Mark Nale September 5, 2010 8:38am EDT in the Centre Daily Times:
A battle rages in central Pennsylvania over the right of the Philipsburg Rod and Gun Club to resume operations at the 23-acre shooting range that they lease in Centre County’s Black Moshannon State Park. The Pennsylvania Department of Conservation and Natural Recourses closed the range in 2006, and according to the club, has stonewalled all efforts to reopen the facility.
At first glance, it seems as if the shooting activities of club members have contaminated the park soil with lead to the point that it must pose a serious hazard to park patrons or park wildlife. A closer inspection shows something is amiss. Please bear with me as we examine this complicated issue.
The PRGC shotgun range had been in operation in various Moshannon State Forest locations since before the park opened in 1937. According to club president Dave Laux, at the suggestion of the Bureau of Forest and Waters, they moved the range to its current location over 60 years ago.
In the 1960s, they built a large brick clubhouse on their leased land — the building, according to the club, is now valued at $250,000. Club secretary Paul Bobby said that the club had a good relationship with park management until things went sour in 2006. Until four years ago, the park had considered the club’s range a positive addition. The agency even encouraged the club to increase the number of traps to six. At the time, their club membership listed 150 shooters.
“Park management called a meeting in the fall of 2006. They told us that they had found soil samples with high levels of lead and that they wouldn’t renew our lease to shoot on the property,” Bobby said. With no place to shoot, club membership has declined. However, the current membership has vowed to do anything reasonably possible to get the range up and shooting again.
Using a grant, DCNR hired a professional testing company — Baker Engineering & Risk Consultants — to do soil testing and groundwater testing. I have not seen this data, but according to the club, only one small area of the shooting range showed high soil lead levels, and only one of the many wells showed even a trace of lead contamination. The lead levels in the soil turned out to be a tenth of what DCNR had originally claimed. The club’s consultants have confirmed this. Regardless of the results, DCNR stipulated that the club needed to have ecological and human health risk assessments done for the 23 acres.
DCNR gave them a list of recommended consultants from which to choose. That assessment, done at club expense, was conducted in 2008, by Converse Consultants of State College, one of the DCNR suggested firms. Contrary to DCNR hopes, the assessments found no excessive human or ecological risks associated with the shooting range activities, as long as the club implemented best management practices and monitored the site. Bill Brusse of Converse Consultants said, “In our opinion, the club has to manage the site and not clean up the area at this time. They should be in a management phase with a later recovery of lead. No large-scale remediation is necessary at this time. Measured concentrations of soil lead above any real level of concern are found in only one small area.”
Bill Brusse
DCNR balked at the results, which further irritated the club. “We used one of their recommended consultants and did what they had asked us to do,” said Laux. “The results didn’t turn out the way they planned, so they started to criticize them.” DCNR Deputy Press Secretary Terry Brady responded, “Perhaps the findings aren’t what we think they should have been. We have serious concerns about the long-term effects of the lead as well as in the findings in their consultant’s report.”
“The intent of this department never was to surrender its right to contest findings or question long-term, protective measures,” Brady said. Nonetheless, if DCNR will not honor the results of the study, Laux wonders why the club paid for it in the first place. According to the club, the Western Pennsylvania Conservancy also looked at the site and found the levels of lead did not pose a risk to existing species. John Norbeck, DCNR’s Director of Parks, disagrees with the study’s findings. “I think that there is a serious issue at Black Moshannon. Lead is oxidizing and some of it is migrating into a wetland. They need to follow a good Environmental Stewardship Plan.”
All parties agree that the acidic soils found at the site could speed up the leaching of lead into the environment. Following Brusse’s risk assessments, the club contacted Dr. Richard Peddicord, a very well-known expert in lead management. Peddicord wrote the management plans for all of the Pennsylvania Game Commission shooting ranges. In addition, he has worked with the Environmental Protection Agency and the National Shooting Sports Foundation to develop best management practices for shooting ranges. He has consulted on lead management all over the world and throughout much of the United States. Peddicord’s job (again at club expense) was to do what Norbeck suggested — draw up an environmental stewardship plan for the PR&GC range. Peddicord’s plan — over 20 pages in length — outlines goals, objectives and actions for management of lead at the range. “My plan is a site-specific implementation of EPA guidelines for the Philipsburg Rod and Gun Club,” Peddicord said. “At some point, but not now, they will need to reclaim and recycle the shot to the extent practical. The lead at the one ‘hot spot’ can be easily stabilized with EcoBond, a product that makes lead inert to the environment,” Peddicord said. “In other areas, the acidic soil can be tested and its pH managed with applications of lime, while the club monitors the wetland. I’m convinced that we can do that — get into the recommended EPA soil acidity range — without changing the wetland.”
Peddicord also recommended that the club stop shooting at Trap 1, the trap closest to the wetland. Norbeck agrees that the trap should be shut down, and he even allows that the club could add a trap at the other end to replace Trap 1. However, Norbeck claims that many of Peddicord’s other actions do not go far enough. “The plan should contain a cocktail of things, including a cleanup of lead on the ground, chemical treatment of some of the lead in the soil, closing the trap that is closest to the wetland and an installation of a system that will make future lead easier to pick up,” Norbeck said. “We want them to do it right and I know that it can be done.”
DCNR cites a letter from the U.S. Fish and Wildlife Service, calling for vacuuming of lead, completing further ecological studies and having the club switch to non-toxic shot. It would be well within DCNR’s rights to terminate the lease with the PRGC. However, that would place the responsibility for clean-up directly on DCNR, and ultimately, the taxpayers would end up footing the bill. “One can always ask for further studies, but I personally see nothing wrong with Brusse’s work,” Peddicord said. “Nothing raises any eyebrows — it feels right.”
According to Peddicord, vacuuming lead at this site would be very impractical, and based on what has been attempted at other ranges, it probably would not work at all. “The club is willing to follow Peddicord’s stewardship plan,” said Laux. “He is the expert. DCNR is asking us to take impractical, expensive and unnecessary steps. Who are their experts? I know one thing for sure — we aren’t starting any cleanup or treatment unless we have a signed lease.”
According to Laux, many DCNR promises have been broken along the way. Club members have evidence to support their allegation that DCNR actually wants their land and clubhouse for use by a snowmobile club. It could be a stopping point along the proposed North-South Snowmobile Trail. The club claims that DCNR’s actions are just an excuse to remove the club. DCNR, of course, denies this. One thing for certain — at this point, the club’s level of trust is low and their level of frustration is high.
Seeing no other recourse, they have involved a number of elected officials. One of those is Sen. John Eichelberger (R-Blair), who has been involved for over a year. “In April, during the Senate confirmation process for (DCNR secretary) John Quigley, he promised me that if he was confirmed, he would have the club up and shooting again soon,” Eichelberger said. “As far as I know, the club has done everything that they have been asked to do. Since this is now September, we are long past any reasonable definition of the word, ‘soon.’”
Former PRGC president Bob Nuss puts it this way, “No matter what we do, they change the rules or add more to what they say we need to do. If any group did to DCNR what they are doing to us, they’d be in front of a judge so fast your head would spin. This has gone on for four years— it is just ridiculous.” Even though DCNR has also closed down the 7H Skeet Club range adjacent to Prince Gallitzin State Park last Thursday, John Norbeck looked me in the eye and said that DCNR was not opposed to having organized shooting ranges in state parks. If there is truly no hidden agenda, I do not see why the Philipsburg Rod and Gun Club had to stop shooting while the studies were being done. Nothing would have changed. If the club hired the top lead expert in the world, why is his plan not good enough? If the EPA is happy with the plan, why is State Parks not satisfied?
Eichelberger put it this way, “Something is amiss. When has DCNR become an environmental expert where they claim to know more than DEP or the EPA?” I hope that common sense prevails and that club members are soon able to use their shooting range again.
Mark Nale, who lives in the Bald Eagle Valley, is a member of the PA Outdoor Writers Association. He can be reached at MarkAngler@aol.com. Read more: http://www.centredaily.com/2010/09/05/2189472_throwing-lead.html#ixzz0yrY9e6KA
Mr. Bill Brusse is the Executive Vice President; the Northeast Regional Manager for Converse offices in New Jersey, New York, and Pennsylvania; and a registered Professional Geologist in Pennsylvania. Mr. Brusse is responsible the operation and management of the offices, staff development, technical management and the maintenance of long term working relationships with major clients in the Northeast Region. Mr. Brusse is an experienced Brownfield's consultant, presented a paper (Brownfield's in Small and Rural Communities) at a National Brownfield's conference; and has used and provided seminars on the Pennsylvania Land Recycling and Cleanup Standards Act.
Converse Consultants routinely provides lead, asbestos and other environmental surveys for public and private entities nationwide. For more information please contact:
bgeorge@converseconsultants.com.
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