2 SHOOTING RANGES: Why do we Care? The lead deposited on a range is not hazardous waste . . .. . . as long as it stays on the range or goes to recycling.So, BMPs to help keep the lead where it belongs.
3 BMPs: What they areShooting range design considerations and operational procedures employed to better contain, concentrate and manage projectiles and other materials in a way that will minimize impacts to the environment;Strictly voluntary measures that can minimize range liability;Documented to be successful
4 BMPs: What they aren’t Not a regulatory program requirement; Not a guarantee that a site can close without some measure of cleanup;Not a shield for third party legal action against the range operation;Not uniform in application, and must be tailored to site specific conditions.
5 BMPs: What is being managed? Primarily lead in metallic form of bullets and shotgun pellets;Secondary metals antimony, arsenic, copper and zinc;Broken skeet targets- Polycyclic Aromatic Hydrocarbons (PAHs);Containment features such as soil berms.
6 Originally Published by FDEP Hazardous Waste Regulation Section November 2002Reprinted June 2003 and October 2004
7 Source Documents included: A Good Manual from EPA Region 2
8 Source Documents included: NSSF Facility Development Series
9 Source Documents included: Draft BMPs for Florida, Compiled by the U of F Florida Center for Solid and Hazardous Waste Management
10 Source Documents included: FSU/FAMU School of Engineering Florida DEP Tallahassee Community College Santa Rosa Sheriff’s Dept. Wildlife Management Institute Florida Fish and Wildlife Conservation Commission Florida Department of Corrections Sarasota County George Stone Center Orange County Sheriff’s Dept. Martin County Sheriff’s Dept.And a lot of input from dedicated Stakeholders --both government and private industry experts:
11 Source Documents included: Flagler Gun and Archery Club Hopping, Green and Sams George Stone Center U.S. Air Force Department of the Navy Massachusetts DEP National Sport Shooting Foundation Escambia County U.S. Environmental Protection Agency Clark Vargas (range doc) Florida Shooting Services, Inc.And a lot of input from dedicated Stakeholders --both government and private industry experts:
12 Florida’s BMPs are organized into a brief Introduction, then two chapters of specific range siting and management guidancefollowed by reference materials in 16 Appendices.
13 The Introduction presents plain English goals and expectations for ranges to establish proper management and environmental stewardshipand a five-step approach to lead management.
14 Chapter 2 discusses concerns with lead in the environment and details Step 1 of the lead management approach, to: Evaluate existing environmental conditions.
31 Step 3 Prevent Lead Migration Chapter 3 includes sub-chapters on:Step 3 Prevent Lead Migration
32 Lead Mobility Management techniques: pH adjustment Erosion control Range orientationProjectile containmentAlternative ammoRecovery/recyclingClay barrierChemical stabilizationStormwater run-off managementVegetative controls with soil amendmentsLead MobilityResources potentially impacted:Soil and sedimentSurface water qualityGroundwater qualityIngestion by wildlifeFrom the initial fragmented bullet pocket areas, the lead particles can do a variety of things, depending on the specific environment.In the extreme, if there was a vacuum (no atmosphere, no water), all the lead would stay exactly where it landed in whatever size it was upon impact.In the case where there is strong wind and little rain water, the speed of the wind, the presence or absence of vegetation and the size of the particles will determine the degree and nature of transport. Silt is the most susceptible to wind transport and in the absence of vegetation over the soil will become airborne in moderate winds. Since lead adheres/adsorbs readily to clay and silt, this mode of transport must be considered.Rain water can create one of two conditions: over land flow or infiltration. How much of each depends on the type of soil. Very permeable sandy soil will tend to have more infiltrating water (vertical to ground water) than silty or clay rich soils, where water can not penetrate very quickly. Less permeable soils have more overland flow in cases where the rate of rainfall (inches/hr) exceeds the rate of movement into and through the soils. Temperate climate ranges, that have very intense rainstorms and streams nearby to the small arms ranges, are most susceptible to lead particulate transport from the bullet pocket and into the streams.Lead rarely moves vertically to groundwater. Lead is sparingly soluble, even under fragmented and high surface area conditions that prevail on ranges, AND clays and organic material strongly adsorb the lead. The clay is negatively charged and the lead is positively charged and so they form a well suited match.In order to have dissolution and migration to groundwater, the lead must dissolve. Lead is more susceptible to dissolution under extremes of pH (very high or very low). Acidic soils in the pH 4-5 range meet this criteria. In addition, the soil would have to have very little clay and organic matter. Even soils with as little as 10 percent clay/organic material would not necessarily have a groundwater issue, unless the distance between the bullet pockets and the groundwater was very short (10 feet or less).Soil erosion and surface water lead mobility go hand in hand. Erosion effects the soil, the sediment, groundwater quality as well as impacts wildlife through exposure.Although discussed at length later, we can just mention here some of the simple ways to manage our ranges and prevent migration as well as wildlife ingestion.We can orient and place our ranges in locations that make transport less likely. The larger the catchment area, the more the flow downstream…thus, avoiding upstream input over ranges can be instrumental at avoiding transport. Side berms can help with this.We can maintain a simple vegetative cover by adding soil amendments and seed.We can manage soil pH.We can use our knowledge of sorption and make sure the soils beneath the bullet pocket have sufficient clay.And last but not least, we can manage the mass, to make it less available to transport. This can be as simple as some OSHA masks, shovels and sieve once a year or hiring a contractor to do the same.
33 Step 4 Periodically Remove the Lead Chapter 3 includes sub-chapters on:Step 4 Periodically Remove the Lead
34 Step 5 Document Activities and Keep Records Chapter 3 includes sub-chapters on:Step 5 Document Activities and Keep Records
37 Lead vs. Steel ShotUse required for waterfowl hunting over lakes, rivers and bays;Some research indicates that collocation with steel shot increases the corrosion rate lead shot thereby increasing lead mobility;Purely academic issue at present, but might be a concern for long term use of steel shot at ranges.
42 Section 3.9 points to Appendix M of highly recommended BMPs.
43 The remainder of the Florida BMP manual consists of reference Appendices:
44 Of 150 pages in the manual -- 2/3 are appendices The remainder of the Florida BMP manual consists of reference Appendices:Of 150 pages in the manual -- 2/3 are appendices
45 Splash page on the CDROM that links to the electronic BMP manual, checklists, forms and Internet resources.
46 Internet resources are posted on DEP’s Web site at:
47 They include Range Operator’s Checklists: and from EPA’s publicationBoth from FDEP’s Appendix C
48 Also included – a template for developing a Range’s Environmental Stewardship Plan from FDEP’s Appendix D:
49 And record keeping forms from FDEP’s Appendix D:
50 Range Environmental Management Goals Manage potential detrimental impacts posed by range activities to the environment, public health or public welfareRange environmental management objectivesKeep lead on-site and in its metallic formPrevent surface migration of lead and other hazardous constituentsPrevent projectiles from impacting wetlands or surface watersPrevent projectiles from landing off propertyReduce noise impacts to surrounding propertiesNo associated notes.
52 Cleanup at Shooting Ranges Location of ranges in Florida;Potential range contaminants;Operational areas likely to be contaminated;Select assessment sampling topics;Typical remedial technologies;Site cleanup closure.
54 Potential Contaminants ConstituentCommentLeadPrimary projectile constituentAntimonyIncreases hardnessArsenicUsed to increase roundness of small shotTinCopper and zincJacket alloy metalTungstenAmmunitionNickelCoating improves shot performance; an alloy in center fire ammoPAHs (PolycyclicAromatic Hydrocarbons)In limestone matrix of clay targets used at shotgun rangesArsenic – used In the production of small shot it increases the surface tension of dropped lead, thereby improving lead shot roundnessPAHs - Appears to be bound within the limestone matrix of the target. Concentration varies, but may be as high as 1000mg/kg. Manage as solid waste.
56 Knight’s Trail Park in Sarasota County, near Venice, FL It’s all about the lead, stupid!Knight’s Trail Park in Sarasota County, near Venice, FL
57 Lead FactsMetallic lead is subject to breakdown into bio-available and toxic form;Lead has no biological benefit;Not naturally elevated above risk based levels;High percent of ranges have years/decades of accumulation;Most ranges have not implemented lead recovery programs or BMPs that effectively manage lead.
58 Florida environmentEasily elevated due to low soil background Pb concentrationsRange = ppmGeometric mean = 5.4 ppmEnhance chemical reactionsHigh temperature and humidityAcid soil pHFavour chemical leachingHigh rainfallSandy soilShallow groundwater
59 Lead Mobility Metallic lead insoluble; Pb + O2 lead oxide, hydroxide, etc. (soluble)pH < 7– increased dissolution;Precipitation rate affected by presence of metals with greater solubility;Organic matter and clays may provide considerable sorption and arrest transport.
60 Arsenic Facts: Arsenic is a known human carcinogen; Associated with lead at outdoor ranges;Naturally present in Florida soils with concentrations that often exceed risk based corrective action criteria;More soluble and mobile than lead.
62 Characterization - Static Rifle and Handgun Range Primary Impact BermRange FloorSafety FanRefer to Figure 2-1 in the documentResidues from Muzzle DischargeDispersed Metal in Impact AreaConcentrated Metal in Impact AreaLateral Berm Not Shown
67 Concentrations of Pb and As (ppm) and pH in surface soil of 100-yard rifle/pistol range
68 Total Pb and As (ppm) in soils of a 200-yard rifle/pistol range
69 Concentrations of Pb & As (ppm) and pH in a soil profile of a 100-yard pistol range
70 Characterization - Shotgun Range Layout Firing LineArea with highest potential lead shot accumulationArea with potential target fragment accumulationRefer to Figure 2-1 in the documentDispersed targetDispersed metal shot in surface soilfragments in surface soil
71 Cartridges, Clay Targets, and Litter No associated notes.
72 Characterization - Skeet Range Layout Maximum Shot Fall Area375 ftRefer to Figure 2-1 in the document770 ft600 ft
74 Select Assessment Topics Soil screening for lead and arsenic using X-ray fluorescence (XRF);Soil sample sieving;TCLP and SPLP analysis;Clay target fragments / PAHs.
75 XRF ScreeningCan quickly define widespread areas of gross metals contamination;Equipment is rugged and portable;Cost effective for large scale assessment;Confirmation by laboratory analysis is needed for contamination boundaryInterference with collocated metals.
78 To sieve or not to sieve?Field samples are often sieved using a #10-mesh screen for extraneous matter;Laboratories often use #10 & #30-mesh screen sieves for soil during sample prep;Should sieve prepared XRF samples;End use of results should figure into extent of soil sample matrix separation.
79 TCLP/SPLP Tests Toxicity Characteristic Leaching Procedure (TCLP) Hazardous waste determination under conditions of municipal landfills under RCRATCLP regulatory limit for Pb = 5 mg/LSynthetic Precipitation Leaching Procedure (SPLP)Metal leachability ug/Lunder simulated rainfallSPLP regulatory limit for Pb = 15
80 Panama City Pace Lake City Ocala Indian River Lakeland Charlotte SampledIndian RiverLakelandCharlotteBroward
81 TCLP Pb (ppm) in surface soil of a 50-yard pistol range
82 TCLP Pb (ppm) in surface soil of a 200-yard rifle range
83 TCLP Pb (ppm) in surface soil of a sport clay range
87 Trap & Skeet Clay Targets Contain PAHs, non-toxic and not bio-available;Broken target fragments are solid waste;Impacts are limited to very near surface unless accumulation zone soil is reworked;Targets now available that don’t contain PAHs.
88 Remedial Options:Dig and Haul;Soil washing/Particle separation;Soil stabilization/solidification;Chemical extraction.
89 Regulatory Perspective Depending on conditions at the range and range siting, different federal and state environmental laws may applyClean Water ActWetlands Protection ActRCRANo associated notes.
90 RCRA RequirementsLead bullets/shot are not a solid or hazardous waste when discharged; no RCRA permit is required;Recycled lead bullets are considered a scrap metal and exempt from RCRA waste management;Processed reclamation soil is RCRA exempt if reused in backstop or shotfall areas at an active range;Soil removed from range site must be characterized;Lead left in media after a range closes is subject to a RCRA 7002/7003 cleanup order if it poses harm.
91 Site Cleanup ClosureClosure plan required at time of changing land use;BMP Manual has checklist of major items that need to be included;RCRA waste management concerns can be addressed early in remediation order;Florida Legislature mandated that “principals of risk-based corrective action” be utilized regarding cleanup at ranges.
92 Cleanup at Shooting Ranges When is a range subject to RBCA ?Usually when there is a range closure and change in land use;Third party complaint for offsite contamination;The range owner(s) may request assistance from the Department with site assessment.
93 Helpful DocumentsColorado Department of Public Health and Environment, Hazardous Materials and Waste Management Division, Corrective Action at Outdoor Shooting Ranges Guidance Document, Version One, January (http://www.cdphe.state.co.us/hm)Interstate Technology and Regulatory Cooperation Work Group, Technical/Regulatory Guidance: Characterization & Remediation of Soil at Closed Small Arms Firing Ranges. January 2003 (http://www.itrcweb.org/SMART-1.pdf)U.S. EPA, Office of Solid Waste and Emergency Response/ Brownfields Technology Support Center, Analysis of Considerations for Developing a Methods Applicability Study- Small Arms Firing Range, Bluffton, South Carolina. April 2003
94 Cleanup SquirrelThis isn’t about hunting, is it?