January 2, 2018
Lead-Containing Material Disposal Considerations for Firearms Ranges
Shooting range owners and operators retain responsibility for all lead waste and materials derived from their range. This is what is commonly known as “cradle” (generating the potentially hazardous waste) to “grave” (disposal of the potentially hazardous waste) management. In this article, we’ll examine the most critical components of this management.
The Resource Conservation and Recovery Act (RCRA), state and possibly other laws govern the specific responsibilities of the lead waste generator, and these responsibilities are determined by the generator’s “status.” Generator status is not a designation to be fearful of, but you do need to understand your responsibilities and steps to make sure you stay in compliance.
Your status is determined by the amount and type of waste that is generated on a monthly or yearly basis. A comprehensive definition of generators and status can be found in the EPA report titled “Introduction to Generators.”
A basic summary of responsibilities for generators include but are not limited to:
- Determining RCRA Hazardous Waste — To determine where the waste from your range can be disposed, you must first determine if it is hazardous under RCRA guidelines. In almost all circumstances, a toxicity and characteristic leachability procedure (TCLP) test is performed to make that determination. If TCLP testing is not performed, then the waste is automatically considered hazardous waste unless proven otherwise by some other means. (California range owners, please note that a different analytical method applies for testing your facilities’ waste for hazardous status. This link will help those range owners in California understand how a laboratory communicates the rules and testing for lead in their state).
It is important to note that even if your lead waste passes the TCLP test and is determined non-hazardous by RCRA definition, it still may be considered “special waste” by Subtitle D landfills. Such landfills may accept this kind of waste, but usually under a different circumstance than what they provide under municipal services. If you decide to dispose of your TCLP-non-hazardous lead waste via available landfill programs, you must follow their regulations exactly. Never throw this kind of non-hazardous lead waste into the regular garbage.
Note that lead may not always be classified as a waste. It may be a recyclable product after being used on a range. Recyclable materials can be exempt from waste categorization, but the first step is to determine if a material is legitimately recyclable. The material must be evaluated as containing enough lead concentration (greater than 50 percent) by weight and in a form that recyclers can reclaim cost-effectively (typically larger solid parts). Recyclable materials include expended bullets, shot or used brass cases.
- Managing Waste Onsite — At a minimum, all generators must ensure that their lead waste is properly containerized, labeled and staged while awaiting transport to the disposal facility. Additional, simply applied measures can also be implemented.
- Transportation — Only properly licensed and insured transporters should transport your lead waste. If the waste is hazardous lead, then additional hazardous waste transporter requirements will apply. Information documenting a transporter’s compliance with these conditions is recorded on their manifest. If more than one transporter is used, each transporter will sign the shipment manifest separately to document the full transportation history of the waste. You can discover more information on relevant manifests here.
- EPA ID Numbers — Depending on the range location and/or the amount of lead waste generated, a generator may have to obtain an EPA ID number. An EPA ID number provides regulators with the information they need regarding your waste disposal activities. A simple phone call to your state EPA or similar regulatory agency should answer most of your questions regarding your need for this. Keep in mind, if you are required to have an EPA ID number, disposal facilities will also require this number before accepting your lead waste.
It is highly recommended that ranges dispose of their lead waste only with EPA-approved disposal sites. While non-EPA disposal sites may accept your waste, if such a disposal site is cited for EPA violations connected to your lead waste disposal, you as the generator may have to pay for the cleanup of the site where the waste was taken. It’s not hard to imagine that such cleanup and remediation can be very costly.
As you examine your current lead waste management protocols and look for places within them that can be improved, it is worth noting that proper documentation is critical. Once the process is in place, it is very easy to maintain. Throughout the lifespan of your range, you as the generator are responsible for documenting the amount, type, transportation and disposal of the lead waste generated, in other words, maintaining thorough documentation of the entire cradle-to-grave process. Should an unexpected EPA or OSHA audit of your facility occur, or your transporters or disposal facility are found to be in violation, your documentation process can go a long way towards preventing monetary fines (which are often substantial) or other actions that affect your day-to-day operations.
Have questions about your range and your current range management program? Visit www.nssf.org and click on the “Range” heading at the top of the page. There you’ll find numerous resources for today’s firearms range owners and operators, including NSSF’s Range Action Specialists, who can provide on-site consultations. For more information, contact Zach Snow, NSSF Director, Range Services, at [email protected].
MT2 is a nationwide indoor and outdoor firearms range lead reclamation and maintenance contractor. It has served over 1,500 public and private firing ranges in all 50 states since 2000. MT2’s services include complete firing range maintenance and improvements, lead remediation services, lead reclamation, OSHA and environmental consulting, operational maintenance and range closure.