improving environmental performance of a targeted sector using multiple agency tools and resources
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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. - PowerPoint PPT PresentationTRANSCRIPT
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 Sectora 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 0Terre Haute - Chamber of Commerce 643 Wabash Ave. 4/ 29/ 03 7 0 0SWRO 5/ 7/ 03 2 3Fort Wayne - Chamber of Commerce at 826 Ewing Street 5/ 15/ 03 15 0 5Indy - Indiana Development Finance Authority @ One North Capitol 5/ 21/ 03 9 4 6NWRO 5/ 28/ 03 6 1 1Muncie - Ivy Tech Community College 4301 South Cowan Road 6/ 4/ 03 10 3 0NRO 6/ 11/ 03 11 5 1Monticello - Courthouse @ 100 Main Street, G2 6/ 18/ 03 17 7 2New Albany - Community Foundation @ One Commerce Square; 4104 Charlestown Road 47150 6/ 23/ 03 2 4 1Indianapolis - 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 added
55 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
FlyoversWhy?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 SummaryViolation Class Violation
CountPercent
Open dumping of garbage/debris 32 67Storm 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 inspectedOf 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
