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Best Management Practices for Ranges
By Steven T.
Petrucelli, Environmental Engineer
(This article is reprinted from the Third National Shooting Range Symposium, 1996 with permission from International Association of Fish and Wildlife Agencies, Wildlife Management Institute and U.S. Fish and Wildlife Service.)
My name is Steve Petrucelli. I'm from the U.S. Environmental Protection Agency's Region II; my office is in New York City. The reason I, rather than a headquarters person, am talking to you is because Region II has taken the lead as a result of the Westchester County Sportsmen's Center case, which I'll talk about, and our involvement with area environmental groups that have really been pushing lead shot civil suits.
Those activities pushed our EPA region into the forefront among regulatory agencies, and we anticipate that our headquarters will follow suit. What I will talk about today is specific to Region II, but we hope that other EPA regions around the country will follow us.
I'm here to talk about best management practices for shooting ranges. We want to provide technical and compliance assistance, rather than have to inspect and enforce at many sites.
I want to say up-front that we're not looking to close ranges. That's not our goal by any means. There may be a few instances where we must use our legal authority to force cleanups, but we are not looking to close down ranges. In fact, we have no problem with more ranges opening up, as long as they follow guidelines to prevent lead contamination and migration.
Today I'd like to answer two questions: Why is lead a problem? What laws and regulations apply? After answering those questions, I'll focus on what ranges can and should be doing to prevent lead contamination. I'll follow up with comments on the future of shooting ranges from the EPA's perspective.
Lead and human health
Lead affects human health. You've probably read about lead's effects through your work on shooting ranges or through stories about lead paint issues. Lead poisoning creates brain and nervous system disorders. Lead is a neurotoxin, causing decreased attention span, anemia, kidney disfunction and immune system depression.
Please note that when you read EPA studies or you hear us cite numbers, we tend to be very conservative. We look at a child exposure model; in fact, most of what we did is based on biokinetic uptake studies for children. Children are smaller with smaller body mass and faster metabolism. This creates more of a problem where lead is concerned. Testing involves TCLP, Toxicity Characteristic Leaching Procedure, which is recognized to be a conservative test method.
On the environmental side, studies have been published on mortality in cattle, sheep and waterfowl. The United States' focus has been mostly on waterfowl. Sheep and cattle studies, I believe, were European, but nevertheless indicated a similar problem.
Deformity and mortality in fish and shellfish may not seem like a problem in the Midwest or any other inland areas. However a lot of ranges shoot into estuaries or other marine and aquatic environments, so it's a very real concern to EPA.
Lead tends to accumulate in two ways. Within an individual organism it tends to simply stay put in the system. Also, it can work its way up through the food chain.
Scope of lead problems and developing guidelines
I don't know where our estimate of 30,000 ranges nationwide comes from, but it is the number we have been using. The EPA also talks about millions of pounds per year of bullets used at ranges. It tells you something about how lead at shooting ranges compares with other industries; it's right in the ballpark of what we would normally handle. So don't feel like we're picking on lead shot. Lead shot and shooting ranges are within the range of the size of industry that we normally regulate.
The scope of the problem is that many ranges are decades old, and most ranges are outdoors. The result is that the material is weathering, and lead mobility in soil may be a problem, depending upon the pH of your soil. I deal with New York and New Jersey. Southern New Jersey tends to have high pH soils. We're not dealing with lead mobility concerns too heavily there because the soil's pH prevents lead mobility problems from occurring. However, since upstate New York and the Adirondacks gets a lot of acid rain from the Midwest factories or Great Lakes factories, it's a big concern because lead is much more mobile at a lower pH.
Lead shot regulation is sort of a mixed bag. The Second Circuit Court of Appeals decided that on a day-to-day basis you're not regulated. We're not regulating your shooting. We're not regulating your lead sitting on the berm for a while. However, when the material is considered discarded-when you close your range and don't clean up, or it's just been there so long that it's built up and posing an environmental or a public health threat-the court has said that we can use our statutory authorities to deal with it.
Similarly, under the National Pollutant Discharge Elimination System and State Pollutant Discharge Elimination System regulations, the court decided that lead is regulated. The case was in regards to the New York Athletic Club, which you'll hear about. I'm not going to deal too much with water issues, but it's important to note that this case ruling is something that will take effect.
In some ways, the New York Athletic Club case is good news for ranges, because it means that regulatory agencies will figure out what they want. We'll determine how we want you to deal with your sites. Then once you follow our guidelines, that will be it. You won't be hearing from us, as long as you follow these guidelines. Hopefully, the guidelines will be practical for you. We have not yet developed those guidelines, however, because the New York Athletic Club case was decided only a few months ago.
EPA's focus on lead shot is through the Hazardous Waste Compliance Program, which implements the Resource Conservation Recovery Act and amendments to that act. Our focus on the regulatory end has been via RCRA Section 7002 citizen suits, over which we have some review responsibilities. We have to review court decisions or citizen suit decisions.
More important to EPA is RCRA Section 7003 which addresses imminent and substantial endangerment. This is what we're trying to avoid needing to use too frequently. This is EPA's hammer to force ranges or other facilities to clean up. However, we would rather have ranges clean up and recycle lead voluntarily on a routine basis.
One case that we have dealt with is Westchester County Sportsmen's Center, which is being worked on by EA Engineering, Science, and Technology, Inc. It's a county-owned range that was subject to a citizen suit that was offset by a settlement with EPA under RCRA Section 7003.
Westchester County Sportsman's Center was sued by the Hudson River Fishermen's Association because streams that ran through the site led to the Hudson River. Significant quantities of lead were found in the soil and had been building up for years. There also was lead in the sediment and in the surface water. We believe there was a potential for lead migration. There were some definite and potential impacts to public health and wildlife that we had to review.
I mention the Westchester County Sportsmen's Center because even though they are cleaning their site under our statutory authority through a consent order the case has served as a model. I think the Westchester case has laid out the process that we ultimately want to follow. That process is as follows. In the short term, Westchester removed surface debris, targets and lead shot from their trap and skeet range. They delineated and evaluated contaminants to look at long-term issues.
In the longer term, Westchester County Sportsmen's Center must remediate the site, clean up the lead, and institute new handling procedures. The EPA reacts positively to that. As I said, this is the process that we're looking for ranges to follow.
A similar case involves the New York Police Department Firing Range in the Bronx, New York. The police had been shooting there for a long time, and large quantities of lead were in the soil. Remediation was under way; actually I think the remediation is now completed. A lot of lead was pulled from the berms. In the future the range will look at lead more frequently. That's what it will take to keep us out of the way in this case.
Our general approach is to encourage ranges to control risk due to lead shot and clay targets, encourage redesigning to minimize future problems, and promote reclamation and recycling. This is the number one, long-term issue for us.
We're looking to change things and to improve environmental protection for the next 20 years. We want to create a situation where you have guidelines to properly develop your ranges without creating an environmental or public health problem 20 years down the road.
You can look at traps for your range including: sand traps, steel traps, rubber traps, water ignitions traps. It may cost some money up front, but it may reduce your liability in the long term. Actually, if you look on the long-term planning schedule, it may be cost effective.
Sand traps are an excellent example of things you can do. Sand traps are simply sand contained in a high berm. You sift it when it's saturated, and you reuse your sand. The idea is to give you control over your berm so you don't have runoff into local streams, wetlands or other areas. Sand traps are a simple, easy-to-do solution. It's something you can do on your own, but you may want contractor support. I think sand traps could work well. It helps you collect your lead and keeps it in a concentrated area. You put your sand trap on a regular lead collection schedule, and you don't have a problem.
There is also a lot of information available about steel traps. Steel traps are useful systems in which you can collect lead for recycling using steel backstops or smash plates. The upside is that you collect the lead; the downside is that it costs money. If you have a steel trap, you have to be particularly careful because you can get some fragmentation creating lead dust. If you're hosing and sweeping your traps, bear in mind the concerns about lead dust. You need to be concerned about any and all health situations resulting from lead exposure.
Rubber traps are another real possibility. For example, Action Target is a symposium exhibitor, and I know they work with rubber traps. There are two types of rubber traps you can use. One type has layers of solid rubber designed to catch and hold the bullet. Another type uses thinner rubber layers to slow down the bullet so it will drop into a collection tray.
Rubber traps are promising because they collect lead easily with no dust or minimal dust. It requires maintenance such as regular changing of rubber layers. Keep in mind that if you use the thick rubber that collects lead and can't get the lead out of the rubber layers, you may create a hazardous waste situation. Rubber traps still can be cost-effective.
The last trap I'll talk about is a water munitions trap. This trap funnels lead into a deceleration chamber containing water. It almost eliminates your likelihood of fragmentation and airborne lead dust. It yields clean, whole shot. The shot won't be weathered; it's going to be solid material perfect for recycling. The downside is this trap system takes some effort and manpower to manage, and it may be expensive to install. If you have a big range, though, it may make some sense. You could get a little money back for your lead; hopefully you can make it a break-even proposition in the longterm.
Additional site modifications
Now I'll discuss more ideas on what you can do with your range.
Regarding site modifications, you can focus on filter beds. Filter beds are a combination of using sand traps with limestone dolomite or gypsum to raise the pH to prevent migration of lead. Filter beds can keep lead from becoming a lead salt and working its way into the groundwater. However, it's only a short-term solution.
Similarly, you can sift and rake. We have concerns regarding ranges with soil berms. The problem is that the soil berms often contain lead for a number of years. When the berm becomes saturated, range personnel may simply throw another 18 inches of dirt on top. After doing that for 30 years or so, you'll get a lot of lead in the berm. You've got a problem.
We'd like to see range owners focus on the long term by creating a regular collection schedule. Don't just let the lead sit in that soil; clean it out.
Surface covers also are another consideration. One of the problems with lead is that surface runoff. At some sites lead has worked its way into surface water or sediment. You need to control surface runoff. That doesn't mean you can funnel it down into a pipe to collect all your lead, because then you're subject to NPDES regulations. You may need a permit for that. You can look at Astroturf, vegetative cover at the base of your berm or regrading to prevent surface runoff.
Similarly, you can use settling ponds, basins or traps to catch lead shot. It can simplify your cleanup because you won't have lead scattered from runoff.
Ideas that EPA considers appropriate for managing lead at trap and skeet facilities include filter beds, sifting and raking, lime spreading, reducing your range size and relocation of ranges. Filter beds and drainage areas are ways to catch runoff from your trap and skeet ranges through a piping system or basin system.
Sifting and raking should be a routine activity for all trap and skeet ranges. You should collect your lead shot and clay targets as part of your long-term management.
A goal is to keep a pH of around 7, which is neutral, so you don't get lead migration into the groundwater. The exact amounts are going to depend on rainfall and soil type. Soil type must take pH into consideration. Your local agricultural extension service or soil conservation office can give you ideas on how much lime you might need to keep a pH of 7. Again, this is for your deposition area on trap or skeet ranges.
Reducing range size and range location also can be important. One of the big problems is that trap and skeet ranges tend to be large. We see them in wooded areas, which makes lead collection difficult. What we like to see for future trap and skeet ranges are flat, open fields. You must develop your range with lead collection foremost in your mind. You must set up your range in a way that you can easily collect lead.
When managing reclaimed lead, you should keep several things in mind. Avoid dust generation. That may involve wetting, if you're dealing with bullet traps. It may involve using HEPA (High Efficiency Particulate Air) filters if you're vacuuming. This is similar to working with indoor ranges where it's easy to generate dust.
EPA goals and considerations
The EPA's goals and primary considerations are as follows:
1. We want to see a one-time cleanup.
2. We want to see ranges redesigned to improve lead collection and runoff control. If you're developing a new range, we want to see those issues factored into development.
3. We'd like to see people use nontoxic shot materials, something that's not necessarily available right now. Obviously, steel shot must be used for waterfowl, but some ranges use steel shot for trap and skeet. Not many ranges use steel shot yet, because it can require some equipment changes.
"Sporting Clays" magazine's April issue contained an article about Bismuth shot. The author started out very negative on it; he wasn't expecting much. However, he found that Bismuth shot was similar to shooting with lead, and he was able to use his existing equipment. It's expensive right now because it's not being used on a large scale, but Bismuth is something to keep in mind. I don't foresee an outright ban on lead shot in the next few years. If you get started using Bismuth shot now, it may work out in the long term and reduce the regulatory burden.
4. Recycling is important, although only a handful of vendors take lead shot right now. Hopefully that will increase. We'd like to see people consider proper handling. It's been going very well on the indoor ranges. At outdoor ranges, you have to start thinking about how to handle lead shot. There are similar adverse health effects. Studies that have looked at covered ranges, for example, show that where you think you have adequate airflow there still may be health effects from airborne particulate lead.
Best management practices manual
The EPA is developing a best management practices manual. Currently, we are in the draft stage; it's about a 40-page manual discussing different types of traps, collection systems and handling procedures. The manual will focus on how environmental regulations affect everything you do.
The manual is geared towards range owners and range operators. The draft is based on a literature review and discussion with contractors and vendors. We've worked with a review team including National Rifle Association, Wildlife Management Institute, USDA Forest Service and U.S. Fish and Wildlife Service; hopefully, we'll also get several cleanup contractors to review this.
EPA doesn't want to release this manual until it's received approval from NRA, Wildlife Management Institute and a few others. This manual will be very useable and practical for you. So I just want you to know that we are working with these groups to make sure that what we do is feasible and viable. The manual should be available in September 1997.
The last thing I want to give you is contact information. You can reach me at 212-637-3129. If you have any questions about the manual or regulations, feel free to call me. I'm available from 9 a.m. to 6 p.m. Eastern time. Information also is available at EPA Region II's web page at http://www.epa.gov/region02/haz_wast.htm.
Question and Answer Session
WARREN B. REID, Affiliated Engineers SE, Inc.:
Do you see a problem if a range is constructed using your practices for the actual berm and collection area, but you have a safety fan? Are you going to pursue the strays that go with that rather than the primary bullet impact area?
STEVEN T. PETRUCELLI, Environmental Engineer, U.S. Environmental Protection Agency:
I would say it would be very site-dependent. Again, this is all very site-dependent because, of all the sites I've visited, I've only found a few that have been a problem.
When we look at a site, we look at it from border to border. All sides, top to bottom. If we thought it was going to pose an environmental threat or a public health threat, then, yes, we might do something about it. Generally if you designed your berms correctly, the strays will be so minimal that it shouldn't be a problem.
WILLIAM T. OWENS, White Flyer Targets:
Now we've lumped targets and lead shot together for trap and skeet. You've talked about toxicity of lead but not talked about targets. Would someone want to address that, please?
STEVEN T. PETRUCELLI:
There's very little information on that. Actually, the only study I've really seen was by Dupont. And what they found is targets weren't toxic for the organisms which they reviewed which were salt water organisms, not from fresh water. There are some concerns about petroleum aromatic hydrocarbons, PAHs. As far as leaching was concerned, they found that it wasn't toxic.
Dupont did find that when eaten whole or in parts, targets created health effects on some animals. Specifically they looked at pigs. I don't know how often you're going to have pigs eating clay targets. I guess it was a real case; it really did happen.
The only answer I can give you is that there are still a lot of questions. We're looking into whether PAHs are a problem, but we don't have any detailed information right now.
RICHARD K. PEDDICORD, EA Engineering, Science, and Technology, Inc.:
I would just mention that in this New York Athletic Club situation, the targets were defined as pollutants that required a National Pollutant Discharge Elimination System permit for their discharge into water. This is not a question of impact, but just a question of did they meet the definition of the terms.
GREGORY A. SCHIRF, Navy Ordnance Environment Support:
Federal EPA is coming out in December with a munitions rule, which, among other things, is going to address small arms ranges. Do you see any impact from that rule on the private sector?
STEVEN T. PETRUCELLI:
I'm not too familiar with the munitions rule, but from my understanding, it's not going to be too different from the kind of stuff we're reviewing. If you follow anything that's been going on in the EPA, I think it's all pretty consistent. You won't see too much effect on the private sector from that.
[The munitions rule was published in the "Federal Register" on February 12, 1997, and is effective on August 12, 1997. Copies of the rule can be obtained from EPA's RCRA Hotline at 1-800-424-9346. The rule also is available electronically from the World Wide Web at http://www.epagov/epaaswer, and then select the option for "Rules and Regulations."]
GREGORY A. SCHIRF:
Are other EPA regions also pursuing some process for range owners?
STEVEN T. PETRUCELLI:
Well, as far as the outreach goes, no. EPA Region I in Boston did a cleanup at a trap and skeet range under the Superfund. Region VIII had looked at some military ranges, but that was a few years ago. They never really got beyond a draft document stage. So I think they're all pretty much waiting to see what happens in Region II.
ROBERT A. MATHEWS, Ocala Gun Club:
I'd like to thank you, the EPA, for your cooperation in joining with the other organizations around here and your positive attitude. I did need to make a small observation.
We keep talking, "We don't know in the long term." In the long term, we've been shooting here for 100 years, most of us for more than 50 years. Now the targets are laying out there and we're not sure whether they are a hazard. I would say that some empirical data over 50 years ought to indicate the hazard is not quite as large as we're to believe.
Over and above that, I see that we're trying to develop a system to handle a problem that hasn't developed. As you originally said in the first part, presence doesn't indicate exposure. The military has had berms out there for years and years; they used to sell the lead and people came and mined it.
Now all of a sudden we have an attitude that you have to get it out of there, and you can't leave it. If the lead's lying on the ground, and it's not acidic, and if it doesn't put a higher level of lead in the water, why would we want to handle it at all?
STEVEN T. PETRUCELLI:
Well, you're right. I mean, for the most part we're looking at a very small number of sites relative to what's out there that can pose a problem. We're not looking for ranges to clean up necessarily if they're located on high pH soils with no receptors.
We're really trying to make sure people keep some control over it. We don't want places to be abandoned, which has been a problem with the military. We've seen some places that closed in the last 20 years; they forgot about the berms, and there have been some wildlife effects-some potential long-term health effects.
GENE PITTS, Manatee County Gun & Archery Club:
You discussed remediation. Can you enlighten us for a typical cost of remediation per acre per year especially on like the Westchester Club?
STEVEN T. PETRUCELLI:
I can't really give you costs. I recognize it can be a large cost the first time around, particularly if you have a large range. It also depends on a few things. When you do a cleanup, there are going to be sites where you can just scoop the lead, and that's all you need to do. We're talking backhoes plus some sampling, which can cost a few thousand dollars.
There may be sites where you need to do a little more work. The cost range is so wide. Admittedly, some cleanup is going to be very expensive. Prices are steadily coming down over the last few years as there are more vendors and more competition.
I see three cleanup contractors here today. Give them a year or two; they're going to be fighting so much, and that hopefully will drive down the cost. I can't give you specific numbers though.
Would you say it's $500,000 for a 10-year project?
STEVEN T. PETRUCELLI:
Yes, some of them. Some of the bigger ranges potentially could be that costly. Some of the trap and skeet ranges have been able to do decent cleanups for $50,000 to $100,000. That's a lot of money, but it may reduce your liability in a large way.
MARK NASTALLY, Stoney Point Sporting Clays, Inc.:
I noticed that you made reference to "Sporting Clays" magazine. What suggestions do you have for sporting clay ranges where you are shooting in the woods; you're constantly moving targets; you're constantly moving stations? If you're going to go to reclaim that lead, you're going to destroy the whole environment. Where do you justify that?
STEVEN T. PETRUCELLI:
That's something we don't know. A tradeoff with any kind of remediation is to make sure that you don't destroy the environment more by ripping things up for cleanup. For sporting clays remediation, some other things might work. We've looked at things like lime spreading in the short term to raise pH. Setting up filtration methods with sand and limestone may work for sporting clays.
We focus more on trap and skeet for now because they seem to be the much bigger activities. We're planning to look at sporting clays beginning next year. So I don't really know. It seems as if some of the things for trap and skeet might be viable, but we recognize that half of them won't work.