U.S. Environmental Protection Agency
Hazardous and Solid Waste Amendments Permit Modification
Blue Grass Chemical Agent-Destruction Pilot Plant (BGCAPP)
Richmond, Kentucky (EPA ID. KY8-213-820-105)
*»ERH
Fact Sheet
General Information
The U.S. Environmental Protection Agency has reviewed a permit
modification request submitted by the U.S. Department of the Army
and Bechtel Parsons Blue Grass (BPBG), where they are seeking a
modification to their existing Hazardous and Solid Waste
Amendments (HSWA) Permit for the BGCAPP Main Plant. The Main
Plant proposes to treat nerve agents GB and VX via chemical
neutralization, followed by Supercritical Water Oxidation (SCWO).
The proposed chemical weapons destruction is anticipated to
start in the late-2019 or early-2020 timeframe.
The EPA HSWA Permit was originally issued for the BGCAPP
Explosive Destruction Technology (EDT) facility on October 31,
2016 and imposed certain permit conditions for organic air
emissions. The proposed draft HSWA Permit modification
includes additional organic air emissions standards associated
with the proposed treatment of GB and VX nerve agents at the
Main Plant.
August 2018
We want to hear from you!
The 45-day public comment period
for the proposed draft Permit:
August 15 to October 1, 2018.
BGCAPP Background:
BGCAPP will be used to destroy munitions that contain GB and VX
nerve agents. The Kentucky Department for Environmental
Protection (KDEP) has issued a Research, Development and
Demonstration (RD&D) Permit for hazardous waste operations,
and the proposed modified EPA HSWA Permit will be a companion
permit to the RD&D Permit. The Commonwealth of Kentucky does
not yet have federal authorization to implement the
organic air emission requirements of the Resource
Conservation and Recovery Act set forth at Title 40 of the
Code of Federal Regulations, for Subparts AA, BB and CC.
Until final authorization has been granted to KDEP by the
EPA, the responsibility for issuing such permits to regulated
entities lies with the EPA.
Figure 1: BGCAPP Control Device - MDB Filter System
Regulatory Applicability
Public Notice of Draft HSWA Permit
The EPA is committed to fostering meaningful public
involvement in environmental decision making. Interactive
communications enable the public and other stakeholders
to provide input. The proposed draft modified HSWA
Permit is available for a 45-day public comment period
from August 15, 2018 to October 1, 2018. The public may
provide written comments during the 45-day comment period. A public hearing will be scheduled if a request is made
in writing before October 1, 2018. Please submit your comments by letter or email, postmarked by the deadline, to
KDEP has authority to issue RCRA permits in the
Commonwealth of Kentucky, except for certain HSWA
requirements, including the RCRA organic air emission
standards included in 40 CFR §264.1030 through §264.1090.
Because KDEP has not been authorized to implement these
standards, the EPA must issue a companion HSWA Permit in
conjunction with the KDEP permit. The KDEP and the EPA
permits will constitute the full RCRA Permit for BGCAPP's
operations.
The EPA HSWA Permit only includes applicability of the RCRA
organic air emission standards included in 40 CFR §264.1030
through §264.1090, as well as land disposal restrictions.

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Regulatory Background:
Organic air emissions are regulated under 40 CFR Subpart
AA, Subpart BB, and Subpart CC of the RCRA hazardous
waste regulations. The following equipment is regulated at
the BGCAPP:
Subpart AA (Process Vents): None
Subpart BB Equipment containing or contacting
hazardous wastes with organic concentrations of at
least 10 percent by weight (>10 wt% Total Organics)):
Pressure Relief Devices, Sampling Connections, Valves,
Pumps, Flanges & Other Connectors
Subpart CC (Containers, Tanks and Other Units
Containing Hazardous Wastes with an Average Volatile
Organic Concentration greater than 500 parts per
million by weight (>500 ppmw)): Containers, Tanks &
Subpart X Regulated Miscellaneous Units
BGCAPP complies with Subpart BB by monitoring identified
equipment for leaks during operations, when safely to do
so, and after repairs. Compliance with Subpart CC is
demonstrated by using Department of Transportation
compliant containers; equipping tanks with Level 2 Controls
(closed-vents carrying volatile organics to control devices);
and equipping miscellaneous units with various control
devices.
EPA Outreach and
Community Engagement
Keriema Newman
404-562-8859; 404-304-2490
newman.keriema@epa.gov
Brian Holtzclaw
404-821-0697
holtzclaw.brian@epa.gov
Figure 2 Storage Tanks for the Main Plant Wastes
FOR MORE INFORMATION
Public Notice Website-
www.epa.gov/aboutepa/about-epa-region-4-southeast
Information Repository for All BGCAPP
Documents
Blue Grass Chemical
Stockpile Outreach Office
1000 Commercial Drive, Suite 2
Richmond, KY 40475
(859) 626-8944
or e-mail bgoutreach@iem.com
Tips on Effective Public Comments -
www.epa.gov/sites/production/files/2017-
01/documents/final rcra
m.pdf
Terri Crosby-Vega at the address below. The EPA wiil not finalize its decision until after review of and response to ail
received written comments. A copy of the draft modified HSWA Permit is available at the EPA's public notice website
at www.epa.gov/aboutepa/about-epa-region-4-southeast. The draft modified HSWA Permit and supporting
documents are available in hard copy format at the: Madison County Public Library, Richmond Branch, 507 West Main
Street, Richmond, KY 40475; Madison County Public Library, Berea Branch, 319 E. Chestnut Street, Berea, KY 40403;
John G. Crabbe Library, Eastern Kentucky University, 521 Lancaster Avenue, Richmond, KY 40475; Blue Grass Chemical
Stockpile Outreach Office, 1000 Commercial Drive, Suite 2,
Richmond, KY 40475; Berea College Hutchins Library, 100
Campus Drive, Berea, KY 40404; and Estill County Public
Library, 246 Main Street, Irvine, KY 40336.
EPA Technical Project Manager
Terri Crosby-Vega
U.S. EPA Region 4, 10th floor, RCRD
61 Forsyth St, SW
Atlanta, GA 30303
404-562-8497

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