Name Comment Susanna Drogsvold I Am Absolutely Appalled That You Would Consider the Area North of Ward Near Beaver Reservoir As a Possible Shooting Range

Name Comment Susanna Drogsvold I am absolutely appalled that you would consider the area north of Ward near Beaver Reservoir as a possible shooting range . As a homeowner in the area and a frequent hiker near the reservoir I can assure you that the woods there are full of people hiking all through the woods. The Boy Scout camp is right there (there are young boys from the city who come to the area to experience the solitude and quiet of nature and one of them could easily wander into harms way), hikers, and in the winter skiers, on the Sourdough Trail, Cony Flats Trail and other trails nearby. Beaver Reservoir itself is owned by a veterans group to provide them with a safe quiet refuge. Veterans with PTSD will be traumatized.

Debra Biasca I strongly oppose placement of any sport shooting in the County, and especially in Magnolia Road area. My family lives there (although I live in the City) and they have children and dogs. If 1/4 mile is the limit for sport shooting, people are going to hear gunshots throughout the day and hiking, snow-shoeing and other quiet enjoyment of the area will be impossible. That's unfair to residents. I fear for the safety and quality of life of my children and grandchildren and their pets.

Let the people who want to practice shooting go to an existing location -- there are plenty. We hear them when we hike on open space in South Boulder/Superior/Marshall. Not that we're happy about that.

My views about gun-control notwithstanding, I don't see why the County has to accommodate every sport people enjoy. We don't have a bungy-jumping court, nor do we need to expend any of our precious resources on that, or gun practice. Let's fix the county roads before we think about these extras.

I may not be able to attend the meetings, and it seems to me that the County is as weak in gathering public input as the City if that is how they plan to do it. That said, I truly appreciate being able to express my views through this contact form.

Thanks for listening -- a reply would be appreciated if that's possible. Perhaps you can respond especially to the safety and nuisance issues I am raising here.

Ron Cheyney I got a copy of the letter that Annie wrote to you. I just want to say that not "all" of us are "very concerned". Some of us, like me, are in favor of such sites, especially if they are well-maintained by responsible gun owners. Our forests should not be a place where one fears for his life. They must not be essentially wide open shooting ranges.

I have personally heard bullets whiz barely above my head while hiking in Mammoth Basin in Arapaho Nat Forest. I know three other people who similarly have nearly been hit by stray bullets in the same area.

Enough is enough.

It is clearly time to ban target shooting in National Forests, except maybe in small supervised areas where bullets, gunshot sounds, and associated vaporized lead and other gun smoke pollution are strictly confined. Shooters should pay a fee to use these designated shooting ranges to cover management, clean up and other related costs.

Aside from the imminent danger that target shooters impose on the rest of us who just want to enjoy nature, there is the excruciating sound of gun play. While camping in Mammoth Basin many times, shooters blast away all day and into the night. It is unfair that a few shooters can rattle off loud rounds which disturb and terrify every one else including animals for miles around.

If we ban noisy and dangerous fireworks in the forests, we should also ban firearms.

In addition, the forest service has to begin seriously enforcing current laws about shooting near people. I know for a fact that in Mammoth Basin, many shooters blast away very close to other people. Apparently, forest rangers are ignoring the infractions as illegal shooting seems to be more frequent each years.

Currently various laws call for shooters to be a minimum of 150 yards distance from hikers, campsites, roads, etc. Of course, bullets can fly and kill much further away than 150 yards, so this minimum distance must be extended considerably.

Please ban open shooting in our National Forests immediately before another innocent camper is killed. And, put resources into actually enforcing current laws. Kerrie Badertscher Gary - We are unable to attend either meeting that is upcoming. I am voicing my objection to either site in the Allenspark area. This is specific to the "old dump site" as well as the area up Bunce School Road. While we have installed the new fire barn close to either locale: our neighbors, visitors and Hilltop Guild members are at SERIOUS risk if reinstated. I know of owners who have had errant shots enter their property and endanger them. We have had shots fired when we are meeting or worse on our bazaar day endangering not just members but the general public. Bunce is NOT a safe place at all. Is county/state/feds ready to be sued if someone is shot? Our fire department is not needed to answer these type of calls - we already have them in need of volunteers - do you think the flatlanders are going to come up and help us when we need additional response?

I further understand these are to be shooting ranges with attendants which is still unacceptable. Boulder County would do themselves a lot of hassle to avoid a great deal of expense if a fire occurs from a spark on a rock (see California examples for the last several years.) We will not always have adequate moisture. Finally shooting ranges BELONG on the flats. There what one North of Boulder at the turnoff at Niwot Road. Why does the county only focus on the mountains when a facility and property exist? Ranges belong down below - heck Carolyn Homberg would have agreed with that. Suzanna Webel As a recreational trail user, nothing terrifies me more than encountering someone shooting near the trail I'm on. Not mountain lions, not bears, not ATVs, not lightning, not trees falling in the forest. People shooting usually wear soundproof ear protection and can't hear us shouting for them to stop as we go by -- and of course they can't hear how loud the noise they make really is, because they have insulated themselves from the rest of the world.

Several years ago gun advocates proposed putting a shooting range near my farm. The Boulder County Sheriff told all the neighbors explicitly that "the Sheriff's Department could not guarantee the personal safety of any gun range neighbors inside a three mile radius of the site, because that is the distance a stray bullet can travel." There are many documented incidents of stray bullets in mountain neighborhoods, along mountain roads, and across the trails at the south end of Boulder Valley Ranch (which were temporarily closed due to the danger).

I have strong objections to the SportShootingPartners' proposed buffer zone of "1/4 mile from any trails." That is a trivial distance and will eliminate neither the racket nor the danger to passers-by from people shooting their guns on public lands. I sympathize with individual homeowners' concerns as well regarding noise, danger, and trash left behind by shooters. I have no knowledge of communication towers, but I recommend that the minimum distance to single homes and recreational development (trails, campgrounds, recreation areas, etc.) alike be 1/2 mile.

Having now compared the map of "Potential Sites on Public Lands" shown on the SportShootingPartners website with the Boulder Area Trails Coalition map (The BATCO Map) of all designated trails in Boulder County, I have strong objections to any proposed shooting sites anywhere in West Magnolia, along the Bunce School Road (other than perhaps taking over the southeast end of FR 317 exclusively for this purpose), and anywhere near Beaver Reservoir: there is simply too much recreational trail use in those areas. The former Allenspark Dump remains a viable option because it is a small and isolated block of land with no other recreation potential. Ruby Gulch might work as long as the site is more than 1/2 mile from the rest of the Switzerland Trail. An additional site to consider that I have not seen mentioned would be at the bottom of Dowe Flats after the quarrying operation has ceased and the land reclaimed. Joanna Cole As a mountain resident I am firmly OPPOSED to a recreational shooting area located in the mountains of Boulder County. I suggest the County consider one of the MANY open spaces located along the foothills, but NOT in the mountains! These open spaces are already designated for recreational use. There is no reason to create/designate rural areas for this purpose. I am VERY concerned about fire danger in mountain areas. Yes, this is a very wet year but we know for a fact that unsupervised, recreational shooting results in fires. We also know that we are unable to POLICE areas of recreational shooting. I am referring to the 1990 Michael Bell cause that left 2 dead & 2 wounded. The Boulder Police & Sheriff's department are UNABLE to patrol our mountain area. I see smoldering fires, trash, etc EVERY YEAR as a result of " unsupervised" camping in my area. Adding sanctioned shooting to the area is a recipe for disaster. Consider the murder that just took place at camp ground in Pike National Forest. It would be a NIGHTMARE for the County to create/sanction a recreational shooting area in the mountains. I am all in favor of the Commissioners commitment to keeping portions of Boulder County rural and I applaud your efforts. A shooting range should be created in a place where it can be monitored by the authorities and where it poses the least fire danger. Here is the link to your 25 Open Space parks that could incorporate a shooting range. http://www.bouldercounty.org/os/parks/Pages/default.aspx PLEASE, DO NOT create a new area for recreational shooting. Charles Ward I’ve been pretty vocal on social media on what I think is a solution to the issues standing on recreational shooting on the Front Range, so I thought I’d share my thoughts with you directly. I live in Nederland, but work away and am currently in Utah, and may not be able to attend the scheduled meeting.

I believe that the current dispersed shooting areas are not adequate for the growing population of the area, not withstanding the millions of people who come to the front range for varying recreational activities, every year.

I like to think of myself as a responsible shooter: Regularly, I try to shoot at what I believe is the Bunt School area, I know it as Trail 2171 off Highway 72, south of highway 7. I’m sure you’re familiar with the area. It’s popular with the off road vehicle/ dirt bike crowd, and if I see any sign of them, I don’t shoot, despite the rock outcrop of the “shooting area”. It’s not like I’m shooting suppressed, or enormous or very powerful rounds, it’s just not worth the risk of someone I don’t see coming over the top, or a ricochet hurting anyone. I shoot steel and paper targets, I pick up my brass. I pick up other people’s brass, aluminum cans, fridges, old doors etc, because it makes me look like a shit kicking, degenerate gun nut with no sense of social or environmental activity if I don’t.

With an elementary understanding of the issues of land use sharing, but none what so ever of “landscape level strategy” ( Did you make that up?) I believe that a dedicated range will give recreational shooters coming to the area little excuse to shoot in dispersed or designated shooting areas. While this will be a more financially costly endeavor initially, it will pay dividends by consolidating the logistics of safety, environmental impact and fire mitigation.

A range with facilities appropriate for rifle targets from 25 to 500 yards, pistol from 5 to 25 yards, and a trap and skeet shotgun range could be operated and maintained by a small staff and would easily address the needs of the public. The inclusion of a separate dynamic pistol/rifle/ shotgun range could provide supplemental income through popular competitions (USPSA, IDPA, 3-Gun etc.)

Appropriate berm material would capture and contain expended lead and copper, preventing contamination with the local environment and regulation of target materials would prevent “trigger trash”. I’ll spare you more details.

While the construction of a range would not keep every shooter who wished to wished to follow National Park guidelines on recreational shooting, it would offer a much more attractive alternative then dispersed or designated shooting areas by providing a safe, clean facility with ll th iti Dick Cole Good morning Gary. I am sharing the following article from the DC today: http://www.dailycamera.com/news/ci_28466076/fatal-colorado-national-forest-shooting-highlights-growing-problem I am sure you are aware of this incident where a person had to die so some idiot could exercise what he considered his right to shoot his gun wherever the hell he pleased. License should not be confused with liberty, and this incident is an example of one person stepping on the rights of many others. Maybe this man's death can stand for more than just irresponsible gun safety and be an awakening to us as we consider the proposed shooting areas. I am against any designated shooting areas sanctioned by Boulder County in our open space or on USFS land in the mountains, and I am not alone for many of the following reasons. The risk is too great as this man's death points out, not to mention the disturbing the peace aspect and probable lead contamination of the watershed and environment. The areas proposed for public discussion as possible shootin' sites include popular camping sites( west Magnolia, Ruby Gulch,Beaver Reservoir) and Bunce School Road, already overused by 4 wheelers. According to a resident living near the old Allenspark dump site(also proposed) to whom I spoke, a CU doctoral candidate has identified ponderosa pines on his property that had survived as many as five fires, fires possibly started by stray bullets from the ol' shootin' range. Anecdotal, sure,but you can't rule it out. There were also numerous fires started near the former Lefthand site.The mountains of the Front Range are becoming increasingly populated, and public safety is a huge concern, what with bullets flying around. Does the County plan on having a deputized staff person onsite should a site be approved? I remember an incident some years ago involving an escaped convict who went to the old(and now,properly abandoned) shootin' site in Lefthand Canyon to round up some firearms and then killed some teenagers. What about use/possession of prohibited firearms and ammunition? Trash,spent casings-and shot-up target clean-up? Sanitary facilities? Is Boulder County's exposure to lawsuits a concern should a preventable 'accident' occur? Has a survey of users of former sites been conducted to examine just who it is benefiting from them? Certainly not the neighbors. A forty-year-plus mountain resident, I haven't used these sites,don't plan to, and I think my neighbors also have a little more respect for our mountain community than to go bang-bangin' in the woods, ruining the solace that the mountains afford us and endangering others.Hunting seasons are something to which we adjust our behavior and awareness in the woods, but to open up our mountains year-round to shooters who want to target shoot is inviting trouble. Aren't there enough options on the Plains without a bunch of yahoos coming up here? Doesn't it seem like the arguments against these proposed areas outweigh the arguments for them? Mike Shaw Follows are my recommendations I just sent to the USFS:

I really want the USFS to grow up and act responsibly in designating and MOST importantly actually create sustainable professional shooting facilities. This is modern times guys.

1. Lease one or more of these remote areas to a corporation just like you do for Ski Areas 99 year lease Allow the leaser to build the following: 2. Good roads for highway access and parking for 50 cars. 3. Build a main facility.. a gun shop / repair an Indoor range. 4. Snack bar with restrooms and trash facilities 5. Hold classes 6. Have times for the Cops to practice. 7. Have a plan for clean up of toxic lead and recycling of shell casings. 8. Supervised shooting at all times .. Only allow safe legal guns and bullets, No drunks or Drugs allowed. 9. Adequate dirt berm for out door shooting 10. Make 10 jobs. 11. Operate with daylight business hours. Safety First.

The 2nd amendment ain't going away any time soon... It is time to step up to the 21st century . Get Real Walt Kramarz I'm writing to ensure that the Town of Nederland and Boulder County weigh in unequivocally and in a timely manner, to ensure that the current USFS South Nederland target shooting closure remains in place, permanently, and also considered for expansion so that target shooting is not permitted within 2 miles of incorporated town boundaries. That action is consistent not only with past Nederland Board of Trustee Resolutions, but also common sense and basic decency -- property rights, safety, and the mental and physical health of taxpayers need to take precedence over a single hobby/sport-- particularly an extremely high impact hobby/sport that imposes itself on non-participants.

Please confirm that that will happen. Resumption of the past carnage of target shooting within earshot and stray bullet range of town boundaries is unacceptable.

The USFS' request for comments is copied below. My own comments to Mr. Sanfacon are copied further below that, for those of you who may not be familiar with the history of target shooting in Nederland.

Decisive action is needed now. Thank you. Bill Vail 19 July 15

The American Experiment was about self-reliance, independence, and responsibility. Despite how battered, neglected and officially despised these virtues are today, I suggest they are robust, useful, and can provide guidance in this debate.

As I read comments about this issue I wonder why the Bill of Rights is never mentioned. The Second Amendment is central to this argument. There are no objections to spending public money on bicycles trails, or building hiking trails that are graded, backfilled, and wide enough for golf carts, or bigger and better parking lots, such as that ghastly gash in the landscape at Brainard Lake.

However, spending monies to create ranges of sufficient length and with an adequate backstop in some quarters is regarded as preposterous. Why?

The Puritans objected to bear bating not because it was bad for the bear but because people enjoyed it and I think there is something similar here. Enjoying driving your car is OK and bicycling is OK and skiing is OK and goofing around on smart phones is OK and watching trash on computer screens is OK and getting drunk and stoned is OK and going to baseball, basketball, football, and hockey games is OK, but shooting firearms for fun IS NOT OK AT ALL!!

It’s kind of like the gay marriage debate. If this isn’t OK with you, don’t marry someone who’s gay. If you think abortion is wrong, don’t have one. Nonetheless, people have very strong feelings about this both ways. Gee, isn’t that why we have the First Amendment? Anybody can say whatever they want without fear of reprisal provided that they maintain some decency in their discourse. Go along with that?

Let me suggest that freedom is freedom from, such as the Fourth Amendment, Freedom from unreasonable search and seizure. I think is germane to our discussion that this Freedom is flung down and danced upon every time you go to the airport. Deafening silence from the Colorado Delegation.

Liberty, on the other hand is doing whatever you want provided that it does no harm, or to be more realistic, the harm it does is within limits. See above list of activities. In a civil society we must tolerate each other.

Th 2 d A d t tifi d D b 17 1791 Caroline Garhart My husband and I want to leave comments for tonight's meeting - we are unable to attend because of our work.

We have no problems with responsible others owning and shooting guns for sport. We do have a problem with the fringe element who do not respect others that may be affected by their lack of responsibility.

We are gun owners, and enjoy practicing with them. Growing up, we both were taught responsible gun ownership.

We would never use the Allenspark Dump Firing Range, even tho it is 3 miles from our house (near Riverside). We know too many people who live near the range who could potentially be hurt by stray bullets, ricochets, and irresponsible gun ownership. We do not want to keep our fingers crossed that one of our friends or community members will get hurt. Sure, it will be shut down after oops! some body gets shot, or oops! there is a forest fire from ricochets (in this day and age a REAL concern for people who actually live on this land) But then it is too late. Referring to the man who was just killed at Pike National Forest.

We also are affected in that a firing range of that size (40 stations) would make our life on our land unpleasant. When the range was open, we continually heard gunfire all day on weekends, even at this distance. Pop-pop-pop-pop-pop-pop-pop-pop-pop-pop-pop ad nausum. This takes way from our intent of living in the mountains, and the peace of the community we belong to.

We understand there will be many tourists who come up here to play. I used to be one of them. But respect needs to be shown to homeowners that pay taxes and make this a community. Just because we are not Boulder or Longmont does not mean our community should be disrupted in this manner.

We support firing ranges in less populated places, where danger of fire is low, and the chance of people being hurt is nil. Nathan Moyer Thank you for the opportunity to comment on the selection of shooting range sites in Boulder County. The Nature Conservancy is a non-profit organization dedicated to conserving the lands and waters on which all life depends. In Colorado, the Conservancy has worked with local communities to conserve over 900,000 acres of grasslands, forests, sagebrush and wetlands. We are science-based and collaborative, and work to bring public and private partners together to find solutions to the most important conservation issues. The Nature Conservancy currently holds eight conservation easements with four landowners in the area around the proposed Beaver Reservoir Road shooting range. The Rangeview Ranch Conservation Easement, completed in 1976, was one of the Conservancy's first easements in Colorado. Since that time the Conservancy has protected an additionai1J14 acres in the immediate area. Together with Boulder County's conservation easement on the Welch Ranch, our conservation efforts form a block of protected land encompassing 2,824 acres. Much of this protected property is within a few hundred feet to two miles of the proposed shooting range site at Beaver Reservoir Road . These protected properties are in a substantially undisturbed, natural state and provide significant habitat for native plants and wildlife. This cluster of protected lands provides a unique permanent connectivity of the high elevation mountains to the foothills which provides a migration route for bear, elk, deer, and other wildlife. Together the protected properties form a Conservation Area that is ecologically diverse, and includes riparian vegetation communities, narrow canyons, extensive meadows, montane forests, wetlands, rivers and creeks, and springs. The Conservation Area provides natural habitat for a rich assemblage of plants, invertebrates, fish, amphibians, reptiles, mammals, and birds including, otter, moose, elk, deer, mountain lion, bobcat, coyote, bear, raptors, songbirds, heron and other water birds, and many other kinds of birds. The protected properties provide important calving areas for elk. In addition to the biological values protected, the conservation easements protect outstanding scenic and open space values that can be enjoyed by the general public from multiple Boulder County Roads, the "Peak to Peak Highway/' and public trails . . The Nature Conservancy is entrusted to perpetually protect the conservation values of the eight ti t i thi C ti A W d th t th l ti f th Barb Petruzzi We would like to voice concern about the fact that ALL of the proposed shooting sites are in the mountains. Many very close to where we and many others live. We have lived here for over 37 years and have heard gunshots over that time as well as seeing the damage that the shooters have caused. We cannot believe that three of the five sites are this close to us. Currently, we hear gunshots when people are shooting near the Ceran St. Vrain trail. We cannot imagine what we will hear if one of the Allenspark, Gold Lake or Beaver Reservoir sites are chosen! Why are there no sites on the plains? Why are the only sites in the mountains? Even in the foothills that lie lower would work for some. The sound will carry for miles up here!

This is very unfair and we would like to make note that many of us would like to see some proposed sites elsewhere. It seems that people in the plains do not want any shooting near them, but for over 37 years, they have been coming into the mountains and not only making noise, but as you know ruining the hills, setting fires, etc. Now is the time to think that people on the plains should have a shooting area near where they live. There used to be ranges out there and now there are homes and those people do not want anything! We would like this taken into consideration as you move forward with your plans. We would like to voice concern about the fact that ALL of the proposed shooting sites are in the mountains. Many very close to where we and many others live. We have lived here for over 37 years and have heard gunshots over that time as well as seeing the damage that the shooters have caused. We cannot believe that three of the five sites are this close to us. Currently, we hear gunshots when people are shooting near the Ceran St. Vrain trail. We cannot imagine what we will hear if one of the Allenspark, Gold Lake or Beaver Reservoir sites are chosen! Why are there no sites on the plains? Why are the only sites in the mountains? Even in the foothills that lie lower would work for some. The sound will carry for miles up here!

This is very unfair and we would like to make note that many of us would like to see some proposed sites elsewhere. It seems that people in the plains do not want any shooting near them, but for over 37 years, they have been coming into the mountains and not only making noise, but as you know ruining the hills, setting fires, etc. Now is the time to think that people on the plains should have a shooting area near where they live. There used to be ranges out there and now there are homes and those people do not want anything! We would like this taken into consideration as you move forward with your plans. Dennis Channer We have been Nederland Big Springs residents for 38 years. The extraordinary level of shooting near our home persisted from 2010 through 2012, when it was closed to shooting (permanently). The shooting was dangerous and oppressive. It’s now our understanding that the permanent closure was only temporary. You can only imagine how disappointing and confusing that is to our neighborhood.

Further, any shooting near a populated area such as the proposed West Magnolia site is inappropriate. The danger to peaceful hikers, bikers, snowshoers and Nordic skiers that have traditionally and extensively used that area is impossible to process for a reasonable citizen.

Please remove the West Magnolia and South Nederland Closure from consideration as a Recreational Sport Shooting site.

Meredith Tyburczy The shooting areas that are being organized by the Shooting Partnership in Boulder, Laramer and Gilpin counties should be the main areas that are used by recreational shooters. Rules and regulations posted at the entrance to the National Forest on Taylor Road (forest road 330), Pine Valley are repeatedly being ignored and violated. People enter the forest and shoot whatever, and wherever, they like. Unless there is law enforcement and stiff penalties for violations, there is really no sense in writing more regulations. Below is an e-mail sent to Mr. Sanfacon regarding Shooting Partnership.

Dear Mr. Sanfacon, After reviewing the map of the potential shooting sites, I would like to recommend that only one of the Allenspark area sites be used. The Bunce School site is in continuous use at this point, and it makes sense to develop that area. The dump has not been used in a few years, and is very close to the highway, where parking would become an issue if it were opened instead of the Bunce School site. To have four areas for sport shooters available is a reasonable number of sites. The overlap of the Bunce and Dump sites noise map, makes it clear that the use of both sites would be an undue noise burden for the residences in that area. I still strongly recommend use of the areas on a rotating basis. They could be open every other week, which would make two sites available every weekend. It would give residents in the areas a break from the noise on weekends. Thank you for your consideration of these recommendations. John Gilburt I am, most perplexed and upset over revisiting the ‘possibly suited’ gun fun ranges in populated areas in nearby mountain communities, in my case Allenspark. A few years ago this idea was soundly and sanely condemned and abandoned as, not only far too dangerous, but an extreme insult to the quiet environment in our mountains. Are you now willing to risk the collateral damage, like Glenn Martin, the grandfather killed last week by a stray bullet? Has the resident and guest population in our nearby mountains decreased, do you think? And now the risk of an occasional Glenn Martin killing is acceptable? I raised my family in a cabin near Allenspark and well within range of the proposed sites. I would not have let my children live next to a shooting gallery where they would have to think about a stray shot every day. Bullets travel far. Twice as far as their sound. Even a .22 will carry a mile, hundreds and hundreds of homes, cabins, guest facilities, hiking, camping, biking areas lie within easy range of gunfire which is still lethal, like an offhand shot into the air. Do we really think that stray shots don’t land and won’t occur? How much would the odds go up with each beer? Shooting is not like snow shoeing. Even if no one happens to get shot on a given day - at the very least it interferes with many others’ “right to quiet enjoyment” of their home or campsite and is completely incongruent in our mountain recreation areas. Add the four-wheelers and dirt bikes? What are we creating? An auditory war zone? Is that the idea? With an occasional grandfather sacrifice to pay for our fun and amusement. A shooting range needs not to be a hidden, unsupervised, unbounded hillside in a mountain forest. It would serve far better to be in the open where sightlines are long and safety is certain. This should happen on the plains on private property as legitimate business for landowners and ranchers where shooting can be enjoyable, safe and professionally managed. It would also be safer to build indoor ranges if we need them that badly. If there is really a demand, people will come and enjoy their firepower, and others will not be forced to endure the awful sound of gunfire, and the occasional meaningless destruction of a family, (it’s not just fireworks, which we are much more responsible and careful with than bullets.) No amount of happy fun or recreational imperative overrides the certainty of careless periodic loss of a life and destruction of a peaceful, natural environment. No gunfire occurs naturally in nature. There already are a number of successful privately owned and managed shooting ranges in our county. Why is this long-established, common sense recreation establishment not encouraged and our mountains left to nature and in peace? Liz Ford I have lived next to West Magnolia hiking, biking and camp grounds for 16 years and object to a shooting range in this area. I have seen many hikers and mountain bikers lost and wandering in the dark trying to find their way out. I can see camp fires outside of the regulation sites. Hundreds of people visit this area to enjoy the peace and solitude the National Forest provides. The silence is palpable. Boulder County is highly regulated for light pollution and environmental impact. How can noise pollution not be considered a nuisance. Consider the neighboring Nederland High School with every football and soccer game, Homecoming and Graduation being accompanied by continuous gun fire.

I have sold real estate in Nederland for over 20 years and never has one person asked me where the closest shooting range is located. You don’t see gun racks in trucks and rarely a gun or trophy rack in a Boulder County home. Over 300 people a day are moving into the Denver Metro Area. That’s who comes to the mountains for a day to shoot off guns. I have a client who lives on Magnolia next to open space. Since the shooting range was closed on Magnolia the shooters have moved next to his home. They shoot at his dogs and house guests. Now the owner doesn’t go outside in the summer. Reckless and inconsiderate shooters are all he has encountered.

Is this shooting range going to be manned 24/7? Even with controls in place accidents will happen and complaints will be constant. I don’t think anywhere in Boulder County a shooting range is appropriate. It’s tough enough to overcome the stigma of Nederland being the marijuana capital of the state. Drugs and guns, what are we thinking?

I truly appreciate the fire mitigation completed in our forest and the service all have given to keep Boulder County a beautiful place to live. We have recovered from flood and fire. But I don’t see how a shooting range will make Boulder County a better place to live. Thank you. Mike Shaw 1. After a successful lease to an operator allow them to make access along the + or - the 9400 elevation line to a parking area and a site with a bridge that spans the creek area. Shooting will happen into a 10,000 high mountain making a great berm with no homes shooting to the WNW. 2. My site plan includes a future dam so if lead is found in the water way exceeding EPA standards it can be treated.

3. find an operator with NRA ties for funding...

4. Lease 1 section... 1 square mile and put there in the middle... My drawing is close

5. You have my wise ideas for the last 4 years.... This does work

West Magnolia does not work... Please (city folks) Come up and hike it to see my positive Ideas Jeanne Turnage I would like to ask some questions:

1. Some items do not refer to on site management of the proposed ranges.

2. Will they be managed or will shooters be allowed to shoot ad lib with no supervision as was the previous years .

3. There are many commercial shooting ranges through out Colorado. Some are very upscale and I’m sure very expensive. Will these intended shooting ranges be for free use. Who will see if the shooters have registered guns and can they use their guns outside of their own residence.

4. It seems that many taxpayers dollars are being spent now to engage in this program.

5. Basically, the public needs to be assured that there is more than adequate safety issues that need to be addressed. There are many rules/requirements addressed in Colorado laws, many addressed City by City. Are County’s included in the City laws such as Boulder.

I have no problem with people with guns as long as they know how to use them and appreciate the safety issues and respect with owning a gun.

After the accidental shooting in Douglas County last week or so, one realize more that it’s a tremendous responsibility to define places such as recreational or practice shooting be in a restricted area with on site management, such as the businesses have to abide by. Thanks Garry, you do a lot for our Boulder mountains.

Elynne Hering I would like to share my objections to a shooting range at Ruby Gulch. My family owns a cabin at Glacier Lake at mile post 38 on the Peak to Peak. It is my haven to go to year round. I enjoy hiking and fishing and the serenity of the mountains. Occasionally we do have to listen to shooters in the adjacent National Forest. I cannot imagine being there with the constant sound of a shooting range and the danger imposed by errant bullets. For veterans....the sounds of gunshots stirs many intense memories. our cabin would become a place that my husband and sons would not want to be. I understand that for some, shooting is a recreation. But the impact of that recreation on those within earshot is disturbing. Please, find a place that is not near a community which has been created to find peace in our mountains. Linda Wages What there will not be at any of these open houses is any opportunity for dialogue, direct questions and answers, discussions, or any face to face conversation of any sort. Nor has there been. The public is at arms' length at best. We can submit questions or comments, but we can have no real interaction or input with those making decisions that significantly effect our lives up to and including the very real and demonstrated unfortunately quite recently risk of losing our lives. We remain more than concerned about the process and the outcome. 1st is the risk to life, human and animal, 2nd is the risk to the environment: egregious disregard for the land, the trees, and enormous trash left behind by the shooters, unattended fires and explosive targets, which continue to be used and have caused our last two forest fires, where others had to risk their lives to defend property and people for the careless amusement of target shooters who, of course, did not call in the fires nor stay around to help put them out. I hope there is consideration for the absurdity of considering target shooting a compatible activity with any other use of the same area. Just this past week-end, bikers on Sugarloaf had bullets blowing by their heads. People, animals, trees, and the forest is at risk continually unless shooting areas are enclosed and supervised with fines appropriate to the risk of death involved and seizure of guns which is the only effective deterrent for those who repeatedly disobey the rules. Writing as there is no opportunity for dialogue, I hope you will give this and other feedback full consideration with awareness of the burden of savings lives that is in your purview.

Monica Tymcio I live at the end of glacier lake, county road 120. I'm very glad that the issue of "free for all " shooting near homes is finally being addressed. Numerous times I have be in my yard gardening,playing with pups or visiting with friends, when bullets have zipped past my head. My home has a few bullet holes in it, while the nut thatch loves it, I don't. To have to live in fear of getting struck down by stray bullets, yet alone live with the non stop sound of gun fire is horrific and terrifying. I would like to know how this will be enforced once a range for shooting has be picked? There are so many target shooters on any given day, what's to stop them from continuing to drive into the gorden gulch area or the Switzerland trail. The Gordon gulch backs up to my property, the Switzerland trail crosses thru it. So as you can understand, I am surrounded by shooting and its a miracle no one here has been shot ...yet.

The big ???? Is how will this be enforced, as I have called the BC Sheriffs too many times when shots are flying in my face, literally. There seems to be nothing they can do, except file a report.

Can you give me some answers on how this will be enforced. David I talked to you at the meeting in Nederland last night. http://a123.g.akamai.net/7/123/11558/abc123/forestservic.download.akamai.com/11558/www/nepa/101606_FSPLT3_2548398.pdf

This is the forest service map, released July 9, that I was referring to. You seemed to be unacquainted with it. If you look at it, you will see that 100% of Boulder County USFS lands except the Indian Peaks Wilderness is designated as inappropriate for dispersed shooting. No zoning about the 1/4 mile rule etc (which is already the law re: shooting, not close to occupied roads, houses etc). 100% really!

So WHEN is the USFS going to do a closure or ban on dispersed shooting, just like they did in Magnolia? (The temporary, no-end specified closure that was enacted, with no NRA fuss, still in effect) How many more innocent people have to be struck by stray bullets?

At the meeting last night, you seemed to firmly deny that the USFS had designated all of BoCo not in the Wilderness Area as inappropraite for dispersed shooting. Look at their map. They did.

I don't trust the USFS to do ANYthing right. Look at the Eldora decision. Public comments were 9 to 1 against the full expansion, yet they went ahead with this, against the wishes of BoCo Commissioners, Fish and Game etc etc etc. I am really concerned that the shooters will get their shooting range, and then the USFS will fail to BAN dispersed shooting in areas they have designated inaapropraite. If they are afraid to meet with the public, at open house meetings how are they going to stand up to the NRA? Ban dispersed shooting in areas designated innapropriate NOW, this summer, indefinitely. And enforce the ban! Bill Ikler Regarding the possibility of a West Mag shooting site, I couldn't think of a worse place. Too close to residences on West Mag, too close to Ned, and it is one of the most heavily used recreation sites around. Mountain bikers, equestrians, hikers, skiers and snowshoers use it and because of the trail layout, circulate within the area rather than pass through. There are kid's mountain bike classes there in the summer. There has also been chronic off-trail use over the years, making the possibility of a tragic rec user/ stray bullet more likely. The noise factor would certainly degrade the recreation experience.

The 1/4 mile buffer from residences- it is not nearly enough distance. I live on the hill on the north side of Ned, across the valley from the previous shooting site on the west end of Magnolia Road. I could hear the gunfire quite clearly from my home, more than a mile away. I think the folks who came up with the 1/4 mi. buffer should be the ones who live that close to a shooting site.

There seems to be a set-in-stone assumption that a sport shooting site has to be located somewhere in the mountains or foothills west of the metro area. This may have made sense when the Forest Service was founded in the early 1900's when they were encouraging use of forest lands for recreation, but fast forward to 2015 and you have one of the most heavily used National Forest districts in the US. Trails have proliferated. Add to that a checkerboard of private/forest land ownership with most buildable lots that were vacant 20 years ago now full with private residences. Subdivisions have been created and filled and small towns like Nederland have quadrupled in size since I moved here in the early '70's.

So the chance of locating a shooting site that is not in conflict with existing recreation or residences is going to be a slim one at best. I would like to know what the demographic is of the sport shooter that wants to use the mountain forests. If most come from down below, then locate the shooting range there and let them put up with the constant gunfire.

I understand that the Forest Service is conducting its own process of locating a sport shooting site while being a part of the North Front Range process. This seems like a confusing and unnecessarily redundant situation.

This is a safety and quality of life issue for mountain residents, and I point to the recent tragic death of a camper accidentally hit by a stray bullet as a grim illustration of my point. Thanks for considering my comments. Carlos Soledade I live on Magnolia Rd. I can tell you unequivocally that our experience with shooters has been very positive. We have seen hunters in the area and they are very polite and respectful. The sport shooters in the area have been the same. I have thankfully not run into irresponsible shooters that do not follow safe practices or clean up after themselves. Hunters have asked us for permission before crossing our land.

On the other hand I have had problems with illegal campers and other recreational users that ignore private property signs and trespass on our property to camp, party, etc...

I understand that my experience as a rural property owner is not the same as all property owners in the county (I hear left hand canyon has a problem with irresponsible shooters).

I am leery of the sport shooting partners organization. It appears to be moving forward with an agenda to limit sport shooting to designated sites in the county. I am seriously concerned about this. Limiting the access and practice of responsible gun ownership from public lands because of lack of enforcement against a few bad actors is akin to denying road access to all drivers because we cannot enforce DUI laws. Gun safe handling and marksmanship are perishable skills. They must be practiced. Limited access to distant practice sites will discourage people from practicing marksmanship and safe handling.

The proposed sites at Ruby Gulch, West Magnolia, Allenspark Dump, Bunce School Road, and Beaver Reservoir Road are all too far from the main county population centers. Choosing between them while limiting sport shooting access in the remainder of the front range public lands is not an acceptable tradeoff. Travel distance to the sites from the various population centers in the county should be clearly called out in the proposals.

Can you please clarify the position of the Sports Shooting Partners organization on these questions:

1. Are you seeking to work with county and federal officials to limit sport shooting in public lands? 2. Are you advocating for structured shooting sites in addition to the public land access that is enjoyed today by many responsible firearm owners? 3. Are you advocating for additional enforcement of responsible shooting practices at the existing popular shooting site locations? 4. Are you working with the county staff currently preparing shooting range zoning regulations? 5 D k if th t t ff ill h d ibi th ibl h ti l ti th t lt ft th i l ti Katrina Peterson I am writing to you today (and cc'ing a number of my Glacier Lake Property Owners Association neighbors and other neighbors) to voice my concern about the inclusion of Ruby Gulch on the list of five Boulder County sites under consideration by the Sport Shooting Partners (SSP) as a Developed Shooting Area.

As it is less than a mile away from the GLPOA subdivision to the north, I understand that under the current distance guidelines that the SSP is operating under (over 1/2 mile from a subdivision), Ruby Gulch passes, however, we already hear gunfire from Ruby Gulch and fear that an established site would simply mean CONSTANT GUNFIRE NOISE - highly disconcerting and immediately negatively impacting our quality of life and property values.

From a safety standpoint, all hiking, cycling, and other recreation by GLPOA residents (and others) would likely have to cease in Ruby Gulch given the risk of stray bullets or interaction with unskilled shooters removing an excellent recreation option from us.

Furthermore, while they are not part of the Glacier Lake Subdivision, Martin Boniek and his family has lived for well over 20 years on a property that is less than 1/4 mile from Ruby Gulch, too close even for the current distance guidelines of the SSP.

I watched the 2 hour webcast on April 13 that the SSP broadcast and know that the distance requirements at that time were brought up as a concern and just "a starting point" for discussion. There seemed to be acknowledgement from the commissioners and others that a distance requirement of 1/4 mile from a single family home or 1/2 mile from a subdivision is more than likely inadequate from a safety and noise perspective. Also there seemed to be acknowledgement that the topography around a shooting area greatly influences how far noise can carry, so that a set distance of 1/2 mile from a subdivision could be greatly inadequate as a buffer.

Where exactly is the Shooting Area envisioned to be were Ruby Gulch to be chosen? Have existing topographical features been factored in?

My neighbors and I are aware of the Open Houses that are happening on July 20 and 21. I will be on a previously scheduled trip and unable to attend, but I expect that other GLPOA owners and our other neighbors - there are numerous other permanent residents off of County Road 103, Gold Hill Road, and County Rd. 120/Switzerland Trail - will likely show up. We already have to contend with the shooting and transient populations that occurs in Gordon Gulch. I am deeply concerned about the increased gunfire noise and safety concerns were Ruby Gulch to be designated a Developed Shooting Area. Dorothy Nepa Thanks to a good friend I began shooting at the age of 37 when I was gifted a gun. Over the 50 years I have been shooting, I have done competitive trap, waterfowl, ig game and practice shooting. I belonged to the Sloan Lake Club in Denver, continued after the move to Eire and then changged to big game hunting. Finally got a revolver and have been learning to be more comfortable shooting my S & W.

I am concerned that as more women have entered the shooting sports, more land has been removed from shooting club s because of the spread of housing. I maintain my home in Golden and also have a small ranch in Custer County where I have herds of deer and antelope.I allow wounded warriors to shoot on my land. I still hunt these animals when my freezer supply gets low. I certainly want to support the shooting public in finding suitable places on public lands and private lands in Boulder County to serve those shooters. Meredith Tyburczy Use All the sites on a rotating basis, maybe three per weekend. That would take pressure off them because they would not be used all the time. I have property near the Allenspark Dump so we would hear the use there, but if it wasn't open all the time, that would be better. James Henry I am a longtime Boulder County and Raymond area resident and wish to comment regarding abuses of the National Forest resource by recreational shooters in the area of trail 217.1, located above and adjacent to the township of Raymond Colorado. These abuses are degrading the National Forest and are excluding many other recreational activities from the safe use of this multi-use area.

Trail 217.1 has historically been a gateway into the Ironclads and Bunce School Road recreational areas and has been accessed in the past by hikers, bikers, horseback riders and campers. Presently it is not safe or enjoyable to pursue these activities in the area due to the high level of recreational shooting and associated noise. Much of the shooting activity is destructive and irresponsible.

This past summer I did venture into the area and captured a few photographs illustrating the unsafe and destructive practices of shooters along multi-use trail 217.1. The photos show how shooters have degraded the forest in the area by reckless and unsafe practices. Killing trees by shooting them and cutting them in half or shooting at trees and killing them slowly by imbedding multiple bullets in them are apparent in the photos. On my short trek through the area I counted over 30 trees that were mutilated by shooters and either killed outright or were in the process of dying, trees from 6" caliper in size up to approximately 12" in size. It is obvious most of these trees that were destroyed were live trees as the photos clearly show the green needles on severed trees.

In some spots severed and dying trees can be seen littering the forest floor that was just professionally thinned a few years ago. This unnatural deadfall is now fuel for the next fire in the area. This is especially problematic because over one hundred structures are located directly east of the 217.1 area and fire is a constant concern and threat to property and life in the area.

Also apparent are unsafe targets such as a propane tank and targets without a safe backstop. In addition, illegal targets such as wood, a television, a punching bag, etc were mutilated and left in the area. Authorities have been called multiple times when exploding targets have been ignited by shooters.

I implore you to put a stop to shooting in this area and to provide for the original intent of the area as being a shared and safe multi-use area. It is disheartening to witness the devastation of this National Forest Resource by shooters and to not be able to safely use this public resource, and to live close-by fearing the danger of the unsafe shooting practices and the increased fire danger associated with shooting in the area. Stan Heginbotham The procedures and criteria that the Sport Shooting Partnership is employing in its well-intentioned venture to identify Shooting Range sites in four front range counties are seriously flawed.

The use of firearms has been a traditional feature of life in these mountains. As an Expert rifle and pistol marksman trained in the U.S. Marine Corps, I understand and value the tradition of recreational shooting. At the same time, populations along the Peak to Peak Scenic Byway are committed to promoting and ensuring safe practices in our communities and have strong commitments to the extraordinary natural beauty and rich wildlife and flora of this scenic corridor. We are highly conscious of the fact that human presence and activity -- especially activities that endanger public safety and produce significant noise -- impinge on and undermine the quality of life in these mountains.

The fact is that the Peak to Peak Scenic corridor is not only significantly populated but is also used by numerous organizations and parks to expose visitors to the great natural resources of the area. As a result there are precious few acreages large and remote enough to meet the very considerable land requirements for safe and non-destructive shooting areas. In order to provide even minimal choices for Shooting Range areas, the Forest Service and its partners have established preliminary criteria for identifying potential sites that seriously impinge on the natural uses of the land by residents and visitors. Their preliminary criteria establish ludicrously small standards for distances of facilities from a possible shooting range site: a quarter-mile from campgrounds, recreation areas, trails, and single homes; a half mile from subdivisions and or town sites, and a mile from municipalities.

Both safety and even moderate noise considerations require well over a mile separation of shooting ranges from significant human and wildlife habitation and usage. Unsupervised shooters cannot be counted on to observe rigorous safety procedures that might justify minimal separation standards from a safety perspective. Human activities and wildlife corridors require much greater separation norms when realistic noise considerations are taken into account (noise carries surprising distances in the rarified mountain air, especially when it reflects off rocky cliffs). Two miles or more would be an appropriate separation criterion. But even minimally reasonable separation criteria would virtually eliminate site options along the Peak to Peak Scenic corridor.

That result, however, would be bureaucratically and politically unpalatable. Nationally, the Forest Service has concluded -- for whatever reason - - that it needs to integrate Recreational Sport Shooting provisions into its Forest Plan. When that mandate gets passed down to the local level, the resulting “objective” (bureaucratese for “directive”) is to “Identify at least one designated shooting area within each county inside or adjacent to the Arapaho and Roosevelt National Forests.” There is no proviso that appropriate land for such an area need be available within h f th ti Th i t t f i di id l id i tit ti d ildlif ithi th h ld i th d b b di t d t Megan Melamed I am a resident at 15927 Gold Hill Rd., perhaps one of the closest residents to the proposed designated shooting area in Ruby Gulch. I just returned from my morning run in Ruby Gulch, an area I have been running and hiking for almost 4 decades.

My gut reaction on my run this morning as the single track ended and I entered into the area where people currently camp and shoot was "I need to fight having this as a designated shooting area!" This gut reaction comes from the idea that this beautiful area would be destroyed by sport shooting, the noise would be unbearable (perhaps at my house too), I would no longer be able to recreate in an area for safety reason and an area I love so much and have enjoyed for almost 4 decades would no longer be a place I could go to.

Then I started thinking harder and I decided that at this point, I actually do not have enough information to know if I should fight against having Ruby Gulch be a designated shooting area because I don't know exactly what a designated shooting area would entail. It made me think that this might be why the conversation has become more hostile than it ever needed to be. Perhaps if the conversation was more about speaking with home/land owners and those that sport shoot on the National Forest in these areas about what would be the ideal designated shooting DESIGN on proposed sites then the tone might be different. I think many residents are imagining at this time that the sites that are now being proposed will look much more like the disperse shooting areas that exist now that have shooting in all directions, trash everywhere, no oversight, and are extremely dangerous.

Therefore, my opinion about whether Ruby Gulch should be a designated shooting area depends a significant amount on how the area would be developed. The following questions came to me this morning on my run: • Would shooting only be allowed in a very specific site within Ruby Gulch? • Would this site be developed and have infrastructure, e.g. berms to prevent stray bullets, berms to eliminate noise travel, one directional shooting into a safe backdrop, bathrooms, trash and recycling containers, designating parking, etc.? • Would a fee be imposed for use to maintain such an infrastructure? • Who would be in charge of monitoring the site? • What rules would be put in place and who would enforce them? • Would there be educational outreach at the site on safe shooting practices? • What types of guns for sport shooting would be limited? • What would be the hours allowed for shooting? • What seasons would shooting be allowed? D di d i f d i t d th t ld th t f ti i dditi t h th di h ti ld b Barbara Baring I am writing to express my vehement objection to the creation of a shooting site at the old Allenspark dump, on Bunce School Road, or on any land that is close to residential property and quiet recreational use by thousands of people from the nearby suburbs along the Front Range of Colorado. I live near Allenspark just off the Peak to Peak scenic highway, CO 7. Even with the safety closure at the dump site we are regularly disturbed by gun noise and even frightened to go outside because of dispersed shooting on neighboring USFS lands. We have close friends who live close to the dump site and actually had bullets at their patio before it was closed for safety concerns. It should stay closed forever and dispersed shooting throughout all scenic by way areas should be prohibited! No amount of mitigation will keep these activities from being an unacceptable risk to the community and its visitors.

• Please reject the 2010 Forest Service Proposal (Allenspark Recreation Shooting Project) scheduled for decision in January, 2016! • Please reject the Northern Front Range Recreational Sport Shooting Management Partnership idea to develop these areas as designated shooting! • Please reject the proposed update to the Arapaho/Roosevelt National Forest Plan with its possible future designation of these areas for shooting!

I used to own guns and did a little hunting. I have an NRA hunter safety card. I still support licensed hunting and understand that guns must be sighted and tested for these activities to be safe and compassionate. This can be done at indoor ranges. Outdoor areas must be well over a mile from areas of residential or hiking/camping usage. Some of the current proposals are only a few hundred yards away, and are also right next to highways. It has been demonstrated that preparing for safe hunting is not the primary objective of shooters in these areas. Some taunt each other for tougher targets, some get drunk, and most have no awareness and certainly no respect for surrounding life. Did you find the Loveland sniper along that highway? What about the shooter who killed an innocent camper, Glenn Martin, in Douglas Country last month? Do you want more events like that here? Or anywhere?

The culture of guns and violence in this country must be slowed down. These proposals are enabling more of it. We must sacrifice in some ways for the good of the whole. In spite of being a former gun owner and hunter I will never again own a gun and always object to the word “recreation” paired with the word “shooting”. Why?

• Daniel Mauser, the son of a family friend, was killed at Columbine High School at age 14 in 1999. My own daughter was the same age at the time and locked down for hours in another Jefferson County High School. She remained frightened and anxious for months, as did her parents. A th f il f i d i t h t C l bi H h l d t d t t t f t th t d d th l d th h d l t Betina Mattesen This simple fact should rule out this site. All efforts to establish a site should include enhanced education and enforcement on all littering, noise and safety issues anywhere on public land. Thanks. Jim Drevescraft I have previously commented numerous times on shooting issues within the Front Range mountains, to include Arapaho and Roosevelt National Forests within Boulder County where I reside. I am attaching two long comments I made previously to the Sport Shooting Partnership for reference.

In addition, I would like to specifically comment on the Proposed Directions document and the individual sites mentioned for possible shooting ranges in the mountains of Boulder County.

First, I am pleased to see that there are in essence deemed to be no suitable locations for dispersed sport shooting in National Forest areas east of the Peak to Peak Highway. This area is rather heavily populated on private lands, and the public land areas are heavily used by recreational users who are not shooters. I would single out one formerly egregious location at the old Magnolia dump site, which until the USFS had the good sense to close was one of worst locations for unsafe "dispersed" shooting in Boulder County. I strongly support the banning of dispersed (de-ranged) sport shooting on National Forest lands east of the Peak to Peak, understanding that this will not affect legal hunting or private land applications.

I generally do not support any of the proposed range locations because of proximity to structures, towns, schools, wilderness trails, and more. A very central problem for me with shooting of any kind is the negative impacts of the specific and highly disturbing sound produced during shooting, be it "sport" or merely arbitrary. Siting a range within even two miles of homes will not mitigate the noise pollution (of a type that many find disturbing and frightening). This issue has public health, safety, and property value implications.

I will not comment on the Allenspark dump, since it is apparently already being considered more formally.

Bunce School Road is way too close to Raymond, Ferncliff, and "Peaceful" Valley. Increases in vehicle traffic and noise would be detrimental to camping, hiking, conference uses at Peaceful Valley, the Camp Dick Campground, and homes in the area.

Beaver Reservoir would be a poor choice owing to homes, a private camp, a Boy Scout Camp, and a major vehicular and hiking access road to the Indian Peaks Wilderness.

The Ruby Gulch location is perhaps the closest to acceptability for a range, but there are still issues with homes (but fewer than near the other d it ) th b hi h th l d h f th f di d i d th S d h T il Joe Lostracco For over forty years, we have owned a cabin on County Rd 103 (Raymond townsite), and we well remember the days before the former Allenspark dump site was closed to recreational shooting. Our otherwise peaceful mountain retreat was constantly subject to the noise of gunfire, the litter from inconsiderate shooters, the traffic around the intersection of Hwys 7 & 72, and the constant threat of stray bullets.

Given our experience--and our hope that our grandchildren can enjoy the peace and beauty that we originally came here to find, we are opposed to reopening the dump site for recreational shooting. Besides, those seeking a recreational shooting area already have a site on Hwy 72, just a mile from the intersection with Hwy 7. Katrina Peterson As I was unable to attend either of the two Open Houses last week and will be unable to attend the August 6 Open House on the 5 proposed designated shooting sites in Boulder County, I am taking the opportunity to email you with my OPPOSITION TO THE RUBY GULCH SITE(S).

My concerns are multi-fold: * I am president of the Glacier Lake Property Owners Association, which has 20 owners and even more families and other individuals using the area for peace, quiet and recreation. We have lived at the lake for 19 years and the prospect of constant gunfire, heavy weaponry percussions, and stray bullets is devastating to our health, well-being, and property values.

* While Glacier Lake is technically listed as 1 and 1/4 miles away from the Ruby Gulch sites and therefore outside of the "preliminary criteria" that no subdivision be within 1/2 mile of a shooting range, I do not believe that the "preliminary criteria" for distance were based on any persuasive data or science - bullets can travel for up to 3 miles (according to the Boulder County Sheriff) and the sound of gunfire, especially high caliber weapons, booms, resonates, and echoes endlessly in the mountains.

* The CU Research station has property within .75 miles of Ruby Gulch. The Station has state and federally funded research projects studying wildlife whose behavior would be negatively affected by gunfire and the presence of shooters. Prior to naming the Ruby Gulch site, the Boulder County reps on the SSP did not connect with the Research station director to ascertain whether the site would even be viable given the strong environmental protections already afforded to the Niwot Ridge area.

* There are at least three property owners who own lots within the 1/2 mile "preliminary SSP criteria" radius and an additional nine who own either properties or homes literally just over the 1/2 mile "preliminary SSP criteria". Apparently the only effort made to engage these owners pro-actively (a number of whom keep to themselves, are elderly, or who have yet to build) was a single postcard mailed last spring, before Ruby Gulch was listed as one of the 5 final spots. It seems inconceivable that the County and the USFS could contemplate placing a shooting range, with its inherent and abundant safety and noise concerns and an accompanying drop in property values, adjacent to these properties without engaging each homeowner in a direct dialogue.

I would like to see the shooting areas as far as possible from neighborhoods and frequently used recreation areas. A quarter mile is not enough distance from houses and trails. Many shooters are using semi-automatic weapons which can cover a great distance, they are also extremely loud even when the sound is a half mile away. The counties need to find spots that are as remote as possible. I would like to see all of the chosen areas overseen by supervisory personnel to avoid litter and exploding targets. If they prevent even one wildfire it will be worth the cost to hire someone to oversee the areas.

Designating a shooting area in Golden Gate State Park is a terrible idea. The area you are considering off Gap Road on the border of Jefferson County is very close to two heavily used campgrounds, several trails and three fairly large subdivisions. It also appears to border the Nelson- Gruchy Ranch, an important historical area that is currently home to many horses. This area is also very important for Elk migration and I have often seen both Elk and Moose very close to the area you have marked as a possible shooting site. Gross Reservoir is heavily used by boaters, anglers and hikers. The noise, traffic and litter created by a shooting site would really spoil both Gross Reservoir and Golden Gate State Park. Thank you for your work on this project. Jane Curtis As residents of 7578 Magnolia Drive, we are completely, 110% opposed to any shooting range(s) being erected along Magnolia Drive and its offshoots. We sent a letter to the Boulder County Commissioners and Garry Sanfacon dated 10/25/2013 and 6/8/2014 (no reply received) explaining several incidents of irresponsible shooters at FS357 (1/2 mile from our house along Magnolia and approximately 1000' to the back of our property line). On one occasion, we were walking our dogs, and bullets were flying above our heads. It is absolutely ridiculous that the Forest Service, Boulder County Commissioners and other leaders have not dealt with the issue of shooting on multi-use trails. We hope it will NOT take someone getting shot and filing a lawsuit before action is taken.

Regarding the recreational shooting range issue at hand, the map is useless. There are no road names or reference points – just somewhere up in the trees. Have any of the Shooting Partner members visited the Magnolia area (for more than 30 minutes) to get a sense of the quiet world we have chosen to live in? And how constant gunfire is incompatible? Have you visited the Boulder County Assessor's website to see just how dense the area is with houses? Do you know how little noise exists here, outside of the birds, wind, woodpeckers and babbling streams? Do any of you have a basic understanding of ambient noise sound and specifically, the vast difference in how it travels in an urban setting vs. in the mountains?

We concur with Dave Bahr's comment in his letter: "As a mountain resident, I can assure you that recreational shooters have used up all of their goodwill in our neighborhood on Magnolia Road. The vast majority of us living in the Magnolia area are no longer willing to put up with the noise, trash, and safety issues. You clearly have not spoken with local residents and you do not understand the intense level of opposition that you will meet if a designated shooting area is placed within our Magnolia community."

We viewed the video about self-managing a range and laughed. It is obvious to the residents who have had to deal with this problem over the past several years, that the shooters are completely incapable or unwilling to self-police themselves. And as anyone who does policy work understands, providing education only goes so far. At some point, you have to start issuing tickets, and that requires a deputy and county money!

In addition to enjoying the natural beauty of the area, many of us love the wildlife that we share the space with. Elk herds, moose (and their young) have recently returned to Magnolia; bobcats, mountain lions, bears and a few more. Have you thought about how creating a shooting range up here would disturb their existence; interrupt their established trails and/or birth rates?

Mark Jordahl As a resident of Gold Hill, the recreational shooting decisions made by your committee will have a big impact on my family’s quality of life. After the displacement of recreational shooting from the Lefthand OHV Area, the near-constant rattle of automatic weapon fire was very disturbing. The closure of the Mt. Alto area pushed the shooting a bit farther away, for which I am very grateful. Many of us in town appreciated this show of concern by the USFS.

I fully support the Forest Service’s mission of providing multi-use lands, and as a dog owner have always done most of my recreating in the National Forest. The issue with sport shooting is that no other activity affects all other users within a radius of several miles. For this reason, the regulations governing shooting need to be more restrictive than other uses out of respect to other users. There are also the obvious safety concerns, as not all shooters act responsibly and, again, no other use of the forest comes with potentially fatal impacts on others.

Designated shooting areas are a good solution to this, as the rest of us can know to avoid those areas. Ruby Gulch is one of my favorite places to camp with my kids, but I would be willing to shift my activities to different areas in order to keep the shooting confined to this area. It is a good one, since it’s location in a depression will hopefully keep the sound somewhat contained as well.

Eric Gordon Thank you for moving forward with regulation of open shooting on Forest Service land in Gilpin, Boulder, and Larimer Counties. This is a welcome proposal, especially given the number of times I have experienced random shooting up close in this region and the experiences that the Pike National Forest has had.

I would like to request careful consideration of the proposed shooting areas. The Ruby Gulch shooting area is far too close to the University of Colorado's Mountain Research Station, where not only does important research occur, but a number of students not from the region frequently come to study. I also suggest you avoid the Beaver Reservoir Road shooting area, which would put shooters very close to the popular campgrounds of Camp Dick and Peaceful Valley and ruin the experiences of so many who come there to camp and enjoy our natural setting. Wendy Kramer Please, no shooting areas near Ruby Gulch or West Magnolia. I have lived in Nederland for 22 years because of the peaceful quite of the mountains. We hike and bike in both of these areas and feel outraged that there is a proposal for shooting in our two favorite biking and hiking sanctuaries. We walk in the west Magnolia every single day with our dogs. Please, let us who treasure the peacefulness of the mountains continue to enjoy our lovely mountain living.

Shooting should be NOWHERE NEAR where we walk and bike!

Michael Grant I write, as a long time Colorado Resident and former resident at the University of Colorado Mountain Research station to argue strongly against the Ruby Gulch potential recreational shooting range. One of the saddest experiences in my life was to have a graduate student working on a project on Niwot Ridge, above the MRS, get shot and killed accidentally.

This area supports a large array of different types of research projects which means students are likely to be anywhere within that region at any time. The gain of this as a recreational shooting site is dramatically outweighed by the need for no firearm range near there at all. Molly Melamed There are infinite reasons to not have sport shooting in the mountains, dispersed or at any of the proposed shooting ranges. These valid reasons have been stated by others and need not be repeated here.

Our question is: Why is sport shooting even being considered to be a legitimate use of National Forest land? Shooting involves everything the National Forest strives to protect the land from; noise pollution, negative impacts on wildlife, negative environmental impacts, threats to public safety and eliminating a place for all to enjoy the serenity and beauty of nature. Unlike other uses of the National Forest such as hiking, mountain biking, running, fishing, camping, etc, shooting excludes all other users of the public lands because, for obvious safety reasons, only shooters can be in the shooting areas. Closing those areas of the National Forest Lands to all other users is clearly creating inequality.

We have experienced this exclusivity from our home of 44 years that is within one mile of the proposed Ruby Gulch area. There is frequent unregulated, dispersed shooting nearby and we are unable to safely walk in our woods on most days due to the constant sound of gunfire and fears for our safety. We have even found a shot bullet in our driveway. There is no need to go into the negative environmental impact we have experienced. The point is: where there is shooting there is no other use of the land.

Trying to choose a designated area in the mountains is not only inappropriate, it is pitting neighbor against neighbor and is a futile exercise in bureaucratic red tape. No one who lives in the mountains or all other National Forest users who enjoy the peaceful and natural environment want or deserve this impact on their lifestyle, nor do they want the impact of sport shooting on the natural environment that exists here. None of the proposed sights are more suitable than any other, they are all inappropriate.

At the “information meeting” in Nederland on July 20, more likely dubbed the “non-information meeting”, County Commissioner Deputy Michelle Krezek was quoted as saying that mountain sites were chosen because “People want to come up here to shoot and enjoy the whole mountain experience.” Well these “people” are more than welcome to come up here and enjoy the “whole mountain experience” but they should leave their guns at home if they do indeed want a “whole mountain experience”. As stated by others, shooting belongs in an urban environment in closed and controlled quarters that are monitored and regulated.

Please protect the safety of our National Forests and honor their purpose; ban all shooting in the mountains and let everyone enjoy the forests equally. Sport shooting in our beautiful national forests is simply inappropriate and should not even be considered. Heidi Dugan We are Boulder County residents living at Glacier Lake which is located very close to the proposed Ruby Gulch shooting site. Glacier Lake is within the buffer radius drawn around the proposed Ruby Gulch site on the map of proposed sites that meet the preliminary siting criteria. As nearby residents we have concerns with noise, safety, environmental quality (lead contamination), the preservation of mountain wildlife, and our property value. We are strongly opposed to a designated shooting site at Ruby Gulch.

Noise: The Declaration of Policy of the Boulder County Noise Ordinance states, “It is hereby declared to be the policy of the County of boulder that the peace, health, safety and welfare of its citizens require protection from excessive, unnecessary and unreasonable noise.”

From our home we can currently hear the shooting at the Ruby Gulch campground on a daily basis. An officially designated shooting site located at Ruby Gulch would, without a doubt, increase the intensity and frequency of shooting there. As citizens of Boulder County we are asking to be protected from “excessive, unnecessary and unreasonable noise” that will, without question, affect our peaceful life at Glacier Lake.

What sound abatement measures are being installed? Will there be a procedure to enforce operating hours? Will the area be fenced with a gate that will be locked outside of designated operating hours? Gordon Gulch campground is also located near our home and we have had to call the Nederland police department on several occasions because people have been shooting there after dark, even at 2:30 am on Sunday August 2nd.

Environmental Quality & Wildlife: One of the reasons we live in the mountains is to enjoy wildlife. In our “neighborhood” we see eagles, moose, elk, deer, bears, mountain lions, bobcats, lynx, and many other animals. We appreciate the fact that the forest is their home and do not disrupt their habitat. It would be heart- breaking if the wildlife were frightened away by noise from gun shots.

We also have great respect for the research being conducted at the CU Mountain Research Station near Ruby Gulch, some of which includes wildlife research. We are adamantly opposed to introducing activities to the area that would disrupt this research.

Lead contamination from bullets is a serious environmental concern at shooting areas/ranges. Four Mile Creek is located in Ruby Gulch. It is a water source for wildlife and residents in the area use groundwater wells as their domestic water source.

Glenn Patterson I do not think the existing criteria for safe siting of shooting areas are sufficient to prevent adverse effects to nearby residents. Modern high- powered weapons are capable of firing bullets a mile or more. Prior to the temporary closure of the old Allenspark dump site near Highways 7 and 72, friends living more than 1/2 mile from the site frequently had stray bullets whizzing past their houses. A Sheriff's Deputy visiting one of those friends felt compelled to take cover from such stray bullets.

I am aware of concerns within the Boulder Ranger District over lead-contaminated soil found at the informal shooting area along Carnage Creek in Left Hand Canyon. I find it hard to understand why the Forest Service would wish to inflict this type of soil contamination on a small mountain community.

If a designated shooting area must be developed, the Forest Service should show a little more creativity in working within the scope of the Five- County initiative for Front Range shooting. Since most of the recreational shooters come from lower elevations, it would make sense to put the designated shooting area at a lower elevation, where access would not be such a problem during inclement winter weather. One potential location, currently owned by Boulder County Parks and Open Space, is the old andesite quarry along Highway 7 just west of Lyons. This location seems much more preferable than the suggested locations of the former Allenspark dump site, the site near Beaver Reservoir, or along Bunce School Road. I would also like to see the partnership consider locations such as land near the Boulder County Airport. I have heard that other communities have had success locating shooting areas near airports.

In summary, I am strongly opposed to having the Forest Service develop a designated shooting area at the former Allenspark dump site, along Bunce School Road, or near Beaver Reservoir. I would like to see dispersed recreational shooting more closely regulated to protect the safety of residents a mile or more from the shooting areas. And I would like to see the Forest Service work more closely with the neighboring counties to find a more creative solution to siting a designated shooting area, rather than assuming it must be located on Boulder Ranger District land near small mountain communities. Paul Melamed After attending the open house in Nederland and reading a bunch of emails the biggest issue is one of trust. Time and again I keep hearing that there is little trust in the Forest Service actually banning disperse shooting. Until that happens all other discussions are academic. I recommend that the Boulder County Commissioners and The SportShooting Partners take a strong stance with the Forest Service to impose an immediate ban on dispersed shooting. This would alleviate some of the concerns many have and open a path for civil discussions around the merit, need and locations of potential designated shooting areas. Mike Depalms As a long time hunter, sport shooter and outdoor recreationalist I am writing as a stakeholder in the RSS proposal. First some background – I was raised shooting for sport, from a young age I was taught gun safety. At the age of 12 I took a hunter education class, learned about safe outdoor shooting, and practiced the same. Similarly for the last 16 years since becoming a resident of the state of Colorado, I have hunted big game, shot recreationally, hiked, camped, mountain biked, rock climbed, dirt biked and snowmobiled on Colorado’s public lands. I own a foothills home outside of city limits, in unincorporated Boulder County, that while not bordering US Forest Service lands, offers easy foot access to those lands.

I understand the US Forest Service lands are lands of many uses, and while the motto of the US Forest Service is “Caring for the Land and Serving People,” the proposal of closing lands to RSS is not serving the people. The controversy of RSS should be deeply rooted in safety above all else. As an active real estate investor, the not in my back yard often rises to the top, and unfortunately those opinions cannot bear weight in these arguments. While those opponents to RSS do not prefer noise, that does not justify closure of lands to RSS. By that logic the same lands would be closed to OHVs, logging, and the like. Similarly there are other perils that often come with ones choice of residence, for example, wildfire, flood, and wild animal danger. Those opponents to RSS have chosen to be located in proximity to these alleged perils, and while those others are not controllable by land closure, neither should this one be.

The proposed closure is extremely too far reaching, as the only USFS lands that are proposed to remain open to RSS are those that are approximately above treeline west of the foothills. These areas are essentially inaccessible for more than half of the year due to weather and snowpack, and likewise inaccessible to the general public without long costly drives, special equipment, and often non-traditional vehicles.

Further, the proposal to add designated, improved shooting areas, does not replace RSS. As a member of a shooting club, and a safety officer for the club, I know that concentrating inexperienced shooters in a confined area only magnifies their inexperience and endangers others. I have seen all too often guns pointed at others on the firing line, shooters handling guns at incorrect times, gun or ammo failures harming others, and the like, and all only magnified by confining multiple shooters in small areas.

While some proponents of RSS would via for no further restriction, I view gun ownership and sport shooting as a privilege, just like legal concealed carry which requires education. Again, the controversy of RSS should be deeply rooted in safety above all else. I am a proponent of education as a requirement of RSS. The infrastructure is already in place with statewide hunter education classes taking place frequently, and more and more shooters participating in legal concealed carry of guns, having already had proper education. Education and verification of lifi ti th l ti t th RSS t t l d l G d th t f RSS d ’t h t l t di tf l Dave Query I am writing to you tonight in strong opposition to the designation of Ruby Gulch in Western Boulder County as a potential shooting range. I am a hunter and a recreational gun user and as someone who grew up in Boulder, have spent my life shooting guns in Western Boulder County.

Ruby Gulch has long been a destination for wild-life watchers, campers, hikers, mountain-bikers, off-roaders and generations of local folks out to enjoy this unique and pristine mountain setting. Why is it that this long list of generations of Colorado residents would have to take a junior position to the needs and desires of recreational gun activities? These are Federal lands funded by Federal tax dollars and this property has a long and established history of uses that would be entirely eliminated by this potential designation as a recreational shooting location.

It takes me longer to find locations to shoot than it use to. But that is my dilemma as a sport shooter. And I realize as a sport shooter that I am a minority, just like I am when I ride my bicycle along N. 36 to Lyons. Just because I am on a bike, it doesn't give me the same ownership of the roads as an automobile, although there are some very vocal in the biking community that feel this should be their right. The sport shooting community of Colorado is a tax paying, resident just like everyone else. But they are a minority to the enormous amount of recreational users of Federal lands, and especially Ruby Gulch. Enabling this location to become a sport shooting site immediately makes them the majority, and all other uses on this sector of land become completely off limits due to the safety hazards sport shooting in open spaces create.

60 year old Glenn Martin was one of those recreational users on July 7th at Rainbow Falls west of Castle Rock who while sitting with his family and his granddaughters, took a stray bullet to the head and was killed immediately. This is the risk you put everyone in when you award a high density recreational area the right to accommodate recreational firearm use.

This would be a terrible mistake that you are considering. Sport Shooters need a location, many locations, to be able to enjoy their rights as Colorado tax payers just like everyone else. But most ALL of the other uses that are enjoyed in the Colorado outdoors don't kill complete strangers. These uses - designated sport shooting areas, CANNOT carry the same rights and passage as other uses as they have deadly consequences and burdens on the entire population.

I shoot. I get it. But I realize that when I do go shooting, I must stay away from people, homes, valleys where sound carries at 10x the normal levels and I find places that are not going to disturb anyone, or god forbid KILL them. This is the huge responsibility of the Boulder County agencies and US Forest Service offices making this decision.

RUBY GULCH i t i t lli t h i f ti l h ti Jeannine Fox My sister-in-law and her family have been full time residents at a home on Glacier Lake. I have been lucky to have spent a lot of time there over the past 20 years. It is truly a special and peaceful place where many families who own homes on the lake and their families and friends spend time. As it is a unique place and enjoyed for its peace and serenity for many it would be ruined by the presence of a shooting range in its vicinity. It would be a travesty. Please reconsider your proposal to mar a heavenly place. I am sure there are other places that are not within earshot of an inhabited and lovely lake neighborhood. Connie Heginbotham I am a Colorado citizen and homeowner who moved with my husband to Peak to Peak Scenic Highway in 1996, loving and enchanted by the beauty of the high Rockies, the hills and meadows below them, the old growth forests, the thick aspen stands, the bright blue skies, showers, thunder storms, rain, hail, and rainbows. After we came, we were so grateful to learn of the commitment of many neighbors to protecting this beauty through conservation easements with the Boulder County Conservancy and Nature Conservancy. Goodnows, Welches, McKennas and Benedicts have lands that provide wildlife habitats and corridors that allow the many residents to share space with hundreds of species of birds and a huge variety of wild animals: bear, deer, elk, moose, mountain lions, bobcats, coyotes, rabbits, squirrels, chipmunks, weasels, porcupine, frogs. In addition to the families who have been able to establish conservancy protection for large areas, many families like us have been able to buy adjoining acreages (10 to 100plus) that connect with the conservancy areas to increase opportunities of wildlife to live and migrate. In 2010, I was stunned by the effect of target shooting along the Beaver Reservoir Road. At that time, I subsequently learned, campers were setting up targets on Forest Service lands for target shooting. I talked and wrote to Ms. Cat Luna at the Forest Service about how frightening and loud this was. We are across the road facing the McKenna and Welch conservancies, and we border the Benedict conservancy. Though the shooting was more than a mile from us, I thought that someone was shooting or hunting right by in on our property. The shooting was so loud and bouncing off surrounding hills so that it was impossible to tell if it was 100 feet away in any direction from our home or the decades old paths I usually walked that went through old growth and floral areas. Guests from out of state said in alarm, “Where is the shooting?” A formal range on or near Beaver Reservoir Road will completely change the environment of this area for people, animals, and birds whether they are living, hiking, or camping for miles around. I am also very concerned about many adjoining neighbors who will be as impacted as we are: Gates Camp is a Denver Boys and Girls camp that brings intercity, disadvantaged children for time in the natural world, away from the violence and poverty that so define their lives. This camp, though nearly 2 miles from the proposed site, will most certainly be impacted by the loud sounds of shooting. The Tahosa Boy Scout camp, only a mile away, also brings young people for an experience of the joys of the outdoors. They will be startled and some will be alarmed by very loud shooting. The American Legion Fishing Camp provides peace and space to veterans, some of whom have PTSD type severe reactions to gunfire. Peaceful Valley leads horseback rides for children and adults who may not know how to handle horses started by gunfire. The Hidden Lake housing development is even closer than we are in terms of hearing loud, sudden, and sometimes continuous gunfire from directions that cannot be determined. Many of those homeowners come to the mountains for retreat and peace from urban life. In addition to Santazakeres and Hidden Lake developments, there are many private residences on both sides of Peak to Peak Hwy between O l d R d d R k L k R d Katrina Peterson Having sent a comment yesterday outlining my opposition to the SSP and the USFS selecting Ruby Gulch for a designated shooting range, we would like to convey some additional information regarding our unease and dismay around the establishment of ANY shooting range in the mountains.

In speaking with a friend this morning who has lived near Jamestown, for nearly 20 years, we learned numerous disturbing and discomforting details about the former shooting range in Lefthand Canyon. 1. The range was often populated by shooters who were drinking or even drunk. 2. The shooters would haul up refrigerators, old cars, household detritus of all types to use as targets, so the area became a dumping zone. According to my friend, rather than patrol and prevent this type of behavior, the County or USFS would annually send in multiple dumpsters and remove the trash, thereby seeming to condone (and even pay for) the trashing of the environment. 3. On TWO recent occasions, bullets and shooting caused dangerous wildfires. It is inconceivable to us that after such an event happened the first time, shooting was allowed to continue. 4. Campers at the site would often drink and have large bonfires, concerning activities when numerous weapons are around and in a mountainous setting already at risk for wildfire. 5. On an average weekend day, fifty or more vehicles would be parked on Lefthand Canyon presenting serious traffic hazards. 6. My friend said that she and other Jamestown residents eventually chose to stop driving Lefthand and instead would go up and over Lee Hill Road (a more arduous drive) just to avoid being in the vicinity of the innumerable irresponsible shooters and their culture of trash, drinking, and weaponry. In researching her comments online for veracity, we learned that even gun enthusiasts felt that the Lefthand site was a disaster. Two comments from a gun enthusiasts chat room re: the Lefthand site (http://www.ar15.com/forums/t_8_20/521957_Lefthand_Canyon_shooting_.html) :

Nick, I shot there for years and, frankly, the place scared the crap out of me. I would always have a spare "I don't have a gun" gun on my person in case anything unpleasant happened. Even before I moved here, some fugitive fellow claimed to be a forest ranger, told five shooters to turn over their weapons for inspection, then gunned them down and took their stuff. Two dead, three wounded. And that was *before* it got sketchy.

It needs to be closed. As stated above, nobody would ever pick up their trash, the place looked more like a dump than public wilderness. There were also several fires started there by irresponsible shooters using tracers. If we, as a shooting community, can't police up our trash and b h ibl th d t l th i ht t bli l d t h t Teresa I just want to clarify the claim that a fire was started by recreational shooters in 2005 at the Allenspark Dump Site. As a member of the Allenspark volunteer fire department, I can say that fire was investigated and it was not determined to have started by shooters.

I live in Allenspark, have heard the shooters since we moved here in 1988 and can still hear them at Bunce School Road. I am not a hunter and do not own a gun.

I would vote to open the dump site as well as several others sites open to shooters to spread the possible shooting sites around, so there are not so many folks at one place.

There have not been any emergency calls due to shooting. So, it seems safer than most people think.

I think the people that move here and then complain about the shooters who have been here long before them are very selfish. Jon Hatch As I was unable to attend either of the two Open Houses last week and will be unable to attend the August 6 Open House on the 5 proposed designated shooting sites in Boulder County, I am taking the opportunity to email you with my OPPOSITION TO THE RUBY GULCH SITE(S).

* Ruby Gulch is currently a gorgeous spot used by campers, off-roaders, mountain-bikers, hikers and folks out to enjoy its abundant wildlife and mountain setting. All these recreational activities would cease and instead a motley collection of responsible and irresponsible shooters would take-over. I have not been impressed with the conduct of the "dispersed shooting" people I have encountered over the years and so have little fid th t th ld d thi b t t h R b G l h Linda Andes-Georges I would like to add some suggestions to a previous letter I wrote concerning this same issue. But I must preface them with my reasoning: A few of my principle objections to currently proposed shooting areas are: 1) They exist close to too many recreational uses, which endangers the public (my family, grandkids, and foreign or out-of-state visitors). My USFS friends oblige me to wear hunter orange when we are anywhere near (1/2 mile) recreational shooting areas. This situation is ridiculous! 2) Recreational shooting leaves a great deal of trash which shooting groups do not appear motivated to clean up, obliging taxpayers to achieve it with public funds. 3) They further endanger the public with both personal smoking as well as spark-producing munitions, which cause wildland fires (there have been local instances of this). 4) They are extremely noisy, destroying the very peace which the large majority of public lands users seek. Furthermore, this racket displaces use by wildlife. 5) Many types of ammunition contain lead, which presents a physical danger to wildlife. Gun owners have steadfastly refused to pay a penny more for non-lead ammunition, and have opposed all laws proposed to limit such ammunition. I warmly suggest this alternative to outdoor shooting: That all public shooting facilities be required to be in an enclosed building with soundproofing. We can have as many of these as Congressional funding allows the USFS to build and maintain. This would solve the safety, noise, and fire issues. I would be happy to pay more taxes to make this a reality. If it is politically impossible to do this, I strongly urge the USFS to prohibit recreational shooting sites on national forests in all locations except for those that meet the following MINIMAL criteria (endorsed by the Sport Shooting Partners Association): 1. Distance from municipalities - 1 mile 2. Distance from residential development • subdivisions and/or townsites - 1/2 mile • single homes - 1/4 mile 3. Distance from recreational development - trails, campgrounds, recreation areas, etc. - 1/4 mile 4. Distance from communication towers - 1/4 mile The proposed facilities in Ruby Gulch and Beaver Road are particularly inappropriate, containing few topographic barriers to free-flying bullets, and used by thousands of recreationists of all types and ages, not to mention a Boy Scout Camp and a nationally-renowned research center. Bill Bowman I support the efforts of the Arapaho & Roosevelt National Forest and the Boulder County Land Use Department to manage dispersed shooting within the forest. For the past 25 years I have served as the Director of the University of Colorado's Mountain Research Station (MRS), surrounded by the Arapaho & Roosevelt National Forest. While I support the establishment of organized shooting ranges, I do not favor selection of the Ruby Gulch site, which is less than a mile away from the MRS. The sound of large caliber rifles carries a long distance, and likely impacts the behavior of the animals we study. The noise also seriously compromises the educational experiences of the many students, researchers, and staff who work at the Mountain Research Station. With over 3 million dollars in research grants each year that help inform land management within the USFS and National Park Service lands, numerous environmental field courses from K12 to graduate levels, and visitors from throughout the U.S. and many countries, the MRS is a valuable asset to Colorado and the nation. Thus it is in the best interests of taxpayers and the general public to maintain and improve the conditions for work and education at the MRS, which would be compromised by a small number of recreational shooters using a concentrated site less than a mile away.

We strongly support this project to contain dispersed shooting within the Arapaho and Roosevelt National Forest, but favor selection of a site other than the Ruby Gulch. None of the proposed sites has clear advantages, and a shooting range so close to the Indian Peaks Wilderness doesn't make much sense anyway. However, given the legacy of shooting at the Allenspark dump site, it seems most logical to site the shooting range there, once the safety concerns raised in the past about stray bullets are addressed. The site is near the junction of two major roads, and thus noise is already greater than at the Ruby Gulch site. Louise Buck I would like to comment on your Proposed Forest Plan Direction regarding Forestwide Goals and Objectives to provide for recreational sport shooting (RSS), and specifically your proposal to site a shooting range near the intersection of Rtes 7 and 72 at Bunce School Road or Allenspark Dump near Allenspark, Colorado. As the owner of 40 acres of land at 563 Big John Road (Mountain Meadow Section 33 LLC), holder of a conservation easement on the property with Boulder County Parks and Open Space Department, and a specialist in natural resource management (M.Sc. Colorado State University, Recreation Resources; PhD, Cornell University, Natural Resources and current faculty member there) I find a permanent shooting range to be an entirely incompatible land use with other vitally important uses and values in and around the USFS areas of Allenspark. A landowner since 1978, I bought the property from a neighbor and friend (James Welch) for the land’s special mosaic of mixed forest, meadow, stream and topographic features that make it a magnet for wildlife. I also valued the peace and quiet that the property affords. When the opportunity arose to partner with Boulder County Parks and Open Space (BCPOS) in protecting the wildlife habitat and open space values of the property I worked with the Department (copied here) to develop one of its early mountain conservation easements in 2004. Since purchasing the land and especially since signing the conservation easement I have collaborated closely with my neighbors to the west, Jim Welch initially, followed by Andrew Butcher and now Russel Hullet (copied here) in co-managing the 80 acres. The Hullet property is under a BCPOS conservation easement as well, to help us jointly protect the wildlife corridor for mountain lion, big-horn sheep, elk and other mammals as well as the birdlife that our unique meadow-mountain-stream scape attracts. A permanent shooting range within earshot of these properties is a fully incompatible land use, both for the wildlife and for the land owners who highly value the peace and quiet offered by the properties and constitute a key motivation for purchasing and holding them. In the late 1970’s I conducted research for my master’s degree at Colorado State University in collaboration with the US Forest Service to develop a methodology for assessing socio-economic impacts of USFS actions around the concept of “futures foregone”. Recognizing the USFS mandate to manage for multiple uses, the methodology, which gained wide acceptance at the time, established that uses valued by certain stakeholders which fundamentally undermine and ruin (forego) uses valued by others are socially unacceptable. Putting land use policies into place that do forego the desired futures of any stakeholder stands to generate polarized conflict, which is far more difficult for society to deal with than the inevitable and more manageable “cross-cutting” conflict patterns that arise from multiple use land policy and decision-making. While it is not clear to me exactly what your criteria are for assessing the socio-economic impacts of a proposed shooting range in Allenspark area, in the literature presented on your proposed actions (plan directions) I find no mention of the noise factor. I find mention of safety from stray bullets and from traffic associated with concentrated permanent shooting range. From my perspective noise is the most fundamental and far-ranging impact of your proposal. And the impact of noise on wildlife and on people who live many miles away from a shooting site, in all directions, foregoes the value for peace and quiet that one chooses and expects in living in and/or visiting mountain forest areas. Furthermore, i hb d I ill b t l di t b d i th k l d f th i l l bl di t b t ildlif th t th t f i th t Mike Daley Gary, I am only commenting on the two possible locations for shooting ranges in Allenspark, the area which I live full time, and I have no context of the more southern areas. I do not live close to either of the area so I have no selfish agenda only the general quality of life in this beautiful area.

The site known as the old dump site was closed for good reasons to shooting previously with great consideration and I do not think that berms and fences will stop the noise from all the nearby residences and the scenic highway and have no confidence it will stop the stray bullets that are well documented leaving the property. It seems crazy to me to consider reopening, as site that was shut down for safety and noise and think it will be safe and quiet with a few fences and berms. This site is not the location for a shooting range under any conditions and I am thinking serious consideration of this site to be like reopening 3 Mile Island – yeah, no way. I would believe that the county ordinance of maximum of 55 decibels at the property line cannot be met with any mitigation short of total enclosure. But if you are going to totally enclose it, then locate it close to the population of shooters and save the gas and highway crowding by putting in the “valley” somewhere.

Bunce is a possibility in my mind for consideration, although I cannot tell how far back the road the proposed site is. I have driven on Bunce many times and there are very few houses back there and nice hillsides/mountain sides to shoot into that are surely 10x or more higher than the berms you could build on the flatter site above. If you go back Bunce at least a mile from highway 7 as a crow flies, to get away from the Guild, the Bunce school house, the fire department and the residents near Highway 7, I could begin to support that as a location if the shooters had a tall hill or mountainside to shoot into. On weekend the noise is high there anyway with the tons of 4-wheelers, so the gun noise on weekends, should be just part of the chaos of the area anyway and blend in.

Denise Motta NO WAY! To Allenspark Dumpsite Shooting Range! I own property in Allenspark, CO and I am AGAINST a shooting range in Allenspark, CO!!!

Jeff Kersting NO WAY to this project! I'm an Allenspark property owner and don't want this kind of activity near my property Karelle Scharff As one of the communities on the Peak to Peak Corridor where the Recreational Sport Shooting Partnership has concentrated its attention, we are submitting the following comment: The Town Council and General Assembly have passed the attached resolution regarding the 2 suggested sites that sit fully in the Indian Peaks Fire Protection District (IPFPD). Many town residents are avid hikers, cross country skiers, showshoers, campers, mountain bikers and many enjoy motorized off-road sports. Many parents encourage their children to engage in these kinds of outdoor activities. Thus far I have yet to hear a resident of the Town of Ward say that they like the current situation with dispersed shooting in our adjacent National Forest, and many lament that they no longer feel safe hiking trails that they’ve hiked for dozens of years, a few for almost a half century. Parents are concerned about their children playing in the woods, a treasured childhood activity. Some of these people are gun owners, hunters, shooters themselves. At a recent town meeting when asked how many people recently had heard nearby gunfire when walking in or near the National Forest, of 26 people in attendance, 6 raised their hands. As we’ve seen in the recent news from the Pike and San Isabel National Forest, dispersed shooting can end very badly. With that in mind we applaud the idea of closing much of the crowded, highly populated and highly popular Boulder County sections of the Arapaho and Roosevelt National Forests to dispersed shooting. However, none of the 5 sites that the Boulder County reps of the Northern Front Range Recreational Sport Shooting Management Partnership (NFRRSSMP – or RSS for short) are even remotely suitable, and the two that fall in the IPFPD are especially problematic for our residents and emergency services. The Indian Peaks Fire Protection District covers more area with less personnel and funding than other districts affected by these selections and our district is already strained by the medical calls to which they respond for hikers at Brainard Lake and on the road leading to Ward and Brainard Lake due to bicycle accidents. Despite the awesome department that the IPFPD fields, if we were to add another site with the potential to generate serious accidents, that might well overtax our department’s resources. Additionally, our residents live here partially for the proximity to hiking, cross-country skiing, camping, and the 2 sites in question are especially favored. These sites and everything within a mile of them will no longer be available to any activity other than shooting (thus no longer being “multi-use”), unless the site is supervised and managed and the County and Forest Service have already made it clear that they won’t be doing that management. Even if clubs and non-profits step forward to volunteer their time and energy to the management of a designated shooting area, there are certain to be gaps in that supervision and those gaps are likely to be filled by shooters who don’t want to be supervised. There’s nothing to stop those generous organizations from tiring of babysitting irresponsible shooters and just quitting, though the site and its attendant troubles won’t go away. We try hard to take care of our woods – such as putting out abandoned campfires and cleaning up trash, and generally just don’t need the dditi f th ki d f th t thi ki d f ti it t tt t Rob Gerritsen (This is a copy of an email I sent you a few minutes ago that was sent under the wrong email address. I would appreciate it very much if any responses are sent to [email protected] rather than the email address used in the initial message.)

Thank you very much for organizing last night’s meeting at Peaceful Valley.

I want to provide you with my reaction to what I learned last night. I own a cabin on Big John Rd, close to both Bunce School Rd and the old Allenspark Dump site, and therefore fear that I will be significantly affected by a shooting range at either of these locations. There is already a lot of shooting going on in the Bunce School area and the peace and quiet that I used to enjoy on Saturday and Sunday are now gone and have been replaced the incessant popping of gunfire that echoes across the valley.

I fear that concentrating more shooting into a shooting range in that area will just produce increased noise levels and also produce noise on weekdays that now still remain relatively quiet. So my position is that I am absolutely opposed to a shooting range that at either of these locations close to my cabin.

Beyond that I have some comments wrto the preliminary criteria that the partnership used to select the proposed sites. All of the minimal distances seem ludicrously small. ¼ mile from a residence? ¼ mile from a trail, campground or recreational area? Are you kidding me? Your own brochure explains that some bullets travel up to 2.5 miles. Given that fact, how can you defend a criterion that would allow firearms to be repeatedly discharged at any distance less than 2.5 miles from a residence?

Missing from the criteria is any criterion having to do with noise. I would propose that a criterion like the following be added · Sites be far enough away from residences so that the sound at the residence from gunfire be at or below 30 dB David Pinkow The US Forest Service is pursuing an extraordinary three-pronged push to reestablish the old Allenspark dumpsite as a sport-shooting venue. There are, in fact, currently three independent governmental actions under consideration that could lead to the renewal of recreational shooting at the old dump:

1) The 2010 Forest Service proposal, called the Allenspark Recreational Shooting Project, which sought to establish a developed shooting range at the old Allenspark dump, is still on the books and is currently scheduled for a final decision in January, 2016. Complaints to the Forest Service over safety-related issues at the site date back at least to 2006, when a forest fire started by recreational shooters threatened destruction of nearby homes and properties. After many years of complaints, dozens of petitions and innumerable documented instances bullets zooming past innocent bystanders, (including those experienced by a Boulder County Deputy Sheriff), the US Forest Service in April, 2010 finally closed the dumpsite to recreational shooting for reasons of safety.

Unbelievably, one month after that closure the Forest Service published a proposal to reopen the site as a developed shooting range complete with berms, backstops, baffles, parking and other amenities. Regardless of those plans and in spite of any safety features that may be proposed, the old dumpsite is simply the wrong place for sport shooting--no amount of site modification can rectify its deficiencies. Following the USFS proposal to establish a developed shooting range, citizens in the Allenspark area, spearheaded by the Glacier View Neighbors' Association, filed a host of objections that continue in their validity to the present day: 1) the Forest Service holding at the old dumpsite is too small (approximately ¼ by ½ mile) and is surrounded completely by private property, which means that the owners of that private land would provide the necessary buffer zone to absorb ear-splitting noise and errant projectiles; 2) toxic material buried not too far beneath the surface (the site, after all, served as an unregulated dump for decades) poses a threat to both personal health and the environment; 3) the firing line for recreational shooters would be located only 650 feet from the Peak to Peak Scenic Byway, creating an incompatible and degrading element within the corridor. A US forest Service final decision to implement the plan has been postponed numerous times, but is currently scheduled to be made in January, 2016.

2) The second scenario by which the old dump site may be tapped for designation as a shooting venue is through actions of the Northern Front Range Recreational Sport Shooting Management Partnership, of which the US Forest Service is a member (other members being the Division of Parks & Wildlife and four counties: Boulder, Clear Creek, Gilpin & Larimer). The Partners have recently revealed a list of five sites in Boulder County that are under consideration as designated sport shooting areas, among which is the old Allenspark dumpsite. To their credit, the Sport- Shooting Partners have established an open and transparent process to stimulate discussion and consider advantages and disadvantages of ifi l ti f ti l h ti A b f th P t hi B ld C t h h d l d O H i th diff t Nathalis Chardon As a graduate student at the University of Colorado, Boulder studying alpine ecology, I often spend time working at our Mountain Research Station (MRS) on Niwot Ridge. I'm aware of the proposed shooting ranges to replace the dispersed shooting that is becoming common in this area, and fully support this in order to concentrate recreational shooting. However, I strongly oppose the Ruby Gulch site due to its proximity to MRS. This is the only proposed site that would have a very large negative impact on the research activities at MRS, and this internationally renowned research station would certainly lose key partners if a shooting range were to exist so close to it. Not only would our research activities be impacted, but also the large amounts of educational and outreach activities would likely cease to exist due to people's concerns to the proximity of a shooting range. As there are no topographic barriers between Ruby Gulch and MRS, the chance of stray bullets is one we would have to be concerned with. As the weather up there is often characterized by low visibility, this further causes additional concern for alpine researchers. Please consider not choosing the Ruby Gulch site for a shooting range, as a federally supported research station would be very negatively impacted. Ralph Nelms 1. I read about the Devils Nose area in Clear Creek County. I would like to know where this area is located 2. I have a home at 1094 Pisgah Lake Road which is just west of the Columbine Camp Ground West of Blackhawk. On weekends we experience a large volume of gun fire activity which makes walking in the forest sometimes scary to say the least. At times I have had bullets traveling over my house. Since my home is at the top of the hill west of the Columbine Camp Ground the shooters do not know about any of the residences at the top of the valley west of the Roads near the Columbine Camp Ground. There was a recent article in the Denver Post about a family camping in the Columbine Camp Ground West of Central City/Blackhawk last week who were very concerned about the volume of gun fire and vowed never to return to the camp ground. I think they left early because of the large volume of close proximity gun fire. There are about 20 residences west of the Columbine Camp ground and sometimes it feels like World War III and you are afraid to even go outside until evening. We also have a lot of gun fire to the south and West of our home. 3. We have found people sport shooting right on Pisgah Lake Road in front of our home. The shooters believe if they are on Forest Service property they can shoot anywhere and are not aware that about 20-50 homes are directly off the road behind the trees and that there is private property intermingled with the public lands. The USFS at least needs to put up signs in these areas. However when the locals put up signs they all tend to be shoot to pieces in 1-2 days. Of note is the trail up Pisgah Mountain just south of our home on Pisgah Lake Road. A fence was placed on the edge of the parking lot and people shoot directly into the Trail. If you hiked up the mountain you would be returning on the trail directly into gun fire. Locals who placed signs on the fence near the trail had the signs shoot to pieces in 24 hours. 4. We also have a lot of ATV and motor cycle traffic on the Pisgah Lake Road. Target shooting also poses a hazard to these users in the area as well. 5. I recommend the following for target practicing in the York Gulch area and West of the Columbine Camp ground. a. Make all sport shooting West of Columbine Camp Ground illegal until you reach the western limit of the residences on Pisgah Lake Road USFR 1751 which is about 4 miles West of the end of the Clear Creek County Road and road to the Central City cemetery on York Gulch. There are existing shooting areas 4-5 miles West of the Clear Creek County York Gulch Road which are now in use and will not create a danger to any of the homes along Pisgah Lake Road and York Gulch. b. Post no shooting signs along Pisgah Lake Road telling shooters there is an area they can shoot farther down the road so they know about it. c. Have at least one forest service representative in the area on weekends to monitor the shooting activity. d. Another major concern from un-controlled gun fire is the risk for forest fires from hot bullets. Wild fire prevention should also be a concern for limiting and restricting sport shooting in this area of 20-50 homes West and South of Columbine Camp Ground.

A h th i ht t h t th F t S i b t ith th i d d it f b th l t ffi d h W t f C t l Cit Kent Wolcott We are writing to express our opposition to the proposed Ruby Gulch shooting range. Since 1968, we are property owners on Gold Hill Road, 1 mile east of the Peak-to-Peak Highway. We bought here in 1968 to be able to enjoy peace, quiet, and hiking in the mountains on and around our property. The proposed shooting range would be located within 1 mile of our property---and probably closer. We have received no official information regarding the proposed Ruby Gulch site and only recently received notification via a 29 July letter from a concerned neighbor. Therefore, we have been unable to attend any of the recent open houses on this matter.

Due to excessive noise and safety considerations (gunfire noise resonating throughout the mountains and the distance that bullets can fly), we are opposed to the possible Ruby Gulch designated shooting range location. Additionally, we are concerned about how the site would be policed/controlled and the hours of operation—should this site location be approved. Toby Schnuck I am a resident of Boulder County. I am a firearms owner, voter, environmentalist and enjoy hiking, skiing, backpacking on our public lands. On several occasions over the past 20 years I have been in the line of fire of shooters on public lands. I have seen numerous places in Boulder County that have been negatively impacted by trash, shell casings, lead projectiles from recreational shooting. It is hard to find a place to legally and responsibly shoot in this county.

HOWEVER, I do not believe in the ‘right’ to engage in behavior that endangers the life and welfare of others, to destroy our public lands, to negatively impact the right of others to recreate or to make life a living hell for other people and animals.

No one has the ‘right’ to discharge a firearm, especially not irresponsibly and on public lands. While our constitution may guaranty the right of firearms ownership, it does not mention the right to discharge those weapons or direct any government entity to provide a place to do so.

As much as Boulder County needs a place for people to be able to shoot safely, it is neither a ‘right’ nor the responsibility or duty of our government to accommodate people that want to shoot. I have worked as a police officer, federal agent and emergency responder for over 15 years. During this time, I have seen numerous and sometimes fatal firearms accident and personally seen incredible acts of violence committed with firearms. In the USA, we have far more firearms violence and accidents than any other civilized country.

I could think of many more, far more urgent and important things that our government could be doing. Amongst them are mitigating and preventing climate change, conservation and preservation of our natural resources, ensuring peace and tranquility, protecting children, animals and the disadvantaged as well as reducing poverty and hunger.

I understand that the gun lobby is a powerful actor and that gun owners tend to be the most forceful voices in this debate. Regardless of how loud these voices may not stand the scrutiny of intelligent, compassionate reasoning. I urge you to listen to reason and common sense and make a decision to protect the people, the animals and the environment. I would like the county to set aside a small area with a user fee that covers ALL costs of this area (purchasing, maintaining, environmental di ti d t ffi ) Clare Tone I am trying to educate myself on the designated recreational shooting area issue. I am reading back through some of the committee work and details posted through the Gold Hill website. My husband, Kevin Tone and the rest of our family have significant concerns about designating Ruby Gulch as a recreational shooting area. I believe I understand the rationale behind designated shooting areas, as a way to consolidate otherwise dispersed shooters. My question at this time which is unanswered is why, exactly, each county is required to have it’s own designated recreational shooting area? Can you please refer me to the law or rationale that indicates this necessity for each county? It simply seems that some counties, due to previously established land and recreational-use patterns make them inappropriate (dangerous) for both dispersed shooting, but also high-density recreational shooting. (I’m thinking of fire risk, specifically, which surely will increase for that designated area. Have you ever hiked Ruby Gulch? It must be assumed that it will behave like any other dry, densely forested steep canyon when it starts to burn. Think: next Four Mile fire.) I am wondering why residents of, say, Larimer, Boulder and Weld Counties couldn’t be directed to the same, appropriate site in an area less dense than anywhere along the foothills? I understand the desire for people from the plains to be able to have a ‘mountain’ experience (which shooting in the foothills certainly isn’t!) but we all travel a great distance to gain access to our preferred recreational use of USFS lands, and we certainly can’t always find what we are looking for within the boundaries of our home county.

One more question I’d like to ask is about noise pollution. Many others have made good observations and comments about personal safety and increased fire danger, so rather than echoing those concerns (which I certainly share) I would like to know what, specifically, will be done to mitigate noise pollution from a designated shooting area? Jerry Leigh Proposed Boulder County Sport Shooting Areas One of the proposed areas is east of Beaver Reservoir in West Boulder County. Our family has visited this area for hiking and camping for at least 35 years. Based on the Sport-Shooting-Partners map that I have seen, the proposed area infringes on an area that I have seen heavily populated by campers for as long as I can remember. The noise created by this activity in this particular area would degrade the outdoor experience of all users. The Sport-shooting-partners map clearly shows the ½ mile circle that serves as a safety zone as extending over both sides of the Beaver Reservoir road and as far west as the Sourdough Trail. We feel the site shown on the map is located too far west. The entire Beaver Reservoir area is heavily used by campers, hikers, woodcutters, and others whose experiences would be negatively affected. Karelle Scharff My concerns are • Safety - both for the shooters and for the people who are trying to recreate nearby • Wildlife - all the sites on the Peak to Peak are popular not only with hikers, skiers, campers but with wildlife, large and small, that would be driven away by the noise and intrusion and risk lead poisoning • Noise - sound reverberates in the mountains and it would be difficult to dampen that sound, especially over Beaver Res (I feel deeply for the Am Legion camp there - PTSD doesn't respond well to gunfire • Property values of surrounding properties, and the value of lands that people have given as conservation easements for wildlife, managed by the Nature Conservancy, that will be meaningless if the wildlife is driven away. • Ungodly amounts of trash • Human waste • Lack of supervision and enforcement - 1 officer for 160,000 acres? Really? • The risk of fire (in an IMA meeting with Jay (last name?) at the training center north of Boulder last year, he made it clear that our forest up here near Ward is one of the most at risk areas in Boulder County. • Risk to our IPFPD Emergency Services All the sites are at risk, but Beaver Res particularly. However I don't want to see community pitted against community.

Perhaps revisiting the LHC site that's already burned several times, been trashed and had what trees weren't burnt, killed by gunfire. timothy Seastedt As an educator who uses the Mountain Research Station as both a research and educational area, I'm suggest that should Ruby Gulch be considered as a site, that the direction of any shooting be away from Niwot Ridge.

Indeed, the whole concept of outdoor 'practice' for shooting might be reconsidered. Why use public lands (and arguably penalize taxpayers for the negative ecosystem services caused by this activity) when as good capitalists we could develop private shooting ranges that are as safe as possible and generate income? This would also contain the 'wastes' of the activity. Clearly a win-win. Colin Morrison I have viewed the Bunce School Road and Allenspark Dump sites. I live nearby and would prefer neither be considered but that's just being NIMBY. Both seems to have decent potential I think. The dump is quite close to the highway but somewhat prepped already. I don't believe there's lot of private landowners affected. Wildlife is already impacted now. ADA access looks easier at the dump. The level of work and expense appears to me to be much greater at Bunce School Road. I know nothing about the other sites. I do think there needs to be a shooting range out of the mountain areas. The travel time would potentially be less as well as less impact on wildlife and wildfire hazards.

Sam Simkin I am writing to express my concern about the proposed Ruby Gulch shooting range location. This location is very close to the University of Colorado's Mountain Research Station and the Niwot Ridge Long Term Ecological Research site, which host a wide range of long-term research studies and substantial numbers of students, both of which could be negatively impacted by the Ruby Gulch location. Christy Howe First of all, I’d like to thank you for closing the informal shooting areas in Lefthand Canyon and west of Jamestown after the 2013 flood. While greatly appreciated by the locals in this area, unfortunately, closing these areas has not solved any problems, it has only moved them to other locations.

My husband and I have lived in the mountains of Boulder County for 37 years. Our current home for the past 27 years is 2.6 miles from the proposed Allenspark shooting area. Over the past five or six years, the noise pollution from this site has steadily increased. On any given day from sunup to sundown we listen to gunshots from that site. On any given weekend day in the summer it is essentially non-stop. This is the current situation, without this area even having a designation as a recreational shooting site.

Your proposal states that “suitable lands for RSS included areas that were further than ½ mile from residential subdivisions or concentrated high use recreation areas”. In light of my own experience, a more realistic radius would probably be 5 miles. Considering the thousands of people who live up here, I doubt there is any “suitable” location in the mountains of Boulder County. Forget the legal definitions, recreational shooting is Disturbing the peace, which is a crime. We all pay a price to live in the mountains, but when we made that choice 37 years ago, we never imagined that one of them would be listening to the constant noise pollution and danger that recreational shooting brings to our forest.

My husband and I have been inadvertently shot at, while hiking near our home, by recreational shooters. I have encountered shooters in our neighborhood who disregarded posted signs stating that no shooting is allowed there. I have seen and heard shooters firing across gulches and well inside the required boundaries of 150 yards or more from an occupied area. Before the 2013 flood closed the area west of Jamestown to shooting, shooters had totally trashed the forest. They shoot the trees, they bring in trash to shoot at and leave it there, and they have started forest fires on more than one occasion. My husband has submitted detailed reports to the National Forest Service, Boulder County Commissioners, and Boulder County Sheriff’s Department, complete with photos of the destruction that recreational shooting has brought to our national forest. Recent tragic shootings in our National Forests have underscored the obvious danger that recreational shooting brings to populated and highly used public areas.

I realize that you want to concentrate the shooting so that it can be regulated and controlled. I know you are going to hear arguments for placing a shooting area in one location or another, and why a specific location is not a good place. This, of course, can be interpreted as NIMBYism. I’m here to present another argument. Rather than “Not in my back yard” how about Not At All, in the Roosevelt or Arapaho National Forests? I propose that there is no longer an appropriate place for recreational shooting OF ANY TYPE anywhere in the forests of B ld C t James Richards We were unable to attend the recent public meetings regarding developing a designated recreational target shooting site in Boulder County. In fact, even though we have a residence within 1/2 mile of one potential site, we only received notification from Boulder County regarding this planning process when we returned from vacation after the July and early August open houses. Please accept our comments via this e-mail. We are strongly opposed to the potential recreational shooting site at Ruby Gulch. The location at Ruby Gulch should be removed from consideration as a designated recreational shooting site for at least the five following reasons. 1. A designated shooting site with greatly increased shooting noise and vehicular traffic is incompatible with the nearly century long history, as well as the continuing mission, of environmental education and research at the University of Colorado Mountain Research Station. Students of all ages and researchers from around the globe come to this location to study many aspects of the mountain environment. The increased noise and disruption of gunshots within less than a mile would be exceptionally disturbing for studies of birds and wildlife in the area. Potential pollution from the smoke and gas emissions from shooting could be damaging to the long-term air sampling at the Station. These direct effects are in addition to the disruption of the wilderness (or wilderness like) environment that is the focus of the educational mission of the Station by the repeated and continuing noise of shooting nearby. In addition, many students and researchers can often be seen in remote locations (off trail) in the forests, meadows, and ridges around the station where they would be exposed to stray bullets or ricochets. Safety of students and researchers should not be compromised by siting a designated shooting area at Ruby Gulch. 2. An area of one mile radius around the potential Ruby Gulch site includes approximately two miles of the Peak to Peak highway and scenic corridor. Many people use this corridor for enjoyment of the mountain environment, both visually as well as to enjoy the peace and quiet of the mountains. This would be severely disrupted by continuous shooting that often occurs at popular managed shooting areas. Hikers, walkers, flower-lookers, bikers, photographers, and many others use this corridor for activities year round, but especially during the summer and fall seasons when the shooting site would likely have high use. People moving along the corridor would also be exposed to potential dangers of stray shots and ricochets. At least one mile of Gold Hill Rd is also very close to the site and this road traverses closer than ¼ mi from the site location. 3. Like the Peak to Peak highway, the Sourdough Trail has a significant section that is within the mile radius and thus hikers, mountain bikers, and skiers, among others, would be exposed to the noise, disruptions, and potential dangers of the shooting site at Ruby Gulch. In addition there are significant areas of Boulder County Open space within short distance of the site. Public use of these open spaces, now or in the future, would be severely compromised by a shooting area at Ruby Gulch. 4. At the Ruby Gulch location there are many beautiful meadow and open forest areas now used for dispersed camping and picnicking in the National Forest. Siting a shooting range in that Gulch would make these uses untenable. Would you want to camp with your family and children in an area so close to the noise and potential dangers of being essentially right next to a shooting range? These current uses of this b tif l ld b li i t d Thi i t j t l h b t h it i ti d d f t d th t d t i l b Allison Louthan I am a student at CU-Boulder who uses the Mountain Research Site at Niwot Ridge for research projects. The Mountain Research Site is used by up to 100 students (including K12 through graduate students like myself), as well as researchers and staff. One of the proposed Boulder County sites for a concentrated shooting range is Ruby Gulch, which is located very close to this Research Station. I do not support using Ruby Gulch as a shooting location, as it will have negative impacts on both educational and research objectives of children, graduate students, and scientific projects, as well as will affect animal behavior near the Research Site, which is an active area of research at this Site. In addition, the shooting range will likely increase foot traffic to this area, negatively impacting the research and educational opportunities at this site.

Will Dator We do not want shooting ranges up in our pristine wilderness areas. These areas are reserved for wildlife and for people that want to camp and enjoy the forest. Why add a noisy and not compatible sport to these wilderness areas. We are already the largest emergency service area, with the least amount of funds and volunteers. Don't give us more problems to respond too. We live up here to get away from the city and not be part of the noise and confusion of Boulder. We also struggle to live up here, and work harder than most to carve out a home and living at 9000'. Please keep your shooting ranges closer to the people that want to use them; and closer to the noise and confusion that's already down there. Check out Park City Utah , they just built a awesome indoor shooting range right outside the city limits. You can shoot any kind of gun in there

Courtney Meier I am writing to say I do not support the creation of a recreational shooting area in the Ruby Gulch area of Boulder County. The Ruby Gulch area is less than 1 mile from the Niwot Ridge Biosphere Reserve where I conduct scientific research during the summer, and there is nothing to prevent an irresponsibly fired bullet originating from Ruby Gulch from reaching Niwot Ridge. There are over 100 students, staff, and researchers who work at Niwot Ridge, and the proximity of the proposed Ruby Gulch site is troubling.

More generally, I strongly believe the National Forests should be managed for the greatest good of the *most* people. Recreational shooting, while perhaps physically occupying a relatively small space for the shooters and their targets, takes a up a disproportionate amount of space due to the noise and distance that stray bullets can travel, and greatly compromises the outdoors experience for hikers, backpackers, hunters, and anyone else who doesn't want to fear for their safety while enjoying the outdoors. I do not believe the rest of the public should have to deal with this nuisance, and I do not believe that recreational shooting is an appropriate activity within National Forests. In my mind, hunting is another matter entirely, as the number of bullets discharged is much smaller compared to recreational shooting, and the risks are therefore much reduced. Laura Backus Ruby Gulch, less than 1 mile from the University of Colorado Mountain Research Station and Biosphere Reserve, is a highly inappropriate site for a designated shooting range: - The Mountain Research Station has permanent summer residents as well as numerous visitors who would be at risk from stray bullets. - The noise and habitat disruption from a shooting range would change the behavior of animals in study projects as well as greatly reduce the quality of visitor experience and limit areas safe for study. Martha Dick The proposed shooting range in Ruby Gulch is a poorly thought out concept. This area has a 90 year history as a site for researchers in the area. Many of their study projects would be adversely impacted by gunshots in the vicinity. And the possibility of stray bullets could prevent excellent researchers from establishing their studies in the area. please reconsider this site. Mark Johns As a property owner near the Ruby Gulch area, not to mention a citizen of Boulder County, I am absolutely opposed to the siting of a shooting range in the Ruby Gulch area specifically, and anywhere else in Boulder County, in general. One only has to look at the disaster of the Lefthand experience to get sense of what Ruby Gulch will turn into.

While there are many responsible gun enthusiasts out there that would always try do the right thing at a shooting range, there are also enough people out there with guns that have no business owning one, and it's those individuals that ruin it for everyone; again, Lefthand Canyon as a case in point.

Please do not approve Ruby Gulch or any other shooting range within Boulder County. Dean Rundle I come to this process late, and regret being first unaware of, and then unable to attend, the recent meetings in Nederland and Allens Park. First, I want to commend the partner State and Federal agencies and local governments of the Northern Front Range Recreational Sport Shooting Management Partnership for tackling this important issues. As a retired federal land manager with over 33 years in the National Wildlife Refuge System, I am completely aware and empathetic with the complexity of this public process and the challenges faced by USFS decision-makers and elected officials of the represented counties. As a sportsman and hunter I am also really tired of driving to Hot Sulfur Springs, Hayden, Summit County dump in Keystone, or fighting the traffic to Cherry Creek State Park whenever I need to sight-in a rifle, or test some new recipe hand-loads. There is nothing that Boulder County needs more than several designated public shooting ranges.

Hence, I applaud the purpose of the NFRRSSMP, and look forward to working in the public process to succeed in the goal of providing good, safe places to shoot in each county.

I quickly reviewed the USFS map in the Forest Plan Amendment proposal, and it appears that within Boulder and Gilpin Counties, the proposal would ban dispersed RSS on all National Forest Lands except within the Indian Peaks Wilderness. I like to do my range shooting from a bench on measured ranges and have not personally engaged in recreational "plinking" in dispersed areas of the NF. However, I understand the desire of other shooters to engage in that type of shooting. If, for safety reasons, it is truly necessary to ban dispersed shooting in all non-wilderness areas of NF lands in Boulder and Gilpin, then I believe the goal should be to provide not one, but 3 designated shooting areas in Boulder County. One area should be north of Ward, one south of Ward, and we frankly need a range in Boulder County that is not in the mountains. We need a place to shoot during the winter when snow is too deep over 8,000 feet.

Prior to it's closure several years ago, I regularly shot at the Allen's Park dump site near the intersection of Hwy 7 and 72. I understand that is one site under consideration, and recommend that it would be a good site for a real range. We need ranges equivalent with the Div. of Parks and Wildlife ranges at Hayden, along U.S. 40 between Hot Sulfur Springs and Kremmling, or the one just east of La Junta along the Arkansas River. With proper berms, the Allen's Park site is a good one, although I acknowledge that engineering adequate and safe parking will be a challenge. If the dispersed shooting is banned, the Partnership is going to have to provide sufficient parking at any designated sites.

That parking issue is one reason that I've always thought that the area just south of the large parking lot at the south end of the Sourdough Trail, off the Rainbow Lakes Road and north of Caribou Ranch would be a good spot for a range. There's a bench that is mostly lodgepole just off the parking lot before you drop off into the wetland riparian areas along the creek that might be large enough for a 100 yd. range. The site ld b i ht ff th ki d ld d b If h f 100 d t Ch C k St t P k ld Thomas Veblen I would like to comment on the proposal to create a designated shooting area at Ruby Gulch in Boulder County.

I oppose this proposal because the location is less than a mile from the University of Colorado’s Mountain Research Station where I have taught classes and led field trips since 1982.

Each year during the summer and early fall I take groups of CU students to the Mountain Research Station to conduct research involving dispersed sampling of vegetation over extensive areas surrounding the Station. Given the lack of a topographic barrier between the Ruby Ridge site and much of the area used for our research, location of a shooting range at Ruby Ridge would create a hazard for students and others conducting fieldwork near the Station. In addition to the life threatening hazard, the location of a shooting range so close to the Station is incompatible with some of our research and educational objectives such as making bird counts.

CU’s Mountain Research Station is one of Colorado’s most prestigious scientific resources with more than 90 year history of research and educational activities. It attracts more than $3 million in federal research funding in a highly competitive funding environment. Many researchers from out of state who currently select the CU Mountain Research Station to conduct their federally funded research in the future easily could base their research at competing field research stations elsewhere in the Rocky Mountains if they perceive a high risk to their students and staff due to proximity to a shooting range.

I strongly encourage you to not approve the location of a shooting range at Ruby Gulch. Brett Melbourne I am writing to express my concern about the proposed Recreational Sports Shooting (RSS) site at Ruby Gulch. This site is less than a mile from the University of Colorado Mountain Research Station (MRS), a significant national research and education facility. The research station is part of the Niwot Ridge USFS-UNESCO Biosphere Reserve and, as such, locating a shooting range at Ruby Gulch is inconsistent with the existing forest plan. A shooting range at Ruby Gulch would have a significant impact on Niwot Ridge and the MRS in a number of ways. First, the MRS typically is host to a population of up to 100 students, including K12 through graduate students, and researchers. An RSS site at Ruby Gulch would thus significantly impact on the environmental education experience of a large number of students of all ages, both through noise pollution and the simple fear response that gunshots trigger in children. Second, an RSS site at Ruby Gulch would significantly impact wildlife in this area by altering their behavior, thus also impacting studies of wildlife conducted from the MRS. Third, it is inappropriate to locate the RSS near a research site that brings in $3 million dollars in Federally funded research each year. It is not clear that the Ruby Gulch RSS site would not impact on this nationally significant research effort such as through changes in behavior of wildlife. I welcome the proposal to provide a venue for recreational shooters but Ruby Gulch is not an appropriate location. Mark Correll Please oppose the proposed shooting ranges at the former Allenspark dumpsite and on Bunce School Road. My family has owned property for 48 years at 525 Big John Road, adjacent to the Big John Mountain wildlife corridor and 1-2 miles from each site.

A formalized shooting facility would fundamentally change the environment by concentrating and popularizing shooting at a single site. When assault rifles are fired repeatedly through a magazine of a dozen bullets, it sounds like a war zone. This loud and prolonged noise would severely impact the Big John wildlife corridor.

This kind of noise belongs in a more industrialized area, not in a wildlife habitat. I believe many of the shooters are mostly interested in practicing with their weapons, and an enclosed shooting facility closer to home would serve their needs just as well. Bob Snell I live on Riverside drive in the heart of Raymond / Riverside area and within 5/8 of a mile of two of the five Sports Shooting Partners and US Forest Service proposed shooting sites. These are the Allenspark Dumpsite and the Bunce School road sites. I am quite familiar with shooting at these because our property has been our vacation home since 1971 and our full time residence since 2004.

Shooting is inherently dangerous and invasive. Because of these basic facts it is incumbent upon shooters to act responsibly and courteously. Responsible shooting was the case in our area for decades thus shooting was not an issue until eight to ten years ago. Reasons for this decline can be debated but the primary cause is a dramatic increase in shooting. Thankfully the problem is finally recognized by the various government agencies and this is appreciated.

Because too many shooters do not accept responsibility it is the obligation of any site developer and manager to accept this responsibility and insure the shooters actions are safe and appropriate. Hopefully this is fully understood by the Sports Shooting Partners various agencies whether working as a group or independently.

The Boulder County Land Use department is developing parameters to apply to the development of defined shooting sites. There are two significant deficiencies in their Preliminary Criteria document which I request be modified.

Items 1 and 2 – Distance from municipalities 1 mile, subdivions/ townsites ½ mile, single homes ¼ mile.

For this subject there is not a practical difference between municipalities and subdivisions or townsites except municipalities have local representation. In round numbers there are 200 homes within two miles of the Allenspark Dumpsite, 100 within one mile with many of those near the ½ mile mark. For the homeowners within the one mile circle this differentiation is inherently descrimitory. Why would Jamestown or Ward have significantly more protection than the similarly sized Raymond / Riverside townsite? Because they have a Mayor and we don't? Safety and noise are exactly the same no mater the level of government jurisdiction.

As mentioned above I have significant practical, common sense experience with noise created by shooting. One half mile or less from a designated site is not nearly enough and any finite distance does not properly address the problem because distance is only one factor. Topography, surface conditions, humidity and other items all contribute. For example the Allenspark Dumpsite is literally on top of a mountain providing zero absorption of noise throughout the area. Add this to large outcrops of stone on opposing mountains reflecting the sound and we bj t t " lti l " h t h l i fi d Thi ff t i ti bl i d d i th l h id th d t d d i Barbara Baring I hope you have had many emails for people like me who wonder what more it will take to convince everyone that dispersed and designated shooting ranges should not be allowed in areas like Allenspark, CO. Please see my attached letter and vote/act against recreational shooting of any kind, anywhere. Thank you. Barbara Baring SHOOTING RANGE SPARKS 500-ACRE FIRE Target practice at a public shooting range in Grand County sparked a wildfire Monday that has burned more than 500 acres. The fire started at about noon at the Byers Canyon Shooting Range, according to the Grand County Sheriff's Office. The shooting range is operated by Colorado Parks and Wildlife. By early evening, the Byers Range fire had burned 568 acres as it moved west, according to a sheriff's office media release. One residence was evacuated, but there were no reports of injuries. At about 8:45 p.m. the fire was 70 percent contained. No other structures are threatened. Firefighters were aided by air support out of Grand Junction, and six slurry loads were dropped on the blaze. U.S. 40 was closed east of Hot Sulphur Springs because of the fire, the sheriff's office said. Denver Post, August 25, 2015 Jeffry Mitton As a biologist who is conducting research for his 42 year at the University of Colorado’s Mountain Research Station, I am vehemently opposed to the idea of establishing a shooting range in Ruby Gulch, less than one mile from our research area.

The Mountain Research Station was established as the Science Lodge and Science Camp in 1920, and it has served University of Colorado faculty and students for 95 years. It has never been bigger or my dynamic than now, for it is currently used to introduce K-12 students, CU undergraduate and graduate students, and faculty from across North America, Europe, Russia, etc. The site is a treasure for its research areas are only 26 miles from Boulder but are maintained in conditions that are as close as possible to wilderness.

Research at the MRS comes from CU, Boulder Open Space and Mountain Parks, the National Science Foundation, the Department of Energy and National Oceanic and Atmospheric Administration and Colorado State Forest Service. It is a Man and the Biosphere Site, an NSF Long Term Ecological Research site, and it hosts an Ameriflux Tower Site. Students live at the Mountain Research Station all summer, and meetings are held at the site during the academic year.

The noise from a shooting site at Ruby Ridge would probably alter the behavior of large animals such as moose, elk and deer, and smaller animals such at the least chipmunk, pine squirrels and a variety of bird species. The noise would substantially deteriorate the experience of working at the site, and parents of students from K-12 through high school would justifiably be worried about safety.

Would we entertain the notion of establishing a shooting range within earshot of Rocky Mountain National Park? I don’t think so. But Ruby Gulch is essentially adjacent to a treasured research site and just a little further from the Indian Peaks Wilderness. The idea of establishing a shooting area in Ruby Gulch is a terrible idea. Mark Franzen From a public safety and noise standpoint this is not a good choice for a rec. shooting area. We can hear shooting quite clearly in Raymond from this site (yes, there is still shooting going on there, but not as much as in the past). A good shooting area needs to be supervised and could be operated for a fee by a private sector provider or non-profit. A good example is the shooting area at Cherry Creek State Park. We'll look forward to continued progress on this issue. Kent Wolcott We are writing to express our opposition to the proposed Ruby Gulch shooting range. Since 1968, we are property owners on Gold Hill Road, 1 mile east of the Peak-to-Peak Highway. We bought here in 1968 to be able to enjoy peace, quiet, and hiking in the mountains on and around our property. The proposed shooting range would be located within 1 mile of our property---and probably closer. We have received no official information regarding the proposed Ruby Gulch site and only recently received notification via a 29 July letter from a concerned neighbor. Therefore, we have been unable to attend any of the recent open houses on this matter.

Due to excessive noise and safety considerations (gunfire noise resonating throughout the mountains and the distance that bullets can fly), we are opposed to the possible Ruby Gulch designated shooting range location. Additionally, we are concerned about how the site would be policed/controlled and the hours of operation—should this site location be approved. Charlotte Sorenson My husband, Bud Sorenson, and I are Boulder residents and we have spent twenty plus years recreating along the Scenic Peak to Peak Highway and particularly in the Ruby Gulch, Glacier Lake, Niwot Ridge areas. We would like to take this opportunity to comment on the USFS's two-part plan regarding shooting sports in Boulder County.

First, thank you, thank you for putting forth your proposal to close much of the Arapaho Roosevelt Forest that is east of the Peak to Peak to "dispersed" shooting. In the decades that we have spent hiking and camping in the mountains along there, we have witnessed a marked increase in gunfire in all kinds of random spots in the forest. It is our firm conviction that the current levels (and seemingly ever increasing) of "dispersed" shooting pose unacceptable threats to personal safety, wildfire, and all other non-shooting forms of recreation. We applaud your office for pursuing an end to "dispersed" shooting east of the Peak to Peak, where there are so many private homes, so much personal property, and so many more folks interested in recreating in ways that do not involve a weapon.

We understand that to even get to this point in the process, you and your team have had to undergo years of negotiation. We also understand that the USFS is likely under extraordinary (and we would say, unconscionable) pressure from the NRA and Second Amendment zealots not to close any land to "dispersed" shooting. However, at this point the valid safety concerns of the mountain residents and non-shooting recreationists should outweigh the desires of gun enthusiasts to have all public lands always open to them. It seems to us, that while we always hear protests from responsible gun users that their shooting opportunities should not be curtailed because of the negative actions of the irresponsible shooters, the reality is that the irresponsible users have increased in number and impact and indeed caused the public to lose faith in shooters, in general.

Second, while we understand that your office has as a goal of the Sport Shooting Partners program that each of the four involved counties propose a spot for a "designated" shooting range, we urge you to proceed with the proposal to end "dispersed" shooting separate from whether or not Boulder County (and the others) are able to meet the goal of proposing a "designated" site that is acceptable to the county. There should not be a "quid pro quo". If the USFS has determined, as we also believe, that "dispersed" shooting should no longer be legal in the heavily used and populated regions east of the Scenic Peak to Peak Byway, then it should effect the closure, whether or not Boulder County has been able to identify a "designated" shooting site anytime soon.

We are aware that Ruby Gulch is one of five/six sites in Boulder County that the three Boulder County Representatives have put forth as a possible "designated" shooting site. It strikes us that placing a "designated" shooting site along a Scenic Byway, adjacent to a federally funded ildlif d i t l h t ti i th h t f ildlif i ti id d i t th t ill b bj t t l d t i it Dan Nelson I own property at 436 reindeer drive in Ward CO I spend my summers there. Since our property abuts the Boy Scouts property we are exposed to gunfire at there shooting range. It is very disturbing to me, my family, and our guests. The explosions are not a natural part of the environment. Hearing the gunshots ruins our peace and quiet which is what we come here for. I feel that the proposed firing range on beaver reservoir road will cause similar angst for us considering we are within the outer ring on your map and will hear the gunshots. It will also diminish my property values since only the people shooting will be the ones enjoying it, the rest will suffer. I don't feel this to be an appropriate location for an outdoor shooting range. It seems reasonable that it should be incumbent upon the people who are shooting to take responsibility for the intrusion upon the community of people and wildlife with there noise pollution. I realize that an enclosed structure would be a substantial investment, yet it would solve many of the issues, and the users could pay a fee to use the facilities, thereby financing the facility they use. If such a structure was to be built, and paid for by the users, the proposed shooting range would fit seamlessly almost anywhere, including Beaver reservoir Rd. Dave Osborne PLEASE PROTECT US. The Allenspark Dump Site must be closed permanently and removed from your list as a "designated" shooting area, for our safety and for the protection of our mental health. The site is totally unsuitable. It does not meet the necessary criteria for a safe shooting location. It is too small. There are 9 residences within 1/2 mile of the site and over 100 within one mile. We and neighbors living within 1/4 mile have reported over 40 near misses to Sheriff Pelle. A deputy, on our property, has had two. A 45 cal bullet was recently retrieved from my neighbor's roof. The dumpsite along hwy 7 experiences extremely heavy traffic by motorists, bikers and cyclists. All are at risk of being shot. Road workers from Aggregate Industries have had to "hit the dirt".

Buried lead, phosphorous, Mercury and Arsenic, disturbed by the recent flooding still pose a threat to our water quality and health, more so now if the area is disturbed by heavy machinery.

The only way we can protect ourselves, our friends and family from harm is to have the Allenspark Dump Site PERMANENTLY CLOSED to recreational shooting and removed from your list as a proposed "designated" shooting area. What about other areas like Button Rock Reservoir and Johnny Park? You make no mention of these areas. Dean Rundle I come to this process late, and regret being first unaware of, and then unable to attend, the recent meetings in Nederland and Allens Park. First, I want to commend the partner State and Federal agencies and local governments of the Northern Front Range Recreational Sport Shooting Management Partnership for tackling this important issues. As a retired federal land manager with over 33 years in the National Wildlife Refuge System, I am completely aware and empathetic with the complexity of this public process and the challenges faced by USFS decision-makers and elected officials of the represented counties. As a sportsman and hunter I am also really tired of driving to Hot Sulfur Springs, Hayden, Summit County dump in Keystone, or fighting the traffic to Cherry Creek State Park whenever I need to sight-in a rifle, or test some new recipe hand-loads. There is nothing that Boulder County needs more than several designated public shooting ranges.

Hence, I applaud the purpose of the NFRRSSMP, and look forward to working in the public process to succeed in the goal of providing good, safe places to shoot in each county.

I oppose this proposal because the location is less than a mile from the University of Colorado’s Mountain Research Station where I have taught classes and led field trips since 1982.

I strongly encourage you to not approve the location of a shooting range at Ruby Gulch. Brett Melbourne I am writing to express my concern about the proposed Recreational Sports Shooting (RSS) site at Ruby Gulch. This site is less than a mile from the University of Colorado Mountain Research Station (MRS), a significant national research and education facility. The research station is part of the Niwot Ridge USFS-UNESCO Biosphere Reserve and, as such, locating a shooting range at Ruby Gulch is inconsistent with the existing forest plan. A shooting range at Ruby Gulch would have a significant impact on Niwot Ridge and the MRS in a number of ways. First, the MRS typically is host to a population of up to 100 students, including K12 through graduate students, and researchers. An RSS site at Ruby Gulch would thus significantly impact on the environmental education experience of a large number of students of all ages, both through noise pollution and the simple fear response that gunshots trigger in children. Second, an RSS site at Ruby Gulch would significantly impact wildlife in this area by altering their behavior, thus also impacting studies of wildlife conducted from the MRS. Third, it is inappropriate to locate the RSS near a research site that brings in $3 million dollars in Federally funded research each year. It is not clear that the Ruby Gulch RSS site would not impact on this nationally significant research effort such as through changes in behavior of wildlife. I welcome the proposal to provide a venue for recreational shooters but Ruby Gulch is not an appropriate location. Clare Wall Natives of Colorado since 1880, my family came into the mountains from Longmont just after Rocky Mountain National Park was created, and built a summer cabin in Raymond. From Spring through Fall, we have treasured the sounds of the Middle St.Vrain Creek, the wind in the trees and birdsong for nearly a hundred years. Nothing disturbed our quiet.

But on a typical day in 2015--such as last Sunday September 6--we now hear gunfire from the north and northwest continuing throughout the days, and even into the darkness. Last Sunday, shooting began at 7 AM. I'm not certain where the shooters were, but whether they were in the Old Dump or near Bunce School House, their firing echoed through the canyon, and through our nerves, for the entire day. This noise was not from hunting, of course. That sound would be supportable, for it would be seasonal and useful. But now, this dreadful phenomenon, the so- called "recreational shooting", is making our peaceful canyon retreat into a frustrating and unnerving urban war zone. I am familiar with the sound of gunfire in city streets, for I have lived in central Fresno California for 3 decades. But I never thought that Boulder County would countenance or encourage turning the mountains into such an unsettling and violent environment. I never heard gunfire for my first 55 years up here in the mountains--why should it be accepted and accommodated now?

Clearly, I am ABSOLUTELY NOT in favor of setting up ANY sort of gun range within the close proximity of Raymond, Riverside, Allenspark, or Nederland. We do not come to the mountains to be traumatized. Has anyone begun to consider what effect this barrage of sound has on our veterans? Our elders? Our children? Surely an indoor range, or one far, far from the settled communities of the foothills, would be preferable. A range within one quarter mile of homes is obscenely close, and even within one mile, the percussive sound of gunfire carries far in our clear air.

I hope that before the decision is made that each voting bloc member spend one whole day listening to a loud recording of constant and various gunfire, from 7 AM to 7 PM, as they go about their regular lives, in order to understand why we object so strongly to the site plans before us. If we had wanted such a life, we would never have wanted to be in the mountains. This is a moment when the famous Boulder County regulations could work to preserve the mountains and their inhabitants, rather than those whose sport could be accomplished just as easily on the flatlands (such as the Lyons gravel pit?), and indoors. A shooter does not require birdsong and murmuring trees--we do. Brent Andrews My name is Brent Andrews, a resident of Glacier Lake. I would like to offer the following comments and observations on the process so far. Needless to say, I am opposed to the selection of Ruby Gulch as a site; it's extremely hard to imagine that any noise mitigation technologies could reduce the noise pollution coming from a site so nearby to a tolerable level at Glacier Lake. Adding the additional noise impacts to other nearby residents special use facilities, and the other risks of safety, fire, and watershed pollution associated with this site, all of which have been commented upon at length already, would seem to make it fairly self-evident that it is not at all suitable.

But beyond the site specific issues revolving around Ruby Gulch, I would also like to express my opposition to siting such a facility anywhere along the Peak to Peak Scenic Byway.

In reading the management plan for the scenic byway I found the following language:

Tourism Management – Strategy Component 3: Encourage visitors to experience the landscape and the place and to be "invisible visitors". Encourage small experiences.

Tourism Management – Strategy Component 7: Adopt a set of criteria for the type of tourism activities that compliment the Plan (eg must be educational, low environmental impact on landscape, should move people through awareness- understanding-appreciation-protection spectrum)

Locating a shooting range on, or in the immediate vicinity of the Byway would seem to be not only inconsistent with, but antithetical to these guidelines, in particular the guideline of visitors being "invisible". While most of the plan revolves around management of visual impacts to the experience of the Byway, it goes without saying that visitors (and residents) stop frequently along the Byway to enjoy and photograph the many scenic vistas to be found along it. The second they do, they then enter the 'soundscape' of the Byway. A large and growing literature documents the importance of the soundscape to the enjoyment of landscapes. Locating a shooting range anywhere along [ie within earshot of] the Peak to Peak Byway will mean that the experience will then be degraded by the noise pollution associated with such a facility. Again, I discount the potential for noise mitigation technologies (whatever those may be, short of bringing the facility indoors into a fully sound-proofed building) to prevent this impact.

I would add that given the importance of the Byway, that I was surprised when reviewing the planning process documentation that its exclusion t i t i t i th i iti l li i it bilit t d it i i li ht f th b I t d h l it it t d l Dave Pinkow Thank you for requesting public comment on the Proposed Forest Plan Direction, published July 10, 2015. I am the owner of property on CO Highway 7, a few hundred feet from the Peak-to Peak Highway and contiguous to a USFS parcel known as the old Allenspark dump site. Below are some comments and observations I have on the USFS proposed Forest Plan Amendment:

While it makes good sense restrict "dispersed shooting" from occurring in a Forest such as ARP, identification of the old Allenspark dump site as a designated shooting area is inappropriate and contrary to the USFS goals and objectives.

The USFS has referred to the old Allenspark dump site as "an isolated parcel," which is true only in the sense that the parcel is isolated from other USFS holdings. The old dump site is not isolated from human activity--there are in fact 100 homes within a 1 mile radius and hundreds more within 2 miles. The ¼ mile by ½ mile Forest Service holding is completely surrounded by private land and homes, several of which are located directly down range of the planned shooting venue. Those down-range neighbors documented and reported over 45 near misses of errant projectiles in the months prior to the emergency closing of the Allenspark dump site in 2010 for reasons of safety. The USFS should not surmise this is a safe location simply because there have been no complaints of errant bullets in the past five years. The paucity of errant bullets is the result of the site's very appropriate closure to recreational shooting, not from any attribute derived from worthiness as a sportshooting venue.

Furthermore, proposed location of a recreational shooting facilityon the property would be dangerously close to Colorado State Highway 7. The US Forest Service plan for this proposed shooting site calls for shooting stations no more than 200 feet from this very busy state highway, which by any rational definition would be regarded as "an occupied area" (proximity to which for shooting is prohibited by USFS regulations). Further, the concept plan for this venue shows a series of firing stations aiming directly toward said highway.

While the USFS seeks to recognize recreational sport-shooting as a viable sport, RSS is an activity that precludes nearly all other uses of nearby lands (public and private). Dangers of ricochets, errant bullets and accidental discharges are unavoidable. Only a very expensive and sophisticated baffling system, shooting station construction, bullet trap and other safety features could begin to add a dimension of safety to this site. Even then, with the proximity of the State Highway and homes directly down range, a reasonable level of safety is doubtful.

The USFS must consider the impact its Forest Plan will have on nearby communities, private property and nearby residents. Noise is an important consideration. Excessive noise generated by the proposed shooting venue at the old Allenspark dump site will greatly exceed any bl t d d f i ll ti Thi ld l i t l t b l d i th illi f d ll t t Sarah Albertson Dear Forest Service and Sportshooting Partners, Regarding your Forest Plan Direction, I absolutely am opposed to the re-establishment of sport shooting at the old Allenspark dump site. People and firearms don’t mix. There is too much chance of a tragedy at the old dump site as a shooting range. And the noise ordinances prohibit it as well. I have a family cabin adjacent to the Roosevelt National Forest near Allenspark. It has been in our family since 1955. I am also opposed to fire arms being allowed in open spaces in the National Forest. We hear guns being fired all the time when we are at our cabin. What is to prevent those bullets from hitting a hiker within the forest? Let the guns be allowed IN A BUILDING out on the flatlands. Scott Hardesty This “official” comment is in response to face-to-face and telephone conversations with you over the past couple of months.

My family have been citizens of Boulder County for over 60 years, with 50 of those spent living in the foothills. Throughout this time, we have actively participated in most of the outdoor sports available to local residents- hiking, fishing, hunting, camping, mountain biking, 4x4ing, rock climbing, show shoeing and cross county skiing. One of our most cherished family traditions is the ability to find a location in the local National Forest suitable for dispersed shooting and enjoy some light target practice firing at some paper targets or assorted pop cans on a dirt embankment or tailings pile. We have ALWAYS conducted ourselves in a safe, responsible and lawful manner, including picking-up more trash than we brought-in to improve the area. We do NOT appreciate the tone taken by many in the anti-shooting, anti-gun community who take pride in labeling all National Forest shooters as morons and reckless slobs.

We strongly DISAPPROVE of the current proposed plan to restrict dispersed shooting for essentially all non-wilderness National Forest areas in Boulder and Gilpin counties. The establishment of a very limited number of designated shooting sites does not compensate for the loss of thousands of acres of previously permitted property. These designated sites, while suitable for some recreational shooters, will not meet the needs of ALL citizens. Imagine trying to teach your young child how to ride a bike in the middle of a mountain bike park on a sunny Saturday afternoon, or an established racing track during Olympic trials. The same applies to designated sites- it does not work to combine all shooters together regardless of skill, equipment or desired type of marksmanship practice. We do support the creation of some designated sites, but making those the ONLY option for shooting is unacceptable to our family, and thousands of other local shooters whose tax dollars pay for the National Forest program.

We understand that there are certain, LIMITED, areas of National Forest property that are unsuitable for shooting. Such areas may include locations in immediate proximity to mountain neighborhoods (like Suagrloaf or Magnolia), or well establish recreation areas (like Brainard Lake). We have been on the receiving end of unwanted projectiles on at least three occasions, and understand the fear present in such a situation. However, an essentially blanket prohibition of dispersed shooting in any accessible areas of Boulder and Gilpin Counties is too extreme. It is unclear how areas in other counties, such as Clear Creek, with similar concentrations of private property co-mingled with National Forest property, are still indicated as being open to dispersed shooting, but large unpopulated regions in Boulder County, like southeast of Raymond, would be prohibited. It is apparent that the software and subjective selection criteria in this proposed program were far too restrictive, and eliminated areas that are still very suitable, perhaps with a bit of tweaking. Such areas include, but are definitely not limited to:

L L fth d C (Th “ ld” h ti th t tili d f d d b MANY Cit f B ld id t ) Paul Burkhouse I am writing in response to the Scoping Request for the Arapahoe and Roosevelt National Forest Recreational Sport Shooting Project.

First and foremost, I am adamantly opposed to re-opening the Dumpsite in Allenspark as a designated shooting area in any form for the following reasons:

1. It is unsafe. There are too many homes within ½ mile and 1 mile. I have personally experienced near misses when visiting family and friends who live within that range. The fact that there are homes within ½ mile should automatically eliminate it as a “suitable” location for a shooting range. I believe this is reasonable especially as firearms that shoot ammunition 2-3 miles are used.

2. It would be prohibitively costly and disruptive to develop the Allenspark Dumpsite to an acceptable level of safety and I seriously question whether that is even possible given the particular considerations of the site (terrain, proximity of homes, proximity of traffic, bikers, etc. and the environmental concerns around disturbing the longtime unregulated dumpsite.

I understand some people want a place for recreational shooting. I do NOT understand how their wants and wishes should be valued over local people’s (tax payers, constituents…) quality of life, safety and other visitors’ enjoyment of the area.

Recreational shooting is not compatible with many other activities traditional in public areas, and is certainly not compatible within ½ or 1 mile of private land and homes. I do support some designation of suitable and unsuitable areas for recreational shooting. I suggest a minimum of 1 mile from private homes or other public areas and activities. (And actually, to preserve safety, 3 miles would be most appropriate based on firearms used.)

Finally, let’s face it, not all firearms users are responsible. Users of the Dumpsite in Allenspark started a costly wildfire a few years ago, and do not collect their shell casings. I have even heard reports of observed unsafe and threatening activity there. Because that behavior has been demonstrated and firearms are lethal, very strict guidelines need to be in place to protect the public and allow folks to pursue their hobby in a way that does not injure or negatively impact others. Bill Bowman I am providing an addendum to my previous comments regarding the selection site of an organized shooting range in Boulder County.

1. The purpose of the dispersed shooting ban and establishment of organized shooting ranges is to address the lack of inclusion of shooting regulations in the 1997 Arapaho & Roosevelt National Forest plan. The A&R National Forest Plan does include a provision for special regulations in the Niwot Ridge Biosphere Reserve, recognizing the important legacy of this area for environmental research and education. University and Federal scientists, K12 teachers, and many others have been using this area for research and education form over six decades. The placement of a dispersed shooting range at Ruby Gulch, in close proximity to the Niwot Ridge Biosphere Reserve would therefore directly contradict and compromise the existing Forest Plan.

2. Additional consideration of the proposed five sites along the Peak to Peak Highway suggest none of these are a viable site for an organized shooting range. The negative impacts on the local communities, tourist economy, and wildlife far outweigh any benefit to a minority of users. While the construction of berms has been suggested as a way to mitigate noise and safety concerns, the success of these berms can't be known until they are constructed. This is not an acceptable mitigation plan. It is therefore incumbent on the Boulder County Commissioners to seek additional alternative sites where the impact of the shooting range is not as great as the five alternatives located along the Peak to Peak Highway. Alice Osborne I am gravely concerned about the threat of the Allenspark Dumpsite being opened as a designated shooting range. It was closed in 2010 for reasons of safety. It should not be reopened. There is no way to make it safe. To be clear, I strongly oppose the Allenspark Dumpsite as a designated shooting range.

Before the temporary closure, my husband and l had 21 near misses on our property. We and our near neighbors have homes within 1/2 mile down range (up hill) from the dumpsite. There was a total of over 40 near misses in the neighborhood. A deputy sheriff had three near misses on our property.

Recently a neighbor found a bullet embedded in the roof of his home. He lives more than 1/2 from the dumpsite. A deputy sheriff determined that the bullet came from the direction of the dumpsite. His home is very close to Hwy. 7.

The one half mile criteria is seriously flawed. There are over one hundred homes within one mile of the proposed range. The small acerage of national forest land is surrounded by private property. There are over 6.8 miles of paved roads within one mile. The weapons used by shooters have ranges up to three miles. The dumpsite is not a safe place for shooting no matter what mitigation is put in place.

I also strenuously object to the horrendous noise of shooting from the dumpsite. Sound reverberates in the mountains causing our peaceful, quiet environment to be destroyed. Our quality of life is gone. Wildlife in the surrounding mountains and meadows disappears.

Our home is 21 years old. We built it for ourselves in retirement and for future generations in our family. Many of the tiny cabins tucked away in this area were built more than 100 years ago and more.

Does recreational sport shooting supersede the rights of families to live in a safe, quiet environment? I THINK NOT!!!! Stuart Bernstein We are writing to express our concerns about the shooting range proposed for slightly over one-half mile from our home in the foothills of Boulder County.

Our family moved to this location for solitude, quiet, clean air and water, and nature. This has become increasingly challenging. We've built a berm and a fence, but traffic continues to rapidly increase. Were a shooting range installed up the road from us, our quality of life would be destroyed. Already, stranded drivers knock on our door asking for a tow out of a ditch because they were driving too fast on the hairpin turns, or the use of our phone when they discover their cell phones don't work up here. We have had repeated damage to our property from careless drivers who run off the road. They do not hesitate to drive twice the speed of the 25mph limit, kicking up clouds of dust into our living room.

Further concerns include but are not limited to the following: • danger of a stray bullet as we go for walks, or even one reaching our home; • potential fire hazard from superheated bullets--with westbound summer winds, a fire one-half mile away would arrive at our home in a short amount of time; • sound disruption: we are already disturbed by the noise from shooters currently in the surrounding forest; to have multiple shooters in such short distance every day all day, would erase any remaining quiet; • a dramatic decrease in natural wildlife movement, including moose who often live on our property; • lead accumulation in massive quantities, potentially contaminating our groundwater; • decreased property value due to all of the above reasons; • vehicular collisions on a road already inadequate to handle hunters, mountain bikes, hikers, ATVs, dirt bikes, skiers, and campers.

W t th t th B R i it b d f th li t f t ti l h ti Annie Muldrew My husband and I have lived in Riverside since 1982. The interior kitchen walls of our home formed the first homesteaded cabin in our area built in the late 1800s. We have seen many changes over the years, with people coming and going, and especially recent changes due to flood damages and losses. But our Riverside/Raymond areas have come a long way since 9/11/2013.

My concerns about a local outdoor shooting area are listed below. They stem from the point of view of a local resident who lives only a few miles from three of the five proposed shooting sties, well within stray bullet and hearing ranges.

I realize that "shooting has been a part of mountain life" for years way back in history. But times and lifestyles do change. We are seeing many more people on the roads and in the forests enjoying recreational pursuits such as hiking, bicycling, camping, ATVing, fishing, and walking. They love the peace and quiet of the mountains as much as we residents do.

Please consider all the impacts below that would affect all of us up here if an ear-shattering sport shooting venue was put in place so close to us all. Put yourselves in our shoes and reflect on what your feelings would be if one of these sites near your home and/or business was chosen for the shooting enjoyment of only a select few:

>>>Safety issues based on documented "near misses" in the Glacier View neighborhood near the old Allenspark dump site as well as a recent fire started at the outdoor Grand County shooting range near Parshall and the accidental shooting death of an innocent camper in Gilpin County ~ bottom line, live stray bullets can travel long distances into areas not meant to be shot into

>>>Fire safety and monitoring as mentioned in the news of the recent Parshall shooting range fire; we have a lot of standing grasses and dead trees up here that can act as fuel for a devastating fire started by live ammo.

>>>Noise pollution which was not researched by the FS in the local study ~ we would like to continue having our at-home tim be as stress free and quiet as possible without errant gunfire disturbing any of us, our pets, and the wildlife that live up here, too. In years past when informal shooting was going on, it was nerve-wracking even walking Riverside Drive not knowing when a bullet may come down; the noise from the rapid-fire assault rifles made the area feel like a war zone.

Rich Lirtzman I am submitting this email as my comments regarding the proposed Forest Management Plan Direction for recreational sport shooting activities on National Forest System lands.

Specifically I urge that the shooting area which has been used on Left Hand Canyon in Boulder County should NOT be considered a possible designated shooting area.

We live close (3/4 to 1 mile) to the Left Hand Canyon ORV/shooting area, ("LHCSA") which is 3 and 1/2 miles west of US 36 on Left Hand Canyon.

LHCSA is within earshot of hundreds of homes along Olde Stage Road, Left Hand Canyon, Rembrandt Road and much of the Boulder Heights subdivision. Even neighbors along US 36 in the Crestview and Lake of the Pines subdivisions report hearing the booms and popping sound from the constant gunfire.

The unregulated chaos in the LHCSA has caused 6, count them, 6 fires in the area between 2011 and 2012. The Forest Service has examined the cause of those fires and confirmed them to be a direct result of activities in the LHCSA. The cost of fighting those fires and protecting the very nearby homes totals hundreds of thousands if not millions of dollars. This Forest Service Management Plan Direction provides an opportunity to impose some sanity on this source of demonstrated man made fire risk to our lives and massive amounts of property values.

In addition to shooting the area has been used for off road vehicles which create additional fire risk from hot mufflers and sparks which have ignited dry fuels as well. The combination of the shooting and off road use has resulted in a chaotic and horribly unsafe environment , Rules that have been put in place there have been flouted and the Forest Service has acknowledged it does not have sufficient enforcement personnel to monitor compliance with rules. Not designating the area for shooting would go a long way toward eliminating this obvious source of fires.

At a minimum there should be a fee area created there along with the changes in use and practically enforceable regulations the USFGSD itself supported in its own 2006 NEPA review of the area.

This is truly an opportunity for you to prevent another wildfire which history makes clear is nearly certain to occur again here in Boulder County if th i d f h ti Yvonne Short I have viewed the potential Boulder county sites under consideration for RSS and object to ALL mountain site suggestions, Boulder County and elsewhere for the following reasons;

1) By its very nature this is a life threatening "sport" to innocent bystanders within proximity to an RSS site, as we have recently seen from the untimely death in CO. of the grandfather roasting marshmallows catching a stray bullet. We have had many, many near misses of residents in my own area over the years, much more so in recent times. This death could have easily been in our own neighborhood. It could also easily have been prevented! To have this "sport" contained in an area that isn't frequented by so many other activities or wildlife would be the common sense solution. If RSS wish to have a mountain experience no one is stopping them from enjoying it as others do, without guns! We should have resect for the very nature of nature! I have a right to enjoy the nearby trails in our area and elsewhere as much as others, we pay a lot of property taxes in part because of where we live, but I don't go out on trails anywhere near dispersed shooting anymore because of the very real danger of catching a stray bullet, likewise when hunting season starts. RSS are given priority over my rights to safely hike USFS trails in dispersed shooting areas, this is totally unjust. Who is responsible when someone is shot? Such a dangerous "sport" requires more containment so there is no chance any human or wildlife getting killed int the process of RSS"fun."

2) RSS has an added noise pollution factor that needs to be considered in relation to its geographic location. Noise pollution is dramatically increased with mountainous geography, so even if the distance of 1/2 mile from homes or high intensity recreational use is adhered to RSS noise is not generally contained within that area, I speak from experience as I live within a mile or more away from the popular FR359 trailhead. I can attest to very loud shooting over the years from that area for extended periods of time. We and other neighbors have even experienced rapid semi automatic gunfire. On one occasion longer than 15 yrs. ago I heard explosive automatic gunfire, it was far and above the most war zone-like experienceI have ever livd through and very different from semi-automatic gunfire. It went on for more than an hour. Also influencing the noise pollution are weather conditions. it is hard to distinguish sometimes where shooting is taking place as sounds travel in unusual ways up here, but nevertheless it is still shooting noise pollution and goes on sometimes most of a daylight's hrs. depending on how many shooters there are. The natural quiet and solitude of a mountain area is what so many come to experience. Noise pollution from gunfire is better distributed among noisy areas where it won't be out of place; in areas where noisy activities routinely take place like industrial locations or off of nearby highway areas, dirt-bike courses. etc. Realize that wildlife is equally disturbed by gunfire and deserves consideration as their habitat is shrinking with excessive clearcut and patch tti i i USFS H ildlif d i t b RSS? I h 't Seth Patterson As a long time resident of the Olde Stage/Valley Lane area, a retired volunteer firefighter for Lefthand Fire, and a command officer for the same. I saw my fair share of fires started from legal shooting in the Lefthand shooting area. There were also a number of illegal fires started there by almost any manner of ignition you might imagine - testing your flare gun in July, trying out your new tracer rounds in the dark, shooting at stolen acetylene tanks, shooting at abandoned vehicles and then lighting them on fire. There is also the question of conflicts between users in that area. For a time, it was legal to shoot in an area that was directly below a road that was used by the off road vehicle community. Thankfully someone saw that was a catastrophe waiting to happen and some changes to the road plan were made to separate users. With the number of users of our close-in forest areas increasing the chance for human caused wildfire also increases. Since this area has been closed it has given residents of this area some relief from the fires that have frequently occurred there.

The Lefthand shooting area is basically unmonitored, unpatrolled, unmaintained. There is an atmosphere and attitude of some users there that they can do what ever they want there - this used to pervade into the off-roading aspect of use as well but that community became involved with the use of the area and made great strides to turn around that attitude. Though, I am sure there are still some incidences occurring there related to off-roading. The likelihood of getting caught is extremely small even with the increased presence of the one LEO for the forest service and additional BCSO presence. The behavior of users in this area needs to change but it is unlikely it will with a return to shooting under the current circumstances. If you had ever experienced one of the clean-ups hosted by Mile Hi 4-Wheel Club before the closure, and maybe even some years before that, it was truly astounding the amount and variety of shot-up stuff they would haul out of the combined shooting and off- road areas. They would typically fill half a dozen or more large rolloff dumpsters and haul out many abandoned vehicles. This happened on an annual basis for several years, but I think Mile Hi stopped doing their volunteer clean-ups before the closure.

When the area was open to shooting and off-roading, a busy weekend in the canyon could see 200 users in the area in one day. As an emergency services provider it was cause for concern because of the free-for-all attitude. It is surprising to experience this when there is no real evidence of this activity from the road - users typically 4-wheel up into the area day and night. Trying to evacuate this area during a large fire that is moving quickly could be a disaster. It also greatly hinders the ability of responding resources when users are trying to get out during an incident. Sometimes it was just drinking and partying and having an overly zealous group throwing too much of the abundant dry wood on their bonfire - it is not always single user group like sport shooters. You know there is an area above what is called Four-Corners that is called Fireman's Hill for a reason.

The 'shooting area' near the road does serve a group of sport shooters but the amount of peripheral activity in this area needs to be considered b f thi h ld b id d f ib d h ti Nancy Kamin We bought our land in 1979 and built our cabin in 1981. At that time, a friend of ours was living in a trailer managing a sort yard on the former Allenspark dump site. There was no shooting problem then!

Fast forward, and as other shooting sites were closed, the former dump site became a mecca for unsupervised and unsafe shooters. In 2006, a fire at the dump caused by shooters threatened our homes. We were saved by aircraft, a change of wind direction, and a light misty rainfall.

The unsafe shooting grew worse and worse. Chet and I had seven near misses at our cabin in the summer of 2009 and couldn't have our grandchildren there. (Our neighbors the Dowells and the Osbornes, had even more near misses.) People shot semi-automatic weapons and automatic weapons with no regard for near-by homes or the highway. People shot in the middle of the night and shot down trees. As you know, after a deputy sheriff visited one of our neighbors and experienced three near misses himself, the dump was closed to shooting in 2010.

In 2011 the Forest Service issued its EA for a proposed shooting range at the former dump site. The Glacier View Neighbors Association, formed in 2006 after the fire at the dump, filed expert reports opposing the EA.

Our experts demonstrated that the proposed shooting range would still be very unsafe for neighbors of the former dump site; that the sound levels would be unsafe, and that the environmental consequences of building a range on the former dump site with its undoubtedly toxic contents could be horrific. Based on these reports, the mayor of Lyons opposed the proposed range and the Boulder County Commissioners came out against it.

Until this spring, we thought the proposal for a shooting range at the dumpsite was behind us.

We are taken aback by the about-face on the question of shooting at the former dump site. The safety, noise and environmental problems that the GVNA raised have never been addressed.

Indeed, since the 2013 flood, erosion at the former dump site has become more severe. Building berms on the site would be an even more expensive and environmentally dangerous project at this time.

I also would like to comment on the 1/2 mile distance proposed in the Forest Service scoping proposal: the FS believes suitable lands for ti l t h ti ll i l d " f th th h lf il f id ti l bdi i i t t d hi h ti Russ Hullet As property owners on Big John Road and holders of two conservation easements on our land, we would like to comment on the Forest Service plan to prohibit dispersed shooting in the Arapahoe and Roosevelt National Forests within Boulder County, a plan which is contingent upon the construction of a sport shooting range in Boulder County.

While we applaud the Forest Service for the first half of its plan to greatly restrict recreational shooting within populated areas of Boulder County, we do not believe this part of the proposal should be contingent upon building a shooting range for recreational shooters. The move to restrict open shooting on Forest Service land located near private land and residences is overdue. Threats to safety, of fire and the noise encroachment on our right to use our land and homes without the frequent intrusion of gunfire noise is real and documented.

Regarding safety, area residents logged 64 near misses of bullets they could hear passing over their property. Another neighbor found a bullet lodged in their roof, which was verified by the Deputy Sheriff to have come from the direction of the old Allenspark Dump. Although the Allenspark Dump site has been temporarily closed to recreational shooting, it was a legal shooting site under the dispersed shooting regulations, and is currently a proposed site for a shooting range. How can a site be considered for construction of a shooting range when lives were endangered dozens of times due to its proximity to dozens of homes within a one mile radius? Yet another neighbor stopped having their grandchildren visit their cabin, fearing for their safety. Glenn Martin was shot and killed from a stray bullet while sitting around a campfire in the Pike National Forest. The risk of injury or death from stray bullets is real.

Fire danger from sport shooting is a real risk as well. Target practice at a public shooting range in Grand County sparked a wildfire burning more than 500 acres just last month. What did the Forest Service spend in fighting this fire? Closer to home, a fire was sparked by gunfire at the old Allenspark Dump in 2006 where there is no cell phone coverage to report the incident. If a Sheriff had not happened to drive by and see bystanders waiving him down, the fire could have spread into a major event. As we know from the Gold Hill fire and others, hundreds of homes can be lost in a single wildfire.

The noise has been an ongoing nuisance to us and our neighbors, and is a threat to the wildlife corridor our easements were established to protect. Dispersed shooting and certainly shooting ranges, need to be prohibited within 2 or 3 miles of private property and critical wildlife habitat and corridors. Gunfire noise is known to affect mating behavior and wildlife migration, and some habitats are more sensitive to this noise than others. The Boulder County Comprehensive Plan Update maps "Critical Wildlife Habitats" and "Wildlife Migration Corridors," and the county plan states the protection of these habitats and corridors as a primary goal. The Forest Service's regulations on dispersed shooting d t b i t t ith thi B ld C t C h i Pl t t t ildlif h bit t ildlif id d th ti James Richards On our mountain property with an off-grid residence near (less than 1/4 mile) the Peak to Peak Highway we are surrounded by National Forest lands. We are writing to strongly support the Forest Service Plan proposal to close areas (287,000 acres) of the Arapaho and Roosevelt National Forest lands to recreational sport shooting. This closure is essential to protect many people, ourselves included, from potential hazards and disruption associated with unregulated recreational sport shooting and should be implemented as soon as possible. Implementation of this closure need not and should not be linked to identifying a location(s) where target shooting can be practiced in a designated area.

We have written previously to indicate problems with specific sites (e.g. Ruby Gulch) along the Peak to Peak Scenic Corridor as possible designated areas for sport shooting. In fact, none of the five areas identified within Boulder County between Nederland and Allenspark are suitable shooting areas, given their proximity to the concentrated recreational use along the Scenic Corridor in addition to their proximity to many residences. To Whom It May Concern,

We are residents at Mile 39.2 on the Peak to Peak Highway. We reside on 10 acres surrounded by National Forest Service land, and have lived there since 1986. Our property is at the top of the Ruby Gulch valley.

We are gun-owners that enjoy target practicing and are uncomfortable with restrictions on shooting on public land. However, we would like to voice strong opposition to the designated shooting area ideas, and specifically the placement of it in Ruby Gulch. These are the following reasons:

1. Proximity to private residences, popular and accessible camping and hiking areas, and the University Research Station. Ruby Gulch is quite accessible to the road, and as such is popular for a variety of outdoor activities. A shooting site does not in any way seem compatible with an area used for it's beautiful surroundings and mountain activities. Additionally, our home and property is well within a mile radius of what would be uncontrolled shooting

2. Concentrated noise pollution in a small area. There's no doubt that the narrow valley amplifies the shooting noise. The dispersed shooting that is currently allowed already draws a fair amount of traffic. Having a designated shooting area would condense the traffic and destroy the peace and quiet for a large radius.

3. Fire Danger. Again, with a narrow valley, any type of fire will tend to race up the sides. This issue was a constant worry with the Rainbow Family gatherings. We know that there were fires started at the Left Hand Canyon shooting site, so it seems entirely plausible that this would be a possibility.

4. Environmental Impact. Heavy use in the Ruby Gulch valley in years past resulted in a large amount of garbage and human waste. We believe the damage would be higher in Ruby Gulch than what was experienced in Left Hand Canyon due to the remote setting.

Perhaps our largest opposition is due to the abysmal lack of enforcement in the area. Historically, Ruby Gulch for many years was popular every summer for the Rainbow Family Gatherings. Despite noise, fire danger, illegal activities (shooting at night, rape, and quite serious violent acts), as well as serious environmental damage and trash- we were consistently told that there was not the budget or man-power to take care of the problem. If you couple this track record with the Left Hand Canyon shooting area issues-why on earth would this be a good idea that will be manageable?

Note: http://themtnear.com/2013/05/summer-begins-with-horror-story/ http://www.timescall.com/ci_13100619, http://www.coloradodaily.com/ci_12962361 (particularly note comments), http://www.hipforums.com/forum/topic/294066-rainbow-hippies-arrested-after-nederland-brawl/

The designated site needs to be placed in an area where enforcement and monitoring is more easily managed, not in an area that has a 45 minute response time by the Sheriff's department.

We sincerely hope the County will take to heart the serious concerns of residents regarding this manner. Martin and Laura Boniek [email protected] [email protected]

Peak-to-Peak Scenic Byway Coalition

To: Deb Gardner, Elise Jones, Cindy Domenico Boulder County Commissioners

Northern Front Range Partnership for Recreational Sport Shooting 1325 Pearl Street, Boulder, CO 80302 (submitted via email to [email protected])

Emily Greenwood, Conservation Easement Mgr., Boulder County Parks and Open Space 5201 St. Vrain Road, Longmont, CO 80503 Boulder, CO 80302 (submitted via email to [email protected])

Re: Potential Target Shooting Sites in Boulder County

Sept. 3, 2015

To the Commissioners, Partnership, and Ms. Greenwood,

Introduction. The Peak-to-Peak Scenic Byway Coalition represents the shared interests of a great many property owners and other stakeholders in the Front Range’s high country along the Peak-to-Peak Highway, primarily in Boulder County.1 The Coalition comprises the owners of ranches, residences, summer residences, off-grid residences, wilderness cabins, and land—including large adjacent tracts under conservation easement with either Boulder County or the Nature Conservancy—as well as renters, visitors, hikers, backpackers, family campers, mountain bikers, students, ﬁshermen, birders, rock climbers, equestrians, religious retreats, wedding parties, veterans, photographers, students, researchers, and many other wilderness, wildlife, and forest stakeholders who regularly enjoy, use, or study western Boulder County’s spectacular mountains, lakes, wildlife, and forest. A partial list of our members and initial signatories is appended below.

Our Coalition has formed out of concern about the obvious inappropriateness of the initial target shooting sites chosen by the Northern Front Range Recreational Sport Shooting Management Partnership (the “Partnership”), of which Boulder County is a member. The Partnership is considering at least one of these sites to recommend to the U.S. Forest Service, essentially as a “sacriﬁce zone,” in furtherance of the Forest Service’s poorly documented and overreaching desire to build designated target shooting ranges along the increasingly populated Front Range. This sacriﬁce supposedly counterbalances, in an unnecessary quid-pro-quo fashion, the Forest Service’s well-documented need to shut down unregulated dispersed shooting in a portion of the Arapahoe and Roosevelt National Forests (”ARNF”).

Dispersed shooting has become a serious national problem—most recently the subject of an editorial in the New York Times on Sunday, Aug. 23, 2015—that has increased signiﬁcantly in the last decade. There is simply no longer any reason to permit dispersed shooting on public lands in Boulder County, nor any reason to link limiting it to some allegedly necessary creation of designated target shooting ranges. Colorado has many shooting ranges in appropriately less-populous areas.

To be clear, the Coalition takes no stand on the right to own a ﬁrearm. Indeed, many, perhaps most, of us in the mountains are responsible gun owners. What we are concerned about is recreational ﬁrearm use that risks—regardless of whether shooting occurs responsibly or irresponsibly or in either concentrated or dispersed form—catastrophic property damage, injury, or loss of life. Over and above risks, any designated target range will—with 100% certainty—cause continual, long-term, concentrated harm to the quiet enjoyment of public

1 The Peak-to-Peak Highway includes Colorado State Roads 72 and 7. The Scenic Byway extends from south of Nederland in Gilpin County through Boulder County to Estes Park in Larimer County. The Peak-to-Peak High- way provides the primary mountain access to federally owned Arapahoe and Roosevelt National Forests and the Indian Peaks Wilderness Area in those counties, especially to the west and in Boulder County. page 2 lands (including wilderness areas) as well as private property and residences. Any target shooting range will disrupt Boulder County’s wildlife population and habitat, degrade water quality, and plainly be contrary to Boulder County’s well-regarded, supported, and publicly stated conservation and environmental goals, especially in the mountains. Every outdoor shooting range, with its concomitant too-loud or fear-inducing noise, safety issues, ﬁre and stray bullet danger, chemical and other pollution, sewage, and trafﬁc, negatively impacts its surrounding area. Minimal Forest Service rules notwithstanding, such impacts realistically can extend up to several miles from any shooting activity.

Furthermore, we do not per se oppose a sport shooting target range in Boulder County, either on private land, or on non-Open Space County land, or on Forest Service land, if such a site is sufﬁciently remote or otherwise protected in a way the leaves its circle-of-harm reasonably small. But we believe that the Peak to Peak Scenic Byway corridor is simply no longer an acceptable place for a designated, open-air, target range that it might have been at an earlier time when there were fewer residents, visitors, and other stakeholders everywhere.

Speciﬁc Concerns. After participating in several Partnership and Forest Service feedback sessions, including meeting with members of the Partnership and several Commissioners, and upon careful examination of the Partnership’s documentation and methodology as well as the Forest Service’s, we are deeply concerned over the inappropriateness of all ﬁve of the sites (Allenspark Dump, Bunce School Road, Beaver Reservoir Road, Ruby Gulch, and West Magnolia Road areas) that the Partnership is promoting and considering.

The informal manner the Partnership used to choose them was seriously ﬂawed. Remarkably, decisions are being made with little concrete information from the Forest Service on what constitutes a designated target shooting range, what its size and layout are, how many people can use it simultaneously, hours of operation, and/or what weapons will be allowed or disallowed. Will there be a requirement for “clean” (lead-free) ammunition? Will target shooting range use be limited to, for example, every other weekend to permit neighbors and forest users to at least partially enjoy some quiet and solitude? Will there be a requirement to use noise- suppression equipment? What will be the consequences to target shooters when rules or law is broken, as history shows is certain to occur? Indeed, under what violative or harmful circumstances will a target shooting range be closed down, either temporarily or permanently? How will any such shooting range will be regulated, patrolled, managed, protected, cleaned up, and/or ﬁnanced by a cash-strapped2 and understaffed federal agency with a very poor regulatory track record in Boulder County? Etc.

One would think having the answers to these speciﬁc and important questions would bear considerably on the choice of any site.

The Forest Service is proposing (1) to declare 287,000 acres, or about 20%, of ARNF as inappropriate for unregulated shooting; and (2) to establish at least one designated target shooting range on Forest Service land, one in each of several adjacent counties along the Front Range. The linkage of these two proposals is obviously due to the pressures the Forest Service faces from advocates of gun rights on all federal lands. But this arbitrary “quid pro quo” linkage of the unpopular second half should not be considered a given. The two goals can be implemented, or not, at wholly different times. Decisions should be made after answering important questions such as those listed above, not as an afterthought to a “fait accompli.”

Nonetheless, the Commissioners have (implicitly, via staff and the Partnership) made a preliminary decision to commit and lend their prestige to this quid pro quo situation, in a manner that pits neighbor against neighbor and community against community: the process encourages opponents of each individual site to argue that another site would be “better” (in the sacriﬁcial sense) than the one they oppose.

This is a governmentally, environmentally, intellectually, and recreationally bankrupt compromise. If there is no appropriate site for a designated shooting range on Forest Service or other land in the mountains of Boulder County, the Commissioners fail to represent the majority of Boulder County citizens, property owners, and stakeholders by committing the County to recommending one wholly inappropriate site out of ﬁve wholly inappropriate sites.

2 The Forest Service is overwhelmed with responsibilities, particularly related to ﬁre-ﬁghting, and can spend only a fraction of its budget “for every other important ecological job the agency is responsible for, such as watershed restoration, tree thinning or recreation projects,” as reported in NPR story on Aug. 28th, 2015. page 3

Worse, the entire process appears to be in the service of avoiding accountability. Everyone can conveniently blame someone else: the Commissioners or Boulder County Parks and Open Space can point at the Partnership, and vice-versa. Boulder County can then point to the Forest Service, and vice-versa. Be that as it may, this politically expedient choice will eventually prove a profound embarrassment when large numbers of people in Boulder County ﬁnd themselves harmed.

Fire. What, for example, will be the fallout when a forest fire erupts at a Boulder County shooting range sacrificed to the Forest Service by the Commissioners. This is not hypothetical. A fire has just occurred in Grand County at the Byers Canyon Shooting Range. Sparked by a target shooter’s .223 full-metal jacket rifle round, this fire burned a square mile of land, traveling nearly two miles in the process, closing highway and railroad, with the usual attendant residence evacuation. “We were sitting at a picnic table on the Colorado River when the fire jumped up behind us,” commented one nearby visitor (see Sky-Hi News, Aug. 24, 2015).

Boulder County’s foothill and mountain dwellers are subject to a constant, well-documented, high-probability risk of forest fires, many of which, quite recently, have proven to be exceptionally destructive to property and expensive for the County and its residents. A superheated bullet fragment ricocheting off a rock in a berm in a designated open-air shooting range need only drop onto tinder a short distance away to start a fire. Forest fires on windy summer days care nothing about the legalities of 1/4 or 1/2 or 1 or 2 mile radii, and when a fire starts in the high-country, the wind will sweep it east towards more populated areas of the County. Given Grand County’s recent experience, it is simply untenable to presume that a designated target shooting range in western, densely forested Boulder County is less risky than the unregulated dispersed shooting now occurring. Try- ing to manage the federal decision-making process notwithstanding, increasing the fire risk to Boulder County property owners, visitors, and users is not the Commissioners’ job, in any way, shape, or form.

The risk of a forest fire increases the more one enables separate independent uses (shooting, campfires, fireworks, etc.), each with its own individual risk. Neither initial risk need be larger than a tiny probability before it becomes essentially certain over the course of a few years that a forest fire will erupt to destroy people’s homes and lives, and drain county coffers yet again. Forest fires don’t necessarily respect county boundaries, either.

Indeed, two of the Partnership’s proposed sites are within the fire-fighting jurisdiction of the town of Ward, along the Peak-to-Peak Scenic Byway. The burden of protecting large numbers of nearby property owners and residences from the inevitable fire erupting at Ruby Gulch or Beaver Reservoir will fall, first and foremost, on Ward’s Indian Peaks Fire Dept. Yet its ratio of funding to acreage and buildings protected is one of the smallest in all of Colorado. The issue is just as salient for the remaining candidate sites.

Harmful sound. Target ranges are usually open sunrise to sunset, seven days a week, and, like most other forest uses, are most heavily used on weekends. Berms in designated target shooting ranges generally occur on only three sides of a long, ﬂat rectangular area. Given the topography of western Boulder County, this means carv- ing a range into a forested hillside where the open fourth side will likely be facing east, towards more populated areas. For easy access and safety, the shooters will be concentrated at the end of the range without that fourth protective berm. Worse, with the beneﬁt of ear protection, shooting regularly occurs “in concert” at near simultaneous times, maybe once per minute, at this unprotected end of the range. This plainly can amplify the total sound intensity. Noise suppression can help, but where is the County’s, or the Forest Service’s, or responsible target shooters’, commitment to requiring its use?

A typical intensity level of a single rifle shot is higher than that of a pistol shot, and varies from 140 to 190 decibels depending on the weapon. A recent OSHA study 3 of hearing loss for target ranges used by the Fort Collins Police Department measured a rifle shot at 172 db, where such measurements are at a muzzle-to-ear, two-foot distance. A medium-sized designated target shooting range has a capacity for 20 simultaneous shooters. Thus, for just 10 shooters, a conservative estimate of initial sound intensity might be 175 db. Using the well-known formula whereby the intensity of sound drops 6 db for every doubling of the distance measured, that means the sound of gunfire can still be at about 110 db one half mile (over 800 yards) away, 105 db at one mile, and about 99 db at two miles. These are all completely inappropriate, disruptive, plainly harmful, even dangerous,4 levels of sound, foisted on unwilling forest users, residences, and wildlife nearby. The Forest Serv-

3 Noise Health Hazard Evaluation Report, March 2003, HETA #2002-0131-2898

4 See, e.g., www.dangerousdecibels.org/education/information-center/noise-induced-hearing-loss/ page 4 ice’s circle-of-harm, at a mere 150 yards, is far too small. But the Partnership’s larger radius criteria using one quarter and one half mile circles are also entirely inadequate thresholds to determine acceptable sites that won’t harm neighboring residents, cabins, subdivisions, scientiﬁc studies, or campers or hikers or wildlife, or anyone seeking the slightest modicum of quiet or solitude in the mountains and wilderness nearby. A circle of radius 1 mile encompasses an area of over 3 square miles; a circle of radius 2 miles covers 12.5 square miles.

Lead contamination. Over 20 years ago, the U.S. Fish and Wildlife Service banned lead ammunition when hunting waterfowl. But no such ban applies to ammunition used in target ranges, where bullet shrapnel and vaporized lead dust will settle into the ground, especially at the berm being aimed at. Books and articles about the problem continue to published about the harms of lead contamination at target shooting ranges.5 Lead-free ammunition is available, but where is the Forest Service’s or the County’s or target shooters’ commitment to enforcing a no-lead ammo rule on target ranges to prevent the poisoning and contamination of these sites? Gunpowder or other ammunition propellant also contains a variety of toxic chemicals that will accumulate.

Disruption to Wildlife. Boulder County has carefully mapped important wildlife migration corridors and spawning grounds in the county, as part of its 2014 Comprehensive Plan Update. Remarkably, the majority of the ﬁve proposed sites are situated directly within these migration corridors. There is simply no way to reconcile these sites with the letter or spirit of Boulder County’s long-standing conservation goals with respect to protecting wildlife habitat for the beneﬁt of all citizens and visitors to Boulder County. For example, a note accompanying Conservation Area #1 (areas west of the Peak to Peak Highway) states that “All efforts to limit or reverse habitat fragmentation should be pursued.” There is no even remotely intellectually honest way to argue that a designated, open-air target shooting range will not harm wildlife habitat in its vicinity, when the constant, star- tling sounds of warfare emanating for at least two miles from the target range can still reach over 90 db. Studies of the effects of sound on wildlife indicate that wildlife becomes affected at far, far lower noise levels, starting at around 40-50 db. It is well-known that constant noise affects wildlife in numerous ways, including causing substantial changes in foraging and anti-predator behavior, reproductive success, population density, and community structure.6

Conservation Easements. The Forest Service desires to place a target shooting range in every county along the Front Range. To the extent that any target shooting site, proffered up by Boulder County representatives in the Partnership, compromises the conservation values of a nearby property under easement with Boulder County Parks and Open Space, then Boulder County has an afﬁrmative responsibility to protect the conservation values of such properties.

Conservations easements dramatically constrict the use of these properties for owners. Limits on the number, size, location, and use of structures, on property subdivision rights, fences, even types of vehicles, all decrease a conserved property owner’s economic value on the open market. Property owners have thus sacrificed many millions of dollars in resale value in order to limit the use of the land for the benefit of a much larger sphere of stakeholders to protect critical wildlife habitat and corridors, water quality, scenic values, development density, and more. Both dispersed and concentrated shooting too near such easements defeats their essential purpose, and will directly conflict with Boulder County’s goal that “The county shall identify and work to assure the preservation of Environmental Conservation Areas, critical wildlife habitats and corridors, ….”7

Disregarding the legal and social contract that permanent conservation easements represent may subject the county to legal action, or worse, the nulliﬁcation of the easement. Yet there has been no obvious communication between the Partnership and Boulder County’s Parks and Open Space Department with respect to recognizing, much less rectifying, this serious conﬂict of interest. Easement vicinity to the current proposed sites has plainly been of little or no priority. Is not Boulder County obligated to protect the conservation easements they hold?

5 See, e.g., http://projects.seattletimes.com/2014/loaded-with-lead/1/ or http://www.nytimes.com/1992/08/09/nyregion/a-suit-over-lead-at-a-ﬁring-range.html

6 See, e.g., Barber, Crooks, and Fristrup, “The costs of chronic noise exposure on terrestrial organisms”, Trends in Ecology and Evolution, Volume 25, Issue 3, March 2010, pp. 180–189.

7 See Boulder County’s Comprehensive Easement Program Policies and Practices page 5

Flaws in the Forest Service Plan. The first half of the Forest Service’s two unnecessarily linked proposals (the “Plan”) contains much of value. The Plan identifies about 20% of the Arapahoe and Roosevelt National Forests where just about everyone agrees that dispersed recreational shooting is inappropriate given the increasing density of population and use. This portion of the Plan makes a good-faith effort to deal with the numerous, demonstrable, documented, and longstanding problems of unregulated dispersed shooting throughout the ARNF. The Coalition, many of whose members have been directly and negatively affected for decades by dispersed shooting, believes the first half of the Plan deserves strong praise.

The Plan’s ﬂaw is in its concluding paragraphs, wherein the Proposed Forest Service Direction establishes as a goal the cooperation with certain Colorado counties, as well as with Colorado Parks and Wildlife, in identifying target shooting areas in the ARNF within each county. But in its otherwise closely stated argument, the Plan provides no rationale for its “within each county” provisions. This gives every indication of being an arbitrary let’s throw as much as possible against the wall to see what sticks, quid pro quo to satisfy the demands of those with “vested interest in access and opportunities on federal public lands for [their] members to enjoy ... recreational shooting.” The Forest Service does not need to install designated hobbyist shooting ranges in every one of four counties; they desire to look “reasonable” when just one county with the weakest opposition caves. Boulder County should be strongly and vocally opposed to this tactic, not acquiescing to it.

At the ﬁrst of the Forest Services open houses, a representative of the Service was heard to say that it was possible that no site might be found for a given county, even though the stated goal is to identify one site per county. Hence, any assumption on anyone’s part that a quid pro quo is mandatory appears incorrect.

The Forest Service has stated that any of its land within a half-mile of residential subdivisions or concentrated recreational use areas is unsuitable for recreational sport shooting. This prima facie establishes that no Forest Service land in the Peak-to-Peak Scenic Byway is appropriate for recreational sport shooting, dispersed or designated.

The Partnership has bought into the arbitrary quid pro quo of one shooting range on Forest Service land in each of several counties, without acknowledging that this is a deliberate strategy to make it look like building just one will be a “compromise.” There are myriad uses of public lands, but not every such use is acceptable, especially when the use has such a large-scale negative impact on others’ ability to use and enjoy those same public lands, or private lands.

An important rationale used by the Partnership members for buying into the quid pro quo is that unregulated dispersed shooting’s significant problems of fire- and stray-bullet safety, noise (anxiety- and fear-inducing or otherwise), and degradation of Forest Service land would be solved by creating supposedly regulated conditions in designated shooting ranges. But of course a part of the attraction of existing dispersed shooting practices is precisely that they are unregulated. Irresponsible shooters are unlikely to be attracted to regulated sites. Current enforcement of shooting regulations is well-known among mountain residents as nearly useless, yet no commitment, by the County or the Forest Service, to further enforcement resources has been made. Without such commitment no problem will be solved: the risks of fire and stray bullets, and the certainty of pollution, noise, and other harms will simply increase.

Flaws in the Partnership Process. A serious and authentic process must refine and develop firm criteria before identifying areas for consideration, and get the answers to specific questions of Forest Service target shooting policy first. The uproar over the current choice of five sites demonstrates that the process used is flawed.

For example, the Partnership’s choice of these sites was accomplished using incomplete GIS maps presented to the public. On these maps, for instance, some nearby off-the-grid residences were not shown. Many square miles of land under conservation easement went unlabeled; trails and dozens of nearby campsites went un- marked, etc. One site is within earshot of CU’s high-country scientiﬁc Research Station, whose ongoing work will likely be compromised by virtue of control conditions being changed mid-study. Another site is a few feet from a large wildlife migration corridor protected by both Nature Conservancy and Boulder County Open Space easements. Another site is a mere one-half mile away from a school. All of this was presented without rationale, explanation, or attribution of responsibility for the decisions.

Each of these open-air sites will create or exacerbate water pollution problems. Lead or other metals used in ammunition, and arsenic, mercury, phosphorous, or chlorates from partially combusted, constantly accumulat- page 6 ing gunpowder residues will settle into the porous sandy ground and be washed downstream or into groundwater after every single summer afternoon downpour.

Because of the mistrust engendered by this slapdash, poorly documented process, we wonder whether outside interests or institutions have been involved. Were these sites chosen after only cursory review? We have no idea. But the selections are plainly all inappropriate and insensitive to both local and county-wide circumstances.

Requests. We urge the Commissioners to promptly take the following steps:

1. Issue a formal statement to the U.S. Forest Service, in response to its request for comments on its ARNF Plan, due no later than Sept. 9, 2015, stating that the County strongly supports closing the 20% portion of ARNF to dispersed shooting, and that such closure in no substantive way depends on or should depend on whether building designated target shooting ranges. Solve one problem cleanly, and move on the next more contentious one. A camper in Colorado has recently died due to unregulated shooting, and ﬁres in Colorado have been ignited by both unregulated and regulated shooters. It is imperative that the County comment in this way by the above deadline, because such commenting may impart legal standing to the County as an entity that can demonstrate considerable harm should the Forest Service’s plan be scuttled or otherwise not go forward. The status quo regarding dispersed shooting mayhem in public forests is not an option. It is an emergency situation.

2. Independently from the above, state to the Forest Service (again, no later than Sept. 9, 2015) that in response to the Partnership’s preliminary public feedback on potential target shooting range sites, the Commissioners have concluded that after the Partnership’s best efforts, no appropriate sites in Boulder County have yet been found for a designated, open-air target shooting range. The Gilpin County Commissioners have established a precedent for just such a statement.

3. Additionally, the County has an obligation to protect the conservation easements into which it has entered. As such the County needs to work to protect its right to later defend its legal obligations with respect to those easements. We urge the County to submit a comment stating as much to the Forest Service. If the County is concerned that without its input the Forest Service will reach an arbitrary or capricious Forest Service choice in the absence of a County recommendation, so be it. The County should be preserving its later rights to argue against such arbitrary or capricious decision-making, not aiding and abetting it. The County’s comment as a possibly harmed entity (e.g., the legal injury to its conservation easements) may serve to give it standing to ﬁght the decision on any number of grounds later on in the federal administrative process.8

4. If the Partnership is truly considering other unpublicized sites in Boulder County, then it can say so and continue the public feedback process. Perhaps there is an appropriate target shooting site in western Boulder County not yet found. Perhaps some form of enclosed target range might be less harmful. But all the additional evidence and feedback collected from the public so far conclusively shows that the nomination process was flawed by a lack of information among staffers and in County mapping databases. Target ranges at or near these five proposed sites will harm the quality of life and a large number of uses in significant areas of the County. Worse, such ranges plainly risk serious harm and potentially the complete destruction of large numbers of residences in the path of any fire sparked by even the most careful of shooting range users.

5. Re-examine the site disqualification process. If an otherwise qualified site within Boulder County has been disqualified solely because of inaccessibility, determine if spending county or Forest Service money (possibly a shared expense) to make the site accessible would cause less harm than any site proposed so far.

6. Assure the Forest Service that the Commissioners will continue to work with the Service and with neighboring counties to identify and promote an appropriate site for a shooting range in or near Boulder County, whether on Forest Service land or not, to help meet the legitimate needs of recreational shooters. Emphasize that this is a regional, not county or federal, problem, but that an appropriate solution may not include any site in Boulder County.

8 Under the federal Administrative Procedure Act, the phrase “arbitrary and capricious” has special meaning in disputes over federal administrative decisions. page 7

7. Review and revise the Partnership’s Preliminary Criteria to establish more detailed, rigorous, and scientiﬁ- cally defensible selection criteria that meet and protect the needs and interests of residents, land-owners, institutions, visitors, and other Boulder County stakeholders, as well as wildlife habitat and water quality. The results will almost certainly clarify that there are no appropriate sites for recreational target shooting on Forest Service land in densely used, western Boulder County.

Conclusion. Glen Canyon dam in Utah was created as a “compromise” sacrifice zone to save Echo Park and the Grand Canyon from being submerged. In an interview 20 years later, Senator Barry Goldwater said his greatest regret in political life was participating in that compromise by voting in favor of drowning and destroying Glen Canyon. 9 Target shooting ranges are of course nowhere near as damaging, but the principle remains: each such shooting range will permanently harm, degrade, and threaten large swaths, measured in square miles, of nearby populated and widely used land, both public and private, at the expense of the many for little more than the pleasures of a far smaller, hobbyist minority—one that historically has demonstrated considerable difficulty in policing themselves, and for which there are significant and well-documented harms.

The nationally known Peak to Peak Scenic Byway and the mountain areas it provides access to are a tremendous asset to Boulder County. Wittingly or not, Boulder County and its Commissioners are participating in a process that essentially co-opts the County’s authority and legal standing to protect its many taxpaying mountain property owners, and a great many more stakeholders—as well as the County’s own Comprehensive Plan, Open Space, and other conservation goals—from the Forest Service’s likely arbitrary and capricious and very harmful decision to install a designated target shooting range in an almost certainly inappropriate spot on federal lands in western Boulder County, among others. If a decision must be made imminently, the County should tell the Forest Service that the Partnership’s good-faith efforts to ﬁnd a suitable area for a target shooting range have not panned out. If the County can ﬁnd a site that truly is appropriate, with a carrot of helping create accessibility to a currently inaccessible site, then there remains a small chance that all might work out to everyone’s satisfaction.

We stand ready to meet with the Commissioners in their ofﬁces or at any of the nominated sites to discuss these issues further and answer any questions you may have. We look forward to hearing of your consideration and action with regard to the foregoing information, recommendations, and requests.

Respectfully submitted,

The Peak-to-Peak Scenic Byway Coalition, whose members include (as of this date):

Allenspark and Bunce School Glacier View Neighbors Association Rebecca Male (Raymond) Annie Muldrew-Pancoast (Riverside) Louise E. Buck, Mountain Meadow Section 33 LLC Russ and Diane Hullet, holders of two conservation easements with Boulder County David Pinkow Alice and Dave Osborne Bill Weakley Bill and Lori Neff

Beaver Reservoir (Ward) South St. Vrain Valley Neighbors Association Silver Spruce Ranch, Inc. and McKenna Properties, LLLP, under conservation easement with the Nature Conservancy, directly adjacent to Beaver Reservoir site Douglas McKenna and Judith Houlding Andrew and Jacquie McKenna

9 See p. 59, footnote xxiv, of Bureau of Reclamation document on Glen Canyon Unit history, at http://www.usbr.gov/projects/ImageServer?imgName=Doc_1232657383034.pdf page 8

Priscilla McKenna Caitlin McKenna Stanley and Connie Heginbotham Welch Matthews Ranch, under conservation easement with Boulder County Jim Welch, Henry Gilbert Welch, William P. Welch Denise and John Mathews Audrey Benedict, with South St. Vrain creek land under conservation easement with the Nature Conservancy Karelle Scharff June Peterson Bill and Lori Neff Bruce and Susanna Drogsvold Craig Cameron Ken Bradley (Hidden Lake) Jennifer Kern, Director, Phuntsok Choling Retreat and Event Center Diane Turechek and Percy Lopez

Ruby Gulch (Ward - Nederland) Katrina Peterson (president of Glacier Lake Property Owners Association) Dick and Sandi Reinhardt (Glacier Lake) Susan Clifton (Glacier Lake) John and Lise Cordsen William D. Bowman, Professor & Associate Chair for Graduate Studies, Department of Ecology and Evolutionary Biology, Director, CU Mountain Research Station, University of Colorado Paul and Molly Melamed Megan Melamed Elliot Larsen Kent and Ingeborg Wolcott Jenny Paddock and Dixon Hutchinson Ben Blaugrund Nancy Waldron, with land under conservation easement David Nitsch Vincent Greene

West Magnolia Road (Nederland) Emmit and Geoff Hoyl, Los Lagos Ranch (Nederland), representing some 440 signers (as of Sept. 3) of their sponsored petition opposing the Magnolia Road site Donna K Flynn

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[Contact: Doug McKenna, at doug @ mathemaesthetics . com]

University of Colorado at Boulder Office of the Vice Chancellor for Research 26 UCB (303) 492-2890 Boulder, CO 80309 http://www.colorado.edu/VCResearch/

Stein Sture, Ph.D. [email protected] Vice Chancellor for Research

September 3, 2015

Boulder County Commissioners P.O. Box 471 Boulder, CO 80306 Via email to: [email protected]

Dear Commissioners,

Thank you for the opportunity to provide CU Boulder’s perspective on the proposed designated shooting range locations for Boulder County which have been identified as part of the county’s participation in the Forest Service process on recreational sport shooting.

As you know, the university owns and operates the Mountain Research Station (MRS) located on County Road 116 off Highway 72 between Nederland and Ward. The MRS covers approximately 200 acres surrounded by the Roosevelt National Forest and is operated year round.

The MRS is an interdisciplinary research facility devoted to advancement of study of mountain ecosystems and climates, a key part of Colorado’s natural beauty and tourist economy. The MRS runs undergraduate field courses, and provides site support for visiting K12, undergraduate, and graduate courses. Research at the MRS is performed by a multitude of investigators from numerous organizations. Additionally the MRS organizes research conferences held on location.

While there are multiple buildings on the site, the majority of the research and environmental education is done in the field, including on forest service lands. As such we have expressed our support of the Forest Service Plan to limit areas for dispersed recreational sports shooting, identify suitable lands for shooting areas and develop enforceable closure orders in areas that are not suitable for recreational sports shooting.

It is important to us that you understand our grave concerns. Over the years, researchers, students and personnel have reported many incidents of bullets whizzing by in dangerously close proximity and, tragically, in the 1970’s a graduate student was killed by gunshot attributed to dispersed shooting.

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While dispersed shooting may ultimately no longer be allowed adjacent to or in proximity to the MRS, we also strongly oppose the location of designated shooting areas in proximity to the MRS, specifically the Ruby Gulch sites. We believe life safety risks would remain, and that impacts to research would result from a nearby shooting area. These impacts, such as noise, intensified human activity and increased vehicle traffic, would impact animal behavior, which is among our prime areas of research. Additionally, repetitive gunfire would compromise the educational environment. Each summer the MRS hosts K12 environmental courses from the Boulder Valley and Denver Public Schools. In addition, the station runs its own undergraduate and graduate courses which use the surrounding area as a classroom. Multiple research groups use the MRS's facilities, with over $3 million in Federal research occurring at the site annually. All of this may be compromised by the designation of a shooting range in close proximity. Finally, the Ruby Gulch sites are adjacent to the Niwot Ridge Biosphere Reserve, which was given special designation in the Arapaho Roosevelt Forest Plan in 1997 for its benefit for research and environmental education. Establishing a shooting range near the biosphere reserve would directly contradict the intent of the 1997 Forest Plan.

We strongly urge you to reject the two potential shooting range locations that are under a mile’s distance to the MRS.

Thank you for taking our concerns into consideration.

Please contact MRS Director Bill Bowman, [email protected], 303 492 2557, with any specific questions you may have about the Mountain Research Station.

Sincerely,

Stein Sture Vice Chancellor for Research

CC: Michelle Krezek, Intergovernment Relations Director Dale Case, Land Use Director

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July 27, 2015

Sport Shooting Partners Att’n: Garry Sanfacon PO Box 471 Boulder, CO 80306-0471

Re the Partners’ Site-specific Considerations for Evaluating the Suitability of Developed Shooting Areas, Preliminary Criteria for Identifying Potential Opportunities for Developed Shooting Areas and the five sites proposed by Boulder County as potential developed shooting locations After careful consideration, the Town of Nederland Parks, Recreation and Open Space Advisory Board (PROSAB) offers the following comments on the above. From a safety standpoint, the preliminary developed shooting area site criteria for distance from towns (1 mile), housing developments (½ mile), single homes and recreational sites (¼ mile) badly miss the mark:

But perhaps the site will be actively managed and oriented so that the shooters are at least four miles from homes and recreationalists in the direction of their targets. That leaves the noise from firearms as the determining factor in siting a developed shooting area in relation to residential and recreational assets. The distance such noise travels is heavily dependent upon topography and atmospheric conditions. There may be little impact from shooting noise to an area separated from the site by the mass of a mountain, yet noise from the same location may travel for miles down or across a canyon. Noise from the now-closed shooting site off Magnolia Road was audible (and loud) throughout the Town of Nederland, over two miles away from the site at its furthest point. The ideal shooting site might be a box canyon with no residential development for miles in the direction of the open mouth. There are multiple problems with the distances from municipalities, subdivisions and single homes in the County’s Preliminary Criteria for Identifying Potential Opportunities for Developed Shooting Areas. To start

Town of Nederland  PO Box 396, Nederland, CO 80466  303-258-3266  www.nederlandco.org with, there should be no distinction between the allowable impact on these three categories; it is morally indefensible to potentially force a homeowner to move in order to escape the audio onslaught from a shooting site (and with lowered property values as an added insult). The prevalence of veterans with PTSD in our communities must also be acknowledged and the potential impact of shooting noise upon these individuals. Aside from the indefensible application of different buffer distances for different concentrations of residences, the distances themselves are far too short. As part of the site evaluation at each potential location, noise tests must be conducted, in which large caliber weapons are fired at a specified date and time. Residents within a three mile radius should be notified of the test and asked for feedback, and observers stationed at various locations within this zone. Observed noise levels must be evaluated, not on the basis of decibel readings, but on the potential for disrupting the peaceful use of one’s home. The Board would like to have seen specific selection criteria developed for each consideration before specific sites were put before the public for comment, as a site cannot be properly evaluated without knowledge of how the site would be developed and managed. To take a few items from the considerations list: 1. How will wildfire risk be managed? Will there be a minimum distance that is maintained clear of flammable material between a shooting backdrop and surrounding grassland or forest? Will there be fire suppression materials and equipment onsite? 2. What wildlife impacts would disqualify a site from further consideration? How far does a designated shooting site need to be from an established wildlife corridor? Will the wildlife of the surrounding area be inventoried, especially for the presence of threatened and endangered species, and will the detection of such species disqualify a site? 3. How many parking spaces would be required at a designated site? How would any overflow be managed? Will runoff from the parking area be naturally filtered? 4. How will drainage and erosion be controlled to ensure that lead contamination does not find its way into the surrounding ecosystem, especially bodies of water and wetlands? What provisions for lead management will be imposed? How will funding for such management be guaranteed, so that it is immune to possible future budget cuts? For the reasons stated, the five sites so far selected by Boulder County as potential locations for developed shooting sites cannot be fully evaluated. Nevertheless, PROSAB offers this limited feedback on the two sites that are within the Town of Nederland planning area, West Magnolia and Ruby Gulch. West Magnolia Pros: (We couldn’t think of any positive aspects for this location). Cons:  The proximity to the heavily-used West Magnolia trails, Nederland Middle-Senior High School, the Eldora townsite and Eldora Mountain Resort are serious concerns with this location. A shooting site at West Magnolia would need to be actively managed and constructed in such a way that stray bullets could not endanger recreators nor residents. Noise testing would be essential.

Town of Nederland  PO Box 396, Nederland, CO 80466  303-258-3266  www.nederlandco.org  Distance from Highway 119 is a concern and the lack of an all-season maintained access road an even greater one. Significant road improvements would be necessary, or the site would have to be closed seasonally.  A conflict is possible with future plans for the Toll open space property; Boulder County POS needs to be included in the site evaluation. Ruby Gulch Pros:  The site is relatively isolated from residences, though there are a number of homes potentially within the impact area. Preliminary noise testing is necessary. If a site were to be built at this location, active management would be required and the layout would have to be oriented in such a way that stray bullets could not endanger residents within a 4 mile radius.  This location is close to Highway 72 and relatively accessible. Cons:  The Ruby Gulch area is extensively utilized by the County’s homeless population in the summer. Displacement of these people could be expected to increase pressure on other mountain camping sites; any remaining might raise safety concerns. PROSAB appreciates that Boulder County is actively involved in the Northern Front Range Recreational Sport Shooting Partnership, recognizing that conflicts betwwen recreational shooters and recreationalists and mountain residents are increasing, as more people move into the WUI and recreational pressure from the expanding Denver Metro Area population grows. These two growth factors make us wonder whether it will be possible to locate a designated shooting site in the Mountains of this county without compromising on one or more of the critical considerations of health, safety or the environment. We hope such a site can be found, as we recognized the need for sites where sport shooters can sight-in and practice, but we also hope that the County agrees that health, safety and the environment trump the need for designated mountain shooting locations. Any potential site must be rigorously vetted, and if an apporopriate site cannot be found, the County must be willing to consider alternatives (a location on the plains, indoor shooting facilities). Thank you for your consideration.

Sincerely,

Randy Lee, Town of Nederland Trustee and Nederland PROSAB Chair, on behalf of the Town of Nederland Parks, Recreation and Open Space Advisory Board [email protected]

Town of Nederland  PO Box 396, Nederland, CO 80466  303-258-3266  www.nederlandco.org Technical Guideline

Environmental Management at Operating Outdoor Small Arms Firing Ranges

February 2005

Prepared by The Interstate Technology & Regulatory Council Small Arms Firing Range Team

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

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.

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

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.

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.

iii

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.

TABLE OF CONTENTS

ACKNOWLEDGEMENTS...... i EXECUTIVE SUMMARY ...... iii 1. INTRODUCTION ...... 1 1.1 Problem Statement...... 3 1.2 Environmental Stewardship Principles...... 4 1.3 Document Overview...... 4 2. POTENTIAL ENVIRONMENTAL ISSUES AT RANGES ...... 4 2.1 Fate, Transport, and Exposure...... 8 2.2 Shot and Bullet Distribution...... 15 2.3 Shooting Off Property ...... 21 2.4 Cartridges and Clay Targets and Litter ...... 21 2.5 Shooting Sound...... 22 2.6 Dust...... 22 3. BEST MANAGEMENT PRACTICES ...... 23 3.1 Identification of Best Management Practices...... 24 3.2 Alternative Shot Materials...... 26 3.3 Nonlead Bullets and Primers ...... 27 3.4 Control of Lead Shot Dispersion...... 27 3.5 Bullet Containment...... 31 3.6 Metal Recovery Techniques for Berm Maintenance...... 36 3.7 Stabilization of Lead Shot and Bullets in Soil...... 41 3.8 Soil Washing (Physical and Gravity Separation) ...... 42 3.9 Vegetative Control...... 42 3.10 Management Alternatives for Erosion...... 44 3.11 Targets, Casings, and Wads and Environmentally Friendly Targets ...... 48 3.12 Controlling Shooting Sound...... 49 3.13 Newer and Emerging Technologies ...... 53 4. ENVIRONMENTAL MANAGEMENT PLANNING...... 59 4.1 Site Characteristics...... 60 4.2 General Environmental Conditions...... 62 4.3 Selecting Best Management Practices...... 63 4.4 Management Plan Development...... 64 4.5 Environmental Management Plan Implementation...... 66 4.6 Monitoring Review and Evaluation...... 67 5. CASE STUDIES...... 68 5.1 Massachusetts Initiative Case Study ...... 68 5.2 Florida Case Study—Best Management Practices for Environmental Stewardship of Florida Shooting Ranges...... 75 5.3 Fort Rucker Case Study...... 77 5.4 Fort Jackson Case Study (ongoing U.S. Army Environmental Center project)...... 82 5.5 Naperville, Illinois Case Study...... 83 5.6 New York Police Department Outdoor Firing Range Lead Stabilization Case Study...... 84 6. BIBLIOGRAPHY...... 85

LIST OF TABLES

Table 2-1. Contaminants potentially found at ranges ...... 5 Table 3-1. Summary of potential operational and engineering approaches for control of lead at outdoor ranges...... 25 Table 4-1. Sources of information ...... 61 Table 4-2. Sample project evaluation comparison sheet ...... 64 Table 4-3. Template for an environmental management plan ...... 65 Table 4-4. Sample projects implementation schedule ...... 67 Table 5-1. Treatment results at New York Police Department outdoor firing range, Rodman’s Neck, Bronx, New York...... 84

LIST OF FIGURES

Figure 1-1. Typical sequence for establishing a range environmental management program ...... 4 Figure 2-1. Decision tree ...... 6 Figure 2-2 Conceptual model of groundwater flow and contaminant transport...... 7 Figure 2-3. Example of berm erosion ...... 9 Figure 2-4. Military rifle range...... 16 Figure 2-5. Automated field-fire range...... 17 Figure 2-6. Automated record-fire range...... 17 Figure 2-7. Combat pistol qualification course ...... 17 Figure 2-8. Theoretical shot fall zone and area of maximum shot fall at trap fields...... 18 Figure 2-9. Theoretical shot fall zone and area of maximum shot fall at skeet fields...... 19 Figure 2-10. A sporting clays course configuration with six shooting stations and multiple shot fall zones...... 20 Figure 2-11. Layout for a sporting clays course with a single shot fall zone ...... 21 Figure 2-12. Flight paths of different materials resulting from clay target shooting...... 21 Figure 3-1. Range siting problems identified at some trap and skeet ranges ...... 28 Figure 3-2. Range reorientation to reduce shot fall zone...... 28 Figure 3-3. A shot curtain at a trap range ...... 29 Figure 3-4. A shot curtain protecting a water body ...... 30 Figure 3-5. Design of shooting range in Garlstorf, near Hamburg, Germany...... 30 Figure 3-6. Conceptual berm system ...... 31 Figure 3-7. Fort Rucker berm and backstop ...... 31 Figure 3-8. Diagram of a bullet trap ...... 32 Figure 3-9. Examples of backstop berm and runoff trenching designed to collect bullets and lead runoff ...... 35 Figure 3-10. Side view of bullet traps and auger removal system for deceleration chamber at Kirtland Air Force Base ...... 36 Figure 3-11. Test simulator system...... 56 Figure 3-12. A lead recovery demonstration at a central Massachusetts range...... 57 Figure 5-1. Example of a range overlay map...... 72 Figure 5-2. Gray surface of range indicating location of lead shot pellets...... 74

Figure 5-3. Environmentally reengineered berm...... 79 Figure 5-4. Water and sediments moving into, through, and out of detention pond ...... 81 Figure 5-5. Off-range sediment transport in March 1997...... 81 Figure 5-6. Fort Jackson berm prior to modification and after amendment and revegetation...... 82

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 Small arms firing ranges are enforcement—serve as good stewards of the environment. the focus of this document. The terms “range” and “ranges” Their efforts result in the preservation of open space and the used herein refer specifically to protection of wildlife and other natural resources encompassed small arms firing ranges. by and associated with the lands they manage.

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 designed to assist This guidance is a follow-up to Characterization and range operators in developing, Remediation of Soils at Closed Small Arms Firing Ranges using, and monitoring environmental (SMART-1, ITRC 2003a). That guidance document, management plans at their active addressing the cleanup of closed ranges (i.e., the outdoor small arms firing ranges. 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.

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.

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

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.

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

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 Establish and accept environmental stewardship principles outlining the process for developing Chapter 1 environmental management plans discussed in this guidance. These same principles provide range operators with a framework Understand your range environment for successful environmental management. Chapter 2 That is, range design plans and day-to-day operations should be evaluated in terms of consistency with these principles. Delineate environmental issues Chapter 2 1.3 Document Overview

This guidance is organized sequentially in Select best management practices the order of activities range operators should Chapter 3 undertake in developing and implementing an environmental management plan. Figure Prepare an environmental management 1-1 depicts the topics covered in each plan and implement chapter of the document that follows. Chapter 4 Chapter 2 deals with identification of the range-specific environmental issues. Monitor environmental conditions and Chapter 3 discusses which BMPs are most revise plan as needed reliable and effective in addressing the Chapter 4 particular issues identified by the range evaluation. Chapter 4 provides guidance on Document implementation of plan incorporating the selected BMPs into an activities environmental management plan for the Chapter 4 facility; implementing, assessing and Figure 1-1. Typical sequence for establishing a modifying the plan, as necessary; and range environmental management program. documenting its implementation.

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

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

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/ Primary constituent of most primers lead azide Antimony Alloy used as a hardening agent (Increases hardness) Antimony From 5% to 30% is used in most primer compounds sulfide 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 Alloys in some ammunition rounds chromium Polycyclic Clay targets (Concentration of PAHs in clay targets varies from one aromatic manufacturer to the next but may be as high as 1000 mg/kg [Baer et al. hydrocarbons 1995]) (PAHs)

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.

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

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

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

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).

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

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

• 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

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

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).

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. Figure 2-3. Example of berm 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.

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

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

Water can transport metals in both the metallic form (bullets, shot, fragments, etc.) and through sediment Lead shot, lead bullets, projectile fragments, or dissolved metals can transport where lead (and other metals) has been adsorbed be moved by storm water runoff. 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

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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.

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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 This manual does not cover many of the firing line comes from the precipitation of lead the potential serious health effects compounds from muzzle vapors, from lead azide and caused by exposures to lead and lead poisoning. The reader is encouraged lead stiphnate primers, and from abrasion between the to use other sources of more detailed shotgun pellets or the projectile and the gun barrel. information on those subjects. Berm or downrange deposits of lead come entirely from whole and fragmented projectiles.

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 To reduce the possibility of exposure, impact areas of the range should be requirements, where applicable, of the Occupational posted and access restricted. 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. Failure to comply with the requirements of the lead standard could result in fines to a business. OSHA does not endorse any specific equipment; its only function is to regulate the impact on the employee. For a copy of the complete standard, contact OSHA (http://www.osha.gov). OSHA training videos and manuals can be obtained at http://www.osha- safety-training.net/ and are a good source of personal protective equipment recommendations.

Range workers should be trained in the procedures required to handle lead and the possibility of overexposure to lead particles. Everyone using or working on the range should be encouraged to

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

wash hands often in facilities provided for this purpose. Workers and users should be cautioned about eating and drinking in these areas. Simple placards should be posted at a range noting the presence of lead. Consider prohibiting food, drinks, and The relative risk of lead exposure to use of tobacco products on the range. See people is low in a well-designed and http://www.state.ma.us/dos/leaddocs/Lead-firing.htm and -managed facility, where common- sense precautions are taken. http://www.tdh.state.tx.us/epitox/firingranges_emp.pdf for more information on the health effects of lead. As noted earlier, this document is intended to address the minimization of potential exposures to 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 document on range safety. The reader is encouraged to find other sources of more detailed information on these subjects.

Detrimental effects due to elevated lead levels can also be found in both domestic and wild animals. Excessive exposure to lead, primarily from ingestion, can cause increased mortality rates in cattle, sheep, and waterfowl. Many of the legal and government actions that have been brought against ranges are based on elevated levels of lead and increased mortality in waterfowl.

2.1.4 Lead in Plants and Crops

Most of the effects of lead in plants and crops involve the lead pellet fallout area. Pellets are unlikely to damage plants except where trees and shrubs are damaged or disfigured by shot-in or passing pellets. Embedded lead pellets in trees grown for timber are not normally a problem; however, trees with steel shot imbedded in them have been rejected as timber products. Falling pellets can accumulate in certain crops with upturned leaves or in cereal or grass crops that have been flattened by weather. This has been known to affect feeding livestock or cause a crop to be rejected at point of sale. Once lead has decomposed into a more soluble form, it can enter certain types of plants from the soil through their roots. While most plant species that accumulate lead deposit it in the subsurface portions, a number of agriculturally significant plants can translocate the lead to areal parts. Crop plants like broccoli, cabbages, wheat, rutabaga, and turnip; forage crops like fescue; and stock feed plants like corn and sunflowers have all been noted as hyperaccumulators of lead.

2.1.5 Lead Shot and Livestock

In general livestock are unlikely to eat shotgun pellets. Spent pellets usually settle through vegetation to the soil surface. Cattle and horses rarely graze down to the soil itself, although sheep and goats can do so. Pellets trapped in growing or conserved herbage, however, can be ingested. The digestive system of livestock is normally resistant to lead poisoning.

2.1.6 Wildlife and Habitat Concerns

Spent lead may be available to wildlife and, when it is, may result in detrimental effects. Under existing law, suits and/or regulatory actions can be brought upon parties that are thought to be involved with damage to natural resources, including wildlife populations or their habitats. Ranges can take steps to minimize lead availability and reduce the opportunity for birds and other animals to ingest lead. The presence of wildlife near ranges is often desirable. The goal of protecting wildlife in areas where lead is present goes hand in hand with that of having wildlife present in high-quality habitat on other parts of the range property.

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Direct ingestion of lead shot or lead bullet fragments is the most important exposure pathway for wildlife. Birds may consume lead shot as grit for the gizzard, or it may be mistaken for small seeds and eaten. This can occur whether birds are feeding on land or in the water. Waterfowl are particularly susceptible to lead poisoning, a fact that resulted in the ban on lead shot for waterfowl hunting.

Lead shot and small bullet fragments may also be mistakenly eaten by birds and animals feeding on earthworms, soil insects, fallen seeds, and other foods at the surface of the soil. Range soils with elevated lead levels may also be inadvertently ingested by wildlife while feeding or when animals are cleaning their fur or feathers. The soil ingestion exposure pathway is generally considered a secondary risk for most animals; however, this exposure pathway may be more significant for terrestrial invertebrates and/or aquatic benthic organisms and for small mammals that may have a significant portion of their territories on the shot fall or impact area of a range than for larger mammals or birds that use larger areas. Generally, except for endangered or threatened species, unacceptable adverse effects are related to maintaining viable reproducing local populations rather than maintaining individual animals. For example, some small mammals whose restricted feeding territories substantially overlap the shot fall zone may be at high risk but represent only minimal impact on the local population.

Lead from shot or bullets in the soil that has weathered can be absorbed by plants and may accumulate in roots, leaves, seeds, and other parts that may be eaten by birds or animals. However, this pathway has not been demonstrated to be a major risk to most wildlife (Eisler 1988). If a range shoots into a field of corn or similar forage crop, there may be potential for ingestion of shot embedded in plants by domestic animals as well as wildlife (U.S. Department of the Interior 1986).

Generally, risks to wildlife at ranges are as follows:

• Waterfowl, coots, and snipe—Numerous studies have documented the risk to waterfowl. The risk is especially high if spent shot falls into wetlands or water where waterfowl may feed. However, waterfowl (especially geese) may be at risk if they are allowed to feed in shot fall areas that are maintained as a short grass habitat.

• Small, ground-feeding, seed-eating birds—Few studies have been conducted on this exposure; however, they are believed to be at a moderate risk. Mourning doves have been documented to ingest spent shot in heavily hunted areas. Because ranges represent only a fraction of a population’s distribution, any exposure is likely at the local level only.

• Small mammals—Most studies generally have identified small mammals as being at risk at ranges; however, they conclude that the exposure is only at the local level.

• Ground-feeding, worm- or insect-eating birds—These birds have a potential risk. The exposure pathway is through inadvertent ingestion of soil associated with worms or subterranean insects. Because ranges represent only a fraction of a population’s distribution, any impact is likely at only the local level. As a result, the risk is believed to be moderate to low.

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• Medium-sized and larger mammals—These animals have a low risk. Several studies considered this exposure and concluded that any risks present were not significant.

• Fish-eating wading birds, fish, reptiles, amphibians, and invertebrates—Localized elevated lead levels may pose a risk where lead-contaminated runoff or shot is allowed migrate or fall into wetlands or water.

2.1.7 Lead Shot in Water

Spent lead pellets either sink into the sediments or remain on the bed of a water body (such as ponds, lakes, marshes, reservoirs and rivers) unless they are carried elsewhere by currents. The pellets, however, can remain potentially available to feeding waterfowl in shallow water bodies. In acidic water some lead may dissolve into surface water and reach regulatory limits.

2.2 Shot and Bullet Distribution

Knowing where projectiles are deposited on a range is a key first step in the management of lead and other constituents. Projectiles land in a particular area based on range design, site conditions, range activities, and operating procedures. Typically, these variables are part of a safety plan. The goal of the safety plan is to keep projectiles within a defined area. The range can then control the access to and use of that area. However, this practice also has a direct bearing on lead management. As was discussed earlier, you need to know where the projectiles are deposited in order to know where to focus your management efforts.

Whether at a recreational, military, or law enforcement training facility, there are three basic types of rifle and handgun ranges. The first and most common is the static range. A static range has fixed firing points and fixed targets. The static nature of both the shooter and target results in a very concentrated lead deposition area right behind a clearly defined target. Typical distances from a shooter to a target include 25 feet, 25 yards, 40 yards, 50 yards, and 100 yards up through 1000 yards in 100-yard increments.

The second type of range is the dynamic range. With this type of range, there is some movement on the part of the shooter and some on the part of the target, but the movement is planned in advance, and the target is clearly defined. Dynamic ranges are more typical of law enforcement and military training, but recreational ranges that have some form of “action” shooting (International Practical Shooting Confederation, International Defensive Pistol Association, cowboy action, etc.) exhibit similar lead deposition patterns. The areas of lead deposition are clearly identifiable, but less concentrated than with a static range.

The third type of rifle/handgun range is the interactive range, commonly known as a “tactical range.” Tactical ranges, designed to simulate shooting scenarios in the field, are used almost exclusively in military and advanced law enforcement training. There is considerable movement on the part of both shooters and targets. The targets themselves are typically hidden in random patterns to add an element of surprise to the shooter’s training. Lead deposition is widely dispersed throughout such ranges.

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From an environmental perspective, the major difference between rifle/pistol ranges and shotgun ranges relates to the physical distribution of the lead. The vast majority of rifle/pistol ranges have a backstop berm, and lead is typically concentrated in a small area of the backstop berm behind the targets. Although bullets may occasionally strike the side berms or the foreground between the firing line and the targets, lead is usually sparsely distributed throughout these areas relative to its concentration in the backstop berm. Range use should be carefully considered when choosing a backstop design. Ricochets increase the distribution of lead to other areas. In heavily used ranges with bullet traps, significant lead recovery and recycling is feasible. A variety of different bullet traps are available.

2.2.1 Military Range Configurations

Rifle/pistol qualification ranges have a variety of layouts depending on the weapon and shooting scenario. They may use fixed distances and/or pop- up target configurations (Packer 1996). Figure 2-4 depicts one lane of a 25-m range. A 25-m rifle/pistol range may have 110 firing lanes, each 4 m wide. The distribution of bullets on this type of range is highly concentrated at the “bullet pocket” and the “toe” area. The toe area lies below the pocket where much of the debris (dirt and spent rounds) splatters and falls. This toe area is at the intersection of the berm base and the range floor. Its loose nature and high concentration of projectiles make it susceptible to surface water transport. Rounds that do not hit the target may either impact higher on the berm or skip over the berm and fall in a highly diffuse area behind the berm, defined as the “safety danger zone” or the “range fan.” Figure 2-4. Military rifle range.

An automated field-fire range typically has 32 firing lanes, each 15 m wide, with known pop-up targets at 75, 175, and 300 m. The shooter normally fires 40 rounds: 10 at 75 m, 20 at 175 m, and 10 at 300 m. Figure 2-5 shows a single lane of an automated field-fire range. Note that the area over which the bullets land increases with distance from the firing point (indicated by yellow areas). These yellow highlighted areas have the highest projectile concentration. Bullet pocket and toes (impact related dug-out areas and piles of splattered soil) may exist as a result of repeated impacts on the mounds in front of the target. Although many of the rounds hit the target and also the mound in front of the “target coffin” (generally a hardened rectangular container for the pop-up target that protects the mechanical parts), rounds do miss the target and the mound in front of it. Rounds that miss generally fall to the ground as they lose velocity downrange. Therefore, an area of diffuse lead distribution exists in a fan shape out from each lane. Range fan maps exist for military ranges for safety purposes and are a good indicator of where these diffuse areas may be.

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Figure 2-5. Automated field-fire range. Figure 2-6. Automated record-fire range. Figure 2-6 shows one firing lane on an automated record-fire range. The range generally has 16 firing lanes with seven pop-up targets per lane at 50, 100, 150, 200, 250, and 300 m. The shooter fires 40 rounds at various targets. The projectile distribution pattern on this range is similar to that on the automated field-fire range, with targets at greater distances having more diffuse distribution. The mounds in front of the targets have a high concentration of projectile material and may show distinct bullet pockets. An area of diffuse lead distribution exists in a fan out from each lane, and a range fan exists for the entire range, indicating the total area of diffuse projectile distribution.

Figure 2-7 shows a combat pistol qualification course. The course has 15 lanes, each 8 m wide, with pop-up targets at 10, 13, 16, 17, 23, 27, and 31 m. Given the shorter distances, the distribution of projectiles on this range is more focused than those on automated field- and record-fire ranges and similar to that on a 25-m range. Again, the highest concentration is in the mound in front of the target, and targets at greater distances have wider projectile distribution, including a range fan for Figure 2-7. Combat pistol qualification shots that miss the target. course.

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2.2.2 Shotgun Ranges

In contrast to rifle/pistol ranges, shot at shotgun ranges (trap, skeet, and sporting clays) is widely distributed. When a shotgun target is hit by a well-centered shot, only a relatively few of the several hundred pellets in the shot string actually strike the target. These may be deformed or deflected and fall to the ground nearby. Most of the pellets in the load, however, continue beyond where the target was hit.

The full extent of the total shot fall zone at a trap or skeet field or sporting clays stations must be known before effective lead management practices can be implemented. Careful examination of the ground for the presence of shot around the theoretical shot fall zone perimeter (indicated by the size and shape of the theoretical shot fall zones in Figures 2-8, 2-9, and 2-10) should be performed to determine the extent of the actual shot fall zones. In general, actual shot fall zones should not be considered to be any smaller than those illustrated in the figures unless unusual topography exists. If shots are fired on a downhill slope, the actual shot fall zones could be considerably larger than indicated in the figures.

Maximum shot fall

Figure 2-8. Theoretical shot fall zone and area of maximum shot fall at trap fields. Typical layout of multiple trap fields at top; modified layout to minimize total shot fall zone at bottom (NSSF 1997). 18 ITRC – Environmental Management at Operating Outdoor Small Arms Firing Ranges February 2005

Distribution of Shot at Trap Ranges

The positions of the shooters and the angles at which trap targets are thrown result in a funnel- shaped theoretical shot fall zone as illustrated in Figure 2-8. Depending on the load, the angle at which the shot was fired, wind, and other factors, typical lead trap loads can reach about 770 feet from the shooter, although most shot tends to fall roughly 375–600 feet from the shooter. (Note: The maximum range of shot is highly variable and is directly related to elevation above sea level.) Figure 2-8 illustrates the theoretical shot fall zone and the area of maximum shot fall at a trap field. Note the overlap of the shot fall zones from adjacent fields, resulting in areas with increased amounts of lead. The theoretical shot fall zone of a single trap field covers approximately 4 acres, and about 1¾ acres are added with each additional overlapping field (assuming the trap houses are spaced 100 feet apart). The top of Figure 2-8 illustrates a typical layout for multiple trap fields. The lower portion of Figure 2-8 illustrates a slightly different layout to maximize the overlap of the shot fall zones, which confines the lead to a smaller area and results in easier recovery and less potential environmental disturbance. If shooting games other than regulation trap are shot on a trap field, the shot fall zone and area of maximum shot fall tend to expand to the sides, depending on the angles at which targets are thrown and shots fired. At a maximum, they resemble the shape described below for skeet fields, with an outer perimeter about 770 feet from the shooters.

Distribution of Shot at Skeet Ranges

At skeet ranges, the positions of the shooters and the angles at which targets are thrown result in a fan-shaped theoretical shot fall zone. Depending on the load, the angle at which the shot was fired, wind, and other factors, typical lead 375′ 600′ skeet loads can reach about 680 feet from 680′ the shooter, although most shot typically tends to fall roughly 375–600 feet from the shooter. The theoretical shot fall zone and the area of maximum shot fall at a skeet field are illustrated at the top of Maximum shot fall zone Figure 2-9. The lower part of Figure 2-9 shows the shot fall zone and area of maximum shot fall from several adjacent skeet fields. The theoretical shot fall zone of a single skeet field is approximately 14 acres, and about 2 acres is added with each additional overlapping field. Even if shooting games other than regulation skeet are shot on a skeet field, the shot fall zone Figure 2-9. Theoretical shot fall zone and area and area of maximum shot fall are of maximum shot fall at skeet fields. Single field typically no larger than those described shown at top; multiple adjacent fields shown at above for standard skeet. bottom (NSSF 1997).

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The shot fall zone at a single combination trap and skeet field is very similar to that at a single skeet field, except that the “funnel” of trap shot fall extends about 90 feet beyond the perimeter of the skeet shot fall zone due to the greater range of typical trap loads. The areas of maximum shot fall overlap, producing an area of maximum lead in the center of the fan. Where there are several adjacent combination trap and skeet fields, multiple shot fall zones and areas of maximum shot fall overlap.

Distribution of Shot at Sporting Clays Courses

The defining feature of sporting clays courses is the complete flexibility in target angles and shooting directions. Because there is no standard layout, it is impossible to illustrate a standard shot fall zone or area of maximum shot fall for a sporting clays course. Figure 2-10 illustrates a typical configuration of a sporting clays course. As you can see, the shot fall zones do not overlap, and shot distribution is widespread. Figure 2-11 illustrates an idealized layout for a 10- station sporting clays course which provides overlapping shot fall areas and makes shot deposition more manageable. The boxes around the perimeter represent the shooting stations, and the colored lines represent the direction of shot from each station. The oval represents the overlapping shot fall area for each shooting station. This illustration makes it clear that sporting clays courses can distribute shot widely or provide overlapping shot fall areas depending on the characteristics of the course area. The theoretical shot fall zones could extend 770 feet from the firing positions, depending on the loads and angles at which they are fired.

Figure 2-10. A sporting clays course configuration with six shooting stations and multiple fall zones.

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2.3 Shooting Off Property

For ranges where shooting activities impact properties not owned or controlled by the range, there is potential human health concern if current or future use of that property Shot increases potential exposure. Off-property Trajectory lead shot deposition could be resolved through remediation or property acquisition for incorporation into the existing range. It could also be controlled by using shot curtains as can be seen later in Section 3.13.

2.4 Cartridges and Clay Targets and Litter

In addition to spent lead shot, other components, such as cartridge cases, wads, Figure 2-11. Layout for a sporting and clay targets, are produced and need to be clays course with a single shot fall zone. considered (Figure 2-12).

Figure 2-12. Flight paths of different materials resulting from clay target shooting (in meters, 1 m = 3.28 feet).

Cartridge Cases and Wads

Spent cartridge cases and wads are unsightly litter and contain metals and other residue that can contribute to contamination issues at a range.

Clay Targets

Clay targets are typically made of about 70% limestone bound with 30% pitch, bitumen, or other organic material. The binding material, particularly if derived from tar or pitch, may contain a complex mix of PAHs, some of which are regarded as toxic. The PAH content varies considerably, with bitumen binding containing the lowest levels. The use of clay targets with low

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or zero PAH levels is likely to increase in the future. In addition to low-PAH traditional clay targets, new materials are being developed in both America and Europe, including true clay material. These are claimed to have no hazardous components and to break down rapidly in the environment. Fragments of clay targets are not known to cause problems for wildlife. Farmers sometimes express concern over their livestock, but no current information indicates any problems. Uncontrolled accumulations of clay fragments may become an aesthetic problem or interfere with other land uses.

2.5 Shooting Sound

Sounds of shooting and other activities from a range are Whether or not shooting inevitable. They create one of the most common issues for both sounds are perceived by proposed and existing ranges with respect to range neighbors. neighbors as unwanted noise, the key issue is how such What to one person is a sound of no great consequence may be noise can be controlled. an unacceptable noise to another. The perception of sound is both a psychological and physical process, and how people respond to it depends on many factors, including its nature, the time of day, and whether they like its cause. A community’s reaction to the sounds of shooting can be influenced by its attitude to the range itself. Range managers need to develop and maintain good community relations with all in the neighborhood (see Section 3).

The sound at the muzzle of a shotgun firing a typical clay shooting cartridge reaches some 140– 150 decibels [dB(A), A = weighted scale to approximate human hearing for steady state noise]. For comparison, normal speech is around 50–60 dB(A), and clapping hands up to around 80 dB(A). For many people sound levels above 140 dB(A) become painful. A relevant feature of sound is that with increasing distance its level rapidly declines. At 1 km from a range, for example, the sound level can be 60–70 dB(A).

The main sources of sound on rifle/pistol ranges are muzzle blast, supersonic bullet flight, and, least importantly, bullet impact. Muzzle blast is caused by rapidly expanding gas from the burning propellant powder as it leaves the barrel. The sound level of a large-caliber rifle bullet traveling at 700–1000 m/sec (supersonic) is much lower than the muzzle blast, but, because it is typically in a much higher frequency band (some 1–4 kHz, compared with the broad spectrum of the muzzle blast), it is often perceived to be a more unpleasant sound. This ballistic sound does decline more quickly, however, with distance from the bullet path. Sound from bullet impacts varies; it is generally lowest in sand traps or earth berms and highest in metallic bullet traps. The extent to which the sounds from rifle/pistol ranges are perceived as unwanted noise by people outside depends much on the type of range itself.

2.6 Dust

Dust from bullets impacting berms and from lead recovery/recycling operations often contains lead. Lead recovery may be a large generator of dust at shotgun and rifle/pistol ranges. Lead can also enter the air from

• a release of lead due to the heat of burning powder acting on bullet base with exposed lead, • friction between the barrel and an unjacketed bullet, and • burning lead compounds used in primer mixtures.

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These minute lead particles can fall onto shooting benches or to the ground where they mix with or The possibility of inhaling lead from the air is probably greatest for recovery/recycling attach to soil. These particles may become airborne workers, who should always wear respiratory dust when the soils are disturbed. Several of these protection and otherwise comply with sources of lead may occur close to the breathing applicable safety and health standards. zone of the shooter. These processes introduce lead Good ventilation should be maintained at the into the air, where it could be inhaled. Range shooting positions to minimize any potential for inhalation of lead by shooters. operators should be aware of potential concerns about inhalation of lead and take appropriate steps to control dust. Dust from these sources, especially lead recovery operations, can also contribute to aesthetic concerns discussed above.

Mechanized lead shot recovery equipment is designed to scrape the upper layer of soil, which inevitably generates airborne particles. Some of the particles can contain lead. The amount of dust generated by these operations is dependent on timing. Recovery that is done when soil is moist may generate less dust; however, any dust generated from these activities could result in lead exposure to range operators and nearby areas.

3. BEST MANAGEMENT PRACTICES

Prevention of metal migration from the range bullet impact area is typically the least expensive and easiest to implement of the actions that may be taken to manage metal issues on operating small arms ranges. The selection of the appropriate metal migration prevention method is the key to successful lead management on a range or group of ranges because each range is unique in terms of metal concentration, climate, soils physical and chemical properties, and topography. A plan for controlling metal migration must be designed based on these site characteristics. Typically, these plans include designs to control storm water runoff, which is the predominant transport mechanism for metal contaminants. Some methods of controlling storm water runoff that may be used in a metal migration prevention plan are identified below.

A wide array of options exists for managing lead and other environmental issues at ranges. Range Environmental Management Goal These include range layout, bullet or shot 3 Manage detrimental or potential impacts containment structures, bullet or shot recovery posed by range activities on the public health or environment. and recycling, lead stabilization and control Range Environmental Management Objectives measures, and use of nonlead bullets or shot. 3 Keep lead in its metallic form. Operational methods for range improvement 3 Minimize the surface distribution and prevent are minor to moderate changes in the way a surface migration of lead and other range is used or maintained in an effort to hazardous constituents. 3 Prevent projectiles from affecting wetlands or reduce contaminant transport from the range surface waters. areas. In particular, concerns from lead 3 Prevent projectiles from landing off property. residues and suspended solids (from soil 3 Reduce noise impacts to surrounding erosion) leaving ranges or range areas may be properties. decreased or eliminated through relatively simple changes to range management. Some changes have no impact on operations and can be implemented with little or no cost to the installation or range. These operational methods include the following:

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• Evenly distribute/stagger firing lane The general goal of environmental management at usage to minimize impact to berm ranges is to effectively eliminate detrimental stability and vegetation in the high-use impacts posed by the range or shooting activities areas of the berm and to reduce the on the environment, public health, or public frequency of berm repairs. welfare. Options to accomplish these objectives vary and require thorough understanding of the potential environmental issue and consequences if • Minimize or eliminate firing into bodies potential contaminants are not properly managed. of water or wetlands, which increases the potential for ecological risk to lead exposure as well as the risk for lead migration.

• Sustain vegetative cover on and around the range. If vegetation is present, ensure maintenance activities will sustain and promote its growth, especially on the berm and in storm water runoff pathways. Caution should be exercised during irrigation to prevent overirrigation and possible dissolution of lead. Sustainable activities include annual fertilization and/or lime addition based on a soil nutrient analysis and a mowing regime that allows tall vegetation on the berm and runoff pathways. Tall grass slows storm water runoff and filters out suspended solids before they leave the range.

• Improve impact berm maintenance and repair. Do not grade the berm at a steep slope. A 2:1 slope will produce an inherently stable berm for most soil types and will be easier to vegetate. When repairing a berm, or a section of a berm, focus on filling the impact points where concentrated impacts have created holes in the berm. Remove rocks, which can ricochet, while avoiding widespread damage or unnecessary removal of established vegetation. Avoid bulldozing or pushing berms back. These practices loosen soils and increase potential for erosion.

3.1 Identification of Best Management Practices

Table 3-1 lists specific actions that can be taken at shotgun and outdoor rifle/pistol ranges to address specific environmental concerns like those discussed in Section 2. Once environmental concerns at a particular facility have been identified, the actions listed in this table, supplemented by the background information in Section 2, will provide a starting point for designing an effective environmental management plan.

The range manager should consider the specific range situation before choosing any one of the techniques shown in Table 3.1. There is no perfect solution to manage lead on ranges, and time, as well as money, is always a factor. Each technique has its pluses and minuses, and each range must be evaluated based on its unique circumstances. Some range managers may have a situation that requires a smaller range layout than is needed for a typical range (large surface danger zone) and thus, have a special requirement for a bullet trap and baffle. An important shallow aquifer may also influence this choice. Alternatively, other range managers may have a high tempo of range use that keeps their ranges operating all but a few days per year, leaving them little time to manage high-maintenance structures. They might choose to focus on techniques to manage bullet pocket metals mass and maintain a well-groomed and vegetated range.

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Table 3-1. Summary of potential operational and engineering approaches for control of lead at outdoor ranges Approach type Shotgun ranges Rifle/pistol ranges Operational • Range reorientation • Bullet recovery and • Shot recovery and recycling recycling • Target recovery • Chemical soil • Alternative shot materials amendment • Chemical soil amendment • Nonlead bullets Engineering • Range siting • Range siting • Clay layers/mixing • Clay layers/mixing • Physical barriers to shot distribution • Bullet containment • Shot curtains • Baffles/tube ranges • Shot fall zones designed to be outside of • Berm construction surface water bodies and maintenance • Ranges designed to maximize overlap of • Bullet traps shot fall zones while maintaining shooter • Runoff controls safety • Storm water • Elimination of depressions that hold water management/erosion • Storm water management/erosion control control

The list below outlines some important considerations before choosing one management technique over another:

• Will the technique I am considering (e.g., bullet trap, berm, and vegetation) contain the metal debris, thus reducing or preventing transport? • What type of metal particulate will form as a result of this technique? Will it be very fine dust or larger particles? What percentage of this particulate will be released to the environment (e.g. not contained within the berm or trap)? • Will the technique encourage or discourage corrosion or leaching of the metal into the environment? • Will any other hazards be incurred as a result of this technique (e.g., ricochet, fire hazard, stagnant water collection point, increased exposure to range users or maintenance personnel)? • Will the material used generate any wastes that will be designated hazardous, requiring special disposal considerations? If so, how much and how often? How much will this cost? • What are the maintenance time requirements for the technique I am choosing? Does it require a daily inspection? Weekly mowing? How often will I need to do minor maintenance (fertilize for berm and patch repairs for hardened structures)? Can this maintenance be done such that it does not interfere with range use? If not, how long will the range be out of commission? Is this time frame acceptable? • How much will minor routine maintenance cost? Is there special equipment or personnel necessary for doing this maintenance? How much of it can range personnel do themselves, and what type of protective equipment might they need to do it? At some point in time, especially with bullet traps, a major maintenance or complete replacement is going to be

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required. This requirement should to be determined prior to procurement. When will this need arise? How much range downtime will be required? How much will this process cost? • How will my particular climate affect the performance of this technique? If, for example, fine dust is generated by the technique under consideration and the dust is exposed to the elements, including wind and surface water, this technique may not be well matched to the users needs. Excessive rain and humidity may increase the frequency of maintenance needed for harden metal structures and may also decrease the life of the structure. • What is the capital cost for the technique under consideration? Does it require a concrete pad or grading of the range to install? • What express warranty does the vendor or maintenance crew/groundskeeper provide for this technique? • Will the vendor supply a list of prior clients with long-term history with this product for me to do an adequate assessment?

The sections that follow describe various management techniques in detail. It should be noted that range use (shooting regularity, intensity, etc.) has an effect on the environmental management of a facility. The appropriateness of many alternatives is range specific.

3.2 Alternative Shot Materials

In response to environmental concerns associated If the cost of environmental management with lead, manufacturers have examined a variety of lead shot, particularly the potential cost of alternative shot materials. Manufacturers of removal, is factored in, then the net cost continue to develop target loads with shot materials of using newer material is much less. such as steel, bismuth, tungsten, tin, molybdenum, and other substances. For shooting clay targets, there is no current perfect replacement in terms of cost and performance. However, as these and other new target loads are developed, the potential environmental benefits of switching to nonlead loads should be seriously considered. The added cost of nonlead shot is often noted as a reason for not using newer materials. It is important to note that fate and transport of many of these alternative metals and their environmental impacts are not well known.

Today, steel shot is the most common alternative to lead, and steel target loads are presently available in Ranges that shoot into or over water, wetlands, or other sensitive areas most areas of the country. Although slightly more should reorient to avoid sensitive areas. costly than lead and ballistically different, steel is the most viable alternative shot material for shotgun target shooting. To encourage use of lead shot alternatives, some ranges provide nontoxic shot for range users.

It should be noted that other metals used as a replacement for lead shot may have different physical or chemical properties. For example, lead shot produces very little ricochet, but steel shot may produce high-energy ricochets off many The use of steel or other alternative shot is surfaces, which could pose a safety risk. If a range a recommended BMP in established switches to steel or other shot material, care should sporting clays areas at which reclamation of lead shot is difficult or impossible. be taken to update safety measures appropriate for that material. Whatever type of nonlead shot is

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used, there still may be potential, even though minor, environmental issues arising from the cartridges and their components. Depending on the location, it may be necessary to recover spent shot even from nonlead materials.

3.3 Nonlead Bullets and Primers

Recent innovations in projectile technology have allowed most major munitions manufacturers the ability to offer low-lead, nonlead, and nonlead frangible type rounds for shooters. Environmental impact considerations for long-term use of frangible projectiles include the release of nonlead metals and the inability to recover intact projectiles in the environment. Frangible ammunition also works well in indoor ranges with containment bullet stops and is commonly available for many handgun and rifle calibers at a slightly higher cost than conventional ammunition. Lead-free and reduced-lead ammunition for hunting purposes is also available in limited calibers and bullet weights. Copper, tungsten, and zinc are the primary replacement metals being used. Some ammunition uses a lead core contained in a jacket of nonlead metal. These bullets are designed to maintain the integrity of the lead core so that no lead is exposed after impact. Additional research on both bullet design and alternative materials is ongoing.

Lead-free primers are available for pistol cartridges and are being developed for center-fire and rim-fire ammunition. These primers are not yet as reliable or available as standard primers— however, research and development continue. A well-designed and -implemented environmental management plan for these areas should reduce the need to change to nonlead alternatives. However, as in shotgun shooting, if the cost of environmental management of lead bullets, particularly the cost of reclaiming, is factored in, then the net cost of using newer material is much less.

Nonlead ammunition is being developed under a DoD program to eliminate the use of hazardous materials in small-caliber ammunition manufacturing processes and in the ammunition itself. Tungsten has been used as the primary metal to replace lead in the 5.56-mm round. However, recent research on the environmental fate and transport and human health implications of tungsten has resulted in reappraising its future use in small-caliber ammunition. Other nonlead ammunition is being developed.

3.4 Control of Lead Shot Dispersion

Controlling dispersion can be one of the most cost-effective means of managing spent lead shot (and other cartridge components) on a range. Conventional layouts of trap, skeet, sporting, and other clay target disciplines are shown in Section 2. Realigning the shooting stands and the angles and trajectories of clay targets to concentrate the spent shot into a smaller area can reduce the potential for environmental contamination and/or keep shot from landing in sensitive areas (waterways) or off property (Figure 3-1). Use of barriers, such as shot curtains, is another means of controlling lead shot dispersion. Concentrating the shot then helps reduce the area subject to potential lead reclamation or other management efforts.

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Shot fall zone extends onto neighboring property

Shot fall zone extends into waterway

Figure 3-1. Range siting problems identified at some trap and skeet ranges.

3.4.1 Range Reorientation

Reorientation can involve changing the direction of shooting to prevent shot and targets from landing in wetlands or waterways or landing off property. Reorientation can also involve rotating shooting positions at trap, skeet, or sporting clay ranges to decrease the overall shot fall area. This type of reorientation not only reduces Area of the area affected by shot, but also concentrates the shot into maximum a smaller area (Figure 3-2). Reorientation can also avoid shot fall shot fall accumulations in potential erosional areas and storm water runoff control zones. Efforts to concentrate shot fallout must be Range managers should implemented in a manner evaluate whether reorientation that does not compromise can be used to reduce overall shot fall zone area. the safety of the shooters or others at the range. Once reorientation is completed, the range operator must continue to manage shot present at the previous location and must understand potential environmental issues Figure 3-2. Range reorientation associated with it. For facilities with limited acreage or land to reduce shot fall zone surrounded by wetlands or waterways, however, (from NSSF 1997). reorientation is not always an option.

3.4.2 Shotgun Pellet Barriers

In addition to range reorientation, a shot barrier can be used to limit the shot fall zone size or prevent shot from landing in wetlands, waterways, or off property. Barriers can take several forms, such as a curtain (Figure 3-3) or a berm (see Figure 3-5). Because captured lead pellets accumulate at their

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base, shot curtains provide the added benefit of making it easier to recover and recycle lead. Some clubs have erected shot curtains using a woven nylon material suspended from telephone poles. Shot curtains are an option for clubs that cannot or choose not to reorient their range; however, several factors may limit their application in some settings. First, curtains must be located at least 60 yards from the firing line to allow sufficient distance for the target flight path. Some facilities with a small footprint, such as those shooting directly over wetlands or waterways, may be unable to meet this requirement. Second, curtains may need to span multiple fields to be effective. If a facility needs to limit the flight of shot pellets on multiple trap fields, the cost of erecting a barrier across several fields may be prohibitive. Finally, shot curtains have a limited and uncertain lifespan, so a facility must factor in maintenance and replacement costs as it evaluates this option.

A club in the Northeast has erected a shot curtain across a single trap field. The curtain fabric is a green nylon resistant to degradation associated with ultraviolet radiation. It hangs from 11 telephone poles, which rise 47 feet above ground surface and located 100 yards from the shooting positions. The club spent approximately $17,000 to purchase the materials and install the curtain and provided the following breakdown of costs: $5,100 for telephone poles; Figure 3-3. A shot curtain at a trap range. $5,000 for fabric; and the balance for equipment rental, labor, and wire/hardware. The Billerica curtain comprises vertically hung panels, each 20 feet in width, which can be readily raised and lowered via a system of wires and pulleys. The club initially fixed the curtain to the telephone poles as one continuous horizontal panel. Strong winds, however, began to pull a few of the telephone poles over. The club subsequently redesigned the curtain into sections that more effectively shed the wind and could be lowered in high winds. The curtain is stored in boxes at the base of the telephone poles when it is not in use. By providing protection for the curtain fabric during inclement weather and periods of infrequent use, the retractable curtain system extends the lifespan of the shot curtain fabric.

An April 2000 article in Shotgun Sports magazine featured a range in California that had erected a curtain made of paper-making felts. These discarded felts, used by the paper industry to press and dry paper pulp, are a possible free source of shot curtain fabric. The felts are made of Kevlar, which effectively stops shot pellets in flight. The felts are not, however, impervious to ultraviolet light, so their life span is expected to be limited.

Figure 3-4 illustrates how a shot barrier can limit the size of a shot fall zone and prevent shot from entering a surface water or wetland. A strategically placed barrier of trees is often assumed to be effective at intercepting shot. It can be helpful, but its value is often limited, and other problems can be created. For example, pellets concentrate under the trees, where they are more difficult to

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recover. It may be possible to hang a curtain between a stand of trees at the front of a wooded area, preventing shot from traveling into the woods, where it is difficult to recover. Using the trees as the curtain mounts, however, may result in a less conspicuous, more aesthetically pleasing shot barrier.

Earth banks (or berms) can help control pellets, but they need to be carefully researched to determine their cost-effectiveness. In Germany, soil Shot barrier berms up to 20 m high are being developed to reduce substantially the area of shot dispersion. This approach has potential to reduce lead solute Figure 3-4. A shot curtain protecting a water body. transport problems, simplify lead shot recovery and sound control, and reduce the need for large land areas for shooting ranges. Figure 3-5 shows a conceptual design of berms (about 20 m high) being used to combine trap, skeet, and other layouts. Figure 3-6 depicts a new European concept (Ceccarelli and Stefano 2004) that combines a curtain or intercepting net atop a berm.

Key: Stand A – Skeet Stand B – Skeet Stand C – Trap Stand D – Trap Stand E – Rabbit

Figure 3-5. Design of shooting range in Garlstorf, near Hamburg, Germany. (Made by SUG Germany in cooperation with BVS. Opened in October 2000. Drawing not to scale. From Association of European Manufacturers of Sporting Ammunition 2002.)

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Figure 3-6. Conceptual berm and net system (in meters, 1 m = 3.28 feet, Ceccarelli and Stefano 2004, copyright World Forum on the Future of Sport Shooting Activities).

3.5 Bullet Containment

Bullet containment is extremely important not only for shooter/public safety reasons, but also metal recovery and containment to mitigate impacts to the environment. Figure 3-7 shows a constructed berm at Fort Rucker, Alabama. Typically, the mostly likely pathway for lead to leave a range is through overshoot, ricochet, or erosion runoff. Under some environmental conditions, lead may dissolve and leach into the ground. Berms, bullet traps, and baffles are all components of a containment system. Figure 3-7. Fort Rucker berm and backstop.

The selected containment system should be designed to meet site-specific training/shooting requirements, as well as available space for surface danger zone (SDZ), and address all of the environmental concerns. A typical containment system using an earth berm and overhead baffles is detailed in Figure 3-8.

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Target Center Baffle and Rain Cover

2.8 m Ceiling

Sand-Filled Bullet Trap

Figure 3-8. Diagram of a bullet trap including a sand trap, ceiling, rain cover, and berm as platform for the sand trap material.

Bullets should be contained in the defined area of the range—the smaller the area of containment, the smaller the potential for environmental impacts due to lead. This includes bullets that may ricochet off previously fired rounds or small rocks in the backstop berm or off the surface of the side berms or the foreground soil. There are several ways to contain bullets after hitting the targets on rifle/pistol ranges. The most common is a simple earth berm behind the targets. More sophisticated containment systems include sand traps, steel bullet traps, shock-absorbing concrete (SACON), crumb-rubber blocks, granular-rubber (shredded-tire) berms, and other materials that contain and decelerate projectiles, improve safety on the range, and collect the bullets for recovery.

Overhead baffles can also be part of a containment system, with varying degrees of containment based on size, location, and orientation of the baffles. These are generally described as “total containment,” “partial containment,” or “open” ranges. Each has a specific SDZ requirement that needs to be considered during range design (USAF 2002).

A total containment range includes baffles oriented such that no blue sky is visible by the shooter aiming at the target. The total containment range also includes a safety ceiling or ballistic canopy over the firing line. When coupled with a steel bullet trap or other manufactured backstop, it provides total containment with the absolute smallest “footprint” for lead containment. With regard to SDZ size/orientation, a properly designed backstop with total containment overhead baffles and sidewall containment, while more costly to construct than an open earth berm range, can significantly reduce or eliminate the SDZ.

A partially contained range contains a reduced number of baffles and reduces the SDZ, but not to the level of a totally contained range. The baffle orientation is such that there is no line of sight past the baffles from typical firing positions/weapons orientation during firing. The partially contained range has fewer baffles than a totally contained range and a larger SDZ.

An open range, with an earth berm and no overhead baffles, is the least expensive to build of all of the containment scenarios but has the largest SDZ and is the range layout most likely to have rounds leave the range proper. Each has advantages and disadvantages to be considered during range design.

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3.5.1 Design Considerations

Selection of bullet containment involves many factors, including the size of the range, the location of the range, types of weapons to be used (bolt action, semiautomatic, full automatic), the number, caliber, and types (penetrators, tracers, etc.) of rounds to be fired, tactical training requirements (if any), and the targetry systems to be used. In addition, site-specific conditions must also be factored into the design, including static temperature ranges, statutory snow loads, prevailing wind loads, and rainfall. An engineering firm or other subject matter experts with range experience can provide assistance with new range construction or existing range upgrading, including calculation of the SDZ for the containment system selected.

Field-testing and performance should be accommodated before investing in specific bullet containment systems. As a reference, the Army Environmental Center tested three bullet trap designs under military test scenarios, with notably higher automatic firing sequences than commercial range conditions. The test included a composite-rubber block trap, a granular-rubber trap, and a steel deceleration trap. The rubber media traps appeared to function as specified except for heat transfer. Each rubber trap design caught fire, an event attributed to the poor heat dissipation of the rubber media under automatic fire tests (USAEC 2003). The steel trap design performed, but airborne lead levels were exceeded. The Army concluded that the lead concentration in the soil near the trap would increase over time due to the airborne lead. The Army test raised concerns, but it should be noted that test design was conservative for military use and cannot and should not be applied to commercial ranges.

Since that test, another steel bullet trap has been developed using a circular deceleration chamber and “wet” ramps. This design differs significantly from the one tested in that it does not fragment the rounds in the deceleration chamber, and the “wet” ramps cause the incoming rounds to “hydroplane” up the ramp, totally eliminating all dust.

The need for the safety of range users, workers, and nearby residents greatly emphasizes the containment and recovery of spent bullets. The bullets can be trapped after hitting the target (Figure 3-8), and individual ranges, or the complex as a whole can be contained by earth berms. By implementing these measures and by controlling lead, range managers can minimize the potential for additional problems.

Where berms are used as a backstop, they have to be managed for both safety and environmental stewardship. Berm management is likely to involve the periodic restoration to original dimensions and removal of the projectiles. Soil amendments (See Section 3.7 of this document), if needed, can be added at this time and the surface re-vegetated as appropriate. Please refer to Section 3.13 on newer and emerging technologies for more information on this topic.

The chemical processes acting on lead bullets and fragments within a berm (Section 2.1) are much like those acting on spent lead shot and are likely to increase the mobility of lead. If these processes are not controlled, then lead-contaminated runoff may leave the berm and, depending on drainage conditions and distance to receptors, cause problems away from the range.

Often, very important environmental as well as occupational health issues are overlooked. Note that the use of hard soil or soil with rocks in berm construction may increase ricochet and usually

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requires an increase in the range SDZ. An improperly designed containment system or a system used in a manner outside the design parameters can potentially result in lead exposure to maintenance personnel and in some cases generate a more mobile lead form than shooting into the soil, thus increasing the environmental risk to the range.

With all containment designs, erosion/runoff control needs to be addressed, including steps such as establishing vegetative cover and redesigning berms to reduce erosion, storm water controls, etc. If a bullet trap is used, the design needs to address not only the bullet trap, but also management/containment of the collected lead. Regardless of what containment method is considered—steel bullet traps, block traps, or engineered berms—the ultimate selection should be made only after a life-cycle cost analysis has been performed. All containment methods, including earth berms, require maintenance and repair as part of their operation. Some state-of- the-art bullet traps of hardened steel make bullet recovery easy.

3.5.2 Berm Construction and Maintenance

Backstop berms and side berms are commonly the major components of the bullet containment system at outdoor rifle/pistol ranges and typically have to be constructed. However, a fairly steep, natural hill may serve as the backstop berm at some ranges. If so, the lower part of the hill where bullets hit should be actively managed as a backstop berm.

Soil Berm—A soil berm is typically constructed of site soils. However, imported soil may be used if the site soil is not suitable (hard clay or contains large rocks, etc.). Reducing the contact between water and projectiles can minimize the possibility for metals in the backstop berm deteriorating. A variety of berm designs can help keep water away from lead in berms. In addition, many approaches can be used to control the pH, which would reduce the potential for lead to dissolve in water. A waterproof material can be placed over the top of the berm to prevent the infiltration of water. The material can be extended to include an “eyebrow” to reduce the amount of rain hitting the face of the berm. Figure 3-9 also illustrates an approach that collects water running off the berm and manages its pH with limestone. A similar approach could be applied in conjunction with ground baffles in the foreground of rifle/pistol ranges. Other techniques (e.g., side wings and terraced face) reduce erosion and water contact with lead particles (see Section 3.10).

Berm Maintenance—Berm maintenance between lead recovery and recycling operations for earth berms typically involves periodically replacing eroded dirt, reseeding bare areas, fertilizing, watering, and otherwise maintaining vegetation. On small ranges, people who operate or use the range may perform maintenance. It can be done with hand tools such as rakes and shovels, and should be done according to a schedule in the environmental management plan (see Chapter 4). Application of insoluble phosphate additives (Apatite II) can reduce lead leaching and runoff, and since it is relatively insoluble, it does not wash away during rain events.

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Figure 3-9. Examples of backstop berm and runoff trenching designed to collect bullets and lead runoff (from NSSF 1997).

3.5.3 Bullet Trap Construction and Maintenance

Some bullet traps, unlike earth berms, are fabricated systems that need to be installed on properly prepared foundations. These include steel bullet traps, rubber or SACON block traps, and granular-rubber traps. Considerations as identified in Section 3.5.1 must be incorporated into the design. In addition, foundation design must account for live loads and dead loads associated with the trap installation, and the electrical/plumbing requirements and physical space requirements for the installed equipment must be accounted for.

Steel Bullet Trap Construction—Steel bullet traps consist of a top and bottom ramp leading to a circular deceleration chamber. These systems typically require 25–40 feet front to back to accommodate the trap, depending on design and use parameters. Included in the system is a lead

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collection conveyor/auger under the deceleration chamber (Figure 3-10) to collect and transfer the collected rounds to an appropriately sized container, such as a 55-gallon drum. The trap can also incorporate a “wet” ramp which includes a holding tank and pumps to circulate the lubricant on the ramps. The system may also be outfitted with a pulstronic dust collection system to collect and filter the air from the deceleration chamber if a dry trap is used in an indoor application. The trap can also be used dry in an outdoor application, without Figure 3-10. Side view of bullet traps and auger removal system for the pulstronic deceleration chamber at Kirkland Air Force Base. system.

Steel Bullet Trap Maintenance—Maintenance of a steel bullet trap is relative simple and consists primarily of visual inspection, emptying the collection drum, and lubricating rotating parts. High-wear areas such as the hot zone of the scroll require replacement in time (>10-year service life), and this is a bit more involved, requiring unbolting/removing the worn pieces and replacing/rebolting the replacement parts.

Rubber/SACON Block Trap Construction (see Section 3.13)—The rubber and SACON block traps are similar in that they consist of media blocks stacked on top of each other to form a wall. Each requires mechanical bracing to maintain the wall in a vertical configuration. The wall is relatively shallow front to back and does not encroach on the range floor.

Rubber/SACON Block Trap Maintenance—These blocks are not practical for heavy-use, fixed- target ranges. Maintenance includes removing the blocks saturated with spent rounds, and replacing them with new blocks. Rubber blocks can generally be moved with manual labor, while the SACON blocks require a small machine to lift and place. A suitable recycling method has yet to be developed for SACON, and this media is typically disposed of. The rubber blocks can be shredded and recycled at a secondary smelter.

3.6 Metal Recovery Techniques for Berm Maintenance

Periodic removal of projectiles from the range may be considered pollution prevention if it is used to control the migration of lead and (or) other metals, by removing the source. Periodic removal is also a range maintenance activity when operational or maintenance issues arise

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(ricochets off of accumulated metals, elevated airborne lead level, etc.). Periodic removal can be a simple focused removal or removal of the entire berm face. The majority of this section focuses on large-scale removals; however, information on focused removal can be found in Section 3.6.1.1.

Metal recovery, as a maintenance activity on an operating range, is exempted from the Resource Conservation and Recovery Act (RCRA) Subtitle C requirements when the lead removed is recycled and the soil from which the lead was removed is returned to the range. EPA considers this to be range maintenance activities and not hazardous waste management activities (Heckelman 1997). Although the recovered metal fragments are solid waste being recycled, the metal fragments are considered a reclaimed scrap metal that is exempt from RCRA Subtitle C requirements. Storage, handling, and shipping requirements should be closely monitored. This method of removing lead from open ranges can be very expensive, depending on the scale of removal, and may result in range downtime.

After the necessary scale of removal is determined, if most rounds enter bullet pocket/toe areas of the berm, then focused removal around these areas may suffice, particularly if focused removal is part of the regular scheduled activity. In that case it may not take a significant amount of time, effort, or money and may be completed by on-site labor (see Section 3.6.1.1). If the face of the berm has the potential to create lead transport, a large-scale removal may be necessary.

Periodic metals-removal programs for ranges should be coordinated with the range or installation environmental manager since some state and local regulations may be more stringent than the federal regulations. This method of managing lead on ranges can be expensive and can result in range downtime during the maintenance event. Metal removal should be considered as a part of a larger BMP program, especially when other migration and pollution prevention methods have been exhausted or operation and maintenance safety is jeopardized (e.g., ricochet and airborne lead).

Regardless of the scale of the removal, lead and other metals may be removed from a range by physical separation methods alone or by a combination of physical and chemical (soil washing) separation methods. Factors include soil physical and chemical characteristics, moisture content, lead physical and chemical characteristics, and organic content. There are five classes of physical separation techniques: size separation (screening), hydrodynamic separation (classification), density (gravity) separation, froth flotation, and magnetic separation. After physical separation, which removes the coarse particulate metals, an acid leaching (soil washing) process may be needed to remove the lead still remaining in the soil either as fine particulates or as molecular or ionic species bound to the soil matrix. Two basic steps must be taken to determine the best method to remove the lead:

• The lead removal goal for the maintenance action must be determined. For example, if lead is being removed to mitigate a ricocheting issue with the accumulated metal, then the lead removal action need remove only the metal particle size fraction that creates the ricochet hazard. This approach would probably require a simple screening process as the removal method. However, if lead removal is desired to prevent migration to a shallow water table, a more aggressive removal and mitigation plan may be necessary to ensure that dissolved lead does not migrate vertically. In this case, lead fixation, acid leaching, pH adjustment, and

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wholesale disposal of affected soil may all be considered as possibilities to mitigate the situation. If lead removal is desired to mitigate fine particulate lead from moving into surface water, simple focused sieving may not be sufficient. Additional measures may be necessary to keep the lead on the range and include focused lead fixation; focused disposal of affected soil and replacement with coarse sand at bullet pockets; as well as standard erosion prevention techniques on the berm and range floor (soil amendments, vegetation, riprap areas, side berms). Simply removing the coarse particulate lead will not eliminate a lead transport problem because the finer particles are more easily transported. The smallest fraction is the most difficult and therefore expensive fraction to remove.

• Since the most efficient removal method will be site specific, a bench-scale treatability study may be required to determine the most efficient method to reach the established lead removal goal. Treatability studies can be conducted in accordance with ITRC guidance document for characterizing and remediating small arms firing ranges (SMART-1, ITRC 2003a).

Ranges in regions with high precipitation and/or with acidic soil conditions may require more frequent lead recovery since the potential for physical and chemical lead migration is greater. In regions with little precipitation and/or where the soil is somewhat alkaline, lead shot, bullets and fragments may be allowed to accumulate on the soil for a longer time between reclamation events. The ITRC Small Arms Team considers that well-planned and -executed environmental management using the best available technologies and documenting their performance may help ensure that lead is not classified as discarded or abandoned, which could trigger additional requirements.

Since cost of BMPs is of high importance, range operators should always perform a cost evaluation to determine what methods would most effectively reduce the availability of lead to the environment. The answer may involve one or more of the following:

• lead recycling/recovery “Routine recovery and recycling of lead may be one of the most basic and cost- ○ size separation (screening) effective environmental actions a range ○ hydrodynamic separation (classification) manager can undertake. Lead recovery ○ density (gravity) separation and recycling on a regular schedule ○ froth flotation should be part of the Environmental ○ magnetic separation for iron based alloys Stewardship Plan for every shooting range. Simply put, lead that is removed • hand raking and sifting from the range in a timely manner • vacuuming cannot cause a problem." (NSSF 1997) • treatment additives • soil treatment • soil washing (wet screening, gravity separation, pneumatic separation)

(EPA is completing a study on lead-reclaiming technologies that is expected in 2005.)

3.6.1 Recovery of Lead Shot from Shotgun Ranges

As depicted in Figures 2-8 through 2-11, lead shot fall is rather predictable at shotgun ranges. Recovery and recycling of lead is easier if shotgun ranges are constructed and operated in a manner consistent with periodic lead recovery and removal. Strategically positioning shooters or

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

targets so that shot fall areas overlap concentrates the shot and lessens the area to be mined. Recovery of shot from water or wetlands, steep slopes, and bushy or wooded areas can be very difficult, inefficient, and expensive. Recovery is generally easiest from relatively smooth, barren areas and is simplified if the approximate amount of lead present is known. Records of rounds shot annually or estimates from the number of targets purchased annually can be used to approximate the mass of shot in the shot fall area. Since sporting clay ranges often have trees and or shrubs/brush, lead recovery may be difficult and may in fact allow erosion if precautions are not properly implemented in the recovery process. However, removing vegetative debris (fallen limbs, tree bark, etc.) and some trees prior to reclamation at these ranges may allow adequate access for recovery equipment. Of course, when designing a new sporting clay range, steps to facilitate future lead reclamation should be considered in the original range design and layout.

3.6.1.1 Sifting and Raking for Spot Removal

A simple BMP is raking and/or sifting bullet fragments and shot from the soil. (Ensure workers are adequately protected from exposure to lead dust.) Sifting and raking activities are effective at the surface. This is a cost-effective management alternative employing relatively simple lead- recovery techniques.

Once collected, the lead must be taken to a recycler or reused. Arrangement with a recycler should be made prior to lead collection to avoid having to store the lead and incur associated potential health, safety, and regulatory concerns.

At trap and skeet ranges, sifting and raking activities in the shot fall zone yield the most lead. For sporting clay ranges where trees exist, lead shot may collect at tree bases. Basically, the process consists of raking the topsoil in the shot fall areas into piles with a yard rake as if raking leaves, removing any large debris (rocks, twigs, leaves, etc.), and then sifting the soil with screens.

Once the soil has been raked and collected, pass it Those conducting the hand-raking and through a standard 3/16-inch screen to remove the sifting reclamation at ranges should large particles. This process will allow the shot- protect themselves from exposure to lead. sized particles to pass through the screen. The sifted Proper protective gear and breathing apparatus should be worn. OSHA or an material (that not captured by the 3/16-inch screen) appropriate health professional should be should be passed through a 1/20-inch screen to contacted to learn about proper protection. capture the lead and lead fragments. This process will also allow sand and other small sediment to pass through the screen. Screens can be purchased at many local hardware stores. The screens should be mounted on frames for support. The frame size will vary based on the technique used. If one person is holding the framed screen, it may be better to use a smaller frame (2 × 2 feet); if several people are holding the framed screen, it can be larger.

At recreational ranges, raking and sifting can be performed by gun club members on a volunteer basis. Some clubs provide incentives, such as reduced fees, to members who assist with lead removal. A number of small clubs have found that reloaders volunteer to rake in exchange for collected shot. Hand-raking and sifting are cost-effective lead-removal techniques for small and low-shooting-volume ranges; however, these techniques may not be appropriate where there is a

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large volume of lead on the range. In this instance, reclamation machinery may be more appropriate.

Recovered lead should not be stored or BMPs for storing lead on site must, at a accumulated indefinitely on the premises and minimum, prevent lead from exposure to should be sent to a recycler as soon as possible. the elements and should be managed so Any required lead storage should be conducted in as to prevent releases to the environment. an environmentally responsible manner.

3.6.1.2 Mechanical Separation (Screening) Machinery

It may be possible to rent equipment for lead shot reclamation such as a screening machine (also referred to as a “mobile shaker,” “gravel sizer,” or “potato sizer”). This machine uses a stacked series of vibrating screens of different mesh sizes to sift soil containing lead shot. The uppermost screen (approximately 3/16-inch mesh) collects larger than lead shot particles and allows the smaller particles to pass through to the second screen. To minimize cost, this size screen will be 75%–95% effective to remove lead shot from a range. For trap and skeet ranges a second screen (approximately 1/20-inch mesh) is added to capture the small shot sizes of lead shot but allow smaller particles to pass through. The lead shot is then containerized. In its 2003 update, EPA noted, “In the Northeastern United States, the typical rental cost for this equipment is between $500 and $4,500 a week, depending on the size shaker desired” (EPA 2003).

3.6.2 Recovery of Lead Bullets from Rifle/Pistol Ranges

For ranges with effective bullet traps, recovering bullets may be as easy as emptying the catchment areas of the traps (see Figure 3-8). Bullets in earthen berms may be deep (up to 1–2 feet) in the berm and should be included in the recovery effort. Depending on usage rate and firing accuracy, metal may begin to accumulate in the face of the berm away from the bullet pocket. Recovery may require excavation of 1–2 feet of the face of the berm, mechanical screening of the soil to separate the bullets, and replacement of the soil on the berm face. Ranges should consider amending soils with lime, phosphate, or other stabilization additives prior to replacing the amended material on the backstop berm. Recovery from side berms and the foreground is similar, although excavation does not have to be as deep or frequent. Depth of bullet penetration and the resulting depth of excavation is a function of the angle of impact and the caliber of the ammunition. After lead recovery is completed, the areas should be regraded and vegetation reestablished to control soil erosion.

Using machinery to reclaim lead usually requires that the area be clear of scrub vegetation, grass, mulch, or compost. Regardless of how lead-laden soil is collected, the actual separation of the lead from sediments, soils, and debris is the same as described above. Soil, sediment, and debris screened out during the process is either returned to the field/berm or rescreened to ensure that no lead remains. Moist, clayey soils are more difficult in lead-recovery processes because they bind into shot-sized pellets, producing more “false product” from the screening process. Wet soils can also clog the screens.

After sifting the soil and returning the separated soil to the range surface or berm, some take reclamation one step further by sending the resulting lead, soil, and other lead-sized particles

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through a blowing system. Here the remaining lead particles are separated from the soil and other debris by the blowing air—the lead is much denser than the soil and other debris, so it falls through the column of air. Traditional screening cannot separate shot and bullets from other shot- and bullet-sized material (i.e., rocks, stones, roots, and various debris). A recycling facility considers nonlead items as “contaminants” that drastically reduce the value of the recycled lead. Pneumatic separation is an effective means of enhancing traditional screening.

Reclamation activities may generate dust, especially in drier locations. To prevent or minimize dust from traveling off the range and causing problems for neighbors, reclamation activities potentially generating dust should be controlled.

3.7 Stabilization of Lead Shot and Bullets in Soil

Layers of clay soil, either natural or constructed, can act as barriers to control mobility of soluble lead. A clay layer can restrict downward (but not lateral) movement of dissolved lead and lead particles. Even if the clay has to be imported from an off-site source, costs per acre are relatively low, depending on the location and the size of the shot fall zone (see ITRC 2003a).

Where lead is present and there is a potential for it to be transported to groundwater or off site by surface runoff, ranges can benefit from soil amendments reducing the availability of lead that can migrate. Amendments may be applied to ranges soils to chemically stabilize soluble lead in the soil pore fluid (see Section 3.13). These chemicals promote the precipitation of lead ions and the formation of relatively insoluble lead species. This procedure can be used in areas where lead in the shallow surface soil is providing a source of soluble lead ions to surface and/or groundwater. At this point, the application guidance and performance of this method of mitigating lead mobility is conceptual. The chemistry supporting the use of phosphate as a stabilizing amendment has not been proven in large-scale field tests. For more information, see Sporting Arms and Ammunition Manufacturers Institute 1996; Ma et al. 1993 and 1994; Ma, Logan, and Traina 1995; Wright et al. 2001; and Conca et al. 2002. Larson et al. (2004) show that lead phosphate (calcium phosphate and potassium phosphate) has a greater potential for surface transport, due to low particle density, than does the lead soil prior to treatment. Additionally, Larson et al. show that some forms of lead phosphate can leach significant amounts of phosphate, affecting local surface waters and shallow groundwater. It may not be advisable to use this technique if surface water transport is an issue at your particular range. When this method is considered, small test plots should first be designed and monitored to assess its lead stabilization performance, application rate, frequency, and efficiency and to ensure the chemical amendments are not mobilized and become a surface runoff or groundwater problems. This work should be coordinated with the range environmental management team and local environmental oversight agencies. Large-scale application should not be implemented until these application and mobility issues are addressed.

Range operators can purchase additives designed to chemically stabilize lead to reduce its mobility. These additives can be applied in a wet or dry form. Amendments (phosphate, lime, iron, etc.) can be topically applied on ranges soils either through direct broadcast or spraying in a slurried form. Depending upon the effectiveness, the range owner/manager may simply spread the additive over the soil; however, to maximize effectiveness, the additive should be raked

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

(mixed) into the soil to maximize contact between the additive and lead particles. Some amendments can actually exacerbate transport (see Section 3.13.3).

When purchasing soil amendments, the range owner/manager should

• determine the credibility of the company offering the additives, • review the application instructions to ensure the capacity to meet the requirements, • review the additive’s warranty to ensure protection from product failure, and • require a treatability study using range soil before purchasing.

These additives are cost-effective because they can be used in a variety of methods and not all of the lead fragments need to be removed to achieve significant stabilization. This fact provides tremendous cost advantage because the range does not need 100% removal of lead shot, bullets, or fragments. See Section 5 for case studies of soil amendment applications. In addition, Section 3.3 of ITRC 2003a provides greater detail on the application of soil stabilization techniques. It also discusses various compounds frequently used. Soil stabilization is as effective and necessary in active ranges as in closed ranges.

3.8 Soil Washing (Physical and Gravity Separation)

Soil washing is the separation of soils into their constituent particles of gravel, sand, silt, and clay. It is a reclamation method used to separate lead particles from soils. It generates a clean sand and gravel fraction by removing fines particles adhering to the larger soil particles and, if necessary, to transfer contaminants bound to the surface of the larger particles to the smaller soil particles.

Soil washing uses mineral processing techniques and procedures to recover particulate lead and refined products (see ITRC 2003a, pp. 29–31). The operation requires soils to be excavated from the range and mixed into a water-based wash solution. The wet soil is then separated using either wet screening or gravity separation techniques (see ITRC 2003a, Section 3.2). Since excavation is required, soil washing is more appropriate at closing ranges, which will no longer be used as a range. The technique is virtually cost-prohibitive as a regular maintenance operation on operating sites other than very large ranges.

3.9 Vegetative Control

Vegetative cover reduces erosion by slowing down water and wind and effectively holding the soil in place. This technique is natural, relatively inexpensive, and self-sustaining through production of seeds or roots by the plants. Another benefit of vegetative cover is to filter nutrients and pollutants from runoff (see ITRC 2003b). Vegetation can be uprooted by rapidly flowing water, thereby increasing the erosion of soil (see the photos in Section 5-4).

Vegetative control requires that the community of plants Woody vegetation should not be (i.e., trees, shrubs, grasses, and herbs) be well delineated and planted in impact and shot fall located to facilitate lead recovery and erosion control. Soil areas where it is likely to impede texture is an expression of the relative amounts of sand, silt, lead recovery (see Section 3.6).

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and clay. Texture is a key property of soils that affects a wide variety of soil-related phenomena, including drainage, erosion, plant ecology, and suitability for construction. The selection of the appropriate vegetation for the range area may be dependent on or limited by soil texture. Modifications to soil texture are possible; however, it is recommended only when the available vegetative options for the type of soil present do not provide protection from storm water erosion effects. The primary nutrients for vegetative growth are nitrogen, phosphorus (phosphate), and potassium (potash). Also, soils that contain a low organic content and an inactive microbial population inhibit the ability to establish and maintain vegetative growth. Soil amendments and fertilizers should be applied based on soil analysis results and recommendations provided by the state agriculture agency or natural resource program office.

Following the design and selection of plants, establish how to start the plants community (i.e., plants, rhizomes, or seeds), and density of plants needed to adequately cover the soil and produce the optimal control. Special care must be taken during plant selection to avoid noxious and invasive plants. Soil stabilization is the most desired effect of the vegetative community. The most effective vegetative plantings include a variety of long- Remember to avoid noxious and lived trees, fast-growing nurse trees, and shrubs interspersed invasive species of plants when with grasses and herbs. Cost of vegetative plantings is selecting your plant community. comparatively low; however, periodic care and maintenance are required after new plantings are established. Some of the kinds of plants that can be effective in erosion control attract birds and wildlife and may not be suitable for shotgun ranges, while others may not be suitable for berms or foregrounds at rifle/pistol ranges. Assistance in selecting plants may be obtained from local landscaping firms, county NRCS office, and environmental consulting firms.

The pattern and type of vegetation at a range influences the suitability of habitat and the types of wildlife that occurs there. Any time there are vegetated areas, there is the potential for wildlife to use the area. Most ranges are intentionally maintained in relatively open condition to establish a clear field of view for shooting. These open, often grass-covered areas are suitable habitat for deer, small mammals, and ground-foraging birds. Preferred wildlife food, such as plants that produce edible fruits and seeds, should not be planted around operating range areas. Other areas of firing facilities (away from the ranges) may be managed to support wildlife.

Mowing as an approach to vegetation management can be desirable because grass provides limited habitat for many animals. Grassy areas should be planted in less palatable plants, such as fescue and Bermuda grass. Your state wildlife agency may be able to suggest other plants that are not attractive to wildlife in your area. These management techniques can be used to keep shooting areas in open cover, keep weedy vegetation away from structures and equipment, and manage ornamental plantings for aesthetic purposes.

Vegetation condition also affects where, when, and how wildlife use a site. Deterring sensitive wildlife (such as waterfowl) from a range pond is important. Not planting or discouraging preferred food or cover plants will create marginal habitat in areas of potential lead deposition. Planting trees or other tall woody plants on the edges of ponds will deter some waterfowl, such as geese and swans, from landing and using the pond. In field areas, dense, higher vegetation and small shrubs may deter geese, crows, gulls, and several other types of birds from landing.

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However, as is the case with many factors of range use, the actual management techniques and vegetative condition of range areas depends upon the specific situation of a range layout and the associated shooting needs.

Areas of range facilities where active shooting does not occur are potential areas to Many state natural resources departments, wildlife undertake wildlife food and habitat divisions, heritage programs, and other similar agencies have recommended planting lists for enhancement. Many types of fruit-bearing important native species valuable to wildlife. trees and shrubs can be planted for wildlife value, including apples, cherries, blueberries, blackberries, dogwoods, grapes, and nut-bearing trees such as beeches, hickories, and oaks, among others. Field areas can be planted in wildlife food and cover, including grasses, wildflowers, clover, lespedezas, etc. to provide for wildlife needs. The exact species of plants best suited to a given area differ depending on the region of the country and associated climate and soils.

It is important to note that wildlife should be kept wild and well away from areas used by people. If an artificial feeding program is undertaken, only recommended foods should be used. Bread products or other human food items should be avoided. Feeding areas should be kept well away from lead impact on shot fall areas. Artificial feeding may quickly attract animals that become problems. Any feeding should be carefully evaluated before it is initiated and only after seeking the advice of the state’s natural resources department.

3.10 Management Alternatives for Erosion

Storm water management to improve runoff quality from ranges or range areas is an effective overall range sustainment effort that can be performed by personnel at military, public safety, or recreational ranges. Storm water runoff represents the predominant mechanism that transports the greatest volume of pollutants (lead residues and eroded soils/sediments), the quickest and for the greatest distances. It also represents the media and quickest pathway for affecting human or ecological health by potentially introducing pollutants into nearby surface water resources. The establishment and maintenance of vegetation on the berm, in impact areas, and in storm water pathways has already been discussed. Other storm water management methods include the following:

• Promote sheet flow of runoff water over the range surface. Sheet flow will lower the water velocity, which will lower the water’s sediment load–carrying capacity. It reduces the potential for erosion on the range and avoids potential point source discharge issues and monitoring requirements that may occur with channeled flow. Promoting sheet flow may be accomplished by regrading and flattening out the slope of the land surfaces and by creating broad, very shallow drainage pathways to replace ditches or deep, narrow channels.

• Prevent storm water from impact berms or areas that have the highest potential for erosion from flowing onto comparatively clean range areas or mixing with storm water from the clean areas. This tactic minimizes the land area affected by mobilized contaminants in the runoff and the volume of contaminated runoff requiring management. It is accomplished by

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

grading the slope of range area surface to change drainage patterns and constructing diversion channels/swales and small berms to alter runoff flow and drainage patterns.

• Detention ponds are a valuable last resort to manage storm water in areas where the runoff waters have the highest potential for carrying sediments and lead residues. Detention ponds must be designed and sized properly to effectively slow the water and allow the suspended solids to settle out. The drainage area that the pond will serve must be well defined, and the calculated volume of water the pond must handle must be accurate; otherwise, the pond’s effectiveness will be minimal. Often range space is limited, and installing these types of structures is costly. Also, under the strictest interpretation of the current definitions for point source and nonpoint source discharges, the discharge pipe or effluent from a storm water detention pond could be considered a point source. Installing a detention pond creates the possibility that sampling/monitoring as part of a storm water program or NPDES permit may be required. Consult with installation environmental management or the local oversight agency before designing a detention pond.

• When designing a range, consider berm orientation such that storm water and prevailing winds minimize the transport of lead off the range. Side berms may provide an effective wind break and surface water break.

Protection and stabilization of soil surfaces from excessive rainfall or snowmelt and diversion of runoff from them may be needed, depending on the soil types present. For any one range, a combination of control measures may be appropriate. A decision tree and detailed technical information about using constructed treatment wetlands as a form of storm water control is found in Technical and Regulatory Guidance for Constructed Treatment Wetlands (ITRC 2003b). This natural or created cover of suitable vegetation can

• reduce the eroding impact of heavy rain on the soil surface, • slow down the flow of surplus water over its surface, • bind the soil more tightly through the root systems, and • filter out lead particles or other constituents of concern from runoff water.

Establishing suitable vegetation cover is relatively easy and cheap, but advice from environmental consultants or other subject matter experts may be needed to ensure the most appropriate plant species are used and to guide their subsequent management. Care is needed to ensure such vegetation does not jeopardize lead and other recovery operations or attract wildlife species susceptible to harm from range activities.

In general, the steeper the slope, the more likely soil erosion. Terracing slopes can greatly reduce downhill runoff, especially if they are also suitably vegetated. Riprap can prevent channel erosion and provide a stable bank where velocity and channeling promote erosion. Water baffles, dams, and dikes reduce the velocity on steep slopes, thereby allowing suspended lead to be deposited upgradient of the structure. Construction of channels, low banks, or other features can also be used to collect runoff water and divert it from susceptible areas of the range.

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Geosynthetic and erosion control materials are used in a wide range of applications, such as general land management and rehabilitation, sediment and erosion control, and storm water management. Uses at small arms ranges include soil stabilization on eroding impact berms, hillsides, or stream banks; seeding or vegetating range areas; as a waterproof liner underneath a storm water drainage channel or detention pond; and silt fencing to filter or trap sediments in runoff. Geosynthetics and erosion control materials encompass a wide range of material types and compositions, physical properties, and applications. When choosing the type of material for a range project, it is important to have a clear understanding of what needs to be accomplished, how any given product needs to perform, and what properties it must possess to be able to do that. Some of the factors to be considered when making the decision of which product, if any, to use includes intended use, ultraviolet stability, biodegradability, strength rating, temperature rating, permeability, filtering capabilities, and material composition. Generalized types of geosynthetic and erosion control materials are listed below:

• Geotextiles are any permeable textile used with foundation, soil, rock, earth, or any other geotechnical engineering material as an integral part of a structure or system. Geotextiles are used for a variety of applications, such as filtration, separation, slope stabilization, drainage, and soil erosion control. The geotextile acts as a filter through which water passes while it restricts soil from passing.

• Geogrids are net-shaped synthetic polymer-coated fibers used to reinforce soil structure. This stabilization occurs as the soil fills and interlocks with the grid. The interlocking effect is determined by the geogrid strength, mesh size, and base materials used. Typical applications include slope reinforcement and berm reinforcement.

• Geocells, or geowebs, are a class of geosynthetic product designed in some form of rigid or flexible material that has three dimensions and contains or holds a volume of soil or fill materials for soil stabilization and reinforcement. Geocells can improve the performance of vegetated slopes by reinforcing root systems and directing hydraulic flows over the top of cells, with the cells acting as a series of check dams. A geocell placed on a steep slope not only holds the soil in place, but the cell walls slow the flow of water down the slope. This feature reduces or eliminates the formation of rills on the slope face. In addition, water is trapped in the cells and seeps down through the soil, which is conducive for deep root growth.

• Liners are impervious sheets of rubber or plastic material used that may be used to limit downward migration of lead to groundwater. They may be installed under areas where lead concentrations are likely to accumulate. The use of liners often requires drainage systems to manage the water that collects above the liner.

• Erosion control blanket materials can be divided into two large categories, temporary (degradable) materials and permanent (nondegradable) materials. Temporary erosion control blankets are designed to provide immediate and short-term soil erosion protection and promote vegetation establishment on moderate slopes and low-flow channels where bare- ground seeding and loose mulches often fail. Permanent erosion control blankets or materials are designed to be a long-term part of an overall soil erosion protection project. These

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

materials provide immediate as well as permanent soil stabilization and assistance to revegetation efforts.

Structural enhancements to impact berms can be used to provide an inherent stability to the slope of the berm and the concentrated impact points. Steep berm slopes naturally erode excessively. This erosion is accelerated by the soil disturbance caused by the impact of the rounds on the berm. Also, the establishment of vegetation on berms with steep slopes is extremely difficult. The following methods may be used to enhance the structure and stability of a berm:

• The berm slope may vary slightly depending upon the soil characteristics; however, a 2:1 slope produces an inherently stable berm for most soil types and is easier to vegetate. This slope is conducive of low-velocity sheet flow, which reduces the potential for rills and gullies to develop on the berm. A concern with this slope is that there may be a slightly increased potential for rounds to skip over the berm than on berms with steeper slopes; however, the reduced slope does not affect the SDZ for the range.

• Structural enhancement of the bullet pocket (a concentrated impact point on a berm formed from repeated firing on a static target) helps mitigate the erosion and soil loss from the berm. This type of structural enhancement may be implemented simultaneously with vegetative efforts to stabilize the berm. The bullet pocket structural support can consist of a small roof over the impact point that provides weather protection to the disturbed soil. This will provide stability by preventing runoff water from eroding the sides of the hole formed by the impact of the rounds on the berm. This weather protection structure, along with vegetation, provides surface and subsurface structural stability to the berm and greatly reduces erosion, lead transport, and maintenance frequency. The size of the structure is site specific and varies with the spread of fire on each firing lane. Typically, the larger the impact area on the berm, the less effective and more costly this structural enhancement is. The structure may be fabricated from wood or from a material such as shock-absorbing concrete.

Wind erosion is most likely in arid environments where the soil surface is friable and loose. A cover of suitable vegetation may be the most effective preventive measure; however, design should account for the additional irrigation water applied to maintain the vegetative cover. This could unintentionally produce vertical migration of soluble lead. 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.

Windbreaks can also be beneficial for aesthetic and sound-management objectives but should be planned so as not to interfere with other range management needs, such as lead recovery operations.

Concentrated human use of parts of a range can encourage erosion in susceptible areas. Access roads, unsurfaced car parks, and walkways may need to be vegetated or otherwise protected with gravel, stone chippings, or chipped bark to reduce erosion risks.

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3.11 Targets, Casings, and Wads and Environmentally Friendly Targets

In addition to the spent lead, target and other shooting debris can be an environmental issue at a range. Components of a shot cartridges need to be considered along with the clay targets (see Figure 2-12).

3.11.1 Cartridge Cases and Wads

Spent cartridges and wads constitute litter. In addition, plastic wads, which form shot cups, may contain a residue of lead from the shot, observable as black or gray spots on the white plastic cups. Regular collection as part of normal housekeeping helps to prevent migration and potential exposure.

3.11.2 Clay targets

Whether or not broken clay targets can cause significant environmental problems is still debated. They contain PAHs and therefore continue to be of environmental interest. Baer et al. (1995) found that targets did not exhibit characteristics of toxicity using an EPA leachability test (Toxic Contaminant Leaching Procedure [TCLP]). Results from new and aged targets suggest that PAHs are tightly bound in the petroleum pitch and limestone matrix. However, they do constitute litter on ranges, and litter control measures can be taken, such as alignment of the shooting layout and shooting stands to limit the litter coverage area.

Clay fragments typically accumulate 20–80 m from each stand, depending on the layout, with missed targets up to 90 m away. Netting material laid over the fallout zone can be effective in facilitating recovery. Hand raking or mechanical scraping can also be used, depending on the terrain. Since sporting clay ranges generally have many trees or brush, removal of vegetation may not directly apply. At these ranges, the focus is on removing vegetative debris (fallen limbs, tree bark, etc.) prior to reclamation. This process may include removing some trees to gain better access with the reclamation machinery. Of course, when designing a new sporting clay range, steps to facilitate future lead reclamation should be considered. Recovery of spent shot, concentrating the fall of clays into flat areas free of vegetation, and rough ground will help this operation.

Options for their subsequent disposal depend on any state or local environmental laws applying to such waste and whether facilities can accept the target fragments under the terms of their operating/environmental permits. These may include landfill, incineration, road making, or new clay target manufacture.

3.11.3 Environmentally Friendly Clay Targets In view of the environmental Bitumen-free clays are slightly more expensive, but the small interest caused by high-PAH increase in cost is more than justified by the demonstration of clays, it is recommended that the range’s efforts to practice pollution prevention and be ranges use low-PAH clays. responsive to environmental concerns. Research and development continue among manufacturers to find effective and affordable clay materials. Their suitability for both shooting

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and disposal needs to be assessed. If colored clays are desired, only those with harmless pigments should be used.

3.12 Controlling Shooting Sound

Ranges that are not managed responsibly generate opposition. Local support for, or at least tolerance of, a new or established range is vital for its future. That future is more certain if potential objectors can be persuaded of the community benefits of the range and that all reasonable measures will be taken to minimize any unwelcome effect on their community. In some instances range activities or designs have been altered to address noise concerns.

3.12.1 Siting of Range to Control Sound Levels

New firing ranges should be located and designed to It is preferable that there be no line of sight between a range and minimize the potential for objections to the sounds any noise-sensitive premises. produced. Complaints about the sound of shooting can be difficult to resolve and often evolve into environmental complaints. Ranges have historically tended to be located in rural areas where land costs and sparse development are more suitable for this type of activity. However, the rapid development of rural areas is making it inevitable that range owners and operators will have to address the effect that development may have. Whether operating an existing range or planning a new one, it is important to consider surrounding land uses and landowners. Particular care is needed with the local topography. Hills and woods can reduce awareness of the range on neighboring land, but they can also reflect and increase sound levels.

When planning a new range, the manager should consult with the local administrative authorities about the level of sound permitted and any control measures required. A common mistake is to assume too low a daily use of the range. Predictions of future use should be based on the busiest days. The impact of the likely sound levels on the residents and users of the neighborhood should be assessed and steps taken to reduce it, if appropriate.

Direction and Angles of Shooting

The propagation of sound from a shotgun is largely directional, with its loudness being nearly halved to the side and less still behind the shooting stands. Shooting should be away from noise- sensitive premises. This orientation can be difficult, though, as shooting is usually best facing north for favorable light conditions.

Altering the angles of shooting can focus the resulting sounds away from sensitive areas. Some layouts, such as down-the-line, are more directional than others and can be used to help direct sounds. Sporting layouts create the widest acoustic impact, as it generally spreads all around each stand.

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Amount, Frequency, and Timing of Shooting

Sound can be characterized by its duration, frequency, loudness, pitch, and impulsivity, and any of these features can cause annoyance to the local community. The range manager can alter many aspects of the shooting operation to help reduce problems for the enterprise:

• the number of different layouts; • the amount of shooting at any one time; • the number of shots fired on any one day; • the times of day and days of the week for shooting; • the rate of shooting per hour; • the size and number of competitions, club, and open events; • the number, size, and timing of practice sessions; and • the types of cartridges.

A general contribution to lowering sound levels can be Incentives such as reduced fees may made by using subsonic cartridges or cartridges with prove helpful to offset unwanted smaller loads, as both produce lower sound levels. The restrictions or to encourage shooters at times to meet community concerns. time of day when shooting takes place is particularly important. Shooting can be confined to certain hours of the day, with the total number of hours fixed. The limits may be different on days of religious or cultural importance. Some balance is needed in applying such measures, however, as the manager is responsible for a business that depends on shooter custom and satisfaction. If either is reduced too far, the business will suffer.

Other Sounds

Less obvious, ancillary sounds associated with the range may also need attention. Public address systems can produce far-carrying sounds, as can the vehicles of visitors and range workers and the equipment and machinery used in the day-to-day management. If range facilities are used at night for social or other purposes, care may be needed to prevent these sounds from troubling the local community.

3.12.2 Sound Barriers and Berms

Barriers to sound propagation can be used to reflect, redirect, absorb, contain, and isolate sounds from ranges. Natural barriers should be used where possible, including banks, cliffs, rock or quarry faces, woods and other thickly vegetated areas, walls, and buildings. Care is needed, however, that they not increase sound levels at noise-sensitive sites. No one type, construction method, or material will solve all the problems. The best combinations vary from range to range, depending on specific needs. Banks of trees are often favored but, in fact, are rarely effective. They take years to develop fully and need to be more than 50 m thick, with aisles spaced through them, to reduce sound levels substantially. They can scatter rather than reduce sound. Vegetation barriers need to be managed to maintain their density. Finally, they can make the reclamation of spent shot difficult, as noted previously. Trees can provide visual barriers between a range and the surrounding people, enhance the wildlife interest of the site, and act as windbreaks in exposed areas.

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Artificial barriers or berms can be an effective solution to noise problems since they can be tailored to the specific requirements of the range. Their effectiveness depends on their design and positioning in relation to the source of sound and the sensitive areas. They should be close to the source and acoustically “soft” to help absorb the sounds. Two or more barriers can be placed around a given shooting stand. Their effectiveness is increased if the stands are set into the ground so that the guns project just above ground level. Large straw or hay bales around a stand can provide cheap and effective sound reduction. Once individual stands have been considered, larger berms can be constructed strategically around the periphery of the range. They should be built in a way to prevent echoes and to be environmentally friendly. Permission to make such constructions on the site may be needed from the local administrative authority, and advice from acoustic engineers is strongly recommended.

Sound barriers Sound barriers and berms may be expensive to construct and take up • permanently depress sound levels from the range; land, but they can have additional • can reduce the land needed for the range since less benefits beyond sound containment. separation is needed from its neighbors; • break the line of sight between the range and neighbors, which can reduce local opposition; • increase safety for range users and workers; and • reduce the natural air flow, perhaps decreasing airborne lead (and other compounds) exposure to the shooters and range workers.

If perimeter berms are vegetated with shrubs and trees, they can improve the appearance of the range (provided the vegetation does not increase noise problems). Another form of barrier, vegetation on the ground, can help reduce sound propagation from shooting. Maintaining a grass covering is better than hard, bare surfaces from which sound waves readily reflect. Such a covering should be compatible with other management needs, including the recovery of lead shot, cartridge components, or clays. Vegetative covering can also control runoff (see Section 3.9).

Care is needed where shooting stands are set on concrete or other hard material and provided with some form of weather protection. The combination of hard surfaces can cause increased sound reflection and greater sound levels.

Bullet traps, baffles, and side berms may be enough to control sound levels. If large-caliber rifles are used, then side berms or walls on either side of each firing line may be needed. Further sound reduction, particularly from muzzle blast, can be achieved by roofing each firing line, but some roof designs can amplify sounds. The use of side and end berms for bullet containment, each up to some 2.5 m high, can reduce sound levels by 10–20 dB. Greater reductions can be achieved by creating narrow alleyways with berms or other structures, each some 2 m wide, from the shooting position to the target.

As circumstances and local needs dictate, additional measures can be considered:

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• Firing positions can be partly surrounded by sound-absorbing materials, such as glass or rock wool. • More effective is the partial roofing of the positions with similar materials to reduce muzzle blast levels. • Bullet sound levels can be greatly reduced by applying sound-absorbing materials on side baffles and hanging plates of sound-absorbing material from overhead baffles at around 1-m intervals, down the range. • Where several ranges lie parallel to each other, sound-absorbent partitions can be placed between them. • Tube ranges assist in the reduction of sound. (The “tube range” is aptly named simply because it involves shooting within a tube to attenuate or redirect sound. The muzzle is enclosed and muzzle blast is reduced in many directions. It has been criticized by shooters because of the sound directed back at the shooter and gasses). • Impact surfaces on bullet traps can be covered with sound-absorbent materials.

Weather Influences

Weather is particularly important on the propagation of shooting sounds. During windy conditions, for example, the sound from the range may be hardly audible in upwind locations, but up to a 30-dB increase in sound levels can be recorded downwind. Under clear skies and calm winds, sound propagation can be at its greatest; however, a layer of snow or low clouds can cause reflect/redirect sound and therefore increase its perceived level. The range manager can’t control the effects of local weather, especially where they vary greatly, but it is worth being aware of weather effects on shooting sound propagation.

3.12.3 Measurement of Shooting Sound

Before a shooting sound reduction program is considered, the sound levels produced by the proposed or current shooting stands should be measured. This step gives a baseline both for comparison with any government limits applying in the vicinity and for assessing the effectiveness of any sound reduction measures undertaken. Sound measurement is complicated by the facts that different characteristics of sound can be measured, equipment and units of measurement vary, and interpretation of results can be difficult.

An International Working Group, CEN/ISO, with experts in acoustics from around the world, is developing ISO standards on the measurement and prognosis of shooting noise for new or existing ranges. These standards will provide the measurement criteria necessary to calculate and assess the effect of shooting sound in the vicinity of a range. The standards will allow the calculation of ambient shooting sound levels without the need to record individual sound measurements. If no emission data for the specific range and its buildings are available, methods are given to obtain these data from measurements in the vicinity.

3.12.4 Sound Suppression

The development of sound suppressors (“silencers”) or sound moderators for sporting and target shooting use is increasing. They can be used on rifles and pistols and can remove the need for

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special sound containment measures on a range. Some designs are specifically for supersonic, high-powered ammunition. Regulations on the use of suppressors vary from country to country. Suppressors control only muzzle blast, reducing large-caliber sound levels for shooters from ~160 dB to <140 dB, and, at 10 m to the side, to <130 dB. They do affect the mean point of impact, but this factor can be corrected by adjusting the sights.

Suppressors cannot affect the ballistic downrange sound from a supersonic bullet. Management of this source of shooting sound may still need berms or other constructions. The use of subsonic ammunition is particularly beneficial with suppressors (or with standard rifles and pistols). The main benefit of suppressors is to reduce the overall sound levels from a rifle/pistol range, which may then reduce the need for greater separation distances from human habitation. They also help to protect the hearing of range users and bystanders. For a given rifle/pistol range, a combination of management techniques may provide the most cost-effective means of controlling sound levels. Siting and other factors are also important.

3.13 Newer and Emerging Technologies

A variety of new or emerging technologies and research on existing technologies with new application may have a role in managing environmental conditions at a given range. All of the following have applications but depend entirely on range characteristics and shooting practices. Many are being developed for military applications and are not likely cost-effective in commercial and private applications. They are, however, valuable to the industry and should be considered and tested at the appropriate level before investing in fully operational systems. The status of several technologies at the time of this writing is described below. They will have advanced by the time you use this guidance, so Web addresses are included where possible to facilitate access to updated information that may be available on specific technologies or techniques. The DoD Environmental Security Technology Certification Program (ESTCP, see http://www.ESTCP.gov) is a major source of the following information.

3.13.1 Berms

Copius Sand Trap—Improvements to the traditional berm are the Copius Sand Trap, developed by Copius Consultants, and the PRBerm, a collaborative effort between the U.S. Army Engineer Research and Development Center (ERDC) and AMEC Earth and Environmental. For the Copius Sand Trap, a sand berm is constructed within a concrete catchment. The design includes proprietary water collection and recycle systems such that all water contacting the berm is collected and recycled for dust control. The PRBerm involves cutting a notch in the face of the impact berm, using a nonwoven geofabric to isolate the native soil from the ballistic sand, and placing ballistic sand, amended with Apatite II, in the berm face.

Maintenance is simplified for the Copius Sand Trap and the PRBerm, as the ballistic media in each is an easily sifted sand. Sifting can be by hand or with a rotary screen bucket mounted to a skid steer loader. For the Copius Sand Trap and the PRBerm, vegetation is not present in the impact area but is established on areas outside the impact area to prevent erosion. Vegetation in the impact area can hinder lead recovery efforts.

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Granular-Rubber Trap/Berm—The granular-rubber berm is similar to both the Copius Sand Trap and the PRBerm, except that granular rubber is the ballistic media instead of sand. While it offers very good bullet capture, it is a flammable material and could pose problems when using full automatic weapons or firing tracers. In collaboration with SuperTrap, ERDC has developed an improvement to the granular-rubber trap, incorporating a water-retaining gel to provide integral fire suppression.

For granular-rubber traps, maintenance is not as simple and requires specialized pneumatic separation equipment to recover the spent rounds from the rubber media. Also, continued heavy use can cause the rubber particles to break down, requiring disposal of the degraded particles and replacement with new media.

3.13.2 Shot Curtains

The Massachusetts Department of Environmental Protection is working with researchers from the University of Massachusetts at Dartmouth, with the support of a grant from the Massachusetts Strategic Envirotechnology Partnership, to evaluate suitable and cost-effective materials for the construction of shot curtains. The Massachusetts Lead Shot Initiative team has estimated that about over half of the state’s 150 shooting sports clubs could use a shot barrier on trap or skeet ranges to prevent lead from landing in or near wetlands/waterways or off property and to limit the shot fall zone. The research to date has made some initial identification of fabrics that meet the cost and durability criteria. Researchers teamed with a textile manufacturer to produce sample materials for field testing in 2004. A number of Massachusetts shooting sports clubs are consulting on the project and have agreed to participate in the field testing.

3.13.3 Phosphate-Based Stabilization

Purpose—Soil and groundwater in the United States at numerous locations are contaminated with metals, including lead. Phosphate-induced metal stabilization (PIMS) is a technology developed to treat the metal contamination in place, either by mixing the amendments directly into the soil or by emplacing the amendments within a permeable reactive barrier to passively treat groundwater. At the U.S. Army’s Camp Stanley Storage Activity, a subinstallation of Red River Army Depot, in Boerne, Texas, a demonstration of an in situ process using PIMS for remediation of lead-contaminated soil from training ranges will be conducted.

Description—PIMS stabilizes metals using a natural and reportedly benign additive, Apatite II, which chemically binds the metals into stable, insoluble minerals. PIMS technology is applicable for cleaning up soil and groundwater contaminated with soluble lead and other metals. Treatment can occur in place or in an aboveground facility. PIMS is suitable for all types of soil and groundwater and for all contaminant concentrations, from parts-per-billion to weight-percent levels. PIMS reportedly reduces the bioavailability of the metals if the treated soils are ingested, which is particularly important for public health concerns. Apatite II can hold up to 20% of its weight in lead, uranium, or other metals, and once the metals are sequestered, they are stable under a wide range of environmental conditions for geologically long time periods. The sequestration reactions are fast, occurring in seconds to minutes. PIMS has been tested successfully at bench to pilot scale on soils and water from mining sites and Department of

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Energy sites through Small Business Innovative Research, EPA, and Strategic Environmental Research and Development Program–funded efforts. The ESTCP demonstration at Camp Stanley Storage Activity will be the first field-scale demonstration of this technology. This demonstration will validate the technical effectiveness and costs associated with the application of PIMS for the remediation of lead-contaminated soil.

Benefits—The benefits of this technology are the ability to treat the metal-contaminated materials in place without removal and disposition at a landfill or other treatment facility. Apatite II, available in large quantities at relatively low cost, can be mixed directly with contaminated soil; used as a liner; or mixed with grout, clay, and other reactive media. In addition, PIMS can potentially be used in combination with other technologies, such as soil washing. The technology should not harm existing ecosystems and, therefore, may be ideal for revegetation efforts and wetlands development.

Lead Immobilization Using Phosphate-Based Binders—In situ solidification/stabilization, the most used in situ metal treatment technology, reduces the metals’ mobility although metal contaminants remain in the soil and may cause long-term problems. If treatment is not complete due to issues such as poor mixing, future contaminant migration is possible.

Recent studies have shown that the in situ treatment of soil with phosphate-based binders reduces soluble lead and other metals contaminants to below the RCRA standards for hazardous waste. The phosphate-based binders react with the metal ions, such as lead, to form insoluble metal phosphate complexes called “pyromorphites.” Phosphate binders can be added in many forms that will create the desired pyromorphites; however, the kinetics of the reaction depend on the phosphate form. In situ treatment methods include land-farming application of the binder (plowing and grading), injection, and surface application of the binder, as well as mixing the binder with the soil in situ via auguring. With the soluble fraction of the metal contaminants bound by the phosphate binders, the only remaining mobility pathway is surface transport of particulate metals by quick-moving surface runoff to nearby streams. Erosion control measures may be necessary to eliminate this mobility pathway. Another concern is the potential transport of the phosphate binder out of the treatment area through leaching or physical transport, thus leaving any elemental lead particles free to oxidize and form soluble, mobile complexes.

The ESTCP demonstration project (http://www.estcp.org/projects/cleanup/200111o.cfm) validating the long-term immobilization of lead via phosphate amendment will assess the effects of erosion and precipitation on the in situ application of various forms of phosphate binders. The project will use treatment methods employing phosphate-based binders coupled with appropriate leaching, wind, storm water runoff, and vegetation monitoring methods to assess the stability of the treatment area and the potential for metals or phosphate transport. Potential effects of changes in the redox and pH characteristics of treated soil on the stability of the insoluble phosphate complexes will also be investigated.

Immobilization of metals eliminates the risk of metals migration to groundwater and surface water receptors. Also, as a result of the insoluble lead species formed, the bioavailability of the lead remaining in the soil is greatly reduced. Reducing the bioavailability of the species may lead to less-restrictive cleanup requirements. With approximately 200 small arms ranges currently slated for closure (or transfer), the cost savings to DoD alone could easily be in excess of $100 million.

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Lead Stabilization using Phosphates (U.S. Army Corp of Engineers)—Through the Environmental Quality and Technology program, the U.S. Army Corps of Engineers has performed the first laboratory rainfall simulation study on soil treated using phosphate amendments (Larson et al. 2004, Figure 3-11). A complete mass balance for the lead and phosphate leaving the treated soil through runoff and leaching was determined for four phosphate treatments with rainfall of a neutral pH and an acid rain. In none of the four treatments (1% and 5% potassium phosphate and 1% and 5% hydroxyl apatite) was there a statistically significant reduction in the total lead leaving the simulator system. Reductions in the mass of lead Runoff leaving the system as dissolved lead outlets in both the leachate water and the runoff water and the total lead in the leachate water were observed, but Runoff these reductions were less than the exit tube increase in the total lead leaving the system in the runoff water. With On/off regards to phosphate, all four valves systems had elevated phosphate Lysimeter levels in both the runoff and the stand Leachate leachate from the systems. exit tube Potassium phosphate showed levels Figure 3-11. Test simulator system. exceeding 1 g/L.

Many claims are made about the effectiveness of berm amendment using phosphates. The state of the practice is that a demonstration of the effectiveness of the technology has not been performed. The work performed at ERDC is indicating that phosphate treatment may exacerbate lead transport from berms.

3.13.4 Vacuuming

Vacuuming has traditionally been used for removal of lead shot from trap, skeet, and sporting clay ranges. Another way to apply this method involves removing the top layer of an earthen backstop or sand trap with shovels and spreading it thinly over an impermeable material such as plywood. A vacuuming device is then used to collect the materials lighter than lead (e.g., sand or soil), while leaving behind the heavier materials (i.e., lead bullets/shots and fragments). The soil can then be returned to the range. This process is most efficient for dry, sandy soils without a lot of organic material. A more recent innovation is the use of a high-suction vacuum. This vacuum itself does not have to be moved about, since a very long hose (up to 600 feet) is used to move in and around trees during the collection of lead shot at trap and skeet ranges (Figure 3-12).

For ranges on hilly, rocky, and/or densely vegetated terrain, several reclamation companies employ a vacuum system that collects the lead shot (and soil and other detritus). The resulting mix is then placed into the reclamation machinery discussed above. This method is especially effective for sporting clay ranges where lead shot tends to pile up around tree bases.

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3.13.5 Lead-Free Projectiles for .22- Caliber Ammunition (http://www.estcp.org/projects/pollution/ 200203o.cfm)

Purpose—The military services use .22-caliber ammunition primarily in training environments. The goal of the training is to familiarize recruits with the nature of ballistic performance and weapons in general. Current military specifications specify lead as the only approved material for the projectile. The .22-caliber lead projectiles weigh Figure 3-12. A lead recovery demonstration at a approximately 40 g. Based on the central Massachusetts range (2001, sponsored by average of the next five years of Massachusetts Lead Shot Initiative partnering with production, this weight translates to a total lead production requirement of the National Shooting Sports Foundation). more than 8,500 pounds of lead per year for this round. This lead not only vaporizes at the weapon as a result of normal firing but also enters the environment when the projectile terminates in berms and sand traps at firing ranges. The current medium-caliber ammunition used during training presents a hazard to human health and the environment.

Description—The overall objective of this project is to eliminate the use of lead in .22-caliber ammunition by demonstrating the viability of using a commercial off-the-shelf (COTS) projectile that qualifies according to the ammunition specification and manufacturing operation requirements. Commercial projectile suppliers will be solicited to provide lead-free .22-caliber projectiles that are expected to meet the performance requirements. These products will be evaluated against the present specifications (MIL-C-70600 and MIL-C-46935) and a qualification test program to be developed jointly through the Non-Toxic Working Group.

Benefits—The economic benefits of lead-free ammunition accrue over the total life cycle of the round. Over the last few years, installations that own firing ranges have halted training because of lead contamination. This lead concentrates in soils and becomes a problem with regard to rainwater runoff and biological uptake. Indoor ranges also have been closed due to airborne lead contamination. By eliminating lead from the projectiles, ranges can continue to operate without causing further damage to either people or the environment.

3.13.6 Field Validation of Real-Time Airborne Lead Analyzer (http://www.estcp.org/projects/compliance/199905v.cfm)

Objective—Many (DoD) facilities require rapid, on-site measurements of airborne lead levels to ensure worker safety and verify that the OSHA permissible exposure limit (PEL) of 50 μg/m3 has not been exceeded. EPA has mandated (40 CFR 50) monitoring at lead-based paint facilities and firing ranges. Current OSHA protocols require personal breathing zone (PBZ) samples to be

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sent to an off-site laboratory for analysis, resulting in delayed reporting times and high compliance costs. Field demonstrations of the portable AeroLead™ PBZ Analyzer were conducted at shooting ranges at the Naval Amphibious Base in Little Creek, Virginia and at the Marine Corps Air Ground Combat Center facility in Twentynine Palms, California. The AeroLead™ analyzer was also tested on aerosol lead samples generated under controlled conditions at the Oak Ridge National Laboratory in Tennessee.

Results—The AeroLead™ analyzer automatically samples and measures metal concentrations in ambient air. Air samples are drawn through a sample filter/detector assembly. The airborne lead is then extracted and concentrated into a specially designed aqueous phase consisting of dilute hydrochloric acid and extractants and analyzed voltammetrically. An integrated airflow meter is used to determine air-sample volume, which is combined with the voltammetric data to yield an accurate airborne lead concentration. The instrument then automatically resets for the next sample. The analyzer has the capability to automatically measure airborne lead concentrations to below 10 μg/m3 within a total sampling and analysis time of 15 minutes.

AeroLead™ did not meet all of the performance criteria during this program and therefore was not validated. A high degree of variability was observed in performance between the analyzer units at the three standard lead concentrations tested (126–356 μg/m3). Interinstrument variability contributed to an overall precision for all instruments of 65%–82%. Interinstrument variability in accuracy (bias) ranged 29%–74%. Capture efficiency (100%) and extraction efficiency (91%) were validated under this program.

Benefits—The AeroLead™ analyzer has several advantages, including rapid, cost-effective turnaround of analytical results and enhanced health and safety for on-site workers. These features will enable workers to adapt to changes in the ambient lead concentrations during training, cleanup, or lead abatement activities and permit rapid reoccupancy of recently abated buildings. Estimates indicated that costs would have been reduced from $25 to less than $3 per sample, which means that potential DoD-wide savings alone could exceed $100 million.

Implications—The primary source of the interinstrument variability was traced to response differences between working electrodes. The manufacturer is currently improving working electrode design and manufacturing techniques so that sensitivity/response issues may be resolved.

3.13.7 Shock-Absorbing Concrete (SACON) Bullet Traps for Small Arms Ranges (http://www.estcp.org/projects/pollution/199609v.cfm)

Objective—Small arms training is a requirement in all branches of the military. In a typical year, small arms training activities consume over 300 million rounds and add 1–2 million pounds of lead to the ranges in the form of bullet debris. Because elevated levels of lead in groundwater and soils can present a health hazard, the migration of heavy metals can result in environmental regulators imposing training restrictions that ultimately would reduce operational readiness. The innovative use of SACON, a low-density, fiber-reinforced foamed concrete, was demonstrated as a bullet-trapping technology to address the lead issues on small arms ranges at West Point, New York and at Fort Knox, Kentucky (Hudson, Fabian, and Malome 1999).

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Results—SACON bullet traps tested in a 25-m range application contained 87% of the bullets fired at the trap. The majority of the released fraction of bullet debris was deposited immediately in front of the trap, forming a debris pile. Exposure of the bullet debris to the SACON material resulted in the formation of insoluble lead corrosion products. As a result, even though lead concentrations in the trap and debris pile exceeded 60,000 mg/kg, all weathered SACON debris removed from these ranges was classified as nonhazardous, with TCLP levels below 5 mg/L, and was disposed of as a solid waste. Soil erosion resulting from repeated bullet impacts was reduced in front of and behind the target emplacements by burying SACON in these areas. Ricochet testing determined that SACON had no effect on the SDZ of the range.

Benefit—SACON offers significant benefits in comparison to current COTS technologies and provides a means of effectively capturing and containing lead on small arms ranges. It is able to inhibit the leaching of lead corrosion products. Other COTS bullet traps and soil berms do not have this lead stabilization capability. SACON is not flammable and can be formed in any shape, making it adaptable to more range applications than standard COTS technologies. The waste generated from the use of SACON is not classified as a hazardous waste and can be disposed of as a solid waste. Fixed, start-up costs were estimated at $1,600 per 25-m firing lane. Annual operating and maintenance costs were between $1,000 (low use) and $3,800 (high use) per firing lane. At low usage (7,500 rounds per year per lane), SACON becomes cost-competitive with conventional soil-berm technology on ranges with medium to high risk of lead transport.

Implications—SACON is a technically feasible method of capturing and containing lead on small arms ranges. However, like all bullet traps, it is an expensive means of mitigating lead transport from ranges and should be considered as a last resort for keeping ranges environmentally compliant. Other methods of reducing lead transport risk should be investigated prior to installing any bullet trap technology. New methods of stabilizing the lead on the range and mitigating physical lead transport in storm water runoff are being developed and may provide more cost-effective means of reducing lead transport risk and bioavailability.

4. ENVIRONMENTAL MANAGEMENT PLANNING

An environmental management plan provides a written Environmental Management framework for planning, implementing, and monitoring Planning progress of good environmental stewardship at a range. Once 1. Site characteristics the manager has assessed the features of a range, potential 2. Evaluate general environmental issues need to be identified (see Section 2). The environmental conditions 3. Select BMPs potential environmental issues determine what problems may 4. Develop plan arise and provide the basis to select suitable management 5. Implement options (Section 3). The environmental management plan then 6. Monitor documents the management techniques, schedule for implementation of priorities, and methods of evaluation and documentation of the management option’s performance. See Appendix C for an example outline of an environmental management plan. An environmental management plan and supporting documentation helps demonstrate that the range manager has an active commitment to care for the environment. They can become especially helpful if regulatory action is taken against the range on environmental issues. Well- planned and -executed environmental management using the best available technologies and

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documenting their performance may help ensure that lead is not classified as discarded or abandoned. Implementing a well-written plan demonstrates that identified environmental concerns are being appropriately managed.

As noted in Figure 2-1, the process of gathering and assessing the necessary information is valuable itself. It helps the range manager understand the interrelations among the many factors involved in managing range environmental conditions effectively and identify the most important issues to be considered first. The selection of the most cost-effective management options and the careful monitoring of their effectiveness then help assure any interested person or organization that the range is being managed both successfully and responsibly with respect to human health and environmental protection.

The public is becoming increasingly aware of environmental issues in general and seeks assurances that range activities are not adversely impacting human health or environment. A plan to listen to the concerns of neighbors provides an opportunity to discuss both the safety and environmental programs incorporated into the operating plans for the range. It is particularly important to inform the community of the safeguards that you are taking to protect the environment. Putting a well-designed and implemented environmental management plan in place helps provide those assurances. Range owners and operators should become involved in local community meetings, zoning boards, and other community activities. Being a part of the community helps others recognize the range as a valuable community asset.

4.1 Site Characteristics Step 1 The first step in preparing an environmental management Evaluate the facility site to determine its environmental features plan is to evaluate the range facility to determine its and physical characteristics. general environmental features, physical characteristics, and operational attributes. Several sources of information may already be available at the facility or readily obtainable through public sources, some of which are included in the bibliography of this guidance. Table 4-1 lists additional sources of information.

Geological and hydrological maps are useful to determine the type of geologic material beneath the soils profile and the depth to groundwater and whether there are any sensitive groundwater sources (aquifers). Information concerning bedrock may be an indicator of conditions affecting the acidity of surface waters (e.g., limestone areas are typically not acidic). Hydrologic maps give further information on depth to groundwater; show the drainage patterns created by rivers, creeks, and lakes (watersheds); and sometimes show the floodplains of streams, which may influence decisions if a range or components of a range are sighted in a Wetlands, including those entirely on designated floodplain. Soil maps provide useful private property, are protected by law and cannot be filled, dredged, or information regarding the type of soil likely to be found otherwise modified without a permit. at any particular site along with a wealth of information Range managers should consult county regarding soil properties, such as thickness, NRCS offices to determine whether permeability, engineering characteristics, stratified there is a wetland on their range. compositions, and vegetation supporting capacity.

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Table 4-1. Sources of information Criteria Source Purpose Geological • U.S. Geological Survey (USGS, • Evaluate drainage http://www.usgs.gov) and state geologic • Factors affecting acidity survey maps • Land use planning constraints • Background lead concentrations Hydrologic • National Oceanic and Atmospheric • Rainfall patterns Association (http://www.noaa.gov) • Depth to subsurface groundwater • USGS and state geologic survey maps • Drainage patterns • Flood potential and frequency • Land use planning • Temperature Soil • Natural Resource Conservation Service • Soil properties soil conservation surveys (by county) • Soil stability • Drainage characteristics • Vegetation limitations • Background lead concentrations Wetland • National Resource Conservation Service • Soil properties delineation (by county) • Soil stability • Drainage characteristics • Vegetation limitations Topography • USGS 7.5-minute quadrangles • Site elevations • Drainage patterns • Land use Aerial • USGS • Drainage photographs • Local universities • Ground cover (vegetation) • Planning departments • Stressed areas • Land use Site layouts • Construction plans • Shooting positions and shot fall zones • Maps produced for site design and • Berms operations • Buildings • Roads Water quality • USGS databases • Support facilities (water and sewer lines, etc.) data • Laboratory results from on-site samples • Acidity • County extension agent • Background lead concentrations • Local university agriculture department • Suspended solids/siltation in water bodies • State and local environmental agencies • Concentration of other contaminants Number of • Operating records • Parking, restroom, trash facilities users • Business plans • Amount of lead • Club meeting notes • Frequency of recovery/recycling • Range control • Feasibility studies and projected use figures for new and/or expansion projects Number of • Operating records • Amount of lead targets • Business plans • Amount of target fragments • Club meeting notes • Frequency of recovery/recycling • Range control • Feasibility studies and projected use figures for new and/or expansion projects Months, days, • Business plans, club meeting notes • Timing of recycling and hours of • Range control • Magnitude of sound operation • Feasibility studies and projected use figures for new and/or expansion projects

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Criteria Source Purpose Current land • Planning boards or governments • Maintaining compliance use laws and • Installation environmental office • Planning expansions regulations

Many wetland areas have been mapped by the U.S. Fish and Wildlife Service or state natural resource agencies. Some areas may be categorized as wetlands because they meet certain technical criteria, yet they may not appear to be wet, marshy, or swampy to the public. An ITRC document (WTLND-2) provides a thorough description of the different types of wetlands. EPA also has a Web site specific to wetlands (www.epa.gov, search for “wetlands”). U.S. Fish and Wildlife maps provide official designation of these areas, which may be important when making range development or range modification decisions (see WTLND-2). Even though an area is not officially designated on government maps or may be too small to show on a map, it may nevertheless qualify as a wetland. Only a trained specialist can make a reliable delineation.

Topographic maps show site elevations (which affect drainage), line of site, steepness of slopes, many manmade excavation and fill features, bridges, roads, etc. If a range is small and the USGS maps are not at an adequate scale to provide useful information, the county planning department, the county extension agent, and local universities (NSSF 1997) can be valuable sources of general information about conditions relevant to environmental issues in the vicinity of the range. Aerial photographs can supplement map information. A “snapshot” using an aerial photograph often helps pinpoint areas of environmental problems such as stressed vegetation, eroding slopes, wetlands, and water bodies. Finally, each facility is likely to have some level of site mapping showing structures, ranges, and supporting utilities. These maps are important for comparing existing or planned changes with the environment “lay of the land” provided by other map and photo sources.

Other components of the range information baseline necessary for developing an environmental management plan are the operating parameters of the range. These are likely available in business and operating records of existing ranges, although they may have to be located and compiled. Information related to the type and amount of range use (e.g., number of shooters, amount of lead used, number of targets thrown, history of lead recovery/recycling) is important. Projections based on this type of information should be included in the business plans for range modifications and expansions and new ranges.

4.2 General Environmental Conditions

This section recaps issues discussed in Chapter 2. Step 2 Lead is the fundamental environmental issue facing Identify the potential environmental all outdoor ranges. Scientific evidence establishes circumstances that require management. that lead is toxic and can be harmful in excess quantities (see Chapter 2). The presence of lead shot or bullets in the environment does not necessarily mean that they will be ingested by birds and wildlife or cause unhealthy effects in humans. However, even if only a small proportion of lead deposited becomes mobile at a range, it could become significant if not properly managed (see Figure 2-1 for environmental mechanisms enabling lead to become a contaminant in the environment).

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Spent lead at ranges can interact Under certain conditions (ITRC 2003a, Section 2.5), shot or with the environment in a variety bullets may dissolve in water. Where conditions exist that of ways, if conditions allow. cause lead to dissolve, rainfall may carry dissolved lead into groundwater or streams, ponds, lakes, and wetlands, where it may affect water quality. It also may have the potential to be taken into the bodies of aquatic animals and plants, where it may affect these organisms or other organisms that eat them. Whether enough lead dissolves to cause adverse environmental effects depends on complex interactions of a variety of factors and can be determined only by an evaluation of the specific site in question. Some of the most important factors determining how much lead will dissolve include how acidic or alkaline the water is (pH below ~6.5 or above ~8.5 increases the rate at which lead dissolves; see ITRC 2003a, Figure 3-1) and how long the water stays in contact with the lead (less lead dissolves if the contact time is short). ITRC 2003a provides a detailed discussion on the stability of lead compounds in soils.

Lead shot can be accidentally consumed by birds as grit for the gizzard or can be mistaken for small seeds and eaten. These events can occur whether birds are feeding on land or in the water. Waterfowl are particularly susceptible, which resulted in the ban on lead shot for waterfowl hunting. Lead shot and small bullet fragments can also be accidentally eaten with food by birds and animals feeding on earthworms, soil insects, fallen seeds, and other foods that are eaten at the surface of the soil. Lead in the soil can be taken up by certain kinds of plants and may accumulate in leaves, seeds, and other parts that can be eaten by birds or animals. Once lead particles or lead-contaminated food is taken in by a bird or animal, that lead can be passed on to predators. For example, if a range shoots into a field of corn or similar crop, there may be potential for bird or wildlife ingestion of shot embedded in plants.

Lead tends to attach to clay particles in the soil, especially if the soil is not acidic (i.e., pH > 6.5). Lead attached to clay has a lower potential to enter groundwater but can enter surface water attached to clay particles that are eroded into a stream, pond, lake, wetland, etc. Groundwater that is below clayey soils is not likely to be contaminated by lead because water doesn’t penetrate clay layers very well and because lead in water that does reach clay layers tends to attach to the clay particles and not stay entrained in the water.

4.3 Selecting Best Management Practices Step 3 Preparation of an environmental Having identified the environmental issue(s) relating to management plan involves selecting the range, now identify the appropriate management the appropriate management and options, or BMPs, (Step 3) and incorporate them into a engineering solutions for the range and documenting the intended plan of action. This step requires careful consideration of course of action. many factors, including an estimated cost and the projected effectiveness of each option or the series of options, availability of equipment and techniques, ease of on-site implementation, likely benefits, timing, and others related to site and range business requirements.

Table 4-2 provides a comparative matrix to help evaluate alternative methods for managing environmental concerns. Each management option for a given issue can be scored under the description of the option at the head of the column. The totals of the scores for each option offer

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a guide to the more appropriate management option(s) for a given circumstances. A weighting factor may be added to particular criteria to place importance to certain parameters.

Table 4-2. Sample project evaluation comparison sheet Alternative projects (each in separate column) (Values: high = 5, moderate = 3, low = 1) Criteria Weighting Alt # 1 Alt # 2 Alt. #3 Alt #4 factor Health and safety impacts Erosion benefits Wildlife benefits Air benefits Surface water benefits Groundwater benefits Soil benefits Cost Level of professional assistance needed Impact on range operations Ease of implementation Timing Regulatory benefits Total score

This step results in an objective comparison of site-specific practicability, cost, and effectiveness of alternative solutions. This information is necessary to accurately assess the various options and document how decisions were made. It also guides range operators in setting site-specific goals that are within the means of the individual range (time, budgets, etc.). This process can be helpful if any question of management priorities arises from either internal or external sources.

4.4 Management Plan Development

Once the decision-making process is complete, the decisions Step 4 should be documented in the environmental management plan. However simple or intricate Table 4-3 contains a template for the plan itself and will be the format, it is important that helpful as an outline for a range’s first. This outline, modified some documentation take place to record the basis for from NSSF 1997, may be used by sports clubs and recreational, decisions and to lay out a military, or law enforcement ranges during environmental plan to guide future actions. management plan preparation as a starting point for tailoring a plan to a particular range. This template is simply a tool to assist range owners and operators to make preparation easier and should be modified to incorporate specific information relative to a given range. This template is intended to be used in conjunction with this ITRC document and does not serve as a substitute for understanding the concepts and techniques discussed in this manual. The objective of the plan is usability, not necessarily volume. Each plan can be as detailed or simple as desired. A brief but concise plan is used and referred to more often than a bulky and overly inclusive document.

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Table 4-3. Template for an environmental management plan ENVIRONMENTAL MANAGEMENT PLAN [Club or Range Name] [Address] [City/Town, State Zip Code] [Date] [Principal Contact] Table of Contents 1.0 Introduction 1.1 Environmental Principles of the Range 1.2 Purpose of Environmental Management 1.3 Goals of Environmental Management 2.0 Site Assessment 2.1 Description of Ranges and Support Facilities 2.2 Existing Environmental Conditions (Range Type 1) 2.2.1 Soil pH 2.2.2 Erosion Due to Storm Water Runoff 2.2.3 Distribution and Type of Vegetation on Range/Berms 2.2.4 Distance to Surface Water (Streams) 2.2.5 Distance to Groundwater 2.2.6 Wind Erosion 2.2.7 Distribution of Projectiles 2.3 Existing Environmental Conditions (Range Type 2) 2.3.1 Soil pH 2.3.2 Erosion Due to Storm Water Runoff 3.0 [Range Name 1] Action Plan (e.g., Trap and Skeet Fields, 25-Meter Ranges) 3.1 Action Plan 3.1.1 Potential Management Alternatives 3.1.2 Selection of Management Alternatives to Be Implemented 3.1.3 Alternatives Selected a) Management Actions b) Operational Actions c) Construction Actions 3.2 Plan Implementation 3.2.1 Schedule for Implementation 3.2.2 Responsibilities 4.0 [Range Name 2] Action Plan (e.g., Rifle, Black Powder, and Outdoor Handgun Range) 4.1 Action Plan 4.1.1 Potential Management Alternatives 4.1.2 Selection of Management Alternatives to Be Implemented 4.1.3 Alternatives Selected a) Management Actions b) Operational Actions c) Construction Actions 4.2 Plan Implementation

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4.2.1 Schedule for Implementation 4.2.2 Responsibilities 5.0 [Range Name 3] Action Plan (e.g., Sporting Clays Course) 5.1 Action Plan 5.1.1 Potential Management Alternatives 5.1.2 Selection of Management Alternatives to Be Implemented 5.1.3 Alternatives Selected a) Management Actions b) Operational Actions c) Construction Actions 5.2 Plan Implementation 5.2.1 Schedule for Implementation 5.2.2 Responsibilities 6.0 Measuring Success 6.1 Planned Monitoring Intervals 6.2 Planned Monitoring Variables 6.2.1 Erosion 6.2.2 Vegetation 6.2.3 Soil Type/Character (e.g., sand, silt, clay, organic content/nutrients) 6.2.4 Soil and Runoff pH 7.0 Plan Review and Revisions

4.5 Environmental Management Plan Implementation

Environmental management plans must contain a schedule Step 5 for implementing the desired actions. They need not occur An environmental management plan all occur at once nor immediately; in fact, staging the must contain a implementation actions over time may be necessary from a logistical or schedule, designated responsibility, financial standpoint. Simple, relatively low-cost actions and start and completion dates. (e.g., changing the mowing schedule or changing positioning of planned vegetative improvements) should be implemented immediately. These pay considerable environmental benefits and improve the facility’s local image. Implementing actions requiring larger investment must be integrated into out-year business planning. Low-cost sources of assistance from colleges and universities, civic and volunteer groups, public programs (e.g., local agricultural extension office) should not be overlooked as valuable methods of implementing various parts of the environmental management plan.

Implementation plans must also contain information concerning the primary person(s) or contractors responsible for carrying out the activities of the environmental management plan and outline the actions required to initiate and implement each environmental improvement. Table 4-4 provides a means of documenting each management action, the person(s) responsible, the start date and planned completion dates, and costs.

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Table 4-4. Sample projects implementation schedule (adapted from NSSF 1997) Person or Initial (I) or Completion Project or action primary Start date Cost recurring (R) date responsibility

4.6 Monitoring Review and Evaluation

Step 6 includes an evaluation of the success of the Step 6 environmental management plan, which should occur Monitoring and evaluation determine one or more times per year. It also provides whether the EMP is being implemented documentation of the results from the previous year’s as intended and what adjustments must be made to the implementation plan to activities. The focus of the evaluation is to determine achieve the desired goals. whether the environmental management plan has been implemented and performed as intended, the problems (if any) encountered, and what types of adjustments should be made. It is also useful to monitor the environmental benefits that have resulted from implementation of management and engineering actions. This step demonstrates and documents the effectiveness of the actions that have been taken.

Just as with other aspects of business, record-keeping is essential for evaluation of an environmental management plan. Typical records that may be useful in evaluating the effectiveness of a plan include but may not be limited to the following:

• range “inspections” by a range manager; • photographs of preexisting conditions versus conditions after environmental improvements have been implemented (“before” and “after” photographs); • log of actual implementation dates, problems addressed, associated costs, conditions, problems encountered, and follow-up actions; • frequency of changed operational practices (i.e., mowing on poorly vegetated soils) and observed results; • comparison of changes in operational costs related to changed procedures; and • frequency and type of environment-related complaints from customers or the public.

Quantitative measurement of environmental improvements may be beyond the capabilities of range operators and need not be burdensome unless they are necessary to support the resolution of a contentious issue. However, when necessary, evaluating the effectiveness of range modifications at reducing lead transport can be performed in a number of ways. Lead levels found in transport pathways (surface water/runoff, groundwater, air) can be measured directly or calculated as a change in transport potential. Two direct quantitative methods for measuring the effectiveness or success of range modifications are as follows:

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• comparison of lead concentrations in a particular transport pathway (surface water/runoff, groundwater, air) before and after range modifications and • comparison of lead levels to a regulatory standard or concentration goal after modifications.

An indirect quantitative method for measuring the effectiveness or success of range modifications for improving runoff water quality is to calculate a decrease in the potential soil loss. Estimated soil losses are highly dependent on the percentage of vegetative cover on a land area. Any increase in the percentage of vegetative cover on a range, as part of modifications or renovations, should result in a potential decrease in soil loss from erosion. Calculations using the Universal Soil Loss Equation can be performed to estimate the decrease in soil transport.

Regardless of whether direct measurement or an indirect quantitative method is being used, at least one full growing season (one year) should be allowed for vegetation growth before evaluating performance. Two full seasons (years) of growth and establishment are even more desirable to accurately judge the success of revegetation efforts to minimize erosional transport of lead.

5. CASE STUDIES

The following are examples of environmental management at ranges. They range from government programs designed to offer technical assistance to range managers in a voluntary compliance setting, to environmental management approaches at Army ranges. These are included to assist a range operator understand a variety of issues, tests, and approaches often encouraged at ranges to further the effectiveness of environmental management at ranges.

5.1 Massachusetts Initiative Case Study

In Massachusetts, environmental regulators have worked with the shooting sports community to improve the management of lead shot and other environmental issues at ranges. This partnership has developed into an innovative program known as the Massachusetts Lead Shot Initiative (LSI). By providing technical and compliance assistance to range operators, the LSI program aims to protect environmental quality at and around shooting facilities across the state.

This case study describes the development of the LSI and some of the progress it has made in communicating the necessity of lead management to range managers and identifying specific measures ranges should take to prevent or mitigate detrimental impacts from shooting on the environment. This case study also summarizes some of LSI’s most recent efforts in the areas of outreach, compliance assistance, and technology and guidance development.

Background

The Massachusetts LSI is a partnership between the Massachusetts Department of Environmental Protection (DEP) and representatives of the shooting sports community, including the Gun Owners’ Action League, Massachusetts Sportsmen’s Council, National Shooting Sports Foundation (NSSF), and others. The LSI works to protect wildlife habitat and environmental quality on thousands of acres owned and operated by ranges across the state. LSI

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achieves this goal by assisting range managers with their management of lead shot, bullets, and other environmental issues.

Massachusetts is home to more than 150 operating shooting facilities. These include shooting sports clubs, public safety ranges, and military ranges. Recreational and public safety ranges alone compose well over 10,000 acres of open space statewide with additional thousands of acres of military ranges. In this regard, shooting facilities play an important role in preserving natural resources and habitat as land development pressures continue to rise.

Unfortunately, within the areas of a range that are directly affected by shooting activities, lead from lead shot deposited on the ground or in some cases, into surface waters and wetlands, persists in the environment and can present a threat to wildlife, human health, and/or water quality. After decades of use, tons of lead can accumulate on each of these ranges. Acidic soil and acid rain conditions that exist in much of Massachusetts can dissolve lead shot, and dissolved lead, under certain conditions, can wash into surface waters or enter groundwater. Lead can also spread as airborne dust.

LSI Program Development

DEP developed the lead shot program strategy in 1997 in response to a growing need for a coordinated agency approach to range issues. At that time, DEP staff in different regulatory programs and regional offices were dealing with potential environmental or public health issues at several ranges. DEP was asked to intervene in cases where local conservation commissions had closed ranges because lead shot and targets were landing in wetlands. DEP was also involved in a case where a residential development was being built in the former shot fall zone of a closed club. In addition, DEP received an increasing number of complaints, often by gun club members, about the lack of lead management and environmental protection at ranges.

A DEP task force that included the Deputy Commissioner of Operations, a Regional Director, and other senior staff from the Office of General Counsel, wetlands, and RCRA programs was formed. It began reviewing how the agency had handled different cases, checking the case law, and contacting other states and the shooting sports industry. These efforts turned up ample evidence in the scientific literature that lead shot poses a threat to wildlife. The shooting sports industry already recognized the need for lead management at ranges and had begun the process of developing guidance on how to best mitigate the environmental impacts of shooting activities.

The task force put together a “white paper” on the lead shot issue. This paper, presented to senior DEP management, the Division of Fisheries and Wildlife, and the Secretary of Environmental Affairs, outlined the potential environmental problems posed by lead shot at Massachusetts ranges, the relevant legal and regulatory issues, and recommendations on how DEP should proceed in addressing lead shot. The task force advocated an approach of compliance assistance and enforcement discretion, focused on educating range managers and collaborating with the shooting sports community to advance environmentally sound practices at ranges. Members of the task force met with state legislators who, in turn, offered support of the proposed approach.

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DEP’s Cross-Program Team

In 1999, DEP assembled a team to implement the strategy developed by the lead shot task force. Because the issues of lead at ranges cut across several regulatory areas, by design this team comprises staff from the wetlands, hazardous waste management, and disposal site cleanup programs. The team members from the regional offices serve as the contacts for shooting facilities located in their respective regions. The members from headquarters coordinate the team’s efforts to ensure a consistent statewide approach.

LSI Partnership with the Shooting Sports Community

To effectively inform range owners/operators and club members about the risks posed by lead and the need for lead management at ranges, the DEP team began working with the Massachusetts Division of Fisheries and Wildlife and representatives from the Massachusetts shooting sports community, including the Gun Owners’ Action League (GOAL) and the Massachusetts Sportsmen’s Council in 1999. This group referred to its partnership and program as the “Massachusetts Lead Shot Initiative,” or LSI. Its initial priorities included developing an education and outreach program for range managers and gathering better information on the number, location, and environmental conditions at ranges across the state.

From the start, the LSI partners worked closely with representatives of the national shooting sports community. In particular, the group has partnered with NSSF and the Wildlife Management Institute. LSI has also participated in meetings of the environmental subcommittee of the Sporting Arms Ammunition Manufacturing Institute.

LSI’s early outreach included attending night and weekend county league and membership meetings at individual

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clubs, as well as presentations at annual meetings of the Massachusetts Sportsmen’s Council and GOAL. Articles about the program were published in MassWildlife and The Message (GOAL’s newsletter). LSI representatives also spoke about the program on a radio show for hunting and shooting sports enthusiasts. At informational seminars, DEP and GOAL gave coordinated presentations on the existing case law and regulations applicable to lead at ranges, the associated environmental and human health concerns, and the objectives of the LSI. The LSI partners also used these meetings to distribute copies of the NSSF guidance manual. By providing range managers with the opportunity to ask questions about the program, these early forums were key to addressing initial concerns and skepticism about the LSI approach and goals.

Range Visits

At every meeting with range managers and club members, the LSI partners also encouraged managers to invite LSI representatives to visit their ranges. Frequently, a representative from GOAL or the Massachusetts Sportsmen’s Council also participates in the visit. Many ranges are more comfortable having representatives from the shooting sports community in attendance. NSSF and Wildlife Management Institute representatives have also joined in a dozen range visits. These joint visits help to reinforce the LSI partnership.

During a range visit, the LSI representatives provide the range manager with an assessment of the facility’s current lead shot management and direction on correcting existing or potential problems. Such visits enable the LSI team to gather information on the types of problems that exist across the state, look for solutions that may be transferable from one range to the next, and identify any situations that pose an imminent environmental or human health hazard requiring short-term action. As part of the visit the LSI team completes a checklist to record observations and its recommendations for improved environmental management.

Issues Identified by Range Visits

As of the close of 2004, LSI partners have visited more than 100 sport, police, and military firing range facilities. The type (rifle/pistol, trap, skeet, sporting clays), size, and combination of ranges at these facilities vary widely, as do the amount of shooting and environmental setting. Environmental and lead management issues, consequently, depend on-range specific conditions. The LSI partners have found, however, that shotgun ranges—trap, skeet, and sporting clays— generally pose the greatest challenge for lead management. The primary reason is that the lead shot on these ranges is so widely dispersed and were more likely to include wetlands issues.

Bullets discharged at a rifle/pistol range are fired into a backstop berm located behind the targets. While potential lead migration is an issue that needs to be addressed at rifle/pistol ranges, it is one that can be managed in most cases by proper bullet backstop design and maintenance. In contrast, the shot fall zone on a single trap field covers about four acres. Shot is dispersed over an even greater area on a skeet field. Consequently, lead management measures to prevent or mitigate lead migration at trap and skeet ranges must be implemented over a much greater area.

A range’s environmental setting can further complicate lead management at trap, skeet, and sporting clays ranges. Most ranges in Massachusetts were set up long before environmental concerns were fully understood. Ranges were sited, in most cases, to face north, minimizing the

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sun in the eyes of shooters. Some ranges are oriented so that the lead shot and/or targets land in wetlands or waterways. At other ranges, the lead shot is landing beyond the facility’s property boundary. Of the more than 100 ranges visited by the LSI partners, approximately half were found to be shooting into or near wetlands or waterways; approximately 20% were shooting onto neighboring property.

N Shot Fall Zone Overlay Maps 300 0 300 600 Feet

To assess whether a range may be affecting a wetland/waterway or neighboring property, the LSI program produces range-specific maps (Figure 5- 1). These maps overlay the theoretical trap or skeet range shot fall zone developed by MassGIS on an aerial orthophoto of the range. At range visits, these maps are given to the facility managers to confirm the accuracy of the information and Drop Zones skeet provide them with a tool for assessing the extent of trap lead shot deposition. The maps can be used to evaluate and design appropriate alternatives to Figure 5-1. Example of a range overlay address lead management problems. The map. Theoretical trap and skeet range theoretical shot fall zone as it appears on the maps shot fall fans are indicated in blue and generally represents the maximum extent of shot pink, respectively. dispersion. Under actual range conditions, large trees or an upwardly sloping range can reduce the distance that shot travels.

Environmental Stewardship Plans

The range visit and overlay maps give range managers a starting point for evaluating lead management issues and potential environmental problems that are specific to their facility. Following each visit, the DEP LSI representative sends the facility a letter identifying any lead management or other environmental issues the range needs to address and alternatives for dealing with these issues. Every facility is asked LSI Bottom Line to develop a written best management practices • Stop shooting into wetlands or waterways. or “Environmental Stewardship Plan” (ESP) for • Stop shooting off property. its ranges using NSSF and EPA guidance. To • Control off-range migration of lead and assist clubs, DEP provides them with an other hazardous constituents. electronic ESP outline based on the plan format • Conduct periodic lead reclamation. that appears in Environmental Aspects of • Use nontoxic, biodegradable targets. Construction and Management of Outdoor Shooting Ranges (NSSF 1997, see Appendix C).

The environmental setting (soil types, soil pH, type and amount of vegetation, site slope and drainage) and the amount of past and current shooting activity vary widely from facility to facility. These are all factors that present different issues and obstacles for lead management. Consequently, the development of an ESP with the appropriate combination of management alternatives is a very range-specific process.

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The general objective of an ESP is the implementation of range improvements and maintenance activities that effectively eliminate detrimental impacts posed by the range or shooting activities on the environment or public health. Specifically, the LSI program directs all facilities to discontinue the discharge of lead shot into surface waters or wetlands, discontinue the discharge of lead shot onto any property not owned or leased by the facility, implement adequate measures to prevent any off-range migration/transport of lead and other hazardous constituents, and implement periodic lead reclamation. In addition, all facilities are encouraged to use nontoxic, biodegradable targets on their trap, skeet, and sporting clays ranges.

DEP’s post-visit letter specifies a time period by which the shooting facility should submit its draft plan so that DEP can review the management alternatives the facility intends to implement and the implementation schedule. If necessary, DEP as well as other LSI partners revisit a facility to go over the specifics of the draft plans and provide assistance on implementation issues.

Range Reorientation

Several Massachusetts facilities are in the process of reorienting ranges. Reorientation can involve changing the direction of shooting to prevent shot and targets from landing in wetlands or waterways or landing off property. Reorientation can also entail rotating shooting positions at trap, skeet, or sporting clay ranges to combine drop zones and thereby decrease the overall shot fall area. The latter type of reorientation not only reduces the area affected by shot; it also concentrates the shot in a smaller area, making it easier to reclaim. The LSI staff encourages all facilities to evaluate whether range reorientation can be used to reduce overall shot fall zone area. For facilities with limited acreage or land surrounded by wetlands or waterways, however, reorientation is rarely an option.

Shot Barrier or Curtain

In addition to range reorientation, a shot barrier or “curtain” can be used by facilities with a need to limit shot fall zone size or prevent shot from landing in wetlands, in waterways, or off property. Because captured lead pellets accumulate at their base, shot curtains provide the added benefit of making it easier to recover and recycle the lead. Four Massachusetts clubs to date have erected shot curtains using a woven nylon material suspended from telephone poles. Many other clubs are now considering doing the same (see Section 3.13).

Lead Reclamation and Recycling

At all trap, skeet, and sporting clays ranges where lead pellets have been deposited, the LSI partners are asking facilities to periodically reclaim and recycle the lead as scrap metal. Lead reclamation is routinely done at ranges in Midwestern states using excavation equipment to remove surface soil and lead shot and shaker screens to separate the shot from the soil. Reclaimed shot is subsequently sent to a lead smelter, where it is recycled for use in car batteries and other products.

Unfortunately, the terrain, soil types, and type and amount of vegetation at the majority of Massachusetts’ ranges, as they are currently constructed, do not easily lend themselves to lead

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recovery via soil excavation. Most trap, skeet, and sporting clays ranges are located on hilly terrain, covered with rocks, boulders, trees, and other vegetation. Lead recovery can be done at some ranges using a high-powered vacuum, however. The vacuum method was effectively used to recover tons of lead at a Massachusetts facility.

In partnership with NSSF, LSI sponsored the lead recovery and recycling demonstration project at a club in central Massachusetts. The project looked at the feasibility of using a vacuum truck to recover lead shot from a trap range (Figure 5-2). Over a two-day period 13 tons of lead was recovered from the top 1–3 inches of a 30- by 60-foot area of the shot fall zone. The lead and lesser amounts of soils/organic material recovered from the range were deposited into 55-gallon drums and shipped to a company where it was recycled for use in car batteries. Because of the amount paid by smelters for recovered Figure 5-2. Gray surface of range indicating lead increases as the purity of lead increases, location of lead shot pellets. At this facility, the finding better technologies for segregating density of metallic lead shot is greatly lead from soil, rocks, and organic material diminished a few inches below the surface. will make lead recovery more affordable.

Nontoxic Shot

Several Massachusetts shooting facilities have switched to using nontoxic (primarily steel) shot pellets at their trap, skeet, or sporting clays ranges. Some facilities are using club funds to make nontoxic shot available for shooters to use. Other facilities have switched to nontoxic shot on ranges where future lead reclamation would be extremely difficult, such as sporting clays ranges where the shot is distributed in irregular patterns in a wooded area. Facilities are looking at using nontoxic shot at newly constructed ranges to avoid the costs and effort of future lead management on those ranges.

Vegetative Maintenance/pH and Erosion Control

All Massachusetts facilities participating in the LSI program are asked to evaluate and, if necessary, manage the vegetation, drainage, and soil pH on their trap, skeet, and sporting clays ranges to reduce the potential off-range transport of lead. Vegetative maintenance can include planting appropriate grasses or other ground cover to prevent soil erosion. It can also include routine mowing of grasses to discourage the presence of wildlife on the range. Drainage controls can include changing the contour of the range to prevent or control surface water runoff. Ranges have been instructed to routinely monitoring soil pH and add amendments to keep it between 6.5 and 8.5. Maintaining a neutral to slightly basic soil pH keeps lead in a stable form, thereby reducing its potential to leach from shot and lead compounds in soil to groundwater.

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Environmental Stewardship Plan Workshops

In partnership with GOAL, NSSF, the Wildlife Management Institute, and EPA, DEP’s LSI staff sponsored two Environmental Stewardship Plan Workshops. Held in 2001 and 2002, the workshops were offered free of charge to representatives from 35 Massachusetts shooting sports clubs. GOAL provided the workshop accommodations, and both the Wildlife Management Institute and NSSF donated expert instruction. Club representatives received guidance from national experts on their range-specific draft ESPs to improve lead management and address other environmental issues.

Advances in Shot Curtain Material

LSI staff are working with researchers from University of Massachusetts at Dartmouth with the support of a grant from the Massachusetts Strategic Envirotechnology Partnership on evaluating and identifying suitable, cost-effective materials for the construction of shot curtains. The research has made some initial identification of fabrics that meet the cost and durability criteria. Once the candidate fabrics have been identified, the researchers plan to construct a full-scale curtain model and conduct field-testing (see Section 3.13).

Funding for Range Improvements

The LSI partners worked to secure $50,000 in Pittman Robertson funds from a program administered by the Massachusetts Division of Fisheries and Wildlife to help facilities pay for improvements related to environmental management of their ranges.

5.2 Florida Case Study—Best Management Practices for Environmental Stewardship of Florida Shooting Ranges

Florida has approximately 400 shooting clubs, and approximately 1 million shooting sports enthusiasts visit these ranges each year. A State of Florida manual, Best Management Practices for Environmental Stewardship at Florida Shooting Ranges (Florida Department of Environmental Protection Hazardous Waste Compliance Assistance Program 2003) focuses on lead, which composes 92%–98% of the weight of most bullets and shot. While lead is a natural element, it is rarely found in such concentrated form as in bullets and shot and therefore is rarely found in soils at the high levels encountered in range backstops, berms, and shot fall zones. Until recently people assumed that lead from bullets and shot was stable and therefore did not consider it a potential source of contamination. Based on recent and ongoing research, range owners and operators should recognize the potential environmental risks and understand the importance of managing facilities to minimize such risks. Range management ideas presented in the Florida manual are intended to help minimize, or even eliminate, the amount of lead that breaks down and poses a problem during the operational life of a range.

Florida depends on groundwater for its drinking water supply and on surface water for outdoor recreation industry. High rainfall and acidic conditions, typical in Florida, cause lead to be more mobile in the environment. Therefore, proper management of outdoor shooting ranges is especially important in the Sunshine State. The Florida manual provides owners and operators of outdoor, rifle, pistol, skeet, and sporting clay ranges with information on management of

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environmental issues. While each range is unique in both the type of shooting activity and its environmental setting, the Florida manual is a reference guide that presents reliable BMPs that effectively reduce or eliminate problems associated with lead. BMPs may also be economically beneficial to the range manager.

Federal, state, and local environmental and regulations provide a framework for environmental stewardship, as well as substantial potential liabilities for poor stewardship. Citizens as well as regulatory agencies may bring suits to enforce compliance with applicable laws.

Florida encourages an environmental stewardship program that includes a written plan or roadmap for planning, implementing, and monitoring the progress of environmental improvements at shooting ranges. By developing and implementing an environmental stewardship program, range management documents its commitment to the environment and the community. Environmental stewardship means taking action to correct current problems and working proactively to prevent future ones. Some of the benefits ranges may realize from implementing BMPs as part of an environmental stewardship program include the following:

• increased protection of the environment, • evidence of proactive stewardship, • documentation of any environmental concerns, • identification of effective and appropriate solutions for any environmental concerns encountered, • development of information on which to base prudent decision making, • planning and soliciting support for funding of range improvements, • enhanced community relations, • better range aesthetics, • improved profitability through recovery and recycling lead, and • reduced public and regulatory scrutiny.

A variety of cost-effective operational and engineering techniques can be used to successfully manage environmental issues at an outdoor shooting range. Some can be implemented immediately; others require long-term planning.

Every owner/operator of a shooting range should begin an environmental stewardship program by documenting the physical and operational characteristics of the range. This process includes description of the facility, documentation of current and past operating practices, and an assessment of existing environmental conditions. An essential element of environmental stewardship is documenting activities and keeping accurate records:

• range inspections; • photographs of preexisting and improved conditions; • logs of actual problems encountered and follow-up actions, implementation dates, associated costs and range conditions; • logs of changed operational practices and observed result; • comparison of changes in costs related to procedures; and

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• frequency and type of environmentally related complaints or compliments from customers, the public, and the regulatory agencies.

Management techniques as described in Chapter 3 of Florida’s manual contain BMPs available to protect the environment from the impacts of shooting sports at an outdoor range. A five-step approach to lead management is as follows:

• Evaluate existing environmental conditions. • Control and contain lead bullets and bullet fragments. • Prevent migration of lead to the groundwater and surrounding surface water bodies. • Periodically remove the lead from the range and recycle it. • Document activities and keep records.

Some combination of BMPs will be appropriate of any particular range.

The Florida Department of Environmental Protection is very interested in any suggestions readers might have about practices in this manual that may have proven effective in preventing lead migration from a range or in recycling led bullets or shot. The full Florida manual can be viewed and downloaded at the following Internet address: http://www.dep.state.fl.us/waste/categories/hazardous/pages/lead.htm.

5.3 Fort Rucker Case Study

Abstract

The demonstration objective was to mitigate the off-range migration of projectile-related hazardous metal (lead) and identify techniques that the Army could apply to some of its thousands of small arms ranges. This work demonstrates that, for a 25-m range with a berm, lead transport originates primarily from bullet impact depressions (pockets) and soil splatter piles (toes) near the base of the berm. More than 90% of the rounds hit and pulverize soils in pocket and toe areas, creating concentrated source areas. High-energy, storm-generated runoff can move particles, particularly fine-grained material, from bullet pocket areas away from the range.

Some lead migration mitigation techniques were proven useful in this demonstration:

• The addition of bentonite increases slope stability and decreases berm surface erosion. • Erosion matting promotes vegetation. • End berms and range grading help manage storm water runoff. • A detention pond captures some but not all lead particulate material.

Water samples indicated that dissolved lead was not a problem at Fort Rucker’s South Range. With regard to mitigating potential lead dissolution, all five test cell bullet pocket/toe areas failed TCLP by a significant margin after six months of firing. These data suggest that these chemical technologies (clay amendments and phosphate fixation), designed for landfill applications, are inappropriate for whole berm application on most operating ranges where significant lead addition and soil disturbance occurs over small areas (pocket/toes).

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Partial Project Details

(The full report is Environmentally Redesigned Small Arms Range Demonstration Final Report, SFIM-AEC-ET-CR-97042, September 1997.)

The demonstration ran from September 1995 until April 1997 at the 25-m South Range at Fort Rucker, Alabama. The project team left the existing berm in place, excavated high-concentration (lead) surface sediments from the berm and range floor, and removed 78%–81% of the lead by sieving. The sieved soil (866 mg/kg lead) was used to reconstruct the range, which included a large main impact berm, two end berms, a detention pond, and range grading to focus rainwater runoff from the main berm toward the detention pond. The team applied five chemical/physical soil stabilization technologies to the sieved soil and placed this material into five test cells on the berm front. Two test cells used proprietary chemical techniques to reduce the leachable lead while the remaining three test cells used clay or bentonite. Clean soil from a borrow pit (12 mg/kg) was used to construct the remaining range.

The project team collected soil samples five distinct times at South Range: before construction, just after construction (baseline), and three times (two, four, and six months) during live firing on South Range. Soils were tested primarily for lead: total lead and TCLP. A wooden divider system separated the five test cells so that runoff water and sediment from the cells did not commingle on the berm face or at the toe of the berm.

Clogging of automated storm water samplers prevented cell-to-cell comparisons of lead migration. Only nine individual samples were taken. These nine storm water samples were analyzed for dissolved phase lead (filtered), total lead (including particulates), and total suspended solids.

Bullets were tallied to allow calculation of lead mass fired into each test cell. This mass was compared to the starting mass of lead in each test cell (sieved soil) and to the actual lead mass found in each test cell. After six months of firing, the team calculated that approximately 50% of the total lead mass for each test cell should reside in bullet pocket/toe area (90% firing accuracy and an average of 3956 rounds per target) and that the remaining 50% came from the sieved soil (averaged 877 mg/kg) spread over the whole berm front. Predicted six-month lead masses in bullet pockets and toes exceeded actual lead mass (calculated from concentrations), suggesting that lead shot into test cells moved off of the berm.

Photographs and measured lead data in runoff channels and automated samplers also suggest that lead moves away from the berm by physical particle migration in surface water. Soil lead concentrations decrease with distance from the berm to the detention pond inlet (see Figure 6 in the full report, excerpted in Figure 5-3 below), indicating the berm as the source area and therefore the pockets, since pockets should contain 50% of the lead and are pulverized and unvegetated. Concentrations increased over the six-month duration of the demonstration. Within the pond soil, lead concentrations increased from the inlet to the outlet (see figure). This trend suggests that small, less-dense material, which settles out of the water last and therefore at greater distances into the pond, carries some of the lead. Automated storm water samples support this notion. All but one water sample (filtered to remove particulate material) showed lead

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Figure 5-3. Environmentally reengineered berm (from Environmentally Redesigned Small Arms Range Demonstration Final Report, SFIM- AEC-ET-CR-97042). concentration below the national drinking water standard (15 μg/L). This finding confirms previous work that dissolved phase lead transport is not a problem from many Army ranges (Packer 1997a,b). Unfiltered samples (with suspended solids) show lead concentrations which far exceed the drinking water standard, suggesting that particulate lead is transported in storm water runoff.

With regard to mitigating potential lead dissolution, all five test cell bullet pocket/toe areas failed TCLP by a significant margin after six months of firing, suggesting that these chemical technologies, designed for landfill applications, are inappropriate for whole berm applications on most operating ranges where significant lead addition and soil disturbance occurs over small areas (pocket/toe). Owners or operators should chemically treat sieved range soil if lead is widely dispersed in range soils and (a) a range is closing or (b) there is a high potential for vertical transport to groundwater (e.g., low soil pH, shallow water table) or (c) very little lead will be added to the range. Under these limited circumstances, range soils may benefit from a phosphate treatment similar to that applied in Cell #2, which was the only test soil to pass the TCLP test directly after treatment. This treatment allowed for moderate vegetation and may be compacted in future applications to promote shear strength and internal slope stability. For treated soils on berm surfaces (Cell #2 technology), long-term reduction in leachability (greater than six months) is unknown at this time.

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Moreover, given that bullet pocket and toe sediments contain the highest lead concentrations and are continually pulverized by bullets, any significant volume of surface water runoff will inevitably transport particles from these areas, regardless of the erosion resistance and stability of the remaining berm surface. Climatic conditions, soil particle distribution, and mass of lead added per unit time will determine the extent and degree of surface water lead transport.

Some useful lead migration mitigation techniques resulted from this demonstration. The addition of bentonite increased slope stability and decreased berm surface erosion. The erosion matting promoted vegetation. The end berms and range grading helped to manage storm water runoff. A detention pond is an effective means of controlling lead migration, but care should be taken, since its capture of lead makes it a potential point source, requiring a discharge permit. Some lead still exits the outlet pipe.

Physical and chemical treatment of the entire berm soil does not mitigate the lead transport from the concentrated areas in the bullet pockets and toes. These small soil volumes lie nearly directly on the range floor, where potential dissolved lead interacts little with treated soil. Pocket/toe soils are pulverized, unvegetated, and highly concentrated with lead, allowing surface water to carry these particles off range.

Figure 6 in the Fort Rucker final report uses surface soil composites on range floor and within the detention pond to show concentration trends. Sample points are plotted in the direction of range grading (left to right). The first two sample points (east wing and inlet) were taken from the range floor, i.e., moving toward the detention pond. The 10-, 40-, 80-, and 130-foot sample points were all within the detention pond, measured from the inlet toward the outlet that is in the direction of water flow. The last sample point (detention pond outlet) was actually outside the detention pond (see Figures 5-4 and 5-5).

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Photo A Photo C Figure 5-4. Water and sediments moving into, through, and out of detention pond. Photo A shows the inlet channel (and raised/covered ISSCO sampler) to the detention pond. Photo B shows the detention pond. The range gradient in the background channels water and sediment into the detention pond where the heaviest particles settle out as water moves toward the end of the pond (shown in the foreground). Slotted red pipe (Photo B) lets water exit the pond into riprap (Photo C), where any remaining suspended fine material exits with the water. Photo B

Photo A Photo C Figure 5-5. Off-range sediment transport in March 1997. Photo A shows screening on the side of the PVC completely inundated with sediment. Photo A also shows small plumes of sediment exiting from open PVC, out of the sampling channel (under wood timbers) and onto the grassy area in between the targets and berm. Plume of light-colored sediment on the unvegetated range floor moves off range toward the detention pond in Photo B. Range sediments which were suspended in water enter the detention pond (Photo C) and settle out as water velocity decreases down the pond axis. Photo B 81 ITRC – Environmental Management at Operating Outdoor Small Arms Firing Ranges February 2005

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

Fort Jackson small arms range project objectives are as follows:

• improve storm water management, • long-term range maintenance reduction, • ease of future lead extraction from impact berm, and • no increase in bullet ricochet/skip-over.

Several techniques are applied:

• Range regrading limits upstream storm water from washing over the berm front and range surface soils. Separating “clean” upstream water from “range runoff” is essential. This regrading decreases the storm water volumes and velocity. This lower velocity decreases the surface water transport of particulate lead. The berm face grade is limited to no more than 26° to limit erosion and increase structural stability.

• Soil amendments increase the potential to grow vegetation and the structural stability of soils, thus decreasing erosion. Top soil, chicken litter for additional organic matter as well as nutrients, pH adjustments using lime/calcium carbonate, and nitrogen fertilizer as needed were all added to range soils. In addition, soil amendments which include clay and organic matter mitigate the potential of vertical migration as an added bonus.

• Revegetation of berm faces and range floor (all barren areas), decreases erosion and storm water velocity, thus decreasing lead transport (Figure 5-6). Revegetation is the single most important improvement to bullet pocket stabilization as well as overall range management of lead Figure 5-6. Fort Jackson berm prior to modification transport. (top) and after amendment and revegetation (bottom).

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• Geotextile fabrics around bullet pockets are under evaluation for stabilization of soils adjacent to bullet pockets.

A year of monitoring is planned at Fort Jackson, to be completed in March 2004. Interim Army Small Arms Range Guidance based on all Army small arms ranges projects is being developed with the BMPs document expected in July 2004.

5.5 Naperville, Illinois Case Study

Naperville Sportsman Park, Naperville, Illinois National Pollution Discharge Elimination System Permit

On October 13, 2000, the Naperville Park District, on behalf of its Sportsman’s Park, became the first range to be issued a National Pollution Elimination Discharge System (NPDES) permit. The Clean Water Act requires an NPDES permit when any “pollutant” is discharged into “the water of the United States.” The permit was issued by the Illinois Environmental Protection Agency (IEPA), which oversees the NPDES program in that state.

Several jurisdictions have determined that ranges meet the criteria contained in the Clean Water Act to warrant the need to obtain an NPDES permit if the range is shooting into water or wetlands. The impact or shot fall area need not be wet to qualify as a wetland.

The City of Naperville, the Naperville Park District, and the Naperville Sportsman’s Park were sued in 1998 by a neighbor who was opposed to the range., The court ruled that an NPDES permit was required. The IEPA did not institute any action against the club and became involved after the court ruled that a permit was required. The parties named in the lawsuit spent many thousands of dollars on legal defense of the club and on scientific studies required to obtain a permit.

The Sportsman’s Park had the only NPDES permit issued to an operating firing range in the United States as of the end of 2004. The permit requires that the trap range use steel shot and biodegradable targets, manage the litter created by the shotgun wads, and monitor water quality.

The club voluntarily suspended its operations during the litigation. As a result, many members canceled their membership. However, after reopening in 2001, the club successfully has rebuilt its membership and currently is throwing more targets than before the suit was filed. Many of the new members also are new to the shooting sports.

Clubs that shoot into waters or wetlands can avoid these huge costs, loss of membership, and potential closure by reorienting their ranges to avoid water or wetland areas or switching to nonlead ammunition. It is important to note that an NPDES permit still may be required, even if nonlead ammunition and biodegradable targets are used. However, it is likely that a permit will be easier to secure—and less expensive—if it obtained before lawsuits or agency actions are initiated.

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

Introduction

The Rodman’s Neck firing range is located on the southernmost portion of the Pelham Bay peninsula, which juts into Eastchester Bay. The City of New York developed and implemented an operations and maintenance plan on the Boy Range to demonstrate the effectiveness of economical lead recovery and lead-contaminated soil stabilization using a material named ECOBOND®.

Operations and Maintenance Procedure

The project demonstrated the ability to remove the bullet fragments using dry screening and treatment of the lead-contaminated soil to background levels so the soil levels can be reused on site. The lead recovery procedure allowed for 85% lead recovery and 90% soil reuse.

Soil Characterization

The City of New York had Consulting Engineers perform soil characterization at the Rodman’s Neck range (Table 5-1). The highest TCLP/Synthetic Precipitation Leaching Procedure (SPLP) leachable lead concentrations were observed in samples collected from the lower berm of the Charlie and Eddie Ranges and the flat and lower berm of the Albert and Frank Ranges. The majority of the samples collected from these areas exhibited leachable lead concentrations in excess of the TCLP Project Action Level (PAL) of 5.0 ppm and SPLP PAL of 0.172 ppm.

In contrast, TCLP and SPLP leachable lead concentrations for the majority of the samples collected from the Boy Range after treatment were found to be well below the TCLP and SPLP PALs in spite of the facts that soil within the range was treated over six months prior to sampling and the range is used on a daily basis. The sample results for the Boy Range demonstrate that the removal and recycling of lead fragments along with treatment of soil effectively reduces the leachability of lead present in the soil. Application of the stabilization material did not have any adverse impacts such as hardening of the soil matrix. Hardening of the soil matrix during previous maintenance efforts may have several adverse effects such as creating ricochets and drainage problems.

Table 5-1. Treatment results at New York Police Department outdoor firing range, Rodman’s Neck, Bronx, New York Firing Range Pretreatment Treatment Pretreatment Treatment Sample TCLP lead TCLP SPLP lead SPLP lead West side #1 788 0.005 ppm 20 0.035 ppm West side #2 788 0.270 ppm 20 0.031 ppm East side #1 280 0.104 ppm 15 0.0469 ppm East side #2 280 0.0545 ppm 15 0.0176 ppm Project Action Level for TCLP lead is <5.0 ppm. Project Action Level for SPLP lead is <0.172 ppm.

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Conclusions

Based on the success of the maintenance and operation procedures, Consulting Engineers recommended to the City of New York that the lead fragment removal and recycling along with the lead stabilization technology be used to treat other ranges to meet BMPs and to save money.

6. BIBLIOGRAPHY

Association of European Manufacturers of Sporting Ammunition. 2002. Shooting Ranges and the Environment: A Handbook for European Range Managers. Baer, K. N., D. G. Hutton, R. L. Boer, T. J. Ward, and R. G. Stahl, Jr. 1995. “Toxicity Evaluation of Trap and Skeet Shooting Targets to Aquatic Test Species.” Ecotoxicology 4: 385–92. Ceccarelli, G., and R. Stefano. 2004. “Future Range Design,” in Proceedings, World Symposium on Lead in Ammunition, September 9–10. World Forum on the Future of Sport Shooting Activities. Conca, J., E. Strietelmeier, N. Lu, S. D. Ware, T. P. Taylor, J. Kaszuba, and J. V. Wright. 2002. “Treatability Study of Reactive Materials to Remediate Groundwater Contaminated with Radionuclides, Metals and Nitrates in a Four-Component Permeable Reactive MultiBarrier.” Chapter 8 in Groundwater Remediation of Trace Metals, Radionuclides, and Nutrients, with Permeable Reactive Barriers, D. L. Naftz, S. J. Morrison, J. A. Davis, and C. C. Fuller, eds. San Diego: Academic Press. 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. Eisler, R. 1988. “Lead Hazards to Fish, Wildlife and Invertebrates: A Synoptic Review.” Biology Report 85(1.14). U.S. Fish and Wildlife Service, Patuxent Wildlife Research Center. EPA (U.S. Environmental Protection Agency). 2001. Best Management Practices for Lead and Outdoor Shooting Ranges. EPA-540-F-00-009. EPA. 2003. Best Management Practices for Lead at Outdoor Shooting Ranges. EPA-902-B-01- 001, Revised. Available on the Internet at http://www.epa.gov/region2/waste/leadshot/. 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. Furnari, D. L., and G. Fabian. 2003. Final Report for the Demonstration of Commercial Bullet Trap Technologies. U.S. Army Environmental Center, Military Environmental Technology Demonstration Center. [Presidential] Executive Order 13148. 2000. “Greening the Government Through Leadership in Environmental Management.” Heckelman, K. E., Attorney, U.S. Army Environmental Center Office of Command Counsel. 1997. “Lead Recovery on Active Ranges.” December 16 memorandum to Ms. Joan VanderVort. Hudson, K. L., G. L. Fabian, and P. G. Malome. 1999. Demonstration of Shock-Absorbing Concrete (SACON) Bullet Trap Technology. SFIM-AEC-ET-CR-99017. Prepared for U.S. Army Environmental Center.

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Indian Head Division, Naval Surface Warfare Center. 1998. Outdoor Small Arms Ranges: Management Practices Guidebook. OES Document 01-98. Indian Head, Md. ITRC. 2003a. Characterization and Remediation of Soils at Closed Small Arms Firing Ranges. SMART-1. Available on the Internet at www.itrcweb.org. ITRC. 2003b. Technical and Regulatory Guidance Document for Constructed Treatment Wetlands. WTLND-1. Available on the Internet at www.itrcweb.org. Larson, S., B. Tardy, M. Beverly, A. Hearn, M. Thompson, and G. Williams. 2004. Application of Phosphate Amendments to Lead-Contaminated Small Arms Firing Range Soils. ERDC/EL TR-04-15. Available on the U.S. Army Engineer Research and Development Center Web site at http://ww.wes.army.mil/el. Ma, Q. Y., T. J. Logan, and S. J. Traina. 1995. “Lead Immobilization from Aqueous Solutions and Contaminated Soils Using Phosphate Rocks.” Environmental Science and Technology 29: 1118–26. Ma, Q. Y., S. J. Traina, T. J. Logan, and J. A. Ryan. 1993. “In Situ Lead Immobilization by Apatite.” Environmental Science and Technology 27: 1803–10. Ma, Q. Y., S. J. Traina, T. J. Logan, and J. A. Ryan. 1994. “Effects of Aqueous Al, Cd, Cu, Fe(II), Ni and Zn on Pb Immobilization by Hydroxyapatite.” Environmental Science and Technology 28: 1219–28. 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. Massachusetts Division of Occupational Safety. n.d. “Firing Ranges: The Airborne Lead Hazard.” Available on the Internet at http://www.mass.gov/dos/leaddocs/Lead-firing.htm. National Climactic Data Center of the National Weather Service. Available on the Internet at http://lwf.ncdc.noaa.gov/oa/ncdc.html. Natural Resources Conservation Service, U.S. Department of Agriculture. Available on the Internet at http://www.fl.nrcs.usda.gov/soils.htm. National Rifle Association of America. 1999. The Range Sourcebook: A Guide for Planning and Construction. NSSF (National Shooting Sports Foundation). 1997. Environmental Aspects of Construction and Management of Outdoor Shooting Ranges. Available on the Internet at www.rangeinfo.org. Packer, B. 1996. Bullet Trap User’s Guide. SFIM-AEC-ET-CR96201. Army Environmental Center. Packer, B. 1997a. Demonstration of the Range Evaluation Software Tool (REST) and the Army Sampling and Analysis Plan (ASAP) at Three Army National Guard Sites. TRW report. Packer, B. 1997b. Presentation at the Second Tri-Service Environmental Technology Workshop, St. Louis, June 10–12. Soeder, D. J., and C. V. Miller. 2003. Ground-Water Contamination from Lead Shot at Prime Hook National Wildlife Refuge, Sussex County, Delaware. Water Resources Investigations Report 02-482. Baltimore: U.S. Department of the Interior and U.S. Geological Survey, in cooperation with the U.S. Fish and Wildlife Service, Chesapeake Bay Field Office. Available on the Internet at http://md.water.usgs.gov/publications/wrir-02-4282/wrir_02_4282.pdf. Sporting Arms and Ammunition Manufacturers Institute, Inc. 1996. Lead Mobility at Shooting Range. Newtown, Conn. USAEC (U.S. Army Environmental Center). 1997a. “The Range Evaluation Software Tool (REST)” and Army Sampling and Analysis Plan for Small Arms Ranges (SFIM-AEC-ET-

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CR-97037). Available on the Internet at http://aec.army.mil/usaec/technology/rangexxi03g.html. USAEC. 1997b. Implementation Guidance Handbook—Physical Separation and Acid Leaching to Process Small-Arms Range Soils. SFIM-AEC-ET-CR-97046. USAEC. 1999. Results of the 1998 Field Demonstration and Preliminary Implementation Guidance for Phytoremediation of Lead-Contaminated Soil at the Twin Cities Army Ammunition Plant, Arden Hills, Minnesota. SFIM-AEC-ET-CR-99001. USAEC. 2003. “Bullet Traps for Outdoor Small Arms Ranges.” Small Arms Range Technology. Available on the Internet at http://aec.army.mil/usaec/technology/rangexxi03a.html. USAF (U.S. Air Force). 1998. “Lead Contamination in Soils at Military Small Arms Firing Ranges.” PROACT Fact Sheet TI#17472. Available on the Internet at http://www.afcee.brooks.af.mil. USAF. 2002. “Small Arms Range Design and Construction.” Engineering Technical Letter. Tyndall AFB, Fla.: Headquarters, Air Force Civil Engineering Support Agency. U.S. Department of Interior. 1986. Fish and Wildlife Service, Final Supplemental Environmental Impact Statement of the Use of Lead Shot for Hunting Migratory Birds. Prepared by the U.S. Fish and Wildlife Service, Office of Migratory Bird Management, Washington D.C. U.S. Department of Labor, Occupational Safety and Health Administration. Available on the Internet at http://www.osha.gov. U.S. Department of Labor, Occupational Safety and Health Administration National Safety Compliance site on the Internet at http://www.osha-safety-training.net/. Wright, J. V., B. Murphy, K. R. Rice, K. Caskey, P. Heller, and J. L. Conca. 2001. “Field Demonstration of Particulate-Pb Remediation at a Former Open Burn/Open Detonation Site.” Presented at SERDP/ESTCP Partners in Environmental Technology Technical Symposium and Workshop, Washington, D.C.

APPENDIX A

Acronyms

BMP best management practice CFR Code of Federal Regulations COTS commercial, off-the-shelf DEP (Massachusetts) Department of Environmental Protection DoD U.S. Department of Defense EMP environmental management plan EPA U.S. Environmental Protection Agency ERDC (U.S. Army) Engineer Research and Development Center ESP Environmental Stewardship Plan ESTCP Environmental Security Technology Certification Program GOAL (Massachusetts) Gun Owners’ Action League IEPA Illinois Environmental Protection Agency LSI (Massachusetts) Lead Shot Initiative MIC metastable intermolecular compound NASR National Association of Shooting Ranges NPDES National Pollution Elimination Discharge System NRCS Natural Resources Conservation Service NSSF National Shooting Sports Foundation OSHA Occupational Safety and Health Administration PAH polycyclic aromatic hydrocarbons PAL project action level PBZ personal breathing zone PEL permissible exposure limit PIMS phosphate-induced metal stabilization RCRA Resource Conservation and Recovery Act REST Range Evaluation Software Tool SACON shock-absorbing concrete SDZ surface danger zone SPLP Synthetic Precipitation Leaching Procedure TCLP Toxic Contaminant Leaching Procedure USDA U.S. Department of Agriculture USGS U.S. Geological Survey

A-1

APPENDIX B

Glossary

GLOSSARY absorption – the act of taking in or soaking up. adsorption – the process that removes dissolved metals from the water column through binding the ions to the surface of a sediment particle. acids – pH below 7.0. Under acid conditions, leads tend to dissolve and adhere to particles. The lower the pH, the more acidic the conditions and the more lead tends to dissolve. agglomerate – to form into rounded masses. alkaline – not acidic, basic, pH above 7.0. Under moderately alkaline conditions, lead tends to adhere tightly to soil and other particles; however, under strong alkaline conditions lead mobilization may be increased. aesthetics – appearance. An aesthetically pleasing range looks well-managed and attractive. ammunition – one or more loaded cartridges consisting of a primed case and propellant, with or without one or more projectiles. backstop – a structure specifically constructed to stop and store projectiles fired on a range. baffle – a barrier to intercept projectiles and/or reduce, redirect, or suppress sound. Baffles are used overhead, alongside, or at ground level to restrict or intercept errant or off-target shots. Use of baffles and backstops reduces the surface danger zone to the immediate limits of the range containment area. berm – a wall of earthen materials that separates two physical features. Can be a manmade or natural feature. In the context of this manual, a berm would be a (generally manmade) mound or wall of earth that would delineate the back and/or sides of a firing range. buffer – solutions the resist changes of hydrogen ion (H+) concentrations. In surface water, dissolved specific ions (bicarbonate and carbonate) are in equilibrium with the carbon dioxide in the atmosphere (gas) and dissolved in water. Together they act like a buffer: this means the pH of water won’t change even if acid or base is added (within limits) to a solution. bullet trap – a device designed to trap and capture bullets and fragments. cartridge – a single round of ammunition consisting of the case, primer, and propellant, with or without one or more projectiles. Also applies to a shot shell. firing lane – the area within which a firearm is fired. It consists of firing and target lines and left and right limits of fire. firing line – the base line to a range to which the targets are parallel to, from where firearms are discharged and forward of which no one is permitted during fire. firing position (point) – an area directly behind the firing line having a specific width and depth that is occupied by a shooter, equipment, and, if appropriate, an instructor or coach. foreground – the area between the firing line and the backstop berm (and between the side berms) at an outdoor rifle/pistol range. green ammunition – lead-free bullet or shot. ground baffle – a device on the range floor designed to intercept and stop ricocheting projectiles. May be used on backstop areas where the slope does not positively contain bullets. impact area – the area behind a backstop bullet trap or shot fall zone directly behind the target where bullets are expected to impact the shotgun pellets land. The term may also refer to the part of the surface danger zone area downrange of an outdoor range where bullets will impact if not intercepted by a backstop.

B-1

no-blue-sky rule – jargon that applies to baffled ranges only. It refers to the placement of a series of overhead baffles in such a manner that no “blue sky” can be seen from the firing line. noise baffle – a sound suppression barrier constructed using sound-absorbing materials. Noise baffles may be designed to either absorb (stop) and/or reflect sound. pollutant – as defined by the Clean Water Act, “dredged spoil, solid waste, incinerator residue, sewage, garbage, sewage sludge, munitions...wrecked or discarded equipment...discharged into the water.” primer – a cartridge ignition component consisting of brass or gilding metal cup, priming mixture, anvil and foil disc, which fires the cartridge when struck with sufficient force. projectile – an object propelled from a firearm by the force of rapidly burning gases or other means. safety baffle – vertical or angled barrier to prevent a projectile from traveling into an undesired area or direction. Used to reduce the surface danger zone to prevent bullets from leaving the ranges property between the backstop and berms. saltation – (geology) the leaping movement of sand or soil particles as they are transported in a fluid medium over an uneven surface. shot fall zone – the area at a trap, skeet, or sporting clays range on which spent shot falls. The shot fall zone as discussed in this manual should not be confused with the similarly shaped but somewhat larger safety zone. target line – a line parallel to the firing line along which targets are placed.

B-2

APPENDIX C

Comprehensive Template for an Environmental Management Plan

COMPREHENSIVE TEMPLATE FOR AN ENVIRONMENTAL MANAGEMENT PLAN

1.0 Introduction The XYZ Club, Inc. is located at 123 X Road in Blanktown, Florida… 1.1 Mission Statement The XYZ Club, Inc. is committed to… 1.2 Purpose The purpose of this Environmental Stewardship Plan (i.e., the Plan) is to: • identify issues of potential environmental concern that may exist; • identify, evaluate, and prioritize appropriate actions to manage these issues; • list short- and long-term action items and the steps needed for implementation; • develop and implementation schedule; • identify ways to measure the Plan’s success; and • annually evaluate the progress made towards achieving our environmental stewardship goals; etc. 1.3 Goals • Avoid shooting over and into water and wetlands. • Prevent off-site migration of lead through groundwater and surface water runoff. • Conduct lead recovery. • Discourage ingestion of lead by wildlife. • Maintain soil pH between 6.5 and 8.5 in the shot fall zone. 2.0 Site Assessment 2.1 Description of Ranges and Support Facilities The XYZ Club has an x position Trap Range, a y position Skeet Range, a z position Sporting Clays Course, and a q position Small Arms Range. These ranges are located in a rural setting and are oriented away from residential areas and surface water bodies. [Briefly describe each range, its dimensions, orientation, vegetative cover, numbers of shooters and targets used per year, wildlife usage, etc.] 2.2 Existing Environmental Conditions [Describe the most significant environmental issues associated with the ranges. Refer to figures, tables, the results of surveys, inspections, professional opinions, etc.] 2.2.1 Trap and Skeet Fields 2.2.2 Sporting Clays Course 2.2.3 Rifle and Black Powder Range(s) 2.2.4 Outdoor Handgun Range(s) 3.0 Trap (and) Skeet Field(s) 3.1 Action Plan 3.1.1 Potential Management Alternatives Alternative 1: Achieve all of the environmental goals identified simultaneously. Alternative 2: Work on one goal this year and address all other later. Alternative 3: Choose a few goals that can be implemented immediately and begin planning longer-term alternatives. Alternative 4: Vegetate sparse grass area of trap/skeet field. Alternative 5: Reorient trap field to avoid lead shot entering wetlands.

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Alternative 6: Reorient sporting clays stations to maximize the overlap of falling shot into the open field where it can be more easily recovered for recycling. Alternative 7: Limit use of the trap/skeet range to only those stations that do not have wetland area within the shot fall zone. Alternative 8: Apply lime to shot fall zones if soil test results indicate this step would be beneficial. Alternative 9: Prepare fields for lead reclamation. Alternative 10: Get bids for lead reclamation project. Alternative 11: Conduct lead reclamation within the trap/skeet shot fall zones. Alternative 12: Conduct lead reclamation within the berm of the small arms range. Alternative 13: Conduct lead reclamation within the sporting clays shot fall zone. Alternative 14: Change mowing frequency to closely mow grass in shot fall zones. Alternative 15: Construct lean-tos at backstop berms. Alternative 16: Construct a lime lined drainage swale for storm water management. Alternative 17: List additional Best Management Practices that may be appropriate to your club. 3.1.2 Selection of Management Alternatives to be Implemented [Describe the process by which the above alternatives will be, or were, selected (incorporate range managers, the membership, and outside consultants as applicable).] 3.1.3 Alternatives Selected Based on the stewardship goals of the Plan, the benefits provided, and the current availability of funds, the following priorities were chosen for the current calendar year. Alternative x: Alternative y: Alternative z: These choices were made to address the most pressing concerns and the most easily resolved issues and to initiate management practices that would create longer-term environmental benefits. In order to achieve the goals of the Plan, the following actions are necessary. a) Management Actions: [assign personnel responsible for initiating, conducting, and completing the alternatives selected above.] b) Operational Actions: [collect soil samples for pH analysis, consult with USDA’s Natural Resources Conservation Service and/or the county Cooperative Extension Service regarding best suited vegetative management recommendations.] c) Construction Actions: [do site preparation work, get bids, institute mowing and vegetative management recommendations, reorient shooting position as appropriate.] 3.2 Plan Implementation 3.2.1 Schedule for Implementation Winter/Spring: [pH survey, contact local officials for vegetation management recommendations, reorient shooting positions as appropriate, realign shooting positions as appropriate.] Summer/Fall: [prepare site for reclamation project, apply lime/fertilizer/seed, get bids for berm lean-tos/reclamation. As a rule of thumb, 50 pounds of lime per 1,000 square feet should raise soil pH by 1 once the residual acidity is overcome.] 3.2.2 Responsibilities [i.e.: the trap/skeet chairman/chairmen will… The club treasurer will… The membership will provide the labor to…]

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4.0 Rifle, Black Powder, and Outdoor Handgun Range(s) 4.1 Action Plan 4.1.1 Potential Management Alternatives Alternative 1: Achieve all of the environmental goals identified simultaneously. Alternative 2: Work on one goal this year and address all other later. Alternative 3: Choose a few goals that can be implemented immediately and begin planning longer-term alternatives. Alternative 4: Culvert the stream through the shooting ranges. Alternative 5: Vegetate the backstop berm(s) to minimize erosion. Alternative 6: Construct a lime lined drainage swale for storm water management. Alternative 7: Apply lime to the berm and foreground if pH test determines it is necessary. Alternative 9: Begin planning a lead reclamation project. Alternative 10: Change mowing frequency to closely mow grass in shot fall zones. Alternative 11: Construct lean-tos at berms. Alternative 12: List additional Best Management Practices that may be appropriate to your club. 4.1.2 Selection of Management Alternatives to be Implemented [Describe the process by which the above alternatives will be, or were, selected (incorporate club officers, the membership, and outside consultants as applicable).] 4.1.3 Alternatives Selected Based on the stewardship goals of the Plan, the benefits provided, and the current availability of funds, the following priorities were chosen for the current calendar year. Alternative x: Alternative y: Alternative z: These choices were made to address the most pressing concerns and the most easily resolved issues and to initiate management practices that would create longer-term environmental benefits. In order to achieve the goals of the Plan, the following actions are necessary. a) Management Actions: [assign personnel responsible for initiating, conducting, and completing the alternatives selected above.] b) Operational Actions: [collect soil samples for pH analysis, consult with USDA’s Natural Resources Conservation Service and/or the county Service Forester regarding best suited vegetative management recommendations.] c) Construction Actions: [do site preparation work, get bids, institute mowing and vegetative management recommendations, reorient shooting position as appropriate.] 4.2 Plan Implementation 4.2.1 Schedule for Implementation Winter/Spring: [pH survey, contact local officials for vegetation management recommendations, reorient shooting positions as appropriate, realign shooting positions as appropriate.] Summer/Fall: [prepare site for reclamation project, apply lime/fertilizer/seed, get bids for berm lean-tos/reclamation.] 4.2.2 Responsibilities [i.e.: the small arms range chairman/chairmen will… The club treasurer will… The membership will provide the labor to…]

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5.0 Sporting Clays Course 5.1 Action Plan 5.1.1 Potential Management Alternatives 5.1.2 Selection of Management Alternatives to be Implemented 5.1.3 Alternatives Selected 5.2 Plan Implementation 5.2.1 Schedule for Implementation 5.2.2 Responsibilities 6.0 Measuring Success (to refer to the document for the type of activities used to measure success, so that the EMP could be tailored to specific range conditions) By monitoring the impact or success of the Plan, the club is best prepared to make whatever changes may be necessary to reinforce success and make the most of environmental stewardship efforts. 6.1 Vegetation [The density of vegetation growth should be measured throughout the growing season, especially in areas of sparse growth where steps have been taken to increase the vegetative cover. This is can be done by taking periodic photographs (e.g., once a month) from the same places to document the impact of the Plan.] 6.2 Wildlife [Keep a log of visual observations made regarding the frequency of range usage by the variety of species in your area.] 6.3 Soil and Runoff pH [Track soil and runoff pH through semiannual monitoring and adjust the amount of lime applied to different areas of the range to maintain a pH level that will prevent lead from dissolving (i.e., a pH of 6.5–8.5).] 6.4 Erosion [Again, keeping a photographic record of problem areas best prepares your club to document achievements and adjust the Plan as appropriate.] 7.0 Plan Review and Revisions Continue to monitor the environment and review the Plan on an annual basis. Update the Plan as needed and set goals for subsequent years. Make recommendations for future club officers to consider when updating the Plan and in setting goals (tell them what worked, what didn’t work, and what still needs to be done). FIGURES [Insert site location map here] Typically, a site location map is cut from a USGS topographic map of the club’s area. The club should be centered on the map. Indicate the property boundaries and layout of the range. [Insert other figures as necessary to support the text] Other figures may include an aerial photograph, and sketches of the club property in general and/or specific ranges in particular. Example: ______Appendix A Information from USDA, Natural Resources Conservation Service [and/or county Cooperative Extension Service] [concerning soil and vegetation management recommendations] ______

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Appendix B (etc.) [For other supporting documentation as needed.] ______APPENDIX C Record Keeping APPENDIX D RECORD-KEEPING AND EVALUATION Evaluation of the success of an Environmental Stewardship Plan should occur one or more times per year. Keeping the Plan current will help the range make midcourse corrections where necessary and document the results from the previous year’s initiatives. The focus of the evaluation should be to determine whether the Environmental Stewardship Plan has been implemented as intended, the problems (if any) encountered, and what types of adjustments should be made to the plan for the future. In addition, it will be useful to monitor the environmental benefits that have resulted from implementation of management and engineering actions. This will demonstrate the effectiveness of the actions that have been taken. Just as with other aspects of business, record-keeping is essential for evaluation of the Environmental Stewardship Plan. Typical records that may be useful in evaluating the effectiveness of a plan may include: • Range “inspections” by range manager. • Photographs of preexisting conditions versus conditions after environmental improvements have been implemented (“before” and “after” photographs). • Log of actual implementation dates, problems addressed, associated costs, conditions, problems encountered and follow-up actions. • Frequency of changed operational practices (i.e., mowing on poorly vegetated soils) and observed results. • Comparison of changes in operational costs related to changed procedures; and • Frequency and type of environmentally related complaints from customers or the public. Quantitative measurement of environmental improvements will most likely be beyond the capabilities of range operators and need not be sought unless they are necessary to support legal proceedings. In these cases, support from outside consultants may be in order. Local universities or nonprofit groups with an environmental research interest may also represent a viable source of assistance. Examples of record-keeping forms and logs are included below.

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DOCUMENT IMPORTANT INFORMATION FOR EACH PLANNED IMPROVEMENT: FACILITY NAME:______Lime and Phosphate Addition Form Date:______Employee______Time:______Type of Lime:______Source of Lime:______Type of Soil Amendment:______Source of Soil Amendment:______Firing Lane Location of Lime Addition: ______Amount of Lime Added at each Firing Lane: ______

______Firing Lane Location of Soil Amendment: ______Amount of Soil Amendment Added at each Firing Lane: ______Notes:______pH Testing Form Year______Date Method Firing Lane No. pH Action Taken Range Log for each Firing Lane Firing Lane______Date Organization Ammunition Type Rounds Fired Total

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APPENDIX D

Response to Comments

RESPONSE TO COMMENTS

Section 1.2, Para. 2, Sent. 1—Should EMP be a part of the overall Range Management Plan? See Section 4, paragraph 3 states “A plan to listen to the concerns of neighbors provides an opportunity to discuss both the safety and environmental programs incorporated into the operating plans for the range.”

Installations should probably consider these practices in designing ranges and in developing their site-specific environmental management system (EMS). However, there may be good reasons why whether there is any substantial risk. As an example, the decision tree for the management plan on page 57 does not address the “no action” alternative if there are no real issues. No further action has been included in the decision tree, which is now Figure 2-1. After considering all of the potential environmental issues, if there is nothing that potentially presents a risk, then no further action can be chosen.

Section 2.0—The lead pathway and fate in the environment discussion is presented in both Sections 2 and 4.2. This seems redundant. It is redundant in concept, but it is appropriate in both since the introduction explains overall fate and transport as it relates to exposure and Chapter 4 addresses fate and transport as it relates to specific environmental characteristics.

Pages 11–14: These two pages discuss the distribution of shot at trap and skeet ranges. There are a couple of statements that should be verified. First that maximum shot fall is directly related to elevation above sea level. I do not think this has as much effect as indicated. Second, the assumption that normal skeet loads do not travel as far as trap loads. I think this is an erroneous assumption. The maximum shot fall distances need to be clarified with the following variables in mind. Maximum shot distance will be based on shot size, powder load, gun barrel length, gun choke, vertical angle the shot was fired, and local terrain. I do not believe normal trap and skeet loads differ as much as indicated. Also, most trap and skeet shooters reload their own shells. Shot distance should come from published ballistic tables, including reloading manuals. I also think they will be the same for trap and skeet. Shot distance has come from published ballistic tables and verified by SAAMI.

Section 2.1.3, Para. 3—Expand this section by providing additional guidance such as: “Recommend posting a simple placard at the range noting potential presence of lead and recommendations to avoid eating in the area and to wash hands and face following working or shooting at the range.” Accepted.

Section 2.1.3, Para. 3—Expand this section by providing additional guidance such as: “Medical surveillance (periodic blood lead levels) should only be considered for those where measured environmental lead levels in conjunction with sufficient exposure would lead to predictable elevated blood lead levels in a chronically exposed member. Industrial hygienists as needed can quantify lead exposures. Intermittent users should not be in a medical surveillance program. The OSHA-mandated lead surveillance program is not an incidental program and medical surveillance for lead should not be taken lightly. Placing personnel in lead surveillance without performing appropriate environmental lead monitoring is a frequent and costly mistake.” The team will revisit the wording around the medical surveillance issue; however, this specific wording was rejected by the team because the reference to OSHA and associated citations are more accurate. The recommended language may lead to an inaccurate interpretation by range operators that blood lead testing is a broad recommendation. We have many levels of environmental sophistication on small arms firing ranges and this type of detail could confuse and alienate the reader, thus jeopardizing the useful nature of the overall document.

Sections 2.2 and 3.5 depict the use of bullet containment traps to assist in lead recovery. Note that the use of hard bullet traps increases ricochet and usually requires the need to increase the surface danger zone for the range. This should be considered prior to installation of a hard trap on an outdoor range. Similar ricochet concerns exist with the baffled ranges also depicted. Consider for development of BMPs. Language and additional examples of bullet traps have been included.

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Section 2.4, Para. 2, Sent. 1 and 2—Change second paragraph to: “The sound at the muzzle of a shotgun firing a typical clay-shooting cartridge reaches some 140-150 decibels (dB). For comparison, normal speech is around 50-60 dBA (A = weighted scale to approximate human hearing for steady state noise) and clapping hands up to around 80 dB. Sound levels above 140 dB for many people become painful.” Accepted.

In April 2000, President Clinton signed Executive Order (EO) 13148 “Greening the Government through Leadership in Environmental Management” that established a five-year Environmental Management System (EMS) implementation goal for all Federal Facilities. EO 13148 requires an EMS at all appropriate federal facilities by December 31, 2005. Developing and implementing an EMS is required at all Army installations. Evaluating and resolving environmental concerns associated with small arms ranges would be subject to the installation EMS. Additional steps, even more protective than the recommendations suggested in the ITRC document, do not necessarily conflict.

The International Organization for Standardization developed the ISO-14001 standard to provide a set of internationally recognized criteria for EMSs. The Army has chosen to use the ISO-14001 standard as a model for implementing EMSs at Army installations. No conflicts with ISO-14001 in the document.

Section 3.3—Throughout the document, alternative non-lead ammunition is mentioned as an available management technique. Section 3.3 specifically mentions frangible type of projectile. Environmental impact considerations for long-term use of frangible projectiles include the release of copper and the inability to recover intact projectiles in the environment. Frangible ammunition does work well in indoor ranges with containment bullet stops. Consider including this discussion on environmental impacts of frangible projectiles. This section has been revised accordingly.

Section 3.4.2, Para. 5—How does an earthen berm reduce lead mobility? Adding more soil to a berm does not alter the transport characteristics of lead. The conductivity of the soil and/or ground has to be reduced to slow transport via leaching to ground water. Surface runoff is another problem all together. Consider clarifying this idea. The term “mobility” has been replaced by the phrase “solute transport.” A berm slope can redirect rain water, thereby reducing percolation. The berm concentrates the shot, thereby allowing recovery and recycling, and the shot is now separated from the groundwater table by nearly the thickness of the berm. Solute transport must migrate through the berm material below as well as the soils, sand, or rock above the water table.

Section 3.6 (page 33 lead recovery techniques)—“It should be noted that to ensure that lead is not considered “discarded” or “abandoned” on your range within the meaning of the RCRA statute, periodic lead management activities should be planned for and conducted.” The foregoing is contrary to the Munitions Rule, and this statement should be modified or deleted. There is no contradiction because the Range Rule is incomplete.

Section 3.6.1.1, (Page 34)—While sifting for lead shot appears to be the best method, it may prove to be too difficult. The soil will have to be broken up into very fine particles. Clarify, elaborate? Crushing is a possibility that must obviously be factored into the cost of the operation.

Section 3.7.1, Pg. 37, Last Para., Last Sent.—Be careful with use of the word “treatment.” This has very definite RCRA/CERCLA meaning. The term “treatment” has been removed. It add little to the statement since stabilization is discussed earlier in the text.

Page 16, Clay Targets—I have read on clay target boxes that they are toxic or may be harmful to swine. This may need to be clarified. The language in Section 3.11.2 has been clarified regarding the findings of Baer et al. in the 1995 report.

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Section 4.0—Environmental Management Planning. DoD recommends that consideration be given to moving this section to the front. Doing so might help to give the message clearly that one sets up an EMS, does an assessment, etc., first. Then, the document could offer some practical alternatives. Perhaps even all the technical alternatives could be an appendix, while the other materials could be the main part of the document? The team has considered this in the past and feels it is important to build a foundation of knowledge and understanding before performing the task. The team has modified Figure 1-1.

Recommend deleting Appendix B, captioned “Environmental Law and Regulations,” in its entirety. If it is to remain in the document, DoD believes that a much higher level of legal review would be required, potentially the DoD Office of General Counsel, as several of the specific paragraphs make broad statements of jurisdictional applicability that in fact may be counter to DoD positions in pending litigation and elsewhere. A few specific problems with Appendix B are shown in succeeding comments and recommendations. This section (Appendix B) has been removed.

The Army has developed The Army Training Range Aspect and Impact Methodology to support and be an integral component of the installation-wide EMS. It provides appropriate, range-specific guidance on completing the assessment of environmental aspects and impacts (environmental exposures), and provides criteria to help characterize their relative significance. The methodology ensures that the installation’s EMS addresses range environmental issues while focusing on its mission priorities. The systematic identification of potentially significant environmental aspects provides the basis for setting environmental objectives and performance standards, and for structuring the Army’s environmental management programs, operational controls and other system components that are necessary for the orderly, complete and reliable management of significant environmental exposures associated with the operation of its small arms ranges. The guidance titled “Aspect and Impact Methodology for Army Training Ranges” can be found at www.denix.gov. Thank you for the suggestion.

The document can serve as a guide for management and operators of small arms ranges to consider for the sustainability of their ranges. However, there is serious concern that endorsement by the Army or DoD might be construed to mean that these practices should or will be implemented at all ranges. Many factors are involved in the decision process for implementation as each site has specific characteristics that need to be considered. It may be inappropriate to implement these practices at ranges where the risks are relatively small. Additionally implementation will require a substantial increase in funding and could impact readiness. We hope to alleviate some of these fears through the disclaimer.

Tracer ammunition is often fired on military small arms ranges. To a lesser extent, incendiary ammunition is sometimes fired. Both types of ammunition are prone to starting range fires which could have a detrimental impact on vegetation and sensitive wildlife. Good point and applicable to more than simply military ranges. The team will add language to note this type of ammunition.

Some established small arms ranges were used in the past for other than small arms firing. They may contain dangerous UXO (40MM grenade duds for example), which might have an effect on current range maintenance. Indeed this is a concern, and all military ranges should evaluate the history of their range before any activity is conducted on the site.

This is a superb document, which obviously reflects well upon the knowledge of the authors, reviewers and team members. It is also a much needed document due to the general lack of knowledge on the part of state and federal regulators, the shooting public, the military and law enforcement regarding the environmental and health consequences related to small arms ranges. While range safety precepts have been developed for many decades, environmental challenges may not be so well understood. The content and format of the document addresses the major environmental and health concerns very well. Thank you.

1.0 Introduction First paragraph first sentence—I would add law enforcement after military, separating it from government environmental agencies, since they are a major segment of the shooting community. Change accepted.

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1.0 Introduction Third paragraph second sentence—Why is non-exploding here and does that includes tracers and incendiary? Obviously most small arms ammo is non-exploding, however some military 50 cal may be exploding or incendiary and others may be tracer. The growth of 50 cal sporting rifles and use of surplus military ammo may introduce some of these ammo types to civilian ranges. We are covering only “most” ammo. We are not covering incendiary or tracer rounds. This scope has been clarified in the document.

1.1 Problem Statement Second paragraph second sentence—I would eliminate the reference to “Soviet” ammunition as fulminate of mercury is common in older ammunition of any country of origin and some modern percussion caps. Agreed. It has been removed.

1.1 Problem Statement, Fourth paragraph second sentence—This statement seems misleading to me. Most states have a resource conservation and Recovery Act (RCRA) equivalent, which covers ranges as generators of hazardous waste (i.e. lead, whether it is released into the environment or not. For those states, which do not have a RCRA equivalent statute, EPA will regulate the ranges under RCRA. The fact that most states statutes probably do not specifically mention ranges is of no moment. If the range is not a generator of “waste,” RCRA does not apply until a waste is generated above conditionally exempt amount. If there is no documented release, the Clean Water Act does not require corrective measure, and RCRA cannot require corrective action. The document now contains the following statement, “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.”

2.0 Potential Environmental Issues at Ranges Table 2-1—Add Antimony Sulfide from 5% to 30% is used in most primer compounds” Add, “Bismuth is used for lead shot replacement.” Accepted. Done.

2.0 Potential Environmental Issues at Ranges Page 7—Add two questions. “Are there animals or birds that feed on the ranges when not is use?” “What is the pH of the rain?” (Acid rain causes the lead bullets or shot to form lead oxide, which dramatically increases transport.) Animals and birds on the site are defined by habitat. The last bullet identifies water or wetlands as the habitat that would attract waterfowl and thereby expose them to lead if lead is deposited in the habitat. Establishing the pH of the soil better defines the capacity of the soil and soil moisture to stabilize the lead in the soil. The pH of the rain may contribute although it may also be buffered by limestone (CaCO3) in the soil. Soil pH is a more direct measurement than rain.

2.0 Potential Environmental Issues at Ranges Last Paragraph last sentence page 7—I would eliminate, “The user is cautioned that…” The caution seems to relate to the second phrase, i.e. that cleanup sampling is more detailed and requires a larger scale that confirmatory sampling. If the caution is necessary, consider rearranging the sentence. The team feels that we must reinforce a distinction between cleanup of closed ranges and limited investigations to understand the range environment, including pathways. The caution is warranted, and the suggestion is rejected.

2.0 Potential Environmental Issues at Ranges Third Bullet page 10—Add, Copper from jackets or cores and tin from lead alloys can act as an herbicide, reducing the vegetative cover and allowing more erosion. Language added.

2.3.1 Human Health and Exposure, First paragraph, Third sentence, page 11—Add, Lead can also have serious effects on adults who drink alcoholic beverages due to a synergistic effect. Suicidal tendencies and gray looking skin are warning signs of lead poisoning. The following language has been added. “This manual does not cover many of the serious health effects caused by exposures to lead and lead poisoning, and the reader is encouraged to access other sources of more detailed information on those subjects.”

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2.3.1 Human Health and Exposure, Second paragraph, first sentence, page 11—Change to read. “Exposure to lead at outdoor shooting ranges can occur by three main pathways: Inhalation and incidental ingestion and drinking water. Many ranges are in rural areas where people use well water. In sandy areas, heavy metals can easily migrate down 400 feet or more and reach many drinking water aquifers. Since “drinking water contaminated by lead” is an example of incidental ingestion, not another pathway, the phrase has not been added.

2.3.1 Human Health and Exposure, First partial paragraph, page 12—Add, Windblown lead dust can stick to lips and licking lips can also cause substantial ingestions, particularly in dry and hot areas. For Ranges which provide firearms and or cleaning facilities, solvents used to remove lead from bores present another human and environmental exposure pathway. The team does not feel we need to go into this level of detail. At the end of paragraph 2 on page 12 the following has been added at the end of the final sentence: “and is a good reference for any personal protective equipment recommendations.”

2.3.1 Human Health and Exposure, Third paragraph, page 12—Add “Range workers (and frequent shooters) should be particularly alert to other potential lead exposure in their routines, such as gardening near roadways, lead paint or soldered pipes in their houses and work that involves soldering, casting bullets or sinkers. The lead body burden is cumulative.” The following language has been added: “This document is intended to address the minimization of potential exposures to lead associated with shooting ranges. It is not a general discussion of health effects stemming from exposures to lead, nor is it intended as a manual on range safety. The reader is encouraged to access other sources of more detailed information on those subjects.”

2.1.4 Lead in Plants and Crops, First partial paragraph, page 13—Add, “Some plants have been bioengineered to hyper-accumulate lead and could be planted on ranges. Mowing these plants periodically can remove large amounts of lead.” Plant accumulation requires dissolution of the lead. This might be a sensitive balance to prevent lead from continuing to the water table. It might be particularly dangerous in areas where the water table is very close to the surface.

2.5 Shooting Sound Suggest at the end of the section—The lower the frequency noise of a muzzle blast strikes the hair cells in the cochlea at a particular location. Without hearing protection these hairs will be damaged over time. These hairs are connected to the nerves that transmit sound to the brain. Muzzle brakes often worsen the effect by directing some of the blast (and attending noise) rearward toward the shooter and sometimes sideways toward the next shooter. The damage to the hair cells in the cochlea will eventually cause deafness for the particular frequency. That frequency often corresponds to the frequency heard in some consonant and may produce a type of deafness that makes it difficult to hear speech, while higher pitched sounds can still be heard clearly. Interesting; however, not part of this document. We don’t want to minimize the importance of hearing protection; however, we have had to draw some limits. Thank you for the comment.

3.0 Best Management Practices, First paragraph, First sentence—I believe the least expensive and only way to control metal (lead) migration on shotgun ranges is to use steel shot. There is no appreciable difference, since there will be no competitive differences and steel shot is cheaper. Modern bores can handle steel shot and modern plastic cup wads protect all bores with the lighter skeet loads. In parts of the country with acid rain (Now most of the country) lead will rapidly migrate into groundwater and/or surface water. In arid regions, wind will cause abrading of lead shot and migration of lead dust. This there is no effective way to prevent lead migration from shotgun ranges. Therefore, I would exclude shotgun ranges and rewrite the first sentence to relate only to rifle/pistol ranges. Some differ in their evaluation of steel and other alternative shot material. We leave it to the operator to exercise appropriate management techniques.

3.0 Best Management Practices, Third bullet—Add, “Some fertilizers contain arsenic which may add to the heavy metal contamination.” This should be a consideration when adding fertilizer to any media, not specifically ranges.

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3.0 Best Management Practices, Fourth bullet—Add, “Carefully check berm for rocks, which may cause ricochets.” This is noted on page 32. Change accepted.

3.2 Alternative Shot Material, First paragraph, Third sentence, page 25—I disagree with this sentence, “For shooting clay targets, there is no current ideal replacement in terms of cost and performance.” The only realistic disadvantage with using steel shot is comparing a record of 999 out of 1,000 targets set with lead shot to 993 out of 1,000 with steel shot. In other words, while there might be some disadvantage for clays at 35+ yards, all shooters have the same disadvantage. Since we’re not dealing with cripples as in a hunting ban on lead shot, I don’t think the team should parse the issue. The comment is well taken. We have changed the text “ideal” to “perfect.”

3.5.2 Berm Construction and Maintenance, First partial paragraph, page 33—Add, “natural hills are formed by surface water flow (or perhaps wind) and may have to be managed more carefully.” Hills are the result of erosion. This does not necessarily mean erosion is still active and will unnecessarily transport lead. Slopes are the issue of control regardless of their development.

3.6.1.1 Sifting and Raking—I do not see that raking would be an effective shot recovery technique on ranges covered with vegetative cover such as grasses. Is this realistic? I would add a section on vacuuming, which seems to be a far better alternative. Sifting may involve shoveling material from the surface. Raking may not mean the traditional garden rake. It is realistic on smaller ranges. See Section 3.15 for vacuuming case study.

3.7 Stabilization of lead shot and bullets in the soils—Where the method chosen is to continue to allow lead shot and the BMP selected is to stabilize the lead in the soil, the deed should be annotated to prevent incompatible future use such as farming or housing, that could open an exposure pathway. That is a function of a closed range. Abandoned lead at a closing range will be subject to waste generation and disposal requirements. See SMART-1, Characterization and Remediation of Soils at Closed Small Arms Firing Ranges (ITRC 2003a, www.itrcweb.org).

3.9 Vegetative Cover Fourth paragraph—Plants such as marigolds which contain insecticide, will deter insects from eating the vegetative cover and thereby ingesting lead which can escalate up the food chain. Thank you for the suggestion. Many plants can act as natural barriers to pests.

3.10 Management Alternatives for Erosion—Two additional thoughts. We used coconut fiber logs to control erosion at an old range, with good success. Second, where the berm is manmade, placing it in a direction so that the backside is toward the prevailing bad weather (wind direction) can be helpful. Thank you. Range orientation is an important management practices.

3.11.1 Cartridge Cases and Wads—Plastic wads, which form shot cups (most commercial ammunition), chafe off a considerable amount of lead from the shot. This is readily observable on the white plastic cups as black or gray spots. This lead dust is easily washed off by rain. Therefore, a second reason exists to clean the litter. This is true. Even though this may not cause the soils to fail leach tests, they are an easily controllable source of some lead on the range. “These should be collected and containerized to prevent migration and potential exposure.”

Population density—During deliberations in deciding a small range (now a park) cleanup in southeast DC, a risk assessment found that children playing in the park would only increase their blood levels by 3. The clinical standard for plumbism is 10 u/dl, therefore the responsible party advocated that cleanup wasn’t necessary. A survey of the blood lead levels of surrounding children found that 10% had blood lead levels >7u/dl, thus playing on the range would add enough body burden to give them a lead poisoning, supporting a clean up decision. If a range were in an area of heavy lead exposure for animals or man, such as downwind from a smelter, then the additional body burden should be considered in deciding BMPs. The following language has been added in several locations in the document to refer the reader to more in-depth information on consequences of lead exposure: “This document is intended to address the minimization of potential exposures to lead associated with shooting ranges. It is not a general discussion

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of health effects stemming from exposures to lead, nor is it intended as a manual on range safety. The reader is encouraged to access other sources of more detailed information on those subjects.”

Video Practice ranges—Law enforcement and the military might consider virtual reality ranges for much of their shooting practice, just like pilots train in simulators. Thank you.

Toxic Table—List toxics issues with other range metals contaminants such as tungsten, epoxy, arsenic, antimony, etc. While lead is the current culprit, we don’t want to replace it with something worse. Correct. All metals must be managed in the amounts most commonly used at ranges to prevent problems. See last sentence in Section 1.1.

Unburned explosive residues are a big issue on artillery and bombing ranges. The Massachusetts Military Reservation Range has contaminated many of the wells in Cape Cod with explosive residue. For reasons unknown to me, shells which detonate properly often leave large chunks of undetonated explosive behind. Small arm ammo also leaves behind unburned powder. One can actually see the unburned powder cleaning a shotgun or 22. Many double-based powders are nitroglycerine and nitrocellulose. Some of these residues are toxic and more importantly water soluble. This might be another area to consider. Appropriate text/edits made to reflect your concerns.

Size and amount of firing at a range—The shooting club ranges used two weeks before hunting season to sight in rifles is a far different scenario from military ranges which fires 10,000 rounds a day. Perhaps some distinction should be made with respect to BMPs. The following has been added at the end of Section 3.1: “It should noted that range use (shooting regularity, intensity, etc.) has an effect on the environmental management of a facility. Many things are range specific according to use.”

Use of smaller caliber ammo or lighter weight bullets—Perhaps smaller gauge shotguns (410-28) could be used on shotgun ranges, particularly those ranges that supply the guns. Using 120 grain bullets instead of 180 grain bullets would reduce the heavy metal contamination at a ranges by 30%. We understand the concept; however, smaller caliber and smaller bullet size have other consequences also. 410 have a higher wound rate. Smaller projectiles may have a higher velocity, resulting in fragmentation, deeper penetration in berms, higher ricochet, etc.

Smaller gauge shotguns (410-28) also reduce sound. Also most ranges are fenced in to prevent kids, etc. from wandering onto the range by accident (either drawn by the shooting or entering before opening time) ivy (grapes, mile and minute etc.) can be planted on the fence to reduce the noise. We do not think we should to go into what guns to use. Plantings are not an effective range control practice.

Page 20—Section on Cartridge and Wads at the top of the page is a duplication of information found at the bottom of page 19. Correction completed.

...very useful document. I found it very informative. Congratulations to you and your team. Thank you.

We would like to review the regulatory section of the document when it is completed. There is no regulatory section in this document simply because the operation of a firing range is not overseen by any regulatory authority unless (1) it generates a waste and transports it off site or (2) there is a documented release to the environment. The team supports a voluntary program to reduce and prevent pollution using this guide.

The Illinois EPA did not fully agree with ITRC’s earlier guidance document on the characterization and remediation of soils at small arms ranges because it did not include regulatory flexibility for individual states. We recommend

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that the ITRC take our previous comments regarding the need for regulatory flexibility into account when they form the section on regulatory compliance. The team supports a voluntary program to reduce and prevent pollution using this guide, but states can choose other approaches to assure environmental protection at ranges.)

Executive Summary—The opening paragraph emphasizes the potential for migration of contaminants off-site; however, there is no discussion of the direct contact impact (i.e., inhalation and ingestion exposure) to humans using the operating firing range. This omission is repeated throughout the text. The human health exposure pathway should be mentioned as of equal concern when developing an Environmental Management Plan (EMP). The following has been added to the Executive Summary at the end of Paragraph 1: “This document is intended to address the minimization of potential exposures to 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.”

Section 2.0: Potential Environmental Issues at Ranges, Figure 2-1, Decision Tree—There is no pathway presented for considering direct contact to humans using the operating range. This should likely take preference over wildlife, and therefore, a diamond before “Is Wildlife an Issue?” should be included to reflect the discussion presented in Section 2.1.3. The dust/air quality issue should be placed under the direct contact to humans. Immediate or acute exposure is not depicted as are chronic or long-term exposure in the diagram.

Section 2.1.6: Wildlife and Habitat Concerns. Section 2.0—Makes an abrupt transition from discussing general issues associated with fate and transport to a discussion of lead. It has been found that copper may be a risk driver for water fowl where lead shot enters surface water. In addition, arsenic may be a problem in impacted soil. A small discussion of these other contaminants should be included. While it should be acknowledged that lead is the primary contaminant of concern, the impression should not be given that if exposure to, and transport of, lead is controlled then all environmental problems will be solved. Copper has been included as a related metal in earlier sections.

Section 3.6: Metal Recovery Techniques for Berm Maintenance—Since this is an EMP document, it would be beneficial to range operators to have a list of contacts for lead recycling operations, such as a generic web site for lead recycling associations, etc. Please see the list of references in Chapter 1.

Section 3.6.1.1 Sifting and Raking—The text box in this section indicates that proper personnel protection equipment (PPE) should be used when workers come into contact with lead-impacted soil. However, no discussion is included to the effect of what this protection would entail. A separate subsection within Section 2.0 on PPE would probably be beneficial for a range operator to know (i.e., dust mask, gloves, disposable Tyvek suit, etc.). The team feels this guidance should not describe what to use, just suggest they contact lead exposure/poisoning prevention sources for details.

Section 3.9: Vegetative Control—At the bottom of page 42, a suggestion is made to contact state wildlife agencies for a list of plants not attractive to wildlife. Are there any websites that provide a comprehensive list of these agencies throughout the U.S., and if so, can it be included within the document? Any outside references would be helpful to range operators in finding the resources needed to design and implement the EMP. See www.itrcweb.org for a listing of all state Web sites. Each can lead you to related state, county, and federal agencies helpful in this and other areas.

Section 3.15: Emerging Technologies, Sulfur-Based Stabilization Technology, Sulfitech Compound—Please provide a reference for the EPA study cited at the end of page 61. Adequate supporting testing documentation has not been provided as of this printing and the section has been deleted.

Section 4.2: General Environmental Conditions—Possible copper and arsenic contamination should be briefly mentioned here.

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Good point. The following has been added at the end of the section: “Other metals may become the environmental concern at a site and should not be ignored or assumed not to pose a potential problem see Table 2-1.”

Section 4.4: Management Plan Development—On Table 4-3, Template for an Environmental Management Plan, it may be prudent to condense Section 3.0 through 5.0 into one section, so that the EMP outline is not too long and daunting. The different range types are discussed in the text, and it should be implicit to the range operators that they will need to develop an action plan and plan implementation for each type of range The range type is an important function of lead dispersal and should drive much of the investigation. Comment rejected.

Section 2.1.1, Soil Cover—Include the words “and fine-grained sediment” into the first sentence. Add the following sentences, “Organic carbon also reduces oxidized forms of lead into lead sulfides, which are relatively immobile in anoxic environments. Therefore, thicker organic-rich soil covers generally result in lower concentrations of lead in groundwater and pore moisture.” Changes adopted.

Section 2.1.2, Transport—In the “Precipitation” section, include the idea of lead transport through sediments. Suggested language was adopted to include lead sediment transport.

Section 2.1.6, Wildlife and Habitat Concerns—Add language to recognize the significance of soil ingestion as an impact on terrestrial invertebrates and aquatic benthic organisms. Suggested language adopted.

Section 3.15, Phytoremediation of Lead-Contaminated Soil—Add the following sentence to the end of “Implications”: “Caution must be taken as this technology may result in an increased risk of groundwater contamination from EDTA or increased soluble metals produced via soil acidification.” The suggested sentence has been added.

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APPENDIX E

ITRC Contacts, Fact Sheet, and Product List

Small Arms Firing Range Team Contacts

Richard Albright Robert Byrne, Wildlife Prog. Coordinator Washington D.C. Department of Health Wildlife Management Institute P: 202-535-2283 1101 14th Street, N.W. Suite 801 [email protected] Washington, DC 20005 P: 202-371-1808 Mark Begley, Team Co-Leader F: 202-408-5059 Executive Director [email protected] Massachusetts Environmental Management Commission Elizabeth Callahan P: 508-968-5127 MA Dept of Environmental Protection F: 508-968-5128 1 Winter Street [email protected] Boston, MA 02108 P: 978-661-7722 Marshall Bracken Jr. F: 617-292-5850 Surbec-ART Environmental [email protected] 3200 Marshall Ave, Suite 200 Norman, OK 73072 William Call P: 405-364-9726 PMK Group F: 405-366-1798 P: 732-751-0799 [email protected] Michael Burkett, Vice President Metals Treatment Technologies John L. Cefaloni 12441 West 49th Ave, Suite #3 RangeSafe Technology Demonstration Wheat Ridge, CO 80126 Initiative (RTDI) P: 303-456-6977 US Army AMSTA-AR-WEA F: 303-456-6998 Building 321 [email protected] Picatinny Arsenal, NJ P: 973-724-3295 John Buck F: 973-724-3162 US Army Environmental Center C: 973-220-8192 Building 4430 [email protected] Aberdeen Proving Ground, MD 21010 P: 410-436-6869 James F. Crowley, P.E. F: 410-436-6836 RMT, Inc. john [email protected] 744 Heartland Trail Madison, WI 53717 Greg Butler P: 608-662-5322 BEM Systems F: 608-831-3334 1600 Genesee, Suite 610 [email protected] Kansas City, MO 64102 P: 816-842-7440 F: 816-842-7844 [email protected]

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Rick Cox Ed Guster Parson USEPA P: 703-967-6910 290 Broadway 22nd Floor [email protected] DECA-RCB New York, NY 10007 Jim Dawson, Principal P: 212-637-4144 Concurrent Technologies Corporation F: 212-637-4949 999 18th St., Suite 1615 [email protected] Denver, Co 80202 P: 303-297-0180 Charles Harman F: 303-297-0188 AMEC Earth and Environmental, Inc. [email protected] 205 Division Ave., Suite 100 Somerset, NJ 08873 Scott Edwards P: 732-302-9500 Senior Program Manager F: 732-302-9504 Metals Treatment Technologies [email protected] 7928 Bayberry Drive Alexandria, VA 22306 John Christopher P: 703-765-3510 Cal EPA Department of Toxic Substance F: 703-660-9296 Control [email protected] 916-255-6630 [email protected] Stacey L. French, Environmental Engineer SC Dept of Health & Environ. Steve R. Hill, ITRC 2600 Bull Street Reg-Tech, Inc. Columbia, SC 29201 2026 North Meyers Drive P: 803-896-4255 Pine, ID 83647 F: 803-896-4002 P: 208-653-2512 [email protected] C: 208-250-4392 F: 208-653-2511 Stephen C. Geiger [email protected] The RETEC Group, Inc./ESTCP 2111 Wilson Blvd., Suite 700 Keith Hoddinott, Senior Soil Scientist Arlington, VA 22201 US Army Corps of Engineers P: 703-351-5086 3743 Ady Road F: 703-351-9292 Street, MD 21154 [email protected] P: 410-436-5209 F: 410-436-8170 Dibakar (Dib) Goswami, Ph.D., Team Co- [email protected] Leader Washington Dept of Ecology Terry Jennings Port of Benton Blvd. Concurrent Technologies Corporation Richland, WA 99354 999 18th St, Suite 1615 P: 509-372-7902 Denver, CO 80202 F: 509-372-7971 P: 303-297-0180 [email protected] [email protected]

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Satish Kastury Bonnie Packer V.P. Government & Regulatory Affairs U.S. Army Environmental Center WRS SFIMAEC-PCT 625 E. Tennessee Street, Suite 100 5179 Hadley Road Tallahassee, FL 32308 Aberdeen Proving Ground, MD P: 850-339-9947 21010-5401 [email protected] P: 410-436-6846 F: 410 436-6836 Jeff Lockwood [email protected] FL Dept of Environmental Protection 2600 Blairstone Road, Room 438J R. Richard Patterson, Managing Director MS 4535 Sporting Arms and Ammunition Tallahassee, FL 32301 Manufacturers' Institute, Inc P: 850-488-3935 11 Mile Hill Road F: 850-922-4939 Newtown, CT 06470-2359 [email protected] P: 203-426- 4358 [email protected] George Meyer USEPA Ioana G. Petrisor, Ph.D. 290 Broadway 22nd Floor Environmental Scientist DECA-RCB DPRA, Inc. New York, NY 10007 100 San Marcos Blvd., Suite 308 P: 212-637-4144 San Marcos CA 92069 F: 212-637-4949 P: 760 752-8342 (ext. 12) [email protected] F: 760 752-8377 [email protected] Robert T. Mueller, Team Co-Leader www.DPRAenvironmentalforensics.com New Jersey DEP 401 E. State Street Ed Stevenson P.O. Box 409 New Jersey DEP Trenton, NJ 08625 401 East State Street P: 609-984-3910 PO Box 409 F: 609-292-7340 Trenton, NJ 08625 [email protected] P: 609-633-1342 F: 609-292-7340 Susan Newton [email protected] Colorado Department of Public Health and Environment Peter M. Strauss P: 303-692-3321 PM Strauss & Associates [email protected] 317 Rutledge Street San Francisco, CA 94110 P: 415-647-4404 F: 415-647-4404 [email protected]

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Dennis Teefy Kimberly Watts U.S. Army Aberdeen Test Center, Military USAEC Environmental Technology Demonstration SFIM-AEC-PCT Center 5179 Hoadley Rd P: 410-278-4062 Aberdeen Proving Ground, MD 21010 [email protected] P: 410-436-8843 F: 410-436-6843 Mike Warminsky [email protected]/army.mil AMEC Earth & Environmental, Inc. 285 Davidson Avenue, Suite 100 Rafael Vasquez Somerset, NJ 08873 Air Force Center for Environmental P: 732-302-9500 Excellence F: 732-302-9504 HQ AFCEE/ERT [email protected] 3207 North Road Brooks AFB, TX 78235-5363 P: 210-536-1431 F: 210-536 4330 [email protected]

E-4 United States EPA-902-B-01-001 Environmental Protection Revised June 2005 Agency Region 2

Best Management Practices for Lead at Outdoor Shooting Ranges For additional copies of this manual, please contact:

United States Environmental Protection Agency Division of Enforcement and Compliance Assistance RCRA Compliance Branch 290 Broadway, 22nd Fl. New York, New York 10007-1866

Tel: 212-637-4145 Fax: 212-637-4949

Copies of this manual along with any additions or updates can also be obtained on-line at: http://www.epa.gov/region2/waste/leadshot

Copying and Reprinting

This document is in the public domain and may be freely copied or reprinted.

Fourth Printing, June 2005 BMP for Lead at Outdoor Shooting Ranges

Best Management Practices for Lead at Outdoor Shooting Ranges

Notice

This manual is intended to provide useful general information to shooting range owners/operators. The United States Environmental Protection Agency (EPA) does not certify or approve ranges, range design or lead management practices. While every effort has been made to provide up-to- date technical information, this manual is not to be used as a substitute for consultation with scientists, engineers, attorneys, and other appropriate professionals who should be called upon to make specific recommendations for individual range design and lead management.

Any variation between applicable regulations and the summaries contained in this guidance document are unintentional, and, in the case of such variations, the requirements of the regulations govern.

This guidance was developed by EPA Region 2 in cooperation with a few states as well as many EPA offices. In addition, EPA, with the assistance of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) provided all 50 states with an opportunity to review the RCRA regulatory portion of the guidance. At the time of printing, about 40 states had contacted the EPA and given their support and concurrence. EPA is continuing to get the agreement of the remaining states. Therefore, it appears that most, if not all, states will share the same view as to how lead shot is regulated.

Following the steps set forth in this guidance should result in compliance with applicable regulations. EPA does not make any guarantee or assume any liability with respect to the use of any information or recommendations contained in this document.

This guidance does not constitute rulemaking by the EPA and may not be relied on to create a substantive or procedural right or benefit enforceable, at law or in equity, by any person.

Notice BMP for Lead at Outdoor Shooting Ranges

Acknowledgements

The USEPA would like to acknowledge the support of:

• The National Rifle Association of America • The National Shooting Sports Foundation • The Wildlife Management Institute • Mark Begley of the Massachusetts Department of Environmental Protection • Mr. Dick Peddicord of Dick Peddicord and Company, Inc.

These participants provided valuable information and assistance as peer reviewers in the development of the manual and their efforts are truly appreciated. EPA also wishes to give special thanks to Dr. Charles W. Sever of Okie Environmental Consulting, L.L.C., Inc., Mr. Mike Warminsky of Brice Environmental Services Corp., and Mr. Victor Ordija of Sporting Goods Properties.The EPA also wishes to acknowledge and thank the many others who provided important comments and insight, and especially those individuals who took the time to meet with us in person or on the phone.

Cover photo by: Mr. Jack Hoyt, EPA Region 2

Acknowledgements BMP for Lead at Outdoor Shooting Ranges

Statement of Goals

The goals of this manual are:

to inform shooting ranges :

that the United States Environmental Protection Agency’s (EPA) purpose in developing and distributing this manual is to assist range owners and operators to operate in an environmentally protective manner.

to promote an understanding of:

why lead is an environmental, public and regulatory concern,

what laws and regulations apply,

the benefits of applying good management practices,

what can be done to successfully manage lead,

why implementing lead best management practices is an integral part of environmental stewardship,

how to minimize litigation risk.

to promote action by ranges to:

adopt and implement best management practices for managing lead,

recycle a finite natural resource,

become a model for other ranges through proper lead management,

advocate environmental stewardship.

Statement of Goals This page intentionally left blank BMP for Lead at Outdoor Shooting Ranges

EPA Statement on National Guidance

EPA Statement on National Guidance BMP for Lead at Outdoor Shooting Ranges

Best Management Practices for Lead at Outdoor Shooting Ranges

Table of Contents

Page

List of Figures ...... ii List of Tables ...... ii Introduction ...... iii

Chapter I - Environmental and Regulatory Concerns at the Shooting Range ...... I-1 1.0 Background ...... I-1 1.1 Lead Contamination’s Impact on Human Health and the Environment ...... I-2 1.2 Legal Requirements & Court Rulings ...... I-6 1.3 Benefits of Minimizing Lead’s Environmental Impact ...... I-12

Chapter II - Range Characteristics & Activities to Consider When Implementing BMPs ...... II-1 2.0 Background ...... II-1 2.1 Physical Characteristics ...... II-1 2.2 Operational Aspects ...... II-4 2.3 Planning a New Range ...... II-4

Chapter III - BMPs for Outdoor Ranges ...... III-1 3.0 Background ...... III-1 3.1 Bullet and Shot Containment Techniques (Step 1) ...... III-1 3.2 BMPs to Prevent Lead Migration (Step 2)...... III-5 3.3 Lead Removal and Recycling (Step 3) ...... III-11 3.4 Documenting Activities and Record Keeping (Step 4) ...... III-17 3.5 Additional Economic Considerations ...... III-18 3.6 Summary of Key BMPs for Shooting Ranges ...... III-18 3.7 Certificate of Recognition...... III-18

References Appendix A - Resources Appendix B - Lead Shot Alternatives Appendix C - Sample Bullet Containment Devices Appendix D - RCRA Regulatory Requirements and Interpretations Appendix E - Template for an Environmental Stewardship Plan for Management of Lead Shot/Bullets

Table of Contents - i BMP for Lead at Outdoor Shooting Ranges

List of Figures

Figure Number Page

1-1 Effects on the Human Body from Excessive Exposure to Lead I-5

2-1 pH Scale II-1

3-1 Four Steps to Build a Successful Lead Management Program III-1 Utilizing a Variety of BMPs

3-2 Sample Filter Bed System III-10

3-3 Examples of Common Lead Reclamation Equipment III-11

List of Tables

Table Number Page

1-1 Application of Key Terms to Outdoor Ranges I-10

2-1 Common Physical Characteristics at Ranges - Potential Risks II-3 and Benefits Associated with Range Operations

3-1 Summary of Key BMPs III-19

3-2 Calculating Weight of Lime to Increase Soil pH Values III-6

Lists of Figures and Tables - ii BMP for Lead at Outdoor Shooting Ranges

and the importance of an integrated BMP Introduction program to manage lead. • Chapter II discusses physical and operational characteristics to be considered This manual provides owners and operators of when selecting a successful BMP program. outdoor rifle, pistol, trap, skeet and sporting clay ranges with information on lead management at • Chapter III addresses best management their ranges. This manual serves as a reference techniques for rifle/pistol ranges, skeet and guide and presents best management practices trap ranges, and sporting clay ranges. In this (BMPs) available to the shooting range chapter, the manual explores possible community. The practices have been proven to solutions to prevent, reduce and/or remove effectively reduce or eliminate lead lead contamination for each type of range. contamination and may also be economically beneficial to the range owner/operator. Since • The Appendices provide current (as of June each range is unique in both the type of shooting 2005) contacts for lead reclamation and activity and its environmental setting, specific recycling companies, vendors that provide solutions are not provided in this manual. prevention and/or remediation techniques and Rather, a range owner or operator may use this shooting organizations that have additional manual to identify and select the most information on the lead issue. Additionally, appropriate BMP(s) for their facility. Other the Appendices provide information on information on environmental aspects of alternatives to lead, diagrams of bullet trap management at outdoor shooting ranges can be designs, summaries of regulatory found in the National Shooting Sports requirements and interpretations, and a Foundation’s Environmental Aspects of sample Environmental Stewardship Plan. Construction and Management of Outdoor Shooting Ranges. EPA is very interested in any suggestions you have about practices included in this manual The manual does not address range layout or which have proven effective in controlling lead design to meet range safety or competition contamination or recycling lead bullets/shot. requirements. For information on range safety Please send such information to the address and competition requirements, range owners/ below. Also, for additional information, or to be operators are directed to other comprehensive added to the list of lead reclaimers or reference materials available on that subject, remediation contractors, contact the National such as the National Rifle Association’s Range Rifle Association (NRA), the National Shooting Source Book, and the National Association of Sports Foundation (NSSF) or: Shooting Range’s website (www.rangeinfo.org). Lead Shot Coordinator Owners/operators of ranges may want to RCRA Compliance Branch assign the use of this BMP Manual to a U.S. Environmental Protection Agency specific team or committee. Delegating this Region 2 responsibility to a specific team or group 290 Broadway helps to assure that the BMP’s are identified New York, New York 10007-1866 and implemented. Telephone: (212)637-4145 E-Mail: [email protected] The manual is organized as follows:

• Chapter I provides the background on why lead is of concern to human health and the environment. It includes a discussion of how environmental laws impact shooting ranges

Introduction - iii This page intentionally left blank BMP for Lead at Outdoor Shooting Ranges

(CDCP), and a large number of states have Chapter I: identified human exposure to all forms of lead as Environmental and Regulatory a major health concern in the United States.

Concerns at the Shooting Range Lead management practices at ranges across the United States remain inconsistent. Some range owners/operators have examined the 1.0 Background impact of range operations on human health and the environment and have implemented Outdoor shooting ranges provide recreational procedures to manage and/or remove facilities for millions of shooting sports accumulated lead from ranges. Other range enthusiasts in the United States. Recently, there owners/operators are just beginning to has been a growing public concern about the characterize and investigate their ranges in potential negative environmental and health order to design an environmental risk prevention effects of range operations. In particular, the and/or remediation program(s) specific to their public is concerned about potential risks sites. A third group of ranges has adopted a associated with the historical and continued use “wait and see” policy – taking no action until of lead shot and bullets at outdoor ranges. specifically required to do so by law or clear guidance is in place. Finally, a fourth, small, but This concern is not unfounded. An estimated important group of range owners/operators 9,000 non-military outdoor ranges exist in the remain unaware of lead’s potential to harm United States, collectively shooting millions of human health and the environment, and of pounds of lead annually. Some ranges have existing federal and state laws. operated for as long as several generations. Historical operations at ranges involved leaving To manage lead, many owners and operators expended lead bullets and shot uncollected on have successfully implemented Best ranges. Many of these ranges continue to Management Practices (BMPs) at their ranges. operate in the same manner as in the past. These range owners and operators have realized many benefits from sound lead It is estimated that approximately four percent management including: (4%) (80,000 tons/year) of all the lead produced in the United States in the late 1990’s (about 2 - stewardship of the environment, natural million tons/year), is made into bullets and shot. resources and wildlife, Taking into account rounds used off-range, and - improved community relations, rounds used at indoor ranges, it is clear that - improved aesthetics of the range/good much of this 160,000,000 pounds of lead shot/ business practices, bullets finds its way into the environment at - increased profitability through recovery/ ranges. recycling lead, a valuable and finite resource, and Since the mid-1980’s, citizen groups have - reduced public scrutiny. brought several lawsuits against range owners and have urged federal and state agencies to Shooting sports organizations [e.g., National take action against owners and operators of Rifle Association (NRA) and the National outdoor shooting ranges. The citizen groups Shooting Sports Foundation (NSSF)] promote argued that range owners improperly managed lead management throughout the United States. discharged lead bullets and shot. Federal courts These organizations have researched different have supported parts of these suits, requiring methods to effectively address potential and range owners/operators to clean up lead- actual lead mobility and exposure without contaminated areas. Concurrent with the detracting from the enjoyment of the sport. The increased citizen suit activity, the federal EPA, NRA, NSSF, and a number of other shooting the Centers for Disease Control and Prevention sports organizations strongly encourage range

Chapter I - Page I-1 BMP for Lead at Outdoor Shooting Ranges owners/operators to develop a BMP program soil, it breaks down by weathering into lead that contains elements discussed later in this oxides, carbonates, and other soluble manual. Contact the NRA and NSSF for compounds. With each rainfall, these additional guidance materials available on lead compounds may be dissolved, and the lead may management practices. move in solution in the storm runoff waters. Decreases in water acidity (i.e., increases in its By implementing appropriate lead management pH) will cause dissolved lead to precipitate out of at outdoor shooting ranges, range owners and solution. Lead concentrations in solution are operators can reduce the environmental and reduced by this precipitation. At pHs above 7.5, health risks associated with lead deposition, very little lead remains in solution. Increased meet legal requirements and realize quantifiable time of contact between lead and acidic water benefits. generally results in an increase in the amount of dissolved lead in the storm runoff water. The five 1.1 Lead Contamination’s Impact factors which most influence the dissolving of lead in water are summarized below: on Human Health and the Environment Annual Precipitation Rate - The higher the annual precipitation rate, the faster the lead Exposure Routes weathers. Also, during prolonged rains, the contact time between water and lead is Historically, the three major sources for human increased. In general, the higher the exposure to lead are lead-based paint, lead in precipitation rate, the higher the potential risk of dust and soil and lead in drinking water. lead migration off-site in solution. Typically, human exposure occurs through ingestion, which is the consumption of lead or pH of Rain and Surface Water - The acidity of lead-contaminated materials, or by inhalation. the rainwater decreases as basic (alkaline) The main human exposure to lead associated minerals in the soil are dissolved. If sufficient with shooting ranges is through lead- minerals such as calcium, magnesium, and iron contaminated soil. However, other pathways are are present in local soils, then the lead may discussed below, along with lead’s detrimental quickly precipitate out of solution entirely as effects on humans and animals. these other minerals are dissolved. The pH of shallow surface water is an indicator of the Lead can be introduced into the environment at presence or absence of basic minerals in the shooting ranges in one or more of the following local soil and in gravel within the stream beds ways. Each of these pathways is site-specific through which the water has moved. The water and may or may not occur at each individual in deeper streams and lakes is more likely to be range: composed of acidic rainwater that is not neutralized. • Lead oxidizes when exposed to air and dissolves when exposed to acidic water or Contact Time - The contact time between soil. acidic surface water and lead is a factor in the amount of lead that is dissolved. For example, • Lead bullets, bullet particles, or dissolved lead shot deposited directly into a lake has a lead can be moved by storm water runoff. longer contact time then lead shot deposited in • Dissolved lead can migrate through soils to upland areas. groundwater. Soil Cover - Organic material will absorb lead Lead oxidizes when exposed to air and and remove it from a water solution. The thicker dissolves when exposed to acidic water or soil the organic leaf and peat cover on the soil, the lower the lead content in solution in water leaving When lead is exposed to acidic water and/or the shot area. Organic material has a strong

Chapter I - Page I-2 BMP for Lead at Outdoor Shooting Ranges ability to extract lead out of solution in water. Vegetative Cover and Man-made Structures - Structures such as dams and dikes reduce the pH of Groundwater - During periods of no water’s velocity and greatly reduce the size and rainfall, the water flowing within most streams weight of the lead particles the water can carry. comes from groundwater discharging into the Since lead particles are heavy compared to the stream channel. Therefore, the acidity of the other suspended particles of similar size, they groundwater affects the acidity of the surface are more likely to be deposited under the water, and hence, affects the solubility of any influence of anything that reduces velocity of the lead particles carried into the stream during storm runoff. Grass and other vegetation storm runoff. reduce runoff velocity and act as a filter to remove suspended solids from the water. Lead bullets, bullet particles or dissolved lead can be moved by storm water runoff Dissolved lead can migrate through soils to groundwater The ability of water to transport lead is influenced by two factors: velocity of the water and weight Acidic rainwater may dissolve weathered lead or size of the lead fragment. Water’s capacity to compounds. A portion of the lead may be carry small particles is proportional to the square transported in solution in groundwater beneath of the water’s velocity. Clear water moving at a land surfaces. Groundwater may transport lead velocity of 100 feet per minute can carry a lead in solution from the higher topographic areas to particle 10,000 times heavier than water moving the lower areas such as valleys, where it is at a velocity of 10 feet per minute. Muddy water discharged and becomes part of the surface can carry even larger particles. The five factors water flow. If the water flowing underground that most influence velocity of runoff are passes through rocks containing calcium, described below: magnesium, iron, or other minerals more soluble then lead, or through minerals that raise the pH Rainfall Intensity - The greater the volume of of the water, then the lead in solution may be rainfall during a short period of time, the faster replaced (removed) from the solution by these the velocity created to carry the rainfall off-site. other metals. However, if the soil is a clean The higher the annual rainfall, the greater the silica sand and gravel, fractured granite, or number of periods of heavy rainfall. similar type material, then the lead may move long distances in solution. The factors most Topographic Slope - Generally, the steeper the likely to affect the amount of lead carried by the topographic slope, the faster the velocity of groundwater in solution are discussed below: stormwater runoff. Annual Precipitation - Generally, high Soil Type - More rainfall will soak into sandy precipitation rates result in heavy dew, more soils then into clay soils. Hence, for a given frequent rainfall, numerous streams, shallow rainfall intensity, the volume of runoff will be depth to groundwater, shorter distance of travel, greater from areas underlain by clays or other and more rapid rates of groundwater flow. Also, low permeable soils than from permeable sandy the greater volumes of rainfall over geologic time soil. probably have reduced the amount of calcium and other soluble basic minerals that could raise Velocity - Velocity tends to decrease as stream the water pH and cause lead to precipitate width increases. Merging streams, eddy (settle) out of solution from the groundwater. currents, and curves in streams are other factors that may reduce the velocity. Generally, the Soil Types - Clays have a high ionic lead shorter the distance from the lead deposit to the bonding capacity and more surface area to property line, the more likely it is that the lead which the lead can bond. Also, groundwater fragments in suspension will be transported off- movement in clay is very slow, which increases site. the contact time for lead to bond to the clay.

Chapter I - Page I-3 BMP for Lead at Outdoor Shooting Ranges

Low permeability reduces the amount of Federal, state and local actions, including bans historical leaching and increases the probability on lead in gasoline, paint, solder and many other of the presence of basic (pH-increasing) lead-containing products, have resulted in minerals that can precipitate out of solution in significant reductions in average blood-lead groundwater or cause the lead to bond to the levels. Despite these advances, the number of clay. All of the basic calcium and related lead-poisoned children remains alarmingly high. minerals generally will have been removed from Children living in older homes may be exposed the clean silica sand and gravel soils, so the to lead in peeling paint or paint dust. Children lead in solution in groundwater in these type can also come in contact with lead in soil and soils can move long distances (miles) through with lead dust carried home on the clothing of the ground relatively unchanged. parents.

Soil Chemistry - The more basic minerals like On ranges, inhalation is one pathway for lead calcium and magnesium that are present in soils exposure since shooters are exposed to lead along the pathways through which the dust during the firing of their guns. Because groundwater moves, the greater the lead wind is unlikely to move heavy lead particles precipitation (removal) rate. Lead should move very far, airborne dust is generally considered a in solution only a short distance (a few feet) potential threat only when there are significant through a sand composed of calcium shell structures that block air flow on the firing line. fragments, but could move in solution long Under such conditions, the hygiene and other distances (miles) through clean quartz sand. practices proposed by the NRA for indoor shooting ranges in their “Source Book” are Depth to Groundwater - In areas of applicable to outdoor ranges. groundwater discharge such as river flood plains and most flat areas, the groundwater surface is Range workers may also be exposed to lead often a few feet below the surface. Remember, dust while performing routine maintenance the shorter the distance traveled, the greater the operations, such as raking or cleaning out bullet risk that the lead will migrate into the traps. Owners/operators may want to protect environment. Shallow depth to groundwater is these workers by requiring them to wear the indicative of higher risk for lead to reach the proper protective equipment or dampening the water. soil prior to work. pH of Groundwater - Although other factors Another exposure route for lead at outdoor influence solubility of lead in water, a good rule of ranges is ingestion by direct contact with lead or thumb is that lead will precipitate out of solution lead particles. For example, lead particles when the pH or alkalinity of water is greater then generated by the discharge of a firearm can about 7.5. But, lead dissolved in acid collect on the hands of a shooter. These groundwater may travel many miles without particles can be ingested if a shooter eats or change. smokes prior to washing his/her hands after shooting. The relative risk of lead exposure to Health Effects of Lead Exposure on Ranges people in a well managed facility is low.

Lead poisoning is a serious health risk. At Detrimental effects due to elevated lead levels higher concentrations, it is dangerous to people can also be found in animals. Excessive of all ages, leading to convulsions, coma and exposure to lead, primarily from ingestion, can even death. At even very low concentrations, it cause increased mortality rates in cattle, sheep is dangerous to infants and young children, and waterfowl. For example, waterfowl and damaging the developing brain and resulting in other birds can ingest the shot, mistaking it for both learning and behavioral problems. Figure 1- food or grit. Waterfowl, in particular, are highly 1 describes the effects of exposure to lead on susceptible to lead ingestion. This is a concern children and adults. at ranges where shooting occurs into or over

Chapter I - Page I-4 BMP for Lead at Outdoor Shooting Ranges

Effects on the Human Body from Excessive Exposure to Lead

If not detected early, children with relatively low levels of lead (as low as 10 microgram/deciliter for children) in their bodies can suffer from:

- damage to the brain and nervous system, - behavior and learning problems (such as hyperactivity and aggressiveness), - slowed growth, - hearing problems, - headaches, and - impairment of vision and motor skills.

Adults can suffer from:

- difficulties during pregnancy, - reproductive problems in both men and women (such as low birth weight, birth defects and decreased fertility), - high blood pressure, - digestive problems, Hearing Problems - neurological disorders, - memory and concentration problems, Brain or Nerve Damage - muscle and joint pain, and - kidney dysfunction.

Slowed Growth

Digestive Problems

Lead affects the body in many ways Reproductive Problems (Adults)

Figure 1-1: Effects on the Human Body from Excessive Exposure to Lead

Chapter I - Page I-5 BMP for Lead at Outdoor Shooting Ranges water. Many of the legal and government actions understand the legal issues and requirements. that have been brought against ranges are based on elevated levels of lead and increased 1.2.1 Resource Conservation and mortality in waterfowl. For example, in one case, Recovery Act (RCRA) an upland area of a range became a temporary pond after a thunderstorm. Waterfowl used the pond to feed and shortly thereafter, there was a RCRA provides the framework for the nation’s waterfowl die-off (increase in bird mortality), solid and hazardous waste management apparently from lead ingestion. program. Under RCRA, EPA developed a “cradle-to-grave” system to ensure the 1.2 Legal Requirements & Court protection of human health and the environment when generating, transporting, storing, treating Rulings and disposing of hazardous waste. RCRA potentially applies to many phases of range To date, most litigation concerns have been at operation because lead bullets/shot, if shotgun ranges where the shotfall zone impacts abandoned, may be a solid and/or a hazardous water or wetland areas. The potential waste and may present an actual or potential environmental and human health risks are imminent and substantial endangerment. greater at these ranges. However, all ranges, including those not located near water bodies, Connecticut Coastal Fishermen’s may be subject to legal and government action if Association v. Remington Arms Company, et proper range management programs are not al. implemented. Range owners/operators should expect greater scrutiny as ranges become more In the late 1980s, the Connecticut Coastal visible to regulators, environmental groups and Fishermen’s Association filed a lawsuit against the general public. Remington Arms Company as the owner of the Lordship Gun Club. The Lordship Gun Club Citizen groups have been the driving force (a.k.a. Remington Gun Club) is a 30-acre site in behind most legal actions taken against outdoor Stratford, Connecticut, located on the Long ranges. These groups have sued range owners/ Island Sound at the mouth of the Housatonic operators under federal environmental laws. Two River. In the mid-1960s, the Lordship Gun Club of EPA’s most comprehensive environmental was reconstructed to its final configuration of 12 laws, the Resource Conservation and Recovery combined trap and skeet fields and one Act (RCRA) and the Clean Water Act (CWA), additional trap field. Over the years, the specifically provide citizens with the right to sue Lordship Gun Club became known as one of the in cases in which the environment and human premier shooting facilities on the East Coast. health are threatened. These citizen suits have been highly effective in changing the way ranges The Connecticut Coastal Fishermen’s operate, even when out-of-court settlements Association filed a lawsuit, alleging that lead shot have been reached. The decisions of the United and clay targets are hazardous waste under States Court of Appeals for the Second Circuit in RCRA. The Complaint alleged that because the Remington Arms and New York Athletic Club set lead shot and clay targets were hazardous a legal precedent in the application of RCRA wastes, the gun club was a hazardous waste and/or the CWA to outdoor ranges. Lead storage and disposal facility subject to RCRA management programs at outdoor ranges must requirements. The plaintiff also sought civil comply with both laws. Actions have also been penalties and attorney’s fees. taken under the Comprehensive Environmental Response, Compensation and Liability Act Remington moved for a summary judgment (CERCLA) commonly know as Superfund. dismissing the complaint, and the Connecticut State and local statutes and regulations may Coastal Fisherman’s Association cross-moved also apply. To ensure environmental laws are for a partial summary judgment on the issue of being followed, range owners/operators must liability. On September 11, 1991, the United

Chapter I - Page I-6 BMP for Lead at Outdoor Shooting Ranges

States District Court for the District of are not subject to RCRA regulations, EPA or any Connecticut ruled on the case. state, municipality, or citizen group can take legal action under the statutory provisions of Regarding the plaintiff’s claims under RCRA, the RCRA against gun clubs for actual or potential District Court ruled in favor of the Connecticut environmental damage occurring during, or even Coastal Fishermen’s Association, holding that after, the operation of the club. Under RCRA, the lead shot and clay targets were “discarded the plaintiff would be eligible to recover its legal materials” and were “solid waste;” therefore, the fees as well. materials were subject to regulation under RCRA. The court further stated that the 3. The court concluded that lead shot and discharged lead shot was a “hazardous waste,” clay targets meet the statutory definition of solid but declined to rule on whether the clay target waste because these materials were “discarded fragments were also hazardous waste. (i.e. abandoned)” and “left to accumulate long Remington petitioned the United States Court of after they have served their intended purpose.” Appeals for the Second Circuit Court to review Further, the court concluded that based upon the lower court’s ruling. toxicity testing and evidence of lead contamination, the lead shot was a hazardous On June 11, 1992, both parties presented oral waste subject to RCRA. arguments before the court. Subsequent to oral arguments, the appellate court requested that The important point to consider here is that if EPA file an amicus brief “addressing whether lead shot and clay target debris are discarded lead shot and clay target debris deposited on (i.e. abandoned), these materials are considered land and in the water in the normal course of a solid waste as defined in the statute and the trap and skeet shooting is ‘discarded material’... facility may be subject to governmental or citizen so as to constitute ‘solid waste’ under RCRA.” suits.

On March 29, 1993, the United States Court of If, on the other hand, the discharged lead shot is Appeals for the Second Circuit reached its recovered or reclaimed on a regular basis, no decision. With respect to RCRA, the court both statutory solid waste (or hazardous waste) reversed and affirmed the lower court’s opinion would be present and imminent hazard suits in part. would be avoided.

Briefly, the decision affects currently operating Thus, the Remington Arms case is an important and future gun clubs, and the following key legal precedent. Even though regulations have points are of primary concern: not been issued regarding gun club operations and environmental protection, gun clubs are still 1. With respect to RCRA, the court agreed at risk of legal action under RCRA if they fail to with EPA’s amicus brief, which had argued that routinely recover and reclaim lead, do not take shooting at gun clubs is not subject to regulatory steps to minimize lead release or migration, or if (as opposed to statutory) requirements. In other they abandon lead in berms. words, during routine operations, gun clubs are not viewed as facilities that manage hazardous Gun clubs where there is shooting into water, wastes subject to RCRA regulations and, as wetlands, rivers, creeks, and other sensitive such, do not require RCRA permits. environments have the highest degree of litigation risk. Conversely, gun clubs that have 2. Another argument in the EPA’s amicus the lowest risk of environmental litigation or brief with which the court agreed was the view government action are those clubs that do not that the RCRA statute allows citizen suits to be shoot into water or wetlands and which have an brought if a gun club’s shooting activities pose active program to recover lead. an “imminent and substantial endangerment to health or the environment.” Although gun clubs The following describes how RCRA may apply to outdoor shooting ranges. Chapter I - Page I-7 BMP for Lead at Outdoor Shooting Ranges

How is Lead Shot Regulated Under reclamation. Therefore, only reputable RCRA? reclaimers should be utilized. • Lead from ranges destined for recycling may Lead shot is not considered a hazardous waste be temporarily stored on range property after subject to RCRA at the time it is discharged separation from soil if the lead is stored in from a firearm because it is used for its intended closed, sealed containers, the containers are purpose. As such, shooting lead shot (or stored in a secure location and routinely bullets) is not regulated nor is a RCRA permit inspected by range staff, and records of required to operate a shooting range. However, inspections are maintained. spent lead shot (or bullets), left in the environment, is subject to the broader definition • Sections 7002 and 7003 of the RCRA statute of solid waste written by Congress and used in allow EPA, states or citizens to use civil sections 7002 and 7003 of the RCRA statute. lawsuits, to compel cleanup of or other action for “solid waste” (e.g., spent lead shot) posing With reference to reclaiming and recycling lead actual or potential imminent and substantial shot, the following points should serve as endangerment. Such actions can be sought guidance in understanding RCRA and how it whether the range is in operation or closed, applies to your range. (A more detailed and is based solely on a determination that discussion of the underlying RCRA rules harm is being posed or may be posed by the applicable to lead shot removal at ranges is range to public health and/or the environment. included in Appendix D) Since the risk of lead migrating increases with time, making ranges that have not removed • Removal contractors or reclaimers should lead more likely candidates for government apply standard best management action or citizen lawsuits under RCRA Section practices, mentioned in this manual, to 7002 and 7003, ranges are advised to separate the lead from soil. The soil, if maintain a schedule of regular lead removal. then placed back on the range, is exempt from RCRA. However, if the soil is to be • With time, lead in soil can become less removed off-site, then it would require desirable to reclaimers and smelters, thereby testing to determine if it is a RCRA potentially reducing or eliminating financial hazardous waste. returns from lead removal. Moreover, such soil may be subject to more expensive • Lead, if recycled or reused, is considered treatment to separate the lead for recycling. a scrap metal and is, therefore, excluded from RCRA. • Lead removal will allow the range to: avoid contamination of the site and potential impacts • Collected lead shot and bullets are excluded to human health and the environment; reduce from RCRA regulation, and need not have a liability with regard to potential government manifest, nor does a range need to obtain a agency or citizen suit action; and, possibly, RCRA generator number (i.e., the range is benefit economically from the recycling of not a hazardous waste “generator”), provided lead. Additional guidance on reclaiming lead that the lead is recycled or re-used. The is provided in other parts of this manual. reclaimer does not need to be a RCRA transporter. However, it is recommended • Soil from berms and shotfall zones may be that ranges retain records of shipments of moved to another area of the range for such lead to the receiving facilities in order to reasons as addressing potential demonstrate that the lead was recycled. environmental impacts (e.g., runoff), altering Records should also be kept whenever the layout to address safety concerns or the lead is reused (as in reloading.) The allowing different types of shooting activities, range should be aware that it ultimately or adding or removing shooting positions. may be responsible for the lead sent for However, removal of lead prior to such

Chapter I - Page I-8 BMP for Lead at Outdoor Shooting Ranges

movement of soil is normal practice and highly advised because it extends the usable In the Remington Arms and the New York life of the materials and reduces the Athletic Club lawsuits, citizen groups argued that possibility of release of lead into the the defendants violated the CWA by discharging environment. If lead is not first removed, it pollutants from point sources into the Long will be further dispersed and will be more Island Sound without a NPDES permit. difficult to remove in future reclamation. Application of the CWA requires the violations to Written records of all such activity should be be ongoing. Consequently, the court in maintained indefinitely, as they will be Remington Arms dismissed the CWA charge necessary in subsequent construction or against the range because it had ceased range closure. operating before the lawsuit was filed.

• This RCRA summary applies to operating However, in the New York Athletic Club case, and non-operating ranges, and the use of the club was still in operation during the time of BMPs at operating ranges is highly litigation, but had switched to steel shot. EPA’s recommended. However, because of opinion on this case also addressed the CWA increased risk if lead is not actively managed, violation. EPA argued that certain trap/skeet such application may not preclude the need ranges can convey pollutants, via point sources, for remediation, as appropriate and/or as to water in violation of the CWA if a NPDES required by states’ regulations, when a range permit is not obtained. Although some shooting is permanently closed, on-site lead is organizations have disagreed with the EPA abandoned, or the land use changes. position, the United States District Court for the Introductory guidance for remediation can be Southern District of New York specifically found found at www.epa.gov/epaoswer/osw or that: www.epa.gov/superfund. Look under the sections “Cleanup” or “Resources,” or use • The mechanized target throwers, the the Search function. concrete shooting platforms, and the shooting range itself are considered point 1.2.2 - Clean Water Act sources as defined by the CWA;

The goal of the Clean Water Act (CWA) is to • Expended shot and target debris, including “restore and maintain the chemical, physical, non-toxic shot, such as steel shot, left in and biological integrity of the Nation’s waters.” water, are pollutants as defined by the CWA. The most common allegation against ranges by the EPA and citizen groups, is that they violate Although the New York district court’s decision in the CWA if they do not have permits that allow the New York Athletic Club case is not spent ammunition to be discharged into water. controlling in any other district, range owners The CWA prohibits “the discharge of any and operators of outdoor ranges that shoot over pollutant by any person” into the waters of the or into wetlands or other navigable waters of the United States without a National Pollution United States should be aware of it. Discharge and Elimination System (NPDES) Based on the court’s decision in the New York permit. There have been two court cases that Athletic Club case, any range whose shot, have applied the provisions of the CWA to bullets or target debris enter the “waters of the civilian shooting ranges. To understand how the United States” could be subject to permitting CWA can apply to shooting ranges, a summary requirements as well as governmental or citizen of the cases follows. Also see Table 1-1. suits. “Waters of the United States” or “navigable waters of the United States” are To understand the application of the CWA to waters of the United States, including territorial outdoor ranges, one must know the definitions of seas that include any body of water that has any key terms and how they have been applied to connection to, or impact on, interstate waters or shooting activities. See Table 1-1. commerce. The waters may include lakes,

Chapter I - Page I-9 BMP for Lead at Outdoor Shooting Ranges

Table 1-1: Application of Key Terms to Outdoor Ranges

Key Term Statutory Definition Application to New York Athletic Club

Discharge of a "any addition of any pollutant to Shooting into water (including wetlands) Pollutant navigable waters from any point constitutes a discharge. In the New York source" (emphasis added) Athletic Club, the range did not dispute that its shooting operations resulted in the 33 U.S.C. § 1362 (12) deposition of spent shot and other debris into the waters of the United States. Pdoint Source "any discernible, confined, an In New York Athletic Club, the court found discrete conveyance... from which that shooting ranges act to systematically pollutants are or may be channel pollutants into regulated waters discharged" into the Nation's and that mechanized target throwers waters. convey pollutants directly into water. Specifically, it stated, "A trap shooting 33 U.S.C. § 1362 (14) range... is an identifiable source from which spent shot and target fragments are conveyed into navigable waters of the United States." The court also determined that the concrete shooting platforms can be seen as separate "point sources" under the CWA or as one facet of the shooting range that systematically delivers pollutants (e.g. shot and wadding) into the water. P.ollutant "dredged spoil, solid waste,.. In New York Athletic Club, shot and target munitions... discharged into residue constitute a form of "solid waste" water" subject to regulation under the CWA as a "pollutant." Based on these 33 U.S.C. § 1362 (6) determinations, the court supported EPA's contention that the ranges were discharging pollutants from a point source without a permit, in violation of the CWA.

Chapter I - Page I-10 BMP for Lead at Outdoor Shooting Ranges ponds, rivers, streams, wetlands, or even guts 1.2.3 Comprehensive Environmental that are frequently dry, which may not be Response, Compensation, and obvious to range owners/operators. These Liability Act (CERCLA) ranges may be required to remediate contaminated sediments and soils, which could The Comprehensive Environmental Response, be both difficult and expensive, and to cease Compensation, and Liability Act (CERCLA), operations over waters and wetlands. It is imposes liability on past and present owners or essential that these ranges change the operators of properties where a release of a direction of shooting, to avoid shooting over hazardous substance into the environment or into wetlands or other navigable waters of exists. CERCLA is used to ensure that an the United States, and initiate lead removal owner/operator cleans a contaminated site or to and recycling activities, where feasible. seek reimbursement from past owners/operators or disposers (potentially responsible parties or In addition, these ranges can cause a PRPs) when a party, either the government or substantial impact on wildlife and wetlands, private party, has cleaned up the contamination. which range owners/operators may be required Under CERCLA, lead is considered a hazardous to restore under other federal laws (e.g., substance. CERCLA, discussed below). Lead shot entering a water body substantially increases EPA has the authority to order a PRP to clean up the potential risk of contaminating surface and a site or conduct the cleanup and recover its groundwater which, in turn, threatens human costs from the PRP under CERCLA. health and the environment. Finally, as New Responsible parties may be held liable for all York Athletic Club, Remington Arms and similar cleanup costs, which can be substantial. Under cases show, neighbors have the most leverage CERCLA, shooting ranges may be liable for when range activity affects wetlands and government costs incurred during the cleanup waterways. of ranges, natural resources damages, and health assessments and/or health effects For ranges located away from coastal areas or studies. The following two examples illustrate whose operating areas are situated wholly over how shooting ranges (including one operated by land, compliance with the CWA can be achieved the federal government) can be affected by by obtaining a NPDES permit for piped or 1 CERCLA. channeled runoff from the range into water . Southern Lakes Trap and Skeet Club Site, Shooting ranges impacting wetland areas may Lake Geneva, Wisconsin, et al. be subject to other regulations found in Section 404 of the CWA. This section is the principal In 1992, the US Fish and Wildlife Service federal regulatory program protecting the (USFWS) began an investigation to determine Nation’s remaining wetland resources. Any plan the cause of death of over 200 Canada geese. by range owners/operators to dredge and/or fill The geese died as a result of acute lead wetlands may require a permit and will come poisoning after ingesting lead shot, which under close scrutiny by federal, state and local research indicated came from the Southern governments and citizen groups. Owners and Lakes Trap and Skeet Club. The USFWS, in its operators must comply with the CWA for range role as Natural Resource Trustee, took action to design, redesign, construction, reclamation or recover the cost of damage to the natural remediation occurring in wetland areas. resources (i.e., migratory geese) under CERCLA. In addition, EPA pursued a separate action under the Agency’s CERCLA response authority. The club had leased the property from the property owners to operate a shooting range. Shortly after EPA sent out the notice of potential 1 The term “land” in this instance refers specifically to terrain recognized as “non-wetland” areas. liability to the current and former owners and

Chapter I - Page I-11 BMP for Lead at Outdoor Shooting Ranges operators of the club site, the club closed have adopted their own environmental laws, permanently. which are based on federal laws. Specifically, these states have laws and regulations that In 1994, EPA issued an Administrative Order on mirror the CWA and RCRA program laws. EPA- Consent (AOC) against one current and one approved state program laws must be as former owner of the property where the now stringent as the federal laws and may be more closed Southern Lakes Trap and Skeet Club was stringent. Activities at shooting ranges may also located. The AOC required the owners to be subject to local laws, ordinances and perform a site assessment, which included an regulations addressing issues such as noise, evaluation of the costs to restore the wetlands. zoning, traffic, wetlands and nuisance. Often, In 1998, EPA completed activities to clean up the citizens or neighbors of outdoor shooting ranges site and restore some of the natural resources can initiate noise nuisance claims against and wetlands. In a negotiated settlement, EPA range owners/operators. Because many states recovered $1 million of the cost of the cleanup. have passed legislation protecting ranges from noise nuisance lawsuits, these may turn into Walter L. Kamb v. United States Coast Guard, claims of environmental violations under the et al. laws discussed above due to the presence of lead and other products at ranges. In another CERCLA action, Mr. Kamb (court appointed property guardian) sued the U.S. 1.3 Benefits of Minimizing Coast Guard, California Highway Patrol, City of Fort Bragg, and the County of Mendocino (the Lead’s Environmental Impact defendants) for recovery of cleanup costs under CERCLA. Mr. Kamb had been appointed by the All ranges will benefit from proactively Mendocino County Superior Court to sell the implementing successful BMPs. Even if range property on behalf of the property owners. The activities currently do not cause adverse public property was formerly used by defendants as a health and environmental impacts, by developing rifle, pistol and trap range. Soil analysis and promoting active lead management indicated the presence of lead in the form of programs, ranges will benefit in the following leadshot, bullets, pellets, and dust. The court ways: found the defendants were “responsible parties” (liable for cleanup costs) under CERCLA. No • Through a sound lead management apportionment of liability was made and the final program, shooting sports enthusiasts can determination of each parties’ pro rata share of reduce the potential of lead exposure and the response cost was deferred. contamination to humans, animals and the environment. This case shows that range activity need not affect a water body to trigger CERCLA liability. • A lead management program will result in CERCLA is a powerful statutory authority that improved public relations for the range can greatly impact current and former range and the shooting sports. Ranges can owners/operators. The statute allows for promote and publicize their successful BMP recovery of damages to natural resources, the programs to improve their public image. cost of any health assessment studies and all Since many of the legal and governmental cleanup costs. Liability may extend to past actions begin with or are due to citizen owners and operators long after a range ceases groups, an active lead management program operation. may improve the public image of the range with these citizen groups. 1.2.4 Additional Laws and Regulations • The removal of spent lead from the range presents a clean, well maintained facility, Shooting ranges may also be subject to state which will increase customer satisfaction. and local laws and regulations. Many states

Chapter I - Page I-12 BMP for Lead at Outdoor Shooting Ranges

• Lead is a recyclable and finite resource and can be recovered from the active portion of ranges and sold to lead reclaimers. Frequently, reclaimers do not charge range owners/operators to recover lead from ranges, and owners and operators may receive a percentage of the profit from the sale of reclaimed lead. This factor drives recycling efforts at many ranges.

• By reducing or eliminating a potential source of lead migration in soil, surface water and groundwater, range owners/ operators may avoid costly and lengthy future remediation activities.

• Finally, implementing a BMP program for lead may eliminate or greatly reduce the risk of citizen lawsuits and the legal costs associated with these lawsuits. Through management and removal practices, lead may no longer represent a threat upon which citizen lawsuits are based.

Range owners/operators may question whether the benefits of a regular and timely BMP program outweigh the efforts of implementing and maintaining a program. The questions may arise especially for ranges at which shooting activities involve waterways, since national attention has focused on ranges located adjacent to water (e.g., Remington Arms and the New York Athletic Club). However, all outdoor ranges may be subject to legal actions under RCRA and CERCLA authority. All of the benefits for adopting best management practices are available and worthwhile for every range owner and operator.

The following sections provide information that will assist the range owner or operator in implementing a BMP program for recovery and recycling of lead shots and bullets.

Chapter I - Page I-13 This page intentionally left blank BMP for Lead at Outdoor Shooting Ranges 2.1 Physical Characteristics Chapter II: Range Characteristics & Physical characteristics of ranges, relative to Activities to Consider When lead management issues, are discussed below. Implementing Best Management Practices (BMP) Range Size

Shotgun range design and type affects the ease 2.0 Background of lead shot collection. Larger ranges typically tend to have lead shot that is dispersed over a Since each firing range site is unique, BMPs wider area, while smaller ranges tend to for lead must be selected to meet site- concentrate lead shot in a smaller area. specific conditions in order to achieve Reducing the area of the shotfall zone will maximum success. A range’s physical concentrate the shot within a smaller area, characteristics and the operational aspects (e.g., allowing for easier cleanup and reclamation. volume of shooting, shooting patterns and BMP techniques for reducing the shotfall zone at operating schedules) will effect which BMPs trap and skeet ranges, as well as sporting clay may apply and how they will be implemented. ranges, are discussed in Chapter III. Accordingly, whether designing a new outdoor range or operating an existing range, it is Soil Characteristics important that BMPs incorporate techniques appropriate for the range’s individual Spent lead bullets and shot are most often characteristics. deposited directly on and into soil during shooting. When lead is exposed to air and water, Section 2.1 of this chapter identifies the physical it may oxidize and form one of several characteristics that must be considered when compounds. The specific compounds created, evaluating your range. A summary of common and their rate of migration, are greatly influenced physical characteristics at ranges is also by soil characteristics, such as pH and soil presented in Table 2-1. These factors include: types. Knowing the soil characteristics of an existing range site is a key component to • Range Size (primarily for shotgun ranges) developing an effective lead management • Soil Characteristics plan. • Topography/Runoff Direction • Annual Precipitation Soil pH • Ground and Surface Water • Vegetation 1234567891011121314 • Accessibility

Section 2.2 discusses the operational aspects Acidic Neutral Alkaline that must be considered. These factors include: = Ideal Soil Range

• Lead Volume Figure 2-1 – pH scale • Size of Shot/Bullets • Operating Schedule Soil acidity is measured as pH on a scale • Shooting Direction and Pattern (illustrated as Figure 2-1) between 1 (most • Range Life Expectancy acidic) and 14 (most alkaline, or basic), where 7 is termed neutral. Ideal soil pH for shooting In addition, Section 2.3 discusses issues that ranges is 6.5 to 8.5.1 are specific to implementing BMPs when 1 National Shooting Sports Foundation, “Environmental Aspects planning a new range. of Construction and Management of Outdoor Shooting Ranges,” June 1997.

Chapter II - Page II-1 BMP for Lead at Outdoor Shooting Ranges

Lead reacts more readily and may become more arid regions. This is especially true of outdoor mobile under acidic (pH < 6) or higher alkaline ranges using “Steel Bullet Traps.” (pH>8) conditions. This means that spent lead shot left in or on such soils may eventually break Steel bullet traps build up a layer of lead residue; down and contaminate underlying soil. In these particles are extremely small and more moderately alkaline soils (pH 7 - 8.5), the lead easily transported by rain/water. Also, the precipitates out of solution and binds to the soil. smaller the particle, the quicker it will degrade. A This “binding” effect prevents the lead from bullet trap needs to have a means to collect migrating to the subsurface. In general, soils in contact water, or be covered to prevent water the eastern part of the United States tend to be from reaching it, and to minimize releases and acidic, whereas western soils tend to be more degradation. alkaline. Topography/Runoff Directions Soil Physical Characteristics The topography of your range impacts both the The migration rate of specific lead compounds is ease of lead reclamation and the mobility of the affected by the physical characteristics of soil. lead. For example, lead reclamation is more For example, dense soils, consisting of heavy successful at ranges where the shotfall zone is clays, will prevent the lead compound from relatively flat, since many lead reclamation moving quickly through the subsurface. Any companies use heavy machinery that cannot “free” lead ions become attached to clay operate on slopes or steep hills. particles, with this bond helping to prevent migration. However, with denser soils, the Another important characteristic is the direction amount of surface runoff increases. in which your range topography slopes. During and after periods of rain, stormwater runoff may Although clay soils inhibit migration, lead wash lead particles or lead compounds off the reclamation by contemporary removal range. If there are surface water bodies such as machinery tends to be more difficult in clayey lakes, rivers, or wetlands downgradient, the conditions. Clayey soils tend to clog the potential for lead to adversely affect the screens and “bind” with shot and bullets. This surrounding environment is even greater. situation may require additional traditional Therefore, it is important to identify and control screening, or perhaps screening using water to the direction of surface water runoff at your enhance separation. range. BMPs for modifying and controlling runoff are described in detail in Chapter III. In contrast, sandy soils or gravel may not impede migration because the open pores of Groundwater these soils allow lead compounds to percolate quickly. Fortunately, lead reclamation activities Groundwater depth should be considered are more easily conducted in sandy soils. With when developing a lead management plan this in mind, ranges located in sandy soils since the closer the groundwater is to the should remove lead more frequently. surface, the greater the potential for dissolved lead to reach it. Annual Precipitation Vegetation One of the most important factors that influences lead degradation (i.e., chemical reactions) and Vegetative ground covers can impact the migration is precipitation. Water, most often in mobility of lead and lead compounds. the form of rain, provides the means by which Vegetation absorbs rainwater, thereby reducing lead is transported. In general, ranges located in 2 areas with high annual/seasonal rainfall have a 2 Heavy annual rainfall is anything in excess of the average annual higher risk of lead migration than those located in rainfall, which for the northeast United States (e.g. New York, New Jersey) is between 40 and 45 inches.

Chapter II - Page II-2 BMP for Lead at Outdoor Shooting Ranges

Table 2-1 – Common Physical Characteristics at Ranges – Potential Risks and Benefits Associated with Range Operations

Physical Potential Risk to Environment Potential Benefits in Preventing/Managing Characteristics Contamination

Cnlay, acidic soils Acidic soils contribute to lead dissolutio May impede percolation of water through -- increasing the potential for lead contaminated soil contamination Binds "free" lead ions -- may increase run-off May benefit growth of vegetative covers Difficult to reclaim lead via sifting/raking

Sandy, alkaline Contaminated rainwater can easily Alkaline soils may inhibit lead dissolution soils percolate through soil and groundwater Easier to reclaim lead via sifting/raking Extremely alkaline soil will not support vegetation

Snandy, acidic soils Acidic soils contribute to lead dissolutio Easier to reclaim lead via sifting/raking -- increasing the potential for lead contamination

Contaminated rainwater percolates quickly through sandy soils

Steep Rolling May promote off-site drainage or None Terrain drainage to on-site surface water bodies

Can impede reclamation of expended shot via raking

F,lat Terrain Rainwater may "pond" in areas Expended shot easily recovered promoting lead dissolution and contamination Off-site drainage minimized

Wooded areas May impede lead reclamation activities None making equipment difficult to maneuver

May provide habitat for wildlife - increasing exposure to lead

On-site or VERY high potential for contamination None contiguous surface when shot fall zone is located over or water bodies adjacent to water; increased wildlife exposure; increased lead dissolution. This is NOT an option for successful range location and may be more likely subject to litigation and/or governmental action if lead is deposited into water bodies

Vegetation Lead may be absorbed into grasses, Ground covers slow down surface water run- other wildlife food sources on and run-off

Some vegetation can extract lead ions from the soils

Chapter II - Page II-3 BMP for Lead at Outdoor Shooting Ranges the time that the lead is in contact with water. Shooting Direction and Patterns Vegetation also slows down surface water runoff, preventing the lead from migrating off-site. Shooting directions and patterns are However, excessively wooded areas (such as important to consider when determining the those often used for sporting clay ranges) inhibit effectiveness of bullet containment devices. lead reclamation by making the soils For example, many bullet traps are effective in inaccessible to some large, lead-removal containing bullets fired from specific directions. machinery. Understanding the type, It is vital that you utilize bullet containment concentration and variety of vegetation on your devices that match your range’s specific range is necessary for developing your lead shooting patterns and manufacturers management program and implementing BMPs specifications. Understanding the shooting at your range. direction and patterns will also help to correctly identify the shotfall zone at trap and skeet Accessibility ranges.

Accessibility to shotfall zones and backstops Shooting into Water Bodies is extremely important for lead reclamation activities. A range that is not accessible to Shooting into water bodies or wetlands reclamation equipment will have difficulty should not occur. Besides the environmental implementing lead reclamation practices. impacts discussed previously, the introduction of lead to surface water bodies will likely cause a 2.2 Operational Aspects range to be susceptible to litigation and/or governmental action. Shooting into water bodies Operating practices can have a great affect on or wetlands is NOT an option for ranges that the volume and dispersion of lead at your range. want to survive in the future.

Lead Volume Range Life Expectancy and Closure

Keeping records of the number of rounds The life span of your range may be impacted by fired over time at your range is important. many factors, including financial and The number of rounds fired provides a realistic environmental issues, noise, and encroachment estimate of the quantity of lead available for on residential areas. If your range is slated for reclamation. This information helps to determine closure, contact your local state or EPA when reclamation is necessary in order to representatives for guidance. prevent accumulation of excess amounts of lead, thereby decreasing the potential for the 2.3 Planning a New Range lead to migrate off-site. As discussed in the previous sections, site Size of Shot/Bullets characteristics and operational aspects affect lead migration, degradation and reclamation Knowledge of the size shot/bullets used on activities at ranges. If you are planning on your range may be helpful. Lead reclamation opening a new range, you should select and/ companies generally use physical screening or design a site in consideration of the techniques to separate lead shot and bullets factors discussed in this manual. This will from soil. These screens come in a variety of allow you to minimize the potential of lead sizes. Knowing what size shot/bullets have impacting your site or adjacent properties. A been used at your range will allow the reclaimer new range owner has the advantage of being to maximize the yield of lead shot/bullets at your able to design a successful lead management range. program in full consideration of the site characteristics and recommended BMPs. This advanced understanding of operational aspects

Chapter II - Page II-4 BMP for Lead at Outdoor Shooting Ranges and requirements will allow you to minimize the potential for lead migration prior to opening.

The most important site selection criteria to consider when selecting a new range location include: topography; surface water flow patterns; and depth to groundwater. If possible, ranges should be developed on flat terrain, as it facilitates reclamation and reduces the chance of off-site migration due to surface water runoff as compared with highly sloped terrain. When considering a prospective location for a range, ask yourself: What is the direction of surface water runoff? Does the site drain to surface water (e.g., streams, rivers) on-site? Off-site? Can the range design be modified to minimize potential runoff? Is reclaimation equipment accessible to the area to clean the range?

By selecting an appropriate location and designing a lead management program in consideration of site characteristics, new shooting ranges can be developed to minimize the potential for lead contamination. Other important site characteristics can be modified. For example, a new shotgun range can be designed to concentrate the shotfall area, vegetation can be added or altered, and the most advantageous shooting direction can be selected. These modifications are BMPs, and are discussed in further detail in Chapter III.

Chapter II - Page II-5 This page intentionally left blank BMP for Lead at Outdoor Shooting Ranges

practices that should be followed between lead Chapter III: reclamation events. Best Management Practices (BMPs) For Outdoor Ranges It is important to note that the cost and complexity of these BMPs vary significantly. It is your range’s individual characteristics that will determine which BMPs should be implemented. The specific BMPs are described 3.0 Background more fully below.

To operate an outdoor range that is 3.1 Bullet and Shot Containment environmentally protective requires implementing an integrated lead management Techniques (Step 1) program, which incorporates a variety of appropriate BMPs. These BMPs create a four 3.1.1 Bullet Containment step approach to lead management: Knowing where spent lead is allows the Step 1 - Control and contain lead bullets appropriate BMP to be used. The single and bullet fragments most effective BMP for managing lead in Step 2 - Prevent migration of lead to the these areas is by bullet containment. subsurface and surrounding surface Owners/operators should employ a water bodies containment system that allows for the Step 3 - Remove the lead from the range maximum containment of lead on-site. The and recycle containment systems mentioned in this section Step 4 - Documenting activities and are for reference only. Each containment design keeping records for a range is site specific. Each owner/operator must look at the various factors in determining An effective lead management program requires which containment system is best for his or her implementing and evaluating BMPs from each range. Some factors include: overhead, cost of of the four steps identified above and illustrated installation, maintenance (e.g., creation of lead as Figure 3-1. The BMPs discussed in Sections dust from steel containment systems). Range 3.1 and 3.2 should not be considered owner/operators should consult with various alternatives to lead reclamation, but rather contractors to determine which containment system is best for their range.

S2tep 1 S3tep S4tep Step

Control and Contain Prevent Migration Remove and Recycle Document Activities (Section 3.1) (Section 3.2) (Section 3.3) and Record Keeping (Section 3.4)

-- Bullet containment -- Monitor and adjust -- Hand raking and -- Document number of soil pH (e.g., lime sifting rounds fired/shot size ~ Earthen Backstops spreading) -- Screening -- Document BMP(s) ~ Sand Traps -- Immobilize lead e.g., used at ranges to phosphate spreading) -- Vacuuming control migration ~ Steel Traps -- Control runoff -- Soil washing -- Document date and ~ Lamella or Rubber provider of services Granule Traps ~ Plant vegetation -- Working with a and utilize organic reclaimer -- Keep records for the ~ Shock Absorbing ground cover life of the range and Concrete -- Recycling at east 10 years after ~ Implement closing -- Shot Containment engineered runoff controls -- Evaluate the ~ Reduce shotfall effectiveness of zones BMPs used

Figure 3-1 – 4 Steps to Build a Successful Lead Management Program Utilizing a Variety of BMPs Chapter III - Page III-1 BMP for Lead at Outdoor Shooting Ranges

This section discusses BMPs for controlling backstop (earthen material, i.e., sand, soil, etc., spent lead bullets and fragments in a which is located directly behind the targets). “controlled” and well-defined area behind the The earthen backstop is generally between 15 target area. Containing bullets and bullet and 20 feet high with a recommended slope as fragments is critical to successfully managing steep as possible1. In many instances, lead. backstops may be naturally occurring hillsides. When using an earthen berm or backstop, There are a variety of containment device ensure that the uppermost layer (to a depth of options available that serve as BMPs to control one to two feet) exposed to the shooting activity lead. The principle behind all of them is trapping is free of large rocks and other debris. These and containing the actual bullet. They include: materials tend to increase ricochet and bullet fragmentation, which will, in turn, make lead Earthen Berms and Backstops reclamation activities more difficult, not to Sand Traps mention possible safety issues. Steel Traps Removal of lead from earthen backstops may Lamella or Rubber Granule Traps require lengthy reclamation (see Section 3.3) of Shock Absorbing Concrete the soil to remove the lead. Continued use of the backstop without removing the lead may For each type of trap, design variations have result in increased ricochet of bullets and been developed to fit the specific needs of an fragments. In addition, the backstop may lose individual range. Below are discussions of each its slope integrity because of “impact pockets” general category of trap. Some bullet that develop. Once the lead has been removed containment devices are so comprehensive that from the earthen backstop, the soil can be they virtually eliminate lead’s contact with the placed back on the range and used again. environment. Adding lime and phosphate during the rebuilding process is recommended as appropriate (see However, it is important to discuss all types of Section 3.2). However, other bullet containment bullet containment devices because they are techniques, including those listed below, should part of comprehensive BMPs for managing lead be considered prior to reestablishing an earthen at rifle and pistol ranges. backstop.

EPA does not endorse any bullet containment Sand Traps design as being “better” than another. Different containment designs attempt to eliminate lead’s A variation of the earthen backstop is the sand contact with the environment, however, trap. Sand traps range from those that are additional BMPs may be required for lead simply mounds of sand or soil located directly management. behind the bullet targets, which serve as backstops to a sand trap that employs a system EPA recommends that you discuss your designed to contain, collect and control lead and range’s bullet containment needs with a contact water. This sand trap uses a grade of variety of vendors before deciding what type sand that is ballistically acceptable. Regular of containment device to use. This manual maintenance must be performed to remove does identify the possible advantages and larger particles (bullets) from the impact area. disadvantages associated with each These traps are placed so that bullets fired containment device in Table 3-1, at the back of across the range pass through the targets and this chapter. become embedded in the sand. These traps are typically 15 to 20 feet high with a slope as Earthen Berms and Backstops

Perhaps the most common bullet containment 1. National Rifle Association, “The NRA Range Source Book: A Guide to Planning and Construction,” June system at rifle and pistol ranges is the earthen 1998 Chapter III - Page III-2 BMP for Lead at Outdoor Shooting Ranges steep as possible. The most important design trap is full, or on a more frequent basis, the spent criterion for these traps is that the uppermost lead can easily be reclaimed for recycling. layer (to a depth of 1 to 2 feet) be free of large rocks and other debris to reduce ricochet and With some steel traps, expended lead bullets bullet fragmentation, and to facilitate reclamation may not come in direct contact with soils, efforts. There may also be an impermeable thereby possibly minimizing lead’s contact with layer (e.g., clay or liner) under the sand to the environment. Consequently, the need for prevent lead from contacting the soil underlaying other BMPs (e.g., lime spreading, and/or the trap. engineering controls), such as those required at ranges with unlined earthen backstops or Sand traps come in various designs and levels unlined sand traps, may be avoided if this trap of complexity. The sand trap may be ballistic design is selected for the range’s bullet grade sand contained in a high backstop, or a containment device. In addition, bullet removal more complex “Pit and Plate” system. The Pit is somewhat easier than from a sand trap, and and Plate system uses an angled, steel may only require emptying the bucket or tray deflection plate cover that helps to direct bullets containing the bullets and/or bullet fragments. and bullet fragments to the top layer of sand However, an increase of lead dust and only. Some of the more sophisticated sand fragmented lead may be an additional traps incorporate lead recovery devices. environmental concern. Therefore, However, the Pit and Plate may increase the understanding the amount of lead dust and surface-to-mass ratio of the bullet splatter and, fragments is important to a successful lead therefore, may increase environmental risk of management program. Also, some steel trap lead migration. designs are not intended for shooting at different angles, therefore limiting the shooter to shooting Regardless of the type of sand trap that is used, straight on (no action shooting). the traps become saturated with bullets/bullet fragments. Once this happens, the sand must As with sand traps, steel traps vary in design be sifted (see Section 3.3) to remove the bullets. and complexity. For example, the Escalator The recovered bullets can then be sold to a lead Trap has an upward sloping deflection plate that recycler (this is discussed in more detail later in directs bullets into a spiral containment area at the chapter). After sifting, the sand can be the top. The Vertical Swirl Trap is a modular, returned to the trap. Continued use of the trap, free standing trap with four steel plates that without removing the lead, may result in an funnel the bullets into a vertical aperture in increased risk of ricocheting off the backstop which they spin, decelerate, and become and thus creating an increased safety hazard. trapped in a bullet collection container. The Wet Furthermore, the sand trap will become unstable Passive Bullet Trap is equipped with steel over time. Sand traps may be located over an deflection plates that slope both upward and impermeable liner, to prevent lead from downward. The upwardly sloped deflection contacting soil underlying the trap. This will plate is covered with an oil/water mixture to help provide additional protection to soil and reduce the occurrence of ricochet and bullet groundwater. fragmentation. The bullet follows its own path in the round deceleration chamber for bullet Steel Traps recycling.

Steel traps are located directly behind the Lamella and Rubber Granule Traps targets so that expended bullets, along with bullet particles, are directed into some form of The Lamella Trap uses tightly-hanging, vertical deceleration chamber. Once inside the strips of rubber with a steel backing to stop chamber, the bullets decelerate until the bullets/ bullets. This trap is located directly behind the bullet particles fall into collection trays at the targets and, in many cases, the targets may bottom of the deceleration chamber. When the actually be mounted to the trap. Lead removal

Chapter III - Page III-3 BMP for Lead at Outdoor Shooting Ranges

requires mining the bullets from the rubber. The 3.1.2 Shot Containment Rubber Granule Trap uses shredded rubber granules, housed between a solid rubber front Reducing the Shotfall Zone and a steel backing, to stop bullets once they pass through the target. For both traps, the Unlike rifle and pistol ranges, the area impacted bullets remain intact, thus eliminating lead dust by lead shot fired at trap, skeet and sporting and preventing lead and jacket back splatter. clays ranges is spread out and remains primarily Depending on the design of the rubber trap, the on the surface. Knowing where spent lead is bullet either remains embedded in the rubber allows the appropriate BMP to be used. The strip or falls to the bottom of the trap, from which single most effective BMP for managing lead the bullets are removed for recycling. in these areas is reducing shotfall zones.

These traps, when properly installed, are Concentrating the lead shot in a smaller area by intended to increase safety by decreasing the modifying the shooting direction facilitates lead occurrence of back splatter and eliminating the management by providing a smaller and more introduction of the lead dust into the air and dense area of lead to both manage in-place and ground. However, there are several concerns reclaim, thereby making the management and over their use, since they may: reclamation process simpler and more effective.

require additional maintenance; Sporting Clays Courses in some cases, present a fire threat under extremely high volume use (due to heat from Technologies have been developed to assist in friction created upon bullet impact); reducing the range size of trap and skeet, and not withstand weather elements over the sporting clays facilities. The National Sporting long term; and Clays Association (NSCA) supports and cause the rubber particles to melt to the lead promotes the Five-Stand Sporting Clays bullets, making reclamation more difficult. compact course design for shooting sporting clay targets, invented by Raymond Forman of With the availability of fire-resistant rubber and Clay-Sport International, Cochrane, Alberta, gels (see Appendix A), these issues are becom- Canada. The targets are directed over a smaller ing less of a concern than in earlier models. area than in English Style Sporting Clays (conventional sporting clays). It was originally designed to be overlaid on a conventional trap or Shock Absorbing Concrete skeet field and to be an alternative to earlier designs, which cover a much larger area. In addition to the bullet containment devices Another design, known as the National Rifle discussed above, there are new designs and Association (NRA) Clays, is a portable target innovations continually being developed. One of throwing unit which concentrates 15 rail- these innovative bullet containment devices is mounted machines on a two-story flatbed trailer. Shock Absorbing Concrete (SACON). SACON, The NRA has also developed “compact which has been used as a bullet containment sporting,” which is specifically for sporting clay device since the 1980s and was extensively facilities. This practice alters the angle that the field tested by the military, has become target is thrown to concentrate the shotfall zone. commercially available in the past several years as a backstop material for small arms ranges. Skeet Fields For conventional rifle and pistol ranges, SACON may provide a means to easily reclaim lead. The typical single skeet field has a shotfall zone Additionally, crushed, lead-free SACON can be that is fan-shaped. For skeet fields with multiple recycled (recasted) after bullet fragments have stands side-by-side, the shotfall zones would been removed by adding it to other concrete overlap creating a shotfall zone that has a mixtures for use as sidewalks, curbs, etc. concentration of shot near the center of the fan.

Chapter III - Page III-4 BMP for Lead at Outdoor Shooting Ranges

Trap Fields 3.2.1 Monitoring and Adjusting Soil pH and Binding Lead One way to reduce the shotfall zone at trap fields is to build the fields at an angle to one Lime Addition another. This will make the shape of the shooting dispersal pattern smaller and more The BMP for monitoring and adjusting soil pH is concentrated. However, if you do decide to an important range program that can effect lead choose this option, be aware of safety issues migration. Of particular concern are soils with when designing the overlapping shotfall zones. low pH values (i.e., acidic conditions), because lead mobility increases in acidic conditions since For a range with only one trap field, one way to the acid of the soils contributes to the lead break minimize the shotfall zone is to keep trap down. The ideal soil pH value for shooting machines set in as few holes as possible (e.g., ranges is between 6.5 and 8.5. This BMP is the number two or three hole setting). This important because many soils in the eastern reduces the area of lead concentration by United States have pH values lower than 6.2 limiting the angles for pigeon throwing, and therefore the area for lead shot fall. However, To determine the pH of your soil, purchase a pH when two or more trap fields are positioned side meter at a lawn and garden center. The pH by side, the shotfall zone will be continuous meters are relatively inexpensive but valuable regardless of the “hole” setting. tools in the management of lead at your range. If the soil pH is determined to be below 6, the Shot Curtains pH should be raised by spreading lime. It is recommended that the pH be checked Another method to consider for concentrating annually. lead shot is the use of a shot curtain. This device is emerging as a potentially effective tool One way to control lead migration is by to keep lead shot out of selected areas of the spreading lime around the earthen backstops, range and, thereby, reduce the size of the sand traps, trap and skeet shotfall zones, shotfall zone and corresponding cost of sporting clays courses and any other areas reclamation. Different designs and material have where the bullets/shots or lead fragments/dust been utilized in shot curtains and a number are accumulate. For example, lead mobilized in in operation. The effectiveness of shot curtains rainwater from the lead that spatters in front of is site specific and their long term viability and backstops after bullet impacts can be effectively expense have yet to be fully determined. controlled by extending a limestone sand layer out about 15 feet in front of the backstop. Likewise, spreading lime over the shotfall zone 3.2 BMPs to Prevent Lead will help to raise the pH of the very top soil layer Migration (Step 2) to a pH closer to ideal levels and reduce the migration potential of lead. This is an easy, low This section discusses BMPs for preventing lead cost method. Spreading lime neutralizes the migration. These BMPs include: acidic soils, thus minimizing the potential for the lead to degrade. Lime can be easily spread by Monitoring and adjusting soil pH using a lawn fertilizer drop spreader available at Immobilizing lead any lawn and garden center. Controlling runoff Smaller forms of limestone (powdered, These BMPs are important for all outdoor pelletized, and granular) are better suited ranges.

2 National Shooting Sports Foundation, “Environ- mental Aspects of Construction and Management of Outdoor Shooting Ranges,” June 1997

Chapter III - Page III-5 BMP for Lead at Outdoor Shooting Ranges because they dissolve and enter the soil more less accessible to conventional lead removal quickly then larger forms. However, the smaller equipment. These types of ranges also tend to forms of lime must be replenished more often. have more detritus (e.g., leaves, twigs, etc.) on Conversely, limestone rock dissolves more the ground, which can increase soil acidity as slowly but does not need to be replenished as they decompose. In these areas, semiannual often. The larger rock form is better suited for monitoring of the soil pH levels is drainage ditches, where it can decrease lead suggested. mobility by raising the pH of the storm water runoff. Spreading bags of 50 pounds (at ranges with sandy soils) or 100 pounds (at ranges with Another way to control lead migration in earthen clayey soils) per 1,000 square feet of range will backstops is to break the capillarity within the raise the pH approximately one pH unit for a base of the backstop. Most porosity in the soil period of between one and four years, material used in backstop is of capillary size, respectively. The market price of lime in either and, as a result, water is pulled upward into a the granular or pelletized form commonly ranges capillary fringe within the base of the backstop. from approximately $2.00 to $4.00 per fifty pound The height to which the water will rise in an bag. earthen backstop depends on the soil material in the backstop. Water will rise more then 6 feet in Table 3-2 provides information for raising pH clay, 3.3 feet in silt, 1.3 feet in fine sand, 5 levels of clay soils in temperate climates (i.e., inches in coarse sand, and only 2 inches in Mid-Atlantic/Northeast). Additional information gravel. on the amount of lime to apply may also be found on the bags of the purchased lime and/or Because of capillarity, the spent bullets may be from the local lawn and garden center. It should in contact with acidic rainwater for a longer be noted that if the soil pH is below 4.5, the period of time, hence more lead is dissolved. addition of lime may only raise the soil pH to Breaking the capillarity by adding a layer of approximately 5. In this situation, other BMPs limestone or gravel to the base of the backstop should be used as well. If the soil pH is above should reduce the rate of deterioration of spent the ideal range upper value (8.5), do not add bullets, the erosion of the backstop, and the lime. Adding lime to a soil of this pH could result amount of lead going into solution in the water in in mobilization of the lead. Lime spreading may the backstop. Also, any lead dissolved should be done at anytime during the year, except precipitate out of solution as the acids are when the ground is frozen. neutralized and the pH raised from the water passing through and reacting with the limestone. Additionally, it is important to remember to monitor the soil pH annually, as the Lime spreading is an especially important effectiveness of the lime decreases over time. method for implementing this BMP at sporting Additional routine applications will be necessary clays ranges where heavily wooded areas are throughout the life span of most ranges.

Table 3-2 – Calculating Weight of Lime to Increase Soil pH Values* Current pH

4.0 4.3 4.5 4.8 5.0 5.5 6.0 6.5

Desired 54.0-6.0 111853--- pH 6.5-8.5 ---27 01117-

* Lime requirements stated as pounds of lime/100 square foot of problem area for clay soils in temperate climates (i.e., Mid-Atlantic/Northeast US). Chapter III - Page III-6 BMP for Lead at Outdoor Shooting Ranges

Phosphate Addition Other Ways to Bind Lead

In addition to lime spreading, another way to Although it may be possible to minimize lead’s control lead migration is phosphate spreading. mobility by spreading fertilizers that contain This method is recommended where lead is phosphate at impacted areas of the range, a widely dispersed in range soils, a range is more comprehensive procedure for immobilizing closing, or there is a high potential for vertical leachable lead in soils, by using pure phosphate lead transport to groundwater (e.g., low soil pH, in rock form or a ground phosphate rock [Triple shallow water table). Under these Super Phosphate (TSP)], was developed and circumstances, range soils may benefit from patented by the U.S. EPA/Ohio State University phosphate treatment. Unlike lime spreading, the Research Foundation and RHEOX, Inc. This main purpose of phosphate spreading is not to procedure used a three step approach to adjust soil pH but to bind the lead particles. This minimize lead’s mobility. The first step was to process also decreases the potential amount of identify the boundaries of the area of the range to lead that can migrate off-site or into the be treated. This included not only determining subsurface. Phosphate spreading can be done the length and width of the range area, but also either separately or in conjunction with lime the depth of lead within the area. spreading. Generally, 15 to 20 pounds of phosphate per 1,000 square feet will effectively Depth was determined by taking sample cores control the lead. of the area, which also identified “hot spots” where lead accumulation was greatest. Once Phosphate spreading is especially the area was identified, the second step was to recommended for sporting clays ranges and treat the area with TSP. Pure phosphate rock those parts of ranges not easily accessible by was used rather then fertilizers, as this reclamation equipment. Phosphate spreading phosphate is insoluble in water and will not should be repeated frequently during the range’s cause an increase in phosphate runoff. lifetime. See pilot testing under “Other Ways to Bind Lead” below for proper frequency for In this step, pilot testing was conducted. Here, replacing phosphate. various amounts (in increasing percentages by weight) of TSP were added to the affected soil You can purchase phosphate either in its pure areas, then the area was tested according to an form, as phosphate rock, or as lawn fertilizer. EPA test method that identified the amount of The average lawn fertilizer costs approximately leachable lead in a given soil sample. This test $7.00 per 40 pound bag. If you purchase lawn is called the Toxicity Characteristic Leaching fertilizer, remember to check the bag for the Procedure, or TCLP. Separate TCLP testing of actual percentage of phosphate. Most fertilizers the range’s hot spots was conducted. contain 25% phosphate, so that if you purchase a 40 pound bag of fertilizer that contains 25% Upon completion of the pilot testing, which phosphate (i.e., 10 pounds of phosphate) you determined the amount of TSP needed at the will need to spread 80 pounds of fertilizer per range, the third step was to begin actual 1,000 square feet of the backstop. A typical treatment of the range. Where the depth of the fertilizer drop spreader can be used for lead accumulation was shallow (less than two distributing the phosphate. Like lime, phosphate feet), then standard yard equipment, such as should not be spread when the ground is frozen. tillers, seed/fertilizer spreaders, and plows were In addition, it is not advised to use phosphate used to mix TSP with the affected soil. Where near water bodies since it contributes to algal the affected area’s lead accumulation was blooms. Rock phosphate is a better choice if deeper than two feet, an auger was required to water is nearby. mix the TSP with the affected soil. Random testing of the range ensured the effectiveness of the treatment level.

Chapter III - Page III-7 BMP for Lead at Outdoor Shooting Ranges

3.2.2 Controlling Runoff of backstops, which can be removed prior to reclamation and replanted thereafter; The BMPs for controlling soil erosion and Avoid vegetation that attracts birds and other surface water runoff are important to preventing wildlife to prevent potential ingestion of lead lead from migrating off-site. There are two by wildlife; and factors that influence the amount of lead Use grass to direct surface water drainage transported off-site by surface water runoff: the away from the target area (e.g., planting amount of lead fragments left on the range and them at the top of the backstop or sand trap). the velocity of the runoff. This will minimize the water’s contact with lead bullet fragments, minimizing the The velocity of the water can successfully be potential for lead migration. controlled at outdoor ranges by: (1) using vegetative, organic, removable and/or Grass is not impermeable; however, it does slow permanent ground covers; and (2) implementing down the rate of flow and reduce the amount of engineered controls which slow down surface lead entering the soil via rainwater. Remember, water runoff and prevent or minimize the grass requires periodic maintenance (i.e., chances of lead migrating off-site. Bear in mind mowing) to maintain its effectiveness as well as that safety considerations and potential for aesthetic reasons. ricochets need to be considered when implementing any engineered controls. Mulches and Compost

Vegetative Ground Cover Mulches and composts can reduce the amount of water that comes in contact with the lead Planting vegetative ground cover (such as fragments. In addition, mulches and compost grass) is an important and easy erosion control contain hermic acid, which is a natural lead method. Vegetation provides several benefits chelating agent that actually sorbs lead out of by minimizing the amount of lead that will run off solution and reduces its mobility. At a minimum, the land surface during heavy rainfall. It is the material should be two inches thick. These important to use a mixture of grass seeds to materials can be spread over any impacted area ensure that the cover will last into the future (i.e., and/or low lying areas where runoff and lead annual rye grass lasts one year and dies and may accumulate. Like vegetative covers, perennial rye grass lasts three to four years, organic surface covers are not impermeable. In then dies off). Fescue grasses form useful mats addition, the organic material needs periodic that are effective in controlling erosion. replacement to maintain effectiveness and aesthetic integrity. Furthermore, these materials Ground cover absorbs rainwater, which reduces should be removed prior to any lead removal the amount of water the lead is in contact with, event, as they may impede sifting or screening. as well as the time that the lead is in contact Note that these materials tend to be acidic with the water. Furthermore, the ground cover (especially during decomposition), so, if low will divert and slow down surface water runoff, pH is a concern at your range, this option thus helping to prevent lead from migrating off- may not be appropriate. Again, however, site. lime may be used to control pH (see Section 3.1.1) Grasses yield the greatest benefit at rifle and pistol ranges where the bullet impact areas are Surface Covers sloped, and water runoff and soil erosion may be more likely. Specific recommendations are Removable Surface Covers to: Removable surface covers may be effective at Utilize quick growing turf grass (such as outdoor trap and skeet ranges. In this case, fescue and rye grass) for the grass covering impermeable materials (e.g., plastic liners) are

Chapter III - Page III-8 BMP for Lead at Outdoor Shooting Ranges placed over the shotfall zone during non-use Examples of “hard” controls include: periods. This provides the range with two benefits during periods of rainfall: (1) the shotfall Filter beds zone is protected from erosion; and (2) the spent Containment Traps and Detention Ponds lead shot is contained in the shotfall zone and Dams and Dikes does not come in contact with rainwater. Ground Contouring. Designing and implementing these “hard” Permanent Surface Covers engineering controls may require the assistance of a licensed professional civil engineer. They For outdoor rifle and pistol ranges, impact are included in this manual to offer the reader a backstops and target areas can also be covered general understanding of these BMP options. with roofed covers or other permanent covers to However, this manual does not offer specific prevent rainwater from contacting berms. instructions for construction and operation of However, this method may be less desirable these controls. For information about designing because of the cost to install the roof, which and implementing any of these controls, or must be carefully designed to avoid safety assistance with other range design questions, issues with ricochets, etc. contact a licensed professional civil engineer having applicable experience or the NRA Range For shotgun and other ranges, synthetic liners Department, at (800) 672-3888, ext. 1417. The TM (e.g., asphalt, Astroturf , rubber, other synthetic National Sports Shooting Foundation (NSSF) liners) can also be used beneath the shotfall may be contacted at (203) 426-1320 for specific zone to effectively prevent rainwater or runoff references regarding the use and design of from filtering through lead and lead these controls. contaminated soil. Synthetic liners will generate increased runoff, which must be managed, Filter Beds however. No single type of liner is suitable for all situations based on site characteristics. Filter beds are engineering controls built into an Therefore, liners must be chosen on a site- outdoor range to collect and filter surface water specific basis, bearing in mind the site’s unique runoff from the target range. The collected characteristics, such as soil type, pH level, runoff water is routed to a filtering system, which rainfall intensity, organic content of soil, and screens out larger lead particles, raises the pH surface water drainage patterns. of the water (thus reducing the potential for further lead dissolution), and drains the water Engineered Runoff Controls from the range area. This technique may not completely prevent lead from entering the Runoff control may be of greatest concern when subsurface, since lead bullets, fragments and a range is located in an area of heavy annual large particles may still remain on the range. rainfall because of an increased risk of lead migration due to heavy rainfall events. A “hard” Filter beds should be established at the base of engineered runoff control may be needed in this the backstop (see Figure 3-2). In addition to situation. A heavy rainfall event is defined as mitigating off-site migration, the filter beds work rainfall that occurs at such a rate that it cannot to raise the pH of the rainwater, which has fallen be absorbed into the ground and causes an on the target range, to reduce lead dissolution, increase in the volume and velocity of surface and to strain small lead particles out of the runoff. The impacts of rainfall are greater in rainwater. The filters typically consist of two rolling or sloped terrain (increases velocity of layers: a fine-grained sand bed underlain by runoff) or where surface water bodies are limestone gravel or other neutralization material. located on, or immediately adjacent to, the By design, the backstops and berms direct the range. runoff so that it drains from the range to the filters. The collected water then soaks through the top sand layer into the neutralization material,

Chapter III - Page III-9 BMP for Lead at Outdoor Shooting Ranges

Figure 3-2 – Sample Filter Bed System (Adapted from Proceedings for National Shooting, Range Symposium, October 17-19, 1993, North American Hunting Club and Wildlife Forever)

which raises the pH of the filtrate. The lead of containment traps and ponds by further particles in the rainwater are collected on the reducing the velocity of runoff and allowing for sand, while the pH-adjusted water drains more lead fragments to settle from the runoff. It through the filter to a perforated drainage pipe is important to regularly collect the lead and send located within the limestone gravel. this lead to a recycler.

Filter beds are designed to capture fine particles Dams and Dikes of lead transported in surface water runoff. They are not designed to capture bullets. The At shotgun ranges, dams and dikes can also be operation and maintenance requirements of filter used to reduce the velocity of surface water beds are minimal. Maintenance activity is limited runoff. Dams and dikes must be positioned to periodic removal of debris (such as litter, perpendicular to the direction of runoff to slow leaves, etc.) and occasional replenishment of the flow of surface water runoff. To accomplish the limestone. this, determine the direction of the range’s surface water runoff. This will be particularly The use of filter beds is most effective on sites obvious at ranges with sloped terrain. The dams with open, rolling terrain where surface water or dikes should be constructed using mounds of runoff is directed to them. At existing rifle and dirt that are approximately a foot high. These pistol ranges, a limited system of trenches and mounds should transect the entire range filters can be installed at the base of natural soil perpendicular to the stormwater runoff direction. backstops or at natural drainage depressions. These runoff controls are most important at Containment Traps and Detention Ponds ranges at which off-site runoff is a potential problem, such as ranges where the lead Containment traps and detention ponds are accumulation areas are located upgradient of a designed to settle out lead particles during surface water body or an adjacent property. heavy rainfall. Typically, they are depressions Since lead particles are heavier than most other or holes in the range’s drainage paths. Here, suspended particles, slowing the velocity of the lead-containing runoff passes through the surface water runoff can reduce the amount of trap or pond, allowing the lead bullet fragments lead transported in runoff. to settle out. Vegetative cover can be placed in the drainage path to increase the effectiveness

Chapter III - Page III-10 BMP for Lead at Outdoor Shooting Ranges

Ground Contouring reclamation program will allow you to avoid expensive remediation and potential litigation Another mechanism to slow runoff and prevent costs. Ranges in regions with high precipitation lead from being transported off site is ground and/or with acidic soil conditions may require contouring. By altering drainage patterns, the more frequent lead recovery since the potential velocity of the runoff can be reduced. for lead migration is greater. In regions with little Furthermore, in areas where pH is high precipitation and/or where the soil is somewhat (resulting in a lower potential for lead alkaline, spent bullets may be allowed to dissolution), the soil can be graded or aerated to accumulate on the soil for a longer time between increase the infiltration rate of precipitation, so reclamation events. It should be noted that to that rainwater is more easily absorbed into the ensure that lead is not considered “discarded” or soil. This slows down or prevents surface water “abandoned” on your range within the meaning runoff and off-site migration. It should be of the RCRA statute (i.e., a hazardous waste), pointed out that this design, in effect, collects periodic lead removal activities should be lead in the surface soils. Therefore, range planned for and conducted. This typically operation and maintenance plans should include requires one or more of the following: lead reclamation as well as adjusting the pH, and adding phosphate. Hand Raking and Sifting Screening 3.3 Lead Removal and Recycling Vacuuming (Step 3) Soil Washing (Wet Screening, Gravity Separation, Pneumatic Separation) To successfully minimize lead migration, the These methods are discussed in detail below. most important BMP for lead management is Figure 3-3 provides examples of common lead lead reclamation. Implementing a regular reclamation equipment. Figure 3-3 – Examples of Common Lead Reclamation Equipment

Example of shaker system. Courtesy of National Range Recovery

Example of final separation device (Patented Pneumatic Separation Unit) used with a Shaker System. Courtesy of MARCOR.

Chapter III - Page III-11 BMP for Lead at Outdoor Shooting Ranges

one person is holding the framed screen, it may Also, it is important to be aware that state be better to use a smaller frame (2 feet by 2 feet) regulations may require that the material being whereas, if several people are holding the sent for recycling have a minimum lead content framed screen, it can be larger. in order to qualify as a scrap metal that can be shipped under a bill of lading (i.e., exempt from Raking and sifting can be performed by club RCRA). members on a volunteer basis. Some clubs provide incentives, such as reduced fees, to 3.3.1 Hand Raking and Sifting members who assist with the lead removal process. Other clubs have hired college A simple BMP that can be done by club students during the summer. A number of small members, particularly at small ranges, is raking clubs have found that reloaders will volunteer to and/or sifting bullet fragments from the soil. rake in exchange for collected shot. Sifting and raking activities should be Hand sifting and raking are cost effective lead concentrated at the surface layer. This is a low- removal techniques for small ranges, or low technology and low-cost management shooting volume ranges. However, these alternative for lead reclamation. Once collected, techniques may not be appropriate for situations the lead must be taken to a recycler or reused. in which there is a large volume of lead on the Arrangement with a recycler should be made range. In this instance, reclamation machinery prior to collecting any spent lead to avoid having may be more appropriate. to store the lead and avoid potential health, safety and regulatory concerns associated with Note: Those conducting the hand raking and storing lead. sifting reclamation at ranges should protect themselves from exposure to lead. Proper At trap and skeet ranges, conducting sifting and protective gear and breathing apparatus raking activities in the shot fall zone should be worn. The Occupational Safety (approximately 125 - 150 yards from the and Health Administration (OSHA) or an shooting stations) will yield the most lead. For appropriate health professional should be sporting clay ranges, these activities should be contacted to learn about proper protection. conducted around tree bases, where lead shot tends to collect. Basically, the process consists 3.3.2 Purchasing/Renting Mechanical of raking with a yard rake the topsoil in the shot Separation Machinery fall areas into piles, as if you were raking leaves, removing any large debris (e.g., rocks, twigs, Reclamation equipment may be rented from leaves, etc.), and then sifting the soil using local equipment rental services. One type of screens. machine that it may be possible to rent for lead shot reclamation is known as a screening Once the soil has been raked and collected, machine (also referred to as a mobile shaker, pass it through a standard 3/16 inch screen to gravel sizer, or potato sizer). This device uses a remove the large particles. This process will series of stacked vibrating screens (usually two allow the lead shot sized particles to pass screens) of different mesh sizes and allows the through the screen. The sifted material (those user to sift the lead shot-containing soil not captured by the 3/16 inch screen) should be [gathered by hand raking, sweeping, or passed through a 5/100 inch screen to capture vacuuming (discussed above)]. The uppermost the lead and lead fragments. This process will screen (approximately 3/16 inch mesh) collects also allow sand and other small sediment to larger than lead shot particles, and allows the pass through the screen. Screens can be smaller particles to pass through to the second purchased at many local hardware stores. The screen. The second screen (approximately 5/ screens should be mounted on a frame for 100 inch mesh) captures lead shot, while support. The frame size will vary based on the allowing smaller particles to pass through to the technique used by each range. For example, if ground. The lead shot is then conveyed to a

Chapter III - Page III-12 BMP for Lead at Outdoor Shooting Ranges container such as a five gallon bucket. In the Please note that reclamation companies tend to Northeastern United States, the typical rental be in high demand — it may take over a year for cost for this equipment is between $500 and the company to start at your club. Therefore, it is $4,500 a week, depending on the size shaker wise to plan ahead and make the call to the desired. It may be possible to get more reclamation company as early as possible. information on rentals for this type of equipment from heavy equipment rental companies. Some reclamation companies require a site visit to view the topography, the soil composition, and Another possible option is to rent a vacuum amount of lead observed on the ground. During system that will collect the lead shot-containing the visit, some companies may even do a site soil from the range. Here, vacuuming takes the analysis to determine whether or not it is place of hand raking or sweeping. A vacuum feasible to reclaim. This analysis identifies the machine is used to collect the lead shot- location of lead, the expected recovery amount, containing soil. Once collected, the lead shot- and the depth lead reaches into the soils. containing soil must be sifted through a screening system (either a rental screening machine, or a series of home made framed 3.3.4 Reclamation Activities screen sets). You may be able to obtain more information about renting vacuums or Using machinery to reclaim lead usually requires vacuuming services (e.g., it may include a that the area be clear of scrub vegetation. person to operate the machinery) from heavy Grass, mulch, or compost is generally removed equipment rental companies. or destroyed during the reclamation process. Some reclamation companies have no problem Some clubs have found that performing their beginning reclamation on a grassy field. Other own lead reclamation to be very time reclamation companies will remove grass before consuming. Part of the reason these or during reclamation (by burning it, if allowed reclamations took so long is that the soils were locally, leaving behind the lead shot), and still wet. Reclamation is much easier under dry soil others require that all vegetation be removed conditions. For example, one club reclaimed before they arrive at the range. Some lead from their range using equipment they companies will re-seed the area once the modified themselves. Twenty-five tons of lead reclamation is completed. were collected but the reclamation took over two years. Another club took a year to reclaim 10 Since sporting clay ranges generally have many tons of lead. A more preferable option may be to trees, removal of vegetation as discussed above hire a reclamation company. may not directly apply to existing sporting clay ranges. At these ranges, the focus is on 3.3.3 Hiring a Professional Reclamation removing vegetative debris (i.e., fallen limbs, Company tree bark, etc.) prior to reclamation. This may include removing some trees to gain better Another option for lead removal is to hire a access with the reclamation machinery. Of professional reclaimer. Lead reclamation course, when designing a new sporting clay companies claim to recover 75%-95% of the range, steps to facilitate lead reclamation should lead in the soils. Generally, with reclamation be taken into account. For example, less and companies there is no minimum range size more widely spaced trees will facilitate lead requirement for lead reclamation. Concentration reclamation. of lead is more important than quantity spread over a field, especially if it is a difficult range for Reclamation companies use several types of reclamation (e.g., hilly, rocky, a lot of clay in the machinery to reclaim lead. Some companies soil). drive their separation machinery over the site. The lead-laden soil is picked up, processed and then returned to the ground after most of the lead

Chapter III - Page III-13 BMP for Lead at Outdoor Shooting Ranges is removed. Other companies scrape off the top Reclamation time varies depending on weather, several inches of soil from the ground, using a site accessibility, range size, and number of front-end loader to bring the soil/lead to personnel assigned to perform the reclamation. stationary reclamation machines, and then return the soil to the field after reclamation. Many Reclamation activities may generate dust, companies till the top two to five inches of soil especially in drier western locations. To prevent and grass immediately prior to reclamation to or minimize dust from traveling off the range and facilitate the process (some companies may causing complaints from neighbors, reclamation require this to be done prior to arrival on the activities generating dust should only be range). conducted during periods of no wind. In addition, such activities should be completed as Regardless of how it is collected, the actual quickly as possible. reclamation of the lead follows the same general pattern. Most often, it is sifted through a series Vacuuming of shaking screens. The lead and soil pass through shaking screens (usually at least two For ranges that are located on hilly, rocky, and/or screens) of decreasing mesh (hole) size, with densely vegetated terrain, several reclamation the topmost screen having the largest mesh. companies employ a vacuum system that This part of the reclamation machinery is usually collects the lead shot (and soil and other adapted from machinery used for potato or detritus). The resulting mix is then placed into gravel sizing. the reclamation machinery discussed above. This method is especially effective for sporting Any soil/debris automatically screened out as clay ranges where lead shot tends to pile up being too big or too small is either returned to around tree bases. the field or re-screened to ensure no lead is caught in the debris. This procedure is why Vacuuming has traditionally been used for moist, clay soils are more difficult to reclaim. removal of lead shot from trap, skeet and The moist, clay soils can bind together into shot- sporting clay ranges. Another way to apply this sized pellets producing more “product” for the method involves removing the top layer of an second part of the reclamation. The wet soils earthen backstop or sand trap with shovels. It is can also clog the screens. then spread thinly over an impermeable material such as plywood. A vacuuming device is then For some reclamation companies, their process used to collect the materials that are lighter than ends after sifting the soil and returning it to the lead (e.g., sand or soil), while leaving behind the ground. However, some companies take heavier materials (i.e., lead bullets/shots and reclamation one step further. After screening, fragments). The soil can then be returned to the the resulting lead, soil, and other lead-sized range. This process is most efficient for dry, particles enter a blowing system. Here the lead sandy soils without a lot of organic material. A shot is easily separated from the soil and other more recent innovation is the use of a high debris by the blowing air. The lead is much suction vacuum. This vacuum itself does not more dense than the soil and other lead-sized have to be moved about, since a very long hose debris so that it falls out first. Figure 3-3 depict (up to 600 feet) is used to move in and around examples of actual lead reclamation machinery. trees during the collection of lead shot at trap and skeet ranges. Some lead reclamation companies will perform the reclamation during club off-hours so that Soil Washing (Physical and Gravity club activities are not interrupted. Additionally, Separation) some perform the reclamation on a field-by-field basis, to minimize any disruptions to club Soil washing is a proven technology and another activities. However, others companies require lead reclamation method used by some the club to shut down during the reclamation. reclaimers to separate the lead particles from

Chapter III - Page III-14 BMP for Lead at Outdoor Shooting Ranges the soils. Soil washing is the separation of soils the volume of the soil mixture is reduced. Large into its constituent particles of gravel, sand, silt particles such as lead shot/bullets and and clay. Because of the much higher surface fragments are screened out of the soil/wash area and surface binding properties of clay, most mixture early in the process and can be taken lead contaminants tend to adhere to the clay off-site for recycling - allowing the soil to be particles. placed back on-site.

Soil washing, therefore, attempts to generate a Gravity Separation clean sand and gravel fraction by removing any fines adhering to the larger soil particles and, if This technique can be used in cases where the necessary, to transfer contaminants bound to lead particles are the same size as surrounding the surface of the larger particles to the smaller soil particles. The wet soil/wash mixture is soil particles. Typically, the soils are first passed through equipment, which allows the excavated from the range and then mixed into a more dense materials (i.e., lead materials) to water-based wash solution. The wet soil is then settle to the bottom of unit and separate out of separated using either wet screening or gravity the soil/wash mixture. separation techniques. One benefit of this Pneumatic Separation system of reclamation is that it does not require that soils be dry. Pneumatic separation (see figure 3-3) is an effective means to enhance the traditional In addition, soil washing may be able to recover screening results. Traditional screening cannot all or almost all lead particles through a separate shot and bullets from other shot and combination of wet screen sizing and density bullet sized material, i.e., rocks, stones, roots, separation. This technique is an option for and various debris. A recycling facility considers remediation of a range being closed and may non-lead items as “contaminants” which compare favorably from an economic standpoint drastically reduces the value of the recycled with the disposal option. lead. Pneumatic separation utilizes an air stream, and specific density analysis, to Soils treated using this method have been effectively separate the shot/bullets from the shown to be below 5 mg/L TCLP and to have up other shot/bullet sized material. to 99% of particulate lead removed. Treatment costs are site specific, but can range from less 3.3.5 BMPs to Assist Lead Reclamation then $40 per ton (1999 levels) for simple and Recycling physical/gravity separation up to about $100 per ton for processes involving leaching. Credits for There are several operational activities that recycled lead help offset the treatment cost and should be conducted throughout the year to the cost of recycling any treatment sludges and facilitate reclamation. The following is a concentrated soil fines. Water used in soil discussion of these activities. washing is from a closed loop system and should only be disposed at completion of Frequency of Lead Removal cleanup. Experience shows the water to not be a RCRA regulated hazardous waste, therefore It is important to perform lead removal at a probably allowing disposal to a local wastewater frequency appropriate for your site. The treatment plant. frequency is dependent on several factors. These include: Wet Screening Number of rounds fired With this method, particles larger and smaller Soil pH than the surrounding soils are passed through a Annual precipitation series of large-mesh to small-mesh screens. Soil Type Each time the mixture passes through a screen, Depth to groundwater.

Chapter III - Page III-15 BMP for Lead at Outdoor Shooting Ranges

more cost effective is for a number of ranges in Lead quantity, as estimated by the number of the same geographical area to work together in rounds fired, is a factor in determining the organizing coordinated removals at their ranges. appropriate frequency of reclamation at ranges. This will reduce the reclaimer travel and It also assists in determining the cost of mobilization cost for each range. reclamation. One reclamation company indicated that reclamation was most cost Minimization of Vegetation effective when it contains at least 20 pounds of lead per square foot of backstop. Another As discussed previously, vegetation is useful source indicated that a minimum of 100,000 both for controlling the amount of runoff and rounds per firing lane should be allowed before erosion from the range and inhibiting lead lead reclamation occurs. This would ensure mobility. However, excessive or good range operation and maintenance, while unmaintained vegetative cover can interfere minimizing the cost per quantity of lead with reclamation activities. For example, large recovered. amounts of vegetation impedes the screening and sifting processes used by many reclamation For shotgun ranges, tracking the number of companies. Therefore, prior to reclamation targets thrown can help indicate when the lead activities, it is best to remove, reduce, or mow shot should be reclaimed. For example, excessive vegetation from the area. Once the considering environmental issues, the reclamation has been conducted, quick-growing market for scrap lead and common cleanup vegetation such as a rye/fescue grass mix methods, one source indicated that when a should be replanted. This process should be range has thrown at least 250,000 to 1,000,000 repeated for each reclamation event. targets, depending on the shooting area, In addition, heavily wooded areas may inhibit reclamation of the lead shot is encouraged. lead reclamation because they are less Another reclaimer indicated that if at least two accessible by heavy reclamation machinery. pounds of lead per square foot have For ranges that are heavily wooded, it is accumulated on the range, reclamation is recommended that you minimize the vegetation recommended. or modify the range design to allow lead reclamation equipment access to the range. Because the number of rounds fired is important Access to the impact area should be developed to know, establishing record keeping procedures to facilitate reclamation. Make sure that the to monitor the number of rounds fired is pathways do not present a safety risk. recommended. This can be accomplished by maintaining logbooks and asking shooters to list Innovative Landscaping the number of rounds shot and the type/size of shot/bullets they use. This should be done by Some new ranges are landscaping their ranges lane and by stand. to include a sand track (an area the size of the shotfall zone that is only sand) located behind There are many ranges at which lead removal some aesthetically pleasing shrubs. This allows has not occurred for many years. Many of these the spent shot to concentrate on the sand, ranges are used extensively. Such ranges are making it very easy to perform reclamation especially good candidates for lead removal and because there is no interference by vegetation. recycling. Subsequent removal frequency depends on range use and environmental Selecting a Lead Reclaimer factors. The NRA recommends a frequency of one to five years for lead cleanup, even on In ensuring that the reclamation is conducted ranges with minimal use4. One possible appropriately, selecting a reclaimer that is right approach to reducing the cost of reclamation for your range is extremely important. Some lead reclamation companies will travel to your 4. National Rifle Association, “Metallic “Bullets” lead range and assess the range prior to conducting Deposits on Outdoor and Indoor Firing Ranges” 1991 Chapter III - Page III-16 BMP for Lead at Outdoor Shooting Ranges lead collection activities. This assessment trip and reclamation company and technique used. allows the reclamation company to confirm Because the economics vary due to many information gained during initial discussions, as factors, this manual does not provide specific well as to assist in appropriately estimating estimates. However, it is important to costs, time required, and the estimated volume understand that lead reclamation will generally of lead at the range. Conducting this pre- require an expenditure by the range, even when assessment also allows you to determine which considering any monetary returns from selling reclaimer is right for your situation. reclaimed lead. By tracking the range use and using the criteria discussed earlier (see Questions Commonly asked by the Reclaimer Frequency of Lead Removal), the reclamation costs per quantity of lead can be optimized. For When you contact a reclamation company, it is long term range management, routine lead likely that the reclaimer will ask several general removal will help future cost avoidance by questions. Typical questions include: minimizing the need for costly site remediation

When was the last reclamation conducted? Some reclaimers bid the lowest flat fee with all How many rounds have been shot since the lead provided to the range for selling. The that last reclamation? range owners/operators must then consider the What is the use frequency of the range? transportation costs and recycling fee What are the site characteristics and soil associated with sending the reclaimed shot and types? bullets to a recycling company. Alternatively, the reclaimer will use the economic return of lead What type of bullet containment device is sold for recycling, based on the volume used at the range? reclaimed and the current value of lead, to reduce the total cost of reclamation and Answering these questions will be a lot easier if recycling. Although the value of lead varies, the you have maintained good records, as is scrap value of reclaimed lead typically falls suggested above. between $.06 and $.25 per pound, excluding transportation cost. See the appendix for Questions to ask the reclaimer contact information regarding lead reclamation companies that specialize in lead removal at When choosing a reclaimer be sure to ask the outdoor ranges. general questions about prior cleanups (past projects), insurance to cover company and cleanup (general liability insurance, pollution 3.4 Documenting Activities and insurance, bonding, etc.), and site plans to Record Keeping (Step 4) ensure health and safety of workers and range personnel. Other questions you may want to ask Documenting activities and keeping good the reclaimer include: records is of paramount importance for an effective lead management program at a range. Can the reclamation take place outside Owners/operators should document all activities normal hours of range operation? done at the range with respect to BMPs and What costs are involved? recycling of lead. Records should be kept on How long will the reclamation take? when services were provided and who provided Does vegetation at the range need to be them. removed? Owners/operators may want to document what Economic Considerations type of BMP(s) were implemented to control lead migration, the date of service, and who did Lead removal costs may vary dramatically the services. The records should be kept for the depending upon the type and volume of soil or life of the range. Records may be used to show sediments, topography, amount of lead, location, that owners/operators are doing their part to Chapter III - Page III-17 BMP for Lead at Outdoor Shooting Ranges help prevent lead migration off-site and show formats. This template, combined with that they are doing their part to be stewards of information provided throughout this manual, the environment. other resources and guidance, and site- specific factors, will help in guiding the 3.5 Additional Economic process of evaluating relevant information Considerations about your facility and determining which BMP(s) might be appropriate for your ranges. EPA’s template was adapted from Not all BMPs need to be implemented at once. Appendix C of the National Shooting Sports Many can be phased in over time. However, it Foundation’s manual, Environmental is important to begin implementing BMPs, Aspects of Construction and Management of especially lead reclamation and recycling, as Outdoor Shooting Ranges (the NSSF soon as possible. Implementing the most manual.) Accordingly, use of that template appropriate BMPs for your range requires would also be acceptable for use in EPA’s consideration of your range characteristics and Certificate of Recognition program. costs associated with implementing the BMPs. This manual provides a large selection of BMPs In order to request this certificate, a range that vary in both cost and sophistication. In must submit a notice to the Lead Shot selecting BMPs for your range, it is important to Coordinator in EPA Region 2 stating that look at all costs and all the benefits (or potential they have completed an Environmental problems) associated with each BMP. Stewardship Plan as indicated above and are intending to implement it within six 3.6 Summary of Key BMPs for months. The certificate is intended to Shooting Ranges convey, to all that may see it, that the range has declared its intention to properly manage There are several BMPs that are highly lead shot and bullets. However, it must be recommended to be implemented, if applicable noted that a certificate is not a permit to to your range. Table 3-1 identifies the operate and provides no additional advantages and disadvantages of all BMPs operational approval, implied or otherwise. discussed in this chapter. This table serves as a quick reference guide for potential BMPs. Readers should refer back to the detailed discussions above for further information regarding these BMPs.

3.7 Certificate of Recognition

EPA has established a voluntary process whereby a shooting range may apply for a “Certificate of Recognition.” The Certificate is intended to be awarded to ranges that have certified that they have prepared and intend to implement, or have implemented, a written Environmental Stewardship Plan that is consistent with the EPA Best Management Practices for Lead at Outdoor Shooting Ranges manual. To assist in this process, Appendix E contains a template for an Environmental Stewardship Plan, an electronic copy of which is available on EPA’s shooting range website (http://www.epa.gov/region2/leadshot) in several

Chapter III - Page III-18 BMP for Lead at Outdoor Shooting Ranges

Table 3-1 – Summary of Key BMPs

BMPs for Preventing Lead Migration

Monitoring and Adjusting pH

BMP Option Advantages Disadvantages Lime Spreading 1. Easy 1. Does not offer a 2. Inexpensive permanent solution 3. Effective 2. Will not work in extremely acidic conditions

Immobilizing Lead

BMP Option Advantages Disadvantages Phosphate Spreading 1. Easy 1. Does not offer a 2. Inexpensive permanent solution 3. Effective

Controlling Runoff

BMP Option Advantages Disadvantages Vegetative Ground Cover (e.g., grass, etc.) 1. Easy 1. Requires periodic 2. Aesthetically pleasing maintenance 3. Relatively inexpensive 2. Must be removed or 4. Effectively slows and reduced prior to can redirect runoff reclamation 5. Some may "bioabsorb" 3. Excessive vegetation lead will interfere with reclamation Organic Surface Cover (e.g., mulch and 1. Easy 1. Requires periodic compost) 2. Aesthetically pleasing maintenance 3. Relatively inexpensive 2. Must be removed prior 4. Effectively slows and to reclamation can redirect runoff 3. May not be suitable at ranges with acidic soil conditions Filter Beds 1. Diverts and treats lead 1. May require hiring a contaminated runoff licensed engineer 2. Low maintenance 2. Higher initial setup cost 3. Assists with range drainage

Chapter III - Page III-19 BMP for Lead at Outdoor Shooting Ranges

Table 3-1 – Continued

Controlling Runoff (cont.) BMP Option Advantages Disadvantages Water/Sediment Traps 1. Low maintenance 1. May require hiring a 2. Assists with range licensed engineer drainage 2. Higher initial setup cost

Dams and Dikes 1. Low maintenance 2. Higher initial setup cost 2. Assists with range drainage

Ground Contouring 1. Lower initial setup cost 1. May require hiring a 2. Assists with range licensed engineer drainage

Controlling and Containing Bullets

Bullet Containment Devices BMP Option Advantages Disadvantages Earthen Backstop 1. Minimal (if any) initial 1. Build up of bullets setup cost increases chances of 2. Accepts firing from ricochet and fragmentation various guns and directions problems 2. Lead removal requires mining 3. Potential decreased value of lead because it is less clean than lead reclaimed from other trap systems 4. Does not eliminate lead's introduction into the environment

Sand Trap 1. Low initial setup cost 1. Build up of bullets 2. Ease of maintenance increases chances of 3. Accepts firing from ricochet and fragmentation various guns and directions problems 2. Lead removal requires mining Pit and Plate Trap (Sand) 1. Low initial setup cost 1. Lead builds up on top 2. Simple installation layer of sand causing 3. Lead removal and ricochet problems recycling requires less 2. Increased bullet extensive mining fragmentation 3. Higher level of maintenance than sand traps

1 Much of this information was obtained from Action Target’s Bullet Containment Trap Technologies video. Reference to various pros and cons of individual bullet containment devices is included in this manual for informational purposes only. The USEPA does not endorse any particular bullet containment device, design, or product.

Chapter III - Page III-20 BMP for Lead at Outdoor Shooting Ranges

Table 3-1 – Continued

Controlling and Containing Bullets (Cont.) Bullet Containment Devices (cont.) BMP Option Advantages Disadvantages Escalator Trap (Steel) 1. Can be used indoors and 1. Deflection plates require outdoors regular oiling. The oil used is hazardous and can easily migrate at outdoor ranges 2. Relatively high maintenance 3. Poor lead collection because the bullets may become clogged at the spiral collection area at the top of the deflection plate 4. Increased bullet fragmentation 5. May require rubber curtains to be placed in front of the trap to slow bullets 6. More noise 7. Possible creation of lead dust Vertical Swirl (Steel) 1. Can be used indoors or 1. Does not accept shooting outdoors from all directions 2. Bullets are captured in 2. Corners where each unit pure form in containers, meet can cause ricochet thus removal and recycling and fragmentation problems is easy 3. More noise 4. May create lead dust Wet Passive Bullet Trap (Steel) 1. Can be used indoors and 1. Expensive outdoors 2. Oil and water mixture is 2. Excellent results (i.e., low hazardous ricochet, low fragmentation, 3. More noise ease of removal) 3. Bullets are captured in containers, thus removal and recycling is easy Lamella Trap 1. Can be used indoors or 1. Rubber strips quickly outdoors become destroyed and must 2. Reduction of lead dust be replaced 2. Potential fire hazard 3. High maintenance 4. Scattered lead fragments mixed with rubber can migrate; lead contaminated granules are hazardous and require special handling

Chapter III - Page III-21 BMP for Lead at Outdoor Shooting Ranges

Table 3-1 – Continued Controlling and Containing Bullets (Cont)

Bullet Containment Devices (cont.)

BMP Option Advantages Disadvantages

Rubber Granule 1. Can be used indoors or 1. Rubber strips can outdoors quickly become destroyed 2. Reduction of lead dust and must be replaced 3. Minimizes 2. Some pose potential fire fragementation, compared hazard, although fire- with some backstops retardant/resistant materials are available in some designs 3. High maintenance 4. Scattered lead fragments mixed with rubber can migrate; lead contaminated granules are hazardous and require special handling Shock Absorbing Concrete 1. Adaptable/can be 1. Mechanical lifting and formed in any shape handling equipment must 2. Can be used to reduce be used during installation erosion in soil berms/target and maintenance emplacements 2. High maintenance 3. Crushed concrete can (replacement) costs potentially be recast after fragments removed Removal and Recycling of Lead

Hand Raking and Sifting 1. Easily done by club 1. May be more time members consuming at large ranges 2. Inexpensive 2. Weather sensitive (i.e., 3. Can be done outside works best under dry operating hours conditions) 4. Relatively effective 3. Exposure to lead and lead dust possible Screening 1. Effective 1. Vegetation must be 2. Potential economic removed returns 2. Weather sensitive (i.e., works best under dry conditions) Vacuuming 1. Effective 1. Weather sensitive (i.e., 2. Can be used at least works best under dry accessible ranges conditions) 3. Less vegetation needs to be removed Soil Washing 1. Effective at cleaning the 1. Vegetation must be soil to remove the lead removed particles so one is left with non-lead soil Chapter III - Page III-22 BMP for Lead at Outdoor Shooting Ranges

References

Battelle Memorial Institute, Field Demonstration of a Sieving and Stabilization Technology on Lead-Contaminated Soils at a Small Arms Range at Mayport Naval Air Station, Colum- bus, Ohio, February 1991

Brister, B. The Speed Factor, Field and Stream, January 1995

Connecticut Coastal Fisherman's Ass'n v. Remington Arms Co., Inc., 989 F.2d 1305 (2d Cir. 1993)

George, C.J., Joachim, A., and Le, Phu Trong, Long-Buried Lead Shot: Its Stability, Possible Transport by Waterfowl and Reexposure by Hydraulic Dredging at Collins Lake, Department of Biological Sciences, Union College, Schenectady, NY, June 1991

Long Island Soundkeeper Fund, Inc. v. New York Athletic Club of the City of New York, 1996 U.S. Dist. LEXIS 3383 (S.D.N.Y. 1996)

Magdits, Louis J., Recycling Regulations, Proceeding from the Third National Shooting Range Symposium, June 23-25, 1996, Orlando, Florida

Middleton, J.R., Development of Toxic Free Ammunition, U.S. Armament Research, Development and Engineering Center

National Rifle Association of America, Lead Article, Risk Issues in Health and Safety - Volume I, Pages 6-8, Winter 1990

National Rifle Association of America, Metallic “Bullets” Lead Deposits on Outdoor and Indoor Firing Ranges, 1991

National Rifle Association, The NRA Range Source Book: A Guide to Planning and Construction, June 1998

National Shooting Sports Foundation, Environmental Aspects of Construction and Management of Outdoor Shooting Ranges, June 1998

Ordija, Victor, Lessons from Lordship, Proceedings from the National Shooting Range Symposium, October 17-19, 1993, Salt Lake City, Utah

Peddicord, Richard K., Lead Mobility in Soils, Proceedings from the Third National Shooting Range Symposium, June 23-25, 1996, Orlando, Florida

References - 1 BMP for Lead at Outdoor Shooting Ranges

Sever, C.W., Lead and Outdoor Ranges, Proceedings from the National Range Symposium, October 17-19, 1993, Salt Lake City, Utah

Sporting Arms and Ammunition Manufacturers Institute, Inc., Lead Mobility at Shooting Ranges, Newtown, CT, 1996

Stansley, W., Widjeskog, L., and Roscoe, D.E., Lead Contamination and Mobility in Surface Water Trap and Skeet Ranges, Bulletin of Environmental Contamination Toxicology, Springer-Verlag, New York, NY, 1992

U.S. Department of the Interior, Pollution Prevention Handbook -- Firing Ranges, Department of the Interior, Office of Environmental Affairs, Washington, D.C.

U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response, Washington, D.C., Directive 9355.4-12, Revised Interim Soil Lead Guidance for CERCLA Sites and RCRA Corrective Action Facilities, July 14 1994

U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response, Washington D.C., A Citizen's Guide to Soil Washing, EPA 542-F-96-002. , April 1996.

U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response, Washington, D.C. Physical/Chemical Treatment Technology Resource Guide, EPA 542-B- 94-008. September 1994.

References - 2 BMP for Lead at Outdoor Shooting Ranges

Appendix A: Resources

This manual provides contacts for lead reclamation companies, lead recycling companies, bullet trap manufacturers, and organizations that provide prevention and/or remediation techniques to assist clubs and firing ranges in implementing Best Management Practices for shooting ranges. The list was updated for the June 2005 printing. Vendors who are interested in being added to the list of lead reclaimers or remediation contractors should contact:

Lead Shot Coordinator RCRA Compliance Branch US EPA Region 2 290 Broadway New York, NY 10007-1866 Telephone: (212)637-4145 E-mail: [email protected]

Appendix A - Page A-1 BMP for Lead at Outdoor Shooting Ranges Lead Recycling Companies Below is a list of recycling companies for lead in soils and spent lead shot/bullets that were contacted during the writing of this manual. Lead recycling companies smelt lead. It is not inclusive and is included for informational purposes only. Local scrap metal recyclers may also accept spent lead shot or spent bullets. Mention of these companies does not serve as an endorsement by the EPA.

The Doe Run Company East Penn Manufacturing Company, Inc. Resource Recycling Divsion P.O. Box 147 HC1 Box 1395 Lyon Station, PA 19536 Boss, MO 65440 610-682-6361 Rick Leiby 800-633-8566 573-626-3476 Web Site: http://www.eastpenn-deka.com Lou Magdits [email protected]

Exide Gopher Smelting and Refining Spring Valley & Nolan Streets 3h385 Highway 149 Sout Reading, PA 19612 Eagan, MN 55121 800-437-8495 651-454-3310 Robert Jordan, Maritza Rojas-Suarez 800-354-7451 Mark Kutoff Web site: http://www.exide.com Web Site: http://www.gopherresource.com/

Gulf Coast Recycling Kinsbursky Brothers, Inc. 1901 N. 66th St 1314 N. Anaheim Blvd Tampa, FL 33619 Anaheim, CA 92801 813-626-6151 714-738-8516 William Weston Paul Schneider

Web Site: http://www.kinsbursky.com

Reserve Trading Corp. P.O. Box 302 Medina, OH 44258 330-723-3228

Appendix A - Page A-2 BMP for Lead at Outdoor Shooting Ranges Lead Reclamation Companies Below is a list of reclamation companies for lead in soils and spent lead shot/bullets that were contacted during the writing of this manual. Lead reclamation companies reclaim lead from ranges. It is not inclusive and is included for informational purposes only. Mention of these companies does not serve as an endorsement by the EPA.

Brice Environmental En·Range, Inc. Entact 3200 Shell St, 3326 NW 29th St. 1010 Executive Court P.O. Box 73520, Miami, FL 33142-6310 Suite 280 Fairbanks, AK 99707 Thomas M. Taylor Westmont, IL 60559 Craig Jones 305-999-9965 630-986-2900 907-456-1955 Fax 305-635-8645 www.entact.com www.briceinc.com Email: [email protected] www.en-range.com Performs physical removal of Reclaims primarily from the lead from backstops, earthen backstops and sand Provides lead reclamation and chemical treatment of soils traps. other environmental and and returns soil to the maintenance services. backstop.

Karl & Associates, Inc. MARCOR Metals Treatment 20 Lauck Road 246 Cockeysville Road Technologies, LLC (MT2) Mohnton, PA 19540 Hunt Valley, MD 21030 12441 West 49th Avenue Edmund Karl III Dave Jungers Suite 3 610-856-7700 410-785-0001 Wheat Ridge, CO 80033 www.marcor.com Jim Barthel Works primarily in the the mid- 303-456-6977 Atlantic area. Lead-containing Uses a pneumatic separation www.metalstt.com soil is physically removed and unit to remove lead from sent to licensed disposal sites contaminated soil and treats Removes lead from soil and or licensed recycling facilities. soil to pass TCLP. treats soils at all types of ranges.

Sears Trucking Company Solucorp Industries, Ltd. Southern Lead Removal P.O. Box 38 250 West Nyack Road P.O. Box 2645 El Reno, OK 73036 West Nyack, NY 10994 Daytona Beach, FL 32115 Garland Sears Mike DeLuca Kevin Gilchrist 800-522-3314 845-623-2333 386-763-0115 Fax 405-262-2811 Fax 845-623-4987 Fax 386-761-6991 Email: [email protected] Physically removes lead from www.solucorpltd.com Removes lead from indoor and soils at trap and skeet ranges. outdoor pistol ranges only. Removes and treats soil using their Molecular Bonding System (MBS) soil stabilization technology.

Sport Shooting Services Terra Resources, Ltd. Waste Recycling Solutions, P.O. Box 667 HC4 Box 9311 Inc. Crawfordville, FL 32326 Palmer, AK 99645 1850 Route 112 Ed Tyer Larry Wood Medford, NY 11763 850-926-7375 907-746-4981 Tommy Arabia, President Cellphone 850-294-0132 Cellphone: (907) 232-5059 631-654-3811 Email: [email protected] Fax: 907-746-4980 www.terrawash.com Uses a vacuum system to Removes lead from earthen remove lead from trap and berms, uses a shaker and Uses gravimetric process to skeet ranges. screen system to separate separate lead and lead from soils, rents TerraWashTM soil washing screening equipment, and technology. consults on range design, primarily in Florida.

Appendix A - Page A-3 BMP for Lead at Outdoor Shooting Ranges Other Resources

Below is a list of additional phone numbers that may be of use if you have general questions including questions on range construction, design, and implementing BMPs.

U.S. Fish and Wildlife Service Institute of Scrap Recycling Industies, Inc. 4401 North Fairfax 1325 G Street, NW, Suite 1000 Arlington, VA 22203 Washington, DC 20005-3104 703/358-2156 202/737-1770

Web site: http://www.fws.gov/ Web site: http://www.isri.org/

Lead Industries Association, Inc. National Rifle Association of America 13 Main Street 11250 Waples Mills Road Sparta, NJ 07871 Fairfax, VA 22030 973/726-LEAD (973/726-5323) 800/NRA-3888 fax: 973/726-4484 Web site: http://www.nra.org Web site: http://www.leadinfo.com

National Shooting Sports Foundation and Sporting Arms and Ammunition National Association of Shooting Ranges Manufacturers' Institute, Inc. 11 Mile Hill Road Flintlock Ridge Office Center Newtown, CT 06470 11 Mile Hill Road 203/426-1320 Newtown, CT 06470-2359 203/426-4358 NSSF web site: http://www.nssf.org NASR web site: http://www.rangeinfo.org Web site: http://www.saami.org

Wildlife Management Institute 1101 14th Street, N.W. Suite 801 Washington, DC 20005 202/371-1808

Web site: http://www.wildlifemanagementinstitute.org

Appendix A - Page A-4 BMP for Lead at Outdoor Shooting Ranges Web Resources Useful Web Sites Description Web Address Federal Government Sites U.S. EPA's Outdoor Shooting Range http://www.epa.gov/region2/waste/leadshot/ Home Page U.S. EPA – Military Munitions Rule http://www.epa.gov/epaoswer/hazwaste/military/ http://www.epa.gov/tribalmsw/thirds/remunition.htm U.S. Occupational Safety and Health http://www.osha.gov/ Administration (OSHA) National Institute for Occupational http://www.cdc.gov/niosh/ Safety and Health (NIOSH) State Government Sites Florida: BMPs for Shooting Ranges http://www.dep.state.fl.us/waste/categories/shooting_range/

Massachusetts : Lead Shot in the http://www.state.ma.us/dep/files/pbshot/pb_shot.htm Environment Minnesota: Poster for "Firing Range http://www.cdc.gov/niosh/mnables.html Hazards" Ohio: Lead Shot Reclaimers list http://www.epa.ohio.gov/dhwm/leadrecy.htm Wyoming: Lead Recyclers List http://deq.state.wy.us/outreach/lead.htm Court Decisions Connecticut Coastal Fishermen's http://www.duedall.fit.edu/summer/rcra.htm Association v. Remington Arms Long Island Soundkeeper Fund and NY http://www.epa.gov/region02/waste/leadshot/lisfnyac.htm Coastal Fishermen's Assoc. v. New York Athletic Club Articles and Research USAF - Lead Contamination in Soils at http://www.afcee.brooks.af.mil/pro-act/fact/june98a.asp Military Small Arms Firing Ranges U.S. Army Env. Center (AEC) – Small http://aec.army.mil/usaec/range/operations03.html Arms Range Technology http://aec.army.mil/usaec/technology/rangexxi03.html http://aec.army.mil/usaec/publicaffairs/update/win97/range.htm AEC – Green Bullets http://aec.army.mil/usaec/publicaffairs/publicity02.html http://aec.army.mil/usaec/technology/rangexxi00a.html http://aec.army.mil/usaec/publicaffairs/update/spr97/bullets.htm AEC - Recycling of Firing Range Scrap http://aec.army.mil/usaec/publicaffairs/update/spr99/spr9911.htm Florida Center for Solid and Hazardous http://www.floridacenter.org/ Waste Management National Association of Shooting http://www.rangeinfo.org/resource_library/facility_mngmnt/ Ranges' Reference Library

Appendix A - Page A-5 BMP for Lead at Outdoor Shooting Ranges Bullet Trap Manufacturers1 . t , i n f r s o s s e i e n n t e t t r r i s n f r d d u s e h a e o s e s l t e t e t o o e e f l t l g n b t r n a n s b b n i o i i e u d o e l s f n l i d h e h r e i l d t l b n t a - y e t s a i e i o t u . c y a a c m , h m d a l u i e n - h b p w u s t s h m g g n c i o y i g w i m 0 m i l m T a d a i t l f a a l r d r e h o 5 u h s s r c e t t d s i u t e u f l , I r e e i n f . a e a C n d r n d h s e s s b e t m d p w a l d e u g e i . g v n e s d e b h t l u a n t n s b f r n e a m s e e y w g i u m r p i i l c i i l a t n r r o c s , l n s e a c y n t e o l i d o c n a s f o u c a T i u l n a p s e d t t r e d u o e n s a a a e i u s u y C e r i a s s t e s n s - u e r c s r i u d d c c r c T t G c u k b d g i o e , a a l n e t e d e e a . n h l d o l e p e c e p d l t w e d o l n p e e e u r a d h a h e l p n s r u o o e s r h o a r i o e n s T t T f s c a c a a e b b b p b l i i u r B n . , d r o r o p d i s t n t e t e a e u n r a n c d b a i b t p o d o e n b i h w i l p t m l n d t r v a e u o o w l l e r m a o a e a o b h p r h r o u t y h c h t i l e t t o f t a a o c f m e g d c r a f s r s g r a f e a h t f e n e e m l u o t u s a e e o t h t d n o r h a c h o s d t i d w e t n h r n e y l e o s T e n i t l f a l o t t p r e l e r y b d l o h t a s p n u m s i a u s l t . h d d l a a t i i s t e n r i u o u d t - c B a n e e k n a r p l s e o e l l o w i e f l n i a m e a a o l r e e o t i l b b i b s l , u . e s m t c e u e s r h n s p i r a f e r p t s m v f b e o m s n o e d e s o s l b a t y e a r y o o s u u t r v g a r c e u i e f t t i h n e r e t b l c g D o t n e t m l d d t i c n r h h a a i A e n v a l t t e u i e a r e e m m a r n a i p n b r l n e v e b e s s p i . i u m n d t i r i r t o l i e e o o s i s e t t r a t . e n r e m a b e n n o r T T n o h t p c a u e e i t n t o o e n r t p i m h i i B n n C m n f n t t r b i s s s o e a i s e g e e e i l u T R t c c r r e r t a e e r r t u h l l t m e u s e e e p t c b e l e e l l e e o c g g d r l c n l a l f e o n e r b h f h h h e n n r t i n a u a s o o h o u h h u v w T T f t t c c c c d a a d o d a e b u r n f e o o s y s r u * . p e d a - . t g g g i r f a - g - n s r r r . o n n n d o r o l l i i i a e d T o o n n o c c c s o o p n e e e t t r r r n e l l m m e U f f m u s s p e e e c a r r i i i i r i i i d y o n A t A a * C p p p i r P R P R d e e c t i d r o u l P N c n n i I y f r s o t e n e n e v ) e o o i d i i e l c d t s t t y i u e r r l e h a a a m l l e c l l P D d g h p i i v n a a c u i I t t l e l u r d r s s c e q u n F n n n a i ( D E P I I f o ) d 0 t t e s 0 t o o 8 n c , o o C e f 1 l p t $ t r e a d n r s o e e o e t T t o n i f s d a l / e n 0 r r m 0 e i 0 a u t 0 p t 6 e s , 1 e a n 1 1 i E l d e / f $ $n ( t e l n b e a l i m a n m i v r ) ) a t e A T T n B B s C o r n T R C ( ( e g i l b s p p a b t e a a u r r o D T T T R e O v r m E o 3 e p t t o r C b 3 a c u e e r a 0 . , t t g g T 8 s c r r i e s - t l a t i a a g r f 7 e r

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Appendix A - Page A-6 BMP for Lead at Outdoor Shooting Ranges Bullet Trap Manufacturers Con’t.1 t e y y ) a t . i h n s t t h e s t e t a n d h e d d p n n t t a e y s u n y e i 0 e r . o r a c t . u a i s t i a n d 0 f s f r d q s s r m i e n r d o n i p 0 p r r e e p c , u , u n t a e t e l a a o m u f c a e 0 d r e r o e s s t e . a o r t . t o a c m t p 9 n c t g e a e a n d s d o s s n e C a s b b f . u e n i e m d - e y n n f t l n i e s p i c l d o q o o e n e g l t s e p n e o t i u e i r e a c i i e d t a m n ) e v n s r t o r g o u d f o s e i c u y n a n a f . a o e , : p t a d n r e f b l r o i i i q d e l o t c e h p e i g a s a i a m n g r l d r i e o r c i , a y o l g n n e e i m t n e l b m w t i x n s m o f v b i . n n c i b a u p d t r t a o i o , e d t a o n m e w G g l g o t c s y l a . e l r o i i i e e v t p n h d o e l t o s L E c e i u T c g s g t p s l l o a i o . l e c u g n a u e p u r i r ) ) f e n u v p e u h ) e o d e o w f 2 s 3 o d a o a a d O C S S b ( ( r r P E P R 1 l t r e m e n y n e i h . r e e ' t s e t v t e . a t e a e t 4 d t s p e f s o s s c v d e h t s i a 1 y l s e o r g o t d t l n a d e a i d d n s s s n o a l - s e i f d u e l n i e r e n e e l u l e ' e o n b s l u e a h n e e e s m o n t z l f l 2 t i i n r i o a a r b h l v t o o s t n a o p g 1 i n a i ' b r u S e a T a t p c e e t r a s e n i o 2 e s c x r i t s n , p s h s e i b h i a t t r d i v . t 1 t m . t f s e e r o i r m i e c i T e n o p e g a r t b - o y h l o z c d e m e n v l c a t i o t o a t l e s a ' l n s t l o e m . r o t i e u r e d n s t f t b N 0 i a s r o n e c d d b g y a s m w u a i d k 1 t g c o a w n e s c y D i ; . o o t c r e e n t m t a l a m i t s s s p p s e h l n a a i e . n a o p s d a e a a n c r u e y l b h ; s g s i e t o d r r a l f i n c i t m t t n r c b e u e d a i t a h e k t m e a d t l r a a d n s s d g n f a l c g t i e e g p d d i - i n n a r e r a a e e n c u f s t h h h a e n v n f i u r r e l r a o e u i i r h a e o T T f T f f t s c s s d a a a o d q g g h r r r p g k ) n a . a i r p e c n n T r e p u u e f i g g R S ( o P s e e n n s - e e n n u u r l r i i l l g g g e a o h h t t o o a c e c c t t S o o l l s m a f f s s a a r i i h h i i r o U A T t S S M M P R P R d e d e c u i l g r c n P i n I p n t p i i o h N Se f f s o o t t n e n n e ) e e o d i e e c t d s s t i y u r r l h e a a a m m l e c l g d P h h p p i i i v a n c c u i t e l I l r u r u r s c e u q u q F n n i ( D P E P E I s f e f r o r o a u e t e t p o a n t s t i h y l e o t o t / f t i o 0 C f o n r w n p 0 o g e r o f i d a 3 s h m , a r s t t r e e o 1 e i t e T n o a r r $ n f ) ) a d e i e a l d d d d / n v s o m c i n e i e t i n 0 l e t f t t / i a e e 0 c c g s 0 0 c c p t 0 i e e n p , 0 4 l e l E r e o a a 1 6 9 e p e P d o r f t $ $ s s $ s ( ( R t / t e e s l l n l n b e u g a i y l B r m i r s a r n a e l i e m e v v u a s e D t b o t n A p n c b s a a r o e u y r T C S G R R e r s n e 9 1 p r n o 8 0 a s u e s r l 4 2 t f s u t T e 7 6 c e i i - - n t a p n D 3 6 f a s o e l : :

a EPA does not endorse any particular bullet containment device or product. Information on this table is offered to offered is table this on Information product. or device containment particular any bullet endorse not does EPA t 8

0 l literature. marketing vendor on based is and options trap bullet common some of understanding general a for readers l u t t t l l t s C 7 7 D c c m e i n u u u a a e g a ) ) s i w g t t t n B

i 1 g 6 2 n p s n n s a M a i 1 1 e o o a o r o y r 5 6 C C C C C C S ( ( B M

Appendix A - Page A-7 BMP for Lead at Outdoor Shooting Ranges Bullet Trap Manufacturers Con’t.1 e t . l h r o t a t g - i g e m h n 5 s n b t i w g i e t l h t 5 b t s n c n i i s d , u d m y r . e r y g e a w n c e e g s n t d m . m i a e i d e s o t s r o e t v e e n r r p y o ( m i t d f r . c o t o s a o g o t r n n s o r n e r o f t h l n n p e a e l e C . a i e t d s e t ) g c u e n l o l d a n e i n i . i n n c b e e p a m p d b y v u t o r a a n i r c u n i g t o b r n e n y r e e a i o o r - v a c o f h o r v e d l r n s a n p t i i l u m t v o o e e r n e s e a t m t n c o s n e o s n g - u t g s i n o l G e p o g d i h l l l s n a l s t l w n l c c o c n a u a s u e u r x a o o o e a t c c d o a d e g C C m r L U F m o e e e t f u h d h h n t . t t o t i , r e n t m d r e l e t l s n l o s g l u t n a e i m e n t g a u n n l u n e a o i e i b i u l i l c e d o r c b s a t i s w u r t e m n t m m n l e n a e i e b l d f a n e a o a a d x i n n s o e r o c n o r h o i t h h i r r t e t a o t c s e i c a c c s l T l o i a i n h m e p t i r l t m t w i e b l . i a e f s s e r t r u s p c e i r e o e u l e h s c n o p t l s o a e e t a o l t d r o s f o y h a c a u e i d e t i l i l t g r n c l t i n t e d z i b t u h i i u r d n a n L e n g w t D T I c d a e a s e i u e y l m h a t t e t i t n t r A p l h o r g u r c l t . i t n e a n e r w o i c T a N r u u . e v r y r b e r o m i s p l . s t e S b t h d s m n e c s p s m c e e c e t e l t t d h e e p d d d l n a a o s t e m a a i a h h a n n n u l l c o h p y s h r a i t e w T T t t c c s s a a a b p p i l r r t l o a f h c o s ) ( s 0 p e g 5 a n g . r u u l a ) T l o g s s t t o o G e e t t o l l U d f f p s s i i h M i i n u a S ( B P P R R n i d e d e c u n i l r o c i g t P n t n I a i l h l p t g a i p o t i e s h N r n S Fl I f f o o s t t n e n n e e e o i e e d c s s t i u a a a r m m l l l h h p p c P i i a c c n t r u r u I s u q u q n P E P E I f t f o : r s t d ) a p s n h n t e a o i a o r t t t t n i t f f f f i t w C l a / p i f c r r r r r s 0 d a o e a a a a l e r e : 5 e t e e e e i : t e i s t : T r 2 : y r t n n n n e s , i i i i e a r a y l l l l c e 1 / / / / r t p v D W m $ c 0 0 0 0 y n i D W - t l l t e u 0 0 5 5 g 0 o o i s c d 3 4 e e 1 2 t t i o l l 0 , , , , s r f f o E s s i i i i w 8 2 2 2 2 e r P T $ $ $ $ $ d p ( P P R R M e T s r r l M L n o o T b I t t g p a r i a a A l l l i a s a r N l u u a e M T s s u S v T a a n D p p c A e c c a a a o r h l n n r r T T T G B E E m s r o e 0 7 1 e c p m s r g . 0 1 0 r m a e a s u n 2 2 0 t e r o t a m 9 1 7 k s m c T c - - - . e c y o R t t a s 3 9 8 u f h s s : : S r e p 3 9 6 t t y l e u T l a 5 9 5 c c m s D e g n r

- EPA does not endorse any particular bullet containment device or product. Information on this table is offered to offered is table this on Information product. or device containment particular any bullet endorse not does EPA u

a readers for a general understanding of some common bullet trap options and is based on vendor marketing literature. marketing vendor on based is and options trap bullet common some of understanding general a for readers e t e ) ) ) g l t t a a e t n i v B 3 8 3 n v n n g s a a e M 6 8 1 n o o a y a t o

n 1 7 8 4 a J s C C S S S ( ( r ( R

Appendix A - Page A-8 BMP for Lead at Outdoor Shooting Ranges Bullet Trap Manufacturers Con’t.1 . l y e b n n d o e s s t r t m r n e e . o e p n f d . r m e n e t e o g p m p z n i a o r e a d r C e b a v l y n a e b r @ t a i e c r c s r n o t - n e e i r o k C i G a t s B a w s E o n m : l p k i g a i l s p a i s c a c e e t m S m D E R r r g . n e e f f r n f e b v i o e y e o v b o d e b n r r b n e l e u n b a e r a r d u a f h u u n r y t e e , r o d o t s r a m a t r i e h i l o n y c e r c u r c l o n a i b t m u r m u i n e t o v p r d a o e s r - e t o g c h t d t i d m r n c v t t s e t t n e i a e e e j a o s o n t x p t a h i e h w h o t c r e l b o c e e r i r l c r T l c r m c e t y l o d s w P r a l u s e . t s e . c t n s n e . i r f o b i e c n o p s r a a a b i n c e o e o D e l i p m , P o w l h t r s m l o i n y i l g t t n c l o i P a u e i t e e f g t t n t a c e i e a A a t r h d h n t n a s r r t i t ) r T e c e u e t s y r e l r l u d i i e r t f g S s t a a u e i s p i , r m p c e f e r e t n b d n l l e e g u l d n m i e a m b o o r f h h a n r u n o o t n c r e u i n T T f t c c s a g b m l i ( u r r d p e s o & ) e r s f a s e g t r r l l e d t m a e o e d T o b t s n e s t k i n c l d n l m f f e u s c a i a U i n a p a 2 o b r o a j t c a C h ( u r P R 1 n i d e d e c u i l r c P n I t o N f o t s n n e e e o ) i e d c t s t y i u r r h a a l m l e l c g h p P i i v a c n i t e l I r u r s e u q F n ( D P E I f o d c i e t f i r ) s t c u o o e s C o p a f p s e a d r e e y m r t T ( b a a u n s m q g i e i t i s r s s a e y E V d b t e l e s l l n u b g a B i l r i s e a P e h v P D c A t A a T C S , i , r 3 4 m d k n e 2 2 p o r a s o d , c 2 2 a i . u o t r r e w t 9 9 C t - - a e T R c o t a B h 9 9 9 k a t r : f S x c 3 3 3 s t E t e i o l u 0 2 2 c l O a

x EPA does not endorse any particular bullet containment device or product. Information on this table is offered to offered is table this on Information product. or device containment particular any bullet endorse not does EPA p

n C readers for a general understanding of some common bullet trap options and is based on vendor marketing literature. marketing vendor on based is and options trap bullet common some of understanding general a for readers p c 2 a u ) ) r a t t a f 1 t : p 2 3 3 B . e o t r n l i x 0 a l M 0 0 c a E o t A a a 1

u 1 . 7 7 n V 8 C S b ( ( M P F F I

Appendix A - Page A-9 BMP for Lead at Outdoor Shooting Ranges Bullet Trap Manufacturers Con’t.1 - , l l ) l r h a o s d t e m s x o t n m g i s f c f n e r i e a t f m w o p n s l t 0 t t i i o y . e o n i s e t p m 4 s p n 0 a s g t . t s s a r b t n n e n 1 d y s s a 0 s u e a r d d e l a r i p o r s b , a r o e s r n i m f y ( i o n e e a p a m e a , u 0 r d h i t g v w . t a a r s t a r t r s d y c p e f s i t 0 e a p i a y e t r o e n c m r i o t m u l r L r a e d n 1 t p e a t p t e a s d g o a o o c l c l m a e r e i p n t r g e i f s o a t a z t t r e d e n i o i d a u y s r l b ) r C o n o n u t l i t n d a a . t g n a s i T m o e u c a y e r o a r b l t n e n o c n h l s s s u m t c y d i f t d r p n m t h a a c o e s a C R a o o r t t c e i a n o a e e n r s e e o s l r t s m m i u l p o v e s e f r s h s m t o e b s e e f g g a l r . n a i m t o s o t u t t i a i r t o e 0 t e a b n n n n i a g m n a f n u y f b e i a i i x i m b s v f e 0 t y u t l t e y d r P n t i a o m n f o . h n r o i a u i i o o m i i 0 , c i u g s o l e d d r s l e L t o , k r c a ’ G c s d t d r o l y e I I o n c o e a p n d a c r n o 0 . p i o m C n c c c a e o i n y s e T T h p e n u s l a s e s c o h 3 T u i e e e n a a m v v f c s a d a q a e S S S b m m m i l l ( i u r r r r U R 1 . s d d t s s d ) e g l . n n e f e e l f r n r d l i n f a l l i a o g a o a e a e e r g a l l u l i d l r c n o h f , l 0 k f y i n b c u e s i b t l t e e i a d l c r e u 1 y o e t i n e r e l c s c t e t e a r n r r o l b c t h u a o f a n u a s a r h c - c b o r l t i u s g e e i s o i h T t o , o e r T t e g p i n e t , p t ) e e i r p t t s : n e d w c m e r f n r e . s d r i y a , e l d h r i r i s e s a b t r p e t e f r e o e s f g n h i d l g a u s e c r b e a t z s f c , r t t b i e i o a 0 e n e e y y f b l g a n e l t c e n c n w e b t g i n 0 s s l a n r b n z , m l o a t u d s o o o s t u n i d a d d 5 a i l / a r o l ( r s a l e u c e t n e t r n e a v e d n e t c b s r o l a t e r a b a a s i t e e R i e s a d R D e e . d d a R a t m ® c n n a f v i p r p y n a i i r l n y f s g n r n A g r i l B e r i e f p u s o N l c d a o e e a n n a ( r t p i i m i m i ” p t g s . S n o m t a e a t o e i s O p o e r d s s a a a 8 t o e g h s s d r g o t t t o / l d k i t l a e m g e s a t C l i l r I I n e e d p t c u l r t c r l n n n o 3 i e i n t l u n a T T A h n l n p e n a a u u a o s o o o h h a a a g s w T t c c c s a a o a d e O g S S S b p b b n i u i r r r p g a n l r n i 0 o & T c u n t 5 r & l . f s o G d y i e i a i r t o n e n i g g P l n & e a P l e a i n n n b t o e n i i i a i r r i d u t & s t g o c i d g e : o h n i t o g a t m d c u n e

c o ) e l o l n l c s m a a a f

p s a c c r m i l h u r r r a a u U n n A A T T T T c S i ( M F R I A d e ) d e n n l l c u o o i i l i g r t c w d n a P i n n I n e p i e t n c t p i i i p s r o h e e P N d d S ( f s o t n e n e e o d i e c s t i g u r l a a m n l i c l P h p i n a n c i t I r u a s u q r n T P E I t f o o o f t s , r n o a o t g e i C p p n s 0 i l a d a e 2 r r n e t d r 5 t o T i e f $ : t r a y p o g a o r b m n x d o i o i 0 h t s t o n d o d 0 t r s e d u i d u i 6 u l p r , E o n c f o i w p a 1 n A V $ - - - - i g , n s i l t l r - s e o s a e l e e l ® r o i n s b i b W p h T p g b F a s i r a l M , a u S i r ® , p T s r e s M & r t l a T R o T s e A T N e t o e i a v s e e r t R t s D i d c O s I k C A l i g g e m k e i t - i e s x l c l C n n t p c l r I c c a o e l a a a A u a u l e L a a T C G S S B B B F P E R R R t 0 S m 8 r . . e o 8 e c D p c c 0 r . 2 . r n 0 a 4 u I p 9 S r m e 5 t , . 4 a o T c 4 r n p 9 A A m t c . - 9 r t a . e a f - C L m e r 6 s e p l : 6 u p , o 3 l T , n t

EPA does not endorse any particular bullet containment device or product. Information on this table is offered to offered is table this on Information product. or device containment particular any bullet endorse not does EPA readers for a general understanding of some common bullet trap options and is based on vendor marketing literature. marketing vendor on based is and options trap bullet common some of understanding general a for readers 3 n u r a 7 c d a u C t r : s 7 r l a r n a e i ) ) B e t r F : e o 1 i a @ 1 1 M p n r

t 1 x p 0 t o 5 5 o o r u f e m a u 6 9 9 n A s C C S i ( ( F E R 1

Appendix A - Page A-10 BMP for Lead at Outdoor Shooting Ranges

Appendix B: Lead Shot Alternatives

Another method of preventing lead contamination at pistol, rifle, trap, skeet, or sporting clays ranges is to use less toxic or non-lead ammunition.

Much progress has been made in the development of alternatives to lead shot for hunting uses. Information gathered since 1976 on lead poisoning of endangered and non- endangered migratory birds due to lead shot ingestion led the United States Fish and Wildlife Service (USFWS) to consider several alternatives to eliminate lead poisoning among migratory waterfowl birds. A ban on lead shot for water fowl hunting was phased in beginning in 1986 and finalized in 1991. Lead shot is also now banned for shotgun hunting occurring near wetlands in national wildlife refuges. Starting in the fall of 1998, the USFWS banned the use of lead shot in waterfowl production areas. Additionally, many state- managed hunting areas require non-toxic shot for upland/small game hunting.

There are several alternatives to lead shot on the market today and still more alternatives are being developed. Before being used for waterfowl hunting, these alternatives must be approved by the USFWS. Bismuth, steel, tungsten/iron, and tungsten/polymer shots have been approved by the USFWS and additional alternative shot materials are in the USFWS approval process. Most of the ammunition manufacturers in the United States, as well as the military, have developed non-toxic alternatives to lead. Research in Europe may also result in additional non-toxic shot alternatives from which U.S. shooters may choose in the future. The following pages compare lead shot to non-toxic, alternative shot.

Appendix B - Page B-1 BMP for Lead at Outdoor Shooting Ranges , . d e s t l r e o o o s h g m r u s , d e ) . l y h n n d t y l o n t u a i u o l a g i m t d m s b n m o i i i s a i h g l B e y b l - l s e n b t s o f a a s t n d r u o f e e p e n l r l t k e o r a s c t a a P u e , u ( c m c s e m d t f u e o e n a d n r d r i n s e n i t p e a c a r f y i s m i e o b d g y d r i t e v n e p n a o a a m h s s s o h , i t t t t t e s t s i T s : i e h n n . n n n l c g d i s e e e e e h h t b . n s t t d i i e a g m m m u u m m m a d r e n d l i m u a l m m m m m m m l e a s n e s s a i c o o o o o h i i r e o i n f T c C Cs m m i B Cs B C C L h t e l u b m a l i s l i r a y y y b t t o t t t v i i i i i f l l l l l a w i i i i i o b b b b b y d l y a a i a a a l l l l l l e i i i i i t d p i a a a a a a p m v v v v v e i u A Ay s Ay A A L Re s e v i t a n r e t l a e e e l l c c c c c a n n n n n a a a a a h c m m m m m i r r r r r h o o d o o o d f f f f f w a r r r r r e e r e e o e e e l t a P P P P P p o d t r c c c c c m i i i i i r a t t t t t o a d s s s s s l c i i i i i i l l n l l l l l l l l a e m a a i t a a a r a Sd S B Be Be B B d n e i - d 5 5 5 d 0 a 2 2 2 2 2 e 0 o . l k r r r r r 5 e c r e e e e e 1 a x p p f p p p $ p o o t t t t t b † e s s s s s x r @ d o o o o o o a n s C C b C C C u / s e l l o 0 x e e e e e 1 1 1 r t t t t t e 0 o x . x x a a a a a h b 0 4 o o o o o s 1 m m m m m $ B B d B B B i i i i i o / h - n x x x x x b t 0 / d d d d d u o o o o o u s 0 0 0 r r n n r r r n n n l o . l r 0 0 m p p u u p p p u u u 5 . . e s p p o o p p p o o o i 2 3 5 h 0 A A5 $ s $ $ A5 A A B R Rx 1 Rx R R l l l / a a a a a h i i i i i t r r r r r u e e e e e t t t t t * * * m a a a a a s h h h h h i t t t t t M M M M M B n u u u u u i t t t t t t d d d m m m m m o o o o o a a a a a % s s s s s h h i i h h h Product reference within this table is not an endorsement by EPA. is not an endorsement by within this table Product reference Costs will vary from store to and were valid at the time of manual development. i i i % 7 e e e e e * Approved by USFWS for migratory waterfowl hunting. † 1 3 9 S Sl B B* Sl S S Lx Ld B* B B Ld L L Summary of Lead Shot Alternatives

Appendix B - Page B-2 BMP for Lead at Outdoor Shooting Ranges e t , r e o e o l g f h n e b n e s t e y h r n a a t t r i l s g e l i h r e i i l n t e l n n g e i c w n i h I a i h r e t r t r e e o w e s v r i l t w w a g i e k n o l t e . a o F s t e d o l r w t r c o e u n v r h n d e a c s e e h e b l . s o w l g i a r e a t e i c f b b t d f l n o a d a , g a l g i m t s t r e l u t i m n s n . h i a g h o s i s e a t t g s u a % a s r n n g h u d i g a i m n i 3 r h e s r t s o t s s a i h a e k 3 e s t n a s e n l i n e o l i s d y o l t m m o h w e u i r h i t a u t , n d t l h t t u t e e e g i e l o s a o c e , o t t o e m t i n v b e c h t n t s s e n e b g e u r n s c o h o p r r a i e l p f i t a a r y b l o - e t l e a i e h f o f p a t f y , r t m f a e c i s e w t e i w r l c g o a u e r s m e s . b e n r t t n i e s t t t i e n c r i i c e i g t e s . y h p n o o o e n c s o l n h n t u t n g g i , d s u T h h p e e r e a r s T b e g s n n t s s e g b f s s i e i e s m t t t r , n i a . v p t l l i e o i l r t . l s t v o o m o e e d e e i e e h s o m e l d r t v n l n a o o e o c e e h e e s u d o a c t t t d c l u e u e s s h h e h e e n W s s s s a a a o C g S S p m h h u l i u r m o r f d . s n e l e a b c r c a i l t u i s o a y t e s v i l a i m d b o y e l t i a d r l i d o h a a t p v e o m A b i R o n d , . n s t s u s n a i e o o f t g i n d t o n m a e a a h a e a r c e r u r i s h e t r t i L g r l e w s o e e y r e . m g e s b g s c t P n e A n e s n i e c o t n c l a c h n d n o n t t i n r e m n u t a a r r a t o a h a e s o c f i e N m f f d n r i r u d v i i a o e d † t d e f ) e e v c r t l l i E P P t e e n b f a n E f n p c a a r i e e u c t S t n e i e f g s s o i p N t i e l e s w r n o l o t t O a o g o a h e i C e n s C S b m ( B r I r e d p e - r t d x e s a o p o o b 1 l p / C x e o 5 r o c 9 e f ( . t B o 2 a x 1 d x o m $ n i o b / u - x b ) / 0 o o d s 0 0 0 r l . l e R 0 0 p t . . 5 e a p 5 8 6 1 l h A 2 $ $ s $ p l a i r e t a M * l t e o e t h Product reference within this table is not an endorsement by EPA. is not an endorsement by within this table Product reference Costs will vary from store to and were valid at the time of manual development. Summary of Lead Shot Alternatives – Continued * Approved by USFWS for migratory waterfowl hunting. † 1 S S

Appendix B - Page B-3 BMP for Lead at Outdoor Shooting Ranges f i . s y , l n t t n e e b . o e r e r f g a n . h e , n l o e , i i t a l a . f e c c e t d l s a o s b e t t o n m r r e b v h n a o a c o s l a i o e d a a i s u e f f h l r c l i d h a l g s t t y d a d o d l e a o e o l l e r t , t v a n e s h e e s i e n m m d a e a r l n s y e u a d e o l L t l u n r r s l y a c e e l s r o o a i s m e c e k . b d u r i b d e e l w e b l o c d n t o n a t r f n h t s s a t s a I i e n h a e i a T r e o c t c a t c h d h t . g h t . t n c u r o i l l . t o y s l a o e g t i e h t e s o h w m i n n e s b e m e i s n m h w f t s l n a e e s h o p l a e i , s m r i t r r r e s d s t l i e l d u e u e / l a e u n e e r e n r t c q n t n a a r m e i a s e a e n s e s t e l c t t h o o i t s s s k h o , s t f l t t , s t t t e d r n s l s c i e m r d t n n n n n b r e o e i g h e p s r e a u e e e d s e e e m n n w g s o g e e h c e d d o u r t l u w u t m m r m m m k n t e h i e i p u t o o s a a u t a r s n b t m m m m m o s h e e c E o n h m u t e e s o o o o o l n h e e b m u o a o r h h n s t A t t t T t A c c a e C Cs h i i Cs C C B I e l b a l i a y y y t t t t t v i i i i i l l l l l a i i i i i b b b b b y l a a i a a a l l l l l i i i i i d a a a a a a v v v v v e A Ay Ay A A Re y y . t l f i s t d o s a s n a n t e a e e l t e n c g i v a f d u i f d i t i h o o r t c n e t t r e g m h i f e a a f a t T s h c e a t . e s c i s i d s h t e d a % a e e e e g , n e 4 c c c c c i l r g s d 9 i n n n n n i e l d i r s a a t a a a v t t a r s i t r r o e c r m m i m m m a o h r r r r r a w n p c p s o o c o o o o y o l f f e f f f t r r i r r r r r n H e /

h † e e e e e o n e c n y i r t i . r P P P P P a e / t s t a n e n o s c c c c c n e n i i i i i i e h g t t t t t n t h e i s t n s s s s s s m v i i i i i i t l l l u l l l g d e l l s l l l t o e n s a a a a a a r f r h u e e t s o o l l B Be P Be B B 5 5 5 0 n 2 2 2 2 2 1 / o r r r r r r 0 0 i e e e e e / 1 0 . p p n p p p 5 n e t t t t t i t 2 s s s s s s $ d o o o o o g e n C C C C C k @ u c t e e e e e ( 1 1 1 a t t t t t s x x x p a a e ) a a a x o o o o o x x o e m m m m m o o B B B B B i i i i i b r / b b x x x x x a 0 d d d d d o o o o o d d 5 r r s n n r r r n n n . t n n p p u u p p p u u u 2 o u u p p o o p p p o o o 6 h o o A A5 s $ A5 A A r r R Rx Rx R R / * l l l n n a a a a a i i i i i e o r r r r r t r I s e e e e e / t t t t t g n n a a a a a n e o t u r M M M M M * * * t i s l l l t t t t t

g Costs will vary from store to store and were valid at the time of manual development. manual of time the at valid were and store to store from vary will Costs

e e Product reference within this table is not an endorsement by EPA. by endorsement an not is table this within reference Product ) e e e ) ) . . . . o o

o o o

1 * Approved by USFWS for migratory waterfowl hunting. waterfowl migratory for USFWS by Approved *

t t † t t n % % e e e e e n n n n t h t h t t t h h h u 0 0 o o o o c c c c T 4 6 () ( S S Sl Sl ( () (

Sl S S Sl S S Summary of Lead Shot Alternatives – Contiued – Alternatives Shot Lead of Summary

Appendix B - Page B-4 BMP for Lead at Outdoor Shooting Ranges s t s n i y o e e a a t l r , l n r h s l h u t s t a a t e e d i t n a i e p r h e c l r e r , , o m n i t e t s t i l e t y a a e e d m y a f l l t a c b l n n b o m g d u u s o a h e a u a o c j o r y n a n o s p l t i e p / m o l e y t m e a l a o y g r r l w r l n n n g m a h p s n p u o m r p i i e / a e t n o f d t l i o p m h d n c p c n s n f t o a g m i i a e t n e a g a t r f m a e f p s b e e f i r y n s e u t o o o d y p l t m o h o u g c n u n e t l m t o e e a t a r l n i s a a s a m l v d t d e o u c u m A g s v a t t s e m , h s n e o f t s i r b d i f s r n S n c g i i a s n e , t c u t p e r o o n h e d U . o s o u i s l r r i p e d t m e i n T t h d d / i p r a y b v e o e a r a l e s o n n o e p h t h . r r o o b e s t e s u s o h s o c t n t o p w p l i . h , e f a / c l t c s n o y n o m s e c h r e i y l i n b t g r l b A e v i n a T S H d s t x m a e a n o i x e t u e f e a n o a m r d c . u t t s W e d . g . i s t e l h e l e - e t t t s a f r g r t t F m e o i p t s n r o o o e r t e e n s a o i S w p e u a o s u h h h h h u e n A T t t t t c s s s a C b b h m n u i U l b a l i a v a t o y n t i l y i l t b n a l e i r r a u v A Ce o r i / n e e t c s g n n a u t m r o o t f r e e l b P † a r c i a t p s i l m l o a Ce B r e p t s t o 1 e C x y o e e t l B a b d a l m i n i a u x v o o r a R p t p o 5 A 2 Nn S W F s f r S o e * r U l e u a e t e p n c i h y m f t t a f y l l d s u a i m o i e n h r o p v t a r i / e f t t e n m l e a c e a k t e s r v M r s u a o . t g o r t e i o m n r p v o h u a p a h o Tr t V s a S h Product reference within this table is not an endorsement by EPA. is not an endorsement by within this table Product reference Costs will vary from store to and were valid at the time of manual development. Summary of Lead Shot Alternatives – Continued † 1

Appendix B - Page B-5 BMP for Lead at Outdoor Shooting Ranges s e a a t . h u t t d i s t c i t i e u s t p , i d r tion n o I l t o e r e a v h p v h e c t e r s w i d a n o i h e t g H l s n e e g i . e n e R t i e b s p v i n t i o t l s s T a e a u n l j . v r s a d e e s n t i a d m l o l e i e a l s l t a i i t b a s s s r n o t t t t t o d n e e r r h t n n n n n n h p e s a t e e e e e a t l r n r m d g m m m m m I a e l a n i t s m m m m m e i e e h l o o m o o o h h i g n i T T s a C Cs i l Cs C C e l b a l i a v a t o y y y n t t t t t i i i i i l l l l l y i i i i i l t b b b b b n a a a a a l l l l l e i i i i i r r a a a a a v v u v v v A Ay Ay A A Cs e b s e i a c y n n d a i . t a e e m p f l m o o r b l e o a c e l f y i t r v n i a e e a s . v l p d n a e m , e e e e r e g t d t c c d c c c o n e f s a i n n n n n r y e e e a a a a a e l n t h b p t a o m m m m m o t r r , r r r t h n l e t s o o o o o e c f f f f f u e s j r r i r r r e e n v i t i v e e e e e t i s † s s n i t P P P P P a , o c i r n n n t e i c c r c c c e a f t i i i i i a f t e t t t t v h t e t l s s s s s e e m i i i i i r l l a l l l c l l s s w l l l o n s s f o a a i a a a n e e n a S l l i B Be H Be B B 5 5 5 2 2 2 2 2 r r r r r e e e e e p p p p p t t t t t s s s s s t o o o o o e C C C C C y e e e e e e 1 1 1 t t t t t l x x x a a b a a a o o o o o a l m m m m m i B B B B B i i i i i a x x x x x d d v d d d o o o o o r r a n n r r r n n n p p u u p p p u u u t p p o o p p p o o o o A A5 A5 A A Ns R Rx Rx R R y r a r 0 o n 0 p o 0 r m I 2 / e - t n 9 e 9 t d l l l s 9 n e e e e e e l l l t g 1 o e e e e e a a a a a n t t i i t t t i i i n s r r r r r r a s s s s s u a r o / / / / / t e e e e e f e t t t t t g n n n n n s l s a a a a a e e e e e a a t t t t t S g v M M M M M s s s s s n e o W i t t t t t g g g g g r t F o o o o o n n n n n m p n n n n h h S h h h i a u u i i u u u p u Tn T T Tl a T Tn T Tl T T S S Sl h Sl S S U Other materials that are currently being experimented with as alternatives to lead molybdenum and zinc. Not enough informa is available to have included these alternatives in the above table. Summary of Lead Shot Alternatives – Continued Product reference within this table is not an endorsement by EPA. is not an endorsement by within this table Product reference †

Appendix B - Page B-6 BMP for Lead at Outdoor Shooting Ranges

Summary of Lead Shot Alternatives - Conclusions

The table clearly illustrates that a number of non-toxic alternatives to lead shot exist such as steel and tungsten as well as alloys and synthetic polymers. As demand for shot from these metals increases from migratory waterfowl hunters, it is anticipated that the costs will come down. However, alternatives currently cost approximately two to twenty times more than lead shot.

The ban on lead shot in hunting situations impacts target shooting. The alternatives to lead shot that are now being developed for or are already approved by the USFWS for migratory bird hunting could be considered for use by target shooters.

Although alternatives to lead shot are now being used by hunters, it is rare that the alternatives are used by target shooters. The limiting factors appear to be the expense and performance. All the alternatives to lead are much more expensive, some prohibitively. Unfortu- nately, the least expensive alternative, steel, is also perceived to be less effective.

To encourage use of lead shot alternatives, some ranges sponsor shooting competitions using lead-free ammunition, but these are rare. The use of steel or other alternative shot is a recommended BMP in established sporting clays areas at which reclamation of lead shot is difficult to impossible.

Note: Switching to non-toxic shot may create additional issues. For instance, steel has an increased risk of ricochet. Switching to steel may require additional safety features and/or operating procedures.

Appendix B - Page B-7 BMP for Lead at Outdoor Shooting Ranges

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Appendix B - Page B-8 BMP for Lead at Outdoor Shooting Ranges

Appendix C: Sample Bullet Containment Devices

The bullet containment designs in this appendix are sample designs for the containment systems mentioned in this manual. Design systems may vary from different manufacturers. Reference to various individual bullet containment devices is included in this manual for informational purposes only. EPA does not endorse any particular bullet containment device, design, or product.

Target

Bullets impact and are contained in the sand Di recti on of Fire

Sand

Sand Trap

Rubber Granule Trap (Adapted from: Bullet Trap Feasibility Assessment and Implementation Plan: Technology Identification Final Report, U.S. Army Environmental Center, March 1996)

Appendix C - Page C-1 BMP for Lead at Outdoor Shooting Ranges

Gel-Cor Bullet TrapTM (Provided by Super Trap, Inc.)

Escalator Trap (Adapted from: Bullet Trap Technologies, Action Target Educational Video Series)

Appendix C - Page C-2 BMP for Lead at Outdoor Shooting Ranges

Vertical Swirl Trap (Adapted from: Bullet Trap Feasibility Assessment and Implementation Plan: Technology Identification Final Report, U.S. Army Environmental Center, March 1996)

Wet Passive Trap (Adapted from: Bullet Trap Feasibility Assessment and Implementation Plan: Technology Identification Final Report, U.S. Army Environmental Center, March 1996)

Pitt and Plate (Adapted from: Bullet Trap Feasibility Assessment and Implementation Plan: Technology Identification Final Report, U.S. Army Environmental Center, March 1996)

Appendix C - Page C-3 BMP for Lead at Outdoor Shooting Ranges

Steel Bullet Trap (Adapted from: Bullet Trap Technologies, Action Target Educational Video Series)

Lamella Trap (Adapted from: Bullet Trap Feasibility Assessment and Implementation Plan: Technology Identification Final Report, U.S. Army Environmental Center, March 1996)

Appendix C - Page C-4 BMP for Lead at Outdoor Shooting Ranges

Appendix D: RCRA Regulatory Requirements and Interpretations

Timely separation of lead shot and bullets from soil at active ranges, recycling of the lead, and subsequent redeposition of the soil on the active range is exempt from RCRA regulation.

1. Reclaiming and Recycling Lead Shot

EPA’s Office of Solid Waste issued guidance in 1997 indicating that lead shot, when recycled, is considered a scrap metal and is therefore exempt from RCRA regulation. A copy of the March 17, 1997 letter with this guidance is attached. Under the RCRA Subtitle C hazardous waste management regulations, lead shot would be considered scrap metal, which is exempt from hazardous waste regulations if it is recycled (see 40 CFR 261.6(a)(3)(ii)). Although storage of scrap metal being recycled is not affected by specific time limits such as the speculative accumulation provision (40 CFR 261.1(b)(8)), the scrap metal must legitimately be recycled to remain exempt under this provision. It should also be noted that lead shot may be subject to the authority of RCRA 7003, which addresses imminent hazards. However, use of best management practices is likely to prevent situations which would present an imminent hazard. Using such practices, together with following a clear, written policy governing the facility’s recycling efforts, should also assist in assuring that the facility’s practices can be demonstrated to be legitimate recycling.

2. Storage of Lead on Shooting Ranges Prior to Recycling

Some ranges have indicated that it may be desirable to store recovered lead shot and bullets on the range property for some periods of time prior to sale for recycling.

Provided that best management practices are followed in terms of storing and recycling the sorted lead, a range that follows such practices, and engages in legitimate recycling, should be able to store such material prior to recycling without RCRA regulatory controls (see discussion below). Best practices would suggest that the sorted lead, at a minimum, should not be exposed to the elements and should be managed so as to prevent releases to the environment. Best practices also indicate that the sorted lead should be stored in containers in good condition, regular inspections of the container condition should be conducted, and the records of inspections should be maintained and be readily available. Further, best practices also suggest that the sorted lead should be recycled in a timely manner and storage times should not exceed the time-frames or goals articulated in a clear, written policy.

Appendix D - Page D-1 BMP for Lead at Outdoor Shooting Ranges

3. Placement of Soil After Removal of Lead

For soil placed back on an active range after a BMP has been applied to remove the lead, the following regulatory approach has been followed. On February 12, 1997, EPA published the RCRA Subtitle C Military Munitions Rule in the Federal Register (62 Fed. Reg. 6621). The Military Munitions Rule considers range management to be a necessary part of the safe use of munitions for their intended purpose. Thus, the range clearance activity (recovery of lead shot and bullets) is an intrinsic part of the range operation. Therefore, the rule excludes range clearance activities (including the placement of soil back on the range) from RCRA Subtitle C regulation. Although the Military Munitions Rule did not apply to non-military ranges, EPA, in its response to comments on the proposed rule, clearly stated that “it felt that the ‘range clearance’ interpretation in the final Military Munitions Rule is consistent with the EPA’s interpretations for non-military ranges.” In addition, the EPA’s Director of the Office of Solid Waste sent the New York State Department of Environmental Conservation a letter dated April 29,1997, confirming that the Military Munitions Rule range clearance principles apply equally to non-military ranges. A copy of the letter is attached.

4. Relocation of Backstop and Shotfall Zone Soil

Some ranges have indicated to the EPA that it may be desirable to transport and/or relocate a backstop in order to reorient or modify their range. This may occur when there is a need to reorient the range due to environmental concerns (e.g., shooting over water (wetland, stream, pond) or excessive runoff), alter the layout to improve shooter safety, or redesign to modify shooting conditions (e.g., adjusting number of shooting positions, increasing or decreasing target distance.) In some cases backstop material would not be moved off the range property, but to another area on the range property.

EPA’s position is that range backstop materials are part of the range and are not wastes when they are moved or relocated, as long as the range continues to be used as a range and the backstop materials continue to be used as backstop materials. Hence, backstop materials that are still in use are not subject to the RCRA hazardous waste management regulations and need not be tested for hazardous waste characteristics. However, removal of lead from backstop materials that are to be relocated or moved is a normal practice of good range management in that it extends the usable life of the materials and reduces the possibility of releases of lead into the environment. If lead removal does not occur before moving the backstop material, the lead will become more dispersed throughout the material during movement and will thus be more difficult to recover in future reclamation events.

As a range management practice, it is environmentally preferable to use soil that may already contain lead and is on an active portion of the range, which will therefore undergo regular lead reclamation in the future, than to leave such soil in place and construct a new backstop with lead-free soil. Records of all movements of berm and shotfall zone soils, along with corresponding site plans, should be maintained indefinitely, as they will be necessary in evaluating cleanup needs during subsequent construction or range closure.

Appendix D - Page D-2 BMP for Lead at Outdoor Shooting Ranges

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 March 17, 1997

Mr. Duncan Campbell Environmental Protection Agency, Region V RCRA Enforcement 77 West Jackson Boulevard Chicago, Illinois 60604-3507

Dear Mr. Campbell:

Enclosed please find a memorandum on the regulatory status of lead shot, which includes a general discussion on the regulatory status of lead shot as scrap metal. I hope that this information is sufficient to address your specific concerns as they relate to the pile of lead shot at the Saxon Metals facility.

If you have any questions or would like to discuss this matter further, please contact me at (703) 308-8826. Sincerely, Jeffery S. Hannapel Office of Solid Waste

Enclosure

To: Duncan Campbell, EPA Region V From: Jeff Hannapel, EPA Office of Solid Waste Date: March 13, 1997 Re: Regulatory Status of Lead Shot

Based on our conversations, it is my understanding that Saxon Metals received for recycling a shipment of approximately 30,000 pounds of lead shot from a commercial indoor shooting range. Smokeless gun powder is, presumably, commingled with the lead shot. The mixture appears to exhibit the ignitability characteristic of hazardous waste (as evidenced by the incident in which the material ignited when Saxon Metals was attempting to load it into the furnace with a front-end loader). You have asked our office to provide you with guidance on the regulatory status of the lead shot portion of the mixture, specifically whether it is considered a spent material or scrap metal.

The Agency has taken the position that the discharge of ammunition or lead shot does not constitute hazardous waste disposal because the Agency does not consider the rounds from the weapons to be “discarded.” As you know, discard is a necessary criterion to be met

Appendix D - Page D-3 BMP for Lead at Outdoor Shooting Ranges before a material can be considered a solid waste and subsequently a hazardous waste. (40 CFR §261.2(a).) The Agency’s interpretation regarding discard is based on the fact that shooting is in the normal and expected use pattern of the manufactured product, i.e., the lead shot. Enclosed for your information is a September 6, 1988 letter from EPA to IDEM on this particular point.

In the federal regulations, the term, “scrap metal,” is defined as “bits and pieces of metal parts (e.g., bars, turnings, rods, sheets, wire) or metal pieces that may be combined together with bolts or soldering (e.g., radiators, scrap automobiles, railroad box cars), which when worn or superfluous can be recycled.” (40 C.F.R. §261.1.) In the Federal Register preamble for the final regulations on the definition of solid waste, EPA indicated that “scrap metal is defined as products made of metal that become worn out (or are off-specification) and are recycled to recover their metal content, or metal pieces that are generated from machine operations (i.e., turnings, stampings, etc.) which are recycled to recover metal.” (50 Fed. Reg. 614, 624 (1985).) The lead shot portion of the Saxon Metals pile would be considered scrap metal pursuant to the regulatory definition of scrap metal.

EPA provided further clarification on the regulatory status of scrap metal in the Federal Register preamble to the definition of solid waste final regulations:

[a]t proposal, scrap metal that was generated as a result of use by consumers (copper wire scrap, for example) was defined as a spent material. (This type of scrap is usually referred to as “obsolete scrap.”) Scrap from metal processing, on the other hand (such as turnings from machining operations) was defined as a by-product. (It is usually called “prompt scrap.”) Yet the scrap metal in both cases is physically identical (i.e., the composition and hazard of both by-product and spent scrap is essentially the same) and, when recycled is recycled in the same way - by being utilized for metal recovery (generally in a secondary smelting operation). In light of the physical similarity and identical means of recycling of prompt scrap and obsolete scrap, the Agency has determined that all scrap metal should be classified the same way for regulatory purposes. Rather than squeeze scrap metal into either the spent material or by-product category, we have placed it in its own category.

(50 Fed. Reg. at p. 624) Based on these regulatory passages, the lead shot portion of the pile would be considered scrap metal, and not a spent material. The lead shot is a product that is made of metal that can be recycled to recover metal content. Furthermore, the lead shot has not been “discarded” by virtue of its discharge at the shooting range, because the discharge is within the normal and expected use pattern of the manufactured product. Ac- cordingly, lead shot would be considered scrap metal for regulatory purposes. Scrap metal is a solid waste, but it is exempt from the regulatory requirements of Subtitle C when it is recycled. (40 C.F.R. §261.6(a)(3)(ii).) As part of the Phase IV land disposal restrictions supplemental rulemaking (which was proposed January 25, 1996 and is expected to be finalized in April 1997), processed scrap metal and two categories of unprocessed scrap metal that is being recycled would be excluded from RCRA jurisdiction.

Appendix D - Page D-4 BMP for Lead at Outdoor Shooting Ranges

Please note that this discussion of the regulatory status is limited to the lead shot portion of the pile as you requested. To the extent that the entire pile exhibits the ignitability or reactive characteristic of hazardous waste, the mixture of materials would be considered hazardous waste and not scrap metal. The scrap metal designation for the lead shot would be applicable only to the extent that the lead shot could be segregated from the other materials in the pile.

I hope that this guidance on the regulatory status of lead shot recovered from shooting ranges provides you with the clarification that you needed. If you have any questions or would like to discuss this matter further, please contact me.

Appendix D - Page D-5 BMP for Lead at Outdoor Shooting Ranges

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Appendix D - Page D-6 BMP for Lead at Outdoor Shooting Ranges

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 APR 29 1997

Mr. John P.Cahill Acting Commissioner State of New York Department of Environmental Conservation Albany, New York 12233-1010

Dear Mr. Cahill:

Thank you for your letter of April 3, 1997 to Administrator Browner requesting a clarification of the Environmental Protection Agency (EPA) Final Military Munitions Rule regarding the extension of its range clearance principles to non-military ranges. Although the final rule addresses only military ranges, we agree with your view that the range clearance principles apply equally to non-military ranges [see comment no. 5 on page 36 of the enclosed excerpt from the Military Munitions Final Rule Response to Comments Back- ground Document].

We are aware of the State of New York’s active leadership role in the clean-up of private firing ranges. We appreciate your writing in support of the range clearance aspects of the final Military Munitions Rule and we will consider your suggestions that we issue broader guidance on the applicability of its principles to non-military ranges.

Sincerely yours,

Elizabeth Cotsworth, Acting Director Office of Solid Waste

Enclosure

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Appendix E: Template for an Environmental Stewardship Plan for Management of Lead Shot/Bullets

Instructions

EPA encourages outdoor shooting ranges to adopt and implement the Best Management Practices (BMPs) found in this manual. To this end, it is recommended that ranges first prepare an Environmental Stewardship Plan (ESP or Plan), which gathers information about, and guides evaluation of, site specific conditions of each range. As such, the ESP assists in selection of appropriate BMPs.

This document serves as a template that may be used by sportsmen’s clubs and shooting ranges in their preparation of an ESP. This template was adapted from Appendix C of the National Shooting Sports Foundation’s manual, Environmental Aspects of Construction and Management of Outdoor Shooting Ranges (the NSSF manual.) This template is only a tool to assist in making ESP preparation easier and can, and in some cases should, be modified to incorporate specific information relative to your club and its ranges. It is intended to be used in conjunction with a full understanding of the NSSF, U.S. Environmental Protection Agency (EPA) and, for ranges in Florida, Florida Department of Environmental Protection (DEP) manuals for the safe management of lead at outdoor shooting ranges. This template is intended to encourage ranges to prepare ESPs and submit them to EPA or NSSF to obtain a Certificate of Recognition from EPA. In this regard, either the following template or the NSSF template is recommended for use in conjunction with EPA’s Certificate of Recognition program.

An electronic copy of this template is available on EPA’s shooting range website (http://www.epa.gov/region2/leadshot) in several formats.

Disclaimer: This template does not serve as a substitute for understanding the concepts and techniques discussed in the EPA manual or other manuals. This template is not to be used as a substitute for consultation with scientists, engineers, attorneys, other professionals, or U.S. EPA.

Appendix E - Page E-1 BMP for Lead at Outdoor Shooting Ranges

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Appendix E - Page E-2 BMP for Lead at Outdoor Shooting Ranges

Environmental Stewardship Plan for Management of Lead/Bullets at Outdoor Shooting Ranges

Club Name

Address City/Town, State & Zip Code Phone #:

Date

Appendix E - Page E-3 BMP for Lead at Outdoor Shooting Ranges

Table of Contents

❑ Introduction • Mission Statement • Purpose • Goal • Delete

❑ Site Assessment • Description of Ranges and Support Facilities • Existing Environmental Conditions - Trap and Skeet Fields - Sporting Clays Course - Rifle and Black Powder Range(s) - Outdoor Handgun Range(s)

❑ Trap and Skeet Fields • Action Plan - Potential Management Options - Selection of Management Options to be Implemented - Options Selected a) Management Actions b) Operational Actions c) Construction Actions • Plan Implementation - Schedule for Implementation - Responsibilities

❑ Rifle, Black Powder, and Outdoor Handgun Ranges • Action Plan - Potential Management Options………………………………... - Selection of Management Options to be Implemented………... - Options Selected………………………………………………. a) Management Actions…………………………………………... b) Operational Actions……………………………………………. c) Construction Actions…………………………………………... • Plan Implementation……………………………………………………….. - Schedule for Implementation………………………………………. - Responsibilities……………………………………………………..

Appendix E - Page E-4 BMP for Lead at Outdoor Shooting Ranges

Table of Contents (continued)

❑ Sporting Clays Course……………………………………………………………. • Action Plan…………………………………………………………………. - Potential Management Options………………………………... - Selection of Management Options to be Implemented………... - Options Selected………………………………………………. a) Management Actions……………………………………... b) Operational Actions………………………………………. c) Construction Actions……………………………………... • Plan Implementation……………………………………………………….. - Schedule for Implementation………………………………………. - Responsibilities……………………………………………………..

❑ Measuring Success………………………………………………………………... • Vegetation………………………………………………………………….. • Soil and Runoff pH………………………………………………………… • Erosion……………………………………………………………………...

❑ Plan Review and Revisions………………………………………………………

Figures Figure 1: Site Location Map Figure 2: Facilities Diagram (Additional figures, as appropriate)

Tables Table 1: Table 2:

Appendices Appendix A: Appendix B: (Additional Appendices, as appropriate)

Appendix E - Page E-5 BMP for Lead at Outdoor Shooting Ranges

Introduction

The XYZ Club, Inc. is located at 123 X Road in Anytown, USA…

Mission Statement

The XYZ Club, Inc. is committed to…

- Purpose:

The Purpose of this Environmental Stewardship Plan (i.e., the Plan) is to:

• Identify potential environmental concerns that may exist; • Identify, evaluate, and prioritize appropriate actions to manage lead shot and bullets safely, as well as identifying and addressing environmental concerns; • List short- and long-term steps needed for implementation; • Develop an implementation schedule; • Identify ways to measure the Plan’s success; • Evaluate annual progress made towards achieving environmental stewardship goals; • etc.

- Goal – To minimize the release of lead into the environment.

Activities to Reach Goal: Examples include: Avoid shooting over and into water and wetlands. Prevent off-site migration of lead through groundwater and surface water runoff. Conduct lead recovery. Discourage ingestion of lead by wildlife. Maintain soil pH between 6.5 and 8.5 in the shotfall zone.

Site Assessment

Description of Ranges and Support Facilities

The XYZ Club has an x position Trap Range, a y position Skeet Range, a z position Sporting Clays Course, and a q position Small Arms Range. These ranges are located in a rural setting and are oriented away from residential areas and surface water bodies.

[Briefly describe each range, its dimensions, orientation, vegetative cover, numbers of shooters and targets used per year, wildlife usage, etc.]

Existing Environmental Conditions

[Describe any known environmental conditions associated with the ranges. This might include type of soil, depth to groundwater, soil pH, drainage to surface water, unique animal or bird populations, etc. Refer to figures, tables, the results of surveys, inspections, professional opinions, etc.]

Appendix E - Page E-6 BMP for Lead at Outdoor Shooting Ranges

- Trap and Skeet Fields

- Sporting Clays Course

- Rifle and Black Powder Range(s)

- Outdoor Handgun Range(s)

Trap and Skeet Fields

Action Plan

[Briefly describe the management options selected.]

- Potentially Applicable Management Options

[See EPA or NSSF guidance manual for full listing of options]

Examples include: - Vegetate sparse grass area of trap/skeet field. - Reorient trap field to avoid lead shot entering wetlands. - Reorient sporting clays stations to maximize the overlap of falling shot into the open field where it can be more easily recovered for recycling. - Limit use of the trap/skeet range to only those stations that do not have wetland area within the shotfall zone. - Apply lime to shotfall zones if soil test results indicate this would be beneficial. - Prepare fields for lead reclamation. - Get bids for lead reclamation project. - Conduct lead reclamation within the trap/skeet shotfall zones. - Change mowing frequency to closely mow grass in shotfall zones. - Construct lean-tos at backstop berms. - Construct a lime lined drainage swale for stormwater management. - List additional Best Management Practices that may be appropriate to your club.

In addition to appropriate site-specific management options, the list should always include conducting lead reclamation within the berm for rifle and pistol ranges and conducting lead reclamation within the trap, skeet, and sporting clays shotfall zones.

- Selection of Management Options to be Implemented

Option x: Option y: Option z:

[Describe why the above options were selected and the general roles of club officers, the membership, and outside consultants, as applicable, in implementation.]

Appendix E - Page E-7 BMP for Lead at Outdoor Shooting Ranges

In order to implement the options selected, the following actions are necessary.

a) Management Actions: [Examples include: assign personnel responsible for initiating, conducting, and completing the alternatives selected above.] b) Operational Actions: [Examples include: collect soil samples for pH analysis, consult with USDA’s Natural Resources Conservation Service and/or the county Cooperative Extension Service regarding best suited vegetative management recommendations.] c) Construction Actions: [Examples include: do site preparation work, get bids, institute mowing and vegetative management recommendations, reorient shooting position as appropriate.]

Plan Implementation

- Schedule for Implementation

Winter/Spring: [Examples include: pH survey, contact local officials for vegetation management recommendations, reorient shooting positions as appropriate, realign shooting positions as appropriate.]

Summer/Fall: [Examples include: prepare site for reclamation project, apply lime/fertilizer/seed, get bids for berm lean-tos/reclamation. As a rule of thumb, 50 pounds of lime per 1,000 square feet should raise soil pH by 1 once the residual acidity is overcome.]

- Responsibilities

[Specific duties (i.e., the trap/skeet chairman/chairmen will…, The club treasurer will…, The membership will provide the labor to…)]

Rifle, Black Powder, and Outdoor Handgun Range(s)

Action Plan

[Briefly describe the management options selected.]

Potentially Applicable Management Options

[See EPA or NSSF guidance manual for full listing of options]

Examples include: - Culvert the stream through the shooting ranges. - Vegetate the backstop berm(s) to minimize erosion. - Construct a lime lined drainage swale for stormwater management. - Apply lime to the berm and foreground if pH test determines it is necessary. - Begin planning a lead reclamation project. - Construct lean-tos at berms. - List additional Best Management Practices that may be appropriate to your club.

Appendix E - Page E-8 BMP for Lead at Outdoor Shooting Ranges

Selection of Management Options to be Implemented

Option x: Option y: Option z:

[Describe why the above options were selected and the general roles of club officers, the membership, and outside consultants, as applicable, in implementation.]

In order to implement the options selected, the following actions are necessary.

a) Management Actions: [examples include: assign personnel responsible for initiating, conducting, and completing the alternatives selected above.] b) Operational Actions: [examples include: collect soil samples for pH analysis, consult with USDA’s Natural Resources Conservation Service and/or the county Service Forester regarding best suited vegetative management recommendations.] c) Construction Actions: [examples include: do site preparation work, get bids, institute mowing and vegetative management recommendations, reorient shooting position as appropriate.]

Plan Implementation

- Schedule for Implementation

Winter/Spring: [examples include: pH survey, contact local officials for vegetation management recommendations, reorient shooting positions as appropriate, realign shooting positions as appropriate.]

Summer/Fall: [examples include: prepare site for reclamation project, apply lime/fertilizer/seed, get bids for berm lean-tos/reclamation.]

- Responsibilities

[Specific duties (i.e.: the small arms range chairman/chairmen will…,The club treasurer will…, The membership will provide the labor to…)]

Sporting Clays Course

Action Plan

- Potentially Applicable Management Options

[See EPA or NSSF guidance manual for full listing of options]

- Selection of Management Options to be Implemented

- Options Selected

Appendix E - Page E-9 BMP for Lead at Outdoor Shooting Ranges

Plan Implementation

- Schedule for Implementation

- Responsibilities

Measuring Success

By monitoring the success of the Plan, the club is best prepared to make whatever changes may be necessary to reinforce success and make the most of environmental stewardship efforts. Below are some examples of areas to monitor:

Lead Recovery

[Document the quantity (pounds) of lead recovered and recycled, along with the cost of conducting the activities.]

Vegetation

[The density of vegetation growth should be measured throughout the growing season, especially in areas of sparse growth where steps have been taken to increase the vegetative cover. This is can be done by taking periodic photographs (e.g., once a month) from the same places to document the impact of the Plan.]

Wildlife

[Keep a log of visual observations made regarding the frequency of range usage by the variety of species in your area.]

Soil and Runoff pH

[Track soil and runoff pH through semiannual monitoring and adjust the amount of lime applied to different areas of the range to maintain a pH level that will prevent lead from dissolving (i.e., a pH of 6.5-8.5).]

Erosion

[Again, keeping a photographic record of problem areas best prepares your club to document achievements and adjust the Plan as appropriate.]

Plan Review and Revisions

Review the Plan on an annual basis. Update the Plan as needed and schedule activities for subsequent years. Make recommendations for future club officers to consider when updating the Plan and designating future activities to be conducted (tell them what worked, what didn’t work, and what still needs to be done.)

Appendix E - Page E-10 BMP for Lead at Outdoor Shooting Ranges

FIGURES

Figure 1 Facility diagrams

Figure 2 Resource maps (USGS topographic map, wetlands maps, soil survey maps, FEMA floodplain map, etc.)

Figure 3 (Optional) Site photographs

Figure 4 (Optional) Aerial photo of range and surrounding area

Appendix A (Optional)

Appendix B (Optional)

Appendix E - Page E-11 BMP for Lead at Outdoor Shooting Ranges

[Insert other figures as necessary to support the text]

Other figures may include an aerial photograph, and sketches of the Club property in general and/or specific ranges in particular.

Example:

Appendix E - Page E-12 BMP for Lead at Outdoor Shooting Ranges

[Insert Site Location Map Here]

Typically, a Site Location Map is cut from a USGS Topographic Map of you Club’s area. The Club should be centered on the map. Indicate the property boundaries and layout of the range.

Appendix E - Page E-13 BMP for Lead at Outdoor Shooting Ranges

Appendix A

Information from USDA, Natural Resources Conservation Service [and/or county Cooperative Extension Service]

[concerning soil and vegetation management recommendations]

Appendix E - Page E-14 BMP for Lead at Outdoor Shooting Ranges

Appendix B (etc.) [For other supporting documentation as needed.]

Appendix E - Page E-15 U.S. Environmental EPA-902-B-01-001 Protection Agency Revised June 2005 Region 2

FIRST-CLASS MAIL United States Environmental Protection Agency U. S. POSTAGE 290 Broadway PAID New York, NY 10007-1866 MAILED FROM ZIP CODE 10007 PERMIT NO. G-35 Official Business Penalty for Private Use $300 Forwarding and Address Correction Requested