Risk of Lead Migration On Small Arms Firing Ranges (2014 - 09 - 18 13 - 49 - 44 UTC)

RISK OF LEAD MIGRATION ON SAFRS 1
Risk of Lead Migration on Small Arms Firing Ranges
Andrew P. Cempa
ENMG 6200
Webster University, June 2014

LEAD MIGRATION ON SAFRS 2
Contents
Abstract................................................................................................................................5
Situation Analysis................................................................................................................7
Premise..............................................................................................................................10
Study Limitations...............................................................................................................11
Focus of Research..............................................................................................................11
Applied Research Methodology........................................................................................12
Participants........................................................................................................................12
Modelling Techniques Utilized..........................................................................................12
Comparison Analysis.........................................................................................................13
Study and Findings............................................................................................................15
Problem Statement.........................................................................................................15
Description of Lead deposition processes.....................................................................15
Rifle and Pistol/Fixed impact area Deposition..........................................................15
Aerial Target/Shotgun/Shot fall Zones Deposition....................................................16
Research Objectives...........................................................................................................17
Purpose..........................................................................................................................17
Scope..............................................................................................................................18
Science and Theory of Lead in the Environment..............................................................18

History of Lead as both a Human health hazard and an Environmental Hazard
Research.....................................................................................................................................18
Relevant Research.........................................................................................................18
General Conditions on SAFRs.......................................................................................19
Concern over Migration of Contaminants.................................................................19
Basic considerations for Migration of Lead from SAFRs.........................................20
Literature Search................................................................................................................21
Primary Research Considered........................................................................................21
Environmental Fate of Lead in Florida Shooting Range Soils (Hardison D. , 2003)21
Lead Mobility at Shooting Ranges (SAAMI, 1996)..................................................26
Secondary Research Considered....................................................................................34
Corrective Action at Outdoor Ranges Guidance Document (Colorado Deptartment
of Public Health and Environment, 2012).............................................................................34
Lead Mobility In Soil: A Refresher (Morton, 2001)..................................................36
Risk Model Employed.......................................................................................................38
Findings.............................................................................................................................40
Observations..................................................................................................................40
General.......................................................................................................................40
Conclusions........................................................................................................................41
Risk Assessment................................................................................................................41
Human Health Risk........................................................................................................41
Human Health Risk Modelling on SAFRs................................................................43
Environmental Risk.......................................................................................................47
Summation of the problem and outcomes.........................................................................51
Premise Assessment...........................................................................................................53
Premise Restated................................................................................................................53
Premise Evaluation............................................................................................................53
Recommendations for Future Studies................................................................................55
Environmental................................................................................................................55
Range Design, Management and Operations.................................................................55
Bibliography and References.............................................................................................56
Appendices........................................................................................................................58
Abstract
Lead, a known hazardous element that has a wide range of biological and systemic effects
on both humans and the environment, has been aggressively controlled by the US Government to
prevent contamination and potential exposure. Metallic lead (Pb) is a known toxic substance
subject to strict controls and is a primary component of ammunition shot on Small Arms Firing
ranges (SAFRs). Migration of lead from SAFRs into both soils and water sources is a topic that
evokes passionate discussion from both shooting and environmental groups. There is little risk of
lead becoming mobile and impacting the environment off SAFRs. The use of lead in ammunition
in the shooting sports and for self-defense, hunting and law enforcement/national defense is
widespread. There are many thousands of public, private and government owned/operated
shooting ranges in the US where many thousands of tons of lead is deposited into and on to the
range complex annually. Lead is potentially active in the environment due to geochemical,
physical and human activity. Lead can be weathered, abraded, fragmented and dissolved after
deposition due to environmental conditions and chemical and mechanical action. Ranges are
designed to limit the dispersion of lead as a safety mechanism and range design features
concentrate lead bullets, fragments and shot into relatively small areas. Comparatively, several
studies concerning the fate of lead on SAFRs were studied and contrasted. Both studies used
standard testing procedures and standards to arrive at similar conclusions. Lead is both capable
of being environmentally and biologically active and available due to known geochemical and
mechanical causes found on SAFRs. However, the probability of migration of lead in both
metallic and mineral form is low due to those same processes and other inherent qualities of
range design, operation and management (both general and environmentally focused). Therefore
the risk of lead migrating from SAFRs is low. Additional studies primarily designed to
dcharacterize range design and management should be conducted to better define more effective
use of materials, construction and passive controls to further reduce the likelihood of lead
migration.
Keywords: migration, mobility, bioavailable, geochemical, SAFR, weathering, risk

Situation Analysis
The use of lead in ammunition has increasingly come under scrutiny from both human
health and environmental concerns. Since the institution of the US Environmental Protection
Agency and its statutory oversight of pollutants in the environment, lead has become a major
concern for both human and environmental health. Shooting ranges have found themselves
scrutinized by citizens groups and state and federal agencies over the presence of lead that is
obviously being deposited thereon. Rulings from federal courts have reinforced the need for
control of lead on and off firing ranges. While firing ranges deposit many tons of lead into the
environment annually, this is only a tiny portion of lead consumed in the US. According to the
US Geological Survey, the 65,000 metric tons of lead used for ammunition (both private and all
government and military organizations) in the US in calendar year 2010 comprises only 4.5% of
the total volume (1,430,000 metric tons)of lead used (USGS, 2012). While 4.5% seems like a
small portion, and it is, it is interesting to note that while there are no specific controls on how
individuals dispose of most lead bearing items (electronics, plumbing fixtures, lead bearing dry
cell batteries) it is of great public and politic interest how SAFRs manage their use of lead.
Lead is uniquely suitable for use as a major component for small arms projectiles for
many reasons including cheapness, availability and metallic characteristics. As a relatively
common metal that is fairly easily refined from widely available ores, it is inexpensive and
plentiful. Its malleability, ease of forming into shape either by molding or swaging and density
make it very useful for small arms projectiles. Lead is one of the densest common metals;
ballistically, density is critical energy transfer and trajectory efficiency.
Lead is deposited on outdoor Small Arms Firing Ranges (SAFRs) in large amounts by
shooters. Annually, American target shooters expend approximately 58000 of tons of lead
bearing ammunition on these SAFRs (US EPA, 2001). This lead is fired at a variety of target
media and into catchment berms, or at steel reactive targets on rifle and handgun ranges or is
shot onto shot fall zones on aerial clay target shotgun ranges.
The deposition of lead and other known contaminants on SAFRs is a unique situation.
Lead and other materials on SAFRs are unequivocally not defined as waste and therefore not
subject to the controls established for dealing with materials that are wastes by definition (US
EPA, 2001).
Unlike lead in paint, unintentional releases, accidents etc., lead shot during firing is not a
waste process. Specifically and critically, lead on firing ranges is defined by the US EPA as
“expended as intended” and not subject to CERCLA or other remediation requirements for waste
until the range is permanently closed and the land is determined for use other than a firing range
(US EPA, 2001). This condition wherein lead is deposited into the environment intentionally and
routinely is unlike an industrial or manufacturing operation dealing with lead. In this case, lead
is not a product or waste, but it is a part of a procedure. Bullets are not the focus, they are simply
a media used to effect an outcome. Once a shot is expended, it and its fragments are either
deposited on the surface (fragments, shotgun shot) or buried in an earthen or fabricated berm
where they undergo weathering processes to varying degrees based on the materials,
construction and exposure to weathering agents (sunlight, water, soil chemistry, erosive action
etc). It is this aspect of the process we are looking at-what happens after the lead component is
deposited. Does weathering by exposure to air, water or soil promote mobility from its in-situ
location to either soil or water resources off the range? While this question is easily answered by
even the most elementary chemist, the issue goes deeper than this. The real question is whether
the lead deposited and weathered actually creates a potential risk to both human and
environmental health. Many studies have been conducted that would tell different stories, given
the test protocols and conditions created to replicate the gross chemistry of the equation. The
final issue is whether lead in any of its forms, elemental (metallic) ionic or compounded, does
create actual exposure to biological life simply by being present on the SAFR?
Premise
Metallic lead (Pb) is a known toxic substance subject to strict controls and is a primary
component of ammunition shot on Small Arms Firing ranges (SAFRs).
Migration of lead from SAFRs into both soils and water sources is a topic that evokes
passionate discussion from both shooting and environmental groups.
There is little risk of lead becoming mobile and impacting the environment off SAFRs.
Study Limitations
Focus of Research
We will limit the focus of this research effort to the chemical and mechanical processes
that impact the mobility of lead from ammunition deposited in/on to SAFRs. Specifically, we
will focus on the chemical reduction of metallic lead from projectiles and shot as a process of
weathering by exposure to air and water and mechanical breakdown of lead objects. Finally, we
will consider the relevant research available to better understand the risk and probability of lead
migrating from SAFRs.

Applied Research Methodology
Participants
This study was conducted solely by the Author.
Modelling Techniques Utilized
For this study, actual scientific research conducted on soils, environment and lead and
how they interact in-situ as well as how lead deposited from gunshot into and onto soils found on
SAFRs will be used as a baseline of understanding the problem. There are many instances of
SAFR s in history where lead deposition was questioned as a source of environmental as well as
human health risk. We explored many of these relevant cases to better understand the problem
and have elected to use several primary and several secondary research studies to determine
through comparative analysis whether lead deposited on SAFRs creates a risk of both mobility
from the SAFRs as well as how and if lead on the SAFR actually constitutes a hazard to person
and the environment thereon. We had to identify and isolate several contexts to arrive at the
core issues. Primarily, historical cases show that an assumption that a high concentration of
metallic lead on a firing range constituted a hazard. However, as an avid marksman, personal
experience shows that the zone of separation between firing of ammunition and the final
deposition of the expended ammunition indeed creates a standoff between man and lead. Next,
we determined that both with impact berms and shot fall zones, there is little to no probability of
harm to the environment due to the nature of the reaction of lead projectiles into berm media,
rain water effect and weathering in general. Nature has a way of reducing or converting lead
into either harmless compounds, or suspending potentially harmful compounds of lead into the
soils where they then are found to be relatively inert and immobile.
Ranges of the past as well as modern ranges are designed to minimize exposure of shot
fall or impact to humans as a safety feature, however this design feature generally also protects
man and nature from other potential hazards associated with lead. Controlled entry, perimeter
fencing, rural settings, barriers to impact and catch bullets, curtains to stop shot, landscaping to
suit the range types. Drainage and erosion controls primarily designed for range operations and
shooter comfort also provide for soil stability and mobility reducing characteristics. Finally,
exposure to lead/lead minerals is reduced to very low or non-existent to users and maintainers of
SAFRs through the natural stand-off or separation of occupant/firer to deposition of expended
lead. Logically, a potential hazard with no exposure results in no risk. With this in mind, also
used is the US EPA Outdoor Firing Range Best Management Practices Handbook (US EPA,
2001) as a companion tool to better understand the complexities and relationships between the
shooting range developer/manager and the end result of lead deposition on the range.
Characteristics pertaining to both rifle/handgun (fixed and dedicated impact areas) and aerial
(clay target) (widely scattered but well defined surface shot fall zones) ranges were analyzed and
evaluated for risk of lead migration in either surface or near surface zone soils, surface water
and or ground water resources on and off the range complexes. Once the primary research was
evaluated for probability of decomposition of lead, then the contributing factors and conditions
that may lead to lead becoming mobile and leaving the range area were analyzed and assessed to
determine the reasonable probability of if and how much lead would indeed be leaving the
SAFR.
Comparison Analysis
For this study, we recognized that there is a large body of scientific material available for
the exploration of the topic. We chose to use several studies that clearly take a scientific
approach to the concern of lead on SAFRs and how it reacts with its environment. There are two
primary mechanisms that we chose to focus on for this study. First, the chemical characteristics
of metallic lead in an in-situ condition and secondly, the mechanisms present in the environment
that would move metallic lead physically from the impact areas or shot-fall zones on a range off
the premises and into the surrounding environment in general.

Study and Findings
Problem Statement
Lead from ammunition is deposited on SAFRs in varying quantities and in various forms
on SAFRs across the nation. Since lead is an element with known human health and
environmental impacts due to toxicity primarily due to ingestion and inhalation exposures, we
want to explore how lead is deposited, what mechanisms effect the lead once deposited on or into
range soils, how soil chemistry, hydrologic cycling and weathering processes reduce lead into
bioavailable components and what impacts it has to human health and the environment off the
range property.
Description of Lead deposition processes
Generally on SAFRs ammunition is fired toward a safe area where both enough distance
and area is available, or a dedicated impact area is defined, built and maintained to catch
projectiles and fragments of bullets created at impact to create standoff from any persons or
property to reduce safety risk. Some firearms (rifles) have a maximum range of several miles
when fired at optimal elevation with no horizontal limitations. There are generally two types of
SAFR commonly in use in the US; those using single projectile ammunition and shotgun/aerial
target ranges.
Rifle and Pistol/Fixed impact area Deposition
In this type of range design, bullets made of lead and other trace elements, often covered
in a copper/zinc envelop or jacket are fired at targetry made of paper, cardboard or steel and
catchment berms with surface impact zones between the firing line(s) and catchment berms and
beyond as safety areas. When bullets impact soft targetry, they penetrate and continue on to
either impact surface areas or berms with resultant abrasion, smearing or fragmentation of the
bullet as it decelerates/penetrates the range surfaces. When impacting steel targetry, bullets often
are destroyed beyond recognition and
residual fragments range in size from
atomic to somewhat less than
original bullet size. These bullets and
residuals from bullets are found buried
and/or scattered on or near the surfaces of the catchment materials. Catchment materials are
often constructed of sandy clay soils or local soils
which are screened to remove rocks which reduces
ricochet potential. Expended bullet materials
remain in-situ for varying durations, often years or
decades. More ranges recycle bullet materials
from concentration areas to both remove lead and other bullet components for re-smelting as
well as for environmental control purposes.

Aerial Target/Shotgun/Shot fall Zones Deposition
Shotgun ranges usually are much more
compact than rifle and
pistol ranges due to the reduced maximum
range of small lead pellets. Shot fall zones are
probabilistic areas wherein virtually all
expended pellets land and concentrate on the
surface or very near the surface. Often,
multiple trap and skeet fields are oriented
toward a central point and shot fall zones
overlap increasing the concentration of pellets over time. As in rifle and pistol ranges, shotgun
pellets are recovered and sold as scrap to both generate funds for maintenance or other fiscal
requirements as well as to remove lead from the range for environmental or human health
reasons (NSSF, 1997).

Research Objectives
Purpose
The purpose of this research is to scientifically evaluate relevant research to see if and
how lead is made available for potential migration off SAFRs and into the surrounding
environment. We will also explore the inherent characteristics of SAFRS in terms of design,
construction and general landscaping or maintenance. We will look at what exposure to human
health or the environment, if any, is created by all of the above considerations. Finally we will
conduct brief risk assessments on both the human health and environmental impact of the results
analyzing whether lead deposited on SAFRs migrates and what residual exposure, if it does
migrate it poses to human and environmental health. And, if so, how does that lead impact both
the environment and human health concerns?
Scope
Only outdoor ranges and lead impacts or affects to surface or ground water and soil and
resultant risk of exposure to human or environmental health will be explored. Best Management
Practices are assumed to be reasonable and appropriate for controlling lead migration and
potential contamination off-range (US EPA, 2001). We will not address air quality as there are no
known requirements for outdoor SAFRs.
Science and Theory of Lead in the Environment
History of Lead as both a Human health hazard and an Environmental Hazard Research
 Lead has been identified as a poisonous substance to human and other life forms.
 Lead is a common elemental heavy metal found in varying concentrations and
forms (primarily Carbonates, Oxides, Hydroxides, Sulfates/ides and Phosphate
minerals) throughout the US
 Lead a known toxic substance controlled by the US EPA since the 1960s
 Metallic lead readily reacts with Oxygen, Sulfur, Phosphorus once exposed in the
environment
 Soil composition contributes to the reactivity of lead
 pH of surface and ground water is key to geochemical weathering of metallic lead
(acidic conditions increase reactivity, alkaline conditions reduce reactivity

Relevant Research
There are many types of research involving Lead and SAFRs. Many of these reports
studies and assessments are based on real or perceived problems of lead becoming mobile and
effecting the environment. Often, many cases are resolved at the local or state level and require
nothing more than application of an effective EM program by using well-known and widely
practiced techniques to mitigate the risk of lead mobility. Often, shooting ranges are found to be
“out of compliance” concerning concentrations of lead in the soils or waters of the facility, and
oversight entities direct remediation, cleanup and sometimes “cease operations” orders. Usually,
once a range that is found to be out of compliance for lead, the range operator or club contracts
for an independent assessment to determine if the concern is valid. These specific assessments
are designed with the peculiar conditions of shooting ranges, rather than a generic test for lead in
some location being higher than allowed. We looked at several cases where ranges were cited
based on a complaint, and were then excused due to a better understanding of what lead does on
a range, given proper management and mitigation procedures.
General Conditions on SAFRs
SAFRs of specific concern for this study are characterized by the following general
criteria: Outdoors, weather exposed impact surfaces, continuous operation and non-explosive
ammunition specific. These generic criteria enable our efforts to focus on lead deposition that is
subject to weathering cycles of sunlight, rain/surface water, erosive effects by both water and
wind and human activity (mowing, routine occupation and maintenance).
Concern over Migration of Contaminants
Given the toxicity of lead to both humans and environment, SAFRs are scrutinized as
potential sources of lead contamination to both humans and the environment in general. Since
lead on the range itself is an understood condition, we will analyze and assess the risk of lead
migration off the range property by looking at the weathering processes and best management
practices (BMP) in general use by SAFR operators. While it is obvious that lead will be present
on SAFRs, it is not so obvious whether the presence of that lead and its weathering species are a
hazard given the specifics of firing operations to include, shooting, maintaining and grooming
the range itself (NRA, 2012).
Basic considerations for Migration of Lead from SAFRs
After deposition by discharge from a firearms occurs, subsequent processes and
mechanisms occur that reduce the mass of a given bullet. Abrasion, smearing and fragmenting
of bullets into impact media, are the immediate mechanisms that increase surface area of bullet
lead and begin the potential processes of weathering of metallic lead into other lead minerals.
Some of these lead
minerals are quite
benign (lead
pH Availability phosphates) while
others (lead
Duration carbonates) are
much more
bioavailable. In the former, lead phosphates, which form when lead is exposed to soils or soil
amendments high is phosphorus, react to create a strongly acid resistant compound which both
reduces bioavailability of lead at the ionic level, as well as isolates the underlying metallic lead
from further weathering even in rather acidic soils/rain. Lead carbonates on the other hand, are
soluble in mildly acidic rain or surface water and may be bioavailable to animals and are often
absorbed by plants as well.
On ranges with good drainage, well planned elevations and storm water control, rapid
removal of water from impact areas/shot fall zones reduces the exposure time of lead to water
and mitigates the potential for acid reduction of bullet or pellet lead in other surface water.
Additionally, soil amendments consisting of phosphate rock preparations that are cyclically
mixed into or spread on to concentrated areas readily converts exposed lead to lead phosphates,
further removing lead from availability to further weathering (NRA, 2012), (US EPA, 2005).
Literature Search
Primary Research Considered
Environmental Fate of Lead in Florida Shooting Range Soils (Hardison D. , 2003)
Introduction
In the first study analyzed, the authors conducted scientific testing to determine what
happens to lead when fired into a homogenous sand catch box. The 22 caliber rimfire projectiles
are composed of a soft lead alloy. The catch media was fine sand. The resultant testing showed
that small amounts of metallic lead were abraded from the bullets as they impacted and
decelerated in the catch media. This media and its minute fragments of metallic lead were then
treated IAW EPA TCLP standards for determining residual lead and concentration. This test,
while of relevant scientific value, simply shows that bullets made of lead indeed leave metallic
residues in the impact media. This is no surprise. The toxicity testing is of concern, however,
since the impact berms on SAFRs are not places where humans congregated, unlike an
industrial center or similar location where a potentially hazardous material would be
concentrated and human exposure occurs. Indeed, the down range areas of SAFRs are off limits
to all personal and are accessed by maintenance and mowing personnel on infrequent basis and
generally not disturbed during activities short of major bullet material recovery or earthwork of
similar magnitude. This is one major consideration to be understood. Bullet lead deposition on
SAFRs is NOT a major health concern to humans nor most other animal or plant life with
exceptions. To treat lead where it belongs on SAFRS as an occupational or general health risk is
nonsensical. Indeed, the EPA clearly demonstrated that CERCLA and other clean-up regulations
and practices only apply to SAFRs when they are permanently shut down and shooting activities
terminated (US EPA, 2001). Bullets fired on SAFRs are “expended as intended” and are not
categorized as waste as well. “Lead shot 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) is not regulated nor is a RCRA permit required to operate a
shooting range. However, spent lead shot (or bullets), left in the environment, is subject to the
broader definition of solid waste written by Congress and used in sections 7002 and 7003 of the
RCRA statute.” (US EPA, 2005). The above rulings are of great importance to operators of
SAFRs as they are therefore not required to obtain permits for RCRA purposes.
Situation and Conditions
Hardison replicates several range conditions likely found on south Florida shooting
ranges and his research uses test procedures that are standardized for determining residual lead
and concentration levels as if the situation was a clean-up response to a contaminated area
(Hardison, 2003). With plentiful rainfall, soils that are not favorable to reduced mobility
(lacking clays and fines), erosive weather patterns, Hardison’s study seemingly is a worst case
for lead migration.

Scientific Methodology
In his testing, Hardison uses both a contrived test strategy (bullet catch box) and in-situ
discovery of bullet lead concentration and fragment size determination using basis scientific
methods of controlled deposition and subsequent sieving of media to separate the intact bullet
mass and then weigh it to determine residual lead in soils by abrasion and overall in-situ
characterization of shot fall within the soil column. Hardison uses standard EPA TCLP testing
protocols to determine the residual concentration of lead in the soil of the test media. This is in
keeping with the practice of determining lead concentration for the purpose of identifying
potential exposure risks.
Results
Hardison’s study clearly shows that in simulated south Florida weather and soil
conditions, residual lead indeed is found on SAFRs. Again, this is not a surprise; nor are his
findings that concentrations of lead and lead minerals are at levels greater than allowed by EPA
for toxicity. No objection to his methodology is noted. Indeed, for characterization of lead
concentration and mineralization etc.; his testing probably would be sufficient to allow for design
of a remediation strategy should the range in question be considering shuttering operations and
clean up. Given that 22 Rimfire ammunition is of a fixed heel crimp type and therefore not able
to be separated to weigh the bullet apart from its case and propellant and then reassembled and
fired, it seems that the best Hardison could do in knowing the original mass of the bullets fired
into the media box would be to assume that every bullet weighed exactly as much as it was
advertised. Common 22 Long Rifle Rimfire ammunition is found in various bullet weights,
normally 40 and 38 grains of lead. However, these bullets can and do vary to some extent so
Hardison’s assumed weight could be incorrect to a few grains per bullet. Therefore the
recovered mass of expended abraded bullets is not accurate regardless of what his measurement
was, as is by extension the mass of abraded lead remaining in the test media. Hardison did not
describe any control to this variability situation. Perhaps he could have separated a statistically
significant number of rounds of ammunition from the same lot and weighed the projectiles to
gain an understanding to the average weight and average deviation to create a baseline for the
actual test.
Abraded lead was found to weather rapidly and nearly completely into a lead carbonate
(PbCO). These lead minerals are soluble in mild acids and could be risk factors to human health
if exposure was defined. Hardison further states that given the climatic conditions extant in
South Florida (poor soils, abundant rain), this residual concentration of lead and lead minerals
could indeed be found to become mobile from the range and become a hazard to both humans
and the environment. He states this without actually testing adjacent land and water to determine
if this indeed is the case.
Discussion and Analysis
Hardison shows that under standardized EPA test conditions indeed, residual minute
fragments of lead shot into homogenous impact media generally found in South Florida weather
easily into lead minerals which are able to migrate off SAFRs and on adjacent soils and water
sources. However, the abrasion test used is not an actual in-situ exploration and subsequent tests
used are procedures designed and purposed to determine presence of and concentrations of lead
defined as contaminants. This is, unfortunately irrelevant to the concerns of lead migration.
Indeed, Hardison’s study would be of value to the range operators in south Florida if they were
shuttering firing operations and planning on remediating the SAFRs soils and waters for re-
purposing or resale. The flaw in Hardison’s study is his equation of the presence of lead and lead
minerals in soils with risk of exposure either on or off the range, which simply is not pertinent to
the basic concern of SAFR operation. Contamination without exposure breaks the risk
characterization equation and process by delinking a hazard to exposure. “Without exposure to a
particular pollutant, there is no risk” (Molak, 1997, p. Ch I.1.4). This is a basic equation, there
must be present both elements- a hazard to cause harm and a probability of being exposed to that
harm.
Dick Petticord clearly states that the failure of these types of assessments of lead on
SAFRs is that they consider SAFRs as significant hazards to human or other life forms due to the
mere presence of lead and lead minerals (Petticord, 2001, p. 106). Petticord further demonstrates
that the process of environmental risk assessment and analysis using CERCLA standard
procedures fails to address the probability of exposure and solely focuses on dose (Petticord,
2001, p. 109). That is to say that O2 is a human health hazard in high concentrations, yet fails to
recognize that the natural concentration of O2 is needful for life, while exposure to high
concentrations of O2 is highly unlikely in any normal human endeavor. Characterization of
toxicity without proper consideration of exposure unfortunately seems how many government
entities and special interest groups react to lead or other potentially harmful residues found on
SAFRs and is based on the dose/hazard found in occupational/residential settings where people
are found in continual contact or near continual contact with the hazard, thereby being exposed
to a dose over time-with a likelihood a achieving some sort of dose-response. Such a flawed
assessment of the presence of lead on SAFRs leads to declarations of hazardous concentrations
and resultant orders to remediate-even if an actual exposure condition is missing from the risk
analysis equation. Hardison’s study is lacking a meaningful application of exposure to residual
levels of lead and lead minerals as it applies to human or environmental health hazards.
Looking at the residual lead, both metallic and mineral, solely as a function of
concentration as defined by toxicity is not likely to draw rational and practicable conclusions
about exposure to either humans or the environment in general. SAFRs operate in a highly
regulated fashion to assure legal and financial risk avoidance. Controls ranging from impact
berm and shot fall zone siting and overlap, to super elevation of impact area surfaces and
drainage control and design all are optimized to reduce exposure of bullet materials to
weathering and migration action by storm water runoff. Restricted access to impact areas and
overall access to the SAFR in general control (reduce) the exposure of humans to potentially
harmful lead and lead minerals. Furthermore, Hardison does not explore the mitigation of
either lead or soluble lead mineral concentration by simple alteration of the conditions which
produce availability of these harmful materials by application of surface or near subsurface
application of phosphate bearing rock or other amendments.
Lead Mobility at Shooting Ranges (SAAMI, 1996)
Introduction
The Sporting Arms and Ammunition Manufacturers Institute (SAAMI) is the primary
professional collaboration arm of the industry. It tests and creates safety standards for many
aspects of the shooting sports, from cartridge dimensions and pressure specifications, to range
design and operational guidance to provide the best, safest and most economical solutions to the
industry and the general public. One of its efforts includes the understanding of lead on SAFRs.
SAAMI undertook a major project to explore and publish the actual science of lead on
SAFRS and its impact on the environment, in the context of both shooting clientele as well as
impacts to the general public and the environment. SAAMI published its findings in a
document titled Lead Mobility at Shooting Ranges which is cited in the above section heading.
This study included the chemical, mechanical and weathering processes that lead from spent
ammunition goes through on shooting ranges in many soil, weather and design situations.
SAAMI does not claim that lead is not a harmful substance, rather it clearly and concisely
describes the actual processes and subsequent impacts of lead on and off SAFRs. Specifically,
SAAMI states “A variety of issues have been raised about potential environmental impacts of
lead associated with shooting ranges, including the potential mobility of lead that may be
transported from shooting ranges. Of the metals present in shot and bullets, lead is the dominant
component, is the most likely driver of potential environmental risk at shooting ranges, and will
be the focus of this assessment. Hence, this review of scientific literature was conducted to
summarize the current understanding of the environmental mobility of lead in surface or ground
water, sediment, and soil, and the factors controlling lead mobility.” (SAAMI, 1996, p. 11).
SAAMI’s document is a comprehensive work that examines the processes of deposition, what
happens upon deposition, what happens after deposition over time and the processes that interact
with lead during its deposition life cycle and its environmental impacts throughout. It also
describes mitigation and remediation options to both reclaim expended lead and the benefit of
periodic removal and simultaneous amendment application.
Situation and Conditions
SAAMI published this study due to the increased concern of lead from many sources
such as paint, industry etc. including SAFRs impacting the environment and potentially human
health (SAAMI 1996). Specifically, SAAMI focuses on the following mechanism or transport
routes concerning lead on SAFRs:

“Ranges exist in a wide variety of environmental settings, and the site-specific hydrologic
and geologic conditions can greatly influence lead mobility. The following illustrates some of
these conditions, all of which can interact in complex ways:
• Water- At many ranges bullets or shot are deposited on land, but at some the lead
falls directly into water.
• Rainfall - The amount and intensity of rainfall can greatly affect lead mobility.
• Acidity- The acidity of soil, rainfall and surface water are interrelated and can
greatly influence mobility.
• Vegetation - Vegetation affects runoff and erosion rates, as well as influencing the
chemical characteristics of soil that determine mobility.
• Soil - Characteristics such as mineralogy, coarseness, organic matter content and pH
affect lead chemistry and mobility” (SAAMI, 1996, p. 13).
Scientific Methodology
Lead is controlled by a set of parameters for determining acceptable lead concentrations
promulgated by the US EPA, via Clean Water Act, CERCLA, SARA and other laws to protect
human populations and the environment. These standards are:
WATER (Aquatic Life Criteria (60 Fed Reg 22228: 4 May 1995))
• Freshwater Chronic Criteria (dissolved) 1.0, 2.5 and 6.1 µg/L (parts per billion - ppb)
at water hardnesses of 50, 100 and 200 mg/L, respectively.
• Saltwater Chronic Criteria (dissolved): 8.1 µ g/L Drinking Water Regulation Values
(40 CFR 141)
• Maximum Contaminant Level Goal (MCLG): zero (40 CFR 141.51)
• Lead "Action Level": 15 µ g/L in >10% of tap water samples (40 CFR 141.80)
SOIL (RCRA Hazardous Waste Characterization (40 CFR 261.24)
• TCLP leachate extract concentration of 5 mg/L (parts per million - ppm) Residential
Screening Level for Soils (U.S. EPA’s OSWER Directive # 9355.4-12)
These standards reflect contamination in general and there is no connected exposure criteria for
these standards, again, reinforcing the premise that with no exposure, there is no risk.
SAAMI developed battery of protocols to determine the fate of lead on SAFRs.
However, SAAMI uses multiple test conditions with widely varying conditions to
understand what the differences are and how multiple variables interact on the fate of lead.
SAAMI expresses that there is variability in lead availability/mobility that are able to be
controlled by both design, active and passive amendment protocols and good housekeeping
practices. SAAMI begins with a basic but detailed summary of the processes that occur on
SAFRs. From deposition processes (firing) to berm or surface impact and subsequent
mechanical processes that affect bullet materials as they are deposited into catchment media are
described. This is the initial step in a complex equation. As bullets or shot is deposited into the
environment of a SAFR, the continuous process of weathering, abrading, fragmenting and
smearing of lead bearing bullets occurs until the bullet or shot mass is removed either for
recovery/recycling effort or as an outcome of final remediation. “When bullets hit a berm they
may behave in any of several ways, including:
• Penetrating - Sporting loads typically expand and do not penetrate as deeply as full
jacketed bullets from military loads.
• Agglomerating - The impact of one bullet on another may join them into a single
mass, especially if the bullets are of relatively soft composition.

• Fragmenting - Bullets may strike stones or other bullets already in the berm and
fragment into large or small pieces, even to microscopically fine particles.
• Smearing - Bullets penetrating the berm may leave a smear of extremely fine lead on
the surface of soil particles they contact.
• Ricocheting - Bullets may strike other bullets already in the berm and ricochet into
surrounding areas.” (SAAMI, 1996, p. 14)
Each of these mechanical process makes metallic lead available to the following
geochemical processes that exist on SAFRs. These processes are commonly known to include
lead:
 Particles moved via storm water run-off
 Dissolved in storm water run-off
 Dissolved in Ground water
 Particles moved by wind action
SAAMIs describes how the document proceeds for chemical processes through the
continuum of application to SAFRs as follows
• First, each process and important terms are defined for those unfamiliar with the
terminology used.
• Second, the environmental significance of each process is described.
• Third, a description of the important factors influencing the chemical process is
summarized.
• Fourth, the bulk of the geochemistry, including a detailed review of pertinent
scientific literature is provided. This section is technical in nature.

• Fifth, a summary is presented where the process is put into perspective with respect to
shooting ranges” (SAAMI, 1996, p. 16).
Results
SAAMI covers a wide range of geochemical processes that affect the state of bullet lead
in solid and waters of SAFRs. They clearly and exhaustively study the dynamics of each process
identified and then study the potential for interaction among these processes. Geochemical
Processes involved in the life cycle of Lead on SAFRs includes:
• Oxidation/reduction - the process responsible for converting metallic lead into more
soluble forms, reduction being the opposite of oxidation.
• Precipitation/dissolution - the process that removes lead from solution as a discrete
solid form, dissolution being the opposite of precipitation.
• Adsorption/desorption - the process through which naturally occurring mineral
organic remove lead from solution by binding them to their surfaces, desorption being the
opposite of adsorption.
• complication/chelation - the process where dissolved lead associates with other
dissolved materials, resulting in higher dissolved lead levels.” (SAAMI, 1996, p. 16)
These chemical processes are complex and dependent upon availability of
agents/reagents (primarily water and carbonates, sulfates and phosphates) with the environment
and therefore are not the same at every, or any SAFR. As these processes occur, resultant species
of lead minerals are generated as lead from the bullet is consumed. These lead minerals all have
varying effects and actions on the environment, ranging from great bioavailability to virtually
inert and non-bioavailable. These species include:
 Lead Oxides and Hydroxides

 Lead Carbonates
 Lead Sulfates
 Lead Phosphates
These compounds are also interdependent on the pH of the surface and subsurface waters of the
range. Generally, the more acidic (lower pH) the faster (more lead mass) lead minerals will be
formed and the more lead could be available for mobility and conversely, the more alkaline or
basic the waters are, less lead minerals will be formed and less lead mass would be available for
mobility (SAAMI, 1996, p. 12).
SAAMI looks at the waters available on SAFRs, both in terms of rainfall, surface and
subsurface waters and how the pH of these waters drives the geochemical reactions for the most
part. This describes the environmental significance of these lead minerals and the processes that
form them. Indeed, a careful study of the chemistry, related to the environmental processes and
impacts makes this approach easily followed and while the chemistry may be daunting, the
interaction and interrelation to the environmental significance is clear and easily understood.
Discussion and Analysis
SAAMI acknowledges that there is potential for migration of lead due to geochemical
process, precipitation and other factors with pH being a clear indicator, but not a sole
denominator in understanding the potential for migration; “Studies published to date indicate a
general lack of lead mobility under most environmental conditions. From the relatively few lead
mobility studies conducted at shooting ranges, pH appears to be an important factor. Surface
water pH values of ≥7.0 tend to indicate restricted lead mobility whereas pH values of ≤6.5 tend
to indicate enhanced lead mobility. Attempts to statistically correlate lead concentrations in

water with pH, alkalinity, or shot density, however, have not been successful, likely due to
complex interactions of several other environmental factors” (SAAMI, 1996, p. 12).
Each of the geochemical and natural processes described in the SAAMI study clearly
show that there is potential for availability of lead for conversion into lead minerals, that these
lead minerals (with exceptions-such as lead phosphates which for all intent and purposes are not
bioavailable or dissolvable to either plant or animal life) are can be mobile in the surface waters
and soils of SAFRs.
SAAMIs approach is comprehensive and rational, using geochemical processes and
physical attributes along with good housekeeping and management principles to show that
while lead is a present factor on SAFRs, that the environmental in-situ conditions could be
making deposited lead available in terms of dissociation from bullet mass, and that while
environmental factors like run off, erosion and other natural effects can expose or mobilize
these lead minerals and minute particles of metallic lead, that basic controls for erosion,
recovery of bullet mass and common landscaping and maintenance efforts are critical controls
to mitigate the potential for migration off SAFRs. SAAMI’s study follows through with
acknowledgment of the self-mitigating characteristics of well-designed and maintained SAFRs.
As mentioned previously, flat surfaces, well vegetated and maintained use areas, regular
recovery and recycling effort, controlled access and relatively isolated concentration areas all
tend to reduce the exposure of people to the presence of lead and lead minerals. While erosion
controls designed to mitigate damage to the range (as with any other outdoor sports complex)
do double duty in guarding against channelized flows of storm runoff and the potential for
disturbance of settled and bound metallic or mineral compounds of lead. Soils play a big part in
the equation of whether lead and lead minerals can become mobile. Ranges specifically deposit
soils that are both durable and compactable to retard erosion on slopes and to force sheet flows
of run off. Soils of this type are more apt to allow penetration of bullets without significant
displacement of material and are softer and more suited to slowing projectiles gradually rather
than causing further fragmentation and smearing as would be more likely with harder, well-
graded soils containing greater proportions of gravel and clasts of rock. These soils are
characterized by being made up of sandy clays, with many fines that tend to bind with lead and
lead minerals. Furthermore, these soil tend to shed water well and the removal of water is a key
to limiting the dissolution of lead from bullet mass. All of these factors are presented in the
SAAMI study with clarity. Lead is a valuable commodity and most SAFRs cyclically recover
and recycle expended lead and other bullet materials to benefit the range operations financial
status. Since the lead is deposited by others, it is a no or low-
cost benefit that can and is exploited to defray the operating
costs, to pay for EM activities and to fund general
operations accounts. As with any commodity, the price of
lead rises and falls and often SAFRs await ideal market
conditions to recover and sell lead metal as scrap for re-smelting. This can be a lucrative option,
or it can delay the removal of deposited with potentially negative impacts to the characterization
of lead on the SAFR.
Secondary Research Considered
Corrective Action at Outdoor Ranges Guidance Document (Colorado Deptartment
of Public Health and Environment, 2012)
This guidance document is designed to help operators of SAFRs who are ceasing
operations permanently. The guidance includes informative summaries of how lead reacts in
general with the environment, what mechanisms are present that may contribute to mobility and
what general procedures SAFR operators should be using during operations. Colorado DPH&E
mentions that once lead is recovered from range soils, it must be disposed of as hazardous
material. This is an important distinction made; as otherwise one could assume that such lead
would be considered hazardous waste, which falls under very different control and management
requirements by both states and the EPA via RCRA. Once again, the concept that expended
bullet materials are not wastes is made (Colorado Deptartment of Public Health and
Environment, 2012, p. 2).
The Colorado DPH&E clearly states that once a range ceases operations, that the lead
deposited becomes waste by definition and is then subject to specific controls for recovery,
storage, and disposal. “In addition, if soil containing lead or debris at a shooting range is in
some way “managed,” including being excavated, moved without being excavated, or buried, it
is considered to be a solid waste. Once a solid waste, the material is considered to be a
hazardous waste if it exhibits the toxicity characteristic for lead when analyzed by the Toxicity
Characteristic Leaching Procedure (TCLP) using EPA Test Method 1311. If a shooting range
has closed or is closing, or if soil will not be managed using a best management practice at an
active range, corrective action to address impacted soil may be necessary” (Colorado
Deptartment of Public Health and Environment, 2012, p. 5). It is important to note that these
same requirements exist at the national level based on the US EPA regulation, court ruling and
federal law. It is imperative to note that the characterization of hazardous waste becomes
operation only if there is either migration off the SAFR or if the range is being closed or has
been abandoned etc. Operational ranges , unless off-site contamination is documented, are not
subject to handling lead deposition as Hazardous wastes, although several court cases have
ruled that firing points or firing lines can be considered “point sources” of contamination. What
is interesting here is that although such definition has been made, the expended shot or bullets
still fall in to the previously defined category of “used as intended” and not hazardous or
wastes.
The Colorado DPH&E further delves into the assessment requirements of a range that is
being closed or abandoned. In section five, the state provides a concise summary of what
considerations must be taken into account when assessing the range for closure and clean-up. If
testing shows no contamination according to the previously mentioned TCLP leachate testing
protocols, then there is no need for further effort. On the other hand, if the test indicates lead in
equal or greater concentration to the TCLP standard, then remediation and retesting must be
conducted. Remediation process include sifting soils for lead removal, complete removal of
soils contaminated or application of amendments that reduce the TCLP leachate concentration
after application (Colorado Deptartment of Public Health and Environment, 2012, p. 4).
Colorado DPH&E separates shotgun ranges from other types of SAFRs and describes
how such a range with relatively wide thinly concentrated shot fall areas must be assessed.
Whereas handgun and rifle ranges generally have areas of little to no concentration of bullet lead
and relatively small impact berms that contain the majority of expended projectiles and are
therefore more easily surveyed to isolate the soils that exceed lead concentrations either by
weight or residual lead levels per the TCLP leachate process. Once soils have been assessed,
management options of either doing nothing, removing mass lead, remediating with
amendments to reduce residual lead concentrations to below federal standards (5 ppm) or
removing the contaminated and disposing of in the appropriate hazardous or municipal waste
treatment facility (Colorado Deptartment of Public Health and Environment, 2012, p. 16).
Lead Mobility in Soil: A Refresher (Morton, 2001)
This report to the 4th National Shooting Range Symposium discusses in brief the basic
processes of lead deposition, the physical processes lead bullets and shot undergo in the
deposition process that enable the bullet lead to be more available to the follow on geochemical
processes already described in the primary research studies reviewed above, and the primary
mediation, remediation and preventive measures SAFR operators can and ought to be employing
to reduce the potential for both reduction of lead into lead minerals and for the migration of
these potentially mobile compounds. Morton concisely describes the background concerning
bullet lead on SAFRs. He states “As the principal component of traditional ammunition
formulations, lead has received the greatest amount of public attention. Based on the potential
for exposure to lead by ecological receptors and the potential adverse health effects associated
with such exposure (both exposure to lead and the toxicity of lead are addressed in detail in
other presentations), various federal and state regulations have been instituted” (Morton, 2001,
p. 89).
Morton further describes the basic science and chemistry related to the effects of water,
soils composition and weather commonly found on SAFRs. He summarizes much of the work
already cited in the SAAMI study. Of particular note is his treatment of the proactive actions
SAFR operators should be aware of and purposefully implementing or conducting to assure that
their SAFR is not a potential candidate for lead related problems and the scrutiny that
accompanies such situations. Specifically he states “Based on increased public scrutiny of the
potential environmental impacts of outdoor shooting ranges, potential for exposure to and the
toxicity of lead in the environment, processes and factors affecting the mobility of lead in the
environment, and potential preventive and remedial options, the following general conclusions
may be drawn:
• Increased attention to the impacts of lead warrants that shooting range managers
evaluate whether such impacts exist at their range.
• The basic processes controlling lead
mobility at outdoor shooting ranges are well
known; however, range- specific interactions of factors
may need to be assessed.
• Range-specific lead mobility can be
determined if certain site characteristics are known
and appropriate site- specific evaluations are
performed.
• Most outdoor shooting ranges probably do
not have adverse environmental impacts caused
by lead; however, conditions may exist that could
result in such impacts.
• Outdoor shooting ranges can be proactive in evaluating the potential for adverse lead
impacts and can minimize or prevent such impacts” (Morton, 2001, p. 94).
Risk Model Employed
Since this study has explored contamination sources that could be potential risks to both
humans and the environmental in general, both human health and environment risk assessment
models will be used.

First, the human health risk model will be examined to study whether the lead deposition
on SAFRs would indeed be a hazard, whether such a hazard equates to a dose-response threat
and if exposure by either patrons or employees of SAFRs to the dose-response condition could
be characterized as a risk. We will discuss the linkage of hazard and dose-response to exposure
and to devaluate whether or not a real risk is posed by the contamination found in specific areas
of SAFRs.
Next, since the lead deposited on SAFRs

Environmental Risk
directly Assessment Model
Dose-Response
impacts the environment by
Hazard/Stressor ID Assessment
its mere
presence, we will examine an environmental
Risk model which will Hazard Exposure help to understand if

Assessment Assessment
the deposition of lead and its subsequent
weathering into daughter species of lead minerals poses a risk of

Risk
migration from dedicated Characterization impact/collection and shot fall areas. Petticord
again describes how ERA is defined based on current theory in the
industry, including the regulatory agencies that oversee such effort.

Uncertainty
Analysis
He states “… (environmental) risk assessment is a process
for evaluating the impact of a chemical on the health of individual humans or the environmental
well-being of a population or community of animals and plants. In its most basic form, risk
assessment means answering several simple questions that usually underlie environmental
evaluations” (Petticord, 2001, p. 104).
The process is generally similar to the Human Health Risk Model, but is applied to the
environment in general, including other “receptors” that may be impacted by a hazard rather than
solely focusing on humans. Furthermore, other pathways must be identified and examine to see
if they provide a route to these other organisms in the environment. Summarized, we see that
ERA process involves the following steps to arrive at a logical conclusion if an impact to the
environment exists:
1. Problem Formulation.
a. Identification of likely receptors that may be present on or near the range?
b. What Hazards/Stressors caused by the range may be able to effect these
receptors?
2. Effects Assessment. What levels of the existing hazards (chemical or physical) that
present or nearby are known both in type and quantity/concentration that receptors
identified above are likely to be impacted by?
3. Exposure Assessment.
a. What realistic activities or behaviors are the receptors likely to engage in that
create physical or biological pathways for the hazard be delivered or
encountered by?
4. Risk Characterization. Given the known conditions at the range, will the encounter
identified above result in exposure of a receptor to the identified hazards in a quantity
or duration or both that is likely to cause adverse effect?
5. Uncertainty Analysis. How certain or uncertain are the answers to all of the above
assessed features of the range; the hazards, the receptors, the exposure pathways and
the likelihood of interaction?
These steps are found summarized in both Petticord (Petticord, 2001, p. 104) and
Manuilova (Manuilova, 2003, pp. 7,15).

Findings
Observations
General
Both studies are clear, articulate and well written. Hardison wrote his study as a graduate
student in a master’s program of Environmental Science while at the University of Florida. He
conducted a solid research study using standard test protocols to determine residual lead
concentrations in both soils and surface waters and his study was thorough and detailed to the
extent of its scope and limitations. SAAMI’s study was completely comprehensive in the subject
area and detailed every reasonable process and effect that lead undergoes in the environment.
SAAMI did not limit their scope to a specific range or area as Hardison did, rather they explored
known interactions of soil, water, weathering and geochemical process known to involve lead
and its fate in the environment. As such, SAAMI is a handbook for reference on the subject and
could be used by both environmental managers, range operators and government overseers at
every level.
Conclusions
Risk Assessment
Since lead deposition on SAFRs presents both a localized presence of lead and its
geochemical by-products on the SAFR proper, and the potential of lead dust and lead minerals to
become mobile on and perhaps off the SAFR, we will explore both the Human Health and
Environmental Risk potential.
First, we will review and describe the human health risk model and its results in the
context of SAFRs, focusing on an accurate assessment of the conditions on the range and how
the lead and lead minerals ought to be viewed in light of actual range operations to correctly
determine exposure probabilities to clearly understand the risk to people on the SAFR proper.
Second, we will examine the environmental risk that lead and lead mineral by-products may pose
both on and off the SAFR. Again, we will focus on accurately assessing the probability of
migration and mobility aspects of lead contamination in the context of the environmental risk.
Human Health Risk
The human health risk associated with lead deposition and mobility on or off SAFRs is
topic that has been in the media due to the overall stigma that any toxic substance has to be a bad
thing regardless of the real risk involved. While it is clear that lead from bullets and shot is
indeed a potential health risk, characterizing any specific situation as a public or occupational
risk is not logical nor accurate without fully understanding the actual risk of exposure and its
impacts (Office of Solid Waste and Emergency Response, 2003). In this section we will explore
the human health risk of lead on SAFRs as it has been conducted in the past, how the science of
lead in the environment (specifically, SAFRs) depicts the risk and how the actual risk based on
both bullet lead on the SAFR as well as lead migrating off SAFRs may impact human health.
In the systematic determination of risk, there must be a harm-causing mechanism, a subject that
may be harmed, an exposure probability and a risk caused by the hazard. As we have seen in the
previous sections of this study, there certainly is a potential hazard- lead, a known toxic material.
What is seemingly assumed is that the risk of that lead and its daughter species of lead minerals
formed by interaction of the environment (soils, water, wind etc.) exists because of the physical
presence thereof. What appears to be lacking in the first study examined is a clear understanding
of the exposure probability to the lead present. The second study, while much more detailed and
comprehensive, does not fully explore the relationship of the hazard to exposure. What is needed
is a fair and unbiased risk analysis and characterization which accurately determines the
exposure of person on and off SAFRs to the hazard of lead and lead minerals. As we have seen, a
hazard without exposure poses no risk, so that is the task at hand-to determine if humans are
exposed to the hazard of lead deposited on and environmentally reduced and perhaps mobilized
daughter compounds. To that end we will conduct a brief risk analysis and characterization of
this situation.
The risk model we will use to examine human health risk due to lead and lead minerals
from SAFRs is described as a systematic determination of Hazard, Dose and response
( established standards of “no observable adverse effect level” (NOAEL)) compared to ambient
conditions at the site in question) an exposure assessment that defines the time of exposure of a
model person followed by a risk characterization which combines of the outputs of the previous
processes to determine what effect the hazard and exposure will cause the model person.
“1. Hazard identification — identifying potentially toxic chemicals.
2. Dose–response relationships — determining toxic effects depending on amounts
ingested, inhaled, or otherwise entering the human organism. These are usually
determined from animal studies. Different “end points” of toxicity are observed,
depending on the target organ of a chemical. Severity of a particular effect is a
function of dose.
3. Exposure assessment — determining the fate of the chemical in the environment
and its consumption by humans. Ideally, by performing environmental fate and
transport of chemicals, and by evaluating food intakes, inhalation, and possible
dermal contacts, one can assess total quantities of toxic chemicals in an exposed
individual or population, which may cause adverse health effects. In criteria derivation,
one uses either worse case exposure scenario or most probable exposure
scenario and point values for various human parameters. Monte Carlo modeling
uses real-world distribution data for those parameters.
4. Risk characterization consists of evaluating and combining data in Items 2 and 3.
For establishing criteria and standards, assumptions are made about “average
exposures,”and the criteria are set at the concentration at which it is believed that no
harm would occur. For example, reference dose (RfD) and health advisories (for
1-day, 10-day, and subchronic exposures) are derived for many chemicals with the
use of safety (uncertainty) factors to protect most individuals. If an actual exposure
to environmental pollutant (or pollutants) exceeds limits set by the criteria, efforts
should be made to decrease the concentrations of pollutant. The magnitude of risk
can be estimated by comparing the particular exposure to derived criteria or reference
doses.” (Molak, 1997, p. I.1.1)
Human Health Risk Modelling on SAFRs
Using the above definitions SAFRs would be assessed as described below.

1. Hazard Identification. We have already determined that lead and its daughter species of
carbonates, sulfate, oxides and phosphates are present on/in specific areas of the range
complex. It is rather easy to therefore state that lead is the thing that can cause harm- the
hazard.
2. Dose-response relationships. Since lead and its effects are widely studied and
understood, we know that the acceptable concentrations of lead in the water, soils and air
( via wind-blown dust or manmade disturbances like walking, mowing, digging, raking
etc.) are likely present, we can refer to the published standards which are:
WATER Freshwater Chronic Criteria (dissolved) 1.0, 2.5 and 6.1 µg/L (parts per
billion - ppb) at water hardnesses of 50, 100 and 200 mg/L, respectively.
Saltwater Chronic Criteria (dissolved): 8.1 µ g/L Drinking Water Regulation
Values (40 CFR 141)
Maximum Contaminant Level Goal (MCLG): zero (40 CFR 141.51)
Lead "Action Level": 15 µ g/L in >10% of tap water samples (40 CFR 141.80)
SOIL (RCRA Hazardous Waste Characterization (40 CFR 261.24)
TCLP leachate extract concentration of 5 mg/L (parts per million - ppm)
Residential Screening Level for Soils (U.S. EPA’s OSWER Directive # 9355.4-
12)
Using the results of the in-situ testing for presence of lead under these criteria, we can
determine if the lead concentration levels in the waters and soils of a SAFR are greater than the
acceptable standards for exposure. If they are, then we must continue the risk assessment and
characterization process to determine if there is a remaining hazard to either persons using the
range facility or if the findings include off-site tests that show unacceptable levels of lead
contamination, persons who may come into contact with the contaminated areas via other routes
or means. If the tests show that levels are at or below the standards, there is no hazard and we
can terminate the assessment. This leads us to the next step.
3. Exposure Assessment. The flaw seen in some SAFR assessments tends to fall into this
area. As Petticord notes, the combined presence of a hazard and an exposure creates a
risk, and often the exposure determination is skewed as if the SAFR was a full-time
occupation for those who frequent it. Petticord states the following:
“Assumption: Shooters and workers were assumed to spend their entire time at the range
(and thus receive their full exposure to the COC) in each of the areas.
Critique: This is logically impossible. A person can only be in one place at a time. At the
most extreme, a person could spend his/her entire time at the range (and receive their
exposure to COC) in any one of the areas, which would mean no time in any of the other
areas. More realistically, a shooter might divide his/her time among the areas, with
nearly all the time being at the firing points of the rifle/pistol range or the trap/skeet
range” (Petticord, 2001, p. 104). Since we know that SAFRs by definition have lead
deposition across the areas to varying degrees and situations, it would be rather illogical
and ill-suited to assume that any or all people who frequent the range would be there for
extended lengths of time and in the areas where lead contamination would be a likely
hazard. In fact, the shot fall areas and impact areas of SAFRs are off-limits to anyone
except maintenance workers and then only for short periods of time during which OSHA
rules requiring PPE and other protective measures apply. It is therefore unreasonable to
assume that exposure to the range complex in general is a threat, even if the person was a
full-time employee who conducted routine housekeeping and range maintenance duties.
Again, the assumption that human exposure would occur at the area of highest
concentration and for the longest duration is illogical and unsupported by fact. No one
(shooters, observers etc.) would spend time in these areas at all, and only relatively short
periods on firing points or firing line, where there is in fact no bullet or shot lead
deposition by definition (Petticord, 2001, p. 110). Petticord further states that “…the risk
assessment assumed that workers spent their entire 40-hour work week within this area
for their entire 30 years of employment at the range” (Petticord, 2001, p. 110).
4. Risk Characterization is the final step in the basic human health risk model. The US EPA
defines risk characterization as“... the process of estimating the incidence of a health
effect under the various conditions of human exposure described in exposure assessment.
It is performed by combining the exposure and dose-response assessments. The summary
effects of the uncertainties in the preceding steps are described in this step” (US EPA,
2000, p. 5).
So, using the factors identified in the first three steps, we can demonstrate that there is a
hazard, or thing which causes harm, there is a known dose-response mechanism based on
scientific studies and promulgated by laws and regulations and well defined areas of
contamination in all of the pathways that could affect human health. We see that there is
a certain potential level of exposure deduced by obtaining a clear understanding of the
human activity on the range. What must be articulated by the range operators to the
environmental assessors is the critical description of the human activity on the range,
metrics of how long and where patrons and employees frequent become critical to the
equation of hazard, dose-response and exposure probability.

Certainly, the current attitude prevalent in the government, media and public
minds tend to vilify shooting sports and overstate the concerns over some contaminants
and exposure risks over others. This is a condition of the operating environment that
must be recognized and through best management practices, overcome with sound data
and actions to demonstrate how the range operator is mitigating any real or perceived risk
of lead contamination on or off the SAFR property and to its patrons and employees.,
and more particularly, on the areas where the concentrations of lead and lead minerals are
most highly concentrated as well as where people, both transient shooters as well as
dedicated range operation and maintenance staff frequent.
In the context of human health risk, this study shows that while there is a hazard
of lead on SAFRs in specific areas that are not commonly frequented by persons, there is
little risk of exposure to that hazard and therefore there is no significant risk
characterization to be controlled past the best management practices that SAFRs
implement currently in order to maintain operational status from the local and state
governments that directly permit, inspect and oversee such enterprises. Additionally, the
federal regulations that govern the management of harmful substances like lead and its
weathered daughter species through both clean water and soils provisions, are restraints
to SAFR operators who may otherwise allow lead to build up and become a greater
hazard both on and off SAFRs than we see in most cases.
Environmental Risk
Looking specifically at the environment including and surrounding SAFRs, we see that
while the range property may be fenced and gated to prevent unauthorized human entry,
acceptable design features to capture lead from bullets and shot, with reasonable storm water
run-off and erosion controls, good management practices concerning expended shot and bullet
lead build-up, cyclical application of appropriate amendments based on soil and surface/ground
water conditions, there remains a certainty of stressors to aquatic and terrestrial life forms.
Plants, insects, birds, amphibians, fish and mammals all have a probability of being capable of
actively or passively being impacted. Therefore, an ERA is a rational step in determining what
impacts the interaction of the human activity (deposition of lead into the soils and waters of the
area) and the reasonable behaviors that these environmental considerations pose. Given a
theoretical SAFR and its local environment, we can quickly assess what factors and conditions
are present and proceed to develop an ERA. By conducting a concise environmental survey of
the geological and biological attributes of the area creating a bio-assay that can be used to move
forward.
1. Hazard ID. Discovering Stressors and receptors.
a. By testing the various areas of the SAFR using the requisite protocols, available lead
can be identified and characterized as a hazard or not.
b. As areas of the range are defined and a map of contamination built, a geological
assessment of the rainfall and drainage patterns of the range surface can be conducted
to discover what the surface and ground water flow characteristics are. This multi-
layered map can then be used to assess whether or not lead is moving on the range
and potentially off the range.
c. As this hazard identification assessment is being conducted to define stressors and
routes if any, a study of potential receptors can be done. This will help understand the
various life forms that are found on the range, the areas of concern and how long and
to what degree of reliance on the range area these life forms may use the range.
2. Effects Assessment. After the stressors characteristics have been defined and the
receptors have been identified, the concentrations, locations, accessibility of the stressors
to the receptors must be understood to develop a clear understanding of any resultant
adverse effects.
3. Exposure Assessment. Identified Stressors & Receptors are examined to determine what
exposure is likely based on the likelihood of interaction by receptors and the stressor. The
living, mating, reproducing and feeding patterns of receptors and their peculiar behaviors
that involve the range and identified routes of contamination and biological pathways can
be assessed to obtain a detailed picture of the ecological interactions occurring on and
around the range. Routes of contamination that intersect with known or assumed
biological pathways for the receptors will define an exposure condition, and the known
concentrations and accessibility of the stressors create an equation that describes
expected exposure. Since there likely would be several or many receptors involved
given the context of soil and water contamination of expended lead and its resultant lead
minerals, this process may be rather intense and detailed.
4. Risk Characterization. This process will compare the Effects Assessment with the
Exposure Assessment to determine if the overall interaction causes or could cause
adverse effects to each of the receptors in light of the stressors. Here is where thorough
knowledge of the chemistry and biology of the stressors and the receptors is critical. As
seen before, often the presence of a stressor is automatically assumed cause an adverse
effect. That assumption is not logical in the light of the need for an interrelationship
between the critical components of the risk equation; Stressor, Receptor and Exposure.
5. Uncertainty Analysis. As in all multi-variate equations, prediction of an outcome assumes
a level of uncertainty due to the understood level of fidelity or confidence that can be
assessed to each variable. Hence, after the preceding processes are completed, a review
of each process step is made to assign a quality or confidence rating to the product. If the
Problem Formulation process is found to have a confidence level of 90%, then there is
apparently 10% uncertainty of the accuracy or completeness of that process. This
concept flows through the overall ERA and must be judged at some point for its overall
usefulness and either progressed forward into risk management or returned to improve
the risk assessment certainty.
Once the ERA is completed, then management decisions must be considered, adopted and
implemented to accomplish the goals identified in the Problem Formulation and Hazard
Identification steps. “Environmental management plans must contain a schedule for
implementing the desired actions. They need not occur all occur at once nor
immediately; in fact, staging the actions over time may be necessary from a logistical or
financial standpoint. Simple, relatively low-cost actions (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” (ITRC , 2005, p. 66).

Here is where range operations are often assumed to be hazardous to the environment-it is
convenient and socially correct to define a contaminant as a hazard and force action, even if
exposure is not very well described. The common response to lead on SAFRs is, “well, it
(lead) could eventually harm the environment”. While that is true in an unconstrained
operating environment, the current state of management and oversight does not allow that
condition to exist, or at least, not for long.
Summarizing:
 Stressor and Receptors are present in varying form, quantity and degree
 Concentrations of stressors are likely to have harm on receptors based on
institutionalized standards compared to receptor’s behaviors
 Receptor's behavior pathways and stressors locations, type, concentration and routes
may interact to varying degrees
 Adverse effects may be caused by the combination of effects and exposures
 Uncertainty may vary considerably based on the fidelity of previous process steps
SAFRs may pose risk to the environment if lead mass removal/recovery, soil amendment
application techniques, erosion, dust suppression, run-off controls and other Best
Management Processes are not conducted in a timely and correct fashion; otherwise there is
little risk of lead migrating off SAFRs
Summation of the problem and outcomes
Since lead and many of its mineral compounds found in the environment are hazards to
biologically life processes, it is an obvious human health and environmental concern. Deposition
mechanics, geochemical processes, climatic conditions and interactions with human activity and
ecosystems all interact. The assessment of these facts, conditions and the interactions with the
environment in general creates a complex, potentially risky problem. Research shows that these
interactions are well understood and techniques to manage the outcomes are employed to reduce
residual risk to at or near ambient levels. Lead exists in many natural forms and in varying
concentrations throughout our environment apart from human involvement. Man has learned to
some modern degree through scientific and rational study to understand that the common use of
potentially harmful substances can be accomplished with reasonable controls and practices that
reduce risk to what are known as acceptable standards. This is done through legislation and
oversight and these management practices pervade our everyday life in the form of EPA, OSHA,
NIOSH and a myriad of other regulatory agencies with volumes of regulations designed to
protect human and environmental health and safety. Additionally, society has developed a set of
norms, values and processes, primarily through media and civic awareness techniques that make
SAFRs (and other potential sources of contamination producers) conform to what are known as
“best management practices” to avoid the onerous distinction of becoming the next local, state or
federal object of concern. Therefore, the risk of lead of lead migrating from SAFRs is a well-
controlled, managed, mitigated, remediated and overseen condition.

Premise Assessment
Premise Restated
Metallic lead (Pb) is a known toxic substance subject to strict controls and is a primary
component of ammunition shot on Small Arms Firing ranges (SAFRs).
Migration of lead from SAFRs into both soils and water sources is a topic that evokes
passionate discussion from both shooting and environmental groups.
There is little risk of lead becoming mobile and impacting the environment off SAFRs.
Premise Evaluation
The research considered and the review of the risk model performed support the premise.
Specifically, lead migration from SAFRs is not a major concerns for either human health or
environment contamination. According to the EPA, lead from expended ammunition deposited
on firing ranges is not a hazardous waste since the lead is expended as intended. The supporting
scientific profile of how this lead on SAFRs reacts with the environment take n from the primary
research sources supports the premise that there is little risk of lead becoming mobile and
impacting the environment off SAFRs even though lead is potentially made bioavailable through
the ambient conditions that exist on SAFRs. Due to the design, maintenance and regular
recovery/removal/recycling evolutions on most SAFRs, metallic lead is physically removed at
regular intervals for economic and environmental management reasons. Lead for re-smelting
carries a fair commodity price and range operations use this lead to fund continued operations.
Range design, whether specifically considered for environmental management or not,
generally contributes a stabilizing and mitigating feature to slow storm water runoff, limit
saturation and erosion. This varies of course across the wide variety of location, soils, terrains
and climatic settings. Grounds keeping and grooming of vegetation further slows or impedes the
potential of lead migration. Use of fertilizers and specifically intended amendments to alter the
chemistry and pH of the soils and waters of the range and its local area are applied with good
results in binding lead into less mobile mineral species than may naturally exist on some ranges.
Soils used to stop bullets, grow grass and form general landscaping features (sandy loamy clays)
are nearly ideal for the binding of lead fines into immobile soils where they can be exposed to
amendments stated above to both prevent migration and reduce bioavailability as in the form of
lead phosphates. Once primary technique used is to applied rock phosphate or “triple super
phosphate” which when mixed with range soils act as both a fertilizer and as binding amendment
which transforms lead particles into nearly inert and non-bioavailable fragments or minerals .
EPAs BMP for Outdoor Shooting Ranges states: “the main purpose of phosphate spreading is not
to adjust soil pH but to bind the lead particles. This process also decreases the potential amount
of lead that can migrate off-site or into the subsurface” (US EPA, 2005, p. III.7).
All of these basic operating and management procedures contribute to the general
reduction of lead in-situ as well as available for transport. With such an overall characterization,
the likelihood of lead migration from a shooting range generally is low, and incidental operations
are shown to be mitigating factors to the availability of hazards or stressors to both human health
and the environment. However, while the premise is supported, it is with clear awareness that
not all SAFRs are logically found to be in this general category and there are some, perhaps
many that due to poor design, poor operating practices and oversight, poor climatic and soil
conditions that indeed do pose a greater risk of the lead migrating from the range.
Recommendations for Future Studies
Environmental
As in all science, mankind gathers knowledge as time passes and new technologies and
insights gained become institutionalized. While today’s environmental science is considered
quite mature, there is much that we likely do not know that we do not know ( uncertainty);
therefore we recommend that continued research into the relationship of man and our
environment as well as the environment and man be conducted. As we gain understanding into
the infinite secrets of the Creator’s world, we will be able to better protect both ourselves and
the environment (to some extent, there is a limit before we may realize we really are unable to go
further without becoming so regulated that we can only throw our hands up and sigh?).
Range Design, Management and Operations
We would like to see the (Petticord, 2001) industry, the Federal government, states, the
public and other stakeholders conduct a range characterization assessment which studies a wide
variety of ranges in various locations with the intent to develop a comprehensive Best
Management Practices Guide n several companion volumes that provides range operators,
oversight agencies and the public a dedicated layered treatise on human health and
environmental risk considerations. Such a document, updated regularly as insight and process
improvement evolves, would be invaluable to the industry and the public to provide clear
awareness and understanding of one of our major national sports and pastimes.
Bibliography and References
(n.d.). 40 CFR 141.
(n.d.). 40 CFR 141.51.
(n.d.). 40 CFR 141.80.
(n.d.). 40 CFR 261.24.
(n.d.). 60 Fed Reg 22228: 4 May 1995.
Colorado Deptartment of Public Health and Environment. (2012). Corrective Action at Outdoor
Ranges Guidance Document. Hazardous Material and Waste Management Division.
Hardison. (2003, December 11). Lead Contamination in shooting range soils from abrasion of
lead bullets and subsequent weathering. Elsevier, p. Abstract.
Hardison, D. (2003). Environmental Fate of Lead in Florida Shooting Range Soils.
Hardison, M. L. (2002, December 11). Lead Contamination in shooting range soilsfrom abrasion
of lead bullets and subsequent weathering. Elsevier, p. Abstract.
ITRC . (2005). Environmental Management at Operating Outdoor Small Arms Shooting
Ranges . Washington DC: Interstate Technology and Regulatory Council.
Manuilova, A. (2003). Methods and tools for Assessment of Environmental Risk. Azko Nobel
Surface Chemistry AB.
Molak, V. (1997). Fundamentals of Risk Analysis and Risk Management. Boca Raton: CRC
Press.
Morton, E. (2001). Lead Mobility in Soils: A Refresher. 4th Natioanl Shoting Rnage Symposium
(pp. 89-94). Chicago: Tetra Tech EM Inc.
NRA. (2012). NRA Range Source Book. Fairfax VA: National Rifle Association.
NSSF. (1997). Environmental Aspects of Construction and Management of Outdoor Shooting
Ranges. Newtown CT: National Shooting SPorts Federation.
Office of Solid Waste and Emergency Response. (2003). TRW recommendations of Performance
of Human Healh Risk Assessment on Small Arms Shooting Ranges. Washington DC: US
EPA.
Petticord. (2001). Environmental Risk Assessment at Outdoor Shooting Ranges. 4th National
Shooting Range Symposium, p. 106.
SAAMI. (1996). Lead Mobility at Shooting Ranges. Newtown CT: SAAMI.
(n.d.). U.S. EPA’s OSWER Directive # 9355.4-12.
US EPA. (2000). Risk Characterization Handbook. Washington: US EPA.
US EPA. (2001). Best Management Practices for Firing Ranges.
US EPA. (2005, June). Best Management Practices for Lead at Outdoor Shooting Ranges. EPA
902-B-02-001, pp. I-8.
USGS. (2012). Mineral Usage Survey. p. Table 5.

Appendices
Appendix A- Risk of Migration of Lead on Small Arms Firing Ranges (Briefing)
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RISK OF LEAD MIGRATION ON SAFRS 1

Risk of Lead Migration on Small Arms Firing Ranges

Webster University, June 2014

Applied Research Methodology........................................................................................12

Modelling Techniques Utilized..........................................................................................12

Study and Findings............................................................................................................15

Description of Lead deposition processes.....................................................................15

Rifle and Pistol/Fixed impact area Deposition..........................................................15

Aerial Target/Shotgun/Shot fall Zones Deposition....................................................16

Science and Theory of Lead in the Environment..............................................................18

History of Lead as both a Human health hazard and an Environmental Hazard

General Conditions on SAFRs.......................................................................................19

Concern over Migration of Contaminants.................................................................19

Basic considerations for Migration of Lead from SAFRs.........................................20

Primary Research Considered........................................................................................21

Environmental Fate of Lead in Florida Shooting Range Soils (Hardison D. , 2003)21

Lead Mobility at Shooting Ranges (SAAMI, 1996)..................................................26

Secondary Research Considered....................................................................................34

Corrective Action at Outdoor Ranges Guidance Document (Colorado Deptartment

of Public Health and Environment, 2012).............................................................................34

Lead Mobility In Soil: A Refresher (Morton, 2001)..................................................36

Risk Model Employed.......................................................................................................38

Human Health Risk........................................................................................................41

Human Health Risk Modelling on SAFRs................................................................43

Summation of the problem and outcomes.........................................................................51

Recommendations for Future Studies................................................................................55

Range Design, Management and Operations.................................................................55

Bibliography and References.............................................................................................56

Keywords: migration, mobility, bioavailable, geochemical, SAFR, weathering, risk

many reasons including cheapness, availability and metallic characteristics. As a relatively

ballistically, density is critical energy transfer and trajectory efficiency.

component of ammunition shot on Small Arms Firing ranges (SAFRs).

passionate discussion from both shooting and environmental groups.

migrating from SAFRs.

Applied Research Methodology

This study was conducted solely by the Author.

Modelling Techniques Utilized

SAFRs through the natural stand-off or separation of occupant/firer to deposition of expended

the premises and into the surrounding environment in general.

Study and Findings

Description of Lead deposition processes

Rifle and Pistol/Fixed impact area Deposition

are destroyed beyond recognition and

residual fragments range in size from

atomic to somewhat less than

original bullet size. These bullets and

residuals from bullets are found buried

often constructed of sandy clay soils or local soils

which are screened to remove rocks which reduces

ricochet potential. Expended bullet materials

remain in-situ for varying durations, often years or

decades. More ranges recycle bullet materials

well as for environmental control purposes.

Aerial Target/Shotgun/Shot fall Zones Deposition

Shotgun ranges usually are much more

compact than rifle and

pistol ranges due to the reduced maximum