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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