Investigation and Remediation
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Investigation and Remediation of a Small Arms Firing Range. JP Messier U.S. Coast Guard Civil Engineering Unit - Cleveland. Presentation Overview USCG Environmental Organization Regulatory Framework USCG Firing Ranges Site Characterization Remediation O&M and Upgrades Compliance

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Investigation and Remediation of a Small Arms Firing Range

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Investigation and remediation of a small arms firing range

Investigation and Remediation

of a

Small Arms Firing Range

JP Messier

U.S. Coast Guard

Civil Engineering Unit - Cleveland


Investigation and remediation of a small arms firing range

Presentation Overview

  • USCG Environmental Organization

  • Regulatory Framework

  • USCG Firing Ranges

  • Site Characterization

  • Remediation

  • O&M and Upgrades

  • Compliance

  • Pollution Prevention

  • References


Investigation and remediation of a small arms firing range

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


Investigation and remediation of a small arms firing range

  • Facilities Design and Construction Center (FD&CC)

    • Major Construction and Design Services

      • Atlantic – Norfolk, Virginia

      • Pacific – Seattle, Washington

  • Civil Engineering Units (CEU)

    • Minor Construction, Design, Environmental, and Real Property Services

      • Cleveland

      • Honolulu

      • Juneau

      • Oakland

      • Miami

      • Providence


Investigation and remediation of a small arms firing range

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


Investigation and remediation of a small arms firing range

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


Investigation and remediation of a small arms firing range

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


Investigation and remediation of a small arms firing range

(Taken from ITRC training)


Investigation and remediation of a small arms firing range

  • 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


Investigation and remediation of a small arms firing range

  • 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


Investigation and remediation of a small arms firing range

  • 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


Investigation and remediation of a small arms firing range

  • 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


Investigation and remediation of a small arms firing range

  • 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


Investigation and remediation of a small arms firing range

  • Remedial Alternatives Evaluation

    • Evaluation Factors

      • Future Land Use

        • Continued Range Operation

        • Industrial

        • Residential

      • Cleanup Goal Establishment

      • Budget and Timeframe


Investigation and remediation of a small arms firing range

  • 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


Investigation and remediation of a small arms firing range

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


Investigation and remediation of a small arms firing range

  • 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


Investigation and remediation of a small arms firing range

  • Soil Recycling

    • Chemically Treat/Utilize Soils in a Product

      • Rendered Inseparable by Physical Means

      • Meets Universal Treatment Standards

    • Road Base Emulsions/Materials


Investigation and remediation of a small arms firing range

  • Physical Separation

    • Use for On-Site Management or Off-Site Disposal

      • Dry Screening/Sifting

      • Bullet Fragment Removal/Recycling

      • Lower Limit of ¼ inch


Investigation and remediation of a small arms firing range

  • 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


Investigation and remediation of a small arms firing range

  • 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


Investigation and remediation of a small arms firing range

  • 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


Investigation and remediation of a small arms firing range

  • Soil Washing

    • Mineral Processing Technique

      • Physical Sizing

      • Magnetic Separation

      • Soil Classification

      • Gravity Separation

    • Bench-Scale Study Required to Evaluate Process


Investigation and remediation of a small arms firing range

  • 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


Investigation and remediation of a small arms firing range

  • 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


Investigation and remediation of a small arms firing range

  • 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


Investigation and remediation of a small arms firing range

Humates

Washes Oversized

Coarse Soil

Boulders

Separates by Size

Soil Fines

Particulate Contaminants

Separates by Density


Investigation and remediation of a small arms firing range

  • 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


Investigation and remediation of a small arms firing range

  • 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


Investigation and remediation of a small arms firing range

  • 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


Investigation and remediation of a small arms firing range

  • O&M and Upgrades – continued

    • Bullet Trap Systems

      • Decelerator

      • Granular Rubber

      • Block Rubber

      • SACON – Shock Absorbing Concrete

      • Earthen Berm


Investigation and remediation of a small arms firing range

  • 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


Investigation and remediation of a small arms firing range

  • 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


Investigation and remediation of a small arms firing range

  • 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


Investigation and remediation of a small arms firing range

Questions/Discussion


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