vv EPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9443.05(84)
TITLE: Blasting Caps as Reactive Wastes
APPROVAL DATE: 9-n-84
EFFECTIVE DATE: 9-11-8*.
ORIGINATING OFFICE:
0 FINAL
of Solid Waste
D DRAFT
STATUS:
[ ] A- Pending OMB approval
{ j B- Pending AA-OSWER approval
[ ] C- For review &/or comment
[ ] D- .In development or circulating
headquarters
REFERENCE (other documents):
OS WER OS WER OS WER
/£ DIRECTIVE DIRECTIVE Di
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PART 261 SUBPART C - CHARACTERISTICS
DOC: 9443.05(84)
Key Words: Blasting Caps, Reactive Wastes
Regulations: 40 CFR 261.23
Subject: Blasting Caps as Reactive Wastes
Addressee: David Wagoner, Director, Air and Waste Management Division,
Region VII
Originator: John Skinner, Director, Office of Solid Waste
Source Doc: #9443.05(84)
Date:
Summary:
9-11-84
Blasting caps fall within the definition of a reactive hazardous waste.
40 CFR 261.23 states that a waste which is capable of detonation or explosive
reaction if subjected to heat or a strong initiating force is a reactive
hazardous waste.
The notation in the SW-846 manual stating that blasting caps in quantities
of less than 1000 are not hazardous wastes is incorrect and should be disregarded.
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9443.05 (84)
11 SIT? 19S4
MEMORANDUM
SUBJECT: Status of Blasting Caps as Reactive Wastes
PROM: John Skinner, Director
Office of Solid Wasto (WH-552)
TO: David Wagoner, Director
Air and Waste Management Division
Region VII
This is in response to your recent memorandum requesting ,.'
.clarification of the definition of a reactive waste as it applies
to out-dated blasting caps. According to 40 CFR 261.23, a waste
which is capable of detonation or explosive reaction, if subjected
to heat or a strong initiating force/ is a reactive hazardous
waste. Blasting caps clearly fall within that definition*
As you brought to our attention, Section 2.1.3 of "Test
Methods for Evaluating Solid Waste* (SW-846) appears, however,
to suggest otherwise. A note in the manual states that blasting
caps in quantities of less than 1000 are not a hazardous waste.
This is a mistake. SVr-346 is a compilation of sampling and
analytical methods that may be used to test for the presence of
Appendix VII or VIII constituents. It is not, however, the '
basis on which the identification or listing of a particular
material as a hazardous waste is made. Thus, Note 5- in Section
2.1.3 of SW-345, should be disregarded.
•
• A package of revisions and updates to SW-846 is currently in
preparation; as part of this update, Note 5 will be deleted to
prevont future misunderstandings, we appreciate your bringing
this problem to our attention. If you have any questions, please
contact Florence Richardson of my staff. She can be reached at
332-4801. • • .-"".'
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vv EPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9443.05(84)
TITLE: Blasting Caps as Reactive Wastes
APPROVAL DATE: 9-n-84
EFFECTIVE DATE: 9-11-8*.
ORIGINATING OFFICE:
0 FINAL
of Solid Waste
D DRAFT
STATUS:
[ ] A- Pending OMB approval
{ j B- Pending AA-OSWER approval
[ ] C- For review &/or comment
[ ] D- .In development or circulating
headquarters
REFERENCE (other documents):
OS WER OS WER OS WER
/£ DIRECTIVE DIRECTIVE Di
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