D.4 Activity III Example Activity Scenario.docx

Attachment D.4 Example Activity Scenario Activity III: Illegal Marijuana Grow Site Investigation And Cleanup

For each of the illegal marijuana grow site scenarios provided below, prepare and submit a work plan that provides a description of how contractor would address the incident. The work plan needs to include and address the following:

i. Description of how the work is to be performed.

ii. Discussion of any specific exclusions/assumptions the contractor may have regarding their response to the scenario in question.

iii. Conceptual listing of personnel, including subcontractor(s) that would be utilized for the response.

iv. Conceptual listing of equipment and supplies to be utilized for the response.

v. Sample Contingency Plan for addressing emergency spills and releases.

vi. Sample Field sampling and analysis protocols that would be utilized for hazardous material/waste identification, identification of chemical residual and contamination, etc.).

vii. Hazardous material/waste management plan and protocols for material/waste handling, transport and disposal.

viii. Sample Safety & Health Plan and procedures the contractor will follow for addressing hazardous chemicals routinely found at grow sites, including but not limited to:

· Acephate

· Aldicarb

· Aluminum Phosphide

· Bifenthrin

· Brodifacoum

· Bromethalin

· Carbaryl

· Carbofuran

· Cyhalothrin (gamma)

· Fenbutatin-oxide (Hexakis)

· Malathion

· Methamidophos

· Pyrethrum

· Tralomethrin

· Triforine

· Zinc Phosphide

ix. Provide the estimated cost for the response. Breaking down cost items into key categories (work plan development, mobilization, performance of work, disposal cost, and final report preparation).

For each scenario factor the devlopment of your work plan based on performing the following activites:

i. Field characterization and Identification of all unknown material/wastes. This includes the identification of the contents of all unlabeled containers and any chemical sprayers found at the site/s.

ii. Field characterization of the irrigation lines to determine is contaminated with pesticides.

iii. Prepare hazardous material/waste inventory of materials/waste and contaminated items found at the site/s which includes waste identification, waste classification, and quantity.

iv. Segregating and lab-packing of the material/waste as appropriate; labeling material/waste containers for transportation and disposal.

v. Selection of appropriate recycling and/or treatment,storage or disposal facility.

vi. Preparation of waste profile sheets and waste manifests.

vii. Off-site transport and disposal of materials.

Please note that the chemical inventories provided which each scenario are an example of the typical level of detail which is avaialble for a given grow site and should not be considered as complete.

I. GROW SITE SCENARIO 1:

Several grow sites on the San Bernardino National Forest have been identified with illegal pesticides which require investigation and cleanup.

A. Pierce Creek Site :

The primary grow site camp area is located at N34 06.581’ -W116 58.697’. Site is a is approximately 1.5 miles from FS Road 3N59 (nearest lat/long for a staging area is N34 06.599’ -W116 58.548’). FS Road 3N59 is accessible by 2wd vehicles. The Site is down a shallow ravine and is accessible by hiking in via an unimproved foot path. There are two grow areas near the grow site camp which covered approximately 6 acres. Plants were removed by Forest Service law enforcement officers during the initial law enforcement response.

The following is an initial inventory of some of the hazardous materials found at the site. :

· 6 bottles labeled “uFuran”. 2 full, 4 partially full

· 1 gallon container broken open with white powder spilt (partial label Furadan 5G).

· 1 partially full container with label “Lorsban -4E”

· Multiple aerosol cans of various over the counter bug repellant

· Multiple open containers labeled “TOMCAT® WITH BROMETHALIN BAIT CHUNX”

· 1 Open and deterioated container labeled in Spanish “Ratone: Forfuro de Zinc”

· 3 unlabeled bottles with pinkish liquid residue in it.

· 1 unlabeled bottle with redish liquid in it.

· 4 agricultural sprayers with apparent pink chemical staining on the spray nozzels

· Approximately 200 lbs of Miracle Grow fertilizer

· 1 car battery

· Several 20 lb propane tanks Water contained in the irrigation reservoir was a "Caribbean blue" color and the irrigation piping has chemical staining and residue. A Forest Service employee was splashed with the water in the hose line on the arm and a few hours later suffered from skin blistering in the location where skin contact occurred.

B. Cottonwood Creek:

The primary grow site camp area is located at N34 13.613’ -W117 30.646’. This site is approximately 1.5 miles from FS Road 3N59 (nearest lat/long for a staging area is N34 14.085’ -W117 29.587’). FS Road 3N59 is accessible by 2wd vehicles. According to law enforcement access to the site is a difficult hike down a game trail through poison oak and buck brush. There are three grow areas near the grow site camp which covered approximately 7 acres. Plants were removed by Forest Service law enforcement officers during the initial law enforcement response.

The following is an initial inventory of some of the hazardous materials found at the site:

· 2 partially full bottles labeled “uFuran”

· 2 5 lb bags labeled “Sevin-5”

· 1 full bottle labeled “Metafos 600CE”

· Multiple aerosol cans of various over the counter bug repellant

· Multiple open containers labeled “TOMCAT® WITH BROMETHALIN BAIT CHUNX”

· 2 partially full containers labeled “Talon-G Rodenticide Mini Pellets”

· 1 open container labeled “Cooke Quick Action Gopher Mix”

· Several unlabeled bottles with whiteish liquid in them.

· Two agricultural sprayers with apparent chemical staining on the spray nozzels. Both partially full.

· Several open tins with a yellowish powder mixed with what appears to be cat or dog food.

· Approximately 300 lbs of YaraMila (15-15-15) fertilizer.

· Several 20 lb propane tanks.

Several dead animals were found near the site and were removed for examination. Wildlife biologists indicate that the animals died of pesticide poisoning.

II. Grow Site Scenario 2:

A grow site on the Lassen National Forest has been identified with illegal pesticides which require investigation and cleanup.

A. Wildhorse Creek The primary grow site camp area is located at N40 14.622’ – W121 34.443’. This site is approximately 2 miles downslope from FS Road 29N48 (Tamarack Road) (nearest lat/long for a staging area is N40 15.393’ -W121 35.314’). FS Road 29N48 is accessible by 2wd vehicles. According to law enforcement access to the site is a difficult hike into a canyon down a game trail through poison oak. There are five grow areas near the grow site camp which covered approximately 8 acres. Plants were removed by Forest Service law enforcement officers during the initial law enforcement response.

The following is an initial inventory of some of the hazardous materials found at the site:

· 3 partially full bottles and 1 empty bottle labeled “Metafos”

· 1 partially full container labeled “Tres Pasitos”

· Three agricultural sprayers with apparent chemical staining on the spray nozzels. One empty and two partially full.

· Multiple aerosol cans of various over the counter bug repellant

· Several unlabeled bottles with white and pinkish liquid in them

· Multiple open containers labeled “Ratol”

· 1 broken container with Spanish label “Ratone:Forsfuro de Zinc”

· Approximately 400 pounds of fertilizer

· Multiple small propane cylinders.

· Multiple piles of alkalyne batteries Water contained in the irrigation reservoir had a bluish tinge and the irrigation piping has chemical staining and residue.

B. Bonita Site The primary grow site camp area is located at N40° 9.798' – W121° 21.916'. This site is approximately 0.5 miles upslope from Humbodlt Road (nearest lat/long for a staging area is N40° 10.261' - W121° 21.867'). FS Road 29N48 is accessible by 2wd vehicles. According to law enforcement access to the site is a moderate hike upslope. To access the site, you must cross a flowing creek . The creek is approximately 15 feet wide and is 0.5’ – 1.5’ in depth. There are two grow areas near the grow site camp which covered approximately 1.5 acres. Plants were removed by Forest Service law enforcement officers during the initial law enforcement response.

The following is an initial inventory of some of the hazardous materials found at the site:

· 3 partially full bottles and 1 empty bottle labeled “uFuran”.

· 1 full container labeled “Monitor”

· 1 partially full container labeled “Lannate”

· 3 partially full agricultural sprayers.

· Multiple aerosol cans of various over the counter bug repellant.

· Unlabeled botle with yellowish liquid.

· Several unlabeled bottles with yellowish liquid.

· Multiple open containers of warfarin labeled “Cov-R-Tox”

· 1 broken container with Spanish label “Ratone:Forsfuro de Zinc”

· Approximately 350 pounds of fertilizer

· 3 20 pound propane tanks

· Multiple small propane cylinders.

· Multiple piles of alkalyne batteries and 1 car battery

Several dead animals were found near the site and were removed for examination. Wildlife biologists indicate that the animals died of pesticide poisoning.

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