5_-_FOH_-_Indoor_Firing_Range_Evaluation_-_LPOE_Indoor_Firing_Range_1559_Highway_16_North_-_April_2015.pdf

DEPARTMENT OF HEALTH & HUMAN SERVICES Federal Occupational Health

Division of Environmental Health Services 1301 Young Street, Suite 772 Dallas, Texas 75202

INDOOR FIRING RANGE EVALUATION

REPORT AND IMPLEMENTATION PLAN

CONDUCTED FOR:

US GENERAL SERVICES ADMINISTRATION

GSA PUBLIC BUILDINGS SERVICE CENTRAL OFFICE

1800 F STREET, NW, ROOM 4238

WASHINGTON, DC 20405

AT:

LAND PORT OF ENTRY

INDOOR FIRING RANGE

1559 HIGHWAY 16 NORTH

RAYMOND, MT 59256

APRIL 2015

CONDUCTED BY:

FEDERAL OCCUPATIONAL HEALTH

US DEPARTMENT OF HEALTH & HUMAN SERVICES

1301 YOUNG STREET, SUITE 772

DALLAS, TEXAS 75202-5433

i

TABLE OF CONTENTS

SECTIONS

I. EXECUTIVE SUMMARY

II. INTRODUCTION

III. BACKGROUND SITE INFORMATION

IV. STUDY OBJECTIVES AND TECHNICAL APPROACH

V. DISCUSSION OF INDIVIDUAL PARAMETERS EVALUATED

VI. TESTING METHODOLOGIES

VII. EVALUATION FINDINGS, FIELD NOTES, AND FIELD MEASUREMENTS

VIII. EVALUATION SUMMARY AND RECOMMEDATIONS

IX. REFERENCES

APPENDICES

A. IFR DESIGN AND OPERATIONS EVALUATION CHECKLIST

B. ESTIMATED COSTS

C. PHOTOGRAPH DOCUMENTATION

D. LABORATORY REPORTS

I. EXECUTIVE SUMMARY

At the request of the US General Services Administration (GSA) Public Buildings Service Central Office, the US Department of Health & Human Services (DHHS) Federal Occupational Health (FOH) conducted an Indoor Firing Range Evaluation at the Land Port of Entry (LPOE) Indoor Firing Range Facility located at 1559 Highway 16 North, Raymond, Montana. The assessment included the indoor firing range that is used by Custom and Border Patrol (CBP) staff, adjacent areas, and the air-handling equipment serving these areas. The assessment included conducting interviews with CBP staff and building maintenance personnel who have responsibility for the range.

FOH Industrial Hygienists (Mr. Michael J. Hentgen, CIH, CSP and Mr. Jeff Danchenko) conducted this assessment on March 23rd and 24th, 2015 under an Interagency Agreement established between FOH and GSA.

The LPOE Raymond Firing Range is located in a single story building with a basement and is utilized by CBP officers. The firing range occupies the entire basement level and has a dedicated stairwell which leads from the support room portion of the range to the outdoors. The range consists of three rooms: the range, a support room, and a bathroom. The support room contains a gun cleaning area, lockers, and a lockable fenced storage area. The range area is accessed from the support area through a single door. The range consists of four (4) firing lanes with an automatic targeting system. The range controls are located on an elevated platform behind the firing line that is not separate from the range.

An inspection was performed throughout the spaces, focusing on the criteria outlined in the GSA Public Buildings Service’s document entitled “Indoor Firing Range Design, Operations & Maintenance Criteria”. In the interest of brevity, only key findings and recommendations are covered within this executive summary. The remainder of the findings and recommendations are contained within the body of the report.

The range was designed to have a single firing line located 25 yards from the bullet trap. The 25 yard firing line is equipped with 4 firing positions delineated by prefabricated shooting stalls. All four positions are served by an automatic retractable target system. Through the use of the retractable target system, the distance from the 25 yard line to the target can be set to any distance up to 25 yards.

The range currently allows the following types of ammunition and firearms to be used:

Handguns – primarily Smith & Wesson 40 caliber handguns however calibers may be used.

Shotguns – 12 gauge 2 ¾” buckshot and rifled slugs

Although range shooters, instructors, and range masters use acceptable firearms safety procedures while firing from shorter distances, the construction date of the range predates the 2012 GSA IFR Design, Operations & Maintenance Criteria. Subsequently, the range layout and construction deviate from the GSA IFR Criteria.

KEY FINDINGS

Key findings with respect to the range include:

1. The range does not have a control room separated from the range.

2. Lane partitions are not 48” wide. All partitions are 44” wide.

3. The range does not have a two door air lock system separating the support areas from the range.

4. Range doors do not have sacrificial plywood cladding and do not appear to have a ballistic rating.

5. Range design specification and mechanical drawings were not available at the range for review.

6. The horizontal canopy does not extend at least 12’ in front of the firing line and does not have any splatter protection.

7. The airflow at the firing line on average was in excess of the required 75 feet per minute requirement. However the flow in each of the lanes was not within 10% of 75 fpm.

8. Sampling ports on the ductwork could not be found. Subsequently the ratio of exhaust to supply air could not be measured.

9. The range does not have a pressure gauge to measure the negative pressure differential. The range does however maintain a negative pressure differential to the surrounding areas.

10. The interlock does not have an alarm if either the supply or exhaust is not working properly.

11. The interlock is not timed to start the exhaust fan in advance of the supply fan.

12. The interlock alarm does not shut down the system if the range pressure goes positive for more than 2 minutes.

13. There is no alarm to notify the range master if the pressure drop across the HEPA filters indicates needed maintenance.

14. There is no noise insulation on the walls and ceiling.

15. Lighting levels throughout the range are below GSA criteria.

16. Sticky mats are not used at the range.

17. The range is not equipped with the following triggers or alarms:

A laser or infrared trip at the firing line

An open door to the range

Ventilation malfunction

RECOMMENDATIONS

The building was reportedly constructed in 2005 subsequently the construction of the range deviates from the requirements in the GSA IFR Criteria which was published in 2012. In some cases the deviations are minor and correctable while others are not.

Therefore FOH tried to take this into account in formulating the recommendations below:

1. Install an Airlock with Ballistic Door - The range does not have a ballistic door.

The existing door can be replaced with a ballistic door with ½” sacrificial plywood.

Since the range does not have an airlock, replacing the door should include a discussion of installing one.

2. Install Alarm and Shutdown Interlocks - The installation of interlocks to provide malfunction alarms and delay the start of the supply fan is likely to require the replacement of existing electronics and controls. The installation of the interlocks and alarms would also require that pressure gauges be installed to monitor the range pressure to the surrounding areas and pressure drops across exhaust filter banks. Other considerations include:

Firing line trip – Installation of laser or Infrared trip. See discussion of widening the firing lanes

Open door alarm Ventilation Malfunction Alarm/Notification Lit range in use sign

3. Install an Enclosed Control Room - The installation of an enclosed control room behind the firing line to the existing range would require significant modifications to the facility since the range is below grade and building’s poured concrete foundation serves as the back wall of the range as well as the supply plenum. The back wall is approximately 10 feet behind the firing line which means the range has to be lengthened beyond the boundaries of the foundation to accommodate a control room.

4. Widen Firing Lanes - The existing four firing lanes are too narrow and the side walls of the range are poured concrete. In order to meet the requirements of the GSA IFR Criteria the range should be reconfigured from 4 lanes to 3 lanes which would involve moving the targeting system. Lasers or infrared trips should be installed on the firing line when the lanes are reconfigured.

5. Sound Insulation - Sound insulation can be added to the poured concrete range walls and ceiling without other significant modifications to the space.

6. Ballistic Shielding – The horizontal ballistic canopy needs to be extended from

8 feet to 12 feet out from the firing line in order to comply with the GSA IFR Criteria. Without any information on the type of fiberboard used to construct the canopy it could not be determined whether or not the canopy provides sufficient splatter protection as is. Extending the canopy 4’ may require that other fixtures be relocated.

7. Lighting – Without design drawings it is difficult to determine whether or not the range lighting system has the capacity to provide adequate levels of light with respect to the GSA IFR Criteria. FOH recommends that the lighting plan from the design documents be reviewed to determine whether the existing system has the capacity to meet the GSA Criteria. Emergency lighting should be added to the range as well as a panic bar on the door leading from the range to outdoors. A strobe light should also be installed if warranted by the users.

II. INTRODUCTION

At the request of the US General Services Administration (GSA) Public Buildings Service Central Office, the US Department of Health & Human Services (DHHS) Federal Occupational Health (FOH) conducted an Indoor Firing Range Evaluation at the LPOE Indoor Firing Range Facility located at 1559 Highway 16 North, Raymond, Montana. The assessment included the indoor firing range that is used by Custom and Border Patrol (CBP) staff, adjacent areas, and the air-handling equipment serving these areas. The assessment included conducting interviews with CBP staff and building maintenance personnel who have responsibility for the range. FOH Industrial Hygienists (Mr. Michael J. Hentgen, CIH, CSP and Mr. Jeff Danchenko) conducted this assessment on March 23rd and 24th, 2015 under an Interagency Agreement established between FOH and GSA.

The purpose of this assessment is to determine if the indoor firing range’s design and operation meet the minimum criteria outlined in the GSA Public Buildings Service’s document entitled “Indoor Firing Range Design, Operations & Maintenance Criteria”.

III. BACKGROUND SITE INFORMATION

US CBP firearms instructors and staff use the range. The following types of ammunition and firearms are permitted for use on the range:

Handguns – primarily S&W 40 caliber handguns other handgun calibers may be used.

Shotguns – 12 gauge 2 ¾” buckshot and rifled slugs

Both shotguns and handguns were used while this evaluation was being conducted.

The LPOE Raymond Firing Range is located in a single story building with a basement and is utilized by CBP officers. The firing range occupies the entire basement level and has a dedicated stairwell which leads from the support room portion of the range to the outdoors. The range consists of three rooms: the range, a support room, and a bathroom. The support room contains a gun cleaning area, lockers, and a lockable fenced storage area. The range area is accessed from the support area through a single door. The range consists of four (4) firing lanes with an automatic targeting system. The range controls are located on an elevated platform behind the firing line that is not separate from the range.

The range’s ventilation system consists of interlocked supply and exhaust fans which are located on the ground level outdoors.

The purpose of the range ventilation system is to filter lead and other contaminants from the air as a means to prevent the contaminants from becoming a hazard to building occupants and the environment. The exhaust fan consist of an air filtration bank and exhaust fan. The intake for the exhaust was located behind the rubber berm bullet trap and was not accessible without climbing up the berm. The supply air used to ventilate range is served by a single supply fan and provides conditioned fresh outdoor air (OA).

The supply fan does not have any return air. FOH was unable to locate/access any pitot holes to measure the flow of air on either the supply or exhaust.

IV. STUDY OBJECTIVES AND TECHNICAL APPROACH

The purpose of this assessment is to determine if the indoor firing range’s design and operation meet the minimum criteria outlined in the GSA Public Buildings Service’s document entitled “Indoor Firing Range Design, Operations & Maintenance Criteria”.

FOH provided the personnel, equipment, and expertise to perform the following tasks:

• Use the GSA Public Buildings Service’s “Indoor Firing Range Design, Operations & Maintenance Criteria” document to evaluate the indoor firing range. Compare all measurements and general information collected against the GSA Public Buildings Service’s “Indoor Firing Range Design, Operations & Maintenance Criteria” document dated April 2012.

• Perform an inspection of the general range layout and ballistic design.

• Perform an audit of the operations of the range. Check recordkeeping, protective equipment (PPE) usage programs, hygiene, signage, communication, alarms, cleaning, maintenance, waste management (including manifests), and recycling.

Review written operational procedures/policies to determine compliance with the criteria set forth in the GSA IFR 3 Design, Operations and Maintenance Criteria, the attached checklist, and applicable governing regulatory requirements (e.g., OSHA, EPA, etc).

• Collect samples and measurements as appropriate to determine compliance with applicable standards. When collecting samples during live-fire, collect during periods of maximum use, and use of higher-caliber ammunition if more than one type of ammunition is used. Monitoring shall include up to:

• Personal air samples for lead. Air samples shall be analyzed in accordance with Occupational Safety and Health Administration (OSHA) Analytical Method 121 at the FOH Environmental Laboratory in Chicago, Illinois. All results will be compared to the OSHA Action Level of 30 micrograms (µg) per cubic meter of air for an 8 hour time weighted average (TWA).

• Lead air sample from the exhaust air. The air sample shall be analyzed via OSHA Analytical Method 121 at the FOH Environmental Laboratory in Chicago, Illinois. The results will be compared to a level of 15 µg per cubic meter of air.

• Lead dust wipe samples. Wipe samples shall be analyzed via OSHA Analytical Method 121 at the FOH Environmental Laboratory in Chicago, Illinois. Samples collected outside the range will be compared against 200 µg per square foot as prescribed by GSA.

• TCLP sampling. Samples collected from the waste trap are to be analyzed via the EPA Toxicity Characteristic Leaching Procedure (TCLP) for lead content

• Personal air samples for carbon monoxide. Air samples will be compared against the OSHA 8-hour Permissible Exposure Limit (PEL) of 50 parts per million (ppm) and the ACGIH 8-hour Threshold Limit Value of 25 ppm.

• Collect airflow measurements from various locations on the range and compare the values against GSA “Indoor Firing Range Design, Operations, and Maintenance Criteria” document dated April 2012.

• Conduct noise dosimetry on the Range Safety Officers (RSOs) inside the control booth to determine total noise dose. Results will be compared against the OSHA Action Level of 85 dBA and the OSHA PEL of 90 dBA for an 8-hour TWA.

• Collect sound level measurement readings from various locations throughout the range during periods when weapons are not being fired to ensure that ambient noise levels do not exceed 85 dBA.

• Collect light measurements throughout the range and at the target face.

V. DISCUSSION OF INDIVIDUAL PARAMETERS EVALUATED

Per the GSA Public Buildings Service’s “Indoor Firing Range Design, Operations & Maintenance Criteria” document:

Lead in Air

Lead in air samples are collected using 37mm sampling cassettes containing 0.8-micron mixed cellulose ester sampling media. Lead in air samples shall be analyzed via Occupational Safety and Health Administration (OSHA) Analytical Method 121. All results will be compared to the OSHA Action Level of 30 µg per cubic meter of air for an 8 hour time weighted average (TWA).

Lead Dust

Lead dust levels as measured from wipe samples collected according to ASTM E1728- 03 and taken behind the firing line and in support areas adjacent to the range (including training, storage, and HVAC maintenance areas) shall be less than 200 μg/ft2. Other more stringent standards may be applied by GSA environmental personnel in areas outside the range where the general public has access, as necessary to limit exposure in those areas.

Carbon Monoxide

Carbon monoxide (CO) is a colorless, nonirritating, odorless, and tasteless gas. It is found in both outdoor and indoor air. Carbon monoxide is formed by the incomplete oxidation of carbon in combustion when carbon in fuel is not burned completely.

Carbon monoxide is produced from both manmade and natural sources. The most important manmade source of carbon monoxide arises from the exhaust of automobiles.

Within commercial office buildings and light industrial facilities, some of the more common sources of carbon monoxide include unvented kerosene and gas space heaters, back-drafting from gas fired boilers or furnaces, gas water heaters, and automobile exhaust introduced by the outdoor air intakes. Carbon monoxide is also a byproduct of environmental tobacco smoke, so second-hand exposure to the particles and gases from smoke can also lead to an increased exposure to carbon monoxide.

The US EPA National Ambient Air Quality Standard (NAAQS) for carbon monoxide outdoor air is 9 ppm (parts per million), based on an 8-hour average. For the purposes of this report, carbon monoxide (CO) exposure levels shall be less than the OSHA 8-hour TWA PEL established in 1971 of 50 ppm (parts per million) with a targeted goal of 25 ppm which is the 2011 ACGIH threshold limit value (TLV).

Noise

Ambient noise levels at the firing line, including the ventilation system noise, shall not exceed 85 decibels, A-scale (dBA), and should be considerably less to improve communication between the shooters and the range official. Short duration noise such as gunfire will exceed the 85 dBA level and may be as high as 160 dBA. The range design must prevent the reflection of these higher noise levels by using sound-absorbing materials where possible.

Lighting

Downrange lighting (both red and white light) shall be designed in accordance with the IESNA Lighting Handbook to provide for safety and housekeeping operations as well as general range illumination. Light intensity at the target face should be 85 to 100 foot-candles measured at 47 inches above the range surface at the target face. A minimum of 30 foot-candles for white light general range illumination and 10 foot-candles for red lights shall be provided.

Lighting shall be provided by multiple banks of lights arranged behind overhead baffles along the length of the range. Lighting banks shall be provided to illuminate standard training distances. These are generally 3, 5, 10, and 25 yards downrange. Other distances may be approved specific to a firing range and target system. Controls shall be provided to vary lighting intensity throughout the range to accommodate subdued-light training requirements. Controls for all lighting shall be operated from the RSO control room. Flashing red and blue lights at the firing line and downrange can be provided to simulate emergency situations.

VI. TESTING METHODOLOGIES

Carbon monoxide levels were measured using a QRae Plus 4-Gas Monitor. Airflow and direction were measured using a TSI Alnor Micromanometer Model EBT720 utilizing the Velocity Matrix wand. Noise levels were measured using 3M Edge Model eg5 personal noise dosimeters. Lighting levels were measured using a Sper Scientific light meter Model 840006. Lead dust wipes were collected using GhostWipes. Lead in air samples were collected using 37mm sampling cassettes containing 0.8-micron mixed cellulose ester sampling media, attached to battery powered low volume air sampling pumps.

VII. EVALUATION FINDINGS, FIELD NOTES, AND FIELD MEASUREMENTS

1. Exposure

Personal lead exposure monitoring was conducted on March 24, 2015 and included one shooter and one instructor that remained at and operated the range controls behind the firing line. All results were below the OSHA Action Level of 30 micrograms per cubic meter of air for an 8 hour time weighted average (TWA). The results are as follows:

Sample Number Personnel / SS#

Activity / Location Time

(Mins) Flow

(LPM)

Volume (liters)

Sample Result (µg/m3)

8-Hour

TWA*

(µg/m3)

032415-LA-01

Vines / xxx-xx-0572 Shooter, Lane 2

67 2.0 134 90 12.6

032415-LA -02

Wang / xxx-xx-1797 Range Controls

67 2.0 134 140 19.5

032415-LA -03

Exhaust Air Outdoors

63 2.0 126 <6.4 <0.84

Sample Number Personnel / SS#

Activity / Location Time

(Mins) Flow

(LPM)

Volume (liters)

Sample Result (µg/m3)

8-Hour

TWA*

(µg/m3)

032415-LA -04 Field Blank NA NA NA <0.80 ug NA

* - assumes a zero exposure for the remainder of the work day.

During this evaluation both 12 gauge ammunition and handgun ammunition was used.

The 12 gauge course of fire was first and lasted approximately 4-5 minutes during which time 19 rounds were fired from a Remington 870 pump shotgun. Of the 19 rounds, fifteen were Winchester Super X 2 ¾” one ounce rifled slug rounds and the remaining four rounds were Federal 2 ¾” 00 buck shot containing 9 pellets per round.

The 40 S&W handgun courses of fire lasted approximately 40 minutes during which time approximately 140 rounds were fired using a Heckler & Koch P2000. All of the 40 S&W ammunition expended was manufactured by Federal and had 135 grain jacketed hollow point bullets.

2. General Range Layout

Dimensions: The distance from the firing line to the target line is 75 feet. There are 10 feet behind the firing line to the air supply plenum which consists of perforated wall panels. The range does not have a designated control room separated from the firing range. The range controls are a table which is situated on a 6’x7’ elevated platform. The control platform is more or less centered on the back wall of the range roughly 4’ behind the firing positions. There is a separate secure fenced storage area for supplies and ammunition. There is a dedicated gun cleaning area however this area is contained within a larger room which also houses lockers and the fenced storage area.

Firing Line: The firing line is not marked with a 4-inch wide red line. The range does not have a ready line 8 feet behind the firing line.

Although range shooters, instructors, and range masters use acceptable firearms safety procedures while firing from shorter distances, the construction date of the range predates the 2012 GSA IFR Design, Operations & Maintenance Criteria. Subsequently, the range layout and construction deviate from the GSA IFR Criteria. Key findings with respect to the range include:

The range does not have dedicated control room The controls are located on a platform in between the supply air diffuser and firing line. The platform interferes with laminar air flow at the firing line.

The range does not have an airlock separating the firing range from the support areas.

The horizontal canopy only extends to 8’ from the firing line not 12’.

Shooting Lanes: The lanes are clearly designated however they are not numbered. For purposes of this report the lanes were designated 1-4, left to right looking down range.

The partitions more or less allow for adequate air flow downrange, however the control platform interferes with the airstream between the firing line and the supply air diffuser.

All firing positions at the line measure are approximately 44” wide which is slightly under 4 feet wide. Shooting position 1 is offset from the wall approximately 1 foot however shooting position 4 is set flush to the adjacent wall.

Openings and Egress: General access to the range is through a single doorway from the from the support room. An emergency egress ladder is located down range along the east wall. The egress ladder is shielded by a vertical baffle. The main egress from the range however, is through the door into the support room then up the stairs to the outdoors. The doors do not have a panic bar or door handles conforming to the fire code for emergency escape. The exit from the range is clearly designated. The range door to the support room does not appear to have a bullet resistance rating.

Safety Control Room: The range controls are located on an elevated platform behind the firing line but are not housed in a separate room. Subsequently, there is not a ventilation system serving the control room that is separate from the range. There is a table dedicated for all controls, alarms, lighting, and communication for the range.

There is not a two-way communication system on the range, however it should be pointed out that it appears the instructor also serves as the range master at this site.

The seating surfaces are cloth and not easily cleaned from lead dust. Communication to the outside is available to contact emergency services.

Target System: There is a target retrieval system that eliminates the need for personnel to go beyond the firing line during normal operation. The targets turn 90 degrees in 0.5 seconds or less.

Support Facilities: The support room that houses the gun cleaning area has a sink in the gun cleaning area that range users pass by when exiting. Lockers are also located in the support room. There is no dedicated locked storage area for recyclables however it was reported that these materials were removed from the range as they are produced.

Spent brass is stored behind the firing line. The support room has eyewash bottles stationed next to the sink and a gun clearing receptacle. The gun cleaning area does not have compressed air or an ultrasonic cleaner.

3. Ballistic Design

General Design: A single floor plan was available for review however, this drawing did not have details specific to the ballistic protections. All pipes, conduits, utilities, etc., concealed in the range envelope are protected by baffles which are properly positioned with respect to the firing line.

Floors: The range floor is continuous, level, but did not appear to be coated with a waterproof surface sealant. While there are some marks on the floor none of them appeared to require repair as the overall appearance of the floor is undamaged. The construction specifications of the concrete floor were not available.

Walls: The walls are constructed of reinforced concrete that are at least 8” thick. The tops of the walls extend up to the floor slab of the ground level.

Ceiling: The ceiling is sealed of all openings to isolate the range from the surrounding areas for purposes of ventilation and ricochet protection.

Baffles: A horizontal canopy baffle extends over the firing line and shooting positions from the firing line only to 8 feet in front of the firing line. The canopy is constructed of ½” Kevlar/fiberglass epoxy resin fiber board panels which are mechanically fastened to metal framing. The panels are not protected splatter protection consisting of a minimum of 1.5 inch air space and plywood sheeting on the face of the baffle. The overhead baffles extend downrange and eliminate any “line of sight” openings in the ceiling from every position on the 25 yard line firing line. The overhead baffles are oriented at 12 to 42 degree angles to the ceiling with the angle opening toward the bullet trap. The baffles are spaced such that they provide “line of sight” protection from the 25 yard line for all lighting and utilities. The bottom of the baffles extends at least 6 inches beyond the top of the next baffle when viewed from the “line of sight” from the 25 yard line.

The angled overhead baffles are constructed of 3/8” AR500 plate steel laminated with sacrificial plywood cladding covered with acoustic foam.

Bullet Trap: The manufacturer of the rubber berm bullet trap is unknown. Rubber berm bullet traps are typically capable of handling center fire rifle and shotgun ammunition provided the berm is properly maintained. Rubber berm traps consist of a berm of rubber pellets which protect an angled ballistic steel backstop. The trap did not have any thin spots in the berm or deformations/perforations in the backstop.

4. Ventilation

Carbon monoxide levels were measured on March 24, 2015. All recorded measurements were less than the 2011 ACGIH threshold limit value (TLV) target goal of 25 ppm. The results are as follows:

Date Location Duration

(min) Measurement (AVG ppm)

3/24/15 Wang / xxx-xx-1797 Range Master/Instructor

59 1.0

3/24/15 Vines / xxx-xx-0572 Shooter, Lane 2

59 10.4

The range ventilation does not display laminar flow characteristics at the 25 yard line, and none of the firing positions are within 10% of 75 feet per minute flow requirement.

The 4 firing positions are on average, within +/- 30%.

The results are as follows:

Range Air Flow Velocities

Distance Height Shooting Position

1 2 3 4

25 Yard Line

6’ 20 24 40 35

3’ 89 85 135 105

1’ 190 90 159 145

Average 100 66 111 95

In its current condition, the range does not meet current GSA requirements.

The system appears to be designed to exhaust 10% more air downrange than supplied behind the firing line as evidenced by the negative pressure differential between the range and the adjoining support area however quantitative measurement of the differential and ratio of exhaust to supply air could not be determined. There were no pressure gauges present.

The GSA design criterion for the duct work exhausting from the range is 2,000 feet per minute. FOH was unable to locate any pitot holes in the existing duct work.

There is not a local exhaust hood on the gun cleaning bench.

The air supply distribution plenums consisted of a perforated back wall.

The area behind the firing line and in front of the supply plenum is not kept free of stored materials so as not to interfere with proper air flow but this would appear to be by design. The control platform is situated in between the supply plenum and the firing line.

There do not appear to be fire and smoke dampers in the ducts however without design drawings this was difficult to confirm.

The outside air inlet for the range is located approximately 75 feet away from the outdoor range exhaust.

The ventilation system equipment is interlocked and instrumented such that its components operate simultaneously. The system has a dedicated OA supply fan.

Outside air is preconditioned before entering the supply plenum. It is important to mention that at the time of the site inspection the heating system associated with the supply fan was not working. When outdoor temperatures dropped below freezing the range ventilation system could only be operated for approximately 1 hour without risk of freezing water and sprinkler pipes. The interlocks are not timed to start the exhaust fan first so as to avoid a positive pressure within the range. The interlock does not alarm and shut down the system if the range pressure goes positive for more than 2 minutes.

There did not appear to be an alarm to notify the range master if the pressure across the HEPA filter indicates any necessary maintenance.

5. Noise

Noise dosimetry was performed on a shooter as well as the Range Master who also served as the Instructor. The Range Master/Instructor was on the control platform during live-fire activities. The following results are to be compared against the OSHA Action Level of 85 dBA and the OSHA PEL of 90 dBA for an 8-hour TWA.

Date Location Duration

(min) Peak (dBA)

Measurement TWA (dBA)

3/24/2015 Wang / xxx-xx-1797 Range Master/Instructor

69 142.5 83.8

3/24/2015 Vines / xxx-xx-0572 Shooter, Lane 2

70 142.8 91.5

Sound level measurement readings were collected from various locations throughout the range, during periods when weapons are not being fired but with the ventilation system running, to ensure that ambient noise levels do not exceed 85 dBA. None of the readings was in excess of 70 dBA.

There is no noise insulation on the ceilings or walls.

6. Lighting

Lighting is provided by multiple banks of lights arranged behind baffles along the length of the range. Lighting is directed downrange to prevent glare at the firing line. Each bank is capable of being dimmed independently from the control room.

Lighting measurements were taken at 4’ above the floor at the target lines, firing line, and in the control room (as well as other locations), but most measurements failed to be at least 915-1075 lux. Measurements taken are as follows:

Location Average Light Measurement (Lux)

Location Average Light Measurement (Lux)

Control Area Behind Firing Line 764

Firing Line - 25 Yard Line 276

20 Yards from Trap 222

15’ from Trap 244

Target Line 248

The range is not equipped with a strobe light to simulate emergency vehicles.

Instantaneous emergency lighting is not installed in case of power loss.

7. Operations

All range firing sessions are conducted under the direction of a firearms instructor. The firearm instructor generally serves as the Range Master. The Range Master controls are located in the control platform where the range master communicates with the shooters through an intercom system. Access in front of the active firing line is prohibited except for cleaning or maintenance. There are written operating procedures and safety rules which are reviewed in a classroom setting before each range session.

8. Recordkeeping and Personal Protective Equipment

There is a sign-in sheet/log maintained of personnel using, visiting, or working at the range. The type of ammunition used and the number of rounds fired are tracked through inventory. A log is also kept for maintenance. A list of authorized users, however, is not kept at the range.

Double hearing protection (earmuffs and foam plugs) is available for use in the range and appeared to be a common practice. Hearing protection is NIOSH approved. Eye protection is in compliance with the necessary regulations. Disposable gloves are not used to pick up spent casings. A fully-stocked, up-to-date trauma kit is maintained on the firing range by the Range Master.

9. Hygiene

Sticky mats are were not present at the range. Range users can and do exit from the range through the support room.

All personnel are required to wash their hands and face after each session. Rubber mats are provided for firing from a kneeling position. Prone firing positions are not used on the range.

10. Signage

A sign is present to remind shooters that food and drinks are not allowed on the range;

however, it doesn’t include restrictions for alcohol, tobacco, or gum.

The following signs and information are not posted:

A sign indicating the highest powered ammunition allowed at the range.

A lighted range in operation sign; however, paper flip sign is used.

A sign prohibiting the storage of items on the range.

A sign prohibiting the cleaning of firearms except in designated areas.

A sign listing emergency services telephone numbers and maps to the nearest emergency medical facility.

There are not illuminated exit signs indicating the route to the outside of the building.

The range is not identified with ADA-AG compliant tactile Braille signage modules.

11. Communication

Per staff interviews, it was reported that training sessions are held to familiarize all shooters with the firing range safety rules and operating procedures prior to each use of the range. Annual training sessions are held to communicate the health hazards associated with lead and gun cleaning chemicals. Annual training sessions are also held to communicate the hazards associated with noise exposure.

12. Alarms

The following interlocks were not provided to trigger an audible and visual alarm at the firing line and throughout the range: a laser or infrared trip at the firing line, an open door to the range, ventilation malfunction, or manual shutdown. Audible and visible (strobe) fire alarm indicators were present.

The range is equipped with sprinklers protected by baffles which are properly positioned for firing from the 25 yard line.

13. Cleaning

The range is reportedly cleaned by an outside contractor on a quarterly basis. Range personnel had no detailed knowledge of a range cleaning plan as that work is contracted out by others. If there is a site-specific range cleaning plan, it would be contained within the statement of work executed by the range cleaning contractor.

It was reported that CBP officers collect lead wipe samples following the periodic cleaning however they indicated that were not provided with the results.

14. Maintenance

The range maintenance is done by an outside contractor. Range personnel had no detailed knowledge of a range maintenance plan as that work is contracted out by others. If there is a site-specific range maintenance plan, it would be contained within the statement of work executed by the range maintenance contractor.

15. Inspection and Testing

According to staff interviews, biennial inspections of the range were not conducted;

however, a previous inspection reported dated 2010 was found posted in the range support area on a bulletin board.

The following lead dust wipes were taken on March 24, 2015 to determine if lead dust is present on various surfaces.

Sample Number Location Concentration

(μg/ft2)

032415-LW-01 Firing Line – Shooting Position #2 - Floor 17,000

032415-LW -02 Control Area Floor 1,500

032415-LW -03 Control Area Desk 87

032415-LW -04 Support Room Floor at Door to Range 3,400

032415-LW -05 Support Room Counter Top 270

032415-LW -06 Range 10’ from Trap 8,200

032415-LW -07 Range 30’ from Trap 12,000

032415-LW -08 Landing at top of Stairs 730

Lead dust levels as measured from wipe samples collected according to ASTM E1728- 03 and taken behind the firing line, and in support areas adjacent to the range shall be less than 200 μg/ft2.

16. Waste Management

Recovered brass casings as well as all recovered lead slugs and lead-impregnated wastes are collected for recycling. The recycling containers for the casings are stored inside the range behind the firing line. Recycling manifests do not appear to be maintained on site.

The waste containers are stored outside of the building adjacent to the air handling equipment. The used air filters (pre, mid, and HEPA) from the firing range air handling systems are removed from the site when they are replaced.

Two waste samples were collected from the bullet trap. The TCLP sample results were 11 mg/L from sample 1 (032415-TCLP 01) and 13 mg/L from sample 2 (032415-TCLP 02). Lead waste with TCLP results exceeding 5 mg/L is considered hazardous.

VIII. EVALUATION SUMMARY AND RECOMMEDATIONS

Following the inspection that was performed throughout the spaces (focusing on the criteria outlined in the GSA Public Buildings Service’s document entitled “Indoor Firing Range Design, Operations & Maintenance Criteria”), the findings are as follows:

Findings

1. The range does not have a control room separated from the range.

2. The last documented range evaluation appears to have been in August 2010.

The previous report described elevated lead dust levels (> 200ug/ft2) outside the range.

3. The firing line is defined by the leading edge of the shooting stalls however it is not marked with a 4” red line.

4. A 4” yellow ready line is not present 8’ behind the firing line. However it should be pointed out that a ready line 8’ behind the firing line would be impractical given the range size and configuration.

5. Lane stalls are not designated or labeled with numbers. As previously mentioned the lanes have been designated 1 thru 4 (left to right facing down range) for purposes of this report.

6. Lane partitions are not 48” wide. All partitions are 44” wide.

7. Lane 4 is less than 4 feet in width and does not have an additional 1 foot or more along the adjacent wall.

8. The range does not have a two door air lock system separating the support areas from the range.

9. Egress from the range does not have a panic bar and does not have illuminated signs leading from the range.

10. Range doors do not have sacrificial plywood cladding and do not appear to have a ballistic rating.

11. The range does not have a two-way communication system between the controls and the firing line. The value of a two-way communication system is minimized given the layout of the range and the normal operational procedures.

The Range Master also served as the instructor during the firing exercises observed. During this time the Range Master/Instructor remained on the control platform which is inside the range within several feet of the firing line. The Range Master/Instructor provides voice instructions to the shooter via a PA system.

12. The Range Master’s seat was a cloth chair.

13. Recyclables are stored on the range in a waste can which is emptied by a contractor.

14. Firearm cleaning is performed using conventional methods (brushes, patches, and cloths). The range does not have compressed air or an ultrasonic cleaner.

15. Range design specification and mechanical drawings were not available at the range for review.

16. The range floor does not appear to be coated with a waterproof sealant.

17. The horizontal canopy does not extend at least 12’ in front of the firing line and does not have any splatter protection.

18. There was no documentation available at the site regarding the construction of the rubber berm bullet trap.

19. The airflow at the firing line on average was in excess of the required 75 feet per minute requirement. However the flow in each of the lanes was not within 10% of 75 fpm.

20. Sampling ports on the ductwork could not be found. Subsequently the ratio of exhaust to supply air could not be measured.

21. The range does not have a pressure gauge to measure the negative pressure differential. The range does however maintain a negative pressure differential to the surrounding areas.

22. The gun cleaning bench does not have local exhaust.

23. The area behind the firing line is not free of stored materials.

24. Details of the construction of the ventilation system could not be verified without drawings. There was no evidence of smoke and fire dampers.

25. Sampling ports in the ductwork were not observed therefore the flow and symmetry of the air flow could not be determined. Furthermore the ratio of exhaust to supply air could not be determined.

26. The interlock does not have an alarm if either the supply or exhaust is not working properly.

27. The interlock is not timed to start the exhaust fan in advance of the supply fan.

28. The interlock alarm does not shut down the system if the range pressure goes positive for more than 2 minutes.

29. There is no alarm to notify the range master if the pressure drop across the HEPA filters indicates needed maintenance.

30. Pressure drop across the filters is not used to determine their replacement.

HEPA filters are changed out on a periodic basis which is reportedly on an annual basis.

31. Peak noise levels exceed 140 dBA during firing of handguns and shotguns.

32. There is no noise insulation on the walls and ceiling.

33. Lighting levels throughout the range are below GSA criteria.

34. There is not a strobe light to simulate emergency vehicles.

35. There does not appear to be emergency lighting on the range in the event of a power loss.

36. A maintenance log was not present at the site. All maintenance work is contracted out.

37. Sticky mats are not used at the range.

38. Rubber mats at the firing line are not cleaned with lead wipes after each session.

39. There are no signs at the range indicating the highest powered ammunition allowed at the range or prohibiting the storage of materials between the firing line and the supply plenum or limiting firearms cleaning to a designated area.

40. The range is not equipped with a lit range in use sign or a lit exit sign.

41. None of the signage at the site is ADA compliant.

42. The range is not equipped with the following triggers or alarms:

A laser or infrared trip at the firing line

An open door to the range

Ventilation malfunction

43. A site specific range cleaning plan or a range maintenance plan is not maintained at the site. The range cleaning and maintenance is performed by outside contractors.

44. Lead contaminated waste is stored in a drum outdoors.

45. Wipe sample results following cleaning are not maintained at the site.

46. Periodic range maintenance procedures are not maintained at the site.

47. The range does not appear to have gone through biennial comprehensive inspection and testing evaluation. The range’s last inspection appears to have been in 2010.

48. It appears that spent casings and shells are stored on the range.

49. Hazardous waste manifests were not present at the site for review.

Recommendations

Based on the findings of the Indoor Firing Range Evaluation performed at the LPOE firing range in Raymond, MT, FOH presents the following recommendations:

Lead Dust

The following controls should be put in place to reduce the lead dust levels behind the firing line and the surrounding support areas:

The shooting mats at the firing line should be cleaned after each use using wipes. The use of mats with rough surfaces should be avoided where possible as they will be more difficult to clean.

Sticky mats should be installed at the entrance to the range and at the door to the outdoors.

Any cloth chairs on the range should be replaced with chairs that are smooth and cleanable.

Range recyclables should be collected and stored in marked closed-top containers.

The range floor and the floor of the support area should be coated with a sealant such as an epoxy paint.

Install local ventilation in the gun cleaning area.

Lead in Air Exposures

Previous exposure data from the 2010 report indicated that exposures to lead from the use of handgun ammunition were below detection limits therefore, it is likely that the firing of the shotgun ammunition was largely if not solely responsible for the measured lead exposures which were 25% and 40% of the OSHA Permissible Exposure Limit.

Administrative controls should be used to control the exposure of shooters and instructors on the range. FOH recommends limiting shooter and Range Master/instructor time on the range to a single 12 gauge shotgun courses of fire per day consisting of a single shooter firing no more than 20 rounds per course. The range instructor and shooter should leave the range ventilation system on and exit the range immediately following the completion of the course of fire. The range should remain vacant until the range has sufficient time for four air changes to occur.

FOH also recommends that no one (shooters or instructors) be exposed to more than two 12 gauge shotgun courses of fire per day with each course of fire consisting of a single shooter firing no more than 20 rounds per course. Furthermore the two courses of fire should be separated by sufficient time to allow the ventilation system adequate time to flush the airborne lead from the range. It is important to note that two 12 gauge shotgun courses of fire conducted sequentially or simultaneously may result in exposures above the OSHA action level if not the OSHA PEL.

The above recommendations are based on limited data therefore FOH recommends conducting lead exposure monitoring on a more frequent basis so that the range’s characteristics and capacities can be documented and shooter/instructor exposures can be reasonably predicted. All lead exposure monitoring should be accompanied with the following information:

Types of rounds fired Number of rounds fired Data relating to the rate of fire

Sampling ports should also be installed in the ductwork to permit the calculation of the ratio of exhaust to supply air.

Marking and signage

The following markings should be applied to the range:

4” painted firing line Shooting Lane/Stall numbers Sign indicating the approved ammunition for the range.

Sign stating to clean firearms in designated areas.

A lit range in operation sign Illuminated exit signs Posting of emergency numbers and maps to nearest emergency medical treatment.

Onsite Records

The availability of documents and records is essential for determining compliance with the GSA IFR criteria. Specifically sufficient information needs to be available so that a determination can be made whether or not the range is functioning as specified by its design.

FOH recommends that detailed design and construction drawings for the range be maintained at the site. Other supporting documentation regarding the construction of the range, the ventilation system, the bullet trap, and acceptable performance criteria should also be readily accessible.

The scopes of work for the maintenance and cleaning service contractors should be maintained at the site since they contain all the details regarding the range maintenance, recycling, cleaning, and waste disposal procedures.

All contractors working at the range should be required to complete a log of their onsite activities which is maintained at the site.

Deviations in Construction from GSA IFR Criteria

The building was reportedly constructed in 2005 subsequently the construction of the range deviates from the requirements in the GSA IFR Criteria which was published in 2012. In some cases the deviations are minor and correctable while others are not.

Therefore FOH tried to take this into account in formulating the recommendations below:

1. Install an Airlock with Ballistic Door - The range does not have a ballistic door.

The existing door can be replaced with a ballistic door with ½” sacrificial plywood.

Since the range does not have an airlock, replacing the door should include a discussion of installing one.

2. Install Alarm and Shutdown Interlocks - The installation of interlocks to provide malfunction alarms and delay the start of the supply fan is likely to require the replacement of existing electronics and controls. The installation of the interlocks and alarms would also require that pressure gauges be installed to monitor the range pressure to the surrounding areas and pressure drops across exhaust filter banks. Other considerations include:

Firing line trip – Installation of laser or Infrared trip. See discussion of widening the firing lanes

Open door alarm Ventilation Malfunction…