The EPA does not require gun ranges to register as generator of hazardous waste under the terms of the RCRA since gun ranges do not generate hazardous material. Individuals contracted to reclaim or remove lead from the site of a gun range are not required to be registered as transporters under the RCRA. The EPA does recommend that gun ranges maintain accurate and credible records demonstrating that the lead from the site was removed.
Gun ranges are only excluded from regulations under the RCRA so long as reclaimed lead from the site is recycled or reused. According to the EPA gun ranges may store lead that is destined for recycling on site in closed containers at a secure location. Ranges are also required to regularly inspect temporary lead containers and maintain records of each inspection.
The RCRA provides the EPA, state governments and private citizens with the ability to sue gun ranges that are a substantial or imminent threat to public health or the environment. The terms of the RCRA allows plaintiffs to compel range owners to clean up their site and recoup legal expenses. Civil suits may be brought against gun ranges whether they are open or closed.
Clean Water Act
Gun ranges that operate near wetlands or bodies of water are also subject to the provisions of the Clean Water Act. According to the EPA's Best Management Practices Guide materials--including shot and clays-that are introduced into a water source protected by the CWA are potential violations. Gun ranges can avoid these violations and the need to register with the EPA by directing lines of fire away from water sources.
- Shotgun Shells image by Bailey from Fotolia.com