United States
Environmental Protection
Agency
EPA-902-B-01-001
Revised June 2005
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
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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 scien-
tists, 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 docu-
ment 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 re-
maining 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
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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 develop-
ment 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
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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
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BMP for Lead at Outdoor Shooting Ranges
EPA Statement on National Guidance
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OCT 10
OFFICE OF
SOLID WASTE AND EMERGENCY
RESPONSE
MEMORANDUM
SUBJECT: National Guidance on Best Management Practices for Lead at Outdoor Shooting
FROM:
Office ofLSblid Waste
TO: RCRA Senior Policy Advisors
The purpose of this memo is to transmit a Region 2 document entitled "Best Management
Practices for Lead at Outdoor Shooting Ranges," EPA-902-B-01-001, January 2001. This report
is a technical information manual to assist range owners and operators in managing lead at
shooting ranges. The report covers the environmental concerns, applicable laws and regulations,
and current best management practices. This document was developed collaboratively with a
number of stakeholders and is considered by my office to be the national guidance on this
subject.
Background
Lead at some shooting ranges can be a significant environmental concern depending on location
(e.g., proximity to wetlands) and hydrogeologic setting, as evidenced by a number of cases where
lead pellets and shot have been taken in by fish and fowl at ranges over wetlands, and at some
ranges where streams in acid lead-leaching environments have picked up lead contamination.
Recognizing these problems, Region 2 in collaboration with EPA HQ, States, shooting range
associations, and other shooting range experts, developed the enclosed technical guidance to
identify the problems and solutions for preventing and controlling these problems. We commend
this guidance to you as an information source for your use in working with range owners and
operators to identify and address these concerns at specific ranges. Copies of this manual have
been sent to all 50 States, with the help of ASTSWMO, and at least 40 States have responded
with concurrence and support for this guidance.
Also enclosed for your information is a list of references "Summary of Shooting Range Lead
Management Guidance" prepared by various shooting range-interested associations, and a copy
of an NPDES permit for the Naperville, IL Sportsman's Park shooting range.
Internet Address (URL) • http://www.epa.gov
Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 25% Postconsumer)
EPA Statement on National Guidance
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BMP for Lead at Outdoor Shooting Ranges
If you have any questions regarding lead at shooting ranges, please contact George Meyer (Chief,
RCRA Compliance Branch, Region 2) at 212-637-4144, Meyer.George@epa.gov. or Ken
Shuster in the Office of Solid Waste at 703-308-8759, shuster.kenneth@,epa.gov.
It is my hope that wide distribution of these documents will help encourage greater cooperation
and coordination on shooting range issues among RCRA, Superfund, and Water staff in the
regions and states. To this end, it would be helpful if you would send the name of a point of
contact in your region to Ken Shuster and George Meyer.
For additional copies of the Region 2 guidance, please contact George Meyer. It is also available
atwww.epa.gov/region2/waste/leadshot.
Enclosures
cc: George Meyer, Region 2
Elaine Davies, OERR
Michael Cook, OW
Eric Schaeffer, ORE, OECA
Craig Hooks, FFEO, OECA
Bob Byrne, Wildlife Management Institute
Barbara Simcoe, ASTSWMO
Regional Superfund Division Directors w/o Region 2 enclosure
Regional Water Division Directors w/o Region 2 enclosure
Regional RCRA Enforcement Section Chiefs w/o Region 2 enclosure
EPA Statement on National Guidance
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BMP for Lead at Outdoor Shooting Ranges
Best Management Practices for Lead at
Outdoor Shooting Ranges
Table of Contents
List of Figures.
List of Tables..
Introduction....
Chapter I - Environmental and Regulatory Concerns at the Shooting Range 1-1
1.0 Background 1-1
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 1-12
Chapter II - Range Characteristics & Activities to Consider When
Implementing BMPs 11-1
2.0 Background 11-1
2.1 Physical Characteristics 11-1
2.2 Operational Aspects II-4
2.3 Planning a New Range II-4
Chapter III - BMPs for Outdoor Ranges 111-1
3.0 Background II1-1
3.1 Bullet and Shot Containment Techniques (Step 1) 111-1
3.2 BMPs to Prevent Lead Migration (Step 2) III-5
3.3 Lead Removal and Recycling (Step 3) 111-11
3.4 Documenting Activities and Record Keeping (Step 4) 111-17
3.5 Additional Economic Considerations 111-18
3.6 Summary of Key BMPs for Shooting Ranges 111-18
3.7 Certificate of Recognition 111-18
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
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BMP for Lead at Outdoor Shooting Ranges
List of Figures
Figure Number
1-1 Effects on the Human Body from Excessive Exposure to Lead I-5
2-1 pH Scale 11-1
3-1 Four Steps to Build a Successful Lead Management Program MI-1
Utilizing a Variety of BMPs
3-2 Sample Filter Bed System 111-10
3-3 Examples of Common Lead Reclamation Equipment IM-11
List of Tables
Table Number Page
1-1 Application of Key Terms to Outdoor Ranges 1-10
2-1 Common Physical Characteristics at Ranges - Potential Risks ||-3
and Benefits Associated with Range Operations
3-1 Summary of Key BMPs 111-19
3-2 Calculating Weight of Lime to Increase Soil pH Values III-6
Lists of Figures and Tables - ii
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BMP for Lead at Outdoor Shooting Ranges
Introduction
This manual provides owners and operators of
outdoor rifle, pistol, trap, skeet and sporting clay
ranges with information on lead management at
their ranges. This manual serves as a reference
guide and presents best management practices
(BMPs) available to the shooting range
community. The practices have been proven to
effectively reduce or eliminate lead
contamination and may also be economically
beneficial to the range owner/operator. Since
each range is unique in both the type of shooting
activity and its environmental setting, specific
solutions are not provided in this manual.
Rather, a range owner or operator may use this
manual to identify and select the most
appropriate BMP(s) for their facility. Other
information on environmental aspects of
management at outdoor shooting ranges can be
found in the National Shooting Sports
Foundation's Environmental Aspects of
Construction and Management of Outdoor
Shooting Ranges.
The manual does not address range layout or
design to meet range safety or competition
requirements. For information on range safety
and competition requirements, range owners/
operators are directed to other comprehensive
reference materials available on that subject,
such as the National Rifle Association's Range
Source Book, and the National Association of
Shooting Range's website (www.rangeinfo.org).
Owners/operators of ranges may want to
assign the use of this BMP Manual to a
specific team or committee. Delegating this
responsibility to a specific team or group
helps to assure that the BMP's are identified
and implemented.
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
and the importance of an integrated BMP
program to manage lead.
• Chapter II discusses physical and
operational characteristics to be considered
when selecting a successful BMP program.
• Chapter III addresses best management
techniques for rifle/pistol ranges, skeet and
trap ranges, and sporting clay ranges. In this
chapter, the manual explores possible
solutions to prevent, reduce and/or remove
lead contamination for each type of range.
• The Appendices provide current (as of June
2005) contacts for lead reclamation and
recycling companies, vendors that provide
prevention and/or remediation techniques and
shooting organizations that have additional
information on the lead issue. Additionally,
the Appendices provide information on
alternatives to lead, diagrams of bullet trap
designs, summaries of regulatory
requirements and interpretations, and a
sample Environmental Stewardship Plan.
EPA is very interested in any suggestions you
have about practices included in this manual
which have proven effective in controlling lead
contamination or recycling lead bullets/shot.
Please send such information to the address
below. Also, for additional information, or to be
added to the list of lead reclaimers or
remediation contractors, contact the National
Rifle Association (NRA), the National Shooting
Sports Foundation (NSSF) or:
Lead Shot Coordinator
RCRA Compliance Branch
U.S. Environmental Protection Agency
Region 2
290 Broadway
New York, New York 10007-1866
Telephone: (212)637-4145
E-Mail: Leadshot.Region2@epa.gov
Introduction - iii
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BMP for Lead at Outdoor Shooting Ranges
Chapter I:
Environmental and Regulatory
Concerns at the Shooting Range
1.0 Background I
Outdoor shooting ranges provide recreational
facilities for millions of shooting sports
enthusiasts in the United States. Recently, there
has been a growing public concern about the
potential negative environmental and health
effects of range operations. In particular, the
public is concerned about potential risks
associated with the historical and continued use
of lead shot and bullets at outdoor ranges.
This concern is not unfounded. An estimated
9,000 non-military outdoor ranges exist in the
United States, collectively shooting millions of
pounds of lead annually. Some ranges have
operated for as long as several generations.
Historical operations at ranges involved leaving
expended lead bullets and shot uncollected on
ranges. Many of these ranges continue to
operate in the same manner as in the past.
It is estimated that approximately four percent
(4%) (80,000 tons/year) of all the lead produced
in the United States in the late 1990's (about 2
million tons/year), is made into bullets and shot.
Taking into account rounds used off-range, and
rounds used at indoor ranges, it is clear that
much of this 160,000,000 pounds of lead shot/
bullets finds its way into the environment at
ranges.
Since the mid-1980's, citizen groups have
brought several lawsuits against range owners
and have urged federal and state agencies to
take action against owners and operators of
outdoor shooting ranges. The citizen groups
argued that range owners improperly managed
discharged lead bullets and shot. Federal courts
have supported parts of these suits, requiring
range owners/operators to clean up lead-
contaminated areas. Concurrent with the
increased citizen suit activity, the federal EPA,
the Centers for Disease Control and Prevention
(CDCP), and a large number of states have
identified human exposure to all forms of lead as
a major health concern in the United States.
Lead management practices at ranges across
the United States remain inconsistent. Some
range owners/operators have examined the
impact of range operations on human health and
the environment and have implemented
procedures to manage and/or remove
accumulated lead from ranges. Other range
owners/operators are just beginning to
characterize and investigate their ranges in
order to design an environmental risk prevention
and/or remediation program(s) specific to their
sites. A third group of ranges has adopted a
"wait and see" policy - taking no action until
specifically required to do so by law or clear
guidance is in place. Finally, a fourth, small, but
important group of range owners/operators
remain unaware of lead's potential to harm
human health and the environment, and of
existing federal and state laws.
To manage lead, many owners and operators
have successfully implemented Best
Management Practices (BMPs) at their ranges.
These range owners and operators have
realized many benefits from sound lead
management including:
- stewardship of the environment, natural
resources and wildlife,
- improved community relations,
- improved aesthetics of the range/good
business practices,
- increased profitability through recovery/
recycling lead, a valuable and finite resource,
and
- reduced public scrutiny.
Shooting sports organizations [e.g., National
Rifle Association (NRA) and the National
Shooting Sports Foundation (NSSF)] promote
lead management throughout the United States.
These organizations have researched different
methods to effectively address potential and
actual lead mobility and exposure without
detracting from the enjoyment of the sport. The
NRA, NSSF, and a number of other shooting
sports organizations strongly encourage range
Chapter I - Page 1-1
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BMP for Lead at Outdoor Shooting Ranges
owners/operators to develop a BMP program
that contains elements discussed later in this
manual. Contact the NRA and NSSF for
additional guidance materials available on lead
management practices.
By implementing appropriate lead management
at outdoor shooting ranges, range owners and
operators can reduce the environmental and
health risks associated with lead deposition,
meet legal requirements and realize quantifiable
benefits.
1.1
Lead Contamination's Impact |
on Human Health and the
Exposure Routes
Historically, the three major sources for human
exposure to lead are lead-based paint, lead in
dust and soil and lead in drinking water.
Typically, human exposure occurs through
ingestion, which is the consumption of lead or
lead-contaminated materials, or by inhalation.
The main human exposure to lead associated
with shooting ranges is through lead-
contaminated soil. However, other pathways are
discussed below, along with lead's detrimental
effects on humans and animals.
Lead can be introduced into the environment at
shooting ranges in one or more of the following
ways. Each of these pathways is site-specific
and may or may not occur at each individual
range:
• Lead oxidizes when exposed to air and
dissolves when exposed to acidic water or
soil.
• Lead bullets, bullet particles, or dissolved
lead can be moved by storm water runoff.
• Dissolved lead can migrate through soils to
groundwater.
Lead oxidizes when exposed to air and
dissolves when exposed to acidic water or soil
When lead is exposed to acidic water and/or
soil, it breaks down by weathering into lead
oxides, carbonates, and other soluble
compounds. With each rainfall, these
compounds may be dissolved, and the lead may
move in solution in the storm runoff waters.
Decreases in water acidity (i.e., increases in its
pH) will cause dissolved lead to precipitate out of
solution. Lead concentrations in solution are
reduced by this precipitation. At pHs above 7.5,
very little lead remains in solution. Increased
time of contact between lead and acidic water
generally results in an increase in the amount of
dissolved lead in the storm runoff water. The five
factors which most influence the dissolving of
lead in water are summarized below:
Annual Precipitation Rate - The higher the
annual precipitation rate, the faster the lead
weathers. Also, during prolonged rains, the
contact time between water and lead is
increased. In general, the higher the
precipitation rate, the higher the potential risk of
lead migration off-site in solution.
pH of Rain and Surface Water - The acidity of
the rainwater decreases as basic (alkaline)
minerals in the soil are dissolved. If sufficient
minerals such as calcium, magnesium, and iron
are present in local soils, then the lead may
quickly precipitate out of solution entirely as
these other minerals are dissolved. The pH of
shallow surface water is an indicator of the
presence or absence of basic minerals in the
local soil and in gravel within the stream beds
through which the water has moved. The water
in deeper streams and lakes is more likely to be
composed of acidic rainwater that is not
neutralized.
Contact Time - The contact time between
acidic surface water and lead is a factor in the
amount of lead that is dissolved. For example,
lead shot deposited directly into a lake has a
longer contact time then lead shot deposited in
upland areas.
Soil Cover - Organic material will absorb lead
and remove it from a water solution. The thicker
the organic leaf and peat cover on the soil, the
lower the lead content in solution in water leaving
the shot area. Organic material has a strong
Chapter I - Page I-2
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BMP for Lead at Outdoor Shooting Ranges
ability to extract lead out of solution in water.
pH of Groundwater - During periods of no
rainfall, the water flowing within most streams
comes from groundwater discharging into the
stream channel. Therefore, the acidity of the
groundwater affects the acidity of the surface
water, and hence, affects the solubility of any
lead particles carried into the stream during
storm runoff.
Lead bullets, bullet particles or dissolved lead
can be moved by storm water runoff
The ability of water to transport lead is influenced
by two factors: velocity of the water and weight
or size of the lead fragment. Water's capacity to
carry small particles is proportional to the square
of the water's velocity. Clear water moving at a
velocity of 100 feet per minute can carry a lead
particle 10,000 times heavier than water moving
at a velocity of 10 feet per minute. Muddy water
can carry even larger particles. The five factors
that most influence velocity of runoff are
described below:
Rainfall Intensity - The greater the volume of
rainfall during a short period of time, the faster
the velocity created to carry the rainfall off-site.
The higher the annual rainfall, the greater the
number of periods of heavy rainfall.
Topographic Slope - Generally, the steeper the
topographic slope, the faster the velocity of
stormwater runoff.
Soil Type - More rainfall will soak into sandy
soils then into clay soils. Hence, for a given
rainfall intensity, the volume of runoff will be
greater from areas underlain by clays or other
low permeable soils than from permeable sandy
soil.
Velocity - Velocity tends to decrease as stream
width increases. Merging streams, eddy
currents, and curves in streams are other factors
that may reduce the velocity. Generally, the
shorter the distance from the lead deposit to the
property line, the more likely it is that the lead
fragments in suspension will be transported off-
site.
Vegetative Cover and Man-made Structures -
Structures such as dams and dikes reduce the
water's velocity and greatly reduce the size and
weight of the lead particles the water can carry.
Since lead particles are heavy compared to the
other suspended particles of similar size, they
are more likely to be deposited under the
influence of anything that reduces velocity of the
storm runoff. Grass and other vegetation
reduce runoff velocity and act as a filter to
remove suspended solids from the water.
Dissolved lead can migrate through soils to
groundwater
Acidic rainwater may dissolve weathered lead
compounds. A portion of the lead may be
transported in solution in groundwater beneath
land surfaces. Groundwater may transport lead
in solution from the higher topographic areas to
the lower areas such as valleys, where it is
discharged and becomes part of the surface
water flow. If the water flowing underground
passes through rocks containing calcium,
magnesium, iron, or other minerals more soluble
then lead, or through minerals that raise the pH
of the water, then the lead in solution may be
replaced (removed) from the solution by these
other metals. However, if the soil is a clean
silica sand and gravel, fractured granite, or
similar type material, then the lead may move
long distances in solution. The factors most
likely to affect the amount of lead carried by the
groundwater in solution are discussed below:
Annual Precipitation - Generally, high
precipitation rates result in heavy dew, more
frequent rainfall, numerous streams, shallow
depth to groundwater, shorter distance of travel,
and more rapid rates of groundwater flow. Also,
the greater volumes of rainfall over geologic time
probably have reduced the amount of calcium
and other soluble basic minerals that could raise
the water pH and cause lead to precipitate
(settle) out of solution from the groundwater.
Soil Types - Clays have a high ionic lead
bonding capacity and more surface area to
which the lead can bond. Also, groundwater
movement in clay is very slow, which increases
the contact time for lead to bond to the clay.
Chapter I - Page I-3
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BMP for Lead at Outdoor Shooting Ranges
Low permeability reduces the amount of
historical leaching and increases the probability
of the presence of basic (pH-increasing)
minerals that can precipitate out of solution in
groundwater or cause the lead to bond to the
clay. All of the basic calcium and related
minerals generally will have been removed from
the clean silica sand and gravel soils, so the
lead in solution in groundwater in these type
soils can move long distances (miles) through
the ground relatively unchanged.
Soil Chemistry - The more basic minerals like
calcium and magnesium that are present in soils
along the pathways through which the
groundwater moves, the greater the lead
precipitation (removal) rate. Lead should move
in solution only a short distance (a few feet)
through a sand composed of calcium shell
fragments, but could move in solution long
distances (miles) through clean quartz sand.
Depth to Groundwater - In areas of
groundwater discharge such as river flood plains
and most flat areas, the groundwater surface is
often a few feet below the surface. Remember,
the shorter the distance traveled, the greater the
risk that the lead will migrate into the
environment. Shallow depth to groundwater is
indicative of higher risk for lead to reach the
water.
pH of Groundwater - Although other factors
influence solubility of lead in water, a good rule of
thumb is that lead will precipitate out of solution
when the pH or alkalinity of water is greater then
about 7.5. But, lead dissolved in acid
groundwater may travel many miles without
change.
Health Effects of Lead Exposure on Ranges
Lead poisoning is a serious health risk. At
higher concentrations, it is dangerous to people
of all ages, leading to convulsions, coma and
even death. At even very low concentrations, it
is dangerous to infants and young children,
damaging the developing brain and resulting in
both learning and behavioral problems. Figure 1-
1 describes the effects of exposure to lead on
children and adults.
Federal, state and local actions, including bans
on lead in gasoline, paint, solder and many other
lead-containing products, have resulted in
significant reductions in average blood-lead
levels. Despite these advances, the number of
lead-poisoned children remains alarmingly high.
Children living in older homes may be exposed
to lead in peeling paint or paint dust. Children
can also come in contact with lead in soil and
with lead dust carried home on the clothing of
parents.
On ranges, inhalation is one pathway for lead
exposure since shooters are exposed to lead
dust during the firing of their guns. Because
wind is unlikely to move heavy lead particles
very far, airborne dust is generally considered a
potential threat only when there are significant
structures that block air flow on the firing line.
Under such conditions, the hygiene and other
practices proposed by the NRA for indoor
shooting ranges in their "Source Book" are
applicable to outdoor ranges.
Range workers may also be exposed to lead
dust while performing routine maintenance
operations, such as raking or cleaning out bullet
traps. Owners/operators may want to protect
these workers by requiring them to wear the
proper protective equipment or dampening the
soil prior to work.
Another exposure route for lead at outdoor
ranges is ingestion by direct contact with lead or
lead particles. For example, lead particles
generated by the discharge of a firearm can
collect on the hands of a shooter. These
particles can be ingested if a shooter eats or
smokes prior to washing his/her hands after
shooting. The relative risk of lead exposure to
people in a well managed facility is low.
Detrimental effects due to elevated lead levels
can also be found in animals. Excessive
exposure to lead, primarily from ingestion, can
cause increased mortality rates in cattle, sheep
and waterfowl. For example, waterfowl and
other birds can ingest the shot, mistaking it for
food or grit. Waterfowl, in particular, are highly
susceptible to lead ingestion. This is a concern
at ranges where shooting occurs into or over
Chapter I - Page I-4
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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 sufferfrom:
difficulties during pregnancy,
reproductive problems in both men and women (such as low birth
weight, birth defects and decreased fertility),
high blood pressure,
digestive problems,
neurological disorders,
memory and concentration problems, Brain or Nerve Damage
muscle and joint pain, and
kidney dysfunction.
Slowed Growth
Hearing Problems
Lead affects the
body in many ways
Digestive Problems
Reproductive Problems
(Adults)
Figure 1-1: Effects on the Human Body from Excessive Exposure to Lead
Chapter I - Page I-5
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BMP for Lead at Outdoor Shooting Ranges
water. Many of the legal and government actions
that have been brought against ranges are
based on elevated levels of lead and increased
mortality in waterfowl. For example, in one case,
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
waterfowl die-off (increase in bird mortality),
apparently from lead ingestion.
1.2 Legal Requirements & Court
Rulings
To date, most litigation concerns have been at
shotgun ranges where the shotfall zone impacts
water or wetland areas. The potential
environmental and human health risks are
greater at these ranges. However, all ranges,
including those not located near water bodies,
may be subject to legal and government action if
proper range management programs are not
implemented. Range owners/operators should
expect greater scrutiny as ranges become more
visible to regulators, environmental groups and
the general public.
Citizen groups have been the driving force
behind most legal actions taken against outdoor
ranges. These groups have sued range owners/
operators under federal environmental laws. Two
of EPA's most comprehensive environmental
laws, the Resource Conservation and Recovery
Act (RCRA) and the Clean Water Act (CWA),
specifically provide citizens with the right to sue
in cases in which the environment and human
health are threatened. These citizen suits have
been highly effective in changing the way ranges
operate, even when out-of-court settlements
have been reached. The decisions of the United
States Court of Appeals for the Second Circuit in
Remington Arms and New York Athletic Club set
a legal precedent in the application of RCRA
and/or the CWA to outdoor ranges. Lead
management programs at outdoor ranges must
comply with both laws. Actions have also been
taken under the Comprehensive Environmental
Response, Compensation and Liability Act
(CERCLA) commonly know as Superfund.
State and local statutes and regulations may
also apply. To ensure environmental laws are
being followed, range owners/operators must
understand the legal issues and requirements.
1.2.1 Resource Conservation and
Recovery Act (RCRA)
RCRA provides the framework for the nation's
solid and hazardous waste management
program. Under RCRA, EPA developed a
"cradle-to-grave" system to ensure the
protection of human health and the environment
when generating, transporting, storing, treating
and disposing of hazardous waste. RCRA
potentially applies to many phases of range
operation because lead bullets/shot, if
abandoned, may be a solid and/or a hazardous
waste and may present an actual or potential
imminent and substantial endangerment.
Connecticut Coastal Fishermen's
Association v. Remington Arms Company, et
aL
In the late 1980s, the Connecticut Coastal
Fishermen's Association filed a lawsuit against
Remington Arms Company as the owner of the
Lordship Gun Club. The Lordship Gun Club
(a.k.a. Remington Gun Club) is a 30-acre site in
Stratford, Connecticut, located on the Long
Island Sound at the mouth of the Housatonic
River. In the mid-1960s, the Lordship Gun Club
was reconstructed to its final configuration of 12
combined trap and skeet fields and one
additional trap field. Over the years, the
Lordship Gun Club became known as one of the
premier shooting facilities on the East Coast.
The Connecticut Coastal Fishermen's
Association filed a lawsuit, alleging that lead shot
and clay targets are hazardous waste under
RCRA. The Complaint alleged that because the
lead shot and clay targets were hazardous
wastes, the gun club was a hazardous waste
storage and disposal facility subject to RCRA
requirements. The plaintiff also sought civil
penalties and attorney's fees.
Remington moved fora summary judgment
dismissing the complaint, and the Connecticut
Coastal Fisherman's Association cross-moved
for a partial summary judgment on the issue of
liability. On September 11, 1991, the United
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States District Court for the District of
Connecticut ruled on the case.
Regarding the plaintiffs claims under RCRA, the
District Court ruled in favor of the Connecticut
Coastal Fishermen's Association, holding that
the lead shot and clay targets were "discarded
materials" and were "solid waste;" therefore, the
materials were subject to regulation under
RCRA. The court further stated that the
discharged lead shot was a "hazardous waste,"
but declined to rule on whether the clay target
fragments were also hazardous waste.
Remington petitioned the United States Court of
Appeals for the Second Circuit Court to review
the lower court's ruling.
On June 11, 1992, both parties presented oral
arguments before the court. Subsequent to oral
arguments, the appellate court requested that
EPA file an amicus brief "addressing whether
lead shot and clay target debris deposited on
land and in the water in the normal course of
trap and skeet shooting is 'discarded material'...
so as to constitute 'solid waste' under RCRA."
On March 29, 1993, the United States Court of
Appeals for the Second Circuit reached its
decision. With respect to RCRA, the court both
reversed and affirmed the lower court's opinion
in part.
Briefly, the decision affects currently operating
and future gun clubs, and the following key
points are of primary concern:
1. With respect to RCRA, the court agreed
with EPA's amicus brief, which had argued that
shooting at gun clubs is not subject to regulatory
(as opposed to statutory) requirements. In other
words, during routine operations, gun clubs are
not viewed as facilities that manage hazardous
wastes subject to RCRA regulations and, as
such, do not require RCRA permits.
2. Another argument in the EPA's amicus
brief with which the court agreed was the view
that the RCRA statute allows citizen suits to be
brought if a gun club's shooting activities pose
an "imminent and substantial endangermentto
health or the environment." Although gun clubs
are not subject to RCRA regulations, EPA or any
state, municipality, or citizen group can take
legal action under the statutory provisions of
RCRA against gun clubs for actual or potential
environmental damage occurring during, or even
after, the operation of the club. Under RCRA,
the plaintiff would be eligible to recover its legal
fees as well.
3. The court concluded that lead shot and
clay targets meet the statutory definition of solid
waste because these materials were "discarded
(i.e. abandoned)" and "left to accumulate long
after they have served their intended purpose."
Further, the court concluded that based upon
toxicity testing and evidence of lead
contamination, the lead shot was a hazardous
waste subject to RCRA.
The important point to consider here is that if
lead shot and clay target debris are discarded
(i.e. abandoned), these materials are considered
a solid waste as defined in the statute and the
facility may be subject to governmental or citizen
suits.
If, on the other hand, the discharged lead shot is
recovered or reclaimed on a regular basis, no
statutory solid waste (or hazardous waste)
would be present and imminent hazard suits
would be avoided.
Thus, the Remington Arms case is an important
legal precedent. Even though regulations have
not been issued regarding gun club operations
and environmental protection, gun clubs are still
at risk of legal action under RCRA if they fail to
routinely recover and reclaim lead, do not take
steps to minimize lead release or migration, or if
they abandon lead in berms.
Gun clubs where there is shooting into water,
wetlands, rivers, creeks, and other sensitive
environments have the highest degree of
litigation risk. Conversely, gun clubs that have
the lowest risk of environmental litigation or
government action are those clubs that do not
shoot into water or wetlands and which have an
active program to recover lead.
The following describes how RCRA may apply
to outdoor shooting ranges.
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BMP for Lead at Outdoor Shooting Ranges
How is Lead Shot Regulated Under
RCRA?
Lead shot is not considered a hazardous waste
subject to RCRA at the time it is discharged
from a firearm because it is used for its intended
purpose. As such, shooting lead shot (or
bullets) is not regulated nor is a RCRA permit
required to operate a shooting range. However,
spent lead shot (or bullets), left in the
environment, is subject to the broader definition
of solid waste written by Congress and used in
sections 7002 and 7003 of the RCRA statute.
With reference to reclaiming and recycling lead
shot, the following points should serve as
guidance in understanding RCRA and how it
applies to your range. (A more detailed
discussion of the underlying RCRA rules
applicable to lead shot removal at ranges is
included in Appendix D)
• Removal contractors or reclaimers should
apply standard best management
practices, mentioned in this manual, to
separate the lead from soil. The soil, if
then placed back on the range, is exempt
from RCRA. However, if the soil is to be
removed off-site, then it would require
testing to determine if it is a RCRA
hazardous waste.
• Lead, if recycled or reused, is considered
a scrap metal and is, therefore, excluded
from RCRA.
• Collected lead shot and bullets are excluded
from RCRA regulation, and need not have a
manifest, nor does a range need to obtain a
RCRA generator number (i.e., the range is
not a hazardous waste "generator"), provided
that the lead is recycled or re-used. The
reclaimer does not need to be a RCRA
transporter. However, it is recommended
that ranges retain records of shipments of
lead to the receiving facilities in order to
demonstrate that the lead was recycled.
Records should also be kept whenever
the lead is reused (as in reloading.) The
range should be aware that it ultimately
may be responsible for the lead sent for
reclamation. Therefore, only reputable
reclaimers should be utilized.
Lead from ranges destined for recycling may
be temporarily stored on range property after
separation from soil if the lead is stored in
closed, sealed containers, the containers are
stored in a secure location and routinely
inspected by range staff, and records of
inspections are maintained.
Sections 7002 and 7003 of the RCRA statute
allow EPA, states or citizens to use civil
lawsuits, to compel cleanup of or other action
for "solid waste" (e.g., spent lead shot) posing
actual or potential imminent and substantial
endangerment. Such actions can be sought
whether the range is in operation or closed,
and is based solely on a determination that
harm is being posed or may be posed by the
range to public health and/or the environment.
Since the risk of lead migrating increases with
time, making ranges that have not removed
lead more likely candidates for government
action or citizen lawsuits under RCRA Section
7002 and 7003, ranges are advised to
maintain a schedule of regular lead removal.
With time, lead in soil can become less
desirable to reclaimers and smelters, thereby
potentially reducing or eliminating financial
returns from lead removal. Moreover, such
soil may be subject to more expensive
treatment to separate the lead for recycling.
Lead removal will allow the range to: avoid
contamination of the site and potential impacts
to human health and the environment; reduce
liability with regard to potential government
agency or citizen suit action; and, possibly,
benefit economically from the recycling of
lead. Additional guidance on reclaiming lead
is provided in other parts of this manual.
Soil from berms and shotfall zones may be
moved to another area of the range for such
reasons as addressing potential
environmental impacts (e.g., runoff), altering
the layout to address safety concerns or
allowing different types of shooting activities,
or adding or removing shooting positions.
However, removal of lead prior to such
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BMP for Lead at Outdoor Shooting Ranges
movement of soil is normal practice and
highly advised because it extends the usable
life of the materials and reduces the
possibility of release of lead into the
environment. If lead is not first removed, it
will be further dispersed and will be more
difficult to remove in future reclamation.
Written records of all such activity should be
maintained indefinitely, as they will be
necessary in subsequent construction or
range closure.
• This RCRA summary applies to operating
and non-operating ranges, and the use of
BMPs at operating ranges is highly
recommended. However, because of
increased risk if lead is not actively managed,
such application may not preclude the need
for remediation, as appropriate and/or as
required by states' regulations, when a range
is permanently closed, on-site lead is
abandoned, or the land use changes.
Introductory guidance for remediation can be
found at www.epa.gov/epaoswer/osw or
www.epa.gov/superfund. Look under the
sections "Cleanup" or "Resources," or use
the Search function.
1.2.2-Clean Water Act
The goal of the Clean Water Act (CWA) is to
"restore and maintain the chemical, physical,
and biological integrity of the Nation's waters."
The most common allegation against ranges by
the EPA and citizen groups, is that they violate
the CWA if they do not have permits that allow
spent ammunition to be discharged into water.
The CWA prohibits "the discharge of any
pollutant by any person" into the waters of the
United States without a National Pollution
Discharge and Elimination System (NPDES)
permit. There have been two court cases that
have applied the provisions of the CWA to
civilian shooting ranges. To understand how the
CWA can apply to shooting ranges, a summary
of the cases follows. Also see Table 1-1.
To understand the application of the CWA to
outdoor ranges, one must know the definitions of
key terms and how they have been applied to
shooting activities. See Table 1-1.
In the Remington Arms and the New York
Athletic Club lawsuits, citizen groups argued that
the defendants violated the CWA by discharging
pollutants from point sources into the Long
Island Sound without a NPDES permit.
Application of the CWA requires the violations to
be ongoing. Consequently, the court in
Remington Arms dismissed the CWA charge
against the range because it had ceased
operating before the lawsuit was filed.
However, in the New York Athletic Club case,
the club was still in operation during the time of
litigation, but had switched to steel shot. ERA'S
opinion on this case also addressed the CWA
violation. EPA argued that certain trap/skeet
ranges can convey pollutants, via point sources,
to water in violation of the CWA if a NPDES
permit is not obtained. Although some shooting
organizations have disagreed with the EPA
position, the United States District Court for the
Southern District of New York specifically found
that:
• The mechanized target throwers, the
concrete shooting platforms, and the
shooting range itself are considered point
sources as defined by the CWA;
Expended shot and target debris, including
non-toxic shot, such as steel shot, left in
water, are pollutants as defined by the CWA.
Although the New York district court's decision in
the New York Athletic Club case is not
controlling in any other district, range owners
and operators of outdoor ranges that shoot over
or into wetlands or other navigable waters of the
United States should be aware of it.
Based on the court's decision in the New York
Athletic Club case, any range whose shot,
bullets or target debris enter the "waters of the
United States" could be subject to permitting
requirements as well as governmental or citizen
suits. "Waters of the United States" or
"navigable waters of the United States" are
waters of the United States, including territorial
seas that include any body of water that has any
connection to, or impact on, interstate waters or
commerce. The waters may include lakes,
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Table 1 -1: Application of Key Terms to Outdoor Ranges
Key Term
Statutory Definition
Application to New York Athletic Club
Discharge of a
Pollutant
"any addition of any pollutant to
navigable waters from any point
source" (emphasis added)
33 U.S.C. § 1362 (12)
Shooting into water (including wetlands)
constitutes a discharge. In the New York
Athletic Club, the range did not dispute that
its shooting operations resulted in the
deposition of spent shot and other debris
into the waters of the United States.
Point Source
"any discernible, confined, and
discrete conveyance... from which
pollutants are or may be
discharged" into the Nation's
waters.
33 U.S.C. § 1362 (14)
In New York Athletic Club, the court found
that shooting ranges act to systematically
channel pollutants into regulated waters
and that mechanized target throwers
convey pollutants directly into water.
Specifically, it stated, "A trap shooting
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.
Pollutant
"dredged spoil, solid waste,...
munitions... discharged into
water"
33 U.S.C. § 1362 (6)
In New York Athletic Club, shot and target
residue constitute a form of "solid waste"
subject to regulation under the CWA as a
"pollutant." Based on these
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.
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BMP for Lead at Outdoor Shooting Ranges
ponds, rivers, streams, wetlands, or even guts
that are frequently dry, which may not be
obvious to range owners/operators. These
ranges may be required to remediate
contaminated sediments and soils, which could
be both difficult and expensive, and to cease
operations over waters and wetlands. It is
essential that these ranges change the
direction of shooting, to avoid shooting over
or into wetlands or other navigable waters of
the United States, and initiate lead removal
and recycling activities, where feasible.
In addition, these ranges can cause a
substantial impact on wildlife and wetlands,
which range owners/operators may be required
to restore under other federal laws (e.g.,
CERCLA, discussed below). Lead shot
entering a water body substantially increases
the potential risk of contaminating surface and
groundwater which, in turn, threatens human
health and the environment. Finally, as New
York Athletic Club, Remington Arms and similar
cases show, neighbors have the most leverage
when range activity affects wetlands and
waterways.
For ranges located away from coastal areas or
whose operating areas are situated wholly over
land, compliance with the CWA can be achieved
by obtaining a NPDES permit for piped or
channeled runoff from the range into water.
Shooting ranges impacting wetland areas may
be subject to other regulations found in Section
404 of the CWA. This section is the principal
federal regulatory program protecting the
Nation's remaining wetland resources. Any plan
by range owners/operators to dredge and/or fill
wetlands may require a permit and will come
under close scrutiny by federal, state and local
governments and citizen groups. Owners and
operators must comply with the CWA for range
design, redesign, construction, reclamation or
remediation occurring in wetland areas.
1 The term "land" in this instance refers specifically to terrain
recognized as "non-wetland" areas.
1.2.3 Comprehensive Environmental
Response, Compensation, and
Liability Act (CERCLA)
The Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA),
imposes liability on past and present owners or
operators of properties where a release of a
hazardous substance into the environment
exists. CERCLA is used to ensure that an
owner/operator cleans a contaminated site or to
seek reimbursement from past owners/operators
or disposers (potentially responsible parties or
PRPs) when a party, either the government or
private party, has cleaned up the contamination.
Under CERCLA, lead is considered a hazardous
substance.
EPA has the authority to order a PRP to clean up
a site or conduct the cleanup and recover its
costs from the PRP under CERCLA.
Responsible parties may be held liable for all
cleanup costs, which can be substantial. Under
CERCLA, shooting ranges may be liable for
government costs incurred during the cleanup
of ranges, natural resources damages, and
health assessments and/or health effects
studies. The following two examples illustrate
how shooting ranges (including one operated by
the federal government) can be affected by
CERCLA.
Southern Lakes Trap and Skeet Club Site.
Lake Geneva. Wisconsin, et al.
In 1992, the US Fish and Wildlife Service
(USFWS) began an investigation to determine
the cause of death of over 200 Canada geese.
The geese died as a result of acute lead
poisoning after ingesting lead shot, which
research indicated came from the Southern
Lakes Trap and Skeet Club. The USFWS, in its
role as Natural Resource Trustee, took action to
recover the cost of damage to the natural
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
liability to the current and former owners and
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BMP for Lead at Outdoor Shooting Ranges
operators of the club site, the club closed
permanently.
In 1994, EPA issued an Administrative Order on
Consent (AOC) against one current and one
former owner of the property where the now
closed Southern Lakes Trap and Skeet Club was
located. The AOC required the owners to
perform a site assessment, which included an
evaluation of the costs to restore the wetlands.
In 1998, EPA completed activities to clean up the
site and restore some of the natural resources
and wetlands. In a negotiated settlement, EPA
recovered $1 million of the cost of the cleanup.
Walter L. Kamb v. United States Coast Guard.
etal.
In another CERCLA action, Mr. Kamb (court
appointed property guardian) sued the U.S.
Coast Guard, California Highway Patrol, City of
Fort Bragg, and the County of Mendocino (the
defendants) for recovery of cleanup costs under
CERCLA. Mr. Kamb had been appointed by the
Mendocino County Superior Court to sell the
property on behalf of the property owners. The
property was formerly used by defendants as a
rifle, pistol and trap range. Soil analysis
indicated the presence of lead in the form of
leadshot, bullets, pellets, and dust. The court
found the defendants were "responsible parties"
(liable for cleanup costs) under CERCLA. No
apportionment of liability was made and the final
determination of each parties' pro rata share of
the response cost was deferred.
This case shows that range activity need not
affect a water body to trigger CERCLA liability.
CERCLA is a powerful statutory authority that
can greatly impact current and former range
owners/operators. The statute allows for
recovery of damages to natural resources, the
cost of any health assessment studies and all
cleanup costs. Liability may extend to past
owners and operators long after a range ceases
operation.
1.2.4 Additional Laws and Regulations
Shooting ranges may also be subject to state
and local laws and regulations. Many states
have adopted their own environmental laws,
which are based on federal laws. Specifically,
these states have laws and regulations that
mirror the CWA and RCRA program laws. EPA-
approved state program laws must be as
stringent as the federal laws and may be more
stringent. Activities at shooting ranges may also
be subject to local laws, ordinances and
regulations addressing issues such as noise,
zoning, traffic, wetlands and nuisance. Often,
citizens or neighbors of outdoor shooting ranges
can initiate noise nuisance claims against
range owners/operators. Because many states
have passed legislation protecting ranges from
noise nuisance lawsuits, these may turn into
claims of environmental violations under the
laws discussed above due to the presence of
lead and other products at ranges.
1.3 Benefits of Minimizing
Lead's Environmental Impact
All ranges will benefit from proactively
implementing successful BMPs. Even if range
activities currently do not cause adverse public
health and environmental impacts, by developing
and promoting active lead management
programs, ranges will benefit in the following
ways:
• Through a sound lead management
program, shooting sports enthusiasts can
reduce the potential of lead exposure and
contamination to humans, animals and the
environment.
• A lead management program will result in
improved public relations for the range
and the shooting sports. Ranges can
promote and publicize their successful BMP
programs to improve their public image.
Since many of the legal and governmental
actions begin with or are due to citizen
groups, an active lead management program
may improve the public image of the range
with these citizen groups.
• The removal of spent lead from the range
presents a clean, well maintained facility,
which will increase customer satisfaction.
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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.
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BMP for Lead at Outdoor Shooting Ranges
Chapter II:
Range Characteristics &
Activities to Consider When
Implementing Best Management
Practices (BMP)
2.1
Physical Characteristics I
2.0 Background I
Since each firing range site is unique, BMPs
for lead must be selected to meet site-
specific conditions in order to achieve
maximum success. A range's physical
characteristics and the operational aspects (e.g.,
volume of shooting, shooting patterns and
operating schedules) will effect which BMPs
may apply and how they will be implemented.
Accordingly, whether designing a new outdoor
range or operating an existing range, it is
important that BMPs incorporate techniques
appropriate for the range's individual
characteristics.
Section 2.1 of this chapter identifies the physical
characteristics that must be considered when
evaluating your range. A summary of common
physical characteristics at ranges is also
presented in Table 2-1. These factors include:
• Range Size (primarily for shotgun ranges)
• Soil Characteristics
• Topography/Runoff Direction
• Annual Precipitation
• Ground and Surface Water
• Vegetation
• Accessibility
Section 2.2 discusses the operational aspects
that must be considered. These factors include:
• Lead Volume
• Size of Shot/Bullets
• Operating Schedule
• Shooting Direction and Pattern
• Range Life Expectancy
In addition, Section 2.3 discusses issues that
are specific to implementing BMPs when
planning a new range.
Physical characteristics of ranges, relative to
lead management issues, are discussed below.
Range Size
Shotgun range design and type affects the ease
of lead shot collection. Larger ranges typically
tend to have lead shot that is dispersed over a
wider area, while smaller ranges tend to
concentrate lead shot in a smaller area.
Reducing the area of the shotfall zone will
concentrate the shot within a smaller area,
allowing for easier cleanup and reclamation.
BMP techniques for reducing the shotfall zone at
trap and skeet ranges, as well as sporting clay
ranges, are discussed in Chapter III.
Soil Characteristics
Spent lead bullets and shot are most often
deposited directly on and into soil during
shooting. When lead is exposed to air and water,
it may oxidize and form one of several
compounds. The specific compounds created,
and their rate of migration, are greatly influenced
by soil characteristics, such as pH and soil
types. Knowing the soil characteristics of an
existing range site is a key component to
developing an effective lead management
plan.
Soil pH
1 23456789 1011 12 13 14
4
ejiti
Acidic Nevtral
IL I"
Alkaline
1= Ideal Soil Range
Figure 2-1 - pH scale
Soil acidity is measured as pH on a scale
(illustrated as Figure 2-1) between 1 (most
acidic) and 14 (most alkaline, or basic), where 7
is termed neutral. Ideal soil pH for shooting
ranges is 6.5 to 8.5.1
1 National Shooting Sports Foundation, "Environmental Aspects
of Construction and Management of Outdoor Shooting Ranges,"
June 1997.
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BMP for Lead at Outdoor Shooting Ranges
Lead reacts more readily and may become more
mobile under acidic (pH < 6) or higher alkaline
(pH>8) conditions. This means that spent lead
shot left in or on such soils may eventually break
down and contaminate underlying soil. In
moderately alkaline soils (pH 7 - 8.5), the lead
precipitates out of solution and binds to the soil.
This "binding" effect prevents the lead from
migrating to the subsurface. In general, soils in
the eastern part of the United States tend to be
acidic, whereas western soils tend to be more
alkaline.
Soil Physical Characteristics
The migration rate of specific lead compounds is
affected by the physical characteristics of soil.
For example, dense soils, consisting of heavy
clays, will prevent the lead compound from
moving quickly through the subsurface. Any
"free" lead ions become attached to clay
particles, with this bond helping to prevent
migration. However, with denser soils, the
amount of surface runoff increases.
Although clay soils inhibit migration, lead
reclamation by contemporary removal
machinery tends to be more difficult in clayey
conditions. Clayey soils tend to clog the
screens and "bind" with shot and bullets. This
situation may require additional traditional
screening, or perhaps screening using water to
enhance separation.
In contrast, sandy soils or gravel may not
impede migration because the open pores of
these soils allow lead compounds to percolate
quickly. Fortunately, lead reclamation activities
are more easily conducted in sandy soils. With
this in mind, ranges located in sandy soils
should remove lead more frequently.
Annual Precipitation
One of the most important factors that influences
lead degradation (i.e., chemical reactions) and
migration is precipitation. Water, most often in
the form of rain, provides the means by which
lead is transported. In general, ranges located in
areas with high annual/seasonal rainfall2 have a
higher risk of lead migration than those located in
arid regions. This is especially true of outdoor
ranges using "Steel Bullet Traps."
Steel bullet traps build up a layer of lead residue;
these particles are extremely small and more
easily transported by rain/water. Also, the
smaller the particle, the quicker it will degrade. A
bullet trap needs to have a means to collect
contact water, or be covered to prevent water
from reaching it, and to minimize releases and
degradation.
Topography/Runoff Directions
The topography of your range impacts both the
ease of lead reclamation and the mobility of the
lead. For example, lead reclamation is more
successful at ranges where the shotfall zone is
relatively flat, since many lead reclamation
companies use heavy machinery that cannot
operate on slopes or steep hills.
Another important characteristic is the direction
in which your range topography slopes. During
and after periods of rain, stormwater runoff may
wash lead particles or lead compounds off the
range. If there are surface water bodies such as
lakes, rivers, or wetlands downgradient, the
potential for lead to adversely affect the
surrounding environment is even greater.
Therefore, it is important to identify and control
the direction of surface water runoff at your
range. BMPs for modifying and controlling runoff
are described in detail in Chapter III.
Groundwater
Groundwater depth should be considered
when developing a lead management plan
since the closer the groundwater is to the
surface, the greater the potential for
dissolved lead to reach it.
Vegetation
Vegetative ground covers can impact the
mobility of lead and lead compounds.
Vegetation absorbs rainwater, thereby reducing
2 Heavy annual rainfall is anything in excess of the average annual
rainfall, which forthe northeast United States (e.g. New York, New
Jersey) is between 40and 45 inches.
Chapter II- Page 11-2
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BMP for Lead at Outdoor Shooting Ranges
Table 2-1 - Common Physical Characteristics at Ranges - Potential Risks
and Benefits Associated with Range Operations
Physical
Characteristics
Potential Risk to Environment
Potential Benefits in Preventing/Managing
Contamination
Clay, acidic soils
Acidic soils contribute to lead dissolution
- increasing the potential for lead
contamination
- may increase run-off
Difficult to reclaim lead via sifting/raking
May impede percolation of water through
contaminated soil
Binds "free" lead ions
May benefit growth of vegetative covers
Sandy, alkaline
soils
Contaminated rainwater can easily
percolate through soil and groundwater
Extremely alkaline soil will not support
vegetation
Alkaline soils may inhibit lead dissolution
Easier to reclaim lead via sifting/raking
Sandy, acidic soils
Acidic soils contribute to lead dissolution
- increasing the potential for lead
contamination
Contaminated rainwater percolates
quickly through sandy soils
Easier to reclaim lead via sifting/raking
Steep Rolling
Terrain
May promote off-site drainage or
drainage to on-site surface water bodies
Can impede reclamation of expended
shot via raking
None
Flat Terrain
Rainwater may "pond" in areas,
promoting lead dissolution and
contamination
Expended shot easily recovered
Off-site drainage minimized
\Afooded areas
May impede lead reclamation activities
making equipment difficult to maneuver
May provide habitat for wildlife -
increasing exposure to lead
None
On-site or
contiguous surface
water bodies
VERY high potential for contamination
when shot fall zone is located over or
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
None
Vegetation
Lead may be absorbed into grasses,
other wildlife food sources
Ground covers slow down surface water run-
on and run-off
Some vegetation can extract lead ions from
the soils
Chapter 11 - Page II-3
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BMP for Lead at Outdoor Shooting Ranges
the time that the lead is in contact with water.
Vegetation also slows down surface water
runoff, preventing the lead from migrating off-site.
However, excessively wooded areas (such as
those often used for sporting clay ranges) inhibit
lead reclamation by making the soils
inaccessible to some large, lead-removal
machinery. Understanding the type,
concentration and variety of vegetation on your
range is necessary for developing your lead
management program and implementing BMPs
at your range.
Accessibility
Accessibility to shotfall zones and backstops
is extremely important for lead reclamation
activities. A range that is not accessible to
reclamation equipment will have difficulty
implementing lead reclamation practices.
2.2 Operational Aspects I
Operating practices can have a great affect on
the volume and dispersion of lead at your range.
Lead Volume
Keeping records of the number of rounds
fired over time at your range is important.
The number of rounds fired provides a realistic
estimate of the quantity of lead available for
reclamation. This information helps to determine
when reclamation is necessary in order to
prevent accumulation of excess amounts of
lead, thereby decreasing the potential for the
lead to migrate off-site.
Size of Shot/Bullets
Knowledge of the size shot/bullets used on
your range may be helpful. Lead reclamation
companies generally use physical screening
techniques to separate lead shot and bullets
from soil. These screens come in a variety of
sizes. Knowing what size shot/bullets have
been used at your range will allow the reclaimer
to maximize the yield of lead shot/bullets at your
range.
Shooting Direction and Patterns
Shooting directions and patterns are
important to consider when determining the
effectiveness of bullet containment devices.
For example, many bullet traps are effective in
containing bullets fired from specific directions.
It is vital that you utilize bullet containment
devices that match your range's specific
shooting patterns and manufacturers
specifications. Understanding the shooting
direction and patterns will also help to correctly
identify the shotfall zone at trap and skeet
ranges.
Shooting into Water Bodies
Shooting into water bodies or wetlands
should not occur. Besides the environmental
impacts discussed previously, the introduction of
lead to surface water bodies will likely cause a
range to be susceptible to litigation and/or
governmental action. Shooting into water bodies
or wetlands is NOT an option for ranges that
want to survive in the future.
Range Life Expectancy and Closure
The life span of your range may be impacted by
many factors, including financial and
environmental issues, noise, and encroachment
on residential areas. If your range is slated for
closure, contact your local state or EPA
representatives for guidance.
2.3 Planning a New Range I
As discussed in the previous sections, site
characteristics and operational aspects affect
lead migration, degradation and reclamation
activities at ranges. If you are planning on
opening a new range, you should select and/
or design a site in consideration of the
factors discussed in this manual. This will
allow you to minimize the potential of lead
impacting your site or adjacent properties. A
new range owner has the advantage of being
able to design a successful lead management
program in full consideration of the site
characteristics and recommended BMPs. This
advanced understanding of operational aspects
Chapter II- Page 11-4
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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 11 - Page 11-5
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BMP for Lead at Outdoor Shooting Ranges
Chapter III:
Best Management Practices
(BMPs) For Outdoor Ranges
3.0 Background I
To operate an outdoor range that is
environmentally protective requires
implementing an integrated lead management
program, which incorporates a variety of
appropriate BMPs. These BMPs create a four
step approach to lead management:
> Step 1 - Control and contain lead bullets
and bullet fragments
> Step 2 - Prevent migration of lead to the
subsurface and surrounding surface
water bodies
> Step 3 - Remove the lead from the range
and recycle
> Step 4 - Documenting activities and
keeping records
An effective lead management program requires
implementing and evaluating BMPs from each
of the four steps identified above and illustrated
as Figure 3-1. The BMPs discussed in Sections
3.1 and 3.2 should not be considered
alternatives to lead reclamation, but rather
practices that should be followed between lead
reclamation events.
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
more fully below.
3.1 Bullet and Shot Containment
Techniques (Step 1)
3.1.1 Bullet Containment
Knowing where spent lead is allows the
appropriate BMP to be used. The single
most effective BMP for managing lead in
these areas is by bullet containment.
Owners/operators should employ a
containment system that allows for the
maximum containment of lead on-site. The
containment systems mentioned in this section
are for reference only. Each containment design
for a range is site specific. Each owner/operator
must look at the various factors in determining
which containment system is best for his or her
range. Some factors include: overhead, cost of
installation, maintenance (e.g., creation of lead
dust from steel containment systems). Range
owner/operators should consult with various
contractors to determine which containment
system is best for their range.
Step 1 Step 2 Step 3 Step 4
Control and Contain
(Section 3.1)
— Bullet containment
~ Earthen Backstops
~ Sand Traps
~ Steel Traps
~ Lamella or Rubber
Granule Traps
~ Shock Absorbing
Concrete
- Shot Containment
~ Reduce shotfall
zones
^
1 ^V
Prevent Migration
(Section's. 2)
— Monitor and adjust
soil pH (e.g., lime
spreading)
— Immobilize lead e.g.,
phosphate spreading)
- Control runoff
~ Plant vegetation
and utilize organic
ground cover
~ Implement
engineered
runoff controls
^
1 ^V
Remove and Recycle
(Section 3.3)
— Hand raking and
sifting
- Screening
— Vacuuming
- Soil washing
— Working with a
reclaimer
— Recycling
^
1 ^V
Document Activities
and Record Keeping
(Section 3.4)
— Document number of
rounds fired/shot size
- Document BMP(s)
used at ranges to
control migration
- Document date and
provider of services
- Keep records for the
life of the range and
at east 10 years after
closing
- Evaluate the
effectiveness of
BMPs used
Figure 3-1 - 4 Steps to Build a Successful Lead Management Program Utilizing a Variety of BMPs
Chapter III-Page 111-1
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BMP for Lead at Outdoor Shooting Ranges
This section discusses BMPs for controlling
spent lead bullets and fragments in a
"controlled" and well-defined area behind the
target area. Containing bullets and bullet
fragments is critical to successfully managing
lead.
There are a variety of containment device
options available that serve as BMPs to control
lead. The principle behind all of them is trapping
and containing the actual bullet. They include:
> Earthen Berms and Backstops
> Sand Traps
> Steel Traps
> Lamella or Rubber Granule Traps
> Shock Absorbing Concrete
For each type of trap, design variations have
been developed to fit the specific needs of an
individual range. Below are discussions of each
general category of trap. Some bullet
containment devices are so comprehensive that
they virtually eliminate lead's contact with the
environment.
However, it is important to discuss all types of
bullet containment devices because they are
part of comprehensive BMPs for managing lead
at rifle and pistol ranges.
EPA does not endorse any bullet containment
design as being "better" than another. Different
containment designs attempt to eliminate lead's
contact with the environment, however,
additional BMPs may be required for lead
management.
EPA recommends that you discuss your
range's bullet containment needs with a
variety of vendors before deciding what type
of containment device to use. This manual
does identify the possible advantages and
disadvantages associated with each
containment device in Table 3-1, at the back of
this chapter.
Earthen Berms and Backstops
Perhaps the most common bullet containment
system at rifle and pistol ranges is the earthen
backstop (earthen material, i.e., sand, soil, etc.,
which is located directly behind the targets).
The earthen backstop is generally between 15
and 20 feet high with a recommended slope as
steep as possible1. In many instances,
backstops may be naturally occurring hillsides.
When using an earthen berm or backstop,
ensure that the uppermost layer (to a depth of
one to two feet) exposed to the shooting activity
is free of large rocks and other debris. These
materials tend to increase ricochet and bullet
fragmentation, which will, in turn, make lead
reclamation activities more difficult, not to
mention possible safety issues.
Removal of lead from earthen backstops may
require lengthy reclamation (see Section 3.3) of
the soil to remove the lead. Continued use of
the backstop without removing the lead may
result in increased ricochet of bullets and
fragments. In addition, the backstop may lose
its slope integrity because of "impact pockets"
that develop. Once the lead has been removed
from the earthen backstop, the soil can be
placed back on the range and used again.
Adding lime and phosphate during the rebuilding
process is recommended as appropriate (see
Section 3.2). However, other bullet containment
techniques, including those listed below, should
be considered prior to reestablishing an earthen
backstop.
Sand Traps
A variation of the earthen backstop is the sand
trap. Sand traps range from those that are
simply mounds of sand or soil located directly
behind the bullet targets, which serve as
backstops to a sand trap that employs a system
designed to contain, collect and control lead and
contact water. This sand trap uses a grade of
sand that is ballistically acceptable. Regular
maintenance must be performed to remove
larger particles (bullets) from the impact area.
These traps are placed so that bullets fired
across the range pass through the targets and
become embedded in the sand. These traps
are typically 15 to 20 feet high with a slope as
1. National Rifle Association, "The NRA Range Source
Book: A Guide to Planning and Construction," June
1998
Chapter III-Page III-2
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BMP for Lead at Outdoor Shooting Ranges
steep as possible. The most important design
criterion for these traps is that the uppermost
layer (to a depth of 1 to 2 feet) be free of large
rocks and other debris to reduce ricochet and
bullet fragmentation, and to facilitate reclamation
efforts. There may also be an impermeable
layer (e.g., clay or liner) under the sand to
prevent lead from contacting the soil underlaying
the trap.
Sand traps come in various designs and levels
of complexity. The sand trap may be ballistic
grade sand contained in a high backstop, or a
more complex "Pit and Plate" system. The Pit
and Plate system uses an angled, steel
deflection plate cover that helps to direct bullets
and bullet fragments to the top layer of sand
only. Some of the more sophisticated sand
traps incorporate lead recovery devices.
However, the Pit and Plate may increase the
surface-to-mass ratio of the bullet splatter and,
therefore, may increase environmental risk of
lead migration.
Regardless of the type of sand trap that is used,
the traps become saturated with bullets/bullet
fragments. Once this happens, the sand must
be sifted (see Section 3.3) to remove the bullets.
The recovered bullets can then be sold to a lead
recycler (this is discussed in more detail later in
the chapter). After sifting, the sand can be
returned to the trap. Continued use of the trap,
without removing the lead, may result in an
increased risk of ricocheting off the backstop
and thus creating an increased safety hazard.
Furthermore, the sand trap will become unstable
over time. Sand traps may be located over an
impermeable liner, to prevent lead from
contacting soil underlying the trap. This will
provide additional protection to soil and
groundwater.
Steel Traps
Steel traps are located directly behind the
targets so that expended bullets, along with
bullet particles, are directed into some form of
deceleration chamber. Once inside the
chamber, the bullets decelerate until the bullets/
bullet particles fall into collection trays at the
bottom of the deceleration chamber. When the
trap is full, or on a more frequent basis, the spent
lead can easily be reclaimed for recycling.
With some steel traps, expended lead bullets
may not come in direct contact with soils,
thereby possibly minimizing lead's contact with
the environment. Consequently, the need for
other BMPs (e.g., lime spreading, and/or
engineering controls), such as those required at
ranges with unlined earthen backstops or
unlined sand traps, may be avoided if this trap
design is selected for the range's bullet
containment device. In addition, bullet removal
is somewhat easier than from a sand trap, and
may only require emptying the bucket or tray
containing the bullets and/or bullet fragments.
However, an increase of lead dust and
fragmented lead may be an additional
environmental concern. Therefore,
understanding the amount of lead dust and
fragments is important to a successful lead
management program. Also, some steel trap
designs are not intended for shooting at different
angles, therefore limiting the shooter to shooting
straight on (no action shooting).
As with sand traps, steel traps vary in design
and complexity. For example, the Escalator
Trap has an upward sloping deflection plate that
directs bullets into a spiral containment area at
the top. The Vertical Swirl Trap is a modular,
free standing trap with four steel plates that
funnel the bullets into a vertical aperture in
which they spin, decelerate, and become
trapped in a bullet collection container. The Wet
Passive Bullet Trap is equipped with steel
deflection plates that slope both upward and
downward. The upwardly sloped deflection
plate is covered with an oil/water mixture to help
reduce the occurrence of ricochet and bullet
fragmentation. The bullet follows its own path in
the round deceleration chamber for bullet
recycling.
Lamella and Rubber Granule Traps
The Lamella Trap uses tightly-hanging, vertical
strips of rubber with a steel backing to stop
bullets. This trap is located directly behind the
targets and, in many cases, the targets may
actually be mounted to the trap. Lead removal
Chapter III-Page III-3
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BMP for Lead at Outdoor Shooting Ranges
requires mining the bullets from the rubber. The
Rubber Granule Trap uses shredded rubber
granules, housed between a solid rubber front
and a steel backing, to stop bullets once they
pass through the target. For both traps, the
bullets remain intact, thus eliminating lead dust
and preventing lead and jacket back splatter.
Depending on the design of the rubber trap, the
bullet either remains embedded in the rubber
strip or falls to the bottom of the trap, from which
the bullets are removed for recycling.
These traps, when properly installed, are
intended to increase safety by decreasing the
occurrence of back splatter and eliminating the
introduction of the lead dust into the air and
ground. However, there are several concerns
over their use, since they may:
> require additional maintenance;
> in some cases, present a fire threat under
extremely high volume use (due to heat from
friction created upon bullet impact);
> not withstand weather elements over the
long term; and
> cause the rubber particles to melt to the lead
bullets, making reclamation more difficult.
With the availability of fire-resistant rubber and
gels (see Appendix A), these issues are becom-
ing less of a concern than in earlier models.
Shock Absorbing Concrete
In addition to the bullet containment devices
discussed above, there are new designs and
innovations continually being developed. One of
these innovative bullet containment devices is
Shock Absorbing Concrete (SACON). SACON,
which has been used as a bullet containment
device since the 1980s and was extensively
field tested by the military, has become
commercially available in the past several years
as a backstop material for small arms ranges.
For conventional rifle and pistol ranges, SACON
may provide a means to easily reclaim lead.
Additionally, crushed, lead-free SACON can be
recycled (recasted) after bullet fragments have
been removed by adding it to other concrete
mixtures for use as sidewalks, curbs, etc.
3.1.2 Shot Containment
Reducing the Shotfall Zone
Unlike rifle and pistol ranges, the area impacted
by lead shot fired at trap, skeet and sporting
clays ranges is spread out and remains primarily
on the surface. Knowing where spent lead is
allows the appropriate BMP to be used. The
single most effective BMP for managing lead
in these areas is reducing shotfall zones.
Concentrating the lead shot in a smaller area by
modifying the shooting direction facilitates lead
management by providing a smaller and more
dense area of lead to both manage in-place and
reclaim, thereby making the management and
reclamation process simpler and more effective.
Sporting Clays Courses
Technologies have been developed to assist in
reducing the range size of trap and skeet, and
sporting clays facilities. The National Sporting
Clays Association (NSCA) supports and
promotes the Five-Stand Sporting Clays
compact course design for shooting sporting
clay targets, invented by Raymond Forman of
Clay-Sport International, Cochrane, Alberta,
Canada. The targets are directed over a smaller
area than in English Style Sporting Clays
(conventional sporting clays). It was originally
designed to be overlaid on a conventional trap or
skeet field and to be an alternative to earlier
designs, which cover a much larger area.
Another design, known as the National Rifle
Association (NRA) Clays, is a portable target
throwing unit which concentrates 15 rail-
mounted machines on a two-story flatbed trailer.
The NRA has also developed "compact
sporting," which is specifically for sporting clay
facilities. This practice alters the angle that the
target is thrown to concentrate the shotfall zone.
Skeet Fields
The typical single skeet field has a shotfall zone
that is fan-shaped. For skeet fields with multiple
stands side-by-side, the shotfall zones would
overlap creating a shotfall zone that has a
concentration of shot near the center of the fan.
Chapter III-Page III-4
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BMP for Lead at Outdoor Shooting Ranges
Trap Fields
One way to reduce the shotfall zone at trap
fields is to build the fields at an angle to one
another. This will make the shape of the
shooting dispersal pattern smaller and more
concentrated. However, if you do decide to
choose this option, be aware of safety issues
when designing the overlapping shotfall zones.
For a range with only one trap field, one way to
minimize the shotfall zone is to keep trap
machines set in as few holes as possible (e.g.,
the number two or three hole setting). This
reduces the area of lead concentration by
limiting the angles for pigeon throwing, and
therefore the area for lead shot fall. However,
when two or more trap fields are positioned side
by side, the shotfall zone will be continuous
regardless of the "hole" setting.
Shot Curtains
Another method to consider for concentrating
lead shot is the use of a shot curtain. This
device is emerging as a potentially effective tool
to keep lead shot out of selected areas of the
range and, thereby, reduce the size of the
shotfall zone and corresponding cost of
reclamation. Different designs and material have
been utilized in shot curtains and a number are
in operation. The effectiveness of shot curtains
is site specific and their long term viability and
expense have yet to be fully determined.
3.2 BMPs to Prevent Lead
Migration (Step 2)
This section discusses BMPs for preventing lead
migration. These BMPs include:
> Monitoring and adjusting soil pH
> Immobilizing lead
> Controlling runoff
These BMPs are important for all outdoor
ranges.
3.2.1 Monitoring and Adjusting Soil pH and
Binding Lead
Lime Addition
The BMP for monitoring and adjusting soil pH is
an important range program that can effect lead
migration. Of particular concern are soils with
low pH values (i.e., acidic conditions), because
lead mobility increases in acidic conditions since
the acid of the soils contributes to the lead break
down. The ideal soil pH value for shooting
ranges is between 6.5 and 8.5. This BMP is
important because many soils in the eastern
United States have pH values lower than 6.2
To determine the pH of your soil, purchase a pH
meter at a lawn and garden center. The pH
meters are relatively inexpensive but valuable
tools in the management of lead at your range.
If the soil pH is determined to be below 6, the
pH should be raised by spreading lime. It is
recommended that the pH be checked
annually.
One way to control lead migration is by
spreading lime around the earthen backstops,
sand traps, trap and skeet shotfall zones,
sporting clays courses and any other areas
where the bullets/shots or lead fragments/dust
accumulate. For example, lead mobilized in
rainwater from the lead that spatters in front of
backstops after bullet impacts can be effectively
controlled by extending a limestone sand layer
out about 15 feet in front of the backstop.
Likewise, spreading lime over the shotfall zone
will help to raise the pH of the very top soil layer
to a pH closer to ideal levels and reduce the
migration potential of lead. This is an easy, low
cost method. Spreading lime neutralizes the
acidic soils, thus minimizing the potential for the
lead to degrade. Lime can be easily spread by
using a lawn fertilizer drop spreader available at
any lawn and garden center.
Smaller forms of limestone (powdered,
pelletized, and granular) are better suited
2 National Shooting Sports Foundation, "Environ-
mental Aspects of Construction and Management of
Outdoor Shooting Ranges," June 1997
Chapter III-Page III-5
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BMP for Lead at Outdoor Shooting Ranges
because they dissolve and enter the soil more
quickly then larger forms. However, the smaller
forms of lime must be replenished more often.
Conversely, limestone rock dissolves more
slowly but does not need to be replenished as
often. The larger rock form is better suited for
drainage ditches, where it can decrease lead
mobility by raising the pH of the storm water
runoff.
Another way to control lead migration in earthen
backstops is to break the capillarity within the
base of the backstop. Most porosity in the soil
material used in backstop is of capillary size,
and, as a result, water is pulled upward into a
capillary fringe within the base of the backstop.
The height to which the water will rise in an
earthen backstop depends on the soil material in
the backstop. Water will rise more then 6 feet in
clay, 3.3 feet in silt, 1.3 feet in fine sand, 5
inches in coarse sand, and only 2 inches in
gravel.
Because of capillarity, the spent bullets may be
in contact with acidic rainwater for a longer
period of time, hence more lead is dissolved.
Breaking the capillarity by adding a layer of
limestone or gravel to the base of the backstop
should reduce the rate of deterioration of spent
bullets, the erosion of the backstop, and the
amount of lead going into solution in the water in
the backstop. Also, any lead dissolved should
precipitate out of solution as the acids are
neutralized and the pH raised from the water
passing through and reacting with the limestone.
Lime spreading is an especially important
method for implementing this BMP at sporting
clays ranges where heavily wooded areas are
less accessible to conventional lead removal
equipment. These types of ranges also tend to
have more detritus (e.g., leaves, twigs, etc.) on
the ground, which can increase soil acidity as
they decompose. In these areas, semiannual
monitoring of the soil pH levels is
suggested.
Spreading bags of 50 pounds (at ranges with
sandy soils) or 100 pounds (at ranges with
clayey soils) per 1,000 square feet of range will
raise the pH approximately one pH unit for a
period of between one and four years,
respectively. The market price of lime in either
the granular or pelletized form commonly ranges
from approximately $2.00 to $4.00 per fifty pound
bag.
Table 3-2 provides information for raising pH
levels of clay soils in temperate climates (i.e.,
Mid-Atlantic/Northeast). Additional information
on the amount of lime to apply may also be
found on the bags of the purchased lime and/or
from the local lawn and garden center. It should
be noted that if the soil pH is below 4.5, the
addition of lime may only raise the soil pH to
approximately 5. In this situation, other BMPs
should be used as well. If the soil pH is above
the ideal range upper value (8.5), do not add
lime. Adding lime to a soil of this pH could result
in mobilization of the lead. Lime spreading may
be done at anytime during the year, except
when the ground is frozen.
Additionally, it is important to remember to
monitor the soil pH annually, as the
effectiveness of the lime decreases over time.
Additional routine applications will be necessary
throughout the life span of most ranges.
Table 3-2 - Calculating Weight of Lime to Increase Soil pH Values*
Desired
PH
5.0-6.0
6.5-8.5
Current pH
4.0
14
-
4.3
11
-
4.5
8
-
4.8
5
20
5.0
3
17
5.5
-
11
6.0
-
7
6.5
-
-
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
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BMP for Lead at Outdoor Shooting Ranges
Phosphate Addition
In addition to lime spreading, another way to
control lead migration is phosphate spreading.
This method is recommended where lead is
widely dispersed in range soils, a range is
closing, or there is a high potential for vertical
lead transport to groundwater (e.g., low soil pH,
shallow water table). Under these
circumstances, range soils may benefit from
phosphate treatment. Unlike lime spreading, the
main purpose of phosphate spreading is not to
adjust soil pH but to bind the lead particles. This
process also decreases the potential amount of
lead that can migrate off-site or into the
subsurface. Phosphate spreading can be done
either separately or in conjunction with lime
spreading. Generally, 15 to 20 pounds of
phosphate per 1,000 square feet will effectively
control the lead.
Phosphate spreading is especially
recommended for sporting clays ranges and
those parts of ranges not easily accessible by
reclamation equipment. Phosphate spreading
should be repeated frequently during the range's
lifetime. See pilot testing under "Other Ways to
Bind Lead" below for proper frequency for
replacing phosphate.
You can purchase phosphate either in its pure
form, as phosphate rock, or as lawn fertilizer.
The average lawn fertilizer costs approximately
$7.00 per 40 pound bag. If you purchase lawn
fertilizer, remember to check the bag for the
actual percentage of phosphate. Most fertilizers
contain 25% phosphate, so that if you purchase
a 40 pound bag of fertilizer that contains 25%
phosphate (i.e., 10 pounds of phosphate) you
will need to spread 80 pounds of fertilizer per
1,000 square feet of the backstop. A typical
fertilizer drop spreader can be used for
distributing the phosphate. Like lime, phosphate
should not be spread when the ground is frozen.
In addition, it is not advised to use phosphate
near water bodies since it contributes to algal
blooms. Rock phosphate is a better choice if
water is nearby.
Other Ways to Bind Lead
Although it may be possible to minimize lead's
mobility by spreading fertilizers that contain
phosphate at impacted areas of the range, a
more comprehensive procedure for immobilizing
leachable lead in soils, by using pure phosphate
in rock form or a ground phosphate rock [Triple
Super Phosphate (TSP)], was developed and
patented by the U.S. EPA/Ohio State University
Research Foundation and RHEOX, Inc. This
procedure used a three step approach to
minimize lead's mobility. The first step was to
identify the boundaries of the area of the range to
be treated. This included not only determining
the length and width of the range area, but also
the depth of lead within the area.
Depth was determined by taking sample cores
of the area, which also identified "hot spots"
where lead accumulation was greatest. Once
the area was identified, the second step was to
treat the area with TSP. Pure phosphate rock
was used rather then fertilizers, as this
phosphate is insoluble in water and will not
cause an increase in phosphate runoff.
In this step, pilot testing was conducted. Here,
various amounts (in increasing percentages by
weight) of TSP were added to the affected soil
areas, then the area was tested according to an
EPA test method that identified the amount of
leachable lead in a given soil sample. This test
is called the Toxicity Characteristic Leaching
Procedure, orTCLP. Separate TCLP testing of
the range's hot spots was conducted.
Upon completion of the pilot testing, which
determined the amount of TSP needed at the
range, the third step was to begin actual
treatment of the range. Where the depth of the
lead accumulation was shallow (less than two
feet), then standard yard equipment, such as
tillers, seed/fertilizer spreaders, and plows were
used to mix TSP with the affected soil. Where
the affected area's lead accumulation was
deeper than two feet, an auger was required to
mix the TSP with the affected soil. Random
testing of the range ensured the effectiveness of
the treatment level.
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BMP for Lead at Outdoor Shooting Ranges
3.2.2 Controlling Runoff
The BMPs for controlling soil erosion and
surface water runoff are important to preventing
lead from migrating off-site. There are two
factors that influence the amount of lead
transported off-site by surface water runoff: the
amount of lead fragments left on the range and
the velocity of the runoff.
The velocity of the water can successfully be
controlled at outdoor ranges by: (1) using
vegetative, organic, removable and/or
permanent ground covers; and (2) implementing
engineered controls which slow down surface
water runoff and prevent or minimize the
chances of lead migrating off-site. Bear in mind
that safety considerations and potential
ricochets need to be considered when
implementing any engineered controls.
Vegetative Ground Cover
Planting vegetative ground cover (such as
grass) is an important and easy erosion control
method. Vegetation provides several benefits
by minimizing the amount of lead that will run off
the land surface during heavy rainfall. It is
important to use a mixture of grass seeds to
ensure that the cover will last into the future (i.e.,
annual rye grass lasts one year and dies and
perennial rye grass lasts three to four years,
then dies off). Fescue grasses form useful mats
that are effective in controlling erosion.
Ground cover absorbs rainwater, which reduces
the amount of water the lead is in contact with,
as well as the time that the lead is in contact
with the water. Furthermore, the ground cover
will divert and slow down surface water runoff,
thus helping to prevent lead from migrating off-
site.
Grasses yield the greatest benefit at rifle and
pistol ranges where the bullet impact areas are
sloped, and water runoff and soil erosion may
be more likely. Specific recommendations are
to:
> Utilize quick growing turf grass (such as
fescue and rye grass) for the grass covering
of backstops, which can be removed prior to
reclamation and replanted thereafter;
> Avoid vegetation that attracts birds and other
wildlife to prevent potential ingestion of lead
by wildlife; and
> Use grass to direct surface water drainage
away from the target area (e.g., planting
them at the top of the backstop or sand trap).
This will minimize the water's contact with
lead bullet fragments, minimizing the
potential for lead migration.
Grass is not impermeable; however, it does slow
down the rate of flow and reduce the amount of
lead entering the soil via rainwater. Remember,
grass requires periodic maintenance (i.e.,
mowing) to maintain its effectiveness as well as
for aesthetic reasons.
Mulches and Compost
Mulches and composts can reduce the amount
of water that comes in contact with the lead
fragments. In addition, mulches and compost
contain hermic acid, which is a natural lead
chelating agent that actually sorbs lead out of
solution and reduces its mobility. At a minimum,
the material should be two inches thick. These
materials can be spread over any impacted area
and/or low lying areas where runoff and lead
may accumulate. Like vegetative covers,
organic surface covers are not impermeable. In
addition, the organic material needs periodic
replacement to maintain effectiveness and
aesthetic integrity. Furthermore, these materials
should be removed prior to any lead removal
event, as they may impede sifting or screening.
Note that these materials tend to be acidic
(especially during decomposition), so, if low
pH is a concern at your range, this option
may not be appropriate. Again, however,
lime may be used to control pH (see Section
3.1.1)
Surface Covers
Removable Surface Covers
Removable surface covers may be effective at
outdoor trap and skeet ranges. In this case,
impermeable materials (e.g., plastic liners) are
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BMP for Lead at Outdoor Shooting Ranges
placed over the shotfall zone during non-use
periods. This provides the range with two
benefits during periods of rainfall: (1) the shotfall
zone is protected from erosion; and (2) the spent
lead shot is contained in the shotfall zone and
does not come in contact with rainwater.
Permanent Surface Covers
For outdoor rifle and pistol ranges, impact
backstops and target areas can also be covered
with roofed covers or other permanent covers to
prevent rainwater from contacting berms.
However, this method may be less desirable
because of the cost to install the roof, which
must be carefully designed to avoid safety
issues with ricochets, etc.
For shotgun and other ranges, synthetic liners
(e.g., asphalt, Astroturf™, rubber, other synthetic
liners) can also be used beneath the shotfall
zone to effectively prevent rainwater or runoff
from filtering through lead and lead
contaminated soil. Synthetic liners will generate
increased runoff, which must be managed,
however. No single type of liner is suitable for all
situations based on site characteristics.
Therefore, liners must be chosen on a site-
specific basis, bearing in mind the site's unique
characteristics, such as soil type, pH level,
rainfall intensity, organic content of soil, and
surface water drainage patterns.
Engineered Runoff Controls
Runoff control may be of greatest concern when
a range is located in an area of heavy annual
rainfall because of an increased risk of lead
migration due to heavy rainfall events. A "hard"
engineered runoff control may be needed in this
situation. A heavy rainfall event is defined as
rainfall that occurs at such a rate that it cannot
be absorbed into the ground and causes an
increase in the volume and velocity of surface
runoff. The impacts of rainfall are greater in
rolling or sloped terrain (increases velocity of
runoff) or where surface water bodies are
located on, or immediately adjacent to, the
range.
Examples of "hard" controls include:
> Filter beds
> Containment Traps and Detention Ponds
> Dams and Dikes
> Ground Contouring.
Designing and implementing these "hard"
engineering controls may require the assistance
of a licensed professional civil engineer. They
are included in this manual to offer the reader a
general understanding of these BMP options.
However, this manual does not offer specific
instructions for construction and operation of
these controls. For information about designing
and implementing any of these controls, or
assistance with other range design questions,
contact a licensed professional civil engineer
having applicable experience or the NRA Range
Department, at (800) 672-3888, ext. 1417. The
National Sports Shooting Foundation (NSSF)
may be contacted at (203) 426-1320 for specific
references regarding the use and design of
these controls.
Filter Beds
Filter beds are engineering controls built into an
outdoor range to collect and filter surface water
runoff from the target range. The collected
runoff water is routed to a filtering system, which
screens out larger lead particles, raises the pH
of the water (thus reducing the potential for
further lead dissolution), and drains the water
from the range area. This technique may not
completely prevent lead from entering the
subsurface, since lead bullets, fragments and
large particles may still remain on the range.
Filter beds should be established at the base of
the backstop (see Figure 3-2). In addition to
mitigating off-site migration, the filter beds work
to raise the pH of the rainwater, which has fallen
on the target range, to reduce lead dissolution,
and to strain small lead particles out of the
rainwater. The filters typically consist of two
layers: a fine-grained sand bed underlain by
limestone gravel or other neutralization material.
By design, the backstops and berms direct the
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,
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BMP for Lead at Outdoor Shooting Ranges
Berm/Backstop
Vegetative Ground Cover
Sand Layer
Limestone/
Gravel Layer
Perforated
Pipe
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
particles in the rainwater are collected on the
sand, while the pH-adjusted water drains
through the filter to a perforated drainage pipe
located within the limestone gravel.
Filter beds are designed to capture fine particles
of lead transported in surface water runoff.
They are not designed to capture bullets. The
operation and maintenance requirements of filter
beds are minimal. Maintenance activity is limited
to periodic removal of debris (such as litter,
leaves, etc.) and occasional replenishment of
the limestone.
The use of filter beds is most effective on sites
with open, rolling terrain where surface water
runoff is directed to them. At existing rifle and
pistol ranges, a limited system of trenches and
filters can be installed at the base of natural soil
backstops or at natural drainage depressions.
Containment Traps and Detention Ponds
Containment traps and detention ponds are
designed to settle out lead particles during
heavy rainfall. Typically, they are depressions
or holes in the range's drainage paths. Here,
the lead-containing runoff passes through the
trap or pond, allowing the lead bullet fragments
to settle out. Vegetative cover can be placed in
the drainage path to increase the effectiveness
of containment traps and ponds by further
reducing the velocity of runoff and allowing for
more lead fragments to settle from the runoff. It
is important to regularly collect the lead and send
this lead to a recycler.
Dams and Dikes
At shotgun ranges, dams and dikes can also be
used to reduce the velocity of surface water
runoff. Dams and dikes must be positioned
perpendicular to the direction of runoff to slow
the flow of surface water runoff. To accomplish
this, determine the direction of the range's
surface water runoff. This will be particularly
obvious at ranges with sloped terrain. The dams
or dikes should be constructed using mounds of
dirt that are approximately a foot high. These
mounds should transect the entire range
perpendicular to the stormwater runoff direction.
These runoff controls are most important at
ranges at which off-site runoff is a potential
problem, such as ranges where the lead
accumulation areas are located upgradient of a
surface water body or an adjacent property.
Since lead particles are heavier than most other
suspended particles, slowing the velocity of
surface water runoff can reduce the amount of
lead transported in runoff.
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BMP for Lead at Outdoor Shooting Ranges
Ground Contouring
Another mechanism to slow runoff and prevent
lead from being transported off site is ground
contouring. By altering drainage patterns, the
velocity of the runoff can be reduced.
Furthermore, in areas where pH is high
(resulting in a lower potential for lead
dissolution), the soil can be graded or aerated to
increase the infiltration rate of precipitation, so
that rainwater is more easily absorbed into the
soil. This slows down or prevents surface water
runoff and off-site migration. It should be
pointed out that this design, in effect, collects
lead in the surface soils. Therefore, range
operation and maintenance plans should include
lead reclamation as well as adjusting the pH, and
adding phosphate.
3.3 Lead Removal and Recycling
(Step 3)
To successfully minimize lead migration, the
most important BMP for lead management is
lead reclamation. Implementing a regular
reclamation program will allow you to avoid
expensive remediation and potential litigation
costs. Ranges in regions with high precipitation
and/or with acidic soil conditions may require
more frequent lead recovery since the potential
for lead migration is greater. In regions with little
precipitation and/or where the soil is somewhat
alkaline, spent bullets may be allowed to
accumulate on the soil for a longer time between
reclamation events. It should be noted that to
ensure that lead is not considered "discarded" or
"abandoned" on your range within the meaning
of the RCRA statute (i.e., a hazardous waste),
periodic lead removal activities should be
planned for and conducted. This typically
requires one or more of the following:
> Hand Raking and Sifting
> Screening
> Vacuuming
> Soil Washing (Wet Screening,
Gravity Separation, Pneumatic Separation)
These methods are discussed in detail below.
Figure 3-3 provides examples of common lead
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.
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BMP for Lead at Outdoor Shooting Ranges
Also, it is important to be aware that state
regulations may require that the material being
sent for recycling have a minimum lead content
in order to qualify as a scrap metal that can be
shipped under a bill of lading (i.e., exempt from
RCRA).
3.3.1 Hand Raking and Sifting
A simple BMP that can be done by club
members, particularly at small ranges, is raking
and/or sifting bullet fragments from the soil.
Sifting and raking activities should be
concentrated at the surface layer. This is a low-
technology and low-cost management
alternative for lead reclamation. Once collected,
the lead must be taken to a recycler or reused.
Arrangement with a recycler should be made
prior to collecting any spent lead to avoid having
to store the lead and avoid potential health,
safety and regulatory concerns associated with
storing lead.
At trap and skeet ranges, conducting sifting and
raking activities in the shot fall zone
(approximately 125 -150 yards from the
shooting stations) will yield the most lead. For
sporting clay ranges, these activities should be
conducted around tree bases, where lead shot
tends to collect. Basically, the process consists
of raking with a yard rake the topsoil in the shot
fall areas into piles, as if you were raking leaves,
removing any large debris (e.g., rocks, twigs,
leaves, etc.), and then sifting the soil using
screens.
Once the soil has been raked and collected,
pass it through a standard 3/16 inch screen to
remove the large particles. This process will
allow the lead shot sized particles to pass
through the screen. The sifted material (those
not captured by the 3/16 inch screen) should be
passed through a 5/100 inch screen to capture
the lead and lead fragments. This process will
also allow sand and other small sediment to
pass through the screen. Screens can be
purchased at many local hardware stores. The
screens should be mounted on a frame for
support. The frame size will vary based on the
technique used by each range. For example, if
one person is holding the framed screen, it may
be better to use a smaller frame (2 feet by 2 feet)
whereas, if several people are holding the
framed screen, it can be larger.
Raking and sifting can be performed by club
members on a volunteer basis. Some clubs
provide incentives, such as reduced fees, to
members who assist with the lead removal
process. Other clubs have hired college
students during the summer. A number of small
clubs have found that reloaders will volunteer to
rake in exchange for collected shot.
Hand sifting and raking are cost effective lead
removal techniques for small ranges, or low
shooting volume ranges. However, these
techniques may not be appropriate for situations
in which there is a large volume of lead on the
range. In this instance, reclamation machinery
may be more appropriate.
Note: Those conducting the hand raking and
sifting reclamation at ranges should protect
themselves from exposure to lead. Proper
protective gear and breathing apparatus
should be worn. The Occupational Safety
and Health Administration (OSHA) or an
appropriate health professional should be
contacted to learn about proper protection.
3.3.2 Purchasing/Renting Mechanical
Separation Machinery
Reclamation equipment may be rented from
local equipment rental services. One type of
machine that it may be possible to rent for lead
shot reclamation is known as a screening
machine (also referred to as a mobile shaker,
gravel sizer, or potato sizer). This device uses a
series of stacked vibrating screens (usually two
screens) of different mesh sizes and allows the
user to sift the lead shot-containing soil
[gathered by hand raking, sweeping, or
vacuuming (discussed above)]. The uppermost
screen (approximately 3/16 inch mesh) collects
larger than lead shot particles, and allows the
smaller particles to pass through to the second
screen. The second screen (approximately 5/
100 inch mesh) captures lead shot, while
allowing smaller particles to pass through to the
ground. The lead shot is then conveyed to a
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BMP for Lead at Outdoor Shooting Ranges
container such as a five gallon bucket. In the
Northeastern United States, the typical rental
cost for this equipment is between $500 and
$4,500 a week, depending on the size shaker
desired. It may be possible to get more
information on rentals for this type of equipment
from heavy equipment rental companies.
Another possible option is to rent a vacuum
system that will collect the lead shot-containing
soil from the range. Here, vacuuming takes the
place of hand raking or sweeping. A vacuum
machine is used to collect the lead shot-
containing soil. Once collected, the lead shot-
containing soil must be sifted through a
screening system (either a rental screening
machine, or a series of home made framed
screen sets). You may be able to obtain more
information about renting vacuums or
vacuuming services (e.g., it may include a
person to operate the machinery) from heavy
equipment rental companies.
Some clubs have found that performing their
own lead reclamation to be very time
consuming. Part of the reason these
reclamations took so long is that the soils were
wet. Reclamation is much easier under dry soil
conditions. For example, one club reclaimed
lead from their range using equipment they
modified themselves. Twenty-five tons of lead
were collected but the reclamation took over two
years. Another club took a year to reclaim 10
tons of lead. A more preferable option may be to
hire a reclamation company.
3.3.3 Hiring a Professional Reclamation
Company
Another option for lead removal is to hire a
professional reclaimer. Lead reclamation
companies claim to recover 75%-95% of the
lead in the soils. Generally, with reclamation
companies there is no minimum range size
requirement for lead reclamation. Concentration
of lead is more important than quantity spread
over a field, especially if it is a difficult range for
reclamation (e.g., hilly, rocky, a lot of clay in the
soil).
Please note that reclamation companies tend to
be in high demand — it may take over a year for
the company to start at your club. Therefore, it is
wise to plan ahead and make the call to the
reclamation company as early as possible.
Some reclamation companies require a site visit
to view the topography, the soil composition, and
amount of lead observed on the ground. During
the visit, some companies may even do a site
analysis to determine whether or not it is
feasible to reclaim. This analysis identifies the
location of lead, the expected recovery amount,
and the depth lead reaches into the soils.
3.3.4 Reclamation Activities
Using machinery to reclaim lead usually requires
that the area be clear of scrub vegetation.
Grass, mulch, or compost is generally removed
or destroyed during the reclamation process.
Some reclamation companies have no problem
beginning reclamation on a grassy field. Other
reclamation companies will remove grass before
or during reclamation (by burning it, if allowed
locally, leaving behind the lead shot), and still
others require that all vegetation be removed
before they arrive at the range. Some
companies will re-seed the area once the
reclamation is completed.
Since sporting clay ranges generally have many
trees, removal of vegetation as discussed above
may not directly apply to existing sporting clay
ranges. At these ranges, the focus is on
removing vegetative debris (i.e., fallen limbs,
tree bark, etc.) prior to reclamation. This may
include removing some trees to gain better
access with the reclamation machinery. Of
course, when designing a new sporting clay
range, steps to facilitate lead reclamation should
be taken into account. For example, less and
more widely spaced trees will facilitate lead
reclamation.
Reclamation companies use several types of
machinery to reclaim lead. Some companies
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
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BMP for Lead at Outdoor Shooting Ranges
is removed. Other companies scrape off the top
several inches of soil from the ground, using a
front-end loader to bring the soil/lead to
stationary reclamation machines, and then return
the soil to the field after reclamation. Many
companies till the top two to five inches of soil
and grass immediately prior to reclamation to
facilitate the process (some companies may
require this to be done prior to arrival on the
range).
Regardless of how it is collected, the actual
reclamation of the lead follows the same general
pattern. Most often, it is sifted through a series
of shaking screens. The lead and soil pass
through shaking screens (usually at least two
screens) of decreasing mesh (hole) size, with
the topmost screen having the largest mesh.
This part of the reclamation machinery is usually
adapted from machinery used for potato or
gravel sizing.
Any soil/debris automatically screened out as
being too big or too small is either returned to
the field or re-screened to ensure no lead is
caught in the debris. This procedure is why
moist, clay soils are more difficult to reclaim.
The moist, clay soils can bind together into shot-
sized pellets producing more "product" for the
second part of the reclamation. The wet soils
can also clog the screens.
For some reclamation companies, their process
ends after sifting the soil and returning it to the
ground. However, some companies take
reclamation one step further. After screening,
the resulting lead, soil, and other lead-sized
particles enter a blowing system. Here the lead
shot is easily separated from the soil and other
debris by the blowing air. The lead is much
more dense than the soil and other lead-sized
debris so that it falls out first. Figure 3-3 depict
examples of actual lead reclamation machinery.
Some lead reclamation companies will perform
the reclamation during club off-hours so that
club activities are not interrupted. Additionally,
some perform the reclamation on a field-by-field
basis, to minimize any disruptions to club
activities. However, others companies require
the club to shut down during the reclamation.
Reclamation time varies depending on weather,
site accessibility, range size, and number of
personnel assigned to perform the reclamation.
Reclamation activities may generate dust,
especially in drier western locations. To prevent
or minimize dust from traveling off the range and
causing complaints from neighbors, reclamation
activities generating dust should only be
conducted during periods of no wind. In
addition, such activities should be completed as
quickly as possible.
Vacuuming
For ranges that are located on hilly, rocky, and/or
densely vegetated terrain, several reclamation
companies employ a vacuum system that
collects the lead shot (and soil and other
detritus). The resulting mix is then placed into
the reclamation machinery discussed above.
This method is especially effective for sporting
clay ranges where lead shot tends to pile up
around tree bases.
Vacuuming has traditionally been used for
removal of lead shot from trap, skeet and
sporting clay ranges. Another way to apply this
method involves removing the top layer of an
earthen backstop or sand trap with shovels. It is
then spread thinly over an impermeable material
such as plywood. A vacuuming device is then
used to collect the materials that are lighter than
lead (e.g., sand or soil), while leaving behind the
heavier materials (i.e., lead bullets/shots and
fragments). The soil can then be returned to the
range. This process is most efficient for dry,
sandy soils without a lot of organic material. A
more recent innovation is the use of a high
suction vacuum. This vacuum itself does not
have to be moved about, since a very long hose
(up to 600 feet) is used to move in and around
trees during the collection of lead shot at trap
and skeet ranges.
Soil Washing (Physical and Gravity
Separation)
Soil washing is a proven technology and another
lead reclamation method used by some
reclaimers to separate the lead particles from
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BMP for Lead at Outdoor Shooting Ranges
the soils. Soil washing is the separation of soils
into its constituent particles of gravel, sand, silt
and clay. Because of the much higher surface
area and surface binding properties of clay, most
lead contaminants tend to adhere to the clay
particles.
Soil washing, therefore, attempts to generate a
clean sand and gravel fraction by removing any
fines adhering to the larger soil particles and, if
necessary, to transfer contaminants bound to
the surface of the larger particles to the smaller
soil particles. Typically, the soils are first
excavated from the range and then mixed into a
water-based wash solution. The wet soil is then
separated using either wet screening or gravity
separation techniques. One benefit of this
system of reclamation is that it does not require
that soils be dry.
In addition, soil washing may be able to recover
all or almost all lead particles through a
combination of wet screen sizing and density
separation. This technique is an option for
remediation of a range being closed and may
compare favorably from an economic standpoint
with the disposal option.
Soils treated using this method have been
shown to be below 5 mg/L TCLP and to have up
to 99% of particulate lead removed. Treatment
costs are site specific, but can range from less
then $40 per ton (1999 levels) for simple
physical/gravity separation up to about $100 per
ton for processes involving leaching. Credits for
recycled lead help offset the treatment cost and
the cost of recycling any treatment sludges and
concentrated soil fines. Water used in soil
washing is from a closed loop system and
should only be disposed at completion of
cleanup. Experience shows the water to not be
a RCRA regulated hazardous waste, therefore
probably allowing disposal to a local wastewater
treatment plant.
Wet Screening
With this method, particles larger and smaller
than the surrounding soils are passed through a
series of large-mesh to small-mesh screens.
Each time the mixture passes through a screen,
the volume of the soil mixture is reduced. Large
particles such as lead shot/bullets and
fragments are screened out of the soil/wash
mixture early in the process and can be taken
off-site for recycling - allowing the soil to be
placed back on-site.
Gravity Separation
This technique can be used in cases where the
lead particles are the same size as surrounding
soil particles. The wet soil/wash mixture is
passed through equipment, which allows the
more dense materials (i.e., lead materials) to
settle to the bottom of unit and separate out of
the soil/wash mixture.
Pneumatic Separation
Pneumatic separation (see figure 3-3) is an
effective means to enhance the traditional
screening results. Traditional screening cannot
separate shot and bullets from other shot and
bullet sized material, i.e., rocks, stones, roots,
and various debris. A recycling facility considers
non-lead items as "contaminants" which
drastically reduces the value of the recycled
lead. Pneumatic separation utilizes an air
stream, and specific density analysis, to
effectively separate the shot/bullets from the
other shot/bullet sized material.
3.3.5 BMPs to Assist Lead Reclamation
and Recycling
There are several operational activities that
should be conducted throughout the year to
facilitate reclamation. The following is a
discussion of these activities.
Frequency of Lead Removal
It is important to perform lead removal at a
frequency appropriate for your site. The
frequency is dependent on several factors.
These include:
> Number of rounds fired
> Soil pH
> Annual precipitation
> Soil Type
> Depth to groundwater.
Chapter III- Page 111-15
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BMP for Lead at Outdoor Shooting Ranges
Lead quantity, as estimated by the number of
rounds fired, is a factor in determining the
appropriate frequency of reclamation at ranges.
It also assists in determining the cost of
reclamation. One reclamation company
indicated that reclamation was most cost
effective when it contains at least 20 pounds of
lead per square foot of backstop. Another
source indicated that a minimum of 100,000
rounds per firing lane should be allowed before
lead reclamation occurs. This would ensure
good range operation and maintenance, while
minimizing the cost per quantity of lead
recovered.
For shotgun ranges, tracking the number of
targets thrown can help indicate when the lead
shot should be reclaimed. For example,
considering environmental issues, the
market for scrap lead and common cleanup
methods, one source indicated that when a
range has thrown at least 250,000 to 1,000,000
targets, depending on the shooting area,
reclamation of the lead shot is encouraged.
Another reclaimer indicated that if at least two
pounds of lead per square foot have
accumulated on the range, reclamation is
recommended.
Because the number of rounds fired is important
to know, establishing record keeping procedures
to monitor the number of rounds fired is
recommended. This can be accomplished by
maintaining logbooks and asking shooters to list
the number of rounds shot and the type/size of
shot/bullets they use. This should be done by
lane and by stand.
There are many ranges at which lead removal
has not occurred for many years. Many of these
ranges are used extensively. Such ranges are
especially good candidates for lead removal and
recycling. Subsequent removal frequency
depends on range use and environmental
factors. The NRA recommends a frequency of
one to five years for lead cleanup, even on
ranges with minimal use4. One possible
approach to reducing the cost of reclamation
4 National Rifle Association, "Metallic "Bullets" lead
Deposits on Outdoor and Indoor Firing Ranges" 1991
more cost effective is for a number of ranges in
the same geographical area to work together in
organizing coordinated removals at their ranges.
This will reduce the reclaimer travel and
mobilization cost for each range.
Minimization of Vegetation
As discussed previously, vegetation is useful
both for controlling the amount of runoff and
erosion from the range and inhibiting lead
mobility. However, excessive or
unmaintained vegetative cover can interfere
with reclamation activities. For example, large
amounts of vegetation impedes the screening
and sifting processes used by many reclamation
companies. Therefore, prior to reclamation
activities, it is best to remove, reduce, or mow
excessive vegetation from the area. Once the
reclamation has been conducted, quick-growing
vegetation such as a rye/fescue grass mix
should be replanted. This process should be
repeated for each reclamation event.
In addition, heavily wooded areas may inhibit
lead reclamation because they are less
accessible by heavy reclamation machinery.
For ranges that are heavily wooded, it is
recommended that you minimize the vegetation
or modify the range design to allow lead
reclamation equipment access to the range.
Access to the impact area should be developed
to facilitate reclamation. Make sure that the
pathways do not present a safety risk.
Innovative Landscaping
Some new ranges are landscaping their ranges
to include a sand track (an area the size of the
shotfall zone that is only sand) located behind
some aesthetically pleasing shrubs. This allows
the spent shot to concentrate on the sand,
making it very easy to perform reclamation
because there is no interference by vegetation.
Selecting a Lead Reclaimer
In ensuring that the reclamation is conducted
appropriately, selecting a reclaimer that is right
for your range is extremely important. Some
lead reclamation companies will travel to your
range and assess the range prior to conducting
Chapter III- Page 111-16
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BMP for Lead at Outdoor Shooting Ranges
lead collection activities. This assessment trip
allows the reclamation company to confirm
information gained during initial discussions, as
well as to assist in appropriately estimating
costs, time required, and the estimated volume
of lead at the range. Conducting this pre-
assessment also allows you to determine which
reclaimer is right for your situation.
Questions Commonly asked by the Reclaimer
When you contact a reclamation company, it is
likely that the reclaimer will ask several general
questions. Typical questions include:
> When was the last reclamation conducted?
> How many rounds have been shot since
that last reclamation?
> What is the use frequency of the range?
> What are the site characteristics and soil
types?
> What type of bullet containment device is
used at the range?
Answering these questions will be a lot easier if
you have maintained good records, as is
suggested above.
Questions to ask the reclaimer
When choosing a reclaimer be sure to ask the
general questions about prior cleanups (past
projects), insurance to cover company and
cleanup (general liability insurance, pollution
insurance, bonding, etc.), and site plans to
ensure health and safety of workers and range
personnel. Other questions you may want to ask
the reclaimer include:
> Can the reclamation take place outside
normal hours of range operation?
> What costs are involved?
> How long will the reclamation take?
> Does vegetation at the range need to be
removed?
Economic Considerations
Lead removal costs may vary dramatically
depending upon the type and volume of soil or
sediments, topography, amount of lead, location,
and reclamation company and technique used.
Because the economics vary due to many
factors, this manual does not provide specific
estimates. However, it is important to
understand that lead reclamation will generally
require an expenditure by the range, even when
considering any monetary returns from selling
reclaimed lead. By tracking the range use and
using the criteria discussed earlier (see
Frequency of Lead Removal), the reclamation
costs per quantity of lead can be optimized. For
long term range management, routine lead
removal will help future cost avoidance by
minimizing the need for costly site remediation
Some reclaimers bid the lowest flat fee with all
the lead provided to the range for selling. The
range owners/operators must then consider the
transportation costs and recycling fee
associated with sending the reclaimed shot and
bullets to a recycling company. Alternatively,
the reclaimer will use the economic return of lead
sold for recycling, based on the volume
reclaimed and the current value of lead, to
reduce the total cost of reclamation and
recycling. Although the value of lead varies, the
scrap value of reclaimed lead typically falls
between $.06 and $.25 per pound, excluding
transportation cost. See the appendix for
contact information regarding lead reclamation
companies that specialize in lead removal at
outdoor ranges.
3.4 Documenting Activities andl
Record Keeping (Step 4) |
Documenting activities and keeping good
records is of paramount importance for an
effective lead management program at a range.
Owners/operators should document all activities
done at the range with respect to BMPs and
recycling of lead. Records should be kept on
when services were provided and who provided
them.
Owners/operators may want to document what
type of BMP(s) were implemented to control
lead migration, the date of service, and who did
the services. The records should be kept for the
life of the range. Records may be used to show
that owners/operators are doing their part to
Chapter III- Page 111-17
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BMP for Lead at Outdoor Shooting Ranges
help prevent lead migration off-site and show
that they are doing their part to be stewards of
the environment.
3.5 Additional Economic
Considerations
Not all BMPs need to be implemented at once.
Many can be phased in over time. However, it
is important to begin implementing BMPs,
especially lead reclamation and recycling, as
soon as possible. Implementing the most
appropriate BMPs for your range requires
consideration of your range characteristics and
costs associated with implementing the BMPs.
This manual provides a large selection of BMPs
that vary in both cost and sophistication. In
selecting BMPs for your range, it is important to
look at all costs and all the benefits (or potential
problems) associated with each BMP.
3.6 Summary of Key BMPs for ,
Shooting Ranges
There are several BMPs that are highly
recommended to be implemented, if applicable
to your range. Table 3-1 identifies the
advantages and disadvantages of all BMPs
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 I
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
formats. This template, combined with
information provided throughout this manual,
other resources and guidance, and site-
specific factors, will help in guiding the
process of evaluating relevant information
about your facility and determining which
BMP(s) might be appropriate for your
ranges. EPA's 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.) Accordingly, use of that template
would also be acceptable for use in EPA's
Certificate of Recognition program.
In order to request this certificate, a range
must submit a notice to the Lead Shot
Coordinator in EPA Region 2 stating that
they have completed an Environmental
Stewardship Plan as indicated above and
are intending to implement it within six
months. The certificate is intended to
convey, to all that may see it, that the range
has declared its intention to properly manage
lead shot and bullets. However, it must be
noted that a certificate is not a permit to
operate and provides no additional
operational approval, implied or otherwise.
Chapter III- Page 111-18
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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
Lime Spreading
Advantages
1 . Easy
2. Inexpensive
3. Effective
Disadvantages
1 . Does not offer a
permanent solution
2. Will not work in
extremely acidic conditions
Immobilizing Lead
BMP Option
Phosphate Spreading
Advantages
1 . Easy
2. Inexpensive
3. Effective
Disadvantages
1 . Does not offer a
permanent solution
Controlling Runoff
BMP Option
Vegetative Ground Cover (e.g., grass, etc.)
Organic Surface Cover (e.g., mulch and
compost)
Filter Beds
Advantages
1 . Easy
2. Aesthetically pleasing
3. Relatively inexpensive
4. Effectively slows and
can redirect runoff
5. Some may "bioabsorb"
lead
1 . Easy
2. Aesthetically pleasing
3. Relatively inexpensive
4. Effectively slows and
can redirect runoff
1 . Diverts and treats lead
contaminated runoff
2. Low maintenance
3. Assists with range
drainage
Disadvantages
1. Requires periodic
maintenance
2. Must be removed or
reduced prior to
reclamation
3. Excessive vegetation
will interfere with
reclamation
1. Requires periodic
maintenance
2. Must be removed prior
to reclamation
3. May not be suitable at
ranges with acidic soil
conditions
1. May require hiring a
licensed engineer
2. Higher initial setup cost
Chapter III- Page 111-19
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BMP for Lead at Outdoor Shooting Ranges
Table 3-1 - Continued
Controlling Runoff (cont.)
BMP Option
Water/Sediment Traps
Dams and Dikes
Ground Contouring
Controlling and Containing Bullets
Advantages
1 . Low maintenance
2. Assists with range
drainage
1 . Low maintenance
2. Assists with range
drainage
1 . Lower initial setup cost
2. Assists with range
drainage
Disadvantages
1 . May require hiring a
licensed engineer
2. Higher initial setup cost
2. Higher initial setup cost
1 . May require hiring a
licensed engineer
Bullet Containment Devices
BMP Option
Earthen Backstop
Sand Trap
Pit and Plate Trap (Sand)
Advantages
1. Minimal (if any) initial
setup cost
2. Accepts firing from
various guns and directions
1. Low initial setup cost
2. Ease of maintenance
3. Accepts firing from
various guns and directions
1. Low initial setup cost
2. Simple installation
3. Lead removal and
recycling requires less
extensive mining
Disadvantages
1 . Build up of bullets
increases chances of
ricochet and fragmentation
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
1 . Build up of bullets
increases chances of
ricochet and fragmentation
problems
2. Lead removal requires
mining
1 . Lead builds up on top
layer of sand causing
ricochet problems
2. Increased bullet
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- Pagelll-20
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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
outdoors
1. Deflection plates require
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
outdoors
2. Bullets are captured in
pure form in containers,
thus removal and recycling
is easy
1. Does not accept shooting
from all directions
2. Corners where each unit
meet can cause ricochet
and fragmentation problems
3. More noise
4. May create lead dust
Wet Passive Bullet Trap (Steel)
1. Can be used indoors and
outdoors
2. Excellent results (i.e., low
ricochet, low fragmentation,
ease of removal)
3. Bullets are captured in
containers, thus removal
and recycling is easy
1. Expensive
2. Oil and water mixture is
hazardous
3. More noise
Lamella Trap
1. Can be used indoors or
outdoors
2. Reduction of lead dust
1. Rubber strips quickly
become destroyed and must
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 111-21
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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
outdoors
2. Reduction of lead dust
3. Minimizes
fragementation, compared
with some backstops
1. Rubber strips can
quickly become destroyed
and must be replaced
2. Some pose potential fire
hazard, although fire-
retard ant/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
formed in any shape
2. Can be used to reduce
erosion in soil berms/target
emplacements
3. Crushed concrete can
potentially be recast after
fragments removed
1. Mechanical lifting and
handling equipment must
be used during installation
and maintenance
2. High maintenance
(replacement) costs
Removal and Recycling of Lead
Hand Raking and Sifting
1. Easily done by club
members
2. Inexpensive
3. Can be done outside
operating hours
4. Relatively effective
1. May be more time
consuming at large ranges
2. Weather sensitive (i.e.,
works best under dry
conditions)
3. Exposure to lead and
lead dust possible
Screening
1. Effective
2. Potential economic
returns
1. Vegetation must be
removed
2. Weather sensitive (i.e.
works best under dry
conditions)
Vacuuming
1. Effective
2. Can be used at least
accessible ranges
3. Less vegetation needs
to be removed
1. Weather sensitive (i.e.
works best under dry
conditions)
Soil Washing
1. Effective at cleaning the
soil to remove the lead
particles so one is left with
non-lead soil
1. Vegetation must be
removed
Chapter III- Pagelll-22
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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 F2d 1305
(2dCir. 1993)
George, C.J., Joachim, A., and Le, PhuTrong, 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: Leadshot.Region2@epa.gov
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
Resource Recycling Divsion
HC1 Box1395
Boss, MO 65440
800-633-8566
573-626-3476
Lou Magdits
l.magdits@doerun.com
East Penn Manufacturing Company, Inc.
P.O. Box 147
Lyon Station, PA 19536
610-682-6361
Rick Leiby
Web Site: http://www.eastpenn-deka.com
Exide
Spring Valley & Nolan Streets
Reading, PA 19612
800-437-8495
Robert Jordan, Maritza Rojas-Suarez
Web site: http://www.exide.com
Gopher Smelting and Refining
3385 Highway 149 South
Eagan, MN 55121
651-454-3310
800-354-7451
Mark Kutoff
Web Site: http://www.gopherresource.com/
Gulf Coast Recycling
1901 N.eethst
Tampa, FL 33619
813-626-6151
Wlliam Weston
Kinsbursky Brothers, Inc.
1314 N.Anaheim Blvd
Anaheim, CA 92801
714-738-8516
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
3200 Shell St,
P.O. Box 73520,
Fairbanks, AK 99707
Craig Jones
907-456-1955
www.briceinc.com
Reclaims primarily from
earthen backstops and sand
traps.
En-Range, Inc.
3326 NW 29th St.
Miami, FL 33142-6310
Thomas M. Taylor
305-999-9965
Fax 305-635-8645
Email: enrange1@yahoo.com
www.en-range.com
Provides lead reclamation and
other environmental and
maintenance services.
Entact
1010 Executive Court
Suite 280
Westmont, IL 60559
630-986-2900
www.entact.com
Performs physical removal of
the lead from backstops,
chemical treatment of soils
and returns soil to the
backstop.
Karl & Associates, Inc.
20 Lauck Road
Mohnton, PA 19540
Edmund Karl III
610-856-7700
Works primarily in the the mid-
Atlantic area. Lead-containing
soil is physically removed and
sent to licensed disposal sites
or licensed recycling facilities.
MARCOR
246 Cockeysville Road
Hunt Valley, MD21030
Dave Jungers
410-785-0001
www.marcor.com
Uses a pneumatic separation
unit to remove lead from
contaminated soil and treats
soil to pass TCLP
Metals Treatment
Technologies, LLC (MT2)
12441 West 49th Avenue
Suite 3
Wheat Ridge, CO 80033
Jim Barthel
303-456-6977
www.metalstt.com
Removes lead from soil and
treats soils at all types of
ranges.
Sears Trucking Company
P.O. Box 38
El Reno, OK 73036
Garland Sears
800-522-3314
Fax 405-262-2811
Physically removes lead from
soils at trap and skeet ranges.
Solucorp Industries, Ltd.
250 West Nyack Road
WestNyack, NY 10994
Mike DeLuca
845-623-2333
Fax 845-623-4987
Email: solucorpmbs@aol.com
www.solucorpltd.com
Removes and treats soil using
their Molecular Bonding
System (MBS) soil
stabilization technology.
Southern Lead Removal
P.O. Box 2645
Daytona Beach, FL 32115
Kevin Gilchrist
386-763-0115
Fax 386-761-6991
Removes lead from indoor and
outdoor pistol ranges only.
Sport Shooting Services
P.O. Box 667
Crawfordville, FL 32326
Ed Tyer
850-926-7375
Cellphone 850-294-0132
Email: envirorange@aol.com
Removes lead from earthen
berms, uses a shaker and
screen system to separate
lead from soils, rents
screening equipment, and
consults on range design,
primarily in Florida.
Terra Resources, Ltd.
HC4 Box 9311
Palmer, AK 99645
Larry Wood
907-746-4981
Cellphone: (907) 232-5059
Fax: 907-746-4980
www.terrawash.com
Uses gravimetric process to
separate lead and
TerraWash™ soil washing
technology.
Waste Recycling Solutions,
Inc.
1850 Route 112
Medford, NY 11763
Tommy Arabia, President
631-654-3811
Uses a vacuum system to
remove lead from trap and
skeet ranges.
Appendix A - Page A-3
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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 includ-
ing questions on range construction, design, and implementing BMPs.
U.S. Fish and Wildlife Service
4401 North Fairfax
Arlington, VA 22203
703/358-2156
Web site: http://www.fws.gov/
Institute of Scrap Recycling Industies, Inc.
1325 G Street, NW, Suite 1000
Washington, DC 20005-3104
202/737-1770
Web site: http://www.isri.org/
Lead Industries Association, Inc.
13 Main Street
Sparta, NJ 07871
973/726-LEAD (973/726-5323)
fax: 973/726-4484
Web site: http://www.leadinfo.com
National Rifle Association of America
11250 Waples Mills Road
Fairfax, VA 22030
800/NRA-3888
Web site: http://www.nra.org
National Shooting Sports Foundation and
National Association of Shooting Ranges
11 Mile Hill Road
Newtown, CT 06470
203/426-1320
NSSF web site: http://www.nssf.org
NASR web site: http://www.rangeinfo.org
Sporting Arms and Ammunition
Manufacturers' Institute, Inc.
Flintlock Ridge Office Center
11 Mile Hill Road
Newtown, CT 06470-2359
203/426-4358
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. ERA'S Outdoor Shooting Range
Home Page
U.S. EPA - Military Munitions Rule
U.S. Occupational Safety and Health
Administration (OSHA)
National Institute for Occupational
Safety and Health (NIOSH)
http://www.epa.gov/region2/waste/leadshot/
http://www.epa.gov/epaoswer/hazwaste/military/
http://www.epa.gov/tribalmsw/thirds/remunition.htm
http://www.osha.gov/
http://www.cdc.gov/niosh/
State Government Sites
Florida: BMPs for Shooting Ranges
Massachusetts : Lead Shot in the
Environment
Minnesota: Poster for "Firing Range
Hazards"
Ohio: Lead Shot Reclaimers list
Wyoming: Lead Recyclers List
http://www.dep.state.fi. us/waste/categories/shooting_range/
http://www.state.ma.us/dep/files/pbshot/pb_shot.htm
http://www.cdc.gov/niosh/mnables.html
http://www.epa.ohio.gov/dhwm/leadrecy.htm
http://deq.state.wy.us/outreach/lead.htm
Court Decisions
Connecticut Coastal Fishermen's
Association v. Remington Arms
Long Island Soundkeeper Fund and NY
Coastal Fishermen's Assoc. v. New York
Athletic Club
http://www.duedall.fit.edu/summer/rcra.htm
http://www.epa.gov/region02/waste/leadshot/lisfnyac.htm
Articles and Research
USAF - Lead Contamination in Soils at
Military Small Arms Firing Ranges
U.S. Army Env. Center (AEC) - Small
Arms Range Technology
AEC - Green Bullets
AEC - Recycling of Firing Range Scrap
Florida Center for Solid and Hazardous
Waste Management
National Association of Shooting
Ranges' Reference Library
http://www.afcee.brooks.af.mil/pro-act/fact/june98a.asp
http://aec.army.mil/usaec/range/operations03.html
http://aec.army.mil/usaec/technology/rangexxi03.html
http://aec.army.mil/usaec/publicaffairs/update/win97/range.htm
http://aec.army.mil/usaec/publicaffairs/publicity02.html
http://aec.army.mil/usaec/technology/rangexxiOOa.html
http://aec.army.mil/usaec/publicaffairs/update/spr97/bullets.htm
http://aec.army.mil/usaec/publicaffairs/update/spr99/spr9911.htm
http://www.floridacenter.org/
http://www.rangeinfo.org/resource_library/facility_mngmnt/
Appendix A - Page A-5
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Bullet Trap
Manufacturer
Action Target
(801) 377-8033
Contact:
John Curtis, CEO
actiontarget.com
Action Target
(Cont.)
see details above
Designs Available
Total Containment
Trap (TCT)
Rubber Berm
Trap (RBT)
Estimated Cost of
Trap
$1,600 to $1,800
/linear foot
(dependent on
features selected)
$1100/linerfoot
Price
Includes
Purchase of
Equipment
Installation
Delivery
(Freight
included)
Installation
and Delivery
Not
Included
in Price
Usage of
Trap
Rifle
Pistol
Armor -
piercing*
'depends on
type of
armor-
piercing
Rifle or
Pistol.
Armor-
piercing.
Cannot use
incendiary
rounds.
Description
The TCT is a funnel-style trap that
uses steel plates mounted at low
angles to direct bullets into a
deceleration chamber. The low
angles prevent break up of the
bullets until they reach the chamber,
where the bullets lose energy and
drop into removeable storage
containers. An optional dust
collection unit uses a powerful
vacuum to remove lead dust and
other fine particles from the collection
chamber.
The RBT is very similar in form and
function to a traditional sand or
earthen berm trap, with the obvious
difference being the use of chopped
rubber instead of sand as a
collection medium. Bullets fired into
the trap are absorbed by the rubber
and remain there until reclamation
through mining of lead from the trap.
General Comments
The TCT is designed for
both indoor and outdoor
applications. It may be
used safely with handguns,
shotguns, and high-
powered rifles, and has
been successfully tested
and used with 50-caliber
fire.
Because rubber is a softer
collection medium, bullets
can be captured with less
break-up and fragmentation.
The resulting reduction in
lead dust levels is
especially beneficial in
indoor ranges. This benefit
is decreased as more
rounds accumulate in the
trap, causing newly fired
bullets to impact bullets
already in the trap.
1 EPA does not endorse any particular bullet containment device or product. Information on this table is offered to
readers for a general understanding of some common bullet trap options and is based on vendor marketing literature.
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Bullet Trap
Manufacturer
Copius
Consultants
(516) 783-7489
Contact:
Craig Copius
Meggitt Defense
Systems
Caswell
(612) 706-6201
Contact:
Brian Danielson
Designs
Available
Containment/
Recovery
System
Granular
Rubber Bullet
Traps
Estimated Cost of
Trap
Ranges from
$600/linear foot to
$1,0007linearfoot
(Price varies with
specific design
selected)
$940to$1,3007linear
foot
(dependent on type of
trap and other features
selected)
Price
Includes
Purchase of
Equipment
Purchase of
Equipment
Installation
Delivery
(Freight
included)
Not Included
in Price
Shipping
Usage of Trap
Rifle
Pistol
Machine gun
Shotgun
Pistol
Rifle
Armor- Piercing
Shotgun
Machine gun
Tracers (Speak
to Sales Rep.)
Description
This is a modification of the
sand backstop. Sizes vary
depending on the needs
and characteristics of the
range; however, average
height is 10' -12' and
average width is 12' - 14'.
The trap utilizes ballistic
grade sand to trap bullets
and bullet fragments in a
sealed system. The system
contains collection and
filtration systems to ease
reclamation and eliminate
off-site migration of lead.
The trap absorbs bullets
fired from any angle or
distance. No exposed steel
surfaces; bullets are not
fragmented. The
granulated material used in
the trap can be turned over
quickly to recover the spent
rounds.
General Comments
Specific recommended
bullet trap is based on the
following:
1) Type of usage, quantity
of usage, etc.
2) Location in country
3) Environmental issues
(e.g., location near a
waterbody)
Price will depend on the
design adopted.
One unique feature is that
shooting can occur at any
angle.
Suitable for indoor and
outdoor ranges.
Eight types of traps
available.
Custom builds traps.
Provides site-specific
design, if requested.
Reclamation is
recommended after
approximately 90,000
rounds have been fired
(depending on trap type.)
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1 EPA does not endorse any particular bullet containment device or product. Information on this table is offered to
readers for a general understanding of some common bullet trap options and is based on vendor marketing literature.
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Bullet Trap
Manufacturer
Range Systems
(888) 999-1217
(763) 533-9200
Contact:
Steve Thomas
range-systems.com
Savage Range
Systems
(413) 568-7001
Contact:
Joan Drucker
snailtraps.com
Designs
Available
Encasulator
Bloc Trap™
Encasulator
Granular
Trap™
The SNAIL™
Trap
Estimated Cost of
Trap
$800-$1,250/linearft
(Price varies with
design criteria and
product selection)
Two types of traps:
Pistol Wet:
$2,250/linear ft
Pistol Dry:
$2,150/linearft
Rifle Wet:
$2,400/linear ft
Rifle Dry:
$2,300/linear ft
Price
Includes
Purchase of
Equipment
Installation
Purchase of
Equipment
Not Included in
Price
Freight
Shipping
Installation
Usage of
Trap
Pistol
Rifle
Shotgun (shot
and slugs)
Rifle
(up to .50 cal
BMG)
Pistol
Description
The bullet traps are
constructed for maximum
bullet retention with minumum
space and cost. The bullet
traps virtually eliminate
ricochet and airborne lead.
The SNAIL trap is designed
with low angle entrance
ramps to guide the bullet into
the circular deceleration
chamber without scarring the
plate. The bullet loses all of
its energy in the chamber
and drops into a collection
system. The use of water
and synthetic oil contains the
lead particulates and dust,
and minimizes friction on the
plates.
General Comments
Full service shooting
range provider from
design and engineering to
construction and
maintenance.
Custom-built traps with
exclusive patented rubber
technology.
Usage for indoor and
outdoor ranges.
Can also be provided with
a conveyance system that
drops the bullet to a single
collection point (e.g., 55-
gallon drum) for recycling.
Low-maintenance system
1 EPA does not endorse any particular bullet containment device or product. Information on this table is offered to
readers for a general understanding of some common bullet trap options and is based on vendor marketing literature.
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Bullet Trap
Manufacturer
Stapp EBC,
Incorporated
(703) 239-9223
Contact:
Matt Ciskowski,
RE.
8101 Ox Road
Fairfax Station,
VA 22039
Fax:
(703) 239-9224
bulletcatcher.com
Designs
Available
STAPP Bullet
Catcher
Estimated Cost of
Trap
Varies by specific
design (measured
by square foot)
Price
Includes
Purchase of
Equipment
Installation
Delivery
(Freight)
Not Included in
Price
Usage
of Trap
Pistol &
Rifle
(best for
calibers
up to
12mm)
Can
handle
jacketed
rounds
and
tracers
Description
The STAPP bullet catcher
(consisting of a bottom rubber
liner, drainpipe reservoir, rubber
granule fill, and cover layer of
rubber) collects lead and any
infiltrating water without runoff.
The system is constructed over
an earthen berm and can be
modified to any range
configuration. Projectiles are
completely collected by the
bullet catcher with minimal
fragmentation. The surrounding
structure is ricochet-proof even
under the most extreme
temperatures.
General Comments
Designs are site adapted.
Reclamation can be performed by
Stapp EBC or by range personnel.
Email:
mciskowski-trc@verizon.net
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readers for a general understanding of some common bullet trap options and is based on vendor marketing literature.
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Bullet Trap
Manufacturer
Super Trap Inc.
(951) 736-9440
Contact:
Art Fransen,
Retired, L.A.S.D.
1601 Commerce St
Corona, CA 92880
Fax:
(951)736-9450
Email:
info@supertrap.com
supertrap.com
Designs
Available
Gel-Cor™
Class A, Fire-
Rated Rubber
Bullet Traps
ELIxIR™
Tactical Shooting
Ranges
Super Trap*
Range
Backstops
SACON®
Perimeter
Facilities, Walls,
Blocks & Tiles
Estimated Cost of
Trap
Approx $520 to
$1,600 per linear foot
Varies by design,
including:
- indoor
- outdoor
- foundation
- width of trap
Price
Includes
Purchase of
Equipment
Installation
Training
Not Included
in Price
Shipping
(Price will
depend on
destination)
Usage of Trap
Rifle & Pistol
(up to and
including .50
cal)
Machine Gun
Armor Piercing
Tracer &
Incendiary
Ammunition
Also:
Frangible &
Tungsten
Traditional &
Tactical
Shooting
Description
STI specializes in tactical
shooting ranges. The firing
range system captures and
contains bullets whole,
using a treated, granular
ballistic media of recycled
pure SBR (styrene-
butadiene rubber), free of
all steel and fiber
contaminants that could
normally allow fires to
ignite.
The infrastructure is 10
gauge galvanized steel and
the hopper/deflection baffle
is 3/8" AR 500 steel rifle
rated (indoor and outdoor.)
Outdoor Ranges: The
backstop base typically lies
on a graded berm at the
appropriate angle
determined by the user and
STI staff.
SACON® can absorb bullets
and prevent lead
contamination, replacing
railroad ties, logs, brick
walls and concrete
enclosures on firing ranges.
General Comments
STI's bullet trap systems
eliminates hazardous
materials contamination
(TCLP tests below 1ppm),
in addition to preventing
ricochets and lead splash-
back.
Reclamation is
recommended after
approximately 100,000 to
130,000 rounds per 4ft
lane, based on type of
shooter position and
layout of targetry (static
vs. dynamic.) Lead
reclamation is performed
using a vacuum air
density separator system
and rubber media is
continuously reused.
Use of recycled rubber
media in the trap may
qualify the range
improvement for grant
funding. Contact regional
recycling associations for
more information.
STI offers more than six
versions of Tactical
Shooting Ranges, as well
as custom built traps.
1 EPA does not endorse any particular bullet containment device or product. Information on this table is offered to
readers for a general understanding of some common bullet trap options and is based on vendor marketing literature.
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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
-------
Summary of Lead Shot Alternativest
Shot Material
Approximate Cost per 25
Round Box1
Ballistic Performance
Availability
Comments
Lead
$5.00/box
$3.00 - $4.00/box of reloaded
shells
Standard to which all alternatives
are compared
Readily available
Lead is heavy and malleable
Bismuth*
97% Bismuth/
3% tin
Bismuth shells are packed in
10 round boxes @ $15.00-
$25.00/10 round box
Similar to lead
Limited world
supply of bismuth
Bismuth is a byproduct of lead and gold
mining. There are currently many uses,
including: medicine (Pepto-Bismol),
cosmetics, pigments, and shotgun shot.
The addition of tin makes bismuth more
malleable and reduces frangibility.
Bismuth shot is safe to use in older
firearms.
T3
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f Product reference within this table is not an endorsement by EPA.
* Approved by USFWS for migratory waterfowl hunting.
1 Costs will vary from store to store and were valid at the time of manual development.
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Summary of Lead Shot Alternatives - Continued*
Shot Material
Approximate Cost per
25 Round Box1
Ballistic Performance
Availability
Comments
Steel*
$8.00-$12.95/box
$6.00/box of reloaded
shells
$15.00/box (copper-
plated)
In test performance by the
Cooperative North American
Shotgun Education Program
(CONSEP) in hunting situations, no
significant differences were found
between lead and steel shot at
reasonable distances. Lead is
more effective at longer ranges.
Readily available from
both domestic and
imported sources.
Steel shot is about 33% lighter then
lead. Therefore, the initial velocity
must be increased so that downrange
pellet energy remains similar. In
hunting situations, larger, and therefore
heavier, steel shot is used. Few
shooting competitions allow steel shot
at this point, but the number is
increasing.
While steel target loads are available,
shooter perception that steel will
adversely affect guns and scoring
seems to be the limiting factor in
acceptance of steel shot for target
shooting.
Steel shot will not damage newer
guns, but may cause ring bulge in
older guns if a very tight choke is
used. This problem has been
resolved in the newer guns with the
use of screw-in chokes.
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f Product reference within this table is not an endorsement by EPA.
* Approved by USFWS for migratory waterfowl hunting.
1 Costs will vary from store to store and were valid at the time of manual development.
-------
Summary of Lead Shot Alternatives - Contiuedf
Shot Material
Approximate Cost per 25
Round Box1
Ballistic Performance
Availability
Comments
Steel*
(cont.)
Another concern with steel shot is safety.
Because steel is much less malleable
then lead, steel shot is likely to ricochet if
it strikes something hard. Lead shot, on
the other hand, will deform and flatten.
In Europe, steel shot is banned for
hunting because it can become
embedded in trees. The steel shot in
trees cut for lumber can cause damage
to sawmill equipment and raise concerns
about worker safety.
Although steel shot can be reloaded,
components are not readily available.
Tungsten/Iron*
40% tungsten/
60% iron
$62.50/box (tungsten/iron
shots are packed in 10
round boxes @ $25.00/10
round box)
Preliminary reports indicate that
tungsten/iron shot is as effective as
lead shot. However, the amount of
shot in each cartridge is significantly
less then in typical lead cartridges
or even steel cartridges. The density
of tungsten/iron is 94% that of lead.
Readily available
The tungsten/iron shot currently available
is harder than steel. It would, therefore,
cause similar damage to older guns.
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1 Product reference within this table is not an endorsement by EPA.
* Approved by USFWS for migratory waterfowl hunting.
1 Costs will vary from store to store and were valid at the time of manual development.
-------
Summary of Lead Shot Alternatives - Continued*
Shot Material
Approximate Cost per
25 Round Box1
Ballistic Performance
Availability
Comments
Tungsten/polymer*
Various manufacturers
have received final
approval from the USFWS
to market this type of
shot.
Not available yet
Comparable to tungsten/iron
Currently not available
Two ammunition manufacturers are
currently producing tungsten/polymer
shot. This shot is more malleable than
the tungsten/iron alloy and would,
therefore, be less damaging to
shotguns.
A research and development company
has developed a tungsten/polymer
material as a substitute for lead in all its
uses. According to this company, its
tungsten/polymer can be formulated to
be flexible or stiff, depending on the
application. This material has been
tested by the US Army in projectiles,
but has not been used to manufacture
shot. However, the company has
initiated the process of applying to the
USFWS for approval of this material as
non-toxic shot.
T3
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f Product reference within this table is not an endorsement by EPA.
1 Costs will vary from store to store and were valid at the time of manual development.
-------
Summary of Lead Shot Alternatives - Continued*
Shot Material
Approximate Cost per 25
Round Box1
Ballistic Performance
Availability
Comments
Tungsten/steel
Same as tungsten/Iron
Tin
USFWS granted temporary
approval for 1999-2000
hunting season
Not available yet
Since tin is just being developed as
an alternative to lead, performance
information is not yet available.
However, since the density of tin is
less than steel, performance may be
less effective than steel.
Currently not available
This material is just being developed as
a lead shot alternative. However, it has
similar problems as steel in that it is
lighter then lead.
The International Tin Research Institute
in england is developing this product.
Other materials that are currently being experimented with as alternatives to lead are molybdenum and zinc. Not enough information
is available to have included these alternatives in the above table.
Product reference within this table is not an endorsement by EPA.
-------
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 alterna-
tives 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
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BMP for Lead at Outdoor Shooting Ranges
This page intentionally left blank
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.
Bullets impact and are
contained in the sand
Sand Trap
Targe! Area
I
1
Elastic Facing
Direction^
of Fire
Elastic Facing.
Frame System
Granulated
Rubber
Back Plate
for Recycling
and Removal ot Lead
Rubber Granule Trap (Adapted from: BulletTrap
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
SACQN BACK RETAINING WALL
BALLETIC RUBBER MEDtH WfTH GEL COMPONENT
(CLASS * FIRE »TCO BULLET IMP)
Direction
of Fire
CONCRETE FQUNBAIIQN
SACON'SHOCK
ABSORBING CONCRETE
TOE WALL
SftCO.N TILE LEACH FIELD
Gel-Cor Bullet Trap™ (Provided by Super Trap, Inc.)
Bullet Collection
Area
Escalator Trap (Adapted from: Bullet Trap Technologies, Action Target Educational Video Series)
Appendix C - Page C-2
-------
BMP for Lead at Outdoor Shooting Ranges
Front View
Side View
Direction
of Fire
Collection
Bucket
Vertical Swirl Trap (Adapted from: Bullet Trap Feasibility Assessment and Implementation Plan: Technology Identification Final
Report, U.S. Army Environmental Center, March 1996)
Deceleration
Chamber
Wet Passive Trap (Adapted from: Bullet Trap Feasibility Assessment and Implementation Plan: Technology Identification Final
Report, U.S. Army Environmental Center, March 1996)
Direction
of Fire
Bullets are deflected
onto the top layer of sand
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
I
Target
Area
Walkway
Space Deceleration
Chamber
Deflection Plates
Direction
of Fire
Trap Depth
Lead
Collection
Tray
Steel Bullet Trap (Adapted from: Bullet Trap Technologies, Action Target Educational Video Series)
Front Viwu
Top View
St~l Barking
f™— —
'I
i
4 ""'*•-
Direction of Fire
Hanging
"-.., tomtits
(strip* of
fybberj
j
i
i
i •
',
> .
11 -
t - *,
\
i , | i
__^..^ !
- - *. -
Strips of
iRyi^tjer
of Flr«
!_
Support , '
Frame
CfM»sjifeit0>p
™*
iV
uo
if"
™
m
n
X*
!i:.
-—•
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 regula-
tion.
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
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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 ERA'S interpretations for non-military ranges." In addition, the ERA'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
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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 consid-
ered 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
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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. Ratherthan squeeze scrap metal into eitherthe 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
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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 appli-
cable only to the extent that the lead shot could be segregated from the other materials in
the pile.
I hope that this guidance on the regulatory status of lead shot recovered from 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
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BMP for Lead at Outdoor Shooting Ranges
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
APR 29 1997
Mr. John PCahill
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 clear-
ance 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
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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 ERA'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
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BMP for Lead at Outdoor Shooting Ranges
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Appendix E - Page E-2
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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
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BMP for Lead at Outdoor Shooting Ranges
Table of Contents
J Introduction
Mission Statement
Purpose
Goal
Delete
J 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
J 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
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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
J 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
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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.
- Goa/-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
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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 conduct-
ing 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 member-
ship, and outside consultants, as applicable, in implementation.]
Appendix E - Page E-7
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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 appropri-
ate.]
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 mem-
bership 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
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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 member-
ship, 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 appropri-
ate.]
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
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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 subse-
quent 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
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BMP for Lead at Outdoor Shooting Ranges
FIGURES
Figure 1
Facility diagrams
Figure 2
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
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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:
Skeet Field Layout
."\/ 3 Meter Contours
Dropzones. shp
SL
TL
nn
4/4/2002 DFO
All Oaa Subject
to Revision
Appendix E - Page E-12
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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
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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
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BMP for Lead at Outdoor Shooting Ranges
Appendix B (etc.)
[For other supporting documentation as needed.]
Appendix E - Page E-15
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