HomeMy WebLinkAbout2008-0616 Documents submitted at meeting
Remedial Action Recommendation/S taff Report
City of Ashland, Former Ree<rr Pistol Range
Granite Street
Ashland, Oregon
Introduction and Purpose
This summmy report documents site investigation and cleanup activities performed at the former
Reeder Pistol Range site located near Granite Street in Ashland, Oregon. The purpose ofthis report
is to do current and support the Oregon Department of Environmental Quality's (DEQ's)
recommendation for no further a::tion.
The site is a fonner small arms firing range located adjacent to Ashland Creek near Lithia Park in
Ashland, Oregon (Figure 1). The Range lies on a level meadow 5 to 10 feet above the banks of
Ashland Creek, and is located on both City of Ashland property and Forest Service property
(Figure 2). The former range consisted of four asphalt shooting lanes constructed in 1992; a 75-
foot impact berm; and a munitions storage shed. The asphalt lanes and munitions shed were
removed during remediation activities. The site is an open area just outside the boundary of
Lithia Park. Adjoining lands are currently used as part of a nature trail system. Land uses near
Lithia Park are characterized as recreational, residential, comrrercial, and lll1developed open space.
In November 1999, the City of Ashland (Greg Scoles, City Administrator), signed a Letter
Agreement requesting DEQ assistance in resolving cleanup issues at the site, under DEQ's
Yoluntary Cleanup Program (YCP).
Site History and Background
Between 1967 and 1998, the City of Ashland Police Department used the Range, for pistol and
skeet shooting practice. Under a permit issued by the Forest Service, the City was allowed to use
the Forest Service property as part of the Range. A condition ofthe Forest Service permit
required that upon leaving the site, the City would restore the site to a condition acceptable to
the Forest Service. Since 1998, the City decided to terminate use of the Range. The City has
been working with the Forest Service to terminate the permit. To this end, the City has been
working to resolve cleanup issues on both the City and Forest Service Property.
Generally, contaminants of concern at a small arms frringrange include copper and zinc (i.e. brass)
associated with bullet jacketing material, as well as leal Based on a lack of observable brass at the
Range, site investigations focused on lead as the only contaminant of concern.
Staff Report: Former Reeder Pistol Range
November 9, 2000
Page 1
Investigation and Remedial Action Summary
On April 22, 1998, on behalf of the City, CH2M Hill collected 29 soil samples from areas just
north of the range berm and from the range berm.
Samples collected north of the range berm were collected every 25 feet along one of the shooting
lanes and adjacent separation lane, as well as from an area near the back of the Range. Samples
were collected at the ground surface and at I-foot below ground surface (bgs). The samples were
analyzed for total lead concentrations. No detectable lead concentrations were observed.
Detection limits ranged from 6.5 to 11.2 mg/kg.
Samples collected from the range berm were collected at the target elevation in direct line with the
center line of two of the shooting lanes, as well as the center line of one of the adjacent separation
lanes. Samples were collected at the berm surface and at 2-foot intervals horizontally through
the berm. The samples were analyzed for total lead concentrations. The analytical results showed
total lead concentrations ranging up to 9370 mg/kg lead. Two samples containing the highest total
lead concentrations were also analyzed for leachable lead concentrations. The results showed
leachable lead concentrations up to 79.6 mg/L. The highest concentrations of total and leachable
lead were observed at the berm surface, in direct line with the shooting lanes. The results are
summarized below.
Table 1: Berm Samples
Location-Deoth (ft) Total Lead (m-;;;kg) TCLP Lead (mgfL)
RB16-0 62.3 NA
RB16-2 <7.8 NA
RB 16-4 43.5 NA
RB17-0 2610 59.8
RB17-2 <7.3 NA
RB17-4 <8.2 NA
RB 18-0 9370 79.6
RB18-2 <10.2 NA
RB18-4 <9.0 NA
SOCLEAN 2
Appendix I' 200
Soil PRG 400
NA - Not analyzed
I Numerical Soil Cleanup Levels (OAR 340-122-045 and 046)
2 Numerical Soil Cleanup Levels (OAR 340-122-045 and 046), Appendix 1
3 EPA Region 9 Preliminary Remediation Goal (Residential Soil)
Based on these results, remedial actions were evaluated for the range berm soils. In addition, a
munitions shed near the back of the range was also included in the remedial action evaluation.
In February 1999, the munitions storage shed was demolished and removed. Based on evidence
Staff Report: Former Reeder Pistol Range
November 9, 2000
Page2
that rounds had been shot in the direction of the shed, approximately 0.75 cubic yards of material
was removed adjacent to the north and west facing walls and transported offsite. After the
removal, four confirmation soil samples were collected approximately 5 feet from each side of the
footprint of the storage shed. The results showed total lead concentrations up to 80 mg/kg and
leachable lead concentrations up to 0.0047 mglL.
Also in February 1999, based on visual evidence of bullet slugs, approximately 135 tons of
material was removed from the front face of the impact berm and transported offsite. After the
removal, eight confirmation samples were collected at approximately 10- foot intervals, with the
first soil sample collected 8 feet from the east end of the berm. The sample height was again the
target elevation. Bullet slugs were not a part of the material analyzed. The results showed total
lead concentrations up to 3,600 mg/kg, with five out of eight samples exceeding the EP A Region 9
Residential Soil Preliminary Remediation Goal (PRG) for lead. RB-l and RB-4 were retained and
used in the final range berm data set (Table 2).
In April 1999, four narrow trenches were excavated at 15-foot intervals exposing four cross-
sections of the berm. Three soil samples were collected from each trench and analyzed for total
lead concentrations. Bullet slugs were again not a part of the material analyzed. The results
showed total lead concentrations up to 508 mg/kg on the interior of the berm with only one out
oftwelve samples exceeding the EPA Region 9 Soil PRG. All of the trench sample results were
used in the final range berm data set (Table 2).
In August 1999, the City removed additional soils from the berm face to remove the previous
berm face samples from the data set (RB-02, -03, -05, -06, -07, -08), and collect four new
confirmation samples to be added to the data set (RB-9, -10, -11, -12). An additional 74 tons of
material was removed from the front face of the range berm at four different locations. The
confirmatory sampling showed concentrations ranging from 3.4 to 236 mg/kg total lead. Bullet
slugs were not a part of the material analyzed. The results were added to the final range berm data
set (Table 2). To evaluate lead leachability, the sample containing 236 mg/kg total lead was
further analyzed for leachable lead. The results showed a leachable lead concentration of 0.00441
mg/L.
Also in August 1999, the Forest Service elected to conduct their own sampling of the berm. The
Forest Service collected both discrete and composite samples. The discrete results showed total
lead concentrations ranging from 7.09 to 13,300 mg/kg and the composite results showed total
lead concentration ranging from 8.93 to 72.4 mg/kg. Bullet slugs were not a part of the material
analyzed. The discrete sample results were added to the final range berm data set (Table 2).
Staff Report: Former Reeder Pistol Range
November 9, 2000
Page3
Table 2: Range Berm Data Set
Location-Depth (ft) Total Lead (mg/kg) TCLP Lead (mgIL)
RB-OI 110 NA
RB-04 2.9 NA
Tl-Center 50.5 NA
Tl-Bottom 2.75 NA
TI-Back 20.2 NA
T2-Center 2.53 NA
T2-Bottom 5.29 NA
T2-Back 14.4 NA
T3-Center 4.2 NA
T3-Bottom 253 NA
T3-Back 2.88 NA
T 4-Center 508 NA
T4-Bottom 3.14 NA
T4-Back 9.5 NA
RB-9 3.4 NA
RB-1O 236 0.0441
RB-II 8.8 NA
RB-12 23.6 NA
FS RB200 - 0.3 13,300 NA
FS RB700 - 1.5 40.4 NA
FS RB200 - 2.5 280 NA
FS RB200 - 3.2 357 NA
FS RB400 - 15 7.1 NA
FS RB600 - 0.2 612 NA
SOCLEAN' 2
Appendix l' 200
Soil PRG' 400
NA - Not analyzed
1 Numerical Soil Cleanup Levels (OAR 340-122-045 and 046)
2 Numerical Soil Cleanup Levels (OAR 340-122-045 and 046), Appendix I
3 EPA Region 9 Preliminary Remediation Goal (Residential Soil)
Based on a statistical evaluation of the range berm data set, a 90th percentile upper confidence
limit (UCL) of 55.6 mg/kg lead was calculated for berm soils. The EP A Region 9 Soil PRG is 400
mg/kg lead. The 90th percentile UCL was calculated as follows:
.
The mean and standard deviation of the data set were calculated.
.
The coefficient of variation (mean divided by the standard deviation) was then calculated.
.
Based on a coefficient of variation greater than one (data set not normally distributed), the
data set was then logrithmically transformed.
Staff Report: Former Reeder Pistol Range
November 9, 2000
Page4
.
The mean and standard deviation of the transformed data set were then calculated
.
The 90th percentile UCL was then calculated using the following equation, where "count" =
the number of samples in the data set.
90th UCL = mean + t-value(ol, count-I) * [sdev/(count)O.5]
On June 12,2000, DEQ staff visited the site to evaluate the occurrence and distribution of bullet
slugs. A representative from the City of Ashland and the Forest Service were in attendance. To
evaluate the occurrence and distribution of bullet slugs across the berm, the City dug eight small
test pits. DEQ staff sifted through each pit evaluating the presence of bullet slugs. Equal time
(approximately 25 minutes) was spent on each pit and bullet slug counts ranged from two to
eight slugs per pit. After the Forest Service representative found a high concentration of bullet
slugs near the back edge of the berm, DEQ staff sifted through surface soils near the back edge. A
higher occurrence of bullet slugs was observed in this area. Based on this observation, the City
proposed to remove additional soils along the back edge of the berm.
On September 8, 2000, the City removed approximately 40 cubic yards of material along the
back edge of the berm. The removal area was backfilled with approximately 20-30 cubic yards of
clean granite fill, followed by 20-30 cubic yards of topsoil.
Conclusions and Recommendations
The Range was impacted from over 30 years ofpistol and skeet shooting activities. Initial sampling
of the imp oct benn showed elevated total and leachable lead concentrations in berm soils, as well as
the presence of bullet slugs. Between February 1999 and Sep tember 2000, several relIDval actions
tar~ted berm material exhibiting either elevated total lead concentrations based on analy sis or a high
occurrence of bullet slugs. Post-relIDval confrrmatory samp ling demonstrated that acceptable risk
levels had been ochieved for air (inhalation), surface water, and groundwater pathway s. In addition,
the p resent use of the prop erty, which is primarily recreational hiking would not create an
unacceptable risk based on the direct contact (soil ingestion) pathway. However, the DEQ staff
toxicologist determined that without institutional controls, the site represented an unacceptable risk
based on unforeseen, future uses which might involve regular, long-term exposure to site soils by
children. This determination was based on the potential re-surfocing oflatent bullet slugs at the site
and the behavior of children to swallow small objects such as bullet fragments. To ensure that no
future uses are rm.de of the property which might result in an unacceptable risk as defmed in OAR
340-122-115, an institutional control will be recorded prohibiting residential use and any use ofthe
property that would involve regIlar, long-term exposure to site soils by children. The institutional
control will be set forth in a DEQ-approved equitable setvitude and easement recorded in Jockson
County property records, and in such form that it runs with the land and is enforceable by DEQ.
Staff Report: Former Reeder Pistol Range
November 9, 2000
Page 5
References
The following references were reviewed in the preparation of this summary:
Sampling and Analysis Plan. Reeder Pistol Range. Ashland. Oregon, CH2M Hill, February 1998.
Sampling and Analysis Results. Reeder Pistol Range. Ashland. Oregon, CH2M Hill, May 1998.
Remedial Action Results. Reeder Pistol Range. Ashland. Oregon, CH2M Hill, October 1999.
Supplemental Information for Additional Soil Removal from the Reeder Pistol Range in Ashland.
Oregon, CH2M Hill, October 5, 2000.
Staff Report: Former Reeder Pistol Range
November 9,2000
Page6
Leon Pyle, Ph.D.
460 Sunshine Circle
Ashland, OR 97520
541 488-4699
February 26,2005
Mr. Don Robertson, Director
Ashland Parks and Recreation Dept
340 South Pioneer St.
Ashland, OR 97520
Re: Ashland Gun Club Site
Dear Don,
As you know from our recent telephone conversations, a number of Emigrant
Creek Road home and/or landowners, including myself, are concerned about current
operations and long-term environmental and safety issues related to the use of City
property by the Ashland Gun Club. Those of us who will be meeting with you on March
2 appreciate your making time to see us and look forward to an open discussion. In order
to make the meeting as useful as possible, I would like to outline a few of our concerns
for your consideration.
First, I would like to say that no one would dispute the importance of having a
range for shooting practice for sportsmen and the Ashland Police Department. The
question is simply one of location. As you know, the area surrounding the firing range
has become much more residential since the Club began its operation many years ago.
Additionally, the public has become increasingly aware of its responsibility for
preserving our present and future resources.
As pertains to the current operation of the firing range, we would like to discuss
the following issues that have become problematic:
hours of operation
use of "assault-type" and other high-caliber weapons
use of the site by military or para-military groups
the need to monitor the use of the range to prohibit unauthorized use.
As to the long-term use of the site by the Gun Club (it is our understanding that
the Club has recently submitted a request to the City of Ashland to extend its current
lease for an additional 20 years), there are many important issues that need to be
reviewed. These long-term environmental and safety issues can be categorized into
four general areas:
1. Water Supply Contamination. The probability of surface runoff
contamination of Emigrant Creek and the contamination of the underground water supply
via the leeching of lead and other metals associated with firearm use must be taken very
Pg2 of 4
seriously. It has been shown that lead from slugs is leachable over time, and therefore a
potential pollutant of underground water supplies.
In addition to aquifer contamination, we are concerned about pollution of Lithia
Springs and Emigrant Creek. While we know that the City regularly tests the Lithia
Springs water, the potential for future contamination is nevertheless real. Equally
important, other metals and toxic materials associated with the use of gun powder and
explosives are deposited on the ground in the normal process of firing and these wastes
are subject to being washed into the creek via sUlface water runoff. It does not appear that
any agency has undertaken studies necessary to determine the extent of present creek
water contamination or the potential for future contamination.
As you are aware, the issue of lead (bullets) left in the soil was addressed by the
Oregon Department of Environmental Quality in its investigation of the Reeder Pistol
Range. For your convenience, we include below the Conclusions and Recommendations
of that report:
Conclusions and Recommendations
The Range was impacted from over 30 years of pistol and skeet shooting
activities. Initial sampling of the impact berm showed elevated total and
leachable lead concentrations in berm soils, as well as the presence of
bullet slugs. Between February 1999 and September 2000, several
removal actions targeted berm material exhibiting either elevated total
lead concentrations based on analysis or a high occurrence of bullet slugs.
Post-removal confirmatory sampling demonstrated that acceptable risk
levels had been achieved for air (inhalation), surface water, and
groundwater pathways. In addition, the present use of the property, which
is primarily recreational hiking, would not create an unacceptable risk
based on the direct contact (soil ingestion) pathway. However, the DEQ
staff toxicologist determined that without institutional controls, the site
represented an unacceptable risk based on unforeseen, future uses, which
might involve regular, long-term exposure to site soils, by children. This
determination was based on the potential re-surfacing of latent bullet slugs
at the site and the behavior of children to swallow small objects such as
bullet fragments. To ensure that no future uses are made of the property
which might result in an unacceptable risk as defined in OAR 340-122-
115, an institutional control will be recorded prohibiting residential use
and any use of the property that would involve regular, long-term
exposure to site soils by children. The institutional control will be set forth
in a DEQ-approved equitable servitude and easement recorded in Jackson
County property records, and in such form that it runs with the land and is
enforceable by DEQ.
Pg 3 of 4
As you know, high concentrations of lead and leachable lead were found at the
Reeder Range site, resulting in the removal of over 285 tons of soil from the small site in
this cleanup effort. The amount of soil that will have to be removed from the Ashland
Gun Club site when, as will undoubtedly happen at some time in the future, it must be
redeemed for a more appropriate use will be astronomical. The future problem and
liability of the City increases with each use of the range.
The City is to be recommended for taking responsible action in the cleanup of the
Reeder site and now must review the use of the Ashland Gun Club site with the same
commitment to the environment and to the future use of City property.
2. Site of Historical Value. As you are also aware, the water from Lithia Springs
was once thought to have healing value and is still the source of mineral water being
provided in Lithia Park today. It was once planned that a spa would be erected on the site
and visitors would be encouraged to "partake" of the water's healing effects. The
continued activities of the gun club make it more and more difficult and expensive to
ever reclaim the site and restore its historical significance.
3. Noise Pollution. Not only does the crack of the sportsmen's firearms ricochet
through the residential valley, but assault type weapons are fired (sounding like machine
guns) during both the day and night hours by the Ashland Police Department and even
military organizations, creating a completely unacceptable level of noise pollution for
families living in the surrounding area.
As you know, the Department of Environmental Quality Noise Control
Regulation (OAR 340-035-0005) sets out standards for maximum noise levels that
recreational and other noise sources are allowed to create, as well as the requirement that
the polluter must monitor and record statistical noise levels. Noise regulation is becoming
more and more of an important environmental issue for Oregon and the entire country, a
shift in emphasis that is sure to increase in the future as individuals and families seek
recuperative hours from high stress jobs.
4. Safety. Residential homes now completely surround the gun club. The issue of
the safety of the surrounding homeowners and their children must be taken very
seriously. What the City earns in lease fees would pale in comparison to what it would be
forced to payout in legal fees and compensation as a result of just one neighbor being
injured or killed by an errant bullet.
Some might argue that the Gun Club's firing range was present before the
building of the most recent homes and that the builders should have taken noise and
safety into account before buying, but such arguments do not recognize the ever-
changing use of land, nor do they lessen the city's potential liability .
We are very concerned about the problems and potential problems outlined above
and are confident that you too will seriously reflect upon the issues presented. We know
that the City takes its land stewardship role seriously. We ask that you give the same
consideration to the proper use of this "out-of-town" property as you would to an "in-
town" park.
Pg 4 of 4
Thank you for taking time to read this letter and considering the issues raised. We
look forward to meeting with you on Wednesday.
Sincerely,
Leon Pyle
LEON PYLE, PhD
460 Sunshine Circle
Ashland, OR 97520
lconpy Ie ({lchartcr .llct
January 22,2008
Martha Bennett
Ashland City Administrator
20 East Main Street
Ashland, OR 07520
Dear Ms Bennett:
I am writing in response to a recent Tidings article pertaining to the property on Emigrant
Creek Road that the City currently leases to the Ashland Gun Club. It is my
understanding that the current lease expires sometime in 2009.
There are many topics that need to be adequately addressed before the City extends the
current lease or enters into any other agreement with the Gun Club. I have outlined some
of these topics in my letters of February 26 and August 2, 2005 to Don Robertson and to
Mayor Morrison, respectively, and copies of those letters are attached for your
convemence.
In addition to the technical and environmental questions raised in the attached letters, the
following issues and questions need to be addressed:
1. Is it appropriate for the City to make its valuable asset (the land) available to a
special interest group (the Gun Club)? Would, for example, the city provide
similar property to a group interested in equine activities, or tennis, or some other
specialized activity, and make the property available to the group at what amounts
to no cost? Is this reasonable to the citizens of Ashland who have no interest in
that particular activity? Or, if city owned land is to be used as a park facility,
should the land use be multipurpose so that it can be enjoyed by many people
with diverse interests, as, for example, are Lithia and Garfield Parks, which are
available for many purposes and serve the city's citizens especially well.
2. Who are the members of the so-called Ashland Gun Club? Are they tax-paying
Ashland Citizens? Anecdotal information suggests that most of the members of
the Club do not live in Ashland. If, upon investigation, that information were
found to be true, it is doubtful that the tax-paying citizens of Ashland would be
interested in subsidizing the club for the benefit of individuals who do not live in
or contribute tax revenues to the City. If the Gun Club were a serious revenue-
generating asset for the City, non-City residents utilizing the facility would be a
p. 2 of 2
different matter, but because it does not create income for the City, the matter
needs to be seriously addressed.
3. The liability that the City is assuming in the event of an accident at the Gun Club
is adequately addressed in the attached letters. While it is true that the Gun Club
members are for the most part very responsible gun users and gun-use educators,
that would not mitigate the City's liability if an accident were to happen.
4. If the City were to extend the current lease or enter into a new long term lease
with the Gun Club, the potential of valuable city property would be
inappropriately restricted for years to come, a fact that needs to be seriously
considered and my guess would not be a welcomed decision by a majority of
Ashland's citizens.
5. Another question that needs to be asked is, "Can the City annex the property by
extending its property line from the Airport down Emigrant Creek Road to the
subject site?" If that were an option, how then would the property be utilized?
What would the highest and best use of the property be? Could the City then lease
or sell its asset for a substantial gain? Yery expensive homes are being built in the
area, making the property an even more valuable asset. What does that potentially
mean for the City?
6. Lastly, as mentioned in paragraph 1 above, should the City create a real and
multiuse park? How could that rural setting with beautiful Emigrant Creek
running through it be best used and enjoyed by all citizens of Ashland?
Please know that neither I nor other Emigrant Creek property owners whom I know are
"anti-gun" activists. Additionally, the members of the Gun Club with whom I have talked
are responsible individuals who have every right to enjoy their sport and are doing a good
job of educating others in the proper use of guns. My concerns and questions are not
intended to raise an "us against them" mentality or activity. The questions are the same
that any responsible business person would have if s/he were considering the use of her
or his business' assets; i.e., in addition to the safety and environmental questions asked in
my earlier letters, what is the best use of the asset, and what is appropriate
and fair for the majority of the stockholders (or in the case of the City, "stakeholders")?
I and many other Ashland property owners want to insure that all questions are asked
before a decision is made as how to proceed in considering an extension of the Gun
Club's current lease.
Thank you for considering the points I have raised. I will certainly make myself available
at your disposal to further discuss the above mentioned concerns if you would find that
useful.
Sincerely,
Leon Pyle
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