February 12, 2020

EPA Reports on Alternative Treatment Technologies for Energetic Hazardous Wastes

Open burning/open detonation (OB/OD) has been used to treat energetic (i.e., explosive) hazardous wastes for decades. However, OB/OD is known for causing a significant amount of environmental contamination due to incomplete combustion, air emissions, and general dispersion of munitions components. In response to a 2017 congressional mandate, the National Academies of Sciences, Engineering, and Medicine (NASEM) released a report in 2019 titled Alternatives for the Demilitarization of Conventional Munitions. The report identified viable alternative technologies to OB/OD for managing conventional military munitions. Concurrently, EPA was investigating alternative technologies for treating energetic hazardous wastes and, in December 2019, published Alternative Treatment Technologies to Open Burning and Open Detonation of Energetic Hazardous Wastes, EPA/530/R-19/007. EPA’s report highlights key findings of the NASEM report, describes the agency’s research efforts and findings on available alternative technologies, and notes areas needing additional research.

While a small quantity of energetic hazardous waste is generated during chemical manufacturing and in university laboratories, the majority of these waste streams are generated during the demilitarization of military munitions. EPA’s report describes alternative technologies that have been developed for the four key steps in the munitions treatment process:

Case opening of both thick- and thin-cased munitions—Case opening may be required when employing alternative treatment technologies. The process used varies depending on if the munition is thick-cased (e.g., bombs, warheads, rocket motors, grenades, mines) or thin-cased (e.g., small and medium-caliber ammunition, cartridge-actuated devices, fuzes, igniters). Many alternative case-opening technologies have been developed and successfully demonstrated in a sustainable, production-ready, demilitarization environment on a wide variety of munitions.
Energetic material removal—Energetic material removal occurs once the munition case is opened. In some cases, the recovered material may be reused, while other times the material must be destroyed. Currently, autoclave meltout and water jet washout are the only technologies in frequent use that have been demonstrated in a sustainable, production-ready, demilitarization environment.
Energetic material destruction—Energetic material destruction can be classified based on closed (contained) detonation, thermal destruction, and chemical destruction technologies. Depending on the technology employed, both the munition and/or propellant may be treated, and treatment may be possible without prior case opening.
Decontamination of empty metal casings—Treatment of energetic hazardous waste will result in residues, which may themselves be hazardous. In the case of munitions, the residue (typically the remaining metal casing) may still exhibit the characteristic of reactivity. EPA identified several thermal and chemical decontamination technologies to decharacterize the residue (from a RCRA perspective) and/or meet decontamination levels achieving the DOD Explosives Safety Board’s “material documented as safe” status.

Numerous references and resources describing the above technologies in detail are included in the report appendices as is a set of matrices that compare and contrast various alternative treatment technologies.

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This document addresses issues of a general nature related to the federal RCRA regulations. Persons evaluating specific circumstances dealing with the RCRA regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.