Class 3 Hazardous Waste Permit Modification Request ...

24915-00-GPE-GGPT-00324

Resource Conservation and Recovery Act (RCRA)

Class 3 Hazardous Waste Permit Modification Request, Addition of a

Container Storage Facility for the Blue Grass Chemical Agent-Destruction Pilot Plant

Blue Grass Army Depot, Richmond, Kentucky

EPA ID KY8-213-820-105

Submitted to:

Energy and Environment Cabinet Kentucky Department for Environmental Protection

Division of Waste Management 300 Sower Boulevard

Frankfort, Kentucky 40601

Submitted by:

Blue Grass Army Depot 431 Battlefield Memorial Highway, Richmond, Kentucky 40475-5901

and

Bechtel Parsons Blue Grass 830 Eastern Bypass, Suite 106, Richmond, Kentucky 40475

(CDRL A010) Submitted 03 MAY 2018, Revision/Submission 0

Final Page Is L-37

This document has been reviewed for OPSEC and no OPSEC sensitive information was found.This document has been reviewed for ITAR/EAR and no ITAR/EAR sensitive information was found.

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24915-00-GPE-GGPT-00324 − Class 3 Hazardous Waste Permit Modification Request, Addition of a Container Storage Facility (CDRL A010)

Rev. 0, Page 1 Date: 03 MAY 2018

Table of Contents 1

Acronyms/Abbreviations ............................................................................................................... 4 2

Part A : Kentucky Department for Environmental Protection Part A of the Kentucky 3

Hazardous Waste Permit Application (KDEP Form – DEP 7058A) ......................................... A-8 4

Part B : Facility Description [401 KAR 39:060, Section 5 & 40 CFR 270.14] ............................ B-9 5

B-1 : General Description [401 KAR39:060, Section 5 & 40 CFR 270.14(b)] ...................... B-10 6

B-2 : Topographic Map [401 KAR 39:060, Section 5 & 40 CFR 270.14(b)(19)] .................. B-11 7

B-3 : Location Information [401 KAR 39:060, Section 5 and 39:090, Section 5 & 8

40 CFR 270.14(b)(11), and 270.14(b)(11)(i through v)] .................................................... B-11 9

B-4 : Traffic Information [401 KAR 39:060, Section 5 & 40 CFR 270.14(b)(10)] ................. B-12 10

B-5 : Requirements for Applicants for Construction Permits [401 KAR 39:060, 11

Section 5) and KRS 224.46 520(1)] .................................................................................. B-12 12

B-6 : Applicants Other than Interim Status - Other Documents [401 KAR 39:060, 13

Section 5] .......................................................................................................................... B-12 14

B-7 : Financial Responsibility to Construct and Operate [401 KAR 39:090, Section 15

7, KRS 224.40-325 & 40 CFR 270.14(b)(18), 264.145, 264.147, and 264.150] ............... B-13 16

B-8 : Public Participation [401 KAR 39:060, Sections 5 & 40 CFR 124.31] ........................ B-13 17

B-9 : Public Meeting Fees [401 KAR 39:120, Section 3, & KRS 224.46-016 and 18

018] ................................................................................................................................... B-13 19

Part C : Waste Analysis Plan [401 KAR 39:060, Section 5 and 401 KAR 39:090, 20

Section 1 & 40 CFR 270.14(b)(3) and 264.13] ...................................................................... C-17 21

Part D : Process Information: General [401 KAR 39:090, Section 1 & 22

40 CFR 264.170-179, 264.190-200, 264.600-603, 270.15] ................................................... D-17 23

D-1 : Process Information: Containers [401 KAR 39:090 Section 1 and 39:060 24

Section 5 & 40 CFR 264.170–179 and 270.15] ................................................................ D-17 25

D-2 : Process Information: Tank Systems [401 KAR 39:090 Section 1 and 39:060 26

Section 5 & 40 CFR 264.192 and 264.190 and 270.16] ................................................... D-23 27

D-3 : Surface Impoundments [401 KAR 39:090 Section 1 and 39:060 Section 5 & 28

40 CFR 264. 220 and 270.17] ........................................................................................... D-23 29

D-4 : Waste Piles [401 KAR 39:090 Section 1 and 39:060 Section 5 30

&40 CFR 264.250 and 270.18] ......................................................................................... D-23 31

D-5 : Land Treatment [401 KAR 39:090 Section 1 and 39:060 Section 5 & 32

40 CFR 264.270 and 270.21] ............................................................................................ D-23 33

D-6 : Landfill Design [401 KAR 39:090 Section 1 and 39:600 Section 5 & 34

40 CFR 264.300 and 270.20] ............................................................................................ D-23 35

D-7 : Incinerators [401 KAR 39:090 Section 1 and 39:060 Section 5 & 36

40 CFR 264.340 and 270.19] ............................................................................................ D-24 37

D-8 : Miscellaneous Units [401 KAR 39:060 Section 5 and 39:090 Section 1 & 38

40 CFR 270.23 and 264.601] ............................................................................................ D-24 39



Part E : Groundwater Monitoring [401 KAR 39:090 Section 1 & 1

40 CFR 264.90(b)(2)] ............................................................................................................ E-25 2

Part F : Procedures to Prevent Hazards [401 KAR 39:090 Section 1 and 39:060 3

Section 5 & 40 CFR 264 and 270] .......................................................................................... F-26 4

F-1 : Security [401 KAR 39:090 Section 1 & 40 CFR 264.14] .............................................. F-26 5

F-2 : Inspection Schedule [KAR 39:080 Section 1 & 40 CFR 264.15] .................................. F-27 6

F-3 : Waiver of Preparedness & Prevention Requirements 7

[401 KAR 39:060, Section 5 & 40 CFR 270.14 (b)(6)] ....................................................... F-29 8

F-4 : Preventive Procedures, Structures, and Equipment [401 KAR 39:060 Section 9

5 & 40 CFR 270.14(b)(8)] ................................................................................................... F-30 10

F-5 : Prevention of Reaction of Ignitable, Reactive, or Incompatible Wastes [401 11

KAR 39:060 Section 5 & 40 CFR 270.14(b)(9)] ................................................................. F-31 12

Part G : Contingency Plan and Emergency Procedures [401 KAR 39:090 Section 1 13

& 40 CFR 264.50-264.56 and 264.196] ................................................................................. G-37 14

Part H : Personnel Training [401 KAR 39:090 Section 1 & 40 CFR 264.16] .......................... H-37 15

Part I : Closure Plan, Post Closure Plans and Financial Requirements [401 KAR 16

39:090 Section 1 & 40 CFR 264.111–115, 264.178, and 264.601] ......................................... I-37 17

Part J : Other Federal Laws ..................................................................................................... J-37 18

Part K : Waste Minimization [401 KAR 39:060 Section 5 & 40 CFR 270.30] .......................... K-37 19

Part L : Signatures [401 KAR 39:060 Section 5 & 40 CFR 124 and 270] ................................ L-37 20

21



List of Figures 1

Figure B-1: BGAD Location .................................................................................................... B-14 2

Figure B-2: BGCAPP Facility Location and Surrounding Land Use ....................................... B-15 3

Figure B-3: Facility Layout ...................................................................................................... B-16 4

Figure D-1: CSF Conceptual Layout ....................................................................................... D-20 5

Figure F-1: Example Weekly Inspection Form ......................................................................... F-35 6

Figure F-2: Example Inspection Log ........................................................................................ F-36 7

8

List of Tables 9

Table D-1: Container Storage Area ........................................................................................ D-18 10

Table D-2: Commonly Used Hazardous Waste Containers .................................................... D-21 11

12



Acronyms/Abbreviations 1

Acronym Definition 2

ACS agent collection system 3

ACWA Assembled Chemical Weapons Alternatives 4

AEL airborne exposure limit 5

AFS aluminum filtration system 6

AHS agent hydrolysate sampling 7

ANR agent neutralization reactor 8

ANS agent neutralization system 9

AOC Army Operations Center 10

APR aluminum precipitation reactor 11

APS aluminum precipitation system 12

ASTM ASTM International (formerly the American Society for 13

Testing and Materials) 14

ATE ACWA test equipment 15

atm atmosphere 16

BGAD Blue Grass Army Depot 17

BGCA Blue Grass Chemical Activity 18

BGCAPP Blue Grass Chemical Agent-Destruction Pilot Plant 19

BPBG Bechtel Parsons Blue Grass 20

BTRA Bounding Transportation Risk Assessment 21

CAIRA Chemical Accident or Incident Response Action 22

CCR central control room 23

CCTV closed-circuit television 24

CFR Code of Federal Regulations 25

CHB Container Handling Building 26

CLA chemical limited area 27

CON Control Room 28

CRM contaminated rocket motor 29

CSB control and support building 30

CSF Container Storage Facility 31

DA Department of the Army 32

DRE destruction and removal efficiency 33

decon decontamination 34

DoD Department of Defense 35

DOT Department of Transportation 36

DWM Division of Waste Management 37

EAR Export Administration Regulation 38

EBH energetics batch hydrolyzer 39

ECR explosive containment room 40

ECV explosive containment vestibule 41

EDT explosive destruction technology 42



ENR energetics neutralization reactor 1

ENS energetics neutralization system 2

EONC enhanced on-site container 3

EPA U.S. Environmental Protection Agency 4

EVS Exhaust Ventilation System 5

FCC facility construction certification 6

FID flame ionization detector 7

GATS General Atomics Total Solution 8

GB nerve agent sarin, isopropyl methylphosphonofluoridate 9

GLS gas/liquid separator 10

H blister agent mustard made by the Levinstein process, 11

bis(2-chloroethyl) sulfide or 2,2'-dichlorodiethyl sulfide 12

HEPA high-efficiency particulate air (filter) 13

HHRA human health risk assessment 14

HSA hydrolysate storage area 15

HSS hydrolysate storage system 16

HST hydrolysate storage tank 17

HVAC heating, ventilating, and air-conditioning 18

HWMU hazardous waste management unit 19

HSWA Hazardous & Solid Waste Amendments 20

IBC intermediate bulk container 21

IPA isopropyl alcohol 22

ITAR International Traffic in Arms Regulations 23

KAR Kentucky Administrative Regulation 24

KDEP Kentucky Department for Environmental Protection 25

KRS Kentucky Revised Statute 26

KY Kentucky 27

LFL lower flammable limit 28

M&EB material & energy balance 29

MCS MPT cooling system 30

MDB Munitions Demilitarization Building 31

MPR motor packing room 32

MPT metal parts treater 33

MSR motor shipping room 34

MWS munitions washout system 35

NCR nose closure removal 36

NCRS nose closure removal station 37

NPT National Pipe Thread 38

NRC National Research Council 39

NRT near real time 40

OB/OD open burning/open detonation 41

OPSEC operations security 42



OSHA Occupational Safety & Health Administration 1

OTE off-gas treatment (effluent) EBH/ENS 2

OTM off-gas treatment system (MPT/ANS) 3

OTMC OTM Common System 4

P&ID piping and instrumentation diagram 5

PCB polychlorinated biphenyl 6

PE professional engineer 7

PEO ACWA Program Executive Office – Assembled Chemical 8

Weapons Alternatives 9

PFD process flow diagram 10

PHS projectile handling system 11

PID photoionization detector 12

PMD projectile/mortar disassembly 13

PPE personal protective equipment 14

ppmv parts per million by volume 15

ppmw parts per million by weight 16

PSE pressure safety element 17

PSV pressure safety valve 18

psi pound per square inch 19

psia pound per square inch, absolute 20

RCM rocket cutting machine 21

RCRA Resource Conservation and Recovery Act 22

RCU recirculating cooling unit(s) 23

RD&D research, development, and demonstration 24

RHS rocket handling system 25

RM rocket motor 26

RO reverse osmosis 27

RQ reportable quantity 28

RSM rocket shear machine 29

SCWO supercritical water oxidation 30

SDN standard document number 31

SDS spent decontamination system 32

SFT shipping and firing tube 33

SOP standing operating procedure 34

SPB supercritical water oxidation (SCWO) processing building 35

SRC single round container 36

SWG Swagelok® 37

STA supercritical water oxidation (SCWO) tank area 38

SWMU solid waste management unit 39

TAR tank assessment report 40

THC total hydrocarbon 41

TMA toxic maintenance area 42



TOC total organic carbon 1

TOCDF Tooele Chemical Agent Disposal Facility 2

TOX thermal oxidizer 3

TRRP technical risk reduction program 4

TSCA Toxic Substances Control Act 5

TSDF treatment, storage, and disposal facility 6

UN United Nations 7

UPA unpack area 8

VSL vapor screening level 9

VX nerve agent, O-ethyl S-(2-diisopropylaminoethyl) 10

methylphosphonothiolate 11

WAP Waste Analysis Plan 12

WSA waste storage area 13

wt% percent by weight 14

WTS waste transfer station 15


Rev. 0, Page A-8 Date: 03 MAY 2018

Part A: Kentucky Department for Environmental 1

Protection Part A of the Kentucky Hazardous Waste 2

Permit Application (KDEP Form – DEP 7058A) 3

United States Environmental Protection Agency

RCRA SUBTITLE C SITE IDENTIFICATION FORM

1. Reason for Submittal (Select only one.)

� Obtaining or updating an EPA ID number for an on‐going regulated activity that will continue for a period of time. (Includes HSM activity)

� Submitting as a component of the Hazardous Waste Report for __________ (Reporting Year)

� Site was a TSD facility and/or generator of > 1,000 kg of hazardous waste, > 1 kg of acute hazardous

waste, or > 100 kg of acute hazardous waste spill cleanup in one or more months of the reporting year

(or State equivalent LQG regulations)

� Notifying that regulated activity is no longer occurring at this Site

� Obtaining or updating an EPA ID number for conducting Electronic Manifest Broker activities

� Submitting a new or revised Part A Form

2. Site EPA ID Number

3. Site Name

4. Site Location Address

Street Address

City, Town, or Village County

State Country Zip Code

5. Site Mailing Address � Same as Location Address

Street Address

City, Town, or Village


6. Site Land Type

� Private � County � District � Federal � Tribal � Municipal � State � Other

7. North American Industry Classification System (NAICS) Code(s) for the Site (at least 5‐digit codes)

A. (Primary) C.

B. D.

EPA Form 8700‐12, 8700‐13 A/B, 8700‐23 Page __ of __

EPA ID Number

8. Site Contact Information � Same as Location Address

First Name MI Last Name

Title

Street Address



Email

Phone Ext Fax

9. Legal Owner and Operator of the Site

A. Name of Site’s Legal Owner � Same as Location Address

Full Name Date Became Owner (mm/dd/yyyy)

Owner Type


Street Address



Email

Phone Ext Fax

Comments

B. Name of Site’s Legal Operator � Same as Location Address

Full Name Date Became Operator (mm/dd/yyyy)

Operator Type


Street Address



Email

Phone Ext Fax

Comments


�

�

�

�

�

�

�

EPA ID Number

10. Type of Regulated Waste Activity (at your site) Mark “Yes” or “No” for all current activities (as of the date submitting the form); complete any additional boxes as instructed.

A. Hazardous Waste Activities

1. Generator of Hazardous Waste—If “Yes”, mark only one of the following—a, b, c �Y � N

‐Generates, in any calendar month (includes quantities imported by importer site) 1,000 kg/mo (2,200 lb/mo) or more of non‐acute hazardous waste; or

a. LQG

‐ Generates, in any calendar month, or accumulates at any time, more than 1 kg/mo (2.2 lb/mo) of acute hazardous waste; or ‐ Generates, in any calendar month or accumulates at any time, more than 100 kg/mo (220 lb/mo) of acute hazardous spill cleanup material.

b. SQG 100 to 1,000 kg/mo (220‐2,200 lb/mo) of non‐acute hazardous waste and no more than 1 kg (2.2 lb) of acute hazardous waste and no more than 100 kg (220 lb) of any acute hazardous spill cleanup material.

c. VSQG Less than or equal to 100 kg/mo (220 lb/mo) of non‐acute hazardous waste.

If “Yes” above, indicate other generator activities in 2 and 3, as applicable.

2. Short‐Term Generator (generates from a short‐term or one‐time event and not from on‐going processes). If “Yes”, provide an explanation in the Comments section.

�Y � N

3. Mixed Waste (hazardous and radioactive) Generator �Y � N

4. Treater, Storer or Disposer of Hazardous Waste—Note: A hazardous waste Part B permit is required for�Y � N these activities.

5. Receives Hazardous Waste from Off‐site�Y � N

6. Recycler of Hazardous Waste �Y � N

a. Recycler who stores prior to recycling

b. Recycler who does not store prior to recycling

7. Exempt Boiler and/or Industrial Furnace—If “Yes”, mark all that apply. �Y � N

a. Small Quantity On‐site Burner Exemption

b. Smelting, Melting, and Refining Furnace Exemption

B. Waste Codes for Federally Regulated Hazardous Wastes. Please list the waste codes of the Federal hazardous wastes handled at your site. List them in the order they are presented in the regulations (e.g. D001, D003, F007, U112). Use an additional page if more spaces are needed.

C. Waste Codes for State Regulated (non‐Federal) Hazardous Wastes. Please list the waste codes of the State hazardous wastes handled at your site. List them in the order they are presented in the regulations. Use an additional page if more spaces are needed.


EPA ID Number

11. Additional Regulated Waste Activities (NOTE: Refer to your State regulations to determine if a separate permit is required.) A. Other Waste Activities

�Y � N 1. Transporter of Hazardous Waste—If “Yes”, mark all that apply.

� a. Transporter

� b. Transfer Facility (at your site)

�Y � N 2. Underground Injection Control

�Y � N 3. United States Importer of Hazardous Waste

�Y � N 4. Recognized Trader—If “Yes”, mark all that apply.

� a. Importer

� b. Exporter

�Y � N 5. Importer/Exporter of Spent Lead‐Acid Batteries (SLABs) under 40 CFR 266 Subpart G—If “Yes”, mark all that apply.

� a. Importer

� b. Exporter

B. Universal Waste Activities

�Y � N 1. Large Quantity Handler of Universal Waste (you accumulate 5,000 kg or more) ‐ If “Yes” mark all that apply. Note: Refer to your State regulations to determine what is regulated.

� a. Batteries

� b. Pesticides

� c. Mercury containing equipment

� d. Lamps

� e. Other (specify) ______________________________________________

� f. Other (specify) ______________________________________________

� g. Other (specify) ______________________________________________

�Y � N 2. Destination Facility for Universal Waste Note: A hazardous waste permit may be required for this activity.

C. Used Oil Activities

�Y � N 1. Used Oil Transporter—If “Yes”, mark all that apply.

� a. Transporter

� b. Transfer Facility (at your site)

�Y � N 2. Used Oil Processor and/or Re‐refiner—If “Yes”, mark all that apply.

� a. Processor

� b. Re‐refiner

�Y � N 3. Off‐Specification Used Oil Burner

�Y � N 4. Used Oil Fuel Marketer—If “Yes”, mark all that apply.

� a. Marketer Who Directs Shipment of Off‐Specification Used Oil to Off‐Specification Used Oil Burner

� b. Marketer Who First Claims the Used Oil Meets the Specifications


sity

EPA ID Number

12. Eligible Academic Entities with Laboratories—Notification for opting into or withdrawing from managing laboratory hazardous wastes pursuant to 40 CFR 262 Subpart K.

�Y � N A. Opting into or currently operating under 40 CFR 262 Subpart K for the management of hazardous wastes in laboratories—If “Yes”, mark all that apply. Note: See the item‐by‐item instructions for defini‐tions of types of eligible academic entities.

� 1. College or University

� 2. Teaching Hospital that is owned by or has a formal written affiliation with a college or university

� 3. Non‐profit Institute that is owned by or has a formal written affiliation with a college or univer‐

�Y � N B. Withdrawing from 40 CFR 262 Subpart K for the management of hazardous wastes in laboratories.

13. Episodic Generation

Are you an SQG or VSQG generating hazardous waste from a planned or unplanned episodic event, lasting no more than 60 days, that moves you to a higher generator category. If “Yes”, you must fill out the Ad‐dendum for Episodic Generator.

�Y � N

14. LQG Consolidation of VSQG Hazardous Waste

Are you an LQG notifying of consolidating VSQG Hazardous Waste Under the Control of the Same Person pursuant to 40 CFR 262.17(f)? If “Yes”, you must fill out the Addendum for LQG Consolidation of VSQGs hazardous waste.

�Y � N

15. Notification of LQG Site Closure for a Central Accumulation Area (CAA) (optional) OR Entire Facility (required)

�Y � N LQG Site Closure of a Central Accumulation Area (CAA) or Entire Facility.

A. � Central Accumulation Area (CAA) or �Entire Facility

B. Expected closure date: ____________ mm/dd/yyyy

C. Requesting new closure date: ____________ mm/dd/yyyy

D. Date closed : ____________ mm/dd/yyyy

� 1. In compliance with the closure performance standards 40 CFR 262.17(a)(8)

� 2. Not in compliance with the closure performance standards 40 CFR 262.17(a)(8)

16. Notification of Hazardous Secondary Material (HSM) Activity

�Y � N A. Are you notifying under 40 CFR 260.42 that you will begin managing, are managing, or will stop manag‐ing hazardous secondary material under 40 CFR 260.30, 40 CFR 261.4(a)(23), (24), or (27)? If “Yes”, you must fill out the Addendum to the Site Identification Form for Managing Hazardous Secondary Material.

�Y � N B. Are you notifying under 40 CFR 260.43(a)(4)(iii) that the product of your recycling process has levels of hazardous constituents that are not comparable to or unable to be compared to a legitimate product or intermediate but that the recycling is still legitimate? If “Yes”, you may provide explanation in Comments section. You must also document that your recycling is still legitimate and maintain that documentation on site.

17. Electronic Manifest Broker

Are you notifying as a person, as defined in 40 CFR 260.10, electing to use the EPA electronic manifest sys‐tem to obtain, complete, and transmit an electronic manifest under a contractual relationship with a haz‐ardous waste generator?

�Y � N


EPA ID Number

United States Environmental Protection Agency

HAZARDOUS WASTE PERMIT PART A FORM

1. Facility Permit Contact

First Name MI Last Name

Title

Email

Phone Ext Fax

2. Facility Permit Contact Mailing Address

Street Address



3. Facility Existence Date (mm/dd/yyyy)

4. Other Environmental Permits

A. Permit Type B. Permit Number C. Description

5. Nature of Business


EPA ID Number

6. Process Codes and Design Capacities

Line A. Process Code B. Process Design Capacity

C. Process Total Number of Units

D. Unit Name Number (1) Amount

(2) Unit of Measure

7. Description of Hazardous Wastes (Enter codes for Items 7.A, 7.C and 7.D(1) )

Line No.

A. EPA Hazardous

Waste No.

B. Estimated

Annual

Qty of

Waste

C. Unit of

Measure

D. Processes

(1) Process Codes (2) Process Description

(if code is not entered in 7.D1))

8. Map

Attach to this application a topographical map, or other equivalent map, of the area extending to at least one mile beyondproperty boundaries. The map must show the outline of the facility, the location of each of its existing intake and dischargestructures, each of its hazardous waste treatment, storage, or disposal facilities, and each well where it injects fluids under‐ground. Include all spring, rivers, and other surface water bodies in this map area. See instructions for precise require‐ments.

9. Facility Drawing

All existing facilities must include a scale drawing of the facility. See instructions for more detail.

10. Photographs

All existing facilities must include photographs (aerial or ground‐level) that clearly delineate all existing structures; existingstorage, treatment, and disposal areas; and sites of future storage, treatment, or disposal areas. See instructions for more detail.

11. Comments


EPA ID Number K Y 8 2 1 3 8 2 0 1 0 5 OMB# 2050-0024; Expires 05/31/2020

EPA Form 8700‐12, 8700‐13 A/B, 8700‐23 Page 8a of 8b

7. Description of Hazardous Wastes (Enter codes for Items 7.A, 7.C and 7.D(1)) (continued)

Line No.

A. EPA

Hazardous

Waste No.

B. E stimated

Annual Qty

of Waste

C. Unit of

Measure

D. Processes



1 2 D 0 1 8 included with above














2 6 F 0 0 1 included with above





3 1 P 0 9 8 included with above

3 2 P 1 0 6 included with above

3 3 U 0 0 2 included with above








4 1 N 0 0 1 included with above





EPA ID Number K Y 8 2 1 3 8 2 0 1 0 5 OMB# 2050-0024; Expires 05/31/2020

EPA Form 8700‐12, 8700‐13 A/B, 8700‐23 Page 8b of 8b

Line No.

A. EPA

Hazardous

Waste No.

B. E stimated

Annual Qty

of Waste

C. Unit of

Measure

D. Processes

















DWM 7058A (June 2017) 401 KAR 39:060

Kentucky Department for Environmental Protection Division of Waste Management

Hazardous Waste Branch 300 Sower Blvd, Frankfort, KY 40601

(502) 564-6716

Part A Application Addendum (EPA Form 8700-23)

FOR OFFICIAL USE ONLY. DO NOT WRITE IN THIS SPACE.

FEE SUBMITTED: $ (See instructions to determine your fee)

I. Reason for Submittal

(see instructions)

Reason for Submittal: FIRST SUBMITTAL – Must be accompanied by the completed forms EPA 8700-12 and Addendum DWM-7037A.

REVISION – Identify the classification of the revision. See instructions for when a revised application should besubmitted.

Class 1 not requiring approval Class 1 requiring approval Class 2 Class 3

RENEWAL – See instructions for when a renewal application should be submitted.

STANDARDIZED PERMIT – See instructions for the eligibility of a standardized permit.

II. ID Numbers A. EPA ID Number:KY8−213−820−105

B. AGENCY INTEREST Number:2805

III. Existing andNew Facilities

Existing Facilities, the date operation began or construction commenced: (mm/dd/yyyy) 04/01/1942

New Facilities, the date operation is expected to begin: (mm/dd/yyyy) / /

IV. Contact EmailAddress

Facility Contact Email address: [email protected]

V. Facility Operator (2)

Name of Facility Operator 2 (see Instructions): NA

VI. Type ofOperator (2)

Type of Operator 2: Federal (F) State (S) County (C) Indian (I) Municipal (M) District (D)

Private (P) Other (O) Specify:

VII. OperatorMailingAddress (2)

Operator 2 Street Address or P.O. Box:

City: State: County: Zip Code:

Facility Operator 2 Telephone Number: Phone Number Extension:

New Operator Assumed Responsibility for Facility on this Date: (mm/dd/yyyy) / /

VIII. FacilityOperator (3)

Name of Facility Operator 3 (see Instructions): NA

IX. Type ofOperator (3)

Type of Operator 3: Federal (F) State (S) County (C) Indian (I) Municipal (M) District (D)

Private (P) Other (O) Specify:

X. Operator Mailing Address (3)

Operator 3 Street Address or P.O. Box:

City: State: County: Zip Code:

Facility Operator 3 Telephone Number: Phone Number Extension:

New Operator Assumed Responsibility for Facility on this Date: (mm/dd/yyyy) / /

Page 1 of 4

DWM 7058A (June 2017) 401 KAR 39:060

EPA ID Number: KY8−213−820−105 Agency Interest Number: 2805 XI. PROCESS DESCRIPTION: (See Instructions)

a. Commercial Indicator

b. Unique Unit or Group

Name

c. Legal Status Code

d. Operating Status Code(s)

e. Description of Process

4 Container Storage

Facility (CSF) PR CN

S01; Store various hazardous and secondary wastes prior to transportation to final treatment/disposal facility.

Page 2 of 4

DWM 7058A (June 2017)

401 KAR 39:060

EPA ID Number: KY8−213−820−105 Agency Interest Number: 2805 XII. WASTE STREAM DESCRIPTION (See Instructions)

a. Line Number

b. Waste Stream Number

c.

Waste Description

01-59 01 S01 Process Code; Containerized waste from BGCAPP Main Plant

and EDT Facilities stored for transportation and off-site disposal.

Page 3 of 4


Rev. 0, Page B-9 Date: 03 MAY 2018

Part B: Facility Description [401 KAR 39:060, Section 1

5 & 40 CFR 270.14] 2

The Blue Grass Chemical Agent-Destruction Pilot Plant (BGCAPP) Main Plant and EDT 3

facilities are being constructed by the Department of Defense (DoD) and the Department of the 4

Army for the purpose of destroying chemical-agent-filled munitions stored at Blue Grass Army 5

Depot (BGAD). The stockpile of chemical agent items includes munitions filled with either GB or 6

VX nerve agents in projectiles or rockets, one Department of Transportation (DOT) bottle 7

containing VX and H blister agent stored in projectiles. The projectiles, rockets, and DOT bottle 8

currently are stored on-site at BGAD in the Chemical Limited Area (CLA) and managed by the 9

Blue Grass Chemical Activity (BGCA). 10

This Class 3 RCRA Permit Modification request, with BGAD as the owner and the Bechtel 11

Parsons Blue Grass (BPBG) Joint Venture (JV) as the operator, adds a Container Storage 12

Facility (CSF) to the current BGAD RCRA permit (Resource Conservation and Recovery Act 13

[RCRA] Hazardous Waste Facility Permit RCRA Hazardous Waste Storage Permit Renewal 14

Application for Conventional Munition Related Items EPA ID# KY8-231-820-105) IAW the 15

requirements of 401 KAR 39:060, Section 5 & 40 CFR 270.42(c). This CSF is located on BGAD 16

approximately 500 yards west of gate D10W on the south side of the road. The storage facility 17

is an existing structure on BGAD identified as Building 110FF. It is a steel framed metal clad 18

structure approximated 50 feet by 100 feet. Other activities included in this RCRA Class 3 19

Permit Modification Request include transportation of stored secondary wastes from BGCAPP 20

Main Plant and EDT facilities to this permitted CSF for storage prior to transportation to an 21

offsite TSDF for final disposal. 22

The BGAD as owner and BPBG JV as operator have been issued a RCRA permit by KDEP to 23

operate the Explosive Destruction Technology (EDT) Facility for treatment of H (mustard) 24

chemical agent, in addition to a RCRA Research, Development and Demonstration (RD&D) 25

permit to allow construction of the BGCAPP Main Plant and demonstration testing treatment of 26

GB at the BGCAPP Main Plant. A RCRA Part B permit application for treatment of VX in the 27

BGCAPP Main Plant is under preparation. BGAD, owner and permits holder (EPA ID KY8-213-28

820-105), is located at 431 Battlefield Memorial Highway, Richmond, Kentucky. BGAD and the 29

joint venture formed by the Bechtel and Parsons Corporations (i.e., Bechtel Parsons Blue Grass 30

Joint Venture -- BPBG) will operate the BGCAPP Main Plant, EDT Facility and the CSF as co-31

permittees with BGAD. 32

The format of this request for a Class 3 RCRA Permit Modification includes new parts for the 33

existing BGAD permit that mirror the structure of the Kentucky Department for Environmental 34

Protection (KDEP) Part B Permit Application Review Checklist. This format includes applicable 35

Kentucky Administrative Regulation (KAR) sections with the corresponding Code of Federal 36

Regulations (CFR) citations also identified to allow a more efficient regulatory review of this 37

request for Permit Modification. Additional information as referenced throughout this permit 38

modification request can also be found in 24915-000-GPE-GGPT-00001, Resource 39

Conservation and Recovery Act (RCRA) Research, Development and Demonstration (RD&D) 40

Permit Application – Revision 6a, 24915-000-GPE-GGPT-00195, Resource Conservation and 41

Recovery Act (RCRA) Research, Development and Demonstration (RD&D) Permit – Class 2 42

Modification Request, Revision 0a, and 24915-70-GPE-GGPT-00001, Class 3 Hazardous 43

Waste Storage & Treatment Permit Modification Request, Addition of Explosive Destruction 44

Technology (EDT) (CDRL A010), Rev. 2, each of which has been previously submitted to 45

KDEP. 46



1

2

BGAD is located in the Blue Grass region of east central Kentucky, approximately in the center 3

of Madison County. BGAD encompasses 14,596 acres and is approximately 30 miles 4

southeast of Lexington, 85 miles southeast of Louisville, and 90 miles south of Cincinnati, Ohio. 5

It is adjacent to the southeastern portion of Richmond, Kentucky, approximately 5 miles 6

southeast of the center of Richmond, and 10 miles northeast of Berea, Kentucky (Figure B-1). 7

The installation includes a variety of buildings, structures, and undeveloped areas. BGAD is 8

located in the Outer Blue Grass Subdivision of the Blue Grass physiographic region. The 9

topography of the Outer Blue Grass Subdivision includes moderately undulating to gently rolling 10

hills that steepen near major streams. BGAD has open fields and rolling hills with gentle slopes 11

dotted with woodlots of varying sizes. BGAD is surrounded by agricultural, industrial, low-12

density residential, commercial, and public land use areas. The public uses of land in 13

BGAD/Richmond area include educational and recreational activities and areas. 14

BGAD, a federal facility, is a Joint Munitions Command (JMC) Depot with a primary mission of: 15

(1) to provide America's Joint Warfighters reliable, timely and cost-effective munitions and 16

chemical defense equipment in support of full spectrum Military Operations, and (2) to 17

safeguard the remainder of the National Chemical Weapons Stockpile until demilitarization. 18

BGAD is staffed to store conventional (i.e., non-nuclear and non-chemical) munitions for major 19

force deployment. BGAD is also the Department of the Army's major storage site for chemical 20

defense equipment. The conventional munitions operations at BGAD include shipping and 21

receiving, storage, maintenance, inspection, and demilitarization. 22

In addition to conventional munitions, the Department of the Army began to store chemical 23

weapons at the Blue Grass Installation in 1944. BGAD began to receive shipments of modern 24

chemical weapons in 1952, and receipt of chemical weapons continued until the mid-1960s. 25

Since the mid-1960s, BGAD’s mission has included the safe storage of existing chemical 26

weapons. 27

In 1996, the Department of the Army established BGCA as a special unit focused on the 28

management and storage of chemical weapons on BGAD. BGCA is a tenant organization of 29

BGAD. The primary mission of BGCA is the safe storage and monitoring of the chemical 30

weapons stockpile located within the CLA, a highly secured 250-acre site contained within 31

BGAD. 32

The BGCAPP Main Plant is located wholly within the BGAD’s boundary. The BGCAPP Main 33

Plant is approximately 19 acres in size and has its entrance on Kentucky (KY) Highway 52. The 34

BGCAPP Main Plant is being constructed and will be operated by the BPBG JV to destroy the 35

chemical weapons stockpile stored at BGAD by BGCA, including chemical weapons, process 36

wastes, and secondary wastes. Construction and initial operation of the BGCAPP Main Plant 37

will be under a research program permitted under the RD&D Kentucky Permit number 38

KY8-213-820-105 to ensure the integrated processes function efficiently and provide adequate 39

levels of waste treatment and management. The RD&D permit application includes only the 40

treatment of GB munitions and wastes. VX munitions and wastes treatment will be described 41

under the Part B permit application to be submitted to KDEP. 42

The EDT Facility is located wholly within the BGAD’s boundary along the southern boundary of 43

the BGCAPP Main Plant being constructed on the BGAD. BGAD as the owner and BPBG will 44

store and treat State Listed N003 chemical agent munitions at this facility (i.e., projectiles 45

containing the chemical warfare agent, Mustard and the two DOT bottles/containers) under both 46

Federal and Commonwealth of Kentucky hazardous waste regulations. 47



The CSF will receive and store hazardous and secondary waste generated from the operations 1

of both the BGCAPP Main Plant and EDT facility. The CSF will facilitate management of these 2

wastes for shipment to an offsite TSDF for final disposal. These wastes will include 3

Commonwealth of Kentucky listed waste from processing of chemical agents GB, VX and H 4

(N001, N002, N003, N101, N102, N201, N202, N203, N301, N302, N401, N402, N501, N502, 5

N601, N602, N701, N702, N703). These listed wastes are codified by 401 KAR 39:060, Lists of 6

hazardous waste, Section 3 – Table I. In addition, processing of these chemical agents and 7

other maintenance activities may produce other hazardous wastes (e.g., Waste Numbers: 8

D001, D002, D003, D004, D005, D006, D007, D008, D009, D010, D011, D018, D019 D022, 9

D024, D026, D027, D028, D029, D030, D035, D037, D038, D039, D040, F001–F005), and 10

laboratory and maintenance activities may also add other wastes (e.g., Waste Numbers: P098, 11

P106, U002, U003, U044, U080, U154, U188, U196, U213). 12

13

14

Figure B-1 is a topographic map of BGAD and surrounding area showing the general location of 15

BGAD. 16

1. Map Scale, Orientation, and Date Prepared 17

Due to the size of the facility and the need to show surrounding areas, scaled maps are 18

included in this Permit Modification Request as Figure B-1 and Figure B-2. Figure B-2 also 19

contains a north arrow and the date the figure was prepared. 20

2. Buildings/Structures 21

Figure B-3 shows the buildings and structures associated with the BGCAPP facility. There are 22

no established public recreational areas near the BGCAPP facility. 23

3. Other Maps 24

See 24915-000-GPE-GGPT-00001 and 24915-70-GPE-GGPT-00001 submitted to KDEP. 25

26

27

28

29




1

2


Additional traffic to the CSF primarily consists of BGCAPP motor vehicles carrying container 4

waste from BGCAPP and EDT facilities to and from the CSF. This activity will occur as needed, 5

potentially multiple times per day. Waste will also be shipped offsite from the CSF. This activity 6

will generally occur as needed and consist of two subcontractor vehicles and at least one 7

BGCAPP vehicle. Travel to the CSF occurs on BGAD roads, the primary route used for these 8

vehicles is as follows. Vehicles will exit BGCAPP and EDT areas via Depot gate D2 located at 9

the southern end of the BGCAPP boundary, they will travel Depot roads to the CSF 10

approaching the facility from a westerly direction. Departing vehicles will reverse this route and 11

return to the BGCAPP via Gate D2. Subcontractor vehicles intended for offsite waste shipment 12

will depart the BGCAPP site via the access road to route 52 and subsequently following the 13

same routes identified in permits 24915-000-GPE-GGPT-00001 and 24915-70-GPE-GGPT-14

00001 submitted to KDEP. 15

16

17

18

The BPBG JV is the organization contracted to design, construct, and operate the BGCAPP 19

facility for the Government owner. The design, construction, and operation of the BGCAPP 20

facility is under a Federal contract, located on land owned by the Federal government, and 21

exempted as a Federal facility from providing financial assurance in accordance with 22

40 CFR 264.140(c). Additional authority to construct is not being sought since this is a 23

modification to an existing permit and the building has already been constructed. 24

: Alternative Analysis Plan 25

The BPBG Team and BGAD evaluated potential facilities available on the BGAD for use as a 26

CSF. Building 110FF was chosen due to the proximity to the BGCAPP site, ease of access, 27

size and design best meeting the needs of the BGCAPP and EDT facilities hazardous and 28

secondary waste management requirements. 29

: Specific Requirements for Incinerators and 30

Disposal Facilities 31

Not applicable. The CSF is not an incinerator or land disposal facility. 32

33

34

The CSF is a new facility and has not previously received any civil fines or significant 35

deficiencies on environmental compliance inspections. Since the BPBG Team is a JV 36

contracted to operate the BGCAPP Main Plant, these disclosure forms, key personnel 37

statement forms, and disclosure statements have been previously provided as part of ongoing 38

efforts under the RD&D Permit activities for the BGCAPP Main Plant. 39



1

2

3

4

BPBG Team is the organization contracted to operate the CSF for the Government owner. The 5

design, construction upgrades, and operation of the CSF is under a Federal contract, located on 6

land owned by the Federal government, and exempted as a Federal facility from providing 7

financial assurance in accordance with 40 CFR 264.140(c) and as outlined in KRS 224.40-110. 8

9

10

Public meetings will be held IAW the requirements of 401 KAR 39:060, Sections 5 & 40 CFR 11

124.31. 12

13

14

An existing grant from Assembled Chemical Weapons Alternatives (ACWA) to KDEP includes 15

monies to pay the fee for filing and review of this Class 3 BGAD RCRA Permit Modification. No 16

additional monies are required. 17

18



Figure B-1: BGAD Location 1

2



Figure B-2: BGCAPP Facility Location and Surrounding Land Use 1

2



Figure B-3: Facility Layout 1

2


Rev. 0, Page D-17 Date: 03 MAY 2018

Part C: Waste Analysis Plan [401 KAR 39:060, Section 1

5 and 401 KAR 39:090, Section 1 & 2

40 CFR 270.14(b)(3) and 264.13] 3

See 24915-000-GPE-GGPT-00001, Resource Conservation and Recovery Act (RCRA) 4

Research, Development and Demonstration (RD&D) Permit Application – Revision 6a, 5

submitted to KDEP and EPA in addition to 24915-70-GPE-GGPT-00001, Resource 6

Conservation and Recovery Act (RCRA) Volume II - Class 3 Hazardous Waste Storage & 7

Treatment Permit Modification Request, Addition of Explosive Destruction Technology (EDT), 8

submitted to KDEP. 9

Part D: Process Information: General [401 KAR 10

39:090, Section 1 & 40 CFR 264.170-179, 264.190-200, 11

264.600-603, 270.15] 12

13

14

15

This CSF identified in this Permit Modification Request is an existing BGAD structure 16

designated as BGAD building 110FF located on BGAD approximately 500 yards west of gate 17

D10W on the south side of the road. Building 110FF consists of pre-engineered metal building 18

constructed on a concrete slab. The structure has two roll up doors and two man doors located 19

on the east and west sides of the structure. The CSF will be equipped with both MINICAMS 20

and DAAMS for agent monitoring of the interior of the facility. In addition, the CSF will be 21

equipped with an Exhaust Ventilation System (EVS) which includes induced draft fan, filters and 22

activated carbon media. This system when operating will provide induced air flow into the CSF 23

and exhaust out through the EVS. In case of an unplanned or emergency event that resulted in 24

agent vapor inside the CSF the engineering controls provided by this EVS assure no agent 25

vapor is released to the environment in compliance with KRS 224.1-400(4). Hazardous and 26

secondary wastes generated by BGCAPP Main Plant and EDT operations will be stored at the 27

CSF. BGCAPP Main Plant and EDT secondary waste brought to this facility for storage will be 28

shipped offsite for final disposal, or may also be brought back to the originating facility BGCAPP 29

Main Plant or EDT, for further management. The primary function of this facility is to provide 30

storage capacity for these wastes as necessary to facilitate efficient processing of chemical 31

agent containing munitions at the BGCAPP Main Plant and EDT facilities. See 24915-000-32

GPE-GGPT-00001 and 24915-70-GPE-GGPT-00001 submitted to KDEP and EPA for lists and 33

descriptions of the types and characteristics of hazardous wastes stored in containers at the 34

BGCAPP Main Plant and EDT facilities. 35



Table D-1: Container Storage Area 1

Container Storage

Area

Maximum Waste

Capacity (gal)

Containment Design Dimensions

Materials of Construction

Drainage / Container

Management Containment Capacity (gal)

Analysis and Removal of

Accumulated Liquids

Testing/ Demonstration

of No Free Liquids

Air Emissions Control**

Container Storage Facility (CSF)

49,280 Spill pallets and or

containment lockers as necessary

CSF ~100' × ~50'

CSF: Prefabricated

metal building with

concrete floor

CSF: containers with liquids stored on spill pallets

or in containment lockers with

integral containment. Containers stored on pallets.

Not applicable (no free

liquids stored except on

spill pallets or within lockers with integral containment)

No run-on in CSF

Liquids in spill

pallets or containment

lockers analyzed in accordance with WAP

requirements.

SW-846 Method 9095

and/or process

knowledge

Storage Level 1 Containers

that are closed except when

adding or removing material

Run-On Management: The storage facility is covered preventing run-on.

Ignitable and Reactive Wastes 50 feet from Property Line: All container waste storage facilities are >50 feet from BGAD property line. In addition, open flames and other ignition sources are prohibited near flammable or ignitable waste storage areas. Separation of Incompatible Wastes: By waste management best practices, incompatible wastes are not commingled in the same container nor stored near each other in the same container storage area without adequate controls. **Subpart CC standards for Level 1 Containers not in light material service are met by use of containers that meet DOT regulations for packaging hazardous materials or a container equipped with a cover and closure devices that form a continuous barrier over the container openings such that when the cover and closure devices are secured in the closed position there are no visible holes, gaps, or other open spaces into the interior of the container

2



: Container Management [401 KAR 39:090 Section 1 1

and 39:060 Section 5 & 40 CFR 264.170–179 and 270.15] 2


Primarily non-bulk containers will be stored at the CSF, additionally only DOT specification 4

containers will be used to store hazardous and secondary waste in the CSF. Container types 5

that will be managed at the CSF are described below in D-1a(1) and Table D-2. 6

Figure D-1, below, represents a proposed storage arrangement for the CSF. This arrangement 7

allows for 896 x 55 –gallon containers stored 4 containers per pallet and a total storage capacity 8

of approximately 49,280 gallons. The proposed configuration of containers and emergency 9

response equipment shown in Figure D-1 is intended as an illustration showing the maximum 10

potential storage capacity of the CSF while allowing adequate aisle space for inspection and 11

emergency response. 12

13



1

Figure D-1: CSF Conceptual Layout 2

3



: Hazardous Waste Containers 1

D-1a(1)(a): Containers and Compatible Liners 2

A range of container types and sizes will be used for hazardous and secondary waste storage 3

and transportation at BGCAPP. Table D-2 provides a listing of the container types that will be 4

available for use as needed, but is not considered as an exclusive list of allowable containers 5

that may be stored in the CSF. However, all containers used for hazardous or secondary waste 6

stored at the CSF will be DOT specification containers. Plastic and other liners, compatible with 7

the specific wastes to be containerized, will also be used as appropriate. Specifications for 8

each type of container will be obtained to document that these meet the DOT requirements for 9

the type of waste placed in the container. 10

Table D-2: Commonly Used Hazardous Waste Containers 11

CAPACITY (gallons) DESCRIPTION UNITED NATIONS (UN) MARKINGS

275 Cubic Yard Fiberboard Box UN 4G

110 Open head steel drum UN 1A2

95 Open head polyethylene salvage drum UN 1H2

85 Open head steel salvage drum UN 1A2

85 Open head polyethylene salvage drum UN 1H2

55 Open head steel salvage drum UN 1A2

55 Closed head steel drum UN 1A1

55 Closed head polyethylene drum UN1H1


55 Open head polyethylene drum UN 1H2

30 Closed head steel drum UN 1A1

30 Closed head polyethylene drum UN 1H1


30 Open head polyethylene drum UN-1H2

15 Closed head polyethylene drum UN 1H1

8 Open head steel pail UN 1A2

5 Open head steel pail UN-1A2

5 Open head polyethylene pail UN 1H2

5 Closed head polyethylene pail UN 1H1

5 Closed Head Jerrycan UN 3H1

1 Open head polyethylene pail UN 1H2

: Container Management Methods 12

See 24915-000-GPE-GGPT-00001 and 24915-70-GPE-GGPT-00001 submitted to KDEP. The 13

CSF will receive waste containers from BGCAPP Main Plant and EDT facilities. BGCAPP Main 14

Plant and EDT agent contaminated secondary waste containers stored at the CSF will not be 15

opened at this facility. These containers will be managed at the CSF for storage and shipment 16



only. Management methods for the storage and handling of these containers are described in 1

the aforementioned permits. 2

: Containers with Free Liquids, and F020, F021, F023, 3

F026, and F027 Wastes [401 KAR 39:090 Section 1 & 4

40 CFR 264.175] 5

See 24915-000-GPE-GGPT-00001 and 24915-70-GPE-GGPT-00001 submitted to KDEP. In 6

the CSF, all drums will be placed on pallets to provide protection from contact with moisture or 7

accumulated liquids, and the CSF is equipped with a roof and raised threshold to prevent run-on 8

from reaching containers in the CSF permitted storage area. In addition, any containers with 9

free liquids will be placed on portable spill pallets or hazardous material lockers with integral 10

containment. These pallets or lockers will provide their own secondary containment and be 11

compatible with the contents of the containers. The containment volume of these pallets or 12

lockers will include sufficient volume to contain the volume of largest container or 10% of the 13

aggregate volume of all the containers on the pallet or in the locker, whichever is greater. 14

: Containers without Free Liquids and F020, F021, 15

F023, F026, and F027 Wastes [401 KAR 39.060 Section 5 16

and 39:090 Section 1 & 40 CFR 270.15(b) and 264.175] 17

See 24915-000-GPE-GGPT-00001and 24915-70-GPE-GGPT-00001 submitted to KDEP. The 18

CSF Permit Modification Request does not include a request for a waiver for storage of 19

containers without free liquids. Furthermore, no F020, F021, F023, F026, or F027 wastes will 20

be stored in the CSF. 21

: Requirements for Ignitable or Reactive Wastes and 22

Incompatible Wastes [401 KAR 39:090 Section 1 & 23

40 CFR 264.176 and 264.177] 24

See 24915-000-GPE-GGPT-00001 and 24915-70-GPE-GGPT-00001 submitted to KDEP. The 25

CSF facility is located more than 50 feet from the BGAD property line. If ignitable or reactive 26

wastes are stored they will be managed IAW the identified requirements. Any ignitable or 27

reactive waste will be separated and stored on separate pallets, containment pallets or lockers 28

an acceptable distance from each other or other wastes. If incompatible wastes are present 29

they will not be stored in the same container and will be stored on separate containment pallets 30

or lockers an acceptable distance from each other or other wastes. 31

: Organic Air Emissions Subpart CC [401 KAR 39:090 32

Section 1, 40 CFR 264.1080] 33

A variety of containers will be used in the BGCAPP Main Plant and EDT Facilities, as indicated 34

in Section D-1a(1). Subpart CC requirements are not applicable to containers with design 35

capacity of less than or equal to 0.1 m3 per 264.1080(b)(2). Consequently, the containers 36

discussed in Section D-1a(1) in Table D-2 with capacity less than 26.4 gallons (0.1 m3) are not 37

subject to Subpart CC. 38

All other containers used in the BGCAPP Main Plant for permitted storage of waste, with 39

exception of 1.32 m3 (350 gallon) or larger steel/poly intermediate bulk containers, will have 40

design capacity less than 0.46 m3 (121.5 gallons) and will be subject to Subpart CC Container 41

Level 1 standards per 264.1086(b)(i). In addition, all 1.32 m3 (350 gallon) or larger steel/poly 42

intermediate bulk containers will not be in light material service and so also will only be subject 43

to Subpart CC Container Level 1 standards per 264.1086(b)(ii). No containers will be used for 44



treatment of hazardous waste by a waste stabilization process or have volume greater than 0.46 1

m3 and be in light material service. All containers used in the BGCAPP Main Plant for permitted 2

storage of waste will meet applicable U.S. Department of Transportation (DOT) regulations on 3

packaging hazardous materials for transportation as specified in 264.1086(f). Agent-4

contaminated secondary waste containers stored in this facility will not be opened. For all other 5

containers in permitted storage, they will be kept closed except when waste is being added, 6

removed, or accessed for other activities (e.g., sampling) in accordance with 264.1086(c)(3). All 7

containers in permitted storage will be visually inspected as specified in 264.1086(c)(4) and 8

meet applicable documentation and record-keeping requirements (264.1086(c)(5). 9

Documentation of material service is included in 24915-00-GPE-GGPT-00195, Resource 10

Conservation and Recovery Act (RCRA) Class 3 Hazardous Waste Storage & Treatment Permit 11

Modification Request, Addition of Blue Grass Chemical Agent-Destruction Pilot Plant - Main 12

Plant Organic Air Emissions, and 24915-70-GPE-GGPT-00004, Class 3 Hazardous Waste 13

Storage & Treatment Permit Modification Request, Addition of Explosive Destruction 14

Technology (EDT) - Organic Air Emissions, submitted to EPA and KDEP. 15

16

17

18

Not applicable. The CSF does not use facility tank systems as a part of this permit modification 19

request. 20

21

22

23

Not applicable. CSF waste management unit does not include surface impoundments. 24

25

26

27

Not applicable. CSF waste management unit does not include waste piles. 28

29

30

31

Not applicable. CSF waste management unit does not include land treatment. 32

33

34

35

Not applicable. CSF waste management unit does not include landfills. 36



1

2

3

Not applicable. CSF waste management unit does not include incinerators. 4

5

6

7

Not applicable. The CSF does not include any miscellaneous units as a part of this permit 8

modification request. 9

10


Rev. 0, Page E-25 Date: 03 MAY 2018

Part E: Groundwater Monitoring [401 KAR 39:090 1

Section 1 & 40 CFR 264.90(b)(2)] 2

Groundwater monitoring requirements are not applicable. The CSF facility is not a land-based 3

disposal unit. Although the CSF facility will primarily be used for solids there may be a need to 4

store containers with free liquids. Hazard prevention procedures require the use of containment 5

pallets or containment lockers for any containers with free liquids, and these controls provide 6

protection for human health and the environment, eliminating the requirement for groundwater 7

monitoring in the vicinity of the facility. 8

In addition, the CSF facility does not contain any identified solid waste management units 9

(SWMUs) that require groundwater monitoring. 10

11


Rev. 0, Page F-26 Date: 03 MAY 2018

Part F: Procedures to Prevent Hazards [401 KAR 1

39:090 Section 1 and 39:060 Section 5 & 40 CFR 264 2

and 270] 3

This Part contains information concerning procedures to prevent hazards in accordance with 4

Federal and Commonwealth of Kentucky RCRA regulations. These regulations require a 5

description of the security procedures and equipment, inspection schedules, justification for a 6

waiver of preparedness and prevention requirements, spill prevention containment and 7

countermeasures plan, and prevention of accidental ignition or reaction of ignitable, reactive, or 8

incompatible wastes. A request to waive security procedures and equipment requirements is 9

not being made. 10

11

12

: Waiver [401 KAR 39.090 Section 1 & 40 CFR 13

264.14(a)(1) & (2)] 14

Not applicable. Waiver not requested or sought. Paragraph F-1b describes the security 15

measures to be used at the CSF site to prevent hazards to intruders, livestock, workers, or the 16

public. These security provisions prevent physical contact with waste within the active portion of 17

the facility. 18

: Injury to Intruder 19

The security measures (e.g., armed security personnel and authorization to use any necessary 20

force) inside the security controlled area significantly exceed those found at other RCRA 21

permitted storage facilities. As described in the following paragraphs, the fencing and barriers 22

and other security measures control and prevent access of intruders and/or livestock to the CSF 23

and surrounding areas. These measures are more than adequate to prevent injury to 24

unknowing or unauthorized persons or livestock. 25

: Violation of Chapter 39.090 Requirements Caused by Intruder 26

The same security measures to prevent access by unknowing or unauthorized personnel and 27

livestock (i.e., mentioned in F-1a(1) and described in greater detail below also serve to prevent 28

disturbance of waste or equipment at the CSF by an intruder. 29

: Security Procedures and Equipment [401 KAR 30

39:090 Section 1 & 40 CFR 264.14 (b)] 31

The CSF is located inside a fenced and gated security controlled area of the BGAD. Access to 32

this area is restricted and controlled by BGAD security personnel. This security controlled area 33

is patrolled by security personnel 24 hours per day 7 days per week. Entry to the CSF is 34

controlled by locks on the entry ways, key use is restricted to authorized trained personnel only. 35

The RCRA regulations require these measures to prevent unauthorized entry of personnel and 36

livestock. The paragraphs in this Part describe how these requirements are met. 37

: 24-Hour Surveillance System [401 KAR 39:090 Section 1 & 40 38

CFR 264.14(b)(1)] 39

The CSF is not equipped with cameras, however access to the area and the CSF is controlled 40

and restricted to authorized personnel only. The CSF is located in a BGAD restricted area, 41



entry is controlled by armed security personnel. The restricted area is patrolled by armed 1

security personnel 24 hours a day 7 days per week. Entry to the CSF is controlled by locks on 2

the entry ways, key use is restricted to authorized trained personnel only. 3

: Barrier and Means to Control Entry 27 [401 KAR 39:090, Section 4

1 & 40 CFR 264.14(b)(2)] 5

The CSF has both barriers and other means to control entry as part of its security. 6

F-1b(2)(a): Barrier [401 KAR 39:090 Section 1 & 40 CFR 264.14(b)(2)(i)] 7

Barriers prevent entry of unauthorized personnel to the CSF area and locked entry ways 8

prevent access to the CSF by unauthorized personnel or livestock. Examples of the use of 9

these barriers include: 10

• Chain link fencing topped with barbed wire surrounds the BGAD property boundaries 11

and locked entry ways to the CSF and restricted key access prevent unauthorized 12

access to the CSF by unauthorized personnel or livestock. 13

• Fencing is maintained in good repair and entry through the fencing is only provided at 14

access points controlled by security personnel. 15

F-1b(2)(b): Means to Control Entry [401 KAR 39:090 Section 1 & 40 CFR 264.14(b)(2)(ii)] 16

Armed BGAD Security personnel and barriers control access to the BGAD from outside. 17

Security measures for the CSF hazardous waste storage area include: 18

• Six foot high chain link fencing, in good repair around the entire BGAD perimeter 19

• Surveillance by security 24 hours per day, 7 days per week 20

• Warning signs posted at entrances and along perimeter fences to warn personnel and 21

prevent unknowing or unauthorized entry 22

• Entry limited to designated gates, staffed by armed security 23

: Access Limited to Persons and Vehicles Displaying 24

Appropriate Identification: Warning Signs [401 KAR 25

39:090 Section 1 & 40 CFR 264.14(c)] 26

Signs warning, in English, Danger – Unauthorized Personnel Keep Out, are posted to identify 27

the area as restricted and dangerous and that unauthorized entry is illegal, and are posted 28

along the outer perimeter fence surrounding the BGAD at intervals of 500 feet or less and near 29

all access gates. These signs are easily visible at a distance of 25 feet. The legends “Warning, 30

Danger, Restricted Area, and Use of Deadly Force Authorized” to prevent unauthorized entry 31

into the restricted area are clearly legible at distances of 25 feet or more. Additional warning 32

signs are posted at entry ways and each side of the CSF perimeter: “Danger” “Hazardous 33

Waste”, Authorized Personnel Only”, “No Smoking”. 34

35

36

: General Inspection Requirements [401 KAR 37

39:090Section 1, and 39:060 Section 5 & 40 CFR 264.15(a) 38

(b), and 270.14(b)(5)] 39

The scheduled inspections of the CSF area include, but are not limited to, containers, 40

containment devices, safety, emergency, and operating equipment needed to prevent, detect, or 41

respond to environmental or human health hazards. The BGCAPP Main Plant Project 42



Document Control Center (PDCC) maintains the completed inspections and other related 1

documents such as inspection logs. 2

Each inspection record includes: 3

(1) Date and time of inspection 4

(2) Name and signature of inspector 5

(3) Notation of any observations made 6

(4) Repairs made or remedial actions taken at the time of the inspection will be recorded 7

with the observation. 8

If repair or remedial action was to take place following the inspection, it will be tracked using an 9

inspection log. 10

: Types of Problems [401 KAR 39:090 Section 1 & 40 CFR 11

264.15(b)(3)] 12

Figure F-1 (Example Weekly Inspection Form) identifies the criteria used during container 13

storage area inspection. 14

: Frequency of Inspection [401 KAR 39:090 Section 1 & 40 CFR 15

264.15(b)(4)] 16

The "Inspection Frequency" column in Figure F-1 provides the frequency of inspections for 17

containers. Basis for selection of this frequency was the rate of possible deterioration of 18

equipment and the probability of an environmental or human health incident if the deterioration, 19

malfunction, or operator error goes undetected between inspections. The BGCAPP performs 20

weekly inspections of the CSF. 21

: Specific Process Inspection Requirements [401 22

KAR 39:090, Section 1 & 40 CFR 264.15(b)(4)] 23

Inspection requirements are outlined in the subsequent sections. 24

: Container Inspections [401 KAR 39:090 Section 1 & 25

40 CFR 264.174] 26

The BGCAPP conducts weekly inspections of containers in storage areas for deterioration, 27

corrosion, spills, and evidence of leakage. These weekly inspections include a visual inspection 28

for obstructions and proper maintenance of aisle space between the rows of palletized 29

containers. Figure F-1 shows a sample inspection checklist for container inspection activities. 30

: Tank System Inspection [401 KAR 39:090 Section 1 & 31

40 CFR 264.195] 32

Not applicable. The CSF does not have any tank systems. 33

Waste Pile Inspections [401 KAR 39:090 Section 1 & 34

40 CFR 264.254] 35

Not applicable. The CSF does not have any waste piles. 36

: Surface Impoundment Inspections [401 KAR 39:090 Section 1 & 37

40 CFR 264.226] 38

Not applicable. The CSF does not have any surface impoundments. 39

40



: Incinerator Inspections [401 KAR 39:090 Section 1 & 1

40 CFR 264.347] 2

Not applicable. The CSF does not have any incinerators. 3

: Landfill Inspections [401 KAR 39:900 Section 1 & 4

40 CFR 264.303] 5

Not applicable. The CSF does not have any landfills. 6

: Land Treatment Inspections [401 KAR 39:090 Section 1 & 7

40 CFR 264.278] 8

Not applicable. The CSF does not have any land treatment units. 9

: Subpart X Inspections [401 KAR 34:250, Section 6 & 10

40 CFR 264.602] 11

Not applicable. The CSF does not have any subpart X treatment units 12

: Remedial Action [401 KAR 39:090 Section 1 & 40 13

CFR 264.15(b)(5)(c)] 14

Operations personnel conduct inspections of specific areas or equipment based on criteria 15

identified in Figure F-1 and record problems found on the appropriate inspection checklist. Any 16

identified problems are transferred to an inspection log such as the one shown in Figure F-2. 17

This is the log that BGCAPP personnel maintain to track the problems and remedial actions 18

required to resolve the problems/issues identified during routine inspections. 19

: Inspection Log [401 KAR 39:090 Section 1 & 20

40 CFR 264.15(b)(5)(d)] 21

An inspection summary log tracks observations made during inspections. This form includes 22

the following: 23

• Dates and times of inspections 24

• Name(s) of inspector(s) 25

• Observations made 26

• Date and nature of repairs or remedial actions taken 27

Figure F-2 contains an example of an Inspection Log. 28

29

30

31

Not applicable. A waiver of preparedness and prevention requirements is not requested or 32

sought. 33

: Equipment Requirements [401 KAR 39:090 Section 1 34

& 40 CFR 264.32] 35

The CSF will have the following equipment as required by 40 CFR 264.32. 36



: Internal Communications [401 KAR 39:090 Section 1 & 40 CFR 1

264.32(a)] 2

Personnel working in the CSF maintain a communications system consisting of two-way hand-3

held radios. This system provides access to the BGCAPP CON and the facility wide public-4

address system which provides a combination of voice and signal information throughout the 5

facility to employees and BGAD Security. 6

: External Communications [401 KAR 39:090 Section 1 & 7

40 CFR 264.32(b)] 8

Personnel working in the CSF maintain a communications system consisting of two-way hand-9

held radios. This system provides redundant communication channels to summon security, and 10

emergency response from BGAD emergency operations center (EOC). Additional emergency 11

response resources are coordinated through BGAD EOC as needed. 12

: Emergency Equipment [401 KAR 39:090 Section 1 & 13

40 CFR 264.32(c)] 14

Portable fire extinguishers as required by the National Fire Protection Association (NFPA), are 15

located in the CSF and all motorized material handling equipment. Spill kits of sufficient size 16

are maintained for the type and quantities of wastes stored in the CSF storage area. The CSF 17

is equipped with and Exhaust Ventilation System capable of ventilating the CSF in the event of 18

an emergency or off normal event. 19

20

Part G, Appendix G-1 Typical BGCAPP Emergency Response Guide, lists and describes the 21

BGCAPP spill control equipment. 22

: Water for Fire Control [401 KAR 39:090 Section 1 & 23

40 CFR 264.32(d)] 24

Fire hydrant will be located in proximity to the CSF, the fire hydrant system is maintained by the 25

BGAD and readily accessible by responding fire personnel. 26

: Aisle Space Requirements [401 KAR 39:090 Section 27

1 & 40 CFR 264.35] 28

Not applicable. No waiver of the adequate aisle space requirement is required or being 29

requested. 30

31

32

33

The following paragraphs provide information on the procedures, structures, and equipment 34

used to prevent hazards in the BGCAAP Facility. 35

: Loading and Unloading Operations [401 KAR 39:060 36

Section 5 & 40 CFR 270.14(b)(8)(i)] 37

Forklift operators are specifically trained to operate the forklift and use guides to pick up loads, 38

move through congested areas, and place loads. The forklifts are of a size that provides the 39

capacity to handle and transport anticipated loads. 40



: Runoff Prevention [401 KAR 39:060 Section 5 & 40 1

CFR 270.14(b)(8)(ii)] 2

The CSF is designed as a fully enclosed building which prevents runoff from the hazardous 3

waste storage area to other areas of the facility or the environment. 4

: Water Supplies [401 KAR 39:060 Section 5 & 40 CFR 5

270.14(b)(8)(iii)] 6

The storage of hazardous waste at the CSF occurs in an enclosed structure with concrete base, 7

all waste containers containing free liquids and DOT approved containers and stored on 8

containment pallets or containment lockers preventing contamination of water supplies. 9

: Equipment and Power Failures [401 KAR 39:060 10

Section 5 & 40 CFR 270.14(b)(8)(iv)] 11

The CSF is primarily accessed during daylight hours and is equipped with skylights in the roof 12

structure allowing for safe movement in the event of a power failure. 13

: Personnel Protection Equipment [401 KAR 39:060 14

Section 5 & 40 CFR 270.14(b)(8)(v)] 15

The protection of personnel at the CSF involves administrative procedures, and PPE. All 16

containers of hazardous and secondary waste stored at the CSF are DOT specification 17

containers. No containers of secondary waste are opened at the CSF. Selection of PPE will be 18

done IAW procedures and requirements contained in 24915-000-GPE-GGPT-00001, 24915-70-19

GPE-GGPT-00001, and 24915-00-G01-GGPT-00005 (Attachment F – Procedures to Prevent 20

Hazards) submitted to KDEP. 21

: Atmosphere [401 KAR 39:060, Section 5 & 40 CFR 22

270.14(b)(8)(vi)] 23

All containers used for permitted storage of waste in the CSF, from the BGCAPP Main Plant 24

and EDT facilities, will meet applicable U.S. Department of Transportation (DOT) regulations on 25

packaging hazardous materials for transportation as specified in 264.1086(f). Agent-26

contaminated secondary waste containers stored in this facility will not be opened. For all other 27

containers in permitted storage, they will be kept closed except when waste is being added, 28

removed, or accessed for other activities (e.g., sampling) in accordance with 264.1086(c)(3). All 29

containers in permitted storage will be visually inspected as specified in 264.1086(c)(4) and 30

meet applicable documentation and record-keeping requirements (264.1086(c)(5). Additionally, 31

the CSF is equipped with an exhaust ventilation system containing carbon filtration capable of 32

filtering the atmosphere in the CSF in case of any off normal or emergency event that released 33

agent vapor in the CSF. The exhaust ventilation system ensures environmental compliance with 34

KRS 224.1-400(4). 35

36

37

38

See 24915-000-GPE-GGPT-00001, 24915-70-GPE-GGPT-00001, and 24915-00-G01-GGPT-39

00005 (Attachment F – Procedures to Prevent Hazards) submitted to KDEP. 40



: Precautions to Prevent Ignition or Reaction of 1

Ignitable or Reactive Wastes [401 KAR 39:090 Section 1 & 2

40 CFR 264.17 and 264.17(c)] 3

No waste treatment processes take place at the CSF; waste brought to and stored at the CSF is 4

containerized IAW the requirements contained in 24915-000-GPE-GGPT-00001 and 24915-70-5

GPE-GGPT-00001 submitted to KDEP. 6

: Open Flames, Smoking, Welding or Cutting, Heat/Hot Surfaces 7

and Sparks 8

The CSF is located in the BGAD ammunition restricted area which has no smoking or open 9

flames without a permit. Smoking areas exist at specific locations on the facility, posted with 10

signs indicating smoking authorized only in these designated areas. No smoking, cutting, 11

welding, or any other spark producing operations occur without a permit in any hazardous waste 12

storage area with the waste present. Any cutting or welding operations require a "hot work 13

permit." To prevent contact, the CSF is located away from equipment that might produce 14

radiant heat, sparks, frictional heat, or hot surfaces. 15

: Response to Fires 16

The BGCAPP considers a fire in any part of the BGCAPP including the CSF as a serious event 17

requiring immediate attention and corrective action. BGCAPP and EDT personnel do not make 18

any distinction between size and type of fires, all fires are immediately reported and corrective 19

actions instituted. 20

: Fire Protection Systems 21

Fire protection is provided by portable fire extinguishers located in the CSF. These portable fire 22

extinguishers are selected as required by the National Fire Protection Association (NFPA) and 23

placed throughout the facility and at entry/exit points of the CSF. 24

: Chemical Reactions or Detonations 25

No waste treatment processes take place at the CSF, waste brought to and stored at the CSF is 26

containerized IAW the requirements contained in 24915-000-GPE-GGPT-00001 and 24915-70-27

GPE-GGPT-00001 submitted to KDEP. 28

: General Precautions for Handling Ignitable or 29

Reactive Waste and Mixing of Incompatible Waste [401 30

KAR 39:090 Section 1 & 40 CFR 264.17(a) and (b)] 31


: Management of Ignitable or Reactive Wastes in 33

Containers [401 KAR 39:090 Section 1 & 40 CFR 264.176] 34

Containers holding ignitable wastes are located more than 15 meters (50 feet) from the BGAD 35

facility property line. The BGCAPP and EDT facilities do not expect to generate liquid reactive 36

wastes for storage in containers. However, should this occur, the containers of reactive waste 37

would be placed on a containment pallet separated from other wastes by a distance of at least 4 38

feet, and located more than 50 feet from the BGAD facility property line. Storage is within the 39

boundaries set forth in 40 CFR 270.15(c) and 264.176 and details of the management of these 40

wastes are provided in section D-1a, Container Management (401 KAR 39:190 Section 1 and 41

39:060 Section 5 & 40 CFR 264.170–179 and 270.15) of 24915-000-GPE-GGPT-00001 42



BGCAPP RCRA RD&D Permit Application and section D-1, Containers of 24915-70-GPE-1

GGPT-00001 Explosive Destruction Technology permit modification request. The containment 2

pallets and containment lockers have a secondary containment capacity of at least 55 gallons. 3

That is more than 10 percent of the maximum storage capacity of the containers on the 4

containment pallet and equal to or greater than a single 55-gallon drum. 5

: Management of Incompatible Wastes in Containers 6

[401 KAR 39:090 Section 1 & 40 CFR 264.177(a) and (b), 7

264.17(b) and (c)] 8

The BGCAPP and EDT facilities are not expected to generate hazardous waste that are 9

incompatible with each other. Incompatible wastes, if generated, are not stored together in the 10

same container. BGCAPP personnel wash empty containers before reusing if the containers 11

may have previously contained wastes incompatible with new wastes being placed into the 12

container. If questions arise about whether wastes are compatible, the BGCAPP conducts 13

laboratory incompatibility determinations prior to storing containers near each other or storing 14

potentially incompatible wastes within the same container. Incompatible wastes in separate 15

containers are stored in separate containments or stored (if liquid) on separate containment 16

pallets or containment lockers. 17

: Management of Ignitable or Reactive Wastes in 18

Tanks [401 KAR 39:090 Section 1 & 40 CFR 264.198] 19

Not applicable. The CSF does not use facility tank systems. 20

: Incompatible Wastes in Tanks [401 KAR 394:090, 21

Section 1 & 40 CFR 264.199] 22

Not applicable. The CSF does not use facility tank systems. 23

: Ignitable/Reactive Wastes for Waste Piles [401 KAR 24

39:090 Section 1 & 40 CFR 264.256 and 264.17(b)] 25

Not applicable. The CSF does not use waste piles. 26

: Incompatible Wastes in Waste Piles [401 KAR 27

39:090 Section 1 & 40 CFR 264.257 and 264.17(b)] 28

Not applicable. The CSF does not use waste piles 29

: Ignitable/Reactive Wastes in Surface Impoundments 30

[401 KAR 39:090 Section 1 & 40 CFR 264.229 and 31

264.17(b)] 32

Not applicable. The CSF does not use surface impoundments. 33

: Incompatible Wastes in Surface Impoundments [401 34

KAR 39:090 Section 1 & 40 CFR 264.230 and 264.17(b)] 35

Not applicable. The CSF does not use surface impoundments. 36



: Ignitable/Reactive Wastes in Landfills [401 KAR 1

39:090 Section 1 & 40 CFR 264.304 and 264.17] 2

Not applicable. The CSF does not use landfills. 3

: Incompatible Wastes in Landfills [401 KAR 39:090 4

Section 1 & 40 CFR 264.312] 5

Not applicable. The CSF does not use landfills. 6

: Liquid Wastes in Landfills [401 KAR 39:090 Section 7

9 & 40 CFR 264.313] 8

Not applicable. The CSF does not use landfills 9

: Special Requirements for Containers Disposed in 10

Landfills [401 KAR 39:090 Sections 1 & 40 CFR 264.314 11

and 264.315] 12

The BGCAPP does not operate a landfill but, as a generator, plans to use approved commercial 13

landfills for disposal in a limited number of instances, to include disposal of: 14

A. Empty containers (i.e., crushed or volume reduced) 15

B. A limited number of agent-derived wastes composed of solid wastes meeting 16

treatment standards and having a headspace reading of less than 1 vapor screening 17

level (VSL); these agent-derived wastes are screened using headspace monitoring prior 18

to shipment off site for disposal, and results of this monitoring are less than 1 VSL or the 19

waste is not disposed of in a landfill (Part C includes a description of headspace 20

monitoring methods and Army Decontamination levels that will be used) 21

C. Waste containers of material meeting treatment standards packed with sorbents 22

to eliminate the possibility of free liquids 23

D. Closure debris and wastes (e.g., demolition waste from which any residual 24

chemical agent or industrial hazards have been mitigated) in accordance with the 25

Closure Plan. 26

The BGCAPP does not dispose of lab packs in landfills and uses alternative forms of 27

treatment/disposal (e.g., incineration). 28

: Ignitable or Reactive Wastes in Land Treatment 29

Units [401 KAR 39:090 Section 1 & 40 CFR 264.281 and 30

264.17(b)] 31

Not applicable. The CSF does not operate land treatment units. All hazardous waste is 32

shipped to an appropriately permitted, commercial TSDF for final disposal. 33

: Incompatible Wastes in Land Treatment Units [401 34

KAR 39:090 Section 1 & 40 CFR 264.282] 35

Not applicable. The CSF does not operate land treatment units. All hazardous waste is 36

shipped to an appropriately permitted, commercial TSDF for final disposal. 37



Figure F-1: Example Weekly Inspection Form 1

2



Figure F-2: Example Inspection Log 1

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