Lead Contamination in Soils at
Military Small Arms Firing Ranges

June 1998 - TI#17472
Introduction
Environmental Concerns
Review of Applicable Federal Regulations
Remediation Approaches
Pollution Prevention Opportunities
Lead Migration Prevention
Document References

Introduction
United States Air Force (USAF) personnel involved in the design, maintenance, deactivation, and/or clean up of small arms firing ranges must address many regulatory considerations. This is an important issue for the Air Force due to site closures, changes in land use and redevelopment, and questions about the likelihood of lead contamination in soils associated with these ranges. The current regulatory framework established for Federal agencies does not provide definitive guidance on the maintenance or remediation of small arms firing ranges. This fact sheet provides an overview of potential compliance issues pertaining to small arms firing ranges, many of which will require site-specific resolution.

This fact sheet also discusses application of the Environmental Protection Agency (EPA) Final Munitions Rule ("EPA Munitions Rule"), and introduces the Department of Defense (DoD) Proposed Rule ("DoD Range Rule") regarding the maintenance, closure, and transfer of firing ranges. The information provided will allow the reader to develop an initial plan of action addressing the environmental and health concerns of involved regulatory agencies. Finally, the fact sheet summarizes pollution prevention (P2) practices that should be considered during the management of small arms firing ranges.

Environmental Concerns
Small arms firing ranges are essential to weapons training and the mission of the USAF. However, range use often produces soil contaminated with metals from spent bullets. This contamination can create environmental and occupational health problems during range operation and maintenance, as well as during redesign, reuse, and remediation of the range. However, proper management of ranges should alleviate these problems.

Lead is the primary soil contaminant of concern at these ranges. Antimony, a hardening agent in bullets, and copper and zinc, the primary components in shell casings and jackets, can also contribute to soil contamination. Bullets are often fragmented and pulverized upon impact with backstops, berms, or bullet traps located at the range. The normal operation of a range can produce lead concentrations of several percent (one percent = ten thousand parts per million) in soils located behind and adjacent to targets and impact berms. Elevated levels of lead have also been found in vegetation growing near impact berms. Care must be taken to protect human health and the environment from lead's potential harmful effects. Antimony, copper, and zinc should be considered as secondary contaminants of potential concern when developing a list of contaminants targeted for analysis and/or cleanup.

Lead is a naturally occurring, grayish soft metal, found in the Earth's crust. Human activities such as mining, manufacturing, and the burning of refined fossil fuels have concentrated the amount of lead in certain areas of the environment. Harmful exposures to lead can occur from inhalation of lead dust or fumes, and ingestion of lead contaminated food and water. Lead can accumulate in human, animal, and plant tissue and can cause chronic health effects. Lead contamination in soils at firing range sites can be transported via the following mechanisms:

Airborne Particulate Lead - Very small lead particles can become airborne if wind, foot traffic, or maintenance activities disturb contaminated soil. Airborne particles smaller than 10 microns (Sincero, 1996) can be inhaled, and fine particles smaller than 250 microns in diameter can be incidentally ingested (Duggan, 1985). Soil particles smaller than 100 to 200 microns are likely to be ingested because fine particles adhere to skin while larger particles are easily brushed off. Intake of lead through inhalation is usually small (Duggan, 1985).

Storm Water Runoff and Erosion - Storm water runoff has the potential to erode and transport contaminated soil and lead particles away from the normal confines of a firing range. Rainfall intensity, ground slope, soil type, and obstructions such as vegetation and fabricated structures will influence the potential transport of lead away from the range. Once the contaminated soil is transported beyond the firing range's boundary, additional environmental impact (e.g., bioaccumulation or bioconcentration) and human exposure could occur.

Dissolved Lead in Groundwater/Surface Water - At a neutral pH, lead is relatively insoluble. As water becomes more acidic (decreasing pH), lead solubility tends to increase. When storm water (normally slightly acidic) comes in contact with lead contaminated soil, the lead can be dissolved into the water and transported to nearby groundwater or surface water. If sufficient lead is mobilized, environmental receptors can be affected and risk to human health could occur if these sources are used for drinking water. When groundwater is more than 10 feet below ground surface, it is generally not affected by leaching of lead from soil. However, some regulatory agencies consider dissolved concentrations of lead above 15 micrograms per liter (parts per billion) a potential health concern (Reference: Appendix A: National Primary Drinking Water Standards, Action Level for Lead, 1997.)

As with most metals, lead, antimony, copper, and zinc tend to adhere to soil grains and organic material and remain "fixed" in shallow soils.

Review of Applicable Federal Regulations
Routine maintenance and the environmental assessment/clean-up of ranges are not specifically addressed in any single Federal regulation. However, portions of different Federal regulations could be applicable in certain situations and should be considered. The following paragraphs provide an overview of these different Federal regulations and how they might apply.

CERCLA
Title 40 Code of Federal Regulations (CFR) Part 302, "Designation, Reportable Quantities, and Notification," promulgated in response to requirements of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA), designates lead as a hazardous substance and requires the reporting of releases to the environment. To be a "reportable" release under 40 CFR Part 302, the amount of the release must equal or exceed, within a 24-hour period, the "reportable quantity" (RQ) for the hazardous substance. Per Section 302.6, "Notification Requirements," notification must be provided to EPA's National Response Center (800-424-8802) if a release of one pound (RQ) or more of solid lead particles less than or equal to 100 micrometers (0.004 inches) in mean diameter occurs. A release of this type would be unlikely at a military small arms firing range.

Regardless of whether the RQ for lead or other contaminants has been exceeded at a range, the EPA can, under CERCLA authority, require that lead contaminated soils and groundwater be investigated and remediated, including any off-site environmental contamination originating from the site, if such lead contamination has been determined to pose an unacceptable potential risk to human health or the environment.

RCRA
At operational firing ranges, lead-containing bullets are fired and eventually fall to the ground at or near the range. The EPA has determined the act of firing ammunition does not, by itself, generate a solid waste under RCRA because the ammunition is being used for its intended purpose (i.e., it has not been "discarded").

Under the Resource Conservation and Recovery Act (RCRA), removing lead-containing bullets or lead-contaminated soil from a firing range, or abandoning a range containing such material, may be viewed as "discarding," making the removed materials solid waste subject to RCRA disposal regulations. However, the EPA has deferred to the drafters of the DoD Range Rule (discussed further below) any action on the issue of abandonment or transfer being equivalent to discarding. The DoD Range Rule proposes to address such sites according to a CERCLA-like process, rather than under RCRA authority, where risks posed to human health and environmental receptors are evaluated via site-specific investigations and risk-based remediation goals. This is currently the way the EPA Munitions Rule addresses the investigation and cleanup of active and inactive ranges. The public comment period for the DoD Proposed Rule ended December 1997. The EPA will judge whether the DoD's Final Range Rule "adequately protects human health and the environment" after it is published.

Any RCRA regulated solid waste destined for land disposal must be pre-evaluated for its potential environmental impact. (It is important to note that not all ranges or wastes collected/originating from ranges are necessarily going to be subject to regulation under RCRA. See below under "EPA Final Munitions Rule" and "DoD Proposed Range Rule" for further discussion.) RCRA regulated solid wastes are deemed hazardous if they are a listed waste or exhibit any of the hazardous waste characteristics such as toxicity, ignitability, corrosivity, and reactivity. If a soil sample, when subject to the Toxicity Characteristic Leaching Procedure (TCLP), produces a result in excess of the regulatory limit for lead (5 milligrams per liter (parts per million), then the waste represented by the sample becomes a characteristic hazardous waste due its leachable lead concentration and would be subject to RCRA regulation as a hazardous waste for disposal purposes. As the pH of the lead-containing soil approaches 7 (neutral) or higher (alkaline), its potential for leaching lead above 5 ppm during TCLP testing is lowered. In addition to pH, other important variables affecting the potential for leaching lead from soil samples during TCLP testing are grain size and whether the lead is in elemental form or weathered.

Certain sifting and collection activities can be used to recover lead fragments from range soils. Recovered lead fragments destined for recycling are exempt from RCRA regulation. However, recovered material not destined for recycling and soil handled during the recovery process may be subject to RCRA regulation as a solid waste or a hazardous waste.

According to EPA, authority exists under RCRA to compel remediation where an imminent and substantial endangerment to health or the environment (e.g., contamination of a sensitive habitat or a drinking water supply) may have been created by munitions fragments at a firing range.

While cleanup of lead from small arms firing ranges is normally controlled by CERCLA, the decision regarding which regulatory scheme applies is a fact-specific decision. Thus, these decisions, especially if the range is included in a RCRA permit, should always be coordinated with the servicing Judge Advocate's office. Additional guidance may be found in the EPA memorandum addressed to RCRA/CERCLA national policy managers "Coordination between RCRA Corrective Action and Closure and CERCLA Site Activities, 24 Sep 1996." A copy of this document is available from PRO-ACT.

EPA Final Munitions Rule
Section 107 of the Federal Facility Compliance Act (FFCA) of 1992 amended RCRA by adding a new section (3004y) that required the EPA to "identify when military munitions become hazardous waste for the purposes of RCRA Subtitle C, and to provide for the safe transportation and storage of such wastes." The Military Munitions Rule ("EPA Munitions Rule"), published at Federal Register Vol. 62, No. 29, page 6622, 12 February 1997, responded to several key issues raised concerning the application of RCRA to military munitions. The EPA Munitions Rule is codified at 40 CFR Parts 260 through 266, and Part 270 (Subpart M "Military Munitions" is in part 266). Important terms under the EPA Munitions Rule include the following:

Military munitions means all ammunition products and components produced or used by or for the U.S. Department of Defense (DoD) or the U.S. Armed Services for national defense and security, including military munitions under the control of the DoD, the U.S. Coast Guard, the U.S. Department of Energy (DOE), and National Guard personnel. The term military munitions includes, in part: explosives, rockets, bombs, warheads, artillery ammunition, and small arms ammunition. The term does not include nuclear weapons.

Military range means designated land and water areas set aside, managed, and used to conduct research on, develop, test, and evaluate military munitions and explosives, other ordnance, or weapon systems, or to train military personnel in their use and handling. Ranges include firing lines and positions, maneuver areas, firing lanes, test pads, detonation pads, impact areas, and buffer zones with restricted access and exclusionary areas.

Active range means a military range that is currently in service and is being regularly used for range activities.

Inactive range means a military range that is not currently being used, but that is still under military control and considered by the military to be a potential range area, and that has not been put to a new use that is incompatible with range activities.

Under the EPA Munitions Rule, fired military munitions fragments (e.g., spent bullet fragments, debris, and unexploded ordnance) are not considered RCRA waste (i.e., a discarded material) when the munitions were used for their intended purpose, as they would be within the confines of an active or inactive firing range. Under the EPA Munitions Rule, the recovery, collection, and on-range destruction of munitions fragments from an active or inactive range during range clearance activities is also considered "use for intended purpose." Although on-range collection may not by itself render the fragments RCRA waste, the removal of such materials to an off-range location or their burial on-range would be "discarding" and result in the generation of a solid waste, and therefore a potential hazardous waste, subject to RCRA disposal regulations. However, lead-containing munitions fragments destined for off-range reclamation/recycling would be exempted from regulation as a hazardous waste under the RCRA scrap metal provision found in 40 CFR Part 261.6 (a)(3)(ii).

Under the EPA Munitions Rule, fired munitions that land off-range, and are not promptly retrieved, have been discarded and would then be regulated as solid wastes under RCRA.

The EPA did not address in the EPA Munitions Rule the issue of whether munitions fragments at closed ranges (under military control) or transferred ranges (no longer under military control) would be RCRA regulated wastes; that is, if the munitions fragments at closed or transferred ranges would have been "discarded." Instead, the EPA chose to defer the issue in order to allow the agency to evaluate the DoD Range Rule, which proposes that such fragments would not be RCRA waste or subject to cleanup under RCRA (see below). Until the DoD Range Rule is finalized, the provisions of CERCLA would normally control the cleanup of ranges. However, because the decision regarding which regulatory scheme applies is fact-specific, this decision should be coordinated with the servicing Judge Advocate's office.

DoD Proposed Range Rule
"Closed, Transferred, and Transferring Ranges Containing Military Munitions; Proposed Rule," DoD, Federal Register Vol. 62, No. 187, 26 September 1997 ("DoD Range Rule") proposes a process for evaluating and selecting appropriate response actions at closed, transferred, and transferring military ranges.

The Rule was proposed in response to the EPA Munitions Rule and addresses the management of closed, transferred, and transferring ranges, which were not addressed in the EPA Munitions Rule as discussed above. If finalized, the DoD Range Rule will establish procedures for evaluating and responding to safety, human health, and environmental risks on closed, transferred, and transferring military ranges. To accomplish this, the DoD Range Rule proposes a five-part Range Response Process. This process evaluates appropriate response actions, consistent with CERCLA cleanup provisions, which evaluate actual risks posed by contaminants based on reasonably anticipated future land use. This could mean compliance with significantly different cleanup criteria than might be required under RCRA authority, which would apply if the munitions fragments at closed, transferred, and transferring ranges were designated RCRA solid wastes.

Although the DoD Range Rule is a Proposed Rule, it outlines a reasonable approach to address risk-based management of lead contamination at small arms firing ranges. Copies of DoD's "Closed, Transferred, and Transferring Ranges Containing Military Munitions; Proposed Rule" are available from PRO-ACT or may be obtained by visiting the Defense Environmental Network and Information Exchange (DENIX) World Wide Web site at http://denix.cecer.army.mil/denix/denix.html.

Clean Water Act
The Water Quality Act of 1987 created specific provisions for the control of surface water pollution caused by storm water runoff. Runoff from firing ranges can contain elevated levels of dissolved lead and other heavy metals, as well as particulate metal and sediments. Therefore, a National Pollutant Discharge Elimination System (NPDES) permit may be required if the EPA or State determines stormwater discharge from a range contributes to a violation of a water quality standard or is a significant contributor of pollutants to the waters of the U.S.

Summary
There are many existing and potential regulatory issues that must be considered when operating, maintaining, closing, cleaning up, or transferring a small arms firing range. Prior coordination with representatives of the following organizations is recommended:

  • Bioenvironmental Engineering, to assess the potential occupational health risks associated with lead exposure and to obtain recommendations on the necessary protective equipment and training for maintenance workers or clean-up crews.

  • Environmental Management, to assess the regulatory requirements associated with the potential generation and disposal of solid and/or hazardous waste. This is recommended even if the material(s) to be removed are destined for recycling.

  • Judge Advocate, to assess Federal, State, and local regulatory requirements to ensure all operations are in compliance.

After coordinating with the above installation personnel, coordination with the Regional EPA, the Regional Environmental Office (REO), and State environmental governing agencies is also recommended. Many aspects of small arms range maintenance and clean-up are subject to local interpretation and site-specific application. Active interaction and coordination by AF personnel with local agencies will ensure efficiency and compliance.

In the end, the determination of appropriate response actions at a range will result from: 1) a site-specific evaluation that characterizes the lateral and vertical extent of contamination and the potential for contaminant movement, 2) the planned future land use at the site, 3) an analysis of exposure pathways/potential receptors, and 4) appropriate risk characterization.

Remediation Approaches
The remediation of lead contaminated soils at firing ranges, either as part of maintenance or site closure activities, does not differ significantly from any other soil remediation project. However, development of remediation goals will depend upon whether the proposed action is maintenance at an active firing range or remediation supporting a potential change of land use. Firing range remediation activities involve worker protection, soil characterization/remediation, and waste treatment and disposal.

Worker Protection
Worker protection is based on the potential for inhalation and ingestion of lead. Since it is common for lead to be in particulate form in air or soils at a firing range, respiratory protection, protective clothing, and safe work practices should be specified in a site-specific health and safety plan applicable to workers engaged in environmental investigation or remediation. The plan should be approved by the installation Bioenvironmental Engineer or an industrial hygienist. Additional training, record keeping, and medical monitoring requirements for workers potentially exposed to particulate lead are outlined in Federal Occupational Safety and Health Administration (OSHA) regulations and standards.

Another worker protection concern at small arms firing ranges is unexploded ordnance (UXO). The Air Force Deputy Assistant Secretary for Environment, Safety, and Occupational Health has issued a memorandum entitled "Clearance of Unexploded Ordnance at Closing/Realigning Installations" dated 22 March 1996. Although this memorandum offers guidance applicable to closing/realigning installations, it contains information that may be useful to Air Force personnel involved in the clearance, assessment, or clean up of active or inactive ranges. A copy of this document is available from PRO-ACT.

Clean-up Goals for Lead
In July of 1994, the EPA issued "Revised Interim Soil Lead Guidance for CERCLA Sites and RCRA Corrective Action Facilities." This memorandum provides "screening levels" to be used as a tool to define a level of lead contamination above which there may be enough concern to warrant further site-specific study. The guidance encourages the risk manager to select, on a site-specific basis, the most appropriate combination of remedial measures, from intervention to abatement, needed to address lead exposure threats. The memorandum, which is directed toward protection of children and assumes residential future land use, sets a screening level in soils of 400 mg/kg, below which no corrective action is recommended, and a screening level in soils of 5,000 mg/kg, above which corrective action is recommended. Concentrations falling between these screening levels could warrant corrective action depending upon the results of site-specific risk evaluations. Additionally, site-specific risk assessment may lead to a finding of "no further action."

Other EPA guidance applicable to evaluating adult non-residential exposures that would be consistent with commercial or industrial land use scenarios include:

  • "A TRW Report: Review of Methodology for Establishing Risk-Based Soil Remediation Goals for the Commercial Areas of the California Gulch Site," EPA Technical Review Workgroup for Lead, October 1995.

  • "Recommendations of the Technical Review Workgroup for Lead for an Interim Approach to Assessing Risks Associated with Adult Exposures to Lead in Soils," EPA, Technical Review Workgroup for Lead, Patricia VanLeeuwen and Paul White, Chairpersons, December 1996.

Copies of the above documents are available from PRO-ACT.

Remediation goals should be developed to be protective of receptors consistent with planned future land use. Examples of receptors and future land use include: range workers for continued operation as firing range, adult workers for commercial redevelopment of the site, and preschool-age children for residential reuse.

Disposal/Treatment Options for Lead Contaminated Soils
Under the EPA Munitions Rule, the issue of when military munitions become subject to regulation under RCRA is addressed. The DoD Range Rule (not finalized) proposes a risk-based approach to undertaking corrective actions at closed, transferred, and transferring ranges. The investigation and the removal of military munitions from active or inactive ranges to an off-range location for disposal or their burial on-range would be considered generation of a solid waste, and therefore a potential hazardous waste, subject to RCRA disposal regulations.

Off-range Disposal
In accordance with RCRA land disposal restrictions, soil which is hazardous due to the lead toxicity characteristic (exceeds 5 mg/L when subjected to TCLP analysis) cannot be placed in an ordinary solid waste landfill. These soils will not require pre-treatment before disposal, but must be placed in a hazardous waste landfill. Costs associated with hazardous waste disposal can exceed ordinary landfill costs by ten to 100 times. Therefore, removing as many lead fragments as possible for recycling in an effort to reduce the overall lead content of the soil should be evaluated to determine whether the cost of disposal can be reduced.

Physical Separation
These processes use techniques designed to separate particles based on particle size and/or density. Sifting is one method that can significantly reduce the quantity of soil that may require off-site disposal, stabilization, or further treatment by acid leaching. To determine whether such techniques would satisfactorily remove lead fragments from soil, a pilot study may be warranted to determine the volume of lead that could be removed and the lead concentrations and characteristics of the remaining soil.

Stabilization/Solidification
Stabilization and solidification is another treatment/disposal option for soil contaminated with lead in excess of the hazardous waste threshold. This technology involves adding ingredients to contaminated soils that coat the soil grains and/or fill inter-granular pore spaces, permanently sealing off the lead contamination from the environment. This technology immobilizes contaminants in the soil and results in a solid or granular material.

Several techniques for stabilizing and solidifying contaminated soils exist; each should be evaluated with respect to site-specific environmental factors. If soil stabilization and solidification processes are performed on-site, the State may require the facility to obtain a RCRA permit for operation of a treatment, storage, and disposal (TSD) facility. If the stabilized soil mixture does not exceed the hazardous waste threshold as determined by TCLP testing, it may be possible to dispose of it in an ordinary solid waste landfill. Depending on the applicable State regulations, the stabilized soil may be considered safe to remain in-place on site, or to be reused, depending on the results of TCLP testing.

Soil Washing
A soil washing process has been successfully used to reduce lead concentrations in soils to background levels at a U.S. Army Superfund site. The Army had previously burned scrap ammunition, powder and buried shell casings at the site, resulting in total lead concentrations in soil as high as 86,000 parts per million. After sifting the soil and separating the munitions particles from the sand and gravel, the soil was washed in an aqueous acid solution to dissolve and remove the lead from the sand and gravel. Although the process was speedy and cost effective, the spent acid solution required treatment and disposal as a hazardous waste.

Other remedial approaches in addition to those discussed above are available and may be appropriate for your particular situation. Additional information on firing range remediation is available from the following sources:

  • Mr. Sam Taffinder, HQ AFCEE/ERT, DSN 240-4366
Pollution Prevention Opportunities
The best pollution prevention techniques employed at firing ranges include minimizing the amount of lead contained in munitions, preventing the bullets from mixing with soils, and minimizing the migration of lead contaminated soil.

Lead-free Ammunition
The Department of Defense (DoD) has initiated the Green Bullets program in an effort to eliminate the use of hazardous materials, including heavy metals and organic solvents, in small-caliber ammunition manufacturing processes, as well as in the ammunition itself. This initiative is led by the U.S. Army's Armament Research, Development, and Engineering Center (ARDEC) and encompasses all environmental aspects of small-caliber ammunition, from 5.56 mm through 0.50 caliber. Over 400 million units in this size range are produced each year in the U.S. Elimination of the hazardous materials that constitute small-caliber ammunition could result in production cost reductions totaling several million dollars per year. Several alternatives to lead in primers and projectile slugs are being evaluated, including bismuth, molybdenum, tungsten, steel/iron, and copper. Other benefits of lead-free ammunition include:

  • Elimination of indoor range lead contamination;
  • Elimination of adverse effects on outdoor ecosystems and reduced costs of any cleanups;
  • Reduction of ammunition production costs; and
  • Reduction of exposure risks to users and manufacturing personnel.
Stock-listed lead-free training ammunition (reduced range) is currently available to the military in 5.56 mm and 0.50 caliber ball, and tracer sizes. For more information about the Green Bullets program, contact Mr. Wade H. Bunting, U.S. Army ARDEC, (973) 724-6040, DSN 880-6040.

Bullet traps
Several types of bullet traps commonly used in indoor firing ranges may be appropriate for use at outdoor ranges. Generally, bullet traps are designed to decelerate the bullet and collect the resulting fragments. Some bullet traps are also designed to minimize airborne lead dust created when bullets strike the traps. Many bullet trap manufacturers recommend the use of personal protective equipment (PPE) when servicing bullet traps.

The United States Army Environmental Center (USAEC) is currently evaluating the performance and environmental issues associated with bullet traps. USAEC is reluctant to recommend use of bullet traps on outdoor ranges until further information can be developed from demonstrations and currently installed traps. Manufacturer's claims for complete capture of all fragments and dust are still being evaluated by USAEC. An improperly designed or improperly installed bullet trap could actually increase the potential for lead dust creation and migration on outdoor ranges.

Impact Berms
Most outdoor firing ranges use soil impact berms behind the target line to stop bullets from leaving the firing range. These berms are usually constructed of mixtures of sand, silt, and clay soils. The floor of the firing range in the area of the target line may also consist of similar soils. Bullet fragments may be periodically removed from the range if their buildup in soils poses a risk of ricochet.

The design and construction of ranges, including the choice of material for impact berms, should consider pollution prevention opportunities. Ideally, an impact berm should decelerate fired projectiles safely with a minimum of fragmentation and generation of lead dust. The berm material should also be of a texture, e.g., clean sand, that maximizes the ability to separate spent fragments when range clearance activities are undertaken.

Lead Migration Prevention
Methods for prevention of lead migration include, but should not be limited to, implementing the following concepts where practical and safe:
  • Prevent slightly acidic rain water and snow melt from coming into contact with lead contaminated soils.

  • Construct water flow retarding structures, such as terraces and berms, to reduce the velocity of runoff water exiting firing range areas.

  • Use impoundments, traps, or other structures to catch lead particles in sediments transported away from the shooting area by runoff.

  • Elevate slightly acidic soils to a more neutral pH in areas where lead may come in contact with water by supplementing the soil with high-alkaline materials such as limestone, gypsum, and dolomite.

  • Do not relocate soils from ranges to other areas of a facility/installation.

Each firing range site is unique in terms of background lead levels, climate, soils, and topography. A plan for controlling lead migration must be designed based upon site characteristics. Typical plans include designs to control storm water runoff, protect the backstop/berm from rain, and provide a means for capturing and reducing the movement of lead fragments.

Document References
  1. "Closed, Transferred, and Transferring Ranges Containing Military Munitions; Proposed Rule," Department of Defense, 26 September 1997.
  2. "Military Munitions Rule: Hazardous Waste Identification and Management; Explosives Emergencies; Manifest Exemption for Transport of Hazardous Waste on Rights-of-way on Contiguous Properties; Final Rule," EPA, FR, Vol. 62, No. 29, page 6621,12 February 1997, codified at Title 40 CFR parts 260 through 266, and 270. Subpart M "Military Munitions" is in part 266.
  3. "Designation, Reportable Quantities, and Notification," Title 40 Code of Federal Regulations, Part 302.
  4. "Environmental Effects of Small Arms Ranges," Naval Civil Engineering Laboratory Technical Note N-1836, October 1991.
  5. "Lead and Outdoor Ranges," Charles W. Sever, Proceedings: National Shooting Range Symposium, 17-19 October 1993.
  6. "Revised Interim Soil Lead Guidance for CERCLA Sites and RCRA Corrective Action Facilities," EPA, July 1994.
  7. "Development of Toxic Free Ammunition," John R. Middleton, Project Engineer, U.S. Army Armament Research, Development and Engineering Center.
  8. "Green Bullets," Mr. Wade H. Bunting, U.S. Army Tank, Automotive and Armaments Command, Picatinny Arsenal, NJ, Sep-Oct 1997, HTIS Bulletin, Vol. 7, No. 5.
  9. "Bullet Traps on Outdoor Small Arms Ranges, Mr. Gene L. Fabian, U.S. Army Environmental Center, Aberdeen Proving Grounds, MD, Spring 1997, The Bridge.
  10. "Environmental Engineering: A Design Approach," Sincero, A.P. and Sincero, G.A., 1996.
  11. "Childhood Exposure to Lead in Surface Dust and Soil: A Community Health Problem," Duggan, M.J. and Inskip, M.J., 1985.