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Police protection involves law enforcement, traffic safety, police, and other activities related to law enforcement and preservation of order. Local governments have primary policing responsibilities, rather than states or the national government.
A municipal police department has four basic units:
· Patrol. A patrol officer is responsible for investigating compliances, reporting accidents, making arrests, and trying to maintain peace and order.
· Investigative/detective force. The investigative/detective force concentrates on specialized work involved in the detection and apprehension of criminals (e.g.,vice, intelligence, narcotics, homicides, bomb threats).
· Traffic regulation. Traffic regulation involves traffic control, engineering, and enforcement.
· Crime prevention. Crime prevention unit often works with the investigative unit, and focuses on youth investigation, safety education, and other evidence collection and identification activities.
To support the above units, police departments may conduct several activities that have the potential to impact the environment and are regulated under U.S. environmental laws and regulations. Two of these activities are the development of photographs (e.g., photoprocessing) from arrests and shooting range practice conducted at either police department or publicly-owned facilities. More detail on the specific activities and the respective regulations are presented below:
· Activities with aspects regulated under RCRA:
- Photoprocessing hazardous waste storage and disposal
- Solid wastes from photoprocessing (RCRA Subtitle D)
- Disposal of bullets/bullet fragments
· Activities with aspects regulated under RCRA/CERCLA:
- Lead-contaminated soil from shooting ranges
· Activities with aspects regulated under the CAA:
- Emissions from photoprocessing chemicals
- Lead dust releases
· Activities with aspects regulated under the CWA:
- Wastewater from photoprocessing
· Activities with aspects regulated under EPCRA :
- Lead dust releases.
Photoprocessing
Police departments may have their own photoprocessing lab or contract out this activity to a commercial photoprocessing laboratory. The processing of photographic film requires the use of various chemicals to develop and produce finished goods. The photosensitive medium used for black and white processing is an emulsion of fine silver halide crystals in a matrix of gelatin, which is applied in a thin layer on either paper or clear plastic film. The film used for color photography consist of three separate layers of photosensitive emulsion with intermediate layers which are coated on a clear film base. Each emulsion is sensitive to either red, green, or blue light due to the presence of selective dyes in the emulsion.
The wastes generated from photoprocessing vary widely according to the type and volume of processing. Exhibit 49 presents examples of typical photoprocessing wastes.
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Exhibit 49. Examples of Typical Photoprocessing Wastes | |||
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Wastewater |
Hazardous Waste |
Air Emissions |
Solid Wastes |
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- Used, treated fixers
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- Chrome-based system
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- Volatile organic
-- Film cleaners
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- Empty containers
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Wastes resulting from the photoprocessing process are primarily aqueous effluents. Disposal of wastewater from photoprocessing may be regulated under the pretreatment or NPDES section of the CWA. Photoprocessing solutions may be too acidic or alkaline to meet local wastewater discharge limits. Fluids disposed or spilled in floor drains or otherwise released from the facility property, are regulated under the NPDES, pretreatment, or storm water provisions of the CWA. These provisions require notification of EPA, the state, or a local treatment plant, complying with permit provisions, and prevention of untreated fluids from reaching surface waters. The storage and disposal of hazardous wastes (e.g., non-empty aerosol cans; discarded, unused or outdated chemicals; solvent-contaminated rags) are regulated under the hazardous waste provisions of RCRA. The disposal of solid wastes (e.g., empty containers, packaging materials) are regulated under the solid waste provisions of RCRA. Air emissions from the various chemicals used in photoprocessing (e.g., volatile organic compounds or toxics emitted from film cleaners, solvents) may be regulated under the CAA.
Firing Ranges
Most police departments require their police officers to practice firing accuracy at local indoor or outdoor firing ranges. If conducted at outdoor firing ranges, this activity may potentially impact the environment by contaminating the soil (and possibly the groundwater) with lead from the birdshot, bullets, and bullet fragments, and producing airborne lead dust.
Despite the likely contamination, EPA's current position is that the deposition of lead from lead shot, bullets, and bullet fragments at firing ranges is considered to be within the normal and expected use pattern of the manufactured product and the resultant contamination is not subject to the RCRA regulations. The bullets and bullet fragments are not characterized as "hazardous wastes" because they have not been discarded. However, where an imminent and substantial endangerment to health or the environment may have been created by expended shot or debris, remedial requirements may apply under RCRA. In addition, the remediation of lead-contaminated soil at a firing range, either for maintenance or site closure, is regulated under the hazardous waste provisions of RCRA and/or CERCLA. Under the reporting provisions of EPCRA, fire ranges must report releases of lead dust transported by the wind. A release is reportable when more than one pound of lead particles smaller than 0.004 inches in diameter is released beyond the boundaries of the site/facility.
Notwithstanding the above, EPA encourages the use of alternative approaches that ranges can take to reduce the possibility of lead contamination. These include the installation of devices that can intercept and collect the shot and bullets for recycling, and substituting less hazardous materials (e.g., plastic and steel shot) for the lead shot. To reduce and/or eliminate lead pollution, many indoor and outdoor firing ranges use bullet "traps." Bullet traps have a rubber media which capture bullets and contain them, as well as a filter system that eliminates airborne lead dust. These traps prevent the lead pollution of air and soil which would normally occur from bullet impact with metal, sand, or the ground. Most local firing ranges hire salvage companies to recover, clean, and recycle the bullets traps and filter systems. The disposal of bullets and bullet fragments recovered from a bullet trap may be regulated under the hazardous waste provisions of RCRA.
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