Improving Environmental Performance of a Targeted Sector Using Multiple Agency Tools and Resources

1. Improving Environmental Performance of a Targeted Sector Using Multiple Agency Tools and Resources Indiana Auto Salvage Facility Sector Project

2. SUMMARY • - using what we had • - taking advantage of opportunities • - to improve the environment (one sector at a time)

3. Project Process

4. 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”

5. Project History The auto salvage industry was chosen to be the first focus sector.

6. Sector Choice Why Auto Salvage

15. 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

16. 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

17. Project DevelopmentThree Major Phases Compliance Assistance Inspections Enforcement

18. 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

19. 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

20. 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

21. 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

22. 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

23. 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

25. Inspections • Develop Targeting Criteria • Select Facilities to Inspect • Develop Inspection Checklist • Select and Train Inspectors

26. Developing Targeting Criteria 5 Steps: • Obtain Data • Decide on Tools • Spatial Analysis • Scoring • Corroborating list Goal = 50

27. 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

28. 2. Tools • GIS Layers • ArcGIS • Databases • CARS (Compliance Activity Reporting System) • Targeting database • Online tools • Terrafly • Yahoo • Lat/Long Converter

29. 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 Tools GIS Layers – relative to targeting • Sensitive Areas • Public Water Supplies • Wellhead Protection Areas • Surface Water Intakes • Wetlands • Streams • Exceptional Use Areas

30. 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

31. Spatial Analysis Analysis Starting Point:All registered facilities • Approx. 1,100 facilities

32. Spatial Analysis Analysis 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”

33. 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”

34. 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”

35. Spatial Analysis (cont.)Analysis “Hits” • 85 GIS targeted facilities Criteria • Surface water intake; 3,000ft. • Wellhead Protection Areas; 3,000ft / 5-yr TOT • Schools & PWS wells; 1,000 ft

36. 85 Facilities 55 Facilities 5. Corroborating list START • 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 added END

37. 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

38. 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

39. Flyovers Why? • Use during possible legal proceedings • Visual confirmation • Establish geographical extent • Get idea of general “ugliness” of facility • Identify gross areas of contamination • Visually confirm whether or not area was adjacent to a waterway

43. 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

44. 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

45. Train Inspectors • Conducted one pilot inspection • Tested inspection checklist • First 4-5 inspections • Cross-trained with EPA Air • Tested inspection checklist • Included all inspectors

46. 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)

47. 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

48. 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

49. Enforcement • Of 26 referrals • 11 Final Orders (Agreed Orders) • 1 Referral to AG • 3 Complied/Case Closed

50. Violation Summary