vv EPA
               United States
               Environmental Protection
               Agency
            Office of
            Solid Waste and
            Emergency Response
DIRECTIVE NUMBER:

IIILC.
                    classification of Small Arms Ammunition with Respect to
                    Reactivity
               APPROVAL DATE:  U-SO-BA

               EFFECTIVE DATE:  11-30-8A

               ORIGINATING OFFICE:  Office of Solid Waste

               0 FINAL

               D DRAFT

                 STATUS:
         [  1
         [  1
         I  1
         [  1
A- Pending OMB approval
B- Pending AA-OSWER approval
C- For review &/or comment
D- .In development or circulating

          headquarters
                REFERENCE (other documents):
  OSWER      OSWER      OSWER
fE    DIRECTIVE   DIRECTIVE    Di

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PART 261  SUBPART C - CHARACTERISTICS
                                                DOC:  9443.10(84)
Key Words:    Reactive Wastes

Regulations:  40 CFR 261.23(a)(6)

Subject:
Addressee:


Originator:

Source Doc:

Date:

Summary:
Classification of Small Arras Ammunition with Respect to
Reactivity

David Wagoner, Director, Air & Waste Management Division,
Region VIII

John H. Skinner, Director, Office of Solid Waste

#9443.10(84)

11-30-84
     Off-specification small caliber ammunition (ball or sporting ammunition
of calibers up to and including p.50) is not "reactive" within the meaning of
40 CFR §262.23(a)(6).  The disposal of such ammunition is not subject to Sub-
title C hazardous waste requirements.

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                                                              9443.10 (
                           30NOV1984
HEMORA.'lDi'J'l

SUttJ£CT:  Classification of Small Arms Ammunition
          with Respect to Reactivity

   F«OM:  John H. Skinner/ Director
          Office of Solid Waste (WH-562)

     TO:  David Wagoner, Director
          Air & Wasto Management Division
          Region VI IT

     Recently, a'question arose as to the status under RC?\ of
off-specification snail arms ammunition (ball or sporting
ammunition of calibers u? to and including 0.50) intended for
disposal.  The issue concerned whether such wastes are "reactive
wastes" within the meaning of 40 CFR 261.23(a)(6) and, therefore,
subject to RCRA hazardous waste requirements.  Because the
ammunition contains an ignition source that may be shock and 'heat
sensitive and is designed to generate high pressure during u«»e, it
had been our opinion that it is probably  "reactive."  However, on
the basis of information that was received from the Remington
Anns Company and the Army, we now conclude that such material*'
are not "reactive" within the meaning of  40 CFR 261.23 (a)(6).

     Section 261.23 (a)(6) of Title 40 provides that a. solid
waste which is "capable of detonation or  explosive reaction if it
is suhjocted to a strong initiating source or if heated under
confinement" is "reactive."  As discussed in the May 19, 1930,
preamble to 40 CFR 261.23, shock and thermal instability are
important elements of this definition.  While presently there is
no Agency guidance regarding these criteria, the Remington Arms
Company of Independence, Missouri, and the U.S. Army have provided
information which addresses both of these factors.

     Remln-jton Anns Company submitted- details on the effects of
heat and impact to small arms ammunition.  There was no explosion
when a box of anmunrtion was set afire.  Small ar-n*, when subjected
to the SAA'il (Sporting Ams a'rvl Ammunition Manufactur*»r's Institute)
Impact Tost, showed no evidence of mass propagation or explosion.

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     The Department of  the  Army  has  a rigorous  safety and hazard..
tasting program on .all  munition  items.   The  teats,  which include,*
drop tests from 5, 7, and 40  feet  to simulate handling errors
and ."heating under confinement,* 160*F for 4* hours*  also
showed no evidence of detonation or  explosion with  res poet to',
small arms ammunition.   The  tests were  performed on-both the
individual munition and a package  containing a  prescribed number'
of items.     -   •         •""'-'       '        '  '              ' ""
     l                   .••.".                      -   r
     As noted  above, we feel  .that  results  from  these  tents show
that off-specification  small  caliber ammunition up  to and including
0.50 is not "reactive"  within the meaning  of 40 CFR «2*1.23 (*}(fi\S
We, therefore, believe  that the .disposal of  such ammunition is  not"
subject to Subtitle C hazardous  waste requirements.        " _."•'
                        '*•'••*.'.' r " - •                               ' ' •'
     We appreciate your'cooperation.   If you have any questions    •-
regarding, the matter, please  call  David  Friedman or Florence Richardsot
at FTS 382-4770. -   •  -    '-                        ...... .....  .-


          •••-••-•>  ••.••..-      .   -          ,
cct  Air & Waste Management Divisions Directors,
    .Regions I-VI and VIII-X/'    '    -    -   -  •

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