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Australian Department of Defence Pollution Prevention Environmental Management Guideline Operation of Equipment/Infrastructure on Weapons Ranges. June 2011

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Australian Department of Defence Pollution Prevention Environmental Management Guideline Operation of Equipment/Infrastructure on Weapons Ranges ISSUED 2011 Prepared by Environmental Resources Management Australia Pty Ltd For further information contact: Assistant Director Pollution Prevention Directorate of Environmental Impact Management Estate Policy Environment Branch Department of Defence Front Photograph: Gunner Mark Le Messurier from Puckapunyal in preparation to fire at the Puckapunyal Training Area. http://www.defence.gov.au/media/download/2007/aug/20070823/index.htm

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Table of Contents

LIST OF ACRONYMS III

EXECUTIVE SUMMARY IV

1. PURPOSE OF THE POLLUTION PREVENTION ENVIRONMENTAL MANAGEMENT GUIDELINES 1

2. WHEN TO USE THIS GUIDELINE 2

3. STAKEHOLDERS RESPONSIBILITIES 2

4. POLLUTANTS ASSOCIATED WITH WEAPONS RANGES 3

5. SEGMENTS OF THE ENVIRONMENT POTENTIALLY AT RISK 4

6. PROCUREMENT CONSIDERATIONS 5

7. GUIDELINE REQUIREMENTS AND PERFORMANCE STANDARDS 6

7.1 MANAGEMENT AND ADMINISTRATIVE CONTROLS 8 Risk Assessment 8 Licence Requirements 8 Environmental Management Plan (EMP) 9 Preventative Maintenance Schedule 9 Dangerous Goods Manifest & Material Safety Data Sheets (MSDSs) 10 As-constructed Plans 10 Staff Training 10 Record Keeping 10

7.2 DRAINAGE SYSTEMS 11 Stormwater Management and Inspections 11 Maintenance Activities 12 Environmental Testing 12 Record Keeping 13

7.3 TRANSPORT OF MATERIALS 14 Dangerous Goods Transport 14

7.4 STORAGE OF MATERIALS 15 Storage Location 15 Storage Requirements 15 Storage Requirements (cont) 16 Maintenance and Inspection 16

7.5 HANDLING AND USE OF EXPLOSIVE ORDINANCE 17 Weapons Range Set Up 17 Inspections and Housekeeping 17

7.6 WASTE MANAGEMENT 18 Deleading Processes 18 Waste Disposal 18 Site Decommission 19

7.7 EMERGENCY RESPONSE AND CLEAN-UP 20 Emergency Response Plan 20

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Spill Management and Prevention 20 Incident Investigation and Notification 20

8. OTHER CONSIDERATIONS 21

9. CASE STUDY – INSPECTION PROTOCOL AND CHECKLISTS FROM DEFENCE EXPLOSIVES SAFETY MANUAL. 22

10. REFERENCES AND FURTHER READING 23

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List of Acronyms

CMS Comprehensive Maintenance Services

Defence Department of Defence

DMO Defence Materiel Organisation

DPPS Defence Pollution Prevention Strategy

DSG Defence Support Group

EMG Environmental Management Guideline

EMP Environmental Management Plan

EMS Environmental Management System

EO Explosive Ordnance

EPBC Environment Protection, Biodiversity and Conservation

EPA Environment Protection Authority

GSS Garrison Support Services

IAD Infrastructure Asset Development

JLC Joint Logistics Control

MHF Major Hazard Facility

MSDS Material Safety Data Sheet

NEDG Non-explosive Dangerous Goods

OHS Occupational, Health and Safety

PS Performance Standard

RAAF Royal Australian Air Force

REO Regional Environmental Officer

US United States of America

UST Underground Storage Tank

UXO Unexploded Ordinance

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Executive Summary

The purpose of this pollution prevention environmental management Guideline Number 10 for Operation of Equipment/Infrastructure on Weapons Ranges is to assist the Department of Defence (Defence) with:

• Preventing and reducing the likelihood of pollution events;

• Promoting sustainable environmental management; and

• Advising internally on recommended standards and requirements for the operation and maintenance of equipment/infrastructure at Defence weapons ranges.

This Guideline takes a performance-based approach, which is intended to balance Defence operational and training requirements with its legislative and environmental polices and obligations, which include:

• Commonwealth Environment Protection legislation such as the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act);

• Defence Pollution Prevention Strategy (DPPS), June 2007;

• Applicable Defence guidelines, Commonwealth, State and Territory legislation regulations and guidelines and Australian Standards and Codes in relation to the operation and maintenance of equipment/infrastructure at weapons ranges and environmental protection; and

• Applicable international best management practice.

Performance standards have been identified to enable demonstration of compliance with applicable legislation, Australian standards, and, where available, international best management practice, for Defence activities related to operation and maintenance of equipment/infrastructure at weapons ranges. Defence is obliged to comply with Defence and other Commonwealth Government environmental policies, initiatives and legislation/regulations. Defence also endeavours to meet the requirements of State and Territory legislation, regulations and guidelines and to performing tasks to best practice standards. Contractors, lessees or licensees operating or occupying Defence facilities, or undertaking activities on behalf of Defence, are obliged to also comply with State and Territory legislation, regulations and guidelines.

The performance standards discussed in this Guideline include the following key areas where compliance is required:

1. Supporting documentation requirements and required inspections and management reviews

2. Management, monitoring and maintenance of water drainage systems

3. Transport of materials

4. Storage of materials

5. Handling and use of explosive ordnance

6. Waste management

7. Emergency response and clean-up procedures

The Guideline deals predominantly with outdoor rifle ranges, although components of the pollution prevention strategy will be transferrable to areas for grenade training and air or water to land training.

This Guideline does not consider pollutants which may be generated from testing of chemical, biological, radiological or nuclear weapons.

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1. Purpose of the Pollution Prevention Environmental Management Guidelines

The Environment Protection and Biodiversity Conservation Act 1999 (the EPBC Act) requires a proactive approach to waste minimisation by Commonwealth agencies and requires annual reporting of Defence’s alignment with the principles of ecologically sustainable development. The Defence Waste Minimisation Policy (2007) aligns with the requirements of the EPBC Act and requires Defence to:

“a. minimise the amount of material from Defence being diverted to landfill;

b. reduce consumption of natural resources by minimising the amount of packaging material purchased and continuously increasing demand for recycled content in Defence procurement;

c. enhance the Commonwealth’s reputation for environmental management; and

d. reduce waste management and disposal costs through waste streaming”.

Through these mandated requirements, Defence is required to take responsibility for the prevention of potentially polluting activities, thereby reducing wastes and potential impacts to the environment. Commonwealth, State and Territory legislation/regulations and Australian Standards contain guidance and obligations that also require those responsible for an activity with the potential to cause pollution, to ensure that the appropriate safeguards are in place to prevent the pollution.

This pollution prevention environmental management Guideline Number 10 for Operation of Equipment/Infrastructure on Weapons Ranges is part of a set of Guidelines implemented in support of the Defence Pollution Prevention Strategy, 2007 (DPPS). The DPPS was initiated in order to promote policies and legislative obligations, consistent with the Defence Environmental Management System (EMS), relating specifically to pollution prevention within the range of activities that Defence performs. Broadly, regular Defence activities can range from the design, installation and establishment of equipment/infrastructure (e.g. construction and development), through to activities including operation of existing equipment/infrastructure and maintenance and repair activities. Defence also undertakes equipment/infrastructure disposal activities such as decommissioning and demolition.

This Guideline aims to set standards and procedures to ensure that Defence activities involving operation and maintenance of equipment/infrastructure at Defence weapons ranges are environmentally sound and comply with Defence policy and legislative commitments. The Guideline will assist Defence with:

• Preventing and reducing the likelihood of pollution events;

• Promoting sustainable environmental management; and

• Advising internally on recommended standards and requirements for the operation and maintenance of equipment/infrastructure at Defence weapons ranges.

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2. When to use this Guideline

The use of specialised and potentially hazardous materials is sometimes unavoidable in a number of Defence activities and operations in performing its primary mission of defending Australia and its national interests. This environmental management Guideline for pollution prevention refers to activities associated with the operation and maintenance of equipment/infrastructure on existing weapons range on an existing Defence facility. Weapons ranges include indoor and outdoor firing ranges used for training purposes.

Information related to potential pollution associated with the design of the weapons firing ranges and lanes has been addressed in the environmental management Guideline Number 4 for Infrastructure Development: Design and Installation of Weapons Ranges.

This Guideline deals predominantly with outdoor rifle ranges, although components of the pollution prevention strategy will be transferrable to areas for grenade training and air or water to land training.

A Stop Butt Construction and Maintenance Thin Guide for Environmental Officers (2005) was produced which details the background with respect to environmental impact of firing ranges. This Guideline provides an update of the information within the Thin Guide with a focus on pollution prevention strategies.

3. Stakeholders Responsibilities

This Guideline has been prepared for use by all Defence stakeholders likely to have responsibilities for the operation and maintenance of equipment/infrastructure at Defence weapons ranges. Stakeholders include:

• Infrastructure Division managing weapons ranges, such as Defence Materiel Organisation (DMO), Joint Logistics Control (JLC), People Strategies and Policy Group, Occupational Health and Safety (OHS) Branch, Royal Australian Air Force (RAAF), Royal Australian Navy and the Australian Army;

• Contractors managing the operation and maintenance of equipment/infrastructure at weapons ranges on behalf of Defence, such as Garrison Support Services (GSS), Comprehensive Maintenance Services (CMS) and the Infrastructure Asset Development Branch (IAD);

• Regional environmental staff supporting environmentally sound practices; and

• Base support staff, contractors, site users and Defence Support Group (DSG) estate managers all have a level of responsibility for the operation and maintenance of environmentally sound weapons ranges.

Designated owners and operators of weapons ranges are responsible for implementing a management system, maintaining documentation of all installation and repair activities, and ensuring that all staff are appropriately trained in the operation of the facility. A commonsense approach should be taken to determine the appropriate extent to which the guidance should be applied. Advice should be sought from regional environmental staff in the first instance.

The Commonwealth, State and Territory legislation/regulations, Australian Standards and various Codes require those responsible for an activity with the potential to indirectly cause contamination, to ensure that the appropriate safeguards are in place to prevent the contamination.

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4. Pollutants Associated with Weapons Ranges

The pollutants of concern related to the operation and maintenance of weapon ranges, result from the impact and resulting penetration, fragmenting, agglomerating, smearing or ricocheting of the fired ammunition material.

A typical outdoor firing range may comprise of a series of targets in front of an impact berm. The targets may be made of paper, wood or metal and the impact berm may be equipped with bullet traps. Generally there is a distance between the firing line to the target (up to 500 m) creating a potentially large area for ground pollution by the ammunition.

The pollutants are predominantly the heavy metal lead and to a smaller extent other heavy metals including antimony, arsenic, chromium, mercury, copper, aluminium and zinc. There are also further chemical components to ammunition including explosives (e.g. 2,4,6-trinitrotoluene, nitroglycerine), components from the shell casings (e.g. potassium perchlorate, diazodinitrophenol (DDNP), lead salts including lead stearates and lead azides), components from propellants (e.g. dinitrotoluene, diphenylamine) and components of pyrotechnics like hexachloroethane and barium/strontium salts. The entire unexploded ordinances (UXOs) also represent a potentially dangerous solid waste material.

Additional pollutants may be generated during weapon cleaning, maintenance and workshop activities, including oils and organic solvents such as degreasers.

This Guideline does not consider pollutants which may be generated from testing of chemical, biological, radiological or nuclear weapons.

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5. Segments of the Environment Potentially at Risk

The key risk resulting from poor operation and maintencance practices for equipment/infrastructure at weapons range is the potential impacts to soil and groundwater surrounding land by the ammunition. This ammunition frequently comprises lead from lead bullets; however the other chemical components of other types of ammunition described in Section 4 also represent a pollutant to soil and groundwater.

The presence of high concentrations of pollutants in soil can lead to classification of the soil as a solid waste material, which incurs high costs for disposal. These pollutants in soil can further degrade, and may represent a pollutant to air quality should these soil materials be converted dust.

Under certain conditions the ammunition pollutants from the soil can leach into groundwater or be transported via stormwater to surface water, causing immediate impact to groundwater and surface water quality. Such impacts are often complex, expensive to rectify with certainty and at times result in irreversible damage to the environment, and impairment to human health.

Further impacts to air quality, soil, groundwater and surface water quality may result from the use of chemicals as part of maintenance activities, e.g. oils and organic solvents such as degreasers. The fluid nature of these chemicals means that any leaks/spills are highly mobile and may cause pollution of the atmosphere, soil, creeks, groundwater and the ocean. Volatile components may be present in the materials used for maintenance) which may generate vapours during handling that has the potential to impact air quality.

These impacts may also represent a breach of Commonwealth, State and Local regulatory requirements and/or environmental licences, which may in turn give rise to penalties or fines from environmental authorities and present potential reputational issues.

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6. Procurement Considerations

The design and installation of new weapons ranges is the best opportunity to build pollution prevention systems into infrastructure, as prevention technologies are integral to the location and design of the range.

The design and procurement of equipment for a weapons range should be undertaken by qualified personnel, including all works associated with stormwater drainage. All bullet catchers and equipment must be designed or used according to the manufacturers’ instructions and be subject to quality assurance. All equipment for storage of non-explosive dangerous goods should be procured in accordance with the relevant Australian Standards for the material to be stored within facility.

During building activities or while undertaking maintenance of the bullet catchers, ground contouring may occur which may result in the introduction of new soil material to the site. All soil introduced to the site should be assessed prior to use and have a certificate stating that it is acceptable for use as clean fill material on a site (as per the appropriate clean fill guidelines for the State and Territory the material is sourced from and being used within).

The work performed by contractors for Defence is an extension of Defence’s activities. Therefore, due diligence must be taken to assure that the work performed by contractors are in line with Defence’s policies and guidelines and State specific regulations.

A designated responsible person from Defence must ensure that contractors have proper licenses for undertaking the activities.

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7. Guideline Requirements and Performance Standards

The performance standards included in this Guideline aim to assist Defence with reducing key pollution risks (pollution prevention) and support compliance with applicable legislation and Australian Standards in relation to pollution prevention.

It should be noted that Defence is obliged to comply with Defence and other Commonwealth Government environmental policies, initiatives and legislation/regulations. Defence also endeavours to meet the requirements of State and Territory legislation, regulations and guidelines and to performing tasks to best practice standards.

Contractors, lessees or licensees operating or occupying Defence facilities, or undertaking activities on behalf of Defence, are also obliged to comply with State and Territory legislation, regulations and guidelines.

Table 7.1 details the pollution prevention guideline requirements associated with the operation and maintenance of equipment and infrastructure at existing Defence weapons ranges. Table 7.1 is broken up into performance standards which make up the pollution prevention environmental management Guideline. Under each performance standard is a summary of the requirements/actions necessary to achieve the performance standard.

External references to each of these requirements and actions are detailed in the reference column of the table. The references have been provided to allow for further detail to be reviewed on the requirements/actions specified within the table, should this be needed. Further details of the reference documentation referred within the table are located in Section 10 of this document. This Guideline covers only key requirements related to pollution prevention and does not address all requirements detailed within the external reference documents in Section 10. Please review the external reference documents for comprehensive details on the Commonwealth, State and Territory legislation and regulations and the best practice requirements.

For application of the requirements and actions outlined for each performance standard, the specific operational and maintenance requirements of the weapons range needs to be considered. It may be that only some of the requirements and actions are applicable to the weapons range being considered. The onus is on the stakeholder(s) to ensure appropriate review of each requirement/action, and if necessary, the source reference documentation, to ensure specific requirements are undertaken to address the performance standard. The onus is also on the stakeholder(s) to ensure that the full level of application of the requirement is undertaken by the review of the source reference documentation.

For example, the environmental requirements (e.g. level of protection from exposure) for storage of explosive ordinance (EO) outlined in Performance Standard 4, may vary between weapons ranges depending on the weapons stored. The best management practices discussed in Performance Standard 4 should be applied based on review of the referenced documentation. It may be that some requirements do not apply; but it is up to the stakeholder to document how the requirement/action does not apply for their weapons range operation and show how weapons will be managed to ensure that they are appropriately stored to prevent exposure.

It should also be noted that the Australian Standard 2187.1-1998 Explosives – Storage, Transport and Use Part 1: Storage does not apply to explosives storage for Defence purposes where the storage complies with the Defence Explosives Ordnance Publication 103 (DEOP-103) – Defence Explosive Safety Manual. Information from the Australian

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Standard has been included within this guideline to provide further information and recommendations with regard to best practice with regard to pollution prevention; however Defence is only obliged to comply with the Defence Explosive Safety Manual.

The performance standards included in Table 7.1 are:

1. Management and Administrative Controls: Management of weapons range complies with supporting documentation requirements and required inspections and management reviews deemed necessary within applicable best practice guidance and Australian Standards.

2. Drainage Systems: The drainage system at the weapons range complies with management and maintenance requirements to prevent mobilisation of the pollutant (e.g. lead) according to best management practices.

3. Transport of Materials: Transport of explosive ordnances and dangerous goods complies with requirements outlined within applicable legislation and Australian Standards.

4. Storage of Materials: Operation of weapons and explosives storage at the weapons range complies with requirements outlined within applicable legislation and Australian Standards.

5. Handling and use of Explosive Ordinance: The handling and use of Explosive Ordinances (EOs) complies with best practice requirements.

6. Waste Management: Operation and procedures for waste management at the weapons range complies with best management practices.

7. Emergency Response and Clean-Up: Emergency response plans for the weapons range complies with requirements outlined within applicable legislation and Australian standards.

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Table 7.1: Pollution Prevention Guideline Requirements and Performance Standards.

Requirements for meeting the performance standard.

Further details Reference

7.1 Management and Administrative Controls

Performance Standard 1: Management of weapons range complies with supporting documentation requirements and required inspections and management reviews deemed necessary within applicable best practice guidance and Australian Standards.

Risk Assessment

a) Preparation of an environmental risk assessment or site sensitivity assessment of the location of the weapons range which considers the presence of sensitive receptors (Defence requirement).

A risk assessment should be prepared that identifies potential sources of pollution (hazards), environmental receptors including exposure to sensitive ecosystems and pathways between the source and receptors. Data should be collected prior to undertaking the risk assessment regarding the selected locations groundwater, soil conditions, rainfall, surface water and stormwater drainage.

The environmental risk assessment should be completed in accordance with AS/NZS ISO 31000:2009 (Standards Australia, 2009) and with the Defence DSG Risk Management Framework (available from Defence Infrastructure Management).

The location of the explosive ordnance (EO) storage facility and weapons range should consider the distance from sensitive receptors (including buildings, roads, dangerous goods storage, underground tanks or pipelines etc). Defence (2003) specifies the minimum distances between EO storage and other facilities. These distances should be reassessed with any surrounding infrastructure changes.

EO storage facilities should not be sited within 50 m of the base boundary. Potential firing of weapons over water bodies should be avoided wherever possible.

Defence References

Defence (2005)

Defence (2003)

National References

AS/NZS ISO 31000 (2009)

International References

US Army (2007)

US EPA (2005)

Licence Requirements

b) Copies of all current licenses for the bulk storage of explosives are to be held onsite (Defence requirement).

c) Ensure that any licence specific requirements are transposed into the EMP (best practice).

For Defence sites, licence requirements Dangerous Goods are governed by Comcare.

Should the storage of Dangerous Goods be in quantities large enough to meet the requirements of a major hazard facility (MHF) further licence requirements must be adhered to under Comcare’s regulatory requirements governing Commonwealth land (see Commonwealth Occupational Health and Safety (Safety Standards) Regulations 1994). The Dangerous Goods Safety (Major Hazard Facilities) Regulations 2007 introduce the term "critical quantity" in respect of Schedule 1 substances to mark the level above which the operator of a facility must notify the Chief Officer as the first step in the regulatory process (notification of a MHF). The critical quantity corresponds to 10% of the threshold quantity of schedule 1 substances.

Defence References

Defence (2003)

National References

AS 4681 (2000)

State References

Various State Dangerous Goods legislation

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7.1 Management and Administrative Controls Environmental Management Plan (EMP)

d) Management of the weapons range under a quality management system (Defence requirement).

e) Evidence of regular auditing of facilities (Defence requirement).

f) Certification of the facilities prior to commissioning and re-certification as required (Defence requirement).

All aspects of management of the weapons range including weapons storage, handling and use should be completed under a quality management system, including regular auditing and certification of the area or EO.

Certification of the EO facility will assess all aspects of operations including safety, maintenance, quality management and work practice.

Audits of the weapons facility should be undertaken at a minimum annually and should include internal, external, monitoring and certification audits for safety and environmental factors.

Certification of the facility will assess all aspects of operations including safety, maintenance, quality management and work practice.

Defence References

Defence (2003)

g) Prepare an Environmental Management Plan (EMP) for the EO storage and firing range (Defence requirement).

h) Undertake regular inspections and keep records of the completed inspection checklists (Defence requirement).

i) Undertake regular management review of this guideline and the EMP and keep documented records of this process (best practice).

Prepare the EMP based on the outcomes of the Prepare the EMP based on the outcomes of the environmental risk assessment, using the risk assessment hierarchy, focusing on hazard prevention measures and where necessary, engineering and administrative controls to ensure management of the risk. The EMP should address all aspects of on-going operation, including the schedule of use, required maintenance and inspection schedule, any potential soil or groundwater monitoring program, house-keeping, emergency response and requirements for regular management review of the implementation of this Guideline and EMP.

Regular inspections of the EO storage facility and non-explosive dangerous goods storage should be undertaken as well as annual audits of the EO area. These inspections should be in accordance with Defence requirements and include storage, licensing and upkeep.

Defence References

Defence (2005)

Defence (2003)


US Army (2007)

j) Evidence of a line of command for all personnel involved in handling of EO (Defence requirement).

k) Records of staff training in the storage and handling of explosives and the objectives and implementation of the EMP (Defence requirement).

All personnel involved in the handling and use of explosives should receive appropriate training in the:

• environmental risks,

• use of this Guideline and the associated EMP, and

• implementation of the emergency response procedures.

Refresher training should also be scheduled at regular intervals.

Defence References

Defence (2003)

National References

AS 4681 (2000)

Preventative Maintenance Schedule

l) Prepare a maintenance schedule for the weapons range (Defence requirement).

m) Show documented evidence that maintenance is completed in a timely manner (as per Australian Standards).

A maintenance program should be developed with a frequency established to allow pollution prevention, including periodic pruning of vegetation, waste disposal, house keeping and regular inspections of surface soil materials and drainage.

All maintenance works must be conducted under a permit obtained from the officer in charge. Maintenance should be conducted on a preventative schedule to ensure that safe guards are in working order.

Deleading should be undertaken according to the manufacturer’s specification or every 2 to 3 years.

Defence References

Defence (2003)


US Army (2007)

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7.1 Management and Administrative Controls Dangerous Goods Manifest & Material Safety Data Sheets (MSDSs)

n) Keep an up-to-date explosives manifest for the facility (Defence requirement).

o) Material Safety Data Sheets (MSDSs) should be available for all hazardous substances including EO (Defence requirement)

p) Labelling of weapons ranges and EO according to Defence requirement (Defence requirement),

The facility should maintain a register of the types and quantities of explosives held onsite. The manifest should be updated whenever EO movement occurs.

An MSDS should be available for each EO present and personnel should be familiar with the information within the MSDS.

All weapons range, storage area and EO must be labelled with standard Defence supplied labels.

Defence References

Defence (2003)

National References

AS 4681 (2000)

State References

Various State Dangerous Goods legislation

As-constructed Plans

q) Copy of ‘as-constructed’ plans detailing the site and EO facility layout (Defence requirement).

The facility should maintain construction drawings and site layout plans for the facility.

Defence References

Defence (2003)

Staff Training

r) Evidence of a line of command for all personnel involved in handling of EO (Defence requirement).

s) Records of staff training in the storage and handling of explosives and the objectives and implementation of the EMP (Defence requirement).

A All personnel involved in the handling and use of explosives should receive appropriate training in the:

• environmental risks,

• use of this Guideline and the associated EMP, and

• implementation of the emergency response procedures.

Refresher training should also be scheduled at regular intervals.

Defence References

Defence (2003)

National References

AS 4681 (2000)

Record Keeping

t) All records related to the installation, maintenance, operation and decommissioning of a weapons range should be retained for a minimum of seven (7) years (Defence requirement).

Records related to the installation, maintenance, operation and decommissioning of a weapons range should be retained for a minimum of seven (7) years. This includes a review of the number of rounds fired, deleading activities, and all inspections of EO facilities.

Defence References

Defence (2003)


US Army (2007)

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7.2 Drainage Systems

Performance Standard 2: The drainage system at the weapons range complies with management and maintenance requirements to prevent mobilisation of the pollutant (e.g. lead) according to best management practices.

Stormwater Management and Inspections

a) Stormwater management system for the weapons range includes engineering and vegetative controls (best practice).

A stormwater management system should be designed based on the quantity and speed of the stormwater runoff. The system may consist of vegetative systems or hard engineering systems. Design should be undertaken by a qualified engineer.

The stormwater system may consist of grass swales at the base of the earthen berm or at the top of the berm to direct water away from the weapons range. All systems should be contoured to inhibit erosion.

Stormwater runoff can be diverted using land shaping or diversion ditches. The design of the system should allow for an area for stormwater outlet.

Stormwater systems can be further stabilised using riprap lining to decrease the velocity of the stormwater. The velocity can also be decreased by minimizing the slope and putting filter systems or check dams within the runoff pathway.

Filter systems (including filter beds and containment ponds) can be used to remove the sediment and trace metals from the stormwater prior to release to surface water. The filter system or containment pond must be designed for pollution prevention. All containment should be above the groundwater table and an impermeable membrane and a clay lining should be used to prevent trace metals leaching from the pond.

Defence References

Defence (2005)


US Army (2007)

US EPA (2005)

b) Regular inspection of the stormwater drainage after a storm event and within quarterly maintenance (best practice).

The stormwater system should be inspected quarterly and following a storm event for blockages, areas of erosion and silt build up.

Defence References

Defence (2005)

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Maintenance Activities

c) Where feasible, growth and maintenance of vegetation (grass cover) on the weapons range (best practice).

Vegetation cover provides erosion protection and dust control, to prevent sediment and trace metals from entering stormwater. Where feasible consideration should be made to cover the entire range with vegetation, with a focus on backstops, impact areas and runoff paths. All engineering design of the weapons range should be completed prior to vegetating.

The type of grass cover should be able to withstand the environment (people and animals) and be appropriate for the local climate. Consideration must also be given to the potential for fire and vermin associated with vegetative cover.

To maintain grass cover upon the range the mowing frequency should allow time for grass growth. Grass between the firing line and the target should be mown to enable line of site, whilst grass behind the target should be grown as long as possible and not cut shorter than 10 cm.

Ground cover can be improved by fertilizing the grass cover with a slow releasing fertilizer will promote growth more effectively. A mulch can also be used following seeding to promote growth, inhibit erosion and allow water retention.

Where possible the range should have planned down time to allow an opportunity for vegetation growth.

Traffic and access should be limited to the areas surrounding the weapons range to enable a natural vegetation buffer (consisting of trees, shrubs and ground cover) to form. If natural vegetation is not present in the area surrounding the weapons range then a buffer area should be planted.

If necessary, the area can be seeded using aerial seeding. A well developed plan should be implemented prior to seeding.

Defence References

Defence (2003)


US Army (2007)

US EPA (2005)

d) Maintenance of existing native vegetation, including trees, shrubs, vines and grasses, surrounding the weapons range (best practice).

Best possible care should be taken to maintain existing native vegetation surrounding the weapons range, including trees, shrubs, vines and grasses, during the construction and development phases.

The area directly surrounding an EO store (15 – 20 m) or within the traverse should be clear of vegetation to minimise the potential for fire.

Defence References

Defence (2003)


US Army (2007)

US EPA (2005)

Environmental Testing

a) Evidence of soil testing, and where necessary, amendments to stabilize lead in soils (best practice).

e) Monitoring of surface water and groundwater quality (best practice).

If bullets are landing directly on unsealed ground, the pH of the soil should be tested on an annual basis. Lead migration is faster with a lower pH and inhibited when the pH of the soil is between 5.5 and 8.

In soils with an acidic pH the pH should be increased by the addition of lime or phosphate.

Surface water and groundwater quality monitoring can be used to measure the movement of lead from the range to sensitive environments. Consideration should be given to undertaking regular monitoring.

Defence References

Defence (2005)


US Army (2007)

US EPA (2005)

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Record Keeping

f) Documented records of maintenance inspections and assessments on drainage systems should be kept (best practice).

g) Evidence of review of the stormwater drainage after a storm event and within quarterly maintenance (best practice).

A regular inspection maintenance program for drainage systems and interceptors must be implemented.

Defence References

Defence (2005)

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7.3 Transport of Materials

Performance Standard 3: Transport of explosive ordnances and dangerous goods complies with requirements outlined within applicable legislation and Australian Standards..

Dangerous Goods Transport

a) Specific requirements in the Defence protocol and Australian Dangerous Goods Code for placarding, licensing, driver training and provision of on-board emergency response equipment must be ensured (Defence requirement).

All transportation of explosive ordnance and dangerous goods should be conducted in accordance with Defence requirements and the Australian Dangerous Goods Code.

This should include all compliance requirements with regards to placarding, licensing, driver training and provision of on-board emergency response equipment.

Where specified within Defence requirements segregation of explosive ordnances, non explosive dangerous goods and waste explosive ordnances for transportation should occur.

Defence References

Defence (2003)

National References

ATC (2007)

International Air Transport (2005)

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7.4 Storage of Materials

Performance Standard 4: Operation of weapons and explosives storage at the weapons range complies with requirements outlined within applicable legislation and Australian Standards.

Storage Location

a) Review and selection of location for the weapons storage facility should be justified to ensure protection of any potentially impacted sensitive receptors (Defence requirement).

The weapons storage facility should be located within an area protected from fire, flood or landslide to minimize the risks associated with the storage of explosives.

The location should consider the distance from sensitive receptors (including buildings, roads, dangerous goods storage, underground tanks or pipelines etc). Defence (2003) specifies minimum distances between EO storage and other facilities.

Defence References

Defence (2003)

National References

AS 4681 (2000)

Storage Requirements

b) Store weapons/EO in an appropriate storage facility (Defence requirement).

c) Segregate EO and non-explosive dangerous goods where necessary (Defence requirement).

d) Label the storage facility appropriately (Defence requirement).

Weapons storage should be within appropriate facilities in accordance with the Australian Standard and Defence protocol. The facility should be sealed to prevent personnel access and water ingress. Wherever possible EO should be stored in a covered facility (e.g. roof or tarpaulin etc) that prevents exposure to rain and sunshine.

EO should be segregated where possible in different storage facilities according to the Defence requirements. Mixing of some EO types may be feasible where space restrictions exist.

Non-explosive dangerous goods (NEDG) should be stored separately from EO according to the requirements of the relevant Australian Standards and Defence (2003). Separation distances between NEDG and EO are specified within Defence (2003) and relevant Australian Standards. All NEDG should be stored according to their relevant Australian Standards.

Dangerous goods from the same parent weapon component and non-explosive devices may be stored together with the EO.

EO should be packed in appropriate sealed containers according to Defence requirements. Where possible single lots of ammunition should be packaged in a single package.

The facility, packaging and EO should all be clearly labelled with permanent or temporary marking according to Defence requirements.

Defence References

Defence (2003)

National References

AS 4681 (2000)

e) Store non explosive dangerous goods (NEDGs) according to relevant Australian Standard (as per Australian Standard).

f) Where necessary, dangerous goods should be stored within a bunded environment (as per Australian Standard).

g) Store dangerous goods in sealed and labelled containers (as per Australian Standard).

NEDGs should be stored in a sealed container based on the quantity of chemicals used. The drums, packages or tanks used for storage should comply with any State specific requirements for the storage of hazardous materials. At a minimum, the container used for storage should be chemically inert, sealed and corrosion resistant.

The sealed container should be provided with a chemical-impermeable secondary containment area (i.e. a bund or chemical cabinet), which is able to contain at least 100% of the largest tank volume.

Further information on storage of NEDG can be found in the relevant Australian Standards and the Environmental Management Guideline 3: Design of Chemical Storage Facilities.

National References

AS 4681 (2000)

AS 4452 (1997)

AS 3833 (2007)

AS 1940 (2004)

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7.4 Storage of Materials

Storage Requirements (cont)

h) Storage of EO in a controlled environment (Defence requirement).

i) Prohibited articles should not enter an EO facility (Defence requirement).

j) Limited access to storage facilities (Defence requirements)

k) Undertake all maintenance works, including tool use, according to the appropriate permit (Defence requirement).

EO must be stored within specific temperature and humidity ranges to minimise the risk of damage. The storage facility should be environmentally controlled with regular inspection of temperature and humidity.

Ventilation should be used within the EO storage facility to prevent build up of vapours or dust.

Contamination, through dust, entering from outside should be minimised by the use of door mats, ventilation and regular cleaning. All maintenance work that could introduce contamination should be carried out under the appropriate permit.

Certain items (e.g. cameras, watches, matches etc.) are prohibited from entering an EO facility to prevent contamination and manage risks. A full list is provided in Defence (2003).

Storage facilities should have appropriate fencing to limit access. Personnel should only enter following approval by the officer in charge. The fencing should also be suitable to prevent native wildlife accessing the facility and damaging the EO.

Defence References

Defence (2003)

l) Stacking of EO according to Defence requirements (Defence requirement).

Defence (2003) provides the stacking requirements for EO within the storage facility. EO should be stacked to allow air movement between each container and ease of access.

The layout of the storage facility should take into account the position of the exits, the maximum stacking heights and depths, the presence of working aisles and access for personnel.

The maximum stacking height depends on the distance from the roof and any traverses present.

Defence References

Defence (2003)

National References

AS 4681 (2000)

Maintenance and Inspection

m) Evidence of regular maintenance/inspection of the weapons storage facility (Defence requirement).

n) Evidence of regular house keeping and tidy design of weapons storage (Defence requirement).

Regular inspection of the weapons storage facility should address any concerns regarding housekeeping and weapons storage.

Regular maintenance and inspection should address:

• The presence of water or NEDG within the secondary containment facility or any damage to primary containment vessels for NEDG;

• Cleaning of the hardstand adjacent to the EO storage facility;

• Assessment of the vegetation on the traverses;

• Drainage systems around the EO facility;

Stacking, labelling and general cleanliness of the EO facility.

Defence References

Defence (2003)

National References

AS 4681 (2000)

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7.5 Handling and use of Explosive Ordinance

Performance Standard 5: The handling and use of Explosive Ordinances (EOs) complies with best practice requirements.

Weapons Range Set Up

a) Evidence of paved access tracks and parking areas (Defence recommendation)

The use of paved access tracks and parking areas can minimise the potential for vegetation erosion and assist in dust suppression.

Defence References

Defence (2005)

b) Evidence of even distribution of firing lanes (best practice).

Use of specific firing lanes leads to increased break down of the bullet catcher and potentially increased levels of erosion in that area. By spreading the distribution of use, erosion and the need for repair of the bullet catcher can be minimised.


US Army (2007)

Inspections and Housekeeping

c) Regular inspection of the bullet catcher and firing range (Defence recommendation).

The bullet catcher and firing range should be regularly inspected for impact areas where ricochets and erosion can occur.

Inspections may also indicate a need for de-leading of the site.

Defence References

Defence (2005)


US Army (2007)

d) Handling of EO and non-explosive Dangerous Goods (NEDG) should occur within the appropriate facility (Defence requirement and Australian Standard).

Unpacking and repacking of EO should only occur when necessary and within an appropriate building (e.g. workshop or preparations building).

Handling of NEDG should occur within a secondary containment area such as a bund. Any spills within the containment area should be cleaned and disposed of appropriately.

Defence References

Defence (2003)

National References

AS 4681 (2000)

AS 4452 (1997)

AS 3833 (2007)

AS 1940 (2004)

e) Regular house keeping of indoor firing ranges (Defence recommendation).

House keeping at indoor firing ranges includes:

• Inspection of the filters within the ventilation system;

• Cleaning up dust using wet suction sweepers or filtered vacuums;

Appropriate disposal of any dust removed from the facility.

Defence References

Defence (2005)


US Air Force (2008)

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7.6 Waste Management

Performance Standard 6: Operation and procedures for waste management at the weapons range complies with best management practices.

Deleading Processes

a) Regular inspection and de-leading of the firing range. (Defence recommendation).

a) Undertake de-leading activities to minimise lead migration (Defence recommendation).

The weapons range should be de-leaded approximately every 80,000 rounds per lane or every 2 to 3 years. During de-leading, the top layer of soil is removed and sifted to separate the lead casings from the soil. The soil can then be replaced and the lead casings can be appropriately disposed of (with the possibility for recycling).

The soil removed from the range will need to be stored prior to sifting in an area with an impermeable barrier (e.g. concrete hardstand) and good stormwater drainage away from the stockpile. Salvaged exploded ordnances should be stored in a secured, fence area and certified free from explosive before transport or long term storage.

Vegetation upon the range will need to be removed prior to de-leading. Where possible a range downtime may need to be applied to allow for de-leading and subsequent vegetation growth.

The soil and salvaged lead should be well separated to allow the soil to be reused and the lead to be recycled, wherever possible

Defence References

Defence (2003)

Defence (2005)


US Army (2007)

US EPA (2005)

Waste Disposal

b) Appropriate disposal of explosive material (Defence requirement).

b) Minimisation of waste EO (best practice)

Waste explosives should be treated separately from general waste (which would include domestic waste, paper, plastic, glass, wood, metals, food and textiles). The explosive waste should be collected and disposed of appropriately. Waste EO or unserviceable EO should be segregated from standard EO and where the EO is considered unsafe it should be stored in isolation.

All EO packaging must be certified free from explosives and stacked so as not to cause a fire danger and transported for reuse.

During disposal of waste EO, consideration should be given to the:

• potential pollution of soil, surface water or air;

• noise and shock;

• security;

• fire fighting;

• future wind and erosion; and

• products of combustion, residue and the formation of toxic gases.

The procedures for disposal should minimise any impact to the environment.

Defence References

Defence (2003)

c) Appropriate disposal of all non-explosive Dangerous Goods (NEDG) waste and general waste within the storage facility (as per Australian Standard)

All NEDG and general waste should be disposed of within an appropriately licenced facility in accordance with State specific legislation.

NEDG waste should be stored on site in accordance with the relevant Australian Standard prior to disposal.

Any waste material produced within the EO storage facility must be removed and placed in sealed metal bins outside the EO storage facility. Waste material should not remain within storage bins overnight.

Defence References

Defence (2003)

National References

AS 4681 (2000)

AS 4452 (1997)

AS 3833 (2007)

AS 1940 (2004)

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7.6 Waste Management

Site Decommission

d) Certification of the range is required following cessation of use of the location (Defence requirement)

All ranges must be certified prior to disposal or reuse of the land. Areas containing explosives are to be decontaminated and certified to be free of explosives using the latest available methods.

Defence References

Defence (2003)

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7.7 Emergency Response1 and Clean-Up

Performance Standard 7: Emergency response plans for the weapons range complies with requirements outlined within applicable legislation and Australian standards.

Emergency Response Plan

a) An Emergency Response Plan is maintained onsite (Defence requirement).

b) Training records demonstrate that personnel are trained to manage emergencies (Defence requirement).

An emergency response plan should be prepared within the environmental management plan.

The emergency plan should be site specific and deal with emergencies appropriate to the location and circumstances (e.g. vandalism, terrorism, fire, explosion and floods). The emergency response plan should provide details of the locations and types of dangerous goods present, EO facilities and procedural response (e.g. incident reporting, clean up and notification requirements).

All personnel working within the facility should be trained in the emergency response plan. Refresher training should also be provided annually.

Defence References

Defence (2003)

State References

Various State Dangerous Goods Legislation

Spill Management and Prevention

a) A spill kit including desensitising agents and absorbent material is available (Defence requirement).

b) Clean-up and waste disposal procedures following a spill are annotated on the spill kit (requirement as per Australian Standard).

A spill kit should be maintained at all times within all areas where liquid wastes are used, handled or stored. The spill kit should contain covers/booms to protect access to drains and absorbent material for containing the fuel spill. Any absorbent material used to contain the spill should be disposed of in accordance with the State/Local waste disposal regulations.

Where facilities are located adjacent to watercourses, emergency booms to prevent spread of released product should be maintained on site.

Defence References

Defence (2003)

National References

Various Australian Standards for the Storage of Dangerous Goods, e.g. AS 1940 (2004)

Incident Investigation and Notification

c) Spills and Leaks should be reported as per Defence requirements depending on the spill size and level of containment (at minimum, uncontained spills less than 50 L must be reported).

d) For spills and leaks that have spread or have the potential to spread beyond the boundary of the installation the appropriate authority should be notified within 24 hours (requirement as per Australian Standard).

Should leak or spill monitoring suggest a potential fuel leak the appropriate regional environmental officer (REO), JFLA, and [email protected] should be notified.

Where necessary the state regulatory authority should be informed, depending on the size and level of containment of the spill.

Defence Reference

Defence (2003)

Defence (2005)

e) Evidence of accident / incident investigation records should be documented and maintained (legislative requirement).

Following notification of an incident a full assessment should be carried out. The assessment, where necessary, may include an intrusive soil and groundwater investigation.

Defence References

Defence (2003)

State References

Various State Dangerous Goods Legislation

1 It should be noted that this just includes environmental considerations. There are likely to be additional safety requirements.

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8. Other Considerations

OH&S Considerations: There are numerous occupational, health and safety considerations associated with the operation and maintenance of equipment/infrastructure at weapons ranges and storage of ammunition/explosives. A risk assessment in line with Defence’s DSG Risk Assessment Framework (available from Defence Infrastructure Management) should be undertaken to assess the potential risks associated with each activity. All personnel must be trained and made aware of the risks associated with undertaking an activity.

MSDSs: Material Safety Data Sheets (MSDSs) must be present and readily available for each EO and chemical stored within the weapons range. Personnel must be trained and made aware of the emergency response and first aid measures associated with exposure to the ammunition/explosives or the types of chemicals being handled and stored.

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9. Case Study – Inspection protocol and checklists from Defence Explosives Safety Manual.

The Defence Explosives Safety Manual (Defence, 2003) stipulates the need for monthly internal inspections of EO facilities in addition to external audits and certifications. The inspections are a requirement of explosive limit licences and can act to prevent facilities falling into disrepair. Inspections should be undertaken by qualified personnel that do not work within the specific facility. Inspections should assess safety and pollution prevention for various areas of the EO facility. A reference guide is provided in the Manual of the requirements for each area of assessment. A series of checklists (below) are provided by Defence and must be maintained in an inspection register for quarterly review.

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10. References and Further Reading

Australian Government Department of Defence (Defence), 2003. Defence Explosives Ordnance Publication 103 (DEOP-103) – Defence Explosive Safety Manual.

Australian Government Department of Defence (Defence), February 2005. Stop Butt Construction and Maintenance Thin Guide for Environmental Officers.

Australian Government Department of Defence. 2007. Defence Pollution Prevention Strategy: Advancing Defence’s Pollution Prevention Capability.

Australian Government Department of Defence (Defence), 2007. Defence Waste Minimisation Policy, sponsored by the Assistant Secretary Environment, Heritage and Risk (ASEHR).

Australian Transport Commission (ATC). 2007. Australian Code for the Transport of Dangerous Goods by Road and Rail.

International Air Transport Association. 2005. Dangerous Goods Regulations.

Standards Australia. 1997. Australian Standard 4452-1997. The storage and handling of toxic substances.

Standards Australia, 1998. Australian Standard 2187.1-1998, Explosives – Storage, Transport and Use Part 1 Storage.

Standards Australia. 2000. Australian Standard 4681-2000. The storage and handling of class 9 (miscellaneous) dangerous goods and articles.

Standards Australia. 2004. Australian Standard 1940-2004. The storage and handling of flammable and combustible liquids.

Standards Australia and Standards New Zealand, 2009. Australian / New Zealand Standard ISO 31000:2009. Risk management - Principles and guidelines. Adopted by the Australian and New Zeeland Joint Technical Committee on Risk Management.

US EPA, 2005. Best Management Practices for Lead at Outdoor Shooting Ranges.

US Department of Air Force, 2008. Engineering Technical Letter 08-11: Small Arms Range Design and Construction.

US Army Environmental Centre, 2007. Army Small Arms Training Range Environmental Best Management Practices (BMPs) Manual.

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