EPA Issues Report on Alternative Treatment Technologies to Open Burning and Open Detonation of Energetic Hazardous Wastes:
The EPA developed and issued this report in response to inquiries that EPA has received regarding whether there are alternative treatment technologies available to use in place of open burning and open detonation (OB/OD) of energetic hazardous waste, also commonly referred to as waste explosives. This report communicates the current state of alternative technologies that may be applicable for energetic hazardous waste including: munitions and explosives; consumer and commercial fireworks; marine, roadside, and signal flares; auto air bag explosives; and hobby rocket propellants. Specifically, it identifies and describes alternative technologies that have been developed and their status, the types of waste munitions or energetics a technology can treat, and where deployments have occurred. Thus, it provides the formative steps for evaluating the efficacy and the pros and cons of the technologies for particular applications.
This report is intended to be an informative resource for permit agencies, owner/operators, and the public to raise awareness and aid in Resource Conservation and Recovery Act (RCRA) permitting decisions for the treatment of energetic hazardous wastes.
The OB/OD of energetic hazardous wastes is regulated under title 40 of the Code of Federal Regulations (CFR) part 264, subpart X – Miscellaneous Units. The subpart X regulations are general standards that cover diverse treatment technologies and units, including OB/OD units. Miscellaneous units are therefore subject to environmental performance standards rather than technology-specific standards since a single set of technical standards may not be suitable for the diverse types of miscellaneous units. As a result, owners and operators applying for Subpart X permits must ensure compliance of the unit with environmental performance standards. To demonstrate the unit is protective of human health and the environment, the application must provide detailed information on the unit’s location, design, construction, operation, maintenance, monitoring, responses to releases, and closure to prevent and control releases into the groundwater, surface water, surface soil and the subsurface environment, wetlands, and air. This requires the owner or operator to assess the potential environmental impacts of unique design features and to demonstrate that operation of the units will be protective of human health and the environment. These design and operational features then become permit conditions. (See 40 CFR section 264.601). The same procedures would be applicable to most alternative technologies designed to treat energetic hazardous wastes.
Sasha Gerhard
USEPA, Office of Resource Conservation & Recovery