DOE sites have firing ranges for their security personnel. The bullets used by the security personnel are made out of lead. During firing, they release trace amounts of lead, and often disintegrate upon impact with the target. How would lead released from the use of bullets in a firing range be reported on the Form R?
Releases from the firing of the bullets would be reported as fugitive releases to air - Part II, Section 5.1 of Form R. Lead in unrecovered bullets would be reported as releases to land: other disposal -- Part II, Section 5.5.4 of Form R. Lead in bullets that are recovered and sent off-site for disposal or recycling would be reported in the appropriate sections of the Form R. According to the EPA document, Compilation of Air Emission Factors (AP-42), approximately 1.2 pounds of lead is released as fugitive air emission for every 2,000 pounds of lead bullets fired (See Chapter 13, Section 3: Explosives Detonation). General guidance on reporting for lead can be found in the Lead and Lead Compounds Guidance for Reporting Releases and Other Waste Management Quantities of Toxic Chemicals.