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State Innovation Grants

EPA 2005-2006 State Innovation Grants Competition Pre-Proposals

Nevada Environmental Results Program (NVERP) Pre-Proposal

The Nevada Division of Environmental Protection (NDEP) proposes to replicate and further evaluate the dry cleaning environmental results program (ERP) developed by Massachusetts, and being implemented in Michigan. The State seeks to further innovate on the ERP and demonstrate a new application of the dry cleaner ERP by engaging local single media agency programs in an integrated multi-agency multi-media ERP. The project will provide the state and local agencies with experience in developing and implementing an ERP and in multi-agency collaboration to address improvement of environmental regulation and environmental performance of a particular sector. The ERP that NDEP proposes will involve the Nevada Small Business Development Center (NSBDC) Business Environmental Program ( BEP) working with the state and local environmental programs to establish a baseline (through a statistical sampling inspection methodology) of drycleaner environmental compliance and performance, outreach and assistance to dry cleaners, a multi-media self-certification program for dry cleaners, and follow-up assessment that measures and reports improvements in dry cleaner compliance and environmental performance in the metropolitan areas of Reno/Sparks in Washoe County, and N. Las Vegas/Las Vegas/Henderson in Clark County, Nevada. The ERP will address regulatory requirements established under the Resource Conservation and Recovery Act (RCRA), the Clean Water Act (CWA), and the Clean Air Act Amendments (CAAA).

Timeline:

A project period of three years is proposed in order to establish baseline, self-certification, and post certification metrics and to recruit participation in the program to achieve measurable results.

Year One:

Washoe Co.:

Clark Co.:

Year Two:

Washoe Co.:

Clark Co.:

Year Three:

Washoe Co.:

Clark Co.:

Year Two or Three:

Reporting:

Quarterly reports will be provided throughout the project. Reports will include activities conducted, participation in focus/workgroups/workshops, and materials developed, as interim surrogate measures of performance. Data collected from the base-line and post-certification inspections, and self-certifications will be reported as it is collected and compiled, and quantitative estimates of environmental outcomes are calculated.

Roles and Responsibilities:

NDEP will serve as the lead Agency, grant recipient, and administrator.

Through establishment of a sub-grant inter-local agreement between NDEP and the NSBDC- BEP, University of Nevada, Reno (UNR), BEP will:

 

Local agencies will participate in the project through:

NDEP will:

Target Priority Environmental Issues:

The population of Nevada is predominantly urban and concentrated in the metropolitan areas of Reno/Sparks in Washoe Co. and Las Vegas/Henderson in Clark Co. Eighty-seven percent of Nevada’s population resides in these two counties. These areas are selected for the ERP implementation because dry cleaners are concentrated in these communities, and they are subject to regulation from local POTW pretreatment programs, local air quality management programs, and hazardous waste management programs of the district health departments. Over the past several years dry cleaners have become a focus of NDEP and local agencies in Washoe County. The State legislature established a remediation district in Washoe County with a tax assessment that is used to investigate and remediate historic PCE contamination of groundwater in the Truckee Meadows. The remediation fund is for historic contamination and sewer sampling in the area has found elevated levels of PCE in sewers downstream of dry cleaners (similar concerns about PCE contamination near primary sewer lines in Clark County also exist). The attention to the dry cleaning sector that resulted from this has resulted in the local agencies working together in seeking to improve environmental performance of the dry cleaners in order to protect groundwater from potential contamination. This provides a unique opportunity to build on the state ERP experiences of MA and MI, and undertake strategic innovation to develop a locally implemented ERP in Washoe County and to utilize the process and lessons learned from the Washoe Co. ERP to develop a similar multi-agency, multi-media program in Clark Co. It is anticipated the baseline compliance rate in Washoe County will be higher than Clark County based on the attention to dry cleaners that has occurred there to date. If this is correct, the compliance and environmental outcome of the ERP in Clark County is expected to be greater.

The proposed ERP is aligned with EPA’s Innovation Strategy addressing the priority areas of maintaining water quality by preventing the contamination of drinking water, addressing concerns of PCE contamination from sewer lines, and the development and demonstration of an environmental results program that is designed to use outreach, education, assistance, and self-certification to improve multi–media environmental performance across the dry cleaning sector, as an alternative to permitting, to produce superior results to conventional approaches to environmental control. The ERP objective of improved multi-media compliance and environmental performance is aligned with EPA’s Strategic Plan in the following areas:

Goal 1: Clean Air and Climate Change

Sub Objective 1.1.2: Reduced risk from Toxic Air Pollutants.

Goal 2: Clean and Safe Water

Objective 2.1: Prevent Contamination of Sources of Drinking Water, and

Objective 2.2: Protect Water Quality.

Goal 3: Land Preservation and Restoration

Objective 3.1: Reduce adverse effects to land by reducing waste generation, increasing recycling, and ensuring proper management of waste and petroleum products.

Goal 4: Healthy Communities and Ecosystems

Sub Objective 4.1.4: Protect human health, communities, and ecosystems from chemical risks and releases through facility risk reduction efforts .

Goal 5: Compliance and Environmental Stewardship

Objective 5.1: Improve compliance.

Objective 5.2: Improve environmental performance through pollution prevention and innovation.

Improvements in Results from Project Implementation:

The ERP will be implemented by leveraging the extensive environmental compliance and pollution prevention experience that has been developed through the partnership program that BEP has implemented with NDEP since 1988. Through this NDEP funded partnership, and with additional pollution prevention grant funding provided by EPA, BEP has developed experience, expertise, and an environmental assistance delivery infrastructure for the State of Nevada. NDEP will provide sub-grant funding to BEP to coordinate implementation of the program and undertake development of quality assurance, compliance assistance, self-certification, multi-media inspection materials and outreach and training associated with the ERP. BEP will also propose draft Environmental Business Performance Indicators (EBPIs), for review and approval by NDEP and participating local agencies, and for use as additional performance indicators for the ERP.

BEP will engage NDEP, local participating agencies, and representatives of the dry cleaning community in a review and finalization process for the ERP materials developed. BEP will deliver training on environmental compliance/pollution prevention/best management practices (based on the content developed in the compliance manual), compliance self-certification, multi-media inspections, EBPIs, and the overall ERP objectives to the dry cleaners, and participating agency representatives in the Washoe and Clark County metropolitan areas. BEP will issue press releases and pursue media coverage to engage and inform the communities with information about the project.

Dry cleaners will be involved in the process as primary stakeholders. Several have already indicated their intention of participating if funding is awarded. Dry cleaners expect to benefit from greater certainty of their compliance requirements and knowledge of best management practices. They expect to also benefit from the ability to inform their customers of the ERP, and their participation in it. The results of the ERP will allow information about the sector’s compliance and environmental management practices to be communicated to the public which is expected to benefit the public, dry cleaners, and the regulatory agencies. Community representatives from the Truckee Meadows and Southern Nevada Water Authorities and local chambers of commerce will also be invited to participate in the stakeholder focus groups. The project will seek to promote the dry cleaner ERP in the community and encourage consumer consideration of participation in the ERP when obtaining dry cleaning services. Press releases will be issued and media coverage of the ERP events, such as the training workshops, will be sought.

Measuring Improvement and Accountability:

The Nevada ERP will measure improvement in compliance and in EBPI scores from baseline to post-certification inspections, and establish a framework in which dry cleaner performance can be tracked in future years after the grant funding ends. In addition, the program will utilize the approach developed in Massachusetts in which quantifiable environmental outcomes are estimated based on quantities of emissions prevented through improvement of compliance or best management practices. For instance, in dry cleaning, improved compliance in leak detection requirements can be used to estimate a reduction in quantity of PCE emitted to the air. Increased adoption of best management practices for waste waters can prevent soil and groundwater contamination. The baseline and post-certification inspections will collect the data necessary to measure the compliance improvement, and estimate quantitatively the environmental outcome of the ERP. A goal of a 25% increase in environmental compliance and 20% increase in best management practices as determined by EBPI scores is established. The level of improvement that is measured in Washoe County may be lower due to outreach work that has already been done with the dry cleaning community. This is uncertain, and the Washoe Co. and Clark Co. results will be compared.

The project will measure improvements in compliance and best management practices, and provide quantifiable estimates of emissions that were prevented. Baseline measures will be developed in the first year of the project in Washoe County and in year two in Clark County. Baseline and post certification measures of compliance rate and environmental performance will be achieved during the project implementation. A framework for continuing to assess and measure dry cleaner performance after the grant project will be established.

Transferring Innovation:

BEP will take the lead role in coordinating and sharing information with other states implementing ERPs and engaged in EPA’s Innovation Strategy efforts. In addition, BEP is responsible for the Western Regional Pollution Prevention Network (WRPPN), a strategic alliance of Region 9 pollution prevention programs, and one of eight national EPA funded Pollution Prevention Resource Exchange (P2Rx) Centers, that facilitates communication among, and convenes pollution prevention programs in Arizona, California, Hawaii, and Nevada. BEP is uniquely positioned to leverage the EPA and matching funds invested in WRPPN to disseminate ERP information to Network participants in Region 9 and to other P2Rx centers. Many local agencies are delegated responsibilities for implementing environmental regulatory programs in the Region 9 states, and the local agency ERP model developed through this project is anticipated to be particularly applicable to them.

In addition, to share information among state programs implementing ERPs and to allow programs in the western U.S. to learn more about ERP implementation, Nevada proposes to host a meeting of state ERP programs and those interested in ERPs during year two or three of the project (timing to be determined based on discussions with the National Center for Environmental Innovation (NCEI)). Participant support funding is included in the proposal to provide travel support funding for some of the meeting attendees.

The dry cleaning ERP will provide NDEP with an opportunity to pilot this innovation in Nevada, gain experience, and assess opportunities to apply the approach to other sectors. Opportunities exist to apply ERP in Nevada to additional sectors in which the benefits of the statistical sampling approach and self certification protocol could provide substantial administrative efficiency and cost benefits to both NDEP and the regulated community. Additional opportunities for duplication and innovation upon this approach in the western U.S. are substantial.

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