June 23, 2017
How to Manage Your Lead Reclamation — Part I
Lead, as almost everyone knows, is a hazardous material, capable of causing harm to human health or the environment if not responsibly handled. How shooting range owners dispose of their lead is crucial to their operational planning, OSHA and EPA compliance, the environment and the health of their staff and customers. The following guide will focus on defining lead-contaminated and solid lead waste commonly found at firing ranges and how to appropriately manage their disposal.
What is My Lead Waste?
As a shooting range owner or operator, you must identify the types of lead-impacted waste, or “waste streams,” to be managed. Lead-contaminated waste generated during firing range activities can be roughly categorized into two waste streams:
- Recycled Lead — This is material that contain lead of sufficient quality and quantity to have commercial value and can be sold to others. Bullets or bullet fragments recovered from range traps are often considered recyclable. Curiously, recycled materials are not actually considered “waste,” but serious considerations must be made when determining what is considered recyclable, and how best to manage your recycling program. This is a very serious topic to understand as it is the responsibility of the range owner/operator to comply with all applicable laws and regulations.
- Lead-Impacted Waste — This is waste that likely or potentially contacted lead. Typical lead-impacted waste often includes: used personal protective equipment (PPE), such as gloves, suits and tape, as well as used granular rubber, fine particulates from granular rubber; cleaning materials used on the range; filters; and other general waste items such as paper or wood particles that are left behind. This waste must be considered Resource Conservation and Recovery Act (RCRA) hazardous waste unless proven otherwise through a Toxicity Characteristic Leachability Procedure (TCLP) test that determines if the waste is considered RCRA hazardous or RCRA non-hazardous waste (more on this later). TCLP results can vary by the type of waste being tested but, in general, most ranges generate one or more types of hazardous waste during normal firing range operations.
There is one other type of lead-related waste that range owners need to consider. Once a material is no longer being used for its intended purpose, it is considered a waste. That may sound simple, but the term “intended purpose” is a very important concept to understand, because when it comes to lead management on shooting ranges, it’s about more than just the physical solid lead waste.
Consider, for example, timbers being used as a retaining wall or granular rubber or other such materials used for backstop construction. Lead from bullets may contaminate those materials, so are those materials then considered waste? Not when they continue to be useful for their intended purpose. Where a potential issue does exist is when those structures are relocated or removed.
Let’s say you repurpose those timbers or backstops for some other use on your range. In that case, they would still commonly be seen as being used for their intended purpose. However, if they are removed and simply set aside, these items are not being used for their intended purpose any longer and may be considered hazardous waste.
Lead Waste Management and Disposal
The transportation and disposal of hazardous materials such as lead is covered in the Resource, Conservation, and Recovery Act — in other words, you can’t just throw your lead waste into the dumpster! This may seem obvious, but there are too many documented cases where this has happened and severe consequences followed. You must also follow your local, state and other federal regulations.
We’ll cover how to work properly within these many and complex guidelines in subsequent articles, but should you 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 a number of resources, 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 leading nationwide professional firing range lead reclamation and maintenance contractor for both indoor and outdoor ranges and has served over 1,400 public and private firing ranges in all 50 states since 2000. MT2’s proven record of services includes: complete firing range maintenance and improvements, lead remediation services, lead reclamation, OSHA and environmental consulting, operational maintenance and range closure. The author of this article, James M. Barthel, is the company’s CEO.