DEPARTMENTS OF THE ARMY AND THE AIR FORCE NATIONAL GUARD BUREAU 1411 JEFFERSON DAVIS HIGHWAY ARLINGTON, VA 22202-3231 NGB-AVS 1 August 2002 MEMORANDUM FOR THE ADJUTANTS GENERAL OF ALL STATES, PUERTO RICO, THE US VIRGIN ISLANDS, GUAM AND THE COMMANDING GENERAL OF THE DISTRICT OF COLUMBIA SUBJECT: (All States Log Number P02-0033) Army National Guard (ARNG) Indoor Firing Range (IFR) Action Plan and Implementation Guidance 1. References: a. 29 Code of Federal Regulations (CFR), Part 1910-Occupational Safety and Health, Subpart Z-Toxic and Hazardous Substances, Section 1025-Lead. b. DODIG Audit Report #98-170, 30 June 1998, and US Army Reserve Command Small Arms Indoor Firing Ranges". 0. DODIG Audit Report #99-250, 13 September 1999, "Construction and Rehabilitation of Reserve Components Indoor Small-Arms Ranges". AR 385-10, The Army Safety Program, 29 February 2000. e. AR 385-63, Policy and Procedures for Firing Ammunition for Training, Target Practice and Combat, 15 November 1983. f. NGR 200-3, State and Federal Environmental Responsibilities, 1 August 1990. g. NGB-AVS (All-States Memorandum Log Number. December 2001, Army National Guard (ARNG) Policy and Responsibilities for Inspection, Evaluation, and Operation of ARNG Indoor Firing Ranges (IFR) and Guidelines for IFR Rehabilitation, Conversion and Cleaning. h. US Army Center for Health Promotion and Preventive Medicine Technical Guide No. 206, Indoor Firing Ranges. i. Executive Summary No. EPA 747-R-97-002, March 1997, subject: Laboratory Study of Lead?Cleaning Ef?cacy. NGB-AVS SUBJECT: (All States Log Number Army National Guard (ARNG) Indoor Firing Range (IFR) Action Plan and Implementation Guidance j. The Army National Guard Safety and Occupational Health Action Plan "Indoor Firing Ranges" (enclosure 1). 2. Purpose. This guidance is intended to aid the 54 States and Territories with implementation of the ARNG IFR Action Plan. The plan, provided in enclosure 1, is a critical element of the corrective actions proposed to the DODIG in response to their ?ndings. Execution will ensure compliance with references 1.b. and 1.0 3. Requirement. Indoor Firing Ranges are required to meet the provisions of AR 385- 63 and 29 CFR 1910.1025. These requirements are intended to ensure safe usage of small-arms ranges, and to prevent exposure of personnel to harmful amounts of Lead References 1.b. and 1.0. require that speci?c actions be taken to reduce the number of unsafe ARNG IFRs. Further, they recommend speci?c design and housekeeping standards for indoor ranges as prescribed by the National Institute of Occupational Safety and Health. The following corrective actions apply: a. Identi?cation and inventory of all active and inactive ARNG Indoor Firing Ranges to include ranges in Armories, and Readiness Centers. Inventoried ranges will be entered into the PRIDE (Planning Resources for Infrastructure Development and Evaluation) system under Category Code No. 17121. b. Evaluation of each IFR to characterize its ability to meet environmental, and safety and health criteria (Safe, Unsafe, or Limited Use), IAW reference 1.9. This includes assessment by Industrial Hygiene sampling of IFRs to determine the level of lead contamination, if any. 0. Risk Assessment/Analysis (RA) of each IFR. The RAs will include provisions to determine the potential for release of hazardous materials into the environment, and must provide for development of adequate preventive measures and safety assessment of bullet traps, backstops, and baf?es as applicable. d. Determining the disposition of each IFR to include plans for future use by Civilian Law Enforcement agencies, or other public use of the facility(s). e. Completion of necessary IFR corrective actions based on the State's RA, and plans for future use of each range. 4. Process. NGB-AVS SUBJECT: (All States Log Number P02-0033) Army National Guard (ARNG) Indoor Firing Range (IFR) Action Plan and Implementation Guidance a. The FR Safety Evaluation-Each State and Territory is responsible for conducting IFR safety evaluations IAW reference 1.9. Additionally, an IFR inventory that includes the status and disposition of their ranges must be submitted to National Guard Bureau Aviation and Safety Division, NLT the deadlines established by paragraph 4.b. below. b. Scheduling/Milestones. The projected schedule for completion of all required corrective actions for ARNG IFRs is 28 February 2010. The dates for completion of critical milestones are established as follows: (1) 28 February 2003-IFR Inventory and Evaluation by each State. (2) 28 February 2003-IFR disposition and/or plans for future use as determined by the State. (3) 28 February 2005-Abatement plans, Scopes of Work, and Contracts developed for IFR Clean up, Conversion, Rehabilitation, and Closure as required. (4) 28 February 2008-Execution and evaluation of corrective actions. (5) 28 February 2010-Final reporting to the Department of Defense Inspector General of corrective actions taken to reduce the number of unsafe ARNG IFRs. 0. Reporting. The preferred format for reporting of the IF safety evaluation, inventory, and range disposition, as required by paragraph 4.a. above are provided at enclosure 2. The following are minimum reporting requirements: (1) The use of NGB Form 100-14-1, ARNG Risk Management Worksheet, to document and report the RA process, is strongly recommended (See Enclosure 3). (2) Information related to IFR safety evaluation, status, condition, and classi?cation should also be loaded into PRIDE in coordination with the State CFMO. (3) The State Safety Of?ce should provide the safety data to the CFMO for input into the PRIDE system using the applicable data elements and responses described in enclosure 4, or input the required data if access to the system has been granted. NOTE: The appendix to FM 100-14 contains instructions for use of the Risk Management Worksheet, and should be used as a guide in developing local Risk Management procedures. NGB-AVS SUBJECT: (All States Log Number P02-0033) Army National Guard (ARNG) Indoor Firing Range (IFR) Action Plan and Implementation Guidance (4) Additional information such as whether the range is used for Weapons Quali?cation Training is useful in determining resource requirements for maintenance, upkeep and cleaning, and should also be annotated if known (see enclosure 4). 5. Fiscal Responsibilities. These responsibilities have not been clearly de?ned in the past. However, protocol has been established in recent years as follows: a. Funding for operation and maintenance of State owned facilities are the responsibility of each State. Reference 1.0., page 2, states "Military Construction Cooperative Agreements require each State Area Command (STARC) to maintain the armory facilities, including indoor ranges, its own expense? during the term of the agreement, which can extend 5 to 25 years. Generally, STARCs must fully fund the cost of lead cleanup for routine indoor range maintenance and operations, which have grown signi?cantly since 1980 because of increased health, safety, and environmental requirements." b. The STARC can also be reimbursed for the costs of disposing of hazardous wastes, such as lead and lead dust generated from live ?ring. However, this provision applies only to State owned facilities used for Federal missions. 0. State environmental funding is used only for the actual disposal of hazardous waste generated during range cleaning or decontamination operations, as prescribed by reference 1.0. and 1.9. d. Funding for Federally owned facilities are the responsibility of the Federal Government. 6. This memorandum expires 12 July 2003, unless otherwise rescinded or superceded. 7. Point of contact is Colonel George J. Gluski, Chief, Aviation and Safety Division, at DSN 327-7700 or 703-607-7700. Technical questions pertaining to implementation of NGB-AVS SUBJECT: (All States Log Number P02-0033) Army National Guard (ARNG) Indoor Firing Range Action Plan and Implementation Guidance this plan can be addressed to Mr. Alan G. Lott, Safety and Occupational Health Specialist, at DSN 327-7779 or 703-607-7779. FOR THE CHIEF, NATIONAL GUARD BUREAU: amazes 4 Encls ROGER C. SCHULTZ 1. as Lieutenant General, GS 2. Data Submission Director, Army National Guard 3. as 4. PRIDE Safety Data CF: NGB-IG NGB-PL NGB-ARC NGB-ARE NGB-ARI NGB-ARO NGB-ARS NGB-ART NGB-ARZ-PC Each State IG Each State POTO Each State USPFO Each NGB Regional Industrial Hygienist Each State Safety Occupational Health Of?ce Each State Occupational Health Nurse Each State Training Site Commander Each State CFMO ARMY NATIONAL GUARD SAFETY AND OCCUPATIONAL HEALTH ACTION PLAN FIRING PURPOSE This plan identi?es corrective actions designed to control and reduce the number of unsafe ARN Indoor Firing Ranges (IFRs). It sets the milestones necessary to ensure that critical program elements are established and implemented prior to range Operation. The regulatory guidance, and procedural methodology described in this plan are consistent with current environmental safety health practices and standards. Implementation of this plan will safeguard personnel against exposure to Lead (Pb) in harmful amounts, and prevent release of Lead into the environment. Additionally, it will allow ARNG components to safely reactivate IFRs previously determined to be unsafe for Operation. CORRECTIVE The following corrective actions/ initiatives are required as a result of the Department of Defense Inspector Generals (DODIG) report No. 98-170 "Army National Guard and US Army Reserve Command Small Arms Indoor Firing Ranges": 1. The ARN has developed regulatory guidance for operation, maintenance, inSpection/evaluation, rehabilitation, decontamination, conversion, and closure of IFRs. This guidance was ?elded in September 2000. 2. Each state and territory will re-evaluate and report the status of their IFRs to the NGB. The evaluation reporting process will include an IFR inventory and classi?cation of each range (Safe, Unsafe or Limited Use), a status report that describes the condition of each range (Closed, Converted, Rehabilitated, Active or Inactive), and the ?nal determination as to the disposition of each range. Completion of the IFR evaluation process is expected by 28 February 2003. 3. NGB will review scope of work (SOW) documents, abatement plans, action plans, and/or contracts for IFR rehabilitation, decontamination, conversion, or closure submitted by the states and territories. Review of these documents will be completed as they are submitted, in support of item 2 and 4 of this action plan. 4. All ARN Indoor Firing Ranges will fully comply with governing health and safety standards, and applicable regulatory guidance. The Individual State and/or Territory Hazard Abatement Programs will be used to eliminate identi?ed hazards in conjunction with implementation of this guidance. Signi?cant reduction and effective control in the number of unsafe indoor ?ring ranges will take approximately 10 years. Completion is expected by 28 February 2010. SUMMARY Execution of this plan requires close coordination between the NGB and the ?fty-four States and Territories. Budgetary resources must be identi?ed/provided to ful?ll the requirements of the plan. Currently IFR rehabilitation, decontamination, conversion, and closure represent unidenti?ed and unfunded ?scal requirements. This could become an obstacle to executing the provision of the plan. To resolve this pitfall, future budgetary forecast should re?ect the need for dedicated funding. Enclosure 1 IFR DATA SUBMISSION STATE Enclosure 2 It. ARNG RISK WORKSHEET . (The propo. NGB-AVN-S) 1. Organization and Station: 2. Page of 3. Mission/T ask: 4. DTG Begin: 5. DTG End: 6. Date Prepared: 7. Standards. SOPs, and References that will be used to implement Mission/T ask Control Options and Countermeasures for Hazards: 8. Prepared by: (Rank/NamelDuty Position) 9. Identi?ed Hazards: 10. Initial 11. Control Options and Countermeasures 12. Remaining 13. Supervision by: 14. Were Risk for Identi?ed Hazards: Risk (Continuous. Buddy Controls Levek Levek E??c?ve? (Be Speci?c) (Be Speci?c) (Be Speci?c) (From AAR) 15. Remaining Risk Level After Countermeasures Are Implemented: "In" (CIRCLE HIGHEST REMAINING RISK low Minmm Ex 16. RISK DECISION AUTHORITY: (Approval Authority Signature Block) (Rank/NameiTitle) NGB Form 100-14-1, July 99 (FormFlow 2.15) Enclosure 3 Enclosure ARNG MANAGEMENT WORKSHEET (Continuation) 1. Organization and Station: 2. Page of 3. MissionfT ask: 8. Prepared by: (Rank/NamelDuty Position) 9. Identi?ed Hazards: Initial Risk Control Options and Countermeasures for Remaining Supervision by: Were Controls Level: Identi?ed Hazards: Risk Level: (Continuous, Buddy Effective? System. SITREP. etc.) (Be Speci?c) (Be Speci?c) (Be Speci?c) (From AAR) NGB 100-14-1, July 99 (FormFlow 2.15) ?at-3f ?eld 8. SAFETY INFORMATION 39. TRNG DIV INFORMATION PKIUI: bill'tl DA IA Data'- 3801. 3805. Date 3802. Status 3803.Cl cation 804. CBhtaminated 901. Quali?cation qut CL: Closed Converted RE: Rehabilitated A: Active I: Inactlve S: Safe U: Unsafe L: Limited Use Yes/No es/Ne 'Enclosure 4