Env_Management_at_Operating_Outdoor_Small_Arms_Firing_Ranges_Feb_2005.pdf

Environmental Management at Operating Outdoor

Small Arms Firing Ranges

Prepared by The Interstate Technology & Regulatory Council

Small Arms Firing Range Team

February 2005

Technical Guideline

ABOUT ITRC

Established in 1995, the Interstate Technology & Regulatory Council (ITRC) is a state-led, national coalition of personnel from the environmental regulatory agencies of some 44 states and the District of Columbia; three federal agencies; tribes; and public and industry stakeholders. The organization is devoted to reducing barriers to, and speeding interstate deployment of, better, more cost-effective, innovative environmental techniques. ITRC operates as a committee of the Environmental Research Institute of the States (ERIS), a Section 501(c)(3) public charity that supports the Environmental Council of the States (ECOS) through its educational and research activities aimed at improving the environment in the United States and providing a forum for state environmental policy makers. More information about ITRC and its available products and services can be found on the Internet at www.itrcweb.org.

DISCLAIMER

This document is designed to help range operators, regulators, and others develop a consistent approach to the evaluation and deployment of appropriate practices and technologies at applicable sites.

Applicability depends, and should be based upon, the specific circumstances at a given range. Although the information in this document is believed to be reliable and accurate, this document and all material set forth herein are provided without warranties of any kind, either express or implied, including but not limited to warranties of the accuracy or completeness of information contained in the document. The technical implications of any information or guidance contained in this document may vary widely based on the specific facts involved and should not be used as a substitute for consultation with professional and competent advisors. Although this document attempts to address what the authors believe to be all relevant points, it is not intended to be an exhaustive treatise on the subject. Interested readers should do their own research, and a list of references is provided as a starting point. This document does not necessarily address all applicable health and safety risks and precautions with respect to particular materials, conditions, or procedures in specific applications of any technology. Consequently, ITRC recommends also consulting applicable standards, laws, regulations, suppliers of materials, and material safety data sheets for information concerning safety and health risks and precautions and compliance with then-applicable laws and regulations. The use of this document and the materials set forth herein is at the user’s own risk. ECOS, ERIS, ITRC and the authors and organizations developing this guidance shall not be liable for any direct, indirect, incidental, special, consequential, or punitive damages arising out of the use of any information, apparatus, method, or process discussed in this document. This document may be revised or withdrawn at any time without prior notice.

ECOS, ERIS, ITRC and the authors and organizations developing this guidance do not endorse the use of, nor do they attempt to determine the merits of, any specific technology or technology provider through publication of this guidance document or any other ITRC document. The type of work described herein should be performed by trained professionals, and federal, state, and municipal laws should be consulted.

ECOS, ERIS, ITRC and the authors and organizations developing this guidance shall not be liable in the event of any conflict between this guidance document and such laws, regulations, and/or ordinances.

Mention of trade names, trademarks, manufacturers, or commercial products does not constitute or imply endorsement favoring or recommendation of use by ECOS, ERIS, ITRC or the authors and organizations developing this guidance and shall not be used for advertising or product endorsement. This document is not a regulation, nor does it impose legally binding requirements on any user.

Environmental Management at Operating Outdoor Small Arms Firing Ranges

February 2005

Prepared by The Interstate Technology & Regulatory Council

Small Arms Firing Range Team

Copyright 2005 Interstate Technology & Regulatory Council 50 F Street NW, Suite 350, Washington, DC 20001

Permission is granted to refer to or quote from this publication with the customary acknowledgment of the source. The suggested citation for this document is as follows:

ITRC (Interstate Technology & Regulatory Council). 2005. Environmental Management at

Operating Outdoor Small Arms Firing Ranges. SMART-2. Washington, D.C.: Interstate Technology & Regulatory Council, Small Arms Firing Range Team. Available on the Internet at http://www.itrcweb.org.

http://www.itrcweb.org/

ACKNOWLEDGEMENTS

The members of the Interstate Technology & Regulatory Council (ITRC) Small Arms Firing Range Team wish to acknowledge the individuals, organizations, and agencies that contributed to this technical guideline.

As part of the broader ITRC effort, this Small Arms Firing Range Team work is funded primarily by the United States Department of Energy. Additional funding and support have been provided by the United States Department of Defense and the United States Environmental Protection Agency. ITRC operates as a committee of the Environmental Research Institute of the States (ERIS), a Section 501(c)(3) public charity that supports the Environmental Council of the States (ECOS) through its educational and research activities aimed at improving the environment in the United States and providing a forum for state environmental policy makers.

The Small Arms Firing Range Team also wishes to recognize the following states’ support of team leadership and guidance preparation:

• New Jersey Department of Environmental Protection: Bob Mueller, former Team Co-Leader, and Ed Stevenson

• Washington Department of Environment: Dibakar (Dib) Goswami, Ph.D., Team Co-Leader

• Massachusetts Department of Environmental Protection: Elizabeth Callahan

• Massachusetts Environmental Management Commission: Mark Begley, Team Co-Leader,

• California EPA Department of Toxics Substance Control: John Christopher

• Florida Department of Environmental Protection: Jeff Lockwood

• South Carolina Department of Health and Environmental Control: Stacey French

• District of Columbia Department of Health: Richard Albright

• Colorado Department of Health and Environment: Susan Newton

The team also recognizes the exceptional contributions from Michael Warminsky, AMEC Earth and Environmental, Inc.; Keith Hoddinott, U.S. Army Center for Health Protection and Preventive Medicine; Michael Burkett and Scott Edwards, Metals Treatment Technologies; Jim Dawson and Terry Jennings, Concurrent Technologies Corporation; Chuck Harmon, AMEC Earth and Environmental, Inc.; Rick Patterson, National Shooting Sports Foundation; Bob Byrne, Wildlife Management Institute; Ioana Petrisor, DPRA, Inc.; Satish Kastury, WRS Infrastructure and Environment; Greg Butler, BEM Systems; and Bill Call, PMK Group. We also wish to thank Peter Strauss of PM Strauss & Associates for contributing his community stakeholder perspectives to this document and his never-ending contribution to ITRC. Thanks to Ed Guster and George Meyers, EPA Region 2, who offered an EPA regional and national overview during the guidance development. Other unnamed members also contributed valuable perspectives through their advice throughout the project. Special thanks to the Department of Defense and the Army Environmental Center’s Kimberly Watts and Bonnie Packer for the valuable contribution of military range information, technical research, and department-wide coordination. The Army Environmental Center added a distinct perspective to range management and improved the guidance in the process. Thanks also to Steve Hill, RegTech, Inc., for urging constant progress during development of the guidance and assisting wherever necessary.

Lastly, without the leadership, common sense, and coordination of Bob Mueller and Dib Goswami, Team Co-Leaders, and Mark Begley who stepped in as Team Co-Leader when Bob i

Mueller became ITRC Co-Chair, this guidance would not have been prepared. They spent many hours of their own time researching, reviewing drafts, and planning conference calls and meetings. They are the cohesive leadership of the team, and the substance of the guidance is much better due to their efforts.

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EXECUTIVE SUMMARY

Small arms ranges are important locations to provide safe places to learn and practice shooting skills for law enforcement, military and recreational shooters. Contaminants from projectiles, targets, or primers used at a range can potentially migrate in the environment. Depending on the depth of groundwater, climate, soil chemistry, or proximity to surface water at the range, contaminants can reach groundwater or surface waters. In some instances, projectiles and targets are discharged directly to wetlands or surface waters. Left unmanaged, contaminants at or from a range could pose a health risk to wildlife or people who are exposed to affected environmental media. Some range operators may be unaware of the potential for range activities to impact the environment and have not designed or operated the range in a protective manner. State and federal environmental agencies generally have no specific regulations overseeing the operation of ranges. These agencies can and do, however, enforce laws regulating releases of contaminants to the environment and the disposal of wastes. Some state and federal agencies have developed technical assistance programs and guidance to inform range owners and operators and community stakeholders of the design and management options for improved environmental operation of ranges.

This document addresses the minimization of potential exposure to metals, especially lead, associated with shooting ranges. It is not a general discussion of health effects stemming from exposures to lead, nor is it intended to be a manual on range safety. The reader is encouraged to access other sources of more detailed information on these subjects.

Many range operators are committed to being stewards of the environment. The growth of environmental awareness, loss of rural areas through continued land development, and mixed public attitudes toward firearms and ranges shape the context in which ranges operate. Practicing environmental stewardship provides an opportunity for operators to proactively manage their ranges and prepares them to respond to concerns that may arise from range neighbors, the community, or others. Voluntary implementation of science-based environmental stewardship encourages self-oversight rather than regulatory intervention with the range. Well-designed and -managed ranges should incur only manageable environmental issues during operation.

Environmental conditions at operating ranges need to be evaluated, however, to delineate any existing and potential risks to the environment. Upon identifying a problem, measures should be undertaken to correct, prevent, or minimize adverse environmental impacts.

This guidance, a follow-up to Characterization and Remediation of Soils at Closed Small Arms Firing Ranges (ITRC 2003a), is designed to assist range operators in developing, using, and monitoring environmental management plans at active outdoor small arms firing ranges. The central task in formulating an environmental management plan is the selection and implementation of effective and reliable pollution prevention and mitigation measures, otherwise referred to as “best management practices” (BMPs). This document—developed by a partnership among state and federal environmental representatives, U.S. Department of Defense (DoD), shooting sports industry, and stakeholders—focuses on providing range operators with the guidance they need to identify and undertake BMPs that are appropriate for and tailored to the site-specific environmental conditions at their ranges. It is a synthesis of several of the most used and tested guidance documents to date and builds upon this information by adding experiences from case studies.

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This guidance is organized according to the sequence of activities a range operator undertakes to develop and implement an environmental management plan. Beginning with the identification of range-specific environmental issues, options for BMPs provide the most reliable and effective techniques to address the particular issues identified by the range evaluation. Incorporating selected BMPs into an environmental management plan; implementing, assessing and modifying the plan, as necessary; and documenting its implementation should become a routine operation to provide an environmentally safe and secure range.

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TABLE OF CONTENTS

ACKNOWLEDGEMENTS............................................................................................................. i EXECUTIVE SUMMARY ........................................................................................................... iii

1. INTRODUCTION

1.1 Problem Statement

1.2 Environmental Stewardship Principles

1.3 Document Overview

2. POTENTIAL ENVIRONMENTAL ISSUES AT RANGES

2.1 Fate, Transport, and Exposure

2.2 Shot and Bullet Distribution

2.3 Shooting Off Property

2.4 Cartridges and Clay Targets and Litter

2.5 Shooting Sound

2.6 Dust

3. BEST MANAGEMENT PRACTICES

3.1 Identification of Best Management Practices

3.2 Alternative Shot Materials

3.3 Nonlead Bullets and Primers

3.4 Control of Lead Shot Dispersion

3.5 Bullet Containment

3.6 Metal Recovery Techniques for Berm Maintenance

3.7 Stabilization of Lead Shot and Bullets in Soil

3.8 Soil Washing (Physical and Gravity Separation)

3.9 Vegetative Control

3.10 Management Alternatives for Erosion

3.11 Targets, Casings, and Wads and Environmentally Friendly Targets

3.12 Controlling Shooting Sound

3.13 Newer and Emerging Technologies

4. ENVIRONMENTAL MANAGEMENT PLANNING

4.1 Site Characteristics

4.2 General Environmental Conditions

4.3 Selecting Best Management Practices

4.4 Management Plan Development

4.5 Environmental Management Plan Implementation

4.6 Monitoring Review and Evaluation

5. CASE STUDIES

5.1 Massachusetts Initiative Case Study

5.2 Florida Case Study—Best Management Practices for Environmental

Stewardship of Florida Shooting Ranges

5.3 Fort Rucker Case Study

5.4 Fort Jackson Case Study (ongoing U.S. Army Environmental Center project)

5.5 Naperville, Illinois Case Study

5.6 New York Police Department Outdoor Firing Range Lead Stabilization Case Study

6. BIBLIOGRAPHY

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LIST OF TABLES

Table 2-1. Contaminants potentially found at ranges Table 3-1. Summary of potential operational and engineering approaches for control of lead at outdoor ranges Table 4-1. Sources of information Table 4-2. Sample project evaluation comparison sheet Table 4-3. Template for an environmental management plan Table 4-4. Sample projects implementation schedule Table 5-1. Treatment results at New York Police Department outdoor firing range, Rodman’s Neck, Bronx, New York

LIST OF FIGURES

Figure 1-1. Typical sequence for establishing a range environmental management program Figure 2-1. Decision tree Figure 2-2 Conceptual model of groundwater flow and contaminant transport Figure 2-3. Example of berm erosion Figure 2-4. Military rifle range Figure 2-5. Automated field-fire range Figure 2-6. Automated record-fire range Figure 2-7. Combat pistol qualification course Figure 2-8. Theoretical shot fall zone and area of maximum shot fall at trap fields Figure 2-9. Theoretical shot fall zone and area of maximum shot fall at skeet fields Figure 2-10. A sporting clays course configuration with six shooting stations and multiple shot fall zones Figure 2-11. Layout for a sporting clays course with a single shot fall zone Figure 2-12. Flight paths of different materials resulting from clay target shooting Figure 3-1. Range siting problems identified at some trap and skeet ranges Figure 3-2. Range reorientation to reduce shot fall zone Figure 3-3. A shot curtain at a trap range Figure 3-4. A shot curtain protecting a water body Figure 3-5. Design of shooting range in Garlstorf, near Hamburg, Germany Figure 3-6. Conceptual berm system Figure 3-7. Fort Rucker berm and backstop Figure 3-8. Diagram of a bullet trap Figure 3-9. Examples of backstop berm and runoff trenching designed to collect bullets and lead runoff Figure 3-10. Side view of bullet traps and auger removal system for deceleration chamber at Kirtland Air Force Base Figure 3-11. Test simulator system Figure 3-12. A lead recovery demonstration at a central Massachusetts range Figure 5-1. Example of a range overlay map Figure 5-2. Gray surface of range indicating location of lead shot pellets vi

Figure 5-3. Environmentally reengineered berm Figure 5-4. Water and sediments moving into, through, and out of detention pond Figure 5-5. Off-range sediment transport in March 1997 Figure 5-6. Fort Jackson berm prior to modification and after amendment and revegetation

APPENDICES

APPENDIX A. Acronyms APPENDIX B. Glossary APPENDIX C. Comprehensive Template for an Environmental Management Plan APPENDIX D. Response to Comments APPENDIX E. ITRC Contacts, Fact Sheet, and Product List vii

1. INTRODUCTION

Sportsmen and -women, the military, and government agencies share a common goal of a clean and healthy environment. These groups also share a commitment to sound, science-based environmental management of small arms firing ranges (hereafter referred to as “ranges”) to ensure the achievement of this goal. Successful range operators—be they recreational, military, or law enforcement—serve as good stewards of the environment.

Their efforts result in the preservation of open space and the protection of wildlife and other natural resources encompassed by and associated with the lands they manage.

Small arms firing ranges are the focus of this document. The terms “range” and “ranges” used herein refer specifically to small arms firing ranges.

The growth of environmental awareness, loss of rural areas through continued land development, and mixed public attitudes toward firearms and ranges provide a context in which ranges operate.

Many already conduct their activities knowing that range operations could cause environmental problems if not adequately managed. Practicing environmental stewardship provides an opportunity for operators to proactively manage their ranges and prepares them to respond to concerns that may arise from range neighbors, the community, or others. Voluntary implementation of science-based environmental stewardship encourages self-oversight rather than regulatory intervention with the range. Range operators—whether military, recreational or law enforcement—should recognize that potential environmental issues, left unattended, could be magnified beyond the real or initial environmental impacts. Environmental issues are manageable as a function of site conditions, designs, and/or operating procedures. Environmental conditions at operating ranges need to be evaluated, however, to delineate any existing and potential risks to the environment. Upon identifying a problem, measures should be undertaken to correct, prevent, or minimize adverse environmental impacts.

Small arms firing ranges are those ranges accepting .50-caliber or smaller nonexploding ammunition. This document does not specifically cover tracer or incendiary ammunition. The central task in formulating an environmental management plan is the selection and implementation of effective and reliable pollution prevention and mitigation measures, otherwise referred to as “best management practices” (BMPs). This document focuses on providing range operators with the guidance they need to identify and undertake BMPs that are appropriate for and tailored to the site-specific environmental conditions at their ranges.

This guidance is a follow-up to Characterization and Remediation of Soils at Closed Small Arms Firing Ranges (SMART-1, ITRC 2003a). That guidance document, addressing the cleanup of closed ranges (i.e., the remediation of a former range so that the location may be suitable for some other future use), includes an easy-to-follow decision process for determining the best remedial alternatives for lead and lead-contaminated soils at closed ranges.

This guidance is designed to assist range operators in developing, using, and monitoring environmental management plans at their active outdoor small arms firing ranges.

While this document and SMART-1 deal with different topics, there is an obvious and important connection between them—to the extent that operators of active ranges prevent or minimize the impact of activities on the environment through the use of BMPs, they reduce the scope, magnitude, complexity, and cost of future cleanup if the range closes.

ITRC – Environmental Management at Operating Outdoor Small Arms Firing Ranges February 2005

This document was developed by a partnership among state and federal environmental representatives, U.S. Department of Defense (DoD), industry, and stakeholders. It is a synthesis of several of the most used and tested guidance documents to date and builds upon this information by adding experiences from case studies. The case studies highlight environmental management plans implemented at public and private facilities and state and federal technical assistance programs that help ranges operate their facilities in an environmentally protective manner.

Other existing guidance documents contain valuable information on environmental management of active ranges, but none bring together the broad state and stakeholder acceptance and the mix of skills and experience used in preparation of this ITRC guidance. ITRC team members, which include some of the most active and informed of the small arms shooting and environmental community, provide a valuable resource in the compilation of information for this guidance manual (see Appendix E).

Primary sources of information for this guidance include the following:

Association of European Manufacturers of Sporting Ammunition. 2002. Shooting Ranges and the Environment: A Handbook for European Range Managers.

Department of the Air Force, Headquarters Air Force Civil Engineer Support Agency. 2002.

“Small Arms Range Design,” Engineering Technical Letter (ETL) 02-11 (November).

Tyndall Air Force Base, Fla.

Florida Department of Environmental Protection Hazardous Waste Compliance Assistance

Program. 2003. Best Management Practices for Environmental Stewardship of Florida Shooting Ranges. Available on the Internet at http://www.dep.state.fl.us/waste/categories/hazardous/pages/lead.htm.

Indian Head Division, Naval Surface Warfare Center. 1998. Outdoor Small Arms Ranges:

Management Practices Guidebook. OES Document 01-98. Indian Head, Md.

Massachusetts Department of Environmental Protection. 2001. “Lead Shot in the Environment.”

Available on the Internet at http://www.state.ma.us/dep/files/pbshot/working.htm.

National Rifle Association of America. 1999. The Range Sourcebook: A Guide for Planning and

Construction.

National Shooting Sports Foundation. 1997. Environmental Aspects of Construction and

Management of Outdoor Shooting Ranges. Available on the Internet at www.rangeinfo.org.

U.S. Army Environmental Center. 1997. “The Range Evaluation Software Tool (REST)” and

Army Sampling and Analysis Plan for Small Arms Ranges (SFIM-AEC-ET-CR-97037) Available on the Internet at http://aec.army.mil/usaec/technology/rangexxi03g.html.

http://www.dep.state.fl.us/waste/categories/hazardous/pages/lead.htm http://www.state.ma.us/dep/files/pbshot/working.htm http://www.rangeinfo.org/ http://aec.army.mil/usaec/technology/rangexxi03g.html

U.S. Environmental Protection Agency. 2003. Best Management Practices for Lead at Outdoor Shooting Ranges. EPA-902-B-01-001, Revised. Available in the Internet at http://www.epa.gov/region2/waste/leadshot/.

1.1 Problem Statement

There are thousands of active outdoor small arms firing ranges in the United States, including an estimated 9,000 nonmilitary ranges (EPA 2001) and more than 3,000 small arms ranges operated by DoD. Lead and other metals associated with projectiles are of potential concern at these outdoor ranges (ITRC 2003a, Section 1). Lead is present at ranges in the form of spent bullets and shot. Lead can contaminate range soil as the result of projectile fragmentation and leaching due to weathering. Other metals commonly associated with range activities include copper, zinc, tungsten, arsenic, antimony, and nickel. Lead is the metal most often identified as a concern because lead is the principal component of the projectiles; however, other metals may be present and may need to be addressed appropriately.

In addition to affecting soil, contaminants from projectiles, targets, or primers used at a range can potentially migrate in the environment. Polycyclic aromatic hydrocarbons (PAHs) are present in clay targets; however, studies have shown that the targets did not exhibit the characteristics of toxicity as determined by the EP toxicity test. Results from new and aged targets suggest that PAHs are tightly bound in the petroleum pitch and limestone matrix and are unlikely to be readily available in the environment (Baer et al. 1995). Depending on the depth of groundwater, climate, soil chemistry, or proximity to surface water at the range, contaminants can reach groundwater or surface waters. In some instances, projectiles and targets are discharged directly to wetlands or surface waters. Left unmanaged, contaminants at or from a range could pose a health risk to wildlife or people who are exposed to affected environmental media.

Some range operators may be unaware of the potential for range activities to affect the environment and have not designed or operated the range in a protective manner. State and federal environmental agencies generally have no specific regulations overseeing the operation of ranges. These agencies can and do, however, enforce laws regulating releases of contaminants to the environment and the disposal of wastes. For example, according to the U.S. Environmental Protection Agency (EPA) Region 2 manual, “Lead is not considered a hazardous waste subject to RCRA at the time it is discharged from a firearm because it is used for its intended purpose. As such, shooting lead shot (or bullets) may not be regulated nor is a RCRA permit required to operate a shooting range.” Some state and federal agencies have developed technical assistance programs and guidance to inform range owners and operators and community stakeholders of the design and management options for improved environmental operation of ranges.

Many outdoor ranges are operated in conjunction with indoor ranges. Indoor ranges are not addressed by this guidance, but indoor range operators should be actively managing environmental issues at their facilities. These operators should be aware that indoor firing ranges that vent air to the outdoors without a filtering system have the potential to deposit particulate lead below the air system outdoor exhaust vent. This is an outdoor environmental issue created by an indoor range.

http://www.epa.gov/region2/waste/leadshot/

1.2 Environmental Stewardship Principles

In developing this guidance, the Small Arms Firing Range Team adopted the following established principles of environmental stewardship as they relate to active outdoor ranges:

• Minimize potential impact on human health and the environment.

• Protect groundwater, surface water, wetlands, and wildlife.

• Prevent subsurface soil contamination and erosion.

• Manage sound.

These principles served as the framework used by the team in selecting the BMPs and outlining the process for developing environmental management plans discussed in this guidance. These same principles provide range operators with a framework for successful environmental management.

That is, range design plans and day-to-day operations should be evaluated in terms of consistency with these principles.

1.3 Document Overview

This guidance is organized sequentially in the order of activities range operators should undertake in developing and implementing an environmental management plan. Figure 1-1 depicts the topics covered in each chapter of the document that follows.

Chapter 2 deals with identification of the range-specific environmental issues.

Chapter 3 discusses which BMPs are most reliable and effective in addressing the particular issues identified by the range evaluation. Chapter 4 provides guidance on incorporating the selected BMPs into an environmental management plan for the facility; implementing, assessing and modifying the plan, as necessary; and documenting its implementation.

Figure 1-1. Typical sequence for establishing a range environmental management program.

Monitor environmental conditions and revise plan as needed

Chapter 4

Understand your range environment Chapter 2

Prepare an environmental management plan and implement

Chapter 4

Select best management practices Chapter 3

Document implementation of plan activities

Chapter 4

Delineate environmental issues Chapter 2

Establish and accept environmental stewardship principles

Chapter 1

2. POTENTIAL ENVIRONMENTAL ISSUES AT RANGES

The principal metal causing environmental contamination at most ranges is lead. Other contaminants can occur (see Table 2-1), but exposure to lead is used in this section to illustrate how humans, animals, and environmental resources can be affected by contamination from ranges. Many lead management activities are effective for other potential metal contaminants;

however, much of the testing and research focuses on lead. If other constituents of concern have been identified at a range, management activities need to account for the fate and transport of those metals even though they may not have been studied in a shooting range setting as extensively as lead. Appropriate response action(s) at an operating range should be based on a range assessment, including potential fate, transport, and impact of lead and/or other constituents in the environment.

Table 2-1. Contaminants potentially found at ranges (modified from ITRC 2003a)

Constituent Source (Comment) Lead Primary constituent of most projectiles Lead styphnate/ lead azide

Primary constituent of most primers

Antimony Alloy used as a hardening agent (Increases hardness) Antimony sulfide

From 5% to 30% is used in most primer compounds

Arsenic Lead shot constituent (Used in the production of small shot since it increases the surface tension of dropped lead, thereby improving lead shot roundness)

Copper • Sometimes a primary alloy in center-fire ammunition and some small-caliber rifle bullets; also used in frangible pistol ammunition

• Jacket alloy metal (Increases hardness) Bismuth Bismuth is used for lead shot replacement Tin Primary metal for center-fire ammunition and shot (Increases hardness) Zinc Jacket alloy metal Iron Iron tips on penetrator rounds and steel shot (Has been used successfully to remediate high levels of lead and arsenic in some soils) Tungsten Alternative projectile material to lead (Recent research indicates there may be some adverse environmental and human health concerns regarding tungsten)

Nickel Coating to improve shot performance Cobalt and chromium

Alloys in some ammunition rounds

Polycyclic aromatic hydrocarbons (PAHs)

Clay targets (Concentration of PAHs in clay targets varies from one manufacturer to the next but may be as high as 1000 mg/kg [Baer et al.

1995])

Moving through a typical set of questions outlined below or using a program like REST (Range Evaluation Software Tool, USAEC 1997a) can assist range managers in making qualitative assessments. Figure 2-1 provides a decision tree that enables a range operator to evaluate the range appropriately and, based on the outcome, to select the appropriate technique(s) that can be applied to prevent potential surface water, groundwater, or air transport. The bracketed numbers in the decision tree refer to the section in this document discussing that topic.

Figure 2-1. Decision tree.

Later (Table 4.2), this guidance also provides a “sample project evaluation comparison sheet,” offering a possible scoring mechanism for the range manager to help determine which range response actions or BMPs best suit the overall need. The actions/practices selected should address the potential consequence of an identified issue, site-specific condition, range design feature, or maintenance procedure that most effects lead risk on the range or lead transport.

These actions may involve pollution prevention, prevention of lead migration, or lead removal.

The following questions help range operators collect and compile information necessary to adequately understand the characteristics of shot and bullet distribution and the potential for lead and other heavy-metal transport. Note that the following questions are only guidelines and may not, in all circumstances, apply or be the full complement of all necessary questions.

• Where are the property boundaries, and do any rounds or shot fall beyond them?

• How is the metal distributed over the range property?

• Is the metal in areas of soil disturbed by bullet impact (e.g., bullet pockets)? Pulverized soil with high concentrations of lead and lacking vegetative cover is most susceptible to surface water transport.

• Can and have I calculated the mass of shot or bullets fired at each range on a regular basis?

• Are there hot spots (areas of concentrated lead)?

• Does wind or water erosion occur near these concentrated areas? If yes, then surface water and/or wind transport may be an issue.

• How deep is groundwater below the concentrated areas? If it is shallow (<10 feet, depending on soil type, pH, and mass of lead), groundwater transport may be an issue (see Figure 2-2).

• Are site soils sandy and highly permeable, or do the soils contain significant quantities of clay or organic matter? Sandy soils may allow vertical migration of dissolved lead, while clay or organic rich soils may adsorb the lead. Adsorbed lead may still be transported off site by surface water and wind erosion.

Figure 2-2. Conceptual model of groundwater flow and contaminant transport (from Soeder and Miller 2003).

• Does slope of the ground surface encourage surface water runoff? Rills and gullies are an indication of erosion.

• Does the pH of the soil impact areas fall within the low solubility values (~6.0–9.0, ITRC 2003a)? If the pH is outside this range, there is a higher potential for lead migration in surface water or groundwater.

• Is the impact area in a surface water body or wetland?

• How far is the impact area from flowing or nonflowing streambeds?

Figure 2-1 lists the surface and subsurface, climate, operational, physical, and chemical characteristics of a range that operators should consider when initially characterizing potential environmental impacts the range operations might cause. The diagram further lists the possible techniques, technologies, and equipment a range manager can consider to prevent the potential issue from actually deteriorating the environment or posing a risk to humans or wildlife.

To confirm the presence or absence of a transport pathway (see Section 2.1.2), you may choose to conduct limited investigative field sampling. Be aware that such sampling and analytical results may be subject to state notification or reporting requirements. Guidance on sampling and analytical procedure for soil characteristics at ranges can be found in Characterizing and Remediating Soils at Closed Small Arms Firing Ranges (ITRC 2003a). The user is cautioned that confirmatory sampling for understanding the environmental characteristics of an operating range is unlikely to involve the scale or detail required when characterizing a closed site in preparation for remediation; however, the sample collection procedures and analytical techniques may be the same in both cases.

2.1 Fate, Transport, and Exposure

Lead contamination associated with operating ranges is normally limited to surface and near-surface soil. However, lead can be dispersed into the environment at ranges in one or more of the following ways:

• Lead oxidizes when exposed to moist air and can dissolve when exposed to moist soil or acidic water.

• Lead bullets or shot, bullet particles, or dissolved lead can be moved by storm water runoff

(erosion).

• Lead particles or lead adsorbed to silt and clay can move by siltation in strong winds where little vegetation exists to prevent its movement.

• Dissolved lead can migrate through soils to groundwater.

• Plants can uptake lead and introduce it into the food chain.

• Wildlife may ingest lead shot, particles, or lead-contaminated soil.

2.1.1 Fate

When exposed to moist air and/or water, lead oxidizes and forms a variety of weathering products that can include lead oxides, sulfates, carbonates, and organic complexes. The solubility of lead in water is highly dependent on solution pH, increasing the dissolved lead concentration as water pH decreases. While increasing the pH of soil or water generally results in a decrease in soluble metal concentration, these conditions can also result in an increase in soluble metalloids such as arsenic and antimony. Increased contact time between lead and acidic water generally results in an increased amount of dissolved lead in solution and potentially in storm water runoff and groundwater. In contrast, raising the water pH causes dissolved lead to precipitate out of solution, particularly at pH values above 7.5 and below 9.5. Factors such as high clay and organic carbon can further retard the transport of lead in the dissolved phase through adsorptive and absorptive processes, inhibiting lead’s mobility to both surface water and groundwater. High organic carbon content can also induce reducing conditions favorable to the formation of lead sulfides, which are relatively insoluble and immobile as long as these reducing soil conditions are maintained. Rainfall also increases the likelihood that lead will be mobilized in the environment, either through dissolution or erosive sediment transport. The primary factors that most influence the dissolution of lead in water are discussed further below.

Annual Precipitation Rate

The higher the annual precipitation rate, the faster lead weathers and the greater the volume of lead-containing water percolating through the soil (vertically or laterally) to surface and or groundwater. Periodic ponding from precipitation or irrigation can increase the amount of lead going into solution, particularly in areas where water pH is low (acidic). Also, during prolonged rains, the contact time between water and lead is increased. Acid rain and/or acidic soils may influence the dissolution of lead.

Soil Cover

Organic material and clay adsorb lead and remove it from water. Organic carbon in anoxic (oxygen-deficient) conditions may reduce oxidized forms of lead into lead sulfides, which remain relatively immobile in anoxic environments. Therefore, thicker organic-rich soil covers (e.g., leaf and peat cover) generally result in lower concentrations of lead in groundwater or pore moisture. Studies have shown that organic material has a strong ability to extract lead from water (EPA 2003).

Figure 2-3. Example of berm erosion.

2.1.2 Transport

Erosion is the movement and loss of surface layers of soil mainly by water but also by wind and other factors (Figure 2-3).

Soil type and structure and slope of ground and its vegetation cover are important determinants of soil erosion. Topsoil can be lost and deep runoff channels created.

Water quality and aquatic habitats can be degraded, and lead can be transported off range. Construction and poorly timed range management activities may increase the risk of such erosion.

Wind

Wind erosion is most likely in arid environments or during extended dry periods in other environments where the soil surface is friable and loose. A cover of suitable vegetation may be the most effective preventive measure. Further protection could be achieved by natural or artificial windbreaks, both within the range and on its perimeter, positioned according to the prevailing or most problematic winds.

In susceptible areas concentrated human use of parts of a range can encourage erosion. Access roads, unsurfaced parking lots, and walkways may need to be vegetated or otherwise protected with gravel, stone chippings, or chipped bark to reduce erosion risks. Similarly, range management and construction work involving removal of vegetation or other protective coverings can lead to increased erosion and generation of soil dust that can be blown off site if not carefully conducted or preventive measures applied.

Precipitation

Lead shot, lead bullets, projectile fragments, or dissolved metals can be moved by storm water runoff.

Water can transport metals in both the metallic form (bullets, shot, fragments, etc.) and through sediment transport where lead (and other metals) has been adsorbed and through percolation of soil pore water. Water’s physical ability to transport metal is influenced by the velocity of water and by the density and size of the particle being transported. Water’s capacity to carry small particles is proportional to the water’s velocity, while sediment-laden water can carry even larger particles than clear water.

The factors that most influence velocity of runoff are as follows (EPA 2003):

• Rainfall intensity—The greater the volume of rainfall during a short period of time, the faster the velocity of surface runoff created to carry the rainfall off site. This factor may also increase the volume of pore water within the soil horizon.

• Topographic slope—Generally, the steeper the slope, the faster the storm water runoff.

• Soil type—More rainfall will soak into sandy soils than into clay soils. Hence, for a given rainfall intensity, the volume of runoff will be greater from areas underlain by clays or other low-permeability soils than from permeable, sandy soil.

• Stream width—Velocity tends to decrease as stream width increases. Merging streams, eddy currents, and curves in streams are other factors that may reduce the velocity.

• Vegetative cover—Vegetation on slopes and drainage ways physically stabilizes soil and reduces sheet flow velocities, preventing erosion. Grass and other vegetation reduce runoff velocity and act as a filter to remove suspended solids from the water. Vegetative growth requires proper soil quality. Contact your county extension service for advice and assistance.

• Manmade structures—Structures such as dams and dikes reduce water’s velocity and proportionally reduce the size and weight of the lead particles the water can carry. Since lead particles are heavy compared to the other suspended particles of similar size, they are more likely to be deposited under reduced velocity of the storm water runoff.

Runoff flowing down backstops and berms or over ranges and shot fall zones loosens and carries soil particles. Eroded soils can degrade aquatic environments, including streams, ponds, estuaries, and wetlands both on property owned or controlled by the range and off site. Soils eroded from ranges may transport dissolved or particulate lead, increasing the potential for environmental impacts. Generally, the shorter the distance from the soils containing lead fragments to the range boundary or closest stream bed, the more likely it is that the lead fragments in suspension will be transported off range.

In general, the greater the amount of impervious land surface area, the greater the amount of runoff generated, and the higher the erosion potential. Vegetation tends to decrease the erosion potential by holding soils in place and reducing runoff velocity. Gently sloping ranges are less susceptible to erosion from runoff than are more steeply sloped sites. Finer sands and silts are more easily eroded than coarse sands and gravels are. Range sites should be examined for erosion. Regular inspections of berms and bullet impact areas and shot fall zones are advised to identify areas requiring erosion protection or restoration efforts. Information on the amount and intensity of rainfall can be obtained from the National Climactic Data Center of the National Weather Service (http://lwf.ncdc.noaa.gov/oa/ncdc.html). Information on soil texture and soil structure can be obtained from the Natural Resources Conservation Service (NRCS) of the U.S.

Department of Agriculture (USDA, http://www.fl.nrcs.usda.gov/soils.htm). The slope of the ground, vegetative cover, and amount of impervious area can be easily observed or measured at the site by the range manager.

Rainwater can move dissolved lead downward toward the groundwater. Groundwater can discharge and become part of the surface water flow (see Figure 2-2). If the water flowing underground passes through rocks containing calcium, magnesium, iron, or other minerals more soluble than lead or through minerals that raise the pH of the water, then the lead in solution may precipitate or be replaced (removed) from solution. However, if the sediment matrix is a clean silica sand and gravel, fractured granite, or similar type material, then dissolved lead can move longer distances. Factors most likely to affect the amount of lead carried by the groundwater in solution are as follows:

• Annual precipitation—Generally, high annual precipitation results in extended contact between metallic lead and rain water. This can increase the potential for oxidation and/or dissolution (corrosion and leaching) of lead.

• Soil types—Clays have a high ionic exchange capacity and more surface area to which metals such as lead can adsorb. Also, groundwater movement in clay is very slow, which increases the contact time for lead to absorb to the clay. Lower surface area and faster permeability of sandier soils lead to longer transport distance of dissolved lead. All of the basic calcium and related minerals generally will have been removed from the clean silica sand and gravel soils, so dissolved lead in groundwater in these type soils can move long distances (miles) relatively unchanged.

• Soil chemistry—Soils containing carbonates along the pathways through which the groundwater moves increase lead precipitation (removal) rate. Lead should move in solution only a short distance (a few feet) through sand composed of shell fragments but could move in solution long distances (miles) through clean quartz sand. Note that pH above 9.5 mobilizes lead as well (ITRC 2003a, Fig. 3-1).

• Depth to groundwater—The shorter the distance traveled, the greater the risk that the lead will migrate into the environment. Shallow depth to groundwater is indicative of potentially higher risk for mobilized lead to reach the groundwater.

http://lwf.ncdc.noaa.gov/oa/ncdc.html http://www.fl.nrcs.usda.gov/soils.htm

2.1.3 Human Health and Exposure

Exposure to lead can be a health risk to people at any age. At high concentrations lead exposure causing high blood lead levels can lead to convulsions, coma, and even death. At low concentrations, it is dangerous to infants and young children, damaging the developing brain and resulting in both learning and behavioral problems. EPA’s Best Management Practices for Lead at Outdoor Shooting Ranges (EPA 2003) describes the effects of exposure to lead on children and adults. At firing ranges, shooters, firearms instructors, and other range employees can be exposed to significant levels of lead dust and fumes. Protecting the health of range employees and shooters, while minimizing environmental contamination from lead exposures, is an important element in the safety plan for ranges. During shooting activities, lead is deposited at the firing line and the impact berm or drop zone. Lead at the firing line comes from the precipitation of lead compounds from muzzle vapors, from lead azide and lead stiphnate primers, and from abrasion between the shotgun pellets or the projectile and the gun barrel.

Berm or downrange deposits of lead come entirely from whole and fragmented projectiles.

This manual does not cover many of the potential serious health effects caused by exposures to lead and lead poisoning. The reader is encouraged to use other sources of more detailed information on those subjects.

Exposure to lead at outdoor shooting ranges can occur by two main pathways: inhalation and incidental ingestion. Inhalation of lead vapors and dust can occur during both shooting and maintenance activities. Direct inhalation of muzzle vapors can expose shooters and bystanders to lead at the firing line. Exposure to lead-containing dust particles can occur anywhere on the range but is mostly a concern for maintenance workers performing duties in the area of impact.

Incidental ingestion occurs from repeated hand-to-mouth actions. For example, lead particles generated by the discharge of a firearm can collect on the hands of a shooter, or lead-contaminated soil or dust can be picked up during maintenance activities. These particles can be ingested if shooters eat or smoke prior to washing their hands after shooting. This pathway usually generates the majority of lead exposures.

Range operators are required to protect workers from overexposure by following the recommendations and requirements, where applicable, of the Occupational Safety and Health Administration (OSHA), which is charged to protect employee health and safety in the workplace. OSHA has a comprehensive lead regulation, 29 Code of Federal Regulations (CFR) 1910.1025. This standard defines the legal responsibilities to limit employee exposure to lead, provide protective equipment and hygiene facilities, maintain a clean workplace, and provide employees with safety training and medical care. The lead standard also establishes a limit on the amount of lead that can be in the air workers breathe.