It is estimated that over 125 gun clubs exist throughout the state of Pennsylvania. Many of these gun clubs are experiencing a surge in popularity and membership, but some are also facing challenges as suburban development increases around them. One example is the question of what is required by environmental regulations with regard to management of spent lead shot at outdoor gun clubs? At present, the environmental regulations for how to manage lead shot is somewhat undefined which can create a frustrating situation for gun club owners.
A potential option.
One approach to handling spent lead shot is to reclaim it from the soils in the range and sell it. Many outdoor gun clubs have done this already through the use of specialized 3rd party contractors. Recent metal prices typically support this approach – and depending on the salvage revenues from the reclaimed spent lead shot – it may be possible for the effort to largely finance the reclamation process for the gun club.
Great idea but are there any downsides?
One possible obstacle is the unclear status of gun clubs and how they are governed by current environmental regulations. Specifically, there is confusion on what exactly are the appropriate environmental regulations that govern potential environmental impacts from lead shot.
Other conditions adjacent to outdoor ranges could also complicate lead shot reclamation activities. For example, the U.S. Courts have weighed in on some cases when a wetlands or a stream are located next to the shooting range.
Moreover, it is possible different government agencies (even within Pennsylvania) may view a lead reclamation project at a gun club very differently – and require that they be included for seeking authorization from their agency for a lead reclamation project.
Taken together, this has led to much uncertainty and varying experiences by gun club owners as they seek to execute a lead shot reclamation project.
Is lead shot considered a hazardous material?
It depends on how the materials are “used”. According to the U.S. EPA, lead shot is not considered a hazardous waste subject to Federal RCRA laws because of its use with a firearm. However, spent lead shot (or bullets) are subject to a broader definition of solid waste written by Congress. But if the lead is recycled, it is considered a scrap metal pursuant to RCRA regulations.
The US EPA has indicated that if lead shot is removed from an outdoor range and the remediation applies standard Best Management Practices to separate the lead from the soil, then the soil may be placed back on the range without further treatment.
While there is variability with each project, care should be taken by the gun clubs owners when pursuing a spent shot reclamation project to ensure they have addressed what state and local (and perhaps federal) regulations/permits would need to be satisfied for their situation. We have assisted in navigating other gun club owners through spent shot reclamation projects in the past and would welcome the opportunity to field any questions you may have for your particular situation.