Document 5K4MvEn3j3DoZ60gxrvy2gme

United States Environmental Protection Agency Region 7 Enforcement and Compliance Assurance Division Air Branch Inspection Report Unannounced Partial Compliance Evaluation Lake City Army Ammunition Plant 25201 East 78 Highway Independence, Missouri 64051 FRS# 110042063021 Inspection Date(s): September 24-25, 2024 Charlotte Papp, Inspector, ECAD, Air Branch Authorized for Release by: Jodi Bruno, Air Branch Manager, ECAD 11201 Renner Boulevard Lenexa, Kansas 66219 Page 1 of 7 CONTENTS INSPECTION OVERVIEW .................................................................................................................. 3 INSPECTION OBJECTIVE .............................................................................................................. 3 FACILITY CONTACT INFORMATION ............................................................................................. 3 FACILITY OVERVIEW .................................................................................................................... 4 FACILITY OPERATIONS SUMMARY .............................................................................................. 4 FIELD ACTIVITIES SUMMARY....................................................................................................... 5 INSPECTION OBSERVATIONS AND POTENTIAL FINDINGS .............................................................. 5 TABLES Table 1. APPLICABLE PERMIT CONDITIONS, REGULATIONS AND STANDARDS .............................. 3 Table 2. PROJECT TEAM MEMBERS ................................................................................................ 3 Table 3. FACILITY CONTACT INFORMATION ................................................................................... 3 APPENDICES A - Confidential Business Information Form (2 pages) B - Receipt for Documents (5 pages) This Contents page shows all the sections contained in this report and provides a clear indication of the end of this report. Page 2 of 7 INSPECTION OVERVIEW INSPECTION OBJECTIVE The objective of the partial compliance evaluation (PCE) inspection was to determine compliance of the facility with the Clean Air Act (CAA), specifically those requirements listed in Table 1. The inspection was part of the U.S. Environmental Protection Agency's (EPA) core program. Code of Federal Regulation 40 CFR Part 63 40 CFR Part 63 Table 1. APPLICABLE PERMIT CONDITIONS, REGULATIONS AND STANDARDS Standard Name Subpart EEE - National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors Subpart N - National Emission Standards for Chromium Emissions From Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks Table 2 lists the inspection team members. Team Member Charlotte Papp Trevor Urban Daniel Simmons Table 2. PROJECT TEAM MEMBERS Organization EPA Region 7, ECAD, Air Branch EPA Region 7, ECAD, RCRA Missouri Department of Natural Resources Project Role Lead inspector - CAA Lead inspector - RCRA Field team member FACILITY CONTACT INFORMATION Table 3 lists the primary facility contacts alphabetically by last name. Table 3. FACILITY CONTACT INFORMATION Name, Title Phone No. Email Address Tonya L. Aggson, Environmental Manager 816-656-1696 tlaggson@olinlc.com Jaime Allison, Vice President of Operations Closing conference only Brian Batliner, R3 Group Supervisor Closing conference only Denise Bricker, EH&S Director 816-656-1731 DMBricker@olinlc.com Carmen Brock, Environmental Engineer 816-507-8962 cmbrock@olinlc.com Eric Couch, R3 Group Operator Closing conference only Kelly Hester, Environmental Coordinator 816-796-7152 kelly.j.hester.civ@army.mil Adam Hinsdale, Deputy to the Commander Closing conference only Brian Huckabay, Olin Winchester Closing conference only Page 3 of 7 Lieutenant Colonel Brian Jones, Commander, U.S. Army Dalton Kenig, Environmental Engineer Mike Stock, Olin/Winchester Closing conference only 816-819-4510 dkenig@onlinlc.com Closing conference only FACILITY OVERVIEW Lake City Army Ammunition Plant (LCAAP) is a federal facility located in Independence, Missouri. LCAAP is a government owned, contract-operated military industrial installation under the jurisdiction of the U.S. Army Industrial Operations Command. Olin Winchester, LLC, is the current contract operator of the facility and took over operations on October 1, 2020. However, Alliance Techsystems Operations, LLC (ATO)/Northrop Grumman Corporation (NGC) continues as the contract operator of the 20mm production function in Building 65 at the facility. LCAAP has approximately 1,600 employees and operates 24-hours per day, 7 days per week, utilizing multiple daily shifts. The munitions operations are currently operating 24-hours per day, 5 days per week (Monday - Friday). The incinerator operates 24-hours per day, 5 days per week (Monday - Friday). The last onsite compliance monitoring activity at the facility was on June 19, 2024, and consisted of a PCE (stack test) conducted by the Missouri Department of Natural Resources (MoDNR). According to the Enforcement and Compliance History Online (ECHO) database, this performance test had mixed results of passing and failing. According to LCAAP's Title V operating permit issued by MoDNR on November 1, 2021, the facility is subject to the regulations and standards subject to review during this inspection as noted in Table 1. FACILITY OPERATIONS SUMMARY The facility manufactures several types of small ammunition. This CAA inspection focused on the incineration process. Waste is taken to the incinerator via totes and other small containers. Waste is then fed by hand into the incinerator hopper where it is weighed and brought onto the primary, then secondary conveyor systems. If the weight, flow, and mix of waste is appropriate, the conveyor gate arm will open, and waste will be fed into the four-chambered rotary kiln for incineration. Exhaust gasses from the incineration process are vented to an afterburner, evaporative cooler, powdered activated carbon (PAC) injection, baghouse, then finally released to the atmosphere. All process areas within the incineration unit are monitored continuously. Feed rates of waste into the incinerator are monitored and controlled. Different "recipes" (operating parameters, flow rates, and mixes of waste quantities) are used to ensure adequate combustion of materials. Page 4 of 7 FIELD ACTIVITIES SUMMARY Trevor Urban and I arrived at the facility on September 24, 2024, at approximately 9:15 a.m. and completed a drive by surveillance inspection. I did not observe visible emissions. We made entry at the security office where we were met by Denise Bricker who escorted us into the facility. I introduced myself and members of the inspection team, presented my credentials, and provided my business card to facility staff listed in Table 3. I was given a facility safety briefing by Tonya Aggson. I conducted an opening conference during which I explained that the purpose of the visit was to conduct an inspection to determine compliance with the CAA, specifically, to determine compliance with the regulations and standards listed in Table 1. I explained that after asking for some general business information, I would observe the incinerator with associated control devices and review associated records demonstrating compliance with the regulations. I explained to Ms. Bricker that the facility would have an opportunity to make a claim of business confidentiality at the end of the inspection and provided her with a Confidential Business Information (CBI) form. Ms. Bricker did not make a claim of confidentiality (Appendix A). The inspection team was given a facility tour. I was asked to wear the following PPE for general site safety: safety glasses, hearing protection, and steel-toed boots. We began the tour at the incinerator at 11:32 a.m. We remained at the incinerator until we broke for lunch at approximately 1:00 p.m. We reconvened at 1:50 p.m. at which time the RCRA inspection group split off from the CAA inspection group. The RCRA inspection group continued with a site tour while the CAA inspection group reviewed records in the conference room. We departed the facility at approximately 4:15 p.m. I obtained copies of the records as indicated on the Receipt for Documents (Appendix B). Trevor Urban returned to the site the following day (September 25, 2024) to conclude onsite activities. He led the closing conference onsite while I joined remotely. The closing conference began at 2:00 p.m. with facility members listed in Table 3. I provided the facility with copies of the Small Business Resources Information Sheet. We discussed preliminary observations and outstanding documents that were requested to be sent digitally. On October 1, 2024, I received all requested documents via a OneDrive folder. The closing conference concluded at 2:50 p.m. INVESTIGATION OBSERVATIONS AND POTENTIAL FINDINGS Ambient weather, site conditions, and field activities were documented in the field records. No photographs were deemed necessary to complete this inspection, thus none were taken while Page 5 of 7 onsite to accommodate security concerns. I made the following observations during the inspection. I discussed all observations with facility representatives during the closeout meeting unless otherwise noted in the observation description. These observations are not final compliance determinations. The EPA Region 7 Air Branch case review team will make the final compliance determinations based on its review of this report and other technical, regulatory, and facility information. According to Ms. Bricker, the facility does not melt any metal onsite, nor use any furnaces for that purpose. Thus, 40 CFR Part 60 Subpart N requirements do not apply. 40 CFR Part 63 Subpart EEE requires LCAAP to operate their Explosive Waste Incinerator (EWI) within operating parameters established from performance test results and specified within their Title V permit. While onsite, I observed the active values (e.g. temperature, pressure, flow rate), and all values were within the specified operating parameters. I requested historic data of these operating parameters and reviewed examples. Within the data I reviewed, the incinerator appeared to be operating within the specified parameters. This subpart also requires that the EWI have an automatic waste feed shutoff system in place, and the facility permit likewise specifies what the limits for the shutoff system are to be. While onsite, I observed the values used for the automatic waste feed shutoff system. All values were within the range specified in the permit. This subpart requires that a certified operator must be on duty at all times and likewise has training requirements for staff who operate the incinerator. There are currently 11 certified operators on staff. According to Ms. Bricker, the incinerator is never operated without a certified operator present. I reviewed the training program slide deck/manual used for the most recent operator refresher training, and it appeared to have all required components specified in 40 CFR 63.1206(c)(6)(v). The staff were very knowledgeable about the incineration process and monitoring system. The monitoring system appears robust and suited to monitor and regulate materials going into the incinerator. Continuous Emission Monitoring System (CEMS) and Bag Leak Detection System (BLDS) data were observed and demonstrated compliance with the permit requirements. The baghouse collection, PAC storage, and incinerator discharge areas were all well kept and orderly. Very little debris was visible on the ground or in the surrounding areas. I requested and reviewed the most recent Startup, Shutdown and Malfunction Plan, Emergency Safety Vent Operating Plan, Operation and Maintenance Plan, and Page 6 of 7 Feedstream Analysis Plan. All plans appeared complete and to demonstrate compliance with the applicable sections of 40 CFR Part 63 Subpart EEE. End of report. Page 7 of 7