June 1, 2018
Establishing an Environmental Stewardship Plan for Firearms Ranges
An Environmental Stewardship Plan (ESP) is a legally compliant management plan meant to conserve our natural resources and sustain our environment. It is a “living document” intended for use as a long-term management tool and should be reviewed, at a minimum, annually and revised as appropriate based on implementation experience. Accordingly, firearms ranges should consider working closely with a qualified Environmental Stewardship Plan services provider to properly execute the range’s own ESP.
An ESP presents a strategy for ongoing environmental stewardship throughout the life of a range, one that’s consistent with the guidance and recommendations of the United States Environmental Protection Agency, the National Shooting Sports Foundation (NSSF) and the Interstate Technology and Regulatory Council.
The purposes of an ESP can include, but are not limited to:
- Documenting environmental actions that have been completed on the firing range
- Documenting the present environmental setting, including upgrades, if applicable, along with previous range maintenance activities
- Identifying issues of potential environmental concern associated with shooting and related lead constituents
- Identifying, evaluating and prioritizing appropriate actions to manage these issues
- Identifying short- and long-term action items and steps needed for implementation
- Developing an implementation schedule
- Identifying ways to measure and document results of management actions
- Providing periodic evaluation of progress toward environmental stewardship goals and appropriate revisions of plans
Best Management Practices to Consider
I’ve written before about the cradle-to-grave lead management process for ranges. These processes will, of course, be a part of your range’s ESP.
As I’ve noted in earlier articles, EPA’s Resource Conservation and Recovery Act (RCRA) assigns cradle-to-grave liability for solid hazardous waste that is not treated and disposed of properly. Because this focuses on the generator of the hazardous waste and tracks that waste all the way to proper disposal, range owners and operators must be aware of “Best Management Practices For Outdoor Shooting Ranges,” an easy-to-read overview of shooting range ESP practices created by the EPA.
Properly managing a firing range can make environmental stewardship and adhering to your ESP easy. Management techniques that should be employed include, but are not limited to:
- Proper and effective bullet and shot containment
- Best management practices to prevent lead migration
- How to best manage your lead impacted waste removal/recycling
- Thorough recordkeeping for all lead-impacted waste
- Human lead exposure standards and monitoring
Outdoor ranges will need a plan to address their unique lead hazards. These can include, but are not limited to:
- pH adjustments or use of EPA-approved range waste treatment technology to prevent lead leaching (MT2’s ECOBOND® is one such technology)
- Creation of physical barriers, including dikes and organic ground covers
- Recovering spent bullets or shot for potential recycling
Your ESP has the potential to save you money and improve the health of your range. With a well-designed ESP, you can implement ways to avoid or lower the costs of the systemic and permanent toxic effects of lead. At the same time, it will help provide safer conditions for your staff and community, and it can reduce remediation and liability with lead reclamation. Best of all, a savvy shooting range ESP can also generate income for the range through EPA-compliant recycling and reclamation of lead bullets, shot and metallic casings.
Does your range have an ESP in place? Need help designing or updating one? NSSF’s team of Range Action Specialists can help.
MT2 Firing Range Services is a leading provider of indoor and outdoor firing range lead reclamation and maintenance contractor. Now in its 18th year, MT2 offers full-scale outdoor and indoor firing range environmental, maintenance and construction services at more 2,000 ranges nationwide and for law enforcement, military and commercial ranges in all 50 states.