola told council the ammonia problems stem from an unintended consequence of previous improvements. Starting in 2012, the city invested heavily in upgrading its solids handling and dewatering systems at the treatment plant. While those improvements allowed the city to produce drier biosolids suitable for use as fertilizer on farms, they also increased the amount of nitrogen returning to the liquid treatment side of the plant.
“The improvements of the solid handling systems to some extent exacerbated the problems on the liquid train or the aeration system’s ability to process nitrogen,” Boscola said.
Mayor J. William Reynolds provided additional context, noting that “solving project A just created a different chemical issue as far as project B was concerned. The good news is that project B is a lot less expensive … to handle than project A and the solutions of project B will be done in the next couple years.”
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The city has already made progress addressing the violations. Boscola reported only one violation since October 2025, a significant improvement from the 2021-25 period when violations were more frequent.
The settlement requires four specific infrastructure projects. Two are already complete: an upgrade to the Broadway sanitary sewer line, finished last year, and a chemically enhanced treatment system, also completed in 2025. A third project to upgrade the Easton Road lift station is ready to go out for bid and should be finished by 2027.
The fourth and largest project involves a major upgrade to the plant’s aeration tank system, which must be completed by December 2030. This improvement is designed to address the ammonia processing issues that have plagued the facility.
Beyond the initial $26,900 penalty, the agreement includes stipulated penalties for any future violations: $500 for each discharge violation or $1,000 for each sanitary sewer overflow.
The city has dramatically reduced SSOs in recent years. “We’ve only had two SSOs in the past two years,” Boscola said. The overflows are typically caused by blockages from grease, rags, roots, and other materials that shouldn’t be in the sewer system.
Councilwoman Hillary Kwiatek raised concerns about oversight during the compliance period and announced she would propose a resolution requiring regular progress reports to council. She cited the need for “public trust in these systems, especially ones that we have to charge money and we do sometimes raise the rates.”
“And we want people to know that we’re progressing on this path,” Kwiatek said.
Boscola noted the COA already requires the city to submit written progress reports to DEP twice yearly and offered to copy council on those submissions.
The consent order can be terminated after six continuous months without violations, though Boscola indicated the actual end would likely involve negotiations with DEP once all projects are complete and the plant maintains a clean compliance record.
View the entire Consent Order and Agreement at bethlehem-pa.gov.
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