DEPARTMENT OF DEFENCE · Quick Reference Guide ... GEMS EFM – CSR Garrison Estate Management...

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DEPARTMENT OF DEFENCEENVIRONMENT AND ENGINEERING BRANCH

DIRECTORATE OF CONTAMINATION ASSESSMENT, REMEDIATION ANDMANAGEMENT

Contamination Management Manual

Annex GFiring Ranges

March 2018, Amended August 2019

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© Commonwealth of Australia 2018This work is copyright. Apart from any use as permitted under the Copyright Act1968, no part may be reproduced by any process without prior written permissionfrom the Australian Government Department of Defence.Announcement statement—may be announced to the public.Secondary release—may be released to the Australian Government Department ofDefence, its contractors and their equivalents in United States of America, Canada,New Zealand and Great Britain.All Defence information, whether classified or not, is protected from unauthoriseddisclosure under the Crimes Act 1914. Defence information may only be released inaccordance with the Defence Security Manual as appropriate.First edition 2018

SponsorDirectorate of Contamination Assessment, Remediation and Management

DeveloperEnvironment and Engineering Branch

Issued byAlison Clifton with the authority of Assistant Secretary Environment and EngineeringBranch

Effective DateMarch 2018

Amendment DateAugust 2019

Review DateAugust 2020 or when changes to processes require an update

Amendments to the document can be proposed as required. Proposals foramendment of this document are to be forwarded to:

Director of Contamination Assessment, Remediation and ManagementEmail: [email protected]

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Quick Reference GuideWhy is this an issue for Defence?

Mandatory RequirementsFiring ranges are common across the Defence estate but the types of firing ranges vary greatly fromone site to another and can include current operational facilities and former or decommissioned areaswhere there may have been limited previous environmental oversight.

The following requirements are mandatory when undertaking project work on or in the vicinity ofcurrent or former firing ranges:

Review the Garrison Estate Management System Environmental Factor Management –Contaminated Site Records (GEMS EFM – CSR), to access and review available data and sitehistory (current and former land use) that can inform risk identification and planning prior to thecommencement of any intrusive works.

Conduct a site investigation and collect environmental samples, as required, if sufficient existinginformation is not available to inform the risk of potential or actual site contamination. Siteinvestigations may include a Pre-construction Contamination Assessment (PCA), Stage 1Preliminary Site Investigation (Stage 1 PSI) or Stage 2 Detailed Site Investigation (Stage 2 DSI),depending on the objective/s of the works proposed.

Prepare an environmental management/remediation plan with actions identified to preventpotential ongoing contamination and off-site migration of contamination.

Document works and maintain records of all site investigations, monitoring and remediation andupdate the GEMS EFM – CSR.

Further Information Defence Contamination Management Manual

Defence Environment and Sustainability Manager (ESM) Defence Pollution Prevention Management Manual Annex 1K Heavy Metals on Live Firing

Ranges

Draft Defence Unexploded Ordnance Management Manual (DUXOMM)

Defence Training Area Management Manual

HSE RiskHistorical site activities cancause contamination. Healthsafety and ecological risksmay arise from contamination,depending on the nature,extent and concentration ofthe contaminant and theexposure pathway.

Commercial RiskDefence may be subject tocommercial and reputationalrisks when there is aninadequate understanding ofthe extent and magnitude ofcontamination and theassociated risks to humanhealth, the environment andproject constraints.

Defence CapabilityThe time and costsassociated with managingunexpected contamination ina firing range can have asignificant impact to Defencecapability, if training activitiesare curtailed.

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Table of contentsQuick Reference Guide ............................................................................................................................ ii

Abbreviations............................................................................................................................................ ii

1. Introduction.....................................................................................................................................1

1.1 Background..........................................................................................................................1

1.2 Purpose................................................................................................................................1

1.3 Defence Documentation ......................................................................................................3

2. Regulatory Overview......................................................................................................................4

2.1 Overview ..............................................................................................................................4

3. Contamination Risk ........................................................................................................................8

3.1 Background..........................................................................................................................8

3.2 Conceptual Site Model.........................................................................................................9

4. Projects and Contamination Management...................................................................................13

4.1 Background........................................................................................................................13

4.2 Case Studies......................................................................................................................13

4.3 Case Study 1: Activities in a former operational weapons range ......................................14

4.4 Case Study 2: Demolition of a former indoor range ..........................................................15

4.5 Case Study 3: Disposal of wastes from a bullet catcher ...................................................16

4.6 Management ......................................................................................................................17

5. Data and Reporting ......................................................................................................................20

5.1 GEMS EFM – CSR ............................................................................................................20

5.2 Geographic Information Systems ......................................................................................20

6. References...................................................................................................................................21

Table indexTable 4-1 Management considerations..............................................................................................17

Figure indexFigure 1-1 Overview of Defence Environmental Documentation and Annex G....................................3

Figure 3-1 Schematic of different components at a firing range ...........................................................9

Figure 3-2 Potential Contamination Risks at Firing Ranges ...............................................................12

AppendicesAppendix A – Potential Firing Range Contaminants

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AbbreviationsAbbreviation Meaning

2-Am-DNT or 2A-DNT 2-Amino-4.6 dinitrotoluene

4-Am-DNT r 4A-DN 4-Amino-2.6-dinitrotoluene

2,4-DANT 2,4-diamino-6-nitrotoluene

2,6-DANT 2,6-diamino-4-nitrotoluene

2,4-DNT 2.4-Dinitrotoluene

2,6-DNT 2.6-Dinitrotoluene

2-NT or 2-MNT 2-Nitrotoluene/2-mononitrotoluene



ANZECC/ARMCANZ(2000)

Australian and New Zealand Guidelines for Fresh and Marine WaterQuality, for groundwater and surface water contamination

ASC NEPM National Environment Protection (Assessment of Site Contamination)Measure 1999 (Cth) (NEPC 2013)

AWR Air Weapons Range

CoPC Contaminants of Potential Concern

CRAT Contamination Risk Assessment Tool

CSM Conceptual Site Model

CSR Contaminated Site Record

DCARM Directorate of Contamination Assessment, Remediation and Management

DEHPD Director of Environmental and Heritage Policy Development

DEQMS Defence Estate Quality Management System

DNB Dinitrobenzene

DNT Dinitrotoluene

DNX Dinitroso-hexahydro-1,3,5-triazine

DRN Defence Restricted Network

DUXOMM Defence UXO Management Manual

ECC Environmental Clearance Certificate

EOW Explosive Ordnance Waste

EPBC Act Environment Protection and Biodiversity Conservation Act 1999 (Cth)

ESM Environment and Sustainability Manager

FFA Field Firing Areas

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Abbreviation Meaning

GEMS EFM – CSR Garrison Estate Management System Environmental Factor Management– Contaminated Site Records

GIS Geographic Information System

HE High Explosive

HMX Octahydro-1,3,5,7-tetranitro 1,3,5,7-tetrazocine

HSE Health, Safety and Environment

ITRC Interstate Technology Regulatory Council

LOCR Defence Legal Obligations Compliance Register

MC Munition constituents

NEPC National Environment Protection Council

NEPMs National Environment Protection Measures

NGuan Nitroguanidine

NSIMS National Spatial Information Management System

PCA Pre-construction Contamination Assessment

PETN Pentaerythritol tetranitrate

RDX Rapid Detention Explosive

RSO Range Standing Order

SAA Small Arms Ammunition

SAR Small Arms Range

Tetryl N-methyl-2.4.6- trinitrop-aniline

TNB Trinitrobenzene

TNT Trinitrotoluene

Stage 1 PSI Stage 1 Preliminary Site Investigation

Stage 2 DSI Stage 2 Detailed Site Investigation

USACE US Army Corps of Engineers

USEPA United States Environmental Protection Agency

UXO Unexploded Ordnance

WHS Act Work Health and Safety Act 2011 (Cth)

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1. Introduction1.1 Background

The use of firing ranges by Defence for training activities is critical to maintaining Defencecapability. Firing ranges currently or formerly used by Defence can vary from Small ArmsAmmunition (SAA) ranges or indoor ranges, through to large scale Field Firing Areas (FFAs)and Air Weapons Ranges (AWRs).

Defence training activities at firing ranges involve the use of a wide variety of munition types,from practice rounds through to ordnance containing incendiaries and high explosives (HE). Thematerials contained within various ordnance types have the potential to cause environmentalcontamination, at the target area/impact area, at the firing point or in areas away from the firingrange if contamination is mobilised through surface water, wind or groundwater flow.Abandoned and decommissioned firing ranges pose a potential ongoing source ofcontamination from historical activities.

This document provides guidance on managing risks associated with chemical contamination(e.g. lead, explosives residues) caused by firing range activities. In this context, contaminationrefers to recent chemical contamination in soil, water or sediments that has resulted fromactivities that are continuing to occur on the range, or legacy contamination in soils and orgroundwater caused by historical activities. Other contamination sources maybe present if thearea was previously used for other potentially contaminating activities..

The appropriate management or clean-up response to contamination will be influenced by theconstruction or development activity proposed and the risk posed by the contamination tohuman health and the environment.

The following may be of relevance to any proposed activity at a current or former Defenceowned firing range:

Assessment and remediation of UXO or EOW – covered by the Draft Defence UXOManagement Manual (DUXOMM)

Contamination risks (soil, sediment and water) associated with ‘burning grounds’ – whichare often located on or near firing ranges – reference should be made to Annex I

Environmental management guidelines that aim to minimise the creation of contaminationfrom firing range activities – Pollution Prevention Management Manual Annex 1K – HeavyMetals on Live Firing Ranges

Defence Work Health Safety (WHS) Manual Volume 3, Part 3A, Chapter 8 Procedure:LEAD:00 Management of Lead in Indoor Firing Ranges.

Range Standing Order (RSO)

The management measures used to address both historical and recent contamination arecommon however, the timeframe by which the measures are implemented may differ dependingon the degree of risk posed by the contamination to human health and the environment.

1.2 Purpose

This document will assist Defence personnel and contractors to manage contamination riskswhen supervising Defence works that may encounter contamination associated with firingranges across the Defence Estate. Types of firing ranges typically encountered on the Defenceestate include:

FFAs

Category A to Category C live fire training facilities

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Live fire demolition training facilities

Outdoor special forces live fire training facilities

AWRs

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1.3 Defence Documentation

This guidance document is an Annex to the Defence Contamination Management Manual andsupports compliance with site contamination management policy as detailed in the DefenceEnvironment and Heritage Manual. An overview of where this Annex fits into the Manual ispresented in Figure 1-1.

Figure 1-1 Overview of Defence Environmental Documentation and Annex G

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2. Regulatory Overview2.1 Overview

Defence and its contractors must operate to comply with all Commonwealth legislation,including the Work Health and Safety Act (WHS Act), Environmental Protection and BiodiversityConservation Act (EPBC Act) and the National Environmental Protection (Assessment of SiteContamination) Measures (NEPM). Reference can be made to the Defence Legal Obligationsand Compliance Register (LOCR) found on Defence Estate Quality Management System(DEQMS).

Defence may not be subject to State and Territory law in all situations. Whether or not Defenceis bound by State and Territory law is a complex issue and legal advice must be obtained toconfirm whether a particular State or Territory law is applicable to Defence. Defencecontractors must comply with relevant State or Territory laws.

Guidance relating to the assessment of site contamination is outlined in the NationalEnvironment Protection Council (NEPC) 1999 (Cth), National Environment Protection(Assessment of Site Contamination) Measure (NEPM) as amended in May 2013.

2.1.1 NEPM

The National Environment Protection (Assessment of Site Contamination) Measures 1999 (Cth)(the ASC NEPM) was made under the National Environment Protection Council Act 1994 (Cth).The ASC NEPM is the national guidance document for the assessment of site contamination inAustralia. It is given effect by the National Environment Protection Measures (Implementation)Act 1998 (Cth) for the Commonwealth and individual legislation and guidelines in each Stateand Territory.

The National Environment Protection Council (NEPC) agreed to vary the NEPM by approvingan amending instrument to the ASC NEPM in 2013.

All assessments of site contamination on the Defence Estate are to be undertaken inaccordance with the recommended process and guidance provided in the ASC NEPM.

The purpose of the ASC NEPM is to establish a nationally consistent approach for theassessment of site contamination; to ensure sound environmental management practices by thecommunity, including regulators, site assessors, site contamination consultants, environmentalauditors, landowners, developers and industry parties.

The desired outcome of the ASC NEPM is to provide adequate protection of human health andthe environment, where contamination has occurred, through the development of an efficientand effective national approach to the assessment of site contamination.

The ASC NEPM and schedules are available for download through the NEPC website. TheASC NEPM Toolbox contains additional information including calculators, spreadsheets andother supporting documents to assist with application of the amended ASC NEPM. Off-sitedisposal of wastes generated from firing ranges must comply with the requirements detailed inthe applicable State and Territory legislation.

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2.1.2 Commonwealth Work Health and Safety Act 2011

The Work Health and Safety Act 2011 (Cth) (WHS Act) commenced in 2012 and is regulated byComcare, a Commonwealth Government agency that works in partnership with the Safety,Rehabilitation and Compensation Commission. The WHS Act provides for a nationallyconsistent framework to protect workers and other persons against harm to their health andsafety through the elimination or minimisation of the risks so far as reasonably practicable.

Under the WHS Act, employers must take all reasonably practicable steps to ensure the healthand safety of its employees and those who are at or near a workplace under the employer'scontrol. This means that Defence and its contractors have obligations to protect the health andsafety of workers and others operating within the vicinity of contaminated land that is on or nearto a workplace under Defence control.

Model Codes of Practice administered by Safe Work Australia provide practical guides toeliminate and minimise the risks to health and safety as required under the WHS Act.

Any controls outlined in the Defence Health and Safety Manual (SafetyMan) must beimplemented when managing contaminated materials.

2.1.3 Environment and Heritage Manual

The Environment and Heritage Manual (EHM) (2019) describes the agreed approach toenabling Defence capability through long-term sustainable management of the environment.The EHM provides instruction and policy guidance for all Defence personnel and contractors onDefence’s legislative obligations and stewardship goals in line with the Defence EnvironmentalPolicy and Environmental Strategy 2016-2036.

The Defence Environment and Heritage Manual is an administrative policy framework documentthat applies to all Defence personnel.

The EHM is divided into 13 chapters addressing:

Chapter 1 – Environment and heritage management in Defence

Chapter 2 – Environmental assessment and approval

Chapter 3 – Heritage management

Chapter 4 – Domestic biosecurity

Chapter 5 – Native species and communities

Chapter 6 – Soil management;

Chapter 7 – Bushfire management

Chapter 8 – Pollution prevention

Chapter 9 – Site contamination management

Chapter 10 – Estate water management

Chapter 11 – Estate energy management

Chapter 12 – Waste minimisation and management

Chapter 13 – Estate climate adaptation

Each chapter links back to a Strategic Aim of the Defence Environmental Policy and providessupporting documentation to support the implementation of the policy. Chapter 9 addresses sitecontamination management.

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2.1.4 Environment Protection and Biodiversity Conservation Act 1999 (Cth)

The Environment Protection and Biodiversity Conservation Act 1999 (Cth) (EPBC Act) is theAustralian Government’s central piece of environmental legislation. It provides a legalframework to protect and manage matters of national environmental significance.

The EPBC Act protects:

The environment, where actions proposed are on, or will affect Commonwealth landand the environment; and

The environment, anywhere globally on land and water, where a Commonwealthagency – including the Department of Defence – are proposing to take an action.

The EBPC Act also protects nine matters of national environmental significance:

World heritage properties

National heritage places

Wetlands of international importance (Ramsar wetlands)

Listed threatened species and communities

Listed migratory species

Commonwealth marine areas

The Great Barrier Reef Marine Park

Nuclear actions (including uranium mining)

A water resource in relation to coal seam gas development and large coal miningdevelopment.

Defence uses a comprehensive environmental impact assessment and approval program tounderstand and manage the impacts of its activities on the environment and heritage, and toensure compliance with the EPBC Act.

Under the Defence Environment and Heritage Manual, the Director of Environmental Planning,Assessment and Compliance (DEPAC) is the Defence technical authority for determiningcompliance with the EPBC Act. All matters that may trigger the EPBC Act are to be referred toDEPAC.

DEPAC undertakes a self-assessment against the Significant Impact Guidelines 1.1 and 1.2published by the Department of the Environment and Energy to determine if a ‘significantimpact’ EPBC Act protected matter is likely. The self-assessment process considers the natureand extent of contamination and if the presence, disturbance, removal or remediation of existingcontamination is likely to have a significant impact on EPBC Act protected matters. Where asignificant impact to the environment is ‘likely’ the action must be referred to the Minister for theEnvironment and Energy to make a determination on whether a proposed action is a ‘controlledaction’.

For more information with regard to the EPBC Act refer to http://www.environment.gov.au/epbc/.

2.1.5 Off-site migration

The Defence Project Manager should obtain professional advice to inform the reporting andmanagement of any contamination that is found to have migrated off-site into a State/Territoryjurisdiction. Delineating the nature and extent of the off-site contamination will assist Defence toimplement appropriate mitigation measures and to manage any legal implications. A link to thevarious State and Territory environmental agencies can be found in the Defence ContaminationManagement Manual. Any interaction with State or Territory environmental regulators must only

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occur after first consulting the Directorate of Contamination Assessment, Remediation andManagement (DCARM) and if applicable the Environment and Sustainability Manager (ESM).

2.1.6 Defence Legal Obligations Compliance Register

Defence and its contractors must operate to comply with all Commonwealth legislation,including the WHS Act, EPBC Act and the NEPM. In addition, Defence and its contractorsshould be generally familiar with the legislative and other regulatory requirements associatedwith the site activities undertaken relevant to the State or Territory in which the site is located.Contractors must comply with State and Territory laws where applicable. Reference can bemade to the Defence Legal Obligations and Compliance Register (LOCR) found on DEQMS.

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3. Contamination Risk3.1 Background

It is a requirement for Defence to undertake military training activities that involve the use of liveand practice ordnance within open environments to maintain capability. This can result in thebuild-up of chemical contamination in soil, sediments, surface water and groundwater at orwithin the vicinity of the range. The nature and magnitude of contamination will be governed bythe types and frequency of ordnance used.

Munitions used in training activities contain a variety of chemicals, which can generatebreakdown products when they enter the environment. For Small Arms Ranges (SAR), lead andother heavy metal contamination from small arms ammunition is typically the key contaminationissue and risk driver. For weapons ranges (i.e. not SAR), the risk driver may be theaccumulation of explosives residues.

Depending on site conditions, the contamination may become mobile via stormwater orgroundwater flow and erosion and can become concentrated along down gradient drainagelines. If left unmanaged it may become a risk to human health and the environment both on andoff the site.

▲Example AWR ▲Example SAR with bullet catcher ▲Example Demolition Range

Each component of a firing range has a different potential for contamination depending on itsfunction. The broad components of a firing range and the nature of contamination typicallyencountered at each are described below and in the Figure 3-1 of a Small Arms Range:

Firing point – residues of propellants from the firing of projectiles may accumulate ifweapons incorporating propellants (e.g. rocket propelled grenades or the firing cap) havebeen used. There may also be heavy metals in this area from cartridges (e.g. copper).

Target area – the target area is where most contamination at a firing range is typicallyencountered, arising from projectile materials (e.g. lead) or their contents (e.g. HEs). Itmay be an open area in the case of a FFA, or localised within a smaller zone such as anearthen bullet catcher or stop butt for a SAR.

Range floor – contamination may accumulate from projectiles that fall short of theirtarget, or it can migrate to this area through stormwater flow or erosion from target areas.

Safety trace – similar to the range floor, contamination may accumulate within the safetytrace. The safety trace can vary in size and type depending on the type of firing range.The extent of potential contamination may be quite large, but is generally concentrated inthe target area or bullet catcher.

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Examples of other types of ranges include:

B1 (section range) and B2 (sneaker range) – there will be a series of targets situated indifferent configurations depending on the training undertaken.

Demolition ranges – there will be a central impact target area and a safety trace/rangefloor radiating out from this area.

Air Weapons range – comprises a target area only with no ground based firing point.

Figure 3-1 Schematic of different components at a firing range

3.2 Conceptual Site Model

As described in the ASC NEPM, a Conceptual Site Model (CSM) describes the contaminationsources, pathways and receptors and the potential linkages between these.

The initial CSM is constructed from the results of a Stage 1 Preliminary Site Investigation(Stage 1 PSI) and is the basis for defining where potential source-pathway-receptor linkagesmay exist, that requires further investigation. The CSM must be continually reviewed andupdated throughout the assessment process to inform subsequent decisions on whether furtherinvestigation or contamination management actions are required.

The CSM should identify complete and potential pathways between known or potentialcontamination sources and receptors. Where the pathway between a source and a receptor isincomplete, the exposure to chemical substances via that pathway cannot occur, but thepotential for that pathway to be completed (for example, by abstraction of groundwater or achange in land use) should be considered in all stages of assessment. The CSM can also beused to consider where management measures would reduce the likelihood of an exposurepathway becoming complete.

The essential elements of a CSM are:

Known and potential sources of contamination and contaminants of concern including themechanism(s) of contamination (e.g. ‘top down’ spill or sub-surface release from corrodedtank or pipe).

Potentially affected media (e.g. soil, sediment, groundwater, indoor and ambient air).

Human and ecological receptors.

Potential and complete exposure pathways.

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For contaminated land site investigation reports (e.g. Stage 2 Detailed Site Investigation(Stage 2 DSI)) the CSM is to be presented as a graphic, a table or flow chart and adequatelydescribed in written text.

3.2.1 Likelihood of contamination

The likelihood of contamination arising at a firing range will be governed by many factorsincluding its age and frequency of use, the nature of the ordnance used, the range design(including any waste management and contamination management controls) and theenvironmental setting of the site.

The risk of contamination by live firing range can be determined using the Heavy Metal RiskManagement Tool and reference can also be made to PPMM Annex – K Heavy Metals on LiveFiring Ranges.

Frequently used firing ranges have a higher potential to cause contamination compared withfiring ranges that have been used sporadically over a similar period. When considering thepotential for contamination, it’s important to understand the ‘range load’ to gain an appreciationof the total quantity of ordnance likely to have been applied to an area over time. Newly builtfiring ranges are more likely to incorporate controls designed to contain and manage pollution.

The location of historical range areas is an issue that should be considered as part of thepreliminary site assessment. An area may have been occupied by different range types andcomponents over time which will influence the types of contaminants present.

3.2.2 Contaminants of Potential Concern (CoPC)

Firing range activities involve the discharge of projectiles of various compositions and contentsincluding explosive and combustible devices. The composition of projectiles and thesubstances contained within them, also referred to as munition constituents (MC) or explosiveresidues vary greatly. A detailed understanding of the nature of current and previous firingactivities at the range is essential when determining the CoPC.

Firing ranges used to practice with small arms (<20mm) ammunition including rifles, pistols,shotguns and machine guns are typically referred to as ‘small arms firing ranges’. Lead is themost common CoPC for small arms firing ranges and is deposited from spent lead projectiles.Other heavy metals may also be of concern, including the copper coating of steel ballammunition or other heavy metals used in the bullet components.

Weapons ranges are generally distinguished from small arms firing ranges because of the useof weapons containing ‘energetic materials’ which are chemical compounds or mixtures ofchemical compounds. These substances are constituents of explosives, propellants andpyrotechnics that are contained within the ordnance.

CoPC associated with explosives typically used by Defence can be grouped broadly into threeclasses:

1. Primary explosives, including lead azide and ammonium nitrate.

2. Secondary explosives, including: Hexahydro-1,3,5 trinitro-1,3,5-triazine (RDX),Trinitrotoluene (TNT), Octahydro-1,3,5,7-tetranitro 1,3,5,7-tetrazocine (HMX) and N-methyl-2.4.6- trinitrop-aniline (Tetryl).

3. Degradation products, including. 2-Amino-4.6 dinitrotoluene (2-Am-DNT) and Dinitroso-hexahydro-1,3,5-triazine (DNX)

The major commercial analytical laboratories in Australia have the capability to test for most ofthese compounds. CoPC for firing ranges are listed in more detail in Appendix A, and furtherdetails are provided in the references in Section 6.

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3.2.3 Fate and transport

Depending on the solubility and persistence of the contaminants present in a firing range,contaminants may be mobilised from the area as a result of leaching and runoff into theimmediate and surrounding environment, causing contamination of soil, sediment, surface waterand groundwater.

The likelihood of contamination being generated is also governed by the fate of the projectileupon firing. Some solid shot metal projectiles will be captured as complete rounds withinpurpose built bullet traps and have a low likelihood of entering the environment. Others willlodge in areas where there is a potential for them to generate contamination that could enter theenvironment, such as in open areas or earthen mounds/ stop butts. Fragmentation of theprojectile may also occur leading to generation of smaller and more leachable fragments.

The fate of larger munitions is more varied. Complete functioning or detonation of a weapon willtypically result in the release of debris and small quantities of munition constituents (MC),whereas incomplete detonation will cause the generation of a larger quantity of (unexploded orun-combusted) MC. If a munition fails to function resulting in the generation of a UXO, it may beeither intact with a low likelihood of release of MC, or damaged with a potential for release ofMC over time.

Lead is a key CoPC for most firing ranges and its behaviour in the environment has been welldocumented. Lead is oxidised upon exposure to air and then becomes dissolved when exposedto water. Lead bullets, bullet particles, or dissolved lead is moved by stormwater runoff and mayalso percolate downward to contaminate groundwater. Once oxidised and in a mobile form, theextent of migration of lead through the environment is dependent on soil characteristics, climate,topography and hydrogeology.

The fate and transport of explosive compounds is more complex and evaluation of the potentialfate and transport mechanisms is required for specific ordnance on a range-by-range basis.

There is the potential for CoPC from firing ranges to spread into soil, sediment and water,including groundwater. Health, safety and ecological risks may arise depending on the nature,extent and concentration of the contaminant and the exposure pathway. Potential exposurepathways for human and ecological receptors on or off the site may be through inhalation,ingestion or absorption.

3.2.4 Graphical CSM

A visual representation of a CSM for different firing range types, and the potential contaminationsources, pathways and receptors are presented in Figure 3-2.

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Figure 3-2 Potential Contamination Risks at Firing Ranges

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4. Projects and ContaminationManagement4.1 Background

The potential for contamination must be considered for any work that involves the developmentor excavation of areas on or within the vicinity of current or former firing ranges. Steps should betaken to identify contamination prior to the commencement of work so that:

Any contaminated soil, water or sediment identified during design andredevelopment/intrusive works where spoil is produced can be appropriately managed.

There is sufficient delineation of the nature and extent of contamination to identifywhether the area is suitable for its current or intended future use, including as part of anyDefence redevelopment, divestment or acquisition process.

Appropriate occupational hygiene measures are implemented to minimise exposure ofsite workers to contamination during works.

Where a recent investigation report is unavailable, an environmental investigation completed inaccordance with the ASC NEPM will be required. The level of investigation should becommensurate with the sensitivity of the current and intended future use of the land, the wastemanagement options being proposed or sampling requirements for offsite disposal, and theanticipated extent and magnitude of contamination. It should be conducted by a suitablyqualified professional with experience in the assessment and management of contamination.

Section 4.3 provides guidance on the assessment and management of contamination at firingranges. Other useful references for Project officers and environmental consultants include:

EPA Victoria, Publication 1710, Guide for managing contamination at shooting ranges,January 2019

Finnish Ministry of the Environment, Best Available Techniques (BAT), Management ofthe Environmental Impact of Shooting Ranges, 2014

ITRC (Interstate Technology Regulatory Council) 2003, Characterisation and Remediationof Soils at Closed Small Arms Firing Ranges, January 2003

USACE (US Army Corps of Engineers) 2007, Munitions Response Site PrioritizationProtocol Primer, April 2007

USACE, 2013, Environmental Quality, Technical Guidance for Military MunitionsResponse Actions, October 2013

USEPA, 2005, Handbook on the Management of Management of munitions ResponseActions, May 2005

4.2 Case Studies

The following case studies highlight the contamination risks related to live firing ranges andidentify management measures and sources of further information to assist to address thesecontamination issues. These case studies are hypothetical examples only.

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4.3 Case Study 1: Activities in a former operational weaponsrange

4.3.1 Scenario

A former field training area was identified for re-purposing. Defencepersonnel used the area for infantry minor tactics exercises likecrawling with weapons with hand excavated soils in the range footprintto create temporary defensive positions for firing. Environmental siteactivities assessed for the presence of unexploded ordnance burialsand identified elevated concentrations of heavy metals (primarily lead)and some explosive residues that were significantly above adoptedcriteria.

4.3.2 Risks

HSE Risk – Site activities may have commenced in contaminatedareas without appropriate site assessment to characterise anddelineate the contamination resulting in potential exposure of Defencepersonnel or contractors to contaminants.

Defence Capability – Delays to training activities and remediationcosts associated with managing unexpected contamination prior toundertaking projects in firing ranges, led to a significant impact onDefence capability.

Reputational Risk – Proactive site assessment and management canreduce the legal and reputational risks associated with exposure ofDefence personnel to contamination.

4.3.3 Key considerations and management measures

Review the GEMS EFM – CSR and consider all relevantsources of information, including knowledge of experienced sitepersonnel and existing reports or documentation.

If existing information is not available, the physical setting of thesite must be characterised via a Stage 1 PSI or a Stage 2 DSIand the collection of environmental samples (as required).

Prepare an environmental management plan for management ofcontamination risk during demolition activities (e.g. Can chemical residues beappropriately removed from structures prior to demolition to allow re-use of buildingmaterials?).

Prevent potential exposure to personnel from contamination by using dedicated trainingareas where chemical residues are not present, and manage or remediate existingcontamination to prevent risks to potential receptors.

Document and record works and maintain records of investigations, monitoring andremediation that is conducted in GEMS EFM – CSR.

4.3.4 More information Defence Contamination Management Manual Pollution Prevention Management Manual Annex 1K – Heavy Metals on Live Firing Ranges

Environment and Sustainability Manager (ESM)

Draft DUXOMM

Why is this an issue?Use of live firing ranges forother training activitiesneeds to consider thepotential for contaminationto be present from previoususes. Residues andbreakdown products fromprojectiles, ordnance etc.may present risks to healthand/or the environment,and risk Defence’sreputation.

How can I manage it?A thorough desk basedreview of availableinformation must beundertaken during planningfor training or otheractivities in a training areato understand historical useof the area. Investigationsmay then be required toassess the contaminationrisk.

Further information? Defence ESM DCMM PPMM Annex 1K DDUXOMM Training Area Standing

Orders

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4.4 Case Study 2: Demolition of a former indoor range

4.4.1 Scenario

A disused indoor firing range was being demolished to allow for theconstruction of a new administration area. Prior to construction, a siteassessment was undertaken which did not identify the presence ofcontamination in soil or groundwater surrounding the former indoorrange, or the presence of any hazardous building materials (e.g.asbestos, or lead paint) within the building structure. It was proposedthat the concrete and brick from the building be crushed for reuse as fillfor a new car park.

During demolition works, a health and safety audit was undertaken, andit was found that lead residues (in the form of lead contaminated dust)was not removed from inside the building prior to works starting. Acontamination assessment identified lead resides within a stockpile ofcrushed concrete.

4.4.2 Risks

HSE Risk – Site activities may have commenced in contaminated areaswithout appropriate site assessment to characterise and delineate thecontamination resulting in potential exposure of Defence personnel orcontractors to site contamination.

Defence Capability – The time and costs associated with managingunexpected contamination in a training area can have a significantimpact on Defence capability.

Commercial Risk – Significant unplanned costs may be incurred forremediation, monitoring and waste disposal, and these works have thepotential to cause delays to the project.


Undertake all works in accordance with the Defence WHSManual which has detailed requirements for common WHShazards in particular Defence WHS Manual Volume 3, Part 3A,Chapter 8 Procedure: LEAD:00 Management of Lead in Indoor Firing Ranges

Review the GEMS EFM – CSR to access, review available data and understand thehistoric use of the area and where chemical residues may be present.

If existing information is not available, the physical setting of the site must becharacterised via a site investigation and the collection of environmental samples (asrequired). Site investigations may include a PCA, Stage 1 PSI or Stage 2 DSI.

Prepare an environmental management plan for management of contamination riskduring demolition activities (e.g. Chemical residues must be appropriately removed fromstructures prior to demolition to allow re-use/disposal of building materials).

Document and record works and the results of investigations and monitoring.

4.4.4 More information

Defence Contamination Management Manual Environment and Sustainability Manager DCMM Annex J Demolition DCMM Annex C Management of Stockpiles and Re-use of Contaminated Material Defence WHS Manual Volume 3, Part 3A, Chapter 8 Procedure: LEAD:00 Management

of Lead in Indoor Firing Ranges

Why is this an issue?Site redevelopment inareas, including buildings,where there is inadequateunderstanding of historicalcontaminant sources canresult in risks to Defencepersonnel and contractorsand potential delays toproject works.

How can I manage it?Characterisation of thearea, including inside anybuildings used as firingranges, to understandrisks associated with CoPC.Remove chemical residuesto allow maximum re-useof building materials andreduce disposal to landfillwhere possible.

Further information? Defence ESM DCMM DCMM Annex J DCMM Annex C WHS Manual

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4.5 Case Study 3: Disposal of wastes from a bullet catcher

4.5.1 Scenario

An earthen bullet catcher at a classification range was beingdemolished as part of a redevelopment to construct a vehicle trainingarea. A site investigation was undertaken which involved the collectionand analysis of soil samples from the range floor and from the face ofthe bullet catcher. The outcome of the investigation confirmed that thesoils were suitable for disposal to a local Council operated landfill.

Upon receipt of waste material, lead projectiles were identified by thelandfill operator within several of the loads of material. As a result, theloads were returned to the Defence facility and construction workshalted.

Further investigations were conducted and concluded that the initialinvestigation had tested the soil at the rear of the bullet catcher only(where spoil from de-leading operations had been placed), but had notconsidered the presence of lead projectiles in the soil matrix within theimpact zone.

4.5.2 Risks and lessons learnt

Commercial Risk – Significant unplanned costs may be incurred foradditional rounds of investigations and changes to remediation planswhere initial site assessment does not appropriately characterise anarea.

Defence Capability – The time and costs associated with managingunexpected contamination in a training area can have a significantimpact on Defence capability.

Reputational Risk – Unexpected circumstances can result insignificant variations from the contractor. Environmental or safety incidents arising due tounexpected contamination can result in reputational damage.


Review the GEMS EFM – CSR and consider all relevant sources of information, includingthe knowledge of experienced site personnel and any existing reports or documentation.

If existing information is not available, the physical setting of the site must becharacterised via a site investigation and the collection of environmental samples (asrequired). Site investigations may include a PCA, Stage 1 PSI or Stage 2 DSI.

In addition to the soil matrix, the characterisation of contamination at firing ranges mustalso consider contaminants present within intact projectiles (such as lead bullets) or othermunitions wastes.

Document and record works and the results of investigations, monitoring andremediation.

4.5.4 More information

Defence Contamination Management Manual

Environment and Sustainability Manager

Why is this an issue?Poor characterisation ofcontamination can resultin risks to Defencepersonnel and contractorsand potential delays toproject works.

How can I manage it?The design of samplingprograms to characterisecontamination withinfiring ranges mustconsider the nature of thefiring activities and likelycontamination footprintincluding the presence ofcontamination hotspots incertain areas.

Where can I get help? Defence ESM Defence Contamination

Management Manual Site Assessment

Guidelines

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4.6 Management

A staged approach may be required to understand, characterise and to manage the potential forcontamination at firing ranges and surrounding land.

Each stage of works should be considered as a discrete task, and hold points arerecommended at the completion of each stage to consider whether progression to the nextstage is required.

A Stage 1 PSI and/or Stage 2 DSI may already have been completed for many active andlegacy firing ranges across the estate, and pollution prevention or contamination managementmeasures may be in place. For these sites, a review of existing reports, data and documentationthat may be available on the GEMS EFM – CSR must be undertaken as a priority before worksproceed.

A summary of some of the key items to be considered is provided in Error! Reference sourcenot found.. Stages should be completed as necessary to ensure the risk of contamination ismanaged.

Table 4-1 Management considerations

Stage of works Summary of points for consideration Next steps

Pre-constructionContaminationAssessment (PCA)

Review of the GEMS EFM – CSR. Limited soil sampling in the footprint of the

construction area. If groundwater is shallowand construction will require dewateringconsider collection of groundwater samplesalso.

Analysis of samples for the CoPC, includingthose discussed in Section Error! Referencesource not found..

A PCA is suitable forconstruction projectswhere spoil, and / orwaste water, needs tobe characterised for re-use, temporarystockpiling or for off-sitedisposal.

Obtain approval fromDefence (reuse) orregulator (off-sitedisposal) based on thedata and any relevantECC conditions.

Stage 1:

Preliminary SiteInvestigation

Establish historical use of the area through adesktop review and interviews with personsfamiliar with historic legacy waste sites use.

Understand the physical setting of the site(including soils, hydrogeology and hydrology).

Document all works undertaken. Risk assessment based on the Contamination

Risk Assessment Tool (CRAT). Heavy metals risk assessment tool (HMRAT)1

The findings of theStage 1 PSI should becommunicated to theDefence ProjectManager for the decisionto proceed to the Stage2 DSI.

An ECC may berequired.

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Stage of works Summary of points for consideration Next steps

Stage 2:

Detailed SiteInvestigation

Investigation of potentially contaminatedmedia (including soils, sediments,groundwater, and surface water), to delineatethe nature and extent of contamination.

Sampling for explosive residues should beundertaken in a manner consistent withguidance documentation as discussed inSection 4.1, and with ASC NEPM andAustralian Standards for other CoPCs.

Geophysical investigation techniques arerecommended in areas where burials of UXO2

may be present.

Develop a CSM to assess the risk to receptorsunder the existing land use, and any proposedredevelopment included during site works.

Document and report all works undertaken.

Update to Contamination Risk AssessmentTool (CRAT).

The scope of works forsite investigations andfindings of the Stage2 DSI should bediscussed with, andcommunicated to theESM for longer termmanagement of the site.


Stages 3 - 5:

RemediationPlanning,Implementation andSite Management

Undertake risk assessment or remediationoptions analysis and design, as required, todefine further remediation or management.

Establish procedures for the remediation ormanagement of contamination to minimiseany unacceptable risks of potential exposureto contamination. This process must include astop work procedure.

Allow for uncertainty by developingcontingency procedures.

Implement and manage the works inaccordance with the established procedures.

Document works undertaken, includingvalidation of any remedial works.

Site management options and/or monitoringrequirements to be established post


Decommissioning Consideration must be given to contaminationresidues on infrastructure. eg PFAS or PCB’sin concrete

Prior to demolition works, an assessment ofthe contamination status of infrastructuresurfaces must be undertaken so that disposalor recycling options for building materials canbe determined.


1 Refer Pollution Prevention Guideline Annex 1K – Heavy Metals on Live Firing Ranges2 Assessment methods and technologies for UXO are beyond the scope of this document, and reference must

be made to the Draft DUXOMM, where this type of assessment is required.

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Any assessment activities within a firing range, whether current or former, must consider safetyfor personnel present in the area from UXO.

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5. Data and Reporting5.1 GEMS EFM – CSR

Data and reports generated as part of the investigation and assessment of contamination mustbe captured in the GEMS EFM – CSR.

The GEMS EFM – CSR is the database used to capture environmental information across theDefence estate, and provides access to historical contamination investigation reports forDefence properties. Contaminated site records are geo-referenced and they can be accessedby Defence personnel or contractors with Defence Restricted Network (DRN) Access.

Contractors/Consultants working on behalf of Defence must provide reports, updated andcompleted GEMS Date Load Tool (GDL) (for new or existing CSR’s), CRAT, ESdat and(Geographic Information System) GIS files relating to contamination to their Defence point ofcontact, Project Manager or ESM who will be responsible for auditing and validatingsubmissions and ensuring the upload of information into the GEMS EFM – CSR.

Refer to the Defence Contamination Management Manual, Annex L - Data Management.

5.2 Geographic Information Systems

All mapping Geographic Information System (GIS) data is required to be provided to Defence inNational Spatial Information Management System (NSIMS) metadata format. The Defence NSIMSmetadata tool is available through an online search and on DEQMS.

Refer to the Defence Contamination Management Manual, Annex L – Data Management

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6. ReferencesDepartment of Defence 2014, Defence Work Health and Safety Manual, Department ofDefence, Canberra, June 2014

Department of Defence, 2017, Pollution Prevention Management Manual, 2016, Department ofDefence, Canberra, June 2017

EPA Victoria, Publication 1710, Guide for managing contamination at shooting ranges, January2019

Finnish Ministry of the Environment, Best Available Techniques (BAT), Management of theEnvironmental Impact of Shooting Ranges, 2014

ITRC, 2003, Characterisation and Remediation of Soils at Closed Small Arms Firing Ranges.www.itrcweb.org

Jacobs, 2016, Technical Memo, A review of military explosive contaminants’ appropriateness tothe Australian Context, File name Q6827324.docx, 17 June 2016

NEPC 2013, National Environment Protection (Assessment of Site Contamination) Measure1999 (Cth), NEPC

USACE, 2007, Munitions Response Site Prioritization Protocol Primer, April 2007

USACE, 2013, Environmental Quality, Technical Guidance for Military Munitions ResponseActions, Ref EM 200-1-15, October 2013

USEPA (United States Environmental Protection Agency), Handbook on the Management ofManagement of Munitions Response Actions, May 2005

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Appendices

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Appendix A – Potential Firing Range ContaminantsThe following is a suggested analyte suite for the identification of contamination arising from smallarms and weapons usage at Australian Defence sites1.

1 Jacobs, 2016, Technical Memo, A review of military explosive contaminants’ appropriateness to the AustralianContext, File name Q6827324.docx, 17 June 2016.

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