Request to EMC for India Range Design Approval - STATES - The ...

DEVAL L. PATRICK
Governor
TIMOTHY P. MURRAY
Lieutenant Governor
RICHARD K. SULLIVAN, JR.
Secretary
June 8, 2012
Colonel Richard V. Crivello
Camp Edwards Post Commander
Camp Edwards, MA 02542-5003
COMMONWEALTH OF MASSACHUSETTS
EXECUTIVE OFFICE OF ENERGY & ENVIRONMENTAL AFFAIRS
ENVIRONMENTAL MANAGEMENT COMMISSION
Building 1204, Camp Edwards, MA 02542-5003
(508) 968-5127 Telephone (508) 968-5128 Facsimile
Printed on Recycled Paper
MARY B. GRIFFIN
KENNETH L. KIMMELL
EDWARD M. LAMBERT, JR.
Commissioners
RE: Upper Cape Water Supply Reserve; Camp Edwards India Range Small Arms Range
Construction Plans and Specifications Approval
Dear COL Crivello,
The Environmental Management Commission (EMC) is in receipt of your letter dated June 4,
2012, requesting approval to construct India (I) Range following design plans and specifications
submitted to the Environmental Management Commission in accordance with the Environmental
Performance Standards.
As indicated in your letter, I Range was selected as the Copper Ball Ammunition (M855A1 EPR)
“zeroing range” over the previously proposed Tango Range reconstruction due to significant
environmental and safety benefits in using I Range. Tango Range had initially been proposed as
the M855A1 EPR “zeroing range” for Soldiers sighting in their M4 and M16 rifles for
subsequent rifle qualifications on S Range.
The I Range design plans submitted to the EMC by Camp Edwards are titled Massachusetts
Army National Guard, India Range, India Range Improvements, Camp Edwards, Bourne, MA.
The plans are stamped by a professional engineer and dated June 7, 2012. The accompanying
Range Construction Specifications are titled Massachusetts Army National Guard, India Range
Improvements at Camp Edwards, MA, Project Number: 986114, Construction Specifications.
The Construction Specifications are dated June 7, 2012.

The specifications include an upgrade of the forward berm on I Range, one of two existing small
arms range backstop berms on the range. According to the design plans and specifications, the
forward berm will be improved by adding additional fill to increase the height to a 12-foot-high
backstop berm. The additional berm core fill material specifications call for 100 percent of the
fill passing a 3 inch sieve size. The core fill is overlain by a 3-foot-thick select sand fill layer
with 100 percent of the select sand fill passing a No. 4 sieve. The select sand fill layer is topped
by 4 inches of topsoil with a maximum particle size of 1/8 inch. According to the specifications,
the topsoil will be “free of sticks, stones, roots, and other debris and objectionable materials.”
The stone-free nature of the topsoil and sand layers will help reduce both bullet fragmentation
and ricochet, and facilitate metal recovery. The topsoil will be hydro seeded with an approved
grass seed mix and covered with plastic-free erosion control matting to prevent erosion of the
front of the berm while the vegetative layer is established. Topsoil and plastic-free erosion
control fabric will be used on the back of the berm. The backstop berm, with its sand fill layer, is
designed to capture the M855A1 copper and steel 5.56 mm projectiles for future recovery and
recycling.
Operation, Maintenance, and Monitoring Plans and Procedures (SOP) for I Range are well under
development by Camp Edwards and are anticipated to be finalized and submitted for EMC
approval this month. Supervision of the range to assure that the range is operated in accordance
with Environmental Performance Standards (EPS), the EMC’s conditional approval, and a
monitoring program to confirm the environment is being protected, will be included in the SOP.
The Community Advisory Council and the Science Advisory Council, at their respective
meetings on November 17, 2011, and November 2, 2011, reviewed and supported the use of
copper bullets on Camp Edwards within the Upper Water Supply Reserve (“the Reserve”)
subject to further detailed review and design approval by the EMC’s Executive
Director/Environmental Officer.
On December 5, 2011, acting under the purposes and provisions of Chapter 47 of the Acts of
2002, “An Act Relative to the Environmental Protection of the Massachusetts Military
Reservation,” the EMC voted to conditionally approve an initial use of the M855A1 copper
bullet on two small arms ranges within the Reserve. The approval for two small arms ranges was
contingent on range design plan and SOP review and conditional approval by their Executive
Director/Environmental Officer.
While copper jacketed bullets have been used at Camp Edwards for decades, the M855A1 is a
new copper and steel round with ballistic properties that have not been tested at Camp Edwards.
To address any potential unforeseen issues, the Massachusetts Army Guard has proposed a
continual improvement approach that incorporates an adaptive range management process to
address any unanticipated occurrences that are possible on the copper ammunition only ranges.
Contingency plans to make any necessary adjustments are being incorporated in the operations
and maintenance procedures to address any such occurrences in a timely fashion.
I Range is an existing small arms range within the Camp Edwards training area where the
Environmental Protection Agency (EPA) and the Massachusetts Department of Environmental
Protection oversaw the National Guard Bureau’s Impact Area Groundwater Study Program’s

emediation of the I Range backstop berm. In a letter dated May 15, 2012, EPA authorized Camp
Edwards to proceed with plans to use the I Range. The EPA also reiterated in the letter that
“…the use of the proposed Enhanced Performance Round, i.e. 855A1 5.56mm Copper Ball
Ammunition, did not appear to violate the terms of EPA’s Administrative Order…which
prohibits the firing of lead ammunition.”
The proposed I Range design and construction plans are hereby conditionally approved in
accordance with the Environmental Performance Standards. This plan approval may be revoked
at any time for failure to comply with the conditions herein or for failure to follow the range
construction plans and range specifications or this approval. The EMC’s approval for the
construction of I Range is subject to the following conditions:
1. All construction activities shall be in accordance with the Environmental Performance
Standards, the Quality Control/Quality Assurance (QA/QC) procedures in the submitted
documents, this approval letter, and all other applicable laws, regulations, and approvals.
2. pH testing and other field QA/QC tests are required by the range specifications to be
conducted by a qualified geotechnical engineering testing agency. The results of such
testing shall be forwarded to the EMC by Camp Edwards as soon feasible as they are
received by Camp Edwards from the contractor/qualified geotechnical engineering
testing agency.
3. Any proposed field changes to the berm, berm components, or other range design
features, excluding signage, shall be closely coordinated with, and approved by, the EMC
prior to implementing any proposed changes.
4. I Range shall not be operated as a small arms range until a) the range is constructed to
specifications, including following the quality control and quality assurance testing
procedures, b) documentation is submitted to the EMC that the berm fill materials meet
depth and particle size specifications noted above, and c) a completed operation and
maintenance procedure/Range SOP is finalized and approved.
If you have any questions regarding this I Range construction approval letter, please contact me
at (508) 968-5127.
Sincerely,
Mark J. Begley, LSP
Executive Director/Environmental Officer,
Environmental Management Commission
ec: EMC, SARWG