EMERGENCY RESPONSE & SPECIAL PROJECTS BRANCH EMERGENCY RESPONSE PROGRAM Drug Labs Removals. ...

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EMERGENCY RESPONSE & SPECIAL PROJECTS BRANCH

EMERGENCY RESPONSE PROGRAM

Drug Labs Removals.

Off-highway Removals.

Time Critical Removals

Coordination with Other Emergency Response Agencies (Law, Fire, Health, and Environmental Health)

PROGRAM OBJECTIVES

Provide direct contractor and technical support for emergency removals (Clan Labs and Off-highway).

Provide Departmental resources during major emergencies.

Promote interagency emergency response coordination

Duty Officer System (one system, all ER programs!)

Receives requests for ER assistance

Determines appropriate level of ER response

Establishes contractor scope of work

Obtains contractor cost estimate

Authorizes contractor to respond

Only person with authority to direct ER contractors

Coordinates ER field response and multi-agency response at complex sites

ACCESSING DTSC CONTRACTORS

WHO CAN ACCESS?

Any State or local law enforcement agency representative responding to an illegal drug lab site.

Any public agency representative responding to an abandonment of hazardous substances or other emergency situations involving hazardous substances.

HOW TO ACCESS DTSC ER Business hours, 8 - 5

Monday - Friday, call: (800) 260-3972 or (916) 255 6504

After hours, holidays or weekends, call the State Warning Center at:

(800) 852-7550

Ask for the DTSC Emergency Response Duty Officer, leave your name, cell and pager #.

What do I need to know and get?

What was found during the investigation (e.g. inventory of wastes/haz substances).

Get the tracking # issued by the Duty Officer (YYYY-MM-###) and the EPA ID #.

Request a phone number where you can reach the Duty Officer.

DTSC ER Funding Criteria

Materials at site must meet the definition of a hazardous substance

FlammabilityCorrosivity (pH<=2

or pH >= 12.5)ReactivityExplosivityToxicity

Assessment of inventory, chemical ID

Abandonments and dumps also funded

DTSC ER WILL NOT FUND

Solid Waste Waste oil Diesel fuel Petroleum fuels, unless

used as solvents Infectious waste, with the

exception of sharps Small quantities of

common household commodities

Propane tanks with or without propane.

Cleanups of sites that are otherwise subject to federal jurisdiction (i.e., DEA).

Removals from tribal lands or reservations.

Remedial action costs, i.e., extensive soil cleanup, removal of solid waste & structural appurtenances.

Non-hazardous waste otherwise subject to seizure.

DTSC CONTRACTORS

DTSC contractors are not first responders.

DTSC contractors are Level A capable.

DTSC contractors are dispatched only by the DTSC Emergency Response Duty Officer.

FIELD PRACTICES

Rule #1: Be Safe Rule #2: Call DTSC before

you Haul Rule #3: If in doubt, ask

CLANDESTINE DRUG LABS

FY 95/96 965 Labs; Budget = $1.4 Million FY 96/97 1565 Labs; Budget = $5.1 Million FY 97/98 1599 Labs; Budget = $6.0 Million FY 98/99 2006 Labs; Budget = $7.2 Million FY 99/00 2095 Labs; Budget = $7.2 Million FY 00/01 2107 Labs; Budget = $7.2 Million FY 01/02 2205 Labs; Budget = $6.5 Million FY 02/03 1723 Labs; Budget = $6.8 Million FY 03/04 1192 Labs; Budget = $6.5 Million FY 04/05 799 Labs; Budget = $6.5 Million FY 05/06 584 Labs; Budget = $6.5 Million

DRUG LAB REMOVAL STATS

Clan Lab Cleanup Program

Historically, lab cleanups were conducted by State and local law enforcement agencies.

State Legislature passes law to give Cal/EPA’s Department of Toxic Substances Control responsibility to conduct clan lab removal actions upon request by state and local law enforcement agencies. DTSC initiated program July 1, 1995.

Uses the same Duty Officer system to access.

Clan Labs Are Dangerous!Acute threat to human health and the

environment Strong Acids: Hydriodic Acid, Hydrogen

Chloride Gas. Strong Bases: Sodium Hydroxide (Red devil

lye) Red Phosphorus and phosphine gas Methamphetamine Solvents (Freon, White Gas) Fire and Explosion hazards

Who is Involved &Where Does DTSC fit in Investigative (Law Enforcement) Investigations Support (Evidence

Collection, CPS) First Responder ER (Local Hazmat

teams) Fire Suppression (Fire) Assessment (Law, Health, Fire) Support (Animal Control, Ag Inspector,

Fish & Game, Water Resources...) ER Removal (DTSC, Contractor) Remediation (Health, Property Owner)

Where are the Labs?

…In the Kitchen!

In the Bathroom!

…in the closet….

……in the yard…..

……in barns/sheds

….Everywhere

STEPS BEFORE CONTACTING DTSC

Secure the Lab Site Maintain site control and limit site access

even during removal. (Minimize exposure, enhance safety)

Conduct a thorough risk & hazard assessment.

Resolve any evidentiary collection issues (DTSC contractors do not collect evidence).

Prepare an inventory of wastes. Make appropriate notifications. Request support from the DTSC Duty Officer.

SITE ASSESSMENT

Perform prior to requesting a DTSC ER removal action. Assessment includes: All the operational areas of the

laboratory. All storage areas and possible

hidden caches of chemicals; All waste streams and disposal

routes (pits, trenches, septic, waterways, off-site).

SITE ASSESSMENT CONCERNS

A complete lab site assessment is needed to ID haz. substances.

Lab assessment may require specific knowledge of chemical incompatibilities.

On-site stabilization may be required.

Need help, call duty officer.

HANDLING CONSIDERATIONS Wastes should be segregated by

hazard class whenever possible. Identify leaking containers and

contain spills. Exercise caution when evaluating

or handling compressed gas cylinders.

Develop contingencies for on-site stabilization, if and when necessary.

CONTRACTOR CAPABILITIES

Separation (i.e., phase Separation (i.e., phase separation)separation)

Neutralization (Not For HI)Neutralization (Not For HI) Product transfersProduct transfers Pressure releases/venting Pressure releases/venting

(Cylinders)(Cylinders) Thermal controls (icing & Thermal controls (icing &

cooling)cooling) Solidification (Render useless)Solidification (Render useless) Surface decontaminationSurface decontamination

SOME COMMON LOGISTICAL PROBLEMS

Requests for DTSC ER support are made prematurely - before the initial lab assessment is complete.

Disposal pits may be overlooked or not reported.

DTSC contractor has to wait on site for criminalist to complete evidentiary sampling.

DTSC contacted days after enforcement action at the lab site is completed.

OTHER IMPORTANT FACTS

DTSC ER support is not a reimbursement program.

This Program does not provide for evidentiary collection or storage.

If responding in support of law enforcement, the requesting agency is responsible for maintaining site security until the removal is completed.

COMPRESSED GAS CYLINDERS

Specification CylindersSpecification CylindersNon-Specification CylindersNon-Specification CylindersCompromised CylindersCompromised CylindersAcid-Gas GeneratorsAcid-Gas Generators

Compressed Gas Cylinder Issues

Handling gas cylinders requires specialized technical expertise. There is a definitive need for a

unified command between law, health and/or fire (hazmat).

Emphasis Emphasis mustmust be placed on be placed on public public health and safety.health and safety.

MITIGATION OPTIONS

Inclusion of Fire and Health Depts. in decision making is recommended.

On-site controlled release, venting into water (sparging) or neutralization.

DTSC contractors must respond with a minimum of four personnel.

Cylinders or valves may have to be cut

MITIGATION OPTIONS – Off-site relocation of cylinders Emergency relocation of cylinders

may be required. Have plan developed prior to

relocating cylinder (have a Plan B) Local Fire, Law, and Health must

consult in developing the plan. Relocation of the cylinder must be

conducted with a law enforcement escort.

MITIGATION OPTIONS(Bomb Squad)

For catastrophically compromised cylinders, the services of a qualified bomb squad will likely be needed.

Talk to them before you need them.Know their capabilities and

experience with compressed gas cylinders.

And be aware of HCl hazard.

MITIGATION OPTIONS(Coffins)

Utilization of cylinder coffins should not be counted upon as a quick option for relocation of a cylinder.

None of DTSC’s ER contractors own them.

There are too few of them to depend on them being available.

DOCUMENTATION

DTSC Clandestine Laboratory Removal DTSC Clandestine Laboratory Removal Incident Report Incident Report

DTSC Clan Lab Removal Work LogDTSC Clan Lab Removal Work Log Copy of Hazardous Waste ManifestCopy of Hazardous Waste Manifest Mail to DTSC especially if there are Mail to DTSC especially if there are

problems with the DTSC contractor.problems with the DTSC contractor.

IN REVIEW DTSC Duty Officer: Receives requests for

assistance. Determines if request meets

funding criteria. Establishes contractor scope-

of-work. Obtains cost estimate for

response from DTSC contractor.

Issues the DTSC number for the incident (YYYY-MM-XXX)

Issues USEPA ID# for hazardous waste manifest (CLU 111 111 0XX).

Only person that has authority to direct DTSC contractors.

Dispatches contractor to the site.

Questions & Comments

For More Information Contact:

DTSC Sacramento 916-255-6504

OFF-HIGHWAY HAZMAT

H & S Code Section 25354

“...taking immediate corrective action to remedy or prevent an emergency resulting in a fire, explosion of, or human exposure to hazardous substances caused by release or threatened release...”

What does this have to do with my job?

During the normal course of your core business, you may find a hazardous substance release

situation that warrants emergency response actions to protect public

health and/or the environment.

Manner of Discovery

Happenstance discovery during an unrelated inspection or the like.

Discovery in the course of responding to a fire, explosion or odor complaint.

Encountered as the target of an investigation by an enforcement agency.

WHAT YOU MAY FIND

ABANDONED WASTE

COMPROMISED MATERIALS

Misc. Hazardous Substances

DTSC Off-Highway Reponses

Funded by the General Fund

Currently, $874,000/yr for entire State .

Verbal contracts – only for actions <$10K when unique support services are needed

Program Implementation

State provides removal action to minimize acute threats.

Multi-discipline and agency coordination is critical.

Local health agencies responsible for determination of further remedial action.

Call us first; DTSC will refer to US EPA if needed.

DTSC PROGRAMS

HAZARDOUS WASTE MANAGEMENT SITE MITIGATION and BROWNSFIELD REUSE SCIENCE, POLLUTION PREVENTION, &

TECHNOLOGY DEVELOPMENT OFFICE OF EXTERNAL AFFAIRS OFFICE OF LEGAL AFFAIRS ADMINISTRATIVE SERVICES ENFORCEMENT AND EMERGENCY RESPONSE

(new)

CaltransState Water Resources Control BoardDepartment of Fish & GameDFG Office of Oil Spill Prevention &

ResponseDivision of Oil & GasState Lands CommissionU.S. Coast Guard U.S. EPA

Other State/Federal Agency Resources

What Our Contractors Can Do

OFF-HIGHWAY CONTRACTORS Area 1 – A/C Industrial (Northern

California) Area 2 – Clean Harbors (North Coast) Area 3 – Environmental Dynamics

(LA Basin) Area 4- Open but can use EDI

(Riverside, San Bernardino, San Diego, & Imperial)

Area 5 –PARC Environmental (Central Valley)

Area 6 – PARC Specialty (Sacramento)

Discuss the project scope of workTechnical assistance needs (Tech/Specs)Assistance in determining who should do

the final cleanup workReferring site to other State/Federal

agencies

Keep D.O. informed, they are here to help!

Please direct emergency permit inquiries to:

Mr. Aaron Yue, DTSC Permitting Phone: 714-484-5439 Fax: 714-484-5411 Cell: 714-906-1483

Questions & Comments

For More Information Contact:

DTSC Sacramento 916-255-6504