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

Questions & Answers

Rosemary Cantwell

rcantwel@idem.IN.gov

317- 308-3003