FINAL  BEST  DEMONSTRATED  AVAILABLE TECHNOLOGY  (BDAT)
               BACKGROUND DOCUMENT FOR K046  (ADDENDUM)
                           Larry Rosengrant, Chief
                        Treatment Technology Section
                                 Elaine Eby
                               Project Manager
                    U.S. Environmental  Protection Agency
                            Office of Solid Waste
                             401 M Street,  S.V.
                           Washington, D.C.  20460
                                  May  1990
Hote: This background doctsaeat is a proposed addendum to the August 1988 Final Brat Demonstrated
     Available Technology (BOAT) Background Document Cor K046.

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                            ACKNOWLEDGEMENT

    This document was prepared for the U.S.  Environmental Protection
Agency, Office of Solid Waste, by Versar Inc.  under Contract No.
68-W9-0068.  Mr. Larry Rosengrant, Chief, Treatment Technology Section,
Waste Treatment Branch, served as the EPA Program Manager during  the
preparation of this document and the development of treatment standards
for the K046 nonwastewater in the reactive subcategory,  and all K046
wastewaters. The technical project officer for the waste was Ms.  Monica
Chatmon-McEaddy.  Mr. Steven Silverman served as legal advisor.

    Versar personnel involved in the preparation of this document
included Mr. Jerome Strauss, Program Manager;  Mr.  Stephen Schwartz,
Assistant Program Manager; Mr. Amanjit Paintal,  Staff Engineer;
Ms. Justine Alchowiak, Quality Assurance Officer;  Ms.  Juliet Crumrine,
Technical Editor; and the Versar secretarial staff, Ms.  Sally Gravely.

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                           TABLE OF CONTENTS


Section                                                              Page

1.   INTRODUCTION AND SUMMARY 	      1-1

2.   INDUSTRY AFFECTED AND WASTE CHARACTERIZATION 	      2-1

    2.1  Industry Affected and Process Descriptions 	      2-1
    2.2  Waste Characterization 	      2-4
    2.3  Determination of Waste Treatability Groups 	      2-5

3.   APPLICABLE AND DEMONSTRATED TREATMENT TECHNOLOGIES 	      3-1

    3.1  Applicable Treatment Technologies 	      3-1
    3.2  Demonstrated Treatment Technologies 	      3-2

         3.2.1  Nonwastewaters 	      3-2
         3.2.2  Wastewaters 	      3-3

4.   PERFORMANCE DATA 	      4-1

5.   DETERMINATION OF BEST DEMONSTRATED AVAILABLE TECHNOLOGY
    (BDAT) FOR K046 	      5-1

6.   SELECTION OF REGULATED CONSTITUENTS 	      6-1

7.   CALCULATION OF BDAT TREATMENT STANDARDS 	      7-1

8.   REFERENCES 	      8-1
    APPENDIX A - DETERMINATION OF NONREACTIVE AND REACTIVE
    FORMS OF K046 	      A-l
                                    ii

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                             LIST OF TABLES


                                                                     Page

Table 1-1  BOAT Treatment Standards for K046 Wastes 	 1-3

Table 2-1  Generators of K046 Wastes  	 2-2

Table 2-2  Characterization Data for K046 Wastes 	 2-6

Table 2-3  Characterization Data for K046 Wastes Providing
           Range of the Regulated Constituent an Design
           Parameters for Nonwastewaters and Wastewaters 	 2-8

Table 4-1  Performance Data for Stabilization Using Portland Cement
           on K046 Nonreactive Nonwastewater 	 4-3

Table 4-2  Performance Data for Alkaline Precipitation,  Settling,
           and Filtration of a Mixed K062, D007, and D008
           Wastewater 	 4-4

Table 7-1  Calculation of Treatment Standards for K046 Reactive
           Subcategory Nonwastewaters 	 7-2

Table 7-2  Calculation of Treatment Standards for K046 Wastewaters,
           Reactive and Nonreactive Subcategories 	 7-3
                                    iii

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                     1.   INTRODUCTION AND SUMMARY

    Pursuant to section 3004(m) of the Resource Conservation and Recovery
Act (RCRA) as enacted by the Hazardous and Solid Waste Amendments (HSWA)
on November 8, 1984, the Environmental Protection Agency (EPA) is
establishing best demonstrated available technology (BOAT) treatment
standards for the listed waste identified in 40 CFR 261.32 as K046
(wastewater treatment sludges from the manufacturing, formulation, and
loading of lead-based initiating compounds).  If the treatment standards
presented in this document are promulgated, compliance will be a
prerequisite for placement of certain types of K046 waste in units
designated as land disposal units according to 40 CFR Part 268.  The
effective date of these treatment standards would be June 9, 1990.

    In August 1988, EPA established two subcategories for K046 waste--
reactive and nonreactive--and promulgated a treatment standard for non-
wastewaters in the nonreactive subcategory (see 53 FR 31138, August 17,
1988) .  The development of that treatment standard was described in the
BDAT background document for the K046 nonreactive subcategory (USEPA
1988a).  The treatment standard, a concentration-based standard for lead,
was based on performance data from stabilization of a nonreactive K046
waste.

    This final document is an addendum to the 1988 background document,
it provides technical support for the promulgated treatment standards for
K046 nonwastewaters in the reactive subcategory and for all K046
wastewaters.  For the purpose of determining the applicability of the
treatment standards, wastewaters are generally defined as wastes
containing less than 1 percent (weight basis) total suspended solids* and
*The term "total suspended solids" clarifies EPA's previously used
 terminology of "total solids" and "filterable solids."  Specifically,
 the quantity of total suspended solids is measured by Method 209C (Total
 Suspended Solids Dried at 103 to 105°C) in Standard Methods for
 the Examination of Water and Wastewater, 16th Edition (APHA, AWWA, and
 WPCF 1985).
                                    1-1
31BOg

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less  than  1 percent  (weight basis)  total organic  carbon.  Wastes not
meeting  this definition  are considered nonwastewaters  (USEPA  1989a).

    The  Agency  is promulgating concentration-based standards  for lead  in
the K046 wastes of interest.  For the reactive subcategory nonwastewaters,
the BDAT is deactivation followed by stabilization using Portland cement
as a  binder.  The lead standard  itself is based on data transferred from
stabilization of a K046  nonreactive subcategory nonwastewater.  For K046
reactive subcategory wastewaters, the BDAT is deactivation followed by
alkaline precipitation and then  settling and filtration.  For the K046
nonreactive subcategory  wastewaters, the proposed BDAT is alkaline
precipitation followed by settling and filtration.  The lead standard for
both  types of wastewaters is based on data transferred from treatment of
a mixed  K062, D007, and  D008 metal-containing waste, which is thought to
be similar to the K046 wastewaters.

    Table 1-1 presents treatment standards for K046 wastes.  The
treatment standard for all K046 wastewaters is expressed in mg/1 (parts
per million on a weight-by-volume basis).  The treatment standard for all
nonwastewaters reflects  the concentration of lead in the leachate from
the Toxicity Characteristic Leaching Procedure (TCLP), and the units are
mg/1.  If the concentrations of  lead in K046 wastes, as generated, are
lower than or equal to the BDAT  treatment standards when promulgated,
then  treatment is not necessary  as a prerequisite to land disposal.
                                    1-2
3180g

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            Table  1-1  BDAT Treatment Standards for K046 Wastes

Maximum for
anv sinele
Nonwastewaters
Subcategory Constituent
Reactive Lead
Nonreactive Lead
Total composition
(mg/kg)
N/A
N/A
TCLP
(mg/D
0.18a
0.18b
crab sample
Wastewaters
Total composition
(mg/1)
0.037a
0.037a
N/A - Not applicable.

aThese treatment standards are being promulgated in May 1990 under the
 Third Third Final rule.
bThis treatment standard was promulgated in August 1988 (53 FR 31138,
 August 17, 1988).
                                    1-3
3180g

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         2.   INDUSTRY AFFECTED AND WASTE CHARACTERIZATION

    As described in 40 CFR 261.32, K046 wastes are "wastewater treatment
sludges from the manufacturing, formulation and loading of lead-based
initiating compounds."  This section discusses K046 wastes,  their
generation, and the industry affected by the land disposal restrictions
that apply to them.

2.1      Industry Affected and Process Descriptions

    K046 wastes are generated by the explosives industry,  which is
identified by the standard industrial classification (SIC) code 2892.
SIC code 2892 facilities include both commercial firms and government-
owned plants operated by private firms.  In the August 1988  background
document that supported the K046 treatment standard of the First Third
rule (USEPA 1988a), the Agency estimated that 62 facilities  in the United
States were actively involved in the manufacture or use of lead-based
initiating compounds and thus were potential generators of K046 wastes.
The estimation was based on information retrieved in January 1987 from
EPA's Hazardous Waste Data Management System (HWDMS) data  base.  More
recent information developed by the EPA, Office of Solid Waste Listing
Program indicates that only nine facilities manufacture and/or use
lead-based initiating compounds and generate K046 wastes (Versar 1987a).
Seven of these facilities manufacture lead-based initiating  compounds and
use them onsite for production of finished explosive products such as
ammunition, blasting caps, and primers.  The two other facilities
purchase and use the compounds to produce finished explosive products.
Table 2-1 lists the nine facilities along with their locations, products,
and operations.

    Lead-based initiating compounds are produced by reacting in aqueous
solution a soluble lead salt with a soluble salt of an explosive anion.
There are three major lead-based initiating compounds:  lead azide, lead
                                    2-1
334 9g

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                     Table 2-1  Generators of K046 Wastes
Company
Facility location
Products and  operations
E.  I. Du  Pont
Remington Arms Co.,
  Inc.  (E.I. Du Pont)

Remington Arms Co.,
  Inc.  (E. I. Du Pont)

Atlas Powder Co.
Pompton Lakes,  NJ


Bridgeport, CT


Lonoke,  AR


Tamaqua,  PA
IRECO Inc.                Port Ewen, NY

Ensign-Bickford Co.       Simsbury, CT

Federal Cartridge Corp.   Anoka, MN
01in Corp.
U.S. Army Lake City
  Ordnance Plant
East Alton,  IL
Independence,  MO
Lead azide, blasting
  cap production

Lead styphnate,
  ammunition

Lead styphnate,
  ammunition

Lead mononitroresor-
  cinate, fuses

Blasting cap production

Blasting cap production

Lead styphnate,
  ammunition

Lead azide, lead styph-
  nate, ammunition

Ammunition
Reference:  Questionnaire responses from industry, collected under
            authority of Section 3007 of RCRA, as reported in Versar 1987a.
                                    2-2
33498

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styphnate, and lead mononitroresorcinate.  Their manufacturing processes

and the subsequent generation of K046 waste are summarized below.


    •  Lead azide manufacturing - A soluble azide salt is reacted with
       a soluble lead salt in aqueous solution.  The product precipitates
       from solution, is collected by filtration, and then is washed,
       dried, and packaged.  Process wastewaters are collected and
       treated with sodium nitrite and sodium carbonate to convert any
       lead azide present to lead carbonate and to destroy any azide
       ions.  The resulting lead carbonate sludge is a K046 waste.

    •  Lead styphnate manufacturing - A soluble styphnate salt is
       reacted with a soluble lead salt in aqueous solution.  The product
       precipitates from solution, is collected by filtration, and then
       is washed, dried, and packaged.  Process wastewaters are collected
       and treated with sodium sulfide and sodium hydroxide to
       precipitate lead as the sulfide and to destroy any remaining
       styphnate ions.  The resulting sulfide sludge is a K046 waste.

    •  Lead mononitroresorcinate products - A soluble mononitro-
       resorcinate is reacted with a soluble lead salt in aqueous
       solution.  The product precipitates from solution, is collected by
       filtration, and then is washed, dried, and packaged.  The
       wastewaters are collected and treated with sodium sulfide to
       destroy any mononitroresorcinate ions present and to precipitate
       lead as the sulfide.  The resulting sulfide sludge is a K046 waste.


    One of the facilities listed in Table 2-1 generates K046 from a
fourth lead based initiator production process.  This waste is

contaminated with the molecular explosive tetracene.  The wastewater

sludge is chemically deactivated in a hot water bath with hydrogen
sulfide (H2S) to form a lead sulfide precipitate and a biodegradable

dissolved organic compound.  The sulfide reduces the nitro group to amine

group.  The amine group is then biodegradable.


    K046 waste is also generated by load, assemble, and pack (LAP)
operations.   The lead-based initiating compounds and other components are

fabricated into ammunition, primers, and blasting caps during LAP
operations.   Washdown waters from areas used for these operations are

either treated to precipitate lead and destroy any explosive ions present
or left undisturbed to allow any residues to settle out.  The sludge

separated from these "operations" is a K046 waste.


                                    2-3
33*98

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     Filtrates  and  supernatants  separated from the  K046  sludges identified
above  are  also K046 wastes  under  the  "mixture"  and "derived-from"  rules.
According  to comments  received  on the proposed  First Third rule and
responses  to questionnaires that  were distributed  under the authority  of
Section  3007 of RCRA  (Versar 1987a),  these  filtrate and supernatant
wastes are typically discharged to POTWs  or surface waters under an NFDES
permit,  at which point they become subject  to the  requirements of  the
Clean Water Act.

2.2      Waste Characterization

     Characterization data for K046 is shown in Table 2-2,  lead
concentrations is  the  predominant toxic metal in K046 wastes,range  from
as low as  0.59 ppm to  as high as  197,500  ppm.  Other BDAT  list metals are
not  consistently present at concentrations  above 10 ppm.   The  wastes have
few  organic components; no  BDAT list  volatile or semivolatile  organic
constituents have  been detected in the sampled wastes,  and the total
organic  carbon content is less  than 500 ppm.  Assuming  that organics
concentrations are negligible,  percent water  and total  solids  values
should add to  100  percent.

     In all cases,  not  enough information  is available to ascertain
whether  the wastes are technically nonwastewaters or wastewaters.  The
Source 5 waste, however, is identified as a supernatant from treatment
tanks from which settled K046 sludge  is removed, and thus  it is  likely a
wastewater.  The Source 4 waste also  appears  to be a wastewater, based on
its  low  total  solids content (1.5  percent).  Total solids  concentrations
for  the  tentatively identified  nonwastewaters (Sources  1,  2, 3,  and 6)
range from 1.3 to  63 percent.   Therefore, the nonwastewaters have water
concentrations ranging from 37  to almost  99 percent.  The  tentatively
identified wastewaters  (Sources 4 and 5)  have total solids  (disolved plus
suspended) concentrations ranging from 1.5  to 20 percent and thus water
concentrations of  88 to almost  99  percent.
                                    2-4
33*9g

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2.3      Determination of Waste Treatabilitv Groups

    Sometimes  in the  treatment of the wastewaters from which K046 wastes
are generated, not all reactive components are adequately deactivated.
Thus, to distinguish  those wastes that are reactive as initially
generated from those  that are not, the Agency has divided K046 wastes
into two subcategories, reactive and nonreactive.  Treatment residuals
and other "mixed" and "derived-from" K046 wastes are considered to be in
the reactive subcategory if the K046 waste from which they are derived is
reactive as initially generated.

    As discussed in the preamble to the First Third Final rule,
reactivity is  to be determined by a testing protocol developed by the
Department of  Defense.  Although this protocol does not contain official
Office of Solid Waste analytical methods, the Agency believes that the
protocol represents logical and safe analytical procedures for
determining the characteristic of reactivity.  This testing protocol is
presented in Appendix A.

    Both reactive and nonreactive K046 wastes are further subcategorized
into nonwastewaters and wastewaters for the purpose of determining the
applicability  of the  BOAT treatment standards.  (See Section 1 for
definitions of nonwastewaters and wastewaters.)  Characterization data
for various K046 wastes are presented in Table 2-2.

    Note that  the Agency believes that none of the characterization data
in Table 2-2 represent K046 reactive subcategory wastes (i.e., Analytical
laboratories do not normally handle reactive samples for safety
reasons).  However, because the treatment processes that first generate
K046 wastes, whether  reactive or nonreactive, are similar (the aim being
to precipitate out lead in a nonreactive form while destroying explosive
ions), the Agency believes that reactive K046 wastes, after deactivation
by specialized incineration, will be similar to their nonreactive
nonwastewater  or wastewater counterparts.  This subject is discussed
further in Sections 3 and 4.
                                    2-5
3349g

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3352g
                                                       Table 2-2  Characterization Data for K046 Wastes
Concentration (DOT. unless noted otherwise)
Source 1
Const ituent/parameter
BOAT list metals
Ant imony
Arsenic
Bar inn
Beryl liim
Cadmium
Chromium, total
Copper
Lead
Hercury
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
Total

0.022
<0.010
<0.200
<0.005
<0.010
<0.020
<0.025
967
0.00084
<0.040
<0.005
<0.050
<0.010
<0.050
0.295
TCLP

<0.020
<0.010
0.228
<0.005
<0.010
<0.020
<0.025
103
<0.0003
<0.040

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         3352g
10
-j
                                                                             Table 2-2   (continued)
Concentration (DOT. unless noted otherwise)

Const ituent /parameter
Other parameters
Water (X)
0 i 1 and grease
Sulfate
Total organic carbon
pH
Total solids (X)
Total dissolved solids
Chloride
Source 1
Total TCLP

95 NA
3.8 NA
190 NA
461 NA
11.91 NA
NA NA
NA NA
NA NA
Source
Total

NA
NA
169-698
253-288
12.65-13.42
1.3-10.9
10.200-44.000
908-3.140
2 A
TCLP

NA
NA
NA
NA
NA
NA
NA
NA
Source
Total3

NA
NA
NA
NA
NA
24.5-63.1
NA
NA
3
TCLP

NA
NA
NA
NA
NA
NA
NA
NA
Source
Total3

NA
NA
NA
NA
NA
1.5
NA
NA
4 Source 5 Source 6
TCLP Total Total

NA . - 95
NA
NA -
NA -
NA 7.2-13.1
NA 4.78-20
NA -
NA
         aData are reported on a wet weight basis.

         NA = Not analyzed.
         -  = No available data.
         References:

         Source 1.
         Source 2.
         Source 3.
         Source 4.
         Source 5.
         Source 6.
USEPA 1988a. Tables 2-3 and 2-4.
USEPA 1988d. LDRS-Reference 70.
Versar 1987a. Table 5-1. Versar 1987b.  Field nos.  18439-18452.
Versar 1987a, Table 5-1. and Versar 1987b.  Field nos.  18453-18457.
USEPA 1988d. LORS-References 59 and 69.
Environ 1985. K046 data. Tables 1  and 2.

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 3352g
                          Table 2-3  Characterization Data for K046 Wastes Providing
                           Range of the Regulated Constituent and Design Parameters
                                      for Nonwastewaters and Wastewaters
                                                      Monwastewaters                     Wastewaters
                                        Total
Parameters                           Concentration             TCLP               Total  Concentration
Lead                                 27-197.500                0.058-1870          0.059-200
Water X                              95                                           NA
Oil and grease                       3.8
Total organic carbon                 253-461
pH                                   11.91-13.42                 -                7.2-13.1
Total solids X                       1.3-63.1                    -                1.5-20
Source:  Table 2-2

NA = Not applicable.
-  - Hot available.
                                                     2-8

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     3.   APPLICABLE AND DEMONSTRATED TREATMENT TECHNOLOGIES

    This section identifies the treatment technologies that are
applicable to K046 wastes and determines which,  if any,  of the applicable
technologies can be considered demonstrated for the purposes of
establishing BDAT.

    To be applicable, a technology must theoretically be usable to treat
the waste in question, or to treat a waste that is similar in terms of
the parameters that affect treatment selection.   To be demonstrated,  the
technology must be employed in full-scale operation for the treatment of
the waste in question or a similar waste.  Technologies available only at
research facilities or in pilot- and bench-scale operations are not
considered in identifying demonstrated technologies.

    As discussed in Section 2, K046 wastes have been divided into
reactive and nonreactive subcategories.  The  difference between the two
types of wastes is that reactive subcategory  wastes are reactive
according to the testing protocol presented in Appendix A.   Both types of
wastes, however, contain metals and thus require treatment for metals.

3.1      Applicable Treatment Technologies

    Applicable technologies for reactive K046 wastes include deactivation
followed by metals treatment.  Deactivation for nonwastewaters may entail
chemical treatment, or specialized incineration.  Stabilization
technologies using various binder materials (e.g., Portland cement,
lime/fly ash, and kiln dust) are applicable for treating metals in the
deactivated nonwastewaters (see K046 Background Document,  August 1988).
Wastewaters can be deactivated by a variety of chemical treatments (e.g.,
adding carbonate and nitrite salts to a wastewater containing lead
azide).  The deactivated wastewaters can then be treated by alkaline
precipitation followed by settling and filtration to remove metals.

                                    3-1
3622g

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    Applicable  technologies  for  creating metals  in K046  nonreactive
wastes  are  the  same  as  those identified for  the  reactive wastes  after
deactivation, i.e.,  stabilization  technologies for nonwastewaters  and
alkaline  precipitation  followed  by settling  and  filtration for
wastewaters.

    As  discussed in  the August 1988 background document  for K046
nonreactive subcategory wastes,  metals  recovery  was not  judged to  be
applicable  because of the  relatively  low metals  content.

3.2       Demonstrated Treatment  Technologies

3.2.1     Nonwastewaters

    EPA believes that "list"  technologies for deactivation
of K046 reactive subcategory nonwastewaters  are  demonstrated.  Chemical
treatment employing  a variety of chemical reagents  is used on a
full-scale  basis to  eliminate the  reactivity of  "pre-K046"  wastewaters,
i.e., the reactive wastewaters from the  manufacture or use  of lead-based
initiating  compounds from  which  K046 wastes  are  initially  generated.
Reactive  K046 nonwastewaters  can be slurried so  that they  are amenable to
the same  treatment as these  "pre-K046" wastewaters.  Therefore, chemical
treatment is a  demonstrated  deactivation technology for  K046 reactive
subcategory nonwastewaters.

    Specialized incineration  is  being used full-scale on a  variety of
explosive-containing wastes  (see the Final BOAT  Background  Document for
Characteristic  Ignitable Wastes  (D001),  Characteristic Corrosive Wastes
(D002), Characteristic  Reactive  Wastes  (D003), and F and U  Wastes
containing  Reactive Listing  Constituents  (USEPA  1990c)).   Because  the
Agency  believes  that these explosive-containing  wastes are  sufficiently
similar to  K046  reactive nonwastewaters  in terms of reactivity
characteristics,  specialized  incineration also is  considered demonstrated
for the K046 wastes.

                                    3-2
3622g

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    The August  1988 background document for K046 already established
stabilization technologies as demonstrated for metals in K046 nonreactive
subcategory nonwastewaters.  Because the Agency believes that K046
reactive  subcategory nonwastewaters, once deactivated, will be no more
difficult to treat than  the nonreactive wastewaters for which treatment
data are  available.  This belief  is based on the premise that K046
wastes, whether reactive or nonreactive as initially generated, are
produced  by the manufacture/use of lead-based initiating compounds and
that the  techniques and  components used in the manufacture/use do not
vary such that  they have an effect on the performance of stabilization.
Lacking evidence  that would disprove this belief, EPA has determined that
stabilization technologies are demonstrated for treating metals in K046
reactive  subcategory nonwastewaters.  (For a detailed description of
stabilization technologies, see EPA's Treatment Technology Background
Document  (USEPA 1989b).)

3.2.2     Vastevaters

    The Agency  knows of no full-scale technologies being used to
deactivate K046 reactive wastewaters.  However, in the generation of K046
wastes (as mentioned above), reactive wastewaters from the manufacture
and use of the  lead-based initiating compounds are being treated by
various forms of  chemical deactivation on a full-scale basis.  The Agency
believes  that these "pre-K046" wastewaters, though likely more difficult
to treat, are similar to true K046 reactive wastewaters in that they are
expected  to contain the same types of reactive ions that are amenable to
chemical  deactivation.  Thus, chemical deactivation is considered
demonstrated for  K046 reactive subcategory wastewaters.

    The Agency  has not identified any facilities that definitely use
alkaline  precipitation followed by settling and filtration to remove
metals from K046  wastewaters.  (The K046 wastewaters generated
concurrently with the K046 sludges are typically discharged to POTWs and
                                    3-3
36226

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surface waters under NPDES  permits  and possibly  are  being treated  by
these  technologies.)  This  treatment, however,   is demonstrated for other
wastewaters that are similar  to K046 wastewaters in  terms of  available
information on metals content and other factors  that would affect
selection of treatment.  For  example, this treatment has  been
demonstrated for a mixed K062, D007, and D008 waste  that  contained lead
at concentrations up to 212 mg/1.   (Performance  data for  the  mixed waste
are given in Section 4.)  Thus, EPA considers alkaline precipitation
followed by settling and filtration demonstrated for treatment  of  metals
in K046 wastewaters.  (Detailed descriptions of  the  technologies in this
demonstrated treatment train  are given in USEPA  1989b.)
                                    3-4
3622g

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                          4.   PERFORMANCE DATA

    Performance data, to the extent that they are available to EPA,
include the untreated and treated waste concentrations for various
constituents, values of operating parameters that were measured at the
time the waste was being treated, values of relevant design parameters
for the treatment technology, and data on waste characteristics that
affect performance of the treatment technology.

    Where data are not available on the treatment of the specific wastes
of concern, the Agency may elect to transfer data on the treatment of a
similar waste or wastes, using a demonstrated technology.  To transfer
data from another waste category, EPA must find that the wastes covered
by this background document are no more difficult to treat (based on the
waste characteristics that affect performance of the demonstrated
treatment technology) than the treated wastes from which performance data
are being transferred.

    For treatment of K046 wastes, the Agency has three sets of
performance data which are presented in the August 1988 background
document.  These data show treatment of a K046 nonreactive subcategory
nonwastewater (generated from lead styphnate production) by
(1) stabilization using a Portland cement binder, (2) stabilization using
a lime/fly ash binder, and (3) stabilization using a kiln dust binder.
Because performance data are not available from treatment of K046
reactive subcategory nonwaste- waters, EPA is transferring these
available data from stabilization of the nonreactive nonwastewaters.  The
Agency believes that reactive wastes, once deactivated, will be no more
difficult to treat than the nonreactive wastes for which treatment data
are available.  This belief is based on the premise that K046 wastes,
whether reactive or nonreactive as initially generated, are produced by
the manufacture/use of lead-based initiating compounds and that the
techniques and components used in the

                                    4-1
3623g

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manufacture/use  do not vary such  that  they have an effect  on  the
performance  of stabilization.

    Although all three sets of performance data from testing  K046
nonreactive  nonwastewaters may be considered available for developing
treatment standards for deactivated K046 reactive nonwastewaters, only
data from the test using Portland cement are presented here in
Table 4-1.   As shown in the August 1988 background document,  an analysis
of variance  statistical test on lead stabilization data determined that
Portland cement  is most effective in reducing the leachability of lead.

    Because  no performance data are available from treatment  of K046
wastewaters  by the sole identified demonstrated treatment  (i.e., alkaline
precipitation followed by settling and filtration), the Agency used data
transferred  from treatment of a mixed wastewater that contained K062,
D007, and D008 wastes (see Table 4-2).  The Agency believes that K046
wastewaters  would be no more difficult to treat than this mixed
wastewater because the K046 wastewaters have lower concentrations of
metals, particularly lead, according to available characterization data.
(Compare the "Source 4" and "Source 5" columns of Table 2-2, with the
"treatment tank  composite" columns of Table 4-2.)
                                    4-2
3623g

-------
 3352g
                         Table  4-1   Performance Data for Stabilization Using Portland Canent
                                         on IC046 Nonreactive Nonwastewater



Untreated waste
Const ituent /parameter
BOAT list metals
Ant imony
Arsenic
Bar inn
Beryl linn
Cadmiun
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
Other parameters
Sulfide
Sulfate
Oil and grease
Total organic carbon
PH
Total

0.022
<0.010
<0.200
<0.005
<0.010
<0.020
<0.025
967
0.00084
<0.040
<0.005
<0.050
<0.010
<0.050
0.295

1.0
190
3.8
461
11.91
TCLP

<0.020
<0.010
0.228
<0.005
<0.010
<0.020
<0.025
103
<0.0003
<0.040
<0.005
<0.050
<0.010
<0.050
0.335

MA
NA
NA
NA
NA
Concentration
loam]

Treated waste TCLP
Sample #1

<0.17
<0.003
1.8
<0.002
<0.005
0.033
<0.006
0.072
0.0003
<0.030
<0.002
<0.006
<0.0007
<0.008
0.036

NA
NA
NA
NA
NA
Sample 12

<0.17
<0.003
1.8
<0.002
<0.005
<0.020
<0.006
0.100
<0.0003
<0.030
<0.002
<0.006
<0.0007
<0.008
0.027

NA
NA
NA
NA
NA
Sample «

<0.17
<0.003
1.8
<0.002
<0.005
0.030
0.019
0.062
<0.0003
<0.030
<0.002
<0.006
<0.0007
<0.008
0.112

NA
NA
NA
NA
NA
Applicable
percent
recovery (X)a

95
100
100
89
96
95
81
77
94
88
87
25
_b
91
96






NA = Not analyzed.

BThe applicable percent recovery  is the  lower of the matrix spike recovery or matrix spike duplicate recovery
 for the particular metal  in TCLP extracts unless both recoveries exceeded 100 percent (in which case, 100 percent
 recovery  is applicable).

Ttotrix spike recoveries fell below 20 percent, the BOAT Program's limit for acceptable data (see USEPA 1989a).

Note:  Operating data are as follows:  binder-to-waste ratio. 1.2; dry waste plus water weight. 600 grams, binder
       weight, 720 grams; and mixture pH, 12.35.

Source:  USEPA 1988a. Tables 2-4 and 4-1, and USEPA 198Bc, Table 6-4.
                                                     4-3

-------
3352g
                                            Table 4-2  Perfonnance Data for Alkaline Precipitation. Settling, and
                                                    Filtration of a Nixed K062. 0007. and D008 Vastewater
Concentration (mm)
Sannle f 1
Const ituent/parameter
BOAT list metals
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium (hexavalent)
Chromium (total)
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Other parameters
Treatment
tank cooposite

<10
<1
<10
<2
13
893
2.581
138
64
<1
471
<10
<2
<10
116

Filtrate

<1
<0.1
<1
<0.2
<0.5
0.011
0.12
0.21
<0.01
<0.1
0.33
<1
<0.2
<1
0.125

Sample 12
Treatment
tank composite

<10
<1
<10
<2
10
807
2.279
133
54
<1
470
<10
2
<10
4

Filtrate

<1
<0.1
<1
<0.2
<0.5
0.190
0.12
0.15
<0.01
<0.1
0.33
<1
<0.2
<1
0.115

Samole 13
Treatment
tank composite


-------
3352g
                                                                    Table 4-2  (continued)
Concentration (pom)
Sample »5
Const ituent /parameter
BOAT list metals
Ant imony
Arsenic
Barium
Beryllium
Cadmium
Chromium (hexavalent)
Chromium (total)
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Other parameters
Total organic carbon
Total solids
Total chlorides
Total organic ha 1 ides
Treatment
tank composite

<10
<1
<|0
<2
<5
917
2.236
91
18
1
1.414
<10
<2
<10
71

200
NA
NA
0
Filtrate

<1
<0.1
<1
<0.2
<0.5
0.058
0.11
0.14
<0.01
<0.1
0.310
<1
<0.2
<1
0.125

NA
NA
NA
NA
Sample 16
Treatment
tank composite

<|0
<1
<}0
<2
<5
734
2.548
149
<10
<1
588
<10
<2
<10
4

700
NA
NA
700
Filtrate

<1
<0.1
<2
<0.2
<0.5
_a
0.10
0.12
<0.01
<0.1
0.33
<1
<0.2
<1
0.095

NA
NA
NA
NA
Sample
17
Treatment
tank composite Filtrate

<10
<1
<10
<2
10
769
2.314
72
108
<1
426
<10
<2
<10
171

3.400
NA
NA
1.900

<1
<0.1
<1
<0.2
<0.5
0.121
0.12
0.16
<0.01
<0.01
0.40
<1
<0.2
<1
0.115

NA
NA
NA
NA
Sample
IB
Treatment
tank composite Filtrate

<10
<1
<]0
<2
<5
0.13
831
217
212
<1
669
<10
<2
<10
151

5.900
NA
NA
800

<1
<0.1
<1
<0.2
<0.5
<0.01
0.15
0.16
<0.01
<0.1
0.36
<1
<0.2
<1
0.130

NA
NA
NA
NA

-------
         3352g
                                                                             Table 4-2  (continued)
CTi
Concentration (Dim)
Const ituent /parameter
BOAT list metals
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium (hexavalent)
Chromium (total)
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Other parameters
Total organic carbon
Total solids
Total chlorides
Total organic ha 1 ides
Sample
Treatment
tank composite

<10
<1
<10
<2
<5
0.07
939
225
<10

-------
         5.   DETERMINATION OF BEST DEMONSTRATED AVAILABLE
                      TECHNOLOGY (BDAT) FOR K046

    This section presents the Agency's rationale for determining the  best
demonstrated available technology (BDAT) for K046 reactive
nonwastewaters, reactive wastewaters, and nonreactive wastewaters.  BDAT
for K046 nonreactive nonwastewaters was determined to be  stabilization
using Portland cement as a binder (USEPA 1988a).

    To determine BDAT for a particular waste,  the Agency  typically
examines all available performance data on technologies that are
identified as demonstrated to determine (using statistical techniques)
whether one or more of the technologies performs significantly better
than the others.  If a technology is the sole  demonstrated technology,
then it is automatically "best."  The best technology is  then evaluated
to determine whether it is "available," i.e.,  whether the technology  is
commercially available to any generator and whether it provides
substantial treatment of the wastes,  as determined through evaluation of
accuracy-adjusted data, if available.

    In determining whether treatment is substantial,  EPA  may consider the
number and types of constituents treated,  the  concentrations of
constituents in the treatment residuals, and the percent  reduction  of
constituents achieved by treatment.  Where performance data are not
available for the waste in question,  EPA may consider data on the
performance of a similar waste,  provided the similar waste is at least as
difficult to treat.

    In the case of K046 reactive nonwastewaters,  the demonstrated
technologies have been identified as follows:   deactivation by chemical
treatment, or specialized incineration, followed by stabilization using
Portland cement, kiln dust,  or lime/fly ash.   The BDAT is stated as
deactivation followed by stabilization using Portland cement.   Lacking
                                    5-1
3624g

-------
 sufficient data with which to compare performance of the various
 deactivation technologies,  EPA is considering deactivation widely as
 best.   Because any of the deactivation technologies are widely available
 and they provide substantial treatment (i.e.,  they eliminate the
 reactivity characteristics)  if operated properly,  deactivation is
 considered BDAT.

     Stabilization using Portland cement is  best  for treating the metals
 as  shown in the August 1988  background document  (USEPA 1988a,
 Section 5).   Stabilization using Portland cement as the binder is also
 commercially available,  and  it provides substantial treatment  for lead in
 K046 nonreactive nonwastewaters (see  Table  4-1).   As  discussed in
 Sections 3  and 4,  the Agency believes that  the K046 reactive
 nonwastewaters will be no more difficult to treat  than the  nonreactive
 nonwastewaters.   Thus,  stabilization  using  Portland cement  is  being
 proposed as  BDAT for metals  in reactive nonwastewaters.

    Chemical deactivation followed by alkaline precipitation,  settling,
 and filtration is  the only identified demonstrated treatment for K046
 reactive wastewaters.   As the only demonstrated  treatment,  it  is
 considered best.   Because such a treatment  train is commercially
 available, and because it would provide substantial treatment  for both
 the reactivity characteristic and the metals  (see  the  performance data
 for the  mixed waste deemed similar in Section 4),  the  treatment  train is
being promulgated as BDAT for the K046 reactive  subcategory wastewaters.

    Because  it is  the only identified demonstrated technology  for K046
nonreactive  wastewaters,  the alkaline precipitation,  settling, and
 filtration train is considered best.   Because it is commercially
available and because it  provides substantial treatment (again,  see  the
performance  data for the  similar mixed waste  in  Section 4),  this
treatment is  being promulgated as BDAT for  the K046 nonreactive
wastewaters.
                                    5-2
362*8

-------
               6.   SELECTION OF  REGULATED  CONSTITUENTS


    This section presents the rationale for the selection of the
regulated constituents in K046 wastes.  Constituents selected for
regulation must satisfy the following criteria:
    1.  They must be on the BOAT list of regulated constituents.
        (Presence on the BDAT list implies the existence of approved
        techniques for analyzing the constituent in treated waste
        matrices.)

    2.  They must be present in, or be suspected of being present in, the
        untreated waste.  For example, in some cases, analytical
        difficulties (such as masking) may prevent a constituent from
        being identified in the untreated waste, but its identification
        in a treatment residual may lead the Agency to conclude that it
        is present in the untreated waste.

    3.  Where performance data are transferred from one constituent to
        others, the selected constituents must be easier to treat than
        the waste constituent(s) from which performance data are
        transferred.  Factors for assessing ease of treatment vary
        according to the technology of concern.  For instance, for
        incineration the factors include bond dissociation energy,
        thermal conductivity, and boiling point.
    From the group of constituents that are eligible to be regulated, EPA

may select a subset of constituents as representative of the broader

group.  For example, out of a group of constituents that react similarly

to treatment, the Agency might name only those that are the most

difficult to treat as regulated constituents for the purpose of setting
treatment standards.


    In the case of the K046 wastes, the Agency is regulating.only lead.

The Agency investigated the possibility of regulating other BDAT list

metals that have been detected in K046 wastes, but has declined to do so

because the available characterization data show that these metals are

present in these wastes at relatively low concentrations.   Also normally

the BDAT technologies chosen should adequately treat, i.e., (immobilize)
other BDAT list metals.

                                    6-1

3625g

-------
            7.   CALCULATION OF  BOAT  TREATMENT  STANDARDS

    The Agency bases treatment standards for regulated constituents on
the performance of well-designed and well-operated BDAT treatment
systems.  These standards must account for analytical limitations in
available performance data and must be adjusted for variabilities related
to treatment, sampling, and analytical techniques and procedures.

    BDAT standards are determined for each regulated constituent by
multiplying the arithmetic mean of "accuracy-corrected" constituent
concentrations detected in the treated waste by a "variability factor"
specific to each constituent.  The accuracy-corrected concentration for a
constituent in a matrix is the analytical result multiplied by the
correction factor (the reciprocal of the recovery fraction).  For
example, if Compound A is measured at 2.55 mg/1 and the recovery is
85 percent, the accuracy-corrected concentration is 3.00 mg/1:

      2.55 mg/1     x     1/0.85       -            3.00 mg/1
(analytical result) (correction factor) (accuracy-adjusted concentration)

Variability factors correct for normal variations in the performance of a
particular technology over time.  They are designed to reflect the
99th percentile level of performance that the technology achieves in
commercial operation.  Recoveries, accuracy correction, and variability
factor determination and use are discussed further in EFA's Methodology
for Developing BDAT Treatment Standards (USEPA 1989a).

    The calculation of treatment standards for lead in K046 reactive
subcategory nonwastewaters (after deactivation),  reactive subcategory
wastewaters (after deactivation), and nonreactive subcategory wastewaters
is presented in Tables 7-1 and 7-2.  The treatment standard for the
nonwastewaters reflects the concentration of lead in the extract from the
                                    7-1
319*8

-------
3352g







                                 Table 7-1   Calculation of Treatment Standards  for K046 Reactive Subcategory Nomastewaters


Sample No.
Untreated TCLP
concentrat ion
(«g/D
Treatment residual TCLP
concentration, as
analyzed (mg/1)
Accuracy
correction
factor
Treatment residual TCLP
concentration, accuracy-
corrected (mg/1)
Average of
accuracy-corrected
concentrations (mg/1)
Variability
factor
(VF)
Treatment
standard
(mg/1)
1 103
2 103
3 103
0.072
0.10
0.062
1/0.77
1/0.77
1/0.77
0.0935
0.130
0.0805
0.101 1.76 0.18



-------
3352g
                          Table 7-2  Calculation of Treatment Standards for K046 Vastewaters.  Reactive and Nonreactive  Subcategories


Sample Mo.
1
2
3
4
5
6
7
8
9
^ JJ

GO
Untreated
concentration
to/D
64
54
<10 *
<10 "
18
<10 *
108
212
•

-------
 Toxicity Characteristic Leaching Procedure (TCLP)  (51 FR 40643,
 November 7,  1986),  and the units are mg/1 (parts per million on a
 weight-by-volume basis).   The treatment standard for wastewaters reflects
 the  total waste concentration of lead in the wastewater;  the units are
 mg/1.   Note  that the lead treatment standards are  based on data that
 resulted from using EPA-approved methods SW-846  7421 (Atomic Absorption,
 Furnace Technique)  for nonwastewaters and SW-846 7420 (Atomic Absorption,
 Direct  Aspiration)  for wastewaters  (USEPA 1986a).
                                    7-4
31948

-------
APHA, AWWA, and WPCF.   1985.  American Public Health Assocation,
  American Water Works  Association, and Water Pollution Control
  Federation.  Standard methods for the examination of water and
  wastewater.  16th ed.  Washington, D.C.:  American Public Health
  Association.

Environ.  1985.  Characterization of waste streams listed in 40 CFR
  Section 261 waste profiles, Vol. II.  Final report for Waste
  Identification Branch, Characterization and Assessment Division, U.S.
  Environmental Protection Agency.  Washington, D.C.:  U.S. Environmental
  Protection Agency.

USEPA.  1986a.  U.S. Environmental Protection Agency, Office of Solid
  Waste.  Test methods  for evaluating solid waste, SW-846.  3rd ed.
  Washington, D.C.:  U.S. Environmental Protection Agency.

USEPA.  1986b.  U.S. Environmental Protection Agency, Office of Solid
  Waste.  Onsite engineering report of treatment technology performance
  and operation for Envirite Corporation, York, Pennsylvania.
  Washington, D.C.:  U.S. Environmental Protection Agency.

USEPA.  1987.  U.S. Environmental Protection Agency, Office of Solid
  Waste.  Generic  quality assurance project plan for land disposal
  restrictions program  ("BOAT").  EPA/530-SW-87-Oil.  Washington, D.C.:
  U.S. Environmental Protection Agency.

USEPA.  1988a.  U.S. Environmental Protection Agency, Office of Solid
  Waste.  Best demonstrated available technology (BDAT) background
  document for K046.  Washington, D.C.:  U.S. Environmental Protection
  Agency.

USEPA.  1988b.  U.S. Environmental Protection Agency, Office of Solid
  Waste.  Best demonstrated available technology (BDAT) background
  document for K062.  Washington, D.C.:  U.S. Environmental Protection
  Agency.

USEPA.  1988c.  U.S. Environmental Protection Agency, Office of Solid
  Waste.  Onsite engineering report for the stabilization of waste code
  K046 at U.S. Army Corps of Engineers, Waterways Experiment Station,
  Vicksburg, Mississippi.  Washington, D.C.:  U.S. Environmental
  Protection Agency.

USEPA.  1988d.  U.S. Environmental Protection Agency, Office of Solid
  Waste.  Rulemaking record for land disposal restrictions proposed rule
  for Second Sixths waste codes, section 2.4 - K046.  Washington, D.C.:
  U.S. Environmental Protection Agency.
                                    8-1
3195g

-------
USEPA.  1988e.  U.S.  Environmental Protection Agency, Office  of  Solid
  Waste.  Response  to comments related to the First Third wastes
  treatment technologies and associated performance.  Vol.  IX.   Issue
  code 12.  Washington, D.C.:  U.S. Environmental Protection  Agency.

USEPA.  1989a.  U.S.  Environmental Protection Agency, Office  of  Solid
  Waste.  Methodology for developing BDAT treatment standards.
  Washington, D.C.:   U.S. Environmental Protection Agency.

USEPA.  1989b.  U.S.  Environmental Protection Agency, Office  of  Solid
  Waste.  Treatment technology background document.  Washington, D.C.:•
  U.S. Environmental  Protection Agency.

USEPA.  1990.  U.S. Environmental Protection Agency, Office of Solid
  Waste.  Final best  demonstrated available technology (BDAT) background
  document for characteristic ignitable wastes (D001), characteristic
  corrosive wastes  (D002), characteristic reactive wastes (D003), and P
  and U wastes containing reactive listing constituents.   Washington,
  D.C.:  U.S. Environmental Protection Agency.

Versar Inc.  1987a.   Engineering analysis for the production and use
  of lead-based initiating compounds in the explosives industry.
  Prepared for Office  of Solid Waste, U.S. Environmental Protection
  Agency, under Work Assignment 14, Contract No. 68-01-7287.

Versar Inc.  1987b.   Explosives record sample analysis -  K046.  Prepared
  for U.S. Environmental Protection Agency under Project 5020.004,
  March 31, 1987.  Contract No. 68-01-7287.
                                    8-2
31958

-------
                   APPBDDCA
DETERMINATION OF NONREACTIVE AND REACTIVE FORMS OF K046

-------
                        APPENDIX A
       DETERMINATION OF NONREACTIVE AND REACTIVE FORMS OF K046
         UNITE:- STATES ENVIRONMEN.AL PROTECT.-* AGENCY
                     OFFICE OF SOLID WASTE

U.S. Army Procedures to  Determine Reactivity
                                                        ~* 2 I ,-,,
                                                              '•* -1
David Friedman, Manager
Waste Analysis Program,  WCB  HIWD (V.H-565)

Betty Willis, Region IV
Hazardous Waste Section
     We have  reviewed  the test plan submitted by the U.S.
Army Toxic and Hazardous Materials Agency lor determining
reactivity due to  explosive -roperties.  Negative results
in the battery of  tests  outlined in their pJan would be
adequate proof that  the  soil sample is indeed not a
reactive waste.  OSW supports the ur•-• of this -esf plan
and plans to  recommend it for use bj other generators
facing such a probl-..n.

     If you need any assistance in eval'- ting, the data gen-
erated during this study, please contact Florence Richardson
c£ my staff.  She  can  be reached at 755-9187.
                             A-l

-------
                                       RBG1QN IV



                                AiHO — Infozsal MBTD
                 15, 1381
  ."

'
  TOt  David ndjadnan. OW-565)


       tfZ2. Axny Pxocedures to Determine Reactivity
              review this and give ne a call  at FTS 257-3433 oancerning


       bow to handle this request.
                                      A-2

-------
              *    UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
           .  ttP 0 t 18BJ        Region IV - Atlanta, GA


           j)j' 5. Army Toxic 6 Hazardous Materials Agency
           'Draft Procedures to Determine Reactivity
 * **&  ' :  Arthur 0. Lin ton
 -*. £^i£'"* tfederar Activities Coordinator
»-*^^«u • r ..^fc,."      ^
   T. i"»  JL*'  •.
     .  ••*   Janes B.  Finger, Director
     -  ^ "."Surveillance & Analysis Division

       .' y Jaaes B.  Scarbrough. Chief
        V  Residuals Management Branch
                U. S. Army Toxic and Hazardous Materials Agency has
            fiqnieBted that we review the three enclosures.  The purpose
            .oTVthis procedure is to delineate the necessary tests,
            afkociated methods, and interpretation of results to
           .'determine whether contaminated soil and nediments are
            classified as reactive, due to their explosive properties.
           -?hi* information is necessary to determine what, if any,
        rV  processing is required for final disposal of such soil
          -'1 tediaents.
              .
              e .facility this procedure has been developed  for  is
              jan Army Ammunition Plant, Milan, Tennessee.   There  are
            eleven lagoons located at this facility  that  have been used
            tp process waters containing nitrobodies;  specifically,
            what is classified as pink water.  The closing  out  of  these
           'lagoons has a high priority within the Army  and EPA
            because groundwater has been contaminated  within the arsenal
            bo'undaries.  There is an immediate need  to develop  a strategy
            to plose out these lagoons, cither by filling or treating  the
            sediments.
             M
            Feel free to contact Mr. Robert A. Breschi,  who is  referred
           •tg^in the enclosed documents.  Once your review has been
           ~ completed, we need to develop a mutual time  during  which
            ve* can discuss this procedure with Mr. Breschi  and  other
            representatives of the U. S. Army Toxic  and  Hazardous
            Hat*ri*l» Agency.
            •v>*" jri-.v.;
                       ting that you respond to my request  by
                       1* 1981.  I am targeting a meeting with  the
                     -  Toxic and Hazardous Materials Agency during
                     of September 21.
   V^.f                           A-3
   --:'*!»»:•>•
       --'_«.  i..
       -•».i .jj-
 IPA

-------
                          DEPARTMENT  OF THE  ARMY

                    US AJWY TOXIC AND HAZARDOUS NATEHAI.S AGEMCt

                                      OJtOUMO.
                                                           25  AU6 1981
Mr. Art Llnton
Federal Activities Coordinator (fen 203)
Eny1ronBental Protection Agency
345 Courtlind Street
Atlanta. Georgia  30365
Dear Mr. 11 n ton:
      \
In reference to our FONECON of V24 August 1981, inclosed are the draft
procedures developed by US Amy Toxic and Hazardous Materials Agency (USATHAHA)
to determine the reactivity of the soils and sediment within the 11 lagoons
situated at Milan AAP.
.- .                                                                            j*
Inclosures 1 end 2 are copies of the procedures to determine concentrations *
of explosives within soil and sediment.  Inclosure 3 1$ a copy of the
reactivity procedures to determine whether soil and sediment are in fact
reactive.
                                                      •
If there ere questions call 
-------
                   TEST PLAN TO DETERMINE REACTIVITY OF
               EXPLOSIVELY CONTAMINATED SOIL AND SEDIMENT*
I.     PURPOSE

The purpose of this plan is  to  delineate the necessary tests,  associated methods, and
interpretation of  results  to  determine  whether  a  contaminated soil  of  sediment  is
classified as reactive due to its explosive  properties.  Such  information  is necessary  to
determine what (if  any)  processing is required prior to final  disposal of such soil  or
sediment.
II.    REFERENCE

              a. Title 40 Code of Federal Regulations, Part 261, Para 261.23,
                Characteristic of Reactivity.

         b. EPA  Publication  SW  846,  Test  Method  for  Evaluating  Solid  Waste.
           Subsection) 6-2; Definition of Explosive Materials (attached as Incl. 1).

         c. Army Technical Bulletin 700-2, Chapter 3:    Minimum Test Criteria for Bulk
           Explosive Compositions and Solid Propellant Compositions.

         d. FONECONS with  Dr.  H. Matsuguma,  Chief,  Chemistry  Branch, Energetic
           Materials Division, Large Caliber  Weapons System Laboratory,  U.S, Army
           Armament Research and Development Command, SAB.


III.   BACKGROUND

Due to explosives production, employment, and disposal operations  performed through the
years at  various military installations across the country, the Army owns property which
contains  potentially explosively contaminated soils and sediments.  Efforts-are underway
to  begin decontamination and close-out  of  such sites  in  compliance  with" Federal'
Environmental Regulations.  Explosives, however, are governed by Rcf. 2a, which restricts
reactive  materials from begin  landfilled, including placement in. a  hazardous, waste:;
landfill.   By regulation, then, every Army  site which contains explosive residues, which
range from  low parts per million  up to fifty percent in the worst cases,  would require
treatment prior  to final disposal.  Since many sites with low levels of contamination are
not expected  to exhibit any explosive  properties,  identifying such sites  would remove
from them the requirement to treat the residues as reactive wastes.  Therefore, tests are
provided in this plan which are suitable for determining whether  a  contaminated soil or..
sediment  is  reactive due  to explosivity according  to Environmental Protection Agency
definitions.
      •Three sediment samples are obtained from each lagoon and analyzed for explosive
      concentration.  One sample is taken near  the  waste water influent  point,  another
      near  the  effluent point,  and the third sample  is taken  from the  middle of the
      lagoon.


                                   A-5

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a. Of  the  eight characteristics  defining  a  reactive  waste  in  Rcf.  2a,  the
  characteristics pertaining to explosive wastes arc:

   I.    Capable  of  detonation  or explosive reaction if subjected to a strong
        initiating source or if heated under confinement.

  2.    Capable of detonation or explosive decomposition or reaction at standard
        temperature or pressure.

  3.    Is a  forbidden explosive as defined  in  49 CFR  173.51  or a Class A or
        Class B  explosive as defined in 49 CFR 173-53 and 88.

b. Ref. 2b  defined tests for explosives  which address the above definitions of
  reactivity as follows:

   1.    A  Stability Test  is performed  by  heating the  residue  to  75°C  for
        48 hours.   This  test defines  a forbidden explosive  according to  49
        CFR 173.51.

  2.    A Detonation Test is performed by  inserting a blasting  cap into a sample
        and  observing  the detonation.  Reaction  of  the  sample  to  a strong
        initiating source and Class A explosives  as defined in 49 CFR  173.53 are
        tested in this manner.

  3.    A Spark Test is  performed'by  inserting  a  time fuze or an  electric squib
        into  a sample and observing for deflagration or  detonation.  This  tests
        for  explosives as defined  in 49  CFR 173.53 (initiating  explosives)  and
        49 CFR 173.88 (propellants).

  4.    An  Impact  Test is performed  on   the  Bureau  of Explosives  Impact
        Apparatus to define Class A explosives according  to 49  CFR 173.53.

c. In  Ref. 2d,  the  above tests  were discussed  with Dr. H. Matsuguma of  the
  Army's  Primary  Explosives  Research   Laboratory.    Pertinent  comments
  regarding the above tests were as follows:

  1.    The  tests are  adequate  Tor a go/no-go  evaluation of  reactivity, except
        that  the  results of the  Impact Tests will be misleading at  low explosive
        concentrations. Since impact testing is designed  to be a severe test  used
        for  ranking reactions of various explosives.  It is possible to  eke  out
        positive   results  even    from   minute    quantities    of  explosives.
        Supplementing Impact Test results with  a  Card  Gap Test, as outlined in
        Ref.  2c, will  better define  the ability of  a  contaminated  sample to
        propagate detonation.

  2.    Soil and sediment samples should be analyzed to determine the explosive
        constituents and their  concentrations.   However, the chemical  analysis
        methods  are  not germane to  the  actual   reactivity tests and  are  not
        addressed in this plan.
                             A-6

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           3.    The Stability. Detonation. Impact, and Card  Gap Tests are performed, in
                a standard manner, although  some minor  modifications are required to
                accommodate  preparation of environmental  samples.  The Spark Test is
                not  a standard  test  for  the Army,  but  with  modification,  can  be
                performed in  the same manner as the Detonation Test.


V.    TEST EQUIPMENT AND MATERIALS

The following items  are required to perform the necessary explosives tests on one field
sample.  Ancillary laboratory equipment is not included.

         a. One  Bureau of Explosives Impact  Apparatus.

         b. One   ventilated  explosion-proof  oven   equipped  to   continuously   record
           temperature.

         c. One  blasting machine or equivalent.

         d. Electric firing wire.

         e. Electric blasting caps.

           1.    Five  No. 8  electric  blasting  caps  (contains 2 gms  of  80/20 mixture
                mercury fulminate/potassium chlorate).

           2.    Three-engineer special electric  blasting caps.

         f. Five electric match head  igniters.

         g. Two inch  diameter by 1 inch long pressed pentolite  pellet.  National  Stock
           No. 1375-00-991-8891, as required.

         h. Solid lead cylinders 1-1/2 inch diameter by 4 inches high as required.

         f. One  piece of mild  steel plate  SAE  1010  to  1030,  1/2 inch thick  by 12 inches
           square.

         j. Mild steel plates (SAE  1010 to  1030)  6x6 inches x 3/8 inch  as required.

         k. Tubing, steel cold drawn seamless,  mechanical, composition 1015, 1-7/8 inch
           00, 0.219 inch  wall thickness by 5-1/2 inch long, as required.


VI.   SAMPLE PREPARATION:

A  complete set of tests will require  a five pound  sample from each field  sampling point.
Samples  will generally be received  wet and possibly split into multiple containers for
shipping purposes. The field sample will  be prepared and split into laboratory samples as
follows:

         a. Recombine samples if necessary.  Samples may be  mixed while wet to achieve
           uniformity. Large  chunks should be broken up, in a ball mill or mortar and
           pestle, using an operational shield if necessary.
                                      A-7

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         b. The  wet samples must be dried to the appropriate moisture content for testing.

           1.    The apropriate  moisture  content  will  be determined  by taking a soil
                 sample  from a depth of four feet at  a point  close to the lagoon  being
                 sampled.   That  sample will then  be  weighed, dried  in  an  oven until
                 constant  weight  is achieved,  and then  reweighcd.   From  this,  the
                 moisture content will be calculated.

           2.    For  each soil or sediment  sample to  be tested  for explosivity, a sub*
                 sample  will  be  drawn, weighed,  oven dried,  and  then reweighcd  to
                 determine its original moisture  content.  The amount of water weight
                 which must be removed from each sample to reach  the moisture content
                 in 6b(l) above will  then be calculated.

           3.    Each soil  or sediment  sample  will  then  be weighed,  spread  in a thin
                 layer on a tray, and then dried  in an  oven at 60°C until  the amount  of
                 water weight calculated in  6b(2) above has been  removed.  The sample
                 must be monitored and reweighcd  until the desired weight is reached.

         c. Laboratory test  samples  will  be prepared from the  prepared field  sample  as
           follows:

           1.    For  the Thermal  Stability, Detonation, and Spark Tests,  prepare a total
                 of eleven samples by filling a  four-ounce paper cup approximately 2/3
                 full.  The sample should not contain large chunks and should be tamped
                 as it is  filled to insure continuity of the sample.

           2.    For the Impact Sensitivity Test, withdraw an approximate 200 mg sample
                 from the  field sample.  This sample must then be  carefully crushed  so
                 that  10 mg of  uniformly  fine  consistency  can  be drawn  from  it.
                 Description of the  individual samples  is  incorporated under  the Impact
                 Sensitivity Test.

           3.    For the Card Gap Test, prepare  three samples by  filling the tubes listed
                 in para. 5k with the material  to be tested.  Insure that the sample is
                 continuous by tamping.  If  the consistency of the sample  is such that it
                 will not consolidate, a piece of  light cellophane tape may  be placed
                 across the lower end to  retain the sample.


VII.  TEST METHODS

Although it could be argued  that some of these  tests are  not  applicable to certain pure
explosives, it is  possible  to encounter residues from mixed explosives or environmentally
altered  residues which will not behave  in the classic manner.   Therefore, the complete
series of tests will be performed on each sample.   Test  results will  be recorded on a data
sheet similar  to Fig. 1. Tests may be run in any convenient order.

         a. Thermal  Stability.   Place  one   sample from  para.  6d(I)  in  a  constant
           temperature explosion-proof oven.  Raise temperature of the oven to 75°C and
           maintain at 75°C for 48 consecutive hours. Temperatures will be continuously
           recorded.  Constant observation is not  required. Record results  on data sheet.


                                        A-8

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b. Spark Test.  Place a lead block (para. 5h) on the steel plate (para. 5i). Using a
  sample from para. 6d(l). make a small depression  in  the sample with stick or
  pencil, insert an electric match head  igniter (para. 5f) into the depression and
  secure (tape) the igniter wires to  the cup for  stability.  Place  the cup  on the
  lead block, connect the firing circuit, and remotely initiate.  Deflagration will
  be  evidenced by  the  energetic burning of the sample.   Detonation  of  the
  sample will  cause mushrooming of the  lead  block.  Repeat the test five times
  or  until  evidence of a deflagration  or detonation occurs, whichever  is less.
  Record results on data sheet.

c. Detonation  Test.  Place a  lead block (para. 5h) on the steel plate  (para. Si).
  Using  a  sample from  para. 6d(l).  press a hole about half the length  of the
  blasting cap into the center of the sample using a pencil,  then insert a No. 8
  blasting cap into the sample.  A wood block with a hole drilled in it similar to
  Fig. 2 may be used to support the  blasting cap. Place the sample onto the lead
  block, connect the firing  circuit,  and remotely initiate.  Detonation  of the
  sample will  cause mushrooming of the lead  block.  Repeat the test five times
  or until detonation occurs, whichever is less. Record results on a data sheet.

d. Impact Sensitivity Test: Conduct ten individual tests using one sample (para.
  6d(2))  per test in the Bureau  of Explosives Impact Apparatus.  Place a  10 mg
  sample in the cup assembly.  Drop the weight from the maximum height of the
  machine.  Observe the result and record on the data sheet.  Conduct tests at an
  ambient  temperature  of  25°C  5°C.    Insure  cup  and anvil  are  thoroughly
  cleaned and dried between test runs.

e. Gap Test

  I.    Assemble the following  items for each test to be conducted:

        a.    One  sample prepared according to para. 6d(3).

        b.    Two pentolite pellets (para. Sg).

        c.    One  engineer's  special  electric blasting  cap, 32 (para. 5e(2)).

        d.     Blasting machine and firing wire (para 5c. and d).

        e.    One  5x6 inch steel plate (para. 5j).

        f.     Plastic material, 1/16 inch thick cut into 1/2 inch squares.

  2.    Arrange the materials as shown in Fig. 2. The witness plate is supported
        on two edges, about 6  inches above ground surface.   The small  plastic
        squares are placed on the plate to support the pipe and maintain a 1/16
        inch air gap.  The squares should be under  the edge of the pipe, rather
        than under the explosive. The  pentolite boosters are then placed on top
        of  the sample as shown in  Fig. 2, except that the  gap cards and the
        cardboard tube are not  used.  The  blasting cap is then placed on top of
        the  pentolite  (with a  wood  support  ring)  and  remotely   detonated.
        Detonation of the sample is indicated when a clean hole is cut  in the
        witness plate.  This  test is performed three  times or until a detonation
        occurs, whichever is  less. Results are recorded on the data sheet.

                                 A-9

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VIII. INTERPRETATION OF RESULTS

For  the purpose  of reactivity evaluation,  a positive result  from  any single  test  will
indicate that a given field sample is reactive, except that results from the Impact and  Gap
Tests should be considered together.

         a. A sample is considered reactive due to instability if it detonates, deflagrates,
            or  decomposes exothermically  (as evidenced by a rise  in temperature on the
            recorder) during the Thermal Stability Test.

         b. The field  sample  is  considered  to  be  reactive if  one lab sample  detonates,
            deflagrates, or burns in a sustained flame  during  the  Spark  Test.  Localized
            smoldering does not indicate reactivity.

         c. The field  sample  is  reactive if  one  sample detonates  during the detonation
            test.

         d. The  Impact  Sensitivity  Test  may  be  considered positive  if  detonation
            (explosion,  flame, noise)  occurs in  at least  50  percent  of  the  ten tests.
            Conversely, if detonation does  not occur in at least 50 percent of the tests, the
            sample is non-reactive.  However, the  results of the  Impact Sensitivity  Test are
            the  most difficult to  interpret,  since  samples can  exhibit  partial  response
            under such harsh  treatment. In such  cases, the Gap Test should be used  as a
            discriminator, defining a  material as reactive if it detonates once out  of three
            tests.
IX.   CONCLUSION


The tests  conducted  under this plan  exceed  minimum  requirements  for  determining
reactivity  due to explosive  properties as specified  in Ref. 2b.   The  Thermal  Stability,
Spark, and Detonation Tests are performed as specified.  The Impact  Sensitivity Test is
performed in  a manner more stringent than specified to insure that results are safe-sided.
Since Impact  Sensitivity  Tests may present results  which are difficult  to interpret,  the
Shock or Gap Test has been added as a discriminator to determine whether a  questionable
material is detonable  under  worst-case conditions.  It  can  be stated with certainty that a
sample  which does not respond positively  to these tests is not reactive  due  to  explosive
properties  as defined in Ref. 2a.
                                       A-10

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                                SW 84B, DATED MAY 1980
                   "TEST METHODS FOR EVALUATING SOLID WASTE"

                                     SUBSECTION 6.2

                        DEFINITION OF EXPLOSIVE MATERIALS

     For purposes of this regulation, a waste which  is a reactive waste by reason of explosivii
     is one which meets one or more of the following descriptions:

     1.   Is explosive and ignites  spontaneously or undergoes  marked  decomposition whe
          subjected for 48 consecutive hours to a temperature of 75°C (167°F).

     1.   Firecrackers, flash crackers, salutes, or similar commercial devices which produce c
          are intended to produce an audible effect, the explosive content of which exceeds 1
          grains each in  weight, and pest control bombs, the explosive content of which exceed
          18 grains each in weight; and  any such devices, without respect to explosive conten:
          which on  functioning are liable to project or disperse  metal, glass or brittle plasti
          fragments.

     3.   Fireworks that combine an explosive and a detonator or'blasting cap.

     4.   Fireworks containing an ammonium salt and a chlorate.

     5.   Fireworks containing yellow or white phosphorus.

6.    Fireworks  or  fireworks compositions  that   ignite  spontaneously  or undergo marker
     decomposition when subjected for 48 consecutive hours to a temperature of 75°C (167°F).

7.    Toy torpedoes, the maximum outside dimension of which exceeds 7/8  inch,  or toy torpcdoe
     containing a mixture of potassium chlorate, black antimony and sulfur with an average
     weight of explosive composition in  each torpedo exceeding four grains.

8.    Toy torpedoes  containing a cap composed of a mixture of red phosphorus and  potassiurr
     chlorate exceeding an average of one-half (0.5)  grain per cap.

     9.   Fireworks containing copper sulfate and a  chlorate.

10.  Solid materials which can be caused to deflagrate by contact with sparks or flame such a:
     produced  by safety fuse or  an electric  squib, but can  not be  detonated  (see Note 1) b:
     means of  a  No. 8  test blasting cap (see  Note 2).   Example:  Black powder and  lov
     explosives.

11.  Solid materials which contain a liquid ingredient,  and which, when  unconfined (see Not
     3).  can be  detonated  by means of a No. 8 test blasting cap (see Note 2); or which can b
     exploded in at least SO percent of the trials in  the Bureau of Explosives' Impact Apparatu
     (see Note  4)  under a drop of 4 inches or more, but can not be exploded  in more than 5
     percent of the trials  under a  drop of less than  4 inches.   Example:   High  explosive
     commercial dynamite containing a  liquid explosive ingredient,  primarily  nitroglyceri
     component.
                                         A-ll

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12.   Solid materials which contain no  liquid  ingredient and which  can be  detonated, wh«n
     unconfincd (see Note 3), by means  of No. 8 test blasting cap (sec Note 2); or which can  ' j
     exploded in at least 50 percent of the trials in the Bureau of Explosives' Impact Apparat
     (see Note 4) under a  drop of  4 inches or more, but can not be  exploded in  more than .v-i
     percent  of  the trials under a drop  of less  than 4 inches.  Example:   High explosive I
     commercial dynamite containing no  liquid  explosive  ingredient, trinitrotoluene, amatc; J
     tetryl, picric acid, ureanitrate, pentolite, commercial boosters.

13.   Solid materials which can be caused to detonate when  unconfincd (see Note 3), by conta  /
     with sparks or flame  such as produced by safety fuse or an  electric squib; or which can t
     exploded in the Bureau of Explosives' Impact Apparatus (see Note 4), in more than fn
     percent of the trials under a drop of less than 4 inches.  Example:  Initiating and primin ,-
     explosives, lead azide. fulminate of mercury, high  explosives.

14.   Liquids  which may be  detonated separately  or when absorbed in sterile absorbent cottor
     by a No. 8  test blasting cap (see Note 2); but which can not be exploded in the Bureau c
     Explosives' Impact Apparatus (see  Note 4), by a  drop  of less than  10 inches.  The  liqui
     must not be  significantly more   volatile  than  nitroglycerine  and  must  not freeze  sH
     temperatures above minus 10°F. Example: High explosives,  desensitized nitroglycerine.   ,_J

15.   Liquids  that can  be  exploded in the  Bureau of Explosives'  Impact Apparatus (see Note  4r-1
     under a  drop of less than 10 inches. Example: Nitroglycerine.                          '  j

16.   Blasting  caps.  These  are  small  tubes,  usually  made of  an alloy of either copper o
     aluminum, or of molded plastic closed at one end and loaded with a charge of initiating o
     priming explosives.  Blasting caps (see Note 5) which have been provided with a means fo - '
     firing by an electric current, and sealed, are known as electric blasting caps.
                                                                                           n
17.   Detonating primers which contain  a detonator and an  additional charge of explosives, al( |
     assembled in a suitable  envelope.

18.   Detonating fuses, which are  used  in  the  military service to detonate  the  high  explosive
     bursting  charges  of  projectiles, mines, bombs, torpedoes, and grenades.   In  addition to 3
     powerful detonator,  they may  contain several ounces of a high explosive, such a tetryl  or
     dry nitrocellulose, all assembled in a  heavy steel envelope.  They may also contain a small
     amount  of  radioactive  component.  Those that will not cause functioning of  other fuses.
     explosives, or  explosive devices in  the same or adjacent containers  are classed as Class C
     explosives and are not reactive waste.

19.   A shaped charge, consisting of a  plastic  paper  or other suitable container comprising a
     charge  of not  to exceed  8 ounces of a high explosive containing no liquid  explosive
     ingredient and with a hollowed-out portion (cavity) lined with a  rigid material.

20.   Ammunition or explosive projectiles, either fixed, semi-fixed or separate components which
     are  made for  use in  cannon,  mortar,  howitzer, recoilless rifle, rocket,  or other launching
     device with a caliber of 20mm or larger.
                                          A-12

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21.   Grenades.  Grenades, hand or rifle, are small metal or other containers designed to be
      thrown by hand or projected from  a rifle.  They arc  filled  with  an explosive or a liquid.
      gas. or solid material such  as a tear gas or an incendiary or  smoke producing material and
      a bursting charge.

22.   Explosive bombs.   Explosive bombs are metal or other containers filled with  explosives.
      They are used in warfare and include airplane bombs and depth bombs.

23.   Explosive mines.  Explosive mines  are metal  or composition containers filled with a high
      explosive.

24.   Explosive torpedoes.  Explosive torpedoes, such as those  used in warfare, are metal devices
      containing a means of propulsion and a quantity of high explosives.

25.   Rocket  ammunition.   Rocket  ammunition  (including  guided  missiles)  is  ammunition
      designed for launching  from a tube, launcher, rails, trough, or other launching device, in
      which  the propellant material is a solid propcllant explosive.  It consists of an  igniter,
      rocket  motor,  and projectile (warhead) either  fused  or unfused, containing high explosives
      or chemicals.

26.   Chemical  ammunition.   Chemical ammunition used  in  warfare is all  kinds  of explosive
      chemical projectiles, shells, bombs,  grenades, etc., loaded with  tear, or other gas, smoke or
      incendiary  agent,  also such  miscellaneous  apparatus as cloud-gas  cylinders,  smoke
      generators, etc.,  that may be utilized to project chemicals.

27.   Boosters, bursters, and supplementary charges. Boosters  and supplementary  charges consist
      of a casing containing a high explosive and are used to  increase the intensity of explosion
      of the detonator of  a  detonating  fuse.  Bursters consist of  a casing containing a high
      explosive and  are used to rupture a projectile  or bomb to permit release of its contents.

28.   Jet  thrust  units or other  rocket  motors containing  a  mixture of  chemicals capable of
      burning rapidly and producing considerable pressure.

29.   Propellant  mixtures (i.e., and  chemical  mixtures  which  are  designed  to function by  rapid
      combustion with little or no smoke).

      Note 1:    The  detonation test is performed  by placing the sample in an  open-end fiber
                 tube which  is  set on the end of  a lead block  approximately  1-1/2 inches in
                 diameter and 4 inches high which, in turn,  is placed  on a solid base.  A steel
                 plate may be placed between the fiber tube and the lead block.

      Note 2:    A  No. 8 test blasting cap  is one containing two grams of a  mixture of 80
                 percent mercury  fulminate and  20 percent potassium chlorate, or  a cap of
                 equivalent strength.

                 "Unconfined* as used  in this section does not exclude the use of a paper or soft
                 fiber tube wrapping to facilitate tests.
                                          A-13

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Note 4:     The Bureau of  Explosives' Impact Apparatus is a testing device designed so tha_
           a guided 8-pound  weight may  be dropped from  predetermined heights so as t  I
           impact specific quantities of liquid  or  solid materials under fixed condition* '
           Detailed prints may be obtained  from the Bureau of Explosives, 2 Pennsylvania
           Plaza, New York, New York 10001.                                          H

Note 5:     Blasting  caps,  blasting  caps with  safety fuse, or  electric  blasting  caps  ir
           quantities of 1.000 or less are classified  as Class 0 explosives and not subject t<—|
           regulation as a  reactive waste.
                                   A-14

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                     REACTIVITY/EXPLOSIVITY TEST DATA SHEET
     Installation
     Sample Number and Location
      Explosive Components and Concentrations
     Test Result:  Sample is Reactivg/Non-Reactivg (circle J>ne)
Detonation Test
No. 8 Blasting Cap Test I
                  Test II
                  Test III
                  Test IV
                  Test V

Samples:   Five 4 oz. cups
                                   Exploded
                                   Yes   No
                              Deflagration
                              Yes     No
       Test:     One blasting cap per sample.
Spark Test
Electric Match Head Igniter
                     Test I
                     Test II
                     Test III
                     Test IV
                     Test V

Samples:   Five 4 oz. cups
                                   Exploded
                                   Yes   No
                                Burned
                              Yes     No
Thermal Stability Test
                                   Explosion
                                   Yes   No
              Ignition
              Yes No
    Marked
   Decomposition
   Yes    No
Samples:    One 4 oz. cups
       Test:     48 hours at 75°C in vented oven.
Card Gap Test Samples    3 Tubes
Detonation:      Yes
Mo
                                      A-IB

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Impact Sensitivity Test
Bureau of Explosives Impact Apparatus

Maximum Height        Drop Test
                10 Trials

   No. of Trials Exhibiting
                                         Explosion
                                         Flame and
                                         Noise
                No Explosion
                No Flame
                No noise
Approved:

    Test Director
       Test Department Head

       Signature 	

       Title     	
                                                Organization
                                        A-16

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C«rd C»p C«ilulecc
Ac«t*t« Card*
0.01 inch ««ch
Cs«lo»iv«f  Coaeoti
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Cardboard Tub*
               g«p
            *nd VUts
 Hood Stand
                            *•«* /(fr •Btli:*M *****
                                 A-17

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