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Environmental Hazard Case: Methamphetamine Manufacturing

This is a case report of an actual occurrence. The needs of our services included evaluating the amount of seized product, the rate of production, and an evaluation of proposed hazards to the outdoor area and surrounding lives of the area of manufacturing.

1. In May of 2001, the United States Sentencing Commission implemented Amendment 611, which is concerned with Methamphetamine yield estimates. This amendment replaced the theoretical maximum yield estimate of 92% of the mass precursor pseudoephedrine hydrochloride with an estimate of actual yield of 50% of the theoretical yield – i.e. 46% by weight of the precursor.

2. The studies are based on the weight of the active ingredient, in this case listed above – 30mg of pseudoephedrine – and not the total weight of the pill containing the active ingredient. Therefore 100 pills containing 30 mg of pseudoephedrine would be considered to weigh 3000mg or 30 grams.

3. 192 pills were discovered in the master bedroom of the residence.

4. 192 pills of 30 mg pseudoephedrine would equate to 5760mg or 5.76g of pseudoephedrine. The estimated yield of Methamphetamine Hydrochloride is 5.76g x 46% = 2.65g

5. The Report of Investigation from the USDA Forest Service indicates on page 4 of 6 that 74.64 grams of pills were purchased between 4 subjects from August 2010 through July 2011. It is apparent that the weight of the total pill is listed and NOT the weight of the active ingredient. Various studies have been conducted on various brands of pseudoephedrine as to the weight of the active ingredient versus the total weight of each pill including inactive ingredients. The active ingredient in pseudoephedrine based pills can range from 5% to 70% of the total weight of the pill. The weight of pseudoephedrine presuming 30 mg dosages for these purchases combined could be considered to be between 3.72g and 52.25g. Estimated yield of Methamphetamine Hydrochloride is between 3.72g x 46% = 1.71g and 52.25g x 46% = 24.04g

6. The US Department of Justice Office of Community Oriented Policing Service (DOJ COPS) released their Final Environmental Assessment of Clandestine Laboratory Clean-up in May of 2003. According to the data, one of the most common substances recovered is ammonia gas. Therefore, the quantitative analysis was focused on the effects of potential releases of toxic chemicals (i.e., ammonia) to air. In their analysis, the DOJ COPS Office assumed the release of 100kg of ammonia gas. In devising the release scenario they adopted the same definition used by the EPA Risk Management Program Rule, which states that a worst case release is of the entire container of the substance over a ten-minute period. 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. The ERPG-2 for ammonia is 150ppm. The ERPG-2 is the concentration below which nearly all people could be exposed to for up to 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.

Toxic Gas Release (Ammonia) Scenario Calculations and Results:

Single Family House – Indoor Release
Initial concentration in the house is based on 100kg or ammonia released in the house over a 10 minute period

Volume of ammonia for 100kg is 4956ft3
Ammonia Concentration for given footage is 160,000ppm

Ammonia concentration at an adjoining house is based on 55% of the initial 100kg release over a 10 minute period. This would be a concentration of 88,000ppm. This is calculated using an ALOHA (Area Locations of Hazardous Atmospheres) model indicating an adjacent house to be approximately 50 feet from the point of origin.

For the release of ammonia originating outside of a building, the DOJ COPS Office assumed that 100 percent of the release (100kg) would be dispersed downwind from the point of release. ALOHA modeling results indicate that human receptors located in residential/commercial areas 50 feet from the point of origin would be exposed to an ammonia concentration greater than the ERPG level. Human receptors located 75 feet from the point of origin would be exposed to an ammonia concentration of 150ppm, equivalent to the ERPG level.

7. In this evaluated case:

1 gallon of Ammonia = 2.34kg or 2340g
2 gallons of Ammonia required for each pound of Methamphetamine Hydrochloride

5.76g of pseudoephedrine = 453.59g (1 pound)
59.43g of ammonia 4680g (2 gallons of ammonia)

59.43g of ammonia used for all 192 pills extracted at one time.

0.0594kg of ammonia = 100kg of ammonia
52.27ppm ammonia released 88,000ppm ammonia released in the air

52.27ppm of ammonia would have been present in the residence in the first 10 minutes of release which is well below the 150ppm ERPG level.

8. In conclusion, 192 pseudoephedrine pills of 30mg concentration would equate to 5.76g of total pseudoephedrine. The estimate yield for Methamphetamine production of the entire 5.76g is approximately 2.65g and the release of ammonia inside the residence would be less than the ERPG level of 150ppm therefore lending any neighboring residence considered to also be less than the ERPG level of 150ppm. The level of ammonia for this level of manufacturing would not pose an immediate health risk.

By 3rd Degree Investigations, Inc.
Chemistry Forensic Consultant and Expert Witness
Dana Way started her career working in a laboratory in 1989. While working as a Chemist for Commonwealth Laboratories and later for Roche Analytics Laboratories, she learned analysis and reporting, laboratory methods and procedures, method development, and worked with a variety of analysis instruments. Dana started a company called 3rd Degree Investigations in 2005. Since then her work as a defense expert has sent her across the country where she has testified in both state and federal criminal and civil courtrooms. Additionally Dana has acted as a consultant for federal and state law enforcement agencies.

Copyright 3rd Degree Investigations, Inc.

Disclaimer: While every effort has been made to ensure the accuracy of this publication, it is not intended to provide legal advice as individual situations will differ and should be discussed with an expert and/or lawyer.For specific technical or legal advice on the information provided and related topics, please contact the author.

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