Protecting health, the environment through the permitting process
March 30, 2009
By USAE ACWA
The Blue Grass Chemical Agent-Disposal Pilot Plant is being constructed to perform an essential mission: the destruction of aging chemical weapons that have been safely stored at the Blue Grass Army Depot.
In fulfilling that mission, the project must adhere to the requirements of specific permits designed to protect human health and safety, as well as Kentucky air, water and soil. Any facility in Kentucky that plans to treat, store or dispose of hazardous waste must obtain permits from the Kentucky Department for Environmental Protection, and BGCAPP is no exception.
The project is currently operating under two major permits:
Aca,!Ac A Research, Development, and Demonstration permit issued under the Resource Conservation and Recovery Act, and
Aca,!Ac A Title V Air Permit that currently applies to air emissions during construction and will be modified later to cover plant operations.
The permits are held jointly by Bechtel Parsons Blue Grass and Blue Grass Army Depot, requiring close cooperation between the government and contractor staff on the project. The pilot plant team works with KDEP to ensure the project meets all requirements and to keep the permitting process on track.
"Recognizing the unique nature of processing chemical weapons, the Commonwealth of Kentucky chose to regulate the BGCAPP facility under the RD&D permit," explains Kevin Regan, environmental manager for BPBG.
As the regulator, KDEP's role is to enforce the statutes and regulations adopted by the Commonwealth of Kentucky to protect human health and the environment. KDEP staff review the permit applications which include information on treatment processes, procedures to prevent hazards, contingency plans, closure plans and personnel training.
The initial application for the RD&D permit was submitted by the project in March 2004 and, after a public review and comment period, the first revision was approved by KDEP in September 2005. The permit, which is enforced by KDEP, includes a 30-item completion schedule describing activities that must be completed before certain work can be performed. The Air Quality Permit, which covers construction activities such as dust control and emissions from construction equipment, was issued in October 2005.
In addition, KDEP monitors activities at BGCAPP and performs periodic inspections. If problems are found, KDEP can issue a "Notice of Violation" to the project. To date, there have been no such notices.
Public participation is an important part of the permitting process. Permit documents are available for public review (see list of information repositories on this page), and public meetings are held at key steps in the process.