Critical Gun Range Operational and Waste Management Requirements – Discussion with Nationally Recognized Experts to Take the Worry Out of US EPA RCRA Compliance for Your Firing Range.
LEAD MANAGEMENT BEST PRACTICES– HOW TO COMPLY WITH US EPA RCRA & STATE REQUIREMENTS.
- US EPA and State RCRA authority review
- Turnkey range waste generation lifecycle
- Requirements if Small Quantity Generator
- Management of recyclable lead
- Hazardous vs Non-Hazardous range wastes
PRESENTATION BY: ROBERT ANDERSON
My name is Robert Anderson, The easy way to look at it is is of course lead. We’re talking about more than lead. But, lead is the easy culprit and it’s the easy way to keep the discussion going.
So, when we are talking about lead in OSHA, you’re talking about protection of the employee. When we’re talking about lead in RCRA, we’re talking specifically about your waist. So, again, I’m going to give a brief introduction into RCRA and range waste.
I was actually driving in this morning and heard an interesting, a new item that actually related to this. So, in 1969, many of you will remember, the Cuyahoga river in Cleveland catching on fire. This is right around when Nixon was coming into office. And really brought to the nation’s attention a lot of environmental concerns across the country. In fact, Nixon used up more than one quarter of his inaugural speech to talk about protection of the environment.
Shortly thereafter, in 1970, we have OSHA. In 1970, we also had the EPA. 1972 was the Clean Water Act. The Clean Air Act started in 1963 but officially got updated in 1970 and I believe again in 1977. And then a little bit later you have RCRA. Now, it’s a little sad because with the Clean Water Act, it’s clearly, you understand what they’re talking about. Clean water. With the Clean Air Act, clearly, you’re talking about clean air.
RCRA, which we will go into the description here, is a little bit more vague and I’m starting with the name but it’s the Resource Conservation Recovery Act. If you’re writing down in your cheat sheet, RCRA equals waste is the easiest way to look at it. The most important thing to note is that RCRA is applicable to all states, it’s a federal rule, it’s a federal regulation. But it is a federal program that mandates that all states comply within equal or better program.
I bring this up because some of you may be in states that have an enhanced program and there may be additional rules and regulations that could apply. Every state will adhere to RCRA but some may have additional considerations. The largest example but not the only one is California. If you are in the state of California and you want some more information on that, please feel free to reach out to me.
The next discussion we have is on probably what I would say the most important question. And this is the question that most often never gets asked. Is it a waste? When people ask me about waste on their sites, particularly in firing ranges, this is the first question I ask them. And what I normally walk them through is the ITRC Guidance Documents. I find this is great, this is not a regulation, it’s a guidance document. But the beauty of the ITRC Guidance Document is that this document basically provided guidance on how to properly manage your range with respect to environmental issues.
Meet Robert Anderson:
Vice President Range Operations Services MT2 Firing Range Services
Qualifications Summary Mr. Anderson has over 20 years’ direct hands-on experience managing a wide variety of hazardous wastes and specifically in implementing RCRA compliant programs at over 1,000 ranges from the East Coast to the West Coast and in nearly all 50 states. His extensive RCRA Hazardous Waste experience includes handling over 1,000,000 tons of lead-impacted firing range wastes from regular maintenance activities involving filters, cleaning, maintenance, as well as from remediation involving renovation, soil treatment, and range decontamination. He has managed lead containment and recycling at nearly 1,000 firing ranges successfully handling over 3,000,000 lbs. of lead recycled in just the last 4 years alone. Mr. Anderson is highly sought-after for his firing range lead waste expertise from Federal/State, Governmental Agencies and local gun clubs including but not limited to: U.S. National Guard, U.S. Coast Guard, U.S. Air Force, U.S. Pentagon, U.S. Capitol Police, U.S. Border Patrol and police ranges from Seattle to New York City. In addition, he has specific expertise in managing small-quantity wastes from public local gun clubs in nearly all 50 states.
And as it said, it was a coalition of industry experts. It included regulators, firing range operators, and people such as me, not technically me but people such as myself, involved with those that understand the regulations and how to apply it. After going through this and discussing the ITRC Guidance with my clients, the first thing I recommend to them is that they read this document. It’s a great starting point. It won’t touch on every topic that you’re going to want to discuss but again, it gets you in the right frame of mind to discuss how to manage your site and how to manage your waste.
And for today, on the ITRC Guidance Document, I want to focus specifically on two terms. The first term that we have is intended use. Write that one down. The second one we have is best management practices or BMPs. So I’d like to speak first unto intended use and I know everyone is watching the slide show and listening. What I would like you to do for a moment here is close your eyes and let’s talk about the most basic concept that we’re talking about here. That’s the bullet. You are now the bullet. You are part of a bullet. Bullets are button sold, bullets are a commodity. Commodities are not waste, we’ll get more into that later.
Now, pick out your favorite gun, you all have a different type, I know. I’m sure you’re murmuring to yourselves what that might be. Now, that bullet gets fired through that gun to a berm. Let’s say you’re on a standard 25 yard lane, traveling down the range, entering in a few milliseconds down into let’s call it a sand trap or a dirt berm. While you were traveling as that bullet through the air, that is the clearest definition of something being used for its intended used. You were being shot through the air, you were being aimed at your intended target, sometimes better for some other than most. And eventually, you hit that dirt berm.
That’s an easy answer for a description of intended use. So let’s take it a little bit more in depth and a little more complicated. Now, you’ve hit that dirt. The bullet has fragmented. Small portions of that bullet have now entered into that dirt. What is that dirt? It contains lead, does that mean that, oh my goodness, it’s hazardous? The answer is no. Why? Because you have to go back to the discussion which the ITRC Guidance Documents will help you. And that that dirt, in itself, is being used for its intended purpose. That dirt is there to be shot into. Therefore, that dirt is not a waste.
Now, there are some complications to this discussion. And the most important to think about is BMPs or Best Management Practices. These are measures taken by range operators to properly manage their ranges in an environmentally compliant manner. Again, I refer to the ITRC Guidance Documents which will give you some good examples of Best Management Practices, commonly used for outdoor ranges. I’d like to see some more for indoor. We’re working towards that.
And Best Management Practices are what I would say several options that range owners can use to mitigate the effects of predominantly lead but other items which we’ll get into on how to manage these items within the perimeter of the range so that they’re not impacting the surrounding environment because that’s what the regulators are going to be paying attention to.
If you’re an active range and you’re properly managing the materials on your range, it’s not a big issue. But when they start seeing mismanagement or non-management of your ranges is where you’re going to start raising some red flags. So, at any firing range this can refer to bullets and target stands.
I’d like to give a few more example. Let us talk about a few more scenarios on how intended use and BMPs help define if we have a waste or not. At any firing range, this can refer to bullets or target stands or perhaps the wood that you shoot into. There’s a lot of different items that this could apply to. So your next scenario, outdoor range with dirt. Well, we just talked about the dirt. Is the dirt a waste? No, it’s being used for its intended purpose. Is the bullet waste? Go back to the bullet? Not as long as BMPs are properly adhered to.
This is a lot of times when experts will refer to you as lead-reclamation. Removal of that point source to the bullet to mitigate the damage that that bullet has over time on the site. Let’s do another scenario. Now, it’s the exact same range but you’re shooting into a rubber trap. Doesn’t matter. Is that rubber being used for its intended purpose? Yes. Is that rubber contaminated. It probably contains lead. But is it a waste? No.
Another scenario. Old back stop soils move to another location. Little bit different. I think any of you that have managed an outdoor range have probably been underneath this scenario. You shoot for a while into your range, you realize that the material you’re shooting into is probably not the best quality of stuff. Maybe you get some ricochets or some skips or flips over your berm. Hey, let’s put some better stuff in there. You know what we should do? Let’s take the old stuff and move it out. Okay. Where you put that old stuff may determine whether or not that material is considered a waste or not. This is very important.
Is it a waste? We have to ask, has it left the footprint of the active range? Is it no longer within the area of control of the BMPs? This is an area where a lot of ranges have gotten into trouble. A material that leaves your active range can be considered abandoned and once it’s considered the abandoned the regulators will say it’s considered a waste.
Another example is bullets that leave your range. A lot of mitigation comes around this when we have encroachment on residential areas for a range that’s been there for 50 years. The reason why a lot of these ranges have a challenge of staying open isn’t so much of protecting their site. A lot of times it’s because they have bullets that left their range, landed on another home owner’s property. Guess what. That’s considered waste. That is not within your area of control, it is another’s property and this is something that you have to be very careful for.
I’m not going into any further discussions of no blue skies but obviously, that’s why they have that implemented. And then we go back to BMPs. Improperly or not implementing BMPs. This is one of the biggest challenges that ranges have, mainly because implementation of BMPs can vary from site to site. Materials that are on site can be considered abandoned and therefore a waste.
And again, if we go back to the discussion of the bullet flying through the air, we discussed the dirt, we talked about the bullet, and the best gauge of BMP guidance that I say for reclamation is to successfully minimize lead migration.
The most important BMP for lead management is:
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