Hazardous Waste Program

The Boeing Co. - Tract 1

EPA ID# MOD000818963

DNR Contact:      Christine Kump-Mitchell, PE, 314-416-2464 or 800-361-4827
EPA Contact:      Andrea Stone, 913-551-7662 or 800-223-0425
Facility Contact:  Joseph W. Haake, 314-777-9181
Last Updated:      Oct. 21, 2011

Current Activities

Permit Application for Renewal Complete: On Feb. 28, 2007, The Boeing Co. submitted a permit application for the Tract 1 site to the department and U.S. Environmental Protection Agency Region 7, to renew their existing Missouri Hazardous Waste Management Facility Part I Permit and Hazardous and Solid Waste Amendments Part II Permit. The department invites the public to review and offer written comments on the permit renewal application while the department conducts a technical review of the permit application.

The public can review and copy the permit application and supporting documents at the St. Louis County Library's Prairie Commons Branch, 915 Utz Lane, Hazelwood (during normal business hours) or the agency locations above. Comments on the permit application are more effective if they point out legal or technical issues. You may submit written comments online or send comments by mail to Chris Kump-Mitchell, PE, Missouri Department of Natural Resources, 7545 S. Lindbergh Blvd., Suite 210, St. Louis, MO 63125-4839.

Facility Description

The Boeing Co. – Tract 1 site is located on about 210 acres at McDonnell Douglas Blvd. and Lindbergh Blvd., next to Lambert St. Louis International Airport, in Hazelwood. In 1941, the McDonnell Douglas Corp. began operating an aerospace manufacturing facility at the site, known as Tract 1, which is divided into two sections. Tract 1 North is north of Banshee Road and Tract I South is south of Banshee Road.

McDonnell Douglas Corp. manufactured transport aircraft, aircraft components, space systems/missiles and combat aircraft, such as the F-15 Eagle, F/A-18 Hornet and the AV-8B Harrier. Manufacturing aircraft included fabricating aluminum, titanium, composite structures and other airframe material. The manufacturing activities included chemical processing, metal cutting, metal forming and grinding, degreasing, painting, aircraft assembly, aircraft fueling and aircraft flight testing. These activities produced approximately 48 different hazardous waste streams including emulsified cutting oils, waste jet fuels, paint solids, solvents and paint wastes, wastewater treatment sludges and acidic and caustic wastes. McDonnell Douglas stored the hazardous waste in various storage facilities around the site. McDonnell Douglas also operated two certified resource recovery solvent distillation units, one to recover spent methyl ethyl ketone and methyl isobutyl ketone and the other recovered spent perchloroethylene.

McDonnell Douglas merged with The Boeing Co. in August 1997. Boeing stopped operating as a hazardous waste management facility. In 2001, Boeing sold 87.88 acres of Tract 1 North to GKN Aerospace. GKN Aerospace uses the site for developing and manufacturing aircraft structures, components and assemblies. In 2005, Boeing sold most of Tract 1 South, 75.99 acres, to Lambert St. Louis International Airport. The airport demolished the buildings and structures on a large portion of the land and currently use it as part of the runway protection zone. The airport rents the remaining buildings. Boeing kept 40.43 acres in Tract 1 North and 5.11 acres in Tract 1 South.

Corrective Action Status

McDonnell Douglas closed the original reactive cyanide and sulfide-bearing waste storage area in 1989. The department accepted the clean closure certification for this unit in November 1993. According to applicable state and federal hazardous waste laws and regulations, all hazardous waste treatment, storage and disposal facilities are also 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. Tract 1 was subdivided into nine areas for the purpose of investigation and cleanup: Areas 1-5 and 9 are located in Tract 1 South and areas 6-8 are located in Tract 1 North. From 1995 to the present, the Resource Conservation Recovery Act, or RCRA, Facility Assessment, RCRA Facility Investigation and later investigations identified the following potential sources of contaminant release: 68 underground storage tanks, 3 fuel distillation sites, a power plant, a wastewater treatment facility, 32 solid waste management units and multiple drum storage areas. Soil and groundwater in Tract 1 are contaminated with volatile organic compounds, polynuclear aromatic hydrocarbons, polychlorinated byphenols, metals and total petroleum hydrocarbons. The RCRA Facility Investigation concluded that the soil and groundwater contamination was adequately identified and defined. The contamination is confined to the permitted facility and the contamination in Tract 1 North does not cross to Tract 1 South or vice versa.

The nine areas in Tract 1 were subdivided into sub-areas to better assess any risk to human health or the environment caused by the contaminants released to the environment. Risk Assessments are used to determine which areas exceed risk levels and require additional investigation and interim measures to reduce or prevent unacceptable risks to human health and the environment. An interim measure is an action taken to temporarily control the contamination source or path the contamination could take from the source to humans, animals, or the environment, such as air, soil, water, and food. Two Risk Assessments were performed in Tract 1. The 2004 Risk Assessment identified nine sub-areas that exceeded risk levels.  As an interim measure, contaminated soil was removed from five of the sub-areas in May and June 2006. The 2008 Risk Assessment identified two additional sub-areas that exceeded risk levels. Currently 44 groundwater monitoring wells are sampled twice a year. The groundwater monitoring results will be used to develop a long-term groundwater monitoring plan, which will become part of the corrective measures.

The department requested Boeing to conduct a Corrective Measures Study to identify and evaluate possible remedial alternatives for the contamination. Boeing submitted a Corrective Measures Study Work Plan to the department in November 2009. The work plan outlines the procedures that will be used during the Corrective Measures Study. When the study is complete, the department and EPA will review the possible remedial measures and select the best remedy given site-specific considerations. The public will be invited to review and comment on the proposed final remedy before the department and EPA make a final decision.

Regulatory Status

McDonnell Douglas Corp., and later Boeing, operated the various storage facilities under two hazardous waste permits, one issued by the department and one issued by EPA, both effective March 5, 1997. The department issued the Missouri Hazardous Waste Management Facility Part I Permit. EPA issued the Hazardous and Solid Waste Amendments Part II Permit. These permits allowed the companies to store hazardous waste and required additional investigation, monitoring and cleanup of any hazardous waste and hazardous constituents released to the environment.

Boeing submitted a permit application on Feb. 28, 2007, for renewal of their existing hazardous waste permits. Since Boeing closed all permitted hazardous waste storage units and no longer operates as a hazardous waste storage facility, this permit application is for corrective action only for the entire Tract 1 site, including the areas now owned by GKN Aerospace and Lambert St. Louis International Airport. The facility’s existing hazardous waste permits expired March 5, 2007. State and federal regulations, 40 CFR 270.51, allow the existing hazardous waste permits to continue in effect until the department and EPA issue or deny new hazardous waste permits. The department determined the permit application was complete on May 5, 2010. The department is conducting a technical review of the permit application.