Memo Detail

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RCRA Online Number: 14070
Title: REGULATORY STATUS OF LEAD SHOT
Document Date: 1997-03-17
To: Campbell
From: Hannapel
Organization of Recipient: EPA
Description: A mixture of spent lead shot and gunpowder may be ignitable. Discusses the regulatory status of lead shot. Discharge of ammunition or lead shot is in the normal and expected use pattern of the product and does not constitute hazardous waste disposal. Ammunition, rounds, expended cartridges, and unexploded bullets that fall to the ground are not discarded (SEE ALSO: 62 FR 6622; 2/12/97). Lead shot may be considered scrap metal, not spent material, and exempt from regulation when recycled. The exemption extends only to the lead shot portion of the waste.
Regulatory Citation(s): 261.21, 261.6(a)(3), 261.2
Official ORCR Policy: Yes
Associated Topic(s): Characteristic Wastes, Disposal, Hazardous Waste, Hazardous Waste Recycling