DSHW-1992-003523 - 0901a0688015746e

IM HERCULES Hercules Aerospace Company
'" ^^^^^^^^^^ Space/Strategic Propulsion
Bacchus Works
Magna, Utah 84044-0098
[phone]
April 21, 1992
DSHW TN
1992.20409
Dennis Downs
Director
Department of Environmental Quality
Division of Solid and Hazardous Waste
288 North 1460 West
Salt Lake City, UT 84114-4810
Re: Regulatory Status of Waste-Related Testing
Dear Mr. Downs:
This letter is to confmn the conclusions of a meeting that was held between Hercules
and your staff on March 11, 1992. The meeting was attended by Bill Sinclair, Don Verbica,
Rachel Shilton and Bill Wallner of the Division and Susan Jew and myself representing
Hercules.
As discussed at the meeting, Hercules is considering contracting to perform work
related to characterizing explosive, pyrotechnic and flammable materials according to new
Department of Transportation requirements. Such work would involve exposing samples to
energetic stimuli such as heat or shock to determine that material's properties under such
conditions. In some cases the material to be characterized may be a waste stream that the
generator wishes to ship.
A similar situation is work that Hercules wiU be performing for TRW. TRW wishes
to design a facility for disposing of air bag propellant. Hercules will be performing a series'
of tests to define effective initiating methods, parameters for design of an air pollution control
system and other information. The samples for these tests will be propellant mixtures
formulated to represent various conditions that are expected in the waste stream; for example,
there will be a series of samples containing specified amounts of moisture.
It was the conclusion of this meeting that these activities are not regulated as waste
treatment as long as the samples are not themselves waste. That is, samples should be
materials specially prepared to represent a waste stream, rather than collected from the waste
stream itself. If testing needs to be conducted on actual waste materials, either the regulations
for treatability studies or other hazardous waste regulations would apply.
BW-lOOO/689 (REV 4/91)
Regulatory Status of Waste-Related Testing Page 2
Please review this conclusion and let me know whether this accurately represents the
Division's position on this issue. For this type of testing, that is highly variable but uses
small samples, Hercules would prefer to avoid hazardous waste regulation, particularly since
the provisions for treatability studies may not apply. If you need additional information,
please contact me at 251-3574 or Susan Jew at 251-4748.
Sincerely,
E. R. Anderson, Manager
Environmental Engineering
and Hygiene
ERA/SEJew/sg/sHWPrr38