Environmental Activities at BGCAPP

November 2015: RD&D Permit Application, Revision 6, and Class 2 Permit Modification Request for Design Changes

The Blue Grass Army Depot and the Blue Grass Chemical Agent-Destruction Pilot Plant (BGCAPP) submitted a revised RD&D permit application and a Class 2 permit modification request to the Kentucky Department for Environmental Protection, Division of Waste Management, on Nov. 12, 2015.

The requested revision is with respect to the currently issued RD&D permit for the destruction of chemical agents and will transition the permitting documents to a standard, Part B format and modification request methodology, while retaining the RD&D classification. The Class 2 permit modification request includes modifications of the facility which address the destruction of cyanide in the Energetics Neutralization Reactors and the removal of the washout process from BGCAPP.

March 2014: RD&D Permit Application, Revision 5, Volumes I & II

The Blue Grass Army Depot and Bechtel Parsons Blue Grass updated the RD&D permit application to include additional and updated information. There were changes to both Volumes I and II. The majority of the updated information describes how the Blue Grass Chemical Agent-Destruction Pilot Plant (BGCAPP) facility will be operated and includes a revised list of engineering drawings necessary to describe the BGCAPP operations. Volume I of this revision contains the body of the additional and updated information and Volume II contains the RCRA drawings that will be submitted in two separate phases. This drawing submission is to be considered Phase 1.

June 2007: RD&D Permit Application, Revision 4 Volume I

The Blue Grass Army Depot and Bechtel Parsons Blue Grass updated an environmental permit application in June. Revision 3 of the RD&D permit application was submitted to the Kentucky Department for Environmental Protection, Division of Waste Management, in September 2006. After a review of the permit application, the department determined a need for additional information and issued a Notice of Deficiency. As a result of the request for more information, Revision 4, Volume I of the revised permit application was included along with the responses. There were no changes to Volume II of the permit application. The basis of the design for the Blue Grass project continues to be neutralization followed by supercritical water oxidation. Revision 4, Volume I incorporates the following:

• Responses to the Notice of Deficiency comments
• A revision to Part A of the Kentucky Hazardous Waste Permit Application
• Changes in the description of the proposed RD&D process; facility construction and operation; record keeping procedures; closure process; and criteria to be used to determine effects on human health and the environment

September 2006: RD&D Permit Application, Revision 3

The Blue Grass Army Depot and Bechtel Parsons Blue Grass Joint Venture (the Permittees) submitted a revision of the RD&D Permit Application to the Kentucky Department for Environmental Protection, Division of Waste Management on Sept. 27, 2006 in accordance with the requirements of 401 KAR 38:060, Section 6, RD&D Permits. The basis of the design for the BGCAPP continues to be neutralization followed by supercritical water oxidation. This revision incorporates the following design changes:

• Reducing the number of treatment units in the BGCAPP
• Upgrades in the design that have occurred as the design has matured
• Changes in how secondary wastes generated in the facility will be handled

September 2005: BGCAPP Hazardous Waste Management Facility Permit

November 2004: RD&D Permit Application, Revision 2

October 2016:  Clean Air Act (CAA) Title V Permit Renewal

On October 12, 2016, the Kentucky Department for Environmental Protection, Division of Air Quality issued a Title V permit renewal for the BGCAPP facility, which included the addition of the EDT facility at the BGCAPP.

November 2014: Title V Air Quality Permit Modification

In May 2014, the Blue Grass Army Depot, in collaboration with the Blue Grass Chemical Agent-Destruction Pilot Plant’s systems contractor, Bechtel Parsons Blue Grass, submitted a modification for the Title V Air Quality Permit to the Kentucky Department for Environmental Protection (KDEP) Division of Air Quality for an Explosive Destruction Technology (EDT) facility. In August 2014, KDEP completed review of the permit application and judged it to be complete, allowing the project to begin construction on the EDT facility. KDEP officially approved the modification in November 2014.

June 2012: Final BGCAPP Air Quality Title V Permit

April 2010: BGCAPP Title V Air Permit Renewal Application

September 2004: Clean Air Act, Air Permit Application

February 2016: Class I Permit Modification Approvals

The Kentucky Department for Environmental Protection (KDEP) approved Class I permit modifications for the Blue Grass Chemical Agent-Destruction Pilot Plant’s Explosive Destruction Technology permit section. It included the removal of a condition to provide KDEP with a radio receiver in their field office, changes in training requirements, architectural building section drawings, grading and drainage plan revisions and site plan revisions.

October 2016: Addition of Explosive Destruction Technology

An Explosive Destruction Technology (EDT) system will augment the Blue Grass Chemical Agent-Destruction Pilot Plant (BGCAPP) to destroy approximately 15,000 155mm projectiles and two Department of Transportation bottles containing mustard in the Blue Grass stockpile, many of which have been found unsuited for processing through the main plant.

As such, on Oct. 31, 2016, the Kentucky Department for Environmental Protection issued a permit to conduct EDT operations at BGCAPP.

October 2016: Explosive Destruction Technology Organic Air Emissions

On Oct. 31, 2016, the U.S. Environmental Protection Agency issued a Hazardous and Solid Waste Amendments permit for organic air emissions in the Explosive Destruction Technology facility at the Blue Grass Chemical Agent-Destruction Pilot Plant.

November 2015: Class 2 Hazardous Waste Facility Permit Modification Request, Treaty Sampling Operation

An Explosive Destruction Technology (EDT) system will augment the Blue Grass Chemical Agent-Destruction Pilot Plant (BGCAPP) to destroy approximately 15,000 155mm projectiles and two Department of Transportation bottles containing mustard in the Blue Grass stockpile, many of which have been found unsuited for processing through the main plant.

The EDT system that will safely destroy the mustard stockpile is called the Static Detonation Chamber (SDC). Unlike the main plant, the SDC does not access the munitions cavity to allow sampling of chemical agent fill. Sampling, in order to verify agent type, is a requirement under the Chemical Weapons Convention treaty.

As such, the treaty sampling operations process is the subject of this request for Class 2 Modification for the Blue Grass Army Depot’s (BGAD) Resource Conservation and Recovery Act Hazardous Waste Facility Permit. BGAD, in collaboration with BGCAPP, has formally submitted this permit modification request to the Kentucky Department for Environmental Protection.

June 2014: Temporary Authorization Request for Class 3 Modification to the Blue Grass Army Depot’s RCRA Hazardous Waste Permit

On June 23, 2014, the Blue Grass Army Depot and Bechtel Parsons Blue Grass, the permit owner/operator, submitted a Temporary Authorization Request (TAR) to the Kentucky Department for Environmental Protection (KDEP). This submittal complies with the provisions of RCRA and its approval allows the construction of the Explosive Destruction Technology (EDT) system to begin, while the Class 3 RCRA Permit Modification to add the EDT is being reviewed by KDEP. On August 22, KDEP provided the project approval to begin initial construction activities on the EDT system.

March 2014: Class 3 Hazardous Waste Storage & Treatment Permit Modification Request, Addition of Explosive Destruction Technology (EDT)

July 2005: Blue Grass Army Depot Tentative Approval of Hazardous Waste Permit

February 2003: Record of Decision

Chemical Stockpile Disposal Project Destruction of the Chemical Agents and Munitions Stored at Blue Grass Army Depot, Kentucky.

December 2000: Notice of Intent Published In Federal Register

Notice of Intent to prepare an Environmental Impact Statement for the Design, Construction, and Operation and Closure of a Facility for the Destruction of Chemical Agents and Munitions at Blue Grass Army Depot, Kentucky.

Final Environmental Impact Statement for the Disposal of Chemical Munitions at Blue Grass Army Depot (BGAD), Kentucky.

Available for review at our information repositories.