Environmental Forensic Investigation of Historical Open Burning and Open Detonation Operations, Air Dispersion Modeling, and Community Exposure Assessment
Project Overview
This environmental forensic investigation evaluated the historical operation of a hazardous waste thermal treatment facility that utilized open burning and open detonation (OB/OD) to destroy energetic waste materials. The investigation sought to reconstruct historical emissions, evaluate contaminant transport beyond the facility boundary, characterize airborne particulate matter, and assess potential community exposure through a multidisciplinary review of historical operating records, environmental monitoring data, air dispersion modeling, scientific literature, and regulatory documents. By integrating these independent sources of information, the investigation developed a technically defensible understanding of historical environmental conditions and the potential impacts of long-term thermal treatment operations on nearby residential communities.
Unlike contained thermal treatment technologies, open burning and open detonation release combustion products directly into the atmosphere, where pollutants may be transported by prevailing winds before depositing onto surrounding environmental media. Because these operations involve energetic materials and variable burn conditions, emissions may fluctuate considerably depending upon waste composition, burn frequency, meteorological conditions, and operational practices. Consequently, evaluating historical emissions required combining engineering analyses, operational records, atmospheric modeling, environmental sampling, and published scientific literature to reconstruct representative historical exposure conditions.
The investigation also incorporated community observations, environmental monitoring programs, historical complaint information, and independent scientific investigations to compare modeled contaminant transport with measured environmental conditions. This integrated approach reflects accepted environmental forensic practices for evaluating historical emissions from industrial operations where long-term monitoring records are incomplete or where historical operating conditions must be reconstructed using multiple independent datasets.
Chemicals of Concern
The investigation focused primarily on airborne particulate matter generated during open burning and open detonation activities, including particulate matter less than 2.5 micrometers (PM₂.₅) and particulate matter less than 10 micrometers (PM₁₀). These fine and coarse particles serve not only as regulated air pollutants but also as transport mechanisms for metals, combustion byproducts, semi-volatile organic compounds, and other hazardous constituents generated during thermal treatment of energetic materials. Because smaller particles remain suspended in the atmosphere for extended periods and may be inhaled deeply into the respiratory tract, particulate matter represented a primary contaminant of concern throughout the investigation.
The investigation also evaluated combustion-related pollutants commonly associated with energetic waste treatment, including nitrogen oxides (NOₓ), sulfur dioxide (SO₂), carbon monoxide (CO), volatile organic compounds (VOCs), benzene, and combustion-derived particulate emissions. In addition, available environmental sampling data were reviewed to evaluate the presence and distribution of metals associated with historical thermal treatment activities. Metals analyses provided additional information regarding particulate deposition patterns and long-term environmental accumulation within surrounding communities.
Published toxicological literature was incorporated to evaluate potential health effects associated with particulate matter exposure and to understand the behavior of airborne contaminants following atmospheric release. Particular emphasis was placed on contaminant persistence, inhalation exposure, particle deposition, and the relationship between particulate matter and nuisance conditions such as smoke and odors. These evaluations provided the scientific basis for interpreting historical emissions within the broader context of environmental exposure science.
Methods
The investigation utilized a multidisciplinary environmental forensic methodology integrating historical document review, atmospheric dispersion modeling, environmental monitoring, engineering evaluation, geographic information systems (GIS), and exposure assessment. Historical operating records describing thermal treatment activities, burn frequencies, waste processing practices, and regulatory compliance documentation were reviewed to reconstruct representative operating conditions over multiple years. Additional review included environmental permitting records, inspection reports, regulatory correspondence, and technical evaluations addressing historical operational practices and available alternatives to open burning and open detonation.
Atmospheric transport was evaluated using the American Meteorological Society/Environmental Protection Agency Regulatory Model (AERMOD), the regulatory air dispersion model recommended by the U.S. Environmental Protection Agency for evaluating pollutant transport from stationary emission sources. Source characteristics, meteorological information, terrain data, receptor grids, and emissions estimates were incorporated to evaluate airborne concentrations and particulate deposition throughout surrounding residential areas. Multiple modeling scenarios were developed to characterize both representative operational conditions and conservative emission assumptions.
Meteorological inputs were evaluated using validated regional datasets consistent with accepted regulatory modeling practices. Supplemental review of on-site meteorological information was performed to compare wind direction and wind speed patterns with the regional meteorological dataset used during air dispersion modeling. This comparison confirmed that the validated regional dataset remained appropriate for retrospective atmospheric modeling and did not warrant revision of the original modeling conclusions.
Environmental monitoring information from independent sampling programs was reviewed alongside modeled air concentrations to compare predicted contaminant transport with measured field observations. Sampling included particulate monitoring, passive air sampling, electronic monitoring equipment, and laboratory analysis of collected samples. Community observations and publicly available environmental information were also evaluated to provide additional context regarding historical environmental conditions while recognizing that such information serves as supplemental evidence rather than quantitative exposure measurements.
Geographic information systems were used to evaluate spatial relationships among the emission source, residential communities, sampling locations, and modeled concentration gradients. GIS analyses provided visual representation of contaminant transport patterns and facilitated comparison between atmospheric modeling results and environmental monitoring data. The investigation further integrated published scientific literature describing particulate transport, atmospheric dispersion, contaminant fate and transport, and exposure science to support interpretation of environmental conditions.
Results
The investigation demonstrated that historical open burning and open detonation operations generated airborne particulate matter capable of dispersing beyond facility boundaries under a range of meteorological conditions. Air dispersion modeling identified the spatial distribution of particulate concentrations and deposition across nearby residential areas, illustrating the influence of prevailing winds, source characteristics, and terrain on contaminant transport. Comparison of modeled concentrations with available monitoring information provided additional confidence that atmospheric modeling reasonably characterized historical dispersion patterns.
Review of operational records indicated that thermal treatment activities generated emissions containing combustion-derived particulate matter together with gaseous pollutants commonly associated with open burning. Published scientific literature demonstrates that fine particulate matter serves as an efficient transport medium for metals and other hazardous constituents generated during combustion. Consequently, particulate transport represents an important mechanism through which contaminants may migrate beyond facility boundaries and contribute to environmental deposition.
Independent environmental monitoring further supported evaluation of historical air quality conditions. Monitoring programs incorporated multiple sampling technologies, including high-volume particulate samplers, passive samplers, and continuous electronic sensors, to characterize airborne pollution and compare measured concentrations with modeled transport predictions. Combining independent monitoring with retrospective atmospheric modeling strengthened the technical basis of the environmental forensic reconstruction.
Evaluation of meteorological information demonstrated that validated regional meteorological datasets remained appropriate for retrospective AERMOD analyses. Supplemental review of on-site meteorological measurements showed similar wind direction patterns despite minor differences in measured wind speeds, supporting continued use of the validated regional dataset for regulatory modeling purposes. This finding increased confidence in the representativeness of the modeled atmospheric transport results.
The investigation also highlighted the value of integrating multiple independent lines of evidence when evaluating historical environmental conditions. Atmospheric modeling, environmental monitoring, regulatory records, engineering analyses, operational documentation, and scientific literature each contributed unique information regarding historical emissions and contaminant behavior. Considered collectively, these independent datasets provided a substantially stronger technical basis for evaluating historical community exposure than reliance upon any single dataset alone.
More broadly, the investigation illustrates the complexity of evaluating historical emissions from thermal treatment operations involving energetic waste materials. Because emissions vary according to waste composition, burn practices, atmospheric conditions, and operational history, reconstruction of historical exposure requires multidisciplinary analysis incorporating environmental engineering, atmospheric science, contaminant fate and transport, and exposure assessment.
Conclusions
This investigation demonstrates how environmental forensic science can be used to reconstruct historical emissions associated with open burning and open detonation operations through integration of engineering analyses, atmospheric dispersion modeling, environmental monitoring, historical operational records, and scientific literature. By combining multiple independent sources of information, investigators developed a scientifically defensible reconstruction of historical contaminant transport and potential community exposure while accounting for uncertainties inherent in retrospective environmental investigations.
The project further illustrates the importance of particulate matter as both a regulated air pollutant and a transport mechanism for combustion-derived contaminants. Evaluation of particulate transport, deposition, and environmental persistence provides important insight into the movement of contaminants beyond facility boundaries and the long-term environmental implications of historical thermal treatment operations.
Finally, this investigation highlights the importance of multidisciplinary environmental forensic methods when evaluating historical industrial operations. Integration of air dispersion modeling, environmental chemistry, geographic information systems, atmospheric science, exposure assessment, and regulatory review allows historical environmental conditions to be reconstructed using accepted scientific principles and provides a robust technical foundation for evaluating complex environmental contamination cases.
This investigation was conducted under the direction of Dr. Paul Rosenfeld, an environmental scientist and President of RoseyFields LLC with more than 30 years of experience in environmental consulting, forensic investigations, and exposure assessment. Dr. Rosenfeld specializes in evaluating complex environmental contamination cases involving hazardous waste facilities, industrial operations, air emissions, groundwater contamination, and historical releases of hazardous substances. His expertise includes contaminant fate and transport, environmental chemistry, air dispersion modeling, risk assessment, exposure reconstruction, and interpretation of environmental sampling data.
Through RoseyFields LLC, Dr. Rosenfeld provides technical consulting and expert witness services for complex environmental litigation, regulatory matters, and site investigations throughout the United States. His work integrates scientific research, historical document review, environmental modeling, and multidisciplinary forensic analysis to develop technically defensible conclusions regarding contaminant sources, migration pathways, and potential human and ecological exposures.
References
Agency for Toxic Substances and Disease Registry. (2022). Toxicological profile for particulate matter. U.S. Department of Health and Human Services.
National Research Council. (2011). Review of the Department of Defense Enhanced Particulate Matter Surveillance Program Report. National Academies Press.
U.S. Department of Defense Office of Inspector General. (2021). Evaluation of Department of Defense compliance at sites conducting open burning or open detonation of waste military munitions in the United States (Report No. DODIG-2022-013).
U.S. Environmental Protection Agency. (2019). AERMOD implementation guide.
U.S. Environmental Protection Agency. (2024). Integrated Science Assessment (ISA) for Particulate Matter.
U.S. Environmental Protection Agency. (2024). AP-42: Compilation of Air Pollutant Emission Factors.
World Health Organization. (2021). WHO global air quality guidelines: Particulate matter (PM₂.₅ and PM₁₀), ozone, nitrogen dioxide, sulfur dioxide and carbon monoxide.
Zhang, Q., et al. (2021). Atmospheric transport and deposition of particulate-bound contaminants: A review. Atmospheric Environment, 244, 117875.