Improving Environmental Performance of a Targeted Sector
Using Multiple Agency Tools and Resources
Indiana Auto Salvage Facility Sector Project
SUMMARY
- using what we had - taking advantage of
opportunities - to improve the environment
(one sector at a time)
Project Process
Project History
Available Grant Decision to use grant to develop a
prototype model for sector based activities
Prototype model was to be a continuum, beginning with universe identification and ending with environmental indicators
Project model needed to be “transparent” and “transferable”
Project History
The auto salvage industry was chosen to be the first focus sector.
Sector Choice
Why Auto Salvage
Choosing the Sector
a known problem - nature of complaints
- large number - received by various programs
within agency - diverse environmental issues - varied responses - limited resources - no easy solution - “hot” potato
Choosing the Sector Other Considerations and Concerns - size of the universe - available location data - concerns about facility’s response
- lack of money - mom & pop organizations - compliance = huge burden - no inspection history - abandonment and bankruptcy - State left with cleanup
Project Development
Three Major Phases
1. Compliance Assistance2. Inspections3. Enforcement
Compliance Assistance
Develop Database and Project Web Site
Develop and Distribute Various Guidance Materials/Compliance Manual
Develop Internal and External Agency Relationships/Partnerships
Provide Workshops
Compliance Assistance
Database development Web Site www.in.gov/idem/autosalvage CARS database (Compliance Activity
Reporting System) Incorporated BMV list of ASR sites Designed to track inspection and
enforcement information Designed to integrate with other internal
agency databases
Compliance Assistance Developed a multi-media
compliance manual Developed in-house through internal
agency workgroups Formatting, graphics within the agency Printing only was contracted
800 facilities - received a manual with cover letter
Compliance Assistance
Developed posters Developed mercury removal guides
All developed and designed in-house With additional pockets of money – OPPTA
Continually kept eyes open for additional funds and further opportunities to enhance project
Compliance Assistance
Developed Relationship with:
County and State Health Departments
Department of Natural Resources
Bureau of Motor Vehicles
Department of Labor (IOSHA)
Department of Revenue
County Commissioners Indiana State Police Facility Owners
Held 4 regional meetings with potential partners
Who we are What we are doing How can they help
Compliance Assistance
Conducted 11 Workshops Speakers within IDEM and from other
organizations (BMV, OSHA, ISDH) Attendees included:
102 industry 37 government (non-IDEM) 25 consultants
AUTO SALVAGE INITIATIVE WORKSHOP ATTENDEES
LOCATION DATE Industry Gov't (non-IDEM ) Consultants
Bloomington - SBDC at 216 West Allen Street 4/ 23/ 03 2 3 0
Terre Haute - Chamber of Commerce 643 Wabash Ave. 4/ 29/ 03 7 0 0
SWRO 5/ 7/ 03 2 3
Fort Wayne - Chamber of Commerce at 826 Ewing Street 5/ 15/ 03 15 0 5
Indy - Indiana Development Finance Authority @ One North Capitol
5/ 21/ 03 9 4 6
NWRO 5/ 28/ 03 6 1 1
Muncie - Ivy Tech Community College 4301 South Cowan Road 6/ 4/ 03 10 3 0
NRO 6/ 11/ 03 11 5 1
Monticello - Courthouse @ 100 Main Street, G2 6/ 18/ 03 17 7 2
New Albany - Community Foundation @ One Commerce Square; 4104 Charlestown Road 47150
6/ 23/ 03 2 4 1
Indianapolis - IGCS 7/ 23/ 03 21 7 9
Total 102 37 25
Inspections
Develop Targeting Criteria Select Facilities to Inspect Develop Inspection Checklist Select and Train Inspectors
Developing Targeting Criteria
5 Steps:1. Obtain Data2. Decide on Tools3. Spatial Analysis4. Scoring5. Corroborating list
Goal = 50
1. Obtaining Data Acquiring Data Sources
Bureau of Motor Vehicles tabular list Referrals internally Referrals from local law enforcement County health departments
Preparing the Data Address matching (when needed) Preliminary mail-out Importing data into Access Adding fields to use for GIS spatial
analysis phase
2. Tools GIS Layers ArcGIS Databases
CARS (Compliance Activity Reporting System) Targeting database
Online tools Terrafly Yahoo Lat/Long Converter
Tools GIS Layers – relative to targeting
Raster Topographical Map
of Indiana High-resolution
aerials
Sensitive Populations
Schools Hospitals Environmental Justice
areas
Impaired Areas Waste tire sites Impaired Waterways Open Dumping Sites LUST
Sensitive Areas Public Water Supplies Wellhead Protection
Areas Surface Water Intakes Wetlands Streams Exceptional Use Areas
3. Spatial Analysis Choosing Criteria
Primary Consideration: Public Health
Focus on urban areas Schools with public water
supplies Surface water intakes Proximity to public water
supplies
Spatial Analysis Analysis
Starting Point:All registered facilities Approx. 1,100
facilities
Schools & PWS wells
Objective: Select facilities within 1,000 ft from schools within 1,000 ft of a PWS well
Layer(s): Analysis was non-graphical; worked with schools layer and PWS wells layers.
Result: 4 “hits”
Schools & PWS wells
Spatial Analysis Analysis
Wellhead Protection Areas
Objective: Select facilities within 5-year TOT for WHP areas and/or within 3,000 feet from WHP areas
Layer(s): 5-year TOT, merged with 3,000ft bufferon WHP point data
Result: 68 “hits”
WHP Merged
Spatial Analysis Analysis
Surface water intake within 3,000ft.
Objective: Select facilities within 3,000 ft of a major surface water intake
Layer(s): Analysis was non-graphical; illustrating 3,000 ft buffer applied to surface water intake layer
Result: 9 “hits”
SW Intakes
Spatial Analysis Analysis
“Hits” 85 GIS targeted
facilitiesCriteria
Surface water intake; 3,000ft.
Wellhead Protection Areas; 3,000ft / 5-yr TOT
Schools & PWS wells; 1,000 ft
Spatial Analysis (cont.)Analysis
5. Corroborating list
More "Lookin' for a Fender" phone calls Some facilities no longer in business Some not salvage yards
Checking with local officials 10 more facilities added by referral Some facilities removed from list
Flyovers Two removed, two added55 Facilities
85 FacilitiesSTART
END
Result of Targeting 17/55 or 31% Based
on inspector, town, or local law enforcement referrals
36/55 or 65% Based on geospatial proximity to sensitive areas
2/55 or 3.6% added after spotting during flyover
Flyover
GIS Analysis
Referrals
Flyovers
Computer generated tools very useful, however flyovers gave “real time” view of the situation and provided the final information to complete targeting
Identified EPA (integrated strategies) grant
Worked with State Police
Flyovers
Why?1) Use during possible legal proceedings2) Visual confirmation3) Establish geographical extent 4) Get idea of general “ugliness” of facility5) Identify gross areas of contamination6) Visually confirm whether or not area was
adjacent to a waterway
Develop Inspection Checklist
Worked with sister agencies and EPA to develop a truly comprehensive multi-media compliance checklist
Evolved with use Includes: air, water, solid waste,
hazardous waste, OPPTA, BMV, DNR, OSHA, State and Local HDs, EPA
Select Inspectors
Commit resources outside of current job duties
Solicit support from other management groups
Commitment and Competency - people will make or break the project
Train Inspectors
Conducted one pilot inspection Tested inspection checklist
First 4-5 inspections Cross-trained with EPA Air Tested inspection checklist Included all inspectors
Enforcement Trained enforcement staff Developed enforcement referral
criteria Created clearinghouse for referrals All violations handled within one action Developed cleanup criteria (varied
depending on degree and extent) Stipulated penalties only ($500/wk per
order)
Enforcement
Results Of 48 inspections, 26 were referred to
enforcement 20 of 26 received formal action
Of 48 inspections, 4 in-compliance Of 48 inspections, 24 received
informal action
Enforcement
Results Of 20 formal actions
13 site assessments (heavy contamination)
12 remove visible contamination (minor staining plus 6 inches)
14 storm water 11 tire removals 1 open burning
Enforcement
Of 26 referrals 11 Final Orders (Agreed Orders) 1 Referral to AG 3 Complied/Case Closed
Violation Summary
Violation Class Violation Count
Percent
Open dumping of garbage/debris
32 67
Storm water 31 65Refrigerants 30 62Containers/labeling 30 62HW - dumping 29 60Tires 21 44Open Burning 10 21
Impact of Compliance Assistance on Compliance
Of 57 auto salvage facilities represented at the 11 workshops:
9 were inspected
Of those 9:
- 4 formal actions
- 4 informal actions
- 1 in-compliance
Additional Tools Press Releases
Went through different phases Press release naming facilities
receiving formal actions Spawned local news interest Resulted in:
Visible increase in # of complaints ASR reorganized Increase in # of phone calls requesting CA
Additional Tools
EPA/States ASR workgroup/conference calls
Shared information between states (FL, MN, WI, WA) Took States’ information into account
when establishing project Learned what to expect Learned from pitfalls
Lessons Learned Issues and Problems
Encountered
Lessons Learned When IT says it will take a year to get
a database up and running, believe them!
4 year grant terms are very beneficial! Creating a manual is incredibly time
consuming and difficult! Multiple internal and external agency
coordination is a BEAUTIFUL thing!
Issues Encountered
Took quite a bit of time for money to be conveyed from EPA to IDEM and then for IDEM to set up an internal fund center.
Internal workgroup participation could have been enhanced. It was limited at times by participant’s interest & heavy workloads…in the end all goals were met, however.
What’s Next Those involved convinced management not
to abandon 4 years of work and $10,000 spent.
Continuing to use model to address all auto salvage complaints within the agency
Established partnership with BMV to continue to help them identify illegal operations
Establishing partnerships with County Health Departments to address ASRs within their County utilizing the same basic model
What’s Next
Utilizing one section within one office to conduct all ASR inspections
Most violations continuing to be addressed through one action
Continuing work with OPPTA, MACs on compliance assistance