LEAD EMISSIONS FROM INDOOR PISTOL RANGES

Transcription

1 LEAD EMISSIONS FROM INDOOR PISTOL RANGES by Matt McCann, Air Toxics Section Pinellas County Department of Environmental Management On December 10, 1991, an employee of Pinellas County, Department of Environmental Management, was picking up lunch at a local restaurant when she observed some curious grey dust shadowing the stucco wall of a nearby building. As she came closer to the area where the grey dust was first observed it became more apparent that the dust was being emitted by several large exhaust fans mounted on the exterior of an indoor pistol range. As she scanned the area further it became evident that grey dust had accumulated not only on the wall under the exhaust fans, but was also visible throughout the pistol range parking lot. It was not long before she became alarmed by the close proximity of a childrens day care center not more than 40 feet away. The day care property joined the pistol range parking lot, and the fan exhausts from the pistol range faced the playground. She quickly notified the Air Toxics Section of the Pinellas County Environmental Management, as well as the Criminal Enforcement Division of the County's Sheriff's Department. The Air Toxics Section inspected the site on December 20, 1991, and confirmed the information which had been reported. The air toxic inspector also observed that a small lead smelter was present on the outside of the building with numerous 20 gallon sized containers of bullet fragments stored uncovered along the outside wall of the pistol range. A sample was collected of the visible grey dust which had accumulated under the fan exhausts, another sample was taken of the soil at 1

2 the property boundary of the day care joining the pistol range parking lot, and finally a soil sample was taken in a area centrally located in the parking lot. The samples were analyzed for total lead using approved methods. The results from the lead analysis were reported at approximately; 600,000 ppm for the sample collected under exhaust fans, 300,000 ppm at the day care property boundary, and 400,000 ppm at the central parking lot area. The Sheriff's Office inspected the site on December 20, 1991, and found the same reported conditions. He returned on December 23, 1991 to collect samples. The Sheriff's samples were analyzed using E.P. Toxicity Test. The samples that were analyzed had similar high total lead, and it was determined that the lead content was high enough for the material to be consider as hazardous waste. Several meetings were held at the request of the Director of Environmental Management to assess the situation at hand. The initial meeting was attended by Pinellas County's Air Quality Division, the Water Quality Division, the Public Health Unit, the Hazardous Waste Division, the Sheriff Department, and the Hazardous Waste and Air Quality Sections of Florida's Department of Environmental Regulation. It was decided in this meeting that the situation was critical due to the proximity of the day care, and that an additional meeting would be arranged for the following day. The County Attorney, the owner of the indoor gun range and his attorney's, the day care licensing board, and the other persons present at the first meeting were invited to attend. Meanwhile the owner was contacted and told the results of the lead analysis performed on material from the area around his exhaust vents. He was told that 2

3 the Department was taking corrective measures to insure that the children at the day care were adequately protected. The second meeting resulted in the owner voluntarily shutting down his indoor gun range operation. The Public Health Unit decided to inspect and analyze samples on the interior of the day care facility, and test for blood lead levels from the children attending the day care center. The Sheriff collected additional samples from the day care playground. Because the soil samples containing lead dust was determined to be a hazardous waste the owner hired a lead abatement contractor to HEPA vacuum the lead dust in the parking lot and later had to remove and dispose of the lead contaiminated pavement and playground soil. The results of the samples from the playground, and the interior of the day care showed lead levels ranging from 10 ppm to 5503 ppm on the playground and levels as high as 804 ppm in a vacuum cleaner dust bag. One wall wipe showed 40 ug/square inch on the interior of the day care. The blood levels were higher than the recommended 10 ug/dl in four children with the highest being 14 ug/dl in a child that lived nearby and who had played with and collected the bullet fragments left in containers on the outside of the indoor gun range. The Air Compliance and Air Toxics Sections performed inspections of other indoor gun ranges within the county and found five additional indoor ranges. Only two of the five had any controls, one with HEPA filtration and the other with an electrostatic precipitator. It was found that lead waste was being washed into the sewer system at the range with the electrostatic precipitator when the system was cleaned. It is has been reported that some ranges wash down the interior walls and floors with water, resulting in lead dust being washed into the sewer 3

4 drains. The lead dust is created in two ways, one is when the weapon is fired and the other is when the bullets fragment on steel baffle plates at the far end of the NIOSH studies performed to determine shooter exposure to lead, have reported levels as high as 34,000 ug/m3 for personal samples and 13,000 ug/m3 for indoor area air samples in indoor gun ranges without adequate controls to protect shooters. As expected, the greater number of shooters and the greater number of rounds fired gave the higher levels of lead. The results of these and other tests can be found in NIOSH's document "Lead Exposure and Design Considerations for Indoor Firing Ranges". The Occupational Safety and Health Administration (OSHA) has a Permissable Exposure Level (PEL) for lead set at 50 ug/m3 (8 hr. avg.), the EPA's Reference Air Concentration (RAC) is 0.09 ug/m3 (annual avg.) and the EPA's National Ambient Air Quality Standard (NAAQS) is 1.5ug/m3 (quarterly avg.). Obviously indoor gun ranges which have many shooters and no controls are unlikely to meet any of these levels. It is also reported that many ranges conduct shooting competitions, which would obviously result in even higher levels of lead dust being emitted to the inside air as well as the outside air than has previously been reported. This, in most circumstances, would be considered the "worst case condition". Indoor gun ranges are also a source of lead material for recyclers. Many times the lead material is taken to unpermitted secondary lead smelters, for the manufacture of fishing weights, reloads, and diving weights. Sometimes the 4

5 wastes, which are consider hazardous, are disposed of improperly to sewer systems, domestic solid waste streams, property runoff to surface waters, ground water and adjoining property. Lead has in recent years become a great concern, especially as it relates to lead exposure in young children. Lead poisoning may result from inhalation and/or ingestion of lead dust and fumes. Since these facilities are sometimes located next to food establishments, playgrounds, day care centers, residential areas, and schools it is important that proper contols be inplace and operated properly to adequately protect the public. 5