Investigation and Remediationof a

Small Arms Firing Range

JP MessierU.S. Coast Guard

Civil Engineering Unit - Cleveland

Presentation Overview

USCG Environmental Organization Regulatory Framework USCG Firing Ranges Site Characterization Remediation O&M and Upgrades Compliance Pollution Prevention References

U.S. Coast Guard Environmental Organization

Headquarters (G-SEC-3) Policy, Guidance, and Funding

Washington, D.C. Maintenance and Logistics Commands (MLC)

Program Management Atlantic – Norfolk, Virginia Pacific – Alameda, California

Facilities Design and Construction Center (FD&CC) Major Construction and Design Services

Atlantic – Norfolk, Virginia Pacific – Seattle, Washington

Civil Engineering Units (CEU) Minor Construction, Design, Environmental, and Real

Property ServicesClevelandHonolulu JuneauOaklandMiamiProvidence

Regulatory Framework

CERCLA EPCRA Section 313, TRI Form R Release Notification and Corrective Actions

RCRA Spent Ammunition, Bullet Fragments

Recycling/Reclamation – 40 CFR 261 Reuse of Soils On Site

Military Munitions Rule – 40 CFR 266 Clean Water Act – NPDES (State Regulations) Other State Programs for Corrective Action

USCG Small Arms Firing Ranges (SAFR)

Active Seattle, Ketchikan, Kodiak, Honolulu, Galveston,

New Orleans, Portsmouth, Cape Cod, Sandy Hook, Petaluma, Cape May, Academy, and Yorktown

Closed/Inactive Ketchikan, Cape May, and Galveston

Site Characterization

Investigation Site Evaluation

Fate Transport of Considerations Airborne Particulates Storm Water Runoff and Erosion Dissolved Lead in Groundwater/Surface Water

Range History and Layout Ammunition Usage Reclamation and Recycling Firing Positions and Bullet Deposition Future Land/Range Use

(Taken from ITRC training)

Investigation - continued Sampling Plan

Locations and Depths Vertical and Horizontal Extents Hot Spots and Background

Contaminants of Concerns Primarily Lead

Sampling Methodology Field Screening Using XRF and/or Electron

Tube Analyzers• USEPA Method 6200

Constituent Comment

Lead Primary constituent of a projectile

Lead Styphnate/Lead Azide Primer constituent

Antimony Increases hardness.

Arsenic Present in lead. A small amount is necessary in the production of small shot since it increases the surface tension of dropped lead, thereby improving lead shot roundness.

Copper Bullet Core Alloy Increases hardness.

Tin Increases hardness.

Constituent Comment

Copper Jacket alloy metal

Zinc Jacket alloy metal

Iron Iron tips on penetrator rounds

PAHs (Polycyclic Aromatic Hydrocarbons)

Concentration of PAHs in clay targets varies from one manufacturer to the next, but may be as high as 1,000mg/kg. Existing studies show that PAHs are bound within the limestone matrix of the target and are, therefore, not bioavailable.

Sampling Plan - continued Analytical Method (SW-846) Process Sample with a Sieve Soil, Groundwater, and Surface Water

Total and Recoverable/Dissolved Metals• Amount of Lead Present in the Environment• Method 6010B – Analysis AA or ICP• Filtered and Unfiltered for Liquid Samples

pH• Buffering Capacity• Method 9045

Sampling Plan - continued SEM:AVS

• Acid Volatile Sulfide and Simultaneously Extracted Metals

• Bioavailability and Binding Assessment• Ratio <1 Potential for Metals to Bind• Ratio >1 Insufficient Sulfides for Binding

Toxicity Testing• Sediment – In Situ or Ex Situ• Expensive, Last Measure, Higher Certainty of

Risks from Impacts

Sampling Plan - continued Total Organic Carbon

• Solubility/Mobility Indicator• Method 9060

Grain Size Distribution• Soil Classification Data• ASTM D-422

Investigative Derived Wastes (IDW)• Waste Stream Classification• Toxicity Characteristics Leaching Procedure

(TCLP) – Method 3010/6010

Ecological Risk Assessment Tier I

Generic Bulk Soil Sample Results Comparison Against Published Standards

Tier II Site Specific Water Analytical and Additional Soils Data Ecological Characterization Exposure Pathway Identification Estimate of Potential Risks

Remedial Alternatives Evaluation Evaluation Factors

Future Land Use Continued Range Operation Industrial Residential

Cleanup Goal Establishment Budget and Timeframe

Remedial Alternatives Evaluation - continued Technology Selection

Disposal, Recycling , and Reuse Physical Separation Stabilization/Solidification Soil Washing Chemical Extraction Phytoremediation/Phytoextraction

Lower Cleanup Goals = Higher Costs

Remediation

Disposal Off-Range Disposal

Toxicity Characteristics Leaching Procedure (TCLP) Testing Warranted to Define Waste Stream Classification Hazardous or Non-Hazardous?

Haz Soil Can be Treated to Become Non-Haz Physical Separation Stabilization/Solidification Soil Washing Chemical Extraction

Soil Reuse No Testing Required: On-Site Use

Physical Separation of Bullet Fragments Berm Reconstruction Other Uses within Range Boundary

Side/Wing Walls Off-Site Use

Testing Required, Treatment Good Probability Render and Prove Non-Haz Show Totals Meet State Criterias

Fill Materials

Soil Recycling Chemically Treat/Utilize Soils in a Product

Rendered Inseparable by Physical Means Meets Universal Treatment Standards

Road Base Emulsions/Materials

Physical Separation Use for On-Site Management or Off-Site Disposal

Dry Screening/Sifting Bullet Fragment Removal/Recycling Lower Limit of ¼ inch

Stabilization/Solidification Stabilization

Phosphates, Sulfates, Hydroxides, and Carbonates Solidification

Portland Cement, Cement Kiln Dust Use for On-Site Management

Lower/Control Solubility, Leaching to Ground/Surface Water, and Bioavailability/Risk

Use for Off-Site Disposal Render Non-Hazardous to Lower Disposal Costs

and Long Term Risk

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Stabilization/Solidification - continued Pros:

Off-Site Disposal of Non-Haz Soils Reduces Tipping Fees

Risk Remains with Land Owner and Not Transferred to a Landfill for Potential Future Liabilities if Soils Remain On-Site

Stabilization/Solidification - continued Cons:

If Volume is Small, Costs to Perform Option do not Outweigh Savings from Non-Haz Landfill

No Reduction in Total Metal Concentrations Material is Heavily Bulked Land Use Controls Warranted if On-Site RCRA Permit May be Needed by State

Soil Washing Mineral Processing Technique

Physical Sizing Magnetic Separation Soil Classification Gravity Separation

Bench-Scale Study Required to Evaluate Process

Soil Washing - continued Use for On-Site Management

Reduce/Eliminate Leaching to GW/SW Lower Risk to Human Health and the

Environment Use for Off-Site Disposal

Render Non-Hazardous to Lower Disposal Costs and Long Term Risk

Soil Washing - continued Pros:

Off-Site Disposal of Non-Haz Soils Reduces Tipping Fees

Risk Remains with Land Owner and Not Transferred to a Landfill for Potential Future Liabilities if Soils Remain On Site

Soil Washing - continued Cons:

If Volume is Small, Costs to Perform Option do not Outweigh Savings at Non-Haz Landfill

Residuals May Warrant Land Use Controls Warranted if On-Site

RCRA Permit May be Required by State

Coarse Soil

Boulders

Particulate Contaminants

Washes Oversized

Separates by SizeSoil Fines

Separates by Density

Humates

Chemical Extraction Bench Scale Testing to Provide Effective System

pH, Buffering Capacity, Total Organic Carbon, Iron and Manganese Levels, Soil Type

Residuals of Metals and Leaching Solvent May Remain Bound in the Soils, Restricting Site Usage

Residual Acids Require Neutralization Residual Solvents May Remain Toxic in Treated

Soils

Phytoremediation/Phytoextraction Limited Uptake Potential Specific Plants and Conditions Warranted Constructed Wetlands

Indian Mustard Plant Organic Base – Topsoil, Humates, Sandy Loam Soil Ph Levels, Temperature Lead Needed in a More Soluble Form for Uptake

Amendment with Chelates

O&M and Upgrades Best Management Practices

Monitoring and Adjusting Soil pH Lime/Phosphate Addition

Control Runoff Ground/Surface Cover

• Grasses, Mulches, and Compost Filter Beds Containment Traps and Detention Ponds Dams and Dikes Ground Contouring

O&M and Upgrades – continued Bullet Trap Systems

Decelerator Granular Rubber Block Rubber SACON – Shock Absorbing Concrete Earthen Berm

Compliance EPCRA TRI Form-R Reporting

Release and/or Transfer of Toxic Chemicals Lead – 100 pounds per year Annual Submission; On/Before July 1st

EPA and State EPA TRI-ME Software

Pollution Prevention Lead-Free (Green) Ammunition

Frangible Polymers, Nylon Disintegrates upon Contact Shorter Effective Range

Non Toxic Copper Jackets over Zinc/Tin Potential for Ricochet

References Interstate Technology Regulatory Council (ITRC),

Small Arms Firing Ranges; http://www.itrcweb.org

National Association of Shooting Ranges; http://www.rangeinfo.org

Lead Prevention and Migration from a SAFR;

http://aec.army.mil/usaec/technology/leadmigration.pdf

Questions/Discussion