Best Management Practices for Lead at Outdoor Shooting Ranges for Additional Copies of This Manual, Please Contact

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United States EPA-902-B-01-001 Environmental Protection Revised June 2005 Agency Region 2

Best Management Practices for Lead at Outdoor Shooting Ranges For additional copies of this manual, please contact:

United States Environmental Protection Agency Division of Enforcement and Compliance Assistance RCRA Compliance Branch 290 Broadway, 22nd Fl. New York, New York 10007-1866

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

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

Copying and Reprinting

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

Fourth Printing, June 2005 BMP for Lead at Outdoor Shooting Ranges

Best Management Practices for 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 scientists, engineers, attorneys, and other appropriate professionals who should be called upon to make specific recommendations for individual range design and lead management.

Any variation between applicable regulations and the summaries contained in this guidance document are unintentional, and, in the case of such variations, the requirements of the regulations govern.

This guidance was developed by EPA Region 2 in cooperation with a few states as well as many EPA offices. In addition, EPA, with the assistance of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) provided all 50 states with an opportunity to review the RCRA regulatory portion of the guidance. At the time of printing, about 40 states had contacted the EPA and given their support and concurrence. EPA is continuing to get the agreement of the remaining states. Therefore, it appears that most, if not all, states will share the same view as to how lead 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 information or recommendations contained in this document.

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

Notice BMP for Lead at Outdoor Shooting Ranges

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 development of the manual and their efforts are truly appreciated. EPA also wishes to give special thanks to Dr. Charles W. Sever of Okie Environmental Consulting, L.L.C., Inc., Mr. Mike Warminsky of Brice Environmental Services Corp., and Mr. Victor Ordija of Sporting Goods Properties.The EPA also wishes 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.

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

Acknowledgements BMP for Lead 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 range owners and operators to operate in an environmentally protective manner.

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 part of 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 proper lead management,

advocate environmental stewardship.

Statement of Goals This page intentionally left blank BMP for Lead at Outdoor Shooting Ranges

EPA Statement on National Guidance

EPA Statement on National Guidance BMP for Lead at Outdoor Shooting Ranges

Best Management Practices for Lead at Outdoor Shooting Ranges

Table of Contents

Page

List of Figures ...... ii List of Tables ...... ii Introduction ...... iii

Chapter I - Environmental and Regulatory Concerns at the Shooting Range ...... I-1 1.0 Background ...... I-1 1.1 Lead Contamination’s Impact on Human Health and the Environment ...... I-2 1.2 Legal Requirements & Court Rulings ...... I-6 1.3 Benefits of Minimizing Lead’s Environmental Impact ...... I-12

Chapter II - Range Characteristics & Activities to Consider When Implementing BMPs ...... II-1 2.0 Background ...... II-1 2.1 Physical Characteristics ...... II-1 2.2 Operational Aspects ...... II-4 2.3 Planning a New Range ...... II-4

Chapter III - BMPs for Outdoor Ranges ...... III-1 3.0 Background ...... III-1 3.1 Bullet and Shot Containment Techniques (Step 1) ...... III-1 3.2 BMPs to Prevent Lead Migration (Step 2)...... III-5 3.3 Lead Removal and Recycling (Step 3) ...... III-11 3.4 Documenting Activities and Record Keeping (Step 4) ...... III-17 3.5 Additional Economic Considerations ...... III-18 3.6 Summary of Key BMPs for Shooting Ranges ...... III-18 3.7 Certificate of Recognition...... III-18

References Appendix A - Resources Appendix B - Lead Shot Alternatives Appendix C - Sample Bullet Containment Devices Appendix D - RCRA Regulatory Requirements and Interpretations Appendix E - Template for an Environmental Stewardship Plan for Management of Lead Shot/Bullets

Table of Contents - i BMP for Lead at Outdoor Shooting Ranges

List of Figures

Figure Number Page

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

2-1 pH Scale II-1

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

3-2 Sample Filter Bed System III-10

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

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 Risks II-3 and Benefits Associated with Range Operations

3-1 Summary of Key BMPs III-19

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

Lists of Figures and Tables - ii BMP for Lead at Outdoor Shooting Ranges

and the importance of an integrated BMP Introduction program to manage lead. • Chapter II discusses physical and operational characteristics to be considered This manual provides owners and operators of when selecting a successful BMP program. outdoor rifle, pistol, trap, skeet and sporting clay ranges with information on lead management at • Chapter III addresses best management their ranges. This manual serves as a reference techniques for rifle/pistol ranges, skeet and guide and presents best management practices trap ranges, and sporting clay ranges. In this (BMPs) available to the shooting range chapter, the manual explores possible community. The practices have been proven to solutions to prevent, reduce and/or remove effectively reduce or eliminate lead lead contamination for each type of range. contamination and may also be economically beneficial to the range owner/operator. Since • The Appendices provide current (as of June each range is unique in both the type of shooting 2005) contacts for lead reclamation and activity and its environmental setting, specific recycling companies, vendors that provide solutions are not provided in this manual. prevention and/or remediation techniques and Rather, a range owner or operator may use this shooting organizations that have additional manual to identify and select the most information on the lead issue. Additionally, appropriate BMP(s) for their facility. Other the Appendices provide information on information on environmental aspects of alternatives to lead, diagrams of bullet trap management at outdoor shooting ranges can be designs, summaries of regulatory found in the National Shooting Sports requirements and interpretations, and a Foundation’s Environmental Aspects of sample Environmental Stewardship Plan. Construction and Management of Outdoor Shooting Ranges. EPA is very interested in any suggestions you have about practices included in this manual The manual does not address range layout or which have proven effective in controlling lead design to meet range safety or competition contamination or recycling lead bullets/shot. requirements. For information on range safety Please send such information to the address and competition requirements, range owners/ below. Also, for additional information, or to be operators are directed to other comprehensive added to the list of lead reclaimers or reference materials available on that subject, remediation contractors, contact the National such as the National Rifle Association’s Range Rifle Association (NRA), the National Shooting Source Book, and the National Association of Sports Foundation (NSSF) or: Shooting Range’s website (www.rangeinfo.org). Lead Shot Coordinator Owners/operators of ranges may want to RCRA Compliance Branch assign the use of this BMP Manual to a U.S. Environmental Protection Agency specific team or committee. Delegating this Region 2 responsibility to a specific team or group 290 Broadway helps to assure that the BMP’s are identified New York, New York 10007-1866 and implemented. Telephone: (212)637-4145 E-Mail: [email protected] The manual is organized as follows:

• Chapter I provides the background on why lead is of concern to human health and the environment. It includes a discussion of how environmental laws impact shooting ranges

Introduction - iii This page intentionally left blank BMP for Lead at Outdoor Shooting Ranges

(CDCP), and a large number of states have Chapter I: identified human exposure to all forms of lead as Environmental and Regulatory a major health concern in the United States.

Concerns at the Shooting Range Lead management practices at ranges across the United States remain inconsistent. Some range owners/operators have examined the 1.0 Background impact of range operations on human health and the environment and have implemented Outdoor shooting ranges provide recreational procedures to manage and/or remove facilities for millions of shooting sports accumulated lead from ranges. Other range enthusiasts in the United States. Recently, there owners/operators are just beginning to has been a growing public concern about the characterize and investigate their ranges in potential negative environmental and health order to design an environmental risk prevention effects of range operations. In particular, the and/or remediation program(s) specific to their public is concerned about potential risks sites. A third group of ranges has adopted a associated with the historical and continued use “wait and see” policy – taking no action until of lead shot and bullets at outdoor ranges. specifically required to do so by law or clear guidance is in place. Finally, a fourth, small, but This concern is not unfounded. An estimated important group of range owners/operators 9,000 non-military outdoor ranges exist in the remain unaware of lead’s potential to harm United States, collectively shooting millions of human health and the environment, and of pounds of lead annually. Some ranges have existing federal and state laws. operated for as long as several generations. Historical operations at ranges involved leaving To manage lead, many owners and operators expended lead bullets and shot uncollected on have successfully implemented Best ranges. Many of these ranges continue to Management Practices (BMPs) at their ranges. operate in the same manner as in the past. These range owners and operators have realized many benefits from sound lead It is estimated that approximately four percent management including: (4%) (80,000 tons/year) of all the lead produced in the United States in the late 1990’s (about 2 - stewardship of the environment, natural million tons/year), is made into bullets and shot. resources and wildlife, Taking into account rounds used off-range, and - improved community relations, rounds used at indoor ranges, it is clear that - improved aesthetics of the range/good much of this 160,000,000 pounds of lead shot/ business practices, bullets finds its way into the environment at - increased profitability through recovery/ ranges. recycling lead, a valuable and finite resource, and Since the mid-1980’s, citizen groups have - reduced public scrutiny. brought several lawsuits against range owners and have urged federal and state agencies to Shooting sports organizations [e.g., National take action against owners and operators of Rifle Association (NRA) and the National outdoor shooting ranges. The citizen groups Shooting Sports Foundation (NSSF)] promote argued that range owners improperly managed lead management throughout the United States. discharged lead bullets and shot. Federal courts These organizations have researched different have supported parts of these suits, requiring methods to effectively address potential and range owners/operators to clean up lead- actual lead mobility and exposure without contaminated areas. Concurrent with the detracting from the enjoyment of the sport. The increased citizen suit activity, the federal EPA, NRA, NSSF, and a number of other shooting the Centers for Disease Control and Prevention sports organizations strongly encourage range

Chapter I - Page I-1 BMP for Lead at Outdoor Shooting Ranges owners/operators to develop a BMP program soil, it breaks down by weathering into lead that contains elements discussed later in this oxides, carbonates, and other soluble manual. Contact the NRA and NSSF for compounds. With each rainfall, these additional guidance materials available on lead compounds may be dissolved, and the lead may management practices. move in solution in the storm runoff waters. Decreases in water acidity (i.e., increases in its By implementing appropriate lead management pH) will cause dissolved lead to precipitate out of at outdoor shooting ranges, range owners and solution. Lead concentrations in solution are operators can reduce the environmental and reduced by this precipitation. At pHs above 7.5, health risks associated with lead deposition, very little lead remains in solution. Increased meet legal requirements and realize quantifiable time of contact between lead and acidic water benefits. generally results in an increase in the amount of dissolved lead in the storm runoff water. The five 1.1 Lead Contamination’s Impact factors which most influence the dissolving of lead in water are summarized below: on Human Health and the Environment Annual Precipitation Rate - The higher the annual precipitation rate, the faster the lead Exposure Routes weathers. Also, during prolonged rains, the contact time between water and lead is Historically, the three major sources for human increased. In general, the higher the exposure to lead are lead-based paint, lead in precipitation rate, the higher the potential risk of dust and soil and lead in drinking water. lead migration off-site in solution. Typically, human exposure occurs through ingestion, which is the consumption of lead or pH of Rain and Surface Water - The acidity of lead-contaminated materials, or by inhalation. the rainwater decreases as basic (alkaline) The main human exposure to lead associated minerals in the soil are dissolved. If sufficient with shooting ranges is through lead- minerals such as calcium, magnesium, and iron contaminated soil. However, other pathways are are present in local soils, then the lead may discussed below, along with lead’s detrimental quickly precipitate out of solution entirely as effects on humans and animals. these other minerals are dissolved. The pH of shallow surface water is an indicator of the Lead can be introduced into the environment at presence or absence of basic minerals in the shooting ranges in one or more of the following local soil and in gravel within the stream beds ways. Each of these pathways is site-specific through which the water has moved. The water and may or may not occur at each individual in deeper streams and lakes is more likely to be range: composed of acidic rainwater that is not neutralized. • Lead oxidizes when exposed to air and dissolves when exposed to acidic water or Contact Time - The contact time between soil. acidic surface water and lead is a factor in the amount of lead that is dissolved. For example, • Lead bullets, bullet particles, or dissolved lead shot deposited directly into a lake has a lead can be moved by storm water runoff. longer contact time then lead shot deposited in • Dissolved lead can migrate through soils to upland areas. groundwater. Soil Cover - Organic material will absorb lead Lead oxidizes when exposed to air and and remove it from a water solution. The thicker dissolves when exposed to acidic water or soil the organic leaf and peat cover on the soil, the lower the lead content in solution in water leaving When lead is exposed to acidic water and/or the shot area. Organic material has a strong

Chapter I - Page I-2 BMP for Lead at Outdoor Shooting Ranges ability to extract lead out of solution in water. Vegetative Cover and Man-made Structures - Structures such as dams and dikes reduce the pH of Groundwater - During periods of no water’s velocity and greatly reduce the size and rainfall, the water flowing within most streams weight of the lead particles the water can carry. comes from groundwater discharging into the Since lead particles are heavy compared to the stream channel. Therefore, the acidity of the other suspended particles of similar size, they groundwater affects the acidity of the surface are more likely to be deposited under the water, and hence, affects the solubility of any influence of anything that reduces velocity of the lead particles carried into the stream during storm runoff. Grass and other vegetation storm runoff. reduce runoff velocity and act as a filter to remove suspended solids from the water. Lead bullets, bullet particles or dissolved lead can be moved by storm water runoff Dissolved lead can migrate through soils to groundwater The ability of water to transport lead is influenced by two factors: velocity of the water and weight Acidic rainwater may dissolve weathered lead or size of the lead fragment. Water’s capacity to compounds. A portion of the lead may be carry small particles is proportional to the square transported in solution in groundwater beneath of the water’s velocity. Clear water moving at a land surfaces. Groundwater may transport lead velocity of 100 feet per minute can carry a lead in solution from the higher topographic areas to particle 10,000 times heavier than water moving the lower areas such as valleys, where it is at a velocity of 10 feet per minute. Muddy water discharged and becomes part of the surface can carry even larger particles. The five factors water flow. If the water flowing underground that most influence velocity of runoff are passes through rocks containing calcium, described below: magnesium, iron, or other minerals more soluble then lead, or through minerals that raise the pH Rainfall Intensity - The greater the volume of of the water, then the lead in solution may be rainfall during a short period of time, the faster replaced (removed) from the solution by these the velocity created to carry the rainfall off-site. other metals. However, if the soil is a clean The higher the annual rainfall, the greater the silica sand and gravel, fractured granite, or number of periods of heavy rainfall. similar type material, then the lead may move long distances in solution. The factors most Topographic Slope - Generally, the steeper the likely to affect the amount of lead carried by the topographic slope, the faster the velocity of groundwater in solution are discussed below: stormwater runoff. Annual Precipitation - Generally, high Soil Type - More rainfall will soak into sandy precipitation rates result in heavy dew, more soils then into clay soils. Hence, for a given frequent rainfall, numerous streams, shallow rainfall intensity, the volume of runoff will be depth to groundwater, shorter distance of travel, greater from areas underlain by clays or other and more rapid rates of groundwater flow. Also, low permeable soils than from permeable sandy the greater volumes of rainfall over geologic time soil. probably have reduced the amount of calcium and other soluble basic minerals that could raise Velocity - Velocity tends to decrease as stream the water pH and cause lead to precipitate width increases. Merging streams, eddy (settle) out of solution from the groundwater. currents, and curves in streams are other factors that may reduce the velocity. Generally, the Soil Types - Clays have a high ionic lead shorter the distance from the lead deposit to the bonding capacity and more surface area to property line, the more likely it is that the lead which the lead can bond. Also, groundwater fragments in suspension will be transported off- movement in clay is very slow, which increases site. the contact time for lead to bond to the clay.

Chapter I - Page I-3 BMP for Lead at Outdoor Shooting Ranges

Low permeability reduces the amount of Federal, state and local actions, including bans historical leaching and increases the probability on lead in gasoline, paint, solder and many other of the presence of basic (pH-increasing) lead-containing products, have resulted in minerals that can precipitate out of solution in significant reductions in average blood-lead groundwater or cause the lead to bond to the levels. Despite these advances, the number of clay. All of the basic calcium and related lead-poisoned children remains alarmingly high. minerals generally will have been removed from Children living in older homes may be exposed the clean silica sand and gravel soils, so the to lead in peeling paint or paint dust. Children lead in solution in groundwater in these type can also come in contact with lead in soil and soils can move long distances (miles) through with lead dust carried home on the clothing of the ground relatively unchanged. parents.

Soil Chemistry - The more basic minerals like On ranges, inhalation is one pathway for lead calcium and magnesium that are present in soils exposure since shooters are exposed to lead along the pathways through which the dust during the firing of their guns. Because groundwater moves, the greater the lead wind is unlikely to move heavy lead particles precipitation (removal) rate. Lead should move very far, airborne dust is generally considered a in solution only a short distance (a few feet) potential threat only when there are significant through a sand composed of calcium shell structures that block air flow on the firing line. fragments, but could move in solution long Under such conditions, the hygiene and other distances (miles) through clean quartz sand. practices proposed by the NRA for indoor shooting ranges in their “Source Book” are Depth to Groundwater - In areas of applicable to outdoor ranges. groundwater discharge such as river flood plains and most flat areas, the groundwater surface is Range workers may also be exposed to lead often a few feet below the surface. Remember, dust while performing routine maintenance the shorter the distance traveled, the greater the operations, such as raking or cleaning out bullet risk that the lead will migrate into the traps. Owners/operators may want to protect environment. Shallow depth to groundwater is these workers by requiring them to wear the indicative of higher risk for lead to reach the proper protective equipment or dampening the water. soil prior to work. pH of Groundwater - Although other factors Another exposure route for lead at outdoor influence solubility of lead in water, a good rule of ranges is ingestion by direct contact with lead or thumb is that lead will precipitate out of solution lead particles. For example, lead particles when the pH or alkalinity of water is greater then generated by the discharge of a firearm can about 7.5. But, lead dissolved in acid collect on the hands of a shooter. These groundwater may travel many miles without particles can be ingested if a shooter eats or change. smokes prior to washing his/her hands after shooting. The relative risk of lead exposure to Health Effects of Lead Exposure on Ranges people in a well managed facility is low.

Lead poisoning is a serious health risk. At Detrimental effects due to elevated lead levels higher concentrations, it is dangerous to people can also be found in animals. Excessive of all ages, leading to convulsions, coma and exposure to lead, primarily from ingestion, can even death. At even very low concentrations, it cause increased mortality rates in cattle, sheep is dangerous to infants and young children, and waterfowl. For example, waterfowl and damaging the developing brain and resulting in other birds can ingest the shot, mistaking it for both learning and behavioral problems. Figure 1- food or grit. Waterfowl, in particular, are highly 1 describes the effects of exposure to lead on susceptible to lead ingestion. This is a concern children and adults. at ranges where shooting occurs into or over

Chapter I - Page I-4 BMP for Lead at Outdoor Shooting Ranges

Effects on the Human Body from Excessive Exposure to Lead

If not detected early, children with relatively low levels of lead (as low as 10 microgram/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, Hearing Problems - neurological disorders, - memory and concentration problems, Brain or Nerve Damage - muscle and joint pain, and - kidney dysfunction.

Slowed Growth

Digestive Problems

Lead affects the body in many ways Reproductive Problems (Adults)

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

Chapter I - Page I-5 BMP for Lead at Outdoor Shooting Ranges water. Many of the legal and government actions understand the legal issues and requirements. that have been brought against ranges are based on elevated levels of lead and increased 1.2.1 Resource Conservation and mortality in waterfowl. For example, in one case, Recovery Act (RCRA) an upland area of a range became a temporary pond after a thunderstorm. Waterfowl used the pond to feed and shortly thereafter, there was a RCRA provides the framework for the nation’s waterfowl die-off (increase in bird mortality), solid and hazardous waste management apparently from lead ingestion. program. Under RCRA, EPA developed a “cradle-to-grave” system to ensure the 1.2 Legal Requirements & Court protection of human health and the environment when generating, transporting, storing, treating Rulings and disposing of hazardous waste. RCRA potentially applies to many phases of range To date, most litigation concerns have been at operation because lead bullets/shot, if shotgun ranges where the shotfall zone impacts abandoned, may be a solid and/or a hazardous water or wetland areas. The potential waste and may present an actual or potential environmental and human health risks are imminent and substantial endangerment. greater at these ranges. However, all ranges, including those not located near water bodies, Connecticut Coastal Fishermen’s may be subject to legal and government action if Association v. Remington Arms Company, et proper range management programs are not al. implemented. Range owners/operators should expect greater scrutiny as ranges become more In the late 1980s, the Connecticut Coastal visible to regulators, environmental groups and Fishermen’s Association filed a lawsuit against the general public. Remington Arms Company as the owner of the Lordship Gun Club. The Lordship Gun Club Citizen groups have been the driving force (a.k.a. Remington Gun Club) is a 30-acre site in behind most legal actions taken against outdoor Stratford, Connecticut, located on the Long ranges. These groups have sued range owners/ Island Sound at the mouth of the Housatonic operators under federal environmental laws. Two River. In the mid-1960s, the Lordship Gun Club of EPA’s most comprehensive environmental was reconstructed to its final configuration of 12 laws, the Resource Conservation and Recovery combined trap and skeet fields and one Act (RCRA) and the Clean Water Act (CWA), additional trap field. Over the years, the specifically provide citizens with the right to sue Lordship Gun Club became known as one of the in cases in which the environment and human premier shooting facilities on the East Coast. health are threatened. These citizen suits have been highly effective in changing the way ranges The Connecticut Coastal Fishermen’s operate, even when out-of-court settlements Association filed a lawsuit, alleging that lead shot have been reached. The decisions of the United and clay targets are hazardous waste under States Court of Appeals for the Second Circuit in RCRA. The Complaint alleged that because the Remington Arms and New York Athletic Club set lead shot and clay targets were hazardous a legal precedent in the application of RCRA wastes, the gun club was a hazardous waste and/or the CWA to outdoor ranges. Lead storage and disposal facility subject to RCRA management programs at outdoor ranges must requirements. The plaintiff also sought civil comply with both laws. Actions have also been penalties and attorney’s fees. taken under the Comprehensive Environmental Response, Compensation and Liability Act Remington moved for a summary judgment (CERCLA) commonly know as Superfund. dismissing the complaint, and the Connecticut State and local statutes and regulations may Coastal Fisherman’s Association cross-moved also apply. To ensure environmental laws are for a partial summary judgment on the issue of being followed, range owners/operators must liability. On September 11, 1991, the United

Chapter I - Page I-6 BMP for Lead at Outdoor Shooting Ranges

States District Court for the District of are not subject to RCRA regulations, EPA or any Connecticut ruled on the case. state, municipality, or citizen group can take legal action under the statutory provisions of Regarding the plaintiff’s claims under RCRA, the RCRA against gun clubs for actual or potential District Court ruled in favor of the Connecticut environmental damage occurring during, or even Coastal Fishermen’s Association, holding that after, the operation of the club. Under RCRA, the lead shot and clay targets were “discarded the plaintiff would be eligible to recover its legal materials” and were “solid waste;” therefore, the fees as well. materials were subject to regulation under RCRA. The court further stated that the 3. The court concluded that lead shot and discharged lead shot was a “hazardous waste,” clay targets meet the statutory definition of solid but declined to rule on whether the clay target waste because these materials were “discarded fragments were also hazardous waste. (i.e. abandoned)” and “left to accumulate long Remington petitioned the United States Court of after they have served their intended purpose.” Appeals for the Second Circuit Court to review Further, the court concluded that based upon the lower court’s ruling. toxicity testing and evidence of lead contamination, the lead shot was a hazardous On June 11, 1992, both parties presented oral waste subject to RCRA. arguments before the court. Subsequent to oral arguments, the appellate court requested that The important point to consider here is that if EPA file an amicus brief “addressing whether lead shot and clay target debris are discarded lead shot and clay target debris deposited on (i.e. abandoned), these materials are considered land and in the water in the normal course of a solid waste as defined in the statute and the trap and skeet shooting is ‘discarded material’... facility may be subject to governmental or citizen so as to constitute ‘solid waste’ under RCRA.” suits.

On March 29, 1993, the United States Court of If, on the other hand, the discharged lead shot is Appeals for the Second Circuit reached its recovered or reclaimed on a regular basis, no decision. With respect to RCRA, the court both statutory solid waste (or hazardous waste) reversed and affirmed the lower court’s opinion would be present and imminent hazard suits in part. would be avoided.

Briefly, the decision affects currently operating Thus, the Remington Arms case is an important and future gun clubs, and the following key legal precedent. Even though regulations have points are of primary concern: not been issued regarding gun club operations and environmental protection, gun clubs are still 1. With respect to RCRA, the court agreed at risk of legal action under RCRA if they fail to with EPA’s amicus brief, which had argued that routinely recover and reclaim lead, do not take shooting at gun clubs is not subject to regulatory steps to minimize lead release or migration, or if (as opposed to statutory) requirements. In other they abandon lead in berms. words, during routine operations, gun clubs are not viewed as facilities that manage hazardous Gun clubs where there is shooting into water, wastes subject to RCRA regulations and, as wetlands, rivers, creeks, and other sensitive such, do not require RCRA permits. environments have the highest degree of litigation risk. Conversely, gun clubs that have 2. Another argument in the EPA’s amicus the lowest risk of environmental litigation or brief with which the court agreed was the view government action are those clubs that do not that the RCRA statute allows citizen suits to be shoot into water or wetlands and which have an brought if a gun club’s shooting activities pose active program to recover lead. an “imminent and substantial endangerment to health or the environment.” Although gun clubs The following describes how RCRA may apply to outdoor shooting ranges. Chapter I - Page I-7 BMP for Lead at Outdoor Shooting Ranges

How is Lead Shot Regulated Under reclamation. Therefore, only reputable RCRA? reclaimers should be utilized. • Lead from ranges destined for recycling may Lead shot is not considered a hazardous waste be temporarily stored on range property after subject to RCRA at the time it is discharged separation from soil if the lead is stored in from a firearm because it is used for its intended closed, sealed containers, the containers are purpose. As such, shooting lead shot (or stored in a secure location and routinely bullets) is not regulated nor is a RCRA permit inspected by range staff, and records of required to operate a shooting range. However, inspections are maintained. spent lead shot (or bullets), left in the environment, is subject to the broader definition • Sections 7002 and 7003 of the RCRA statute of solid waste written by Congress and used in allow EPA, states or citizens to use civil sections 7002 and 7003 of the RCRA statute. lawsuits, to compel cleanup of or other action for “solid waste” (e.g., spent lead shot) posing With reference to reclaiming and recycling lead actual or potential imminent and substantial shot, the following points should serve as endangerment. Such actions can be sought guidance in understanding RCRA and how it whether the range is in operation or closed, applies to your range. (A more detailed and is based solely on a determination that discussion of the underlying RCRA rules harm is being posed or may be posed by the applicable to lead shot removal at ranges is range to public health and/or the environment. included in Appendix D) Since the risk of lead migrating increases with time, making ranges that have not removed • Removal contractors or reclaimers should lead more likely candidates for government apply standard best management action or citizen lawsuits under RCRA Section practices, mentioned in this manual, to 7002 and 7003, ranges are advised to separate the lead from soil. The soil, if maintain a schedule of regular lead removal. then placed back on the range, is exempt from RCRA. However, if the soil is to be • With time, lead in soil can become less removed off-site, then it would require desirable to reclaimers and smelters, thereby testing to determine if it is a RCRA potentially reducing or eliminating financial hazardous waste. returns from lead removal. Moreover, such soil may be subject to more expensive • Lead, if recycled or reused, is considered treatment to separate the lead for recycling. a scrap metal and is, therefore, excluded from RCRA. • Lead removal will allow the range to: avoid contamination of the site and potential impacts • Collected lead shot and bullets are excluded to human health and the environment; reduce from RCRA regulation, and need not have a liability with regard to potential government manifest, nor does a range need to obtain a agency or citizen suit action; and, possibly, RCRA generator number (i.e., the range is benefit economically from the recycling of not a hazardous waste “generator”), provided lead. Additional guidance on reclaiming lead that the lead is recycled or re-used. The is provided in other parts of this manual. reclaimer does not need to be a RCRA transporter. However, it is recommended • Soil from berms and shotfall zones may be that ranges retain records of shipments of moved to another area of the range for such lead to the receiving facilities in order to reasons as addressing potential demonstrate that the lead was recycled. environmental impacts (e.g., runoff), altering Records should also be kept whenever the layout to address safety concerns or the lead is reused (as in reloading.) The allowing different types of shooting activities, range should be aware that it ultimately or adding or removing shooting positions. may be responsible for the lead sent for However, removal of lead prior to such

Chapter I - Page I-8 BMP for Lead at Outdoor Shooting Ranges

movement of soil is normal practice and highly advised because it extends the usable In the Remington Arms and the New York life of the materials and reduces the Athletic Club lawsuits, citizen groups argued that possibility of release of lead into the the defendants violated the CWA by discharging environment. If lead is not first removed, it pollutants from point sources into the Long will be further dispersed and will be more Island Sound without a NPDES permit. difficult to remove in future reclamation. Application of the CWA requires the violations to Written records of all such activity should be be ongoing. Consequently, the court in maintained indefinitely, as they will be Remington Arms dismissed the CWA charge necessary in subsequent construction or against the range because it had ceased range closure. operating before the lawsuit was filed.

• This RCRA summary applies to operating However, in the New York Athletic Club case, and non-operating ranges, and the use of the club was still in operation during the time of BMPs at operating ranges is highly litigation, but had switched to steel shot. EPA’s recommended. However, because of opinion on this case also addressed the CWA increased risk if lead is not actively managed, violation. EPA argued that certain trap/skeet such application may not preclude the need ranges can convey pollutants, via point sources, for remediation, as appropriate and/or as to water in violation of the CWA if a NPDES required by states’ regulations, when a range permit is not obtained. Although some shooting is permanently closed, on-site lead is organizations have disagreed with the EPA abandoned, or the land use changes. position, the United States District Court for the Introductory guidance for remediation can be Southern District of New York specifically found found at www.epa.gov/epaoswer/osw or that: www.epa.gov/superfund. Look under the sections “Cleanup” or “Resources,” or use • The mechanized target throwers, the the Search function. concrete shooting platforms, and the shooting range itself are considered point 1.2.2 - Clean Water Act sources as defined by the CWA;

The goal of the Clean Water Act (CWA) is to • Expended shot and target debris, including “restore and maintain the chemical, physical, non-toxic shot, such as steel shot, left in and biological integrity of the Nation’s waters.” water, are pollutants as defined by the CWA. The most common allegation against ranges by the EPA and citizen groups, is that they violate Although the New York district court’s decision in the CWA if they do not have permits that allow the New York Athletic Club case is not spent ammunition to be discharged into water. controlling in any other district, range owners The CWA prohibits “the discharge of any and operators of outdoor ranges that shoot over pollutant by any person” into the waters of the or into wetlands or other navigable waters of the United States without a National Pollution United States should be aware of it. Discharge and Elimination System (NPDES) Based on the court’s decision in the New York permit. There have been two court cases that Athletic Club case, any range whose shot, have applied the provisions of the CWA to bullets or target debris enter the “waters of the civilian shooting ranges. To understand how the United States” could be subject to permitting CWA can apply to shooting ranges, a summary requirements as well as governmental or citizen of the cases follows. Also see Table 1-1. suits. “Waters of the United States” or “navigable waters of the United States” are To understand the application of the CWA to waters of the United States, including territorial outdoor ranges, one must know the definitions of seas that include any body of water that has any key terms and how they have been applied to connection to, or impact on, interstate waters or shooting activities. See Table 1-1. commerce. The waters may include lakes,

Chapter I - Page I-9 BMP for Lead at Outdoor Shooting Ranges

Table 1-1: Application of Key Terms to Outdoor Ranges

Key Term Statutory Definition Application to New York Athletic Club

Discharge of a "any addition of any pollutant to Shooting into water (including wetlands) Pollutant navigable waters from any point constitutes a discharge. In the New York source" (emphasis added) Athletic Club, the range did not dispute that its shooting operations resulted in the 33 U.S.C. § 1362 (12) deposition of spent shot and other debris into the waters of the United States. Pdoint Source "any discernible, confined, an In New York Athletic Club, the court found discrete conveyance... from which that shooting ranges act to systematically pollutants are or may be channel pollutants into regulated waters discharged" into the Nation's and that mechanized target throwers waters. convey pollutants directly into water. Specifically, it stated, "A trap shooting 33 U.S.C. § 1362 (14) range... is an identifiable source from which spent shot and target fragments are conveyed into navigable waters of the United States." The court also determined that the concrete shooting platforms can be seen as separate "point sources" under the CWA or as one facet of the shooting range that systematically delivers pollutants (e.g. shot and wadding) into the water. P.ollutant "dredged spoil, solid waste,.. In New York Athletic Club, shot and target munitions... discharged into residue constitute a form of "solid waste" water" subject to regulation under the CWA as a "pollutant." Based on these 33 U.S.C. § 1362 (6) determinations, the court supported EPA's contention that the ranges were discharging pollutants from a point source without a permit, in violation of the CWA.

Chapter I - Page I-10 BMP for Lead at Outdoor Shooting Ranges ponds, rivers, streams, wetlands, or even guts 1.2.3 Comprehensive Environmental that are frequently dry, which may not be Response, Compensation, and obvious to range owners/operators. These Liability Act (CERCLA) ranges may be required to remediate contaminated sediments and soils, which could The Comprehensive Environmental Response, be both difficult and expensive, and to cease Compensation, and Liability Act (CERCLA), operations over waters and wetlands. It is imposes liability on past and present owners or essential that these ranges change the operators of properties where a release of a direction of shooting, to avoid shooting over hazardous substance into the environment or into wetlands or other navigable waters of exists. CERCLA is used to ensure that an the United States, and initiate lead removal owner/operator cleans a contaminated site or to and recycling activities, where feasible. seek reimbursement from past owners/operators or disposers (potentially responsible parties or In addition, these ranges can cause a PRPs) when a party, either the government or substantial impact on wildlife and wetlands, private party, has cleaned up the contamination. which range owners/operators may be required Under CERCLA, lead is considered a hazardous to restore under other federal laws (e.g., substance. CERCLA, discussed below). Lead shot entering a water body substantially increases EPA has the authority to order a PRP to clean up the potential risk of contaminating surface and a site or conduct the cleanup and recover its groundwater which, in turn, threatens human costs from the PRP under CERCLA. health and the environment. Finally, as New Responsible parties may be held liable for all York Athletic Club, Remington Arms and similar cleanup costs, which can be substantial. Under cases show, neighbors have the most leverage CERCLA, shooting ranges may be liable for when range activity affects wetlands and government costs incurred during the cleanup waterways. of ranges, natural resources damages, and health assessments and/or health effects For ranges located away from coastal areas or studies. The following two examples illustrate whose operating areas are situated wholly over how shooting ranges (including one operated by land, compliance with the CWA can be achieved the federal government) can be affected by by obtaining a NPDES permit for piped or 1 CERCLA. channeled runoff from the range into water . Southern Lakes Trap and Skeet Club Site, Shooting ranges impacting wetland areas may Lake Geneva, Wisconsin, et al. be subject to other regulations found in Section 404 of the CWA. This section is the principal In 1992, the US Fish and Wildlife Service federal regulatory program protecting the (USFWS) began an investigation to determine Nation’s remaining wetland resources. Any plan the cause of death of over 200 Canada geese. by range owners/operators to dredge and/or fill The geese died as a result of acute lead wetlands may require a permit and will come poisoning after ingesting lead shot, which under close scrutiny by federal, state and local research indicated came from the Southern governments and citizen groups. Owners and Lakes Trap and Skeet Club. The USFWS, in its operators must comply with the CWA for range role as Natural Resource Trustee, took action to design, redesign, construction, reclamation or recover the cost of damage to the natural remediation occurring in wetland areas. resources (i.e., migratory geese) under CERCLA. In addition, EPA pursued a separate action under the Agency’s CERCLA response authority. The club had leased the property from the property owners to operate a shooting range. Shortly after EPA sent out the notice of potential 1 The term “land” in this instance refers specifically to terrain recognized as “non-wetland” areas. liability to the current and former owners and

Chapter I - Page I-11 BMP for Lead at Outdoor Shooting Ranges operators of the club site, the club closed have adopted their own environmental laws, permanently. which are based on federal laws. Specifically, these states have laws and regulations that In 1994, EPA issued an Administrative Order on mirror the CWA and RCRA program laws. EPA- Consent (AOC) against one current and one approved state program laws must be as former owner of the property where the now stringent as the federal laws and may be more closed Southern Lakes Trap and Skeet Club was stringent. Activities at shooting ranges may also located. The AOC required the owners to be subject to local laws, ordinances and perform a site assessment, which included an regulations addressing issues such as noise, evaluation of the costs to restore the wetlands. zoning, traffic, wetlands and nuisance. Often, In 1998, EPA completed activities to clean up the citizens or neighbors of outdoor shooting ranges site and restore some of the natural resources can initiate noise nuisance claims against and wetlands. In a negotiated settlement, EPA range owners/operators. Because many states recovered $1 million of the cost of the cleanup. have passed legislation protecting ranges from noise nuisance lawsuits, these may turn into Walter L. Kamb v. United States Coast Guard, claims of environmental violations under the et al. laws discussed above due to the presence of lead and other products at ranges. In another CERCLA action, Mr. Kamb (court appointed property guardian) sued the U.S. 1.3 Benefits of Minimizing Coast Guard, California Highway Patrol, City of Fort Bragg, and the County of Mendocino (the Lead’s Environmental Impact defendants) for recovery of cleanup costs under CERCLA. Mr. Kamb had been appointed by the All ranges will benefit from proactively Mendocino County Superior Court to sell the implementing successful BMPs. Even if range property on behalf of the property owners. The activities currently do not cause adverse public property was formerly used by defendants as a health and environmental impacts, by developing rifle, pistol and trap range. Soil analysis and promoting active lead management indicated the presence of lead in the form of programs, ranges will benefit in the following leadshot, bullets, pellets, and dust. The court ways: found the defendants were “responsible parties” (liable for cleanup costs) under CERCLA. No • Through a sound lead management apportionment of liability was made and the final program, shooting sports enthusiasts can determination of each parties’ pro rata share of reduce the potential of lead exposure and the response cost was deferred. contamination to humans, animals and the environment. This case shows that range activity need not affect a water body to trigger CERCLA liability. • A lead management program will result in CERCLA is a powerful statutory authority that improved public relations for the range can greatly impact current and former range and the shooting sports. Ranges can owners/operators. The statute allows for promote and publicize their successful BMP recovery of damages to natural resources, the programs to improve their public image. cost of any health assessment studies and all Since many of the legal and governmental cleanup costs. Liability may extend to past actions begin with or are due to citizen owners and operators long after a range ceases groups, an active lead management program operation. may improve the public image of the range with these citizen groups. 1.2.4 Additional Laws and Regulations • The removal of spent lead from the range presents a clean, well maintained facility, Shooting ranges may also be subject to state which will increase customer satisfaction. and local laws and regulations. Many states

Chapter I - Page I-12 BMP for Lead at Outdoor Shooting Ranges

• Lead is a recyclable and finite resource and can be recovered from the active portion of ranges and sold to lead reclaimers. Frequently, reclaimers do not charge range owners/operators to recover lead from ranges, and owners and operators may receive a percentage of the profit from the sale of reclaimed lead. This factor drives recycling efforts at many ranges.

• By reducing or eliminating a potential source of lead migration in soil, surface water and groundwater, range owners/ operators may avoid costly and lengthy future remediation activities.

• Finally, implementing a BMP program for lead may eliminate or greatly reduce the risk of citizen lawsuits and the legal costs associated with these lawsuits. Through management and removal practices, lead may no longer represent a threat upon which citizen lawsuits are based.

Range owners/operators may question whether the benefits of a regular and timely BMP program outweigh the efforts of implementing and maintaining a program. The questions may arise especially for ranges at which shooting activities involve waterways, since national attention has focused on ranges located adjacent to water (e.g., Remington Arms and the New York Athletic Club). However, all outdoor ranges may be subject to legal actions under RCRA and CERCLA authority. All of the benefits for adopting best management practices are available and worthwhile for every range owner and operator.

The following sections provide information that will assist the range owner or operator in implementing a BMP program for recovery and recycling of lead shots and bullets.

Chapter I - Page I-13 This page intentionally left blank BMP for Lead at Outdoor Shooting Ranges 2.1 Physical Characteristics Chapter II: Range Characteristics & Physical characteristics of ranges, relative to Activities to Consider When lead management issues, are discussed below. Implementing Best Management Practices (BMP) Range Size

Shotgun range design and type affects the ease 2.0 Background of lead shot collection. Larger ranges typically tend to have lead shot that is dispersed over a Since each firing range site is unique, BMPs wider area, while smaller ranges tend to for lead must be selected to meet site- concentrate lead shot in a smaller area. specific conditions in order to achieve Reducing the area of the shotfall zone will maximum success. A range’s physical concentrate the shot within a smaller area, characteristics and the operational aspects (e.g., allowing for easier cleanup and reclamation. volume of shooting, shooting patterns and BMP techniques for reducing the shotfall zone at operating schedules) will effect which BMPs trap and skeet ranges, as well as sporting clay may apply and how they will be implemented. ranges, are discussed in Chapter III. Accordingly, whether designing a new outdoor range or operating an existing range, it is Soil Characteristics important that BMPs incorporate techniques appropriate for the range’s individual Spent lead bullets and shot are most often characteristics. deposited directly on and into soil during shooting. When lead is exposed to air and water, Section 2.1 of this chapter identifies the physical it may oxidize and form one of several characteristics that must be considered when compounds. The specific compounds created, evaluating your range. A summary of common and their rate of migration, are greatly influenced physical characteristics at ranges is also by soil characteristics, such as pH and soil presented in Table 2-1. These factors include: types. Knowing the soil characteristics of an existing range site is a key component to • Range Size (primarily for shotgun ranges) developing an effective lead management • Soil Characteristics plan. • Topography/Runoff Direction • Annual Precipitation Soil pH • Ground and Surface Water • Vegetation 1234567891011121314 • Accessibility

Section 2.2 discusses the operational aspects Acidic Neutral Alkaline that must be considered. These factors include: = Ideal Soil Range

• Lead Volume Figure 2-1 – pH scale • Size of Shot/Bullets • Operating Schedule Soil acidity is measured as pH on a scale • Shooting Direction and Pattern (illustrated as Figure 2-1) between 1 (most • Range Life Expectancy acidic) and 14 (most alkaline, or basic), where 7 is termed neutral. Ideal soil pH for shooting In addition, Section 2.3 discusses issues that ranges is 6.5 to 8.5.1 are specific to implementing BMPs when 1 National Shooting Sports Foundation, “Environmental Aspects planning a new range. of Construction and Management of Outdoor Shooting Ranges,” June 1997.

Chapter II - Page II-1 BMP for Lead at Outdoor Shooting Ranges

Lead reacts more readily and may become more arid regions. This is especially true of outdoor mobile under acidic (pH < 6) or higher alkaline ranges using “Steel Bullet Traps.” (pH>8) conditions. This means that spent lead shot left in or on such soils may eventually break Steel bullet traps build up a layer of lead residue; down and contaminate underlying soil. In these particles are extremely small and more moderately alkaline soils (pH 7 - 8.5), the lead easily transported by rain/water. Also, the precipitates out of solution and binds to the soil. smaller the particle, the quicker it will degrade. A This “binding” effect prevents the lead from bullet trap needs to have a means to collect migrating to the subsurface. In general, soils in contact water, or be covered to prevent water the eastern part of the United States tend to be from reaching it, and to minimize releases and acidic, whereas western soils tend to be more degradation. alkaline. Topography/Runoff Directions Soil Physical Characteristics The topography of your range impacts both the The migration rate of specific lead compounds is ease of lead reclamation and the mobility of the affected by the physical characteristics of soil. lead. For example, lead reclamation is more For example, dense soils, consisting of heavy successful at ranges where the shotfall zone is clays, will prevent the lead compound from relatively flat, since many lead reclamation moving quickly through the subsurface. Any companies use heavy machinery that cannot “free” lead ions become attached to clay operate on slopes or steep hills. particles, with this bond helping to prevent migration. However, with denser soils, the Another important characteristic is the direction amount of surface runoff increases. in which your range topography slopes. During and after periods of rain, stormwater runoff may Although clay soils inhibit migration, lead wash lead particles or lead compounds off the reclamation by contemporary removal range. If there are surface water bodies such as machinery tends to be more difficult in clayey lakes, rivers, or wetlands downgradient, the conditions. Clayey soils tend to clog the potential for lead to adversely affect the screens and “bind” with shot and bullets. This surrounding environment is even greater. situation may require additional traditional Therefore, it is important to identify and control screening, or perhaps screening using water to the direction of surface water runoff at your enhance separation. range. BMPs for modifying and controlling runoff are described in detail in Chapter III. In contrast, sandy soils or gravel may not impede migration because the open pores of Groundwater these soils allow lead compounds to percolate quickly. Fortunately, lead reclamation activities Groundwater depth should be considered are more easily conducted in sandy soils. With when developing a lead management plan this in mind, ranges located in sandy soils since the closer the groundwater is to the should remove lead more frequently. surface, the greater the potential for dissolved lead to reach it. Annual Precipitation Vegetation One of the most important factors that influences lead degradation (i.e., chemical reactions) and Vegetative ground covers can impact the migration is precipitation. Water, most often in mobility of lead and lead compounds. the form of rain, provides the means by which Vegetation absorbs rainwater, thereby reducing lead is transported. In general, ranges located in 2 areas with high annual/seasonal rainfall have a 2 Heavy annual rainfall is anything in excess of the average annual higher risk of lead migration than those located in rainfall, which for the northeast United States (e.g. New York, New Jersey) is between 40 and 45 inches.

Chapter II - Page II-2 BMP for Lead at Outdoor Shooting Ranges

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

Physical Potential Risk to Environment Potential Benefits in Preventing/Managing Characteristics Contamination

Cnlay, acidic soils Acidic soils contribute to lead dissolutio May impede percolation of water through -- increasing the potential for lead contaminated soil contamination Binds "free" lead ions -- may increase run-off May benefit growth of vegetative covers Difficult to reclaim lead via sifting/raking

Sandy, alkaline Contaminated rainwater can easily Alkaline soils may inhibit lead dissolution soils percolate through soil and groundwater Easier to reclaim lead via sifting/raking Extremely alkaline soil will not support vegetation

Snandy, acidic soils Acidic soils contribute to lead dissolutio Easier to reclaim lead via sifting/raking -- increasing the potential for lead contamination

Contaminated rainwater percolates quickly through sandy soils

Steep Rolling May promote off-site drainage or None Terrain drainage to on-site surface water bodies

Can impede reclamation of expended shot via raking

F,lat Terrain Rainwater may "pond" in areas Expended shot easily recovered promoting lead dissolution and contamination Off-site drainage minimized

Wooded areas May impede lead reclamation activities None making equipment difficult to maneuver

May provide habitat for wildlife - increasing exposure to lead

On-site or VERY high potential for contamination None contiguous surface when shot fall zone is located over or water bodies adjacent to water; increased wildlife exposure; increased lead dissolution. This is NOT an option for successful range location and may be more likely subject to litigation and/or governmental action if lead is deposited into water bodies

Vegetation Lead may be absorbed into grasses, Ground covers slow down surface water run- other wildlife food sources on and run-off

Some vegetation can extract lead ions from the soils

Chapter II - Page II-3 BMP for Lead at Outdoor Shooting Ranges the time that the lead is in contact with water. Shooting Direction and Patterns Vegetation also slows down surface water runoff, preventing the lead from migrating off-site. Shooting directions and patterns are However, excessively wooded areas (such as important to consider when determining the those often used for sporting clay ranges) inhibit effectiveness of bullet containment devices. lead reclamation by making the soils For example, many bullet traps are effective in inaccessible to some large, lead-removal containing bullets fired from specific directions. machinery. Understanding the type, It is vital that you utilize bullet containment concentration and variety of vegetation on your devices that match your range’s specific range is necessary for developing your lead shooting patterns and manufacturers management program and implementing BMPs specifications. Understanding the shooting at your range. direction and patterns will also help to correctly identify the shotfall zone at trap and skeet Accessibility ranges.

Accessibility to shotfall zones and backstops Shooting into Water Bodies is extremely important for lead reclamation activities. A range that is not accessible to Shooting into water bodies or wetlands reclamation equipment will have difficulty should not occur. Besides the environmental implementing lead reclamation practices. impacts discussed previously, the introduction of lead to surface water bodies will likely cause a 2.2 Operational Aspects range to be susceptible to litigation and/or governmental action. Shooting into water bodies Operating practices can have a great affect on or wetlands is NOT an option for ranges that the volume and dispersion of lead at your range. want to survive in the future.

Lead Volume Range Life Expectancy and Closure

Keeping records of the number of rounds The life span of your range may be impacted by fired over time at your range is important. many factors, including financial and The number of rounds fired provides a realistic environmental issues, noise, and encroachment estimate of the quantity of lead available for on residential areas. If your range is slated for reclamation. This information helps to determine closure, contact your local state or EPA when reclamation is necessary in order to representatives for guidance. prevent accumulation of excess amounts of lead, thereby decreasing the potential for the 2.3 Planning a New Range lead to migrate off-site. As discussed in the previous sections, site Size of Shot/Bullets characteristics and operational aspects affect lead migration, degradation and reclamation Knowledge of the size shot/bullets used on activities at ranges. If you are planning on your range may be helpful. Lead reclamation opening a new range, you should select and/ companies generally use physical screening or design a site in consideration of the techniques to separate lead shot and bullets factors discussed in this manual. This will from soil. These screens come in a variety of allow you to minimize the potential of lead sizes. Knowing what size shot/bullets have impacting your site or adjacent properties. A been used at your range will allow the reclaimer new range owner has the advantage of being to maximize the yield of lead shot/bullets at your able to design a successful lead management range. program in full consideration of the site characteristics and recommended BMPs. This advanced understanding of operational aspects

Chapter II - Page II-4 BMP for Lead at Outdoor Shooting Ranges and requirements will allow you to minimize the potential for lead migration prior to opening.

The most important site selection criteria to consider when selecting a new range location include: topography; surface water flow patterns; and depth to groundwater. If possible, ranges should be developed on flat terrain, as it facilitates reclamation and reduces the chance of off-site migration due to surface water runoff as compared with highly sloped terrain. When considering a prospective location for a range, ask yourself: What is the direction of surface water runoff? Does the site drain to surface water (e.g., streams, rivers) on-site? Off-site? Can the range design be modified to minimize potential runoff? Is reclaimation equipment accessible to the area to clean the range?

By selecting an appropriate location and designing a lead management program in consideration of site characteristics, new shooting ranges can be developed to minimize the potential for lead contamination. Other important site characteristics can be modified. For example, a new shotgun range can be designed to concentrate the shotfall area, vegetation can be added or altered, and the most advantageous shooting direction can be selected. These modifications are BMPs, and are discussed in further detail in Chapter III.

Chapter II - Page II-5 This page intentionally left blank BMP for Lead at Outdoor Shooting Ranges

practices that should be followed between lead Chapter III: reclamation events. Best Management Practices (BMPs) For Outdoor Ranges It is important to note that the cost and complexity of these BMPs vary significantly. It is your range’s individual characteristics that will determine which BMPs should be implemented. The specific BMPs are described 3.0 Background more fully below.

To operate an outdoor range that is 3.1 Bullet and Shot Containment environmentally protective requires implementing an integrated lead management Techniques (Step 1) program, which incorporates a variety of appropriate BMPs. These BMPs create a four 3.1.1 Bullet Containment step approach to lead management: Knowing where spent lead is allows the Step 1 - Control and contain lead bullets appropriate BMP to be used. The single and bullet fragments most effective BMP for managing lead in Step 2 - Prevent migration of lead to the these areas is by bullet containment. subsurface and surrounding surface Owners/operators should employ a water bodies containment system that allows for the Step 3 - Remove the lead from the range maximum containment of lead on-site. The and recycle containment systems mentioned in this section Step 4 - Documenting activities and are for reference only. Each containment design keeping records for a range is site specific. Each owner/operator must look at the various factors in determining An effective lead management program requires which containment system is best for his or her implementing and evaluating BMPs from each range. Some factors include: overhead, cost of of the four steps identified above and illustrated installation, maintenance (e.g., creation of lead as Figure 3-1. The BMPs discussed in Sections dust from steel containment systems). Range 3.1 and 3.2 should not be considered owner/operators should consult with various alternatives to lead reclamation, but rather contractors to determine which containment system is best for their range.

S2tep 1 S3tep S4tep Step

Control and Contain Prevent Migration Remove and Recycle Document Activities (Section 3.1) (Section 3.2) (Section 3.3) and Record Keeping (Section 3.4)

-- Bullet containment -- Monitor and adjust -- Hand raking and -- Document number of soil pH (e.g., lime sifting rounds fired/shot size ~ Earthen Backstops spreading) -- Screening -- Document BMP(s) ~ Sand Traps -- Immobilize lead e.g., used at ranges to phosphate spreading) -- Vacuuming control migration ~ Steel Traps -- Control runoff -- Soil washing -- Document date and ~ Lamella or Rubber provider of services Granule Traps ~ Plant vegetation -- Working with a and utilize organic reclaimer -- Keep records for the ~ Shock Absorbing ground cover life of the range and Concrete -- Recycling at east 10 years after ~ Implement closing -- Shot Containment engineered runoff controls -- Evaluate the ~ Reduce shotfall effectiveness of zones BMPs used

Figure 3-1 – 4 Steps to Build a Successful Lead Management Program Utilizing a Variety of BMPs Chapter III - Page III-1 BMP for Lead at Outdoor Shooting Ranges

This section discusses BMPs for controlling backstop (earthen material, i.e., sand, soil, etc., spent lead bullets and fragments in a which is located directly behind the targets). “controlled” and well-defined area behind the The earthen backstop is generally between 15 target area. Containing bullets and bullet and 20 feet high with a recommended slope as fragments is critical to successfully managing steep as possible1. In many instances, lead. backstops may be naturally occurring hillsides. When using an earthen berm or backstop, There are a variety of containment device ensure that the uppermost layer (to a depth of options available that serve as BMPs to control one to two feet) exposed to the shooting activity lead. The principle behind all of them is trapping is free of large rocks and other debris. These and containing the actual bullet. They include: materials tend to increase ricochet and bullet fragmentation, which will, in turn, make lead Earthen Berms and Backstops reclamation activities more difficult, not to Sand Traps mention possible safety issues. Steel Traps Removal of lead from earthen backstops may Lamella or Rubber Granule Traps require lengthy reclamation (see Section 3.3) of Shock Absorbing Concrete the soil to remove the lead. Continued use of the backstop without removing the lead may For each type of trap, design variations have result in increased ricochet of bullets and been developed to fit the specific needs of an fragments. In addition, the backstop may lose individual range. Below are discussions of each its slope integrity because of “impact pockets” general category of trap. Some bullet that develop. Once the lead has been removed containment devices are so comprehensive that from the earthen backstop, the soil can be they virtually eliminate lead’s contact with the placed back on the range and used again. environment. Adding lime and phosphate during the rebuilding process is recommended as appropriate (see However, it is important to discuss all types of Section 3.2). However, other bullet containment bullet containment devices because they are techniques, including those listed below, should part of comprehensive BMPs for managing lead be considered prior to reestablishing an earthen at rifle and pistol ranges. backstop.

EPA does not endorse any bullet containment Sand Traps design as being “better” than another. Different containment designs attempt to eliminate lead’s A variation of the earthen backstop is the sand contact with the environment, however, trap. Sand traps range from those that are additional BMPs may be required for lead simply mounds of sand or soil located directly management. behind the bullet targets, which serve as backstops to a sand trap that employs a system EPA recommends that you discuss your designed to contain, collect and control lead and range’s bullet containment needs with a contact water. This sand trap uses a grade of variety of vendors before deciding what type sand that is ballistically acceptable. Regular of containment device to use. This manual maintenance must be performed to remove does identify the possible advantages and larger particles (bullets) from the impact area. disadvantages associated with each These traps are placed so that bullets fired containment device in Table 3-1, at the back of across the range pass through the targets and this chapter. become embedded in the sand. These traps are typically 15 to 20 feet high with a slope as Earthen Berms and Backstops

Perhaps the most common bullet containment 1. National Rifle Association, “The NRA Range Source Book: A Guide to Planning and Construction,” June system at rifle and pistol ranges is the earthen 1998 Chapter III - Page III-2 BMP for Lead at Outdoor Shooting Ranges steep as possible. The most important design trap is full, or on a more frequent basis, the spent criterion for these traps is that the uppermost lead can easily be reclaimed for recycling. layer (to a depth of 1 to 2 feet) be free of large rocks and other debris to reduce ricochet and With some steel traps, expended lead bullets bullet fragmentation, and to facilitate reclamation may not come in direct contact with soils, efforts. There may also be an impermeable thereby possibly minimizing lead’s contact with layer (e.g., clay or liner) under the sand to the environment. Consequently, the need for prevent lead from contacting the soil underlaying other BMPs (e.g., lime spreading, and/or the trap. engineering controls), such as those required at ranges with unlined earthen backstops or Sand traps come in various designs and levels unlined sand traps, may be avoided if this trap of complexity. The sand trap may be ballistic design is selected for the range’s bullet grade sand contained in a high backstop, or a containment device. In addition, bullet removal more complex “Pit and Plate” system. The Pit is somewhat easier than from a sand trap, and and Plate system uses an angled, steel may only require emptying the bucket or tray deflection plate cover that helps to direct bullets containing the bullets and/or bullet fragments. and bullet fragments to the top layer of sand However, an increase of lead dust and only. Some of the more sophisticated sand fragmented lead may be an additional traps incorporate lead recovery devices. environmental concern. Therefore, However, the Pit and Plate may increase the understanding the amount of lead dust and surface-to-mass ratio of the bullet splatter and, fragments is important to a successful lead therefore, may increase environmental risk of management program. Also, some steel trap lead migration. designs are not intended for shooting at different angles, therefore limiting the shooter to shooting Regardless of the type of sand trap that is used, straight on (no action shooting). the traps become saturated with bullets/bullet fragments. Once this happens, the sand must As with sand traps, steel traps vary in design be sifted (see Section 3.3) to remove the bullets. and complexity. For example, the Escalator The recovered bullets can then be sold to a lead Trap has an upward sloping deflection plate that recycler (this is discussed in more detail later in directs bullets into a spiral containment area at the chapter). After sifting, the sand can be the top. The Vertical Swirl Trap is a modular, returned to the trap. Continued use of the trap, free standing trap with four steel plates that without removing the lead, may result in an funnel the bullets into a vertical aperture in increased risk of ricocheting off the backstop which they spin, decelerate, and become and thus creating an increased safety hazard. trapped in a bullet collection container. The Wet Furthermore, the sand trap will become unstable Passive Bullet Trap is equipped with steel over time. Sand traps may be located over an deflection plates that slope both upward and impermeable liner, to prevent lead from downward. The upwardly sloped deflection contacting soil underlying the trap. This will plate is covered with an oil/water mixture to help provide additional protection to soil and reduce the occurrence of ricochet and bullet groundwater. fragmentation. The bullet follows its own path in the round deceleration chamber for bullet Steel Traps recycling.

Steel traps are located directly behind the Lamella and Rubber Granule Traps targets so that expended bullets, along with bullet particles, are directed into some form of The Lamella Trap uses tightly-hanging, vertical deceleration chamber. Once inside the strips of rubber with a steel backing to stop chamber, the bullets decelerate until the bullets/ bullets. This trap is located directly behind the bullet particles fall into collection trays at the targets and, in many cases, the targets may bottom of the deceleration chamber. When the actually be mounted to the trap. Lead removal

Chapter III - Page III-3 BMP for Lead at Outdoor Shooting Ranges

requires mining the bullets from the rubber. The 3.1.2 Shot Containment Rubber Granule Trap uses shredded rubber granules, housed between a solid rubber front Reducing the Shotfall Zone and a steel backing, to stop bullets once they pass through the target. For both traps, the Unlike rifle and pistol ranges, the area impacted bullets remain intact, thus eliminating lead dust by lead shot fired at trap, skeet and sporting and preventing lead and jacket back splatter. clays ranges is spread out and remains primarily Depending on the design of the rubber trap, the on the surface. Knowing where spent lead is bullet either remains embedded in the rubber allows the appropriate BMP to be used. The strip or falls to the bottom of the trap, from which single most effective BMP for managing lead the bullets are removed for recycling. in these areas is reducing shotfall zones.

These traps, when properly installed, are Concentrating the lead shot in a smaller area by intended to increase safety by decreasing the modifying the shooting direction facilitates lead occurrence of back splatter and eliminating the management by providing a smaller and more introduction of the lead dust into the air and dense area of lead to both manage in-place and ground. However, there are several concerns reclaim, thereby making the management and over their use, since they may: reclamation process simpler and more effective.

require additional maintenance; Sporting Clays Courses in some cases, present a fire threat under extremely high volume use (due to heat from Technologies have been developed to assist in friction created upon bullet impact); reducing the range size of trap and skeet, and not withstand weather elements over the sporting clays facilities. The National Sporting long term; and Clays Association (NSCA) supports and cause the rubber particles to melt to the lead promotes the Five-Stand Sporting Clays bullets, making reclamation more difficult. compact course design for shooting sporting clay targets, invented by Raymond Forman of With the availability of fire-resistant rubber and Clay-Sport International, Cochrane, Alberta, gels (see Appendix A), these issues are becom- Canada. The targets are directed over a smaller ing less of a concern than in earlier models. area than in English Style Sporting Clays (conventional sporting clays). It was originally designed to be overlaid on a conventional trap or Shock Absorbing Concrete skeet field and to be an alternative to earlier designs, which cover a much larger area. In addition to the bullet containment devices Another design, known as the National Rifle discussed above, there are new designs and Association (NRA) Clays, is a portable target innovations continually being developed. One of throwing unit which concentrates 15 rail- these innovative bullet containment devices is mounted machines on a two-story flatbed trailer. Shock Absorbing Concrete (SACON). SACON, The NRA has also developed “compact which has been used as a bullet containment sporting,” which is specifically for sporting clay device since the 1980s and was extensively facilities. This practice alters the angle that the field tested by the military, has become target is thrown to concentrate the shotfall zone. commercially available in the past several years as a backstop material for small arms ranges. Skeet Fields For conventional rifle and pistol ranges, SACON may provide a means to easily reclaim lead. The typical single skeet field has a shotfall zone Additionally, crushed, lead-free SACON can be that is fan-shaped. For skeet fields with multiple recycled (recasted) after bullet fragments have stands side-by-side, the shotfall zones would been removed by adding it to other concrete overlap creating a shotfall zone that has a mixtures for use as sidewalks, curbs, etc. concentration of shot near the center of the fan.

Chapter III - Page III-4 BMP for Lead at Outdoor Shooting Ranges

Trap Fields 3.2.1 Monitoring and Adjusting Soil pH and Binding Lead One way to reduce the shotfall zone at trap fields is to build the fields at an angle to one Lime Addition another. This will make the shape of the shooting dispersal pattern smaller and more The BMP for monitoring and adjusting soil pH is concentrated. However, if you do decide to an important range program that can effect lead choose this option, be aware of safety issues migration. Of particular concern are soils with when designing the overlapping shotfall zones. low pH values (i.e., acidic conditions), because lead mobility increases in acidic conditions since For a range with only one trap field, one way to the acid of the soils contributes to the lead break minimize the shotfall zone is to keep trap down. The ideal soil pH value for shooting machines set in as few holes as possible (e.g., ranges is between 6.5 and 8.5. This BMP is the number two or three hole setting). This important because many soils in the eastern reduces the area of lead concentration by United States have pH values lower than 6.2 limiting the angles for pigeon throwing, and therefore the area for lead shot fall. However, To determine the pH of your soil, purchase a pH when two or more trap fields are positioned side meter at a lawn and garden center. The pH by side, the shotfall zone will be continuous meters are relatively inexpensive but valuable regardless of the “hole” setting. tools in the management of lead at your range. If the soil pH is determined to be below 6, the Shot Curtains pH should be raised by spreading lime. It is recommended that the pH be checked Another method to consider for concentrating annually. lead shot is the use of a shot curtain. This device is emerging as a potentially effective tool One way to control lead migration is by to keep lead shot out of selected areas of the spreading lime around the earthen backstops, range and, thereby, reduce the size of the sand traps, trap and skeet shotfall zones, shotfall zone and corresponding cost of sporting clays courses and any other areas reclamation. Different designs and material have where the bullets/shots or lead fragments/dust been utilized in shot curtains and a number are accumulate. For example, lead mobilized in in operation. The effectiveness of shot curtains rainwater from the lead that spatters in front of is site specific and their long term viability and backstops after bullet impacts can be effectively expense have yet to be fully determined. controlled by extending a limestone sand layer out about 15 feet in front of the backstop. Likewise, spreading lime over the shotfall zone 3.2 BMPs to Prevent Lead will help to raise the pH of the very top soil layer Migration (Step 2) to a pH closer to ideal levels and reduce the migration potential of lead. This is an easy, low This section discusses BMPs for preventing lead cost method. Spreading lime neutralizes the migration. These BMPs include: acidic soils, thus minimizing the potential for the lead to degrade. Lime can be easily spread by Monitoring and adjusting soil pH using a lawn fertilizer drop spreader available at Immobilizing lead any lawn and garden center. Controlling runoff Smaller forms of limestone (powdered, These BMPs are important for all outdoor pelletized, and granular) are better suited ranges.

2 National Shooting Sports Foundation, “Environ- mental Aspects of Construction and Management of Outdoor Shooting Ranges,” June 1997

Chapter III - Page III-5 BMP for Lead at Outdoor Shooting Ranges because they dissolve and enter the soil more less accessible to conventional lead removal quickly then larger forms. However, the smaller equipment. These types of ranges also tend to forms of lime must be replenished more often. have more detritus (e.g., leaves, twigs, etc.) on Conversely, limestone rock dissolves more the ground, which can increase soil acidity as slowly but does not need to be replenished as they decompose. In these areas, semiannual often. The larger rock form is better suited for monitoring of the soil pH levels is drainage ditches, where it can decrease lead suggested. mobility by raising the pH of the storm water runoff. Spreading bags of 50 pounds (at ranges with sandy soils) or 100 pounds (at ranges with Another way to control lead migration in earthen clayey soils) per 1,000 square feet of range will backstops is to break the capillarity within the raise the pH approximately one pH unit for a base of the backstop. Most porosity in the soil period of between one and four years, material used in backstop is of capillary size, respectively. The market price of lime in either and, as a result, water is pulled upward into a the granular or pelletized form commonly ranges capillary fringe within the base of the backstop. from approximately $2.00 to $4.00 per fifty pound The height to which the water will rise in an bag. earthen backstop depends on the soil material in the backstop. Water will rise more then 6 feet in Table 3-2 provides information for raising pH clay, 3.3 feet in silt, 1.3 feet in fine sand, 5 levels of clay soils in temperate climates (i.e., inches in coarse sand, and only 2 inches in Mid-Atlantic/Northeast). Additional information gravel. on the amount of lime to apply may also be found on the bags of the purchased lime and/or Because of capillarity, the spent bullets may be from the local lawn and garden center. It should in contact with acidic rainwater for a longer be noted that if the soil pH is below 4.5, the period of time, hence more lead is dissolved. addition of lime may only raise the soil pH to Breaking the capillarity by adding a layer of approximately 5. In this situation, other BMPs limestone or gravel to the base of the backstop should be used as well. If the soil pH is above should reduce the rate of deterioration of spent the ideal range upper value (8.5), do not add bullets, the erosion of the backstop, and the lime. Adding lime to a soil of this pH could result amount of lead going into solution in the water in in mobilization of the lead. Lime spreading may the backstop. Also, any lead dissolved should be done at anytime during the year, except precipitate out of solution as the acids are when the ground is frozen. neutralized and the pH raised from the water passing through and reacting with the limestone. Additionally, it is important to remember to monitor the soil pH annually, as the Lime spreading is an especially important effectiveness of the lime decreases over time. method for implementing this BMP at sporting Additional routine applications will be necessary clays ranges where heavily wooded areas are throughout the life span of most ranges.

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

4.0 4.3 4.5 4.8 5.0 5.5 6.0 6.5

Desired 54.0-6.0 111853--- pH 6.5-8.5 ---27 01117-

* Lime requirements stated as pounds of lime/100 square foot of problem area for clay soils in temperate climates (i.e., Mid-Atlantic/Northeast US). Chapter III - Page III-6 BMP for Lead at Outdoor Shooting Ranges

Phosphate Addition Other Ways to Bind Lead

In addition to lime spreading, another way to Although it may be possible to minimize lead’s control lead migration is phosphate spreading. mobility by spreading fertilizers that contain This method is recommended where lead is phosphate at impacted areas of the range, a widely dispersed in range soils, a range is more comprehensive procedure for immobilizing closing, or there is a high potential for vertical leachable lead in soils, by using pure phosphate lead transport to groundwater (e.g., low soil pH, in rock form or a ground phosphate rock [Triple shallow water table). Under these Super Phosphate (TSP)], was developed and circumstances, range soils may benefit from patented by the U.S. EPA/Ohio State University phosphate treatment. Unlike lime spreading, the Research Foundation and RHEOX, Inc. This main purpose of phosphate spreading is not to procedure used a three step approach to adjust soil pH but to bind the lead particles. This minimize lead’s mobility. The first step was to process also decreases the potential amount of identify the boundaries of the area of the range to lead that can migrate off-site or into the be treated. This included not only determining subsurface. Phosphate spreading can be done the length and width of the range area, but also either separately or in conjunction with lime the depth of lead within the area. spreading. Generally, 15 to 20 pounds of phosphate per 1,000 square feet will effectively Depth was determined by taking sample cores control the lead. of the area, which also identified “hot spots” where lead accumulation was greatest. Once Phosphate spreading is especially the area was identified, the second step was to recommended for sporting clays ranges and treat the area with TSP. Pure phosphate rock those parts of ranges not easily accessible by was used rather then fertilizers, as this reclamation equipment. Phosphate spreading phosphate is insoluble in water and will not should be repeated frequently during the range’s cause an increase in phosphate runoff. lifetime. See pilot testing under “Other Ways to Bind Lead” below for proper frequency for In this step, pilot testing was conducted. Here, replacing phosphate. various amounts (in increasing percentages by weight) of TSP were added to the affected soil You can purchase phosphate either in its pure areas, then the area was tested according to an form, as phosphate rock, or as lawn fertilizer. EPA test method that identified the amount of The average lawn fertilizer costs approximately leachable lead in a given soil sample. This test $7.00 per 40 pound bag. If you purchase lawn is called the Toxicity Characteristic Leaching fertilizer, remember to check the bag for the Procedure, or TCLP. Separate TCLP testing of actual percentage of phosphate. Most fertilizers the range’s hot spots was conducted. contain 25% phosphate, so that if you purchase a 40 pound bag of fertilizer that contains 25% Upon completion of the pilot testing, which phosphate (i.e., 10 pounds of phosphate) you determined the amount of TSP needed at the will need to spread 80 pounds of fertilizer per range, the third step was to begin actual 1,000 square feet of the backstop. A typical treatment of the range. Where the depth of the fertilizer drop spreader can be used for lead accumulation was shallow (less than two distributing the phosphate. Like lime, phosphate feet), then standard yard equipment, such as should not be spread when the ground is frozen. tillers, seed/fertilizer spreaders, and plows were In addition, it is not advised to use phosphate used to mix TSP with the affected soil. Where near water bodies since it contributes to algal the affected area’s lead accumulation was blooms. Rock phosphate is a better choice if deeper than two feet, an auger was required to water is nearby. mix the TSP with the affected soil. Random testing of the range ensured the effectiveness of the treatment level.

Chapter III - Page III-7 BMP for Lead at Outdoor Shooting Ranges

3.2.2 Controlling Runoff of backstops, which can be removed prior to reclamation and replanted thereafter; The BMPs for controlling soil erosion and Avoid vegetation that attracts birds and other surface water runoff are important to preventing wildlife to prevent potential ingestion of lead lead from migrating off-site. There are two by wildlife; and factors that influence the amount of lead Use grass to direct surface water drainage transported off-site by surface water runoff: the away from the target area (e.g., planting amount of lead fragments left on the range and them at the top of the backstop or sand trap). the velocity of the runoff. This will minimize the water’s contact with lead bullet fragments, minimizing the The velocity of the water can successfully be potential for lead migration. controlled at outdoor ranges by: (1) using vegetative, organic, removable and/or Grass is not impermeable; however, it does slow permanent ground covers; and (2) implementing down the rate of flow and reduce the amount of engineered controls which slow down surface lead entering the soil via rainwater. Remember, water runoff and prevent or minimize the grass requires periodic maintenance (i.e., chances of lead migrating off-site. Bear in mind mowing) to maintain its effectiveness as well as that safety considerations and potential for aesthetic reasons. ricochets need to be considered when implementing any engineered controls. Mulches and Compost

Vegetative Ground Cover Mulches and composts can reduce the amount of water that comes in contact with the lead Planting vegetative ground cover (such as fragments. In addition, mulches and compost grass) is an important and easy erosion control contain hermic acid, which is a natural lead method. Vegetation provides several benefits chelating agent that actually sorbs lead out of by minimizing the amount of lead that will run off solution and reduces its mobility. At a minimum, the land surface during heavy rainfall. It is the material should be two inches thick. These important to use a mixture of grass seeds to materials can be spread over any impacted area ensure that the cover will last into the future (i.e., and/or low lying areas where runoff and lead annual rye grass lasts one year and dies and may accumulate. Like vegetative covers, perennial rye grass lasts three to four years, organic surface covers are not impermeable. In then dies off). Fescue grasses form useful mats addition, the organic material needs periodic that are effective in controlling erosion. replacement to maintain effectiveness and aesthetic integrity. Furthermore, these materials Ground cover absorbs rainwater, which reduces should be removed prior to any lead removal the amount of water the lead is in contact with, event, as they may impede sifting or screening. as well as the time that the lead is in contact Note that these materials tend to be acidic with the water. Furthermore, the ground cover (especially during decomposition), so, if low will divert and slow down surface water runoff, pH is a concern at your range, this option thus helping to prevent lead from migrating off- may not be appropriate. Again, however, site. lime may be used to control pH (see Section 3.1.1) Grasses yield the greatest benefit at rifle and pistol ranges where the bullet impact areas are Surface Covers sloped, and water runoff and soil erosion may be more likely. Specific recommendations are Removable Surface Covers to: Removable surface covers may be effective at Utilize quick growing turf grass (such as outdoor trap and skeet ranges. In this case, fescue and rye grass) for the grass covering impermeable materials (e.g., plastic liners) are

Chapter III - Page III-8 BMP for Lead at Outdoor Shooting Ranges placed over the shotfall zone during non-use Examples of “hard” controls include: periods. This provides the range with two benefits during periods of rainfall: (1) the shotfall Filter beds zone is protected from erosion; and (2) the spent Containment Traps and Detention Ponds lead shot is contained in the shotfall zone and Dams and Dikes does not come in contact with rainwater. Ground Contouring. Designing and implementing these “hard” Permanent Surface Covers engineering controls may require the assistance of a licensed professional civil engineer. They For outdoor rifle and pistol ranges, impact are included in this manual to offer the reader a backstops and target areas can also be covered general understanding of these BMP options. with roofed covers or other permanent covers to However, this manual does not offer specific prevent rainwater from contacting berms. instructions for construction and operation of However, this method may be less desirable these controls. For information about designing because of the cost to install the roof, which and implementing any of these controls, or must be carefully designed to avoid safety assistance with other range design questions, issues with ricochets, etc. contact a licensed professional civil engineer having applicable experience or the NRA Range For shotgun and other ranges, synthetic liners Department, at (800) 672-3888, ext. 1417. The TM (e.g., asphalt, Astroturf , rubber, other synthetic National Sports Shooting Foundation (NSSF) liners) can also be used beneath the shotfall may be contacted at (203) 426-1320 for specific zone to effectively prevent rainwater or runoff references regarding the use and design of from filtering through lead and lead these controls. contaminated soil. Synthetic liners will generate increased runoff, which must be managed, Filter Beds however. No single type of liner is suitable for all situations based on site characteristics. Filter beds are engineering controls built into an Therefore, liners must be chosen on a site- outdoor range to collect and filter surface water specific basis, bearing in mind the site’s unique runoff from the target range. The collected characteristics, such as soil type, pH level, runoff water is routed to a filtering system, which rainfall intensity, organic content of soil, and screens out larger lead particles, raises the pH surface water drainage patterns. of the water (thus reducing the potential for further lead dissolution), and drains the water Engineered Runoff Controls from the range area. This technique may not completely prevent lead from entering the Runoff control may be of greatest concern when subsurface, since lead bullets, fragments and a range is located in an area of heavy annual large particles may still remain on the range. rainfall because of an increased risk of lead migration due to heavy rainfall events. A “hard” Filter beds should be established at the base of engineered runoff control may be needed in this the backstop (see Figure 3-2). In addition to situation. A heavy rainfall event is defined as mitigating off-site migration, the filter beds work rainfall that occurs at such a rate that it cannot to raise the pH of the rainwater, which has fallen be absorbed into the ground and causes an on the target range, to reduce lead dissolution, increase in the volume and velocity of surface and to strain small lead particles out of the runoff. The impacts of rainfall are greater in rainwater. The filters typically consist of two rolling or sloped terrain (increases velocity of layers: a fine-grained sand bed underlain by runoff) or where surface water bodies are limestone gravel or other neutralization material. located on, or immediately adjacent to, the By design, the backstops and berms direct the range. runoff so that it drains from the range to the filters. The collected water then soaks through the top sand layer into the neutralization material,

Chapter III - Page III-9 BMP for Lead at Outdoor Shooting Ranges

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)

which raises the pH of the filtrate. The lead of containment traps and ponds by further particles in the rainwater are collected on the reducing the velocity of runoff and allowing for sand, while the pH-adjusted water drains more lead fragments to settle from the runoff. It through the filter to a perforated drainage pipe is important to regularly collect the lead and send located within the limestone gravel. this lead to a recycler.

Filter beds are designed to capture fine particles Dams and Dikes of lead transported in surface water runoff. They are not designed to capture bullets. The At shotgun ranges, dams and dikes can also be operation and maintenance requirements of filter used to reduce the velocity of surface water beds are minimal. Maintenance activity is limited runoff. Dams and dikes must be positioned to periodic removal of debris (such as litter, perpendicular to the direction of runoff to slow leaves, etc.) and occasional replenishment of the flow of surface water runoff. To accomplish the limestone. this, determine the direction of the range’s surface water runoff. This will be particularly The use of filter beds is most effective on sites obvious at ranges with sloped terrain. The dams with open, rolling terrain where surface water or dikes should be constructed using mounds of runoff is directed to them. At existing rifle and dirt that are approximately a foot high. These pistol ranges, a limited system of trenches and mounds should transect the entire range filters can be installed at the base of natural soil perpendicular to the stormwater runoff direction. backstops or at natural drainage depressions. These runoff controls are most important at Containment Traps and Detention Ponds ranges at which off-site runoff is a potential problem, such as ranges where the lead Containment traps and detention ponds are accumulation areas are located upgradient of a designed to settle out lead particles during surface water body or an adjacent property. heavy rainfall. Typically, they are depressions Since lead particles are heavier than most other or holes in the range’s drainage paths. Here, suspended particles, slowing the velocity of the lead-containing runoff passes through the surface water runoff can reduce the amount of trap or pond, allowing the lead bullet fragments lead transported in runoff. to settle out. Vegetative cover can be placed in the drainage path to increase the effectiveness

Chapter III - Page III-10 BMP for Lead at Outdoor Shooting Ranges

Ground Contouring reclamation program will allow you to avoid expensive remediation and potential litigation Another mechanism to slow runoff and prevent costs. Ranges in regions with high precipitation lead from being transported off site is ground and/or with acidic soil conditions may require contouring. By altering drainage patterns, the more frequent lead recovery since the potential velocity of the runoff can be reduced. for lead migration is greater. In regions with little Furthermore, in areas where pH is high precipitation and/or where the soil is somewhat (resulting in a lower potential for lead alkaline, spent bullets may be allowed to dissolution), the soil can be graded or aerated to accumulate on the soil for a longer time between increase the infiltration rate of precipitation, so reclamation events. It should be noted that to that rainwater is more easily absorbed into the ensure that lead is not considered “discarded” or soil. This slows down or prevents surface water “abandoned” on your range within the meaning runoff and off-site migration. It should be of the RCRA statute (i.e., a hazardous waste), pointed out that this design, in effect, collects periodic lead removal activities should be lead in the surface soils. Therefore, range planned for and conducted. This typically operation and maintenance plans should include requires one or more of the following: lead reclamation as well as adjusting the pH, and adding phosphate. Hand Raking and Sifting Screening 3.3 Lead Removal and Recycling Vacuuming (Step 3) Soil Washing (Wet Screening, Gravity Separation, Pneumatic Separation) To successfully minimize lead migration, the These methods are discussed in detail below. most important BMP for lead management is Figure 3-3 provides examples of common lead lead reclamation. Implementing a regular reclamation equipment. Figure 3-3 – Examples of Common Lead Reclamation Equipment

Example of shaker system. Courtesy of National Range Recovery

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

Chapter III - Page III-11 BMP for Lead at Outdoor Shooting Ranges

one person is holding the framed screen, it may Also, it is important to be aware that state be better to use a smaller frame (2 feet by 2 feet) regulations may require that the material being whereas, if several people are holding the sent for recycling have a minimum lead content framed screen, it can be larger. in order to qualify as a scrap metal that can be shipped under a bill of lading (i.e., exempt from Raking and sifting can be performed by club RCRA). members on a volunteer basis. Some clubs provide incentives, such as reduced fees, to 3.3.1 Hand Raking and Sifting members who assist with the lead removal process. Other clubs have hired college A simple BMP that can be done by club students during the summer. A number of small members, particularly at small ranges, is raking clubs have found that reloaders will volunteer to and/or sifting bullet fragments from the soil. rake in exchange for collected shot. Sifting and raking activities should be Hand sifting and raking are cost effective lead concentrated at the surface layer. This is a low- removal techniques for small ranges, or low technology and low-cost management shooting volume ranges. However, these alternative for lead reclamation. Once collected, techniques may not be appropriate for situations the lead must be taken to a recycler or reused. in which there is a large volume of lead on the Arrangement with a recycler should be made range. In this instance, reclamation machinery prior to collecting any spent lead to avoid having may be more appropriate. to store the lead and avoid potential health, safety and regulatory concerns associated with Note: Those conducting the hand raking and storing lead. sifting reclamation at ranges should protect themselves from exposure to lead. Proper At trap and skeet ranges, conducting sifting and protective gear and breathing apparatus raking activities in the shot fall zone should be worn. The Occupational Safety (approximately 125 - 150 yards from the and Health Administration (OSHA) or an shooting stations) will yield the most lead. For appropriate health professional should be sporting clay ranges, these activities should be contacted to learn about proper protection. conducted around tree bases, where lead shot tends to collect. Basically, the process consists 3.3.2 Purchasing/Renting Mechanical of raking with a yard rake the topsoil in the shot Separation Machinery fall areas into piles, as if you were raking leaves, removing any large debris (e.g., rocks, twigs, Reclamation equipment may be rented from leaves, etc.), and then sifting the soil using local equipment rental services. One type of screens. machine that it may be possible to rent for lead shot reclamation is known as a screening Once the soil has been raked and collected, machine (also referred to as a mobile shaker, pass it through a standard 3/16 inch screen to gravel sizer, or potato sizer). This device uses a remove the large particles. This process will series of stacked vibrating screens (usually two allow the lead shot sized particles to pass screens) of different mesh sizes and allows the through the screen. The sifted material (those user to sift the lead shot-containing soil not captured by the 3/16 inch screen) should be [gathered by hand raking, sweeping, or passed through a 5/100 inch screen to capture vacuuming (discussed above)]. The uppermost the lead and lead fragments. This process will screen (approximately 3/16 inch mesh) collects also allow sand and other small sediment to larger than lead shot particles, and allows the pass through the screen. Screens can be smaller particles to pass through to the second purchased at many local hardware stores. The screen. The second screen (approximately 5/ screens should be mounted on a frame for 100 inch mesh) captures lead shot, while support. The frame size will vary based on the allowing smaller particles to pass through to the technique used by each range. For example, if ground. The lead shot is then conveyed to a

Chapter III - Page III-12 BMP for Lead at Outdoor Shooting Ranges container such as a five gallon bucket. In the Please note that reclamation companies tend to Northeastern United States, the typical rental be in high demand — it may take over a year for cost for this equipment is between $500 and the company to start at your club. Therefore, it is $4,500 a week, depending on the size shaker wise to plan ahead and make the call to the desired. It may be possible to get more reclamation company as early as possible. information on rentals for this type of equipment from heavy equipment rental companies. Some reclamation companies require a site visit to view the topography, the soil composition, and Another possible option is to rent a vacuum amount of lead observed on the ground. During system that will collect the lead shot-containing the visit, some companies may even do a site soil from the range. Here, vacuuming takes the analysis to determine whether or not it is place of hand raking or sweeping. A vacuum feasible to reclaim. This analysis identifies the machine is used to collect the lead shot- location of lead, the expected recovery amount, containing soil. Once collected, the lead shot- and the depth lead reaches into the soils. containing soil must be sifted through a screening system (either a rental screening machine, or a series of home made framed 3.3.4 Reclamation Activities screen sets). You may be able to obtain more information about renting vacuums or Using machinery to reclaim lead usually requires vacuuming services (e.g., it may include a that the area be clear of scrub vegetation. person to operate the machinery) from heavy Grass, mulch, or compost is generally removed equipment rental companies. or destroyed during the reclamation process. Some reclamation companies have no problem Some clubs have found that performing their beginning reclamation on a grassy field. Other own lead reclamation to be very time reclamation companies will remove grass before consuming. Part of the reason these or during reclamation (by burning it, if allowed reclamations took so long is that the soils were locally, leaving behind the lead shot), and still wet. Reclamation is much easier under dry soil others require that all vegetation be removed conditions. For example, one club reclaimed before they arrive at the range. Some lead from their range using equipment they companies will re-seed the area once the modified themselves. Twenty-five tons of lead reclamation is completed. were collected but the reclamation took over two years. Another club took a year to reclaim 10 Since sporting clay ranges generally have many tons of lead. A more preferable option may be to trees, removal of vegetation as discussed above hire a reclamation company. may not directly apply to existing sporting clay ranges. At these ranges, the focus is on 3.3.3 Hiring a Professional Reclamation removing vegetative debris (i.e., fallen limbs, Company tree bark, etc.) prior to reclamation. This may include removing some trees to gain better Another option for lead removal is to hire a access with the reclamation machinery. Of professional reclaimer. Lead reclamation course, when designing a new sporting clay companies claim to recover 75%-95% of the range, steps to facilitate lead reclamation should lead in the soils. Generally, with reclamation be taken into account. For example, less and companies there is no minimum range size more widely spaced trees will facilitate lead requirement for lead reclamation. Concentration reclamation. of lead is more important than quantity spread over a field, especially if it is a difficult range for Reclamation companies use several types of reclamation (e.g., hilly, rocky, a lot of clay in the machinery to reclaim lead. Some companies soil). drive their separation machinery over the site. The lead-laden soil is picked up, processed and then returned to the ground after most of the lead

Chapter III - Page III-13 BMP for Lead at Outdoor Shooting Ranges is removed. Other companies scrape off the top Reclamation time varies depending on weather, several inches of soil from the ground, using a site accessibility, range size, and number of front-end loader to bring the soil/lead to personnel assigned to perform the reclamation. stationary reclamation machines, and then return the soil to the field after reclamation. Many Reclamation activities may generate dust, companies till the top two to five inches of soil especially in drier western locations. To prevent and grass immediately prior to reclamation to or minimize dust from traveling off the range and facilitate the process (some companies may causing complaints from neighbors, reclamation require this to be done prior to arrival on the activities generating dust should only be range). conducted during periods of no wind. In addition, such activities should be completed as Regardless of how it is collected, the actual quickly as possible. reclamation of the lead follows the same general pattern. Most often, it is sifted through a series Vacuuming of shaking screens. The lead and soil pass through shaking screens (usually at least two For ranges that are located on hilly, rocky, and/or screens) of decreasing mesh (hole) size, with densely vegetated terrain, several reclamation the topmost screen having the largest mesh. companies employ a vacuum system that This part of the reclamation machinery is usually collects the lead shot (and soil and other adapted from machinery used for potato or detritus). The resulting mix is then placed into gravel sizing. the reclamation machinery discussed above. This method is especially effective for sporting Any soil/debris automatically screened out as clay ranges where lead shot tends to pile up being too big or too small is either returned to around tree bases. the field or re-screened to ensure no lead is caught in the debris. This procedure is why Vacuuming has traditionally been used for moist, clay soils are more difficult to reclaim. removal of lead shot from trap, skeet and The moist, clay soils can bind together into shot- sporting clay ranges. Another way to apply this sized pellets producing more “product” for the method involves removing the top layer of an second part of the reclamation. The wet soils earthen backstop or sand trap with shovels. It is can also clog the screens. then spread thinly over an impermeable material such as plywood. A vacuuming device is then For some reclamation companies, their process used to collect the materials that are lighter than ends after sifting the soil and returning it to the lead (e.g., sand or soil), while leaving behind the ground. However, some companies take heavier materials (i.e., lead bullets/shots and reclamation one step further. After screening, fragments). The soil can then be returned to the the resulting lead, soil, and other lead-sized range. This process is most efficient for dry, particles enter a blowing system. Here the lead sandy soils without a lot of organic material. A shot is easily separated from the soil and other more recent innovation is the use of a high debris by the blowing air. The lead is much suction vacuum. This vacuum itself does not more dense than the soil and other lead-sized have to be moved about, since a very long hose debris so that it falls out first. Figure 3-3 depict (up to 600 feet) is used to move in and around examples of actual lead reclamation machinery. trees during the collection of lead shot at trap and skeet ranges. Some lead reclamation companies will perform the reclamation during club off-hours so that Soil Washing (Physical and Gravity club activities are not interrupted. Additionally, Separation) some perform the reclamation on a field-by-field basis, to minimize any disruptions to club Soil washing is a proven technology and another activities. However, others companies require lead reclamation method used by some the club to shut down during the reclamation. reclaimers to separate the lead particles from

Chapter III - Page III-14 BMP for Lead at Outdoor Shooting Ranges the soils. Soil washing is the separation of soils the volume of the soil mixture is reduced. Large into its constituent particles of gravel, sand, silt particles such as lead shot/bullets and and clay. Because of the much higher surface fragments are screened out of the soil/wash area and surface binding properties of clay, most mixture early in the process and can be taken lead contaminants tend to adhere to the clay off-site for recycling - allowing the soil to be particles. placed back on-site.

Soil washing, therefore, attempts to generate a Gravity Separation clean sand and gravel fraction by removing any fines adhering to the larger soil particles and, if This technique can be used in cases where the necessary, to transfer contaminants bound to lead particles are the same size as surrounding the surface of the larger particles to the smaller soil particles. The wet soil/wash mixture is soil particles. Typically, the soils are first passed through equipment, which allows the excavated from the range and then mixed into a more dense materials (i.e., lead materials) to water-based wash solution. The wet soil is then settle to the bottom of unit and separate out of separated using either wet screening or gravity the soil/wash mixture. separation techniques. One benefit of this Pneumatic Separation system of reclamation is that it does not require that soils be dry. Pneumatic separation (see figure 3-3) is an effective means to enhance the traditional In addition, soil washing may be able to recover screening results. Traditional screening cannot all or almost all lead particles through a separate shot and bullets from other shot and combination of wet screen sizing and density bullet sized material, i.e., rocks, stones, roots, separation. This technique is an option for and various debris. A recycling facility considers remediation of a range being closed and may non-lead items as “contaminants” which compare favorably from an economic standpoint drastically reduces the value of the recycled with the disposal option. lead. Pneumatic separation utilizes an air stream, and specific density analysis, to Soils treated using this method have been effectively separate the shot/bullets from the shown to be below 5 mg/L TCLP and to have up other shot/bullet sized material. to 99% of particulate lead removed. Treatment costs are site specific, but can range from less 3.3.5 BMPs to Assist Lead Reclamation then $40 per ton (1999 levels) for simple and Recycling physical/gravity separation up to about $100 per ton for processes involving leaching. Credits for There are several operational activities that recycled lead help offset the treatment cost and should be conducted throughout the year to the cost of recycling any treatment sludges and facilitate reclamation. The following is a concentrated soil fines. Water used in soil discussion of these activities. washing is from a closed loop system and should only be disposed at completion of Frequency of Lead Removal cleanup. Experience shows the water to not be a RCRA regulated hazardous waste, therefore It is important to perform lead removal at a probably allowing disposal to a local wastewater frequency appropriate for your site. The treatment plant. frequency is dependent on several factors. These include: Wet Screening Number of rounds fired With this method, particles larger and smaller Soil pH than the surrounding soils are passed through a Annual precipitation series of large-mesh to small-mesh screens. Soil Type Each time the mixture passes through a screen, Depth to groundwater.

Chapter III - Page III-15 BMP for Lead at Outdoor Shooting Ranges

more cost effective is for a number of ranges in Lead quantity, as estimated by the number of the same geographical area to work together in rounds fired, is a factor in determining the organizing coordinated removals at their ranges. appropriate frequency of reclamation at ranges. This will reduce the reclaimer travel and It also assists in determining the cost of mobilization cost for each range. reclamation. One reclamation company indicated that reclamation was most cost Minimization of Vegetation effective when it contains at least 20 pounds of lead per square foot of backstop. Another As discussed previously, vegetation is useful source indicated that a minimum of 100,000 both for controlling the amount of runoff and rounds per firing lane should be allowed before erosion from the range and inhibiting lead lead reclamation occurs. This would ensure mobility. However, excessive or good range operation and maintenance, while unmaintained vegetative cover can interfere minimizing the cost per quantity of lead with reclamation activities. For example, large recovered. amounts of vegetation impedes the screening and sifting processes used by many reclamation For shotgun ranges, tracking the number of companies. Therefore, prior to reclamation targets thrown can help indicate when the lead activities, it is best to remove, reduce, or mow shot should be reclaimed. For example, excessive vegetation from the area. Once the considering environmental issues, the reclamation has been conducted, quick-growing market for scrap lead and common cleanup vegetation such as a rye/fescue grass mix methods, one source indicated that when a should be replanted. This process should be range has thrown at least 250,000 to 1,000,000 repeated for each reclamation event. targets, depending on the shooting area, In addition, heavily wooded areas may inhibit reclamation of the lead shot is encouraged. lead reclamation because they are less Another reclaimer indicated that if at least two accessible by heavy reclamation machinery. pounds of lead per square foot have For ranges that are heavily wooded, it is accumulated on the range, reclamation is recommended that you minimize the vegetation recommended. or modify the range design to allow lead reclamation equipment access to the range. Because the number of rounds fired is important Access to the impact area should be developed to know, establishing record keeping procedures to facilitate reclamation. Make sure that the to monitor the number of rounds fired is pathways do not present a safety risk. recommended. This can be accomplished by maintaining logbooks and asking shooters to list Innovative Landscaping the number of rounds shot and the type/size of shot/bullets they use. This should be done by Some new ranges are landscaping their ranges lane and by stand. to include a sand track (an area the size of the shotfall zone that is only sand) located behind There are many ranges at which lead removal some aesthetically pleasing shrubs. This allows has not occurred for many years. Many of these the spent shot to concentrate on the sand, ranges are used extensively. Such ranges are making it very easy to perform reclamation especially good candidates for lead removal and because there is no interference by vegetation. recycling. Subsequent removal frequency depends on range use and environmental Selecting a Lead Reclaimer factors. The NRA recommends a frequency of one to five years for lead cleanup, even on In ensuring that the reclamation is conducted ranges with minimal use4. One possible appropriately, selecting a reclaimer that is right approach to reducing the cost of reclamation for your range is extremely important. Some lead reclamation companies will travel to your 4. National Rifle Association, “Metallic “Bullets” lead range and assess the range prior to conducting Deposits on Outdoor and Indoor Firing Ranges” 1991 Chapter III - Page III-16 BMP for Lead at Outdoor Shooting Ranges lead collection activities. This assessment trip and reclamation company and technique used. allows the reclamation company to confirm Because the economics vary due to many information gained during initial discussions, as factors, this manual does not provide specific well as to assist in appropriately estimating estimates. However, it is important to costs, time required, and the estimated volume understand that lead reclamation will generally of lead at the range. Conducting this pre- require an expenditure by the range, even when assessment also allows you to determine which considering any monetary returns from selling reclaimer is right for your situation. reclaimed lead. By tracking the range use and using the criteria discussed earlier (see Questions Commonly asked by the Reclaimer Frequency of Lead Removal), the reclamation costs per quantity of lead can be optimized. For When you contact a reclamation company, it is long term range management, routine lead likely that the reclaimer will ask several general removal will help future cost avoidance by questions. Typical questions include: minimizing the need for costly site remediation

When was the last reclamation conducted? Some reclaimers bid the lowest flat fee with all How many rounds have been shot since the lead provided to the range for selling. The that last reclamation? range owners/operators must then consider the What is the use frequency of the range? transportation costs and recycling fee What are the site characteristics and soil associated with sending the reclaimed shot and types? bullets to a recycling company. Alternatively, the reclaimer will use the economic return of lead What type of bullet containment device is sold for recycling, based on the volume used at the range? reclaimed and the current value of lead, to reduce the total cost of reclamation and Answering these questions will be a lot easier if recycling. Although the value of lead varies, the you have maintained good records, as is scrap value of reclaimed lead typically falls suggested above. between $.06 and $.25 per pound, excluding transportation cost. See the appendix for Questions to ask the reclaimer contact information regarding lead reclamation companies that specialize in lead removal at When choosing a reclaimer be sure to ask the outdoor ranges. general questions about prior cleanups (past projects), insurance to cover company and cleanup (general liability insurance, pollution 3.4 Documenting Activities and insurance, bonding, etc.), and site plans to Record Keeping (Step 4) ensure health and safety of workers and range personnel. Other questions you may want to ask Documenting activities and keeping good the reclaimer include: records is of paramount importance for an effective lead management program at a range. Can the reclamation take place outside Owners/operators should document all activities normal hours of range operation? done at the range with respect to BMPs and What costs are involved? recycling of lead. Records should be kept on How long will the reclamation take? when services were provided and who provided Does vegetation at the range need to be them. removed? Owners/operators may want to document what Economic Considerations type of BMP(s) were implemented to control lead migration, the date of service, and who did Lead removal costs may vary dramatically the services. The records should be kept for the depending upon the type and volume of soil or life of the range. Records may be used to show sediments, topography, amount of lead, location, that owners/operators are doing their part to Chapter III - Page III-17 BMP for Lead at Outdoor Shooting Ranges help prevent lead migration off-site and show formats. This template, combined with that they are doing their part to be stewards of information provided throughout this manual, the environment. other resources and guidance, and site- specific factors, will help in guiding the 3.5 Additional Economic process of evaluating relevant information Considerations about your facility and determining which BMP(s) might be appropriate for your ranges. EPA’s template was adapted from Not all BMPs need to be implemented at once. Appendix C of the National Shooting Sports Many can be phased in over time. However, it Foundation’s manual, Environmental is important to begin implementing BMPs, Aspects of Construction and Management of especially lead reclamation and recycling, as Outdoor Shooting Ranges (the NSSF soon as possible. Implementing the most manual.) Accordingly, use of that template appropriate BMPs for your range requires would also be acceptable for use in EPA’s consideration of your range characteristics and Certificate of Recognition program. costs associated with implementing the BMPs. This manual provides a large selection of BMPs In order to request this certificate, a range that vary in both cost and sophistication. In must submit a notice to the Lead Shot selecting BMPs for your range, it is important to Coordinator in EPA Region 2 stating that look at all costs and all the benefits (or potential they have completed an Environmental problems) associated with each BMP. Stewardship Plan as indicated above and are intending to implement it within six 3.6 Summary of Key BMPs for months. The certificate is intended to Shooting Ranges convey, to all that may see it, that the range has declared its intention to properly manage There are several BMPs that are highly lead shot and bullets. However, it must be recommended to be implemented, if applicable noted that a certificate is not a permit to to your range. Table 3-1 identifies the operate and provides no additional advantages and disadvantages of all BMPs operational approval, implied or otherwise. discussed in this chapter. This table serves as a quick reference guide for potential BMPs. Readers should refer back to the detailed discussions above for further information regarding these BMPs.

3.7 Certificate of Recognition

EPA has established a voluntary process whereby a shooting range may apply for a “Certificate of Recognition.” The Certificate is intended to be awarded to ranges that have certified that they have prepared and intend to implement, or have implemented, a written Environmental Stewardship Plan that is consistent with the EPA Best Management Practices for Lead at Outdoor Shooting Ranges manual. To assist in this process, Appendix E contains a template for an Environmental Stewardship Plan, an electronic copy of which is available on EPA’s shooting range website (http://www.epa.gov/region2/leadshot) in several

Chapter III - Page III-18 BMP for Lead at Outdoor Shooting Ranges

Table 3-1 – Summary of Key BMPs

BMPs for Preventing Lead Migration

Monitoring and Adjusting pH

BMP Option Advantages Disadvantages Lime Spreading 1. Easy 1. Does not offer a 2. Inexpensive permanent solution 3. Effective 2. Will not work in extremely acidic conditions

Immobilizing Lead

BMP Option Advantages Disadvantages Phosphate Spreading 1. Easy 1. Does not offer a 2. Inexpensive permanent solution 3. Effective

Controlling Runoff

BMP Option Advantages Disadvantages Vegetative Ground Cover (e.g., grass, etc.) 1. Easy 1. Requires periodic 2. Aesthetically pleasing maintenance 3. Relatively inexpensive 2. Must be removed or 4. Effectively slows and reduced prior to can redirect runoff reclamation 5. Some may "bioabsorb" 3. Excessive vegetation lead will interfere with reclamation Organic Surface Cover (e.g., mulch and 1. Easy 1. Requires periodic compost) 2. Aesthetically pleasing maintenance 3. Relatively inexpensive 2. Must be removed prior 4. Effectively slows and to reclamation can redirect runoff 3. May not be suitable at ranges with acidic soil conditions Filter Beds 1. Diverts and treats lead 1. May require hiring a contaminated runoff licensed engineer 2. Low maintenance 2. Higher initial setup cost 3. Assists with range drainage

Chapter III - Page III-19 BMP for Lead at Outdoor Shooting Ranges

Table 3-1 – Continued

Controlling Runoff (cont.) BMP Option Advantages Disadvantages Water/Sediment Traps 1. Low maintenance 1. May require hiring a 2. Assists with range licensed engineer drainage 2. Higher initial setup cost

Dams and Dikes 1. Low maintenance 2. Higher initial setup cost 2. Assists with range drainage

Ground Contouring 1. Lower initial setup cost 1. May require hiring a 2. Assists with range licensed engineer drainage

Controlling and Containing Bullets

Bullet Containment Devices BMP Option Advantages Disadvantages Earthen Backstop 1. Minimal (if any) initial 1. Build up of bullets setup cost increases chances of 2. Accepts firing from ricochet and fragmentation various guns and directions problems 2. Lead removal requires mining 3. Potential decreased value of lead because it is less clean than lead reclaimed from other trap systems 4. Does not eliminate lead's introduction into the environment

Sand Trap 1. Low initial setup cost 1. Build up of bullets 2. Ease of maintenance increases chances of 3. Accepts firing from ricochet and fragmentation various guns and directions problems 2. Lead removal requires mining Pit and Plate Trap (Sand) 1. Low initial setup cost 1. Lead builds up on top 2. Simple installation layer of sand causing 3. Lead removal and ricochet problems recycling requires less 2. Increased bullet extensive mining fragmentation 3. Higher level of maintenance than sand traps

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 for informational purposes only. The USEPA does not endorse any particular bullet containment device, design, or product.

Chapter III - Page III-20 BMP for Lead at Outdoor Shooting Ranges

Table 3-1 – Continued

Controlling and Containing Bullets (Cont.) Bullet Containment Devices (cont.) BMP Option Advantages Disadvantages Escalator Trap (Steel) 1. Can be used indoors and 1. Deflection plates require outdoors regular oiling. The oil used is hazardous and can easily migrate at outdoor ranges 2. Relatively high maintenance 3. Poor lead collection because the bullets may become clogged at the spiral collection area at the top of the deflection plate 4. Increased bullet fragmentation 5. May require rubber curtains to be placed in front of the trap to slow bullets 6. More noise 7. Possible creation of lead dust Vertical Swirl (Steel) 1. Can be used indoors or 1. Does not accept shooting outdoors from all directions 2. Bullets are captured in 2. Corners where each unit pure form in containers, meet can cause ricochet thus removal and recycling and fragmentation problems is easy 3. More noise 4. May create lead dust Wet Passive Bullet Trap (Steel) 1. Can be used indoors and 1. Expensive outdoors 2. Oil and water mixture is 2. Excellent results (i.e., low hazardous ricochet, low fragmentation, 3. More noise ease of removal) 3. Bullets are captured in containers, thus removal and recycling is easy Lamella Trap 1. Can be used indoors or 1. Rubber strips quickly outdoors become destroyed and must 2. Reduction of lead dust be replaced 2. Potential fire hazard 3. High maintenance 4. Scattered lead fragments mixed with rubber can migrate; lead contaminated granules are hazardous and require special handling

Chapter III - Page III-21 BMP for Lead at Outdoor Shooting Ranges

Table 3-1 – Continued Controlling and Containing Bullets (Cont)

Bullet Containment Devices (cont.)

BMP Option Advantages Disadvantages

Rubber Granule 1. Can be used indoors or 1. Rubber strips can outdoors quickly become destroyed 2. Reduction of lead dust and must be replaced 3. Minimizes 2. Some pose potential fire fragementation, compared hazard, although fire- with some backstops retardant/resistant materials are available in some designs 3. High maintenance 4. Scattered lead fragments mixed with rubber can migrate; lead contaminated granules are hazardous and require special handling Shock Absorbing Concrete 1. Adaptable/can be 1. Mechanical lifting and formed in any shape handling equipment must 2. Can be used to reduce be used during installation erosion in soil berms/target and maintenance emplacements 2. High maintenance 3. Crushed concrete can (replacement) costs potentially be recast after fragments removed Removal and Recycling of Lead

Hand Raking and Sifting 1. Easily done by club 1. May be more time members consuming at large ranges 2. Inexpensive 2. Weather sensitive (i.e., 3. Can be done outside works best under dry operating hours conditions) 4. Relatively effective 3. Exposure to lead and lead dust possible Screening 1. Effective 1. Vegetation must be 2. Potential economic removed returns 2. Weather sensitive (i.e., works best under dry conditions) Vacuuming 1. Effective 1. Weather sensitive (i.e., 2. Can be used at least works best under dry accessible ranges conditions) 3. Less vegetation needs to be removed Soil Washing 1. Effective at cleaning the 1. Vegetation must be soil to remove the lead removed particles so one is left with non-lead soil Chapter III - Page III-22 BMP for Lead at Outdoor Shooting Ranges

References

Battelle Memorial Institute, Field Demonstration of a Sieving and Stabilization Technology on Lead-Contaminated Soils at a Small Arms Range at Mayport Naval Air Station, Colum- bus, 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, Possible Transport by Waterfowl and Reexposure by Hydraulic Dredging at Collins Lake, Department of Biological Sciences, Union College, Schenectady, NY, June 1991

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

Magdits, Louis J., Recycling Regulations, Proceeding from the Third National Shooting Range 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 and Indoor Firing Ranges, 1991

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

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

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

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

References - 1 BMP for Lead at Outdoor Shooting Ranges

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 Shooting Ranges, Newtown, CT, 1996

Stansley, W., Widjeskog, L., and Roscoe, D.E., Lead Contamination and Mobility in Surface Water 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 CERCLA Sites 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 - 2 BMP for Lead at Outdoor Shooting Ranges

Appendix A: Resources

This manual provides contacts for lead reclamation companies, lead recycling companies, bullet trap manufacturers, and organizations that provide prevention and/or remediation techniques to assist clubs and firing ranges in implementing Best Management Practices for shooting ranges. The list was updated for the June 2005 printing. Vendors who are interested in being added to the list of lead reclaimers or remediation contractors should contact:

Lead Shot Coordinator RCRA Compliance Branch US EPA Region 2 290 Broadway New York, NY 10007-1866 Telephone: (212)637-4145 E-mail: [email protected]

Appendix A - Page A-1 BMP for Lead at Outdoor Shooting Ranges Lead Recycling Companies Below is a list of recycling companies for lead in soils and spent lead shot/bullets that were contacted during the writing of this manual. Lead recycling companies smelt lead. It is not inclusive and is included for informational purposes 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.

The Doe Run Company East Penn Manufacturing Company, Inc. Resource Recycling Divsion P.O. Box 147 HC1 Box 1395 Lyon Station, PA 19536 Boss, MO 65440 610-682-6361 Rick Leiby 800-633-8566 573-626-3476 Web Site: http://www.eastpenn-deka.com Lou Magdits [email protected]

Exide Gopher Smelting and Refining Spring Valley & Nolan Streets 3h385 Highway 149 Sout Reading, PA 19612 Eagan, MN 55121 800-437-8495 651-454-3310 Robert Jordan, Maritza Rojas-Suarez 800-354-7451 Mark Kutoff Web site: http://www.exide.com Web Site: http://www.gopherresource.com/

Gulf Coast Recycling Kinsbursky Brothers, Inc. 1901 N. 66th St 1314 N. Anaheim Blvd Tampa, FL 33619 Anaheim, CA 92801 813-626-6151 714-738-8516 William Weston Paul Schneider

Web Site: http://www.kinsbursky.com

Reserve Trading Corp. P.O. Box 302 Medina, OH 44258 330-723-3228

Appendix A - Page A-2 BMP for Lead at Outdoor Shooting Ranges Lead Reclamation Companies Below is a list of reclamation companies for lead in soils and spent lead shot/bullets that were contacted during the writing of this manual. Lead reclamation companies reclaim lead from ranges. It is not inclusive and is included for informational purposes only. Mention of these companies does not serve as an endorsement by the EPA.

Brice Environmental En·Range, Inc. Entact 3200 Shell St, 3326 NW 29th St. 1010 Executive Court P.O. Box 73520, Miami, FL 33142-6310 Suite 280 Fairbanks, AK 99707 Thomas M. Taylor Westmont, IL 60559 Craig Jones 305-999-9965 630-986-2900 907-456-1955 Fax 305-635-8645 www.entact.com www.briceinc.com Email: [email protected] www.en-range.com Performs physical removal of Reclaims primarily from the lead from backstops, earthen backstops and sand Provides lead reclamation and chemical treatment of soils traps. other environmental and and returns soil to the maintenance services. backstop.

Karl & Associates, Inc. MARCOR Metals Treatment 20 Lauck Road 246 Cockeysville Road Technologies, LLC (MT2) Mohnton, PA 19540 Hunt Valley, MD 21030 12441 West 49th Avenue Edmund Karl III Dave Jungers Suite 3 610-856-7700 410-785-0001 Wheat Ridge, CO 80033 www.marcor.com Jim Barthel Works primarily in the the mid- 303-456-6977 Atlantic area. Lead-containing Uses a pneumatic separation www.metalstt.com soil is physically removed and unit to remove lead from sent to licensed disposal sites contaminated soil and treats Removes lead from soil and or licensed recycling facilities. soil to pass TCLP. treats soils at all types of ranges.

Sears Trucking Company Solucorp Industries, Ltd. Southern Lead Removal P.O. Box 38 250 West Nyack Road P.O. Box 2645 El Reno, OK 73036 West Nyack, NY 10994 Daytona Beach, FL 32115 Garland Sears Mike DeLuca Kevin Gilchrist 800-522-3314 845-623-2333 386-763-0115 Fax 405-262-2811 Fax 845-623-4987 Fax 386-761-6991 Email: [email protected] Physically removes lead from www.solucorpltd.com Removes lead from indoor and soils at trap and skeet ranges. outdoor pistol ranges only. Removes and treats soil using their Molecular Bonding System (MBS) soil stabilization technology.

Sport Shooting Services Terra Resources, Ltd. Waste Recycling Solutions, P.O. Box 667 HC4 Box 9311 Inc. Crawfordville, FL 32326 Palmer, AK 99645 1850 Route 112 Ed Tyer Larry Wood Medford, NY 11763 850-926-7375 907-746-4981 Tommy Arabia, President Cellphone 850-294-0132 Cellphone: (907) 232-5059 631-654-3811 Email: [email protected] Fax: 907-746-4980 www.terrawash.com Uses a vacuum system to Removes lead from earthen remove lead from trap and berms, uses a shaker and Uses gravimetric process to skeet ranges. screen system to separate separate lead and lead from soils, rents TerraWashTM soil washing screening equipment, and technology. consults on range design, primarily in Florida.

Appendix A - Page A-3 BMP for Lead at Outdoor Shooting Ranges Other Resources

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

U.S. Fish and Wildlife Service Institute of Scrap Recycling Industies, Inc. 4401 North Fairfax 1325 G Street, NW, Suite 1000 Arlington, VA 22203 Washington, DC 20005-3104 703/358-2156 202/737-1770

Web site: http://www.fws.gov/ Web site: http://www.isri.org/

Lead Industries Association, Inc. National Rifle Association of America 13 Main Street 11250 Waples Mills Road Sparta, NJ 07871 Fairfax, VA 22030 973/726-LEAD (973/726-5323) 800/NRA-3888 fax: 973/726-4484 Web site: http://www.nra.org Web site: http://www.leadinfo.com

National Shooting Sports Foundation and Sporting Arms and Ammunition National Association of Shooting Ranges Manufacturers' Institute, Inc. 11 Mile Hill Road Flintlock Ridge Office Center Newtown, CT 06470 11 Mile Hill Road 203/426-1320 Newtown, CT 06470-2359 203/426-4358 NSSF web site: http://www.nssf.org NASR web site: http://www.rangeinfo.org Web site: http://www.saami.org

Wildlife Management Institute 1101 14th Street, N.W. Suite 801 Washington, DC 20005 202/371-1808

Web site: http://www.wildlifemanagementinstitute.org

Appendix A - Page A-4 BMP for Lead at Outdoor Shooting Ranges Web Resources Useful Web Sites Description Web Address Federal Government Sites U.S. EPA's Outdoor Shooting Range http://www.epa.gov/region2/waste/leadshot/ Home Page U.S. EPA – Military Munitions Rule http://www.epa.gov/epaoswer/hazwaste/military/ http://www.epa.gov/tribalmsw/thirds/remunition.htm U.S. Occupational Safety and Health http://www.osha.gov/ Administration (OSHA) National Institute for Occupational http://www.cdc.gov/niosh/ Safety and Health (NIOSH) State Government Sites Florida: BMPs for Shooting Ranges http://www.dep.state.fl.us/waste/categories/shooting_range/

Massachusetts : Lead Shot in the http://www.state.ma.us/dep/files/pbshot/pb_shot.htm Environment Minnesota: Poster for "Firing Range http://www.cdc.gov/niosh/mnables.html Hazards" Ohio: Lead Shot Reclaimers list http://www.epa.ohio.gov/dhwm/leadrecy.htm Wyoming: Lead Recyclers List http://deq.state.wy.us/outreach/lead.htm Court Decisions Connecticut Coastal Fishermen's http://www.duedall.fit.edu/summer/rcra.htm Association v. Remington Arms Long Island Soundkeeper Fund and NY http://www.epa.gov/region02/waste/leadshot/lisfnyac.htm Coastal Fishermen's Assoc. v. New York Athletic Club Articles and Research USAF - Lead Contamination in Soils at http://www.afcee.brooks.af.mil/pro-act/fact/june98a.asp Military Small Arms Firing Ranges U.S. Army Env. Center (AEC) – Small http://aec.army.mil/usaec/range/operations03.html Arms Range Technology http://aec.army.mil/usaec/technology/rangexxi03.html http://aec.army.mil/usaec/publicaffairs/update/win97/range.htm AEC – Green Bullets http://aec.army.mil/usaec/publicaffairs/publicity02.html http://aec.army.mil/usaec/technology/rangexxi00a.html http://aec.army.mil/usaec/publicaffairs/update/spr97/bullets.htm AEC - Recycling of Firing Range Scrap http://aec.army.mil/usaec/publicaffairs/update/spr99/spr9911.htm Florida Center for Solid and Hazardous http://www.floridacenter.org/ Waste Management National Association of Shooting http://www.rangeinfo.org/resource_library/facility_mngmnt/ Ranges' Reference Library

Appendix A - Page A-5 BMP for Lead at Outdoor Shooting Ranges Bullet Trap Manufacturers1 . t , i n f r s o s s e i e n n t e t t r r i s n f r d d u s e h a e o s e s l t e t e t o o e e f l t l g n b t r n a n s b b n i o i i e u d o e l s f n l i d h e h r e i l d t l b n t a - y e t s a i e i o t u . c y a a c m , h m d a l u i e n - h b p w u s t s h m g g n c i o y i g w i m 0 m i l m T a d a i t l f a a l r d r e h o 5 u h s s r c e t t d s i u t e u f l , I r e e i n f . a e a C n d r n d h s e s s b e t m d p w a l d e u g e i . g v n e s d e b h t l u a n t n s b f r n e a m s e e y w g i u m r p i i l c i i l a t n r r o c s , l n s e a c y n t e o l i d o c n a s f o u c a T i u l n a p s e d t t r e d u o e n s a a a e i u s u y C e r i a s s t e s n s - u e r c s r i u d d c c r c T t G c u k b d g i o e , a a l n e t e d e e a . n h l d o l e p e c e p d l t w e d o l n p e e e u r a d h a h e l p n s r u o o e s r h o a r i o e n s T t T f s c a c a a e b b b p b l i i u r B n . , d r o r o p d i s t n t e t e a e u n r a n c d b a i b t p o d o e n b i h w i l p t m l n d t r v a e u o o w l l e r m a o a e a o b h p r h r o u t y h c h t i l e t t o f t a a o c f m e g d c r a f s r s g r a f e a h t f e n e e m l u o t u s a e e o t h t d n o r h a c h o s d t i d w e t n h r n e y l e o s T e n i t l f a l o t t p r e l e r y b d l o h t a s p n u m s i a u s l t . h d d l a a t i i s t e n r i u o u d t - c B a n e e k n a r p l s e o e l l o w i e f l n i a m e a a o l r e e o t i l b b i b s l , u . e s m t c e u e s r h n s p i r a f e r p t s m v f b e o m s n o e d e s o s l b a t y e a r y o o s u u t r v g a r c e u i e f t t i h n e r e t b l c g D o t n e t m l d d t i c n r h h a a i A e n v a l t t e u i e a r e e m m a r n a i p n b r l n e v e b e s s p i . i u m n d t i r i r t o l i e e o o s i s e t t r a t . e n r e m a b e n n o r T T n o h t p c a u e e i t n t o o e n r t p i m h i i B n n C m n f n t t r b i s s s o e a i s e g e e e i l u T R t c c r r e r t a e e r r t u h l l t m e u s e e e p t c b e l e e l l e e o c g g d r l c n l a l f e o n e r b h f h h h e n n r t i n a u a s o o h o u h h u v w T T f t t c c c c d a a d o d a e b u r n f e o o s y s r u * . p e d a - . t g g g i r f a - g - n s r r r . o n n n d o r o l l i i i a e d T o o n n o c c c s o o p n e e e t t r r r n e l l m m e U f f m u s s p e e e c a r r i i i i r i i i d y o n A t A a * C p p p i r P R P R d e e c t i d r o u l P N c n n i I y f r s o t e n e n e v ) e o o i d i i e l c d t s t t y i u e r r l e h a a a m l l e c l l P D d g h p i i v n a a c u i I t t l e l u r d r s s c e q u n F n n n a i ( D E P I I f o ) d 0 t t e s 0 t o o 8 n c , o o C e f 1 l p t $ t r e a d n r s o e e o e t T t o n i f s d a l / e n 0 r r m 0 e i 0 a u t 0 p t 6 e s , 1 e a n 1 1 i E l d e / f $ $n ( t e l n b e a l i m a n m i v r ) ) a t e A T T n B B s C o r n T R C ( ( e g i l b s p p a b t e a a u r r o D T T T R e O v r m E o 3 e p t t o r C b 3 a c u e e r a 0 . , t t g g T 8 s c r r i e s - t l a t i a a g r f 7 e r

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Appendix A - Page A-6 BMP for Lead at Outdoor Shooting Ranges Bullet Trap Manufacturers Con’t.1 t e y y ) a t . i h n s t t h e s t e t a n d h e d d p n n t t a e y s u n y e i 0 e r . o r a c t . u a i s t i a n d 0 f s f r d q s s r m i e n r d o n i p 0 p r r e e p c , u , u n t a e t e l a a o m u f c a e 0 d r e r o e s s t e . a o r t . t o a c m t p 9 n c t g e a e a n d s d o s s n e C a s b b f . u e n i e m d - e y n n f t l n i e s p i c l d o q o o e n e g l t s e p n e o t i u e i r e a c i i e d t a m n ) e v n s r t o r g o u d f o s e i c u y n a n a f . a o e , : p t a d n r e f b l r o i i i q d e l o t c e h p e i g a s a i a m n g r l d r i e o r c i , a y o l g n n e e i m t n e l b m w t i x n s m o f v b i . n n c i b a u p d t r t a o i o , e d t a o n m e w G g l g o t c s y l a . e l r o i i i e e v t p n h d o e l t o s L E c e i u T c g s g t p s l l o a i o . l e c u g n a u e p u r i r ) ) f e n u v p e u h ) e o d e o w f 2 s 3 o d a o a a d O C S S b ( ( r r P E P R 1 l t r e m e n y n e i h . r e e ' t s e t v t e . a t e a e t 4 d t s p e f s o s s c v d e h t s i a 1 y l s e o r g o t d t l n a d e a i d d n s s s n o a l - s e i f d u e l n i e r e n e e l u l e ' e o n b s l u e a h n e e e s m o n t z l f l 2 t i i n r i o a a r b h l v t o o s t n a o p g 1 i n a i ' b r u S e a T a t p c e e t r a s e n i o 2 e s c x r i t s n , p s h s e i b h i a t t r d i v . t 1 t m . t f s e e r o i r m i e c i T e n o p e g a r t b - o y h l o z c d e m e n v l c a t i o t o a t l e s a ' l n s t l o e m . r o t i e u r e d n s t f t b N 0 i a s r o n e c d d b g y a s m w u a i d k 1 t g c o a w n e s c y D i ; . o o t c r e e n t m t a l a m i t s s s p p s e h l n a a i e . n a o p s d a e a a n c r u e y l b h ; s g s i e t o d r r a l f i n c i t m t t n r c b e u e d a i t a h e k t m e a d t l r a a d n s s d g n f a l c g t i e e g p d d i - i n n a r e r a a e e n c u f s t h h h a e n v n f i u r r e l r a o e u i i r h a e o T T f T f f t s c s s d a a a o d q g g h r r r p g k ) n a . a i r p e c n n T r e p u u e f i g g R S ( o P s e e n n s - e e n n u u r l r i i l l g g g e a o h h t t o o a c e c c t t S o o l l s m a f f s s a a r i i h h i i r o U A T t S S M M P R P R d e d e c u i l g r c n P i n I p n t p i i o h N Se f f s o o t t n e n n e ) e e o d i e e c t d s s t i y u r r l h e a a a m m l e c l g d P h h p p i i i v a n c c u i t e l I l r u r u r s c e u q u q F n n i ( D P E P E I s f e f r o r o a u e t e t p o a n t s t i h y l e o t o t / f t i o 0 C f o n r w n p 0 o g e r o f i d a 3 s h m , a r s t t r e e o 1 e i t e T n o a r r $ n f ) ) a d e i e a l d d d d / n v s o m c i n e i e t i n 0 l e t f t t / i a e e 0 c c g s 0 0 c c p t 0 i e e n p , 0 4 l e l E r e o a a 1 6 9 e p e P d o r f t $ $ s s $ s ( ( R t / t e e s l l n l n b e u g a i y l B r m i r s a r n a e l i e m e v v u a s e D t b o t n A p n c b s a a r o e u y r T C S G R R e r s n e 9 1 p r n o 8 0 a s u e s r l 4 2 t f s u t T e 7 6 c e i i - - n t a p n D 3 6 f a s o e l : :

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Appendix A - Page A-7 BMP for Lead at Outdoor Shooting Ranges Bullet Trap Manufacturers Con’t.1 e t . l h r o t a t g - i g e m h n 5 s n b t i w g i e t l h t 5 b t s n c n i i s d , u d m y r . e r y g e a w n c e e g s n t d m . m i a e i d e s o t s r o e t v e e n r r p y o ( m i t d f r . c o t o s a o g o t r n n s o r n e r o f t h l n n p e a e l e C . a i e t d s e t ) g c u e n l o l d a n e i n i . i n n c b e e p a m p d b y v u t o r a a n i r c u n i g t o b r n e n y r e e a i o o r - v a c o f h o r v e d l r n s a n p t i i l u m t v o o e e r n e s e a t m t n c o s n e o s n g - u t g s i n o l G e p o g d i h l l l s n a l s t l w n l c c o c n a u a s u e u r x a o o o e a t c c d o a d e g C C m r L U F m o e e e t f u h d h h n t . t t o t i , r e n t m d r e l e t l s n l o s g l u t n a e i m e n t g a u n n l u n e a o i e i b i u l i l c e d o r c b s a t i s w u r t e m n t m m n l e n a e i e b l d f a n e a o a a d x i n n s o e r o c n o r h o i t h h i r r t e t a o t c s e i c a c c s l T l o i a i n h m e p t i r l t m t w i e b l . i a e f s s e r t r u s p c e i r e o e u l e h s c n o p t l s o a e e t a o l t d r o s f o y h a c a u e i d e t i l i l t g r n c l t i n t e d z i b t u h i i u r d n a n L e n g w t D T I c d a e a s e i u e y l m h a t t e t i t n t r A p l h o r g u r c l t . i t n e a n e r w o i c T a N r u u . e v r y r b e r o m i s p l . s t e S b t h d s m n e c s p s m c e e c e t e l t t d h e e p d d d l n a a o s t e m a a i a h h a n n n u l l c o h p y s h r a i t e w T T t t c c s s a a a b p p i l r r t l o a f h c o s ) ( s 0 p e g 5 a n g . r u u l a ) T l o g s s t t o o G e e t t o l l U d f f p s s i i h M i i n u a S ( B P P R R n i d e d e c u n i l r o c i g t P n t n I a i l h l p t g a i p o t i e s h N r n S Fl I f f o o s t t n e n n e e e o i e e d c s s t i u a a a r m m l l l h h p p c P i i a c c n t r u r u I s u q u q n P E P E I f t f o : r s t d ) a p s n h n t e a o i a o r t t t t n i t f f f f i t w C l a / p i f c r r r r r s 0 d a o e a a a a l e r e : 5 e t e e e e i : t e i s t : T r 2 : y r t n n n n e s , i i i i e a r a y l l l l c e 1 / / / / r t p v D W m $ c 0 0 0 0 y n i D W - t l l t e u 0 0 5 5 g 0 o o i s c d 3 4 e e 1 2 t t i o l l 0 , , , , s r f f o E s s i i i i w 8 2 2 2 2 e r P T $ $ $ $ $ d p ( P P R R M e T s r r l M L n o o T b I t t g p a r i a a A l l l i a s a r N l u u a e M T s s u S v T a a n D p p c A e c c a a a o r h l n n r r T T T G B E E m s r o e 0 7 1 e c p m s r g . 0 1 0 r m a e a s u n 2 2 0 t e r o t a m 9 1 7 k s m c T c - - - . e c y o R t t a s 3 9 8 u f h s s : : S r e p 3 9 6 t t y l e u T l a 5 9 5 c c m s D e g n r

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Appendix A - Page A-8 BMP for Lead at Outdoor Shooting Ranges Bullet Trap Manufacturers Con’t.1 . l y e b n n d o e s s t r t m r n e e . o e p n f d . r m e n e t e o g p m p z n i a o r e a d r C e b a v l y n a e b r @ t a i e c r c s r n o t - n e e i r o k C i G a t s B a w s E o n m : l p k i g a i l s p a i s c a c e e t m S m D E R r r g . n e e f f r n f e b v i o e y e o v b o d e b n r r b n e l e u n b a e r a r d u a f h u u n r y t e e , r o d o t s r a m a t r i e h i l o n y c e r c u r c l o n a i b t m u r m u i n e t o v p r d a o e s r - e t o g c h t d t i d m r n c v t t s e t t n e i a e e e j a o s o n t x p t a h i e h w h o t c r e l b o c e e r i r l c r T l c r m c e t y l o d s w P r a l u s e . t s e . c t n s n e . i r f o b i e c n o p s r a a a b i n c e o e o D e l i p m , P o w l h t r s m l o i n y i l g t t n c l o i P a u e i t e e f g t t n t a c e i e a A a t r h d h n t n a s r r t i t ) r T e c e u e t s y r e l r l u d i i e r t f g S s t a a u e i s p i , r m p c e f e r e t n b d n l l e e g u l d n m i e a m b o o r f h h a n r u n o o t n c r e u i n T T f t c c s a g b m l i ( u r r d p e s o & ) e r s f a s e g t r r l l e d t m a e o e d T o b t s n e s t k i n c l d n l m f f e u s c a i a U i n a p a 2 o b r o a j t c a C h ( u r P R 1 n i d e d e c u i l r c P n I t o N f o t s n n e e e o ) i e d c t s t y i u r r h a a l m l e l c g h p P i i v a c n i t e l I r u r s e u q F n ( D P E I f o d c i e t f i r ) s t c u o o e s C o p a f p s e a d r e e y m r t T ( b a a u n s m q g i e i t i s r s s a e y E V d b t e l e s l l n u b g a B i l r i s e a P e h v P D c A t A a T C S , i , r 3 4 m d k n e 2 2 p o r a s o d , c 2 2 a i . u o t r r e w t 9 9 C t - - a e T R c o t a B h 9 9 9 k a t r : f S x c 3 3 3 s t E t e i o l u 0 2 2 c l O a

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Appendix A - Page A-9 BMP for Lead at Outdoor Shooting Ranges Bullet Trap Manufacturers Con’t.1 - , l l ) l r h a o s d t e m s x o t n m g i s f c f n e r i e a t f m w o p n s l t 0 t t i i o y . e o n i s e t p m 4 s p n 0 a s g t . t s s a r b t n n e n 1 d y s s a 0 s u e a r d d e l a r i p o r s b , a r o e s r n i m f y ( i o n e e a p a m e a , u 0 r d h i t g v w . t a a r s t a r t r s d y c p e f s i t 0 e a p i a y e t r o e n c m r i o t m u l r L r a e d n 1 t p e a t p t e a s d g o a o o c l c l m a e r e i p n t r g e i f s o a t a z t t r e d e n i o i d a u y s r l b ) r C o n o n u t l i t n d a a . t g n a s i T m o e u c a y e r o a r b l t n e n o c n h l s s s u m t c y d i f t d r p n m t h a a c o e s a C R a o o r t t c e i a n o a e e n r s e e o s l r t s m m i u l p o v e s e f r s h s m t o e b s e e f g g a l r . n a i m t o s o t u t t i a i r t o e 0 t e a b n n n n i a g m n a f n u y f b e i a i i x i m b s v f e 0 t y u t l t e y d r P n t i a o m n f o . h n r o i a u i i o o m i i 0 , c i u g s o l e d d r s l e L t o , k r c a ’ G c s d t d r o l y e I I o n c o e a p n d a c r n o 0 . p i o m C n c c c a e o i n y s e T T h p e n u s l a s e s c o h 3 T u i e e e n a a m v v f c s a d a q a e S S S b m m m i l l ( i u r r r r U R 1 . s d d t s s d ) e g l . n n e f e e l f r n r d l i n f a l l i a o g a o a e a e e r g a l l u l i d l r c n o h f , l 0 k f y i n b c u e s i b t l t e e i a d l c r e u 1 y o e t i n e r e l c s c t e t e a r n r r o l b c t h u a o f a n u a s a r h c - c b o r l t i u s g e e i s o i h T t o , o e r T t e g p i n e t , p t ) e e i r p t t s : n e d w c m e r f n r e . s d r i y a , e l d h r i r i s e s a b t r p e t e f r e o e s f g n h i d l g a u s e c r b e a t z s f c , r t t b i e i o a 0 e n e e y y f b l g a n e l t c e n c n w e b t g i n 0 s s l a n r b n z , m l o a t u d s o o o s t u n i d a d d 5 a i l / a r o l ( r s a l e u c e t n e t r n e a v e d n e t c b s r o l a t e r a b a a s i t e e R i e s a d R D e e . d d a R a t m ® c n n a f v i p r p y n a i i r l n y f s g n r n A g r i l B e r i e f p u s o N l c d a o e e a n n a ( r t p i i m i m i ” p t g s . S n o m t a e a t o e i s O p o e r d s s a a a 8 t o e g h s s d r g o t t t o / l d k i t l a e m g e s a t C l i l r I I n e e d p t c u l r t c r l n n n o 3 i e i n t l u n a T T A h n l n p e n a a u u a o s o o o h h a a a g s w T t c c c s a a o a d e O g S S S b p b b n i u i r r r p g a n l r n i 0 o & T c u n t 5 r & l . f s o G d y i e i a i r t o n e n i g g P l n & e a P l e a i n n n b t o e n i i i a i r r i d u t & s t g o c i d g e : o h n i t o g a t m d c u n e

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p s a c c r m i l h u r r r a a u U n n A A T T T T c S i ( M F R I A d e ) d e n n l l c u o o i i l i g r t c w d n a P i n n I n e p i e t n c t p i i i p s r o h e e P N d d S ( f s o t n e n e e o d i e c s t i g u r l a a m n l i c l P h p i n a n c i t I r u a s u q r n T P E I t f o o o f t s , r n o a o t g e i C p p n s 0 i l a d a e 2 r r n e t d r 5 t o T i e f $ : t r a y p o g a o r b m n x d o i o i 0 h t s t o n d o d 0 t r s e d u i d u i 6 u l p r , E o n c f o i w p a 1 n A V $ - - - - i g , n s i l t l r - s e o s a e l e e l ® r o i n s b i b W p h T p g b F a s i r a l M , a u S i r ® , p T s r e s M & r t l a T R o T s e A T N e t o e i a v s e e r t R t s D i d c O s I k C A l i g g e m k e i t - i e s x l c l C n n t p c l r I c c a o e l a a a A u a u l e L a a T C G S S B B B F P E R R R t 0 S m 8 r . . e o 8 e c D p c c 0 r . 2 . r n 0 a 4 u I p 9 S r m e 5 t , . 4 a o T c 4 r n p 9 A A m t c . - 9 r t a . e a f - C L m e r 6 s e p l : 6 u p , o 3 l T , n t

EPA does not endorse any particular bullet containment device or product. Information on this table is offered to offered is table this on Information product. or device containment particular any bullet endorse not does EPA readers for a general understanding of some common bullet trap options and is based on vendor marketing literature. marketing vendor on based is and options trap bullet common some of understanding general a for readers 3 n u r a 7 c d a u C t r : s 7 r l a r n a e i ) ) B e t r F : e o 1 i a @ 1 1 M p n r

t 1 x p 0 t o 5 5 o o r u f e m a u 6 9 9 n A s C C S i ( ( F E R 1

Appendix A - Page A-10 BMP for Lead at Outdoor Shooting Ranges

Appendix B: Lead Shot Alternatives

Another method of preventing lead contamination at pistol, rifle, trap, skeet, or sporting clays ranges is to use less toxic or non-lead ammunition.

Much progress has been made in the development of alternatives to lead shot for hunting uses. Information gathered since 1976 on lead poisoning of endangered and non- endangered migratory birds due to lead shot ingestion led the United States Fish and Wildlife Service (USFWS) to consider several alternatives to eliminate lead poisoning among migratory waterfowl birds. A ban on lead shot for water fowl hunting was phased in beginning in 1986 and finalized in 1991. Lead shot is also now banned for shotgun hunting occurring near wetlands in national wildlife refuges. Starting in the fall of 1998, the USFWS banned the use of lead shot in waterfowl production areas. Additionally, many state- managed hunting areas require non-toxic shot for upland/small game hunting.

There are several alternatives to lead shot on the market today and still more alternatives are being developed. Before being used for waterfowl hunting, these alternatives must be approved by the USFWS. Bismuth, steel, tungsten/iron, and tungsten/polymer shots have been approved by the USFWS and additional alternative shot materials are in the USFWS approval process. Most of the ammunition manufacturers in the United States, as well as the military, have developed non-toxic alternatives to lead. Research in Europe may also result in additional non-toxic shot alternatives from which U.S. shooters may choose in the future. The following pages compare lead shot to non-toxic, alternative shot.

Appendix B - Page B-1 BMP for Lead at Outdoor Shooting Ranges , . d e s t l r e o o o s h g m r u s , d e ) . l y h n n d t y l o n t u a i u o l a g i m t d m s b n m o i i i s a i h g l B e y b l - l s e n b t s o f a a s t n d r u o f e e p e n l r l t k e o r a s c t a a P u e , u ( c m c s e m d t f u e o e n a d n r d r i n s e n i t p e a c a r f y i s m i e o b d g y d r i t e v n e p n a o a a m h s s s o h , i t t t t t e s t s i T s : i e h n n . n n n l c g d i s e e e e e h h t b . n s t t d i i e a g m m m u u m m m a d r e n d l i m u a l m m m m m m m l e a s n e s s a i c o o o o o h i i r e o i n f T c C Cs m m i B Cs B C C L h t e l u b m a l i s l i r a y y y b t t o t t t v i i i i i f l l l l l a w i i i i i o b b b b b y d l y a a i a a a l l l l l l e i i i i i t d p i a a a a a a p m v v v v v e i u A Ay s Ay A A L Re s e v i t a n r e t l a e e e l l c c c c c a n n n n n a a a a a h c m m m m m i r r r r r h o o d o o o d f f f f f w a r r r r r e e r e e o e e e l t a P P P P P p o d t r c c c c c m i i i i i r a t t t t t o a d s s s s s l c i i i i i i l l n l l l l l l l l a e m a a i t a a a r a Sd S B Be Be B B d n e i - d 5 5 5 d 0 a 2 2 2 2 2 e 0 o . l k r r r r r 5 e c r e e e e e 1 a x p p f p p p $ p o o t t t t t b † e s s s s s x r @ d o o o o o o a n s C C b C C C u / s e l l o 0 x e e e e e 1 1 1 r t t t t t e 0 o x . x x a a a a a h b 0 4 o o o o o s 1 m m m m m $ B B d B B B i i i i i o / h - n x x x x x b t 0 / d d d d d u o o o o o u s 0 0 0 r r n n r r r n n n l o . l r 0 0 m p p u u p p p u u u 5 . . e s p p o o p p p o o o i 2 3 5 h 0 A A5 $ s $ $ A5 A A B R Rx 1 Rx R R l l l / a a a a a h i i i i i t r r r r r u e e e e e t t t t t * * * m a a a a a s h h h h h i t t t t t M M M M M B n u u u u u i t t t t t t d d d m m m m m o o o o o a a a a a % s s s s s h h i i h h h Product reference within this table is not an endorsement by EPA. is not an endorsement by within this table Product reference Costs will vary from store to and were valid at the time of manual development. i i i % 7 e e e e e * Approved by USFWS for migratory waterfowl hunting. † 1 3 9 S Sl B B* Sl S S Lx Ld B* B B Ld L L Summary of Lead Shot Alternatives

Appendix B - Page B-2 BMP for Lead at Outdoor Shooting Ranges e t , r e o e o l g f h n e b n e s t e y h r n a a t t r i l s g e l i h r e i i l n t e l n n g e i c w n i h I a i h r e t r t r e e o w e s v r i l t w w a g i e k n o l t e . a o F s t e d o l r w t r c o e u n v r h n d e a c s e e h e b l . s o w l g i a r e a t e i c f b b t d f l n o a d a , g a l g i m t s t r e l u t i m n s n . h i a g h o s i s e a t t g s u a % a s r n n g h u d i g a i m n i 3 r h e s r t s o t s s a i h a e k 3 e s t n a s e n l i n e o l i s d y o l t m m o h w e u i r h i t a u t , n d t l h t t u t e e e g i e l o s a o c e , o t t o e m t i n v b e c h t n t s s e n e b g e u r n s c o h o p r r a i e l p f i t a a r y b l o - e t l e a i e h f o f p a t f y , r t m f a e c i s e w t e i w r l c g o a u e r s m e s . b e n r t t n i e s t t t i e n c r i i c e i g t e s . y h p n o o o e n c s o l n h n t u t n g g i , d s u T h h p e e r e a r s T b e g s n n t s s e g b f s s i e i e s m t t t r , n i a . v p t l l i e o i l r t . l s t v o o m o e e d e e i e e h s o m e l d r t v n l n a o o e o c e e h e e s u d o a c t t t d c l u e u e s s h h e h e e n W s s s s a a a o C g S S p m h h u l i u r m o r f d . s n e l e a b c r c a i l t u i s o a y t e s v i l a i m d b o y e l t i a d r l i d o h a a t p v e o m A b i R o n d , . n s t s u s n a i e o o f t g i n d t o n m a e a a h a e a r c e r u r i s h e t r t i L g r l e w s o e e y r e . m g e s b g s c t P n e A n e s n i e c o t n c l a c h n d n o n t t i n r e m n u t a a r r a t o a h a e s o c f i e N m f f d n r i r u d v i i a o e d † t d e f ) e e v c r t l l i E P P t e e n b f a n E f n p c a a r i e e u c t S t n e i e f g s s o i p N t i e l e s w r n o l o t t O a o g o a h e i C e n s C S b m ( B r I r e d p e - r t d x e s a o p o o b 1 l p / C x e o 5 r o c 9 e f ( . t B o 2 a x 1 d x o m $ n i o b / u - x b ) / 0 o o d s 0 0 0 r l . l e R 0 0 p t . . 5 e a p 5 8 6 1 l h A 2 $ $ s $ p l a i r e t a M * l t e o e t h Product reference within this table is not an endorsement by EPA. is not an endorsement by within this table Product reference Costs will vary from store to and were valid at the time of manual development. Summary of Lead Shot Alternatives – Continued * Approved by USFWS for migratory waterfowl hunting. † 1 S S

Appendix B - Page B-3 BMP for Lead at Outdoor Shooting Ranges f i . s y , l n t t n e e b . o e r e r f g a n . h e , n l o e , i i t a l a . f e c c e t d l s a o s b e t t o n m r r e b v h n a o a c o s l a i o e d a a i s u e f f h l r c l i d h a l g s t t y d a d o d l e a o e o l l e r t , t v a n e s h e e s i e n m m d a e a r l n s y e u a d e o l L t l u n r r s l y a c e e l s r o o a i s m e c e k . b d u r i b d e e l w e b l o c d n t o n a t r f n h t s s a t s a I i e n h a e i a T r e o c t c a t c h d h t . g h t . t n c u r o i l l . t o y s l a o e g t i e h t e s o h w m i n n e s b e m e i s n m h w f t s l n a e e s h o p l a e i , s m r i t r r r e s d s t l i e l d u e u e / l a e u n e e r e n r t c q n t n a a r m e i a s e a e n s e s t e l c t t h o o i t s s s k h o , s t f l t t , s t t t e d r n s l s c i e m r d t n n n n n b r e o e i g h e p s r e a u e e e d s e e e m n n w g s o g e e h c e d d o u r t l u w u t m m r m m m k n t e h i e i p u t o o s a a u t a r s n b t m m m m m o s h e e c E o n h m u t e e s o o o o o l n h e e b m u o a o r h h n s t A t t t T t A c c a e C Cs h i i Cs C C B I e l b a l i a y y y t t t t t v i i i i i l l l l l a i i i i i b b b b b y l a a i a a a l l l l l i i i i i d a a a a a a v v v v v e A Ay Ay A A Re y y . t l f i s t d o s a s n a n t e a e e l t e n c g i v a f d u i f d i t i h o o r t c n e t t r e g m h i f e a a f a t T s h c e a t . e s c i s i d s h t e d a % a e e e e g , n e 4 c c c c c i l r g s d 9 i n n n n n i e l d i r s a a t a a a v t t a r s i t r r o e c r m m i m m m a o h r r r r r a w n p c p s o o c o o o o y o l f f e f f f t r r i r r r r r n H e /

h † e e e e e o n e c n y i r t i . r P P P P P a e / t s t a n e n o s c c c c c n e n i i i i i i e h g t t t t t n t h e i s t n s s s s s s m v i i i i i i t l l l u l l l g d e l l s l l l t o e n s a a a a a a r f r h u e e t s o o l l B Be P Be B B 5 5 5 0 n 2 2 2 2 2 1 / o r r r r r r 0 0 i e e e e e / 1 0 . p p n p p p 5 n e t t t t t i t 2 s s s s s s $ d o o o o o g e n C C C C C k @ u c t e e e e e ( 1 1 1 a t t t t t s x x x p a a e ) a a a x o o o o o x x o e m m m m m o o B B B B B i i i i i b r / b b x x x x x a 0 d d d d d o o o o o d d 5 r r s n n r r r n n n . t n n p p u u p p p u u u 2 o u u p p o o p p p o o o 6 h o o A A5 s $ A5 A A r r R Rx Rx R R / * l l l n n a a a a a i i i i i e o r r r r r t r I s e e e e e / t t t t t g n n a a a a a n e o t u r M M M M M * * * t i s l l l t t t t t

g Costs will vary from store to store and were valid at the time of manual development. manual of time the at valid were and store to store from vary will Costs

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Sl S S Sl S S Summary of Lead Shot Alternatives – Contiued – Alternatives Shot Lead of Summary

Appendix B - Page B-4 BMP for Lead at Outdoor Shooting Ranges s t s n i y o e e a a t l r , l n r h s l h u t s t a a t e e d i t n a i e p r h e c l r e r , , o m n i t e t s t i l e t y a a e e d m y a f l l t a c b l n n b o m g d u u s o a h e a u a o c j o r y n a n o s p l t i e p / m o l e y t m e a l a o y g r r l w r l n n n g m a h p s n p u o m r p i i e / a e t n o f d t l i o p m h d n c p c n s n f t o a g m i i a e t n e a g a t r f m a e f p s b e e f i r y n s e u t o o o d y p l t m o h o u g c n u n e t l m t o e e a t a r l n i s a a s a m l v d t d e o u c u m A g s v a t t s e m , h s n e o f t s i r b d i f s r n S n c g i i a s n e , t c u t p e r o o n h e d U . o s o u i s l r r i p e d t m e i n T t h d d / i p r a y b v e o e a r a l e s o n n o e p h t h . r r o o b e s t e s u s o h s o c t n t o p w p l i . h , e f a / c l t c s n o y n o m s e c h r e i y l i n b t g r l b A e v i n a T S H d s t x m a e a n o i x e t u e f e a n o a m r d c . u t t s W e d . g . i s t e l h e l e - e t t t s a f r g r t t F m e o i p t s n r o o o e r t e e n s a o i S w p e u a o s u h h h h h u e n A T t t t t c s s s a C b b h m n u i U l b a l i a v a t o y n t i l y i l t b n a l e i r r a u v A Ce o r i / n e e t c s g n n a u t m r o o t f r e e l b P † a r c i a t p s i l m l o a Ce B r e p t s t o 1 e C x y o e e t l B a b d a l m i n i a u x v o o r a R p t p o 5 A 2 Nn S W F s f r S o e * r U l e u a e t e p n c i h y m f t t a f y l l d s u a i m o i e n h r o p v t a r i / e f t t e n m l e a c e a k t e s r v M r s u a o . t g o r t e i o m n r p v o h u a p a h o Tr t V s a S h Product reference within this table is not an endorsement by EPA. is not an endorsement by within this table Product reference Costs will vary from store to and were valid at the time of manual development. Summary of Lead Shot Alternatives – Continued † 1

Appendix B - Page B-5 BMP for Lead at Outdoor Shooting Ranges s e a a t . h u t t d i s t c i t i e u s t p , i d r tion n o I l t o e r e a v h p v h e c t e r s w i d a n o i h e t g H l s n e e g i . e n e R t i e b s p v i n t i o t l s s T a e a u n l j . v r s a d e e s n t i a d m l o l e i e a l s l t a i i t b a s s s r n o t t t t t o d n e e r r h t n n n n n n h p e s a t e e e e e a t l r n r m d g m m m m m I a e l a n i t s m m m m m e i e e h l o o m o o o h h i g n i T T s a C Cs i l Cs C C e l b a l i a v a t o y y y n t t t t t i i i i i l l l l l y i i i i i l t b b b b b n a a a a a l l l l l e i i i i i r r a a a a a v v u v v v A Ay Ay A A Cs e b s e i a c y n n d a i . t a e e m p f l m o o r b l e o a c e l f y i t r v n i a e e a s . v l p d n a e m , e e e e r e g t d t c c d c c c o n e f s a i n n n n n r y e e e a a a a a e l n t h b p t a o m m m m m o t r r , r r r t h n l e t s o o o o o e c f f f f f u e s j r r i r r r e e n v i t i v e e e e e t i s † s s n i t P P P P P a , o c i r n n n t e i c c r c c c e a f t i i i i i a f t e t t t t v h t e t l s s s s s e e m i i i i i r l l a l l l c l l s s w l l l o n s s f o a a i a a a n e e n a S l l i B Be H Be B B 5 5 5 2 2 2 2 2 r r r r r e e e e e p p p p p t t t t t s s s s s t o o o o o e C C C C C y e e e e e e 1 1 1 t t t t t l x x x a a b a a a o o o o o a l m m m m m i B B B B B i i i i i a x x x x x d d v d d d o o o o o r r a n n r r r n n n p p u u p p p u u u t p p o o p p p o o o o A A5 A5 A A Ns R Rx Rx R R y r a r 0 o n 0 p o 0 r m I 2 / e - t n 9 e 9 t d l l l s 9 n e e e e e e l l l t g 1 o e e e e e a a a a a n t t i i t t t i i i n s r r r r r r a s s s s s u a r o / / / / / t e e e e e f e t t t t t g n n n n n s l s a a a a a e e e e e a a t t t t t S g v M M M M M s s s s s n e o W i t t t t t g g g g g r t F o o o o o n n n n n m p n n n n h h S h h h i a u u i i u u u p u Tn T T Tl a T Tn T Tl T T S S Sl h Sl S S U Other materials that are currently being experimented with as alternatives to lead molybdenum and zinc. Not enough informa is available to have included these alternatives in the above table. Summary of Lead Shot Alternatives – Continued Product reference within this table is not an endorsement by EPA. is not an endorsement by within this table Product reference †

Appendix B - Page B-6 BMP for Lead at Outdoor Shooting Ranges

Summary of Lead Shot Alternatives - Conclusions

The table clearly illustrates that a number of non-toxic alternatives to lead shot exist such as steel and tungsten as well as alloys and synthetic polymers. As demand for shot from these metals increases from migratory waterfowl hunters, it is anticipated that the costs will come down. However, alternatives currently cost approximately two to twenty times more than lead shot.

The ban on lead shot in hunting situations impacts target shooting. The alternatives to lead shot that are now being developed for or are already approved by the USFWS for migratory bird hunting could be considered for use by target shooters.

Although alternatives to lead shot are now being used by hunters, it is rare that the alternatives are used by target shooters. The limiting factors appear to be the expense and perfor- mance. All the alternatives to lead are much more expensive, some prohibitively. Unfortu- nately, the least expensive alternative, steel, is also perceived to be less effective.

To encourage use of lead shot alternatives, some ranges sponsor shooting competitions using lead-free ammunition, but these are rare. The use of steel or other alternative shot is a recommended BMP in established sporting clays areas at which reclamation of lead shot is difficult to impossible.

Note: Switching to non-toxic shot may create additional issues. For instance, steel has an increased risk of ricochet. Switching to steel may require additional safety features and/or operating procedures.

Appendix B - Page B-7 BMP for Lead at Outdoor Shooting Ranges

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Appendix B - Page B-8 BMP for Lead at Outdoor Shooting Ranges

Appendix C: Sample Bullet Containment Devices

The bullet containment designs in this appendix are sample designs for the containment systems mentioned in this manual. Design systems may vary from different manufacturers. Reference to various individual bullet containment devices is included in this manual for informational purposes only. EPA does not endorse any particular bullet containment device, design, or product.

Target

Bullets impact and are contained in the sand Di recti on of Fire

Sand

Sand Trap

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

Appendix C - Page C-1 BMP for Lead at Outdoor Shooting Ranges

Gel-Cor Bullet TrapTM (Provided by Super Trap, Inc.)

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

Appendix C - Page C-2 BMP for Lead at Outdoor Shooting Ranges

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

Wet Passive Trap (Adapted from: Bullet Trap Feasibility Assessment and Implementation Plan: Technology Identification Final Report, 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)

Appendix C - Page C-3 BMP for Lead at Outdoor Shooting Ranges

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 C - Page C-4 BMP for Lead at Outdoor Shooting Ranges

Appendix D: RCRA Regulatory Requirements and Interpretations

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

1. Reclaiming and Recycling Lead Shot

EPA’s Office of Solid Waste issued guidance in 1997 indicating that lead shot, when recycled, is considered a scrap metal and is therefore exempt from RCRA regulation. A copy of the March 17, 1997 letter with this guidance is attached. Under the RCRA Subtitle C hazardous waste management regulations, lead shot would be considered scrap metal, which is exempt from hazardous waste regulations if it is recycled (see 40 CFR 261.6(a)(3)(ii)). Although storage of scrap metal being recycled is not affected by specific time limits such as the speculative accumulation provision (40 CFR 261.1(b)(8)), the scrap metal must legitimately be recycled to remain exempt under this provision. It should also be noted that lead shot may be subject to the authority of RCRA 7003, which addresses imminent hazards. However, use of best management practices is likely to prevent situations which would present an imminent hazard. Using such practices, together with following a clear, written policy governing the facility’s recycling efforts, should also assist in assuring that the facility’s practices can be demonstrated to be legitimate recycling.

2. Storage of Lead on Shooting Ranges Prior to Recycling

Some ranges have indicated that it may be desirable to store recovered lead shot and bullets on the range property for some periods of time prior to sale for recycling.

Provided that best management practices are followed in terms of storing and recycling the sorted lead, a range that follows such practices, and engages in legitimate recycling, should be able to store such material prior to recycling without RCRA regulatory controls (see discussion below). Best practices would suggest that the sorted lead, at a minimum, should not be exposed to the elements and should be managed so as to prevent releases to the environment. Best practices also indicate that the sorted lead should be stored in containers in good condition, regular inspections of the container condition should be conducted, and the records of inspections should be maintained and be readily available. Further, best practices also suggest that the sorted lead should be recycled in a timely manner and storage times should not exceed the time-frames or goals articulated in a clear, written policy.

Appendix D - Page D-1 BMP for Lead at Outdoor Shooting Ranges

3. Placement of Soil After Removal of Lead

For soil placed back on an active range after a BMP has been applied to remove the lead, the following regulatory approach has been followed. On February 12, 1997, EPA published 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 necessary part of the safe use of munitions for their intended purpose. Thus, the range clearance activity (recovery of lead shot and bullets) is an intrinsic part of the range operation. Therefore, the 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 “it felt that the ‘range clearance’ interpretation in the final Military Munitions Rule is consistent with the EPA’s interpretations for non-military ranges.” In addition, the EPA’s Director of the Office of Solid Waste sent the New York State Department of Environmental Conservation a letter dated April 29,1997, confirming that the Military Munitions Rule range clearance principles apply equally to non-military ranges. A copy of the letter is attached.

4. Relocation of Backstop and Shotfall Zone Soil

Some ranges have indicated to the EPA that it may be desirable to transport and/or relocate a backstop in order to reorient or modify their range. This may occur when there is a need to reorient the range due to environmental concerns (e.g., shooting over water (wetland, stream, pond) or excessive runoff), alter the layout to improve shooter safety, or redesign to modify shooting conditions (e.g., adjusting number of shooting positions, increasing or decreasing target distance.) In some cases backstop material would not be moved off the range property, but to another area on the range property.

EPA’s position is that range backstop materials are part of the range and are not wastes when they are moved or relocated, as long as the range continues to be used as a range and the backstop materials continue to be used as backstop materials. Hence, backstop materials that are still in use are not subject to the RCRA hazardous waste management regulations and need not be tested for hazardous waste characteristics. However, removal of lead from backstop materials that are to be relocated or moved is a normal practice of good range management in that it extends the usable life of the materials and reduces the possibility of releases of lead into the environment. If lead removal does not occur before moving the backstop material, the lead will become more dispersed throughout the material during movement and will thus be more difficult to recover in future reclamation events.

As a range management practice, it is environmentally preferable to use soil that may already contain lead and is on an active portion of the range, which will therefore undergo regular lead reclamation in the future, than to leave such soil in place and construct a new backstop with lead-free soil. Records of all movements of berm and shotfall zone soils, along with corresponding site plans, should be maintained indefinitely, as they will be necessary in evaluating cleanup needs during subsequent construction or range closure.

Appendix D - Page D-2 BMP for Lead at Outdoor Shooting Ranges

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 March 17, 1997

Mr. Duncan Campbell Environmental Protection Agency, Region V RCRA Enforcement 77 West Jackson Boulevard Chicago, Illinois 60604-3507

Dear Mr. Campbell:

Enclosed please find a memorandum on the regulatory status of lead shot, which includes a general discussion on the regulatory status of lead shot as scrap metal. I hope that this information is sufficient to address your specific concerns as they relate to the pile of lead shot 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. Hannapel Office of Solid Waste

Enclosure

To: Duncan Campbell, EPA Region V From: Jeff Hannapel, EPA Office of Solid Waste Date: March 13, 1997 Re: Regulatory Status of Lead Shot

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

The Agency has taken the position that the discharge of ammunition or lead shot does not constitute hazardous waste disposal because the Agency does not consider the rounds from the weapons to be “discarded.” As you know, discard is a necessary criterion to be met

Appendix D - Page D-3 BMP for Lead at Outdoor Shooting Ranges before a material can be considered a solid waste and subsequently a hazardous waste. (40 CFR §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., the lead shot. Enclosed for your information is a September 6, 1988 letter from EPA to IDEM on this particular point.

In the federal regulations, the term, “scrap metal,” is defined as “bits and pieces of metal parts (e.g., bars, turnings, rods, sheets, wire) or metal pieces that may be combined together with bolts or soldering (e.g., radiators, scrap automobiles, railroad box cars), which when worn or superfluous can be recycled.” (40 C.F.R. §261.1.) In the Federal Register preamble for the final regulations on the definition of solid waste, EPA indicated that “scrap metal is defined as products made of metal that become worn out (or are off-specification) and are recycled to recover their metal content, or metal pieces that are generated from machine operations (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 scrap metal pursuant to the regulatory definition of scrap metal.

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

[a]t proposal, scrap metal that was generated as a result of use by consumers (copper wire scrap, for example) was defined as a spent material. (This type of scrap is usually referred to as “obsolete scrap.”) Scrap from metal processing, on the other hand (such as turnings 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 composition and hazard of both by-product and spent scrap is essentially the same) and, when recycled is recycled in the same way - by being utilized for metal recovery (generally in a secondary smelting operation). In light of the physical similarity and identical means of recycling of prompt scrap and obsolete scrap, the Agency has determined that all scrap metal should be classified the same way for regulatory purposes. Rather than squeeze scrap metal into either the spent material or by-product category, we have placed it in its own category.

(50 Fed. Reg. at p. 624) Based on these regulatory passages, the lead shot portion of the pile would be considered scrap metal, and not a spent material. The lead shot is a product that is made of metal that can be recycled to recover metal content. Furthermore, the lead shot has not been “discarded” by virtue of its discharge at the shooting range, because the discharge is within the normal and expected use pattern of the manufactured product. Ac- cordingly, lead shot would be considered scrap metal for regulatory purposes. Scrap metal is a solid waste, but it is exempt from the regulatory requirements of Subtitle C when it is recycled. (40 C.F.R. §261.6(a)(3)(ii).) As part of the Phase IV land disposal restrictions supplemental rulemaking (which was proposed January 25, 1996 and is expected to be finalized in April 1997), processed scrap metal and two categories of unprocessed scrap metal that is being recycled would be excluded from RCRA jurisdiction.

Appendix D - Page D-4 BMP for Lead at Outdoor Shooting Ranges

Please note that this discussion of the regulatory status is limited to the lead shot portion of the pile as you requested. To the extent that the entire pile exhibits the ignitability or reactive characteristic of hazardous waste, the mixture of materials would be considered hazardous waste and not scrap metal. The scrap metal designation for the lead shot would be applicable 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 shooting ranges provides you with the clarification that you needed. If you have any questions or would like to discuss this matter further, please contact me.

Appendix D - Page D-5 BMP for Lead at Outdoor Shooting Ranges

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Appendix D - Page D-6 BMP for Lead at Outdoor Shooting Ranges

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 APR 29 1997

Mr. John P.Cahill Acting Commissioner State of New York Department of Environmental Conservation Albany, New York 12233-1010

Dear Mr. Cahill:

Thank you for your letter of April 3, 1997 to Administrator Browner requesting a clarification of the Environmental Protection Agency (EPA) Final Military Munitions Rule regarding the extension of its range clearance principles to non-military ranges. Although the final rule addresses only military ranges, we agree with your view that the range clearance principles apply equally to non-military ranges [see comment no. 5 on page 36 of the enclosed 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 of private firing ranges. We appreciate your writing in support of the range clearance aspects of the final Military Munitions Rule and we will consider your suggestions that we issue broader guidance on the applicability of its principles to non-military ranges.

Sincerely yours,

Elizabeth Cotsworth, Acting Director Office of Solid Waste

Enclosure

Appendix D - Page D-7 This page intentionally left blank BMP for Lead at Outdoor Shooting Ranges

Appendix E: Template for an Environmental Stewardship Plan for Management of Lead Shot/Bullets

Instructions

EPA encourages outdoor shooting ranges to adopt and implement the Best Management Practices (BMPs) found in this manual. To this end, it is recommended that ranges first prepare an Environmental Stewardship Plan (ESP or Plan), which gathers information about, and guides evaluation of, site specific conditions of each range. As such, the ESP assists in selection of appropriate BMPs.

This document serves as a template that may be used by sportsmen’s clubs and shooting ranges in their preparation of an ESP. This template was adapted from Appendix C of the National Shooting Sports Foundation’s manual, Environmental Aspects of Construction and Management of Outdoor Shooting Ranges (the NSSF manual.) This template is only a tool to assist in making ESP preparation easier and can, and in some cases should, be modified to incorporate specific information relative to your club and its ranges. It is intended to be used in conjunction with a full understanding of the NSSF, U.S. Environmental Protection Agency (EPA) and, for ranges in Florida, Florida Department of Environmental Protection (DEP) manuals for the safe management of lead at outdoor shooting ranges. This template is intended to encourage ranges to prepare ESPs and submit them to EPA or NSSF to obtain a Certificate of Recognition from EPA. In this regard, either the following template or the NSSF template is recommended for use in conjunction with EPA’s Certificate of Recognition program.

An electronic copy of this template is available on EPA’s shooting range website (http://www.epa.gov/region2/leadshot) in several formats.

Disclaimer: This template does not serve as a substitute for understanding the concepts and techniques discussed in the EPA manual or other manuals. This template is not to be used as a substitute for consultation with scientists, engineers, attorneys, other professionals, or U.S. EPA.

Appendix E - Page E-1 BMP for Lead at Outdoor Shooting Ranges

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Appendix E - Page E-2 BMP for Lead at Outdoor Shooting Ranges

Environmental Stewardship Plan for Management of Lead/Bullets at Outdoor Shooting Ranges

Club Name

Address City/Town, State & Zip Code Phone #:

Date

Appendix E - Page E-3 BMP for Lead at Outdoor Shooting Ranges

Table of Contents

❑ Introduction • Mission Statement • Purpose • Goal • Delete

❑ Site Assessment • Description of Ranges and Support Facilities • Existing Environmental Conditions - Trap and Skeet Fields - Sporting Clays Course - Rifle and Black Powder Range(s) - Outdoor Handgun Range(s)

❑ Trap and Skeet Fields • Action Plan - Potential Management Options - Selection of Management Options to be Implemented - Options Selected a) Management Actions b) Operational Actions c) Construction Actions • Plan Implementation - Schedule for Implementation - Responsibilities

❑ Rifle, Black Powder, and Outdoor Handgun Ranges • Action Plan - Potential Management Options………………………………... - Selection of Management Options to be Implemented………... - Options Selected………………………………………………. a) Management Actions…………………………………………... b) Operational Actions……………………………………………. c) Construction Actions…………………………………………... • Plan Implementation……………………………………………………….. - Schedule for Implementation………………………………………. - Responsibilities……………………………………………………..

Appendix E - Page E-4 BMP for Lead at Outdoor Shooting Ranges

Table of Contents (continued)

❑ Sporting Clays Course……………………………………………………………. • Action Plan…………………………………………………………………. - Potential Management Options………………………………... - Selection of Management Options to be Implemented………... - Options Selected………………………………………………. a) Management Actions……………………………………... b) Operational Actions………………………………………. c) Construction Actions……………………………………... • Plan Implementation……………………………………………………….. - Schedule for Implementation………………………………………. - Responsibilities……………………………………………………..

❑ Measuring Success………………………………………………………………... • Vegetation………………………………………………………………….. • Soil and Runoff pH………………………………………………………… • Erosion……………………………………………………………………...

❑ Plan Review and Revisions………………………………………………………

Figures Figure 1: Site Location Map Figure 2: Facilities Diagram (Additional figures, as appropriate)

Tables Table 1: Table 2:

Appendices Appendix A: Appendix B: (Additional Appendices, as appropriate)

Appendix E - Page E-5 BMP for Lead at Outdoor Shooting Ranges

Introduction

The XYZ Club, Inc. is located at 123 X Road in Anytown, USA…

Mission Statement

The XYZ Club, Inc. is committed to…

- Purpose:

The Purpose of this Environmental Stewardship Plan (i.e., the Plan) is to:

• Identify potential environmental concerns that may exist; • Identify, evaluate, and prioritize appropriate actions to manage lead shot and bullets safely, as well as identifying and addressing environmental concerns; • List short- and long-term steps needed for implementation; • Develop an implementation schedule; • Identify ways to measure the Plan’s success; • Evaluate annual progress made towards achieving environmental stewardship goals; • etc.

- Goal – To minimize the release of lead into the environment.

Activities to Reach Goal: Examples include: Avoid shooting over and into water and wetlands. Prevent off-site migration of lead through groundwater and surface water runoff. Conduct lead recovery. Discourage ingestion of lead by wildlife. Maintain soil pH between 6.5 and 8.5 in the shotfall zone.

Site Assessment

Description of Ranges and Support Facilities

The XYZ Club has an x position Trap Range, a y position Skeet Range, a z position Sporting Clays Course, and a q position Small Arms Range. These ranges are located in a rural setting and are oriented away from residential areas and surface water bodies.

[Briefly describe each range, its dimensions, orientation, vegetative cover, numbers of shooters and targets used per year, wildlife usage, etc.]

Existing Environmental Conditions

[Describe any known environmental conditions associated with the ranges. This might include type of soil, depth to groundwater, soil pH, drainage to surface water, unique animal or bird populations, etc. Refer to figures, tables, the results of surveys, inspections, professional opinions, etc.]

Appendix E - Page E-6 BMP for Lead at Outdoor Shooting Ranges

- Trap and Skeet Fields

- Sporting Clays Course

- Rifle and Black Powder Range(s)

- Outdoor Handgun Range(s)

Trap and Skeet Fields

Action Plan

[Briefly describe the management options selected.]

- Potentially Applicable Management Options

[See EPA or NSSF guidance manual for full listing of options]

Examples include: - Vegetate sparse grass area of trap/skeet field. - Reorient trap field to avoid lead shot entering wetlands. - Reorient sporting clays stations to maximize the overlap of falling shot into the open field where it can be more easily recovered for recycling. - Limit use of the trap/skeet range to only those stations that do not have wetland area within the shotfall zone. - Apply lime to shotfall zones if soil test results indicate this would be beneficial. - Prepare fields for lead reclamation. - Get bids for lead reclamation project. - Conduct lead reclamation within the trap/skeet shotfall zones. - Change mowing frequency to closely mow grass in shotfall zones. - Construct lean-tos at backstop berms. - Construct a lime lined drainage swale for stormwater management. - List additional Best Management Practices that may be appropriate to your club.

In addition to appropriate site-specific management options, the list should always include conducting lead reclamation within the berm for rifle and pistol ranges and conducting lead reclamation within the trap, skeet, and sporting clays shotfall zones.

- Selection of Management Options to be Implemented

Option x: Option y: Option z:

[Describe why the above options were selected and the general roles of club officers, the membership, and outside consultants, as applicable, in implementation.]

Appendix E - Page E-7 BMP for Lead at Outdoor Shooting Ranges

In order to implement the options selected, the following actions are necessary.

a) Management Actions: [Examples include: assign personnel responsible for initiating, conducting, and completing the alternatives selected above.] b) Operational Actions: [Examples include: collect soil samples for pH analysis, consult with USDA’s Natural Resources Conservation Service and/or the county Cooperative Extension Service regarding best suited vegetative management recommendations.] c) Construction Actions: [Examples include: do site preparation work, get bids, institute mowing and vegetative management recommendations, reorient shooting position as appropriate.]

Plan Implementation

- Schedule for Implementation

Winter/Spring: [Examples include: pH survey, contact local officials for vegetation management recommendations, reorient shooting positions as appropriate, realign shooting positions as appropriate.]

Summer/Fall: [Examples include: prepare site for reclamation project, apply lime/fertilizer/seed, get bids for berm lean-tos/reclamation. As a rule of thumb, 50 pounds of lime per 1,000 square feet should raise soil pH by 1 once the residual acidity is overcome.]

- Responsibilities

[Specific duties (i.e., the trap/skeet chairman/chairmen will…, The club treasurer will…, The membership will provide the labor to…)]

Rifle, Black Powder, and Outdoor Handgun Range(s)

Action Plan

[Briefly describe the management options selected.]

Potentially Applicable Management Options

[See EPA or NSSF guidance manual for full listing of options]

Examples include: - Culvert the stream through the shooting ranges. - Vegetate the backstop berm(s) to minimize erosion. - Construct a lime lined drainage swale for stormwater management. - Apply lime to the berm and foreground if pH test determines it is necessary. - Begin planning a lead reclamation project. - Construct lean-tos at berms. - List additional Best Management Practices that may be appropriate to your club.

Appendix E - Page E-8 BMP for Lead at Outdoor Shooting Ranges

Selection of Management Options to be Implemented

Option x: Option y: Option z:

[Describe why the above options were selected and the general roles of club officers, the membership, and outside consultants, as applicable, in implementation.]

In order to implement the options selected, the following actions are necessary.

a) Management Actions: [examples include: assign personnel responsible for initiating, conducting, and completing the alternatives selected above.] b) Operational Actions: [examples include: collect soil samples for pH analysis, consult with USDA’s Natural Resources Conservation Service and/or the county Service Forester regarding best suited vegetative management recommendations.] c) Construction Actions: [examples include: do site preparation work, get bids, institute mowing and vegetative management recommendations, reorient shooting position as appropriate.]

Plan Implementation

- Schedule for Implementation

Winter/Spring: [examples include: pH survey, contact local officials for vegetation management recommendations, reorient shooting positions as appropriate, realign shooting positions as appropriate.]

Summer/Fall: [examples include: prepare site for reclamation project, apply lime/fertilizer/seed, get bids for berm lean-tos/reclamation.]

- Responsibilities

[Specific duties (i.e.: the small arms range chairman/chairmen will…,The club treasurer will…, The membership will provide the labor to…)]

Sporting Clays Course

Action Plan

- Potentially Applicable Management Options

[See EPA or NSSF guidance manual for full listing of options]

- Selection of Management Options to be Implemented

- Options Selected

Appendix E - Page E-9 BMP for Lead at Outdoor Shooting Ranges

Plan Implementation

- Schedule for Implementation

- Responsibilities

Measuring Success

By monitoring the success of the Plan, the club is best prepared to make whatever changes may be necessary to reinforce success and make the most of environmental stewardship efforts. Below are some examples of areas to monitor:

Lead Recovery

[Document the quantity (pounds) of lead recovered and recycled, along with the cost of conducting the activities.]

Vegetation

[The density of vegetation growth should be measured throughout the growing season, especially in areas of sparse growth where steps have been taken to increase the vegetative cover. This is can be done by taking periodic photographs (e.g., once a month) from the same places to document the impact of the Plan.]

Wildlife

[Keep a log of visual observations made regarding the frequency of range usage by the variety of species in your area.]

Soil and Runoff pH

[Track soil and runoff pH through semiannual monitoring and adjust the amount of lime applied to different areas of the range to maintain a pH level that will prevent lead from dissolving (i.e., a pH of 6.5-8.5).]

Erosion

[Again, keeping a photographic record of problem areas best prepares your club to document achievements and adjust the Plan as appropriate.]

Plan Review and Revisions

Review the Plan on an annual basis. Update the Plan as needed and schedule activities for subsequent years. Make recommendations for future club officers to consider when updating the Plan and designating future activities to be conducted (tell them what worked, what didn’t work, and what still needs to be done.)

Appendix E - Page E-10 BMP for Lead at Outdoor Shooting Ranges

FIGURES

Figure 1 Facility diagrams

Figure 2 Resource maps (USGS topographic map, wetlands maps, soil survey maps, FEMA floodplain map, etc.)

Figure 3 (Optional) Site photographs

Figure 4 (Optional) Aerial photo of range and surrounding area

Appendix A (Optional)

Appendix B (Optional)

Appendix E - Page E-11 BMP for Lead at Outdoor Shooting Ranges

[Insert other figures as necessary to support the text]

Other figures may include an aerial photograph, and sketches of the Club property in general and/or specific ranges in particular.

Example:

Appendix E - Page E-12 BMP for Lead at Outdoor Shooting Ranges

[Insert Site Location Map Here]

Typically, a Site Location Map is cut from a USGS Topographic Map of you Club’s area. The Club should be centered on the map. Indicate the property boundaries and layout of the range.

Appendix E - Page E-13 BMP for Lead at Outdoor Shooting Ranges

Appendix A

Information from USDA, Natural Resources Conservation Service [and/or county Cooperative Extension Service]

[concerning soil and vegetation management recommendations]

Appendix E - Page E-14 BMP for Lead at Outdoor Shooting Ranges

Appendix B (etc.) [For other supporting documentation as needed.]

Appendix E - Page E-15

U.S. Environmental EPA-902-B-01-001 Protection Agency Revised June 2005 Region 2

FIRST-CLASS MAIL United States Environmental Protection Agency U. S. POSTAGE 290 Broadway PAID New York, NY 10007-1866 MAILED FROM ZIP CODE 10007 PERMIT NO. G-35 Official Business Penalty for Private Use $300 Forwarding and Address Correction Requested