The Mother Lode Gun Club in Jamestown has been engaged in a reclamation program since the summer of 2017 to mitigate potential discharge of lead into creek beds near its outdoor range.
The club closed its indoor shooting range on July 1, 2017 as a “precautionary measure” but the club is safe for use by its members and is not an environmental threat, the club’s lawyer, W. Lee Smith, of Michel & Associates in Long Beach said Wednesday.
Elevated lead levels have been found in a creek bed downstream of the property and high levels of lead have been found in the club’s indoor range and facility.
“The club is not in danger of currently being closed down for lead concerns,” Smith said.
In addition, he said the club has not incurred any current lead violations by a regulatory agency for both the indoor and outdoor ranges.
“The board of directors takes this very serious and they have been very proactive in addressing the program,” he said.
Mother Lode Gun Club President John Popke could not be reached for comment.
The Mother Lode Gun Club, established in 1939 and located on the 19100 block of Jamestown Road, is open to membership by citizens of the United States who “do not belong to any subversive group,” have not been convicted of a felony, and have a membership in the National Rifle Association.
The club is at maximum capacity of 850 members, the club’s website said, and has a waiting list.
Activities at the club include archery, big bore rifle, black powder, cowboy, trap, action pistol, and high-power rifle matches, according to their website. Besides the indoor range, the club has a trap range, a gong and five outdoor ranges for action pistols, at 25 yards, 50 yards, 100 yards, and 200 yards.
Bullets are usually composed of lead and fragments or particles can be produced when the bullet exits the gun and impacts a backstop. Parts of the shooting fall zone at the outdoor skeet range of the Mother Lode Gun Club are bare soil and the particles can be moved into larger waterways as runoff during storms.
Lead poisoning can damage the brain and nervous system, cause reproduction and digestive problems, and dysfunctions of the organs, muscles and joints.
In children, the effects are more pronounced and can generate behavioral issues, slowed growth or the impairment of basic cognitive and motor skills.
A continual exposure to lead, either by circumstance or through an occupation, can go unnoticed until symptoms arise and may lead to a premature death.
In May of 2017, Guy Chetelat, an engineering geologist with the Storm Water & Water Quality Certification Unit at the Central Valley Regional Water Quality Control Board, found that sediment downstream of the club was 230 mg/kg, below the federal guideline limit of 400 mg/kg for sediment in residential play areas used by children, but elevated when compared to likely background levels.
In a letter to the Mother Lode Gun Club, Chetelat said that erosion of lead-laden soil during a storm has the potential to transmit lead-polluted water via gullies that cross the outside skeet shooting area and flow into a seasonal creek on the southern boundary of the shooting range.
Woods Creek is south of the Mother Lode Gun Club, and another creek system is farther east near the Peppermint Creek subdivision and the O’Neil Reservoir.
“We’ve been looking at many shooting ranges in the state and seeing what the threat to water quality might be and asking for them to assess their stormwater runoff conditions and to make some improvements,” Chetelat said.
An Environmental Protection Agency manual, “Best management practices for lead and outdoor shooting ranges,” one of the primary documents used by gun clubs to regulate the potential environmental impact of lead-based pollutants, estimates that 4 percent of the two million tons of lead produced in the United States in the late 1990s was made into bullets and shot.
The manual stipulates that “much of this 160,000,000 pounds of lead shot/bullets finds its way into the environment at ranges” and that the lead contamination are a threat to hydrological settings, spreading to streams and ingested by fish or fowl in wetland environments.
“Lead is a known toxin,” Chetelat said. “It can be a pollution, yes it can be. But most of the ranges we have seen so far have not had a significant lead contamination getting off of site.”
Smith, who said he represented more than 100 ranges in California, said there had been no health concerns raised by the water control board investigation because the elevated levels of lead found in the creek bed sediment had not reached beyond the 400 mg/kg benchmark, which mandates a remedial action enforced by a state agency.
The club retained Holdrege & Kull, a Nevada City-based environmental consulting firm, to evaluate the site for lead migration and to draft a stormwater pollution prevention plan.
“Small amounts of spent lead shot were located in the upper creek-bed and significantly decreased as the creek-bed flowed down gradient,” Smith said in a letter to Chetelat.
The club is located on a sloping mountainside and the seasonal creek flows through the property into adjacent parcels.
Seven of 15 soil samples taken on the property were found to be above the threshold criteria for lead levels, but those samples were located in the shot-fall zone on the trap range, or in the bullet impact area where high lead levels were expected, he said in the letter.
The club has pursued a voluntary lead reclamation plan to contain the lead within the confines of the range and “pull out” as much lead from the environment as possible.
“They’re making sure that lead does not migrate off the ranges,” Smith said.
According to the EPA document, lead contamination can occur in the environment when oxidized lead is exposed to air, acidic water, and soil and subsequently dissolves, when lead bullets, bullet particles or dissolved lead can be moved by stormwater runoff, and dissolved lead migrates through soils into groundwater systems.
The club has instituted plans to keep storm water on the property to percolate and has installed a combination of wattles, berms, check dams, swales and silt fences to slow down the flow of water and “drop out any lead,” he said in the letter.
The EPA's action level for lead in water delivered to users of public drinking water systems is 15 micrograms per liter.
Indoor facility remains closed
John Moore, owner of hazardous materials abatement and demolition general contractor JM Environmental Inc. in Roseville, said he visited the Mother Lode Gun Club facility and submitted a $103,000 clean-up bid for the bullet trap, indoor range, all purpose range, swamp coolers and a confined space area above the indoor range, but the club declined the proposal.
“They wouldn't have had me there if they didnt have high lead levels. I mean it's bullets, its solid lead,” he said.
The evaluation of the indoor facility for lead levels was conducted by Entek, an environmental consulting group in Rocklin. A representative of Entek was not available to provide the exact micrograms of lead per square footage in the building. The United States Occupational and Safety and Health Administration has required limit of 30 micrograms of lead per cubic meter, averaged over an 8-hour workday.
The EPA also has set a standard for lead in the ambient air of a workplace at of 0.15 micrograms per cubic meter over a calendar quarter.
Initially, Moore proposed that the club pursue a release of reliability about the presence of lead in the indoor facility, but gun safety classes, which often involved young children in the facility, would not have been covered by the release.
“That was of high concern to them. They wanted to be compliant but the realities of doing lead remediation to an existing and functioning gun club that shoots lead bullets is very challenging,” he said.
Smith said the indoor range was closed by the club to be “proactive in the management of their range,” but he was not sure if minors were using the indoor range before it closed.
A clean-up would only temporarily solve the issues of lead contamination within the building, Moore said.
“You can remediate it, you can clean all the vertical and horizontal surfaces, clean the soil and remove the bullet but you’re back to where you were a month later because of the active shooting,” he said. “You go right back to shooting and you got lead dust again. It is what it is. If you're going to shoot guns with lead bullets you're going to expose yourself to lead.”
The Mother Lode Gun Club is holding a board meeting on May 14 and first among their unfinished business is a “lead abatement update.”
The agenda also references new business of an indoor range cleaning and reopening with limited use non lead bullets.