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 ------- 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. ------- 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. ------- 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/' ' - - - • ------- |