U.S. DEPARTMENT OF JUSTICE
OFFICE OF COMMUNITY ORIENTED POLICING SERVICES
METHAMPHETAMINE INITIATIVE
FINAL ENVIRONMENTAL ASSESSMENT
May 13, 2003

Table of Contents
1.0 Introduction..............................................................4
2.0 Purpose and Need for Proposed Action......................................5
2.1 Purpose of Proposed Action................................................5
2.2 Need for Proposed Action..................................................6
2.3 Limitations of the Proposed Action........................................7
3.0 Summary of Impacts of the Alternatives....................................8
4.0 Description of Alternatives..............................................17
4.1 DOJ COPS Office Methamphetamine Initiative...............................17
4.2 No Action Alternative....................................................18
5.0 Hazardous Waste Removal, Transportation, and Storage Requirements .......19
5.1 RCRA Requirements........................................................20
5.2 DOT Regulatory Requirements..............................................28
5.3 Fire Protection Codes....................................................32
5.4 DOJ COPS Office Methamphetamine Initiative Policies and Procedures.......37
6.0 Environmental Consequence Analysis Scenarios.............................38
6.1 Scope of Methamphetamine Initiative......................................38
6.2 Hazardous Waste Management Scenarios Development Approach................38
6.3 Removal Action Scenario Development......................................39
6.3.1 Clandestine Drug Laboratory Hazardous Waste Quantity Data..............39
6.3.2 Clandestine Drug Laboratory Site Characteristics Data..................41
6.3.3 Single Family House Removal Action Scenario............................44
6.3.4 Multi-unit Residential Property Removal Action Scenario................44
6.3.5 Rural Open Air Setting Removal Action Scenario.........................44
6.4 Transportation Scenarios.................................................45
6.4.1 Self-transport Scenario................................................45
6.4.2 Licensed Transport Scenario............................................46
6.5 Storage Scenarios........................................................47
6.5.1 Indoor Storage Unit Scenario...........................................47
6.5.2 Outdoor Storage Unit Scenario..........................................49
6.6 Solid Waste Generation ..................................................50

6.7 Other Grant-funded Activities............................................51
7.0 Affected Environment.....................................................52
7.1 Single Family House EnvironmentalSetting.................................52
7.2 Multi-Unit Residential Property Environmental Setting....................53
7.3 Rural Open Air Setting Environmental Setting.............................53
7.4 Storage Scenarios........................................................54
7.4.1 Indoor Storage Scenario................................................54
7.4.2 Outdoor Storage Scenario...............................................54
8.0 Environmental Consequences...............................................55
8.1 DOJ COPS Office Methamphetamine Initiative...............................55
8.1.1 Air Quality............................................................55
8.1.2 WaterQuality...........................................................63
8.1.3 Soil Quality...........................................................69
8.1.4 Human Health and Safety................................................71
8.1.6 Social Effects.........................................................76
8.2 No Action Alternative....................................................77
8.2.1 Air Quality............................................................78
8.2.2 Water and Soil Quality.................................................79
8.2.3 Human Health and Safety................................................79
8.2.5 Social Effects.........................................................81
9.0 Potential Impacts to Children............................................81
10.0 Energy Impacts and Irreversible and Irretrievable Commitment of Resources.84
11.0 EnvironmentalJustice....................................................85
12.0 Energy Impacts..........................................................86
13.0 Coastal Zone Management Act and Coastal Barrier Resources...............87
14.0 Historic Preservation...................................................87
15.0 Wild and Scenic Rivers..................................................88
16.0 Threatened and Endangered Species.......................................89
17.0 Floodplain Management and Protection of Wetlands........................90

18.0 Farmland Protection.....................................................91
19.0 Cumulative Impacts......................................................91
20.0 List of Preparers.......................................................92
Appendix A. Types of Equipment Requested in the Past: Earmarked Grants, FY2001 and
FY2002
Appendix B. Types of Equipment Requested in the Past: Discretionary Grants, FY2001
and FY2002
Appendix C. Conditions of Grant Award
Appendix D. Special Condition for Methamphetamine Initiative: Mitigation of Health,
Safety, and Environmental Risks
Appendix E. Certification of Clean up of Clandestine Drug Laboratories
Appendix F. FY 2002 Methamphetamine Initiative List of Allowable Costs
Appendix G. FY 2002 Methamphetamine Initiative List of Unallowable Costs
Appendix H. Types of Activities and Associated Equipment Requests
Appendix I. Selected State Methamphetamine Initiative Descriptions
Appendix J. Health Hazards of Chemicals Used in Methamphetamine Production
Appendix K. Methodology for Assessing Potential Consequences of Hazardous Waste Air
Releases
Appendix L. Water Quality Impact Analysis
Appendix M. Methodology for Assessing Soil Quality Impacts

1.0 Introduction
Clandestine drug laboratories are used in the illicit production of illegal drugs,
most often methamphetamine, but also other types of illegal drugs. The Department of Justice
(DOJ) Community Oriented Policing Services (COPS) Office Methamphetamine Initiative
provides grant funding to state, local, Tribal, and other public (not Federal) law
enforcement entities (referred to throughout this document as state and local law
enforcement agencies) for their methamphetamine initiatives. The state and local law
enforcement agencies receive grant funding to purchase equipment, administer training,
and fund law enforcement and technical and administrative personnel to investigate and
identify the locations of clandestine drug laboratories and conduct law enforcement
actions to apprehend suspects and remove illegal drugs and other evidence. Grant-funded
personnel may include, but are not limited to, sworn law enforcement personnel,
analytical laboratory chemists, computer programmers, analysts, administrative staff, and
specialized staff to administer specific methamphetamine initiatives, including but not
limited to Drug Endangered Children and Small Rural Community programs. The DOJ
COPS Office may also provide supplemental grants to previously funded agencies under
the supplemental funding program.
Grant-funded equipment may include, but is not limited to, vehicles; surveillance
equipment; health and safety equipment including personal protective equipment,
environmental monitoring equipment, personnel decontamination equipment, and
chemical analytical laboratory equipment and supplies, computer equipment (hardware
and software), and office supplies. Grant funding may also be applied to administration of
law enforcement, health and safety training, and other training.
After law enforcement actions are completed at a clandestine drug laboratory site, the site
generally contains hazardous materials that were used in the production of illegal drugs,
articles and fixtures that are contaminated with drug residues or hazardous materials,
and/or drugs and drug precursors. Illicit production of methamphetamine may involve hazardous
materials that are toxic, corrosive, flammable, or explosive. Such materials include anhydrous
ammonia, sulfuric acid, hydrochloric acid, red phosphorous, lithium metal, sodium metal, iodine,
and toluene. Upon discovery, the hazardous materials
contained at clandestine drug laboratory locations are classified and managed as
hazardous wastes. Under the DOJ COPS Methamphetamine Initiative grant award criteria
and in accordance with Resource Conservation and Recovery Act (RCRA) regulations, the
grantee becomes the legal generator of any hazardous waste that is identified in the
conduct of grant-funded activities. Removal of the hazardous wastes from the discovered
site therefore becomes the responsibility of the state or local law enforcement agency that
discovers the materials. The state or local law enforcement agencies may either perform the
removal action themselves using qualified law enforcement personnel or other
qualified government personnel (referred to throughout this document as qualified law
enforcement personnel); Drug Enforcement Administration (DEA) hazardous waste
management contractors; or other qualified contractors. State and local law enforcement
agencies may also use grant funding to pay commercial hazardous waste disposal fees.
The entity performing the hazardous waste removal action may package and transport the

hazardous waste from the discovered clandestine laboratory to a temporary storage
location. They also may repackage the hazardous wastes and/or consolidate the hazardous
wastes into larger containers for transport, and then transport the hazardous wastes from
the temporary storage unit to a permitted hazardous waste treatment and disposal facility.
Under the Proposed Action, any hazardous waste management activity associated with
clandestine laboratory seizures may be grant funded including hazardous waste removal,
transportation, and storage, and payment of hazardous waste disposal fees. Grantees may
theoretically be any non-Federal law enforcement agency. The DOJ COPS Office
receives funding for the Methamphetamine Initiative from the Congressional annual
appropriations cycle. Congress appropriates both discretionary and earmarked
monies to the DOJ COPS Office Methamphetamine Initiative. Earmarked funds are
designated for specific state and local law enforcement agencies and locations and are
identified explicitly in the Federal budget appropriation language for the DOJ.
Discretionary funds make up any remaining funding provided to the DOJ COPS Office,
after earmarked funds are dispersed. All earmarked and discretionary grantees must
comply with DOJ COPS Office Methamphetamine Initiative grant award conditions. The
earmarked and discretionary grants for fiscal years 2001 and 2002 are presented in
Appendix A and Appendix B respectively. The DOJ COPS Office Methamphetamine
Initiative special grant award conditions are presented in Appendix C, Conditions of Grant
Award; Appendix D, Special Condition for Methamphetamine Initiative: Mitigation of
Health, Safety, and Environmental Risks and in Appendix E; Certification of Clean up of
Clandestine Drug Laboratories. These conditions include meeting Federal, state, and local
environmental laws and regulations. Environmental regulations that apply to grant-funded
activities are discussed in Chapter 5.
The Proposed Action is the Current DOJ COPS Office Methamphetamine Initiative as
described above. The only proposed alternative is the No Action Alternative, which is
required to be assessed in accordance with Federal NEPA regulations. The No Action
Alternative assumes that no Federal funding is provided to the DOJ COPS Office for the
Methamphetamine Initiative and that no grant funding is awarded to prospective grantees.
Under the No Action Alternative, state and local law enforcement entities would either
have to find alternative funding for the activities for which grant funding is requested,
or forego conducting such activities. The No Action Alternative assumes that no grant-
funded clandestine drug laboratory seizures or other grant-funded activities are conducted.
The Federally-funded DOJ COPS Office Methamphetamine Initiative and the proposed No Action
Alternative constitute a major Federal action that is subject to the National Environmental
Policy Act (NEPA) codified at 42 U.S.C. 4321, et seq. This
Environmental Assessment was prepared in accordance with NEPA.
2.0 Purpose and Need for Proposed Action
2.1 Purpose of Proposed Action
The purpose of the Proposed Action is to implement the existing DOJ COPS Office
Methamphetamine Initiative to provide grant funding to state, local, Tribal, and other
public (not Federal) law enforcement entities to address clandestine methamphetamine

laboratories and illicit methamphetamine use in their local and surrounding jurisdictions.
Law enforcement agencies may apply grant funding to investigate and identify the
locations of clandestine drug laboratories and conduct law enforcement actions to
apprehend suspects and remove illegal drugs and other evidence, and equip and administer
other programs related to methamphetamine, including Drug Endangered Children and
Small Rural Community programs. The DOJ COPS Office may also provide supplemental
grant funding to previously funded agencies. Grant-funded activities are classified for the
purposes of this environmental assessment as hazardous waste management activities and
other grant-funded activities. Grant-funded hazardous waste management activities may
include removal of hazardous waste from seized clandestine drug laboratories (i.e., the
removal action,) transportation and storage of such hazardous wastes, and the subsequent
transport of such wastes to hazardous waste treatment and disposal facilities for disposal1.
1 The term removal encompasses the characterization, packaging, labeling, marking, and
physical removal of the hazardous wastes from the clandestine drug laboratory location.
2.2 Need for Proposed Action
The Proposed Action is needed to supplement state and local methamphetamine initiative
budgets because they cannot meet the entire burden of state and local-level clandestine
drug laboratory initiative activities that are needed to combat the illicit production and
distribution of methamphetamine. The incidence of clandestine drug laboratories has
grown dramatically in the past 10 years. For example, in Fiscal Year 1992, the DEAs
National Clandestine Laboratory Cleanup Program funded approximately 400 removal
actions and by fiscal year 2001, the DEA Program funded more than 6,400 removal
actions. The DOJ COPS Office has also found that the number of grant-funded seizures
has increased sharply in recent years. The DOJ COPS Office anticipates that there may be
a similar increase in the number of clandestine drug laboratory seizures conducted by state
methamphetamine initiatives.
Grant-funded activities may include funding of personnel and overtime for sworn law
enforcement officers and investigative, technical and administrative personnel, and
funding for administration of law enforcement and health and safety training, and
administration of Drug Endangered Children and Small Rural Community programs.
Grant-funded activities may include community outreach and chemical and drug diversion
investigation programs. Grants may be used to purchase law enforcement equipment
including surveillance equipment, environmental monitoring equipment, personal
protective equipment and other safety equipment used in clandestine drug laboratory
seizures and hazardous waste removal actions, vehicles used to transport law enforcement
personnel, law enforcement and safety equipment, evidence, or hazardous waste; chemical
analytical laboratory equipment and supplies; and administrative and office supplies. A
review of recent grant applications indicates that grantees use the funding for equipment
and activities that they would otherwise not be able to fund themselves, and the funding
enabled grantees to conduct more effective law enforcement activities, locate and seize
clandestine drug laboratories, and reduce illicit production and use of methamphetamine.
Clandestine drug laboratory seizure operations present unique hazards to law enforcement

personnel and the public. Hazardous materials contained at clandestine drug laboratory
locations include drugs, drug precursors, other raw materials used for and byproducts of
the manufacture of illegal drugs. These materials are toxic, corrosive, flammable, and/or
explosive. According to statistics provided by the El Paso Intelligence Center (EPIC)
NCLSS Reports, the DEA has estimated that 5 pounds of hazardous waste may be
generated for every one pound of methamphetamine produced in a clandestine drug
laboratory. These materials present health and safety hazards to law enforcement
personnel entering the situation. Upon discovery of a clandestine laboratory, hazardous
materials and booby traps pose health and safety hazards to the personnel performing the
seizure and removal action. Availability of grant-funded personal protective equipment
and other safety equipment has enabled law enforcement personnel to conduct seizures
and removal actions safely. After seizure of suspects and evidence, hazardous materials
left at a laboratory would pose a health and safety hazard to residents and the
environment. In addition, the materials could be diverted and reused for illegal drug
manufacture or other illicit purposes. Transporting and storing hazardous waste may also
pose a hazard to the environment and human health and safety if not conducted properly.
Grant funding has improved the capability and effectiveness of law enforcement agencies
to conduct these activities.
2.3 Limitations of the Proposed Action
The environmental consequences analysis in the Environmental Assessment is limited to
grant-funded activities. The DOJ COPS Office Methamphetamine Initiative does not
provide funding for every aspect of state and local methamphetamine initiatives. The list
of fiscal year 2002 Unallowable Costs and fiscal year 2002 Allowable Costs for the DOJ
COPS Office Methamphetamine Initiative are provided in Appendix F and Appendix G.
The DOJ COPS Office Methamphetamine Initiative will not fund salaries for existing
personnel, but will fund overtime for existing personnel and salaries and benefits for new
hire personnel. Funding for training is limited to topics that are directly linked to the
Methamphetamine Initiative, such as health and safety training.
The term removal action, for the purposes of this document, refers to the removal of
bottles, cans, jugs, and other containers of hazardous waste and also to the removal of
contaminated apparatus (e.g., glassware) and inextricably contaminated articles from a
clandestine drug laboratory location. The DOJ COPS Office does not fund, and the
Proposed Action does not include, further cleanup (i.e., environmental remediation) of
residual hazardous wastes that may remain at clandestine drug laboratory sites after the
removal action is completed. The term environmental remediation, for the purposes of
this document, refers to the cleanup of residual hazardous wastes that may remain in
contaminated structures, soil, or water systems after the removal action is completed. The
property owner, state or local health department, or state and local environmental agency
would address any residual contamination that may remain at the site after removal
actions are completed.2
2 Based on the State and local governments that were contacted, law enforcement agencies
typically notify the property owner concerning discovery of clandestine drug laboratories
and the potential need for environmental remediation to be conducted after the removal
action is completed. However, depending on the state or local jurisdiction, there may or
may not be regulations requiring agencies to notify the property owner. Neither the DOJ
COPS Office nor state or local law enforcement authorities are responsible for
remediating residual contamination that may remain at the location after the removal action
is completed. Similarly, there are not necessarily any regulations requiring a property owner
to remediate a clandestine drug laboratory found inside a private residence. Some individual
municipalities have passed laws allowing a law enforcement agency to recover costs from
property owners after remediation.

The Proposed Action also does not include any physical construction or modification of
buildings or structures that would require site-specific environmental review under NEPA.
In the event that any grant-funded construction or modification of buildings or structures
is proposed, the DOJ COPS Office and/or the prospective grantee would conduct site-
specific environmental review in accordance with Federal NEPA regulations and state
environmental review regulations. Any proposed grant-funded construction or
modification of buildings and structures is outside of the scope of this Environmental
Assessment.
3.0 Summary of Impacts of the Alternatives
The Proposed Action evaluated in this Environmental Assessment include:
1) Continue the DOJ COPS Office Methamphetamine Initiative under which state
and local agencies receive grant funding to investigate and seize clandestine drug
laboratories and conduct related activities for their methamphetamine initiatives.
This Alternative is referred to as the DOJ COPS Office Methamphetamine
Initiative;
2) Discontinue the DOJ COPS Office Methamphetamine Initiative. Under this
Alternative, the DOJ COPS Office would not receive federal funding for the
Methamphetamine Initiative. In the event that the DOJ COPS Office does not
receive Federal funding for the Methamphetamine Initiative, prospective grantees
would be responsible for finding alternative funding to fund requested activities or
forgo activities for which the grant funding was requested. This Alternative is
referred to as the No Action Alternative.
The CEQ NEPA regulations require a comparison of the potential impacts of each
Alternative. Table 3.0-1 summarizes the impacts for each Alternative across each of the
impact areas.

Table 3.0-1 Summary of Impacts of Alternatives
Air Quality
No Action Alternative3
DOJ COPS Office Methamphetamine Initiative4
Clandestine Drug Laboratory Seizures:
No grant-funded seizures or removal actions would be
conducted under the No Action Alternative. Clandestine drug
laboratories that are not seized because of resource limitations
and continue to operate would represent a continuing source of
illicit drug production and air releases. Hazardous waste
remaining in place would result in ongoing and future air
releases as a result of fugitive emissions from containers and
contaminated articles and fixtures.
Grant funded clandestine drug laboratory seizures would reduce
sources of illicit drug manufacture and air emissions. Air emissions
from the normal conduct of clandestine drug laboratory seizures and
associated hazardous waste removal actions are anticipated to be
minimal.
Accidental Releases:
No grant-funded removal actions would be conducted under the
No Action Alternative. The potential for release of hazardous
waste remaining in place is high. Releases could result from
catastrophic release from or intentional breach of containers.
Release of 100 kg of ammonia would result in an indoor
concentration of 160,000 to 320,000 parts per million, resulting
in fatality for persons exposed. Concentrations of ammonia in
an adjacent apartment would be 6,400 ppm, resulting in severe
health effects to exposed persons and impaired ability to take
protective action. Concentrations in houses 50 feet from the
point of release would equal the ERPG-2 of 150 ppm. Exposed
persons would experience health effects, but not irreversible or
other serious health effects or symptoms that would impair
their ability to take protective action.
Releases of hazardous waste could result from breach of containers
during removal action. However, the potential for such releases is
much lower than if the hazardous waste were to remain in place.
Release of 100 kg of ammonia would result in an indoor
concentration of 160,000 to 320,000 parts per million, resulting in
potential fatality for persons exposed unless personal protective
equipment or rescue operations were employed. Concentrations of
ammonia in an adjacent apartment would be 6,400 ppm, resulting in
severe health effects to exposed persons and impaired ability to take
protective action. Concentrations in houses 50 feet from the point of
release would equal the ERPG-2 of 150 ppm. Exposed persons
would experience health effects, but not irreversible or other serious
health effects or symptoms that would impair their ability to take
protective action.
3 The No Action Alternative is based on the assumption that no grant-funded activities
are conducted, and that the elimination of the Methamphetamine Initiative funding results
in a reduction in the number of clandestine drug laboratory seizures as compared to the
DOJ COPS Office Methamphetamine Initiative. Under the No Action Alternative, DEA
contractors would cease conducting hazardous waste removal actions, and no grant funded
hazardous waste transportation or storage activities would be conducted.
4 The DOJ COPS Office Methamphetamine Initiative is based on the assumption that
hazardous waste removal activities and transportation and storage activities
associated with grant funded clandestine drug laboratory seizures would be conducted
by qualified law enforcement personnel or other government personnel, DEA contractors,
or other qualified grant-funded contractors.

Normal Operations Hazardous Waste Transportation and Storage:
No grant-funded hazardous waste transportation or storage
activities would be conducted under the No Action Alternative.
Fugitive air emissions from hazardous waste stored in storage units
would be negligible under normal operations, assuming that the
hazardous wastes are handled, packaged, transported and stored in
accordance with regulatory requirements and grant award conditions.
Vehicle emissions from hazardous waste transportation and other
vehicle operations associated with grant-funded activities would be
minimal as compared to overall agency vehicle operations.
Accidental Releases Hazardous Waste Transportation and Storage:
No grant-funded hazardous waste transportation or storage
activities would be conducted under the No Action Alternative.
Releases could result from transportation or materials handling
accident at a storage unit. Release of 100 kg of ammonia from a
transportation accident would result in a concentration of 150 ppm in
houses 75 feet from the point of release. Exposed persons would
experience health effects, but not irreversible or other serious health
effects or impaired ability to take protective action. A release from
an indoor storage unit would result in an indoor concentration of
80,000 ppm. Building occupants would suffer health effects unless
they had personal protective equipment. Concentrations in houses
50 feet from the storage unit would exceed the ERPG-2. Exposed
persons would experience health effects, but not irreversible or other
serious health effects or impaired ability to take protective action.
Water Quality
Clandestine Drug Laboratory Seizures:
Clandestine drug laboratories that are not seized because of
resource limitations and continue to operate would represent a
continuing source of illicit drug production and releases to
surface water. Hazardous waste remaining in place would
result in ongoing and future releases of hazardous waste to
surface water as a result of releases from containers. Such
releases could contribute to exceedances of water quality
standards and aquatic toxicity criteria, and result in exposure to
hazardous wastes in surface water.
Grant funded clandestine drug laboratory seizures would reduce
potential sources of releases to surface water. Surface water
discharges from the normal conduct of clandestine drug laboratory
seizures and associated removal actions are anticipated to be
minimal, assuming that the hazardous wastes are handled, packaged,
transported and stored in accordance with regulatory requirements
and grant award conditions.

Accidental Releases Hazardous Waste Transportation and Storage:
No grant-funded hazardous waste transportation or storage
activities would be conducted under the No Action Alternative.
Release of hazardous waste to surface water could result from
transportation or materials handling accident at a storage unit. The
potential for such release may be higher for activities conducted by
qualified law enforcement personnel than by DEA or other qualified
contractors. Surface water quality and aquatic toxicity criteria could
be exceeded in rivers or streams in the event of an uncontrolled 100kilogram
release of toluene or iodine to surface water. Releases from
transportation accidents would be remediated by personnel
conducting the transportation activity in accordance with regulatory
requirements, minimizing the consequences of any release.
Accidental Releases Hazardous waste Transportation and Storage:
No grant-funded hazardous waste transportation or storage
activities would be conducted under the No Action Alternative.
Vehicles operated by qualified law enforcement personnel or other
qualified contractors would not necessarily be placarded and
hazardous waste manifests would not necessarily be prepared. Some
grantees may be exempt due to Conditionally Exempt Small
Quantity Generators (CESQG) low-quantity exemption. DEA
contractors are required to comply with RCRA SQG regulations for
use of vehicle placards, manifests, and container markings, which
could improve the timeliness of the response to a transportation
accident release. Potential consequences for such release may
therefore be higher for transport conducted by qualified law
enforcement personnel or other qualified contractors than by DEA
contractors.
Normal Operations Hazardous Waste Storage:
No grant-funded hazardous waste transportation or storage
activities would be conducted under the No Action Alternative
Releases to surface water from hazardous waste stored in storage
units would be minimal, assuming that the hazardous wastes are
handled, packaged, transported and stored in accordance with
regulatory requirements and grant award conditions.
Soil Quality
Clandestine Drug Laboratory Seizures:
Clandestine drug laboratories that are not seized because of
resource limitations and continue to operate would represent a
continuing source of illicit drug production and releases to
surface soils. Hazardous waste remaining in place would result
in ongoing and future releases of hazardous waste to surface
soils as a result of releases from containers. Such releases
could contribute to exceedances of soil quality criteria, and
result in exposure to hazardous wastes in surface soils.
Grant funded clandestine drug laboratory seizures would reduce
potential sources of releases to surface soils. Releases to surface soils
from the normal conduct of clandestine drug laboratory seizures and
associated removal actions are anticipated to be minimal.

Normal Operations Hazardous Waste Storage:
No grant-funded hazardous waste transportation or storage
activities would be conducted under the No Action Alternative
Releases to surface soils from hazardous waste stored in storage
units would be negligible, assuming that the hazardous wastes are
handled, packaged, transported and stored in accordance with
regulatory requirements and grant award conditions.
Accidental Releases Hazardous Waste Transportation and Storage:
No grant-funded hazardous waste transportation or storage
activities would be conducted under the No Action Alternative
Release of hazardous waste to surface soils could result from a
transportation accident or a materials handling accident at a storage
unit. The potential for such release may be higher for activities
conducted by qualified law enforcement personnel than by DEA or
other qualified contractors. Release of 100 kg of toluene or acetone
to surface soils could exceed the generic soil screening level (SSL)
concentrations levels for human ingestion of contaminated soils.
Releases from transportation or materials handling accidents would
be remediated by personnel conducting the activity in accordance
with regulatory requirements, minimizing the consequences of any
release.
Human Health and Safety
Clandestine Drug Laboratory Seizures:
Clandestine drug laboratories that are not seized because of
resource limitations and continue to operate would represent a
continuing source of illicit drug production and hazards to
occupants of the clandestine drug laboratories and neighboring
persons. Hazardous waste remaining in place would result in
ongoing and future releases of hazardous waste to air, water,
and soils as a result of fugitive releases from containers. Long-
term exposure to releases could result in chronic health effects
Grant funded clandestine drug laboratory seizures would reduce
health and safety hazards associated with the seized laboratories. The
potential for health and safety impacts due to normal conduct of
clandestine drug laboratory seizures and associated removal actions
would be minimized given adherence with regulatory requirements
and grant award conditions and through application of grant funded
law enforcement and safety equipment and administration of grant
funded health and safety training.
Normal Operations Hazardous Waste Removal Actions:
No grant-funded hazardous waste removal actions would be
conducted under the No Action Alternative
There is some potential for occupational exposure to hazardous
wastes from removal actions, however such exposure would be
minimized through training of qualified law enforcement personnel
or qualified contractors conducting these activities. Occupational
training provided to DEA contractors exceeds regulatory
requirements for CESQGs. Qualified law enforcement personnel
conducting removal actions would generally operate as CESQGs and
receive only the training required for CESQGs. The potential for
occupational exposure may therefore be higher for activities
conducted by qualified law enforcement personnel than by DEA or
other qualified contractors.

Normal Operations Hazardous Waste Transportation and Storage:
No grant-funded hazardous waste transportation or storage
activities would be conducted under the No Action Alternative
Public health and safety impacts would be negligible for normal
operation of the storage units, assuming that the hazardous wastes
are handled, packaged, transported and stored in accordance with
regulatory requirements. The potential for releases and occupational
exposure to such releases may be lower for activities conducted by
DEA contractors and other qualified contractors than for similar
activities conducted by qualified law enforcement personnel.
Qualified law enforcement personnel may conduct such activities
less frequently than DEA contractors and then only as required for
the grant-funded initiative. The lower frequency of conduct of
activities for law enforcement personnel may increase the potential
for releases and occupational exposure.
Accidental Releases Hazardous Waste Transportation:
No grant-funded hazardous waste transportation or storage
activities would be conducted under the No Action Alternative.
Vehicles operated by qualified law enforcement personnel would not
necessarily be placarded and manifests and container markings
would not necessarily be prepared. Some grantees would be exempt
due to CESQGs low-quantity exemption. The potential
consequences of such releases may be higher for transport conducted
by qualified law enforcement personnel than by DEA contractors. In
the event that an unplacarded vehicle is involved in an accident or
that hazardous wastes are released into the vehicle (e.g., through
container seal failure), the driver and any passengers could be
injured or disabled by the release. Such accident and resulting
release could endanger response workers who do not know that the
accident or release involves hazardous waste, and could also affect
response time, as responders may not be able to determine what
substances the occupants of the vehicle have been exposed to.
Other Grant Funded Activities:
Under the No Action Alternative, no grant-funded activities
would be conducted. Established grant-funded initiatives,
including initiatives related to theft and diversion of anhydrous
ammonia and other raw materials for methamphetamine
production, would not be conducted, and no new initiatives
would be established.
Grant funded initiatives, including initiatives related to theft and
diversion of anhydrous ammonia and other raw materials for
methamphetamine production, would reduce the production of
methamphetamine and reduce health and safety hazards related to
theft and mishandling of anhydrous ammonia and other
methamphetamine raw materials.

Other Grant-Funded Activities:
Elimination of availability of grant-funded law enforcement
and safety equipment and administration of grant funded health
and safety training may increase the potential for health and
safety impacts, including occupational exposure, during
clandestine drug laboratory seizure and associated hazardous
waste management operations.
Application of grant-funded law enforcement and safety equipment
and administration of grant funded health and safety training would
reduce the potential for health and safety impacts, including
occupational exposure, during clandestine drug laboratory seizure
and associated hazardous waste management operations.
Social Effects
Hazardous Waste Storage:
No grant-funded hazardous waste transportation or storage
activities would be conducted under the No Action Alternative.
The potential for diversion of hazardous wastes from storage units,
and associated social effects of such a diversion, could be somewhat
lower for transfer stations operated by DEA contractors (that require
RCRA and SQG regulation) than for other storage units operated
under this Alternative that meet regulatory requirements and grant
award conditions. Although it is not anticipated that grant program
personnel would present a risk of diversion, the locations where
storage units may be situated (e.g., police stations, fire stations)
could be accessible by non-program persons, including nongovernment
personnel and members of the public, which could
increase the risk of diversion. DEAs site security requirements for
DEA contractors exceed RCRA regulatory requirements. Site
security at transfer stations operated by qualified law enforcement
personnel or other qualified contractors would meet, but not exceed
RCRA regulatory requirements. Because DEA contractors would
exceed RCRA and SQG regulations, the DOJ COPS Office
anticipates that site security implemented at transfer stations by DEA
contractors may be more stringent than site security implemented at
other storage units operated under this Alternative, in particular with
respect to outdoor storage units.

Impacts to Children:
A significant potential for disproportionate impacts to children
exists for the No Action Alternative. Clandestine drug
laboratories that are not seized and continue to operate would
represent a potential exposure pathway for children. Hazardous
wastes are assumed to remain unattended and unsecured in
either indoor locations or outdoor locations. In either case
these unattended hazardous wastes, or contaminated soil
resulting from release of such wastes, would represent a
potential exposure pathway for children. Also, grant-funded
Drug Endangered Children programs that have been
established by grantees may not continue in operation, and no
new grant-funded programs would be established.
Grant-funded clandestine drug laboratory seizures would reduce
potential exposure pathways for children. Grant-funded Drug
Endangered Children programs have been established by grantees
that provide medial monitoring and child protection services for
children found in clandestine drug laboratory sites.
Irreversible and Irretrievable Commitment of Resources:
Under the No Action Alternative, no grant-funded activities
would be conducted and no grant resources would be
consumed.
Under the DOJ COPS Office Methamphetamine Initiative, resources
would be expended in conducting grant-funded activities, including
but not limited to the purchase of equipment, supplies, and
consumables.
Environmental Justice:
The No Action Alternative raises potential environmental
justice concerns with respect to potential for disproportionate
high and adverse impacts on minority and low-income
populations. Laboratories may be located disproportionately in
areas of minority or low-income population. Laboratories that
not seized and hazardous waste remaining in place may
disproportionately impact such populations.
The DOJ COPS Office Methamphetamine Initiative does not raise
potential environmental justice concerns.
Energy Impacts Under the No Action Alternative, no grant-funded activities
would be conducted and no energy would be consumed
conducting grant-funded activities.
Energy consumption for grant-funded activities would be
insignificant as compared to the total amount of energy consumed by
participating state and local government agencies as a whole.
Coastal Zone Management Act and Coastal Barrier Resources:
Clandestine drug laboratories that are not seized may represent
a continued potential impact to coastal zone resources.
Hazardous waste removal actions would result in reduction of
potential for hazardous waste release to surface water and associated
water quality impacts and ecological impacts to Coastal Zone
Management Areas or Coastal Barrier Areas.
Historic Preservation:
Clandestine drug laboratories are unlikely to be found in
properties listed under or eligible for listing on the National
Register of Historic Places. Therefore, the DOJ COPS Office
does not anticipate impacts related to historic preservation.
Clandestine drug laboratories are unlikely to be found in properties
listed under or eligible for listing on the National Register of Historic
Places. Therefore, the DOJ COPS Office does not anticipate impacts
related to historic preservation.

Wild and Scenic Rivers:
Continued operation of clandestine drug laboratories and
hazardous waste remaining in place would result in ongoing
and potential future hazardous waste releases to surface water
and associated water quality impacts and ecological impacts for
any laboratories in the vicinity of a Wild and Scenic River.
Hazardous waste removal actions would result in reduction of
potential for hazardous waste release to surface water and associated
water quality impacts and ecological impacts to Wild and Scenic
Rivers.
Threatened and Endangered Species:
Continued operation of clandestine drug laboratories and
hazardous waste remaining in place would result in ongoing
and potential future hazardous waste releases to air, water, and
soils and associated ecological impacts for any laboratories in
the vicinity of a threatened and endangered species habitat.
Hazardous waste removal actions would result in reduction of
potential for hazardous waste releases to air, water, and soils, and
associated ecological impacts to any threatened and endangered
species habitat.
Floodplain Management and Protection of Wetlands:
The No Action Alternative would not result in any conversion
of floodplains or wetlands. Continued operation of clandestine
drug laboratories and hazardous waste remaining in place
would result in ongoing and potential future releases to surface
water and associated water quality impacts and ecological
impacts for any laboratories in the vicinity of a wetland.
The Proposed Action would not result in any conversion of
floodplains or wetlands. Hazardous waste removal actions would
result in reduction of potential for hazardous waste release to
wetlands and associated water quality impacts and ecological
impacts.
Farmland Protection:
The No Action Alternative would not result in any conversion
of farmland.
The Proposed Action would not result in any conversion of farmland.

4.0 Description of Alternatives
This section describes the two Alternatives: the DOJ COPS Office Methamphetamine
Initiative and the No Action Alternative.
4.1 DOJ COPS Office Methamphetamine Initiative
This alternative assumes the continued funding and implementation of the DOJ COPS
Office Methamphetamine Initiative without any changes to the program. Under this
alternative, Congress would continue to fund the DOJ COPS Office Methamphetamine
Initiative. Since fiscal year 1998, the Methamphetamine Initiative has provided
approximately $223 million to state and local agencies to fund personnel, purchase
equipment, administer training, establish and administer special programs, and manage
hazardous wastes recovered from clandestine drug laboratories. Congress funds the
Methamphetamine Initiative through the annual appropriations process for earmarked
and discretionary projects at state or local agencies. Earmarked projects and their
funding levels appear explicitly in the Federal budget appropriation for the DOJ.
Discretionary funds make up the rest of the total Federal funding provide to the DOJ
COPS Office Methamphetamine Initiative. The DOJ COPS Office is aware that the ratio
of earmarked to discretionary funding changes each year; some fiscal years there may be
no discretionary funds. Total funding for fiscal year 2002 was $70 million.
The DOJ COPS Office assumes that grant funding would be requested for similar types of
activities from one year to the next, and has based the environmental consequence
analyses in this Environmental Assessment on discretionary and earmarked funding and
grant applications for fiscal years 2001, 2002, and 2003. However, the DOJ COPS Office
cannot predict what prospective grantees will request grant funding for in future years,
or what earmarked funds may appear in Congressional budget authorizations in future years.
The DOJ COPS Office anticipates that the activities identified in this Environmental
Assessment and the associated environmental consequence analyses will bound the
environmental impacts of future grant-funded activities.
Under the Proposed Action the DOJ COPS Office would continue to solicit applications
for discretionary grants. The DOJ COPS Office reviews and approves applications and
then issues an award package for the grantee to sign. Conditions of Grant Award and
Special Condition for Methamphetamine Initiative: Mitigation of Health, Safety, and
Environmental Risks in Appendix C and D respectively. Both earmarked and
discretionary grantees are required as a condition of the grant award to comply with
Federal, State, and local environmental, health, and safety laws and regulations applicable
to their grant-funded activities, including activities relate to the investigation and
seizure of clandestine methamphetamine laboratories and the removal, storage, transportation,
and disposal of the chemicals, equipment, and solid and hazardous wastes recovered from or
resulting from seizure of these laboratories. Appendix E, Certification of Cleanup of
Clandestine Drug Laboratories, explains the requirements for removal actions performed
at clandestine drug laboratories. Grantees may use grant funding to perform their own
removal actions and associated

hazardous waste transportation and storage using qualified law enforcement or other
qualified government personnel, or use grant funding to hire qualified contractors to
remove hazardous wastes from clandestine drug laboratory sites and subsequently
transport, store, and dispose of the removed hazardous wastes. Grantees may also use
DEA or state-funded contractors whose services are provided to state and local agencies.
Non-grant funded hazardous waste management activities conducted for grant-funded
clandestine drug laboratory seizures are not included as part of the Proposed Action.
The DOJ COPS Office Methamphetamine Initiative has in the past funded the purchase of
hazardous waste transportation vehicles using earmarked funding and is anticipated to
continue to fund the purchase, maintenance, and operation of hazardous waste
transportation vehicles in the future. Therefore, the transportation of hazardous waste
recovered from clandestine methamphetamine laboratories is included in the Proposed
Action. Transportation includes conveying the hazardous waste from the clandestine drug
laboratory location to a hazardous waste storage unit location and subsequently conveying
the hazardous waste to a disposal facility, typically a treatment, storage and disposal
facility (TSDF) as defined under the Resource Conservation and Recovery Act (RCRA).
In most states, hazardous waste must not remain at the storage unit for more than 10 days
if the storage unit is to be classified under RCRA as a transfer station. If hazardous
waste were stored at a storage unit location for more than 10 days, the storage unit would
require a RCRA hazardous waste storage permit. Transfer stations used by licensed
transporters to store hazardous waste for less than 10 days are covered under the
hazardous waste transporters license and are not required to be permitted under RCRA.
The DOJ COPS Office Methamphetamine Initiative also may also fund the purchase of
hazardous waste storage units to be used as transfer stations. Grant funding may be used
by some grantees to fund commercial hazardous waste facility disposal fees and therefore
hazardous waste transportation, storage, and disposal are considered to be part of the
Proposed Action.
The DOJ COPS Office also funds law enforcement and health and safety training of law
enforcement personnel, salaries and benefits of sworn law enforcement personnel and
civilians. Grant-funded law enforcement activities include surveillance and investigation,
apprehension of suspects, seizure of clandestine laboratories, and collection and
processing of evidence. Grants also fund the purchase of supplies and equipment.
Appendix H shows the general types of equipment, supplies and training requested by
grantees.
4.2 No Action Alternative
The No Action Alternative assumes loss of Federal funding and termination of the DOJ
COPS Office Methamphetamine Initiative. Under the No Action Alternative, state and
local law enforcement agencies that request funding for specific line items in their
methamphetamine initiative budgets would be responsible for finding alternative funding
for requested activities or forgoing conduct of such activities. Grantees are aware that
funding is provided by Congress for the DOJ COPS Office Methamphetamine Initiative

by Congressional appropriation, and that in the event that Congress does not appropriate
funding no grant money would be dispersed to prospective grantees. The DOJ COPS
Office recognizes that in some cases grantees may reprogram non-grant funding to enable
them to conduct activities for which they requested grant funding, but this would not be
possible for all activities for which grantees requested funding. The DOJ COPS Office
Grant Award Conditions require that grant funding not be used to supplant existing
funding. The DOJ COPS Office does not anticipate that prospective grantees would be
able to replace a significant portion of the funding that would be eliminated if the No
Action Alternative were implemented.
5.0 Hazardous Waste Removal, Transportation, and Storage Requirements
Hazardous materials discovered at clandestine drug laboratory locations may be classified
as hazardous waste and may be required to be managed as hazardous waste. Removal
actions require the management of hazardous waste, which is regulated under RCRA
Subtitle C (42 USC 6901 et seq.). Grantees that use DOJ COPS Office Methamphetamine
Initiative monies to perform removal actions at clandestine drug laboratory sites become
classified as the legal generator of the hazardous waste recovered from the sites for
the purposes of Federal, state, and local hazardous waste management requirements.
Grantees performing their own removal actions or hiring contractors to conduct removal
actions are required by the DOJ COPS Office to comply with the provisions of the RCRA
regulations for hazardous waste generators (40 CFR 261 and 40 CFR 262) and related
state and local hazardous waste management regulations. RCRA regulatory requirements
are discussed in detail in Section 5.1.
DEAs requirements for DEA contractors exceed RCRA regulatory requirements. The
DEA requires its hazardous waste management contractors to manage all hazardous
materials recovered from clandestine drug laboratories as hazardous waste, regardless of
whether the specific material is classified as a hazardous waste, and requires its
contractors to dispose of such wastes in RCRA permitted TSDFs. This exceeds the
minimum requirement set forth in RCRA. Qualified law enforcement personnel and other
qualified contractors are required to meet federal, state and local regulations. The DOJ
COPS Office does not require grantees conducting removal actions to manage all wastes
removed from the sites as hazardous waste, and such wastes may be segregated from and
managed separately from non-hazardous wastes recovered from the laboratory sites. The
DOJ COPS Office requires grantees to meet federal state and local regulations and
therefore it does not require that hazardous wastes generated from removal actions be
disposed of at RCRA-permitted TSDFs. Certain states allow hazardous wastes generated
by Conditionally Exempt Small Quantity Generators (CESQG) to be disposed of at non
RCRA-permitted (generally state-permitted) disposal facilities.
Grantees that use DOJ COPS Office funding to purchase and operate vehicles to convey
hazardous wastes from clandestine laboratory sites to a hazardous waste storage unit at
another location are subject to hazardous waste transportation regulations. Transportation

of hazardous waste is regulated by both the U.S. Environmental Protection Agency (EPA),
under 40 CFR 263, and the U.S. Department of Transportation (DOT), under 49 CFR 171
179. Unless exempt from such requirements as a CESQG under RCRA, a transporter of
hazardous waste must obtain an EPA identification number, comply with the hazardous
waste manifest system to track hazardous waste shipments, and properly handle any
hazardous waste discharges that may occur. Hazardous waste transportation regulatory
requirements are discussed in Section 5.2
Under RCRA Subtitle C, a transporter of hazardous waste may store the waste for up to
ten days at a transfer station. If hazardous waste were stored for more than ten days, the
facility would be classified as a storage facility and would be subject to regulatory
requirements for RCRA Treatment, Storage, and Disposal Facilities (TSDFs), which
include RCRA permitting. The requirements for RCRA-permitted TSDFs (40 CFR 264265)
include general facility design and operating standards, standards for the various
types of units in which hazardous waste is stored and managed, and personnel training.
Grantees storing any quantity of hazardous waste for any length of time in a storage unit
must meet certain National Fire Prevention Authority (NFPA) codes for storage of
combustible and flammable materials. NFPA Codes have been codified as state
regulations in 34 states. Regulatory requirements for hazardous waste storage and for
combustible and flammable materials storage are discussed in Section 5.3.
5.1 RCRA Requirements
The responsibilities of any particular hazardous waste generator facility are based on the
amount of hazardous waste being generated in any one calendar month. EPA Publication
Protocol for Conducting Environmental Compliance Audits for Hazardous Waste
Generators under RCRA (EPA 2001) summarizes federal regulations for hazardous waste
generators5. Under federal regulations there are three classifications of hazardous waste
generators:
Conditionally Exempt Small Quantity Generator (CESQG): A CESQG generates no more
than 100 kg (220.46 lb.) of hazardous waste or no more than 1 kg (2.20 lb.) of acutely
hazardous waste in a calendar month.6 Under the provisions of 40 CFR 261.5, Special
Requirements for Hazardous Waste Generated by Conditionally Exempt Small Quantity
Generators, CESQGs are not subject to RCRA requirements for hazardous waste
generators under 40 CFR 262 and are not subject to RCRA requirements for hazardous
waste transportation under 40 CFR 263.7 CESQGs may not accumulate on-site more than

1,000 kg (2,204.62 lb.) of hazardous waste at any one time. In the event that either the
amount of hazardous waste generated in one calendar month exceeds 100 kg (220.46 lb.)
or more than 1,000 kg (2,204.62 lb.) of hazardous waste have accumulated on-site, the
facility is required to comply with the more stringent standards applicable to Small
Quantity Generators (SQG). In the event that the amount of acutely hazardous waste
generated in a calendar month exceeds 1 kg or the amount of waste generated from the
cleanup of acutely hazardous waste exceeds 100 kg, then the waste is subject to standards
applicable to large quantity generators (LQGs).
5 EPA 2001. Protocol for Conducting Environmental Compliance Audits for Hazardous Waste
Generators under RCRA. United States Environmental Protection Agency, Enforcement and
Compliance Assurance (2224-A), EPA 305-B-01-003, June 2001.
6 None of the more than 7,500 clandestine drug laboratory removal actions for which
hazardous waste quantity data were reported through EPIC in 2000, 2001, and 2002
involved the removal of wastes listed as acutely hazardous under RCRA.
7 Note that certain state and local regulations differ from Federal RCRA regulations
applicable to CESQGs. The State of Rhode Island does not recognize federal exemptions
for small quantity generators, and the small quantity generator provisions of 40 CFR 261.5
do not apply in Rhode Island (RIR #DEM OWM-HW09-01, Rule 5.0.) The State of Kansas defines
a Kansas Generator as generating 25 kilograms (55 pounds) or more and less than 1,000 kilograms
(2,200 pounds) of hazardous waste in any calendar month (KAR Article 31 28-31-2(d)). The federal
regulatory threshold for a CESQG is 100 kilograms in any calendar month. The State of Arkansas
 requires CESQGs to manifest hazardous waste and transport the waste via a transporter permitted
by the State of Arkansas (A.C.A.  8-7-301, Regulation 23,  262.35, 262.13).
Small Quantity Generator (SQG): A SQG generates between 100 kg (220.46 lb.) and
1,000 kg (2,204.62 lb.) of hazardous waste in a calendar month. An SQG cannot
accumulate hazardous waste on-site for more than 180 days unless the waste is transported
more than 200 miles (321.87 km) to a treatment, storage and disposal facility (TSDF), in
which case the hazardous waste may accumulate for up to 270 days. At no time may there
be more than 6,000 kg (13,227.73 lb.) of hazardous waste accumulated at the facility. In
the event that the amount of hazardous waste generated in a calendar month exceeds 1,000
kg (2,204.62 lb.) of non-acutely hazardous waste or 1 kg (2.20 lb.) of acutely hazardous
waste, or the accumulation time limit is exceeded, the facility is required to comply with
the standards applicable to LQGs. In the event that more than 6,000 kg (13,227.73 lbs) of
hazardous waste is stored on-site, a SQG is required to obtain a RCRA hazardous waste
storage permit and comply with the requirements applicable to hazardous waste storage
facilities.
Large Quantity Generator (LQG): A LQG generates more than 1,000 kg (2,204.62 lb.) of
hazardous waste or more than 1 kg (2.20 lb.) of acutely hazardous waste in a calendar
month.8
Table 5.1-1 compares elements of the RCRA hazardous waste generator regulations
applicable to CESQGs, SQGs, and LQGs.9
8 Water weighs approximately 8.34 lbs./gal (3.78 kg/gal or 1 kg/L). Using water as a
basis of measurement, 100 kg (220.46 lb.) would equal about 26.4 gallons (100 L), or
almost one-half of a 55-gallon (208.2 L) drum; 1,000 kg (2,204.62 lb.) would equal
about 264 gallons (1000 L), or almost five 55-gallon drums.
9 EPA 2001. Protocol for Conducting Environmental Compliance Audits for Hazardous Waste
Generators under RCRA. United States Environmental Protection Agency, Enforcement and
Compliance Assurance (2224-A), EPA 305-B-01-003, June 2001.

Table 5.1-1
Comparison of Elements of Federal RCRA Hazardous Waste
Generator Requirements for CESQGs, SQGs, and LQGs
Requirement
CESQG
SQG
LQG
Calendar Month Hazardous Waste Generation Limit
<100 kilograms/month (<220.46 lbs/month)
100 - 1,000 kilograms / month
>1,000 kilograms / month (>2,204.6 lbs./month)
Calendar Month Acutely Hazardous Waste Generation Limit
<1 kg
-
>1 kg
On site Accumulation Limit
1,000 kilograms
6,000 kilograms
No Limit
Accumulation Time Limit
None.
180 days, or 270 days if waste is transported more than 200 miles to disposal
90 days, unless the facility obtains a RCRA storage facility permit.
RCRA Personnel Training Required?
No.
Yes. SQG personnel are required to be thoroughly familiar with proper waste handling
and emergency procedures. (40 CFR 262.34(d)(5)(iii).
Yes. LQG personnel are required to obtain RCRA training. (40 CFR 262.34(a)(4) and 40
CFR 265.16(a) to (c).
Container Requirements for Accumulated Hazardous Waste
None Applicable.
Containers used at SQGs must be compatible with the wastes stored in them. Handling of
incompatible wastes must comply with safe handling practices (40 CFR 262.34(d)(2) and
40 CFR 265.172, 265.173, and 265.177)
Containers used at LQGs must be compatible with the wastes stored in them. Handling of
incompatible wastes must comply with safe handling practices. (40 CFR 262.34(a)(1)(i) and
40 CFR 265.172, 265.173, and 265.177)
Facility Design Requirements?
No.
SQG storage areas must be designed, constructed, maintained, and operated to minimize
possibility of a fire, explosion, or unplanned release. (40 CFR 34(d)(4) and 40 CFR 265.30 to 265.37)
LQG storage areas must be designed, constructed, maintained, and operated to minimize
possibility of a fire, explosion, or unplanned release. (40 CFR 34(a)(4) and 40 CFR 265.30 to 265.37)
Container Design Requirements?
No.
No.
Containers > ~26 gallons used at LQGs must meet design standards. (40 CFR 262.34
(a)(1)(i), 265,178, 265.1087(a) through (b)(1)(i) and (c))
Use Of Hazardous Waste Manifests Required for Transportation?
No.
Yes. (40 CFR 262.20, 262.42(b), and 262.44)
Yes. (40 CFR 262.20, 262.40, and 262.42(a))

Requirement
CESQG
SQG
LQG
DOT Hazardous Materials Transport Requirements applicable to Waste Transportation?
No.
Yes. (49 CFR 171.8 and 40 CFR 262.20, 262.42(b), and 262.44)
Yes. (49 CFR 171.8 and 40 CFR 262.20, 262.40, and 262.42(a))
Self-Transportation of waste by generator to another location allowed?
Yes.10
No. Licensed hazardous waste transporters must be used. (40 CFR 262.12(c))
No. Licensed hazardous waste transporters must be used. (40 CFR 262.12(c))
Emergency Response Coordinator Required?
No.
Yes. (40 CFR 262.34(d)(5))
Yes. (40 CFR 262.34(a)(4) and 40 CFR 265.55)
Inspection Required?
No.
Yes. Storage areas must be inspected each week. (40 CFR 262.34(d)(2) and 40 CFR 265.174)
Yes. Facility must have written Inspection Plan (40 CFR 262.34(a)(1)(i) and 40 CFR 265.178.)
Facility Contingency Plan Required?
No.
No.
Yes. (40 CFR 262.34(a)(4), 40 CFR 265.50 to 265.54)
Generator EPA Identification Number Required?
No.
Yes. (40 CFR 262.12(a) (b) and 40 CFR 265.11)
Yes. (40 CFR 262.12(a) (b))
Permitted or Interim Status Facilities must be used for waste disposal?
No.11
Yes. (40 CFR 262.12(c))
Yes. (40 CFR 262.12(c))
Maintain Waste Analyses, Tests and Determination records for 3 years since waste was sent to TSDF
No.
Yes. (40 CFR 262.40 (c)).
Yes. (40 CFR 262.40 (c)).
Storage Area Fire Prevention Design Requirements?
No.
Yes. (40 CFR 262.34(d)(4) and 40 CFR 265.3  265.37)
Yes. (40 CFR 262.34(d)(4) and 40 CFR 265.3  265.37)
10 Some States, including Arkansas, Minnesota and Wisconsin, require licensed
transporters for CESQG waste.
11 Some state regulations require disposal of CESQG waste in permitted disposal
facilities.

Requirement
CESQG
SQG
LQG
Determine if Waste Requires Treatment Before Land Disposal (Restricted Waste)?
No.
Yes. (40 CFR 268.7(a)(1))
Yes. (40 CFR 268.7(a)(1))
Satellite Accumulation Points?
No.
Yes, as much as 55 gallons of hazardous waste or 1 qt. of acutely hazardous waste
at or near initial point of generation. (40 CFR 262.34(c))
Yes, as much as 55 gallons of hazardous waste or 1 qt. of acutely hazardous waste
at or near initial point of generation. (40 CFR 262.34(c))
Containment Building Operating Requirements?
No.
Yes.
Yes. (40 CFR 262.34(a)(1)(iv), 40 CFR 265.1101(a)(3), (c)(1), and (c)(4))
Packaging and Labeling Requirements for Off-site Transport (Complying with DOT Regulations)?
No.
No.
Yes. (40 CFR 262.30 through 262.33)
Ten-day storage limit at transfer facility in DOT approved containers?
Yes.
Yes. In the event that the ten-day limit is exceeded, the site would be classified
as a hazardous waste storage facility subject to RCRA permit requirements.
Yes. (40 CFR 263.12)

State, local, and Tribal entities using grant funding to conduct hazardous waste removal
actions would become classified as hazardous waste generators. Approximately 97
percent of hazardous waste removal actions reported by DEA in 2000, 2001, and 2002
involved less than 100 kilograms of hazardous waste, the threshold for classification as a
CESQG. Occasionally, law enforcement agencies encounter more than 100 kilograms, or
more than 1,000 kilograms, of hazardous waste to be removed from clandestine drug
laboratories. DEA reported that 3 percent of removal actions involved more than 100
kilograms of hazardous waste and approximately 0.5 percent of removal actions involved
more than 1,000 kilograms of hazardous waste.
The DOJ COPS Office Methamphetamine Initiative will not limit the quantity of
hazardous waste that a grantee may handle in a single grant-funded removal action. If
qualified personnel conduct removal actions involving more than 100 kilograms, or more
than 1000 kilograms, of hazardous waste, the removal action would be subject to RCRA
regulations for small quantity generators (SQG), or large quantity generators (LQG)
respectively. The DOJ COPS Office will neither limit the period of time that hazardous
waste may be stored in a hazardous waste storage unit. Therefore in some cases storage
units may store hazardous waste for more than 10 days, and thereby require a RCRA
permit to operate as a hazardous waste storage facility. It may also be the case that a
grantee may accumulate more than 100 kilograms of hazardous waste at a temporary
storage location, even if individual removal actions are limited to 100 kilograms or less
(i.e., the grant-funded agency discovers more than one laboratory in the same week, or
month.) However, some states (e.g., California, Nebraska) regulate the amount of
hazardous waste that may be self-transported and limit the period of time that the waste
could be stored in a storage unit.
According to statistics provided by the El Paso Intelligence Center (EPIC) NCLSS
Reports from 2000, 2001, and 2002 (to date) the average amount of hazardous waste
removed from clandestine drug laboratory sites is approximately 20 kilograms (44
pounds) of hazardous waste per site. A summary of the reported data for hazardous waste
removal actions for 2000, 2001, and 2002 is included in Table 5.1-2. More than 50
percent of the 7,572 removal actions for which data were reported involved the removal of
less than 3.5 kilograms (7.7 pounds) of hazardous waste, and more than 97 percent of the
removal actions involved the removal of less than 100 kilograms (220 pounds) of
hazardous waste. These data do not include all removal actions conducted by state or local
law enforcement agencies, but only those removal actions reported to EPIC. The DOJ
COPS Office anticipates that the characteristics of grant-funded removal actions would be
similar to the characteristics of removal actions reported to EPIC.
The average amount of 20 kilograms of hazardous waste recovered at a clandestine drug
laboratory location, and attributed to a single hazardous waste generator and generated
within any calendar month, would be under the RCRA threshold for classification as a
CESQG. As discussed above, the DOJ COPS Office Methamphetamine Initiative will not
limit the quantity of hazardous waste removed, transported or stored by a grantee.
Table 5.1-2

Average Amount of Hazardous Waste Removed from
Clandestine Drug Laboratory Sites
Reporting Calendar Year
2000
2001
2002
Total/Average
Total all hazardous waste reported recovered (kg)
31,139.6
86,232.0
33,243.6
150,615.2
Total reported removal actions (Job Numbers)
1,896
3,554
2,122
7,572
Average quantity per Job Number (kg)
16.4
24.3
15.7
19.9
Job Numbers with quantity > 100 kilograms
47
124
60
231 (3.0%)
Job Numbers with quantity > 1000 kilograms
3
8
2
13 (0.2%)
Note: Data are reported for calendar years 2000 and 2001 and for January  August 2002
Source: El Paso Intelligence Center (EPIC) NCLSS Reports from 2000, 2001, and 2002 (to date)
Because the grantees become the legal generators of hazardous waste found and removed
from clandestine methamphetamine laboratories, grantees would be responsible for
meeting the requirements for the quantities of waste recovered, transported, and stored.
The DOJ COPS Office anticipates that most agencies conducting removal actions would
operate as CESQGs. However, in some cases grantees may operate as SQGs or LQGs, or
operate a RCRA-permitted hazardous waste storage facility. Note that some state
regulations limit the quantity of hazardous waste that may be removed, transported, or
stored without a RCRA permit.12 In the event that a grantee does not wish to obtain a
RCRA permit for managing quantities of waste greater than 100 kilograms or greater than
the threshold amount set by state regulations, (or any amount of acutely hazardous waste,)
the grantee may contact a DEA contractor, or in some states a state-funded contractor
(e.g., California), to conduct the removal action, and transport, store, and dispose of
the hazardous waste. In either case the state and local law enforcement agency conducting
clandestine drug laboratory seizures becomes the legal hazardous waste generator for any
hazardous waste encountered at the laboratory location. In the event that Federal funding
is not available for the conduct of removal actions (e.g., under the No Action Alternative)
the state or local agency remains responsible for managing the hazardous wastes encountered.
12 Some states limit the amount of hazardous waste that a CEQSG generator can transport
without obtaining a hazardous waste transportation license. For example, the State of
California restricts CEQSG generators to transporting 23 kilograms of hazardous waste.
The State of Kansas limits CESQGs to generate no more than 20 kgs. of hazardous waste
in a calendar month, while the federal RCRA threshold for CESQGs is 100 kgs.
Although most clandestine drug laboratory removal actions involve quantities of
hazardous waste that would be classified under the CESQG threshold, the DEA National
Clandestine Laboratory Cleanup Program (which may conduct grant-funded removal
actions under the Proposed Action) is structured to meet the more stringent requirements
applicable to SQGs, including training of hazardous waste management personnel and
preparation of hazardous waste manifests. DEA contractors are required to implement
additional security requirements for removal, transportation, and storage of the hazardous
waste, and are required to classify all hazardous materials recovered from clandestine drug

laboratories as hazardous waste.
5.2 DOT Regulatory Requirements
In addition to RCRA requirements, the shipment of hazardous waste from clandestine
laboratory sites to temporary storage units is also subject to DOT regulations for the
transport of hazardous waste (49 CFR 171-179). DOT defines hazardous waste as any
hazardous material for which RCRA provisions require a Hazardous Waste Manifest.
Therefore the applicability of DOT regulations depends on the EPAs definition of
hazardous waste under RCRA and on the exemptions from manifesting requirements as
specified in RCRA. In particular, waste that qualifies for a CESQG exemption is not
required to conform to DOT regulations for transport of hazardous waste.
The DOT regulations for the transport of hazardous waste include general provisions
governing approved containers and packaging methods, labeling and marking of
containers and packages, use of identification numbers to classify specific hazards,
placarding of transport vehicles, use of shipping papers, incident reporting, emergency
response information, training, and procedural requirements when using motor vehicles on
public highways. The DOT general provisions and exemptions for limited quantities and
small quantities are shown in Table 5.2-1 and described below.
General Provisions
Unless a hazard-specific quantity exemption is provided for, the DOT provisions prescribe
rigorous design standards for the packages and containers that are used to transport all
types of hazardous waste. Specific labels are required for all portable containers and
non-bulk packages containing hazardous materials that are listed in the DOT Hazardous
Materials Table (i.e., 49 CFR 172.101). Generators and transporters must mark each
package, freight container, and transport vehicle containing hazardous waste with the
shipping name, material identification number, technical names, and other information as
specified in 49 CFR 172.300 et seq. For shipments of over 1,000 pounds (454 kilograms)
of hazardous waste, placards specific to the relevant hazard class must be affixed to the
transport vehicles. Hazardous waste shipments must be accompanied by readily
accessible shipping papers that contain all relevant information needed to identify and
safely handle the waste, and to respond appropriately in the event of an emergency.
The general provisions also require certain reporting measures in the event of a hazardous
waste release. For example, transporters must contact the National Response Center in the
case of a major incident. To help reduce the probability of an incident, Hazmat employees
must receive training in materials identification, safety, accident prevention, emergency
response measures, and issues specific to the mode of transport in which they are engaged.
For example, the regulations require certain loading, unloading and materials segregation
procedures when motor vehicles are used to transport hazardous waste on public
highways.

Table 5.2-1
Federal DOT Requirements for the Transport of Hazardous Waste13,14
Requirement
General 15
Limited Quantities
Small Quantities
Packaging
-Specific approved packages and containers are required for each type of hazardous material,
as specified in Section 173. Methods of packing and storage that affect transport safety
must be open to inspection.
-Up to 30 kg (gross weight) of certain hazardous materials (e.g., oxidizers and corrosives)
are exempted from these DOT-specification packaging requirements when placed in combination
packages in conformance with hazard-specific requirements.16,17
-Up to one ounce of certain hazardous liquids, solids and compressed gases are exempted
from these specific packaging requirements.18 Packages must conform to the broad guidelines
provided in 49 CFR 173.4.
Labeling requirements
-Specific labels are required for all portable containers and non-bulk packages that contain
hazardous materials listed in the Hazardous Materials Table.19
-Not required.
-Not required. (See 49 CFR 172.400a)
13 CESQGs are not required under RCRA regulations to transport hazardous wastes in accordance
with EPA and DOT regulations. DEA contractors are required to comply with RCRA regulations for
SQGs, including utilization of hazardous waste manifests, container markings, and vehicle placards,
regardless of the quantity transported. The DOJ COPS Office does not anticipate that vehicles used
to transport hazardous wastes generated from CESQGs would be equipped with DOT-regulation placards
or that hazardous wastes being transported would be accompanied by manifests, unless required by state regulation.
14 Iodine, an solid oxidizer and a corrosive that has been found in large quantities at
clandestine drug laboratories, does not appear to be regulated by DOT and is
therefore not subject to DOT packaging or transportation regulations. This may
represent a potential environmental hazard with respect to the Proposed Action because
iodine is incompatible with and reacts with, among other hazardous materials,
ammonia, which has also been found in large quantities at clandestine drug laboratories.
15 Applies to each person who transports (or offers for transport), a hazardous material that is not otherwise exempted.
16 See, for example, 49 CFR 173.152 and 49 CFR 173.154 for limited quantity
specifications for oxidizers and corrosives, respectively. Combination packages
are large packages that contain smaller, separate units of specified capacity,
with intermediate packaging.
17 State hazardous materials transportation regulations also regulate packaging
 of hazardous materials, including anhydrous ammonia. For example, Illinois
Public Act 91-0889 prohibits transport of anhydrous ammonia in a portable container
if the container is not a package authorized for anhydrous ammonia
transportation as defined in rules adopted under the Illinois Hazardous Materials
Transportation Act. Other states, including Washington, have similar laws.
18 These quantities are far lower than the quantities of hazardous waste to
which the CESQG exemption applies. Therefore materials in these quantities are also
exempt from DOT regulations for the transport of hazardous waste under RCRA regulations.
See 49 CFR 173.4 and 173.306.
19 See 49 CFR 172.101 and 49 CFR 172.411 through 172.450

Requirement
General 15
Limited Quantities
Small Quantities
Marking requirements
-Generators and transporters must mark each container and transport vehicle
containing a hazardous material according to specifications in 49 CFR 172.300
et seq. 20 (including shipping name, material identification number, and technical names).
-Same as general unless specified otherwise below (e.g., specific exemptions
for identification numbers).
-Packages must be marked as follows: This package conforms to 49 CFR 173.4
Identification numbers
-The DOT ID number of each hazardous material must be marked on its packaging. (See 49 CFR 172.334)
-Not required.
-Not required.
Placarding of Vehicles
-Hazard-specific placards must be affixed to vehicles used to transport hazardous waste.
-Placards are not required when the transported waste consists of less than 1000lbs
(454kg) of certain hazardous materials. 21
-Not required. These general requirements also do not apply to non-bulk packaging
that contains only residue of certain materials.22
Shipping papers
-Hazardous waste must be accompanied by shipping papers that identify and describe
the waste, hazard class, ID number, packaging group, capacity, emergency contact information,
and signed certification from the waste generator.23
-Same as general. Limited quantity materials must also be identified as
such on the shipping papers.24
-Not required.
Reporting
-In the case of an incident while transport is underway, the driver must contact
the carrier.25 In the case of a major incident, transporters must contact National Response Center.
-Same as general.
-Not required.
Required Emergency Response Information
-The shipping paper must contain the name and description of the material,
immediate hazards to health, risks of fire or explosion, immediate actions
to be taken, first aid information, and the telephone number of someone to
provide comprehensive emergency response information.26
-Same as general.
-Not required.
20 As specified in 49 CFR 172.300
21 See 49 CFR 172.504. The pertinent wastes include all of those typically
found at clandestine laboratories, e.g. flammable and non-flammable liquids,
flammable and non-flammable gases, flammable solids, oxidizers and corrosives.
22 These include several classes of explosives, as well as flammable gas, non-flammable gas,
 poison gas, flammable liquid, flammable solid, spontaneously combustible materials,
oxidizers, and corrosives. Together these exemptions comprise all the types of materials
that have been found in significant quantities at
clandestine drug laboratories by the DEA over the past three years.
23 See 49 CFR 172.204
24 See 49 CFR 172.500.
25 See 49 CFR 172.606
26 See 49 CFR 172.602.

Requirement
General 15
Limited Quantities
Small Quantities
Availability of Emergency Response Information
-Must be immediately accessible at all times to hazmat employees, including drivers,
at any facility where a hazardous material is received, stored or handled during
transportation, and any government employee responding to or investigating an incident.27
-Same as general.
-Not Applicable.
Hazardous Waste Manifests
-Waste shipments must be accompanied by manifests developed jointly by EPA and DOT
for this purpose. Manifests may replace shipping papers.
-Not required based on CESQG exemption in RCRA regulations. State regulations may
require use of hazardous waste manifests for transport of CESQG hazardous waste.
-Not Applicable.
Hazardous Materials Training Requirements
-Hazmat employers28 must ensure that hazmat employees29 are trained in material
identification, safety, accident prevention, and emergency response.30 States may
require more stringent requirements. OSHA/EPA training may be used to avoid duplication.
In addition, carriers must ensure that drivers receive modal-specific training.31
-Same as general.
-Not Applicable.
Use of Motor Vehicles and Public Highways
-Procedures for loading/unloading hazardous materials into/from a motor vehicle
for highway travel must adhere to requirements particular to each type of material.32 In
addition, during loading/unloading, intermediate storage and transport, materials
must be segregated according to specified safety standards.33
-Same as general.
-Not Applicable.
27 49 CFR 172.600, 172.602 and 49 CFR 172.604
28 Includes any private or public sector individual who uses employees to help transport hazardous materials.
29 Includes any private or public sector employee, including a driver, who
directly affects hazardous materials transportation safety.
30 49 CFR 172.700 and 49 CFR 172.702
31 This includes training specific to the transport of hazardous materials by
motor vehicle as well as standard motor vehicle operation training as specified in 49
CFR parts 390 through 397.
32 49 CFR 173.30 and 49 CFR 177.834 and 49 CFR 177.835 through 177.841.
33 49 CFR 177.848

Limited Quantities
Up to 30 kg of certain hazardous materials (e.g., oxidizers and corrosives) qualify for a
limited quantity exemption from the general packaging specifications, provided they are
packed according to certain guidelines in containers that meet a list of performance
standards. These guidelines and standards require the sub-packaging of wastes in small
quantities (e.g., 1 liter of liquid), which may be placed together with other units in
combination packages in conformance with hazard-specific requirements. Limited
quantity shipments under this exemption are not required to follow the labeling
requirements, and are not required to use material-specific identification numbers.
Generators and transporters of limited quantities must follow the marking requirements
specified in the general provisions, or may use a special exemption marking if the broad
packaging guidelines contained in 49 CFR 173.13 are used. Placards are not required on
vehicles transporting limited quantities of hazardous waste. Shipments of limited
quantities must, however, be accompanied by shipping papers, which must additionally
specify that the shipment contains hazardous wastes transported as a limited quantity.
Finally, limited quantity shipments must conform to the general provisions for reporting
release incidents, HAZMAT employee training, and procedures specific to the use of
motor vehicles for the transport of hazardous waste on public highways.
Small Quantities
Certain very small quantities of specific hazardous wastes are exempted from all DOT
general provisions, as long as they are packaged according to the broad guidelines
provided in 49 CFR 173.4, and marked with a label stating this to be the case. The
allowable small quantities are 1 ounce for both liquid and solid wastes that belong to
certain waste classes, e.g. corrosives, oxidizers, and flammable liquids and solids.
DOT Regulations and the CESQG Exemption Under RCRA
As discussed above, waste generators are not required under RCRA to use a hazardous
waste manifest for the transport of CESQG wastes. The required use of the hazardous
waste manifest determines the applicability of DOT regulations for the transport of
hazardous waste. Since virtually all of the grant-funded removal actions are expected to
involve the removal of less than 100 kilograms (220 pounds) of hazardous waste, the DOJ
COPS Office expects nearly all grant-funded removal actions to be carried out using the
CESQG exemption. Hence the DOT regulations for the transport of hazardous waste
would not apply to the vast majority of removal actions.
5.3 Fire Protection Codes
Fire protection codes and regulations are applicable to the storage of hazardous wastes at
storage units under the Proposed Action. Grantees must consider the National Fire
Protection Association (NFPA) Code 30, Flammable and Combustible Liquids Code, and

NFPA Code 230, Standard for Fire Protection of Storage when storing hazardous wastes
removed from clandestine methamphetamine drug laboratories.34 35 The NFPA Code 30
has been adopted as statewide fire protection regulations in 34 states, including Arkansas,
Iowa, Kansas, Louisiana, Missouri, Nebraska, New Mexico, North Dakota, Texas, Utah,
and all states east of the Mississippi River except Indiana and Pennsylvania.36
The hazardous materials found in clandestine methamphetamine laboratories may be
classified as flammable, combustible, toxic, reactive, caustic, and as incompatible with
other materials. For example, NFPA Code 30 divides liquids by properties and classes.
Flammable liquids, known as Class I liquids, are defined as having a flash point less than
100 degrees F. Combustible liquids are known as Class II liquids and are defined as a
liquid having a flash point of 100 degrees F or higher.
For flammable and combustible liquids, many of the NFPA Codes for storage of have
been adopted in OSHA Regulation 29 CFR 1910.106, Occupational Safety and Health
Standards: Flammables and Combustible Liquids.37 RCRA regulations also address fire
protection requirements for the generation, transportation, and storage of hazardous
wastes. Grantees storing hazardous waste for more than a 10 day period are required to
obtain a RCRA hazardous waste storage facility permit and must meet RCRA
requirements for hazardous waste storage, including safety and fire protection standards.
NFPA Codes and OSHA regulations also apply to permitted hazardous waste storage.
These regulations are intended to prevent unauthorized persons from physical contact with
the waste or equipment and are intended to prevent ignition or reaction of ignitable or
reactive waste. Warning signs are obligatory, as are emergency communication
equipment, firefighting equipment, and water or foam supplies. Grantees must provide
space for movement of personnel and fire/spill control equipment. In the event of a spill,
the operator of a RCRA permitted facility must be able to contain any flow and clean up
any release of hazardous wastes. Regulations for Storage of Flammable and Combustible
Materials are summarized in Table 5.3-1.
34 NFPA, 2000. National Fire Protection Association, NFPA Code 30, Flammable
and Combustible Liquids Code, 2000 Edition.
35 NFPA, 1999. National Fire Protection Association, NFPA Code 230, Standard
for Fire Protection of Storage, 1999 Edition.
36 NFPA, 2002. Comprehensive Consensus Codes NFPA 30, Flammable and Combustible
Liquids Code, http://www.nfpa.org/BuildingCode/aboutc3/nfpa_30/nfpa_30.asp
37 OSHA requirements apply only to the storage of flammable or combustible liquids
in drums or other containers (including flammable aerosols) not exceeding 60 gallons
individual capacity and those portable tanks not exceeding 660 gallons individual capacity.

Table 5.3-1
Regulations for Storage of Flammable and Combustible Materials
Requirement
Description
Location
Container and Portable Tank Storage
-Storage of flammable and combustible liquids in containers and design of storage units
-29 CFR 1910.106(d)
Storage of flammable and combustive hazardous wastes
-Types and quantities
-NFPA Code 30 and 20 CFR 1910.106(d)
Fire protection requirements
-Generation, transportation, and storage of hazardous wastes
-40 CFR 262.34(d)(4), 264.14 - 264.37, and 265.3 to 265.37
Storage and handling of anhydrous ammonia
-Storing anhydrous ammonia away from ignitable materials and fire hazards either in a
separate building areas or section of the building
-American National Standard for the Storage and Handling of Anhydrous Ammonia, K61.1, OSHA 1910.111
Storage cabinets for flammable liquids
-Design, construction and capacity requirements
-OSHA regulations, 29 CFR 1910.106(d)(3).
The DOJ COPS Office anticipates that grantees performing their own removal actions
using qualified law enforcement personnel would store the hazardous waste in storage
units either inside or outside a building. In either case, flammable liquids may be stored
in a storage cabinet whereas flammable liquids and other hazardous materials may be
stored in a hazardous materials storage locker. Storage cabinets are usually indoor
storage units. Storage lockers are prefabricated structures designed to meet local, state,
and federal requirements for outside storage of hazardous materials. The lockers are
primarily for outdoor storage, but may also be used inside a building.
Storage cabinets for flammable liquids must meet design, construction and capacity
requirements. Storage cabinets may be constructed of metal or wood and must be
designed and constructed to withstand certain fire tests. These flammable liquids storage
cabinets are not required to have exhaust ventilation systems under NFPA Code 30.
However, NFPA does indicate that most cabinets are designed to be equipped with such
ventilation systems. Flammable liquids storage cabinets that are located indoors also do
not need to be vented. However, if the cabinet is vented, it must be vented outside the
building from the bottom with make-up air supplied from the top.
Safety regulations for storage of hazardous waste also limit the quantities of waste than
may be stored in a cabinet or locker. For example, not more than 60 gallons
(approximately 200 kilograms) of Class I or Class II flammable liquids and not more than
120 gallons of Class III liquids may be stored in a single storage cabinet according to
OSHA. However, quantities above 200 kilograms of Class I or II flammable liquids
would require multiple storage cabinets under OSHA.
Restrictions on quantities of flammable materials stored either inside or outside are
dependent on fire area ratings. A fire area is defined as an area of a building

separated by the rest of the building by some construction that has a fire resistance
of at least one hour. All communication openings (e.g., doors) also must have the same fire
resistance of at least one hour.38 Both OSHA regulations (29 CFR 1910.106(d)(4)) and
NFPA Code 30 allow up to approximately 1,000 kilograms (300 gallons) in one 150
square foot area with a one-hour fire resistance.
Indoor Storage
For indoor storage, NFPA Code 30 allows up to three 60-gallon storage cabinets in one
fire area. Under OSHA and NFPA, any quantities above 1,000 kilograms and below
2,000 kilograms would require fire protection in the form of sprinkler, water spray,
carbon dioxide or other system. Further, quantities above 2,000 kilograms would also
require a 2-hour fire resistance for inside rooms. NFPA Code 30 provides requirements for
automatic fire protection based on the type of container (e.g., metal, fiberboard, glass),
and the type, quantity, and storage style (e.g., pile, rack) of the flammable liquid.
According to OSHA, the inside storage room would have to have a gravity or mechanical
exhaust ventilation system. Also, both OSHA regulations (29 CFR 1910.106(d)(5)) and
NFPA Code 30 specify that Class I flammable liquids may not be stored in the basement
of a building.
OSHA and RCRA regulations and NFPA Codes specify acceptable storage conditions and
locations permitted for indoor storage of flammable materials. Storage cabinets are not to
be located near exit doorways, stairways, or means of egress, and are not to be located
near ignition sources. Indoor windows should be protected as specified in OSHA
regulations and in NFPA Code 251-1969 Standard Methods of Fire Tests of Building
Construction and Materials. Also, according to NFPA Codes for inside storage rooms, all
electrical wiring must meet Class I, Division 2 requirements for Class I flammable liquid
storage.
Outdoor Storage
If hazardous materials or flammable liquids are stored outside, they may be stored in
hazardous materials lockers, piles, or pallets. However, they must meet a variety of
OSHA regulations and NFPA Code 30 requirements including minimum distance to
access way. Flammable liquids may be storage in piles of containers, but cannot exceed
certain quantities. Examples of these quantities per pile are given in Table 5.3-2.
Table 5.3-2
Pile Size for Flammable Liquids
Flammable Liquids 	Pile Size
Class IA 		1,100 gallons
Class IB 		2,200 gallons
38 Resistance rates may be more than one hour depending on whether the room is an inside
room, cutoff room, or liquid warehouse. Inside room is a room totally enclosed in a building
without exterior walls; cutoff room has at least one exterior wall, and liquid warehouse is
separate detached building for warehousing liquids.

Class IC 		4,400 gallons
Source: NFPA Code 30 and OSHA
The smallest size pile is sufficiently more than 1,000 kilograms such that the DOJ COPS
Office anticipates that only a single pile would be needed for most storage activities.
Distances between piles and distances between the pile and the property line or street are
also provided in NFPA Code 30 and OSHA. For example, according to OSHA, for Class
IA liquids, the distance between a pile and a property line must be at least 20 feet and
between a pile and a street or alley must be at least 10 feet. Further, there are
requirements for the pile adjacent to a nearby building. The storage area must be graded
to divert possible spills away from buildings to drain such spills in contained locations.
The storage areas must be protected against tampering or trespassers.
In addition to flammable liquids, there may be toxic, reactive, caustic, and other types of
hazardous materials found in clandestine methamphetamine laboratories. A range of
toxic, explosive materials including flammables and combustibles liquids are included
hazardous materials definitions in 40 CFR 1910 and OSHA. According to NFPA Codes,
hazardous materials present hazards beyond the fire problems related to flash point and
boiling point. The hazards may arise from a materials toxicity, reactivity, instability, or
corrosivity.
In accordance with NFPA Code 30, these toxic, reactive, unstable, and corrosive materials
may be stored in hazardous materials storage lockers that may be placed inside or outside
a building. If stored inside a building, the same limitations as described for storage
cabinets apply. If stored outside a building, the lockers must meet regulatory
requirements such that lockers shall not exceed 1,500 square feet of floor area. Lockers
should have spill containment to prevent flow of liquids from the structure during an
emergency and there should be appropriate distances between the lockers (e.g., five feet)
and between the locker and the property line. Unpackaged materials (not in original
packaging) should only be stored in shelves or on the floor of the locker. Containers over
30 gallons storing Class I or Class II liquids should not be stored more than two containers
high. Additionally, all placarding or warning signs for lockers should be in accordance with
all federal, state, and local regulatory requirements and in accordance with NFPA 704 Standard
System for the Identification of the Hazards of Materials for Emergency Response.
It should be noted that both EPA and individual states (e.g., California) have regulations
and guidelines related to storage of incompatible hazardous wastes (e.g., corrosive
materials and flammable materials.)39 Incompatible materials may be required to be stored
in different cabinets, or to be separated by barriers if stored within the same cabinet. In
that case, grantees may be required to have specially designed storage units that
incorporate such barriers, or may be required to have more than one storage unit, in order
to store the various types of hazardous waste that are anticipated to be recovered at
clandestine drug laboratory sites, depending upon the specific types of hazardous wastes

recovered from removal actions.
39 California Code of Regulations CCR Title 24, Part 8, Section 7902; California Fire Code, Section 8001.11.8.
5.4 DOJ COPS Office Methamphetamine Initiative Policies and Procedures
The DOJ COPS Office Methamphetamine Initiative Policies are outlined in the
Methamphetamine Initiative Grant Owners Manual. Grant conditions are established
within the Public Safety Partnership and Community Policing Act of 1994, under which
the COPS office was established. Other policies are applicable as issued by the DOJ, the
Office of Management and Budget (OMB), the General Accounting Office, the US
Treasury, the EPA, OSHA and DOT. Personnel who remove hazardous wastes and
contaminated materials from a clandestine laboratory site must be qualified to do so. In
order to be considered qualified, an individual must comply with all Federal, State, and
local environmental, health and safety laws and regulations applicable to the removal of
all hazardous wastes and contaminated materials from a clandestine laboratories. These
include, but are not limited to RCRA (40 CFR 260, et seq.,) OSHA regulations (29 CFR
1910.120 and Part 1200), and DOT regulations on the labeling and transportation of
hazardous wastes (49 CFR 171, et seq. and Parts 350-399.)
The grant conditions establish policies to which grantees agree. Procurement
requirements are addressed regarding competitive bids for contractors. Allowable costs
are outlined with the intention to help policing agencies develop infrastructure to
institutionalize and sustain policing practices. Allowable costs include but are not
limited to salaries and benefits, overtime, training, travel, consultants, and equipment.
It is the intention of the DOJ COPS Office to supplement, not supplant funds for activities
that would not have take place in the absence of the grant.
The DOJ COPS Office seeks to document on a continuing basis the proper use of federal
funds by grantees. The DOJ COPS Office conducts evaluations and requires periodic
progress and quarterly financial status reports. Grantees must confirm that they are in
compliance with federal audit requirements and OMB regulations. The reports must
contain information on the status of funded activities, updates on hiring activities,
updates on the purchase and installation of any grant-funded equipment and technology, and
any progress the agency has made with respect to law enforcement as a result of its
involvement in the Methamphetamine Initiative. The DOJ COPS Office requires that
grantees operating inter-jurisdictional criminal intelligence systems (a system that
receives, stores, analyzes and exchanges data regarding ongoing criminal activities)
comply with operating principles in 28 CFR Part 23. Grantee activities may be further
monitored through telephone calls and/or site visits from representatives of the DOJ
COPS Office. In FY 2003, grantees will be required to file reports to the DOJ COPS
Office. The report forms are currently being reviewed and approved by OMB. In FY
2003, grantees will also have to report clandestine drug laboratory seizure activities to
EPIC and RiskNet.
Grantees must also agree to any special conditions as determined by the DOJ COPS
Office. One such special condition is the Special Condition for Methamphetamine
Initiative: Mitigation of Health, Safety, and Environmental Risks (Appendix D). The DOJ

COPS Office expects grantees to comply with all federal, state, and local environmental
health, and safety laws and regulations during all aspects of grant funded activities.
Specific federal regulations are discussed in Sections 5.1, 5.2 and 5.3 of this
Environmental Assessment. Grantees are responsible for complying with any state and
local regulations, which may be more stringent than some federal requirements.
6.0 Environmental Consequence Analysis Scenarios
6.1 Scope of Methamphetamine Initiative
The incidence of clandestine drug laboratories has grown dramatically in the past 10
years. For example, in Fiscal Year 1992, the DEA funded approximately 400 removal
actions at clandestine drug laboratory locations. In fiscal year 2001, the DEA funded
removal actions at more than 6,400 locations, and DEA anticipates funding approximately
7,255 removal actions in fiscal year 2002. Clandestine drug laboratories are still most
prevalent in the West, Midwest, and Southwest, but are becoming more prevalent in the
Southeast. There are at present relatively few clandestine drug laboratories discovered in
the Northeast. More than 500 DEA-funded removal actions were conducted in Arkansas,
Oklahoma, Tennessee, and Texas in fiscal year 2001, and between 200 and 500 DEA-
funded removal actions were conducted in Alabama, Arizona, Colorado, Georgia, Illinois,
Iowa, Minnesota, Mississippi, and Washington. These statistics do not include all
clandestine drug laboratory seizures conducted by state methamphetamine initiatives.
The DOJ COPS Office does not have comprehensive statistics concerning the number of
grant-funded clandestine drug laboratory seizures conducted, however, the number of
grant-funded seizures has increased sharply in recent years.
The increasing rates of removal actions and recent grant application project summaries
indicate that states are dependent upon DOJ COPS Office Methamphetamine Initiative
funding to support and supplement their methamphetamine initiatives. Several state
initiatives have been receiving a significant amount of funding through the DOJ COPS
Office Methamphetamine Initiative, and several states, including Missouri, have received
funding for several initiatives operating in different geographic areas of the state. The
state initiatives discussed in detail in Appendix I are California, Hawaii, Missouri,
Washington, Iowa, Wisconsin, Arkansas and Mississippi.
6.2 Hazardous Waste Management Scenarios Development Approach
The environmental consequence analyses are based on analysis of scenarios for the two
principal activities associated with the Proposed Action: grant-funded hazardous waste
management activities at clandestine drug laboratory locations, and other grant-funded
activities. Hazardous waste management activities include the seizure of laboratories,
removal, transportation and the temporary storage of hazardous waste recovered from
laboratory seizures. The scenario development methodology for the hazardous waste
management scenarios focused on the types of clandestine drug laboratory structures and
the types of neighborhoods in which the clandestine drug laboratories were discovered,
and on the characteristics of the transportation equipment and storage units that may be

used to the manage hazardous wastes recovered in the removal actions.
For the purposes of the quantitative environmental consequences analysis, the DOJ COPS
Office assumed an accidental release scenario of 100 kilograms of hazardous waste. This
release scenario was applied to the air, water and soil quality analyses. The quantitative
analysis is based on a release quantity of 100 kilograms because an anticipated 97 percent
of removal actions would involve less than 100 kilograms of hazardous waste, and
because the DOJ COPS Office anticipates that for most grant-funded removal actions the
largest single container of hazardous waste handled, transported, or stored would contain
100 kilograms. The DOJ COPS Office does not require grantees to restrict grant-funded
removal actions to less than 100 kilograms quantity, and therefore Section 8.0 includes a
qualitative discussion of handling, transportation, and storage of quantities of hazardous
waste greater than 100 kilograms. For the qualitative analysis of the fire scenario the DOJ
COPS Office assumed that more than 100 kilograms of flammable material may be stored
at a single location and involved in the fire. Individual hazardous waste storage units may
contain more than 100 kilograms of hazardous waste.
6.3 Removal Action Scenario Development
The removal action scenarios were developed to reflect the most common characteristics
of clandestine drug laboratory locations. The DEA administers the National Clandestine
Laboratory Cleanup Program, for which it maintains a database of clandestine drug
laboratory seizures reported through the National Clandestine Laboratory Seizure System
(NCLSS) at the El Paso Intelligence Center (EPIC). As of Fiscal Year 2003, grantees will
be required to report seizure operations to EPIC and RiskNet, however, detailed data for
state and locally conducted laboratory seizures for 2000, 2001, and 2002 are not available.
In the absence of such data, DEA data were used. The reporting system characterizes clandestine
drug laboratory seizures with respect to laboratory structure (e.g., single family house),
laboratory neighborhood (e.g., urban), and the types and amounts of hazardous wastes seized
at the location. The types and quantities of hazardous wastes discovered at clandestine drug
laboratory locations vary depending on the types and
quantities of illegal drugs being produced.
6.3.1 Clandestine Drug Laboratory Hazardous Waste Quantity Data
NCLSS data for clandestine drug laboratory hazardous waste removals for 2000, 2001,
and 2002 are summarized in Table 6.3-1. Table 6.3-1 illustrates the hazardous wastes
(chemical names) removed from clandestine drug laboratory sites and the number of sites
where removal of that specific hazardous waste was reported. Relevant physical and
chemical characteristics of these wastes are summarized in Appendix J, Health Hazards of
Chemicals Used in Methamphetamine Production. Based on data for 2000, 2001, and
2002 (to date) the average amount of hazardous waste removed from clandestine drug
laboratory sites was 20 kilograms (44 pounds), and 97 percent of removal actions for
which data were reported involved removal of less than 100 kilograms of hazardous
waste.

Table 6.3-1
Hazardous Wastes Recovered from DEA-funded
Removal Actions at Clandestine Drug Laboratory Sites
Chemical Name
Total quantity recovered from all sites (kg):2000
2001
2002
Maximum recovered from any site (kg)
2,5-DIMETHOXYBENZALDEHYDE
340.69
0
0
340.69
ACETIC ANHYDRIDE
19.03
25.77
4.91
17.28
ACETONE
1,827.76
5,012.79
1,713.67
1,001.69
AMMONIA GAS (COMPRESSED)
5,842.27
26,447.38
12,510.18
2,305.04
ANTHRANILIC ACID
0
801.65
0.10
801.65
BUTYLAMINE
21.39
0
0
21.39
CYCLOHEXANONE
0
75.76
0.10
75.76
EPHEDRINE
265.41
1,238.33
215.56
429.68
ERGOMETRINE
0
1.5
0
1.50
ETHYL ACETATE
14.81
18.52
2.54
17.77
ETHYL ETHER
969.05
1,574.59
348.05
369.68
ETHYLAMINE
0
0
0.38
0.38
FORMAMIDE
0
2.27
0
2.27
FORMIC ACID
94.60
0
0
91.60
HYDRIODIC ACID
185.69
595.35
93.09
387.90
HYDROCHLORIC ACID
1,292.88
1,900.79
1,100.92
136.33
IODINE
4,337.46
17,068.34
10,756.72
1,732.22
IODINE (CRYSTALS)
4,898.43
2,718.41
1,571.45
1,866.21
LITHIUM METAL
2.25
210.59
44.54
28.30
METHAMPHETAMINE LIQUID
3.47
0.45
8.99
3.78
METHYL ETHYL KETONE
53.56
23.58
17.59
15.24
METHYLAMINE
20.58
19.63
0
17.07
N-ACETYLANTHRANILIC ACID
12.49
0.50
0
12.49
N-ETHYLEPHEDRINE
0
1.89
0.11
1.89
NITROETHANE
0.79
0
0
0.79
O-TOLUIDINE
0
0
0.05
0.05
PHENETHYLAMINE
0
2.40
28.35
28.35
PHENYL-2-PROPANONE(P2P)
0
0.96
0
0.96
PHENYLACETIC ACID
11.69
5.11
0
11.69
POTASSIUM PERMANGANATE
4,506.97
0.81
517.60
4,476.49
PSEUDOEPHEDRINE
5.93
52.13
12.15
28.35
RED PHOSPHORUS
1,858.23
20,619.61
855.56
6,930.45
SAFROLE
0
0
1.58
1.04
SODIUM DICHROMATE
1.19
2.50
1.02
2.50
SODIUM METAL
10.20
0.94
0.45
8.52
SULFURIC ACID
1,925.06
4,086.83
1,631.78
210.67
THIONYL CHLORIDE
0
40.90
0
15.43
TOLUENE
2,617.76
3,681.68
1,806.16
623.57

The specific hazardous wastes examined in the removal action and storage scenarios and
release scenarios include the toxic and flammable chemicals that were found at
clandestine drug laboratories. Data for removal actions are shown in Table 6.3-1. One of
the most common hazardous wastes recovered is anhydrous ammonia. Thus, the
quantitative analysis of environmental consequences related to air quality impacts for the
removal action and storage scenarios focuses on the environmental effects of releases of
100 kilograms of ammonia. The quantitative analysis of potential impacts to soil quality
is based on releases of acetone and toluene, and also on releases of sodium dichromate,
which was included in the analysis based on the toxicity of the substance. The
quantitative analysis of impacts to potential water quality is based on releases of toluene and iodine.
Based on historical data, DEA estimates that the number of clandestine drug laboratory
seizures could increase by as much as 35 percent per year over the next five years. The
DOJ COPS Office anticipates that there may be a similar increase in the number of
clandestine drug laboratory seizures conducted by state methamphetamine initiatives. The
environmental consequence analyses assume that the types and quantities of hazardous
wastes that are recovered from each individual removal action will remain relatively
constant for the next five years, but that the total number of sites and the total amount
of hazardous wastes recovered from all sites will increase by 35 percent per year over the
next five years.
6.3.2 Clandestine Drug Laboratory Site Characteristics Data
Clandestine drug laboratories have been discovered in diverse structures, including
vehicles, single-family houses, hotel/motel rooms, apartments, condominiums, mobile
homes, businesses, storage lockers, and in open space areas (i.e., no structure). NCLSS
data for clandestine drug laboratory structures for 2000, 2001, and 2002 are summarized
in Table 6.3-2. Neighborhoods where clandestine drug laboratories have been discovered
include commercial, industrial, rural, suburban, and urban locations. NCLSS data for
2000, 2001, and 2002 are summarized in Table 6.3-3. The DOJ COPS Office has
assumed for the purposes of the environmental consequence analyses that characteristics
would be similar to those reported by the DEA.
Table 6.3-2
Clandestine Drug Laboratory Site Characteristics  Laboratory Structure
Laboratory Structure
2000
2001
2002
TOTAL
Apartment
588
701
334
1623
Business
4
103
70
177
Condominium
28
34
11
73
Hotel/Motel
341
444
205
990
Mobile Home
847
1268
569
2684
Not Identified
270
496
617
1383
Open Air/No Structure
965
2531
1199
4695
Other
1256
1485
505
3246

Public Land
0
0
1
1
Single Family House
3356
4204
1745
9305
Storage Locker
158
177
64
399
Vehicle
1453
2035
1022
4510
TOTAL
9266
13478
6342
29086
Table 6.3-3
Clandestine Drug Laboratory Site Characteristics  Laboratory Neighborhood
Laboratory Neighborhood
2000
2001
2002
TOTAL
Commercial
379
461
282
1122
Industrial
156
174
79
409
Other
250
137
67
454
Public Land
0
0
11
11
Rural
3363
5833
2812
12008
Suburban
2367
3359
1043
6769
Urban
1847
2530
1141
5518
Unknown
914
1048
978
2940
TOTAL
9276
13542
6413
29231
Note: Data for 2002 include seizures reported for JanuaryAugust 2002
The potential environmental consequences of hazardous waste removal actions may differ
significantly based on the characteristics of the laboratory structure and neighborhood
where the laboratory is discovered, as well as on the types and quantities of hazardous
waste discovered. Because clandestine drug laboratory structures and neighborhoods are
diverse, three generic scenarios have been developed for the environmental consequence
analyses in this Environmental Assessment. These scenarios are anticipated to reflect the
range of potential environmental consequences associated with the Proposed Action.
In developing the removal action scenarios, NCLSS Report data from 2000, 2001, and
2002 (to date) was used to characterize the types of clandestine drug laboratory structures
and the types of neighborhoods where they were discovered. The data indicate that the major
portion of the clandestine drug laboratories discovered in the past three years were located
in rural, urban, or suburban neighborhoods, as opposed to commercial or industrial areas. The
removal action scenarios for the Proposed Action are based on rural, urban, and suburban
locations because of greater incidence of human and ecological receptors in those areas than
in commercial or industrial areas.
Examination of the NCLSS data revealed that the four largest categories of structure types
for clandestine drug laboratories are single-family houses, open air/no structure, mobile
homes, and apartments. For the purposes of analyses, single-family homes and mobile
homes are aggregated into a single category, single-family house, and apartments and
condominiums are aggregated into a single category, multi-unit residential property. The
open air/no structure category has characteristics that are significantly different than
categories that involve structures. Therefore open air/no structure is considered a
separate category for the environmental consequence analyses. Other clandestine drug

laboratory structure categories (i.e., hotel/motel, vehicle, storage locker, business)
included in the NCLSS Reports are anticipated to have environmental settings and
characteristics that are within the boundaries of the single-family house, multi-unit
residential property, and open air/no structure categories. Therefore the environmental
consequences analyses in this Environmental Assessment do not analyze all categories but
focus on the most prevalent three categories.
However, the DOJ COPS Office cannot determine from the NCLSS data for example, the
number of single-family houses reported and number of rural neighborhoods reported, or
the number of single-family houses located in rural neighborhoods or the number of
apartments located in urban neighborhoods. Therefore, the structure category and
neighborhood category data were combined into three scenarios:
 Single Family House (Urban, Suburban, Rural)
 Multi-unit Residential Property (Urban, Suburban); and
 Open Air/No Structure (Rural)
The basis for these scenarios is that single family houses (including mobile homes) may
occur in urban, suburban, or rural neighborhoods, while multi-unit residential properties
(apartments, condominiums) are somewhat more likely to occur in urban and suburban
neighborhoods than in rural neighborhoods. Open air/no structure clandestine drug
laboratories are somewhat more likely to occur in rural neighborhoods. Also, for the
purposes of the environmental consequences analyses, an open air/no structure clandestine
drug laboratory located in a rural neighborhood would have potentially greater
consequences with respect to ecological receptors than if located in an urban or suburban
neighborhood. The scenarios used for the environmental consequences analyses are
described in the following section.
Clandestine drug laboratories discovered by DEA and by state and local law enforcement
authorities have contained booby traps. These are constructed by suspects to deter law
enforcement authorities, and may be chemical, mechanical, or explosive in nature. Table
6.3-4 summarizes data from the NCLSS Reports concerning booby traps. Booby traps
may be detected and disarmed by law enforcement authorities in the function of their law
enforcement activities, however in some cases an undetected booby trap may remain at a
clandestine drug laboratory site after law enforcement activities are completed.
Table 6.3-4
Clandestine Drug Laboratory Site Characteristics  Booby Traps Discovered
Booby Traps Discovered
2000
2001
2002
TOTAL
Chemical
20
9
1
30
Mechanical
3
1
2
6
Explosive
8
2
0
10
Type Not Identified
5
37
4
46
TOTAL
36
49
7
92

6.3.3 Single Family House Removal Action Scenario
The Single Family House Removal Action Scenario reflects the characteristics of
clandestine drug laboratory locations that are reported in the NCLSS Reports as Single
Family House in the Laboratory Structure category and reported as Urban, or
Suburban, in the Laboratory Neighborhood category. This scenario is intended to
reflect locations where the laboratory and hazardous wastes are located in a single family
house where a release of hazardous wastes could contaminate the structure and/or soil, or
result in exposure of residents, and where a hazardous waste fire, explosion, or booby trap
could cause injury or ignite a structural fire.
In this scenario, a clandestine drug laboratory is situated in the basement and or ground
floor of a wood-frame single-family house. The single-family house is assumed to be a
two-story house with a basement and with bedrooms on the second floor. The house has a
backyard and the backyard area may also have been used as a storage area for hazardous
wastes. The house and backyard area are assumed to be adjacent to other single-family
houses on three sides (the fourth side being the street) and the backyard is fenced. It is
also assumed that neighboring single-family houses remain occupied by adults and
children during conduct of removal actions.
6.3.4 Multi-unit Residential Property Removal Action Scenario
The Multi-unit Residential Property Scenario reflects the characteristics of clandestine
drug laboratory locations that are reported in the NCLSS Report as Apartment or
Condominium in the Laboratory Structure category and reported as Urban, or
Suburban in the Laboratory Neighborhood category. This scenario is intended to reflect
locations where the clandestine drug laboratory and associated hazardous wastes are in a
multi-unit dwelling and where a release could result in exposure of adjacent dwelling
residents or where a hazardous waste fire, explosion or booby trap could cause injury to
adjacent dwelling residents or ignite a structural fire that could affect adjacent dwelling
units. The Multi-unit Residential Property Scenario represents a multi-unit dwelling in which
a clandestine drug laboratory and associated hazardous wastes are situated in one dwelling unit
of a multi-story, multi-unit dwelling. It is also assumed that neighboring dwelling units remain
occupied by adults and children during conduct of removal actions.
6.3.5 Rural Open Air Setting Removal Action Scenario
The Rural Open Air Setting Scenario reflects the characteristics of clandestine drug
laboratory locations that are reported in the NCLSS Report as Open Air/No Structure in
the Laboratory Structure category and that are reported as Rural in the Laboratory
Neighborhood category. This scenario is intended to reflect clandestine drug laboratory
locations where hazardous wastes are not contained by any building or other permanent
structure and are exposed to the elements, and where the clandestine drug laboratory is
located in the vicinity of surface water, wetlands, vegetation and species habitat. A release
of hazardous wastes in such an environmental setting could directly contaminate soil or surface
water. A hazardous waste fire, explosion, or booby trap in such an environmental

setting could ignite an outdoor fire. Unsecured hazardous waste containers could be
relatively easily removed from the clandestine drug laboratory location and diverted to
other locations, if not subject to removal action. It is assumed that suspects or other
persons do not occupy the location, and that there are no residential or commercial
structures in the vicinity. It is also assumed that the topography of the site is such
that storm water runoff (and any entrained hazardous wastes) would flow towards a nearby
surface water body including wetlands areas.
6.4 Transportation Scenarios
After removal from a clandestine drug laboratory, hazardous wastes would be packaged at
the site into containers appropriate for hazardous waste transportation, and transported
to storage locations, where the wastes would be stored temporarily prior to transportation
to a permitted facility for treatment and disposal. Grantees may utilize qualified law
enforcement personnel or other qualified government personnel to self-transport
hazardous waste, or utilize DEA contractors or other qualified contractors to transport
hazardous wastes generated from removal actions. Grantees would need to obtain a
hazardous waste transporter license to self-transport waste that is not CESQG waste.40
40 It should also be noted that, while self-transport of CESQG wastes are permitted under
RCRA, at least eleven States, including Arkansas and Wisconsin, require CESQG wastes to be
transported by a licensed hazardous waste hauler, or require the CESQG to obtain a hazardous
waste transport license to self transport the CESQG hazardous waste. Other states, including
Missouri, allow CESQGs to self transport hazardous wastes without obtaining a hazardous waste
transport license.
6.4.1 Self-transport Scenario
The DOJ COPS Office anticipates that hazardous wastes that are self-transported by
grantees would be transported in small to medium-sized trucks or trailers and would
generally be transported in 5-gallon, 20-gallon, or 55-gallon containers. The DOJ COPS
Office anticipates that for most removal actions the grantee transporting the hazardous
waste would be operating as a CESQG (i.e., generating less than 100 kilograms of
hazardous waste in a calendar month), and therefore the CESQG exemptions from RCRA
and DOT regulations for hazardous waste shipments would apply.
According to DOJ COPS Office grant award criteria, grantee personnel who would be
involved in the seizure or closure of clandestine laboratories must be equipped with
OSHA-required personal protective equipment and safety equipment as appropriate for the
site conditions, and receive OSHA initial health and safety and annual refresher training.
The DOJ COPS Office award criteria require that grantees that conduct hazardous waste
management activities receive training in accordance with RCRA regulatory requirements
for hazardous waste generators. Due to the wide applicability of the CESQG exemption
to grant-funded removal actions, the DOJ COPS Office anticipates that personnel
conducting removal actions and hazardous waste transportation would receive only a
limited amount of training in the management and transport of CESQG hazardous wastes.
 Specifically, the CESQG exemption allows the transport of less than 100 kilograms of
CESQG waste to proceed without adherence to RCRA and DOT regulations pertaining to:

 Container design / packaging (RCRA/ DOT)
 RCRA Personnel Training and DOT Hazmat training41
 Hazardous waste manifest / shipping papers (RCRA/DOT)
 Containment building operating requirements (RCRA)
 Facility contingency plans (RCRA)
 Markings and labeling (DOT)
 Placarding of vehicles (DOT)
 Emergency response information (DOT)
 Procedures for loading/unloading into trucks traveling on highways (DOT)
 Segregation of incompatible materials (DOT)
DEA contractors are required to comply with RCRA and DOT regulatory requirements
pertaining to SQGs, including regulations pertaining to utilization of hazardous waste
manifests, hazardous waste container labels, and vehicle placards, regardless of the
quantity transported. The DOJ COPS Office assumes that hazardous waste manifests,
container labels, and vehicle placards would not be utilized in conduct of self-transport
of CESQG waste, unless required by state regulation, and that self-transporters of CESQG
waste would not comply with Federal RCRA and DOT regulations for which CESQGs are
exempt, except if such Federal regulations are superceded by state regulations. The DOJ
COPS Office also assumes that self transport of CESQG wastes would be conducted by
grantees only on an as needed basis, and that grantees would not accumulate day to day
experience in conducting hazardous waste transportation activities, as would a qualified
commercial hazardous waste contractor. This would be the case even in states, such as
Arkansas and Wisconsin, where CESQGs are required to obtain hazardous waste transport
licenses to self- transport CESQG waste. RCRA regulations do not permit self-transport
of hazardous waste that is not CESQG waste. Therefore, grantees that conduct removal
actions that generate more than 100 kilograms of waste would be required to use qualified
hazardous waste transporters or obtain transporter license themselves.
41 Certain states have their own requirements for the training of hazardous waste transporters.
6.4.2 Licensed Transport Scenario
Grantees may not self-transport CESQG waste in certain states without obtaining a
hazardous waste transport license, and non-CESQG hazardous waste cannot be self
transported. Although the CESQG exemption from RCRA and DOT regulations for the
transport of hazardous materials would apply to the licensed transport scenario, the DOJ
COPS Office has assumed for the purposes of the environmental consequences analysis in
the environmental assessment that in the event that a grantee chooses to, or is required to,
transport CESQG waste using a licensed hazardous waste transporter, that the licensed
transporter is likely to meet the requirements for the transport of larger amounts of
hazardous waste. Some grantees (e.g., Arizona, Hawaii) have provided grant funding to
DEA contractors to perform hazardous waste management activities that are outside the
scope of the National Clandestine Laboratory Cleanup Program. DEA contractors are

required to comply with RCRA and DOT regulations applicable to SQGs concerning use
of hazardous waste manifests, hazardous waste container markings, and vehicle placards.
The DOJ COPS Office assumes that licensed transporters of hazardous waste, including
DEA contractors and other qualified contractors, would accumulate day-to-day experience
with and knowledge of appropriate procedures for the safe handling and transport of
hazardous materials. In addition, licensed hazardous waste transporters are subject to
more extensive training requirements that pertain to transport of larger volumes of waste
(e.g. SQG and LQG) and conduct of emergency response in the event of a transportation
accident or other hazardous waste release. These factors may affect the timeliness and
effectiveness of emergency response in the event of an incident.
6.5 Storage Scenarios
Under the Proposed Action, the DOJ COPS Office assumes that hazardous wastes
recovered from clandestine drug laboratories would be stored temporarily in either indoor
or outdoor storage units. The DOJ COPS Office has assumed for the purposes of the
environmental consequences analysis that storage units would be located either indoors or
outdoors at a police station or fire station. As noted above, the DOJ COPS Office has not
restricted the quantity of hazardous waste that a grantee may temporarily store, provided
that the grantee meets RCRA and DOT requirements and DOJ COPS Office grant award
conditions. Specific locations of proposed future storage units cannot be anticipated.
Therefore, the environmental consequence analyses for the transportation and storage
scenarios are not location-specific.
The security measures at DEA contractor-owned and operated transfer stations exceed the
requirements of Federal and state hazardous waste management regulations, and may
therefore exceed security measures implemented at other storage unit locations. Qualified
and trained DEA contractor personnel permanently staff the transfer stations and are
subject to security investigation and clearances from the DEA. In terms of physical
security, the transfer stations are surrounded by six foot, three strand barbed wire fences
and generally have additional security measures such as video surveillance cameras.
Hazardous wastes generated from clandestine drug laboratory removal actions are
required to be segregated from other types of hazardous waste that are being managed at
the DEA contractor transfer stations, and are stored in accordance with NFPA Code 30,
NFPA Code 230 and other fire protection codes and building codes.
6.5.1 Indoor Storage Unit Scenario
Under the DOJ COPS Office Methamphetamine Initiative, storage units are anticipated to
be situated at indoor locations in government-owned buildings (e.g., fire stations, police
stations.) The DOJ COPS Office assumes that indoor storage units would be enclosed
areas constructed inside an existing government-owned permanent structure, specifically
for the purpose of storing hazardous waste recovered from clandestine drug laboratory
sites. The DOJ COPS Office also assumes that other hazardous materials used at the
facility (e.g., paint, solvents) would not be stored in the same enclosure or immediately

adjacent to the enclosed area42. The DOJ COPS Office anticipates that the indoor
enclosed area in which the storage unit is situated would be segregated and secured from
other areas of the building by permanent fixtures (e.g., doors, gates) and that only
authorized and qualified personnel would have access to the enclosed area. Indoor storage
units would be equipped with spill containment and fire protection systems in accordance
with grant award conditions and in accordance with fire protection and building codes.
Fire protection codes applicable to indoor storage of flammable and hazardous materials
are summarized in Section 5.3.
42 Note that this assumption is made solely for the purposes of the environmental consequences
analysis. The DOJ COPS Office is not precluding any specific storage unit configuration. Specific
limitations applicable to storage units depend upon the types and amounts of hazardous waste
stored in the units and the length of time that the hazardous wastes are stored in the units.
For indoor storage of flammable and hazardous materials (including hazardous wastes),
the materials may be stored in a building that is not primarily used for chemical storage.
The indoor storage unit may be situated in a corner of a large room or perhaps a separate
room (and separate fire area) designed for chemical storage. A separate room may be
needed for indoor storage of larger quantities of materials, such as greater than 1,000
kilograms (300 gallons). An inside storage room would have to have a mechanical or
gravity exhaust ventilation system. The indoor storage scenario can be broken down into
storage of flammables (e.g., class I and class II liquids) and the storage of hazardous
materials (e.g., ammonia, acids). It is anticipated that small quantities of flammables
would be stored in a storage cabinet that can store a maximum of 60 gallons (equivalent to
more than 100 kilograms). Flammable liquids storage cabinets that are located indoors do
not need to be vented, however, if venting is used, the unit must be vented to outside the
building. If vented, the storage cabinet must be vented from the bottom with make-up air
supplied from the top. Hazardous materials lockers would be used to store larger
quantities of flammable and other hazardous materials.
For indoor storage of quantities of 100 kilograms or less of Class I flammable and
hazardous materials, it is anticipated that at least two storage cabinets or at least two
hazardous materials lockers would be sufficient. At least two storage units would be
needed so that incompatible substances will not be commingled. The DOJ COPS Office
assumes that the fire protection areas would be 200 square feet in area to accommodate
the storage units. With this size fire protection area, the walls, ceiling, and floors
would need the typical 1-hour fire resistance for this size rooms/fire area. No additional
special fire protection such as sprinklers or water sprays would be needed other than those
needed for the building in general for indoor storage of less than 100 kilograms of Class I
materials. The indoor storage rooms should have approved self-closing fire doors and protected
windows as described in OSHA regulations. For indoor storage of quantities of between 100 and
1,000 kilograms of Class I flammable liquids, it is anticipated that from one to five storage
cabinets would be needed. For indoor storage of the same quantities of hazardous materials,
there could be one or multiple lockers. The only restriction is that lockers cannot exceed
1,500 square feet of gross floor area. A maximum of three storage cabinets are permitted in
one fire area (likely a

separate room) which is defined as a building area separated from the rest of the building
by construction having a fire resistance of at least one hour. For example, for indoor
storage of 500 kilograms of flammables and 500 kilograms of hazardous materials (a total
of 1,000 kilograms), the storage scenario would be one fire area containing 3 storage
cabinets (total 600 kilogram capacity for the 3 cabinets) and another fire area containing
sufficient hazardous materials lockers (depending on size of each locker) to accommodate
500 kilograms capacity. The DOJ COPS Office assumes that the fire areas would be 400
square feet in area to accommodate the storage units. With this size fire area, the walls,
ceiling, and floors would need to have a 2-hour fire resistance instead of the usual 1-hour
fire resistance for smaller rooms. In this case, for indoor storage of less than 1,000
kilograms, no additional special fire protection such as sprinklers or water sprays would be
needed other than those needed for the building in general.
The indoor storage area could also have quantities greater than 1,000 kilograms, for a
grantee operating as a large quantity generator. For this scenario, the DOJ COPS Office
assumes that 1,500 kilograms of storage capacity would be needed. For indoor storage of
1,500 kilograms of Class I flammable liquids, it is anticipated that seven storage cabinets
would be sufficient. For the same quantity of hazardous materials, there could be one or
multiple lockers. The only restriction is that lockers cannot exceed 1,500 square feet of
 gross floor area. A maximum of three storage cabinets are permitted in one fire area. If
both flammable and hazardous materials were present, the cabinets and lockers would need
to be located in separate fire areas. For example, for 750 kilograms of flammables and 750
kilograms of hazardous materials (total of 1,500 kilograms), the storage scenario would be
two fire areas containing 3 and 2 storage cabinets respectively, (total 1,000 kilogram
capacity for the 5 cabinets) and another fire area containing sufficient hazardous materials
lockers (depending on size of locker) to accommodate the 750 kilograms capacity and potential
incompatibilities of some of the hazardous materials. The DOJ COPS Office assumes in this
case that the fire areas would be 400 square feet in area to accommodate the storage units.
With this size fire area, the walls, ceiling, and floors would need to have 2-hour fire
resistance instead of the usual 1-hour fire resistance for smaller rooms. In this case,
for more than 1,000 kilograms, no additional special fire protection such as sprinklers
or water sprays would be needed other than those needed for the building in general.
6.5.2 Outdoor Storage Unit Scenario
Storage units may also be situated at outdoor locations on existing government-owned
facility property (e.g., fire stations, police stations.) The DOJ COPS Office has assumed
that the outdoor storage units would be prefabricated hazardous materials storage cabinets
purchased and shipped to the facility and situated on paved areas (e.g., parking areas,
loading docks). The DOJ COPS Office anticipates that the storage units would be
dedicated to storage of hazardous waste, and that other hazardous materials used at the
facility (e.g., paint, solvents) would not be stored in the same enclosure or adjacent to
the enclosed area.43 The DOJ COPS Office assumes that outdoor storage units would be

segregated and secured from other outdoor areas of the facility by permanent fixtures
(e.g., fences, gates) with required signage indicating the presence of hazardous materials,
and that only authorized and qualified personnel would have access to the storage units.
Outdoor units would be equipped with fire protection and spill containment systems in
accordance with grant award conditions and fire protection and building codes. Fire protection
codes applicable to outdoor storage of flammable and hazardous materials
(including hazardous wastes) are summarized in Section 5.3.
43 Note that this assumption is made solely for the purposes of the environmental consequences analysis.
For outdoor storage of less than 100 kilograms of flammable and hazardous materials,
there would likely be two hazardous materials lockers to address potential material
incompatibilities. For a small area where the hazardous wastes are stored (less than and
equal to 100 square feet) to accommodate small amounts of hazardous wastes, distances
between lockers would be a minimum of 5 feet, the distance to the property line would be
a minimum of 10 feet and the distance to a public street would be a minimum of 5 feet.
For outdoor storage of between 100 and 1000 kilograms, there would likely be three
hazardous materials lockers (depending on the locker size) to accommodate the greater
quantities and the potential material incompatibilities. For quantities much greater than
1,000 kilograms, there might be 3-5 hazardous materials lockers (depending on the size of
the locker). For a large area where the hazardous materials are stored (>500 feet and
<1,500 feet) to accommodate large amounts of hazardous materials, the distances between
lockers would be a minimum of 5 feet, distance to the property line would be a minimum
of 30 feet and the distance to a public street would be a minimum of 20 feet. For all
scenarios, fire control devices such as small hose or portable fire extinguishers would
need to be available in the vicinity of the storage area.
6.6 Solid Waste Generation
The DOJ COPS Office anticipates that most grant-funded removal actions would be
classified under the CESQG definition. Hazardous waste generated by CESQGs is not
required under RCRA to be disposed of in Subtitle C permitted RCRA hazardous waste
disposal facilities, but may be disposed at non-RCRA permitted facilities, including
municipal or industrial solid waste management facilities and other state-permitted
facilities. However, many state hazardous waste regulations require that hazardous wastes
generated by CESQGs be disposed of in RCRA Subtitle C-permitted TSDFs and thereby
prohibit disposal of such wastes in municipal or industrial solid waste management
facilities.44 DOJ COPS Office Certification of Cleanup of Clandestine Drug Laboratories
(FY2002) Form specifies that under the Methamphetamine Initiative qualified law
enforcement personnel and qualified hazardous waste management contractor personnel
utilize permitted treatment, storage, and disposal facilities that meet RCRA requirements
to manage hazardous wastes generated from grant-funded activities. This would not

prohibit disposal of CESQG-generated wastes in non-RCRA Subtitle C permitted
facilities, in states where such disposal is permitted. DEA prohibits its hazardous waste
management contractors from disposing of CESQG-generated waste in non-RCRA
permitted facilities. Hazardous wastes generated by agencies classified as SQGs or LQGs
are required under RCRA to dispose of such wastes in RCRA Subtitle C-permitted
TSDFs.
The DOJ COPS Office is not precluding any specific storage unit configuration. Specific
limitations applicable to storage units depend upon the types and amounts of hazardous
waste stored in the units and the length of time that the hazardous wastes are store in the units.
44 States that require disposal of CESQG-generated waste in RCRA-permitted TSDFs include
California, Colorado, Georgia, Kentucky, Illinois, Louisiana, Minnesota, Nebraska, New Mexico, and Wisconsin.
DEA contractors are required to manage all hazardous materials removed from
clandestine drug laboratories as RCRA-regulated hazardous wastes. The DOJ COPS
Office does not require grantees conducting grant-funded removal actions to manage all
wastes removed from the sites as hazardous waste, and such wastes may be segregated
from and managed separately from non-hazardous wastes recovered from the laboratory
sites. This DEA requirement reduces the potential for DEA contractors to inadvertently
misclassify hazardous waste recovered from clandestine drug laboratories as nonhazardous
waste. Misclassification of hazardous waste as non-hazardous waste could
result in disposal of such waste at disposal facilities that are not permitted to accept
hazardous waste.
Some grantees have used grant funding to pay commercial disposal fees to permitted
hazardous waste treatment, storage, and disposal facilities state-permitted treatment and
disposal facilities for disposal of hazardous wastes generated from grant-funded removal
actions. Operation of permitted treatment and disposal facilities is not addressed in the
quantitative environmental consequences analyses in this Environmental Assessment.
The DOJ COPS Office assumes that environmental consequences of operation of
treatment and disposal facilities utilized to dispose of grantee-generated hazardous
wastes have already been assessed through the siting and permitting process for such
facilities, including environmental reviews required under NEPA and state regulations.
The DOJ COPS Office anticipates that the addition of hazardous waste from removal actions to
treatment and disposal facilities would not significantly affect the environmental
consequences of such facilities.
6.7 Other Grant-funded Activities
This section describes other grant-funded activities not directly related to hazardous
waste removal actions that could have potential environmental impacts. These activities
include but are not limited to grant-funded training activities, seizures of clandestine
laboratories, chemical analytical laboratory operations, including analysis of evidence
and environmental samples, on-site environmental monitoring activities, and clandestine
drug laboratory on-site investigation and law enforcement activities. Training activities
generates hazardous waste in the form of chemical laboratory apparatus and chemicals used
by trainers and students to conduct practical exercises. Generation of hazardous wastes
from training activities includes glassware, flammable substances (e.g., automotive starter
fluid (ether), methanol), corrosives, (e.g., sulfuric acid), and reactives
(e.g., lithium batteries).45 The DOJ COPS Office anticipates that agencies and contractors

conducting grant-funded training would not generate more than 100 kilograms of waste in
a calendar month, and would therefore operate as CESQGs. However, it is possible that
some training providers could operate as SQGs.
45 Arkansas State Police ORI# ARASP1300, Section B Project Summary, Supplies for Practical Exercise
Conduct of clandestine drug laboratory seizure operations and removal actions also may
generate other types of hazardous waste in addition to the hazardous chemicals recovered
from the clandestine drug laboratory itself. Clandestine drug laboratory investigation and
law enforcement operations and removal actions may result in generation of other types of
hazardous wastes, including contaminated personal protective equipment, equipment
(consumables) used to conduct site environmental and occupational health and safety
monitoring, site surveillance, and collection of evidence, and potentially also liquids
used on site to decontaminate hazardous waste-contaminated personnel and equipment. The
DOJ COPS Office anticipates that agencies conducting grant-funded clandestine drug
laboratory seizures would not generate more than 100 kilograms of such hazardous wastes
in a calendar month, however, agencies involved in seizures of a large number of
clandestine drug laboratories or that encounter superlabs for which seizures involve
extensive use of personal protective equipment and consumables could generate more than
100 kilograms of hazardous waste in a calendar month.
Grantees also have used grant funding to outfit, equip, and staff chemical analytical
laboratories that are used to analyze evidence and environmental samples taken at
clandestine drug laboratory sites. Analysis of evidence and environmental samples
obtained during clandestine drug laboratory seizures may also be conducted on site,
depending upon the specific types of samples and analyses being conducted. In either
case, hazardous wastes generated from analysis of evidence and environmental samples
may include contaminated glassware, spent chemical reagents, used personal protective
equipment, and other consumables.
7.0 Affected Environment
This section describes the environmental setting for scenarios for which environmental
consequence analyses were conducted. The environmental setting includes a general
description of the air quality, water quality, soil quality, floodplains and wetlands,
human health and safety, and social setting for each scenario. This section also briefly
describes elements of the environment that are unlikely to be affected by the Proposed
Action and the rationale for excluding such elements from the environmental consequence analyses.
7.1 Single Family House Environmental Setting
The single-family house for the Single Family House Removal Action Scenario is
assumed to be located in a residential neighborhood, 50 feet from the closest adjacent
residence. Hazardous waste containers are assumed to be situated both inside the house
and in the backyard. The house and backyard are assumed not to be located in the
immediate vicinity of a wetland or stream or other water body, or in the vicinity of any

threatened or endangered species habitat. The air quality inside the single-family house is
assumed to be degraded by the operation of the clandestine drug laboratory and presence
of hazardous air indoor air pollutants, but baseline concentrations of hazardous indoor air
pollutants are assumed not to represent an acute hazard or immediate danger to life or
health. Surface soils in the area surrounding the house and backyard area are assumed to
be contaminated by previously released hazardous waste; however, baseline
concentrations in soil are assumed not to represent an acute hazard or immediate danger to
life or health.
7.2 Multi-Unit Residential Property Environmental Setting
For the Multi-unit Residential Property Scenario, the dwelling unit in which the
clandestine drug laboratory is situated is assumed to be located in multi-story multi-unit
residential building, adjacent to other occupied units. The air quality inside the dwelling
unit is assumed to be degraded by operation of the clandestine drug laboratory and the
presence of hazardous air indoor air pollutants, but baseline concentrations of hazardous
indoor air pollutants are assumed not to represent an acute hazard or immediate danger to
life or health. It is further assumed that the air quality of adjacent dwelling units has
not been affected by operation of the clandestine drug laboratory, (i.e., no releases of
hazardous wastes from previous operation of the clandestine drug laboratory have affected
the air quality of any adjacent dwelling units). There is assumed to be no significant
potential for surface soil or surface water contamination associated with this scenario,
because the clandestine drug laboratory and associated hazardous materials are situated
within a dwelling unit of a multi-story building. Any liquid releases of hazardous wastes
from the dwelling unit are assumed to be entrained to municipal storm water management
systems connected to a Publicly Owned Treatment Works (POTW).
7.3 Rural Open Air Setting Environmental Setting
The clandestine drug laboratory for the Rural Open Air Setting Scenario is assumed to
contain no buildings or other permanent structures, such that any containers and apparatus
are unsecured and any releases of hazardous wastes from the site would be uncontained.
The site is assumed to be in the vicinity of surface water, wetlands, and vegetation and
potentially in the vicinity of habitat of threatened or endangered species. It is assumed
that the topography of the site is such that any hazardous waste releases or storm water
runoff (and any entrained hazardous wastes) would flow towards a nearby surface water
body, including wetlands areas, and that baseline water quality in the surface water body
and wetlands areas have been affected by previous operation of the clandestine drug
laboratory, (i.e., there have been previous releases of hazardous wastes that have
affected surface water quality). Surface soils in the area of the site are assumed
to be contaminated by previously released hazardous wastes; however, baseline soil
concentrations are assumed not to represent an acute hazard or immediate danger to life or health.
In the DOJ COPS Offices experience, contamination of groundwater as a result of
hazardous waste releases at a clandestine drug laboratory location, while possible,
is very unlikely to occur, and therefore the potential for groundwater contamination not assessed

quantitatively. Hazardous wastes releases from clandestine drug laboratory locations
under the Rural Open Air Setting are more likely to result in soil or surface water
contamination.
7.4 Storage Scenarios
7.4.1 Indoor Storage Scenario
It is assumed that the transfer stations used by DEA contractors are located in enclosed
buildings that are situated in industrial-zoned areas in accordance with local zoning laws,
and that there are residential structures 200 feet of the transfer stations. It is also
assumed that baseline indoor air quality meets occupational health and safety standards
and that baseline outdoor air quality meets federal and state air quality standards. It is
also assumed that the transfer station is equipped with containment structures would contain
any releases of liquid hazardous wastes from the transfer station, and that any air releases
resulting from releases of gaseous or volatile hazardous wastes would be ventilated to the
atmosphere through gravity or mechanical ventilation systems. It is assumed that hazardous
waste contractor personnel are the only individuals permitted to handle hazardous waste in
the storage unit, and that only hazardous waste contractor personnel work in the vicinity of
the storage unit.
It is assumed that other storage units utilized by grantees would be located in existing
government-owned buildings situated in mixed-use-zoned areas in accordance with local
zoning laws, and that there are residential structures 50 feet from the building. It is
assumed that baseline indoor air quality meets occupational health and safety standards
and that outdoor air quality meets federal and state air quality standards. It is also
assumed that any liquid hazardous waste releases from the storage unit would be partially
contained by the building structure and any associated containment systems. In
accordance with NFPA Code 30, storage units may or may not have dedicated ventilation
systems to the outside of the building, but would not be vented to inside the building.
It is assumed that qualified and authorized personnel are the only individuals permitted to
handle hazardous waste in the storage unit, but that non-trained personnel also work in the
vicinity of the storage unit.
7.4.2 Outdoor Storage Scenario
It is assumed that storage units utilized by grantees would be located outside an existing
government-owned building that is situated in mixed-use-zoned areas in accordance with
local zoning laws, and that there are residential structures 50 feet from the building. It is
assumed that baseline outdoor air quality meets federal and state air quality standards. It is
also assumed that paved areas upon which the storage unit is situated would at least partially
contain liquid releases and that any air releases resulting from hazardous waste releases or
fire could directly affect adjacent properties subject to wind direction. It is assumed that
qualified and authorized personnel are the only individuals permitted to handle hazardous
waste in the storage unit, but that non-trained personnel also work in the vicinity of the storage unit.

8.0 Environmental Consequences
This section describes environmental consequences analyses for the DOJ COPS Office
Methamphetamine Initiative (the Proposed Action) and No Action Alternative.
8.1 DOJ COPS Office Methamphetamine Initiative
This section describes the environmental consequences analysis for the DOJ COPS Office
Methamphetamine Initiative for the Proposed Action, including grant-funded hazardous
waste management activities and other grant-funded activities. Included in hazardous
waste management activities are the two removal action scenarios, one transportation
scenario, and three storage scenarios.
8.1.1 Air Quality
Hazardous Waste Management Activities
Air quality benefits are anticipated from the normal conduct of removal actions under the
DOJ COPS Office Methamphetamine Initiative. Clandestine drug laboratories represent a
continuing source of air emissions from hazardous wastes stored at the sites, including
containers and apparatus and furnishings that may be contaminated with hazardous wastes
or controlled substance residues. Conduct of grant-funded removal actions, including the
packaging and removal of the hazardous wastes from the laboratory site, would result in
the reduction in existing air emissions from the clandestine drug laboratory operation.
The DOJ COPS Office assumes that all removal actions will be conducted in accordance
with state and federal requirements (summarized in Section 5) and DOJ COPS Office
grant award conditions (summarized in Appendices C, D, and E).
The DOJ COPS Office anticipates that concentrations of air contaminants may exist
within and in the vicinity of clandestine drug laboratories during seizure operations and
during removal actions that may require the use of personal protective equipment by
personnel conducting the seizure operations and removal actions. Potential impacts
related to potential occupational exposure during normal conduct of seizure operations
and removal actions are discussed below in Section 8.1.4 (Health and Safety.). Potential
impacts related to potential accidental releases of hazardous wastes during conduct of
removal actions are discussed in this section.
Removal Action Scenarios
The air quality impact analysis for potential accidental releases during conduct of a
removal action is based on an assumed accidental release involving 100 kilograms of
anhydrous ammonia gas. Such a release could occur as a result of a materials handling
accident or container failure during a removal action. The DOJ COPS Office considers
the probability of such an occurrence to be low, however, such a release could occur
during the conduct of a removal action. EPA has reported that brass valving of illicit
containers containing anhydrous ammonia that appeared to be physically intact from
outside appearance has been known to break off in the hands of responders creating an

uncontrolled release from the container.46 The potential consequences of such a release
could be significant. The detailed methodology and assumptions for determining air
quality impacts associated with accidental releases for the DOJ COPS Office
Methamphetamine Initiative removal action scenarios are provided in Appendix K,
Methodology for Assessing Potential Consequences of Hazardous Waste Air Releases.
46 EPA, 2000. Anhydrous Ammonia Theft, United States Environmental Protection Agency,
Office of Solid Waste and Emergency Response, (5104), EPA Publication Number EPA-F-00-005,
March 2000, http://www.epa.gov/ceppo/pubs/csalert.pdf
The specific consequences of an accidental release vary for an indoor release or outdoor
release for the Single-Family House Scenario and for an indoor release for the Multi-unit
Dwelling Scenario with respect to the potential for public or occupational exposure. The
potential consequences for an outdoor release for the Rural Open Air Scenario would not
exceed the potential consequences for an outdoor release for the Single Family House
Scenario; therefore no separate quantitative analysis has been conducted for an outdoor
release for the Rural Open Air Scenario.
Single Family House Scenario
If 100 kilograms of anhydrous ammonia gas were released inside the single-family house
(30,000 cubic feet), the anticipated ammonia concentration initially would be 160,000
ppm. This concentration could be fatal to persons conducting the removal action in the
house and exposed to the ammonia release, unless they were wearing personal protective
equipment or removed from the situation by emergency responders. The OSHA
Immediately Dangerous to Life or Health (IDLH) level for anhydrous ammonia is 300
ppm for workers for a 30-minute exposure.
Assuming that 55% of the released ammonia escapes from the building (see Appendix K
for an explanation of this assumption) the indoor ammonia concentration inside the
nearest residence, assumed to be 50 feet away, would equal the ERPG-2 level of 150 ppm.
As a result, persons in this nearby house would experience health effects, but not
irreversible or other serious health effects or symptoms that would impair their ability
to take protective action. The dispersion modeling also indicated that persons that located
outside and at a location 100 feet from the point of release would experience the same ERPG-2
level concentration and experience its corresponding health effects.
If 100 kilograms of anhydrous ammonia gas were released outside the single family
house, the ammonia would disperse so that residents inside houses 50 feet away from the
point of release would experience ammonia concentrations greater than the ERPG-2 level
of 150 ppm, and residents inside houses 75 feet away from the point of release would
experience ammonia concentrations equal to the ERPG-2 level. As a result, persons in
nearby residences would experience health effects, but not irreversible or other serious
health effects or symptoms that would impair their ability to take protective action. The
dispersion modeling also indicated that persons located outside and at 130 feet from the
point of release would experience the same ERPG 2 level concentration and experience
its corresponding health effects.47 For the rural open-air scenario, human receptors

located 130 feet from the point of an outdoor release would experience the same ERPG-2
level concentration as for the outdoor release for the single-family house scenario.
47 For the Rural Open Air scenario, human receptors located 130 feet from the point of
outdoor release would experience the same ERPG-2 level concentration as for the outdoor
release in the Single Family House scenario.
Multi-unit Residential Property Scenario
If 100 kilograms of anhydrous ammonia gas were released inside an apartment (15,000
cubic feet) in a multi-unit residential property, the anticipated ammonia concentration
initially would be 320,000 parts per million (ppm). This concentration could be fatal to
persons conducting the removal action in the dwelling and exposed to the ammonia
release, unless they were wearing personal protective equipment or removed from the
situation by emergency responders. Assuming that 55% of the ammonia escapes from the
apartment into adjacent apartments, the adjacent apartments could be expected to have
ammonia concentrations of approximately 6,400 ppm. This concentration far exceeds the
ERPG-2 level of 150 ppm, and exposure to such concentration would impair the ability of
persons to take protective action. As a result, persons in adjacent apartments would
experience severe health effects. Table 8.1-1 summarizes air quality impacts for the
removal action scenarios.
Table 8.1-1
Potential Air Quality Impacts for Ammonia Release for Removal Action Scenarios
Scenario
Event
Ammonia Concentration^
Exposure Guideline
Distance to Concentration
Single Family House
Indoor Release
160,000 ppm
300 ppm
IDLH Occupational Exposure Guideline
Point of Release
Single Family House
Indoor Release Adjacent House
150 ppm
150 ppm
ERPG-2 Public Exposure Guideline
50 Feet*
Single Family House
Indoor Release Outdoor Receptor
150 ppm
150 ppm
ERPG-2 Public Exposure Guideline
100 Feet
Single Family House
Outdoor Release Adjacent House
370 ppm
150 ppm
ERPG-2 Public Exposure Guideline
50 Feet
Single Family House
Outdoor Release Adjacent House
150 ppm
150 ppm
ERPG-2 Public Exposure Guideline
75 Feet
Single Family House
Outdoor Release Outdoor Receptor
150 ppm
150 ppm
ERPG-2 Public Exposure Guideline
130 Feet
Multi-Unit Dwelling
Indoor Release
320,000 ppm
300 ppm
IDLH Occupational Exposure Guideline
Point of Release
Multi-Unit Dwelling
Indoor Release
6,400 ppm
150 ppm
ERPG-2 Public Exposure Guideline
Adjacent Apartment
Rural Open Air
Outdoor Release Outdoor Receptor
150 ppm
150 ppm
ERPG-2 Public Exposure Guideline
130 Feet
Notes: ^Exposure times for ERPG and IDLH are 60 minutes and 30 minutes, respectively.
Concentrations are calculated for the respective exposure time.
*The closest occupied structure is assumed to be located 50 feet from the single-family house.
Transportation Scenario
Air quality impacts from the normal transportation of the recovered hazardous waste to
the storage units under the DOJ COPS Office Methamphetamine Initiative are anticipated

to be negligible, assuming that the hazardous wastes are packaged, handled, transported,
and stored by qualified personnel in accordance with Federal and state regulations and
grant award conditions. Air quality impacts from the operation of vehicles used to
transport the hazardous waste are negligible with respect to overall transportation traffic.
The air quality impacts of an uncontrolled release during a transportation accident of 100
kilograms of anhydrous ammonia are similar to those associated with the removal action
scenarios. It is assumed that an accident occurs involving a transportation vehicle
conveying hazardous waste from the removal action, which results in a container breach.
The detailed methodology and assumptions for determining air quality impacts associated
with an accidental release during a transportation accident are presented in Appendix K
and summarized in Table 8.1-2.
Similar to the removal action scenario, the primary exposed individuals would be the
qualified law enforcement personnel or contractors operating the vehicle as well as any
passengers in the vehicle. The secondary exposed individuals would be any public
individuals in the vicinity of the release. The DOJ COPS Office has assumed for the
transportation scenario, the nearest exposed public individual is 50 feet from the point of
release (e.g. a residence near the accident location), the same distance assumed for the
removal action scenarios. Thus, the DOJ COPS Office assumes that the dispersion
modeling results for air quality impacts would be the same for the removal action outdoor
release scenario as for the transportation accident scenario.
Table 8.1-2
Potential Air Quality Impacts for Ammonia Release for Transportation Scenario
Scenario
Event
Ammonia Concentration^
Exposure Guideline
Distance to Concentration
Transportation
Transportation Release Indoor Receptor
150 ppm
150 ppm ERPG-2 Public Exposure Guideline
75 Feet
Transportation
Transportation Release Outdoor Receptor
150 ppm
150 ppm ERPG-2 Public Exposure Guideline
130 Feet
Notes: ^Exposure times for ERPG and IDLH are 60 minutes and 30 minutes, respectively.
Concentrations are calculated for the respective exposure time.
*The closest public individual is assumed to be located 50 feet from the transportation incident
The likelihood of a release and timeliness and effectiveness of emergency response may
be affected by the mode of transportation and specific regulatory requirements. CESQGs
transporting CESQG-generated wastes are not required under RCRA to utilize vehicle
placards, hazardous waste container markings, or hazardous waste manifests. DEA
contractors are required comply with RCRA regulations for SQGs, including utilization of
manifests, container markings, and vehicle placards, regardless of the quantity
transported. Other transporters transporting CESQG waste may or may not placard, mark,
or manifest shipments, but may instead use shipping papers that may not provide the same
information to responders. In the event that a vehicle transporting hazardous waste
without placards, container markings, or manifests is involved in an accident, responders
to the accident would not necessarily be aware of the chemical hazards to which the

driver, passengers or members of the public had been exposed. The driver and any
passengers could be exposed to a point of release concentration (i.e. orders of
magnitude higher than the IDLH), which could impair the ability of the driver and
passengers to take protective action.
EPA reported that emergency responders and members of the public were exposed to
anhydrous ammonia as a consequence of a transportation accident. In May 1999, a
vehicle passenger was killed when a makeshift 20-pound container of anhydrous ammonia
he was holding exploded inside a vehicle. The death occurred when two individuals were
driving on an interstate highway in Missouri. The driver of the vehicle was severely
injured. The anhydrous ammonia being transported was to be used for methamphetamine
production. The cause of the smoke emanating from the vehicle was not immediately
known, and therefore one firefighter, one emergency medical technician, and one member
of the general public, all of whom stopped to help and drag the driver and passenger from
the car, were also injured as a result of the ammonia release.48
48 EPA, 2000. Anhydrous Ammonia Theft, United States Environmental Protection Agency, Office
of Solid Waste and Emergency Response, (5104), EPA Publication Number EPA-F-00-005, March 2000,
http://www.epa.gov/ceppo/pubs/csalert.pdf
Storage Scenarios
Under the Proposed Action, hazardous waste generated from removal actions may be
stored either indoors or outdoors in storage units, including grantee- or contractor-
operated transfer stations or permitted storage facilities. A storage unit where hazardous
waste for less than ten days, in transit to a treatment and disposal facility, is classified
as a transfer station and is subject to a limited number of RCRA requirements. Transfer
stations do not require RCRA permits. Table 5.1-1 summarizes the regulatory requirements for
less than ten-day transfer stations.
A storage unit where hazardous waste is stored for more than ten days would be classified
as a storage facility that would require a RCRA hazardous waste storage permit and
would be required to comply with RCRA regulations for hazardous waste storage
facilities. A permitted RCRA hazardous waste storage facility would be required to have
full secondary containment systems for spills and would be required to implement an
inspection plan, which would not be required for less than 10-day storage. Table 5.1-1
summarizes the regulatory requirements for a RCRA permitted storage facility. As
discussed in Section 5.1, the regulatory requirements for management of quantities
between 100 and 1000 kilograms and greater than 1000 kilograms differ from the
regulatory requirements applicable to CESQGs, and requirements differ for storage of
hazardous waste for less than or more than 10 days.
Indoor Storage Scenario
In the event that 100 kilograms of anhydrous ammonia were released inside a storage unit
that was located inside an assumed 60,000 cubic foot building (e.g., an indoor storage unit

at a fire station or police station or contractor-operated transfer station), the ammonia gas
would escape from the building through the ventilation system of the storage unit, if the unit
were equipped with a ventilation system. If the storage unit were not equipped with a ventilation
system, the ammonia release would escape into the building. An ammonia
release that resulted from a materials handling accident inside the building but outside the
storage unit would also escape into the building. In either case the anticipated ammonia
concentration inside a 60,000 cubic foot building initially would be 80,000 parts per million,
exceeding the IDLH level of 300 ppm for a 30-minute exposure. Personnel
would not be able to function in this environment unless they had personal protective
equipment.
Assuming that 55% of the ammonia released into the building escapes from the building
and into the ambient air, dispersion modeling of the ammonia indicates that a residence or
commercial entity located 50 feet from the point of the release would experience indoor
ammonia concentrations equal to the ERPG-2 level of 150 ppm for ammonia. As a result,
persons in this nearby building would experience health effects, but not irreversible or
other serious health effects or symptoms that would impair their ability to take protective
action. The dispersion modeling also indicated that persons located outside and at 100 feet
from the point of release would experience the same ERPG-2 level concentration and experience
its corresponding health effects.
Outdoor Storage Scenario
In the event that the storage unit was located outside of building (e.g., outside of a police
station or fire station,) all of the ammonia released would escape through the ventilation
system of the unit. The ammonia would disperse so that occupants of buildings up to 75 feet
from the point of release would experience indoor ammonia concentrations equal to the ERPG-2
level of 150 ppm for ammonia. As a result, occupants of these buildings would experience health
effects, but not irreversible or other serious health effects or symptoms that would impair
their ability to take protective action. The dispersion modeling also indicated that persons
located outside and at 130 feet from the point of release would experience the same ERPG-2 level
concentration and experience its
corresponding health effects. Potential air quality impacts associated with the indoor and
outdoor storage scenarios are summarized in Table 8.1-3.
Table 8.1-3
Potential Air Quality Impacts for Ammonia Release for Storage Scenarios
Scenario
Event
Ammonia Concentration^
Exposure Guideline
Distance to Concentration
Storage Unit
Normal Operation
Negligible
300 ppm IDLH Occupational Exposure Guideline
Immediate Vicinity
Storage Unit  Indoor Unit
Accidental Release Indoor Receptor
80,000 ppm
300 ppm IDLH Occupational Exposure Guideline
Point of Release
Storage Unit - Indoor Unit
Accidental Release Indoor Receptor
150 ppm
150 ppm ERPG-2 Public Exposure Guideline
50 Feet*

Storage Unit - Indoor Unit
Accidental Release Outdoor Receptor
530 ppm
150 ppm ERPG-2 Public Exposure Guideline
50 Feet *
Accidental Release Outdoor Receptor
150 ppm
150 ppm ERPG-2 Public Exposure Guideline
100 Feet
Storage Unit  Indoor Unit Transfer Station
Accidental Release Outdoor Receptor
75 ppm
150 ppm ERPG-2 Public Exposure Guideline
200 Feet**
Storage Unit  Outdoor Unit
Accidental Release Indoor Receptor
370 ppm
150 ppm ERPG-2 Public Exposure Guideline
50 Feet*
Accidental Release Indoor Receptor
150 ppm
150 ppm ERPG-2 Public Exposure Guideline
75 Feet
Storage Unit  Outdoor Unit
Accidental Release Outdoor Receptor
970 ppm
150 ppm ERPG-2 Public Exposure Guideline
50 Feet*
Accidental Release Outdoor Receptor
150 ppm
150 ppm ERPG-2 Public Exposure Guideline
130 Feet
Notes: ^Exposure times for ERPG and IDLH are 60 minutes and 30 minutes, respectively.
Concentrations are calculated for the respective exposure time. These air quality impacts
are estimated based on a ground level release and do not account for the characteristics of
building ventilation systems. Storage units may be equipped with ventilation systems, and
buildings may be equipped with gravity or mechanical ventilation systems that would reduce
to some extent indoor and outdoor air concentrations.
*The closest occupied structure is assumed to be located 50 feet from the storage unit location.
**The closest occupied structure is assumed to be located 200 feet from the transfer station.
Storage of greater than 100 kilogram quantities
Grantees may encounter quantities of hazardous waste greater than 100 kilograms, or
greater than 1,000 kilograms, in conducting clandestine drug laboratory seizures and
removal actions. Such hazardous wastes would be classified as SQG or LQG wastes, and
transportation of such wastes to storage units would require a RCRA transporter license.
Storage of these quantities by a grantee meeting state and federal regulatory requirements
and DOJ COPS Office Award Conditions would be allowed under the Proposed Action.
However, the DOJ COPS Office has assumed it to be unlikely that in the event that a
grantee stored greater than 100 kilograms of hazardous waste in a single location that an
accidental release would involve the entire quantity of stored hazardous waste at that
location. The DOJ COPS Office anticipates that a release of the entire quantity of stored
hazardous waste from a single location as a result of breaching of all stored containers at
once would only occur in the event of a facility-wide fire. This situation is possible but
highly unlikely, considering that storage of hazardous wastes generated by SQGs or LQGs
would be subject to additional regulatory requirements that do not apply to CESQG-
generated hazardous waste. The DOJ COPS Office therefore has not performed any
quantitative analysis of potential environmental consequences of potential releases of
greater than 100 kilograms of hazardous waste.
In general, an outdoor release of greater than 100 kilograms of hazardous waste would
result in higher concentrations persisting over greater distances and for longer periods
than for a 100-kilogram release. Therefore, the radius of potential exceedance of ERPG-2
levels would increase for a larger quantity release, potentially increasing the number of
exposed public receptors depending upon the location of the accidental release. With

respect to indoor releases, the point of release concentration to which persons within the
building would be exposed would increase in a linear manner with the quantity of release,
without accounting for any differences in the characteristics of storage unit or building
ventilation systems.
Other Grant Funded Activities
Grant-funded training could potentially result in an impact to air quality. Several states
use DOJ COPS Office funding for laboratory demonstrations of how methamphetamine is
chemically produced and the specific precursor chemicals involved. The State of
Arkansas Initiative, for example, provides a grant-funded training program to familiarize
its agents with the methamphetamine cooking process and precursors. Use of chemicals
in training activities would result in fugitive air emissions. However, the quantities of
chemicals utilized for training are low and are used by trainers in a controlled
environment. Air emissions associated with grant-funded training are therefore not
anticipated to significantly affect ambient air quality or to result in occupational exposure of trainees.
Grant funding has been used to purchase vehicles for the transportation of personnel,
safety and law enforcement equipment and hazardous waste. Vehicles purchased using
grant funding have included automobiles, full sized pickup trucks, clandestine laboratory
response vehicles that are designed to carry safety equipment and that may be equipped
with personnel decontamination apparatus, and all-terrain vehicles. Operation of vehicles
has potential environmental impacts with respect to vehicle air emissions.
In general, grant-funded vehicles are used to consolidate transportation of personnel and
safety equipment to clandestine drug laboratory locations and may therefore result in
operation of fewer vehicles and reduction in vehicle miles traveled, or reduction in
emissions per vehicle mile. Vehicles are also used to transport hazardous waste from
clandestine drug laboratory locations. However, some of the vehicles being purchased
are full sized pickup trucks, SUVs with towing packages, and off-road vehicles including
all-terrain vehicles. Some of the vehicles are replacing smaller vehicles or are replacing
older vehicles. However, the availability of additional vehicles may result in increased
law enforcement activities, potentially increasing vehicle miles traveled. Overall
however, operation of grant-funded vehicles would not represent a significant source of
air emissions as compared to overall agency vehicle operations.
The DOJ COPS Office Methamphetamine Initiative also may result in increased air
emissions from operation of chemical analytical laboratories. These analytical
laboratories process evidence and environmental samples from seized clandestine drug
laboratories. Grants are used to purchase additional analytic equipment such as scanning
electron microscopes and general laboratory supplies such as glassware and chemical
analytical reagents. Grants may also fund the training of additional analytical chemists.
Typical air emissions from an analytical laboratory are not anticipated to significantly
affect air quality. For most grant-funded methamphetamine initiatives, the chemical
analytical laboratories are already constructed and operating independently of the

initiative, and grant funding is used to supplement existing operations. Therefore any
grant-funded equipment or personnel would only result in an incremental increase over
existing air emissions from the laboratory facility. The DOJ COPS Office grants would
generally only provide equipment, supplies, and personnel, not construction or
modification of buildings or structures, and the DOJ COPS Office does not anticipate
providing grant funding to establish an entirely new chemical analytical laboratory under
the Proposed Action. Any new construction or modification of a chemical analytical
laboratory would be subject to site-specific NEPA analysis and is outside the scope of the
Proposed Action.
8.1.2 Water Quality
Hazardous Waste Management Activities
Removal Action Scenarios
Potential benefits to water quality are anticipated from the normal conduct of removal
actions under the DOJ COPS Office Methamphetamine Initiative. Clandestine drug
laboratories represent a potential source of releases to surface water from hazardous
wastes stored and used at the sites. Conduct of grant-funded removal actions would
reduce potential sources of releases to surface water from clandestine drug laboratory
operations, including illicit releases of hazardous wastes to sinks, drains, or outdoor
areas. Such releases could contaminate surface water directly or affect the operation of
septic systems or POTW.
Normal conduct of laboratory seizures and removal actions could involve generation of
wastewater from the operation of grant-funded portable decontamination stations used to
decontaminate personnel conducting operations. It is assumed that decontamination
wastewater is not released to the environment at the removal action location but is
collected and disposed of in accordance with federal, state, and local requirements and
DOJ COPS Office grant award conditions. No significant environmental impacts to water
quality are anticipated for normal conduct of removal actions.
Single Family House Scenario / Rural Open Air Setting Scenario
An accidental release during a removal action conducting in an outdoor environment for
the Single Family House or Rural Open Air Setting scenarios could result in potential
environmental impacts to surface water. A release of hazardous waste to surface water,
either directly or indirectly through runoff, could result from a materials handling
accident or container failure. The DOJ COPS Office considers the probability of such an
occurrence to be low, however, the potential consequences of such a release could be
significant if the release is not controlled. The potential release of hazardous waste
directly to surface water during a removal action is unlikely considering that the personnel
conducting the removal action would be available to respond to the release, and the laboratory
location may or may not be in the vicinity of a surface water body. Also, a
release of hazardous waste to surface soil would likely be diluted on its way to any nearby

surface water body and would result in a lower environmental impact than a release
directly to surface water.
The DOJ COPS Office conducted dispersion modeling for an uncontrolled release to
surface water based on a methodology and data developed by the USGS.49 The DOJ
COPS Office based the release modeling on a potential release of 100 kilograms of either
toluene or iodine, based on the amounts of these hazardous wastes found at clandestine
drug laboratory sites and the aquatic toxicity of these compounds. Iodine and toluene
were selected for the screening water quality analysis based on several factors including
that toluene and iodine have been recovered from clandestine drug laboratories in
quantities on the order of 100 kilograms for a single site. Surface water quality and
aquatic toxicity criteria could be exceeded in rivers and streams in the event of an
uncontrolled 100-kilogram release. The consequences of such a release are based on the
quantities and characteristics of the hazardous wastes released and the characteristics of
the river or stream in which the release occurs. The methodology and results of the
surface water release dispersion modeling are shown in Appendix L, Water Quality
Impact Analysis.
49 Jobson, H.E., 1996. Predictions of Travel Time and Longitudinal Dispersion in Rivers and
Streams, USGS Water Resources Investigation Report 96-4013, 1996.
The Rural Open Air Setting location is assumed to be in the vicinity of a surface water
body. A release of a liquid or solid hazardous waste during a laboratory seizure or
removal action would be subject to emergency response by removal action personnel
trained in emergency response. It is assumed that the response would be timely, but not
necessarily totally effective, depending upon the specific response equipment that the
hazardous waste management personnel have available. Effectiveness of the response
would depend upon the circumstances of the release and the environmental setting of the
release, and on the specific equipment that the responders have available. A liquid spill
may not be fully contained by emergency response and could result in impacts to surface
water quality. By comparison, a solid release (e.g., iodine) could be mostly contained and
remediated. It is possible that a liquid release at an urban or suburban location could
impact a storm sewer or sanitary sewer system. Such a release would likely enter a
municipal wastewater treatment system and could result in potential effects on POTW
operation downstream of the release. A liquid release at an outdoor location, if not
contained in a timely manner, could have direct impacts to a surface water body.
Multi-unit Residential Property Scenario
Removal action locations for the Multi-unit Residential Property Scenario are assumed not
to be situated in the vicinity of a surface water body.
Transportation Scenario
The DOJ COPS Office Methamphetamine Initiative may result in potential impacts to
surface water quality associated with transportation of hazardous waste from the removal

action location to the storage location. It is assumed for this scenario that an accident
occurs involving a transportation vehicle conveying hazardous waste from the removal
action. The accident is assumed to result in a hazardous waste container either entering
directly into a stream or hazardous waste from a breached container being inadvertently
washed into a stream by emergency response personnel responding to the accident.
The methodology and results of the surface water release dispersion modeling are shown
in Appendix L, Water Quality Impact Analysis. The modeling for the transportation
scenario assumes the same release quantity and river/stream characteristics as for the
removal action scenario, and therefore the modeled concentrations are the same as for the
removal action scenario, discussed above. Surface water quality and aquatic toxicity
criteria could be exceeded in rivers and streams in the event of an uncontrolled 100 kilogram
release.
The likelihood of a release and potential consequences of a release may differ for the
self-transportation scenario and the licensed transport scenario, and may be affected by
potential differences in release response time and response actions taken by qualified law
enforcement personnel conducting hazardous waste transportation versus DEA contractors
conducting the transportation. For the self-transport scenario, hazardous waste may be
transported by qualified law enforcement personnel in vehicles that are not designed to
carry hazardous waste containers, but that are modified to carry hazardous waste
containers. For the licensed transport scenario, hazardous waste may be transported in
response vehicles that are designed to transport hazardous waste and that may be more
fully enclosed than modified vehicles used for self-transport of waste. The likelihood of a
container breach in the event of an accident may be somewhat lower in the event that a
response vehicle is used to transport the hazardous waste, however, such differences are
not readily quantifiable.
Transportation of less than 100 kg
In the event of a 100 kilogram release of iodine at high river flow rate, the peak iodine
concentration would also be 69,300 ug/l at a distance of 1.9 kilometers from the point of
release, as the modeling approach is independent of the characteristics of the substance
released and only considers the quantity released and the characteristics of the river.
Several factors influence the potential for and the consequences of a release of less than
100 kilograms of hazardous waste as a result of a transportation accident. The potential
for releases associated with transportation accident of hazardous waste, and associated
potential for discharges to surface water may be higher for self-transportation by grantees
than for DEA contractors conducting the transportation. Qualified law enforcement
personnel would not necessarily develop as high a level of familiarity with hazardous
waste management practices and procedures as would DEA contractors. This is because
qualified law enforcement personnel may not be conducting such activities on a day-today
basis as part of their job function, but would be conducting such activities only on an
as-needed basis. This may affect the timeliness and/or effectiveness of response to an
accident. The likelihood of a release also depends upon the type of vehicle used and the

method by which the containers are secured within the vehicle.
The potential for water quality impacts resulting from a transportation accident could be
affected by the timeliness of and effectiveness of response to the accident, which in turn
may be affected by the types of information available to responders concerning the
characteristics of the hazardous waste involved in the accident. Grantees are not required
to use placarded vehicles, container markings, or hazardous waste manifests to self
transport CESQG waste, but may instead use shipping papers that may not provide the
same level of information concerning the nature of the release as would hazardous waste
manifests, container markings, and vehicle placards. Therefore, in an accident scenario,
responders would not necessarily be aware that there was a release of hazardous waste.
The DOJ COPS Office anticipates that a shipping paper would be included in the
grantees vehicle for CESQG shipments but that the shipping paper may not provide as
detailed or as timely information to responders. Information concerning the DOT proper
shipping name, hazard class, DOT identification number, and special handling instructions
for the hazardous waste, information that would be included on a hazardous waste
manifest may not be available to emergency responders if there is no hazardous waste
manifest. This could potentially result in a less timely and less effective response. Solid
or liquid releases from a transportation accident could be inadvertently washed into
surface water by emergency response personnel if the responders are not aware that the
vehicle is transporting hazardous waste. Impacts to surface water associated with
hazardous waste releases during transport could therefore be higher for qualified law
enforcement personnel conducting transportation actions than for DEA contractors
conducting the transportation. However, differences in such human factors are not readily
quantifiable, and therefore no quantitative analysis of potential differences in release
response time and potential effectiveness of response actions taken have been conducted.
Transportation of greater than 100 kilograms
In the case of transportation of greater than 100 kilograms or over 1000 kilograms of
hazardous waste, the grantee would be operating as a SQG or LQG, and therefore all DOT
and RCRA regulations would apply (see Tables 5.1-1 and 5.2-1 for a summary of specific
regulations). Thus, grantees performing their own transportation would be required to
obtain hazardous waste transportation licenses and utilize vehicles placards, container
markings, and hazardous waste manifests in accordance with RCRA regulations for
SQGs. The additional information provided by the vehicle placards and manifests may
increase the timeliness and effectiveness of response actions in the event of a
transportation accident.
The DOJ COPS Office has assumed for the purposes of the quantitative environmental
consequences analysis that only one 100 kilogram container would be breached in the
event of an accident, even if the vehicle were transporting multiple containers with a total
of more than 100 kilograms of hazardous waste. The DOJ COPS Office assumes that the
release of more than one 100-kilograms during a transportation accident is possible, but
unlikely. However, the potential exists for solid or liquid releases from a transportation

accident to directly enter surface water or be inadvertently washed into surface water by
emergency response personnel responding to a transportation accident. Surface water
concentrations resulting from a release of more than 100 kilograms would increase in a
more or less linear fashion proportional to the amount of the release.
Storage Scenarios
Indoor Storage Scenario
Indoor storage units that are not permitted RCRA storage facilities would be equipped
with spill containment systems in accordance with NFPA Codes and OSHA requirements
such that liquid releases would be contained within the unit. It is not likely that building
itself would be equipped with a full secondary containment system unless the storage unit were
a RCRA permitted storage facility, however, the DOJ COPS Office anticipates that the storage
cabinets and lockers would provide containment of releases within the cabinets and lockers.
If the storage unit were a RCRA permitted storage facility, it would be equipped with full
secondary containment systems and the cabinet or locker would need to be situated on a concrete
pad with curbs and without accessible floor drains. This would provide additional containment
in the event of a release. There are also inspection requirements for greater than 10-day storage
facilities that would increase the probability that a leaking container would be identified and
remediated. However, the potential quantity of waste stored at permitted storage facility is
greater than that for a less than 10 day transfer station. The potential for impacts to surface
water from storage or accidental release of hazardous wastes are unlikely for the indoor storage
scenario for both a transfer station and for a permitted storage facility, however the likelihood
of such release would be lower for a permitted storage facility than for a transfer station.
Outdoor Storage Scenario
Outdoor storage units that are not permitted RCRA storage facilities would be equipped
with spill containment systems in accordance with NFPA Codes and OSHA requirements
such that liquid releases would be contained within the unit. It is not likely that storage
area itself would be equipped with a full secondary containment system unless the storage
unit were a RCRA permitted storage facility, however, the DOJ COPS Office anticipates that
the storage cabinets and lockers would provide containment of releases within the cabinets
and lockers. Outdoor storage facilities that are RCRA permitted storage facilities are
required to have full secondary containment systems to contain liquid releases, including
storm water runoff. Therefore, liquid releases occurring at outdoor storage facility that
is a permitted RCRA hazardous waste storage facility would be less likely to migrate to a
nearby surface water body directly or through contact with storm water runoff. There are
also inspection requirements for greater than 10-day storage facilities that increase the
probability that a leaking container would be identified and remediated.
The potential for impacts to surface water from storage or accidental release of hazardous
wastes are unlikely for the outdoor storage scenario for both a transfer station and for a
permitted RCRA hazardous waste storage facility, however the likelihood of such release
would be lower for a RCRA permitted storage facility than for a transfer station.

A release of hazardous waste to surface water from an outdoor storage unit would have
lower consequences than would an uncontrolled release resulting from a transportation
accident. The DOJ COPS Office assumes that the storage units would not be located in
the immediate vicinity of a river or stream and that hazardous waste released (if in the
unlikely case that is not contained and controlled) would migrate to surface water by
means of storm water runoff. This would dilute the release to some extent and therefore
the release would likely not result in exceedance of water quality criteria. Also, this
release pathway would only apply to releases of liquid waste. The DOJ COPS Office
assumes that any release of a hazardous solid waste (e.g., iodine crystals) from an outdoor
storage unit would be remediated prior to any significant transport of the hazardous waste
away from the property.
Other Grant Funded Activities
Grant-funded training could potentially result in releases to surface water. Several states
use DOJ COPS Office funding for laboratory demonstrations of the chemical production of
methamphetamine to familiarize qualified law enforcement personnel with the process. Liquid
wastes may also be generated during demonstration of equipment used for
chemical decontamination of personnel. It is assumed that any hazardous waste generated
during the demonstrations would be disposed according to federal, state, and local
requirements, and would not be disposed of through drain systems. Any liquid effluents
that are classified as hazardous waste are anticipated to be handled and disposed of as
laboratory waste, and any liquid effluents that are classified as non-hazardous waste
could be discharged to drain systems. Discharges to drain systems resulting from training
activities would likely be treated in a POTW. The DOJ COPS Office does not anticipate
that there would be any significant water quality impacts associated with grant-funded
training.
The DOJ COPS Office Methamphetamine Initiative also may result in increased
wastewater discharges from chemical analytical laboratories. These analytical
laboratories process evidence from seized clandestine methamphetamine laboratories.
Grants are used to purchase additional analytic equipment such as scanning electron
microscopes and general laboratory supplies such as glassware and chemical analytical
reagents. Grants may also fund the training of additional analytical chemists.
Typical wastewater emissions from an analytical laboratory are not anticipated to
significantly affect water quality. The DOJ COPS Office anticipates that grant-funded
chemical analytical laboratory activities would result in an incremental increase in the
generation of wastewater, which would be managed in accordance with federal, state and
local regulations, i.e., it would discharged to a POTW and would not represent a
significant load with respect to the overall flow to the POTW. The DOJ COPS Office
assumes that hazardous wastes generated chemical analytical laboratory operations are not
disposed of through the drain system. As discussed above, DOJ COPS Office grants
would only provide equipment, supplies, and personnel, not funding for construction or

modification. Any new construction or modification of a chemical analytical laboratory
would be subject to site-specific NEPA analysis and is outside the scope of the Proposed
Action.
8.1.3 Soil Quality
Hazardous Waste Management Activities
Removal Action Scenario
Potential benefits to soil quality are anticipated from the normal conduct of removal
actions under the DOJ COPS Office Methamphetamine Initiative. Clandestine drug
laboratories represent a potential source of releases to surface soils from hazardous wastes
stored and used at the sites. Conduct of grant-funded removal actions would reduce
potential sources of releases to surface soils, including illicit discharges of hazardous
waste to outdoor areas. The DOJ COPS Office does not anticipate that there would be any
discharges to soil from the normal conduct of hazardous waste removal actions.
Single Family House Scenario / Rural Open Air Setting Scenario
An accidental release during a removal action conducted in an outdoor environment has
the potential to affect soil quality. Such a release could occur as a result of a materials
handling accident or container failure. The DOJ COPS Office considers the probability of
such an occurrence to be low, however, the potential consequences of such a release could
be significant if the release is not controlled. The detailed methodology and assumptions
for determining soil quality impacts associated with normal operations and accidental
releases to surface water are provided in Appendix M, Methodology for Assessing Soil
Quality Impacts.
For a screening analysis of potential soil quality impacts for the release scenarios, the
DOJ COPS Office assumed that a release of hazardous waste to soils could occur as a result
of container breach or materials handling accident. The DOJ COPS Office compared the
calculated soil concentration for each hazardous waste to the SSL for soil ingestion, as
shown in Table 8.1-4.
Table 8.1-4
Soil Quality Impacts for the Removal Action Scenarios
Hazardous Waste Released
Release Amount (Kilograms)
Soil Ingestion SSL (mg/kg soil)
Concentration (mg/kg soil)
Percent of SSL
Toluene
100
16000
66667
416%
Acetone
100
7800
66667
854%
Sodium Dichromate
2.5
390
331
84%
Note: Soil Ingestion SSL and Calculated Soil Concentration are for Chromium+6 for Sodium Dichromate

As shown, concentrations of hazardous waste released to surface soil for the release
scenarios could exceed generic SSLs by nearly a factor of ten for acetone and nearly a
factor of five for toluene. Concentrations of sodium dichromate (calculated as
chromium+6) are estimated to be approximately equal to the SSL. Ingestion of
contaminated soils at such concentrations could represent a human exposure risk,
particularly to children, and existence of contaminated soils at such concentrations would
warrant remediation of the contamination.
Ingestion of contaminated soils at such concentrations could represent a human exposure
risk, particularly to children, and existence of contaminated soils at such concentrations
would warrant remediation of the contamination. Soil quality impacts from the release
scenarios (i.e., hazardous waste releases) are assumed not to be ongoing. The DOJ COPS
Office assumes that releases to soil that occur as a result of removal actions would be
subject to emergency response and that therefore potential releases to soils would not
represent an ongoing impact to soil quality.
Multi-unit Residential Property Scenario
The location for the Multi-unit Residential Property Scenario is assumed not to be in the
vicinity of surface soils
Transportation Scenario
No significant discharges to surface soils are anticipated for normal conduct of hazardous
waste transportation under the DOJ COPS Office Methamphetamine Initiative. However,
a release of hazardous waste to surface soils resulting from a transportation accident has
the potential to affect soil quality. The methodology and assumptions used in screening
soil quality impacts for the transportation scenario are identical to those used for the
removal action scenarios and are summarized in Appendix M, Methodology for Assessing
Soil Quality Impacts and Table 8.1-4.
Storage Scenarios
The DOJ COPS Office does not anticipate any significant potential for releases to surface
soils resulting from indoor storage. Environmental impacts to surface soils from storage
or accidental release of hazardous wastes are unlikely for the outdoor storage scenario for
both a transfer station and for a permitted RCRA hazardous waste storage facility,
however the likelihood of such release would be lower for a RCRA permitted storage
facility than for a transfer station.
Hazardous Waste Disposal
The DOJ COPS Office anticipates that disposal of hazardous wastes generated from grant-
funded removal actions in RCRA Subtitle C-permitted facilities would not result in
significant environmental impacts. In general, the types of hazardous wastes generated
from removal actions, including flammable and combustible wastes, reactive wastes

(oxidizers) and corrosive wastes (acids, bases) would be treated prior to disposal, or, in
the case of flammable or combustible wastes, burned for energy recovery. Also, RCRA
land disposal restrictions (LDRs) prohibit the disposal of free liquids and other untreated
hazardous wastes in hazardous waste landfills. Therefore, the DOJ COPS Office does not
anticipate that any untreated hazardous wastes generated from grant-funded activities would
be disposed of in landfills.
DEA contractors are required to dispose of all hazardous wastes generated from removal
actions in RCRA-permitted TSDFs. CESQGs may, in some states, dispose of CESQG-
generated hazardous waste in non-RCRA permitted facilities, as discussed in Section 6.6.
Non-RCRA permitted disposal facilities (generally state-permitted facilities) permitted to
accept CESQG hazardous waste may be subject to less extensive monitoring and controls
and treatment requirements than RCRA-permitted facilities and may therefore represent a
somewhat higher potential for releases than RCRA-permitted facilities.
The DOJ COPS Office anticipates that treatment and disposal of treated hazardous wastes
generated from grant-funded removal actions would result in minimal environmental
impacts. The quantity of hazardous wastes generated from grant-funded activities is
anticipated to be minimal as compared to the general throughput of hazardous waste to the
RCRA-permitted TSDFs utilized by grantees. Therefore the contribution of such wastes
to TSDF effluents would be minimal under most circumstances. Also, RCRA-permitted
TSDFs are extensively monitored with respect to potential for environmental impacts, and
TSDFs are required to implement effluent monitoring, inspection, and maintenance plans
and closure and post-closure monitoring plans. Permitting of TSDFs (including renewal
of permits for existing facilities) generally involves environmental and human health risk
assessment, in many cases TSDFs are subject to environmental impact assessment under
little NEPAs (e.g., under the California Environmental Quality Act. Therefore, the DOJ
COPS Office concludes that the potential for environmental impact from treatment and
disposal of hazardous wastes generated by grant-funded activities in minimal.
Other Grant-funded Activities
The DOJ COPS Office does not anticipate impacts to soil quality from other grant-funded
activities
8.1.4 Human Health and Safety
Clandestine Drug Laboratory Seizure Activities
Clandestine drug laboratory seizure operations and removal actions present potential
occupational health and safety hazards to qualified law enforcement personnel,
particularly to investigative and other personnel who are first responders to clandestine
drug laboratory sites. These sites generally contain hazardous materials and potentially
hazardous indoor air concentrations of air contaminants that could result in short-term or
long-term health effects to exposed individuals. These sites may also contain corrosive,
flammable, or explosive materials, including booby traps, which may represent physical

hazards to responders. First responders who discover clandestine drug laboratories may
be entering situations where the locations and characteristics of such hazards are not well
characterized. Personnel would characterize, package, label, mark, and physically remove
hazardous wastes from the clandestine drug laboratory locations. These activities have the
 potential to result in occupational exposure to improperly stored hazardous wastes and to
other physical and chemical hazards that may not have been discovered during conduct of law
enforcement activities. Even considering the wider availability of personal protective
equipment, state and local law enforcement agencies may not necessarily be able to afford
to purchase and maintain the types of personal protective equipment (PPE) for clandestine
drug laboratory seizures. 50 51
The Centers for Disease Control (CDC) Agency for Toxic Substances and Disease
Registry (ATSDR) maintains the Hazardous Substances Emergency Events Surveillance
(HSEES) System to collect and analyze information about hazardous substance release
events, including events occurring at clandestine methamphetamine laboratories. The
CDC reported that in 1999 three police officers in Iowa suffered respiratory irritation
after exposure to anhydrous ammonia and ether emissions during seizure of a residential
clandestine methamphetamine laboratory. The police officers required decontamination at
the site and treatment at a local hospital. 52 The CDC also reported that of 67 injured
first responders (including 55 police officers) reported by state health departments in Iowa,
Minnesota, Missouri, Oregon, and Washington, 57 were not wearing personal protective
equipment at the time of injury, including 45 police officers. Approximately one-third of
the 36 reported injury events involved exposure to anhydrous ammonia and one-third
involved exposure to hydrochloric acid. 53 Seven of the reported events involved
explosions. Approximately two-thirds of reported injuries to police officers involved
respiratory irritation. The ATSDR reported that one of the agencys health investigators
conducting environmental sampling at an inactive residential clandestine
methamphetamine laboratory experienced second-degree chemical burns from acid
encountered while conducting sampling activities at the site. 54
50 Hughart, J., 2000. Chemical Hazards Related to Clandestine Drug Laboratories, Agency for
Toxic Substances and Disease Registry, 2000.
51 Chesley, Dr. Michelle R., 1999. Methamphetamines: An Epidemic of Clandestine Labs and
Health Risk. Howard University Hospital, Department of Emergency Medicine, Washington DC, September 28, 1999.
52 CDC, 2000. Public Health Consequences Among First Responders to Emergency Events Associated
With Illicit Methamphetamine Laboratories  Selected States, 1996  1999. U.S. Centers for Disease
Control, Morbidity and Mortality Weekly Report, November 17, 2000.
53 CDC, 2000. Public Health Consequences Among First Responders to Emergency Events Associated
With Illicit Methamphetamine Laboratories  Selected States, 1996  1999. U.S. Centers for Disease
Control, Morbidity and Mortality Weekly Report, November 17, 2000.
54 Hughart, J., 2000. Chemical Hazards Related to Clandestine Drug Laboratories, Agency for
Toxic Substances and Disease Registry, 2000.
The ATSDR and medical department and health researchers have reported on chemical
hazards related to methamphetamine laboratories, and reported that law enforcement
officers have been exposed to respiratory and other hazards and injured while serving
warrants and conducting investigations of clandestine drug laboratory activities, and also
reported that prior to the recent wider availability of personal protective equipment, law

enforcement officers conducting clandestine drug laboratory seizures have experienced
both acute and chronic health effects. Even considering the wider availability of personal
protective equipment, state and local law enforcement agencies may not necessarily be
able to afford to purchase and maintain the types of personal protective equipment for
clandestine drug laboratory seizures. 55 56
The EPA has published a fact sheet concerning hazards associated with clandestine
methamphetamine laboratories, particular with respect to illicit theft and storage of
anhydrous ammonia. 57 The EPA indicates that ammonia's low boiling point, affinity for
water, and inhalation hazard, may result in responders being injured if not wearing
appropriate PPE. The use of self-contained positive-pressure breathing apparatus is
appropriate during a response to an anhydrous ammonia release, and cryogenic gloves
with a moisture barrier may also be needed to protect against freezing and/or chemical
burns.
55 Hughart, J., 2000. Chemical Hazards Related to Clandestine Drug Laboratories, Agency for
Toxic Substances and Disease Registry, 2000.
56 Chesley, Dr. Michelle R., 1999. Methamphetamines: An Epidemic of Clandestine Labs and Health
Risk. Howard University Hospital, Department of Emergency Medicine, Washington DC, September 28, 1999.
57 EPA, 2000. Anhydrous Ammonia Theft, United States Environmental Protection Agency, Office of
Solid Waste and Emergency Response, (5104), EPA Publication Number EPA-F-00-005, March 2000,
http://www.epa.gov/ceppo/pubs/csalert.pdf
The Proposed Action is anticipated to result in health and safety benefits and overall
decrease the potential for occupational exposure of qualified law enforcement personnel to
hazards associated with clandestine drug laboratory seizures. The increased availability of
grant-funded personnel training, personal protective equipment for law enforcement
personnel, and environmental monitoring equipment for use in assessing laboratory site
hazards is anticipated to significantly reduce the potential for occupational exposure of
law enforcement personnel participating in laboratory seizures and associated removal
actions. However, some potential hazards could result from increased law enforcement
activities. When more laboratories are seized, agents are spending more labor hours
during removal actions in the vicinity of clandestine methamphetamine laboratory
hazards. This could result in increased incidence of exposure to laboratory hazards such
as hazardous waste, and booby traps such as explosives. This potential for heightened
incidence of exposure is balanced by the increased availability of safety equipment to
allow law enforcement personnel to better identify and protect against these hazards.
The Proposed Action is also anticipated to increase awareness of health and safety hazards
of clandestine drug laboratory operations and result in an increase in the number of
seizures of clandestine drug laboratories conducted by grant-funded personnel. For
example, law enforcement agents that receive comprehensive training in clandestine
methamphetamine laboratory enforcement, drug recognition, drug symptomology, and
chemical analysis could perform more aspects of methamphetamine law enforcement.
Grant-funded overtime potentially could result in an increased number of laboratory
seizures, and decreases in production/distribution of methamphetamine. Grant-supported
analyses of clandestine laboratory hazards could reduce the exposure of occupants and

neighbors, including children. In addition, grant-funded analytic laboratory chemists and
equipment should facilitate the analyses of evidence. Grant-funded education/outreach
increases public awareness of health and safety hazards.
The DOJ COPS Office Initiative grants allow law enforcement agencies to purchase
personal protective equipment and safety equipment to protect law enforcement officials
from potential health and safety impacts. In addition, potential human health and safety
benefits would result with respect to public safety. Specifically, the Iowa State
methamphetamine initiative uses grants to purchase locking caps for ammonia storage
tanks on farms. The locks deter thieves from removing ammonia to use for processing
methamphetamine. Many states use grant funding to purchase safety vehicles, including
SUVs or other four-wheel drive vehicles in order to transport safety equipment and
personnel. Better training, personal protective equipment, and better monitoring
equipment obtained through the DOJ COPS Office Methamphetamine Initiative would
decrease the likelihood of occupational exposure during removal actions.
Storage Scenarios
A spill of a hazardous liquid could result in a fire. Should a hazardous liquid spill and
catch fire in an indoor or outdoor storage unit, the consequences of the spill and fire would
depend upon the types and quantity of waste stored in the unit, the location of the unit, and
timeliness of the response to the fire. Other chemicals stored in the unit (e.g., oxidizers)
could become involved in the fire and thus further promote the reactivity and intensity of the
fire. However, as discussed in Section 5.3, both EPA and States have standards and guidelines
for storage of incompatible wastes, and such wastes may be segregated from the flammable and
combustible hazardous wastes involved in any fire. It is assumed that no pressurized flammable
gases are contained in the storage unit; otherwise there would be a great potential for explosion.
The rapidity of response will largely determine the degree of impact to the building and
any human receptors. If the storage unit is located at a fire station, trained firefighting
personnel could immediately respond to the fire. If the storage unit was located at a police
station, response of trained firefighters could take longer, potentially affecting the extent
and consequences of a fire. The normal functions in the building (e.g., responding to public
safety/public emergencies) could be temporarily compromised by the fire; however, the DOJ COPS
Office anticipates that the amount of smoke inside the building would be minimal assuming a
rapid response. Assuming a rapid response, the DOJ COPS Office anticipates that the effects of
a fire would be limited and contained by responders.
The DOJ COPS Office anticipates that the fire and smoke from either an indoor or
outdoor fire would not likely compromise the normal functions of the building. After an
indoor fire, the interior of the building may have to be decontaminated. Decontamination
may make parts of the building unavailable for use for a short period of time. For an
outdoor storage unit fire, the extent of damage to the building would depend upon the
location of the storage unit in relation to the building. Assuming a rapid response, the
DOJ COPS Office anticipates that the effects of a fire would be limited and contained by

responders.
Indoor Storage Scenario
A fire in an indoor storage unit could initially be limited to the storage unit. Standards for
location of indoor storage units are summarized in Section 5.3. Storage units may or may not
be equipped with fire suppression systems (see Section 5.3). The DOJ COPS Office
assumes that storage units would be designed and sited in accordance with fire protection
codes (e.g., NFPA Code 30) and would meet requirements outlined in grant award
conditions. An indoor fire involving less than 100 kilograms (e.g., approximately 30
gallons) could be initially limited to only one storage cabinet or locker. The storage unit
either would be vented to the outside of the building or would not be vented. The rapidity
of response will largely determine the degree of impact to the building and to the services
provided by the personnel. Each storage cabinet or locker may contain up to 60 gallons of
hazardous waste. If the fire occurred in a cabinet containing 60 gallons (more than 100
kilograms) of flammable liquids, the fire would involve the additional materials and the
fire would likely engulf the full storage cabinet. NFPA Codes and OSHA and RCRA requirements
for storage cabinet design and separation distances between other storage cabinets would
help limit the potential spread of the fire (see Section 5.3). Smoke would potentially
spread throughout the building. Any hazardous materials lockers would probably not be
located in the same area as the flammable liquids storage cabinet. It is assumed that
no pressured flammable gases are contained in the storage cabinet; otherwise there would
be a great potential for explosion.
For a fire involving a full 60 gallons of flammable liquids, the rapidity of fire response
will largely determine the degree of impact to the building and the services provided by
the building personnel. If the storage cabinet was located in a fire station, trained
firefighting personnel could immediately respond to the fire. If the storage cabinet is
located in a police station, response of trained firefighters could take longer, potentially
affecting the extent and consequences of a fire. The normal functions in the building (e.g.,
responding to public safety/public emergencies) could be temporarily compromised by fire and
smoke and subsequent need for decontamination. The DOJ COPS Office assumes that the occupied
structures may be 50 feet from the storage unit. Smoke generated by the fire could therefore
require that adjoining residential or commercial areas be evacuated.
Outdoor Storage Scenario
The impacts of a fire in a storage unit located outdoors would depend on the location of
the storage unit in relation to the building. Standards for location of outdoor storage units
 are summarized in Section 5.3. A fire could initially be limited to the storage area. Additional
chemicals stored in the unit, if not segregated, could become involved in the fire and thus
further promote the reactivity and intensity of the fire. For an outdoor fire involving between
 100 and 1,000 kilograms of hazardous material, it is likely If more than one storage locker
becomes involved in a fire, the fire could involving more than 100
kilograms of flammable liquids. In this case the fire would intensify and smoke generated

by the fire could necessitate evacuation of adjacent buildings. The rapidity of response
will largely determine the degree of impact to the building and to the services provided
by the personnel. The DOJ COPS Office anticipates that for the outdoor fire scenario the
normal functions of the building would not likely be extensively compromised by fire and
smoke, and the building would probably not be damaged.
Other Grant-funded Activities
The Proposed Action is anticipated to have health and safety benefits to the general public
as well as to law enforcement personnel. Some states have used grant funding to
administer drug and chemical diversion programs. These programs focus on investigating
the illegal distribution and use of legitimate narcotics by those licensed to handle drugs
such as doctors, dentists, veterinarians, and nurses. Drug diversion agents monitor legal
vendors or owners of methamphetamine precursor materials (such as denatured alcohol
and anhydrous ammonia). In some states, drug diversion agents provided farms with
locks for anhydrous ammonia tanks (the ammonia is used for fertilizers on farms). Agents
also track drug theft, forgery, and wire fraud cases to determine if legitimate narcotics
are being diverted to illegitimate uses. The potential reduction in the number of clandestine
drug laboratories could result in benefits to public health and safety due to increased law
enforcement activities. In addition, the DOJ COPS Office Methamphetamine Initiative supports
state and local Drug Endangered Children programs, discussed in Section 9.0.
8.1.6 Social Effects
Hazardous Waste Management Activities
Storage Scenarios
The DOJ COPS Office Methamphetamine Initiative has potential social impacts related to
the potential for temporary loss of use of building areas of a police or fire station or
other government property the event of a fire, release, or other accident involving hazardous
waste in an indoor storage unit. In the event of a fire or other accident event, areas of the
building may need to be evacuated, and building areas could require decontamination before the
 areas may be reoccupied. Decontamination could require several days to complete. Also, the
storage unit itself, presumably damaged by the fire or other accident event, would have to
be replaced. Potential temporary loss of use of building areas resulting from a fire or other
 accident event represents a potential social and economic cost to police/fire station, and
could interfere with the function of the police/fire station as a whole or interfere with
the implementation of the methamphetamine initiative.
No substantive potential social impacts related to the potential temporary loss of use of
DEA contractor property are associated with DOJ COPS Office Methamphetamine
Initiative. Potential temporary loss of use of building areas of DEA contractor-operated
transfer stations could result from a fire, release, or other accident involving hazardous
waste stored at the transfer station. Such temporary loss of use of property would
represent a business cost to the DEA contractor, however the DOJ COPS Office does not

anticipate that any such loss would interfere significantly interfere with the ability
of DEA contractors to conduct removal actions. The DOJ COPS Office anticipates that in the
event of temporary loss of use of property the DEA contractor would have the ability to
divert hazardous waste shipments from clandestine drug laboratories to another DEA
contractor-operated transfer station until the use of the property is restored.
The potential for diversion of hazardous wastes, and associated social effects of such
diversion, could occur at a local police or fire station under the DOJ COPS Office
Methamphetamine Initiative. State and local qualified law enforcement personnel and
other persons that may have access to facilities where storage units are located would not
be subject to background checks and clearances, and therefore there would be less
opportunity for screening and limiting the number of individuals that would have access to
the areas where hazardous waste is handled and stored. Although personnel participating
in a law enforcement program would not be expected to present a risk of diversion, the
police stations and fire stations where storage units may be situated could also be
accessible by non-program persons, including non-government personnel and members of
the public, which could increase the risk of diversion particularly if the storage unit is
located outdoors. Security requirements for storage unit locations for DEA contractors
exceed regulatory requirements, and security requirements for storage units operated by
grantees are not anticipated to be as stringent as those required for DEA contractors under
 the provisions of the DEA contracts. The DOJ COPS Office anticipates that grantees may or
may not implement security measures for their storage units that are as stringent as for
DEA contractors. This could increase the potential that hazardous wastes could be
diverted from the storage unit location as compared to storage units operated by DEA
contractors.
Other Grant Funded Activities
The DOJ COPS Office Methamphetamine Initiative is anticipated to result in social
benefits to communities where clandestine drug laboratories are being operated. General
increased funding for state and local law enforcement agencies would result in greater
social benefits through improvement in the quality, scope, quantity of law enforcement
activities. Grant-funded overtime potentially could result in an increased number of
laboratory seizures, and decreases in production/distribution of methamphetamine. Grant-
supported analyses of clandestine laboratory hazards could reduce the exposure of
occupants and neighbors, including children. In addition, grant-funded analytic laboratory
chemists and equipment should facilitate the analyses of evidence and prosecution of
suspects. An increased number of clandestine methamphetamine laboratory seizures with
associated reductions in the production and distribution of drugs would result in a social
benefit under the DOJ COPS Office Methamphetamine Initiative.
8.2 No Action Alternative
This section describes the environmental consequences analyses for the No Action
Alternative. Under the No Action Alternative, the DOJ COPS Office Methamphetamine
Initiative would not receive Federal funding, and no funding would be dispersed by the

DOJ COPS Office to prospective grantees. Therefore, no grant-funded activities would be
conducted under the No Action Alternative.
Under the No Action Alternative, it is assumed that loss of funding for the DOJ COPS
Office Methamphetamine Initiative would result in a reduction in the effectiveness of state
and local law enforcement activities related to state and local methamphetamine
initiatives. Under the No Action Alternative, law enforcement activities and equipment
purchases proposed for grant funding would not be funded. Law enforcement agencies
that requested grant funding would either forgo such activities and purchases due to lack
of such funding, or would redirect funding for such activities and purchases from other
areas of their state and local budgets. The DOJ COPS Office cannot predict how each
state or local law enforcement agency would react to a loss of methamphetamine initiative
grant funding, however, the DOJ COPS Office assumes that state and local governments
would not be able to replace a significant amount of the Federal grant funding with state
and local funding. The DOJ COPS Office Grant Award Conditions require that grant
funding not be used to supplant existing funding. Budget Narratives prepared by
prospective grantees for FY2002 generally explicitly indicate that requested federal
funding could not be replaced by state or local budget resources. The DOJ COPS Office
therefore assumes that fewer law enforcement personnel would be deployed and less
equipment would be available for state and local methamphetamine initiatives, and that as
a result the effectiveness of such initiatives would be reduced.
The DOJ COPS Office assumes that under the No Action Alternative fewer clandestine
drug laboratories may be seized, as a result of the elimination of grant funding for state
and local law enforcement activities and loss of availability of regular and overtime
personnel and equipment. However, the DOJ COPS Office cannot predict whether,
where, or to what extent, a reduction in the number of clandestine drug laboratories
seizures would occur under the No Action Alternative, as this would be affected by state
and local agency decisions concerning how to respond to the loss of grant funding.
Under the No Action Alternative, DEA contractors under the DEA National Clandestine
Laboratory Cleanup Program would not receive Federal funding to manage hazardous
waste generated from clandestine drug laboratory seizures conducted by state or local law
enforcement agencies. State and local agencies would be responsible for securing
alternative sources of funding to conduct hazardous waste management activities related
to clandestine drug laboratory seizures. Therefore, drugs, drug precursors, and/or
hazardous waste may remain in place at clandestine drug laboratory locations for an
unspecified period of time until such time as alternative sources of funding are identified.
8.2.1 Air Quality
The No Action Alternative would not result in any reduction in baseline air quality
impacts that are assumed to be resulting from releases from improperly stored hazardous
wastes at clandestine drug laboratory locations. Clandestine drug laboratories that are
not identified and seized due to resource constraints would represent a potential
continuing impact to air quality with respect to air emissions from methamphetamine cooking

operations and from fugitive emissions and illicit disposal of hazardous wastes from such
operations. The potential for exposure to air emissions would continue to exists with
respect to occupants of the clandestine drug laboratory and adjacent properties.
Hazardous wastes remaining in place under the No Action Alternative would represent a
continuing hazard with respect to potential accidental releases to air. In the event that
100 kilograms of ammonia were released inside an apartment (15,000 cubic feet) in a
multiunit residential property (e.g., resulting from failure of a container), the
anticipated ammonia concentration initially would be 320,000 parts per million (ppm).
This would cause fatalities for anyone entering the apartment and becoming exposed to
the ammonia gas. Adjacent apartment units could be expected to have ammonia concentrations of
approximately 6,400 ppm, far exceeding the ERPG-2 level of 150 ppm, and exposure to
such concentration would impair the ability of persons to take protective action. As a
result, persons in adjacent apartments would experience severe health effects.
8.2.2 Water and Soil Quality
Clandestine drug laboratories that are not identified and seized as a result of resource
constraints would represent a potential continuing impact to water quality with respect to
illicit disposal of hazardous wastes to sinks, bathtubs, or toilets, which could potentially
affect the operation of POTWs or contaminate domestic septic systems. Illicit disposal of
hazardous wastes outdoors (single family home backyards, rural areas) could result in
surface water and surface soil contamination. Hazardous wastes remaining in place under
the No Action Alternative would represent a continuing potential for impacts to surface
water and soil quality with respect to potential accidental releases to surface water and
surface soils. Under the Proposed Action, the DOJ COPS Office has assumed that
accidental releases to surface water or surface soils resulting from hazardous waste
management activities would be remediated by personnel conducting the activities.
However, under the No Action Alternative, in the event of an accidental release (e.g.,
resulting from a container failure) resulting soil or surface water would not be remediated
in a timely manner and would represent a continuing impact to surface water and soils.
8.2.3 Human Health and Safety
Under the No Action Alternative, no grant-funded activities would be conducted. This
would involve a reduction in the availability of regular and overtime personnel, law
enforcement systems and equipment (surveillance equipment, computers, etc.) safety
equipment (personal protective equipment, on-site environmental monitoring equipment,
etc.) and a reduction in the availability of qualified law enforcement personnel health
and safety training. This could potentially increase the likelihood of occupational
exposure to law enforcement personnel and the public to chemical and physical hazards.
Grant funding for law enforcement equipment has been requested by state and local
methamphetamine initiatives in response to specific law enforcement needs of their
initiatives. For example, initiatives in Mississippi and Utah requested funding for off
road vehicles and safety equipment trailers to enable law enforcement officers to travel
to and seize clandestine drug laboratories that are frequently located in remote areas of their

states. Such state/local initiative-specific needs would not be met under the No Action
Alternative.
Continued operation of clandestine drug laboratories that are not identified and seized as
a result of resource constraints would represent a continued health and safety hazard to
the public. Reduced availability of equipment for on site monitoring of environmental and
physical hazards for non-grant funded clandestine drug laboratory seizure operations
could result in potential occupational exposure of law enforcement personnel. Grant
funding for specific environmental monitoring equipment have been requested by state
and local methamphetamine initiatives in response to specific hazards identified by those
initiatives. For example, the Oregon and Wisconsin initiatives have identified an increase
in the incidence of explosive devices found at clandestine drug laboratories, and requested
grant funding for specialized equipment to respond to this identified hazard. Such state/local
initiative-specific needs would not be met under the No Action Alternative.
Reduction in the availability of training also represents a potential impact to health and
safety. Qualified law enforcement personnel would not be permitted to use Air Purifying
Respirators (APR) or Self-contained Breathing Apparatus (SCBA) equipment unless they
receive the training to do so, even if the equipment itself is available, and would not be
able to perform certain activities at clandestine drug laboratory sites without OSHA health
and safety training. Qualified law enforcement personnel also would not become as
familiar with the specific types of chemical and physical hazards that are associated with
clandestine drug laboratories without receiving specialized training. The reduction in the
availability of training under the No Action Alternative would therefore result in a
reduction of the capability of law enforcement personnel to identify and respond to
specific health and safety hazards associated with clandestine drug laboratory sites.
Under the No Action Alternative, drugs, drug precursors, and/or hazardous waste may
remain in place at clandestine drug laboratory locations for an unspecified period of time.
This would present a relatively high potential for human health exposure and safety issues
for residents of the property and adjacent properties. Collocation of incompatible
hazardous waste at the site may result in ignition, and could result in a building fire and in
ignition or explosion of other hazardous waste containers in the unit. Residents of the property,
residents of adjacent properties, and emergency responders could be exposed to air pollutants
resulting from combustion of the hazardous wastes and hazards associated
with exploding containers. Building fires fed by flammable hazardous wastes such as
acetone or toluene could rapidly become uncontrolled and result in extensive damage to
the building and potentially result in the injury or death of the building occupants if the
fire becomes uncontrolled.
Potential impacts from drugs, drug precursors, and improperly stored hazardous waste
also include potential human health impacts from exposure to corrosive, toxic, or reactive
materials and potential safety impacts from fire or explosion. The DOJ COPS Office
anticipates that containers remaining on site may not have identifying labels and may not
be secured, and therefore individuals may be unaware of the hazards associated with the
wastes. Persons may attempt to remove hazardous wastes or contaminated apparatus from

the location for various reasons (e.g., in order to prepare the location to be reoccupied.)
These persons may not have proper training and personnel protective equipment, and may
breach a container or otherwise be exposed to hazards. Direct exposure of an individual
to hazardous wastes in quantities anticipated to remain on site could result in severe
injury or death. Also, if the property is left unsecured, improperly stored hazardous
wastes, drugs, or drug precursors could result in child endangerment, as these materials
would be potentially accessible and attractive to children residing at the property or in
the vicinity.
If flammable hazardous waste inside a clandestine drug laboratory building caught fire,
the building would be engulfed in flames and smoke. Other hazardous wastes present in
the building could further promote the reactivity and intensity of the fire. The damage to
the property would depend most importantly on the construction materials of the building
(wood/concrete). Other factors include the fire load in the building, the rapidness of
response and the ventilation condition, and the fire fighting techniques employed.
Assuming a modern concrete multi-unit residential property, a response time of several
minutes, and a modest degree of fire load, the fire would engulf the apartment and
seriously threaten apartments on same floor and apartments below and above the fire
floor. There could be fatalities/injuries for residents of adjacent apartments. The entire
apartment building and perhaps nearby areas would probably need to be evacuated
because of smoke and fire. There would be extensive smoke and water damage so that
residents would not return to the property until such damage was repaired.
8.2.4 Social Effects
Under the No Action Alternative fewer clandestine drug laboratory seizures would be
conducted. The social effects of a reduction in clandestine drug laboratory seizures
include continued operation of laboratories that are not seized, and production and
distribution of controlled substances from such laboratories. This has the potential to
preclude the productive reuse of the property, resulting in economic impacts and potential
temporary or permanent displacement of persons living at or in the vicinity of the
clandestine drug laboratory. Also, there is the potential for diversion of drugs, drug
precursors, other raw materials, and apparatus from clandestine drug laboratory locations
under the No Action Alternative because such materials would not be removed or secured
at other locations under the No Action Alternative.
9.0 Potential Impacts to Children
In accordance with Executive Order 13045, Protection of Children From Environmental
Health Risks and Safety Risks, the DOJ COPS Office evaluated the projected effects of the
Proposed Action and the No Action Alternative. The DOJ COPS Office determined that
the DOJ COPS Office Methamphetamine Initiative does not create disproportionate
impacts to children, but that the No Action Alternative has the potential to create
disproportionate environmental health risks or safety risks to children.
Potential releases of hazardous wastes to air could potentially result from an accident
during conduct of a grant-funded activity, including removal, transportation, or storage of

hazardous waste. However, in the event of a release to air, the level of exposure to the
released hazardous wastes via inhalation is anticipated to be greater for children than for
adults because children have higher inhalation rates per unit body weight than adults.
Thus, for the ammonia release scenario for the DOJ COPS Office Methamphetamine
Initiative described in Section 8.1.1, children would show symptoms of respiratory
irritation at lower exposure concentrations and at greater distances from the point of
release than would adults. However, ERPG-2 levels specific to children are not available.
Therefore, no quantitative analyses specific to children are included in the Environmental
Assessment related to accidental release exposure. The DOJ COPS Office does not
anticipate any disproportionate impacts to children with respect to the number of
potentially exposed individuals because children are no more or less likely to be situated
in the vicinity of an accidental release location than are adults. The DOJ COPS Office
considers accidental releases related to grant-funded activities to be unlikely, and children
would not be disproportionately subjected to the incidence of such releases, as compared to adults.
The more significant potential for disproportionate impacts to children is from the No
Action Alternative. For the No Action Alternative, it is assumed that the loss of funding
for the DOJ COPS Office Methamphetamine Initiative would result in a reduction in the
effectiveness of state and local law enforcement activities related to methamphetamine
initiatives. Under the No Action Alternative, law enforcement activities and equipment
purchases proposed for grant funding would not be funded and state and local law
enforcement agencies would either forgo such activities and purchases, or would redirect
funding for such activities and purchases from other areas of their state and local
methamphetamine initiative budgets. The DOJ COPS Office cannot predict whether,
where, or to what extent, a reduction in the number of clandestine drug laboratories
seizures would occur under the No Action Alternative. However, in the event that
reductions in clandestine drug laboratory seizures do occur as a result of implementation
of the No Action Alternative, there could be disproportionate human health and safety
impacts to children.
DEA has collected data concerning exposure of children at clandestine drug laboratory
locations. The number of children present at seized clandestine drug laboratory sites
increased from 950 in 1999 to 2,028 in 2001, according to the DEA EPIC National
Clandestine Drug Laboratory Seizure System. In 2001 approximately 700 (35 percent) of
the 2,028 children tested positive for toxic levels of chemicals in their bodies. The
states reporting the highest number of children present at clandestine drug laboratory
sites in 2001 were California (503), Washington (326), Oregon (241), and Missouri (161),
all states that receive a significant amount of earmarked grant funding under the DOJ COPS
Office Methamphetamine Initiative. These figures are recognized as underreported
because many states do not keep records on children present or medically evaluate them
for the presence of drugs or chemicals.58
58 National Drug Intelligence Center Information Bulletin: Children at Risk, July 2002, Document ID 2002L0424-001
Clandestine methamphetamine drug laboratories are characterized by production of drugs

using hazardous chemicals, which may be used and stored in the food preparation areas or
other areas that are accessible to children. The methamphetamine cooking process itself
represents a health and safety hazard, and waste hazardous chemicals may be disposed of
in sinks, bathtubs, toilets, or outdoor areas.59, 60 Unattended drugs, cooking apparatus,
or hazardous chemicals used in drug production, or contaminated air, soil, or water
resulting from illicit disposal or release of hazardous wastes associated with drug
production, would all represent potential exposure pathways that could disproportionately affect children.
The potential for exposure to children is significantly greater than for adults for the No
Action Alternative. In the event that fewer seizures of clandestine drug laboratories occur,
some clandestine drug laboratories in which children are situated may not be discovered, and
the number of children potentially exposed in such locations and the duration of such exposure
could increase. Children situated in a clandestine drug laboratory location would have less
judgment in keeping away from unattended drugs, cooking apparatus, and toxic, corrosive, and
flammable hazardous wastes than would adults, and may in fact, consider containers and apparatus
to be playthings rather than dangerous articles. Therefore, there is a greater potential for a
child to become exposed to hazardous waste of drugs (e.g., by contacting or breaching a container)
or potentially to start a fire than for an adult. The potential for and level of exposure through
ingestion pathways would be greater for children because children have a higher hand to mouth
contact than adults and are more likely to contact contaminated surfaces such as carpets, floors,
and soil.
Once exposed, children may be more vulnerable than adults to drugs or toxic or corrosive
wastes because of differences in absorption, excretion, and metabolism rates between
children and adults. Both the acute and chronic effects of exposure would be greater for
children than for adults, because a childs neurological, immunological, digestive, and
other bodily systems are still developing. Also, children have a higher surface area to
body weight ratio than adults so exposure through the body from liquids or gases could be
more intense for children (e.g., seizures, nausea, irritation, burns).61 A level of exposure
to a toxic or corrosive waste that would cause injury to an adult could be fatal to a child.
For example, exposure to relatively small amounts of iodine, on the order of 200 milligrams,
has been associated with fatalities in children.62 Thus, the No Action
Alternative could result in disproportionate impacts to children.
59 Minnesota Department of Health, General Cleanup Guidelines for Clandestine Drug Laboratories, October 2002.
60 Minnesota Pollution Control Agency, Environmental Problems Associated with Clandestine
Drug Operations, September 2000.
61 Ferguson, Dr. Thomas J., No Date. Overview of Medical Toxicology and Potential
for Exposures to Clandestine Drug Laboratories in California: University of California,
Davis Department of Internal Medicine, reprinted in Minnesota Department of Health
publication Response to Clandestine Drug Labs, 2002. http://www.health.state.mn.us
62 Chesley, Dr. Michelle R., 1999. Methamphetamines: An Epidemic of Clandestine Labs
and Health Risk. Howard University Hospital, Department of Emergency Medicine, Washington D.C.,
September 28, 1999.
In addition, several states use grant funding to support Drug Endangered Children
programs. These programs focus on identifying and protecting children that are exposed
to hazards associated with methamphetamine laboratories. Some programs, like the City

of Phoenix, Arizona, work closely with local, state, federal, and private organizations.
Programs aim to develop protocols for handling drug-endangered children and to train law
enforcement agents, prosecutors and social workers. Grant-funded activities also may
include medical screening of children for toxicity and malnourishment, emergency and
long-term foster care, and psychological treatment. Under the No Action Alternative,
these programs would not receive grant funding and would not be maintained or would be
limited in their ability to protect children from the hazards of illegal manufacture of
methamphetamine. In some cases, state or local agencies that do not yet have Drug
Endangered Children programs would not be able to apply for funding to establish such
programs. Thus, disproportionate impacts to health and safety of children are anticipated
under the No Action Alternative.
10.0
Energy Impacts and Irreversible and Irretrievable Commitment of
Resources
The DOJ COPS Office Methamphetamine Initiative would involve irreversible and
irretrievable commitment of resources related to the purchase and deployment of grant-
funded law enforcement equipment and also related packaging, transportation, and storage
of the hazardous wastes generated from grant-funded removal actions. Resource
commitments under the DOJ COPS Office Methamphetamine Initiative include personal
protective equipment and packaging materials used by hazardous waste management
personnel. These materials would become contaminated by hazardous waste during use
and would therefore need to be disposed as hazardous waste. Other consumable materials
(e.g., office supplies) would also be purchased, used, and disposed under the DOJ COPS
Office Methamphetamine Initiative. Energy resources, including gasoline, diesel fuel,
natural gas, and electricity, would be consumed in operating vehicles used in conducting
grant-funded law enforcement activities and hazardous waste transportation, and in
heating, cooling, and ventilating storage locations. The overall level of funding of the
DOJ COPS Office Methamphetamine Initiative varies from year to year, however since
1998 approximately $223 million in earmarked and discretionary funding has been
provided to state and local law enforcement agencies under the DOJ COPS Office
Methamphetamine Initiative. Such resources would continue to be committed under the
DOJ COPS Office Methamphetamine Initiative. DOJ COPS Office Methamphetamine
Initiative funding may represent a significant percentage of overall funding for
methamphetamine initiatives for certain state and local law enforcement agencies.
Participating state and local agencies may need to commit additional resources in
establishing storage locations for hazardous waste recovered from grant-funded removal
actions, depending upon whether the agencies choose to manage the recovered hazardous
waste themselves. These resources would include the hazardous waste storage units
themselves, associated fixtures, and the indoor building floor space or outdoor paved area
space for the storage units, which would subsequently be unavailable for other uses. In
some cases, grantees would construct new buildings for storage units. However, any new
construction would be subject to site-specific NEPA analysis. The DOJ COPS Office
anticipates that given the relatively small amount of hazardous waste anticipated to be

stored in most storage units, the resource commitment of facility space for the storage
units would not represent a significant commitment of government property. Under the
No Action Alternative, no grant-funded activities would be conducted. Therefore, no
grant-funded resources would be consumed under the No Action Alternative.
Recycling of hazardous materials recovered from clandestine drug laboratories has been
considered. Although recycling may be beneficial from an environmental perspective,
recycling has not been implemented because of law enforcement considerations and
associated risks and costs that override the potential environmental and economic benefits
of recycling. The DOJ COPS Office anticipates that under the DOJ COPS Office
Methamphetamine Initiative, state and local law enforcement agencies conducting grant-
funded removal actions would also not recycle recovered materials.
Therefore, the DOJ COPS Office anticipates that grantees would continue the current
practice of direct disposal of hazardous materials discovered at clandestine drug
laboratories at hazardous waste treatment and disposal facilities and would not implement
a recycling program for recovered hazardous materials, except for recognized methods
such as fuel blending that constitute both recycling and waste disposal methods.
11.0 Environmental Justice
The DOJ COPS Office evaluated the environmental effects of the Proposed Action in
accordance with Executive Order 12898, Federal Actions to Address Environmental
Justice in Minority Populations and Low Income Populations. Environmental justice
issues would be raised if there were disproportionate and high and adverse impacts on
minority or low-income populations. The DOJ COPS Office does not anticipate that there
would be any disproportionate and high and adverse impacts associated with the DOJ
COPS Office Methamphetamine Initiative. The DOJ COPS Office determined that there
could be disproportionate and high and adverse impacts associated with the No Action
Alternative.
DEA contractors conducted approximately 7,255 hazardous waste removal actions at
clandestine drug laboratory locations in fiscal year 2002.63 DEA does not have detailed
demographic information concerning each clandestine drug laboratory location where
removal actions have been conducted. However, based on the DEAs general experience
in identifying and seizing clandestine drug laboratories, the DEA anticipates that many
clandestine drug laboratories would be identified in areas of economically disadvantaged
populations or minority and ethnic group populations. The DOJ COPS Office anticipates
that clandestine drug laboratories seized through grant-funded activities may also occur
in areas of economically disadvantaged populations or minority and ethnic group
populations, although detailed demographic information is not available for grant-funded
activities conducted under the DOJ COPS Office Methamphetamine Initiative. The DOJ
COPS Office therefore anticipates that an increase in state and local law enforcement
activities may result in environmental benefits to economically disadvantaged
populations. However, the DOJ COPS Office can neither quantitatively determine the

demographics of the locations of prior grant-funded clandestine drug laboratory seizures
nor predict the locations of future grant-funded seizures.
63 DEA El Paso Information Center, 2002.
The DOJ COPS Office does not anticipate that the environmental consequences of the
DOJ COPS Office Methamphetamine Initiative would result in high and adverse impacts
to minority or low-income populations regarding the transportation of hazardous waste.
The DOJ COPS Office cannot predict the transportation routes that would be used in
transporting recovered hazardous waste from removal action locations to hazardous waste
storage unit locations. The DOJ COPS Office also does not have demographic
information concerning the personnel participating in the grant-funded activities, and
cannot predict the future participation of personnel in grant-funded activities. However,
the DOJ COPS Office does not anticipate that storage units would be disproportionately
located in minority or low income areas, or that the personnel participating in grant-
funded activities would disproportionately be members of low-income or minority groups.
Under the No Action Alternative, the DOJ COPS Office anticipates a potential reduction
in the effectiveness of law enforcement activities related to methamphetamine, and
anticipates that the number of clandestine drug laboratory seizures conducted by law
enforcement agencies would decrease as a result of a decrease in the amount of funding
available to such agencies. Clandestine drug laboratories may be disproportionately
located in areas of minority or low-income populations, and therefore may
disproportionately affect economically disadvantaged persons or persons of minority
groups or ethnic groups. Affected individuals may include the occupants of the
clandestine drug laboratories themselves (including children), maintenance workers in
multi-unit residential properties that may encounter such laboratories or become exposed
to hazardous waste releases from such laboratories, and neighboring residents of
clandestine drug laboratory properties that are located in low-income, minority and ethnic
group population areas. Any reduction in the number of clandestine drug laboratories
seized would increase the potential for health and safety impacts from the operation of
such laboratories. Distribution of methamphetamine from such clandestine drug
laboratories may also disproportionately affect economically disadvantaged persons or
persons of minority groups or ethnic groups.
12.0 Energy Impacts
Under the DOJ COPS Office Methamphetamine Initiative, minor amounts of energy in the
form of gasoline, natural gas, diesel fuel, and other fossil fuels, would be consumed in
conducting grant-funded activities, conducting grant-funded removal actions, and
transporting hazardous wastes recovered to storage units. Minor amounts of energy,
primarily in the form of electricity and natural gas, would be expended in heating,
ventilating, and cooling the storage unit locations under the DOJ COPS Office
Methamphetamine Initiative. The DOJ COPS Office does not anticipate that the location
of storage units at existing government buildings would have a significant effect on
energy consumption for those buildings. In addition, DEA contractors utilize fuel
blending energy recovery as one disposal option for recovered hazardous wastes, where

hazardous wastes with high fuel value (e.g., toluene, acetone) are used to augment the
heating value of other wastes burned for energy recovery. Hazardous wastes recovered
from removal actions may also be subjected to fuel blending. Therefore, depending upon
the specific hazardous wastes recovered, the DOJ COPS Office Methamphetamine
Initiative may have an energy benefit. There would be no energy expenditure or energy
benefit for the No Action Alternative, as no grant-funded activities would be conducted.
13.0 Coastal Zone Management Act and Coastal Barrier Resources
Some clandestine drug laboratories may be located within a States approved coastal zone
management area. However, the Coastal Zone Management Acts requirements related to
consistency determinations do not apply to the Proposed Action, because the Proposed
Action does not involve any land use planning activity. In the event that a clandestine
drug laboratory is identified and seized within a designated coastal zone management area
as a result of grant-funded activities, the potential for environmental impacts to such
area would be reduced as a result of cessation of the illegal operation and removal of
illegally stored hazardous wastes under the DOJ COPS Office Methamphetamine Initiative.
Accidental releases of hazardous wastes to surface water could occur in the conduct of
grant-funded activities under the DOJ COPS Office Methamphetamine Initiative,
including the removal, transportation, and storage of hazardous wastes. Any releases to
surface water could result in exceedance of water quality criteria, as discussed in Section
8.1.2 and Appendix L. The DOJ COPS Office considers it unlikely that a release of hazardous
waste resulting from a removal action or transportation accident would occur in
the vicinity of or would affect a coastal zone management area. The DOJ COPS Office
does not anticipate that under the Proposed Action hazardous waste would be stored in the
vicinity of a coastal zone management area, however it is possible that storage in the
vicinity of such area could occur under the Proposed Action.
Any accidental releases to surface water that occur in the conduct of grant-funded
activities would be subject to emergency response, and the agency conducting the activity
would be responsible for remediating any environmental contamination resulting from the
release. Personnel conducting hazardous waste management activities would be trained to
conduct such activities safely and would be trained to respond to release incidents.
Storage unit containment systems would further reduce the potential for and consequences
of releases to surface water from the Proposed Action.
Benefits and potential impacts to coastal barrier resources under the DOJ COPS Office
Methamphetamine Initiative are similar to those for coastal zone management areas,
described above. The No Action Alternative would not result in a reduction of potential
impacts to coastal zone management areas, and would not result in any benefits to coastal
zone management areas, as no grant-funded activities would be conducted under the No
Action Alternative.
14.0 Historic Preservation
Based on DEAs experience, clandestine drug laboratory sites are rarely if ever found in

properties listed on the National Register of Historic Places or in properties that are
eligible for such listing. The DOJ COPS Office anticipates that clandestine drug
laboratories identified and seized as a result of grant-funded activities would also rarely,
if ever, be located in National Register listed or eligible properties. It is possible that
a clandestine drug laboratory may be located in an older residential structure eligible for
listing, however, it would be infeasible for law enforcement officials to determine the
eligibility status of a property prior to conduct of law enforcement actions or removal
actions. Removal actions do not generally result in significant property damage, although
subsequent remediation of residual environmental contamination may do so. However, under
the Proposed Action, the DOJ COPS Office and other law enforcement agencies are not
responsible for remediation of the clandestine drug laboratory property, and historic
preservation issues associated with remediation activities therefore would not be considered
part of the Proposed Action.
15.0 Wild and Scenic Rivers
Clandestine drug laboratories could be located in the vicinity of a river that is included
in the Wild and Scenic Rivers System or that is designated for potential addition to the
system. In the event that a clandestine drug laboratory is identified and seized in the
vicinity of a designated Wild and Scenic River or river designated for potential addition
as a result of grant-funded activities, the potential for environmental impacts to such
area would be reduced as a result of cessation of the illegal operation and removal of
illegally and improperly stored hazardous wastes.
The DOJ COPS Office does not anticipate environmental consequences to wild and scenic
rivers as a result of the normal conduct of grant-funded activities. The DOJ COPS Office
anticipates that releases of hazardous wastes to air, water, or soil as a result of the
normal conduct of removal actions, transportation, and storage of hazardous wastes would
be minimal and would not affect any wild and scenic rivers in the vicinity of which such
activities were conducted. The DOJ COPS Office also does not anticipate that the normal
conduct of other grant-funded activities would affect any wild and scenic rivers.
Accidental releases of hazardous wastes to surface water could occur in the conduct of
grant-funded activities under the DOJ COPS Office Methamphetamine Initiative. Such
releases to surface water could result in exceedance of water quality criteria, as discussed
in Section 8.1.2 and Appendix L. The DOJ COPS Office considers it unlikely that a release of
hazardous waste resulting from a removal action or transportation accident
would occur in the vicinity of or would affect a wild and scenic river. However, it is
possible that such an incident could occur. The DOJ COPS Office does not anticipate that
under the Proposed Action hazardous waste would be stored in the vicinity of a wild and
scenic river, however it is possible that storage in the vicinity of such area could occur
under the Proposed Action.
Any accidental releases to surface water that occur in the conduct of grant-funded
activities, including conduct of removal actions, transportation, or storage of hazardous
waste, would be subject to emergency response, and the agency conducting the activity

would be responsible for remediating any environmental contamination resulting from the
release. This would reduce the potential for and consequences of releases to surface water
from the Proposed Action.
The No Action Alternative would not result in a reduction of potential impacts to wild and
scenic rivers, and would not result in any benefits to wild and scenic rivers, as no grant-funded
activities would be conducted under the No Action Alternative.
16.0 Threatened and Endangered Species
Clandestine drug laboratories could be located in the vicinity of threatened or endangered
species habitat. However, it would be infeasible for law enforcement officials to
determine the status of a property prior to conduct of law enforcement actions or removal
actions. In the event that a clandestine drug laboratory is identified and seized in the
vicinity of a threatened or endangered species habitat as a result of grant-funded activities
under the DOJ COPS Office Methamphetamine Initiative, the potential for environmental impacts
to such area would be reduced as a result of the cessation of the illegal operation and removal
of illegally stored hazardous wastes. Operation of clandestine drug laboratories in rural
settings has been found to have environmental impacts to habitat in the vicinity of the operation,
including mortality of trees and other vegetation in the vicinity as a result of fugitive releases
of air pollutants.64
64 Snell, Marilyn B., Welcome to Meth Country. Sierra Magazine, January/February 2001, reprinted
in Minnesota Department of Health publication Response to Clandestine Drug Labs, 2002.
http://www.health.state.mn.us
The DOJ COPS Office does not anticipate environmental consequences to endangered or
threatened species habitat as a result of the normal conduct of grant-funded activities. The
DOJ COPS Office anticipates that releases of hazardous wastes to air, water, or soil as a
result of the normal conduct of removal actions, transportation, and storage of hazardous
wastes would be minimal and would not affect any endangered or threatened species habitat
in which such activities were conducted. The DOJ COPS Office also does not
anticipate that the conduct of other grant-funded activities would affect endangered or
threatened species habitat.
The DOJ COPS Office considers it unlikely that a release of hazardous waste resulting
from a transportation accident could occur in the vicinity of endangered or threatened
species habitat. The DOJ COPS Office also does not anticipate that any storage units
would be located in the vicinity of threatened or endangered species habitat, and therefore
impacts to such areas are considered to be unlikely. However, it is possible that hazardous
wastes could be removed, transported, or stored in the vicinity of such habitat under the
Proposed Action.
In the event that an accidental release occurs in conducting a grant-funded activity, habitat
in the vicinity of the release location could be affected. Hazardous waste releases

resulting from grant-funded activities could result in environmental concentrations that
could affect biota. Accidental releases that occur in the conduct of grant-funded activities
would be subject to emergency response, and the agency conducting the activity would be
responsible for remediating any environmental contamination resulting from the release. This
would reduce the potential for and consequences of releases from the Proposed Action.
The No Action Alternative would not result in a reduction of potential impacts to
threatened or endangered species habitat, and would not result in any benefit to threatened or
endangered species habitat, as no grant-funded activities would be conducted under the No Action
Alternative.
17.0 Floodplain Management and Protection of Wetlands
The Proposed Action would not result in any conversion of floodplains or wetlands.
However clandestine drug laboratories for which grant-funded seizures and removal
actions are conducted could be located in the vicinity of floodplains or wetlands. In the
event that a clandestine drug laboratory is identified and seized in the vicinity of a
floodplain or wetland, the potential for environmental impacts to such area would be
reduced as a result of cessation of the illegal operation and removal of illegal and
improperly stored hazardous wastes under the DOJ COPS Office Methamphetamine
Initiative.
The DOJ COPS Office does not anticipate environmental consequences to floodplains or
wetlands as a result of the normal conduct of grant-funded activities. The DOJ COPS
Office anticipates that releases of hazardous wastes to surface water as a result of the
normal conduct of removal actions, transportation, and storage of hazardous wastes would
be minimal and would not affect any floodplains or wetlands in the vicinity of which such
activities were conducted. The DOJ COPS Office also does not anticipate that the normal
conduct of other grant-funded activities would affect any floodplains or wetlands.
The DOJ COPS Office considers it unlikely that a release of hazardous waste resulting
from a transportation accident could occur in the vicinity of wetland or floodplain. The
DOJ COPS Office also does not anticipate that any storage units would be located in the
vicinity of a wetland, and therefore the DOJ COPS Office considers it unlikely that
impacts to such areas would occur as a result of the Proposed Action. However, it is
possible that hazardous wastes could be removed, transported, or stored in the vicinity of a
wetland or floodplain under the Proposed Action. The DOJ COPS Office does not
anticipate that any storage units would be located in floodplains, and therefore the DOJ
COPS Office does not expect that hazardous wastes would be released as a result of a
flood.
In the event that an accidental release occurs in conducting a grant-funded activity,
wetlands and floodplains in the vicinity of the release location could be affected.
Hazardous waste releases resulting from grant-funded activities could result in

environmental concentrations that could affect biota, and releases to surface water and soil
could result in exceedance of water quality or soil quality criteria. Any accidental releases
to air, surface water, or soil that occur in the conduct of grant-funded activities would be
subject to emergency response, and the agency conducting the activity would be responsible for
remediating any environmental contamination resulting from the release. This would reduce the
potential for and consequences of releases from the Proposed Action.
The USGS model used to estimate water quality impacts that would result from accidental
releases to surface water is based on dispersion of the release into a flowing stream or
river, rather than a relatively static wetland. Therefore the peak concentrations and
durations shown in Appendix L may not be representative of impacts to wetlands. Release
of hazardous waste to wetlands would potentially have a higher impact than the same
amount of hazardous waste released to a stream or river, because the rate of dispersion of
the release would be greater in a flowing stream or river than in a wetland.
The No Action Alternative would not result in a reduction of potential impacts to wetlands
or result in any benefits to wetlands, as no grant-funded activities would be conducted
under the No Action Alternative.
18.0 Farmland Protection
The Proposed Action would not result in any conversion of farmland. It is possible that a
clandestine drug laboratory would be found on a farm. DEA data from 2000, 2001, and
2002 (to date) indicate that approximately 12,000 of 29,000 clandestine drug laboratory
removal actions were conducted in rural areas, and the DOJ COPS Office anticipates that
clandestine drug laboratories identified as a result of grant-funded activities would also
be located in large part in rural areas. However, the DOJ COPS Office does not anticipate
that grant-funded activities would result in the conversion of farmland, although
subsequent remediation of residual environmental contamination may do so. However,
under the Proposed Action, the DOJ COPS Office and other law enforcement agencies are
not responsible for remediation, and farmland conversion issues associated with
remediation activities therefore would not be considered part of the Proposed Action.
19.0 Cumulative Impacts
Cumulative impacts are impacts of other actions that may be associated and contribute to
the environmental consequences of the Proposed Action. Environmental consequences of
the Proposed Action would be distributed among several thousand individual clandestine
drug laboratory locations for which removal actions are conducted. The DOJ COPS
Offices experience in implementing the DOJ COPS Office Methamphetamine Initiative is
that the locations of clandestine drug laboratories are widely dispersed geographically,
and law enforcement activities and associated removal actions associated with a specific
clandestine drug laboratory location is not anticipated to affect other clandestine drug
laboratory locations. The DOJ COPS Office is not aware of any other foreseeable actions
on the part of the DOJ COPS Office that would affect the implementation of or the
environmental consequences of the DOJ COPS Office Methamphetamine Initiative,

therefore the DOJ COPS Office anticipates no cumulative impacts from other actions
implemented by the DOJ COPS Office. In the event that DOJ COPS Office implements
the No Action Alternative (i.e., terminates grant funding) it is possible that some other
federal, state, or local government entity would initiate an Action to provide grant funding
to state and local law enforcement agencies to conduct law enforcement activities and conduct
removal actions. However, the DOJ COPS Office cannot foresee whether or to
what extent any such agencies would propose such Actions.
The DOJ COPS Office assessed the potential effects of foreseeable DOJ COPS Office and
other DOJ programs and foreseeable state programs on the Proposed Action. The DOJ
COPS Office did not identify any other foreseeable DOJ COPS Office or other DOJ
programs that could affect the Proposed Action, and did not identify any programs that
could be affected by the Proposed Action. It is possible that a state or local government
could implement a methamphetamine initiative that could affect the Proposed Action,
however, the DOJ COPS Office cannot foresee the implementation of any such program.
In the event that a state or local government proposed to implement such a program, the
DOJ COPS Office expects that the Agency would become aware of such a proposal
through the Agencys normal relationship with state and local law enforcement agencies.
20.0 List of Preparers
Robert Lanza, Principal Chemical Engineer -- B.S., Chemical Engineering, Cornell
University, 1980; M. Eng., Chemical Engineering, Cornell University, 1982 -- 22 years
environmental consulting experience.
David E. Goldbloom-Helzner, Project Manager -- B.A., Chemistry, School of Arts and
Sciences, Washington University, 1984; B.S., Engineering and Policy, School of
Engineering, Washington University, 1984  16 years environmental consulting
experience.
Audrey Slesinger, Associate  M. Sc. Geology, University of Bristol, England, 2000; B.S.
Geological Sciences, Tufts University, 1998  Three years environmental analysis
experience.
Stefanie Shull, Analyst - B.S., Economics, University of Louisville, 2000 -- Two years
environmental analysis experience.
Iliriana Mushkolaj, Associate - M.S. Environmental Sciences and Policy, University of
Manchester & Central European University, Budapest, Hungary, 1996; M.S. Chemistry,
University of Zagreb, Croatia, 1993; B.S. Chemistry, University of Prishtina, Kosova,
1990 - 5 years of environmental consulting experience.

Appendix A: Earmarked Grants, FY2001 and FY2002
STATE
GRANTEE
RATIONALE
YEAR
AL
Department of Public Safety
Vehicle, communications and evidence collection equipment, promotional supplies, training
2001
AR
Arkansas State Crime Laboratory
Hire three additional chemists
2001
AR
Arkansas State Police
State police training, lab equipment and supplies, training
2001
AR
Arkansas State Crime Laboratory
Vehicle, personnel costs, laboratory supplies, training 2002
AR
Arkansas State Police
Laboratory equipment and supplies, safety equipment and personal protection supplies
2002
AR
University of Arkansas
Training equipment and supplies, computer
2002
AZ
City of Phoenix Police
Vehicle, trailer, personal protection equipment and supplies, surveillance equipment,
cameras, computers, microscopes, training materials, safety equipment
2002
CA
California Department of Justice, Bureau of Narcotic Enforcement
Funding for a continuation of a portion of the comprehensive CALMS program.
2002
CA
Merced Police Department
Software, drug screening and chemical analysis kits, training 2002
HI
State of Hawaii (Narcotics Enforcement Division)
Address methamphetamine diversion, production, distribution, and enforcement efforts.
2001
IA
Iowa Division of Narcotics
Regional Methamphetamine Training Center Audio-visual equipment, camera, computer
equipment, GPS, air monitors, travel, supplies
2002
IA
Governors Office of Drug Control
Anhydrous ammonia tank locks
2002
ID
Idaho State Police Headquarters
Equipment, supplies, instructors and travel for training
2001
IN
Indiana State Police Department
Waste disposal and safety processing vehicles, safety trailers, chemical analysis equipment
and supplies, safety equipment, training
2001
IN
Indiana State Police Department
Processing and disposal vehicles, laboratory equipment and supplies, personal protection
equipment and supplies, training equipment
2002
KS
Kansas Bureau of Investigations
Combat methamphetamine and to train officers in those types of investigations
2001
KS
Kansas Bureau of Investigation
Laboratory supplies and personal protection equipment
2002
KS
Riley County Police Department
Vehicle, communications and surveillance equipment and supplies
2002
KS
Wichita Police Department
Vehicle, hazmat vehicle, supplies and equipment for safety, evidence, surveillance, and
communications
2002
KY
Davies County Sheriff's Department
Assist local enforcement agencies local in combating production and distribution of
methamphetamine.
2001
LA
Ascension Parish Sheriff's Office
Support officer training and outreach programs.
2001
MO
Henry Co. Sheriffs Department
Computer and related equipment and supplies
2002

MO
Mid-Missouri Unified Strike Team and Narcotics Group
City of Boonville - Interagency coordination, technical assistance, personnel costs
2002
MO
Missouri C.O.M.E.T. program
Computer, office and communications equipment, overtime wages.
2002
MO
MSSC Regional Crime Lab
Laboratory equipment and software 2002
MO
NEMO Narcotics Task Force
Surveillance and communications equipment, computer, GPS, safety gear
2002
MO
Newton County Sheriffs Dept. (SWMO Drug Task Force)
Overtime for officers, investigative equipment and supplies, vehicle leases, conference
travel, outreach
2002
MO
North Central Missouri Drug Task Force
Surveillance vehicle and equipment, office security equipment, overtime hours, community
outreach
2002
MO
Pemiscott Sheriffs Office
Web site development
2002
MO
SEMO Drug Task Force (Mississippi County)
Overtime hours for officers, surveillance and safety equipment, training, AC unit,
communications equipment, computers
2002
MO
South Central Drug Task Force
Overtime hours for officers, communications equipment, computers
2002
MO
Southeast Missouri Regional Crime Lab
Partial funding for renovation of a forensics laboratory that processes meth lab evidence,
among others
2002
MO
Wayne County Sheriffs Office
Computer supplies, vehicle insurance and supplies, training materials
2002
MS
Jackson Co. Sheriffs Office
Safety equipment, training
2002
MS
Mississippi Bureau of Narcotics
Vehicles, safety equipment and protective gear, chemical analysis equipment, training
2001
MS
Mississippi Bureau of Narcotics
Inter-agency coordination, collaborative community outreach, database maintenance
2002
MT
Flathead County
Vehicles, surveillance and investigative equipment, chemical analysis and safety
equipment, outreach, training
2002
MT
Montana Division of Criminal Investigations
Research, personnel costs, vehicles, surveillance and safety equipment, forensic equipment
and personnel, community outreach
2002
ND
Minot State University Rural Crime and Justice Center
Community outreach, program development, technical assistance, program evaluation
2002
NV
Nye County Sheriff's Department
Methamphetamine initiative
2001
NV
Sparks Police Department
Vehicle, surveillance equipment, training
2002
OK
Bureau of Investigation
For costs associated with combating the production and distribution of methamphetamine.
2001
OK
City of Oklahoma
Personnel costs, contractor costs, equipment and supplies, outreach
2002
OK
Oklahoma Bureau of Narcotics & Dangerous Drugs Control
Vehicles, responder equipment and supplies, training, safety equipment and supplies
2002
OR
Marion County
Vehicles, surveillance and safety equipment, personnel costs, training
2002
SD
Prairie View Prevention Services
Expand Community Mobilization Project to include prevention.
2001
SD
Prairie View Prevention Services
Training, personnel costs
2002
UT
Iron County Sheriff's Office
Remote methamphetamine detection labs to identify damage caused by disposal of
hazardous materials
2001

UT
Millard County Sheriffs Office
Personnel costs, training and safety equipment, evidence collection supplies, outreach
2002
VA
Virginia Dept. of State Police
Surveillance equipment and supplies.
2001
VA
Virginia Dept. of State Police
Personnel costs, surveillance equipment, training, public outreach
2002
VT
Vermont State Police Department
Multi-jurisdictional task force. Personnel costs, public outreach, training
2001, 2002
WA
Washington Methamphetamine Initiative
Pierce County Alliance Information seminars, criminal justice training center, office
equipment and supplies
2001
WA
Washington Methamphetamine Initiative
Pierce County Alliance Expansion of FY01 funded program
2002
WI
Marathon Co. Sheriffs Office
Regional cooperation, equipment, training, outreach
2002
WI
State Office of Justice
Presentation equipment, public outreach
2002
Appendix B: Discretionary Grants, FY2001 and FY2002
STATE
GRANTEE
RATIONALE
YEAR
AL
Andalusia Police Department
SUV, surveillance and field communications equipment, computer equipment, training
2002
AR
City of Pine Bluff
SUV, surveillance equipment, sampling and testing supplies, training materials
2002
AR
Conway Police Department
Computer equipment and supplies, surveillance and communications equipment, GPS, training
2002
AR
North Little Rock Police Dept.
AV equipment, safety equipment and personal protection supplies, training
2002
AR
Searcy Police Department
GIS software and equipment, computers and related equipment, surveillance camera
2002
AZ
Prescott Police Department
Laboratory equipment and supplies, personal protection supplies, trailer, tanks, portable
waste pool, training
2002
AZ
South Tucson Police Department
Laboratory equipment and supplies, personal protection supplies, trailer, tanks, portable
waste pool, training
2002
AZ
Pinal Co. Sheriffs Department
Utility van, generator, police radio, miscellaneous equipment
2002
CA
Turlock Police Department
Computers and related equipment and supplies, AV equipment
2002
CA
California Bureau of Narcotics
Training of state and local enforcement officers
2001
CA
California Department of Justice
Gas monitor, goggles, training courses
2002
CA
Merced County
Funds provided upon review of request, if warranted.
2001
CO
Logan County Sheriffs Office
Vehicle, chemical monitors, laboratory and personal protection supplies, training
2002
GA
Gainesville Police Department
Vehicle, generator, chemical testing kits, miscellaneous supplies
2002
IA
Waterloo Police Department
Computer and equipment and supplies, surveillance and training equipment, software training
2002
IL
Quincy Police Department
Search probe, communications equipment, camera, software
2002
IN
Terre Haute Police Department
No description provided
2002

KS
Cherokee Sheriffs Office
Trailer, communications and surveillance equipment, personal protection equipment
2002
KS
Saline County Sheriffs Office
Surveillance and personal protection equipment
2002
LA
Tangipahoa Sheriffs Office
Trailer, software, and surveillance, communications and personal protection equipment
2002
LA
St. Tammany Parish Sheriffs Office
Chemical analysis and laboratory equipment and supplies, cameras, surveillance equipment,
generator
2002
MI
Allegan County Sheriffs Office
No description
2002
MN
Blaine Police Department
Evidence supplies, testing kits, protective gear, training
2002
MN
Minneapolis Police Department
Computers, safety equipment and supplies, surveillance equipment, presentation equipment
2002
MO
Howell Co. Sheriffs Department
Computer
2002
MS
Pearl River Sheriffs Office
Communications, surveillance, safety, and personal protection equipment, training
2002
NM
Eddy County Sheriffs Dept.
Air sampling device
2002
NV
Henderson Police Department
AV equipment, training
2002
OR
Coos County Sheriffs Office
Training
2002
OR
Douglas County Sheriffs Office
Surveillance equipment, training
2002
SC
Lexington Police Department
Communications, surveillance, safety, and personal protection equipment and supplies, training
2002
UT
Salt Lake City
Surveillance equipment, ion scanner, training, promotional and instructional materials
2002

Appendix C: Conditions of Grant Award
1. Grantees which have been awarded funding for the procurement of an item in excess of $100,000
and plan to use a noncompetitive procurement process must provide a written sole source justification
to the COPS Office for approval prior to obligating, expending or drawing down grant funds for that item.
2. The funding under this project is for the payment of salaries, overtime, and approved benefits
for sworn law enforcement officers and support personnel; equipment and technology; and training
and/or travel that has been approved by the COPS Office. The allowable costs for which your grant
has been approved are listed on the budget clearance memo, which is included in your award packet.
3. Methamphetamine Initiative grant funds must be used to supplement, and not supplant, local funds
already committed for the grant purpose (hiring, purchases, and/or activities) that would exist in
the absence of this grant. Grantees receiving Federal funds to pay for the salary and benefits of
an employee must use the grant funds to hire a new, additional
employee during the grant period. This newly hired employee may be dedicated to the Methamphetamine
Initiative project or may be used to backfill a locally funded position if the locally funded individual
is deployed to the Methamphetamine Initiative project.
4. Travel costs for transportation, lodging and subsistence, and related items are allowable under
the Methamphetamine Initiative program with prior approval from the COPS Office. Payment for travel
costs incurred directly by the grantee agency will be based on the rates established in the grantees
written travel policy, up to a maximum of the established federal rate for the relevant geographic
area. Grantee agencies that do not have written travel policies will be funded at the established
federal rate for the relevant geographic area. If grantee agencies are requesting Methamphetamine Initiative
funds to pay for the grant related travel costs of other (non-grantee) individuals, those travel costs
will be paid at the established federal rate for the relevant geographic area.
5. The grantee acknowledges its agreement to comply with the assurances and certifications submitted
with the COPS Methamphetamine Initiative grant application.
6. The grantee acknowledges its agreement to comply with the Special Condition certification concerning
potential environmental issues, which they have submitted to the COPS Office prior to the COPS
Methamphetamine Initiative Grant Application. This certification mandates grantee compliance with Federal,
State and local environmental, health and safety laws and regulations applicable to investigation,
closure of clandestine methamphetamine laboratories and the removal and disposal of chemicals, equipment
and wastes resulting from operations of these laboratories.
7. The recipients receiving funding under this grant program acquiesce that as the entity performing
activities associated with  the investigation and cleanup of clandestine methamphetamine laboratories
that the recipient and not the COPS Office is the generator of hazardous chemical waste for the purposes
of this project.
8. In order to assist the COPS Office in the monitoring of the award, your agency will be responsible
for submitting annual program Status Update Reports (SUR) and quarterly Financial Status Reports (FSR).
9. The COPS Office may conduct or sponsor evaluations of the Methamphetamine Initiative program.
The grantee agrees to cooperate with the evaluators to the extent practicable.
10. The grantee agrees to abide by the terms, conditions, and regulations as found in the Methamphetamine
Initiative Grant Owners Manual and the Uniform Administrative Requirements for Grants and Cooperative
Agreements to State and Local Governments, 28 C.F.R. Part 66 (or the Uniform Administrative Requirements
for Grants and Cooperative
Agreements with Institutions of Higher Education, Hospitals and Other Non-profit Organizations, 28 C.F.R.
Part 70 as applicable).
11. For grants of $500,000 or more (or $1,000,000 or more in grants over an 18-month period), the
grantee acknowledges that failure to submit an acceptable Equal Employment Opportunity Plan (if grantee
is required to submit one under 28 C.F.R. 42.302) that is approved by the Office of Justice Programs,
Office of Civil Rights, is a violation of its Assurances and may result in the suspension of the drawdown
of funds. For grants under $500,000 the grantee must submit a completed EEOP Certification form and return
it to the Office of Justice Programs, Office of Civil Rights, within 60 days of the grant award.
12. You may request an extension of the grant award period to receive additional time to implement your
grant program. These extensions do not provide additional funding. Only those grantees that can provide
a reasonable justification for delays will be granted no-cost extensions.
13. The recipient agrees to complete and keep on file, as appropriate, an Immigration and Naturalization
Service Employment Eligibility Verification Form (I-9). This form is to be used by the recipients of
Federal funds to verify that persons are eligible to work in the United States.
14. The recipient will complete and submit to the El Paso Intelligence Center (EPIC) a form 143 for
each clandestine methamphetamine laboratory that is seized and closed during the grant period.
15. Grantees using Methamphetamine Initiative funds to operate an interjurisdictional criminal
intelligence system must comply with the operating principles of 28 C.F.R. Part 23. The grantee
acknowledges that it has completed, signed, and submitted with its grant application the relevant
special conditions certifying its compliance with 28 C.F.R. Part 23.

Appendix D:
Special Condition for Methamphetamine Initiative:
Mitigation of Health, Safety, and Environmental Risks
A. General Requirement: The applicant agrees to comply with Federal, State, and
local environmental, health, and safety laws and regulations applicable to the
investigation and closure of clandestine methamphetamine laboratories and the
removal and the disposal of the chemicals, equipment, and wastes used in or
resulting from the operations of these laboratories.
B. Specific Requirements: The applicant understands and agrees that any program or
initiative involving either the identification, seizure, or closure of clandestine
methamphetamine laboratories, hereafter referred to as the Program, can result
in adverse health, safety, and environmental impacts to (1) the law enforcement
and other governmental personnel involved; (2) any residents, occupants, users,
and neighbors of the site of a seized clandestine laboratory; (3) the seized
laboratory sites immediate and surrounding environment; and (4) the immediate
and surrounding environment of the site(s) where any remaining chemicals,
equipment, and wastes from a seized laboratorys operations are placed or come to
rest.
Therefore, the applicant further agrees that in order to avoid or mitigate the
possible adverse health, safety, and environmental impacts of its Program, it will
(1) include the nine, below listed protective measures or components within its
Program; (2) provide for their adequate funding to include funding, as necessary,
beyond that provided by the grant agreement; and (3) implement these protective
measures throughout the life of the grant agreement. In so doing, the applicant
understands that it may implement these protective measures directly through the
use of its own resources and staff or may secure the qualified services of other
agencies, contractors, or other qualified third parties.
The applicant agrees to include the following protective measures within its
Program:
1. Provide medical screening of personnel assigned or to be assigned by the
applicant to the seizure or closure of clandestine methamphetamine
laboratories;
2. Provide Occupational Safety and Health Administration (OSHA) required
initial and refresher training for law enforcement officials and other
personnel assigned by the applicant to either the seizure or the closure of
clandestine methamphetamine laboratories;
3. As determined by their specific duties, equip personnel assigned to the
Program with OSHA required protective wear and other required safety
equipment;

4. Assign properly trained personnel to prepare a comprehensive
contamination report on each closed laboratory;
5. Employ qualified personnel to remove all chemicals and associated
glassware, equipment, and contaminated materials and wastes from the
site(s) of each seized clandestine laboratory;65
6. Dispose of the chemicals, equipment, and contaminated materials and
wastes removed from the sites of seized laboratories at properly licensed
disposal facilities or, when allowable, properly licensed recycling facilities;
7. Monitor the transport, disposal, and recycling components of
subparagraphs numbered 5. and 6. immediately above in order to ensure
proper compliance;
8. Have in place and implement an inter-agency agreement or other form of
commitment with a responsible state environmental agency that provides
for that agencys (i) timely evaluation of the environmental conditions at
and around the site of a closed clandestine laboratory and (ii) coordination
with the responsible party, property owner, or others to ensure that any
residual contamination is remediated, if necessary, and in accordance with
existing state and federal requirements; and
9. Include among the personnel involved in seizing clandestine
methamphetamine laboratories, or have immediate access to, qualified
personnel who can respond to the potential health needs of any of the
offender(s) children or other children present or living at the seized
laboratory site. Response actions should include, at a minimum and as
necessary, taking children into protective custody, immediately testing
them for methamphetamine toxicity, and arranging for any necessary
follow-up medical tests, examinations, or health care.
C.
Applicants Acknowledgment and Agreement: Applicant acknowledges that it has
received and reviewed the Environmental Assessment, including its appendices,
and the Finding of No Significant Impact that have been prepared for this grant.
65 In order to be considered qualified personnel, an individual must comply with all
Federal, State, and local environmental, health and safety laws and regulations applicable
to the removal of all chemicals and associated glassware, equipment, and contaminated materials
and wastes from a clandestine laboratory, including but not limited to the applicable sections
of: U.S. EPAs Resource Conservation and Recovery Act (RCRA), 40 C.F.R. Part 260, et seq., U.S.
EPAs Comprehensive Environmental Response, Compensation
and Liability Act (CERCLA), 40 C.F.R. Part 300, OSHAs Occupational Safety and Health Act, 29
C.F.R. Part 1910.120 and Part 1200, and U.S. Department of Transportations regulations governing
the labeling and transportation of hazardous materials and hazardous wastes, 49 C.F.R. Part 100,
et seq. and Parts 350-399.

Applicant agrees to abide by the Environmental Assessment, including its
appendices, and the Finding of No Significant Impact throughout the
implementation of its Program. Applicant understands that this environmental
assessment was prepared under the requirements of the National Environmental
Policy Act, 42 U.S.C. 4321 et seq., and that this assessment provides both the basis
for the above listed protective measures as well as references to several statutes,
regulations, and guidelines that are particularly relevant to the implementation of
these measures.
Certification
I certify that I have read the attached special condition and agree to abide by it:
__________________________________
_
Signature of Law Enforcement Executive Date
___________________________________
Typed name of Law Enforcement Executive Typed title of Law Enforcement
Executive
__________________________________
_
Signature of Government Executive Date
___________________________________
Typed name of Government Executive Typed title of Government Executive

Appendix E:
COPS Logo
CERTIFICATION OF CLEANUP OF CLANDESTINE DRUG LABORATORIES
This section explains the requirements for cleanup of a clandestine drug laboratory
discovered while implementing a Methamphetamine grant. It requires you to certify what
cleanup strategy you plan on utilizing. Specifically, it requests certification regarding (1)
the type of training local law enforcement personnel receive; (2) whether DEA contractors, DEA
equivalent contractors or other qualified contractors and/or local personnel will perform the
cleanup and disposal of hazardous chemical waste; and (3) whether vehicles and/or storage units
funded under the grant program will be used to transport and/or store hazardous chemical waste.
The acceptable cleanup strategies are discussed in more detail in the Environmental Assessment,
which you reviewed and agreed to abide by prior to receiving these application materials.
In order to ensure protection of human health and the environment in implementing a
COPS Methamphetamine grant, applicants must agree to the proper training of law
enforcement personnel, the use of qualified contractors and/or local personnel for the
clean up and disposal of hazardous waste, and the adherence to Federal, State and local
regulatory requirements for the cleanup of hazardous chemical waste, including the
transport and storage of such waste.
The training of law enforcement personnel must meet the requirements of the
Occupational Safety and Health Administration (OSHA) regarding hazardous waste
environments (29 CFR Part 1910.120 and part 1200) and the Environmental Protection
Agencys (EPA) Resource Conservation and Recovery Act (RCRA) regulations pertaining
to the generation, storage, transport, and disposal of hazardous wastes (40 CFR Parts
260 et seq.), as well as any State or local requirements.
In addition to ensuring the proper training of law enforcement personnel, the
environmentally sound cleanup of clandestine laboratories is accomplished through the
utilization of qualified contractors or local personnel who perform the duties of a
generator of hazardous waste, as defined by the EPA in its regulations codified at 40
CFR Parts 260, et seq. 66 67
66 The Drug Enforcement Agency (DEA) undertakes cleanup of clandestine drug laboratories
throughout the country by training agents under OSHA standards and by utilizing qualified
contractors under the Hazardous Waste Cleanup and Disposal Contracts (HWCDC). Pending
funding availability, DEAs services are available to all law enforcement agencies engaging
in the cleanup of clandestine laboratories at no cost to the law enforcement agencies. As
with the applicants law enforcement personnel, the qualified contractor
personnel must be trained under the requirements listed above and are responsible for utilizing
permitted treatment, storage and disposal facilities that meet the above listed requirements
67 Although grantees under the COPS Methamphetamine grant must demonstrate how their clandestine
 drug laboratory cleanup program provides for the protection of human health and the environment,
they are not required to either send their personnel specifically to the DEA training program or
to use only DEA disposal contractors. However, if agencies choose not to use these existing DEA
resources, they must demonstrate that they have equivalent training and disposal resources in
place to include contractor oversight plans and procedures, or that the training and disposal
resources in place meet applicable Federal, State and local laws and regulations.

An applicants cleanup of hazardous chemical waste must also comply with EPAs
Comprehensive Environmental Response Compensation and Liability Act (CERCLA) (40
CFR Part 300) and the US Department of Transportations regulations governing the
labeling and transportation of hazardous waste (Parts 49 CFR Part 100, et seq. and Parts
350-399).
Certifications
A. Clandestine Drug Laboratory Cleanup Program  Training of Law
Enforcement Personnel
So that the COPS Office may ensure that your clandestine drug laboratory cleanup program
adequately provides for the protection of human health and the environment in regard to the
training of law enforcement personnel, please certify as to one of the following:
I certify that I will send my law enforcement personnel to the DEA training program pertaining
to the cleanup of clandestine drug laboratories:
Signature of Law Enforcement Executive Date
Typed name of Law Enforcement Executive Typed title of Law Enforcement Executive
Signature of Government Executive Date
Typed name of Government Executive Typed title of Government Executive
I certify that I have DEA-equivalent DEA-equivalent training in place for my law enforcement
personnel regarding the cleanup of clandestine drug laboratories and that it meets the training
requirements set forth in applicable Federal, State and local laws and regulations:
Signature of Law Enforcement Executive Date
Typed name of Law Enforcement Executive Typed title of Law Enforcement Executive
Signature of Government Executive Date
Typed name of Government Executive Typed title of Government Executive

I certify that I have training in place for my law enforcement personnel regarding the cleanup
of clandestine drug laboratories and that it meets the training requirements set forth in
applicable Federal, State and local laws and regulations:
Signature of Law Enforcement Executive Date
Typed name of Law Enforcement Executive Typed title of Law Enforcement Executive
Signature of Government Executive Date
Typed name of Government Executive Typed title of Government Executive
B. Clandestine Drug Laboratory Cleanup Program  Disposal of Hazardous
Waste
So that the COPS Office may ensure that your clandestine drug laboratory cleanup
program adequately provides for the protection of human health and the environment in
regard to the disposal of hazardous waste, please certify as to one of the following:
I certify that I will only utilize DEA disposal contractors for the cleanup and disposal of
hazardous waste associated with clandestine drug laboratories:
Signature of Law Enforcement Executive Date
Typed name of Law Enforcement Executive Typed title of Law Enforcement Executive
Signature of Government Executive Date
Typed name of Government Executive Typed title of Government Executive

I certify that I will be using non-DEA disposal contractors for the cleanup and disposal of
hazardous waste associated with clandestine drug laboratories, and that these contractors are
DEA-equivalent and are DEA-equivalent and meet all necessary qualifications for the cleanup
and disposal of hazardous waste*:
Signature of Law Enforcement Executive Date
Typed name of Law Enforcement Executive Typed title of Law Enforcement Executive
Signature of Government Executive Date
Typed name of Government Executive Typed title of Government Executive
I certify that I will be using non-DEA contractors and/or local government/law enforcement
personnel for the cleanup and disposal of hazardous waste associated with clandestine drug
laboratories, and that the individuals involved in these activities meet all necessary
qualifications for the cleanup and disposal of hazardous waste*:
Signature of Law Enforcement Executive Date
Typed name of Law Enforcement Executive Typed title of Law Enforcement Executive
Signature of Government Executive Date
Typed name of Government Executive Typed title of Government Executive

C. Clandestine Drug Laboratory Cleanup Program  Funding for Vehicle and
Storage Units
So that the COPS Office may ensure that the vehicles and storage containers that are
funded under your clandestine drug laboratory cleanup program adequately provides for the
protection of human health and the environment in regard to the transport and storage of
hazardous chemical waste, please certify as to one of the following:
I certify that funding received under this program for vehicles and/or storage units for the
specific purpose of transporting and/or storing chemical hazardous waste meets the requirements
set forth in applicable Federal, State and local laws and regulations.
Signature of Law Enforcement Executive Date
Typed name of Law Enforcement Executive Typed title of Law Enforcement Executive
Signature of Government Executive Date
Typed name of Government Executive Typed title of Government Executive
I certify that funding received for vehicles and/or storage units under this project were not
awarded for the specific purpose of transporting and/or storing chemical hazardous waste and
will not be used for such activities associated with the cleanup of clandestine laboratories.
Signature of Law Enforcement Executive Date
Typed name of Law Enforcement Executive Typed title of Law Enforcement Executive
Signature of Government Executive Date
Typed name of Government Executive Typed title of Government Executive

Appendix F:
FY 2002 Methamphetamine Initiative
List of Allowable Costs
The following information summarizes categories of allowable and unallowable costs for
funding from COPS under the Methamphetamine Initiative. The budget items must
programmatically link to the activities described in the proposal. While costs may be listed as
allowable, the COPS Office will determine appropriateness of requested funds for the activities
within each proposal. The burden to adequately demonstrate that the item requested is directly
related to the program is placed on the grantee and the COPS Office may delete any unlinked items
without notification.
Although some of the statutory application requirements for COPS grants have been waived
for the COPS Methamphetamine Initiative, the prohibition against supplanting remains in
force. That is, funds provided must be in addition to locally budgeted items, not in lieu of these items.
Personnel
Law Enforcement officers
. Approved overtime incurred after the award start date for existing full-time officers
working directly on this program
Employees other than law enforcement officers (civilian support staff)
. Salaries and benefits of support staff hired after your award start date to work directly on this program;
. Salaries and benefits of support staff hired after your award start date to backfill a
vacancy created when your agency re-deploys an experienced locally funded civilian to
the COPS grant project.
NOTE: When itemizing fringe benefits, FICA combined with Social Security cannot exceed
7.65 percent, and if you are not requesting reimbursement for FICA, Workers Compensation
or Unemployment, please make a note that your agency plans to cover these items, or provide an
explanation for why your agency does not pay them.
Travel
. Reasonable out of town travel costs (lodging, meals, and transportation costs if travel is over
50 miles from program location) in accordance with applicable guidelines to visit
other jurisdictions engaged in similar programs or to attend conferences/training directly
related to the goals of the program.
Technology and Equipment

NOTE: Any expenses under $5,000 per unit should be itemized under Supplies.
. Technology and equipment that is purchased specifically for this program after the award
start date and can be clearly linked to the implementation or enhancement of the program.
The burden is on the grantee to adequately demonstrate this connection. (Some potential
examples may include computerized crime analysis software, mapping software, or
electronic bulletin boards to enhance communication between police and citizens.)
Supplies
. Supplies such as copying, general office items, postage and others if directly related to the program.
Consultants/Contracts
. Consultant/contractor costs if they directly contribute to the implementation or
enhancement of the program (Note: Consulting may not exceed $450 per day without
prior approval by the COPS Office.);
. Consultant or trainer fees only for additional training that supplements, but does not
replace, any current training of new or re-deployed officers, civilians, and/or
community members in areas or topics that relate to the programs goals;
. Supervisory training related to the program; and
. Conference costs related to the program (registration fees, books).
Other Costs
. Performance evaluation development;
. Publications relating to the program and community policing;
. Reasonable and appropriate community incentives (subcontracts, awards, etc.);
. Local evaluation costs;
. Examples of these costs include: small contracts with local colleges and universities, inhouse
research staff costs, and focused technology costs;
. Training development costs directly related to the program;
. Costs related to survey development, administration, and analysis of survey information;
. In-house newsletters;
. Partnership or team building costs including travel, focus group meetings, and other
related activities (note, however, that meals and refreshments for meetings are not
allowed);
. Video production if directly related to the program;
. Costs of community meetings and workshops, including reasonable room rental costs; and
. Internet access fees, on-line research services, etc. if directly related to the program.

Appendix G:
FY 2002 Methamphetamine Initiative
List of Unallowable Costs
**Items will be reviewed on a case-by-case basis, however, agencies are expected to request items
that are linked to the parameters stipulated in the DOJ Appropriation Act, 2002, Public Law 107-77.
In addition, departments must demonstrate that these items have a direct correlation to their
overall Methamphetamine project objectives and that
without said items the project could not be implemented. The COPS Office will review an applicant's
request based on the feasibility and totality of the circumstances surrounding the jurisdiction's
methamphetamine problem. Historically, the item categories that have consistently not been funded
are indirect costs, response-oriented equipment, items that are funded through the local department
budget, and general office supplies.
Personnel:
. Salaries and benefits of existing officers.
. Salaries and benefits of existing employees.
. Salaries and benefits of grant writers or other staff that do not directly contribute to the
implementation of the program.
. Overtime: For personnel not directly involved in the departments project and that
which exceeds 20% of total budget.
. Fringe benefits for overtime of existing employees.
Travel:
. Local travel costs (lodging, meals, per diem, transportation costs, mileage
reimbursement) within a 50-mile radius of the location.
. Parking fees, taxi fare.
. Meals and/or refreshment costs associated with meetings.
Response-Oriented Technology and Equipment:
. Bunker shield(s)
. Standard issue uniforms
. Animals
. Bulletproof vests and accessories
. Bicycles
. Radar guns
. Dictation systems
. Television / VCR(s)
. Phone lines and voice-mail systems (hotlines will be considered)
. Handcuffs, weapons, and ammunition
. Standard office furniture and equipment
. Office rental space, lease (copiers, fax machines, desks, chairs, shredders, etc.)
. Cellular phones
. Construction and Renovation costs
. PDAs and pagers (including service time)
. Police vehicles (patrol cars, mobile police units, surveillance and leased vehicles).
. Standard issue police vehicle equipment (including light bars, cages, and siren
packages)
. Equipment for surveillance vehicles used specifically in the DEC project will be

considered.
Supplies:
. Standard office supplies not directly related to the Methamphetamine Initiative.
. Indirect costs.
Consultants and Contracts:
. Training in topics that are not directly linked to the Methamphetamine Initiative
(DEC).
. Contractual agreements which cannot be directly linked to the Methamphetamine
Initiative.
. Maintenance and/or service contracts that extend the life of the initial grant period;
(multi-year contracts are allowable, but must be paid in full up-front within the one-
year life of the grant).
. Any consultant fees in excess of $450 per day need to receive prior approval from the
COPS Office, contingent upon written justification by the grantee.
Clean-up Costs:
Costs associated with the clean-up of clandestine drug laboratories utilizing contractors
who are not qualified to dispose of hazardous waste and/or where the applicant does not
have DEA-equivalent disposal resources in place to include contractor oversight plans and
procedures.
Note: Please refer to the Environmental Assessment that was provided to your agency
prior to receiving your proposal kit for further explanation of qualified contractors.

Appendix H:
Types of Activities and Associated Equipment Requests
For each activity, the equipment list is provided only as examples, not as a comprehensive
list of all equipment requested by grantees.
-Types
-Activities
-Equipment
Outreach and Office Operations
-Methamphetamine,Database management
-Database used to track arrest data, seizure date, presence of children, precursors, agent
workload, lab type, purity of drug, demographics
-Laptops, Computer upgrade, Multi media computer, Color printer, Software
-General Office Activities
-Presentations
-Interactive video conferencing connection, Projectors (video, presentations), Digital tape
recorder w/ pen microphones, Laser pointer
-Outreach
-Informing the public about dangers of methamphetamine and recognizing clandestine laboratories
-DEC Conference, Paper office supplies, Information booklets, Displays/banners,Projector, Surveys
Training
-Clandestine lab entry certification training
-Recertification of agents
-Safety equipment (see Removal Action), NES Field Guidebook, NIOSH Field Guidebook
-Other training
-Drug Recognition training, First response investigative, Training for school outreach
program, Covert surveillance training, Undercover narcotics training, Meth Enforcement training,
Education-Intervention Program, Drug Symptomology, Hazardous Waste Operations
training, The COPS Methamphetamine Conference
-Working meals (per diem), Laptop computer, Training materials, Students cost to attend school,
Classroom rental, Travel expenses, Printed material, Safety equipment (see Removal Action)
-Chemical analysis training
-Investigation and identification of drugs, drug residue and components used to cut drugs
-High wattage lasers, Ion scanners
Law Enforcement Activities
-Drug diversion investigations
-Precursor theft and investigation of methamphetamine distribution
-Anhydrous ammonia nurse tank locks
-Surveillance of potential clandestine laboratory
-Monitoring of suspects and laboratory
-Infrared light, Bodywire, Portable X-ray, Color pinhole camera, Low light black/white
camera, Zoom binoculars, Ground sensor, High wattage lasers

-Field communications
-Assist communication and coordination of agents during surveillance and single- and
multi-site raids
-Digital transmitter/recorder, Digital receiver, Portable radio with charger units, Radio
encryption and modification systems, Handheld GPS, Microwave video receiver, Digital cell
phone, AC wall outlet audio transmitter, Radio microphone/ head sets, Mobile radio repeater system
-Seizure of suspects
-Protection of law enforcement officers during entry into laboratory
-Tactical jumpsuits, Gas masks, Protective suits, Protective boots, Waterproof boots, Portable eye
wash system, Airpack for assisted breathing, Air monitoring equipment
-Seizure of laboratory equipment
-Sampling of chemicals and drugs found in laboratory
-Respirators, Pipettes and tubes, Vials, Auto Vial insert, Sample bottles, Teflon caps, pH strips,
Drop cloths, Tubs, Evidence testing kits, Supply cases, Sampling supplies, Camper shells, Latent
print lift kits, Canister adapter, MPC canister, Rehab fan, Snap fold modular tent
-Sampling of crime scene
-Sampling of evidence
- Sampling kit, Smoke/fog machine, Pipettes, Glass vials, Fire-proof evidence safe, Nitrile bottles,
pH strips, Cameras/camcorders, Evidence testing kits
Removal Actions
-Safety Equipment
-Protection of agents during entry into clandestine laboratory and exposure to chemicals or hazardous waste
-Tactical jumpsuits, Gas masks, Protective suits, Protective boots, Waterproof boots, Safety glasses,
Gloves, Medical kits, SCBA with mask & harness, SCBA voice amplifier, Airpack for SCBA, Carbon cylinder
for airpack, Portable eye wash system, PAN disruptor
assembly (bomb equipment), Explosion-proof flashlights
-Hazardous waste removal
-Transport of hazardous waste from clandestine laboratory
-Pickup trucks, response vehicles
-Hazardous waste removal action
-Plastic sheets, Buckets, Containers, Duct tape, Decontamination solvents, Rope
Transportation
-Vehicles
-Transport personnel to and from clandestine laboratory location including agents, investigators,
tactical teams, and support personnel
-Command post vehicle, SUVs for Narcotics K9 Team, Personnel decontamination showers and eye wash
station, Lab response vehicle, Rehab/support trailer

-Transport equipment such as radios, field meters, toxic gas detectors, cameras, respirators and
optical equipment, safety equipment
-4WD, all-terrain vehicle, Extended cab pickup, Cargo trailer, Pickup trucks, Safety processing vehicles
-Transport hazardous waste from clandestine laboratory location to storage unit and, in certain cases,
to the disposal site.
-Waste disposal vehicle, Painting and identification markers
Disposal
-Disposal fees
-Hazardous waste disposal or recycling costs
-Pay fees to disposal facility
Other Activities
-Chemical Analysis
-In-house analysis of chemical found at clandestine methamphetamine laboratories
-Gas chromatograph-mass spectrometer system, Ionization Scanners, Lasers with accessories,
Accessory module, Gas tech air monitoring, Drug screening system, Imagers (e.g. digital
thermal imager), Scanning electron microscope
-Laboratory analysis
-Funding for laboratory technicians, Lab renovation and expansion
-Drug Endangered Children Program
-Ion scanners, Medical monitoring
-Personnel
-New personnel hired with grant funding include administrative assistants, intelligence analysts,
dedicated prosecutors, and agents and troopers
-Physical health examinations for officers, Salaries for new personnel, Benefits, Overtime,
-Miscellaneous
-Office security cameras, Security monitoring service, Portable generator, Audio/alarm cellular
transmitter, Fold-up hoist, Photo quality paper, Batteries, Camera film, Mylar film

Appendix I: Selected State Initiative Descriptions
The DOJ COPS Office Methamphetamine Initiative provided discretionary and earmarked grant funding
for methamphetamine initiatives in several dozen states in 2001 and 2002. These descriptions focus
on typical grant funded activities for state and local methamphetamine initiatives as well as unique
aspects of initiatives in California, Hawaii, Missouri, Washington, Iowa, Wisconsin, and Arkansas.
Detailed lists of grant-funded initiatives are included in Appendices A and B.
California
Grant funds have been provided to several California methamphetamine initiatives including the
California Methamphetamine Strategy Program (CALMS). Grant funding is not generally used to fund
hazardous waste removal actions in California. The State Department of Toxic Substances conducts,
and pays for out of general state revenues, approximately 95 percent of the clandestine drug laboratory
hazardous waste removal actions. The Department conducted removal actions at 2208 clandestine drug
laboratory sites in 2002. However, as there is no requirement that state or local law enforcement
authorities use the Departments services some state and local authorities may be conducting their
own removal actions, storage and disposal. At present, no grant funding has been applied to conduct
of hazardous waste removal actions in California. State and local authorities conducting such removal
actions (whether or not such activities are grant funded) are responsible for complying with RCRA
regulations, DOT regulations, California hazardous waste manifest requirements, and the California
Environmental Quality Act (CEQA) requirements. According to the CEQA Coordinator for the California
Methamphetamine Initiative, clandestine drug laboratory law enforcement actions and associated hazardous
waste removal actions are exempt from CEQA because they are emergency actions.
California regulations require all hazardous waste generators, regardless of generator status, to
manifest waste shipments. The State Department of Toxic Substances program for transporting, storing
and disposing of waste is itself subject to CEQA. Storage of hazardous waste at a transfer location
for more than ten days, or any treatment or repackaging of the waste at a transfer location, would
require a state hazardous waste storage facility permit and would trigger CEQA. The State avoids CEQA
by requiring, by contract, their emergency response contractors to store waste for less than the 10-day
limit before transporting the waste to a permitted TSDF. The State Department of Toxic Substances
inspects the emergency response contractor facilities biannually to ensure that regulatory and contract
requirements are being met. State hazardous waste management contractors are required to implement
security requirements (fencing) so that material cannot be diverted. Hazardous waste is stored outdoors
in the emergency response contractors equipment yards (the same place that the contractors emergency
response vehicles and equipment are stored.) There are seven state-contracted emergency response
contractors that service different parts of the state. Response time for hazardous waste removal actions
for clandestine drug laboratory seizures is on the order of two hours.
Hawaii
Grant funds have been provided to the Narcotics Enforcement Division of the State of Hawaii.68 The
funds enable the payment of overtime hours and benefits for sworn and non-sworn law enforcement officers
and civilian personnel, including inspectors, analysts, and computer programmers, and the purchase of
equipment. Grant funding has been used to fund training and medical clearance exams for law enforcement
Personnel on the Clandestine Laboratory Investigations Support Team (CLIST). This training is required
by OSHA regulations for personnel to use APR and SCBA.
68 FY2002 COPS Methamphetamine Initiative, Hawaii Methamphetamine Program Budget Narrative
Grant funding has also been used to pay hazardous waste contractors to conduct hazardous waste removal
actions and associated transportation, storage, and disposal costs. The State of Hawaii initiative has

employed the same hazardous waste management contractor as DEA employs in Hawaii to conduct hazardous
waste removal actions, transportation, storage, and disposal. The contractor has been employed during
multi-agency responses to clandestine drug laboratories throughout the State of Hawaii. Funding for
removal actions has been provided in part by the grant program, and in part through the DEA National
Clandestine Laboratory Cleanup Program.
Missouri
Missouri grant funded initiatives have used grant funds for payment of overtime salaries, purchases
of operating supplies, vehicles, equipment and supplies and to fund hazardous waste disposal fees
and administration fees.69 The MSSC Regional Crime Lab utilized grant funding to purchase two modern
gas chromatographs and a mass spectrometer system for processing of evidence and environmental samples
in a chemical analytical laboratory. The City of Boonville grant funds have been used to provide overt
and covert narcotics assistance to law enforcement agencies. In partnership with MUSTANG (Mid-Missouri
Unified Strike Team and Narcotics Group), the City of Boonville also developed a program to actively
pursue persons procuring and/or stealing the needed precursors for the manufacture of methamphetamine.
69 COPS Methamphetamine Initiative, Report to House and Senate Appropriations Committees,
Methamphetamine Grants Awarded in FY 2002.
There are approximately 12 hazardous waste bunker units located through Missouri for use by state
and local law enforcement agencies for temporary storage of hazardous waste. All but one of these units
are located at fire stations and are manned by Hazmat-trained firefighters. The Missouri Department of
Natural Resources (DNR) acquired the bunker units approximately three years ago in order to improve
response time. DEA contractors were based in Kansas City, Missouri, and in Tulsa, Oklahoma. During the
transit time from their bases to the remote locations of clandestine drug laboratories in Missouri,
state/local law enforcement personnel had to work overtime for 5 hours or more to secure the laboratory.
Siting hazardous waste bunker units throughout the state and training law enforcement officers to
package and transport waste was done to improve response time. Funding from the DOJ COPS Office
Methamphetamine Initiative has been applied to the operation of these bunker units.
The Missouri DNR provides a six to eight hour course to law enforcement officers to bunker certify
them to use these bunker units. Law enforcement officers who are not trained by Missouri DNR are not
authorized to use the bunker units. The law enforcement officers do not have to be lab certified to
use the bunker units. Missouri DNR also provides lab certification training to law enforcement
personnel, and Missouri DNR and the Missouri highway patrol provide lab re-certification program training
to law enforcement personnel. For the approximately 11 manned units, the law enforcement officer calls
ahead to the fire station and is met by a Hazmat trained fireman, who transfers the hazardous waste to the
bunker unit. For the unmanned unit, the law enforcement officer picks up a key for the unit (and for
the surrounding security fence and gate) and transfers the hazardous waste into the unit him/herself.
Officers transporting hazardous wastes are required to segregate containers (flammables, oxidizers,
corrosives) into separate shelves of the storage unit. The storage units are equipped with shelves and
dividers to facilitate waste segregation. There is a log sheet that the officer fills out indicating
that the unit has been used and what hazardous wastes were placed in the unit. The officer also fills
out the EPIC data form that indicates what hazardous wastes were recovered from the laboratory site.
The bunker unit locations are equipped with lab trash barrels that are used to manage contaminated
personal protective equipment (gloves), empty containers, etc. generated through hazardous waste
management activities.
Washington
Grant funds have been to the Washington Methamphetamine Initiative, and allocated by the state to
several agencies, and approximately 52 jurisdictions.70 Enforcement funding has been used for the hiring and

equipping of detectives in 24 counties to handle precursor chemical investigations. One Washington
grantee, under the funds allocated for treatment/family services developed a model treatment program
that deals with dependency issues of abusive parents or parents addicted to methamphetamine. Grants
have been allocated to Washington State Division of Alcohol and Substance Abuse to expand this treatment
program to two other counties in Western and Eastern Washington. Public education programs that increased public
awareness and mobilized local communities to deal with methamphetamine problems were activated in 28 new
counties using grant funding.
70 FY2002 COPS Methamphetamine Initiative, Washington State Methamphetamine Initiative Project Summary
The Washington Department of Health and Department of Ecology (WDOH and WDOE) have been
allocated grant funds to sustain the overtime needed to conduct removal actions and fund the associated
hazardous waste transportation and storage activities and hazardous waste disposal fees. Hazardous waste
disposal is conducted at county-operated moderate risk waste disposal facilities and also at commercial
hazardous waste disposal facilities.71 Grant funds have also been used by the WDOE to purchase a laboratory
response vehicle that is equipped with a covered, isolated cargo space for transporting hazardous waste and
equipped with outside lockers for transport of tools and supplies. Funds allocated to the Lewis County
Sheriffs Department for law enforcement have been expended to provide for the temporary storage of hazardous
(or potentially hazardous) materials recovered by sheriff's deputies in a certified storage facility until
WDOE can remove the materials72.
71 Moderate-risk waste (MRW) is defined in the Washington Hazardous Waste Management Act as household
waste and CESQG waste. Washington County Governments operate a system of MRW
collection facilities throughout the state. These facilities are used to manage
hazardous waste generated from clandestine drug laboratory removal actions. In some
areas of the state where MRW collection facilities are not available, it is necessary
to use commercial disposal facilities for disposal of hazardous wastes.
72 In Lewis County the local law enforcement jurisdiction owns and operates the hazardous waste storage
unit, and WDOE, periodically, using grant-funded disposal fees, picks up the hazardous waste from the
storage unit and transports it to disposal sites. WDOE or local law enforcement agencies may transport
the hazardous waste from the removal action location to the storage location.
Iowa
Grant funding has been provided to three Iowa methamphetamine initiatives.73 Funding awarded to the
Iowa Regional Methamphetamine Training Center supported the Tri-State Regional Methamphetamine
Training Center that targets small rural agencies. Training is focused on Clandestine Lab Enforcement,
Undercover Operations, Warrant Preparation and Service, Tactical Warrant Service, Highway Interdiction,
Police Officer Safety, and Safety Issues for Fire/Rescue personnel. The Governors Office of Drug Control
Policy carried out a program on reducing the availability of anhydrous ammonia by utilizing the entire
award to purchase anhydrous ammonia nurse tank locks. Nurse tanks are used in agriculture to supply
anhydrous ammonia to agricultural fields. The nurse tank lock program is intended to prevent theft of
anhydrous ammonia from the tanks and diversion of the ammonia to methamphetamine production.
73 Report to House and Senate Appropriations Committees, Methamphetamine Grants Awarded in FY 2002.
Wisconsin
Grant funding has been provided to several Wisconsin Methamphetamine Initiative programs.74 The largest
portion of the grant funds awarded to the Wisconsin Division of Narcotic Enforcement (DNE) was used to
purchase specialized chemical analytical equipment. GPS trackers are used for live or historical tracking
of suspect vehicles. Drager Accuro pumps are used for taking air samples at clandestine drug laboratory
sites to test for hydrochloric acid, nitric acid and ammonia. Grant funds have also been used to purchase
and equip two clandestine drug laboratory response trailers. These trailers are used to transport safety
equipment, chemical decontamination supplies, and surveillance equipment to clandestine drug laboratory
sites. Additional grant funds have been used for Clan Lab Certification training of law enforcement

officers, and for public awareness enhancement.
74 FY2002 COPS Methamphetamine Initiative, Wisconsin Methamphetamine Initiative Project Summary and Budget Narrative
Arkansas
The Arkansas State Police recently filed an amendment to its grant application, seeking to reprogram
certain funds.75 The Arkansas Initiative requested funding to equipment to determine whether children
residing at clandestine drug laboratory locations have been exposed to controlled substances to promote
enforcement of a recently proposed child endangerment statute. The Arkansas Initiative has also requested
funding to purchase air purifying respirators (APRs) for use by non-certified investigators who are
first responders and who may assist certified investigators after the clandestine drug laboratory scene
has been evaluated, but while APRs are still required to enter the scene. Although personnel using the
APRs for the purposes of law enforcement would need to be trained in their use, the Arkansas Initiative
has not requested grant funding to
provide such training in their grant revision application.
The Arkansas Initiative has also requested grant funding to establish a centralized pickup site located
at the Arkansas State Crime Laboratory for chemical analytical laboratory wastes generated by laboratory
chemists working at clandestine drug laboratory sites. The laboratory chemists would package the hazardous
wastes and transport the hazardous wastes to the central pickup site as part of their normal job activities,
and DEA contractors would fund the transportation of the hazardous waste from the pickup site to a disposal
site. Therefore grant funding would be applied only to establishing the pickup site, not for construction activities.
Other Grant Funded Initiatives
The Phoenix Arizona Police Department has used grant funding to administer Clandestine Laboratory Site
Safety training to certify law enforcement personnel as OSHA Site Safety Officers, and for law enforcement
officers to attend HAZMAT training administered by the Phoenix Fire Department. The Phoenix Police Department
continues to use DEA contractors to conduct (non grant-funded) hazardous waste removal actions, such as
conduct of removal actions that fall outside the purview of the DEA.76
The Indiana State Police Department and Terre Haute Police Department have applied grant funding to
conduct hazardous waste removal actions and to pay hazardous waste disposal fees. The Indiana Department
uses forensic scientists to manage small amounts of hazardous waste and disposes of the hazardous waste
using a contract service, and uses DEA contractors to manage hazardous wastes recovered from larger
laboratories. Indiana has also applied grant funding to purchase safety processing vehicles and safety
trailers that are used to transport personal protective equipment and other safety equipment to
clandestine drug laboratory sites. A separate grant-funded waste disposal vehicle is used to transport
hazardous waste recovered from clandestine drug laboratory sites. 77 Kansas applied grant funding to
purchase safety equipment trailers, communications and surveillance equipment, personal protective equipment,
chemical analytical laboratory supplies, and vehicles (including a hazmat response vehicle), and training
in the use of personal protective equipment. Utah applied grant funding to support remote
methamphetamine detection laboratories to identify damage caused by disposal of hazardous materials, a
nd purchase all-terrain vehicles and trailers to enable access to remote, off road clandestine drug
laboratory locations.
75 FY2003 Grant Revision  Arkansas State Police Coordinated Methamphetamine Initiative, January 2003.
76 FY2002 COPS Methamphetamine Initiative, Phoenix Police Department Methamphetamine Laboratory Cleanup
Grant Application, Project Summary.
77 FY2002 COPS Methamphetamine Initiative, Indiana Methamphetamine Initiative II Expanded Budget Detail Information.

Appendix J: Health Hazards of Chemicals Used in Methamphetamine Production
Chemical Name
Health Effects
Chemical Incompatibilities
2,5Dimethoxybenzaldehyde
N/A
N/A
Acetic Anhydride
Highly corrosive liquid that can irritate nose, throat, mouth, eyes, and skin. Exposure to high
doses can result in permanent eye damage and lung damage with coughing and/or shortness of breath.
Strong oxidizing agents, strong reducing agents, bases, alcohols, metal powders, moisture.
Acetone/ Ethyl Alcohol
Extremely flammable, posing a fire risk in and around the laboratory. Inhalation or ingestion of
these solvents causes severe gastric irritation, narcosis, or coma.
Strong oxidizing agents, strong acids, perchlorates, aliphatic amines, chromyl chloride,
hexachloromelamine, chromic anhydride, chloroform + alkali, potassium tert-butoxide.
Anhydrous Ammonia
A colorless gas with a pungent, suffocating odor. Inhalation causes edema of the respiratory tract
and asphyxia. Contact with vapors damages eyes and mucous membranes.
Mercury (e.g. in pressure gauges), chlorine, calcium hypochlorite, iodine, bromine, and
hydrogen fluoride
Anthranilic Acid
Yellowish crystal. Dust can irritate skin, eyes, and respiratory tract. Harmful if swallowed.
Strong oxidizing agents.
Butylamine
Flammable liquid and fire hazard. Vapors can irritate nose, throat, eyes, and skin. Higher exposures
can cause pulmonary edema (build-up of fluid in lungs).
Oxidizing agents.
Cyclohexanone
Inhalation can irritate eyes, nose, and throat causing coughing and wheezing. Exposure to high doses
can cause dizziness, and passing out, and cataracts.
Oxidizing agents and nitric acid.
Ephedrine
Skin, eye and respiratory irritant. Chronic use can lead to hypersensitization. High doses can cause
headaches, dizziness, trembling, sweating, irregular heartbeat, nervousness, and paleness.
Strong acids, acid chlorides, acid anhydrides, and strong oxidizing agents.
Ergometrine
Can cause gangrene, headache, abdominal pain, and allergic phenomena (including shock, hypertension,
chest pain, and palpitation.
N/A
Ethyl Acetate
Flammable liquid and fire hazard.
Inhalation irritates nose, throat, skin, and eyes. Exposure to high levels causes dizziness and passing out.
Strong acids, strong oxidizers, and strong bases.
Ethyl Ether
Highly flammable liquid and dangerous fire hazard. When breathed, can cause drowsiness, excitement,
irregular breathing, unconsciousness, and death. High exposure can affect kidneys.
Peroxides, combustible materials, halogens, oxidizing materials, metal salts, acids, bases.
Ethylamine
Highly flammable liquid and dangerous fire hazard. Can irritate eyes, nose, throat, and lungs when
inhaled. Repeated exposure may damage liver, kidneys, and heart.
Strong acids (such as hydrochloric, sulfuric, and nitric) and strong oxidizers (such as chlorine,
bromine, and fluorine).

Formamide
When breathed, can irritate nose and throat and damage male reproductive glands. Contact can cause
eye irritation, burns, and skin rash.
Iodine, pyridine, and sulfur trioxide.
Formic Acid
A corrosive acid that can irritate skin, eyes, and respiratory system, with possible permanent eye
damage. May cause mutations, nausea, headache, and dizziness. Ingestion or inhalation may result in
kidney or liver damage.
Oxidizing agents (such as permanganates and nitrates), strong acids (such as hydrochloric, sulfuric,
and nitric), strong bases (such as sodium hydroxide), and finely powdered metals.
Hydriodic Acid
A corrosive acid with vapors that are irritating to the respiratory system, eyes, and skin. If ingested,
causes severe internal irritation and damage that may cause death.
Metals, oxidizing materials, peroxides, halogens, and combustible materials.
Hydrochloric Acid
Colorless gas or fuming liquid can cause burns to respiratory tract, skin, eyes, and mucous membranes.
May also cause frostbite, blindness, and liver and kidney damage.
Strong bases, amines, oxidizing agents, organic materials, metal carbides, and sulfuric acid. Reacts with
metals to form hydrogen gas, which is highly flammable and explosive.
Iodine and Iodine Crystals
Gives off vapor that is irritating to respiratory system and eyes. Solid form irritates the eyes and may
burn skin. If ingested, it will cause severe internal damage.
Acetylene, ammonia (laboratory gas of solution)
Lithium Metal
Extremely caustic to all body tissues. Reacts violently with water and poses a fire or explosion hazard.
Moisture, acids, oxidizers, oxygen, nitrogen, carbon dioxide, temperatures above melting point (180.5 C/357 F).
Methamphetamine Liquid
Methyl Ethyl Ketone
Inhalation can cause headaches, nausea, and irritation of the eyes and respiratory tract; high doses can
also result in narcosis. Eye contact with liquid form can cause corneal injury.
Caustics (such as sodium hydroxide), amines, alkanolamines, aldehydes, ammonia, strong
oxidizing agents, and chlorinating compounds.
Methylamine
Highly flammable colorless gas or liquid causing severe irritation of eyes, skin, and respiratory tract
when inhaled. Repeated exposure may cause bronchitis.
Mercury, copper, zinc, aluminum and galvanized surfaces, flammable materials, and strong
oxidizers (such as chlorine, chlorine dioxide, and bromine).
n-Acetylanthranilic Acid
Harmful if swallowed. Eye, skin, and respiratory irritant.
Strong oxidizing agents.
n-Ethylephedrine
N/A
N/A
Nitroethane
Flammable liquid. May be harmful if swallowed, inhaled, or absorbed through skin. Causes eye irritation.
Absorption into body leads to methemoglobinemia resulting in cyanosis (blue lips).
Oxidizing agents, amines, acids, alkalis, hydrocarbon mixtures, metal oxides.
o-Toluidine
Combustible liquid and vapor. Suspected cancer hazard. May be fatal if swallowed, inhaled, or absorbed
through skin. Causes irritation to skin, eyes, and respiratory tract. Affects blood, kidneys, liver, and
cardiovascular system.
Oxidizing agents, strong acids, and strong bases.

Phenethylamine
Combustible liquid and vapor. Contact with skin has a defatting effect, causing drying and irritation.
Liquid may cause permanent eye damage.
Strong oxidizing agents, strong acids.
Phenyl-2-propanone (P2P)
Can be harmful if swallowed, inhaled, or absorbed through skin. Causes irritation to skin, eyes, and
respiratory tract.
Strong oxidizing and reducing agents, strong bases.
Phenylacetic Acid
A corrosive acid that may cause respiratory and digestive tract irritation. Causes eye and skin burns.
May cause reproductive and fetal effects.
Strong oxidizing agents, strong bases.
Potassium Permanganate
Strong oxidizer that may cause fire when in contact with other materials. Causes irritation to skin,
eyes, and respiratory tract. Ingestion of solid or high concentrations causes severe distress of
gastro-intestinal system and may be fatal.
Powdered metals, alcohol, arsenites, bromides, iodides, phosphorous, sulfuric acid, organic compounds,
sulfur, activated carbon, hydrides, strong hydrogen peroxide, ferrous or mercurous salts, hypophosphites,
hyposulfites, sulfites, peroxides, and oxalates.
Pseudoephedrine
Ingestion of doses greater than 240 mg. causes hypertension, arrhythmia, anxiety, dizziness, and vomiting.
Ingestion of doses greater than 600 mg. can lead to renal failure and seizures.
Strong oxidizing agents.
Red Phosphorus
May explode on contact or friction. Ignites if heated above 260oF. Vapor from ignited phosphorus
severely irritates the nose, throat, lungs, and eyes.
Halogens, halides, sulfur, and oxidizing materials (may explode on contact).
Safrole
Carcinogen and mutagen. Contact may irritate skin. High exposure can cause nausea, vomiting, headache,
dizziness, drowsiness, convulsions or unconsciousness. May cause liver damage.
Oxidizing agents.
Sodium Dichromate
Carcinogen and potentially fatal if swallowed. Inhalation, ingestion, and skin absorption are harmful to
skin, eyes, and respiratory tract.
Strong reducing agents, strong acids, organic materials, and combustible materials.
Sodium Metal
May cause burns to skin, eyes, and respiratory tract. Reacts violently with water; extremely corrosive
in the presence of moisture.
Oxidizing and reducing agents, acids, combustible materials, halo carbons, halogens, amines, metals,
metal oxides, metal salts, bases.
Sulfuric Acid
A corrosive acid with vapors that are irritating to the respiratory system, eyes, and skin. Inhalation
can cause tooth erosion. If ingested, causes severe internal irritation and damage that may cause death.
Potassium chlorate, potassium perchlorate, potassium permanganate.
Thionyl Chloride
Poison. May be fatal if inhaled. Vapor causes severe irritation to skin, eyes, and respiratory tract.
May cause serious eye damage.
Reacts violently with water. Strong reducing agents, strong bases, and most common metals.
Toluene
Flammable liquid and vapor. May irritate skin, eyes, and respiratory tract. Aspiration hazard. Can
cause central nervous system depression and nerve damage.
Halogens, combustible materials, acids, oxidizing materials, metal salts.

Chemical
Name Sources
2,5-Dimethoxybenzaldehyde
Acetic Anhydride
http://www.state.nj.us/health/eoh/rtkweb/0005.pdf
http://avogadro.chem.iastate.edu/MSDS/acetanhy.htm
Acetone/ Ethyl Alcohol
http://avogadro.chem.iastate.edu/MSDS/acetone.htm
Anhydrous Ammonia
http://www.ied.edu.hk/sci/safechem.htm
Anthranilic Acid
http://www.basf.com/businesses/chemicals/intermediates/pdfs/anthran.pdf
http://msds.pdc.cornell.edu/msds/msdsdod/a382/m190987.htm
Butylamine
http://www.state.nj.us/health/eoh/rtkweb/0280.pdf
Cyclohexanone
http://www.state.nj.us/health/eoh/rtkweb/0570.pdf
Ephedrine
http://physchem.ox.ac.uk/MSDS/EP/(-)-ephedrine_anhydrous.html
http://www.usg.edu/rtk/msds/MSDS0251.TXT
Ergometrine
http://www.medsafe.govt.nz/Profs/Datasheet/e/Ergometrineinj.htm
Ethyl Acetate
http://www.state.nj.us/health/eoh/rtkweb/0841.pdf
Ethyl Ether
http://www.state.nj.us/health/eoh/rtkweb/0701.pdf
http://www.matheson-trigas.com/msds/MAT08980.pdf
Ethylamine
http://www.state.nj.us/health/eoh/rtkweb/0847.pdf
Formamide
http://www.state.nj.us/health/eoh/rtkweb/0947.pdf
Formic Acid
http://www.state.nj.us/health/eoh/rtkweb/0948.pdf
Hydriodic Acid
http://www.matheson-trigas.com/msds/MAT11100.pdf
Hydrochloric Acid
http://www.mgindustries.com/msds/SubLookup.asp?SubName=11150
http://www.state.nj.us/health/eoh/rtkweb/1012.pdf
Iodine
http://www.ied.edu.hk/sci/safechem.htm
Lithium Metal
http://www.rose-hulman.edu/che mistry/000000/000617.pdf
Methyl Ethyl Ketone
http://www.rose-hulman.edu/chemistry/000000/000816.pdf
http://hillbrothers.com/msds/mek.htm
Methylamine
http://www.state.nj.us/health/eoh/rtkweb/1225.pdf
n-Acetylanthranilic Acid
http://physchem.ox.ac.uk/MSDS/AC/o-acetamidoanthranilic_acid.html
Nitroethane
http://www.rose-hulman.edu/chemistry/000000/000822.pdf
o-Toluidine
http://www.rose-hulman.edu/chemistry/000000/000848.pdf
http://www.state.nj.us/health/eoh/rtkweb/1442.pdf
Phenethylamine
http://physchem.ox.ac.uk/MSDS/PH/phenethylamine
http://hazard.com/msds/mf/baker/baker/files/p1872.htm
Phenyl-2-propanone (P2P)
http://www.rose-hulman.edu/chemistry/000000/000809.pdf
Phenylacetic Acid
http://www.rose-hulman.edu/chemistry/000000/000087.pdf
Potassium Permanganate
http://www.rose-hulman.edu/chemistry/000000/000908.pdf
Pseudoephedrine
http://physchem.ox.ac.uk/MSDS/PS/(+)-pseudoephedrine.html
Red Phosphorus
http://avogadro.chem.iastate.edu/MSDS/P-red.htm
Safrole
http://www.state.nj.us/health/eoh/rtkweb/1642.pdf
Sodium Dichromate
http://physchem.ox.ac.uk/MSDS/SO/sodium_dichromate.html
http://www.matheson-trigas.com/msds/MAT21190.pdf
Sodium Metal
http://www.matheson-trigas.com/msds/MAT20850.pdf
Thionyl Chloride
http://physchem.ox.ac.uk/MSDS/TH/thionyl_chloride.html
http://www.udallas.edu/chemdept/hendrickson/MSDS/thionyl_chloride__ msds.htm
Toluene
http://www.matheson-trigas.com/msds/MAT23590.pdf

Appendix K: Methodology for Assessing Potential Consequences of Hazardous Waste
Air Releases
The hazardous waste release scenarios for the DOJ COPS Office Methamphetamine
Initiative, and the No Action Alternative were based on data collected during seizures of
clandestine drug laboratories. The data collected included the types and quantities of
chemicals found and the neighborhood categories and structure types encountered. The
release scenario modeling approach and assumptions provides a screening type analysis of
potential impacts from releases of selected chemicals to the indoor and outdoor air.
Selection of Chemicals for Analysis
According to the data, one of the most common substances recovered is ammonia gas.
Ammonia gas is generally recovered in the form of compressed gas cylinders. Other
common substances that are recovered at clandestine drug laboratories and that could
cause fire and smoke are the flammable liquids acetone, toluene, and ethyl ether, which
are recovered in containers of various sizes. Red phosphorus, which is incompatible with
other chemicals commonly recovered at clandestine drug laboratories, including
hydrochloric acid, is also one of the more common chemicals recovered. Red phosphorus
may also decompose to the more highly reactive and spontaneously combustible yellow
phosphorus form, or ignite if subjected to heat, friction, or static charge.78 Potassium
permanganate, a powerful oxidizer, may also be found at clandestine drug laboratories.
Potassium permanganate is incompatible with all combustible organic chemicals (e.g.,
acetone, toluene) and is also incompatible with hydrochloric and hydriodic acid79.
Combination of these incompatible chemicals or decomposition of these chemicals could
cause fire and smoke. Therefore, the quantitative analysis focuses on the effects of
potential releases of toxic chemicals (i.e., ammonia) to air.
Selection of Neighborhood Category/Structure Type
The neighborhood category/structure type scenarios discussed above were developed
based on data collected for clandestine drug laboratory seizures, and were developed
specifically to enable the assessment of a broad range of conditions related to potential
hazardous waste releases in the Environmental Assessment. The scenarios selected for the
hazardous waste release analyses are:
a. Single Family House Scenario (indoor release)
b. Single Family House Scenario (outdoor release)
c. Multi-unit Residential Property Scenario
d. Storage Unit Scenario (indoor storage unit)
e. Storage Unit Scenario (outdoor release)

f. Storage Unit Scenario (DEA Contractor)
78 Mallinckrodt, 1999. Material Safety Data Sheet, Phosphorus, Amorphous.
79 J.T. Baker, 1999. Material Safety Data Sheet, Hydriodic Acid 40-60%.
Approach to Analyzing Air Releases
For air releases, the DOJ COPS Office conducted a quantitative analysis that includes
modeling of the release and dispersion of the release. The DOJ COPS Office assumed
that 100 kilograms of ammonia gas is involved in the release. In devising the release
scenario, the DOJ COPS Office adopted the same definition used in Environmental
Protection Agencys (EPA) Risk Management Program Rule, which states that a worst-
case release is a release of the entire container of the substance over a ten-minute period.80
 For ammonia gas released indoors into a Single Family House, Multi-unit Residential
Property (e.g., apartment), storage unit or other structure, the DOJ COPS Office assumed
that the gas initially becomes uniformly distributed within the structure. Therefore, the
concentration of the ammonia within the structure is equal to the volume of the gas
released divided by the volume of the structure. The DOJ COPS Office then determined
the potential health effects of such concentrations based on established exposure limits
such as the Emergency Response Planning Guide (ERPG) from the American Industrial
Hygiene Association.81 The ERPG-2 for ammonia is 150 parts per million (ppm). The
ERPG-2 is the concentration below which nearly all people could be exposed to for a
period of one hour without irreversible or other serious health effects or symptoms that
would impair their ability to take protective action. ERPGs are oriented towards public
exposure.
For an indoor release of ammonia gas, some portion of the ammonia would leave the
building through windows, doors, and/or general ventilation systems. The DOJ COPS
Office assumed that approximately 55 percent of the gas would leave the structure upon
release. This factor was used in the EPA Offsite Consequence Analysis Guidance for
gaseous releases inside a building.82 The 55 percent factor was based on an analysis of
Risk Mitigation in Land Use Planning: Indoor Releases of Toxic Gases83. For 100
kilograms of ammonia gas released into a building, approximately 55 kilograms would
leave the building and disperse into the vicinity. The DOJ COPS Office examined the
possibility of the ammonia released from the building entering a nearby house, apartment,
or other building. The widely used ALOHA model (Area Locations of Hazardous
Atmospheres) developed by the National Oceanic and Atmospheric Administration was
used to assess the dispersion of ammonia and concentrations in nearby buildings.84
Caution must accompany the analysis results because dispersion predictions using
any model are uncertain for the short distances to nearby structures.
80 Emergency Response Planning Guidelines (ERPG); developed by the American Industrial Hygiene
Association, Fairfax, Virginia, 2002.81 Immediately Dangerous to Life or Health (IDLH); developed
by the National Institute for Occupational Safety and Health (NIOSH) in Occupational Health Guidelines
for Chemical Hazards, June 1994.
82 EPA Offsite Consequence Analysis Guidance http://www.epa.gov/swercepp/ap-ocgu.htm
83 Porter, S.R. Risk Mitigation in Land Use Planning: Indoor Releases of Toxic Gases.
84 Area Locations of Hazardous Atmospheres (ALOHA); developed by the National Oceanic and
Atmospheric Administration and the Environmental Protection Agency.
www.epa.gov/ceppo/cameo/aloha.htm

For the releases of ammonia originating outside of a building, the DOJ COPS Office
assumed that 100 percent of the release (100 kilograms) would be dispersed downwind
from the point of the release. Likewise, for ammonia releases originating in an outdoor
storage unit, the DOJ COPS Office assumed that 100 percent of the gas would escape
through the ventilation system of the storage unit and would be dispersed downwind from
the point of release.
Toxic Gas Release (Ammonia) Scenario Calculations and Results
Scenario a: Single Family House: Indoor Release
 Initial concentration inside the house is based on 100 kilograms of ammonia
released into the house:
Volume Ammonia = 100 kg * (m3/0.713 kg) * (1ft3/0.0283 m3) = 4956 ft3
Ammonia Concentration = 4,956 ft3/ 30,000 ft3 * 1,000,000 = 160,000 ppm
 Ammonia concentration at an adjoining house is based on 55% of the initial 100kilogram
release over a 10-minute period.
ALOHA modeling results indicate that at a distance of 50 feet from the point of
release, a human receptor (at an adjacent house) would be exposed to an ammonia
concentration of 150 ppm, equivalent to the Emergency Response Planning
Guidance (ERPG) level.
Scenario b: Single Family House: Outdoor Release
 Release concentration outdoors is based on 100 kilograms of ammonia released in
the backyard of the house:
ALOHA modeling results indicate that at a distance of 50 feet from the point of
release, a human receptor (located at an adjacent house) would be exposed to an
ammonia concentration greater than the Emergency Response Planning Guidance
(ERPG) level. Human receptors located at houses 75 feet away from the point of
release would be exposed to an ammonia concentration of 150 ppm, equivalent to
the ERPG level.
Scenario c: Multi-unit Residential Property (e.g., Apartment Building) Scenario
 Initial concentration inside the apartment is based on 100 kilograms of ammonia
released into the apartment:
Volume Ammonia = 100 kg * (m3/0.713 kg) * (1ft3/0.0283 m3) = 4956 ft3
Ammonia Concentration = 4,956 ft3/ 15,000 ft3 * 1,000,000 = 320,000 ppm

 Ammonia concentration in adjoining apartment is based on 55% of the initial 100kilogram
release over a 10-minute period.
ALOHA modeling results indicate that a human receptor in an adjacent apartment
could be exposed to an ammonia concentration of approximately 6,400 ppm, a
concentration far exceeding the 150 ppm Emergency Response Planning Guidance
level.
Scenario d: Storage Unit Indoor Release
 Initial ammonia concentration inside the storage unit building is based on 100
kilograms of ammonia released into the storage unit and subsequently released into
the building that the indoor storage unit is situated in:
Volume Ammonia = 100 kg * (m3/0.713 kg) * (1ft3/0.0283 m3) = 4956 ft3
Ammonia Concentration = 4,956 ft3/ 60,000 ft3 * 1,000,000 = 80,000 ppm
[Note: The DOJ COPS Office assumes that storage units may or may not be
ventilated to outside of the building. The DOJ COPS Office also assumes that
unventilated storage units are not designed to contain compressed gas releases.
Therefore, it was assumed for this analysis that 100 percent of the 100-kilogram
ammonia release escapes from an unventilated storage unit and into the building.]
 Ammonia concentration in adjoining residential area/commercial area based on
55% the initial 100-kilogram release over a 10-minute period.
ALOHA modeling results indicate human receptors located in
residential/commercial areas 50 feet from the point of release would be exposed to
an ammonia concentration of 150 ppm, equivalent to the Emergency Response
Planning Guidance level.
Scenario e: Storage Unit Outdoor Release
ALOHA modeling results indicate that human receptors located in
residential/commercial areas 50 feet from the point of release would be exposed to
an ammonia concentration greater than the Emergency Response Planning
Guidance (ERPG) level. Human receptors located 75 feet from the point of release
would be exposed to an ammonia concentration of 150 ppm, equivalent to the
Emergency Response Planning Guidance level.
Scenario f: DEA Contractor Transfer Station Indoor Release
 Initial ammonia concentration inside the transfer station is based on 100 kilograms
of ammonia released into the transfer station
Volume Ammonia = 100 kg * (m3/0.713 kg) * (1ft3/0.0283 m3) = 4956 ft3

Ammonia Concentration = 4,956 ft3/ 60,000 ft3 * 1,000,000 = 80,000 ppm
 Ammonia concentration in adjacent house/commercial building is based on 55% of
the initial 100-kilogram release over a 10-minute period.
ALOHA modeling results indicate that a human receptor located at a
house/commercial building located 200 feet from the point of release would be
exposed to an ammonia concentration lower than the 150 ppm Emergency
Response Planning Guidance level.

Appendix L: Water Quality Impact Analysis
The DOJ COPS Office assessed the potential impacts of releases of hazardous waste to
surface water. A release could potentially result from a transportation or materials
handling accident under the DOJ COPS Office Methamphetamine Initiative, or from a
container breach or other inadvertent release from a container remaining in place under
the No Action Alternative. The DOJ COPS Office assumed for the purposes of the water
quality impact analysis that a maximum quantity of 100 kilograms of hazardous waste
could be released to surface water as a result of such events.
The DOJ COPS Office based the analysis of potential impacts to water quality on the
dispersion modeling methodology and river data presented in the USGS Paper Prediction
of Travel Time and Longitudinal Dispersion in Rivers and Stream (USGS Report 964013).
85 The USGS report presents a model to predict the travel time and unit peak
concentration of a contaminant released upstream of a water supply. The model can be
used to estimate the rate of movement of a chemical release through a river reach, the rate
of attenuation of the peak concentration over time, and the length of time for the
contaminant plume to pass a particular point in the river. The USGS Report also presents
tracer-response curve data obtained from soluble tracer (dye) injection studies conducted
by USGS for 90 streams and rivers throughout the United States, for use in applying the
model.
85 Jobson, Harvey E., 1996. Prediction of Travel Time and Longitudinal Dispersion in Rivers
and Streams, USGS Water Resources Investigations Report 96-4013, 1996.
Data for the Apple River in northwestern Illinois and the Little Piney River in central
Missouri are used in this Environmental Assessment for screening of water quality
impacts of the Proposed Action. These rivers were selected for the screening analysis
based upon their size (in terms of average volumetric flow rate), their location within
grantee states, and the availability of a full data set in the USGS Report. Data for the
tracer studies for these two rivers are shown in Table L.1. Larger rivers (e.g., the
Mississippi River, the Missouri River) were not selected for screening analysis because
any release into rivers of such large size would be diluted to levels below concern
relatively quickly.
The tracer study data show the distance downstream of the dye injection point where the
sampling was conducted and the volumetric flow rate of the river at the sampling point.
The data also show the amount of time elapsed from the time of injection until the peak
concentration was observed at the sampling point, and the amount of time elapsed until
the concentration is reduced to ten percent of the observed peak concentration. The unit
peak concentration in units of seconds-1 as calculated using the modeling methodology, is
also reported. The unit peak concentration is the mass flux of solute (dye) at a given point
in the river, in units of [milligrams per liter x liters per second, or milligrams per second]
per unit of solute mass injected, in units of milligrams. This is calculated as

Cup = C/Mr x Q
Where Cup = unit peak concentration (seconds-1)
C = observed concentration (milligrams per liter)
Mr = mass of tracer recovered at a cross section (milligrams) and
Q = river volumetric flow rate (liters per second)
Therefore the unit peak concentration may be used to estimate the peak concentration for
a given flow rate and mass of solute (or contaminant) released.
Aquatic toxicity data for toluene were obtained from the USGS Report Summary of
Published Aquatic Toxicity Information and Water-Quality Criteria for Selected Volatile
Organic Compounds (USGS Report 97-563).86 The USGS reported an EPA freshwater
acute criteria/guideline for toluene of 17,500 micrograms per liter (ug/l.) Aquatic
toxicity data for iodine were obtained from a Material Safety Data Sheets (MSDS) for
iodine.87 The MSDS reported a 24-hour LC50 for iodine of 440 ug/l. The LC50 represents the
concentration at which 50 percent of an exposed aquatic species would experience
mortality over the period of exposure. Iodine is not listed as a priority pollutant in the
U.S. Clean Water Act. However, the Canadian Province of Ontario has developed an interim
Provincial Water Quality Guideline (PWQG) of 100 ug/l for iodine.88
86 USGS, 1997. Summary of Published Aquatic Toxicity Information and Water Quality Criteria
for Selected Volatile Organic Compounds, USGS Open File Report 97-563, 1997.
87 Safety Data Sheet  Iodine, 99.5%. CAS No. 7553-56-2, Personal Chemistry, Sweden, November 2000.
88 Province of Ontario, 1994. Ontario Ministry of Environment and Energy, Policies, Guidelines,
and Provincial Water Quality Objectives of the Ministry of Environment and Energy, July 1994
[reported in Review of Annex 1 of the Great Lakes Water Quality Agreement, Limno-Tech, Inc. March 14, 2001.]
Iodine and toluene were selected for the screening water quality analysis based on the
availability of aquatic toxicity data, the level of toxicity, and the quantities of these
compounds recovered at clandestine drug laboratory sites. Toluene and iodine have been
recovered from clandestine drug laboratories in quantities on the order of 100 kilograms
for a single site. Toluene has higher aquatic toxicity than other organic compounds for
which aquatic toxicity data are available (e.g., methyl ethyl ketone, acetone) and iodine
has higher aquatic toxicity than other inorganic compounds for which aquatic toxicity data
are available (e.g., potassium permanganate (manganese), phosphorus). Based on a
density of 4.93 grams per milliliter, 100 kilograms of iodine is approximately equivalent
to one five-gallon container, and 100 kilograms of toluene is approximately equivalent to
one 30-gallon container, based on a density of 0.867 grams per milliliter.
As shown in Table L.1, in the event of a release of 100 kilograms of toluene to surface
water, peak concentrations of toluene could exceed the freshwater acute criteria/guideline
(FAC) for toluene under some circumstances. Using the USGS dispersion modeling
approach, if a release occurred in the Apple River in the vicinity of the town of Apple
River, Illinois at a high river flow rate (2.6 m3/s) the peak concentration 1.9 kilometers
from the point of release would be 69,300 ug/l, almost 400 percent of the FAC. The peak
concentration would occur 1.3 hours after the time of release, and the concentration would

be reduced to 10 percent of the peak concentration after 3.4 hours. If the release occurred
at a low river flow rate (0.6 m3/s) the peak concentration would be 27,700 ug/l, and would
occur 3.7 hours after the time of release. The concentration would be reduced to 10 percent
of the peak concentration after 7.8 hours.
In the event of a 100 kilogram release of iodine at high river flow rate, the peak iodine
concentration would also be 69,300 ug/l at a distance of 1.9 kilometers from the point of
release, as the modeling approach is independent of the characteristics of the substance
released and only considers the quantity released and the characteristics of the river.
However, this same concentration would be 15,700 percent of the reported LC50 of 400
ug/l for iodine. The peak concentration would occur 1.3 hours after the time of release,
and 3.4 hours after the time of release the concentration would be 10 percent of the peak
concentration, but still 1,570 percent of the LC50. Further downstream, at a point 35.6
kilometers from the point of release, the peak concentration would only be 2,313 ug/l, or
525 percent of the LC50, and would occur 33 hours after the time of release. The
concentration would fall to 10 percent of the peak concentration (231 ug/l, or 52.5 percent
of the LC50) 50 hours after the time of release. Therefore, an iodine concentration greater
than 50 percent of the LC50 would persist for approximately 18 hours at the 35.6 kilometer point.
Lower impacts are predicted for Little Piney Creek, for which tracer study data are only
available for low flow (1.4 - 1.6 m3/s) conditions. In the event of a 100-kilogram release
of toluene, the peak concentration would be 19,850 ug/l (113 percent of the FAC for
toluene) at a distance of 0.6 kilometers from the point of release, however the toluene
concentration would be reduced to 1,985 ug/l (10 percent of the peak concentration) in
less than 60 minutes. In the event of a 100-kilogram release of iodine, the peak
concentration at the 0.6-kilometer point would be 4,500 percent of the LC50, however, this
concentration would persist for only a short time. At a point 5.2 kilometers from the point of
release, the peak concentration would be approximately 2,410 ug/l (550 percent of the LC50),
however the concentration would be reduced to 240 ug/l (55 percent of the LC50)
within approximately 3 hours.
Note that the USGS modeling approach assumes that the release disperses immediately
into the river (instantaneous slug release). A release of liquid toluene into a river would
behave to some extent as an instantaneous source, however, iodine, being a crystalline solid
that is only slightly soluble in water, may not immediately disperse into the river. This
would somewhat reduce the magnitude of the peak concentrations from what are predicted in
the model. Also, the USGS model does not consider chemical reactions that could take place
between the contaminant released and water or other constituents. The contaminant released
is assumed to disperse without reaction. Reactivity of iodine would also reduce the magnitude
of the peak concentrations from the predicted concentrations.

Table L.1
Surface Water Release Screening Model
BASIC DATA Little Piney Creek, Missouri Apple River, Illinois
Inj No. 18  18  18  18  83  83  83  84  84  84
Km Km 0.6  3.4  5.2  7.3  1.9  35.9  52  1.9  35.9  58.4
Q m3/s 1.4  1.4  1.6  1.6  2.6  12.4  16.7  0.6  2.6  3.1
Tl Hours 0.61  3.75  6.03  9.21  1  18.5  30.4  2.7  43.8  97.2
Tp Hours 0.85  5.1  7.4  12  1.3  20.8  32.9  3.7  49.4  105.8
Tt Hours 1.47  7.7  10.8  17.5  3.4  35.6  50.2  7.8  72.8  129.5
Qave m3/s 4.4  4.4  4.4  4.4  0.7  3.8  5  0.7  3.8  5
Cup s-1 873.2  138.1  106.1  75.1  485.2  87.9  60.5  193.8  36.5  29.7
Inj Mass G 48  48  48  48  2400  2400  2400  450  450  450
R Ratio Unitless 0.972  0.948  0.988  1  0.76  0.66  0.84  1.05  0.64  0.57
SCREENING MODEL CALCULATIONS
Release Mass Mg 1.00E+08 1.00E+08 1.00E+08 1.00E+08 1.00E+08 1.00E+08 1.00E+08 1.00E+08 1.00E+08 1.00E+08
Qave liter/s 4.40E+03 4.40E+03 4.40E+03 4.40E+03 7.00E+02 3.80E+03 5.00E+03 7.00E+02 3.80E+03 5.00E+03
Travel Time s-1 873.2 138.1 106.1 75.1 485.2 87.9 60.5 193.8 36.5 29.7
Recovery Ratio Unitless 1 1 1 1 1 1 1 1 1 1
C (peak) = mg/l 19.85 3.14 2.41 1.71 69.31 2.31 1.21 27.69 0.96 0.59
C (peak) = ug/l 19845 3139 2411 1707 69314 2313 1210 27686 961 594
C(peak)/FAC Toluene 113.4% 17.9% 13.8% 9.8% 396.1% 13.2% 6.9% 158.2% 5.5% 3.4%
0.1 C(peak)/FAC Toluene 11.3% 1.8% 1.4% 1.0% 39.6% 1.3% 0.7% 15.8% 0.5% 0.3%
C(peak)/LC50 Iodine 4510.3% 713.3% 548.0% 387.9% 15753.2% 525.7% 275.0% 6292.2% 218.3% 135.0%
0.1 C(peak)/LC50 Iodine 451.0% 71.3% 54.8% 38.8% 1575.3% 52.6% 27.5% 629.2% 21.8% 13.5%
Time to C (Peak) Hours 0.85 5.10 7.40 12.00 1.30 20.80 32.90 3.70 49.40 105.80
Time to 10% C (Peak) Hours 1.47 7.7 10.8 17.5 3.4 35.6 50.2 7.8 72.8 129.5
Distance to C (Peak) Km 0.60 3.40 5.20 7.30 1.90 35.90 52.00 1.90 35.90 58.40

AQUATIC TOXICITY DATA
EPA Freshwater Acute Criteria (FAC) Toluene 17,500ug/l
Aquatic Toxicity Criteria (LC50 24 hour) Iodine 440ug/l
BASIC DATA KEY
Injection Number 	Inj No.
Distance to Sampling Cross Section 	Km
Flow Rate at Sampling Cross Section 	Q
Time to Sampling Cross Section 	Tl
Time to Peak Concentration 	Tp
Time to 10% of Peak Concentration 	Tt
Mean annual flow rate 	Qave
Unit-peak Dye Concentration 	Cup
Mass of Dye Injected 	Inj Mass
Recovery Ratio 	R Ratio
Sources:
USGS Water Resources Investigations Report 96-4013
Prediction of Travel time and Longitudinal Dispersion in Rivers and Streams
Harvey E. Johnson, USGS Water Resources Division, Reston Virginia http://water.usgs.gov/osw/pubs/disp/dispersion.html

Appendix M: Methodology for Assessing Soil Quality Impacts
Potential impacts of the release of hazardous wastes to soil quality were assessed using
generic soil screening levels (SSLs) developed by EPA for 110 chemicals. These include
SSLs developed to assess potential ingestion of contaminated soils.89 The generic SSLs,
contained in Appendix A of the EPA Guidance Document, were derived by EPA using
default values for the standardized equations in the Guidance Document, and are
considered to be conservative and are likely to be protective for the majority of site
conditions for contaminated soils. SSLs are used for evaluating soil contaminant levels at
EPA hazardous waste remediation (Superfund National Priority List) sites and developing
risk-based remediation strategies.
Of the hazardous wastes recovered from clandestine drug laboratory locations and listed
in Table 6.3-1 of the Environmental Assessment, EPA has developed generic SSLs for
soil ingestion for acetone, toluene, and chromium (a constituent of sodium dichromate.)
The SSLs for acetone and toluene are higher than the generic SSLs for most of the other
chemicals for which EPA developed generic SSLs. The DOJ COPS Office therefore
believes that evaluation of soil concentrations against these SSLs would be representative
of other hazardous wastes found at clandestine drug laboratories for which generic SSLs
have not been developed.
For the purposes of assessing soil quality impacts, the DOJ COPS Office assumed that
100 kilograms of toluene or acetone and 2.5 kilograms of sodium dichromate (the
maximum quantity discovered at a single clandestine drug laboratory location) could be
released under the e removal action scenarios and transportation scenario under the
Proposed Action, or from a container breach or other inadvertent release from a container
remaining in place under the No Action Alternative. The calculated soil concentrations are
the same for both Alternatives, because the DOJ COPS Office has assumed that the
maximum amount of hazardous waste that could be released and the amount of soil area
that such a release would cover are the same for each Alternative. The DOJ COPS Office
assumed in calculating concentrations of hazardous waste in the soil that any release
would cover an area of 10 square meters to a depth of one centimeter. The DOJ COPS
Office calculated soil concentrations for each hazardous waste released to its soil
ingestion SSL, as shown in Table M.1.
89 EPA, 1996. U.S. EPA Soil Screening Guidance, EPA 540/R-96/018, July 1996,
http://www.epa.gov/superfund/resources/soil

Table M.1
Soil Hazardous Waste Screening Release Calculations
Release Parameters
Toluene
Acetone
Sodium Dichromate
Spill Amount
100 kilograms
100 kilograms
2.5 kilograms
Spill Amount
1.00E+08 milligrams
1.00E+08 milligrams
2.50E+06 milligrams
Spill Area
10 m2
10 m2
10 m2
Spill Depth
1 cm
1 cm
1 cm
Spill Depth
0.1 m
0.1 m
0.1 m
Soil Density
1.5 kilograms/liter
1.5 kilograms/liter
1.5 kilograms/liter
Soil Density
1500 kilograms/ m3
1500 kilograms/ m3
1500 kilograms/ m3
Soil Mass Amount
1500 kilograms
1500 kilograms
1500 kilograms
Soil Concentration
66,667 mg/kg
66,667 mg/kg
331 mg Cr/kg*
Generic Ingestion SSLs
16,000 mg/kg
7,800 mg/kg
390 mg/kg
Soil Concentration / SSL
416%
854%
84%
Notes:
The molecular weights of Na2Cr2O7 (261.97) and Cr (51.996) were used for the above calculations.
SSL = Soil Screening Level
* Na2Cr2O7 concentration in soil is 1667mg/kg of which 19.85% (or 331 mg/kg) is due to Cr
Source: EPA, 1996. U.S. EPA Soil Screening Guidance, EPA 540/R-96/018, July 1996,
http://www.epa.gov/superfund/resources/soil