best management practices for lead at outdoor shooting … · bmp for lead at outdoor shooting...

United States EPA-902-B-01-001Environmental Protection January 2001Agency Region 2

Best Management Practices forLead at Outdoor ShootingRanges

For additional copies of this manual, please contact:

United States Environmental Protection AgencyDivision of Enforcement and Compliance AssistanceRCRA Compliance Branch290 Broadway 22nd Fl.New York, New York 10007-1866

Tel: 212-637-4145Fax: 212-637-4949

Copies of this manual along with any additions or updates can also be obtained on-line atwww.epa.gov/region2/waste/leadshot

Copying and Reprinting

This document is in the public domain and may be freely copied or reprinted.

BMP for Lead at Outdoor Shooting Ranges

Best Management Practicesfor Lead

at Outdoor Shooting Ranges

Notice

This manual is intended to provide useful general information to shooting range owners/operators.The United States Environmental Protection Agency (EPA) does not certify or approve ranges,range design or lead management practices. While every effort has been made to provide up-to-date technical information, this manual is not to be used as a substitute for consultation with scien-tists, engineers, attorneys, and other appropriate professionals who should be called upon to makespecific recommendations for individual range design and lead management.

Any variation between applicable regulations and the summaries contained in this guidance docu-ment are unintentional, and, in the case of such variations, the requirements of the regulationsgovern.

This guidance was developed by EPA Region 2 in cooperation with a few states as well as manyEPA offices. In addition, EPA, with the assistance of the Association of State and Territorial SolidWaste Management Officials (ASTSWMO) provided all 50 states with an opportunity to review theRCRA regulatory portion of the guidance. At the time of printing, about 40 states had contacted theEPA and given their support and concurrence. EPA is continuing to get the agreement of the re-maining states. Therefore, it appears that most, if not all, states will share the same view as to howlead shot is regulated.

Following the steps set forth in this guidance should result in compliance with applicable regulations.EPA does not make any guarantee or assume any liability with respect to the use of any informationor recommendations contained in this document.

This guidance does not constitute rulemaking by the EPA and may not be relied on to create asubstantive or procedural right or benefit enforceable, at law or in equity, by any person.

Notice


Acknowledgements

The USEPA would like to acknowledge the support of:

• The National Rifle Association of America• The National Shooting Sports Foundation• The Wildlife Management Institute• Mark Begley, of the Massachusetts Department of Environmental Protection• Mr. Dick Peddicord, of Dick Peddicord and Company, Inc.

These participants provided valuable information and assistance as peer reviewers in the develop-ment of the manual and their efforts are truly appreciated. EPA also wishes to give special thanks toDr. Charles W. Sever of Okie Environmental Consulting, L.L.C., Inc., Mr. Mike Warminsky of BriceEnvironmental Services Corp., and Mr. Victor Ordija of Sporting Goods Properties.The EPA alsowishes to acknowledge and thank the many others who provided important comments and insight,and especially those individuals who took the time to meet with us in person or on the phone.

Acknowledgements

Cover photo by: Mr. Jack Hoyt, EPA Region 2

BMP for Lead Management at Outdoor Shooting Ranges

Statement of Goals

The goals of this manual are:

� to inform shooting ranges :

� that the United States Environmental Protection Agency’s (EPA)purpose in developing and distributing this manual is to assist rangeowners and operators to operate in an environmentally protectivemanner.

� to promote an understanding of:

� why lead is an environmental, public and regulatory concern,

� what laws and regulations apply,

� the benefits of applying good management practices,

� what can be done to successfully manage lead,

� why implementing lead best management practices is an integral partof environmental stewardship,

� how to minimize litigation risk.

� to promote action by ranges to:

� adopt and implement best management practices for managing lead,

� recycle a finite natural resource,

� become a model for other ranges through properlead management,

� advocate environmental stewardship.

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Table of Contents - i


Best Management Practices for Lead atOutdoor Shooting Ranges

Table of Contents

Page

Introduction .......................................................................................................................v

Chapter I - Environmental and Regulatory Concerns at the Shooting Range ................ I-11.0 Background ............................................................................................... I-11.1 Impact on Human Health & Environment ................................................... I-21.2 Legal Requirements & Court Rulings ........................................................ I-61.3 Benefits of Minimizing the Environmental Impact of Lead ........................ I-12

Chapter II - Range Characteristics & Activities to Consider WhenImplementing BMPs ................................................................................. II-1

2.0 Background ............................................................................................... II-12.1 Physical Characteristics ........................................................................... II-12.2 Operational Aspects ................................................................................. II-42.3 Planning a New Range ............................................................................. II-4

Chapter III - BMPs for Outdoor Shooting Ranges ........................................................ III-13.0 Background ............................................................................................. III-13.1 Bullet and Shot Containment Techniques (Step 1) ................................... III-13.2 BMPs to Prevent Lead Migration (Step 2)................................................ III-53.3 Lead Removal and Recycling (Step 3) .................................................. III-113.4 Documenting Activities and Record Keeping (Step 4) ........................... III-173.5 Additional Economic Considerations ...................................................... III-183.6 Summary of Key BMPs for Rifle and Pistol Ranges .............................. III-18

List of Figures ...................................................................................................................iii

List of Tables .....................................................................................................................iv


Table of Contents - ii

References

Appendix A - Resources ............................................................................................... A-1

Appendix B - Lead Shot Alternatives ............................................................................ B-1

Appendix C - Bullet Containment Diagrams ....................................................................C-1

Appendix D - RCRA Regulatory Requirements and Interpretations ...............................D-1

List of Figures - iii


List of Figures

Figure Number Page

1-1 Effects on the Human Body from Excess Exposure to Lead I-5

2-1 pH Scale II-1

3-1 Four Steps to Build a Successful Lead Management ProgramUtilizing a Variety of BMPs III-1

3-2 Sample Filter Bed System III-10

3-3 Examples of Common Lead Reclamation Equipment III-11

List of Tables - iv


List of Tables

Table Number Page

1-1 Application of Key Terms to Outdoor Ranges I-10

2-1 Common Physical Characteristics at Ranges - Potential Riskand Benefits Associated with Range Operations II-3

3-1 Summary of Key BMPs for Achieving a Successful Rifleand Pistol Range III-19

3-2 Calculating Weight of Lime to Increase Soil pH Values III-6

Introduction

This manual provides owners and operators ofoutdoor rifle, pistol, trap, skeet and sporting clayranges with information on lead management attheir ranges. This manual serves as a referenceguide and presents best management practices(BMPs) available to the shooting rangecommunity. The practices have been proven toeffectively reduce or eliminate leadcontamination and may also be economicallybeneficial to the range owner/operator. Sinceeach range is unique in both the type of shootingactivity and its environmental setting, specificsolutions are not provided in this manual.Rather, a range owner or operator may use thismanual to identify and select the mostappropriate BMP(s) for their facility. Otherinformation on environmental aspects ofmanagement at outdoor shooting ranges can befound in the National Shooting SportsFoundations Environmental Aspects ofConstruction and Management of OutdoorShooting Ranges.

The manual does not address range layout ordesign to meet range safety or competitionrequirements. For information on range safetyand competition requirements, range owners/operators are directed to other comprehensivereference materials available on that subject,such as the National Rifle Association RangeSource Book, and the National Association ofShooting Range’s “Range Info.” website(www.rangeinfo.org).

Owners/operators of ranges may want toassign the use of this BMP Manual to aspecific team or committee. Delegating thisresponsibility to a specific team or grouphelps to assure that the BMP’s are identifiedand implemented.

The manual is organized as follows:

• Chapter I provides the background on whylead is of concern to human health and theenvironment. It includes a discussion of how

environmental laws impact shooting rangesand the importance of an integrated BMPprogram to manage lead.

• Chapter II discusses physical andoperational characteristics to be consideredwhen selecting a successful BMP program.

• Chapter III addresses best managementtechniques for rifle/pistol ranges, skeet andtrap ranges, and sporting clay ranges. In thischapter, the manual explores possiblesolutions to prevent, reduce and/or removelead contamination for each type of range.

• The Appendix provides current (as ofDecember 2000) contacts for leadreclamation and recycling companies,vendors that provide prevention and/orremediation techniques and shootingorganizations that have additional informationon the lead issue.

EPA is very interested in any suggestions youhave about practices included in this manualwhich have proven effective in controlling leadcontamination or recycling lead bullets/shots.Please send such information to the addressbelow. Also, for additional information, or to beadded to the list of lead reclaimers orremediation contractors, contact the NationalRifle Association (NRA), the National ShootingSports Foundation (NSSF) or:

Lead Shot CoordinatorRCRA Compliance Branch

U.S. Environmental Protection AgencyRegion 2

290 BroadwayNew York, New York 10007-1866

Telephone: (212)637-4145E-Mail: [email protected]

Introduction - v



Chapter I - Page I-1

Chapter I: Environmental and Regulatory

Concerns at the Shooting Range

1.0 Background

Outdoor shooting ranges provide recreationalfacilities for millions of shooting sportsenthusiasts in the United States. Recently, therehas been a growing public concern about thepotential negative environmental and healtheffects of range operations. In particular, thepublic is concerned about potential risksassociated with the historical and continued useof lead shot and bullets at outdoor ranges.

This concern is not unfounded. An estimated9,000 non-military outdoor ranges exist in theUnited States, collectively shooting millions ofpounds of lead annually. Some ranges haveoperated for as long as several generations.Historical operations at ranges involved leavingexpended lead bullets and shot uncollected onranges. Many of these ranges continue tooperate in the same manner as in the past.

It is estimated that approximately four percent(4%) (80,000 tons/year) of all the lead producedin the United States in the late 1990’s (about 2million tons/year), is made into bullets and shot.Taking into account rounds used off-range, androunds used at indoor ranges, it is clear thatmuch of this 160,000,000 pounds of lead shot/bullets finds its way into the environment atranges.

Since the mid-1980’s, citizen groups havebrought several lawsuits against range ownersand have urged federal and state agencies totake action against owners and operators ofoutdoor shooting ranges. The citizen groupsargued that range owners improperly manageddischarged lead bullets and shot. Federal courtshave supported parts of these suits, requiringrange owners/operators to clean up lead-contaminated areas. Concurrent with theincreased citizen suit activity, the federal EPA,and the Centers for Disease Control and

Prevention (CDCP), and a large number ofstates have identified human exposure to allforms of lead as a major health concern in theUnited States.

Lead management practices at ranges acrossthe United States remain inconsistent. Somerange owners/operators have examined theimpact of range operations on human health andthe environment and have implementedprocedures to manage and/or removeaccumulated lead from ranges. Other rangeowners/operators are just beginning tocharacterize and investigate their ranges inorder to design an environmental risk preventionand/or remediation program(s) specific to theirsites. A third group of ranges has adopted a“wait and see” policy – taking no action untilspecifically required to do so by law or clearguidance is in place. Finally, a fourth, small, butimportant group of range owners/operatorsremain unaware of lead’s potential to harmhuman health and the environment, and ofexisting federal and state laws.

To manage lead, many owners and operatorshave successfully implemented BestManagement Practices (BMPs) at their ranges.These range owners and operators haverealized many benefits from sound leadmanagement including:

- stewardship of the environment, naturalresources and wildlife,

- improved community relations,- improved aesthetics of the range/good

business practices,- increased profitability through recovery/

recycling lead, a valuable and finite resource,and

- reduced public scrutiny.

Shooting sport organizations [e.g., National RifleAssociation (NRA) and the National ShootingSports Foundation (NSSF)] promote leadmanagement throughout the United States.These organizations have researched differentmethods to effectively address potential andactual lead mobility and exposure withoutdetracting from the enjoyment of the sport. TheNRA and NSSF strongly encourage range



owners/operators to develop a BMP programthat contains elements discussed later in thismanual. Contact the NRA and NSSF foradditional guidance materials available on leadmanagement practices.

By implementing appropriate lead managementat outdoor shooting ranges, range owners andoperators can reduce the environmental andhealth risks associated with lead deposition,meet legal requirements and realize quantifiablebenefits.

1.1 Lead Contamination’s Impacton Human Health andEnvironment

Exposure Routes

Historically, the three major sources for humanexposure to lead are lead-based paint, lead indust and soil and lead in drinking water.Typically, human exposure occurs throughingestion, which is the consumption of lead orlead-contaminated materials, or by inhalation.The main human exposure to lead associatedwith shooting ranges is through lead-contaminated soil. However, other pathways arediscussed below, along with lead’s detrimentaleffects on humans and animals.

Lead can be introduced into the environment atshooting ranges in one or more of the followingways. Each of these pathways is site-specificand may or may not occur at each individualrange:

• Lead oxidizes when exposed to air anddissolves when exposed to acidic water orsoil.

• Lead bullets, bullet particles, or dissolvedlead can be moved by storm water runoff.

• Dissolved lead can migrate through soils togroundwater.

Lead oxidizes when exposed to air anddissolves when exposed to acidic water or soil

When lead is exposed to acidic water and/or

soil, it breaks down by weathering into leadoxides, carbonates, and other solublecompounds. With each rainfall, thesecompounds may be dissolved, and the lead maymove in solution in the storm runoff waters.Decreases in water acidity (i.e., increases in itspH) will cause dissolved lead to precipitate out ofsolution. Lead concentrations in solution arereduced by this precipitation. At pHs above 7.5,very little lead remains in solution. Increasedtime of contact between lead and acidic watergenerally results in an increase in the amount ofdissolved lead in the storm runoff water. The fivefactors which most influence the dissolving oflead in water are summarized below:

Annual Precipitation Rate - The higher theannual precipitation rate, the faster the leadweathers. Also, during prolonged rains, thecontact time between water and lead isincreased. In general, the higher theprecipitation rate, the higher the potential risk oflead migration off-site in solution.

pH of Rain and Surface Water - The acidity ofthe rainwater decreases as basic (alkaline)minerals in the soil are dissolved. If sufficientminerals such as calcium, magnesium, and ironare present in local soils, then the lead mayquickly precipitate out of solution entirely asthese other minerals are dissolved. The pH ofshallow surface water is an indicator of thepresence or absence of basic minerals in thelocal soil and in gravel within the stream bedsthrough which the water has moved. The waterin deeper streams and lakes is more likely to becomposed of acidic rainwater that is notneutralized.

Contact Time - The contact time betweenacidic surface water and lead is a factor in theamount of lead that is dissolved. For example,lead shot deposited directly into a lake has alonger contact time then lead shot deposited inupland areas.

Soil Cover - Organic material will absorb leadand remove it from a water solution. The thickerthe organic leaf and peat cover on the soil, thelower the lead content in solution in water leavingthe shot area. Organic material has a strong



ability to extract lead out of solution in water.pH of Groundwater - During periods of norainfall, the water flowing within most streamscomes from groundwater discharging into thestream channel. Therefore, the acidity of thegroundwater affects the acidity of the surfacewater, and hence, affects the solubility of anylead particles carried into the stream duringstorm runoff.

Lead bullets, bullet particles or dissolved leadcan be moved by storm water runoff

The ability of water to transport lead is influencedby two factors: velocity of the water and weightor size of the lead fragment. Water’s capacity tocarry small particles is proportional to the squareof the water’s velocity. Clear water moving at avelocity of 100 feet per minute can carry a leadparticle 10,000 times heavier than water movingat a velocity of 10 feet per minute. Muddy watercan carry even larger particles. The five factorsthat most influence velocity of runoff aredescribed below:

Rainfall Intensity - The greater the volume ofrainfall during a short period of time, the fasterthe velocity created to carry the rainfall off-site.The higher the annual rainfall, the greater thenumber of periods of heavy rainfall.

Topographic Slope - Generally, the steeper thetopographic slope, the faster the velocity ofstormwater runoff.

Soil Type - More rainfall will soak into sandysoils then into clay soils. Hence, for a givenrainfall intensity, the volume of runoff will begreater from areas underlain by clays or otherlow permeable soils than from permeable sandysoil.

Velocity - Velocity tends to decrease as streamwidth increases. Merging streams, eddycurrents, and curves in streams are other factorsthat may reduce the velocity. Generally, theshorter the distance from the lead deposit to theproperty line, the more likely it is that the leadfragments in suspension will be transported off-site.

Vegetative Cover and Man-made Structures -Structures such as dams and dikes reduce thewater’s velocity and greatly reduce the size andweight of the lead particles the water can carry.Since lead particles are heavy compared to theother suspended particles of similar size, theyare more likely to be deposited under theinfluence of anything that reduces velocity of thestorm runoff. Grass and other vegetationreduce runoff velocity and act as a filter toremove suspended solids from the water.

Dissolved lead can migrate through soils togroundwater

Acidic rainwater may dissolve weathered leadcompounds. A portion of the lead may betransported in solution in groundwater beneathland surfaces. Groundwater may transport leadin solution from the higher topographic areas tothe lower areas such as valleys, where it isdischarged and becomes part of the surfacewater flow. If the water flowing undergroundpasses through rocks containing calcium,magnesium, iron, or other minerals more solublethen lead, or through minerals that raise the pHof the water, then the lead in solution may bereplaced (removed) from the solution by theseother metals. However, if the soil is a cleansilica sand and gravel, fractured granite, orsimilar type material, then the lead may movelong distances in solution. The factors mostlikely to affect the amount of lead carried by thegroundwater in solution are discussed below:

Annual Precipitation - Generally, highprecipitation rates result in heavy dew, morefrequent rainfall, numerous streams, shallowdepth to groundwater, shorter distance of travel,and more rapid rates of groundwater flow. Also,the greater volumes of rainfall over geologic timeprobably have reduced the amount of calciumand other soluble basic minerals that could raisethe water pH and cause lead to precipitate(settle) out of solution from the groundwater.

Soil Types - Clays have a high ionic leadbonding capacity and more surface area towhich the lead can bond. Also, groundwatermovement in clay is very slow, which increasesthe contact time for lead to bond to the clay.



Low permeability reduces the amount ofhistorical leaching and increases the probabilityof the presence of basic (+pH increasing)minerals that can precipitate out of solution ingroundwater or cause the lead to bond to theclay. All of the basic calcium and relatedminerals generally will have been removed fromthe clean silica sand and gravel soils, so thelead in solution in groundwater in these typesoils can move long distances (miles) throughthe ground relatively unchanged.

Soil Chemistry - The more basic minerals likecalcium and magnesium that are present in soilsalong the pathways through which thegroundwater moves, the greater the leadprecipitation (removal) rate. Lead should movein solution only a short distance (a few feet)through a sand composed of calcium shellfragments, but could move in solution longdistances (miles) through clean quartz sand.

Depth to Groundwater - In areas ofgroundwater discharge such as river flood plainsand most flat areas, the groundwater surface isoften a few feet below the surface. Remember,the shorter the distance traveled, the greater therisk that the lead will migrate into theenvironment. Shallow depth to groundwater isindicative of higher risk for lead to reach thewater.

pH of Groundwater - Although other factorsinfluence solubility of lead in water, a good rule ofthumb is that lead will precipitate out of solutionwhen the pH or alkalinity of water is greater thenabout 7.5. But, lead dissolved in acidgroundwater may travel many miles withoutchange.

Health Effects of Lead Exposure on Ranges

Lead poisoning is a serious health risk. Athigher concentrations, it is dangerous to peopleof all ages, leading to convulsions, coma andeven death. At even very low concentrations, itis dangerous to infants and young children,damaging the developing brain and resulting inboth learning and behavioral problems. Figure 1-1 describes the effects of exposure to lead onchildren and adults.

Federal, state and local actions, including banson lead in gasoline, paint, solder and many otherlead-containing products, have resulted insignificant reductions in average blood-leadlevels. Despite these advances, the number oflead-poisoned children remains alarmingly high.Children living in older homes may be exposedto lead in peeling paint or paint dust. Childrencan also come in contact with lead in soil andwith lead dust carried home on the clothing ofparents.

On ranges, inhalation is one pathway for leadexposure since shooters are exposed to leaddust during the firing of their guns. Becausewind is unlikely to move heavy lead particlesvery far, airborne dust is generally considered apotential threat only when there are significantstructures that block air flow on the firing line.Under such conditions, the hygiene and otherpractices proposed by the NRA for indoorshooting ranges in their “Source Book” areapplicable to outdoor ranges.

Range workers may also be exposed to leaddust while performing routine maintenanceoperations, such as raking or cleaning out bullettraps. Owners/operators may want to protectthese workers by requiring them to wear theproper protective equipment or dampening thesoil prior to work.

Another exposure route for lead at outdoorranges is ingestion by direct contact with lead orlead particles. For example, lead particlesgenerated by the discharge of a firearm cancollect on the hands of a shooter. Theseparticles can be ingested if a shooter eats orsmokes prior to washing his/her hands aftershooting. The relative risk of lead exposure topeople in a well managed facility is low.

Detrimental effects due to elevated lead levelscan also be found in animals. Excessiveexposure to lead, primarily from ingestion, cancause increased mortality rates in cattle, sheepand waterfowl. For example, waterfowl andother birds can ingest the shot, mistaking it forfood or grit. Waterfowl, in particular, are highlysusceptible to lead ingestion. This is a concernat ranges where shooting occurs into or over



Effects on the Human Body from Excessive Exposure to Lead

If not detected early, children with relatively low levels of lead (as low as 10microgram/deciliter for children) in their bodies can suffer from:

- damage to the brain and nervous system,- behavior and learning problems (such as hyperactivity and aggressiveness),- slowed growth,- hearing problems,- headaches, and- impairment of vision and motor skills.

Adults can suffer from:

- difficulties during pregnancy,- reproductive problems in both men and women (such as low birth- weight, birth defects and decreased fertility),- high blood pressure,- digestive problems,- neurological disorders,- memory and concentration problems,- muscle and joint pain, and- kidney dysfunction.

Brain or Nerve Damage

Slowed Growth

Hearing Problems

Digestive Problems

Reproductive Problems(Adults)

Lead affects thebody in many ways

Figure 1-1: Effects on the Human Body from Excessive Exposure to Lead



1.2.1 Resource Conservation andRecovery Act (RCRA)

RCRA provides the framework for the nation’ssolid and hazardous waste managementprogram. Under RCRA, EPA developed a“cradle-to-grave” system to ensure theprotection of human health and the environmentwhen generating, transporting, storing, treatingand disposing of hazardous waste. RCRApotentially applies to many phases of rangeoperation because lead bullets/shot, ifabandoned, may be a solid and/or a hazardouswaste and may present an actual or potentialimminent and substantial endangerment.

Connecticut Coastal Fishermen’sAssociation v. Remington Arms Company, etal.

In the late 1980s, the Connecticut CoastalFishermen’s Association filed a lawsuit againstRemington Arms Company as the owner of theLordship Gun Club. The Lordship Gun Club(a.k.a. Remington Gun Club) is a 30-acre site inStratford, Connecticut, located on the LongIsland Sound at the mouth of the HousatonicRiver. In the mid-1960s, the Lordship Gun Clubwas reconstructed to its final configuration of 12combined trap and skeet fields and oneadditional trap field. Over the years, theLordship Gun Club became known as one of thepremier shooting facilities on the East Coast.

The Connecticut Coastal Fishermen’sAssociation filed a lawsuit, alleging that lead shotand clay targets are hazardous waste underRCRA. The Complaint alleged that because thelead shot and clay targets were hazardouswastes, the gun club was a hazardous wastestorage and disposal facility subject to RCRArequirements. The plaintiff also sought civilpenalties and attorney’s fees.

Remington moved for a summary judgmentdismissing the complaint, and the ConnecticutCoastal Fisherman’s Association cross-movedfor a partial summary judgment on the issue ofliability. On September 11, 1991, the UnitedStates District Court for the District ofConnecticut ruled on the case.

water. Many of the legal and government actionsthat have been brought against ranges arebased on elevated levels of lead, and increasedmortality in waterfowl. For example, in one case,an upland area of a range became a temporarypond after a thunderstorm. Waterfowl used thepond to feed and shortly thereafter, there was awaterfowl die-off (increase in bird mortality),apparently from lead ingestion.

1.2 Legal Requirements & CourtRulings

To date, most litigation concerns are at shotgunranges where the shotfall zone impacts water orwetland areas. The potential environmental andhuman health risks are greater at these ranges.However, all ranges, including those not locatednear water bodies, may be subject to legal andgovernment action if proper range managementprograms are not implemented. Range owners/operators should expect greater scrutiny asranges become more visible to regulators,environmental groups and the general public.

Citizen groups have been the driving forcebehind most legal actions taken against outdoorranges. These groups have sued range owners/operators under federal environmental laws. Twoof EPA’s most comprehensive environmentallaws, the Resource Conservation and RecoveryAct (RCRA) and the Clean Water Act (CWA),specifically provide citizens with the right to suein cases in which the environment and humanhealth are threatened. These citizen suits havebeen highly effective in changing the way rangesoperate, even when out-of-court settlementshave been reached. The decisions of the UnitedStates Court of Appeals for the Second Circuit inRemington Arms and New York Athletic Club seta legal precedent in the application of RCRAand/or the CWA to outdoor ranges. Leadmanagement programs at outdoor ranges mustcomply with both laws. Actions have also beentaken under the Comprehensive EnvironmentalResponse, Compensation and Liability Act(CERCLA) commonly know as Superfund.State and local statutes and regulations mayalso apply. To ensure environmental laws arebeing followed, range owners/operators mustunderstand the legal issues and requirements.



Regarding the plaintiff’s claims under RCRA, theDistrict Court ruled in favor of the ConnecticutCoastal Fishermen’s Association, holding thatthe lead shot and clay targets were “discardedmaterials” and were “solid waste;” therefore, thematerials were subject to regulation underRCRA. The court further stated that thedischarged lead shot was a “hazardous waste,”but declined to rule on whether the clay targetfragments were also hazardous waste.Remington petitioned the United States Court ofAppeals for the Second Circuit Court to reviewthe lower court’s ruling.

On June 11, 1992, both parties presented oralarguments before the court. Subsequent to oralarguments, the appellate court requested thatEPA file an amicus brief “addressing whetherlead shot and clay target debris deposited onland and in the water in the normal course oftrap and skeet shooting is ‘discarded material’...so as to constitute ‘solid waste’ under RCRA.”

On March 29, 1993, the United States Court ofAppeals for the Second Circuit reached itsdecision. With respect to RCRA, the court bothreversed and affirmed the lower court’s opinionin part.

Briefly, the decision affects currently operatingand future gun clubs, and the following keypoints are of primary concern:

1. With respect to RCRA, the court agreedwith EPA’s amicus brief, which had argued thatthe gun clubs are not subject to RCRA’sregulatory (as opposed to statutory)requirements. In other words, gun clubs are notviewed as facilities that manage hazardouswastes subject to RCRA regulations and, assuch, do not require RCRA permits.

2. Another argument in the EPA’s amicusbrief with which the court agreed was the viewthat the RCRA statute allows citizen suits to bebrought if a gun club’s shooting activities posean “imminent and substantial endangerment tohealth or the environment.” Although gun clubsare not subject to RCRA regulations, EPA orany state, municipality, or citizen group can takelegal action under the statutory provisions of

RCRA against gun clubs for actual or potentialenvironmental damage occurring during, or evenafter, the operation of the club. Under RCRA,the plaintiff would be eligible to recover its legalfees as well.

3. The court concluded that lead shot andclay targets meet the statutory definition of solidwaste because these materials were “discarded(i.e. abandoned)” and “left to accumulate longafter they have served their intended purpose.”Further, the court concluded that based upontoxicity testing and evidence of leadcontamination, the lead shot was a hazardouswaste subject to RCRA.

The important point to consider here is that iflead shot and clay target debris are discarded(i.e. abandoned), these materials are considereda solid waste as defined in the statute and thefacility may be subject to imminent hazardgovernmental or citizen suits.

If, on the other hand, the discharged lead shot isrecovered or reclaimed on a regular basis, nostatutory solid waste (or hazardous waste)would be present and imminent hazard suitswould be avoided.

Thus, the Remington Arms case is an importantlegal precedent. Even though regulations havenot been issued regarding gun club operationand environmental protection, gun clubs are stillat risk of legal action.

Gun clubs where there is shooting into water,wetlands, rivers, creeks, and other sensitiveenvironments have the highest degree oflitigation risk. Conversely, gun clubs that havethe lowest risk of environmental litigation orgovernment action are those clubs that do notshoot into water or wetlands and which have anactive program to recover lead.

The following describes how RCRA may applyto outdoor shooting ranges.

How is Lead Shot Regulated UnderRCRA?

Lead shot is not considered a hazardous waste



subject to RCRA at the time it is dischargedfrom a firearm because it is used for its intendedpurpose. As such, shooting lead shot (orbullets) is not regulated nor is a RCRA permitrequired to operate a shooting range. However,spent lead shot (or bullets), left in theenvironment, is subject to the broader definitionof solid waste written by Congress and used insections 7002 and 7003 of the RCRA statute.

With reference to reclaiming and recycling leadshot, the following points should serve asguidance in understanding RCRA and how itapplies to your range. (A more detaileddiscussion of the underlying RCRA rulesapplicable to lead shot removal at ranges isincluded in Appendix D)

• Removal contractors or reclaimers shouldapply standard best managementpractices, mentioned in this manual, toseparate the lead from soil. The soil, ifthen placed back on the range, is exemptfrom RCRA. However, if the soil is to beremoved off-site, then it would requiretesting to determine if it is a RCRAhazardous waste.

• Lead, if recycled or reused, is considereda scrap metal and is, therefore, excludedfrom RCRA.

• Collected lead shot and bullets are excludedfrom RCRA regulation, and need not have amanifest, nor does a range need to obtain aRCRA generator number (i.e., the range isnot a hazardous waste “generator”), providedthat the lead is recycled or re-used. Thereclaimer does not need to be a RCRAtransporter. However, it is recommendedthat ranges retain records of shipments oflead to the receiving facilities in order todemonstrate that the lead was recycled.Records should also be kept wheneverthe lead is reused (as in reloading). Therange should be aware that it ultimatelymay be responsible for the lead sent forreclamation. Therefore, only reputablereclaimers should be utilized.

• Sections 7002 and 7003 of the RCRA statute

allow EPA, states or citizens to use civillawsuits, to compel cleanup of or other actionfor “solid waste” (e.g., spent lead shot) posingactual or potential imminent and substantialendangerment. Such actions can be soughtwhether the range is in operation or closed,and is based solely on a determination thatharm is being posed or may be posed by therange to public health and/or the environment.Since the risk of lead migrating increases withtime, making ranges that have not removedlead more likely candidates for governmentaction or citizen lawsuits under RCRA Section7002 and 7003, ranges are advised tomaintain a schedule of regular lead removal.

• With time, lead in soil can become lessdesirable to reclaimers and smelters, therebypotentially reducing or eliminating financialreturns from lead removal. Moreover, suchsoil may be subject to more expensivetreatment to separate the lead for recycling.

• Lead removal will allow the range to: avoidcontamination of the site and potential impactsto human health and the environment; reduceliability with regard to potential governmentagency or citizen suit action; and, possibly,benefit economically from the recycling oflead. Additional guidance on reclaiming leadis provided in other parts of this manual.

• The above RCRA discussion applies to bothoperating and non-operating ranges. Theapplication of BMPs contained in this manualduring the life of the range is, of course, highlyrecommended. However, such applicationmay not preclude the need for remediation asappropriate, and as required by individualstates’ regulations when a range ispermanently closed and or abandoned or theland use changes and may result in potentialexposure to soil containing lead. Generalintroductory guidance for remediation can befound at www.epa.gov/epaoswer/osw orwww.epa.gov/superfund. Look under thesections “Cleanup” or “Resources,” or use theSearch function.



1.2.2 - Clean Water Act

The goal of the Clean Water Act (CWA) is to“restore and maintain the chemical, physical,and biological integrity of the Nation’s waters.”The most common allegation against ranges bythe EPA and citizen groups, is that they violatethe CWA if they do not have permits that allowspent ammunition to be discharged into water.The CWA prohibits “the discharge of anypollutant by any person” into the waters of theUnited States without a National PollutionDischarge and Elimination System (NPDES)permit. There have been two court cases thathave applied the provisions of the CWA tocivilian shooting ranges. To understand how theCWA can apply to shooting ranges, a summaryof the cases follows. Also see Table 1-1.

To understand the application of the CWA tooutdoor ranges, one must know the definitions ofkey terms and how they have been applied toshooting activities. See Table 1-1.

In the Remington Arms and the New YorkAthletic Club lawsuits, citizen groups argued thatthe defendants violated the CWA by dischargingpollutants from point sources into the LongIsland Sound without a NPDES permit.Application of the CWA requires the violations tobe ongoing. Consequently, the court inRemington Arms dismissed the CWA chargeagainst the range because it had ceasedoperating before the lawsuit was filed.

However, in the New York Athletic Club case,the club was still in operation during the time oflitigation, but had switched to steel shot. EPA’sopinion on this case also addressed the CWAviolation. EPA argued that certain trap/skeetranges can convey pollutants, via point sources,to water in violation of the CWA if a NPDESpermit is not obtained. Although some shootingorganizations have disagreed with the EPAposition, the United States District Court for theSouthern District of New York specifically foundthat:

• The mechanized target throwers, theconcrete shooting platforms, and theshooting range itself are considered point

sources as defined by the CWA;

• Expended shot and target debris, includingnon-toxic shot, such as steel shot, left inwater are pollutants as defined by the CWA.

Although the New York district court’s decision inthe New York Athletic Club case is notcontrolling in any other district, range ownersand operators of outdoor ranges that shoot overor into wetlands or other navigable waters of theUnited States should be aware of it.Based on the court’s decision in the New YorkAthletic Club case, any range whose shot,bullets or target debris enter the “waters of theUnited States” could be subject to permittingrequirements as well as governmental or citizensuits. “Waters of the United States” or“navigable waters of the United States” arewaters of the United States, including territorialseas that include any body of water that has anyconnection to, or impact on, interstate waters orcommerce. The waters may include lakes,ponds, rivers, streams, wetlands, or even gutsthat are frequently dry, which may not beobvious to range owners/operators. Theseranges may be required to remediatecontaminated sediments and soils, which couldbe both difficult and expensive, and to ceaseoperations over waters and wetlands. It isstrongly recommended that these rangeschange the direction of shooting, to avoidshooting over or into wetlands or othernavigable waters of the United States, andinitiate lead removal and recycling activities.

In addition, these ranges can cause asubstantial impact on wildlife and wetlands,which range owners/operators may be requiredto restore under other federal laws (e.g.,CERCLA, discussed below). Lead shotentering a water body substantially increasesthe potential risk of contaminating surface andgroundwater which, in turn, threatens humanhealth and the environment. Finally, as NewYork Athletic Club, Remington Arms and similarcases show, neighbors have the most leveragewhen range activity affects wetlands andwaterways.

For ranges located away from coastal areas or



Table 1-1: Application of Key Terms to New York Athletic Club



1 The term “land” in this instance refers specifically to terrainrecognized as “non-wetland” areas.

whose operating areas are situated wholly overland, compliance with the CWA can be achievedby obtaining a NPDES permit for piped orchanneled runoff from the range into water

1.

Shooting ranges impacting wetland areas maybe subject to other regulations found in Section404 of the CWA. This section is the principalfederal regulatory program protecting theNation’s remaining wetland resources. Anyplans for range owners/operators to dredge and/or fill wetlands will come under close scrutiny bythe federal, state and local governments andcitizen groups. Range owners/operators mustcomply with the CWA when range design,redesign, construction, reclamation orremediation occurs in wetland areas.

1.2.3 Comprehensive EnvironmentalResponse, Compensation, andLiability Act (CERCLA)

The Comprehensive Environmental Response,Compensation, and Liability Act (CERCLA),imposes liability on past and present owners oroperators of properties where a release of ahazardous substance into the environmentexists. CERCLA is typically used when a party,either the government or private party, hascleaned up someone else’s contamination, andseeks reimbursement from past owners/operators or disposers (potentially responsibleparties or PRPs). Under CERCLA, lead isconsidered a hazardous substance.

EPA has the authority to order a PRP to clean upa site or conduct the cleanup and recover itscosts from the PRP under CERCLA.Responsible parties may be held liable for allcleanup costs, which can be substantial. UnderCERCLA, shooting ranges may be liable forgovernment costs incurred during the cleanupof ranges, natural resources damages, andhealth assessments and/or health effectsstudies. The following two examples illustratehow shooting ranges (including one operated bythe federal government) can be affected byCERCLA.

Southern Lakes Trap and Skeet Club Site,Lake Geneva, Wisconsin, et al.

In 1992, the US Fish and Wildlife Service(USFWS) began an investigation to determinethe cause of death of over 200 Canada geese.The geese died as a result of acute leadpoisoning after ingesting lead shot, whichresearch indicated came from the SouthernLakes Trap and Skeet Club. The USFWS, in itsrole as Natural Resource Trustee, took action torecover the cost of damage to the naturalresources (i.e., migratory geese) underCERCLA. In addition, EPA pursued a separateaction under the Agency’s CERCLA responseauthority. The club had leased the property fromthe property owners to operate a shooting range.Shortly after EPA sent out the notice of potentialliability to the current and former owners andoperators of the club site, the club closedpermanently.

In 1994, EPA issued an Administrative Order onConsent (AOC) against one current and oneformer owner of the property where the nowclosed Southern Lakes Trap and Skeet Club waslocated. The AOC required the owners toperform a site assessment, which included anevaluation of the costs to restore the wetlands.In 1998, EPA completed activities to clean up thesite and restore some of the natural resourcesand wetlands. In a negotiated settlement, EPArecovered $1 million of the cost of the cleanup.

Walter L. Kamb v. United States Coast Guard,et al.

In another CERCLA action, Mr. Kamb (courtappointed property guardian) sued the U.S.Coast Guard, California Highway Patrol, City ofFort Bragg, and the County of Mendocino (thedefendants) for recovery of cleanup costs underCERCLA. Mr. Kamb had been appointed by theMendocino County Superior Court to sell theproperty on behalf of the property owners. Theproperty was formerly used by defendants as arifle, pistol and trap range. Soil analysisindicated the presence of lead in the form ofleadshot, bullets, pellets, and dust. The courtfound the defendants were “responsible parties”(liable for cleanup costs) under CERCLA. No



apportionment of liability was made and the finaldetermination of each parties’ pro rata share ofthe response cost was deferred.

This case shows that range activity need notaffect a water body to trigger CERCLA liability.CERCLA is a powerful statutory authority thatcan greatly impact current and former rangeowners/operators. The statute allows forrecovery of damages to natural resources, thecost of any health assessment studies and allcleanup costs. Liability may extend to pastowners and operators long after a range ceasesoperation.

1.2.4 Additional Laws and Regulations

Shooting ranges may also be subject to stateand local laws and regulations. Many stateshave adopted their own environmental laws,which are based on federal laws. Specifically,these states have laws and regulations thatmirror the CWA and RCRA program laws. EPA-approved state program laws must be asstringent as the federal laws and may be morestringent. Activities at shooting ranges may alsobe subject to local laws, ordinances andregulations addressing issues such as noise,zoning, traffic, wetlands and nuisance. Often,citizens or neighbors of outdoor shooting rangescan initiate noise nuisance claims againstrange owners/operators. Because many stateshave passed legislation protecting ranges fromnoise nuisance lawsuits, these may turn intoclaims of environmental violations under thelaws discussed above due to the presence oflead and other products at ranges.

1.3 Benefits of MinimizingLead’s Environmental Impact

All ranges will benefit from proactivelyimplementing successful BMP’s. Even ifrange activities currently do not cause adversepublic health and environmental impacts, bydeveloping and promoting active leadmanagement programs, ranges will benefit in thefollowing ways:

• Through a sound lead management

program, shooting sports enthusiasts canreduce the potential of lead exposure andcontamination to humans, animals and theenvironment.

• A lead management program will result inimproved public relations for the rangeand the shooting sports. Ranges canpromote and publicize their successful BMPprograms to improve their public image.Since many of the legal and governmentalactions begin with or are due to citizengroups, an active lead management programmay improve the public image of the rangewith these citizen groups.

• The removal of spent lead from the rangepresents a clean, well maintained facility,which will increase customer satisfaction.

• Lead is a recyclable and finite resource andcan be recovered from the active portion ofranges and sold to lead reclaimers.Frequently, reclaimers do not charge rangeowners/operators to recover lead fromranges, and owners and operators mayreceive a percentage of the profit from thesale of reclaimed lead. This factor drivesrecycling efforts at many ranges.

• By reducing or eliminating a potentialsource of lead migration in soil, surfacewater and groundwater, range owners/operators may avoid costly and lengthyfuture remediation activities.

• Finally, implementing a BMP program forlead may eliminate or greatly reduce therisk of citizen lawsuits and the legal costsassociated with these lawsuits. Throughmanagement and removal practices, leadmay no longer represent a threat upon whichcitizen lawsuits are based.

Range owners/operators may question whetherthe benefits of a regular and timely BMP programoutweigh the efforts of implementing andmaintaining a program. The questions may ariseespecially for ranges at which shooting activitiesinvolve waterways, since national attention hasfocused on ranges located adjacent to water(e.g., Remington Arms and the New York Athletic



Club). However, all outdoor ranges may besubject to legal actions under RCRA andCERCLA authority. All of the benefits foradopting best management practices areavailable and worthwhile for every range ownerand operator.

The following sections provide information thatwill assist the range owner or operator inimplementing a BMP program for recovery andrecycling of lead shots and bullets.


Chapter II - Page II-1

2.1 Physical Characteristics

Physical characteristics of ranges, relative tolead management issues, are discussed below.

Range Size

Shotgun range design and type affects the easeof lead shot collection. Larger ranges typicallytend to have lead shot that is dispersed over awider area, while smaller ranges tend toconcentrate lead shot in a smaller area.Reducing the area of the shotfall zone willconcentrate the shot within a smaller area,allowing for easier cleanup and reclamation.BMP techniques for reducing the shotfall zone attrap and skeet ranges, as well as sporting clayranges, are discussed in Chapter III.

Soil Characteristics

Spent lead bullets and shot are most oftendeposited directly on and into soil duringshooting. When lead is exposed to air and water,it may oxidize and form one of severalcompounds. The specific compounds created,and their rate of migration, are greatly influencedby soil characteristics, such as pH and soiltypes. Knowing the soil characteristics of anexisting range site is a key component todeveloping an effective lead managementplan.

Soil pH

Figure 2-1 – pH scale

Soil acidity is measured as pH on a scale(illustrated as Figure 2-1) between 1 (mostacidic) and 14 (most alkaline, or basic), where 7is termed neutral. Ideal soil pH for shootingranges is 6.5 to 8.5.1

Chapter II:Range Characteristics &

Activities to Consider WhenImplementing Best Management

Practices (BMP)

2.0 Background

Since each firing range site is unique, BMPsfor lead must be selected to meet site-specific conditions in order to achievemaximum success. A range’s physicalcharacteristics and the operational aspects (e.g.,volume of shooting, shooting patterns andoperating schedules) will effect which BMPsmay apply and how they will be implemented.Accordingly, whether designing a new outdoorrange or operating an existing range, it isimportant that BMPs incorporate techniquesappropriate for the range’s individualcharacteristics.

Section 2.1 of this chapter identifies the physicalcharacteristics that must be considered whenevaluating your range. A summary of commonphysical characteristics at ranges is alsopresented in Table 2-1. These factors include:

Range Size (primarily for shotgun ranges)Soil CharacteristicsTopography/Runoff DirectionAnnual PrecipitationGround and Surface WaterVegetationAccessibility

Section 2.2 discusses the operational aspectsthat must be considered. These factors include:

Lead VolumeSize of Shot/BulletsOperating ScheduleShooting Direction and PatternRange Life Expectancy

In addition, Section 2.3 discusses issues thatare specific to implementing BMPs whenplanning a new range.

= Ideal Soil Range

1 National Shooting Sports Foundation, “Environmental Aspectsof Construction and Management of Outdoor Shooting Ranges,”June 1997.

1 2 3 4 5 6 7 8 9 10 11 12 13 14

Acidic Neutral Alkaline



arid regions. This is especially true of outdoorranges using “Steel Bullet Traps.”

Steel bullet traps build up a layer of lead residue;these particles are extremely small and moreeasily transported by rain/water. Also, thesmaller the particle, the quicker it will degrade. Abullet trap needs to have a means to collectcontact water, or be covered to prevent waterfrom reaching it, and to minimize releases anddegradation.

Topography/Runoff Directions

The topography of your range impacts both theease of lead reclamation and the mobility of thelead. For example, lead reclamation is moresuccessful at ranges where the shotfall zone isrelatively flat, since many lead reclamationcompanies use heavy machinery that cannotoperate on slopes or steep hills.

Another important characteristic is the directionin which your range topography slopes. Duringand after periods of rain, stormwater runoff maywash lead particles or lead compounds off therange. If there are surface water bodies such aslakes, rivers, or wetlands downgradient, thepotential for lead to adversely affect thesurrounding environment is even greater.Therefore, it is important to identify and controlthe direction of surface water runoff at yourrange. BMPs for modifying and controlling runoffare described in detail in Chapter III.

Groundwater

Groundwater depth should be consideredwhen developing a lead management plansince the closer the groundwater is to thesurface, the greater the potential fordissolved lead to reach it.

Vegetation

Vegetative ground covers can impact themobility of lead and lead compounds.Vegetation absorbs rainwater, thereby reducing

2 Heavy annual rainfall is anything in excess of the average annualrainfall, which for the northeast United States (e.g. New York, NewJersey) is between 40 and 45 inches.

Lead reacts more readily and may become moremobile under acidic (pH < 6) or higher alkaline(pH>8) conditions. This means that spent leadshot left in or on such soils may eventually breakdown and contaminate underlying soil. Inmoderately alkaline soils (pH 7 - 8.5), the leadprecipitates out of solution and binds to the soil.This “binding” effect prevents the lead frommigrating to the subsurface. In general, soils inthe eastern part of the United States tend to beacidic, whereas western soils tend to be morealkaline.

Soil Physical Characteristics

The migration rate of specific lead compounds isaffected by the physical characteristics of soil.For example, dense soils, consisting of heavyclays, will prevent the lead compound frommoving quickly through the subsurface. Any“free” lead ions become attached to clayparticles, with this bond helping to preventmigration. However, with denser soils, theamount of surface runoff increases.

Although clay soils inhibit migration, leadreclamation by contemporary removalmachinery tends to be more difficult in clayeyconditions. Clayey soils tend to clog thescreens and “bind” with shot and bullets. Thissituation may require additional traditionalscreening, or perhaps screening using water toenhance separation.

In contrast, sandy soils or gravel may notimpede migration because the open pores ofthese soils allow lead compounds to percolatequickly. Fortunately, lead reclamation activitiesare more easily conducted in sandy soils. Withthis in mind, ranges located in sandy soilsshould remove lead more frequently.

Annual Precipitation

One of the most important factors that influenceslead degradation (i.e., chemical reactions) andmigration is precipitation. Water, most often inthe form of rain, provides the means by whichlead is transported. In general, ranges located inareas with high annual/seasonal rainfall2 have ahigher risk of lead migration than those located in



Table 2-1 – Common Physical Characteristics at Ranges – Potential Risksand Benefits Associated with Range Operations



Shooting Direction and Patterns

Shooting directions and patterns areimportant to consider when determining theeffectiveness of bullet containment devices.For example, many bullet traps are effective incontaining bullets fired from specific directions.It is vital that you utilize bullet containmentdevices that match your range’s specificshooting patterns and manufacturersspecifications. Understanding the shootingdirection and patterns will also help to correctlyidentify the shotfall zone at trap and skeetranges.

Shooting into Water Bodies

Shooting into water bodies or wetlandsshould not occur. Besides the environmentalimpacts discussed previously, the introduction oflead to surface water bodies will likely cause arange to be susceptible to litigation and/orgovernmental action. Shooting into water bodiesor wetlands is NOT an option for ranges thatwant to survive in the future.

Range Life Expectancy and Closure

The life span of your range may be impacted bymany factors, including financial andenvironmental issues, noise, and encroachmenton residential areas. If your range is slated forclosure, contact your local state or EPArepresentatives for guidance.

2.3 Planning a New Range

As discussed in the previous sections, sitecharacteristics and operational aspects affectlead migration, degradation and reclamationactivities at ranges. If you are planning onopening a new range, you should select and/or design a site in consideration of thefactors discussed in this manual. This willallow you to minimize the potential of leadimpacting your site or adjacent properties. Anew range owner has the advantage of beingable to design a successful lead managementprogram in full consideration of the sitecharacteristics and recommended BMPs. Thisadvanced understanding of operational aspects

the time that the lead is in contact with water.Vegetation also slows down surface waterrunoff, preventing the lead from migrating off-site.However, excessively wooded areas (such asthose often used for sporting clay ranges) inhibitlead reclamation by making the soilsinaccessible to some large, lead-removalmachinery. Understanding the type,concentration and variety of vegetation on yourrange is necessary for developing your leadmanagement program and implementing BMPsat your range.

Accessibility

Accessibility to shotfall zones and backstopsis extremely important for lead reclamationactivities. A range that is not accessible toreclamation equipment will have difficultyimplementing lead reclamation practices.

2.2 Operational Aspects

Operating practices can have a great affect onthe volume and dispersion of lead at your range.

Lead Volume

Keeping records of the number of roundsfired over time at your range is important.The number of rounds fired provides a realisticestimate of the quantity of lead available forreclamation. This information helps to determinewhen reclamation is necessary in order toprevent accumulation of excess amounts oflead, thereby decreasing the potential for thelead to migrate off-site.

Size of Shot/Bullets

Knowledge of the size shot/bullets used onyour range may be helpful. Lead reclamationcompanies generally use physical screeningtechniques to separate lead shot and bulletsfrom soil. These screens come in a variety ofsizes. Knowing what size shot/bullets havebeen used at your range will allow the reclaimerto maximize the yield of lead shot/bullets at yourrange.



and requirements will allow you to minimize thepotential for lead migration prior to opening.

The most important site selection criteria toconsider when selecting a new rangelocation include: topography; surface waterflow patterns; and depth to groundwater. Ifpossible, ranges should be developed on flatterrain, as it facilitates reclamation and reducesthe chance of off-site migration due to surfacewater runoff as compared with highly slopedterrain. When considering a prospective locationfor a range, ask yourself: What is the direction ofsurface water runoff? Does the site drain tosurface water (e.g., streams, rivers) on-site?Off-site? Can the range design be modified tominimize potential runoff?

By selecting an appropriate location anddesigning a lead management program inconsideration of site characteristics, newshooting ranges can be developed tominimize the potential for leadcontamination. Other important sitecharacteristics can be modified. For example, anew shotgun range can be designed toconcentrate the shotfall area, vegetation can beadded or altered, and the most advantageousshooting direction can be selected. Thesemodifications are BMPs, and are discussed infurther detail in Chapter III.


Chapter III - Page III-1

Figure 3-1 – 4 Steps to Build a Successful Lead Management Program Utilizing a Variety of BMPs

Chapter III: Best Management Practices(BMPs) For Outdoor Ranges

3.0 Background

To operate an outdoor range that isenvironmentally protective requiresimplementing an integrated lead managementprogram, which incorporates a variety ofappropriate BMPs. These BMPs create a fourstep approach to lead management:

� Step 1 - Control and contain lead bulletsand bullet fragments

� Step 2 - Prevent migration of lead to thesubsurface and surrounding surfacewater bodies

� Step 3 - Remove the lead from the rangeand recycle

� Step 4 - Documenting activities andkeeping records

An effective lead management program requiresimplementing and evaluating BMPs from eachof the four steps identified above and illustratedas Figure 3-1. The BMPs discussed in Sections3.1 and 3.2 should not be consideredalternatives to lead reclamation, but rather

practices that should be followed between leadreclamation events.

It is important to note that the cost andcomplexity of these BMPs vary significantly. It isyour range’s individual characteristics thatwill determine which BMPs should beimplemented. The specific BMPs are describedmore fully below.

3.1 Bullet and Shot ContainmentTechniques (Step 1)

3.1.1 Bullet Containment

Knowing where spent lead is allows theappropriate BMP to be used. The singlemost effective BMP for managing lead inthese areas is by bullet containment.Owners/operators should employ acontainment system that allows for themaximum containment of lead on-site. Thecontainment systems mentioned in this sectionare for reference only. Each containment designfor a range is site specific. Each owner/operatormust look at the various factors in determiningwhich containment system is best for his or herrange. Some factors include: overhead, cost ofinstallation, maintenance (e.g., creation of leaddust from steel containment systems). Rangeowner/operators should consult with variouscontractors to determine which containmentsystem is best for their range.



1. National Rifle Association, “The NRA Range Source Book:A Guide to Planning and Construction,” June 1998

This section discusses BMPs for controllingspent lead bullets and fragments in a“controlled” and well-defined area behind thetarget area. Containing bullets and bulletfragments is critical to successfully managinglead.

There are a variety of containment deviceoptions available that serve as BMPs to controllead. The principle behind all of them is trappingand containing the actual bullet. They include:

� Earthen Berms and Backstops� Sand Traps� Steel Traps� Lamella or Rubber Granule Traps

For each type of trap, design variations havebeen developed to fit the specific needs of anindividual range. Below are discussions of eachgeneral category of trap. Some bulletcontainment devices are so comprehensive thatthey virtually eliminate lead’s contact with theenvironment.

However, it is important to discuss all types ofbullet containment devices because they arepart of comprehensive BMPs for managing leadat rifle and pistol ranges.

EPA does not endorse any bullet containmentdesign as being “better” than another. Differentcontainment designs attempt to eliminate lead’scontact with the environment, however,additional BMPs may be required for leadmanagement.

EPA recommends that you discuss yourrange’s bullet containment needs with avariety of vendors before deciding what typeof containment device to use. This manualdoes identify the possible advantages anddisadvantages associated with eachcontainment device in Table 3-1, at the back ofthis chapter.

Earthen Berms and Backstops

Perhaps the most common bullet containmentsystem at rifle and pistol ranges is the earthenbackstop (earthen material, i.e., sand, soil, etc.,

which is located directly behind the targets).The earthen backstop is generally between 15and 20 feet high with a recommended slope assteep as possible1. In many instances,backstops may be naturally occurring hillsides.When using an earthen berm or backstop,ensure that the uppermost layer (to a depth ofone to two feet) exposed to the shooting activityis free of large rocks and other debris. Thesematerials tend to increase ricochet and bulletfragmentation, which will, in turn, make leadreclamation activities more difficult, not tomention possible safety issues.

Removal of lead from earthen backstops mayrequire lengthy reclamation (see Section 3.3) ofthe soil to remove the lead. Continued use ofthe backstop without removing the lead mayresult in increased ricochet of bullets andfragments. In addition, the backstop may loseits slope integrity because of “impact pockets”that develop. Once the lead has been removedfrom the earthen backstop, the soil can beplaced back on the range and used again.Adding lime and phosphate during the rebuildingprocess is recommended as appropriate (seeSection 3.2). However, other bullet containmenttechniques, including those listed below, shouldbe considered prior to reestablishing an earthenbackstop.

Sand Traps

A variation of the earthen backstop is the sandtrap. Sand traps range from those that aresimply mounds of sand or soil located directlybehind the bullet targets, which serve asbackstops to a sand trap that employs a systemdesigned to contain, collect and control lead andcontact water. This sand trap uses a grade ofsand that is ballistically acceptable. Regularmaintenance must be performed to removelarger particles (bullets) from the impact area.These traps are placed so that bullets firedacross the range pass through the targets andbecome embedded in the sand. These trapsare typically 15 to 20 feet high with a slope assteep as possible. The most important design



criteria for these traps is that the uppermostlayer (to a depth of 1 to 2 feet) be free of largerocks and other debris to reduce ricochet andbullet fragmentation, and to facilitate reclamationefforts. There may also be an impermeablelayer (e.g., clay or liner) under the sand toprevent lead from contacting the soil underlayingthe trap.

Sand traps come in various designs and levelsof complexity. The sand trap may be ballisticgrade sand contained in a high backstop, or amore complex “Pit and Plate” system. The Pitand Plate system uses an angled, steeldeflection plate cover that helps to direct bulletsand bullet fragments to the top layer of sandonly. Some of the more sophisticated sandtraps incorporate lead recovery devices.However, the Pit and Plate may increase thesurface-to-mass ratio of the bullet splatter and,therefore, may increase environmental risk oflead migration.

Regardless of the type of sand trap that is used,the traps become saturated with bullets/bulletfragments. Once this happens, the sand mustbe sifted (see Section 3.3) to remove the bullets.The recovered bullets can then be sold to a leadrecycler (this is discussed in more detail later inthe chapter). After sifting, the sand can bereturned to the trap. Continued use of the trap,without removing the lead, may result in anincreased risk of ricocheting off the backstopand thus creating an increased safety hazard.Furthermore, the sand trap will become unstableover time. Sand traps may be located over animpermeable liner, to prevent lead fromcontacting soil underlying the trap. This willprovide additional protection to soil andgroundwater.

Steel Traps

Steel traps are located directly behind thetargets so that expended bullets, along withbullet particles, are directed into some form ofdeceleration chamber. Once inside thechamber, the bullets decelerate until the bullets/bullet particles fall into collection trays at thebottom of the deceleration chamber. When thetrap is full, or on a more frequent basis, the

spent lead can easily be reclaimed for recycling.

With some steel traps, expended lead bulletsmay not come in direct contact with soils,thereby possibly minimizing lead’s contact withthe environment. Consequently, the need forother BMPs (e.g., lime spreading, and/orengineering controls), such as those required atranges with unlined earthen backstops orunlined sand traps, may be avoided if this trapdesign is selected for the range’s bulletcontainment device. In addition, bullet removalis somewhat easier then a sand trap, and mayonly require emptying the bucket or traycontaining the bullets and/or bullet fragments.However, an increase of lead dust andfragmented lead may be an additionalenvironmental concern. Therefore,understanding the amount of lead dust andfragments is important to a successful leadmanagement program. Also, some steel trapdesigns are not intended for shooting at differentangles, therefore limiting the shooter to shootingstraight on (no action shooting).

As with sand traps, steel traps vary in designand complexity. For example, the EscalatorTrap has an upward sloping deflection plate thatdirects bullets into a spiral containment area atthe top. The Vertical Swirl Trap is a modular,free standing trap with four steel plates thatfunnel the bullets into a vertical aperture inwhich they spin, decelerate, and becometrapped in a bullet collection container. The WetPassive Bullet Trap is equipped with steeldeflection plates that slope both upward anddownward. The upwardly sloped deflectionplate is covered with an oil/water mixture to helpreduce the occurrence of ricochet and bulletfragmentation. The bullet follows its own path inthe round deceleration chamber for bulletrecycling.

Lamella and Rubber Granule Traps

The Lamella Trap uses tightly-hanging, verticalstrips of rubber with a steel backing to stopbullets. This trap is located directly behind thetargets and, in many cases, the targets mayactually be mounted to the trap. Lead removalrequires mining the bullets from the rubber. The



Rubber Granule Trap uses shredded rubbergranules, housed between a solid rubber frontand a steel backing, to stop bullets once theypass through the target. For both traps, thebullets remain intact, thus eliminating lead dustand preventing lead and jacket back splatter.Depending on the design of the rubber trap, thebullet either remains embedded in the rubberstrip or falls to the bottom of the trap, from whichthe bullets are removed for recycling.

These traps, when properly installed, areintended to increase safety by decreasing theoccurrence of back splatter and eliminating theintroduction of the lead dust into the air andground. However, there are several concernsover their use since they may:

� require additional maintenance;� may present a fire threat under extremely

high volume use (due to heat from frictioncreated upon bullet impact);

� not withstand weather elements over thelong term; and

� cause the rubber particles to melt to the leadbullets - making lead reclamation moredifficult.

Bullet Containment Innovation

Aside from the bullet containment devicesdiscussed above, there are new designs andinnovations continually being developed. One ofthese innovative bullet containment devices isShock Absorbing Concrete (SACON). SACONhas been used as a bullet containment devicesince the 1980’s and extensively field tested bythe military. SACON has not yet been availableas a backstop material for small arms ranges.When available for conventional rifle and pistolranges, SACON may provide a means to easilyreclaim lead. Additionally, crushed, lead-freeSACON can be recycled (re-casted) after bulletfragments have been removed by adding it toother concrete mixtures for use as sidewalks,curbs, etc.

3.1.2 Shot Containment

Reducing the Shotfall Zone

Unlike rifle and pistol ranges, the area impactedby lead shot fired at trap, skeet, and sportingclays ranges is spread out and remains primarilyon the surface. Knowing where spent lead isallows the appropriate BMP to be used. Thesingle most effective BMP for managing leadin these areas is by reducing the shotfallzones.

Concentrating the lead shot in a smaller areafacilitates lead management by providing asmaller and more dense area of lead to bothmanage in-place and reclaim, thereby makingthe management and reclamation processsimpler and more effective. To reduce theshotfall area at a range, owners/operators maychoose to modify the shooting direction.

Sporting Clays Courses

Technologies have been developed to assist inreducing the range size of trap and skeet, andsporting clays facilities. The National SportingClays Association (NSCA) has developed aFive-Stand Sporting Clays compact coursedesigned for shooting sporting clay targets. Thetargets are directed over a smaller area then inEnglish Style Sporting Clays (conventionalsporting clays). It was originally designed to beoverlaid on a conventional trap or skeet field andto be an alternative to English Style Sportingclays, which covers a much larger area. Anotherdesign, known as the National Rifle Association(NRA) Clays, is a portable target throwing unitwhich concentrates 15 rail-mounted machineson a two-story flatbed trailer. The NRA has alsodeveloped “compact sporting,” which isspecifically for sporting clay facilities. Thispractice alters the angle that the target is thrownto concentrates the shotfall zone.

Skeet Fields

The typical single skeet field has a shotfall zonethat is fan-shaped. For skeet fields with multiplestands sided-by-side, the shotfall zones wouldoverlap creating a shotfall zone that has a



2 National Shooting Sports Foundation, “EnvironmentalAspects of Construction and Management of Outdoor ShootingRanges,” June 1997

concentration of shot near the center of the fan.

Trap Fields

One way to reduce the shotfall zone at trapfields is to build the fields at an angle to oneanother. This will make the shape of theshooting dispersal pattern smaller and moreconcentrated. However, if you do decide tochoose this option, be aware of safety issueswhen designing the overlapping shotfall zones.

For a range with only one trap field, one way tominimize the shotfall zone is to keep trapmachines set in as few holes as possible (e.g.,the number two or three hole setting). Thisreduces the area of lead concentration bylimiting the angles for pigeon throwing, andtherefore the area for lead shot fall. However,when two or more trap fields are positioned sideby side, the shotfall zone will be continuousregardless of the “hole” setting.

3.2 BMPs to Prevent LeadMigration (Step 2)

This section discusses BMPs for preventing leadmigration. These BMPs include:

� Monitoring and adjusting soil pH� Immobilizing lead� Controlling runoff

These BMPs are important for all outdoorranges.

3.2.1 Monitoring and Adjusting Soil pH andBinding Lead

Lime Addition

The BMP for monitoring and adjusting soil pH isan important range program that can effect leadmigration. Of particular concern are soils withlow pH values (i.e., acidic conditions), becauselead mobility increases in acidic conditions sincethe acid of the soils contributes to the lead breakdown. The ideal soil pH value for shootingranges is between 6.5 and 8.5. This BMP isimportant because many soils in the eastern

United States have pH values lower than 6.2

To determine the pH of your soil, purchase a pHmeter at a lawn and garden center. The pHmeters are relatively inexpensive but valuabletools in the management of lead at your range.If the soil pH is determined to be below 6, thepH should be raised by spreading lime. It isrecommended that the pH be checkedannually.

One way to control lead migration is byspreading lime around the earthen backstops,sand traps, trap and skeet shotfall zones,sporting clays courses and any other areaswhere the bullets/shots or lead fragments/dustaccumulate. For example, lead mobilized inrainwater from the lead that spatters in front ofbackstops after bullet impacts can be effectivelycontrolled by extending a limestone sand layerout about 15 feet in front of the backstop.Likewise, spreading lime over the shotfall zonewill help to raise the pH of the very top soil layerto a pH closer to ideal levels and reduce themigration potential of lead. This is an easy, lowcost method. Spreading lime neutralizes theacidic soils, thus minimizing the potential for thelead to degrade. Lime can be easily spread byusing a lawn fertilizer drop spreader available atany lawn and garden center.

Smaller forms of limestone (powdered,pelletized, and granular) are better suitedbecause they dissolve and enter the soil morequickly then larger forms. However, the smallerthe forms of lime must be replenished moreoften. Conversely, limestone rock dissolvesmore slowly but does not need to be replenishedas often. The larger rock form is better suitedfor drainage ditches, where it can decrease leadmobility by raising the pH of the storm waterrunoff.

Another way to control lead migration in earthenbackstops is to break the capillarity within thebase of the backstop. Most porosity in the soilmaterial used in backstop is of capillary size,



Table 3-2 – Calculating Weight of Lime to Increase Soil pH Values*

* Lime requirements stated as pounds of lime/100 square foot of problem area for clay soils intemperate climates (i.e., Mid-Atlantic/Northeast US).

and, as a result, water is pulled upward into acapillary fringe within the base of the backstop.The height to which the water will rise in anearthen backstop depends on the soil material inthe backstop. Water will rise more then 6-feet inclay, 3.3-feet in silt, 1.3-feet in fine sand, 5-inches in coarse sand, and only 2-inches ingravel.

Because of capillarity, the spent bullets may bein contact with acidic rainwater for a longerperiod of time, hence more lead is dissolved.Breaking the capillarity by adding a layer oflimestone or gravel to the base of the backstopshould reduce the rate of deterioration of spentbullets, the erosion of the backstop, and theamount of lead going into solution in the water inthe backstop. Also, any lead dissolved shouldprecipitate out of solution as the acids areneutralized and the pH raised from the waterpassing through and reacting with the limestone.

Lime spreading is an especially importantmethod for implementing this BMP at sportingclays ranges where heavily wooded areas areless accessible to conventional lead removalequipment. These types of ranges also tend tohave more detritus (e.g., leaves, twigs, etc.) onthe ground, which can increase soil acidity asthey decompose. In these areas, semi-annualmonitoring of the soil pH levels issuggested.

Spreading bags of 50 pounds (at ranges withsandy soils) or 100 pounds (at ranges withclayey soils) per 1,000 square feet of range willraise the pH approximately one pH unit for aperiod of between one and four years,

respectively. The market price of lime in eitherthe granular or pelletized form should rangefrom approximately $2.00 to $4.00 per 50 poundbag.

Table 3-2 provides information for raising pHlevels of clay soils in temperate climates (i.e.,Mid-Atlantic/Northeast). Additional informationon the amount of lime to apply may also befound on the bags of the purchased lime and/orfrom the local lawn and garden center. It shouldbe noted that if the soil pH is below 4.5, theaddition of lime may only raise the soil pH toapproximately 5. In this situation, other BMPsshould be used as well. If the soil pH is abovethe ideal range upper value (8.5), do not addlime. Adding lime to a soil of this pH could resultin mobilization of the lead. Lime spreading maybe done at anytime during the year, exceptwhen the ground is frozen.

Additionally, it is important to remember tomonitor the soil pH annually, as theeffectiveness of the lime decreases over time.Additional routine applications will be necessarythroughout the life span of most ranges.

Phosphate Addition

In addition to lime spreading, another way tocontrol lead migration is phosphate spreading.This method is recommended where lead iswidely dispersed in range soils, a range isclosing, or there is a high potential for verticallead transport to groundwater (e.g., low soil pH,shallow water table). Under thesecircumstances, range soils may benefit fromphosphate treatment. Unlike lime spreading, themain purpose of phosphate spreading is not to



adjust soil pH but to bind the lead particles. Thisprocess also decreases the potential amount oflead that can migrate off-site or into thesubsurface. Phosphate spreading can be doneeither separately or in conjunction with limespreading. Generally, 15 to 20 pounds ofphosphate per 1,000 square feet will effectivelycontrol the lead.

Phosphate spreading is especiallyrecommended for sporting clays ranges andthose parts of ranges not easily accessible byreclamation equipment. Phosphate spreadingshould be repeated frequently during the range’slifetime. See pilot testing under “Other Ways toBind Lead” below for proper frequency forreplacing phosphate.

You can purchase phosphate either in its pureform, as phosphate rock, or as lawn fertilizer.The average lawn fertilizer costs approximately$7.00 per 40 pound bag. If you purchase lawnfertilizer, remember to check the bag for theactual percentage of phosphate. Most fertilizerscontain 25% phosphate, so that if you purchasea 40 pound bag of fertilizer that contains 25%phosphate (i.e., 10 pounds of phosphate) youwill need to spread 80 pounds of fertilizer per1,000 square feet of the backstop. A typicalfertilizer drop spreader can be used fordistributing the phosphate. Like lime, phosphateshould not be spread when the ground is frozen.In addition, it is not advised to use phosphatenear water bodies since it contributes to algalblooms. Rock phosphate is a better choice ifwater is nearby.

Other Ways to Bind Lead

Although it may be possible to minimize lead’smobility by spreading fertilizers that containphosphate at impacted areas of the range, amore comprehensive procedure for immobilizingleachable lead in soils, by using pure phosphatein rock form or a ground phosphate rock [TripleSuper Phosphate (TSP)], was developed andpatented by the USEPA/Ohio State UniversityResearch Foundation and RHEOX, Inc. Thisprocedure used a three step approach tominimize lead’s mobility. The first step was toidentify the boundaries of the area of the range

to be treated. This included not only determiningthe length and width of the range area, but alsothe depth of lead within the area.

Depth was determined by taking sample coresof the area, which also identified “hot spots”where lead accumulation was greatest. Oncethe area was identified, the second step was totreat the area with TSP. Pure phosphate rockwas used rather then fertilizers, as thisphosphate is insoluble in water and will notcause an increase in phosphate runoff. Inaddition, TSP pellets were approximately 80%minus 20 mesh size to ensure a uniformdistribution of TSP after blending with soil.

In this step, pilot testing was conducted. Here,various amounts (in increasing percentages byweight) of TSP were added to the affected soilareas, then the area was tested according to anEPA test method that identified the amount ofleachable lead in a given soil sample. This testis called the Toxicity Characteristic LeachingProcedure, or TCLP. Separate TCLP testing ofthe range’s hot spots was conducted. There hasbeen some discussion that the SyntheticPrecipitation Leaching Procedure (SPLP)proposed by the EPA may be a moreappropriate test.

Upon completion of the pilot testing, whichdetermined the amount of TSP needed at therange, the third step was to begin actualtreatment of the range. Where the depth of thelead accumulation was shallow (less than twofeet), then standard yard equipment, such astillers, seed/fertilizer spreaders, and plows wereused to mix TSP with the affected soil. Wherethe affected area’s lead accumulation wasdeeper than two feet, an auger was required tomix the TSP with the affected soil. Randomtesting of the range ensured the effectiveness ofthe treatment level.

3.2.2 Controlling Runoff

The BMPs for controlling soil erosion andsurface water run-off are important to preventinglead from migrating off-site. There are twofactors that influence the amount of leadtransported off-site by surface water runoff: the



amount of lead fragments left on the range andthe velocity of the runoff.

The velocity of the water can successfully becontrolled at outdoor ranges by: (1) usingvegetative, organic, removable and/orpermanent ground covers; and (2) implementingengineered controls which slow down surfacewater runoff and prevent or minimize thechances of lead migrating off-site. Bear in mindthat safety considerations and potentialricochets need to be considered whenimplementing any engineered controls.

Vegetative Ground Cover

Planting vegetative ground cover (such asgrass) is an important and easy erosion controlmethod. However, planting vegetative groundcover at shotgun range fields may not bepractical. Vegetation provides several benefitsby minimizing the amount of lead that will run offthe land surface during heavy rainfall. It isimportant to use a mixture of grass seeds toensure that the cover will last into the future (i.e.,annual rye grass lasts one year and dies andperennial rye grass lasts three to four years,then dies off). Fescue grasses form useful matsthat are effective in controlling erosion.

Ground cover absorbs rainwater, which reducesthe amount of water the lead is in contact with,as well as the time that the lead is in contactwith the water. Furthermore, the ground coverwill divert and slow down surface water runoff,thus helping to prevent lead from migrating off-site.

Grasses yield the greatest benefit at rifle andpistol ranges where the bullet impact areas aresloped, and water runoff and soil erosion maybe more likely. Specific recommendations areto:

� Utilize quick growing turf grass (such asfescue and rye grass) for the grass coveringof backstops, which can be removed prior toreclamation and replanted thereafter;

� Avoid vegetation that attracts birds and otherwildlife to prevent potential ingestion of leadby wildlife; and

� Use grass to direct surface water drainageaway from the target area (e.g., plantingthem at the top of the backstop or sand trap).This will minimize the water’s contact withlead bullet fragments, minimizing thepotential for lead migration.

Grass is not impermeable; however, it does slowdown the rate of flow and reduce the amount oflead entering the soil via rainwater. Remember,grass requires periodic maintenance (i.e.,mowing) to maintain its effectiveness as well asfor aesthetic reasons.

Mulches and Compost

Mulches and composts can reduce the amountof water that comes in contact with the leadfragments. In addition, mulches and compostcontain hermic acid, which is a natural leadchelating agent that actually sorbs lead out ofsolution and reduces its mobility. At a minimum,the material should be two inches thick. Thesematerials can be spread over any impacted areaand/or low lying areas where runoff and leadmay accumulate. Like vegetative covers,organic surface covers are not impermeable. Inaddition, the organic material needs periodicreplacement to maintain effectiveness andaesthetic integrity. Furthermore, these materialsshould be removed prior to any lead removalevent, as they may impede sifting or screening.Note that these materials tend to be acidic(especially during decomposition), so, if lowpH is a concern at your range, this optionmay not be appropriate. Again, however,lime may be used to control pH (see Section3.1.1)

Surface Covers

Removable Surface Covers

Removable surface covers may be effective atoutdoor trap and skeet ranges. In this case,impermeable materials (e.g., plastic liners) areplaced over the shotfall zone during non-useperiods. This provides the range with twobenefits during periods of rainfall: (1) the shotfallzone is protected from erosion; and (2) the spentlead shot is contained in the shotfall zone and



does not come in contact with rainwater.

Permanent Surface Covers

For outdoor rifle and pistol ranges, impactbackstops and target areas can also be coveredwith roofed covers or other permanent covers toprevent rainwater from contacting berms.However, this method may be less desirablebecause of the cost to install the roof, whichmust be carefully designed to avoid safetyissues with ricochets, etc.

For shotgun and other ranges, synthetic liners(e.g., asphalt, AstroturfTM, rubber, other syntheticliners) can also be used beneath the shotfallzone to effectively prevent rainwater or runofffrom filtering through lead and leadcontaminated soil. Synthetic liners will generateincreased runoff, which must be managed,however. No single type of liner is suitable for allsituations based on site characteristics.Therefore, liners must be chosen on a site-specific basis, bearing in mind the site’s uniquecharacteristics, such as soil type, pH level,rainfall intensity, organic content of soil, andsurface water drainage patterns.

Engineered Runoff Controls

Runoff control may be of greatest concern whena range is located in an area of heavy annualrainfall because of an increased risk of leadmigration due to heavy rainfall events. A “hard”engineered run-off control may be needed in thissituation. A heavy rainfall event is defined asrainfall that occurs at such a rate that it cannotbe absorbed into the ground and causes anincrease in the volume and velocity of surfacerunoff. The impacts of rainfall are greater inrolling or sloped terrain (increases velocity ofrunoff) or where surface water bodies arelocated on, or immediately adjacent to, therange.

Examples of “hard” controls include:

� Filter beds� Containment Traps and Detention Ponds� Dams and Dikes� Ground Contouring.

Designing and implementing these “hard”engineering controls may require the assistanceof a licensed professional civil engineer. Theyare included in this manual to offer the reader ageneral understanding of these BMP options.However, this manual does not offer specificinstructions for construction and operation ofthese controls. For information about designingand implementing any of these controls, orassistance with other range design questions,contact a licensed professional civil engineerhaving applicable experience or the NRA RangeDepartment, at (800) 672-3888, ext. 1417. TheNational Sports Shooting Foundation (NSSF)may be contacted at (203) 426-1320 for specificreferences regarding the use and design ofthese controls.

Filter Beds

Filter beds are engineering controls built into anoutdoor range to collect and filter surface runoffwater from the target range. The collectedrunoff water is routed to a filtering system, whichscreens out larger lead particles, raises the pHof the water (thus reducing the potential forfurther lead dissolution), and drains the waterfrom the range area. This technique may notcompletely prevent lead from entering thesubsurface, since lead bullets, fragments andlarge particles may still remain on the range.

Filter beds should be established at the base ofthe backstop (see Figure 3-2). In addition tomitigating off-site migration, the filter beds workto raise the pH of the rainwater, which has fallenon the target range, to reduce lead dissolution,and to strain small lead particles out of therainwater. The filters typically consist of twolayers: a fine-grained sand bed underlain bylimestone gravel or other neutralization material.By design, the backstops and berms direct therunoff so that it drains from the range to thefilters. The collected water then soaks throughthe top sand layer into the neutralizationmaterial, which raises the pH of the filtrate. Thelead particles in the rainwater are collected onthe sand, while the pH-adjusted water drainsthrough the filter to a perforated drainage pipelocated within the limestone gravel.



Figure 3-2 – Sample Filter Bed System (Adapted from Proceedings for National Shooting, Range Symposium,October 17-19, 1993, North American Hunting Club and Wildlife Forever)

Filter beds are designed to capture fine particlesof lead transported in surface water runoff.They are not designed to capture bullets. Theoperation and maintenance requirements of filterbeds are minimal. Maintenance activity is limitedto periodic removal of debris (such as litter,leaves, etc.) and occasional replenishment ofthe limestone.

The use of filter beds is most effective on siteswith open, rolling terrain where surface waterrunoff is directed to them. At existing rifle andpistol ranges, a limited system of trenches andfilters can be installed at the base of natural soilbackstops or at natural drainage depressions.

Containment Traps and Detention Ponds

Containment traps and detention ponds aredesigned to settle out lead particles duringheavy rainfall. Typically, they are depressionsor holes in the range’s drainage paths. Here,the lead-containing runoff passes through thetrap or pond, allowing the lead bullet fragmentsto settle out. Vegetative cover can be placed inthe drainage path to increase the effectivenessof containment traps and ponds by furtherreducing the velocity of runoff and allowing formore lead fragments to settle from the runoff. Itis important to regularly collect the lead andsend this lead to a recycler.

Dams and Dikes

At shotgun ranges, dams and dikes can also beused to reduce the velocity of surface waterrunoff. Dams and dikes must be positionedperpendicular to the direction of runoff to slowthe flow of surface water runoff. To accomplishthis, determine the direction of the range’ssurface water runoff. This will be particularlyobvious at ranges with sloped terrain. Thedams or dikes should be constructed usingmounds of dirt that are approximately a foothigh. These mounds should transect the entirerange perpendicular to the stormwater runoffdirection.

These runoff controls are most important atranges at which off-site runoff is a potentialproblem, such as ranges where the leadaccumulation areas are located upgradient of asurface water body or an adjacent property.Since lead particles are heavier than most othersuspended particles, slowing the velocity ofsurface water runoff can reduce the amount oflead transported in runoff.

Ground Contouring

Another mechanism to slow runoff and preventlead from being transported off site is groundcontouring. By altering drainage patterns, thevelocity of the runoff can be reduced.



Figure 3-3 – Examples of Lead Reclamation Equipment

Example of final separation device(Patented Pneumatic SeparationUnit) used with a Shaker System.Courtesy of MARCOR.

Example of shaker system.Courtesy of National Range Recovery

Furthermore, in areas where pH is high(resulting in a lower potential for leaddissolution), the soil can be graded or aerated toincrease the infiltration rate of precipitation, sothat rainwater is more easily absorbed into thesoil. This slows down or prevents surface waterrunoff and off-site migration. It should bepointed out that this design, in effect, collectslead in the surface soils. Therefore, rangeoperation and maintenance plans should includelead reclamation as well as adjusting the pH,and adding phosphate.

3.3 Lead Removal and Recycling(Step 3)

To successfully minimize lead migration, themost important BMP for lead management islead reclamation. Implementing a regularreclamation program will allow you to avoidexpensive remediation and potential litigationcosts. Ranges in regions with high precipitationand/or with acidic soil conditions may requiremore frequent lead recovery since the potentialfor lead migration is greater. In regions with little

precipitation and/or where the soil is somewhatalkaline, spent bullets may be allowed toaccumulate on the soil for a longer time betweenreclamation events. It should be noted that toensure that lead is not considered “discarded” or“abandoned” on your range within the meaningof the RCRA statute (i.e., a hazardous waste),periodic lead removal activities should beplanned for and conducted. This typicallyrequires one or more of the following:

� Hand Raking and Sifting� Screening� Vacuuming� Soil Washing (Wet Screening,

Gravity Separation, Pneumatic Separation)

These methods are discussed in detail below.Figure 3-3 provides examples of common leadreclamation equipment.

Also, it is important to be aware that stateregulations may require that the material beingsent for recycling have a minimum lead contentin order to qualify as a scrap metal that can be



shipped under a bill of lading (i.e., exempt fromRCRA).

Hand Raking and Sifting

A simple BMP that can be done by clubmembers, particularly at small ranges, is rakingand/or sifting bullet fragments from the soil.Sifting and raking activities should beconcentrated at the surface layer. This is a low-technology and low-cost managementalternative for lead reclamation. Once collected,the lead must be taken to a recycler or re-used.Arrangement with a recycler should be madeprior to collecting any spent lead to avoid havingto store the lead and avoid potential health,safety and regulatory concerns associated withstoring lead.

At trap and skeet ranges, conducting sifting andraking activities in the shot fall zone(approximately 125 - 150 yards from theshooting stations) will yield the most lead. Forsporting clay ranges, these activities should beconducted around tree bases, where lead shottends to collect. Basically, the process consistsof raking with a yard rake the topsoil in the shotfall areas into piles, as if you were raking leaves,removing any large debris (e.g., rocks, twigs,leaves, etc.), and then sifting the soil usingscreens.

Once the soil has been raked and collected,pass it through a standard 3/16 inch screen toremove the large particles. This process willallow the lead shot sized particles to passthrough the screen. The sifted material (thosenot captured by the 3/16 inch screen) should bepassed through a 5/100 inch screen to capturethe lead and lead fragments. This process willalso allow sand and other small sediment topass through the screen. Screens can bepurchased at many local hardware stores. Thescreens should be mounted on a frame forsupport. The frame size will vary based on thetechnique used by each range. For example, ifone person is holding the framed screen, it maybe better to use a smaller frame (2 feet by 2feet) whereas, if several people are holding theframed screen, it can be larger.

Raking and sifting can be performed by clubmembers on a volunteer basis. Some clubsprovide incentives, such as reduced fees, tomembers who assist with the lead removalprocess. Other clubs have hired collegestudents during the summer. A number of smallclubs have found that reloaders will volunteer torake in exchange for collected shot.Hand sifting and raking are cost effective leadremoval techniques for small ranges, or lowshooting volume ranges. However, thesetechniques may not be appropriate for situationsin which there is a large volume of lead on therange. In this instance, reclamation machinerymay be more appropriate.

Note: Those conducting the hand raking andsifting reclamation at ranges should protectthemselves from exposure to lead. Properprotective gear and breathing apparatusshould be worn. The Occupational Safetyand Health Administation (OSHA) or anappropriate health professional should becontacted to learn about proper protection.

Purchasing/Renting Mechanical SeparationMachinery

Reclamation equipment may be rented fromlocal equipment rental services. One type ofmachine that that it may be possible to rent forlead shot reclamation is known as a screeningmachine (also referred to as a mobile shaker,gravel sizer, or potato sizer). This device uses aseries of stacked vibrating screens (usually twoscreens) of different mesh sizes and allows theuser to sift the lead shot-containing soil[gathered by hand raking, sweeping, orvacuuming (discussed above)]. The uppermostscreen (approximately 3/16 inch mesh) collectslarger than lead shot particles, and allows thesmaller particles to pass through to the secondscreen. The second screen (approximately 5/100 inch mesh) captures lead shot, whileallowing smaller particles to pass through to theground. The lead shot is then conveyed to acontainer such as a five gallon bucket. In theNortheastern United States, the typical rentalcost for this equipment is between $500 and$4,500 a week, depending on the size shakerdesired. It may be possible to get more



information on rentals for this type of equipmentfrom heavy equipment rental companies.

Another possible option is to rent a vacuumsystem that will collect the lead shot-containingsoil from the range. Here, vacuuming takes theplace of hand raking or sweeping. A vacuummachine is used to collect the lead shot-containing soil. Once collected, the lead shot-containing soil must be sifted through ascreening system (either a rental screeningmachine, or a series of home made framedscreen sets). You may be able to obtain moreinformation about renting vacuums orvacuuming services (e.g., it may include aperson to operate the machinery),from heavyequipment rental companies.

Some clubs have found that performing theirown lead reclamation to be very timeconsuming. Part of the reason thesereclamations took so long is that the soils werewet. Reclamation is much easier under dry soilconditions. For example, one club reclaimedlead from their range, using equipment theymodified themselves. Twenty-five tons of leadwere collected but the reclamation took over twoyears. Another club took a year to reclaim 10tons of lead. A more preferrable option may beto hire a reclamation company.

Hiring a Professional Reclamation Company

Another option for lead removal is to hire aprofessional reclaimer. Lead reclamationcompanies claim to recover 75%-95% of thelead in the soils. Generally with reclamationcompanies there is no minimum range sizerequirement for lead reclamation. Concentrationof lead is more important than quantity spreadover a field, especially if it is a difficult range forreclamation (e.g., hilly, rocky, a lot of clay in thesoil).

Please note that reclamation companies tend tobe in high demand — it may take over a year forthe company to start at your club. Therefore, itis wise to plan ahead and make the call to thereclamation company as early as possible.

Some reclamation companies require a site visit

to view the topography, the soil composition, andamount of lead observed on the ground. Duringthe visit, some companies may even do a siteanalysis to determine whether or not it isfeasible to reclaim. This analysis identifies thelocation of lead, the expected recovery amount,and the depth lead reaches into the soils.

Reclamation Activities

Using machinery to reclaim lead usually requiresthat the area be clear of scrub vegetation.Grass, mulch, or compost is generally removedor destroyed during the reclamation process.Some reclamation companies have no problembeginning reclamation on a grassy field. Otherreclamation companies will remove grass beforeor during reclamation (by burning it, if allowedlocally, leaving behind the lead shot), and stillothers require that all vegetation be removedbefore they arrive at the range. Somecompanies will re-seed the area once thereclamation is completed.

Since sporting clay ranges generally have manytrees, removal of vegetation as discussed abovemay not directly apply to existing sporting clayranges. At these ranges, the focus is onremoving vegetative debris (i.e., fallen limbs,tree bark, etc.) prior to reclamation. This mayinclude removing some trees to gain betteraccess with the reclamation machinery. Ofcourse, when designing a new sporting clayrange, steps to facilitate lead reclamation shouldbe taken into account. For example, less andmore widely spaced trees will facilitate leadreclamation.

Reclamation companies use several types ofmachinery to reclaim lead. Some companiesdrive their separation machinery over the site.The lead-laden soil is picked up, processed andthen returned to the ground after most of thelead is removed. Other companies scrape offthe top several inches of soil from the ground,using a front-end loader to bring the soil/lead tostationary reclamation machines, and thenreturn the soil to the field after reclamation.Many companies till the top two to five inches ofsoil and grass immediately prior to reclamationto facilitate the process (some companies may



require this to be done prior to arrival on therange).

Regardless of how it is collected, the actualreclamation of the lead follows the same generalpattern. Most often, it is sifted through a seriesof shaking screens. The lead and soil passthrough shaking screens (usually at least twoscreens) of decreasing mesh (hole) size, withthe topmost screen having the largest mesh.This part of the reclamation machinery is usuallyadapted from machinery used for potato orgravel sizing.

Any soil/debris automatically screened out asbeing too big or too small is either returned tothe field or re-screened to ensure no lead iscaught in the debris. This procedure is whymoist, clay soils are more difficult to reclaim.The moist, clay soils can bind together into shot-sized pellets producing more “product” for thesecond part of the reclamation. The wet soilscan also clog the screens.

For some reclamation companies, their processends after sifting the soil and returning it to theground. However, some companies takereclamation one step further. After screening,the resulting lead, soil, and other lead-sizedparticles enter a blowing system. Here the leadshot is easily separated from the soil and otherdebris by the blowing air. The lead is muchmore dense than the soil and other lead-sizeddebris so that it falls out first. Figure 3-3 depictexamples of actual lead reclamation machinery.

Some lead reclamation companies will performthe reclamation during club off-hours so thatclub activities are not interrupted. Additionally,some perform the reclamation on a field-by-fieldbasis, to minimize any disruptions to clubactivities. However, others companies requirethe club to shut down during the reclamation.Reclamation time varies depending on weather,site accessibility, range size, and number ofpersonnel assigned to perform the reclamation.

Reclamation activities may generate dust,especially in drier western locations. To preventor minimize dust from traveling off the range andcausing complaints from neighbors, reclamation

activities generating dust should only beconducted during periods of no wind. Inaddition, such activities should be completed asquickly as possible.

Vacuuming

For ranges that are located on hilly, rocky, and/ordensely vegetated terrain, several reclamationcompanies employ a vacuum system thatcollects the lead shot (and soil and otherdetritus). The resulting mix is then placed intothe reclamation machinery discussed above.This method is especially effective for sportingclay ranges where lead shot tends to pile uparound tree bases.

Vacuuming has traditionally been used forremoval of lead shot from trap, skeet andsporting clay ranges. Another way to apply thismethod involves removing the top layer of anearthen backstop or sand trap with shovels. It isthen spread thinly over an impermeable materialsuch as plywood. A vacuuming device is thenused to collect the materials that are lighter thanlead (e.g., sand or soil), while leaving behind theheavier materials (i.e., lead bullets/shots andfragments). The soil can then be returned to therange. This process is most efficient for dry,sandy soils without a lot of organic material. Amore recent innovation is the use of a highsuction vaccum. This vaccum itself does nothave to be moved about, since a very long hose(up to 600 feet) is used to move in and aroundtrees during the collection of lead shot at trapand skeet ranges.

Soil Washing (Physical and GravitySeparation)

Soil washing is a proven technology and anotherlead reclamation method used by somereclaimers to separate the lead particles fromthe soils. Soil washing is the separation of soilsinto its constituent particles of gravel, sand, siltand clay. Because of the much higher surfacearea and surface binding properties of clay,most lead contaminants tend to adhere to theclay particles.

Soil washing, therefore, attempts to generate a



clean sand and gravel fraction by removing anyfines adhering to the larger soil particles and, ifnecessary, to transfer contaminants bound tothe surface of the larger particles to the smallersoil particles. Typically, the soils are firstexcavated from the range and then mixed into awater-based wash solution. The wet soil is thenseparated using either wet screening or gravityseparation techniques. One benefit of thissystem of reclamation is that it does not requirethat soils be dry.

In addition, soil washing may be able to recoverall or almost all lead particles through acombination of wet screen sizing and densityseparation. This technique is an option forremediation of a range being closed and maycompare favorably from an economic standpointwith the disposal option.

Soils treated using this method have beenshown to be below 5 mg/L TCLP and to have upto 99% of particulate lead removed. Treatmentcosts are site specific, but can range from lessthen $40 per ton (1999 levels) for simplephysical/gravity separation up to about $100 perton for processes involving leaching. Credits forrecycled lead help offset the treatment cost andthe cost of recycling any treatment sludges andconcentrated soil fines. Water used in soilwashing is from a closed loop system andshould only be disposed at completion ofcleanup. Experience shows the water to not bea RCRA regulated hazardous waste, thereforeprobably allowing disposal to a local wastewatertreatment plant.

Wet Screening

With this method, particles larger and smallerthan the surrounding soils are passed through aseries of large-mesh to small-mesh screens.Each time the mixture passes through a screen,the volume of the soil mixture is reduced. Largeparticles such as lead shot/bullets andfragments are screened out of the soil/washmixture early in the process and can be takenoff-site for recycling - allowing the soil to beplaced back on-site.

Gravity Separation

This technique can be used in cases where thelead particles are the same size as surroundingsoil particles. The wet soil/wash mixture ispassed through equipment, which allows themore dense materials (i.e., lead materials) tosettle to the bottom of unit and separate out ofthe soil/wash mixture.

Pneumatic Separation

Pneumatic separation (see figure 3-3) is aneffective means to enhance the traditionalscreening results. Traditional screening cannotseparate shot and bullets from other shot andbullet sized material, i.e., rocks, stones, roots,and various debris. A recycling facility considersnon-lead items as “contaminants” whichdrastically reduces the value of the recycledlead. Pneumatic separation utilizes an airstream, and specific density analysis, toeffectively separate the shot/bullets from theother shot/bullet sized material.

3.3.1 BMPs to Assist Lead Reclamationand Recycling

There are several operational activities thatshould be conducted throughout the year tofacilitate reclamation. The following is adiscussion of these activities.

Frequency of Lead Removal

It is important to perform lead removal at afrequency appropriate your site. The frequencyis dependent on several factors. These include:

� Number of rounds fired� Soil pH� Annual precipitation� Soil Type� Depth to groundwater.

Lead volume, as estimated by the number ofrounds fired, is a factor in determining theappropriate frequency of reclamation at ranges.It also assists in determining whether a rangemay receive economic returns from lead soldafter reclamation. One reclamation company



4. National Rifle Association, “Metallic “Bullets” leadDeposits on Outdoor and Indoor Firing Ranges” 1991

indicated that to make reclamation economicallyfeasible, a backstop could be reclaimed when itcontains at least 20 pounds of lead per squarefoot of backstop. Another source indicated thata maximum of 100,000 rounds per firing lanecould be allowed before reclamation of the leadoccurs. This would assure good rangeoperation and maintenance as well as be a costeffective amount of lead for recovery purpose.

For shotgun ranges, tracking the number oftargets thrown can help indicate when the leadshot should be reclaimed. For example, onesource indicated that when a range has thrownapproximately 250,000 to 1,000,000 targets,depending on the shooting area, reclamation ofthe lead shot should occur. Another reclaimerindicated that if about two pounds of lead persquare foot accumulated on the range, costeffective reclamation was possible.

Because the number of rounds fired is importantto know, establishing record keeping proceduresto monitor the number of rounds fired isrecommended. This can be accomplished bymaintaining logbooks and asking shooters to listthe number of rounds shot and the type/size ofshot/bullets they use. This should be done bylane and by stand.

There are many ranges at which lead removalhas not occurred for many years. Many of theseranges are used extensively. Such ranges areespecially good candidates for potential positivecash flow as a result of removal and recycling.Subsequent removal frequency depends onrange use and environmental factors. The NRArecommends a frequency of one to five years forlead cleanup, even on ranges with minimal use4.One possible approach to making reclamationmore cost effective is for a number of ranges inthe same geographical area to work together inorganizing coordinated removals at their ranges.This will reduce the reclaimer travel andmobilization cost for each range.

Minimization of Vegetation

As discussed previously, vegetation is usefulboth for controlling the amount of runoff and

erosion from the range and inhibiting leadmobility. However, excessive orunmaintained vegetative cover can interferewith reclamation activities. For example,large amounts of vegetation impedes thescreening and sifting processes used by manyreclamation companies. Therefore, prior toreclamation activities, it is best to remove,reduce, or mow excessive vegetation from thearea. Once the reclamation has beenconducted, quick-growing vegetation such as arye/fescue grass mix should be replanted. Thisprocess should be repeated for eachreclamation event.In addition, heavily wooded areas may inhibitlead reclamation because they are lessaccessible by heavy reclamation machinery.For ranges that are heavily wooded, it isrecommended that you minimize the vegetationor modify the range design to allow leadreclamation equipment access to the range.Access to the impact area should be developedto facilitate reclamation. Make sure that thepathways do not present a safety risk.

Innovative Landscaping

Some new ranges are landscaping their rangesto include a sand track (an area the size of theshotfall zone that is only sand) located behindsome aesthetically pleasing shrubs. This allowsthe spent shot to concentrate on the sand,making it very easy to perform reclamationbecause there is no interference by vegetation.

Selecting a Lead Reclaimer

In ensuring that the reclamation is conductedappropriately, selecting a reclaimer that is rightfor your range is extremely important. Somelead reclamation companies will travel to yourrange and assess the range prior to conductinglead collection activities. This assessment tripallows the reclamation company to confirminformation gained during initial discussions, aswell as to assist in appropriately estimatingcosts, time required, and the estimated volumeof lead at the range. Conducting this pre-assessment also allows you to determine whichreclaimer is right for your situation.



Questions Commonly asked by the Reclaimer

When you contact a reclamation company, it islikely that the reclaimer will ask several generalquestions. Typical questions include:

� When was the last reclamation conducted?� How many rounds have been shot since that

last reclamation?� What is the use frequency of the range?� What are the site characteristics and soil

types?� What type of bullet containment device is

used at the range?

Answering these questions will be a lot easier ifyou have maintained good records, as issuggested above.

Questions to ask the reclaimer

When choosing a reclaimer be sure to ask thegeneral questions about prior cleanups (pastprojects), insurance to cover company andcleanup (general liability insurance, pollutioninsurance, bonding, etc.), and site plans toensure health and safety of workers and rangepersonnel. Other questions you may want to askthe reclaimer include:

� Can the reclamation take place outsidenormal hours of range operation?

� What cost are involved and what is the“profit” sharing arrangement?

� How long will the reclamation take?� Does vegetation at the range need to be

removed?

Economic Considerations

Lead removal costs, if incurred, may varydramatically depending upon the type andvolume of soil or sediments, topography,amount of lead, and location. Because theeconomics of reclamation varies due to manyfactors, this manual does not provide specificestimates. However, it is important tounderstand that lead reclamation may or maynot be economically beneficial. Economicbenefits can be captured in two ways:

� Monetary returns from selling reclaimedlead

� Future cost avoidance by minimizing theneed for costly site remediation Some

reclaimers bid the lowest flat fee with all the leadprovided to the range for selling. The rangeowners/operators must then consider thetransportation costs to send the reclaimedbullets to a recycling company. Alternatively, ina “profit-sharing” situation, the reclaimer willideally split the economic return of lead sold forrecycling based on the volume reclaimed andthe current value of lead. In a best casescenario, the average split may by 50/50, but itmay also be lower. Although the value of leadvaries, the value of reclaimed lead typically fallsbetween $.10 and $.25 per pound excludingtransportation cost. See the appendix forcontact information regarding lead reclamationcompanies that specialize in lead removal atoutdoor ranges.

3.4 Documenting Activities andRecord Keeping (Step 4)

Documenting activities and keeping goodrecords is of paramount importance for aneffective lead management program at a range.Owners/operators should document all activitiesdone at the range with respect to BMPs andrecycling of lead. Records should be kept onwhen services were provided and who providedthem.

Owners/operators may want to document whattype of BMP(s) were implemented to controllead migration, the date of service, and who didthe services. The records should be kept for thelife of the range. Records may be used to showthat owners/operators are doing their part tohelp prevent lead migration off-site and showthat they are doing their part to be stewards ofthe environment.

3.5 Additional EconomicConsiderations

Not all BMPs need to be implemented at once.Many can be phased in over time. However, itis important to begin implementing BMPs,



especially lead reclamation and recycling, assoon as possible. Implementing the mostappropriate BMPs for your range requiresconsideration of your range characteristics andcosts associated with implementing the BMPs.This manual provides a large selection of BMPsthat vary in both cost and sophistication. Inselecting BMPs for your range, it is important tolook at all costs and all the benefits (or potentialproblems) associated with each BMP.

3.6 Summary of Key BMPs forShooting Ranges

There are several BMPs that are highlyrecommended to be implemented, if applicableto your range. Table 3-1 identifies theadvantages and disadvantages of all BMPsdiscussed in this chapter. This table serves as aquick reference guide for potential BMPs.Readers should refer back to the detaileddiscussions above for further informationregarding these BMPs.



Table 3-1 – Summary of Key BMPs



Table 3-1 – Continued

1 Much of this information was obtained from Action Target’s Bullet Containment Trap Technologies video.Reference to various pros and cons of individual bullet containment devices is included in this manual forinformational purposes only. The USEPA does not endorse any particular bullet containment device, design,or product.

References


References

Battelle Memorial Institute, Field Demonstration of a Sieving and Stabilization Technologyon Lead-Contaminated Soils at a Small Arms Range at Mayport Naval Air Station,Columbus, Ohio, February 1991

Brister, B. The Speed Factor, Field and Stream, January 1995

Connecticut Coastal Fisherman's Ass'n v. Remington Arms Co., Inc., 989 F.2d 1305(2d Cir. 1993)

George, C.J., Joachim, A., and Le, Phu Trong, Long-Buried Lead Shot: Its Stability, PossibleTransport by Waterfowl and Reexposure by Hydraulic Dredging at Collins Lake, Departmentof Biological Sciences, Union College, Schenectady, NY, June 1991

Long Island Soundkeeper Fund, Inc. v. New York Athletic Club of the City of NewYork, 1996 U.S. Dist. LEXIS 3383 (S.D.N.Y. 1996)

Magdits, Louis J., Recycling Regulations, Proceeding from the Third National ShootingRange Symposium, June 23-25, 1996, Orlando, Florida

Middleton, J.R., Development of Toxic Free Ammunition, U.S. Armament Research,Development and Engineering Center

National Rifle Association of America, Lead Article, Risk Issues in Health and Safety -Volume I, Pages 6-8, Winter 1990

National Rifle Association of America, Metallic “Bullets” Lead Deposits on Outdoor andIndoor Firing Ranges, 1991

National Rifle Association, The NRA Range Source Book: A Guide to Planning andConstruction, June 1998

National Shooting Sports Foundation, Environmental Aspects of Construction andManagement of Outdoor Shooting Ranges, June 1998

Ordija, Victor, Lessons from Lordship, Proceedings from the National Shooting RangeSymposium, October 17-19, 1993, Salt Lake City, Utah

Peddicord, Richard K., Lead Mobility in Soils, Proceedings from the Third National ShootingRange Symposium, June 23-25, 1996, Orlando, Florida

Sever, C.W., Lead and Outdoor Ranges, Proceedings from the National Range Symposium,October 17-19, 1993, Salt Lake City, Utah

Sporting Arms and Ammunition Manufacturers Institute, Inc., Lead Mobility at ShootingRanges, Newtown, CT, 1996

Stansley, W., Widjeskog, L., and Roscoe, D.E., Lead Contamination and Mobility in SurfaceWater Trap and Skeet Ranges, Bulletin of Environmental Contamination Toxicology,Springer-Verlag, New York, NY, 1992

U.S. Department of the Interior, Pollution Prevention Handbook -- Firing Ranges,Department of the Interior, Office of Environmental Affairs, Washington, D.C.

U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response,Washington, D.C., Directive 9355.4-12, Revised Interim Soil Lead Guidance for CERCLASites and RCRA Corrective Action Facilities, July 14 1994

U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response,Washington D.C., A Citizen's Guide to Soil Washing, EPA 542-F-96-002. , April 1996.

U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response,Washington, D.C. Physical/Chemical Treatment Technology Resource Guide, EPA 542-B-94-008. September 1994.


References


This manual provides current contacts for leadreclamation companies, lead recycling companies, bullettrap manufacturers, and organizations that provideprevention and/or remediation techniques to assist clubsand firing ranges in implementing Best ManagementPractices for shooting ranges. Vendors who are interestedin being added to the list of lead reclaimers or remediationcontractors should contact:

Lead Shot CoordinatorRCRA Compliance BranchUS EPA Region 2290 BroadwayNew York, NY 10007-1866Telephone: (212)637-4145E-mail: [email protected]

Appendix A:Resources

Appendix A - Page A-1


Lead Recycling Companies*

Below is a list of recycling companies for lead in soils and spent lead shot/bullets that werecontacted during the writing of this manual. It is not inclusive and is included for informationalpurposes only. Mention of these companies does not serve as an endorsement by the EPA.


* Lead recycling companies smelt lead


Lead Reclamation Companies*


* Lead reclamation companies reclaim lead from ranges.

Below is a list of reclamation companies for lead in soils and spent lead shot/bullets that werecontacted during the writing of this manual. It is not inclusive and is included for informationalpurposes only. Local scrap metal recyclers may also accept spent lead shot or spent bullets.Mention of these companies does not serve as an endorsement by the EPA.


Lead Reclamation Companies Con’t.



Other Resources

Below is a list of additional phone numbers that may be of use if you have general questions includ-ing questions on range construction, design, and implementing BMPs.



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Another method of preventing leadcontamination at pistol, rifle, trap, skeet, orsporting clays ranges is to use less toxic ornon-lead ammunition.

Much progress has been made in thedevelopment of alternatives to lead shot forhunting uses. Information gathered since 1976on lead poisoning of endangered and non-endangered migratory birds due to lead shotingestion, led the United States Fish and WildlifeService (USFWS) to consider severalalternatives to eliminate lead poisoning amongmigratory waterfowl birds. A ban on lead shotfor water fowl hunting was phased-in beginningin 1986, and finalized in 1991. Lead shot is alsonow banned for shotgun hunting occurring nearwetlands in national wildlife refuges. Starting inthe fall of 1998, the USFWS banned the use oflead shot in waterfowl production areas.Additionally, many state-managed hunting areasrequire non-toxic shot for upland/small gamehunting.

There are several alternatives to lead shot onthe market today and still more alternatives arebeing developed. Before being used forwaterfowl hunting, these alternatives must beapproved by the USFWS. Bismuth, steel,tungsten/iron, and tungsten/polymer shots havebeen approved by the USFWS and additionalother alternative shot materials are in theUSFWS approval process. Most of theammunition manufacturers in the United States,as well as the military, have developed non-toxic alternatives to lead. Research in Europemay also result in additional non-toxic shotalternatives from which U.S. shooters maychoose in the future. The following pagescompare lead shot to non-toxic, alternative shot.

Appendix B:Lead Shot Alternatives


Appendix B - Page B-1

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The table clearly illustrates that a number of non-toxic alternatives to lead shot exist such as steeland tungsten as well as alloys and syntheticpolymers. As demand for shot from thesemetals increases from migratory waterfowlhunters, it is anticipated that the costs will comedown. However, alternatives currently costapproximately two to twenty times more thanlead shot.

The ban on lead shot in hunting situationsimpacts target shooting. The alternatives to leadshot that are now being developed for or arealready approved by the USFWS for migratorybird hunting could be considered for use bytarget shooters.

Although alternatives to lead shot are now beingused by hunters, it is rare that the alternativesare used by target shooters. The limiting factorsappear to be the expense and performance. Allthe alternatives to lead are much more expen-sive, some prohibitively. Unfortunately, the leastexpensive alternative, steel, is also perceived tobe less effective.

To encourage use of lead shot alternatives,some ranges sponsor shooting competitionsusing lead-free ammunition, but these are rare.Promoting steel shot as the “marksman’s ammu-nition” may encourage greater use of that type ofshot. The use of steel or other alternative shot isa recommended BMP in established sportingclays areas at which reclamation of lead shot isdifficult to impossible.

Note: Switching to non-toxic shot may createadditional issues. For instance, steel has anincreased risk of ricochet. Switching to steelmay require additional safety features and/oroperating procedures.




Appendix C - Page C-1

Appendix C:Sample Bullet Containment

Devices

The bullet continment designs in this appendix are sample designs for thecontainment systems mentioned in this manual. Design systems may varyfrom different manufacturers. Reference to various individual bulletcontainement devices is included in this manual for informational purposesonly. EPA does not endorse any particular bullet containment device, design, orproduct.

Rubber Granule Trap (Adapted from: Bullet Trap FeasibilityAssessment and Implementation Plan: Technology Identification FinalReport, U.S. Army Environmental Center, March 1996)


Sand Trap

Escalator Trap (Adapted from: Bullet Trap Technologies, Action Target Educational Video Series)



Vertical Swirl Trap (Adapted from: Bullet Trap Feasibility Assessment and Implementation Plan: Technology Identification FinalReport, U.S. Army Environmental Center, March 1996)

Wet Passive Trap (Adapted from: Bullet Trap Feasibility Assessment and Implementation Plan: Technology Identification FinalReport, U.S. Army Environmental Center, March 1996)

Pitt and Plate (Adapted from: Bullet Trap Feasibility Assessment and Implementation Plan: Technology Identification Final Report,U.S. Army Environmental Center, March 1996)



Steel Bullet Trap (Adapted from: Bullet Trap Technologies, Action Target Educational Video Series)

Lamella Trap (Adapted from: Bullet Trap Feasibility Assessment and Implementation Plan: Technology Identification Final Report,U.S. Army Environmental Center, March 1996)


Appendix D:RCRA Regulatory Requirements

and Interpretations

1. Reclaiming and Recycling Lead Shot

In a final rule published in the Federal Register on May 12, 1997 (62 Fed. Reg.25997), the EPA excluded processed scrap metal from RCRA regulation with the intentionof promoting the goal of safe recycling (40 CFR 261.4(a)(13)). Scrap metal (not requiringprocessing) being reclaimed and recycled was already exempt from RCRA Subtitle Cregulation (40 CFR 261.6(a)(3)(ii)). Thus, the EPA clarified that the exclusion for processedscrap metal being recycled applies to the scrap metal that has undergone a processing stepby the range owner or a reclaimer.

The term “sorted” was added to the definition of “processed scrap metal” (40 CFR261.1(c)(10)) as a typical step used in scrap metal recycling. This definition also includes“manually or physically altered to either separate it into distinct materials to enhance eco-nomic value or to improve the handling of materials.” Lead shot/bullet reclamation at rangesfalls under this type of activity.

The EPA “believes that processed scrap metal being recycled is distinct from othersecondary materials defined as wastes when recycled due to established markets for thematerial’s utilization, inherent positive economic value of the material, the physical form ofthe material, and absence of damage incidents attributable to the material, and is thereforesufficiently product - like that maintaining RCRA regulatory jurisdiction over the material isnot necessary.” (62 Fed. Reg 26011)

EPA’s Office of Solid Waste issued guidance in 1997 indicating that lead shot, when re-cycled, is considered a scrap metal and therefore exempt from RCRA regulation. A copy ofthe March 17, 1997 letter with this guidance is attached.

2. Placement of Soil After Removal of Lead

For soil placed back on an active range after a BMP has been applied to remove thelead, the following regulatory approach has been followed. On February 12, 1997, EPApublished the RCRA Subtitle C Military Munitions Rule in the Federal Register (62 Fed.Reg. 6621). The Military Munitions Rule considers range management to be a necessarypart of the safe use of munitions for their intended purpose. Thus, the range clearanceactivity (recovery of lead shot and bullets) is an intrinsic part of the range use. Therefore, the

Appendix D - Page D-1


Timely separation of lead shot and bullets from soil at active ranges, recycling of thelead, and subsequent redeposition of the soil on the active range is exempt from RCRAregulation.



rule excludes range clearance activities (including the placement of soil back on the range)from RCRA Subtitle C regulation. Although the Military Munitions Rule did not apply to non-military ranges, EPA, in its response to comments on the proposed rule, clearly stated that “itfelt that the ‘range clearance’ interpretation in the final Military Munitions Rule is consistantwith the EPA’s interpretations for non-military ranges.” In addition, the EPA’s Director of theOffice of Solid Waste sent the New York State Department of Environmental Conservation aletter dated April 29,1997, confirming that the Military Munitions Rule range clearanceprinciples apply equally to non-military ranges. A copy of the letter is attached.



UNITED STATES ENVIRONMENTAL PROTECTION AGENCYWASHINGTON, D.C. 2046

March 17, 1997

Mr. Duncan CampbellEnvironmental Protection Agency, Region VRCRA Enforcement77 West Jackson BoulevardChicago, Illinois 60604-3507

Dear Mr. Campbell:

Enclosed please find a memorandum on the regulatory status of lead shot, which includes ageneral discussion on the regulatory status of lead shot as scrap metal. I hope that thisinformation is sufficient to address your specific concerns as they relate to the pile of leadshot at the Saxon Metals facility.

If you have any questions or would like to discuss this matter further, please contact me at(703) 308-8826.

Sincerely,

Jeffery S. HannapelOffice of Solid Waste

Enclosure

To: Duncan Campbell, EPA Region VFrom: Jeff Hannapel, EPA Office of Solid WasteDate: March 13, 1997Re: Regulatory Status of Lead Shot

Based on our conversations, it is my understanding that Saxon Metals received for recyclinga shipment of approximately 30,000 pounds of lead shot from a commercial indoor shootingrange. Smokeless gun powder is, presumably, commingled with the lead shot. The mixtureappears to exhibit the ignitability characteristic of hazardous waste (as evidenced by theincident in which the material ignited when Saxon Metals was attempting to load it into thefurnace with a front-end loader). You have asked our office to provide you with guidance onthe regulatory status of the lead shot portion of the mixture, specifically whether it is consid-ered a spent material or scrap metal.

The Agency has taken the position that the discharge of ammunition or lead shot does notconstitute hazardous waste disposal because the Agency does not consider the roundsfrom the weapons to be “discarded.” As you know, discard is a necessary criterion to be metbefore a material can be considered a solid waste and subsequently a hazardous waste. 40CFR §261.2(a). The Agency’s interpretation regarding discard is based on the fact that



shooting is in the normal and expected use pattern of the manufactured product, i.e., thelead shot. Enclosed for your information is a September 6, 1988 letter from EPA to IDEM onthis particular point.

In the federal regulations, the term, “scrap metal,” is defined as “bits and pieces of metalparts (e.g., bars, turnings, rods, sheets, wire) or metal pieces that may be combined togetherwith bolts or soldering (e.g., radiators, scrap automobiles, railroad box cars), which whenworn or superfluous can be recycled.” 40 C.F.R. §261.1. In the Federal Register preamble forthe final regulations on the definition of solid waste, EPA indicated that “scrap metal isdefined as products made of metal that become worn out (or are off-specification) and arerecycled to recover their metal content, or metal pieces that are generated from machineoperations (i.e., turnings, stampings, etc.) which are recycled to recover metal.” 50 Fed. Reg.614, 624 (1985). The lead shot portion of the Saxon Metals pile would be considered scrapmetal pursuant to the regulatory definition of scrap metal.

EPA provided further clarification on the regulatory status of scrap metal in the FederalRegister preamble to the definition of solid waste final regulations:

[a]t proposal, scrap metal that was generated as a result of use by consumers (copperwire scrap, for example) was defined as a spent material. (This type of scrap is usuallyreferred to as “obsolete scrap.”) Scrap from metal processing, on the other hand (such asturnings from machining operations) was defined as a by-product. (It is usually called“prompt scrap.”) Yet the scrap metal in both cases is physically identical (i.e., the compositionand hazard of both by-product and spent scrap is essentially the same) and, when recycledis recycled in the same way - by being utilized for metal recovery (generally in a secondarysmelting operation). In light of the physical similarity and identical means of recycling ofprompt scrap and obsolete scrap, the Agency has determined that all scrap metal should beclassified the same way for regulatory purposes. Rather than squeeze scrap metal intoeither the spent material or by-product category, we have placed it in its own category.

50 Fed. Reg. at 624. Based on these regulatory passages, the lead shot portion of the pilewould be considered scrap metal, and not a spent material. The lead shot is a product that ismade of metal that can be recycled to recover metal content. Furthermore, the lead shot hasnot been “discarded” by virtue of its discharge at the shooting range, because the dischargeis within the normal and expected use pattern of the manufactured product. Accordingly,lead shot would be considered scrap metal for regulatory purposes. Scrap metal is a solidwaste, but it is exempt from the regulatory requirements of Subtitle C when it is recycled. 40C.F.R. §261.6(a)(3)(ii). As part of the Phase IV land disposal restrictions supplementalrulemaking (which was proposed January 25, 1996 an is expected to be finalized in April1997), processed scrap metal and two categories of unprocessed scrap metal that is beingrecycled would be excluded from RCRA jurisdiction.

Please note that this discussion of the regulatory status is limited to the lead shot portion ofthe pile as you requested. To the extent that the entire pile exhibits the ignitability or reactivecharacteristic of hazardous waste, the mixture of materials would be considered hazardouswaste and not scrap metal. The scrap metal designation for the lead shot would be appli-cable only to the extent that the lead shot could be segregated from the other materials in

the pile.

I hope that this guidance on the regulatory status of lead shot recovered from shootingranges provides you with the clarification that you needed. If you have any questions orwould like to discuss this matter further, please contact me.



UNITED STATES ENVIRONMENTAL PROTECTION AGENCYWASHINGTON, D.C. 20480

APR 29 1997

Mr. John P.CahillActing CommissionerState of New YorkDepartment of Environmental ConservationAlbany, New York 12233-1010

Dear Mr. Cahill:

Thank you for your letter of April 3, 1997 to Administrator Browner requesting aclarification of the Environmental Protection Agency (EPA) Final Military Munitions Ruleregarding the extension of its range clearance principles to non-military ranges. Althoughthe final rule addresses only military ranges, we agree with your view that the range clear-ance principles apply equally to non-military ranges [see comment no. 5 on page 36 of theenclosed excerpt from the Military Munitions Final Rule Response to Comments Back-ground Document].

We are aware of the State of New York’s active leadership role in the clean-up ofprivate firing ranges. We appreciate your writing in support of the range clearance aspectsof the final Military Munitions Rule and we will consider your suggestions that we issuebroader guidance on the applicability of its principles to non-military ranges.

Sincerely yours,

Elizabeth Cotsworth, Acting DirectorOffice of Solid Waste

Enclosure



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