Energetic Hazardous Wastes
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About Energetic Hazardous Wastes
Energetic hazardous wastes or “waste explosives” include wastes that have the potential to detonate and bulk military propellants which cannot safely be disposed of through other modes of treatment. Energetic hazardous wastes include, but are not limited to, a range of explosive items such as:
- Munitions.
- Consumer and commercial fireworks.
- Marine, roadside and signal flares.
- Hobby rocket propellants.
- Automobile airbag propellants.
Munitions
Munitions contain propellants, explosives and pyrotechnics in many different forms including bombs, warheads, grenades, mines, missiles and ammunition. More information about munitions and the energetics they contain as well as how they can be treated when they become wastes, can be found in the Energetic Hazardous Wastes Treated by OB/OD section of the report Alternative Treatment Technologies to Open Burning and Open Detonation of Energetic Hazardous Wastes.
Regulations Specific to Military Munitions
In 1997, EPA finalized regulations that identify when conventional and chemical military munitions become a hazardous waste under the Resource Conservation and Recovery Act (RCRA), and that provides for the safe storage and transport of such waste. This rule is known as the Military Munitions Rule (PDF)(36, 333 K, About PDF). The regulations created by this rule can be found in title 40 of the Code of Federal Regulations (CFR), Part 266, subpart M.
Fireworks
Every year, the United States generates tons of waste energetics in the form of commercial and consumer fireworks that are unused, damaged, fail to function or some other reason that causes them to become a waste. Discarded fireworks may be hazardous waste due to their reactivity, but may also be hazardous for their ignitability (because many contain oxidizer chemicals) and/or toxicity characteristic due to their metal content.
Application of RCRA to Waste Fireworks
There are safety concerns with handling, transporting, and treating or destroying of waste fireworks. Find more about the safety concerns, best management practices and standard operating procedures for waste fireworks in EPA's July 2017 memorandum. Although the scope of the Safe Handling, Storage and Treatment of Waste Fireworks memorandum focuses on waste fireworks, the principles outlined may also be considered for other explosive and pyrotechnic material meeting the definition of hazardous waste such as marine, roadside and other signal flares; automobile air bag explosives; and hobbyist rocket propellants that are hazardous waste when discarded. EPA prepared a brochure that accompanies this memorandum.
Automobile Airbag Propellants
Undeployed airbag modules and airbag inflators frequently exhibit the hazardous waste characteristic of reactivity (D003) and/or ignitability (D001) due to the propellant contained in the inflator. Deployment of the airbag module consumes the propellant and removes the reactivity and ignitability characteristics.
Regulatory Status of Undeployed Automotive Airbag Modules and Airbag Inflators
In July 2018, EPA issued a memorandum clarifying the regulatory status of undeployed automotive airbag modules and airbag inflators, including both those that have never been installed in a vehicle and those removed from vehicles.
Interim Final Rule on the Safe Management of Recalled Airbags
In November 2018, EPA published an interim final rule on the safe management of recalled airbags that exempts the collection of airbag waste from some RCRA requirements as long as certain conditions are met. This new exemption is in addition to the exemptions and exclusions described in the memorandum above, which continue to be in effect.
Treatment Technologies
Energetic hazardous wastes are often treated by open burning and open detonation (OB/OD) which is considered a treatment technology under RCRA. However, there are alternative treatment technologies available to treat these wastes as well.
Alternative Treatment Technologies
For decades, OB/OD have been used to treat energetic hazardous wastes. Unlike technologies that are designed to capture and treat the treatment byproducts prior to release, OB/OD occurs in the open and the majority of treatment byproducts are released directly into the environment. Members of the public, particularly residents living near operating OB/OD units, have expressed concern over the impacts of OB/OD to human health and the environment.
In turn, EPA developed a report in December 2019 that identifies and describes alternative treatment technologies that can be used in place of OB/OD. Many of the developed technologies have been tested and demonstrated their capabilities in terms of the types of waste explosives they can destroy safely. The report also identifies the extent to which individual technologies have been developed and implemented, and the locations they have been used. The report serves as an informative resource for permit agencies, facility owners and operators and others when identifying and evaluating potential alternative treatment options for energetic hazardous wastes.
Open Burning and Open Detonation
On December 10, 1987, EPA finalized permitting standards for a catchall category of waste management units, including OB/OD units, that were not already covered in the regulations (see volume 52 of the Federal Register starting on page 46946). The standards can be found in title 40 of the Code of Federal Regulations (CFR), part 264, subpart X – Miscellaneous Units. Unlike the other RCRA unit-specific regulations, miscellaneous units permitted under Subpart X are subject to general performance standards rather than technical performance standards since a single set of technical standards may not be suitable for the diverse types of miscellaneous units. Learn more about the Subpart X requirements.
There are approximately 225 treatment storage or disposal facilities (TSDFs) that have or had OB/OD units in the U.S. according to records in EPA’s RCRAInfo database. This is the cumulative total of OB/OD facilities that have operated under RCRA since the 1980 standards for owners and operators of TSDFs were finalized. Of the 225 TSDFs, only 60 facilities were still operating under either interim status or a permit as of November 28, 2018. These 60 OB/OD facilities are operated by both the private sector and public sector.
The preference for using OB/OD has been based largely on safety (i.e., reduced personnel exposure, and minimal handling of waste explosives) and the capacity to treat large quantities of diverse waste streams containing explosives.