DSHW-1992-002020 - 0901a0688013da6a

y HERCULES
DivisiDn of Sulid & Hazardous Waste
Utah tepaiiment ol Envifonnienta! ftualiiy
Hercules Aerospace Company
Space/Strategic Propulsion
Bacchus Works
Magna, Utah 84044-0098
[phone]
September 16, 1992
DSHW TN
1992.20399
Dennis Downs
Durector
Department of Environmental Quality
Division of SoUd and Hazardous Waste
288 North 1460 West
Salt Lake City, UT 84114-4810
Re: Regulatory Status of Samples Provided for Reactivity Analysis
Dear Mr. Downs:
Hercules currentiy has a contract with the Tooele Army Depot (TEAD) to perform
reactivity testing on various energetic materials. This testing involves subjecting various
propellants/explosives to stimuli such as impact or friction to determine if the material will
initiate. This particular set of tests will determine the cold temperature response of the
materials, i.e., the tests will be run at Uquid nitrogen temperatures.
The results of these tests may eventually be used in the design of cryogenic processes
used to reduce the size of propellant pieces prior to waste treatment. This testing will not
determine how weU these cryogenic processes wiU work, but can determine how suitable a
particular explosive is for cryogenics simply by determining whether or not it is safe to
handle at cold temperatures.
Two of the samples in question must be taken from sources at TEAD that are already
hazardous wastes. Hercules believes that testing to determine initiation response, albeit at
cold temperatures, direcdy reveals information about the reactive nature of the samples.
Since the tests are concemed with die characteristic of reactivity, then the samples themselves
are not considered hazardous wastes under the provisions of 40 CFR §261.4 (d).
Hercules and TEAD wish to confirm that the above conclusion is correct and
accurately reflects the Division's position on this issue. The possibility exists that the tests
could be considered a treatability study because the samples are taken from hazardous wastes.
Regulatory Status of Samples Provided for Reactivity Analysis Page 2
Once again, it is our belief that the testing simply determines the reactive nature of the
material and not the treatability of it. For this relatively small testing effort, both Hercules
and TEAD wish to avoid the hazardous waste regulation involved with a treatability study.
Please review this issue and if you have any questions please contact me at 251-3574.
Sincerely,
-^^^ •Uc^^C-
E. R. Anderson, Manager
Environmental Engineering
and Hygiene
ERA/CDFalkenberg/TooELE3
cc: T. A. Tumer (TEAD)
P. R. Oyler
G. E. Gooch
S. J. Stormd