GOVERNMENT OF PUERTO RICO

ENVIRONMENTAL QUALITY BOARD

March 26, 2018

Mary Ann Lucking, Director

CORALations
P.O. Box 750
Culebra, PR 00775

RE: Information Request

Differences between Open Burning and Open Detonation Terms
Culebra, Puerto Rico

Dear Mrs. Lucking:

The Puerto Rico Environmental Quality Board (PREQB) has completed the assessment needed to respond
to your request for clarification on the differences between open burning and open detonation activities.
These comments were prepared based on current rules and regulations promulgated and enforced by the
PREQB, under the Environmental Public Policy Act of Puerto Rico, Act 416-2004.

Open Burning (OB) vs Open Detonation (OD) Terms

Open Burning (OB), Open Detonation (OD) and Static Detonation Chambers (SDC) are activities used to
dispose of Waste Military Munitions (WMM) and are not covered in EQB’s Regulations for the Control
of Atmospheric Pollution (RCAP) or any other applicable regulations. These disposal activities are
regulated by the Environmental Protection Agency (EPA) with permits issued under Resource
Conservation Recovery Act (RCRA).

A. Open Burning

An OB unit is dedicated to the thermal destruction of Hazard Class I explosives including propellants,
WMM, and explosive-contaminated wastes. It can be used to treat wastes generated on-site or off-site.
Burning in an open field is prohibited by EQB’s RCAP; Rule 208, except for certain types of agricultural
burning. However, under Rule 301of the RCAP EQB can authorize variances as long as the activity does
not violate National Ambient Air Quality Standards (NAAQS).

B. Open Detonation

OD activity is an open-air process used for the treatment of unserviceable, obsolete, or waste munitions
whereby an explosive donor charge initiates the munitions to be detonated. Although surface detonations
can be performed under certain circumstances, most munitions are treated in 4- to 6-foot-deep pits for
safety purposes. Most OD sites are permitted as miscellaneous units as part of the EPA’s RCRA

1375 Ponce de León Ave., Road 8838, Sector el Cinco, Río Piedras, PR / PO Box 11488, San Juan, PR 00910

☎ 787-767-8181 📠 787-766-0150 juanbaba@jca.pr.gov

CORAlations
Request Information
Page 2
03/15/2018

environmental permitting process. All EPA RCRA permits should have the concurrence of the PREQB’s
Land Pollution Control Area, Solid Waste Section. The Department of Defense’s (DoD) units are
generally permitted as combined OB/OD facilities.

Reference: Military Munitions Response Program (MMRP) Manual (April 2017) defines OB/OD as:
Open Burn/Open Detonation (OB/OD). An open-air combustion process by which excess,
unserviceable, and obsolete munitions are destroyed to eliminate their inherent explosives safety hazards.
OB does not control combustion air to maintain adequate temperature for efficient combustion, contain
the combustion-reaction in an enclosed device to provide sufficient residence time and mixing for
complete combustion, or control emission of the gaseous combustion products. DoD OB units are
permitted as miscellaneous units in the EPA’s RCRA environmental permitting process. OD is an open-
air process used for the treatment of unserviceable, obsolete, or waste munitions whereby an explosive
donor charge initiates the munitions to be detonated. Although surface detonations can be performed under
certain circumstances, most munitions are treated in 4- to 6-foot-deep pits for safety purposes. Most OD
sites are permitted as miscellaneous units as part of the RCRA permitting process. The DoD’s units are
generally permitted as combined OB/OD facilities.

The Culebra clean-up activities may require open field burning to clear the area of vegetation so the
contractors can locate unexploded ordnance (UXO) or shrapnel and remove it or detonate it. This variance
would be issue under Rule 301 of the RCAP, if required and applicable. The treatment of munitions and
explosives of concern (MEC) during these operations follow the Department of Defense Explosive Safety
Board (DDESB) approved Explosives Site Plan (ESP) or Explosives Safety Submission (ESS).

If you have any additional questions, please feel free to contact me at (787) 767-8181 extensions 2401 or
2402, or my email at juanbaba@jca.pr.gov.

Cordially,

Mr. Juan J. Babá Peebles

Federal Facilities Coordinator
PR Environmental Quality Board