U.S. Environmental Protection Agency

TSCA PCB Approval

Blue Grass Army Depot

Blue Grass Chemical Agent-Destruction Pilot Plant
431 Battlefield Memorial Parkway, Richmond, Kentucky

Fact Sheet for Public Notice	July 2017

Introduction

This Fact Sheet is being issued by the Environmental Protection Agency (EPA) to notify the public of environmental
activities that are being proposed for the Blue Grass Chemical Agent-Destruction Pilot Plant (BGCAPP) located at the
Blue Grass Army Depot (BGAD). The activities include the storage and processing of chemical weapons. This fact sheet
provides an opportunity to learn more about the Toxic Substances Control Act (TSCA) Approval process, as well as the
upcoming public comment period and meeting. The main subject of this notification is a proposed draft polychlorinated
biphenyl (PCB) Demonstration Approval (PCB Approval) document.

Upcoming Public Comment Period and Meeting

The draft TSCA PCB Approval document is open for a 45-day public comment from July 1, 2017 to August 16, 2017. The

public may provide written comments during the 45 day Comment Period. Please submit your comments by letter or
email, postmarked by the deadline to Terri Crosby-Vega. EPA will not finalize its decision until after review of and
response to all received written comments. A copy of the draft PCB Approval is available at EPA's public notice website
at www.epa.gov/aboutepa/about-epa-region-4-southeast. The draft PCB Approval and application are available in hard
copy format at these six (6) locations: Madison County Public Library, Richmond Branch, 507 West Main Street,
Richmond, KY 40475; Madison County Public Library, Berea Branch, 319 E. Chestnut, Berea, KY 40403; John G. Crabbe
Library, Eastern Kentucky University, 521
Lancaster Avenue, Richmond, KY 40475;

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.

Comments are being accepted on the draft
TSCA PCB Approval, not the supporting
documents.

In order to give area residents an opportunity to
meet and discuss the draft TSCA PCB Approval,
the EPA will hold a Public Availability meeting
on July 20, 2017 at 6 pm at the BGCAPP
Outreach Office (address on page 2). The
meeting will start with a brief presentation to
provide an overview of the TSCA requirements.

Following the presentation, an informal session
will be held to provide opportunities to discuss
and ask questions.

&EPA

What is TSCA?

TSCA stands for the Toxic Substances Control Act regulations. The
Toxic Substances Control Act of 1976 provides EPA with authority to
require reporting, record-keeping and testing requirements, and
restrictions relating to chemical substances and/or mixtures, which
include PCBs. BGAD currently stores 523 tons of chemical agents,
including GB, VX, and mustard agent. Treatment of the GB and VX
chemical rockets must be performed under the authority of a TSCA
PCB Approval due to the presence of PCBs contained in the M55
rocket SFTs surrounding the motor and agent-containing inner
warhead section. Information regarding chemical weapons treatment
at BGCAPP can be found at the following address:

www.peoacwa.armv.mil/bqcapp/

The BGCAPP facility will destroy nerve agents (GB and VX) in the
main plant facility under a federal Resource Conservation and
Recovery Act (RCRA) permit issued by the Kentucky Department of
Environmental Protection (KDEP). PCBs will incidentally be treated
during processing of the leaking rocket campaign, which is why the
facility is seeking a PCB Approval from the EPA.


-------
Background

The United States Department of the Army (USDOA) and Bechtel Parsons Blue Grass
(BPBG) are currently building a facility to destroy chemical weapons in a neutralization
facility in Richmond, Kentucky. This facility will destroy rockets containing the chemical
agents GB and VX. PCBs are contained in the outer casing of the Shipping & Firing Tubes
(SFTs) which house the GB and VX rockets. Over the duration of storing these munitions,
some have developed leaks and have been placed in outer protection overpacks and were
termed "leakers". These "leaker" munitions will be processed at the end of each agent
campaign inside of their SFTs. Because the SFTs contain PCBs and will be processed
through an overall treatment system, including the metal parts oven, a TSCA PCB Approval
must be issued. The SFTs from the non-leaking rockets will be robotically separated from
the rocket motor and the warhead. The separated SFTs will be sent to a TSCA approved
facility off-site.

i

Left: Cut-out
of Rocket to
be Treated
at BGCAPP

Under the TSCA regulations, USDOA (owner) and BPBG (operator) must obtain an EPA PCB Approval to store
and process PCBs at its facility. The KDEP has authority to issue RCRA permits in the Commonwealth of
Kentucky, but not to issue TSCA PCB Approvals. Because KDEP does not have authority delegated for the TSCA
Program, the EPA must issue the PCB Approval.

As requested by EPA, USDOA/BPBG submitted an application to the
EPA. The EPA has reviewed the USDOA and BPBG application for the
BGCAPP. EPA has determined that the storage and processing of PCB
bulk product waste in accordance with the PCB Approval Conditions
established, all other Commonwealth and local permits associated
with operations, and all engineering controls will not pose an
unreasonable risk of injury to human health or the environment. On
behalf of community involvement, EPA is coordinating a public
Above: Picture of the Shipping and Firing comment period and meeting (refer to page 1).

Tube on a rocket

Contacts:

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

crosby-vega.terri@epa.gov

EPA Outreach/Community
Engagement

Keriema Newman
404-562-8859; 404-304-2490
newman.keriema@epa.gov

Brian Holtzclaw

404-821-0697

holtzclaw.brian@epa.gov


-------