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
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 Duty Officer System (one system, all ER programs!)
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.
Materials at site must meet the definition of a hazardous substance Flammability Corrosivity (pH<=2 or pH >= 12.5) Reactivity Explosivity Toxicity Assessment of inventory, chemical ID Abandonments and dumps also funded DTSC ER Funding Criteria
DTSC ER WILL NOT FUND • 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. • 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.
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
DRUG LAB REMOVAL STATS • 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
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)
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 containersand 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) • Neutralization (Not For HI) • Product transfers • Pressure releases/venting (Cylinders) • Thermal controls (icing & cooling) • Solidification (Render useless) • Surface 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 Cylinders • Non-Specification Cylinders • Compromised Cylinders • Acid-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 must be placed on public 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 Incident Report • DTSC Clan Lab Removal Work Log • Copy of Hazardous Waste Manifest • Mail to DTSC especially if there are 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
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...”