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Discussion Starter · #1 ·
I belong to a small club in northern California. We have 5 trap houses, a skeet field and a small sporting clays layout. We hold three or four PITA registered trap shoots every year and those typically attract 50-60 shooters. The club is open two days a week (Wednesday and Sunday) and has been at its current location for about 25 years.

A representative of the EPA recently visited our club and after looking at the other measures we've taken to alleviate lead entering the environs, determined that shotshell hulls were also contaminated by lead. They are now requiring shooters to remove all spent shotshells from the premises and the club is not able to include them in normal trash as they are now considered hazardous materials. The club would have to pay hazmat fees to remove trash that includes fired hulls.

I would love love to hear from anyone else who's dealt with anything similar.
 

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State or Federal EPA? Right now the Federal EPA is not quite as aggressive under the current administration. As soon as the Dems take over at some point you can be sure the EPA will be used to get of all sorts of things the libs do not like. If this was the feds it would seem this theory about spent shotshells being hazardous would be applied at more than one range in northern California.
 

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I hate to read this, as this would be yet another step towards trying to shut down all shooting sports in California. Best wishes in your proceedings with the EPA.
 

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Several years ago an EPA environmental engineer tackled 'lead' as a range hazard - I have posted his work, and there is a link to the data/info somewhere on TS.com.

His name is Richard Peddicord, and he provided a 'best practices' guide for clubs. Basically he says the lead from a single range is insignificant, but multiply that by the 7,500 ~ 10,000 ranges in the USA and you start to have an issue.

He even produced a 'best practices' document that clubs could use to placate government officials.

I will look for it...

Here is a link to the original discussion here - https://www.trapshooters.com/threads/lead-contamination-gun-ranges.230729/#post-2175760
 

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The EPA's BMP document is silent on range waste, in fact it really only discusses waste lead in terms of containment, collection and disposal. I recall somebody a few years ago was trying to recycle the plastic and metals out of spent shotshell cartridges, but couldn't make a go of it due to the high cost of containment of heavy metals in the recycle waste. I recall a few clubs got some nice HDPE benches in trade for empties before the thing went south.

K
 

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I spent a lot of time dealing with the Fed. EPA, Cal EPA, and dozens of local health agencies, fire departments, and various other environmental organizations while working in the Petroleum Industry through the years. I can tell you from first hand experience that individuals working in these organizations will make up their own rules on the fly. I saw it happen over and over again. And about the only thing a business or individual can do is sue the agency and person that made the rule to show evidence of a law or regulation that has been broken. There is no other way to deal with those groups. I saw it happen hundreds of times. Very frustrating.
 

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There is a settled case law for lead on your property. The lesson is to have some sort of environmental stewardship plan which addresses containment, leaching and remediation. As for hulls etc once you truly to move it to trash different rules kick in. Most state rules are often based on the EPA rules.


Lead-Containing Material Disposal Considerations for Firearms Ranges • NSSF


Questions about the Disposal of Lead-Contaminated Items | Hazardous Waste Treatment, Storage & Disposal | US EPA

https://www.epa.gov/sites/production/files/documents/epa_bmp.pdf


A question you have to answer what amount of lead is in a hull? Similar question is how much lead is in/on a paper target?

How many hulls are you disposing of?

There are options to require your members to take their trash, etc




Sent from my iPhone using Tapatalk
 

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Didn't ask how he found out but our club President in Southern California informed us months ago of the EPA ruling that hulls were hazardous waste. To my knowledge the EPA has never inspected our range, however we are very proactive in safe practices just in case.
 

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I do believe that yes, they would, thanks for alerting them.
As another poster said, the main goal is to shut down all shooting ranges, time will tell.
 

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Discussion Starter · #17 ·
Thanks for all of the info and the links. It's definitely helpful. The club is presently requiring shooters to remove their hulls from the property and I suppose that's the easiest long-term solution.

I just haven't seen this at any of the other clubs in California or Oregon and was wondering if we have someone making requirements up as they go. In the big picture, it seems awfully nitpicky.
 

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At the IWL in Centreville, VA, they had a family-owned company come in and they removed 500,000 lbs. of lead, and paid the club over $14,000 for their share. Don't know how large an area they serve, but maybe somebody out west does the same.
 
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