1. Investigation and Remediation of a Small Arms Firing Range JP Messier U.S. Coast Guard Civil Engineering Unit - Cleveland

2. Presentation Overview  USCG Environmental Organization  Regulatory Framework  USCG Firing Ranges  Site Characterization  Remediation  O&M and Upgrades  Compliance  Pollution Prevention  References

3. U.S. Coast Guard Environmental Organization  Headquarters (G-SEC-3)  Policy, Guidance, and Funding  Washington, D.C.  Maintenance and Logistics Commands (MLC)  Program Management  Atlantic – Norfolk, Virginia  Pacific – Alameda, California

4.  Facilities Design and Construction Center (FD&CC)  Major Construction and Design Services  Atlantic – Norfolk, Virginia  Pacific – Seattle, Washington  Civil Engineering Units (CEU)  Minor Construction, Design, Environmental, and Real Property Services  Cleveland  Honolulu  Juneau  Oakland  Miami  Providence

6. Regulatory Framework  CERCLA  EPCRA Section 313, TRI Form R  Release Notification and Corrective Actions  RCRA  Spent Ammunition, Bullet Fragments Recycling/Reclamation – 40 CFR 261  Reuse of Soils On Site  Military Munitions Rule – 40 CFR 266  Clean Water Act – NPDES (State Regulations)  Other State Programs for Corrective Action

7. USCG Small Arms Firing Ranges (SAFR)  Active  Seattle, Ketchikan, Kodiak, Honolulu, Galveston, New Orleans, Portsmouth, Cape Cod, Sandy Hook, Petaluma, Cape May, Academy, and Yorktown  Closed/Inactive  Ketchikan, Cape May, and Galveston

8. Site Characterization  Investigation  Site Evaluation  Fate Transport of Considerations Airborne Particulates Storm Water Runoff and Erosion Dissolved Lead in Groundwater/Surface Water  Range History and Layout Ammunition Usage Reclamation and Recycling Firing Positions and Bullet Deposition Future Land/Range Use

9. (Taken from ITRC training)

11.  Investigation - continued  Sampling Plan  Locations and Depths Vertical and Horizontal Extents Hot Spots and Background  Contaminants of Concerns Primarily Lead  Sampling Methodology Field Screening Using XRF and/or Electron Tube Analyzers USEPA Method 6200

12. ConstituentComment LeadPrimary constituent of a projectile Lead Styphnate/Lead AzidePrimer constituent AntimonyIncreases hardness. ArsenicPresent in lead. A small amount is necessary in the production of small shot since it increases the surface tension of dropped lead, thereby improving lead shot roundness. Copper Bullet Core AlloyIncreases hardness. TinIncreases hardness.

13. ConstituentComment CopperJacket alloy metal ZincJacket alloy metal IronIron tips on penetrator rounds PAHs (Polycyclic Aromatic Hydrocarbons) Concentration of PAHs in clay targets varies from one manufacturer to the next, but may be as high as 1,000mg/kg. Existing studies show that PAHs are bound within the limestone matrix of the target and are, therefore, not bioavailable.

15.  Sampling Plan - continued  Analytical Method (SW-846)  Process Sample with a Sieve  Soil, Groundwater, and Surface Water Total and Recoverable/Dissolved Metals Amount of Lead Present in the Environment Method 6010B – Analysis AA or ICP Filtered and Unfiltered for Liquid Samples pH Buffering Capacity Method 9045

16.  Sampling Plan - continued SEM:AVS Acid Volatile Sulfide and Simultaneously Extracted Metals Bioavailability and Binding Assessment Ratio <1 Potential for Metals to Bind Ratio >1 Insufficient Sulfides for Binding Toxicity Testing Sediment – In Situ or Ex Situ Expensive, Last Measure, Higher Certainty of Risks from Impacts

17.  Sampling Plan - continued Total Organic Carbon Solubility/Mobility Indicator Method 9060 Grain Size Distribution Soil Classification Data ASTM D-422 Investigative Derived Wastes (IDW) Waste Stream Classification Toxicity Characteristics Leaching Procedure (TCLP) – Method 3010/6010

18.  Ecological Risk Assessment  Tier I  Generic  Bulk Soil Sample Results  Comparison Against Published Standards  Tier II  Site Specific  Water Analytical and Additional Soils Data  Ecological Characterization  Exposure Pathway Identification  Estimate of Potential Risks

19.  Remedial Alternatives Evaluation  Evaluation Factors  Future Land Use Continued Range Operation Industrial Residential  Cleanup Goal Establishment  Budget and Timeframe

20.  Remedial Alternatives Evaluation - continued  Technology Selection  Disposal, Recycling, and Reuse  Physical Separation  Stabilization/Solidification  Soil Washing  Chemical Extraction  Phytoremediation/Phytoextraction  Lower Cleanup Goals = Higher Costs

21. Remediation  Disposal  Off-Range Disposal  Toxicity Characteristics Leaching Procedure (TCLP) Testing Warranted to Define Waste Stream Classification Hazardous or Non-Hazardous?  Haz Soil Can be Treated to Become Non-Haz Physical Separation Stabilization/Solidification Soil Washing Chemical Extraction

22.  Soil Reuse  No Testing Required: On-Site Use  Physical Separation of Bullet Fragments  Berm Reconstruction  Other Uses within Range Boundary Side/Wing Walls  Off-Site Use  Testing Required, Treatment Good Probability Render and Prove Non-Haz Show Totals Meet State Criterias  Fill Materials

23.  Soil Recycling  Chemically Treat/Utilize Soils in a Product  Rendered Inseparable by Physical Means  Meets Universal Treatment Standards  Road Base Emulsions/Materials

24.  Physical Separation  Use for On-Site Management or Off-Site Disposal  Dry Screening/Sifting  Bullet Fragment Removal/Recycling  Lower Limit of ¼ inch

25.  Stabilization/Solidification  Stabilization  Phosphates, Sulfates, Hydroxides, and Carbonates  Solidification  Portland Cement, Cement Kiln Dust  Use for On-Site Management  Lower/Control Solubility, Leaching to Ground/Surface Water, and Bioavailability/Risk  Use for Off-Site Disposal  Render Non-Hazardous to Lower Disposal Costs and Long Term Risk

27.  Stabilization/Solidification - continued  Pros:  Off-Site Disposal of Non-Haz Soils Reduces Tipping Fees  Risk Remains with Land Owner and Not Transferred to a Landfill for Potential Future Liabilities if Soils Remain On-Site

28.  Stabilization/Solidification - continued  Cons:  If Volume is Small, Costs to Perform Option do not Outweigh Savings from Non-Haz Landfill  No Reduction in Total Metal Concentrations  Material is Heavily Bulked  Land Use Controls Warranted if On-Site  RCRA Permit May be Needed by State

29.  Soil Washing  Mineral Processing Technique  Physical Sizing  Magnetic Separation  Soil Classification  Gravity Separation  Bench-Scale Study Required to Evaluate Process

30.  Soil Washing - continued  Use for On-Site Management  Reduce/Eliminate Leaching to GW/SW  Lower Risk to Human Health and the Environment  Use for Off-Site Disposal  Render Non-Hazardous to Lower Disposal Costs and Long Term Risk

31.  Soil Washing - continued  Pros:  Off-Site Disposal of Non-Haz Soils Reduces Tipping Fees  Risk Remains with Land Owner and Not Transferred to a Landfill for Potential Future Liabilities if Soils Remain On Site

32.  Soil Washing - continued  Cons:  If Volume is Small, Costs to Perform Option do not Outweigh Savings at Non-Haz Landfill  Residuals May Warrant Land Use Controls Warranted if On-Site  RCRA Permit May be Required by State

33. Coarse Soil Boulders Particulate Contaminants Washes Oversized Separates by Size Soil Fines Separates by Density Humates

34.  Chemical Extraction  Bench Scale Testing to Provide Effective System  pH, Buffering Capacity, Total Organic Carbon, Iron and Manganese Levels, Soil Type  Residuals of Metals and Leaching Solvent May Remain Bound in the Soils, Restricting Site Usage  Residual Acids Require Neutralization  Residual Solvents May Remain Toxic in Treated Soils

35.  Phytoremediation/Phytoextraction  Limited Uptake Potential  Specific Plants and Conditions Warranted  Constructed Wetlands  Indian Mustard Plant  Organic Base – Topsoil, Humates, Sandy Loam  Soil Ph Levels, Temperature  Lead Needed in a More Soluble Form for Uptake Amendment with Chelates

36.  O&M and Upgrades  Best Management Practices  Monitoring and Adjusting Soil pH Lime/Phosphate Addition  Control Runoff Ground/Surface Cover Grasses, Mulches, and Compost Filter Beds Containment Traps and Detention Ponds Dams and Dikes Ground Contouring

37.  O&M and Upgrades – continued  Bullet Trap Systems  Decelerator  Granular Rubber  Block Rubber  SACON – Shock Absorbing Concrete  Earthen Berm

38.  Compliance  EPCRA TRI Form-R Reporting  Release and/or Transfer of Toxic Chemicals  Lead – 100 pounds per year  Annual Submission; On/Before July 1 st EPA and State  EPA TRI-ME Software

39.  Pollution Prevention  Lead-Free (Green) Ammunition  Frangible Polymers, Nylon Disintegrates upon Contact Shorter Effective Range  Non Toxic Copper Jackets over Zinc/Tin Potential for Ricochet

40.  References  Interstate Technology Regulatory Council (ITRC), Small Arms Firing Ranges; http://www.itrcweb.org  National Association of Shooting Ranges; http://www.rangeinfo.org http://www.rangeinfo.org  Lead Prevention and Migration from a SAFR; http://aec.army.mil/usaec/technology/leadmigration.p df

41. Questions/Discussion