SJ-25-01

LISTING BACKGROUND DOCUMENT

EXPLOSIVE INDUSTRY

Hastewater Treatment: Sludges from the Manufacture and Processingof Explosives (R)

Sp«ac Carbon from ch« Treatment of Hastawtter Containing-Explosive* (R)

Wastevatcr Treatment Sludges from the Manufacture, Formulationand Loading of Lead-Based Inltticlng Compound* (T)

Pink/Red Water from TNT Operations (R)

I. SUMMARY OF BASIS FOR LISTING

Explosives manufacturing produces wastewaters which ar«

often senc co treatment facilities; the reiultlng vaitawattr,

apenc carbon, and/or waittwater tre-ataant jludga* rtiulclng

fron the production of exploilvti havt been found Co contain

explosive conpontnca which can posa an expluilv« hazard; one

af the llatad waitas contain* the toxic heavy n«cal lead,

and therefort, poiet a Coxiclty hazard* The Adalnlscracor

has determined thac the explosives industry gr.nctcaten solid

wastes which may pose a substantial present or potential

hazard to human health or tho environment when iaproporly

transported, created, stored, disposed of or otherwise managed,

and therefort sho'ild be subject to appropriate management

requireneata under Subtitle C of RCRA. This conclusion Is

bated on the following considerations:

1. Hastewater treatment sludges fron the manufacturing andprocasilng of explosives contain significant concentrationsof explosive cowpoundi which could pose an explosion h»z»rJ.

A R I 0 0 0 0 3

It improperly managed, this waste could thus present *substantial hazard to hunan health end the aarlronnaot,Therefor*, thl* waste meet* th* reactivity chuactirli-tic (5261.23).

Spent carbon columns from the treatment of wattewatercontaining explosives are saturated with explosive com-pound* (I.e., BOX, TNT, etc.). Thts waste, If improperlymanaged, could po«e * substantial he.*lfrh-«nd environnentalhazard duo to the axploalve potential of th* constituentsIn this waste. Therefore, this want* malt* the reactivitycharacteristic ($261.23).

Wastewater treatnent sludges (Iron the manufacture, formu-lation, and loading of lend based initiating compound*contain substantial concentrations of the toxic heavy taCallead. The lead Is in a relatively solubln torn, and couldmigrate fron the disposal site into groundwater. Therefore,if this waste la improperly managed and disposed, it couldpose a substantial hazard to human health and the environ-ment.

Pink/red water fron TNT operation* contains high concen-tration* of the explosive compound TNT. If improperlymanaged, thl* waste could Chu* present an explosivehazard, resulting In a aubitantial hazard to human healthand th* environment. Therefore, this wast* mats th*reactivity characteristic ($261.23).

II. OVERALL DESCRIPTION OF INDUSTRY

The explosives industry is comprised of those facllltieo

engaged In the manufacture and load, assemble, and pack (LAP)

of high explosives, blasting agents, propellants, and initiating

compound*. Btgh explosives and blasting agents art substances

vhlch undergo violent, rapid decomposition upon detonation by

heat, friction, Inpaet or shock. Initiating compounds, on the

other hand, are used to initiate or detonate large quantities

of lass sensitive propellants or explosives.

Explosives are manufactured in both the co"ne;cUl and

A R l O O O O l t••(•HI-

military sactors. Those conpanla* (approximately HO) that

coBMrcUlly Manufacture exploilva* art situated geographic illy

In 104 facilities1* located in 30 state* throughout the country.

The states with the greatest number of facilities are

California, Utah, Mltsourl, and Pennsylvania. The military

sector of the explosive* industry 1* segregated Into two

ftroups: Gov*rnm«nt Owned and Contractor Operated (COCO) • plants

and Government Owned and Governnent Operated plants (COCO).

The number of military plant* in thuse two oegaints is

eetlaatac, to be between 23 and 3J. The states with ntjor

GOCO installation* are Tennessee, Wisconsin, Virginia, and

Illinois.

Approximate production range* of individual explosive

product* are gnoupad balowi

Production (average daily productionProduction Range while operating in Ib/day)

Manufacture of Explosive* 1,000 to over 40,000

Manufacture of Propellants 200 to over 30,000

Manufacture of Initiating • under 1 to over 300Compounds

According Co the U.S. fluriau oc Mines3, total consumption

of explosives and'blasting agents in 1973 was approximately

1.8 million netric ton*. This figure only represents domestic

sales by commercial producers. Production of explosives by

*The Bureau of Alcohol, Tobacco and Firearm* Hat* 621 explo-sive manufacturers, including licensees and permittees formanufacture of explosives, distributors, users and mix andM.nd operator, (LAP). AR 100005

-y--C.H2-

the ni.'.ltary sector is not currently availabl*.

la tarn* of growth, total commercial consumption of

explosives and blasting agents has increased each year over

the 1973-1978 period. Consumption has risen from approximately

1.3 million metric tons in 1973 to 1.8 alll-Un metric ton* in

1978, representing an increase of 38 percent:

Out of the total 1978 coniumptlon figure, consumption of

"permlsslblee"1* and "other high explosive*" were approximately

19,000 metric ton* and 81,000 metric ton* respectively. Over

the 1973-1978 period, consumption of permissible! ha* fluctuated

froa year to year; in 1978 consumption was approxiaately 7

percent less than In 1973. However, con*unptlon of permldlble*

is expected to Increase in the future due to increased coal

mining activity to satisfy energy demands. Over the *ane

flva year period, consumption of "other high explosives" ha*

declined each year; in 1978 consumption was approximately 32

percent below 1973 levels. This downward trend is largely

attributable to the inurease use of water gels (permlsslbles

in a slurry form). •t.t \,A. Manufacturing Process**

For the purpose of discussing spaclctc manufacturing

processes, explosive* can be aubcategorized Into the following

three groups: explosives manufacturing (for exsapiie, TNT and

"High explosives approved by the U.S. Bureau of Mines for tneSafety and Health Administration for use in underground coalmines.

"•This document describe* only « few procnssos in the explosivesinduacrj. For a more detailed description, see Reference 22.

ARI00006-X-

RDX), axploilve* processing (for example, dynamite and

nitroceUulose-bai* propellants) and initiating compound*

(for example, load azlde).

Explo»ly»« Manufacturing

Meet exploilvci compounds are manufactured, in a nitration

reaction. The raw matarlal varies, but alwayn includes a

nitrating acid, usually nitric acid or a mixture of nitric

and lulfurlc acid* or nitric and acetic acid* with various

organic compounds (i.e., toluene, cellulose, glycerin, etc.).

The major explosives produced are nitroglycerine (NG), nitro-

glycerine ethylene glycol dlnltrate (NC/EGDN), penuerythr ttol

tetrenltrate (PETN), nltrocalluloee (NC), trinitrotoluene (TNT),

cyclotrlRiathylane cr inltranlne (RDX), and cyclotecramethylen*

tatranltramln<i (UMX) (see Table 1). Flgursi 1 and 2 represent

typical production diagram* for NG and RDX, re*pectiv«Xy.

Kxploslvat Proc*»*iug (Dynamite and Propellant*)

Two types of explosive processes will be discussed below

as examples; dynamite and nitrocelluloae-base propellents •

Dynamite. - Dynnlte formulations art usually composed of

several dry ingredients in varying proportions and nliro-

glyctrln (»ee Tables 2 and 3). In the formulation of

dynamite, all Ingredients except for nitroglycerln and/or

ethylene glycol are premlxed in batch dry blenders In

buildings called "dope houies". The dope and th* nitro-

glycerine and athylene glycol are then batch blended in

th* mix housii The ml* In transported to packaging

ARI00007

•houki* wh*r* they are loaded Into waxed cardboard boxc*

or plaatic tube*.16

Nitrocellulose-Bated Pr ope Hants

Nitrocellulose-based propr.Uants can be divided into single,

double, and multi-based propellents.. ih«i* propellent* are

made by colloldlng and moldiBjj processes" not unlike those

used in the plastics Industry. Single base propellent* are

compositions consisting mostly of nitrocellulose with minor

aaoui'ts of plaitlcizer*, stablllzars, burning rat* catalysts,

etc. Double base Implies nitrocellulose plus a liquid nitrate

ester, usually nitroglycerln, with stabilizer*, catalyst*,

etc.; snd Multi-base Implies a combination of several nitrat*

materials such an nitrocellulose, nitroglycirln, aitroguanlt... .4,

trlethyleneglycol dinltrate, with etabillzer* and the Ilka.26

Inltating Compound*

Initiating compounds are manufactured by nitrating the

starting muterlals (see Table 4) and precipitating the

explosive. The three general steps are: (1) reacting the

starting ingredients and precipitating the product in a

kettle; (2) filtration; and (3) washing the product to

remove impurities). Typical Initiating compounds Include

tetracene, trinltroresorclnol (TNR), lead aside, lead

styphnate, lead monomltroranorcinate (LMR), tetry and nltro-

aannlt*. Figures 4 and 5 are typical flow diagram* for th*

production of initiating compound*, illustrating typical

lead axida and lead mononitrurescorcinate production schema-

tic, rospectlveiy. AR I 00008 |

-./ȣ,

-C.HS"-

B. tfait* Generation and General Deicrlpttoa

four »olld wait** g*ner«t*d in th* explosives Industry have

been ideutlfled and are described below. The production and wa*t*

treatment method* which generate these watte* are not usually found

In any single facility.

Haactwattr Treatment Sludges from the Manufacturing• .*

and Processing of Explosives*

Sludges are generated when wash water* paeo through settling

or catch basin* or screen* to remove partlculate exploslva residues.

Son*, but not all of th* concentrated sludge* are re/turned to th*

process. For clarity, explosive manufacturing and explosive pro-

cessing will be discussed separately,

Explosive Manufacturing

A* Illustrated in Figure* 1 and 2, during the manufacturing

ef explosive compounds, w«atew«ter* are generetid during the

filtration/washing and th* cleaning of th* production equip-

ment and facilities. Such uantewater* consist of particles

of th* explosive compound juupendod In the wastawatir along

Kith solvents and cleaning agints. The partlclos of explo-

sives are removed by gravity separation In catch basins or

Battling tanks. The resulting sludges contain significant

concentrations of the explosive compound (I.e., nitro-

glycerine, TNT, RDX/UMX, ate.). While some of these sludges

may be recycled back to tha process, they are generally too

•Catch bailn material* in RDX/HMX production was proposed a*a hazardou* wast* on Dacember 18, 1978 (43 FR 58959). Thl*waste str«am will not b* listed in the final regulations sinceit la already Incorporated in this listed waste atream.

-/• ARI00009

contaninatid with extraneous material to be rtu*ed. These /*

sludge* coB*tltut* the fir»t listed wa«ce *iri in aad are

marked I in Figure* 1 and 2.*

Explosive Processing (e.g., bleating agents and ordinance)

During the processing of explosive compound* into commercial

• nd military explosive agents and pr«p«n,ants, waitewaters

containing explosive compound* are produced during icveral

operations. Among these operation* are th* following;

•' Cleaning of blending, packaging and handling uqulp-ment and itorag* facilities;

' Wet milling of proptllant castings;

' Operation of air pollution control devices whichemploy wet scrubbers to control emissions anddust Inside production buildings;

' Loading, assembling and packaging of ordinance.

Treatment of the** waitewater* also produce* « wastnwater

treatment sludge.(**)

Spent Carbon from the Treatment of Explosives Containing

Hastewatars

Because of the potential hazard that might reault fron

the discharge of wastewater contaminated with explosives,

a number of allitary Installations employ carbon treatment

•The other waata which 1:'. generated (as shown in Figures 1 and 2)consists of spent acid solutions resulting from th* nitrationstep. Acidic wastes are usually recovered for reuse followingacid reconcentr/ttion or reprocessing. Presently, the Agency doesnot have any data to justify listing this waste. However, If thesespent acids ar* hazardous as defined in Subpart C of Part 261, thegenerator would be responsible for managing th««* wastts under theSubtitle C regulatory control lystem.

•y- A R I O O O I O "

of th**« »**t«w*tiirs, which result fron the loading, assembling,

and packaging operations. Thl* treatnent 1* deilgned to

remove organic contaminants (Including those that are explosive)

from the wsatewatar after the initial settling (see tfa«eewater

Treatment Sludgii froa the Manufacturing and-Jroeming of

Explosives).

During carbon traatment, the aqueou* wait* 1* passed

through chambers or column* containing activated carbon. The

explosives and other organic contaminants are then abaerbed

into the carbon. After the carbon becomes saturated, It is

removed from th* chamber or column; friah carbon is then

added and the spent absorbent discarded. At thia point, •

the carbon contain* high concentration* of exploilv* com-

pound*.

Wastewater Treatment Sludges from the Manufacture, Formulation

and Loading of Lead-Bated Initiating Compounds

During the various stages in the manufacture and

formulation of lead-based initiating compounds and their

fabrication into finished products, wastewater contaminated

with th* initiating compounds and their feedstock Is produced.

These wastewaters are treated In a catch basin and the re-

sulting sludge* treated with either sodium hydroxide or heat

to remove any residual explosive material. However, while

this proc*** removes any possible reactivity hazard, the

sludge still contains substantial quantities of leechable

lead.

A R I O O O I I

Pink/Red Water froaTNT^ Operation!

During the production and formulation of TNT and TNT- ,

containing formulation* and product*, an alkallna, rad-jolored

aqueous waste is generated. This waste itrean li competed of

TNT purification filtrates, air pollution control scrubber

effluents, washwatar fron cleaning of equipment and facilities,

end washwater from product washdown operation* («>8>, cleaning

of loaded shells prior to packaging). Th* pink or red

coloration of the waite stream remits froa contamination of

the wetir with trice* of TNT (solubility of TNT In water 1*

1 ng/llter). Red water Is aore concentrated, and thu* nor*

contaminated than th* pink watir.

C. Quantities of Haste Generation

It 1* estimated that th* total amount of hazardous wait*

generated by all commercial and GOCO facilities 1* approximately

21,500 tons (19,350 metric tons dry bails) per day.' Approxi-

mately eight percent of the waste 1* froa commercial sources

and 92 ptrcant is froa military and GOCO source* (Table 5).

IV. CURRENT DISPOSAL PRACTICES

Current disposal practices for the four listed wastes may

be summarized as follows:

' Ha*ttwater treatment sludges from the manufacturingand' processing of explosives.

In explosives manufacturing, the wastewatar treat-

ment sludges removed from the manufacturing of explosives

are typically disposed of by open burning. Some plants,

however, make ui* of percolation/evaporation pond* for

A R I O O O I 2

final ditposal of conpounda like NG, whsre the liquid

laachna into the ground. Another technique employed by

pome plants it the discharg* of wanttwster to earthen

aump* where, twica a year, the sumps are allowed to dry

up and the sediments ^contaminated for residual NG and

DNG (dinitroglycarin); decontamination ujjjally Involve*

placing the explosives on the bottom of the tump and

detonating the explosives.

" Spent carbon from the treatment of wascawatar con-taining explosives

At present, the spent, carbon an typically disposed

of through open burning or incineration.

• tfastewater treatment sludges from the manufacture,formulation and lotdlng of lead-based initiatingcompound*.

The wastewater craatnent sludges are treated by

boiling and/or the addition of a caustic solution,

usually sodium hydroxide and aluminum, to decompose any

residual explosive compounds. After treatmtnt, the

• sludges are sent to a lagoon. The sludges fron the

lagooni are removed every few years and disposed of in

a landfill.(*) In some cases, however, the sludgts

from the suap'S and storage tanks will be seat directly

to * landfill after treatment.

' Pink/red uat*r from TNT operations *

*Th* Agency is aware that under full production, AAP1* haveused tha rotary kiln to incinarata pink and r«d water.However, presently the Agency does not have adequate Informationon th* residual ash to warrant * listing.

. A R 1 0 0 0 1 3

Disposal practices that have been used include

the placing of pink/red water In evaporation ponds.*

V. DISCUSSION OF BASIS FOR LISTING

A. Hatardom Properties of the Wastes

Solid w«ste materials generated by'tTia explosive*

Industry contain a nunber of explosive component* which, if

Improperly managed, could pose a substantial hazard to human

health or the environment. Data presented in Table* 7-10

support the listing of these waste streams.

1. Uastewatera generated froa the manufacturing and

processing of explosives have bean found to contain

significant concentration* of explosive compound*

such at nitroglycerine, nitrocellulose, TNT, RDX, HMX,

and other nltratad compound* (Table 7), The** explo-

sives art highly sansltlve to Impact, heat, and friction,

Most of these compound* are relatively insoluble in

water (see Table 6); thus they are expected to settle-

out of the waetewatar and be present in the wasta-

»«ter treatment sludges. The oresence of these ex-

•The disposal of pink/red water In evaporation ponds generatesa bottom sludge which is typically removed and open burned.(These sludges are Included In the first listed wait* scream(I.e., "Haitawater Treatment Sludges from the Manufacture andProcasalng of Explosives." The industry practice of open burn-ing these wastes Is employed because it la by far the **festmethod of handling these highly reactive wantaa. This cautiousdisposal practice by the Industry substantiates further thehazards posed by thase wastes If they are not properly disposedof and nanaged.

A R I O O O H i-x-

plotives in the sludges pose a substantial explosive

hazard to human health and the envrlonment; therefore,

this waste aeets the reactivity characteristic (§261.23).

2. The spent carbon, when wasted, are saturated with

high concentrations of explosive eorapoutxU (i.e., TNT

and RDX) (Table 8). These compounds are highly reactive/

explosive, and thus, the presence of these explosives

In the spent carbon would thus pose a substantial hazard

to both human health and the environment; therefore, this

waste would meet the reactivity characteristic (261.23).

3. Waatewater treatment sludges from the manufacture,

formulation, and loading of lead based Initiating com-

pounds have been shown to contain significant concentra-

tions of lead (Table 9). This waste, if Improperly

managed, could pose a substantial hazard to human health

and the environment. Typical Industry disposal of this

waste 19 in a landfill, which, if subjected to an acidic

environment, will certainly enhance the solubility of lead

and other heavy me.'als, since their solubility la pH de-

pendent (I.e., solubility Increases ai the pH decreases). (•

The hazard associated with the IsschlTg of laad from

Improperly designed and operated landfills is the migra-

tion of this contaminant into ground and surface waters.

Thus, if solids are allowed to be disposed of in areas

with permeable soils, the solubilized lead could migrate

fron the site to an aquifer. Surface water* may alao

become contaminated If run-off from ths landfill

controlled by Appropriate diversion eysttnt.

Compounding this problem, and an important consldeia-

tlon for the future, is the fact that should cha lead

escape from the disposal site, it will not degrade with

the passage of time, but will provide 'a potential source

of long-term contamination.

4. Finally, red and pink water from TNT operations have

been shown to contain significant concentration* of TNT,

which is an explosive (Table 10). These compounds are

also highly reactive/explosive, and thus, the presence

of TNT In the pink/red water would also pose a substantial

hazard to both human health and the envlronnent; therefore,

this waste would meat :h; rec«:lvity characteristic ($261.23).

B. Health ar.i Environmental Effects

Lead is a toxic compound that could threaten the health

of both humans and other organisms. The hazards associated

with lead Include neurological damage, renal damage and

adverse reproductive effects. In addition, lead is, carcino-

genic to laboratory animals, and relatively 'toxic to fresh-

water organisms.. ,It also bloaccumulates In many species.

Additional information on lead can be found in Appendix A.

Hazards associated with exposure to lead has been

recognized by other regulatory programs. For example, Congress

designated lead as a priority pollutant under S307(a) of the

Clean Hater Act and an Interim drinking water standard of

0.05 ppm has also been promulgated by EPA. Under R6 or the

R R I O O O I S-•/.--C.53-

Occupational Safety and Health Act of 1970, * final standard

for occupational expoture to lead ha* been established. (23,24,.

Also, a national ambient air quality standard for lead has

been announced by EPA pursuant to the Clean Air Act.(24)

In addition, final or proposed regulation of .tjja states of

California, Maine, Maryland, Massachusetts, Minnesota,

Missouri, New Mexico, Oklahoma and Oregon deflnu lead con-

taining compounds as hazardous wastes or components thereof

A R I O O O I 7

A R I O O O I 8

n

(Q ~

(.Si-

00020

WATER

NITRIC ACID'——i

NiNOj.Ns2C03 '

KILUTANK

DISCHARGE

- 53.Sou—a:

-/r-

Nl°H • , WATER WASH' '2 ACETONE WAS15!

LEAD NITRATEI " , 3AMYLACETATEWASH

REACTOR TUB

LiWASH-FILTER

• AMYLACn'ATE WASHCAUGHT AND BURNED

rWATEH WASH WASTE

ACEXCESS WATERBS.CTORTUB ACETONE WASH WAST,

ARI00022

VII. TABLES

-jrf-

SGBfiSHS1

ARIQOO'214 '-»*•

S 2. QOMM 3«S33S3 OF B

nitratechloride

Scdia nitrateScci : a chlsrideCalciua cassaateCalcL« stearata . . SuiteNitrocellulose •Kjenollc reala es glass SeedsBacass*Sawrist e.nd MKC floutCoalCom meal a.id c=m starchZxs&stii saltsGrain' »d '**** &&* »- ^

Scrrce: (4) page H-2.

TSSCXL coccsim? c? sawcs

. vfc..

acncnica nitrate 50-S5nitscjlyeseine ' • ^18sodiua rj-crata • 0-17tsace ingredients ' . . 10-35

Source: (11) Table 7, 05-30-

ARI00025

Xa-TSs 2-'££»!*»*

sidiae bicar *1*'sul£uric affA

, . ifuric acWf ^ *" 'BescaciM1' suiasws ^i. ,*- ni*"ate or lead acetate,

SSSS' a

(aa5nesi- 'iWdniCTt*ff - :c acid, nittic acid

NitricTetryl

lead'' . c acid,—

(\RlQ0026

00027

lS 6 •

,, slvrtaco-

water

0.68 5/100° ' . 2°'Cwater u>0 " 2S*C.cetcne

•i -solublewater ~'~

'0.025/100*u ^O.Q95/1005

2.95 00

'cthac .

' 0.04

AR00028

TABLE 7.

1, tfiiitovatir tr«atn«nt sludges Iron che nanu.'actur*and processing of exploiivefc (R)

Process Waste (Concentration)

Nitration of cellulose Sludge (2515 vater and(Note; nitrocellulose 75* nitrocellulose) acis used in a nunber of 60 ton/yr at one plantIndustrie*)!'

Nitrocellulose NC fines lose in overflow(NC) Production5 will be picked up in settle

baiin or other waste watersludge and 1* estimated at1 metric ton (2200 J.bs) perda/ per line or about 0.072*of NC output.

Nicrojtlyeerin (NC) production^ NG lost to waitewater at0.006 kg per Kg NG produced

Nitroglycerln production2 NG discharge* in waitewacer:as high as 1000 rag/1

TNT production2 100 ng/1 of TNT to wastevacai

Nitrocellulose production2 NC fines can produce levels ofsolids froa 1000 to 10,000 ng/1

Batch Nicrogl/cerln Production7 Mascewacer (315 to 12,700 ppn)

Combined wastcwater of Ridford Nlcroglycertn in waatewaterAAF continuous NC Nitration and (800 to 1,300 ppn)Spent Acid7

RDX/HMX production7 Catcli basins remove 33percent of SD.'J and 62p e r c e n t ot HMX from

-If-

TABLE 8. .

3. 3p*nt carbon fro* the tr«*t«*nt of wastewatar containingesploflivts (B.)

Process Haste (Concentration)

LAP Melt loading of Composition B* w*shlng»lOSan Cartridge' to Ca'rflon Colunn* at a

< ' rate of 3.64 kg per 10,000loaded rounds

LAP <tOnn Cartridge' Conpotitlon B Co CarbonColunns at a rat* of 0.45Kg per 10,000 loaded round*

"Composition B--60X RDX. 39* TNT, IX Wax

TABLE 9.

4. Ha«c«wac*r tr«atn*nt sludges froa nanufactur*, fornu-latlon and loading of Iced b«aed Initiating compounds (T)

Process Haste (Concentration^

Initiating Compound)1-5 Aqueous waste containing0.'3I Pb 3 at one plantChat produced 300 M galper year

Initiating compounds1' Precipitate 100X. Pb C03,one plant produced 1 tonper year.

Initiating Compounds1' Aqueous Waste (Pb 1.2 ppn)one plant producing 12.5 Mgal/yr

Production of lead azlde 200 ng/1 In wastiwater whichand lead scyphnaee* contributes approximately

I Ibs a day of Pb <

•<•<•»• ARI0003

TABLE 10.

i. Plnt/rsid wacsr froa TNT operation* (R)

Process Hastt (Concentration)

TNT Production^ R«d water tolld* ar«(batch process) produced at « rate of

(0.239.8 kg par Kg TNTproduced)

TNT Production^ Red w*c*r produced at(continuous process) n rat* of )0.50 kg p*r

kg TNT) produced whichcontain* 6* TNT l*o«*r«and alpha- TNT

LAP2 Pink water with about4.5X TNT (M.6-TNT)and by product* (lsoa*r»)

TNT Production^ . Kid water (0.34 kg per kgproduced TNT)

Evaporator Condtniat*7 Pink w*c*r («• high a* 150(A aourcc of pink water) ng/1 of TNT)

Not*; Despite the relatively low TNT concintratlon ofevaporator condiniata, Ch* nan discharged nay be *ub*cantlal.For example, at full TNT production th* cond*n*ate dischargedfor Joll*t AAP i»'projecC*d at 325: gal* .per minute. A TNT'concentration of 4 ng/1, this repreients a daily-dischargedof 15.6 pounds of TNT.'

RRI00032

VI. Reference*

1. Van Noordwyk, H., L. Schallt, H. Wyis, and H. Atkins.Quantification for municipal disposal methods forindustrially generated hazardous wastes. EPA No.600/2-79-135. Municipal Envlronnencal ResearchLaboratory. Cincinnati, Ohio. NTIS PB No. 140 528.August, 1979. • +

2. U.S. EPA. Development document for interim final efflu-ent llnlcaclons, guidelines and proposed new sourceperformance standards. Effluent Guidelines Division,Office of Hater and Hazardous Materials. Washington,D.C. EPA No. 440/176-060. March 1976.

3. Bureau of Mines, U.S. Department of the Interior.Mineral Industry surveys. Explosives Annual 1978.

4. Paccerson, J,, N. I. Shapira, J, Brown, H. Duckerc, andJ. Pjlson. Scace-of-che arc: Military explosives andpropellants production induacry. V.II. Hasce characcerl-zacion. EPA No. 600/2-76-213b. NTIS PB No. 260 918.August, 1976.

5. THH Systems Group. Assessment of industrial hazardouswaste practices: Organic chemicals, pesticides, andexplosives Industries. NTIS PB No. 251 307. April, 1975.

6. Hudak, C. E, , and T. B. Parsons. Industrial processprofiles for environmental use. Chapter 12, The explo-sives Industry. NTIS PB No. 291 641. February, 1977.

7. Paccerson, J., J. Brown, H. Duckerc, J. Poison, andN.I. Shapira. State-of-the-art: Military explosivesand propellanca production Industry. V . I t t , Waace-water treatment. EPA No. 600/2-76-213c. NTIS PB No.265 042. Occober, 1976.

3. JIoc used In texc.

9. Moc used in cexc.

10. Not used In text.

11. Pacterson, J.V., and R.A. Mlnear. SCaca-of-che~artfor the Inorganic chemicals Industry commercialexplosives. EPA No. 600/2-74-009b. NTIS PB No.265 042. March, 1975.

12. Xot uaed in text.

AR100033

13. Not used in text.

14. Hydroiclence, Inc. Draft dev*lop»«nt docunent for proposedeffluent limitation* guldallneo, new source performancestandards and precreatment standards for the explosivesmanufacturing polnc source category. April, 1979.

15. Not used in text.• *

16. U.S. EPA. The health and environmental impact* of leadand an assessment of the need for limitations. Officeof Toxic Substances. EPA No. 560/2-79-001. NTIS PB No.296 603. 1979.

17. Not used In text.

18. Not used In text.

19. State of New Jersey, Unpublished Date. Waste charactarl- .zatlon data fron the State file of "Industrial Halt*Survey*". To Claire Helty of OSH. 8/31/79 and 9/4/79.

20. Not used in text.

21. Not used in text.

22. JRB Associates, Inc. Evaluation of treatment, storageand disposal cechnlques for ignltabl*, volatile andreactive wastes. U.S. EPA, OSW. Contract Number 68-01-5160 (Draft)- January 17, 1980.

23. U.S. Departm«nt of Interior, Bureau of Mines. Mlnerr.1commodity summaries. 1979.

24. NIOSH. Registry of toxic effects of chemical substances.U.S. Department of Health, Education and Welfare,National Institute for Occupational Safety and Health.1977.

25. U.S. EPA. States Regulations Files. Hazardous WasteState Programs, HH-565, U.S. EPA, 401 M St., 5.H.,Washington, D.C. 20460. Contact Sam Morekas. (202) 755-9145.

26. Not used In cexc.

27. Pourbslx, M. Atlas of electrochemical equilibriaIn aqueous solutions. P*rg*non Press, London. 1966.

28. RCRA 3001 Docket. Memo of telephone conversion betweenThomas Hess of JCAP and Chester Oszman of EPA, datedAugust 25, 1980.

ARI000314

RCPA 3001 Docket. Memo of telephone conversation becweeiMajor BaAkowikl of the U.S. Army and Chester Osznan ofEPA, dated August 25, 1980.

ARI00035

SJ-33-01

Reiponi* to Cosment* - EiPlosives Induetry <•""'

Haetewater treatnent sludge* froo th« uanufacturlag end

proce**<:ig of exploslv** (K044), ipent carbon froa the treatment

of waitewater containing axploslvee (K045) aod pink/red watar

fro* TNT operation* (K047) ere llscad a«'h*zardou* because

then* wasces have been found to contain slgnl/lcant concentration*

of explosive component* which can po«* an txploolr* hasard;

thus, aeet* th* reactivity characteristic ($261.23). On«

comaenter disagrees with the Agency line* th**e wasted are

not reactive as determined by DOD case mithoi* and, thu«,

reconnend* that these wnite* be rtnoved frooi Section 261.32.

Specifically, In reference to haxardou* wast* listing

No, K045, th* conminter stated that filtration of pink water

through carbon absorption coluan* result! la thl accumulation

of spent carbon (i.e., granulated carbon contaminated with

TNT/RDX/UMX), Further, regular disposition of wet spent

carbon 1* by open burning. In casting spent carbon, th*

results Indicate thet this naterlal 1* insensitive to initiation

when wet (25-30 percent UjO).

In reference to hazardous waste listing No. K047, the

commenter he* tested the waste using detonation propagation

cescs and reported results which have shown chat aqueous

slurrle* will not support a propagating decollation at concen-

trations of 30 percent or lower (!.«., lies than 31* TNT in

watar) in either a gelled or settled condition. Slnllarly,

ARI00036

aquuous gelled ilurrlia of RDX and HMX at concentration* of

20 percent and HMX at 5 percent or less concentration are

non-propagating. Further, data on 35 percent TNT liquor

indicated that the waste scream was insensitive to friction

pendulum, drop weight, rifle bullet, sliding j'od, and confined

steel pipe cests.

Finally, for hazardous waste listing No, K044, no direct

comment was put forch except that the background documentation

is insufficient to support the listing and that the deteralnaclon

of whether ic be listed should wait further documentation.

Two other points were made In the comments on the explosive

listing. First, red water has been previously sold a* a raw'

material to the paper industry and therefore Is not a manufac-

turing by-product which ha* been typically discarded, Secondly,

rather than a blanket inclusion of these wastes (K044, K045, and

K047) in the hazardous waice list, the commenter suggests that

the determination of whether and when the above listed wastes

are subject to the hazardous waste rules is best made (on a

case by case basis) by each generator, In light of whether

his waste exhibits ac any cine any of the hazardous waste

characteristics set forth In Subtitle C.

The Agency agrees with che comnencer chat chase explosive

Induscry wascewacera, waatswacer sludges, and aoenc carbon

which contain a significant amount of waCer will not be

AR10Q037

readily leniltlv* Co detonation, For example, spent carbon

containing 25-30 percent or more of water and TNT sludges

containing 65 percenc or more or water would be difficult to

detonate.

The Agency is aware,(a* Is the conneivcer), however, chat

a problem doec ?rl*a when the spent carbon and- wastewater

sludges are allowed to dry; the drier che material, che more

reactive the substance. This point was confirmed during

a telephone discussion with che Department of Army,28,29

An additional consideration is that this particular comment

was restricted to TNT, HMX, and RDX, which leaves a large

segment of che explosive industry without comment. For example,

nitroglycerine shavings fron the production of rocket motors

being practically Insoluble in water presents a different

handling problem than the TNT liquor (red water). The allied

•having are easily eepereted fron the water stream and may,

over cloe, self-lgnlce.

Therefore, che Agency believes, In light of plausible

mismanagement practices (for example, the deposition of red

wacer In sanlcary landfills or surface Impoundments), chat

sludges, generated from Che manufacturing and processing of

explosives, red/pink wacer from TNT operations, and apenc

carbon from the treatment of wastewatar concalning explosives

will dewater over time and accumulate solids thus resulting

in an increased reactivity haxard. Surface impoundments

ARI00038

-1.1 r-

have been used In the past for the deposition of red/pink water,

and a botton sludge ha* accumulated over the rear* which toad*

to dry over the depth of the «ludge. Further, the TNT *ludge

Is not readily degraded, becomes reactive when dry, and Is

somewhat coxlc. Dry TNT, is also classified as a Department

of Transportation-Explosive A.2^ • ' •*

In view of the above discussion, the Agency will maintain

che currenc listings of che explosive Industry (K044, K045, and

K047). The Agency recommends that individual exploniv* plant*

who bolieve their waste stream(s) haa properties which are

fundamentally different from those which the Agency haa cited

In che background document aa che basis for listing should

file a petition for dellstlng in accordance with Sections

260.20 and 260.22 (peclcion* to amend Part 261 Co exclude a

waste produced at a particular facility).

ARI00039

'(.Ito-