What Is a Best Management Practice and
How Does It Apply to Shooting Ranges?

A Best Management Practice (BMP) is usually
based on an approach or technology that has
been shown to work and to be effective for the
purpose intended. The United States Environ-
mental Protection Agency (EPA) uses BM.Ps to
specify standards of practice where a regulation
may not be descriptive enough to do so.  A BMP
should also be as inexpensive as possible and the
equipment or technology should be  readily-
available.  A BMP may be adopted based on a
survey of practices (shooting ranges in this case)
that have had successful experiences with an
approach or technology.

BMPs for outdoor shooting ranges are actions
that range owners/operators can take to mini-
mize the impact of lead on the environment.
Lead at outdoor shooting ranges may pose, in
certain situations, a threat to the environment if
BMPs. including reclamation and recycling, arc
not implemented in a timely manner.

What Is the EPA Best Management
Practices for Lead at Outdoor Shooting
Ranges manual?

     The Best Management Practices for Lead at
Outdoor Shooting Ranges manual provides owners
and operators of outdoor rifle, pistol, trap, skeet and
sporting clay ranges with information on lead
management at their ranges. The manual explains
how environmental laws are applicable to lead
management and presents successful BMPs available
to the shooting range community. These practices
have been proven to effectively reduce lead
contamination. Since each range is unique in both the
type of shooting activity and its environmental
setting, site-specific solutions are not provided in the
manual. Rather, range owners or operators may use
the manual to identify and select the most appropriate
BMP(s) for a range. The manual does not address
range layout or design to meet range safety or
competition requirements. It is also not intended for
closing ranges. Range owners/operators are directed
to other comprehensive reference materials available
on that subject, from the National Rifle Association of
America, National Shooting Sports Foundation and
other shooting associations.

     Owners/operators of ranges may want to assign
the implementation of this BMP Manual to a specific
team or committee if possible. Delegating this
responsibility to a specific team or committee helps to
assure that the work gets accomplished.

     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 range physical and
   operational characteristics to be considered when
   selecting a successful BMP program;

   Chapter III addresses BMPs for rifle/pistol
   ranges, trap and skeet 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 Appendix provides current (as of May 2000)
   contacts for lead reclamation and recycling
   companies, other sources of information on lead
   management, bullet trap manufacturers and key
   RCRA regulator}' interpretations.

How Is Lead Shot Regulated  Under the
Resource Conservation and Recovery Act
(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, a RCRA permit is not
required to operate a shooting range. However,
spent lead shot (or bullets) are subject to the
broader definition of solid waste written by
Congress and contained in the statute itself. As
such, spent shot and bullets are potentially
subject to RCRA statutory authority including
section 7002 and 7003.

In general, the following points should serve as
guidance in understanding RCRA and how it
applies to your range.

1. The lead, if recycled, Is considered a
   scrap metal pursuant to 40 Code of
   Federal  Regulations (CFR)
   261.6(a)(3)(ii) and is therefore exempt
   from  RCRA regulation.

2. After the removal contractor or
   reclaimer applies standard BMPs to
   separate the lead from soil, the  soil may
   be placed back  on the range without
   further  treatment.

3. The collected lead shot or bullets are
   excluded from RCRA regulation, and need
   not be manifested, nor

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   does the range need to obtain a RCRA
   generator number (i.e., the range is not a
   hazardous waste "generator"), provided that
   the leadshot is recycled or re-used. The
   transporter does not need to have a RCRA
   I.D. number . However, ranges should retain
   records of shipments of lead from the range,
   and the facilities to which they were sent, in
   order to demonstrate that the lead  was
   recycled.

4.  Sections 7002 and 7003 of the RCRA statute
   allow  the USEPA, states or citizens, using a
   civil lawsuit, to compel cleanup of "solid
   waste" (e.g., leadshot) posing actual or
   potential imminent and substantial
   endangerment.  Such action can be sought
   whether the range is in operation or closed,
   and is based solely on a determination that
   real or potential harm is being posed by the
   range to public health and/or the environment.
   Since the risk of lead migrating increases
   with time,  ranges that have not removed
   leadshot are more likely candidates for
   government action or citizen lawsuits under
   RCRA Section 7003.  Therefore, ranges are
   advised to maintain a schedule of regular lead
   removal.

Benefits  of Lead Management

   Lead removal and implementation of other
   BMPs will allow the range to: minimize
   contamination of the range and potential
   impacts to human health and the
   environment; reduce liability with regard to
   potential agency or citizen lawsuits; possibly
   benefit economically from the recycling of
   lead; enhance its role as a good steward of
   the environment; and increase customer
   satisfaction.
Want More Information?

       For a copy of the USEPA Best
Management Practices for Lead at Outdoor
Shooting Ranges, please complete the informa-
tion below and fax or mail to:

      Leadshot Coordinator
      RCRA Compliance Branch
      U. S. Environmental Protection Agency
      Region2
      290 Broadway- 22nd Fl.
      NewYork,NY 10007-1866
      Fax: (212)637-4949
      E-Mail: LeadshotRegion2@epa.gov


The manual will also be placed on the world
wide web at www.epa.gov/region2/waste/
leadshot.
Name:
             United States Environmental
             Protection Agency - Region  2
                          EPA-902-F-00-001
Do You Use  Best  Management
Practices for Lead at Your
Outdoor Shooting Range?
Address:
Phone:

                                                                                                    Cover photo by: Mr. Jack Hoyt

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