LINDA LINGLE CHIYOME LEINAALA FUKINO, M.D.

GOVERNOR OF HAWAII DIRECTOR OF HEALTH

STATE OF HAWAII In reply, please refer to:

File: EHAlHEEROfftce
DEPARTMENT OF HEALTH
P.O. Box 3378
HONOLULU, HAWAII 96801-3378

February 2,2008

Mr. Mike Smith

District I Supervisor,
Department of Parks and Recreation
2015 Kapiolani Blvd. '
Honolulu, HI 968 14

Facility: Koko Head Shooting Complex, Hawaii Kai, Hawaii Kai, Oahu

Summary of January 15,2009 Site Visit and Recommendations for

Best Management Practices to Reduce Potential Lead Exposures

Dear Mr. Smith:

On January 15, the Department of Health made a site visit to the Koko Head Shooting Complex to
assess potential hazards to neighboring communities or the local ecosystem from range activities.
Representatives were present from the Clean Water Branch, the Clean Air Branch, the Solid and
Hazardous Waste Branch and the Hazard Evaluation and Emergency Response Office.

The purpose of the visit was to examine current conditions at and around the range to evaluate the
potential for lead or other contaminants to migrate offsite and impact area residents, recreational users
or the nearby marine environment. In particular, the following issues were examined: surface water
erosion and runoff potential, impacts to groundwater, potential for migration of lead contaminated dust
offsite, management of wastes generated, and likelihood of exposure within the shooting complex.
Projectile materials were widely distributed across the ranges, with dense concentrations in the target
areas. At the time of the visit, all of the ranges were well vegetated, and there was no evidence of
blowing dust. A summary of our conclusions by media and potential exposure is attached. Note that
we did not evaluate noise concerns.

The site visit did not identify any imminent threats to human health or the environment, or evidence of
off-site migration of contaminants at this time. However, Department of Health has the following
recommendations to reduce the likelihood of potential exposures:

1. Post Do Not Enter signage at key locations around the crater boundaries to alert hikers and other
recreational users in the area about the active range. Lead in soils within the shooting complex is
above levels that are safe for unrestricted use, and so access restrictions are important. Signs can also
serve to alert these inadvertent visitors of potential risks from projectiles.
Letter to Mike Smith
February 2,2009
Page 2 of 2

2. Review and implement appropriate best management practices from the enclosed Technical
Guideline: Environmental Management at Small Arms Firing Ranges, February 2005, prepared by the
Interstate Technology & Regulatory Council. In particular, we recommend:

a. Communicating with range complex users, through signage or usage agreements, about
appropriate practices to limit their exposures to lead and other contaminants. Such warnings
might include recommendations about hygiene practices to avoid inadvertent ingestion of fine
particles, including restrictions on eating, drinking or smoking in the firing areas.

b. Keeping berms well maintained to reduce ricochet potential and creation of fine lead particles

c. As needed, reducing dust in target areas through irrigation and re-vegetation to reduce potential
for wind erosion of contaminated materials.

d. Consider instituting an ongoing reclamation/recyclingprogram to reduce volumes of spent

projectiles in the range areas, and further reduce ricochet potential. Because the main mass of
spent projectiles are concentrated in small target areas, they are amenable to manual removal
actions. This practice reduces contaminant mass on site, reducing potential future exposures to
contaminants.

e. Ensuring that the existing recycling program for shells casings in the rifle and pistol shooting
ranges is managed appropriately. The firing range should set up a Satellite Accumulation Area
(SAA) at each of the six firing ranges. These SAAs should be clearly defined and have
appropriate signage for the areas; have no more than one 55 drum that is clearly marked with
its contents at each SAA, and the drum should be covered and secured at all times when not in
use. Furthermore, a log should be set up at each SAA for the deposition of spent lead shots and
removal by the recycler. The recycler should provide receipts to the firing range. Any
additional reclamation efforts under item d., above would need to follow the same procedures.

f. Using appropriate dust protection for worlters when disturbing potentially contaminated soils

HEER agreed to provide technical assistance to the range to investigate cost effective mechanical
separators that could be used for ongoing range maintenance and lead recycling.

We look forward to your response. If you have questions, please feel free to call Cal Miyahara at 808-
586-4249 or email him at calen.miyahara@,doh.hawaii.gov. You are also welcome to contact me.

Site ~ i s c o & r & k & d n e n t and Remediation Section

Hazard Evaluation and Emergency Response Office
Letter to Milte Smith
February 2,2009
Page 3 of 3

c: Dr. Chiyome Leinaala Fukino

Mr. Steve Brennan
Milte Muramoto, Kolto Head Shooting Complex
Matt Kurano, Clean Water Branch
Jack Liu, Clean Air Branch
Jeff Ung, Solid and Hazardous Waste Branch
Letter to Mike Smith
February 2,2009
Page 4 of 4

Department of Health
Summary of Conclusions
Site Visit to Koko Head Shooting Complex
January 15,2009

Attendees from the Department of Health included:

Fenix Grange ,Cal Miyahara, Dr. Roger Brewer, Dr. Barbara Broolts, HEER Office
Jeff Ung, Solid and Hazardous Waste Branch
Matt Kurano, Clean Water Branch
Jack Liu, Clean Air Branch

I. Offsite Migration Pathways

No offsite migration of contaminants was observed during the visit.

Surface Water Management. Due to the topography of the formation, all surface water from the
facility infiltrates into the ground, there is no surface runoff potential to Hanauma Bay or other areas of
the park.

Groundwater Protection. The groundwater resource under the complex is below the UIC line and is
not used for drinking water. Given the soil characteristics and the local hydrology, it is unlikely that
lead in soils would leach into the groundwater at concentrations that could cause harm to the
environment or human users along the shoreline or within the nearshore marine environment.

Air Quality. The only potentially complete offsite migration pathway identified during the site visit is
offsite movement of contaminated dust through wind erosion. While dust created during shooting into
dry, unvegetated berms, in combination with moderate to strong tradewinds has the potential to erode
soils westward from exposed target areas in the pistol range and the skeet shooting range, it is highly
unlikely that enough dust could be generated to create any human health hazard offsite. The target
areas at each of the ranges cover relatively small areas (<5,000 square feet), and would not be expected
to generate enough mass for transport of fine lead particles over the crest of the crater, leading to
deposition and accumulation of either in the public areas of the district park or in the nearest homes,
which are more than one quarter mile away (see attached aerial).

DOH proposes a follow up visit to the site to visually assess the dust issue during summer, 2009,
during worst case conditions (open range, dry, exposed soils, moderate to strong tradewind
conditions) to confirm this assessment.

Waste Management Practices It was reported that shell casings are collected and recycled. We
recommend that KHSC follow up with the Solid and Hazardous Waste Branch to ensure that recycling
management practices are in keeping with state law. SHWB add info here.. .....
Letter to Milte Smith
February 2,2009
Page 5 of 5

11. Potential On Site Exposure Pathways

Recreational Exposures During Range Use. According to the Environmental Protection Agency
(1ittp:llwww.acslpa.orglEPA-LeadAtOutdoorRanges-RMP-Manual.pdf) the relative risk of lead
exposure to people at a well-managed shooting complex is low. Worlters and shooters have the
highest exposure to lead at shooting ranges. Shooters can be exposed to lead during the firing of guns.
Dust on the shooters' hands is also another source of exposure, particularly for inadvertent ingestion as
a result of eating, drinking or smoking. Range workers can also be exposed to lead dust during
maintenance. Clothing and shoes used at the range from the range can carry lead dust into the home.

Soil Exposures. Soil concentrations of lead and other contaminants within the shooting complex are
above acceptable levels for unrestricted use. In addition, the pellets themselves have high levels of
lead and accidentally eating the pellets poses a health risk. To safely manage the contaminated soils in
place, care must be exercised to ensure that children are not allowed to play in or around the soils, that
the soils are not reused offsite and that appropriate hygiene practices are implemented by all range
visitors. Because entry to the shooting complex is not controlled, warning signs alerting visitors to
potential hazards would be prudent.