Volume X Issue I Volume X, Issue I June 2014 Demil Dispatch Recent Progress on the Blue Grass Army Depot Demilitarization Effort. Kentucky Department for Environmental Protection Division of Waste Management Hazardous Waste Branch Blue Grass Army Depot Section News On Three Reviews The Hazardous Waste Branch (HWB) has received three permit applications recently from the Blue Grass Army Depot (BGAD) and the Blue Grass Chemical Agent-Destruction Pilot Plant (BGCAPP), located near Richmond, Ky. This means that the Permitting Section is going to be very busy for quite some time! Why is that? When a permit application is submitted, there are many pages included, full of information about how the appli- cant plans to handle the hazardous waste that Inside they will generate and/or dispose. This infor- mation will include personnel training, hazardous • Three major permit waste codes, container types, disposal/recycling actions keeping KDEP methods, security measures, and everything in A fine stack of material for KDEP’s summer reading program. between. The Permitting Section has to ensure busy in 2014 pg. 1 that this information meets the regulations of the Kentucky Department for Environmental Protec- • BGAD provides conventional ammunition ser- BGCAPP Applies for tion (KDEP) and US Environmental Protection vices, chemical defense equipment management TSCA Permit pg. 1 Agency (EPA) before the facility operates. and manufacturing capabilities for the Depart- What applications were submitted? The three ment of Defense. The Blue Grass Chemical Activi- • BGCAPP construction submitted are listed here and will be explained ty (BGCA), a tenant of the 15,000-acre depot, is below: responsible for safekeeping the chemical weap- photos pg. 2 ons stockpile stored at the depot. BGAD and BGAD 10 Year Renewal Application • BGAD 10 Year Renewal Application BGCA have submitted an application to the KDEP, EEC Secretary Visits BGAD Class 3 Permit Modification – Addition of Division of Waste Management (DWM), for renew- BGCAPP pg. 3 the Explosive Destruction Technology unit al of the Resource Conservation and Recovery Act BGCAPP RD&D Revision 5 (RCRA) hazardous waste storage permit. The • Rocket separation for RCRA permit, set to expire in September 2014, BGAD 10 Year Renewal Application (referred to covers conventional munitions operations, dis- propellant sampling as: Renewal) posal and waste storage in (continued on page 4) complete pg. 3 • KDEP visits Anniston TSCA Permit Required to Process SFTs SDC pg. 3 The Toxic Substance Control Act sets limits for PCB contamina- popular for many years in indus- (TSCA) is a United States law, tion of the environment. PCBs try and as a result were widely passed by Congress in 1976, are synthetic organic chemical distributed in many previously which regulates the introduction compounds of chlorine at- manufactured products. of new or already existing chem- tached to biphenyl, which is a icals used nationwide, totaling molecule composed of two ben- The M55 rockets that will be in excess of 84,000 chemicals. zene rings. There are over 200 disposed of at BGCAPP consist Acting under TSCA, the US Envi- different chemical configura- of a fin nozzle assembly, a rock- ronmental Protection Agency tions for this class of chemicals et motor, a chemical agent- (EPA) regulates Polychlorinated which vary by the number of filled warhead and fuse. Each Biphenyl (PCB) disposal and chlorine atoms. PCBs were individual rocket is stored in a (Continued on page 4) Volume X Issue I Page 2 BGCAPP Construction Photos Chemical agent destruction will be verified in the laboratory building The energetic neutralization reactors (ENR) treat the energetic hydrolysate from the energetic batch hydrolyzer (EBH) Consoles in the control and support building allow operators the ability to Massive runs of piping in the utility building (UB) distribute various process remotely control and monitor the chemical demilitarization equipment chemicals, water, and steam throughout the BGCAPP The munitions washout system (MWS) will rinse agent out of the agent cavity The Super Critical Water Oxidation (SCWO) tank farm pads are set, coated of nerve agent projectiles and tanks are currently being erected in this area Volume X Issue I Page 3 Secretary Peters Walks the BGCAPP Site Kentucky Energy and Environmental Cabinet Sec- temization accomplishments, discussion of the retary, Len Peters visited the Blue Grass Chemical proposed Explosive Destruction Technology (EDT), Agent-Destruction Pilot Plant (BGCAPP) on Jan. a viewing of the BGCAPP process video, as well as 16, 2014 to personally see the progress that has a walk-through of the construction site. occurred at the site. At the time construction was Secretary Peters’ attention to the site was a wel- over 75 percent complete with the early stages of come development in a time when Kentucky De- systemization occurring making it an ideal oppor- partment for Environmental Protection staff from tunity to actually see several years of planning both the field office and permitting section have taking shape into what will be the safe destruc- enjoyed increased engagement through meetings tion of the Blue Grass Army Depot’s chemical and site visits as the facility rapidly approaches weapons stockpile. operation. Energy and Environment Cabinet Secretary Highlights of the visit included a review of the Len Peters current project schedule, construction and sys- Nerve Agent Rocket Separation Complete Workers at Blue Grass Chemical Activity (BGCA) Twenty-three of the motor segments were have successfully and safely removed the motors shipped to U.S. Army Research, Development and from 42 nerve agent rockets as of March 26. The Engineering Center at Picatinny Arsenal, NJ for warhead segments of the rockets were over- compositional analysis and testing while the re- packed into a single round container and placed maining 19 were placed in storage at the depot back into storage in the earthen igloos that store for future testing to support the chemical demili- the stockpile present at the Blue Grass Army De- tarization effort at the Blue Grass Chemical-Agent pot (BGAD). Pilot Plant (BGCAPP) currently under construction. M55 rocket (right) and shipping KDEP Views Anniston SDC and firing tube (left). Kentucky Department for Environmental Protec- unit with operators in Alabama, get a close-up tion (KDEP) employees received an opportunity in view of the equipment as it processed conven- May to return to Anniston, Alabama and see the tional munitions, and meet with representatives Static Detonation Chamber (SDC) responsible for of the Alabama Department of Environmental destroying the problematic mustard munitions Management (ADEM) to discuss lessons learned that were present at Anniston Army Depot (ANAD). during their time on the Anniston Chemical Agent The unit is the same basic design as the one pro- Disposal Facility (ANCDF) mission. posed for construction at the Blue Grass Army Following the trip to Anniston the BGAD Section Depot. Kentucky is currently in the process of Permitting team travelled to Atlanta to meet and reviewing the modification to the Part B Blue Grass Army Depot (BGAD) concerning the inclu- have a follow-up discussion on the progress of sion of the SDC into the permit as a Subpart X the TSCA permit with Environmental Protection Munitions scrap metals similar to this miscellaneous unit. Agency (EPA) Region 4 as well as delve into the archives there for documents to supplement resulting from SDC treatment, will be Kentucky used the opportunity to discuss the SDC released for recycling at an appropriate those in the state’s database. facility. Volume X Issue I Page 4 News On Three Reviews (Continued) two munitions bunkers (igloos), of this request for Class 3 Modi- application. Most of the updat- as well as chemical munitions fication to the BGAD RCRA Haz- ed information describes how waste stored in 47 igloos. This ardous Waste Permit. BGAD, in the BGCAPP facility will be oper- renewal permit would allow collaboration with BGCAPP sys- ated and includes a revised list of engineering drawings neces- them to continue these RCRA tems contractor Bechtel Par- sary to describe the BGCAPP activities and give them the sons Blue Grass as the permit operations. Once the RD&D required conditions that they operator, has formally submit- permit is completed and the GB have to follow along the way. ted this permit modification munitions are disposed of, the request to KDEP. BGCAPP facility will then have BGAD Class 3 Permit Modifica- BGAD Class 3 Permit Modifica- to apply for a Part B RCRA Per- tion ––– Addition of the Explosive BGCAPP RD&D Revision 5 mit in order to use the facility to Destruction Technology unit (referred to as: Rev 5) dispose of the VX munitions (referred to as: EDT) The previously approved re- that are currently stored at the BGCA tenant igloos at BGAD. BGCAPP has selected an explo- search, development, and If you have any further ques- Example of a hazardous waste label re- sive destruction technology demonstration (RD&D) permit tions on the activities at the quired by RCRA (EDT) system to safely destroy application for the BGCAPP facility allows for the time to BGAD or the BGCAPP facility, the mustard stockpile deemed design and build a waste dis- please visit these websites or unsuitable for processing posal plant according to regula- contact the public affairs indi- through the main pilot plant. tions for the destruction of the vidual listed. Because solidification of the GB munitions that are currently mustard agent was found in a stored at the BGCA tenant ig- BGCAPP: http:// The Permitting Section significant number of mustard loos at BGAD. This revision www.peoacwa.army.mil/ has to ensure that this (Rev 5) to the RD&D permit bgcapp/ projectiles, rendering them information meets the unsuitable for the automated application provides additional, Stephanie Parrett: 859-624- regulations of the neutralization process, the EDT updated information that has 6326 become available since approv- system will be employed to de- Kentucky Department for al of the previous version of this stroy the entire Blue Grass mus- BGAD: http:// Environmental Protection application.