State Highways 7 and 78
Independence, MO 64057-3212
United States
Permanent Hard Copy Location(s)
Location of hard copies of regulatory mechanism(s) and any modifications, reports and other supporting documents.
Missouri Department of Natural Resources, Elm Street Conference Center, Jefferson City, MO 65102 (Submit a Sunshine Law Request to review or obtain copies of the department's files.)
Overview
Background/ History
The Lake City Army Ammunition Plant (LCAAP) is a 3,935-acre, government-owned, contractor-operated, military industrial installation located at the junction of highways 7 and 78, near Independence. LCAAP began operating in 1941 and manufactures and tests small caliber ammunition for the Department of Defense. The facility was deactivated at the end of World War II, then reopened at the beginning of the Korean conflict. It is the largest small-arms (5.56 - 20 mm) ammunition manufacturing plant in the world.
Industrial operations produced large quantities of potentially hazardous waste, including solvents, explosives, heavy metals, perchlorates and depleted uranium. Since 1941, the facility disposed of these wastes in lagoons, landfills and burn pits located throughout the facility. LCAAP currently stores the waste in several hazardous waste container storage areas until shipped for disposal or incinerated in an on-site rotary kiln. The current storage and disposal activities are permitted under two hazardous waste permits, one issued by the department and one issued by EPA, both effective May 17, 2002. The department issued the Missouri Hazardous Waste Management Facility Part I Permit. EPA issued the Hazardous and Solid Waste Amendments Part II Permit.
Cleanup Summary
Past waste handling and disposal practices has led to widespread contamination of the site. Corrective action is being addressed under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) with the understanding that all federal Resource Conservation and Recovery Act (RCRA) issues are being fully addressed. In 1987, the Army began an investigation to determine the extent and type of contamination on site. The study confirmed that soil, surface water and groundwater beneath the site are contaminated with volatile organic compounds, various explosives, perchlorates and heavy metals including lead, arsenic, and chromium. Contaminated groundwater has moved off-site in the northeast corner of the LCAAP, but does not appear to have migrated far beyond the site boundary.
LCAAP was placed on the Superfund National Priority List in August 1987. A Federal Facility Agreement between EPA, the Army, and the State of Missouri was signed in 1989, to address investigative, design, and cleanup activities throughout the Installation. Currently, LCAAP has a pump and treat system to
Due to the Lake City AAP facility being listed on the EPA Superfund National Priorities List, and in order to eliminate overlap, environmental investigation and cleanup activities that would be addressed under federal Resource Conservation and Recovery Act (RCRA) through the Part I Permit are being conducted under the Corrective action is being addressed under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). This deferral remains effective as long as the activities conducted under CERCLA are consistent with and address the substantive requirements that would otherwise apply under the State’s RCRA-equivalent program.
Operations
The Lake City Army Ammunition Plant (AAP) is located on about 3,909 acres at 25201 E. Hwy 78, at the intersection of Highways 7 and 78, on the east side of Independence, Missouri. Lake City AAP is a Class II government-owned, contractor-operated military industrial installation, originally under the jurisdiction of the U.S. Army Armament, Munitions and Chemical Command. The plant began operation in 1941, under the name Lake City Installation, to manufacture and test small caliber ammunition. In 1954, the plant was renamed Lake City Ordnance Plant, which was later changed to Lake City Army Ammunition Plant in 1963.
The plant has operated continuously, except for a five-year period between the end of World War II and the beginning of the Korean conflict. The operating contractor from 1941 to 1985 was Remington Arms Inc., a wholly owned subsidiary of E.I. Du Pont de Nemours & Co. The plant operation was assumed by Olin Corp. in November 1985, and then by Alliant Lake City Small Caliber Ammunition Co. LLC in April 2000. Alliant changed their name to Alliant Techsystems Operations LLC in July 2006. The plant is currently under the jurisdiction of the U.S. Army Operations Support Command and operated by Alliant.
Lake City AAP is the largest small-arms manufacturing plant in the world. The plant manufactures a variety of small-arms ammunition including .30 caliber, .38 caliber, .50 caliber, 5.56 mm, 7.62 mm, 20 mm and 30 mm ammunition for the Department of Defense (DOD). The projectiles are primarily made from materials such as lead, but depleted uranium was also used from 1960-1961 and 1974-1976.
A Small Caliber Ammunition Modernization Program began at the Lake City AAP in 1975, to develop high-speed computer-operated ammunition production. Operations included cartridge case drawing, annealing, pickling and forming; case priming; and cartridge loading and assembly. Materials used in the production process include hydrochloric acid, sulfuric acid, nitric acid, explosive compounds (e.g., lead azide and lead styphnate), phosphate cleaners, petroleum and lubricating oils and cleaning solvents.
A variety of hazardous wastes are produced as part of the facility operations. Historical waste management practices included disposal of wastes in on-site landfills, lagoons and open burn pits located throughout the facility property. Remington Arms historically operated an Industrial Wastewater Treatment Plant (IWTP) to treat wastewater from the production processes. The treated effluent was discharged to one of two land-based settlement systems. Each system consisted of three lagoons, operated in series to remove suspended solids. One settlement system was used at a time, alternating between systems about once a year, so sludge could be removed from the inactive lagoons.
From the mid-1960s until 1988, sludge and dewatered oil residue from the IWTP was disposed in an on-site landfill, which contained four cells. Cell 1 and 2 contained wastewater treatment sludge from the manufacturing, formulation and loading of lead-based initiating compounds, which are classified as hazardous waste (K044 or K046). During the operating life of Cells 1 and 2, about 35,000 cubic yards of sludge was disposed in those cells. Cell 3 was never used. Cell 4 was used to dispose non-hazardous sludges after 1986, when lead-based initiating compound wastewater was no longer processed. These disposal practices continued for many years and exact records of the type and amount of materials disposed of were not kept.
Remington Arms also operated a deactivation furnace in the center of the production areas. In 1989, Olin upgraded the furnace to an Explosive Waste Incinerator, consisting of feed and discharge assemblies, a cast-steel rotary kiln and an air pollution control system.
The waste management procedures at the plant have evolved since 1941. Currently the wastes are stored in several hazardous waste container storage areas until treated or shipped off-site for disposal. The managed wastes include various ignitable, corrosive and reactive wastes, as well as wastes that are toxic for a variety of metal and organic contaminants. The facility also produces certain F-listed spent non-halogenated solvents and discarded commercial chemical products, which may be stored until shipped off-site for disposal.
Alliant currently operates 12 hazardous waste container storage areas, with a combined capacity of 192,720 gallons, and the Explosive Waste Incinerator, with a handling capacity of 2,100 pounds of waste per hour. The IWTP currently operates under a National Pollution Discharge Elimination System permit and is exempt from hazardous waste permitting requirements.
Production and maintenance related wastes generated on-site and obsolete and off-specification ammunition produced on- and off-site by Alliant, DOD and DOD contractors may be stored and treated in the Explosive Waste Incinerator. The incinerator also treats ammunition items, scrap propellant powders and explosive wastes produced during the manufacturing and assembly processes. Hazardous wastes not treated in the incinerator are temporarily stored in container storage areas until they are shipped off-site for processing or disposal.
Closure & Cleanup
Remington Arms stopped using several hazardous waste container storage areas in the early 1980s. In 1987, EA Engineering, Science and Technology Inc. performed a Preliminary Assessment/Site Investigation (PA/SI), for the facility on behalf of the U.S. Army Toxic and Hazardous Materials Agency, as part of its Installation Restoration Program. The PA/SI was conducted to identify and gather information on actual and potential releases of hazardous waste and hazardous constituents to the environment. In August 1987, Lake City AAP was placed on the Superfund National Priorities List (NPL), due to elevated contaminant concentrations found in the environment throughout a large part of the installation. The 1989 PA/SI Report identified 74 potential contaminant sources and recommended a Remedial Investigation/Feasibility Study (RI/FS) be completed for the entire installation.
Past hazardous waste handling and disposal practices has led to widespread contamination of the soil, groundwater and surface water with volatile organic compounds, semi-volatile organic compounds, explosive compounds and heavy metals. According to applicable state and federal hazardous waste laws and regulations, all permitted hazardous waste treatment, storage and disposal facilities are required to investigate and clean up releases of hazardous waste and hazardous constituents to the environment at their facility resulting from present and past hazardous waste handling practices. Due to the historical listing of the Lake City AAP facility on the NPL, and in order to eliminate overlap, the investigation and cleanup activities are being conducted under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), rather than the State’s Resource Conservation and Recovery Act (RCRA)-equivalent program. In 1989, EPA, the Army, and the State of Missouri signed the Lake City Army Ammunition Plant 120 Interagency Agreement, to address most environmental investigation and cleanup activities at the facility under CERCLA.
The hazardous waste container storage areas Remington Arms stopped using in the early 1980s were part of the RI/FS; therefore, closure was deferred to CERCLA. Olin closed several hazardous waste management units during the late 1980s and early 1990s. The department accepted Olin’s closure report and certification for the explosive wastewater impoundments in February 1989, IWTP sludge lagoons and oil and grease trenches in March 1989, and explosive wastewater lagoons in September 1990. During 2008 and 2009, Alliant closed the IWTP sludge landfill. The department accepted Alliant’s closure report and certification for the landfill in April 2016. Because residual hazardous waste remained in place at each of these areas after closure, these areas are required to go through a period of post-closure care. The post-closure activities are being conducted under CERCLA.
Because Lake City AAP is a large facility, the potential contaminant sources were combined into 34 areas, which were further combined into five large operable units: the Northeast Corner, Area 18, Area 10 Sand Piles, Installation-Wide and Building 83. Groundwater, surface water and soil are contaminated in various areas with volatile organic compounds, explosives, perchlorates, depleted uranium and heavy metals including lead, arsenic and chromium. Three separate groundwater contamination plumes are present. Contaminants associated with a groundwater plume in the Northeast Corner had previously moved beyond the facility property boundaries, but are currently contained on-property by a groundwater pump and treat system. Air strippers are also operated on several on-property production wells to remove contaminants from extracted groundwater.
In addition to the 1987 NPL listing by EPA, the department placed the Lake City AAP facility on the Registry of Confirmed Abandoned or Uncontrolled Hazardous Waste sites on March 2, 2001. Additional information on the remedial actions taking place at the facility can be found on EPA’s website at cumulis.epa.gov/supercpad/cursites/csitinfo.cfm?id=0701757.
Oversight
Lake City AAP is currently operating under a department-issued Missouri Hazardous Waste Management Facility Part I Permit, which was issued May 25, 2017. This permit was first issued in 1989 and reissued in 2002, along with an EPA-issued Hazardous and Solid Waste Amendments Part II Permit. The department reissued the Part I Permit; however, EPA decided not to reissue the Part II Permit, since EPA has no site-specific conditions for the facility beyond those contained in the Part I Permit and Missouri is fully authorized for all permitting activities at the facility.
The Part I Permit allows Alliant to store hazardous wastes in container storage areas and treating hazardous waste in its incinerator. The waste includes “characteristic” hazardous waste as well as various F-, K- and U-listed hazardous wastes as specified in the Part A and B applications. The regulated units under the current permits consist of 12 hazardous waste container storage areas and the explosives waste incinerator. These permits also require corrective action in the event there is a newly-identified release to the environment from a new or previously-identified solid waste management unit or area of concern. Most post-closure and corrective action activities for known solid waste management units, areas of concern, and known releases from those units/areas, which would otherwise be addressed under the Part I Permit, were deferred to CERCLA, with EPA providing primary regulatory oversight in coordination with the department’s Federal Facilities Section. The deferral from the RCRA to CERCLA program is clearly recognized in the Part I Permit. This deferral will continue as long as the activities conducted under CERCLA are consistent with and address the substantive requirements that would otherwise apply under the State’s RCRA-equivalent program. If, at any time, the department determines that all corrective action issues are not being addressed according to those requirements, the department retains the option to modify the Part I Permit as necessary to address the requirement(s).
Documents
Listed below are the currently effective regulatory mechanism(s) and any modifications, institutional controls and any supporting documents regarding this property that the department currently has available in electronic form. The department realizes some of the electronic files can be quite large, which may result in long download times for individuals with slow internet connections. If you have any problems accessing these documents, please contact the department’s Waste Management Program by telephone at 573-751-5401 or 800-361-4827, or by email at wmp@dnr.mo.gov.
You can review printed copies of all regulatory agreements, reports and other supporting documents at the department’s Elm Street Conference Center in Jefferson City, Missouri. To review or obtain copies of the department’s files, please submit a Sunshine Law Request.
Regulatory Agreement
| Regulatory Agreements | Regulatory Agreement Note |
|---|---|
Part I Effective Date: Expiration Date: No Part II |