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:
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[ 1
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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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