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State Innovation Grants

EPA 2005-2006 State Innovation Grants Competition Pre-Proposals

Project Title
Auto Salvage Environmental Results Program

Indiana Department of Environmental Management (IDEM)

Project Contacts
Matthew Deaner
Quality Management Plan Coordinator, Office of Planning and Assessment
Indiana Department of Environmental Management
Indiana Government Center North
100 N. Senate Avenue
Indianapolis, IN 46206-6015
Phone: (317)-233-3187
Toll-free: (800) 451-6027 ext., 33187
E-mail: mdeaner@idem.in.gov

Other Federal Program Assistance
The project proposal is not executed with or funded by another Federal program.

Regulatory Flexibility Needs
The project does not require regulatory flexibility.

Approval of the project by the Commissioner
The Commissioner of IDEM, Thomas W. Easterly endorses this proposed innovative permitting effort for grant funding under the State Innovation Grant Program.


Past inspections have shown that air, land, and water violations are commonplace for Indiana auto salvage facilities (see Figure 1: Noncompliance rates for categorized violation classes (sample of 50 facilities)). The Indiana auto salvage sector has historically been a lightning rod for pollution complaints, netting over 100 auto salvage-related complaints per year. IDEM expends a great deal of resources in addressing these complaints. IDEM recognizes the need to address sector-wide environmental problems in a comprehensive manner.

IDEM is in the process of institutionalizing a past OECA-funded auto-salvage compliance pilot program. In building on this past effort, IDEM seeks to implement an integrated, results oriented approach to ameliorate the systemic and ubiquitous environmental problems associated with the auto salvage sector. IDEM is interested in transitioning the OECA-funded auto salvage pilot to an Environmental Management System (EMS), built using the Massachusetts Environmental Results Program (ERP) model. IDEM intends to expand on guidance / inspection materials and lessons learned from the past OECA grant, with an eye towards actuating sector-wide improvement in compliance and management practices using an ERP in concert with an aggressive, multimedia inspection regimen, with an innovative violation resolution model (See Figure 2: Inspection and Outcome Model). IDEM will benefit from learning innovative compliance methodologies such as ERP, and may extend the ERP approach to other regulated sectors.

IDEM's Auto Salvage ERP grant proposal has the following components: Database upgrade Facility self-certification Inspections
Inspections are performed by multimedia-trained staff from IDEM's Office of Land Quality. Staff are certified to issue regulatory citations on behalf of IDEM's Office of Air, Land, and Water quality. Statistically-derived performance measurement
IDEM will use guidelines and methodologies presented in "Generic Guide to Statistical Aspects of Developing and Environmental Results Program" EPA OPEI - April, 2003 Compliance workshops, and on-site pollution prevention and technical assistance.
Workshops held by IDEM Office of Pollution Prevention and Technical Assistance, using materials developed by IDEM Office of Land Quality and IDEM Office of Planning and Assessment. Program Criteria

This project is aligned with the following 2003-2008 EPA Strategic Goals: This project is aligned with the following Environmental Innovation strategic visions and goals:


Goals Likely Improvements from Project Implementation

IDEM's Auto Salvage ERP will improve management practices at auto salvage facilities and will address ubiquitous and persistent environmental problems arising from this sector. Monitoring of EBPI's and reduced pollution complaint rates will show a measurable improvement in land and water quality. How does the proposed tool or approach differ from traditional approaches? How does the project build on "lessons learned” from prior experience? What are the quantifiable improvements in environmental outcome expected?

Possible EBPI's What are the measurable improvements in administrative efficiency and program operational costs? What are the likely savings in costs and efficiency for permit holders and regulated entities? What are the public involvement processes that will be used to ensure public knowledge of and participation in the project?

The current auto salvage website has a comment form that will be used to request input from public and regulated community during program development stage. What factors will be taken into consideration in the design and implementation of the project as it relates to concerns in communities with environmental justice issues?

The Indiana Auto Salvage ERP project will reduce impact to environmental justice communities of concern, as salvage facilities tend to locate in close proximity to these areas. Guidance materials will raise public awareness of the environmental regulations salvage yards are subject to, giving environmental justice communities the knowledge they need to report violations. Measuring improvement and accountability What are the indicators of environmental improvement that will be used to show improvement, and is the relationship to the specified outcome goal clear? (Goal and objective measures should be both qualitative and quantitative and should assess the project’s measurable benefits.)

Please see What are the quantifiable improvements in environmental outcome expected?

The EBPI's in the aforementioned section are linked to the overarching goals of this program, which are mitigating air, land, and water environmental problems associated with the auto salvage sector. How and when will the baseline measurements be developed?

The baseline will be developed during the second quarter of 2006. IDEM will inspect, at a minimum, a statistically significant, random sample of facilities and will release a compiled report with the results. What is the plan, timeline, and commitment for measuring and evaluating how well the project meets its goals and objectives?

Project Schedule and Time Frame



Task Description



- Database upgrade

- Program development (develop EBPIs and supporting materials, develop Return to Compliance and Certification forms, expand on outreach materials, definition of high-level and low-level violations from Office of Enforcement.)

- Gather stakeholder/public comment.

- Multimedia inspector training



- Conduct baseline inspections. Analyze data.

- Conduct compliance workshops.

- Media campaign to encourage self-certification.

- Perform on-site compliance assistance (as requested).



- Implement program.

- Introduce ERP as viable alternative to traditional enforcement (for low-level violations)

- Enforce incorrect / misleading self-certifications

- Perform on-site compliance assistance (as requested).

- Perform targeted inspections.



Second round of survey inspections. Evaluate performance and report to EPA.



- Implement program.

- Enforce Return to Compliance Plans

- Enforce incorrect / misleading self-certifications

- Perform on-site compliance assistance (as requested).

- Perform targeted inspections.

- Develop long-term (non-grant) implementation plan.



- Evaluate success of program. Provide detailed report on web and to EPA.

- Offer all supporting materials to EPA and/or interested states.

- Examine applicability of ERP to other IDEM regulatory programs.


[Removed by EPA]

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