SHOOTING RANGES - ENVIRONMENTAL REGULATIONS AND BEST MANAGEMENT PRACTICES

Hazardous Waste Program fact sheet
02/2016
Division of Environmental Quality Acting Director: Steve Feeler
PUB2450

This fact sheet covers some of the requirements and best management practices to open, operate and close a sporting/target shooting range in an environmentally responsible manner.

The information provided does not cover ranges where atypical military/paramilitary ammunition, such as depleted uranium, tracers or other special purpose or explosive ordnance, have been used.

Questions regarding any of these ranges should be directed to the Hazardous Waste Program.

What are the concerns?
A primary environmental concern at shooting ranges is lead contamination in soil and ground and surface water as a result of spent lead left exposed. Under the right conditions, lead can dissolve and seep into the environment. Exposure to the contamination can harm people and wildlife.

Some types of ammunition can also release other toxic metals, such as mercury, into the environment. Corrosive mercury-based primers are found in many types of old ammunition as well as vintage military surplus ammunition.

Additionally, the construction or operation of a shooting range could impact waterways and cause runoff of soil and other sediments.

Depending on the size and design of the shooting range, there could be state and local drinking water and wastewater requirements.

Environmental Requirements
Hazardous Waste
No permits are required under Missouri’s Hazardous Waste Management Law to construct or operate a shooting range.

The Missouri Department of Natural Resources and U.S. Environmental Protection Agency (EPA) do not consider shooting ammunition to be a waste generating activity. Many normal range maintenance activities, including the reclamation of scrap metal, are not regulated as hazardous waste management.

So, any contamination occurring on shooting ranges, as a result of shooting, is not considered abandonment unless the range is closed or goes through a cleaning activity involving the generation disposal or discarding of expended shot, which would include bullets, shot, shells, fragments and contaminated media.

The department does recommend using lead best-management practices at shooting ranges. Regularly removing lead from the shooting range not only protects the environment, but can also help protect the owner from any future liability as a result of remaining contamination. Refer to the Best Management Practices section of this fact sheet for more information about lead management at shooting ranges.

Hazardous waste requirements for closing a shooting range are listed in the What If I Want To Close the Range? section of this fact sheet.

Water
Land Disturbance Permits
A land disturbance permit form E (MO 780-0795) and form G (MO 780-1408) will be needed to be completed and submitted to the department if proposed construction disturbs an area of land one acre or greater. This is the most likely permit you will need from the department and may be terminated as soon as the soil is stabilized (such as with vegetation, concrete, etc.) The permit will need to be acquired prior to any earth work. For questions about these permits contact the Water Protection Program at 573-751-1300.

Clean Water Act Permits
If placing material or fill into jurisdictional waters, Clean Water Act Section 404 and Section 401 permits will be needed. Examples of activities requiring permits and certification include culverts under road crossings, riprap along stream banks and stormwater outfall pipes. The term “jurisdictional water” refers to large lakes, rivers, streams and wetlands, including those that do not always contain water. For jurisdictional waters or Section 404 Permit information, contact the Army Corps of Engineers, Kansas City District at 816-389-3990. For Section 401 certification information, contact the department’s 401 Certification Unit at 573-751-1300.

Drinking Water System
Will the shooting range serve water to the public? If so, the facility should connect to an existing public water supply or construct its own well. The department has guidelines for transient, non- community public water systems available online. A transient, non-community public water system includes a facility that is not a community water system that regularly serves an average of at least 25 individuals daily, at least 60 days out of the year and does not purchase water from another public water system.

A transient, non-community public water system must apply in writing to the department’s Public Drinking Water Branch for a permit to dispense water to the public. Any well used to dispense water to the public must be constructed in accordance with the fact sheet Standards for Noncommunity Public Water Supplies (PUB 979). The well would also be subject to all Safe Drinking Water Act requirements, such as regular monitoring.

Sewer System
If you choose to construct restrooms at your shooting range, consideration must be given for wastewater disposal. If a sewer system is available and will only require the construction of a lateral to the sewer main, a permit from the department is not required. However, you will likely need to obtain a sewer tap permit from the utility.

If a utility must extend a sewer main to provide service to your property, a sewer extension construction permit would be required. Permits for sewer extensions are typically obtained by the utility.

On-site Treatment of Wastewater
If area sewers are not available, wastewater treatment will need to be provided at the site. If the amount of wastewater produced is less than or equal to 3000 gallons per day and a no discharge system that disposes of the wastewater through a subsurface disposal system is feasible, sewage disposal would be regulated by the Department of Health and Senior Services. In this case contact should be made with the local health department.

If wastewater will be treated with a discharging system, or if the design will be for greater than 3000 gallons per day, a facility plan prepared by a registered professional engineer should be submitted to the department. After the plan is approved, a construction permit application and plans and specifications are submitted. Construction can begin after a construction permit has been issued. An operating permit will be required upon completion of construction and before the treatment system begins operation.

Solid Waste
All the waste generated from the construction of any facilities at the site must be recycled, reused or taken for proper disposal at a permitted landfill or transfer station. No waste may be buried on-site, except for certified clean fill. Certified clean fill includes: uncontaminated soil, rock, sand, gravel, asphaltic concrete and unpainted concrete, cinder blocks and brick.
Clean fill must not contain protruding metals or construction/demolition waste. The department’s fact sheet Managing Construction and Demolition Waste (PUB2045) provides additional information.

Other Environmental Requirements
Burning Of Vegetative Wastes
Vegetative wastes from land clearing activities may be burned, provided the burn site is not located within an incorporated area or within 200 yards of an occupied structure. If these conditions cannot be met, issuance of a burn permit with site specific conditions may be an option. Permits are required in the St. Louis, Kansas City and Springfield metropolitan areas. Burn permits are issued by the department’s five regional offices. Contact information for the regional offices is provided below.

Best Management Practices
Even if an environmental permit is not required, the department encourages anyone opening or operating a shooting range to follow EPA’s Best Management Practices for Lead at Outdoor Shooting Ranges. Following these practices can help control and contain any contamination.

EPA recommends four main steps to operate an environmentally protective shooting range:

EPA’s Best Management Practices for Lead at Outdoor Shooting Ranges provides detailed information for each of these steps.

Open burning or dumping of target materials is not allowed. Typically, this waste is considered non-hazardous waste and must be properly disposed of through a trash service (for disposal at a permitted landfill or transfer station) or recycled. The department’s fact sheet Facts on Open Burning Under Missouri Regulations (PUB2047) provides additional information about open burning.

Following these steps can not only help protect the environment, but can help ensure if you want to close the shooting range, there will be fewer environmental issues needing to be dealt with.

What if I want to close the range?
It is possible contamination may be in place at a shooting range. And, it is possible any remaining contamination may make some sort of cleanup necessary.

If contamination is present, you may be subject to the Missouri’s hazardous waste management laws and regulations. You would also likely be subject to the federal Resource Conservation and Recovery Act or CERCLA (hazardous material release or potential release).

If you excavate contaminated soil or generate contaminated waste (e.g., sandbags, backstops, targets), you need to determine if the soil/waste is hazardous. EPA's Typical Wastes Generated by Industry Sectors explains this process. If it is hazardous waste, you will need to comply with Missouri’s hazardous waste requirements. These requirements are outlined in the following department publications:

If it is not hazardous waste, these materials would likely be considered solid wastes and their beneficial use, management or disposal would be governed under the Missouri Solid Waste Management Law and regulations. Excavation and demolition activities will require a land disturbance permit if more than one acre is disturbed, as described above.

If you let any potential contamination remain on the property, there could be Clean Water Act and Comprehensive Environmental Response, Compensation and Liability Act, often referred to as Superfund issues. Additionally, any modification or redevelopment of the property with potential contamination could trigger a variety of other environmental issues. The department’s Brownfields/Voluntary Cleanup Program can help properly assess any environmental concerns on the property and development.

Additional Information

Air Pollution Control Program

573-751-4817

cleanair@dnr.mo.gov

Brownfields/Voluntary Cleanup Program

573-526-8913

missouribrownfields@dnr.mo.gov

Hazardous Waste Program

573-751-3176

hazwaste@dnr.mo.gov

Solid Waste Management Program

573-751-5401

swmp@dnr.mo.gov

Water Protection Program

573-751-1300

cleanwater@dnr.mo.gov

Regional Offices
Kansas City Regional Office


816-622-7000

 

Northeast Regional Office

660-385-8000

 

St. Louis Regional Office

314-416-2960

 

Southeast Regional Office

573-840-9750

 

Southwest Regional Office

417-891-4300

 

For more information contact:
Compliance and Enforcement Unit
800-361-4827 or 573-751-2032

Additional Information
Brownfields/Voluntary Cleanup Program Web page http://dnr.mo.gov/env/hwp/bvcp/hwpvcp.htm
EPA's Best Management Practices for Lead at Outdoor Shooting Ranges http://www.epa.gov/lead/best-management-practices-lead-outdoor-shooting-ranges
EPA's Typical Wastes Generated by Industry Sectors http://www.epa.gov/hwgenerators/typical-wastes-generated-industry-sectors
Facts on Open Burning Under Missouri Regulations (PUB 2047) http://dnr.mo.gov/pubs/pub2047.htm
Form E Application for General Permit Under Missouri Clean Water Law (MO 780-0795) http://dnr.mo.gov/forms/780-0795-f.pdf
Form G Application for Stormwater Permit Under the General Permit: Land Disturbance (MORA and MOR100) (MO 780-1408) http://dnr.mo.gov/forms/780-1408-f.pdf
Hazardous Waste Management Handbook for Small Quantity Generators (PUB 2174) http://dnr.mo.gov/pubs/pub2174.pdf
Making a Hazardous Waste Determination (PUB 919) http://dnr.mo.gov/pubs/pub919.htm
Managing Construction and Demolition Waste (PUB 2045) http://dnr.mo.gov/pubs/pub2045.htm
Management of Conditionally Exempt Small Quantities of Hazardous Waste (PUB 128) http://dnr.mo.gov/pubs/pub128.htm
Regional Offices http://dnr.mo.gov/regions/index.html
Standards for Noncommunity Public Water Supplies (PUB 979) http://dnr.mo.gov/pubs/pub979.pdf