NRC betrays Iowa Sportsman Again!

[kbnelson3]

It's too bad a few eagles die every year, but with populations at a high and stable level, does it really matter? Are there any other mortality numbers for other types of bald eagle deaths? Nobody wants dead eagles, but you can't micro manage every single species to try to prevent a few dozen mortalities

 

[iowaqdm]

It's too bad a few eagles die every year, but with populations at a high and stable level, does it really matter? Are there any other mortality numbers for other types of bald eagle deaths? Nobody wants dead eagles, but you can't micro manage every single species to try to prevent a few dozen mortalities

Exactly!!! :way:

6x6 - I don't deny that a few scavengers die from lead ingestion. I am fairly confident that it is not from lead shot being used to hunt doves so your point concerning this legislation is a mute one to myself. If your goal was to promote the use of copper slugs for deer hunting because of the scavengers feeding on gut piles or carcusses then fine. If someone chooses to do that then great. I'm fine with the person getting to choose but not making laws because a few scavengers die. Way more scavengers die from powerlines and vehicle collisions. Maybe a call to your local power company to ask that they bury the rest of the powerlines they have with the reason being to help save a few birds. Then start a public campaign for driver awareness to get motorists to watch for scavengers feeding on road kills along Iowa highways.

If I remember right you are located in the Loess hills not far from the Missouri river which is normally not frozen during the shotgun seasons. Remember that eagles migrate and will winter along the rivers. That eagle could have picked up lead in South Dakota, Nebraska, Missouri, Iowa or even futher away. An eagle can travel a long ways in 3-10 days. Very few eagles will be located in Iowa when most of the dove hunting will occur so I don't really feel this regulation will save any eagles. Just my opinion of course.

 

[6x6]

iowaqdm- sorry I was off the topic, just shareing what I have found here.I am not trying to change any laws, but as long as you went there, what about the few pheasants and quail we have left, feeding on the dove fields that have had 20 boxes of shells shot over it? Thats alot of lead. One piece and thats one less hen for next breeding season. I just get sick of guys that as soon as someone questions the lead they automatically go into the, they are going to end all hunting mode. Honestly I have never seen a "scavenger" killed on the road, but I am sure for every one thats rescued there are many more never found, way more than a few.If thats allright with your "qdm" so be it. Its pretty easy to shoot at a deer and go home, without thinking about what happens after .

 

[iowaqdm]

Honestly I have never seen a "scavenger" killed on the road, but I am sure for every one thats rescued there are many more never found, way more than a few.If thats allright with your "qdm" so be it.

I have seen numerous scavengers killed on the road. Mostly red-tailed hawks and turkey vultures. Regardless of the number killed on roads or powerlines. There is no shortage of scavengers/hawks or raptors in general anywhere in Iowa. The life expectancy of raptors/scavengers is generally being between 15-40 years, with no predators and an average of 2 young per year, it's no wonder there is one on every telephone pole and every other fence post. All raptor populations that I am aware of are increasing not decreasing. I'm not worried about the hen pheasants surviving the lead pellet laying on the ground but rather surviving the hawk predation.

If lead shot was really as detrimental as the liberal environmentalists claim why hasn't the EPA banned it? Because there is no science to back it. Lead is so dense that any lead that falls on agricultual ground will settle too deep for any bird to pick up the first time the ground is worked. If pheasants were picking up lead shot off of the ground there wouldn't be a pheasant left out in South Dakota with the semi loads of lead shot dropped on the pheasant habitat/food sources each year. Yet every year millions of pheasants are reared. I wonder how many lead poisioned pheasants they find. I've never heard of anyone finding a single bird.

South Dakota pheasant Stats reported in Sioux City Journal:

"A preliminary report puts the 2010 pheasant harvest in South Dakota at 1.83 million birds.
That's up 12 percent from 2009 and the fifth highest number of pheasants shot by hunters in the past 10 years.
The preseason pheasant population was estimated at 9.9 million birds last year.
The Game, Fish and Parks said there were 172,751 licensed hunters in 2010. For the ninth straight year the season attracted more nonresident hunters than resident hunters."​

One point that you are missing is that I could stand on my land and shoot a hundred cases of lead shot into the air for fun and it is perfectly legal. I shoot at a dove on that same land and now it's not ok. It's not just that there is no science to back banning lead shot for dove hunting it is also a private property issue. Only 2% of Iowa is public land and that leaves 98% private so I would guess 95% or more of the shots fired at doves will be on private property.

 

[6x6]

Wow, relax dude, my fault for posting an opinion in general that really did not have alot to do with the dove lead ban specifically. Again, guys sure tend to get riled up when they think someone is trying to take their lead. Shoot away, its your land.

 

[Cooter]

California band all lead.......so it must be bad.

 

[tc1968]

California band all lead.......so it must be bad.

Hahahahahah! Now that is funny! We are to use California as an example. The state that want to secede (southern california) and become the 51st state, bans happy meals, protects a little minnow over people and is shutting down whole agriculture areas, wants to shut down archery ranges, ban all gun sales, has some of the highest taxes in the world but is beyond broke and is so left wing they make Jimmy Carter look like Reagan.

All I can do is laugh and then cry to think we are to look to California and say - "they did it so we should".

 

[turtlshell]

There is no shortage of scavengers/hawks or raptors in general anywhere in Iowa. The life expectancy of raptors/scavengers is generally being between 15-40 years, with no predators and an average of 2 young per year, it's no wonder there is one on every telephone pole and every other fence post. All raptor populations that I am aware of are increasing not decreasing. I'm not worried about the hen pheasants surviving the lead pellet laying on the ground but rather surviving the hawk predation.

For Iowa, those numbers provide a "more huntable" population, than doves!!!

BTW - you're WRONG about the EPA and lead. The EPA has an immense amount of regs regarding lead...it just hasn't spilled over into hunting side of things.

Concentrating hundreds of hunters on a "public hunting field" (lets just say 50acres) specifically planted for doves...and each person is blasting away with lead shot at a 7shots to 1dove ratio, is NOT beneficial for the land...especially from an environmentally conscious approach. How many years of repeated "dosage" would it take for levels of lead (ppm) to surpass acceptable given this situation? It doesn't take research to prove lead has drawbacks, just common sense!

For the record, I'm not telling you what you can do on your land...you're not concentrating the contamination the way the it's happening on public lands.

Have you ever heard of CERCLA?, because once the contamination levels are exceeded and the EPA steps in to declare the area a problem, it's a hell of a lot more expensive to clean it up at that point than it is to be PROACTIVE about requiring non-toxic shot upfront.

What would the costs of a superfund site do to an already strapped state budget? Say 20, 50yrs down the road an acreage at your favorite public land in Iowa is determined to have unacceptable levels of lead by the EPA. There's no budget for the costs associated with those types of cleanups...so is it fair to pass the costs off to the tax payers (who don't hunt and didn't cause the problem), your children, etc....just for your own stubborn benefits right now?

 

[tc1968]

For Iowa, those numbers provide a "more
For the record, I'm not telling you what you can do on your land...you're not concentrating the contamination the way the it's happening on public lands.


Not a 100% true statment when you concider that only 2% of Iowa land is public and within that 2% the vast majority of the land is WPA and steel shot (non-toxic) is already required - so you there is NO way you can have the scenario of stacked in dove hunters the way you are laying it out. The main points to this law are still the same:

1) More regulations leads to less hunting.
2) There are regulations already in placed for most public areas.
3) Private land and personal choices.
4) No concrete proof lead from upland hunting effects wildlife.

 

[iowaqdm]

BTW - you're WRONG about the EPA and lead. The EPA has an immense amount of regs regarding lead...it just hasn't spilled over into hunting side of things. Concentrating hundreds of hunters on a "public hunting field" (lets just say 50acres) specifically planted for doves...and each person is blasting away with lead shot at a 7shots to 1dove ratio, is NOT beneficial for the land...especially from an environmentally conscious approach. How many years of repeated "dosage" would it take for levels of lead (ppm) to surpass acceptable given this situation? It doesn't take research to prove lead has drawbacks, just common sense! For the record, I'm not telling you what you can do on your land...you're not concentrating the contamination the way the it's happening on public lands. Have you ever heard of CERCLA?, because once the contamination levels are exceeded and the EPA steps in to declare the area a problem, it's a hell of a lot more expensive to clean it up at that point than it is to be PROACTIVE about requiring non-toxic shot upfront. What would the costs of a superfund site do to an already strapped state budget? Say 20, 50yrs down the road an acreage at your favorite public land in Iowa is determined to have unacceptable levels of lead by the EPA. There's no budget for the costs associated with those types of cleanups...so is it fair to pass the costs off to the tax payers (who don't hunt and didn't cause the problem), your children, etc....just for your own stubborn benefits right now?

"BTW - you're WRONG about the EPA and lead. The EPA has an immense amount of regs regarding lead...it just hasn't spilled over into hunting side of things."

I would disagree on the hunting side/lead shot issue. I believe the EPA has not implemented lead shot or ammunition regulations because there is not scientific evidence that supports regulations.

Main sources of lead poisioning are:
Deteriorating lead-based paint (paint chips)
Lead contaminated dust (from dry lead paint/scraping old lead paint off)
Lead contaminated residential soil (from paint dust off exterior of house or spilled/burned lead based gasoline)
The EPA regulations are mainly for lead based paint and lead based gasoline when looking at individual/personal use. That is obviously excluding industrial regulations.

"Have you ever heard of CERCLA?"
Yes.
Here is an example specific to lead shot and its affects according to the EPA-CERCLA. The study was done at a former Naval Base skeet range located on San Francisco Bay, CA where lead shot was used for 30-40 years prior to the study being completed. It is 105 pages long and was finalized in 2005. Feel free to read the entire thing as I have done. I linked the report at the bottom for you. I copied and pasted some highlights of the report as well as the letters from the Navy, EPA, San Francisco Regional Water Quality Control Board and Department of Toxic Substances Control for those who don't want to read all of the report. I highlighted in red the main points needed to understand the study and the findings. I think 30-40 years of skeet shooting on a military base would concentrate a little more lead than your example of a 50 acre dove field on public land in Iowa. The EPA found the following results. The results of the Remedial Investigation and Risk Assessments have shown that the lead shot and polycyclic aromatic hydrocarbons (PAHs) found at this site do not pose an unacceptable risk to either humans or potential ecological receptors such as diving water fowl. The type and concentration levels of the PAHs are similar to surrounding ambient conditions and the lead shot is found approximately 80 feet offshore. The lead shot is not breaking down and hence, is not readily bio-available. Diving water fowl are not expected to ingest a sufficient quantity of whole pellets to be adversely affected. The document follows the format of the EPA guidance: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents, and includes all of the necessary elements for a No Further Action Record of Decision.

EPA/ROD/R0

9-05/058​

2005
EPA Superfund
Record of Decision:
ALAMEDA NAVAL AIR STATION
EPA ID: CA2170023236
LAMEDA, CA

09/21/2005​

DEPARTMENT OF THE NAVY
BASE REALIGNMENT AND CLOSURE
PROGRAM MANAGEMENT OFFICE WEST
1224 COLUMBIA STREET, SUITE 1100
SAN DIEGO, CA 92101-8571
5090
BPMOW.CD\1226

September 19, 2005​

Mr. Mark Ripperda
U.S. EPA Region IX
75 Hawthorne Street
San Francisco, CA 94105-3901
Dear Mr. Ripperda:
Subj: FINAL RECORD OF DECISION SKEET RANGE (IR SITE 29) ALAMEDA POINT, CALIFORNIA

This letter transmits the Final Record of Decision (ROD) for Skeet Range Alameda Point, California, The draft ROD was distributed to the agencies on April 18, 2005. The Skeet Range (IR Site 29) was determined by the Department of the Navy to require no further action for sediments that might have been affected by site-specific use. The Navy subsequently received concurrence on the Draft ROD for no further action from U.S. EPA, the San Francisco Regional Water Quality Control Board (RWQCB), the Department of Toxic Substances Control (DTSC). Concurrent with the submittal of this ROD, a signatory page (page vii) is being forwarded for signatures to the EPA, RWQCB, and OTSC. Upon receipt of the signature page, the Navy will submit a replacement signatory page to the recipients of the ROD. If you have any questions or comments, please call Ms. Claudia Domingo at (619) 532-0935 or me at (619) 532-0907.​

Sincerely,
THOMAS L. MACCHIARELLA
BRAC Environmental Coordinator
By direction of the Director

DECLARATION
SITE NAME AND LOCATION
This decision document addresses the former Skeet Range (Installation Restoration [IR] Site 29) at the former Naval Air Station (NAS), now referred to as Alameda Point, in Alameda, California. The U.S. Environmental Protection Agency (EPA) Comprehensive Environmental Response, Compensation, and Liability Act Information System (CERCLIS) identification (ID)
number is CA2170023236.
STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) presents the selected remedy, no further action, for the former Skeet Range (IR Site 29), in Alameda, California. This document was developed in accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) of 1980, as amended by Superfund Amendments and Reauthorization Act (SARA) of 1986 (Title 42 United States Code Section 9601, et seq.), and, to the extent practicable, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) (Title 40 Code of Federal Regulations Part 300).
This decision is based on information contained in the administrative record file (a site-specific administrative record index is included as Attachment A) as well as on extensive field investigations, laboratory analyses, interpretation of the data, review of current and future conditions, and thorough assessment of the potential human health and ecological risks. Based
on these findings, there are no land use restrictions, environmental monitoring, or Resource and Recovery Act (RCRA) corrective action required at the site. The U.S. Department of the Navy (DON), the San Francisco Regional Water Quality Control
Board (RWQCB), the state of California Environmental Protection Agency, Department of Toxic Substances Control (DTSC), and the U.S. EPA concur on the selected remedy for this site. Agreement letters from the U.S. EPA, DTSC and the RWQCB are included as Attachment B.
ASSESSMENT OF THE SITE
The DON has concluded that remedial action is not required to protect public health or the environment on the basis of the following: site histories; field investigations; laboratory analytical results; evaluation of potential ecological and human health risks; current and reasonable anticipated future land use. Results of investigations at the Skeet Range (IR Site 29) have verified that current and reasonably anticipated future land uses at the site do not pose a risk to human health or the environment. The human health risk assessment indicated that there are no complete pathways in which humans would be exposed to site-related contaminants of concern. Similarly, the ecological risk assessment concluded that there are no unacceptable ecological risks associated with the sediments offshore of the former Skeet Range and that the ecological community is not impacted.
STATUTORY DETERMINATIONS
The DON has concluded that no remedial action is necessary at the site because the current and reasonably anticipated future land use and likely future use of the site is protective of human health and the environment and complies with federal and state requirements. A five-year status review will not be required because: 1) this remedy will not result in hazardous substances,
pollutants, or contaminants remaining on-site at levels above those that allow for unlimited use and unrestricted exposure, and 2) as a result, a remedial action was not necessary or selected in this ROD.
1.0 SITE NAME, LOCATION, AND DESCRIPTION
This Record of Decision (ROD) presents the determination by the Department of the Navy (DON) that no remedial action is necessary at the former Skeet Range (Installation Restoration [IR] Site 29) at the former Naval Air Station (NAS), now referred to as Alameda Point, in Alameda, California. This ROD satisfies the Department of Toxic Substances Control (DTSC)
requirements for a Remedial Action Plan (RAP) for hazardous substance release sites pursuant to California Health and Safety Code Section (() 25356.1.
This document was developed in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980, as amended by Superfund Amendments and Reauthorization Act (SARA) of 1986 (Title 42 United States Code Section [§] 9602 et seq.), and, to the extent practicable, the National Oil and Hazardous Substances Pollution Contingency
Plan (NCP) (Title 40 Code of Federal Regulations § 300 et seq.). The decision for this site is based on information contained in the administrative record file (a site-specific administrative record index is included as Attachment A) as well as on extensive field investigations, laboratory analyses, interpretation of the data, review of current and anticipated future conditions, and
thorough assessment of the potential human health and ecological risks. Based on these findings, there are also no land use restrictions, environmental monitoring, or Resource and Recovery Act (RCRA) corrective action required at the site.
1.1 Site Name
This decision document addresses the former Skeet Range (IR Site 29) at the former NAS, now referred to as Alameda Point, in Alameda, California.
1.2 Site Location and Description
The former Skeet Range (IR Site 29) is located on the northwestern corner of the former NAS (see Figure 1), now referred to as Alameda Point, in Alameda, California. The Skeet Range (IR Site 29) extends offshore into the San Francisco Bay with dimensions of about 1,300 feet (ft) by 800 ft. The primary site-related contaminants (lead shot and polycyclic aromatic hydrocarbons [PAHs] from the clay targets) are located approximately 80 ft offshore, in water depths averaging 5 ft or greater. Figure 2 depicts Alameda Point in relation to San Francisco Bay.
1.3 Lead and Support Agencies
Since 1993, the Alameda Point Base Realignment and Closure (BRAC) Cleanup Team (BCT) has coordinated cleanup and closure activities for Alameda Point to support the transfer and redevelopment of the offshore property by the Alameda Reuse and Redevelopment Authority (ARRA). The BCT consists of representatives from the Navy, U.S. EPA Region 9, DTSC, and
California Regional Water Quality Control Board (RWQCB). The DON is the lead agency for environmental restoration at the site and U.S. EPA is the lead regulatory agency providing oversight. A Federal Facility Agreement (FFA) between the DON and U.S. EPA was signed on July 5, 2001. The FFA defines the DON’s corrective action and response obligations under RCRA and CERCLA
2.0 SITE HISTORY AND INVESTIGATION ACTIVITIES
Historically, the Skeet Range consisted of two main shooting ranges (northern and southern) that were actively used for 30-40 years until their closure in 1993. Lead shot were discharged from guns toward clay pigeon targets projected westerly over San Francisco Bay. As a result, lead shot and clay target fragments reside in the sediment adjacent to the Skeet Range (IR Site 29),
concentrated in an area located 80 ft offshore in average water depths ranging from 5- to 12-ft deep. The clay pigeon targets were bound together with petroleum products that contain PAHs. Based on these historical activities, concerns were raised about possible adverse effects to humans and wildlife resulting from exposure to lead and PAHs in the offshore area. The Skeet Range was initially identified as a specific area of concern based on the results of sediment sampling conducted as part of the 1994 Ecological Assessment for former NAS Alameda. One of five study areas evaluated in the Ecological Assessment was Western Bayside, a region of open bay water adjacent to the northern and western edges of the former NAS Alameda. Of the 13 Western Bayside sample stations, two were located within the Skeet Range (IR Site 29) study area (i.e., Stations B03 and B04) and confirmed the presence of lead shot and PAHs. Additional sampling and analysis was conducted in 1996 as a follow-on to the draft Operable Unit (OU) 4 (Western Bayside) Ecological Risk Assessment (ERA) (PRC, 1996) and in 1998 as a part of the Ecological Assessment of the Alameda Point Skeet Range Area (TtEMI, 2000). A summary of these investigations, which led to the designation of the Skeet Range as an IR site in August 2000 during the development of the Site Management Plan for the Federal Facilities Agreement (FFA), is provided below.
1996 OU4 Ecological Assessment
Based on the results presented in the 1994 Ecological Assessment, PRC (subsequently called TtEMI) performed additional sampling and analysis as follow-on to the draft OU4 Ecological Risk Assessment (PRC, 1996). Initially, a full reconnaissance of the site was performed where grab samples were collected every 45 ft along five transects (A through E) covering an angle of
90 degrees outward from each of the two (northern and southern) shooting ranges (Figure 3). The transects from each range were labeled A through E in a north to south direction from their point of origin (N-A through N-E in the northern shooting range, S-A through S-E in the southern shooting range). The approximate origin of each transect corresponded to the shooting
stand of each range, and extended out to a distance of roughly 1,000 ft. Grab samples were sieved and weighted for lead shot and used to determine the approximate spatial distribution (i.e., fall zone) of lead shot over the site. Using the distributions, a series of arcs representing contaminant distribution were established for the northern and southern regions of the Skeet
Range, which were used to develop the sampling plan. These arcs represented:• The region of the Skeet Range at which shot density was greatest (middle arc)• The inshore boundary of the Skeet Range at which shot density decreases (inner arc)• The offshore boundary at which shot density decreases (outer arc). Based on the results of the field reconnaissance, 12 sediment core locations were sampled from select stations in the northern and southern ranges. Samples were analyzed for lead and PAHs to
characterize the vertical extent of contamination. The data collected from these samples are presented in the Chemical Data Summary Report for Offshore Sediment (TtEMI, 1998).
1998 Supplemental Sampling
In 1998, additional sediment core samples were collected at the Skeet Range (IR Site 29) to further delineate the distribution of lead shot found at depth (TtEMI, 2000). Based on the 1996 investigation, the area of maximum lead shot density was located in the vicinity of sampling location SKB009 with decreasing density extending 10 acres from the shooting ranges. Ten
sediment core samples were randomly collected from this area of highest lead shot density (see Figure 4). Only lead and PAHs were identified as constituents of concern based on the historical activities at the site. Results of the lead shot depth distribution analysis showed that the concentration of lead shot generally increases with depth to about 20 centimeters (cm), with maximum concentration occurring between 4 and 20 cm. Lead shot was not detected in the 40- to 45-cm depth interval, indicating that the shot only occurs in the top 0.5 meter (m) of sediment. Lead shot was not typically found in the top 4 cm of sediment, suggesting that settling and sedimentation are leading to shot burial.
Ecological Assessment
The 1996 study results were integrated with the 1998 investigation and presented in the Ecological Assessment, which was submitted to the BCT on February 20, 2000 (TtEMI, 2000). Based on the 1996 investigation, density of lead shot was highest in the area that overlaps the two shooting ranges. The study also included an investigation of the degree of dissolution of lead
in sediment and porewater from lead pellets to determine if lead dissolving from the shot is biologically available. The results indicated that lead from the lead shot is not dissolving in quantities that would be considered to be biologically of concern based on ambient water quality criteria (AWQC) and is not present at concentrations that could cause adverse ecological effects
(TtEMI, 2000). Therefore, additional investigations focused on exposure to PAHs and to the lead shot. PAH concentrations from sediment and porewater were also compared against San Francisco Bay reference stations and to toxicity benchmarks, specifically the effects range-low (ER-L). Although some PAH compounds were found to exceed ER-Ls, the data show that the
concentrations of total PAHs found in the Skeet Range are comparable to concentrations measured from ambient locations. Concentrations within the Skeet Range either are relatively uniform with depth or (in several locations) increase with depth. Maximum concentrations of PAHs in some samples were found at depths greater than lead shot, suggesting that clay targets
or Skeet Range (IR. Site 29) activities might not be responsible for the PAHs found in sediment.Incorporating the results from both the 1996 and 1998 investigations, theEcological Assessment (TtEMI, 2000) concluded that the bulk and dissolved concentrations of lead and PAHs are belowAWQC and reflect ambient concentrations. In addition, the Ecological Assessment (TtEMI, 2000) suggested, based on the lead shot depth distribution, that sediment was accumulating and burying the lead shot, rendering it unavailable for diving birds and that PAHs within the study area might not be attributable to historical site operations.
The RWQCB identified several significant concerns regarding the conclusions of the Ecological Assessment. Specifically, the RWQCB disagreed with the finding that levels of lead and PAHs in sediments were within the range of ambient concentrations. The RWQCB also expressed concern about the relevance of applying results from the United States Army Corps of Engineers
(USACE) sediment accumulation studies to the Skeet Range (IR Site 29). Finally, the RWQCB disagreed with the low significance of exposure and risks to diving birds from ingestion of shot as stated in the ERA. To address these concerns, the DON conducted a field investigation in November 2001 to further characterize the spatial extent of lead shot distribution, determine the
source of the PAH contamination, and develop sediment depositional rates.
Skeet Range
Final Record of Decision 7 September 2005
2001 Skeet Range Site Evaluation
The primary objectives of the 2001 evaluation were to: 1) further define the lateral and vertical extent of lead shot in sediments to determine the potential for exposures to human and ecological receptors; 2) evaluate the extent of vertical mixing of lead shot based on the sedimentation rate; and 3) determine if PAHs present at the site are associated with fragments of the clay pigeon targets. To achieve these objectives, 40 surface sediment samples and 25 sediment cores were collected within the area and analyzed for lead shot and PAHs. Samples were evaluated to determine the vertical distribution of lead shot throughout the sediments. In addition clay target fragments were collected from the sediment and analyzed to determine the PAH composition for comparison to the PAHs present in sediments. The results of this field investigation were presented in the 2004 Remedial Investigation (RI) Report (Battelle et al., 2004).
Remedial Investigation
The primary objectives of the RI report were to evaluate the offshore sediment quality at the Skeet Range (IR Site 29) to identify areas of unacceptable risk based on the human health and ecological risk assessments conducted using the data collected from the 2001 field effort. Adjacent onshore and nearshore areas will be addressed as part of the IR Site Iinvestigation and
through evaluation of Western Bayside as described in the Offshore Sediment Core Study Workplan (Battelle, 2005; Battelle et al., 2005). The RI focused on PAHs and lead shot as the primary chemicals of potential concern (COPCs). Based on the RI it was concluded that: PAH concentrations in sediment were chemically distinct from PAHs found in clay targets. This result indicates that abrasions or leaching of any organic binder from clay targets was not the source of hydrocarbons in sediment, including PAHs.
The estimated net sediment accumulation rate was estimated to be between 0.65 and 1.0 centimeters per year (cm/yr). The horizontal and vertical distribution of shot supports the hypothesis that lead shot has not been transported significant distances and that gradual burial is occurring. Risks to ecological receptors were low based on potential exposures to lead shot and PAHs. The human health conceptual site model (CSM) indicated that there were no complete direct exposure pathways based on current and proposed future land uses. Indirect exposures to PAHs through fishing or clamming may be possible; however, no evidence has been found which suggests that PAHs biomagnify and bioaccumulate in the environment. In addition, the data indicate that the PAHs in sediments are primarily associated with background sources. Based on the ecological and human health assessments, no unacceptable risks are associated with exposures at the Skeet Range. Because the PAH levels are indicative of background levels and the majority of the lead shot is being gradually buried, exposures to sediment do not pose a health threat to current or future human receptors and the environment. Consequently, a no further action determination was recommended for this site. Based on the conclusions of the RI and the recommendation of no further action, there were no sediments proposed for further evaluation in a Feasibility Study (FS), therefore, an FS was not completed.


UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
75 Hawthorne Street
San Francisco, CA 94105
June 13, 2005
Mr. Darren Newton
Department of the Navy
Program Management Office West

1230 Columbus Street, Suite 1100​

San Diego, CA 92101-8571
Dear Darren:
Subject: EPA Comments on the Draft Record of Decision for the Skeet Range at Alameda Point. EPA has reviewed the Draft Record of Decision for the Skeet Range at Alameda Point and we concur with the Navy’s proposal of No Further Action at this site. The results of the Remedial Investigation and Risk Assessments have shown that the lead shot and polycyclic aromatic
hydrocarbons (PAHs) found at this site do not pose an unacceptable risk to either humans or potential ecological receptors such as diving water fowl. The type and concentration levels of the PAHs are similar to surrounding ambient conditions and the lead. shot is found approximately 80 feet offshore. The lead shot is not breaking down and hence, is not readily bio-available. Diving
water fowl are not expected to ingest a sufficient quantity of whole pellets to be adversely affected. The document follows the format of the EPA guidance: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents, and includes all of the necessary elements for a No Further Action Record of Decision. Please call me at (415) 972-3028 if you would like to discuss this Draft Record of Decision.
Sincerely,
Mark Ripperda
Remedial Project Manager
cc. Marcia Lau, DTSC
Judy Huang, RWQCB
Peter Russell, Russell Resources

June 16, 2005

Mr. Thomas L. Macchiarella​

BRAC PMO

Attn. Code 06CA.TM
1220 Pacific Highway
San Diego, CA 92132-5190
Subject: Comments on the Draft Recor6 of Decision for Skeet Range (Installation
Restoration Site 29), Alameda Point, Alameda, California
Dear Mr. Macchiarella:
The San Francisco Bay Regional Water Quality Control Board (Water Board) staff reviewed the Draft Record of Decision for Skeet Range (Installation Restoration Site 29), Alameda Point, Alameda, California, dated April 20, 2005 (Draft ROD) and concurs with the conclusion that no further action is needed at this site. The Installation Restoration (IR) Site 29 is located on the northwestern corner of former NAS Alameda. IR Site 29 extends offshore into the San Francisco Bay with dimensions of about 1,300 feet by 800 feet. The primary site-related contaminants are lead shots and polycyclic aromatic hydrocarbons (PAHs) from the clay targets located approximately 80 feet offshore. The results of the Remedial Investigation and Risk Assessments have shown that the lead shot and PAHs found at this site do not pose an unacceptable risk to either humans or potential ecological receptors such as diving waterfowl. Staff intends to recommend to the Executive Officer of the Water Board to sign the Record of Decision, provided Department of Toxic Substances Control, the lead State Agency for Alameda Point, does not have significant and substantial comments. Please contact me at (510) 622-2363 if you have any questions.
Sincerely,
Judy C. Huang, P.E.​

Associate Water Resource Control Engineer

Groundwater Protection​

June 23, 2005
Mr. Thomas L. Macchiarella
Southwest Division Naval Facilities Engineering Command
Code 06CA.TM
1220 Pacific Highway
San Diego, California 92132-5190
DETERMINATION OF NO FURTHER ACTION, INSTALLATION RESTORATION SITE
29, SKEET RANGE, ALAMEDA POINT, ALAMEDA, CALIFORNIA
Dear Mr. Macchiarella:
The Department of Toxic Substances Control (DTSC) has reviewed the draft Record of Decision (ROD), dated April 20, 2005, for Installation Restoration (IR) Site 29 at Alameda Point. The draft ROD documents the Navy’s conclusion that the site does not pose unacceptable risk to human health or the environment, and that no remedial action is needed at this site. DTSC, based on the review of the Remedial Investigation Report dated July 2004, has determined that the site characterization conducted to date supports the conclusion that no further action (NFA) is appropriate for IR Site 29, This determination is based on the following

understanding that IR Site 29 will remain open water and there will be no future development at this offshore parcel. The shoreline and nearshore areas adjacent to IR Site 29 will be addressed as part of IR Site 1 and the Offshore Sediment Study.​

Please be advised that this NFA determination is based on existing information available to DTSC at this time. In the event that new information indicating environmental concerns is identified, DTSC reserves the right to require additional investigation and possible remediation as the situation warrants. Please feel free to contact Marcia Liao, of my staff, at (510) 540-3767 should you have any questions.

Sincerely,​

Anthony J Landis, P.E.

Chief​

Northern California Operations
Office of Military Facilities

Link: http://www.epa.gov/superfund/sites/rods/fulltext/r0905058.pdf

 

[turtlshell]

There are plenty of examples to counteract your example.

http://www.lead.org.au/fs/shootingranges.pdf ...or

are friends to the north http://dnr.wi.gov/org/land/wildlife/hunt/nontoxshot.pdf

Another report describes the real concern of lead shot on "dry" ground and how it is transported through groundwater.

Prime Hook National Wildlife Refuge is located in southeastern Delaware in coastal low-lands along the margin of Delaware Bay. For 37 years, the Broadkiln Sportsman's Club adjacent to the refuge operated a trap-shooting range, with the clay-target launchers oriented so that the expended lead shot from the range dropped into forested wetland areas on the refuge property. Investigators have estimated that up to 58,000 shotgun pellets per square foot are present in locations on the refuge where the lead shot fell to the ground.
As part of the environmental risk assessment for the site, the U.S. Geological Survey (USGS) investigated the potential for lead contamination in ground water. Results from two sampling rounds in 19 shallow wells indicate that elevated levels of dissolved lead are present in ground water at the site. The lead and associated metals, such as antimony and arsenic (common shotgun pellet alloys), are being transported along shallow ground-water flow-paths toward an open-water slough in the forested wetland adjacent to the downrange target area. Water samples from wells located along the bank of the slough contained dissolved lead concentrations higher than 400 micrograms per liter, and as high as 1 milligram per liter. In contrast, a natural background concentration of lead from ground water in a well up gradient from the site is about 1 micro gram per liter. Two water samples collected several months apart from the slough directly down gradient of the shooting range contained 24 and 212 micrograms per liter of lead, respectively.
The data indicate that lead from a concentrated deposit of shotgun pellets on the refuge has been mobilized through a combination of acidic water conditions and a very sandy, shallow, unconfined aquifer, and is moving along ground-water flow- paths toward the surface-water drainage. Data from this study will be used to help delineate the lead plume, and determine the fate and transport of lead from the source area.





Granted, these conditions are somewhat extreme...and probably wouldn't apply to Iowa, but I have witnessed the dove opener on Weldon Spring in St.Louis, MO....and there are more people down there that are blasting away a lot more than any shooting range I've ever been too. What's the timeframe before the lead shot creates a problem?...because that lead shot will be on/in the ground longer than any of us are alive. Since we'll be dead and gone, does that make it right to just turn a blind-eye?



Requiring non-toxic shot isn't infringing on your right to hunt...you finally get to waste time shooting doves in Iowa if you want...so ENJOY!!!

 

[iowaqdm]

There are plenty of examples to counteract your example.

The data indicate that lead from a concentrated deposit of shotgun pellets on the refuge has been mobilized through a combination of acidic water conditions and a very sandy, shallow, unconfined aquifer, and is moving along ground-water flow- paths toward the surface-water drainage.

Granted, these conditions are somewhat extreme...and probably wouldn't apply to Iowa

I gave an example of an actual EPA study conducted in the backyard of the most liberal city in the entire United States. In a State that is home to the most liberal colleges. Where I'm sure the most liberal biased researchers in the country analized every aspect of this study. Yet after all the scrutiny, "The Navy subsequently received concurrence on the Draft ROD for no further action from U.S. EPA, the San Francisco Regional Water Quality Control Board (RWQCB), the Department of Toxic Substances Control (DTSC)." Neither of your examples were published studies but rather public releases/opinion publications where neither I or anyone else could look at how they came to their findings. Also the only research I have found where lead in contact with soil can become soluble is when acid rain/water is added to the combination to desolve the lead.

If there was really a body of undisputable research on lead shot/ammunition then why doesn't the EPA ban it?

As recent as last year the EPA reviewed the lead shot issue and still came to the same conclusion.

From Wikipedia, the free encyclopedia:
"On August 3, 2010, The Center for Biological Diversity together with The American Bird Conservancy and several other environmental organizations and groups submitted a 100 page petition to the Environmental Protection Agency (EPA) to request a national ban on lead based ammunition and fishing tackle in order to end the poisoning of wildlife. The petition stated that lead is killing millions of wild birds, and is also a health risk to humans. On August 27, three weeks after receiving the petition, the EPA denied the petition seeking the ban on lead ammunition."

We could argue about this issue forever and that is not my intentions. I just want regulations based on sound science and not speculations. I would much rather see the DNR ask hunters to use non-toxic ammunition when hunting. I would tend to follow their requests if they approached issues like this in a different way. I don't like when they make assuptions, then try to take away my choice to make the decision. This issue is similiar to the mineral sites/feeding wildlife arguement. Many people want to be able to make mineral sites or feed the wildlife on their property. The DNR said that they want to help prevent CWD from spreading. Yet the research is not there to prove that taking away that right from private property owners will affect the spread of CWD. I could even argue that it wont change the transmission rates at all. Look at Kansas, they have CWD and yet they allow feeding and mineral sites. The spread of CWD has not been any faster in Kansas than that of other States with bans on mineral sites and feeding for the same reasons. So restricting peoples rights based on what ifs, possibly or may happen doesn't usually fly with me.

 

[turtlshell]

So restricting peoples rights based on what ifs, possibly or may happen doesn't usually fly with me.

:way:got'cha