Who Is CCI/Speer, And What Were They Doing On The Banks Of The Snake River?

Federal Cartridge Company is a Minnesota corporation that operates under the trade name CCI/Speer in Lewiston, Idaho. Their facility sits at 1023 Snake River Avenue, which is not subtle branding for a company that was actively contaminating the waterway it is named after.

• The Lewiston plant manufactures small arms ammunition, classified under Standard Industrial Classification code 3482 (metal fabrication, small arms ammunition). The primary production process involves working with metals, which is directly why zinc contamination is the central pollutant in this case.
• The facility discharges industrial stormwater through a drainage outfall into the City of Lewiston’s stormwater conveyance system. That system flows into the Clearwater River, which flows into the Snake River, a traditionally navigable waterway and critical regional water resource.
• Under the Clean Water Act (CWA), Section 301(a), it is illegal to discharge pollutants from a point source into U.S. waters without an authorized permit. CCI/Speer held coverage under EPA’s Multi-Sector General Permit (MSGP), which is a stormwater permit specifically for industrial facilities. The problem is not that they lacked a permit; it is that they repeatedly violated the permit’s conditions.
• The two permits in question are the 2015 MSGP (which remained in force through February 28, 2021) and the 2021 MSGP (which became effective March 1, 2021). Violations were documented under both permits, spanning a continuous window from September 2020 to at least September 2023.

What No Fine Can Put Back In That River

The Snake River runs through the heart of the Pacific Northwest. It is the largest tributary of the Columbia River system. Communities along its banks have depended on it for drinking water, fishing, and their sense of place for generations. The Nez Perce Tribe has lived alongside this river for thousands of years. It is not a drainage ditch. It is not a cost of doing business.

When it rains on an ammunition plant, water picks up what is lying around, what is tracked across parking lots, what leaches from uncovered materials. At the CCI/Speer facility, EPA inspectors documented trash and debris across the site. They documented sediment being tracked from a material staging area onto the parking lot. They found metal containers, shelving, racks, and bins sitting uncovered in a storage area where stormwater drainage could flow directly offsite. The rain did not know the difference between a factory floor and a river.

Zinc is a heavy metal. At low concentrations it occurs naturally and causes no harm. At elevated concentrations, the kind that trips the legal benchmark limits that CCI/Speer was repeatedly violating, it is acutely toxic to aquatic life. Fish, particularly salmonids like the Chinook salmon and steelhead trout that the Snake River is known for, are highly sensitive to zinc. It damages their gills. It disrupts their ability to regulate their own body chemistry. It kills them before they can spawn. The Snake River already faces enormous pressure from dams, habitat loss, and warming water temperatures. Every load of zinc-laden stormwater that flowed off that parking lot and into the Clearwater and Snake was one more insult to a system that is already struggling.

Then there is the unmarked drum. EPA inspectors found it near the test firing range. Its contents were unknown. Unknown in the document. Unknown to regulators. Potentially unknown to anyone who had not put it there. That drum sitting beside a firing range, uncovered, unmarked, in a facility that failed to report an entire drainage outfall to regulators, is not a minor paperwork problem. It is a window into how this company treated its legal obligations to protect the public and the environment: as a box to check when convenient, and ignored when not.

For three years, from September 2020 to at least September 2023, this facility discharged zinc into a river system and did not fix the problem. The permit required corrective action within 45 days of a benchmark exceedance. The company had three years. People who fish the Snake River, people whose children swim in it, people whose water supply depends on it, did not get a 45-day notice. They did not get any notice at all. The company neither admits nor denies any of this happened. $76,213 is the price of that arrangement.

For three years, the company was legally required to fix its zinc pollution within 45 days of each exceedance. The river kept receiving the discharge. The public received no notice. $76,213 settled the account.

Straight From The Document: What EPA Actually Found And What The Company Actually Agreed To

The following are direct, verbatim quotes from EPA Docket No. CWA-10-2025-0143. No paraphrasing. No editorializing. The document speaks for itself.

“Between the third quarter of 2021 and third quarter of 2023, the Facility’s benchmark exceedances, also known as ‘AIM triggering events,’ required Respondent to immediately review the Stormwater Pollution Prevention Plan (SWPPP) and onsite control measures. As additional AIM triggering events occurred, more substantial Best Management Practices (BMPs) needed to be installed to minimize the discharge of zinc in the Facility’s stormwater. Respondent implemented some measures but failed to implement sufficient AIM measures in violation of the 2021 MSGP.”

“EPA’s Inspectors observed an outfall located at the southwestern corner of the Facility, which is not identified in the SWPPP or in the SWPPP site map. Respondent failed to identify all discharge points in violation of the 2021 MSGP.”

“EPA’s Inspectors also observed an unmarked metal drum containing an unknown substance at the Facility near the test firing range.”

“Respondent failed to sample PAHs during the third and fourth quarter of 2021 and the first and second quarter of 2022 in violation of the 2021 MSGP.”

“Respondent neither admits nor denies the specific factual allegations contained in this Consent Agreement.”

“Respondent failed to identify all discharge points in violation of the 2021 MSGP.” — EPA Region 10, Docket CWA-10-2025-0143

Who Pays The Price When An Ammo Giant Ignores Its Pollution Controls

Environmental Degradation

The documented discharge path runs from the CCI/Speer facility directly into one of the most ecologically significant river systems in the American West.

• Zinc contaminated stormwater flowed from the facility outfall into the City of Lewiston’s stormwater conveyance system, then into the Clearwater River, and then into the Snake River, a traditionally navigable water under the Clean Water Act. Elevated zinc concentrations are acutely toxic to salmonids, including Chinook salmon and steelhead trout, both of which are present in the Snake River system and are the subject of ongoing federal recovery efforts.
• A discharge outfall at the southwestern corner of the facility was never reported in the company’s Stormwater Pollution Prevention Plan. That outfall was never monitored and never sampled. Its discharge history and the pollutant loads it may have contributed to the waterway during the entire period of the facility’s MSGP coverage are unknown because the company chose not to identify it.
• For four consecutive quarters spanning mid-2021 through mid-2022, the company did not sample for sixteen priority polyaromatic hydrocarbons. PAHs include compounds classified as probable human carcinogens that accumulate in aquatic sediment and organisms. The absence of sampling means no record exists of what PAH concentrations the Clearwater and Snake River systems received from this facility during that window.
• EPA inspectors observed uncovered metal containers, shelving, racks, and bins in a storage area with drainage pathways leading offsite. An unmarked drum of unknown substance was found near the test firing range, an area where lead and other metallic residues from ammunition testing would be expected to accumulate.
• Trash, debris, and tracked sediment were observed across the facility site. Under the 2021 MSGP, facilities are required to minimize the generation of dust and off-site tracking of materials precisely because these pathways carry industrial pollutants directly into stormwater channels.

Public Health

The Snake and Clearwater Rivers are not abstract ecosystems. Communities and tribal nations depend on them for food, water, and cultural continuity.

• The Nez Perce Tribe has treaty rights to fish in the Snake and Clearwater Rivers. Those rights were affirmed by federal treaty in 1855 and have been upheld repeatedly in federal court. Any degradation of the fish population in those rivers, including zinc toxicity impacts on salmon and steelhead, is an injury to those treaty rights and to the food security of tribal members who rely on the fishery.
• The facility failed to sample for all required pollutants in Q1 2022, including zinc, nitrate/nitrite, and total recoverable aluminum. Nitrate and nitrite are relevant not only to aquatic health but to drinking water safety; elevated nitrate levels in water supplies are associated with methemoglobinemia (blue baby syndrome) in infants. The absence of sampling means that the downstream public had no access to data about what was in the water during that quarter.
• The company did not sample for PAHs during four consecutive quarters. Many PAHs are classified by the EPA as priority pollutants due to their carcinogenic potential. People who eat fish from the Snake and Clearwater River systems during this period had no regulatory data informing them of potential PAH exposure through the food they were catching.
• The unmarked drum near the test firing range represents an unquantified and undocumented chemical hazard. The permit system requires facilities to maintain documentation of substances on site specifically so that emergency responders, regulators, and the public can assess risk. An unmarked container of unknown substance eliminates that safety layer entirely.

Economic Inequality

The cost structure of this settlement illustrates who environmental law protects and who it burdens.

• The maximum Class II civil penalty under the Clean Water Act, adjusted for 2025 inflation, is $342,218. EPA assessed $76,213, which is 22.3% of the maximum. The document states that EPA considered “economic benefit or savings resulting from the violation,” meaning the company’s cost savings from not implementing sufficient pollution controls were factored into the penalty calculation. The company profited from non-compliance; the fine is a fraction of what the law permits.
• The “neither admits nor denies” settlement structure means that low-income communities downstream, tribal members with treaty fishing rights, and recreational users of the Snake River cannot use this EPA action as a foundation for civil claims. The regulatory resolution is designed to close the legal record, not open a path to community remediation.
• The facility is located at 1023 Snake River Avenue in Lewiston, Idaho, a working-class city of approximately 34,000 people. The environmental burden of a major industrial facility’s pollution violations falls disproportionately on residents who cannot move away, cannot afford water filtration systems, and cannot hire lawyers to pursue separate legal remedies.
• Federal Cartridge Company is a Minnesota corporation operating through its CCI/Speer subsidiary. Corporate structure insulates the parent entity from direct regulatory liability while the environmental consequences are absorbed locally in Lewiston and in the river systems downstream. The company pays a fine; the river absorbs the discharge.

The Arithmetic of Accountability: What $76,213 Means In The Real World

What You Can Do About It: Watchlist, Contacts, And Next Steps

CCI/Speer agreed to enter into an Administrative Order on Consent (AOC) alongside this fine, which requires specific compliance actions at the Lewiston facility. The fine is settled. The AOC’s implementation is the next accountability lever.

Who Signed This Agreement

• Jeff Ehrich, Vice President and Secretary, Federal Cartridge Company, signed on behalf of the Respondent.
• Edward J. Kowalski, Director, Enforcement and Compliance Assurance Division, EPA Region 10, signed on behalf of EPA. His digital signature is dated September 22, 2025.
• The document was filed with the Regional Hearing Clerk on September 24, 2025, at 9:13 A.M. PST.

Regulatory Watchlist

• EPA Region 10: The enforcing authority for this case. Compliance Officer Wesley Simmons (Simmons.Wesley@epa.gov) is the named EPA contact for monitoring payment and compliance under this agreement. Region 10 covers Idaho, Washington, Oregon, and Alaska.
• Idaho Department of Environmental Quality (IDEQ): As of July 1, 2021, Idaho assumed permitting and compliance authority for the NPDES stormwater program from EPA. IDEQ is now the primary day-to-day regulator for CCI/Speer’s stormwater permit. Pressure on IDEQ to conduct follow-up inspections is the most direct lever available.
• U.S. Army Corps of Engineers / NOAA Fisheries: Both agencies have jurisdiction over the Snake River system and its salmon recovery programs. CWA violations affecting salmonid habitat in a federally designated recovery area can trigger additional Endangered Species Act review obligations.
• EPA Office of Inspector General (OIG): If you believe EPA Region 10 accepted a fine substantially below the legal maximum without adequate public justification, the OIG investigates EPA enforcement decisions. The penalty here was 22% of the legal maximum.

Mutual Aid, Local Organizing, And Grassroots Resistance

• Request the Administrative Order on Consent (AOC): The EPA document references a concurrent AOC requiring compliance actions at the facility. That document is separate from the Consent Agreement published here. File a Freedom of Information Act (FOIA) request with EPA Region 10 (R10_RHC@epa.gov) for the full text of the AOC. The public has a right to know what CCI/Speer is being required to do and on what timeline.
• Contact the Nez Perce Tribe’s Department of Natural Resources: The Tribe has treaty-protected fishing rights in the Snake and Clearwater Rivers and has its own environmental monitoring and legal capacity. Connecting with their water quality and fisheries advocacy strengthens accountability beyond what EPA’s administrative process provides.
• Attend IDEQ public comment periods: When CCI/Speer’s stormwater permit comes up for renewal or modification in Idaho, IDEQ is required to hold a public comment period. Show up. Submit written comments. Your documented concerns become part of the permit record and can inform enforcement decisions.
• Support local fishing and river advocacy organizations: Groups like the Snake River Waterkeeper monitor discharge events and water quality independently of regulatory agencies. Independent monitoring data is often what forces enforcement when agencies are slow to act.
• Know your rights under the Clean Water Act citizen suit provision: CWA Section 505 allows private citizens to bring enforcement actions against violators for ongoing violations. The Consent Agreement resolves the specific violations documented here, but it does not immunize the company against future violations. If sampling exceedances or permit violations recur, citizen suits are a legal option.