Investigation and Remediation
of a
Small Arms Firing Range
JP Messier
U.S. Coast Guard
Civil Engineering Unit - Cleveland
Presentation Overview
 USCG Environmental Organization
 Regulatory Framework
 USCG Firing Ranges
 Site Characterization
 Remediation
 O&M and Upgrades
 Compliance
 Pollution Prevention
 References
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


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
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
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
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
(Taken from ITRC training)

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
Constituent
Comment
Lead
Primary constituent of a projectile
Lead Styphnate/Lead Azide
Primer constituent
Antimony
Increases hardness.
Arsenic
Present 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 Alloy
Increases hardness.
Tin
Increases hardness.
Constituent
Comment
Copper
Jacket alloy metal
Zinc
Jacket alloy metal
Iron
Iron 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.
 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
 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
 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

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

Remedial Alternatives Evaluation
 Evaluation Factors
 Future Land Use
Continued Range Operation
Industrial
Residential
 Cleanup Goal Establishment
 Budget and Timeframe
 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
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

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

Soil Recycling
 Chemically Treat/Utilize Soils in a Product
 Rendered Inseparable by Physical Means
 Meets Universal Treatment Standards
 Road Base Emulsions/Materials

Physical Separation
 Use for On-Site Management or Off-Site Disposal
 Dry Screening/Sifting
 Bullet Fragment Removal/Recycling
 Lower Limit of ¼ inch

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
10,000,000
SO
4
OH
CO 3
PO 4
1,000
O4
P
H
Lead Concentration, mg/L
100,000
10
5 mg/L
0.75 mg/L
0.1
0.001
0.00001
0
2
4
6
8
pH
10
12
14

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

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

Soil Washing
 Mineral Processing Technique
 Physical Sizing
 Magnetic Separation
 Soil Classification
 Gravity Separation
 Bench-Scale Study Required to Evaluate Process

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

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

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
Washes Oversized
Coarse Soil
Boulders
Separates by Size
Soil Fines
Separates by Density
Particulate
Contaminants
Humates

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

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
 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

O&M and Upgrades – continued
 Bullet Trap Systems
 Decelerator
 Granular Rubber
 Block Rubber
 SACON – Shock Absorbing Concrete
 Earthen Berm

Compliance
 EPCRA TRI Form-R Reporting
 Release and/or Transfer of Toxic Chemicals
 Lead – 100 pounds per year
 Annual Submission; On/Before July 1st
EPA and State
 EPA TRI-ME Software
 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

References
 Interstate Technology Regulatory Council (ITRC),
Small Arms Firing Ranges; http://www.itrcweb.org
 National Association of Shooting Ranges;
http://www.rangeinfo.org
 Lead Prevention and Migration from a SAFR;
http://aec.army.mil/usaec/technology/leadmigration.p
df
Questions/Discussion