REPLY TO ATTENTION OF:

SFAE-ACW-BG

DEPARTMENT OF THE ARMY ASSEMBLED CHEMICAL WEAPONS ALTERNATIVES FIELD OFFICE

BLUE GRASS CHEMICAL AGENT-DESTRUCTION PILOT PLANT 830 EASTERN BYPASS SUITE 106

RICHMOND, KENTUCKY 40475-2512

MEMORANDUM FOR RECORD

24 April 2014 ACW-14-0039

SUBJECT: Blue Grass Chemical Agent-Destruction Pilot Plant (BGCAPP) Meeting with Explosive Destruction Technology (EDT) Working Group (EDTWG) Members

1. Summary: On 4 March 2014, the BGCAPP team and the EDTWG, a sub-committee of the Kentucky Chemical Destruction Community Advisory Board (CDCAB), met to discuss the Explosive Destruction Technology (EDT) permitting status. In attendance were the following: Robert Blythe, CDCAB; Steve Bragg, Bechtel Parsons Blue Grass (BPBG); Jeff Brubaker, BGCAPP; Joe Elliott, Blue Grass Army Depot (BGAD); Neil Frenzl, BPBG; Doug Hindman, Kentucky Chemical Demilitarization Citizens' Advisory Commission (CAC); Terry House, CDCAB; Scott Jackson, CDCAB; Leslie Kaylor, CDCAB; John McArthur, BPBG; Sarah Parke, BGCAPP; Stephanie Parrett, BGCAPP; Chasity Pearson, Blue Grass Chemical Activity (BGCA); George Rangel, BPBG; Allison Respess, BPBG; Richard Shelton, Baptist Health; Daniel Walker, Kentucky Department for Environmental Protection (KOEP); Waymond Eddie Whitworth, BGCA and Craig Williams, CDCAB.

2. Actions: Brubaker noted Static Detonation Chamber (SOC) design information will be shared with the EDTWG as soon as it is received and reviewed. Additionally, permitting documents will be provided to the group on or before the date it is submitted to KOEP. Brubaker asked anyone interested in going on the Anniston, AL, trip to view the SOC to confirm by 6 March 2014.

3. Presentations: Frenzl, McArthur and Respess delivered a presentation on the implementation of EDT for mustard projectiles, which included information on the preliminary schedule, permitting process, key engineering attributes for permits, mass and energy balance and SOC pollution control system.

4. Discussion Topics:

a) Brubaker opened the meeting by welcoming the group and saying the permit modification request documents will be sent to EDTWG members as soon as they are reviewed by BGAD and BGCA. This will occur the same day or before the documents are submitted to KOEP to kick off the 60-day comment period. The following questions were asked:

b) Williams asked if the submission to KOEP is a modification to an existing permit and the projected date of submission. Brubaker said it is a modification to the Resource Conservation and Recovery Act (RCRA) Part B, Class Ill permit and the submission is expected in mid­March. McArthur noted there will be an announcement on the date of submission and documents will be available in the information repositories at that time.

SFAE-ACW-BG SUBJECT: Blue Grass Chemical Agent-Destruction Pilot Plant Meeting with Explosive Destruction Technology Working Group Members

c) Respess then began the presentation by reviewing EDT background information. She went over a preliminary SDC operations schedule and iterated the schedule could change. She pointed out the SDC system design work could continue until December 2014. McArthur highlighted the permit process schedule, showed a flow chart of activities and pointed out where the project stood in the process. He told EDTWG members the project was at the point where they were waiting for BGAD and BGCA to review RCRA Part B, Class Ill permit modification request documents and recommend the BGAD commander sign the transmittal letter. He also noted no public meeting is required for Title V modifications but said information on the modification request is available for the public to review. Frenzl highlighted mass energy and balance. He noted when the project reaches 100 percent design, the information will be resubmitted to the permit modification request. McArthur noted the design process involves regulators at the 30, 60, 90 and 100 percent design phases. The BPBG team ended their presentation by showing photos of other SDCs. The following questions were asked:

d) Williams asked if the permit documents submitted to KDEP were considered a draft format. McArthur said, when submitted, the documents were considered a formal request, not a draft. Kaylor asked if the Title V permit modifications would affect the existing permit. McArthur said no, it was only a modification.

e) Williams asked, based on the preliminary schedule, how construction could start before the permit is approved. McArthur said KOEP will review the information and if it's sufficient, will issue a temporary authorization request. House asked if there was a possibility for the permitting process to become open-ended. McArthur said the regulators drive the schedule, but the process is set up to develop a mutually agreeable permit.

f) Williams asked if data from the Anniston SDC was used in the design process. McArthur indicated information from Anniston was used. Williams asked why it was taking so long to receive further details from UXB when the amount of data from Anniston is so great. McArthur said it is mostly due to upgrades the BGCAPP team is incorporating into the Blue Grass SDC based upon information from the Anniston system, specifically the pollution control technology.

g) Several EDTWG members asked if KDEP was aware of the amount of paperwork that would soon be submitted since BGAD is also renewing other permits. McArthur said KDEP is fully on board. Williams asked Walker if KOEP had adequate support and staffing. Walker indicated they do.

h) Williams also asked if the munitions destroyed at Anniston were the same as at Blue Grass. Brubaker indicated Anniston destroyed mustard projectiles, mortars and some overpacks. Williams asked if the same type of SDC had been used elsewhere. B ragg said Anniston's SDC is similar and the SDC had been in use in Europe for quite some time. Williams was pleased to know a great deal of data exists and since the SDC was used in the United States, it fulfills Kentucky law requirements. The group asked if it would be possible to use the SDC for conventional munitions at the depot. Brubaker indicated the environmental assessment only covered mustard munitions. EDTWG members expressed interest in exploring options for SDC use at BGAD in the future.

i) Hindman asked if the difference between the Anniston SDC and Blue Grass SDC would primarily concern pollution control. McArthur indicated the pollution control system to be deployed at Blue Grass included upgrades.

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SFAE-ACW-BG SUBJECT: Blue Grass Chemical Agent-Destruction Pilot Plant Meeting with Explosive Destruction Technology Working Group Members

j) Walker asked about the configuration of the Department of Transportation bottles. Bragg said they looked like a scuba gear bottle and had a test pressure rating of 3000 pounds per square inch. Since Anniston did not process these types of bottles, the contractor will be required to do testing. Kaylor asked if the Blue Grass SOC would need an upscale unit since more munitions would be processed as opposed to Anniston. Bragg said there will be an upgraded pollution control system and throughput demands should meet the requirements.

5. Conclusion: The meeting was conducted to provide a status update and next steps regarding the EDT permitting process. The meeting was held prior to the 12 March 2014 CAC/CDCAB meeting. BPBG will continue to provide updates, schedules and permitting information to the group as it becomes available.

r/dA ___ / JEFFREY L. BRUBAKER Site Project Manager Blue Grass Chemical Agent-Destruction Pilot Plant

sp/dbp

CF: BGCAPP Document Control

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