Piegan_Firing_Range_GSA_Report.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

5023 HWY 89 NORTH

BABB, MT 59411

MAY 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 5023 Highway 89 North, Babb, Montana. The assessment included the indoor firing range that is used by Custom and Border Patrol (CBP) staff including the Border Patrol Officers, 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 26, 2015 under an Interagency Agreement established between FOH and GSA.

The LPOE Piegan Firing Range is located in a single story building and is used by CBP Officers including the Border Patrol Officers. The firing range occupies a portion of the building that also serves as a garage and storage area. Access to the range is from the outdoors and is separate from the rest of the building. The door to the range leads to a common hallway that serves the range, a locked storage room, a bathroom, and a mechanical room which houses the supply air mechanical equipment for the range. The locked storage room contains a desk and chair where gun cleaning is conducted and a lockable fenced storage area. The range area is accessed from the hallway through a single door. The range consists of two (2) firing lanes with an automatic targeting system. The range controls are located on a desk 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 two firing positions delineated by prefabricated shooting stalls. Both 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 SW .40 cal; however, other handgun calibers may be used.

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:

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

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

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

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

5. The range had no baffles, leaving the lights and sprinkler heads unprotected.

Further, the range did not have a horizontal canopy baffle over the firing line.

6. The bullet trap appeared worn by bullet impact causing thin spots that may have allowed bullets to penetrate the ballistic curtains. Also, there was a gap between the bottom of the ballistic curtain and a metal barrier that allowed bullets to pass under the ballistic curtain and impact the wall and equipment behind the curtain.

7. The overall average air flow of the range at the firing line was 68 feet per second;

however, it is not laminar.

8. The range was able to establish a negative pressure; however, the ratio of supply to exhaust air could not be determined as there was no gauge.

9. There was no way to confirm the minimum intake/exhaust ratios as only the exhaust was measurable.

10. There are no interlocks on the air supply and exhaust air handling units.

11. There is no pressure alarm on the filters to indicate when they need to be changed.

12. There is insufficient lighting across the whole range.

13. 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 Manual shutdown in the control area

14. The range cleaning and maintenance is performed by outside contractors;

however, their scopes of work which would contain the range cleaning and maintenance plans are not maintained at the site.

15. Wipe tests are conducted, but records are not maintained on site.

16. Periodic range maintenance procedures are not maintained at the site and are controlled by GSA on behalf of CBP.

Findings & 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:

Formally designate a gun cleaning area.

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

Purchase an ultrasonic cleaner and chemicals for cleaning firearms.

Apply an epoxy paint coating to the range.

Clean the maintenance garage area adjoining the bullet trap.

Install sticky mats at the entrance to the bullet trap.

Lead in Air

The firing of handgun ammunition does not appear to create conditions that could result in exposures exceeding the OSHA PEL for lead in air. The air sampling data would not be representative of exposures created from the use of other types of ammunition, specifically shotgun and rifle ammunition. It was reported to FOH that only handgun ammunition is used on the range.

FOH recommends conducting additional lead exposure monitoring if there are any changes in the general types of ammunition used on the range. FOH also recommends conducting additional exposure monitoring if and when two (2) shooters may be present on the range at the same time. It is essential to document exposures under all normal shooting activities so that the range’s characteristics and capacities can be documented and future shooter/instructor exposures can be reasonably predicted using existing data. 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

The lead-in-air sample collected on the roof at the range’s exhaust vent should have been several orders of magnitude lower than the personal exposure samples, which was not the case. FOH believes that it is likely the filters (and possibly the filter seal mating surfaces) have been damaged and/or perforated by bullets passing under the bullet trap.

FOH recommends replacing the filters on the exhaust air handler and inspecting the unit for conditions such as damaged matting surfaces that would allow air to bypass the filters.

The exhaust sample result (5.6 µg/m3) can be compared to the EPA National Ambient Air Quality Standard (NAAQS) for lead which is 0.15 µg/m3 expressed as a 3-month rolling average. At the measured concentration, the range would exceed the NAAQS if 34 similar sessions were held within a 3-month time frame.

Marking and signage

The following markings should be applied to the range:

4” painted firing line Sign indicating the approved ammunition for the range.

Sign on door to the trap area indicating it as hazardous Sign stating to clean firearms in designated areas.

Sign prohibiting the storage of materials between the firing line and plenum Sign reminding shooter to wash after each session 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 were 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 that swings out from the range. It should be pointed out that the range does not have an airlock; therefore, replacement of the door should include a discussion of installing an airlock.

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 or replaced to monitor the range pressure to the surrounding areas and pressure drops across exhaust filter banks. Other considerations include the installation of the following:

Firing line trip - Installation of laser or infrared trip.

Open door alarm Ventilation Malfunction Alarm/Notification Lit “range in operation” sign

3. Install an Enclosed Control Room - The installation of an enclosed control room behind the firing line to the existing range would require an addition to the facility since the range occupies the full length of the existing building.

4. Sound Insulation - The installation of sound insulation to the ceiling and walls should not be performed separately from addressing the ballistic shielding of the range. As currently configured, the ceiling and parts of the side walls don’t have sound insulation.

5. Ballistic Shielding - Ballistic baffles and a canopy should be added to the range.

The range is not currently equipped with either.

6. Bullet Trap - The bullet trap should be inspected and serviced as necessary to repair any thin spots.

7. Lighting - The current lighting system would have to be replaced in order to meet the requirements in the GSA IFR Criteria. The lighting levels need to be increased and the system needs to have dimmable controls. The new lighting system should also include a strobe light (if needed by the users) as well as exit and emergency lighting.

The lighting system should be designed in conjunction with the design of the ballistic baffles and canopy.

8. Miscellaneous - FOH has the following recommendations:

Install an eyewash station in the gun cleaning area Provide a gun clearing barrel Install sampling ports in the supply air duct Provide smooth and cleanable rubber mats for shooting from a kneeling position

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 5023 Highway 89 North, Babb, 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 26, 2015 under an Interagency Agreement established between FOH and GSA.

The purpose of this assessment was 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 SW .40 cal; however, other handgun calibers may be used.

Heckler & Koch P2000 handguns were used while this evaluation was being conducted.

The LPOE Piegan Firing Range is located in a single story building and is used by CBP Officers including the Border Patrol Officers. The firing range occupies a portion of the building that also serves as a garage and storage area. Access to the range is from the outdoors and is separate from the remainder of the building. The door to the range leads to a common hallway that serves the range, a locked storage room, a bathroom, and a mechanical room which houses the supply air mechanical equipment for the range. The locked storage room contains a desk and chair where gun cleaning is conducted and a lockable fenced storage area. The range area is accessed from the hallway through a single door. The range consists of two (2) firing lanes with an automatic targeting system. The range controls are located on a desk behind the firing line that is not separate from the range.

The supply air is served by air handling equipment across the hallway from the range.

The exhaust air handling equipment is located behind the bullet trap on the left hand side of the range. The area behind the bullet trap is accessible through a door from the garage on the far end of the building.

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 mechanical equipment consists of a HEPA filtered air handling unit that exhausts air through a roof vent. The exhaust fan and filters are located behind the rubber curtain bullet stop. The exhaust fan does not have any associated intake duct work and instead pulls air directly into the unit through the exposed face of the filter bank. The supply air used to ventilate the range is served by a single supply fan and provides conditioned fresh outdoor air (OA). The supply fan does not have any return air.

IV. STUDY OBJECTIVES AND TECHNICAL APPROACH

The purpose of this assessment was 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 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 in outdoor air is 9 ppm (parts per million), based on an 8-hour average. For the purposes of this report, 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

Exposure

Personal lead exposure monitoring was conducted on March 26, 2015 and included one shooter and one instructor who 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)

032615-LA-01

Gray / xxx-xx-5512 Instructor, Range Controls

79 2.0 158 15 2.5

032615-LA -02

Kelly / xxx-xx-7874 Shooter, Lane 1

77 2.0 154 12 1.9

032615-LA -03

Exhaust Air Outdoors on Roof

103 2.0 206 5.6 1.2

032615-LA -04 Field Blank NA NA NA <0.80 µg NA

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

During this evaluation, only handgun ammunition was used. The 40 S&W handgun courses of fire lasted approximately 60 minutes, during which time approximately 145 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.

The exhaust air sample result should have been several orders of magnitude lower than the personal samples since the exhaust air handler is equipped with high efficiency filters. The exhaust air sample result indicates that the exhaust air handling unit was not adequately filtering the exhaust.

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 more or less behind Lane 2 against the side wall. There is a separate secure fenced storage area for supplies and ammunition. There is not a dedicated gun cleaning area; however, gun cleaning does occur in the locked storage room and in the hallway.

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 actual construction date of the range is unknown but 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 a dedicated control room The controls are located on a desk in between the supply air diffuser and firing line. The desk 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 range does not have a dedicated gun cleaning area.

Shooting Lanes: The two lanes are clearly designated and are numbered from left to right looking downrange. The partitions more or less allow for adequate air flow downrange; however, the control table provides some interference with the airstream between the firing line and the supply air diffuser. Both firing positions are approximately 60” wide.

Openings and Egress: General access to the range is through a single doorway which swings inwards (should swing outwards) from the adjoining hallway. The main egress from the range is through the door into the hallway and then through the door to the outdoors. The door to range does not have a panic bar; however, the door to the outdoors does. The exit from the range does not have illuminated signs. The range door to the support room does not appear to have a bullet resistance rating and does not have sacrificial plywood cladding.

Safety Control Room: The range controls are located on a table behind the firing line which is not housed in a separate room. Subsequently, there is not a ventilation system serving the control room that is separate from the range. The fan controls are mounted on the wall next to the door. 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 and subsequently voice commands appear to be adequate.

There is a single cloth chair positioned at the range controls which cannot be easily cleaned of lead dust. Communication to the outside services is available via a wall mounted phone in the adjoining hallway.

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. The targeting system also has electronic controls at the booths.

Support Facilities: The support areas do not have a designated gun cleaning area. It was reported that personnel clean firearms in the hallway; however, there were no appurtenances in the hallway to support cleaning activities. It seems more likely that gun cleaning was performed in the locked storage room which has a chair and desk.

Gun cleaning tools and supplies were observed on the desk. The range is not equipped with compressed air or an ultrasonic cleaner.

The locked storage room has a locked fenced-in area where ammunition, firearms, recyclables, and range supplies are stored. A bathroom is located at the end of the hallway which has a sink for washing. An eyewash station is not present.

Ballistic Design

General Design: Drawings were not available at the site for review and there was no documentation regarding the bullet trap. The range’s ballistic protection consists of walls and ceilings that have ½” Kevlar/fiberglass sheeting beneath ½” drywall on the ceilings, and either 2” tectum board or sheet metal on the walls.

Floors: The range floor is continuous and 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 is 4 inches thick. The tops of the walls extend up to the ceiling with no gaps. The walls have ballistic fiberboard backing. Portions of the wall are laminated with sheet metal that was not damaged.

Ceiling: The ceiling appears to be sealed of all openings to isolate the range from the surrounding areas for purposes of ventilation and ricochet protection. It is unknown if the recessed fluorescent lights are backed with ballistic sheeting.

Baffles: The range is not equipped with any baffles or a canopy.

Bullet Trap: The bullet trap consists of approximately 240 vertical sheets of fiber-reinforced rubber mats that are approximately ½” thick, 18” wide, and 8’ tall. Bullets are fired into the exposed edges of the mats. The mats are suspended in two staggered vertical curtain rows each with approximately 120 mats. The first curtain row of mats is oriented approximately 30-45 degrees to the firing line so that deflections are to the right. The second curtain row of mats is similarly angled in the opposite direction to direct deflections to the left. The bottom edges of the mats are approximately 8-10” above the floor.

Movable ballistic plating was positioned on the floor in front of the bullet trap and is intended to prevent bullets from passing underneath the curtain rows. The back edge of the ballistic plating is propped up with lumber. Neither the plating or lumber supports are secured to the floor or walls. The ballistic plate assembly creates an angled deflection surface that is intended to deflect low shots upwards into the curtain mats.

FOH concluded onsite that the positioning of the ballistic plating was incorrect and had it repositioned prior to live fire activities. Prior to repositioning the ballistic plates, shooters had a direct line of sight to the gap between the floor and curtains which allowed bullets to skip underneath the curtains and strike and damage equipment behind the bullet trap.

Although there was no documentation at the site regarding the bullet trap, it was suspected that the Lane 1 side of the trap needed maintenance as those mats appeared more worn than the remainder of the trap.

Ventilation

The range supply and exhaust fans are not interlocked in such a manner that notifies range operators if there is an equipment malfunction. Since there is no pressure gauge to indicate the pressure gradient to the surrounding areas, the evaluation of range pressurization was performed using air flow measurements and visual indicators. It was discovered during the evaluation of the range pressure gradient that the exhaust fan breaker had tripped and would not reset. FOH concluded the range had been operating with a positive pressure gradient to the adjoining areas for an unknown length of time before the evaluation. The situation was the result of a number of failures, as follows:

The ballistic floor plate in front of the bullet trap was improperly positioned, creating a line of sight from the firing line to beneath the bullet trap curtains.

Bullets fired from the firing line ricocheted through the exposed opening, striking the mechanical equipment behind the firing line.

One of the bullet strikes had severed the power line to the fan motor, rendering it inoperable, which caused the breaker to trip.

There were no visual or audible indicators to notify range users that the ventilation system was malfunctioning.

The ventilation system equipment doesn’t have interlocks.

The noise and airflow from the supply fan helped conceal that the range ventilation system was malfunctioning.

Repairs were made prior to the live fire evaluation. The ballistic floor plate was repositioned to prevent bullets from passing under the curtain, and the fan motor power line was spliced back together by onsite personnel. With the exhaust fan functioning, the ventilation system was able to establish a negative pressure differential with respect to the surrounding areas.

Please note that all air samples results and measurements presented in this report reflect conditions with the exhaust fan in operation.

Based on the lead sample result from the exhaust air, it appears that the ventilation system is not providing adequate filtration. The open face of the exhaust air filter bank points directly up range and is situated ~1 foot behind the curtains in Lane 1. This exposes the banks to indirect fire under the curtain. It would be reasonable to conclude the filters had been perforated by bullets.

Carbon monoxide levels were measured on March 26, 2015. All recorded measurements were less than the 2011 ACGIH TLV target goal of 25 ppm. The results are as follows:

Date Location Duration

(min) Avg. Measurement (ppm)

3/24/15 Kelly / xxx-xx-7874 Shooter, Lane 1

92 0.3

3/24/15 Gray / xxx-xx-5512 Instructor, Range Controls

91 0.0

The system has a dedicated OA supply fan. Outside air is preconditioned before entering the supply plenum. The air supply distribution plenum consisted of a perforated back wall that is 10’ behind the firing line. The range ventilation does not display laminar flow characteristics at the 25 yard line, and neither of the firing positions is within 10% of 75 feet per minute flow requirement.

The results of range air flow velocity measurements are as follows:

Range Air Flow Velocities, fpm

Distance Height Shooting Position

1 2

25 Yard Line

6’ 42 55

3’ 55 92

1’ 40 120

Average 45.6 89

In its current condition, the range does not meet current GSA requirements with respect to air flow.

The ventilation 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 as there were no sampling ports evident on the supply.

The GSA design criterion for the duct work exhausting from the range is 2,000 feet per minute. FOH did locate four pitot holes in the exhaust duct work. The average exhaust duct velocity was measured at 1,700 feet per minute

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

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 table is situated in between the supply plenum and the firing line.

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)

3/24/15 Kelly / xxx-xx-7874 Shooter, Lane 1

76 142.1 89.5

3/24/15 Gray / xxx-xx-5512 Instructor, Range Controls

80 142.5 88.5

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

There is no noise insulation on the ceilings or walls.

Lighting

Lighting is provided by recessed fluorescent lighting that is not protected by baffles.

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 line, firing line, and other locations. All measurements failed to be at least 915-1075 lux. Measurements taken are as follows:

Location Average Light Measurement (Lux)

Behind Firing Line 545

Firing Line - 25 Yard Line 306

10 Yards from Trap 265

10’ from Trap 275

Target Line 270

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

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

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 and there are supplemental controls on the stalls.

The range master/instructor issued voice instructions to the shooter without the aid of an intercom system or two way communication devices. This method of communication with the shooter appeared to be adequate as the instructor/range master stood only a few feet behind the shooter during the exercises. 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.

Recordkeeping and Personal Protective Equipment

There is a sign-in sheet/log maintained of personnel using, visiting, or working at the site maintained in the main building. 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.

Hygiene

Sticky mats were recently installed at the range and were in use at the time of the range evaluation. 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 not provided for firing from a kneeling position. Prone firing positions are not used on the range.

Signage

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

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 on the door to the trap door indicating the area as hazardous A sign prohibiting the cleaning of firearms except in designated areas.

A sign reminding shooters to wash after a session Illuminated exit signs A sign listing emergency services telephone numbers and maps to the nearest emergency medical facility.

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

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.

Alarms

The following alarms and/or interlocks are not present at the range:

Alarm indicating an open door to the range Alarm indicating a ventilation malfunction

The range is equipped with sprinklers but they are not protected by baffles.

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.

Spent brass is collected and stored. Personnel at the range were not sure whether the spent brass and casings were recycled.

Results of previous lead tests were not maintained at the site.

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.

Inspection and Testing

According to staff interviews, biennial inspections of the range have not been conducted.

The following lead dust wipes were taken on March 26, 2015 to determine if lead dust is present on various surfaces.

Sample Number Location Lead (μg/ft2)

032615-LW-01 Firing Line – Shooting Position #2 - Floor 270

032615-LW -02 Control Area Desk Top 160

032615-LW -03 Range Floor at Entrance 250

032615-LW -04 Range 30’ from Trap 620

032615-LW -05 Range 10’ from Trap 950

032615-LW -06 Supply Room Desk Top 120

032615-LW -07 Supply Room Floor at Door to Hallway 70

032615-LW -08 Exhaust Fan Behind Bullet Trap 2,600

032615-LW -08 Maintenance Bay Floor at Door to Bullet Trap 16,000

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.

Waste Management

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

The waste containers are stored in the locked storage room.

Two waste samples were collected from debris behind the bullet trap for analysis in accordance with the Toxicity Characteristic Leaching Procedure. The TCLP results were <0.40 mg/L from Sample 1 (032615-TCLP 01) and 150 mg/L from Sample 2 (032615-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. Guns are cleaned in the hallway or storage room with no running water available or dedicated space. Firearm cleaning is performed using conventional methods (brushes, patches, and cloths). The range does not have compressed air or an ultrasonic cleaner.

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 line is not present 8’ behind the firing line. However, it should be noted that a ready line 8’ behind the firing line would be impractical given the range size and configuration.

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

6. The range door opens inward.

7. Egress from the range does not have a panic bar or door handle that conforms to fire code for emergency escape.

8. The range exit does not have an illuminated exit sign.

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

10. 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. Open voice communication is used.

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

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

13. As-built drawings for the range were not available for review.

14. The range had no baffles, leaving the lights and sprinkler heads unprotected.

Further, the range did not have a horizontal canopy baffle over the firing line.

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

16. No indents in the range floor were visible.

17. The bullet trap appeared worn by bullet impact, causing thin spots that may have allowed bullets to penetrate the ballistic curtains. Also, there was a gap between the bottom of the ballistic curtain and a metal barrier that allowed bullets to pass under the ballistic curtain and impact the wall and equipment behind the curtain.

18. Repairs or recent maintenance to the ballistic curtain was not apparent.

19. No drawings or schematics of the bullet trap were available.

20. The overall average air flow of the range at the firing line was 68 feet per second;

however, it is not laminar.

21. The range was able to establish a negative pressure; however, the ratio of supply to exhaust air could not be determined as there was no gauge.

22. There was not a dedicated gun cleaning area with a dedicated exhaust hood.

23. The area behind the firing line is not free of stored materials. It contained range control equipment and furniture.

24. The exhaust air unit is behind bullet trap and is offset to the Lane 1 side of the range.

25. There is no intake duct work on the exhaust air unit. The unit’s filter bank is open faced behind the bullet trap.

26. There was no way to confirm the minimum intake/exhaust ratios as only the exhaust was measurable.

27. There are no interlocks on the air supply and exhaust air handling units.

28. There is no pressure alarm on the filters to indicate when they need to be changed.

29. Supply air to the range is not filtered. The supply air is 100% outside air.

30. A pressure gauge is present on the filters, however the gauge is not used to determine when filter need to be replaced. Filters are replaced on a periodic basis regardless of the pressure gauge.

31. Peak noise levels on the range exceed 140 dBA.

32. There is insufficient noise insulation on the walls and ceiling.

33. Standard fluorescent lights are used to illuminate the range with no baffling.

34. There is insufficient lighting across the whole range.

35. There is no strobe light to simulate emergency vehicles.

36. There is no instantaneous emergency lighting installed for power loss.

37. There is no log kept on the range listing authorized users. However, the population of range users is very small.

38. There are no signs reminding shooters of the following restrictions and requirements:

The highest power ammunition allowed on the range Requirement for eye protection On the door to the trap area that the area is hazardous Prohibition of storage of material between the firing line and plenum Prohibition of cleaning firearms except in designated areas Reminding shooters to wash their hands after a session

39. There is no illuminated “range in operation” sign.

40. There are no rubber mats for kneeling or prone position firing.

41. There is no exit sign.

42. There were no emergency telephone numbers or maps to the nearest emergency rooms posted.

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

44. Signage was taped or glued to the structure instead of mechanically fastened.

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

An open door to the range

Ventilation malfunction

Manual shutdown in the control area

46. The range is not equipped with heat detectors in case of fire. There is a sprinkler system in place.

47. The range cleaning and maintenance are performed by outside contractors;

however, their scopes of work which would contain the range cleaning and maintenance plans are not maintained at the site.

48. Wipe tests are conducted, but records are not maintained on site.

49. Periodic range maintenance procedures are not maintained at the site and are controlled by GSA on behalf of CBP.

50. The range does not appear to have gone through biennial comprehensive inspection and testing evaluation.

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

52. Recycling manifests are not maintained on site.

53. Recyclable waste may be thrown away. A determination could not be made as to whether contractors were recycling the waste or disposing of it as hazardous.

Recommendations

Based on the findings of the…