One Game, Three Players and Everyone Wins

Automotive Salvage Yards

Sara J. Johnson, M.S.Sara.Johnson@des.nh.gov

603-271-6460N.H. Department of Environmental Services

Pollution Prevention ProgramMay 2008

National Environmental Partnership Summit

Agenda

History of auto salvage outreach and strategy

Legislative changes Transition phase Recognition program Measurement Future plans

1999- 2002:Auto Salvage Becomes Priority

Became clear auto salvage industry needed attention…• Frequent complaints--Air, Water, & Waste Violations

• Many contaminated sites due to spills / leaks—MtBE, etc.

• Regulatory confusion--both internal & external; “who does what?”

• Lack of environmental awareness within the industry

At the same time, unlined landfill closure program was starting to wind down…• Seen as an opportunity to eventually shift resources to new

sector

• DES began designing program to improve environmental performance at auto salvage yards

Step #1: Stakeholder Workgroup Industry Representatives

• N.H. Auto and Truck Recyclers Association• Auto / Scrap Metal Shredder Industry• N.H. Auto Dealer Association• N.H. Towing Association

Town Government• N.H. Municipal Association

State Government• N.H. Department of Safety• N.H. Department of Transportation• N.H. Department of Environmental Services

• Various programs—Air, Water, Waste

Step #2: Industry Fact Finding Random site visits throughout the state

• Large & small operations• Rural, suburban and urban

Baseline questionnaire in 2002• Gathered data re: scope of activities, size, typical work practices• 95% return rate• Built a rough profile of NH Facilities

Other research—• Existing applicable regulations• Industry economics• Information from other States• Contaminated sites info• Stakeholder Work Group input

Profile of Typical N.H. Facility

Variety of yards • Sell used parts

• Sell scrap metal

• Used car dealers

• Repair vehicles

• State inspection stations Family owned

• Passed down to the next generation “One man operations” to 25 employees Modest Profits Poor work practices, for example…

25% – 30% reported they dismantledvehicles outside over bare ground

Less than 15% reported using leak containment systems for fluid storage.

Less than 10% reported protecting theground when crushing.

Over 75% reported improperly stored tires

Obstacles to Achieving Results Lack of Effective Communication

• Literacy issues• No Internet • Jargon: “Bureaucracy Speak” vs. “Industry Speak”• Lack of Trust (2-way)

Generational Issues / Resistance to Change Lack of Environmental Awareness / Stewardship Lack of Resources / Funds “Unfair Competition” / “What’s in it for me?” Dismantling can be physically challenging Regulatory Confusion (State Local)

Step #3: Two Phase Strategyto Overcome Barriers

Phase I—Education & Technical Assistance• Goal: Improve environmental awareness & understanding

• Develop and teach Best Management Practices

• Guide sheets, videos, workbooks, postcards, other tools

• Training Workshops—operators, town officials, consultants

• BMP “White Hat” inspections / On-site P2 technical assistance

Phase II—Compliance Assurance• Goal: Shift burden for compliance from DES to facility owner

• Owner self-inspects & certifies compliance, using workbook / checklist

• Random inspections by DES of some, but not all facilities

• Enforcement / Penalties—Strategy is “make it visible”

• Create incentive for going beyond-compliance, i.e. recognition as a Certified N.H. Green Yard

The Best Laid Plans…derailed 2002—Massive staff reduction in SW Program

• New Governor / served only 2 years

• Left no staff to implement program as planned

• Limped along slowly with Phase I

Recent Legislation• 2007---Requires Town Officials to have operators certify

compliance with BMPs when applying annually for a local “License to Operate a Junkyard” (effective since 1965)

• 2008---Requires DES to establish a General Permit for Auto Salvage Yards and Auto Crushers• Permit conditions = BMPs

• Process similar to federal Storm Water Permitting Process

One Game, Three Players

Game has stayed the same---• Reduce spills and improve compliance

• Mercury switches

• Save money and resources

• Recognize the value of the industry But Players have expanded---

• New three way partnership1. State DES2. Salvage Yard Operators3. NEW: Town Officials

Will It Work? Who wins? Time will tell ---we’re in a transition phase Opportunity for players to pool & leverage limited resources

• DES lacks of resources to inspect and enforce

• Town officials can help monitor conditions & screen complaints

• Facility Operators are now accountable to both DES & Town

• Everyone is talking… Need to educate & inform local officials & facility operators:

• Municipal officials• NH Municipal Association

• Local Licensing Workshops – 6 in 2007 and 8 in 2008

• Salvage Yard Operators• Environmental Rules & BMPs

• Benefits of establishing SOPs & being Green

Measurements

Monitoring Well Samples – MtBE• Facility (Kingston): Sept ‘05 436 ppb to Sept ‘06 7 ppb

• Facility (Goffstown): Oct ’02 69 ppb to June ’06 <1 ppb

• Facility (Pelham): Aug ’01 150 ppb to June ’06 <3 ppb

Mercury switches• Started voluntary state collection program in 2003

• National collection program started in 2007

• 7,558 switches = 16.65 lbs

Measurements 20 yards became N.H. Certified Green Yards in

2006 during pilot program

• Processed 13,970 vehicles

• Reused or recycled

• 69,850 gallons of gasoline

• 13,970 gallons of oil

• 13,970 gallons of antifreeze

• Did not discharge to ground or contaminate ground water

Re-visited yards in 2007

• Results were disappointing

• Backsliding – non-compliance with BMPs

Measurements After 3 years of outreach, DES inspected 180+ facilities ’05 – “06

Evaluated compliance with BMPs in 9 major categories: Fluid Management Greasy Oily Parts Storage Battery Management Scrap Tire Management Freon / Refrigerant Recovery Wastewater Discharge Crushing Practices Site Control /Housekeeping

Other Concerns

Despite some big improvements since 2002 baseline survey:• Less than 15% are compliant in all categories• Less than 35% are compliant with fluid management BMPs• In remaining 8 categories viewed separately, there is 70+% compliance

Data shows some are doing a good job with some BMPs, but very few are doing a good job with all BMPs

Future Plans

N.H. Department of Environmental Services• P2 Program is shifting to new sectors

• Enforcement is current focus

• Seeking resources to develop sustainable on-line interactive BMP training program for all players

N.H. Auto and Truck Recyclers Association• Encouraging 3rd party certification

N.H. Municipal Association• Encouraging annual workshops for municipal officials