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New Hampshire
Project Summary
Project Title
N.H. Green Yards ERP Initiative for Auto Recyclers: Phase II
Project Location
New Hampshire
Applicant
N.H. Department of Environmental Services
Project Contact
Pamela H. Sprague, P.E.; N.H. Department of Environmental Services; 29 Hazen Drive; P.O. Box 95; Concord, NH 03302; Phone: (603) 271-2938; Fax: (603) 271-2456; Email: psprague@des.state.nh.us
Hazardous Waste / RCRA Component
This project is a cross-media project designed to help auto recyclers achieve compliance with the full range of environmental regulations applicable to their industry sector, including RCRA C hazardous waste generator and other requirements.
Other Federal Funds
No federal funds or federal partnerships currently exist for executing Phase II of the N.H. Green Yards Program. However, pending at this time is an application by the N.H. Green Yards Program for $33,400 from the N.H. Department of Environmental Services Watershed Assistance Grant Program using funds from the U.S. Environmental Protection Agency (EPA) under Section 319 of the Clean Water Act. The requested funds are to cover certain publication and training costs that are not budgeted under this Innovations Grant application and, at this time, have no other funding source . A decision on the Section 319 grant application is expected during January 2004.
Note: Phase I of the N.H. Green Yards Program, which is currently ongoing, is supported in part by funds received from a 2002 Watershed Assistance Grant ($38,000 to cover printing and distribution costs of certain educational materials).
Regulatory Flexibility Requirements
Implementation of this project does not require any special regulatory flexibility.
Management Support
The Commissioner of the N.H. Department of Environmental Services endorses the project.
Pre-Proposal Summary
Scope
The scope of the proposed project is to finish developing and then implement Phase II of the N.H. Green Yards Program. The N.H. Green Yards Program is an Environmental Results Program (ERP) designed to improve environmental practices at motor vehicle salvage yards (MVSYs) in N.H. The N.H. Department of Environmental Services (DES) is implementing the program in two phases, as follows, with performance measurement activities spanning both phases:
- Phase I: Education and Compliance Assistance
- Phase II: Environmental Self-Audit and Compliance Certification.
An overarching principle of this project is to develop the performance measurement tools in a manner that builds the agency's capacity to use statistical tools, to sustain the N.H. Green Yards Program beyond the term of this grant and to expand the use of ERP to improve environmental practices in other industry sectors in N.H.
Target Group
The term "MVSY" is used to generally describe facilities that handle and dismantle end-of-life vehicles (ELVs) for parts reuse and scrap material recycling. The N.H. Green Yards Program targets MVSYs that dismantle or crush 12 or more ELVs yearly and/or keep 25 or more ELVs longer than 60 days. Approximately 200 such facilities have been identified in New Hampshire, the majority of which are "Mom & Pop" scale operations involving fewer than 2 employees, less than 5 acres of land, and an annual through-put of fewer than 500 ELVs.
Project Background and Description
The work performed at MVSYs has made motor vehicles the premier recycled consumer product in this country. While MVSYs deserve credit for their significant contributions toward conserving natural resources and reducing the demand for landfill space, experience demonstrates that poorly operated MVSYs also cause serious adverse environmental impacts. For example, MVSYs handle a number of fluids that can contaminate groundwater, surface water, and soils when improperly managed (e.g., fuel, motor oil, lubricants, anti-freeze, and solvents). MVSYs also handle a range of other hazardous substances, including mercury (found in light switches, ABS brake systems, HID head lamps, and navigational/entertainment system display screens); sodium azide (an air bag propellant); lead (found in wheel weights and lead acid batteries); chlorofluorocarbons and other air conditioning system refrigerants; sludge from oil/water separators; and other process wastes.
Based on a recent survey conducted by DES, vehicles are reportedly being dismantled out in the open, over bare ground at over 25 % of all MVSYs in N.H. This practice, and others reported by the survey, suggests serious environmental consequences. Due to a growing concern that many MVSYs may not be operating in full compliance with environmental regulations and the operators may be unaware of best management practices (BMPs) for pollution prevention, DES recently established the N.H. Green Yards Program. The program incorporates many ERP characteristics and is being implemented in two phases. (See Figure 1, next page).
Phase I, launched in February 2003, is scheduled to be completed during the 3 rd quarter of 2004. During Phase I, DES is providing education and compliance assistance to MVSY operators to introduce them to regulatory concerns and processes, and prepare them for Phase II. The assistance is being delivered in the form of BMP guide sheets and training videos, regional information meetings and workshops, and non-regulatory, confidential on-site technical assistance by the DES Pollution Prevention Program. Also during Phase I, DES will adopt rules for mandatory compliance certification, to serve as the basis for implementing Phase II.
In Phase II, MVSY operators will audit their facilities for compliance with state and federal environmental requirements, and either submit compliance certification or a "return-to-compliance" plan, as applicable. To assist operators with this process, DES will provide a workbook and compliance checklist, and also will offer training workshops at various locations across the state. Some of these tools are already partially developed.
During both Phase I and Phase II, DES will track a number of environmental business practice indicators (EBPIs) to measure performance and assess the relative degree of influence the Phase I and Phase II interventions have on improving environmental practices at MVSYs. Although the tools for measuring performance are largely undeveloped at this time, raw baseline data is available from a questionnaire DES distributed to MVSY operators in August 2002 before launching Phase I. Over 90% of the operators responded to the questionnaire, providing broad information about facility size; vehicle storage, dismantling and crushing practices; fluid management methods; parts and scrap management practices; storm water management practices; the status of certain local, state, and federal permits, etc. This information is currently compiled in an Oracle database, to be verified and used in later stages of this project. See also Figure 1, below.
Stakeholder Involvement
DES developed and is implementing the N.H. Green Yards Program in consultation with a stakeholder advisory group comprised of industry representatives, local government representatives, and a broad cross section of state government interests.
Project Schedule and Time Frame
Phase II is scheduled to begin during the 3 rd quarter of 2004, and will require 24 to 36 months to complete.
Program Criteria
Target Priority Environmental Areas: The goal of the N.H. Green Yards Program is to improve environmental practices at MVSYs within an integrated (cross-media) framework. Thus, the proposed project directly addresses each of the priority environmental issues identified in the EPA Innovation Strategy, as follows:
- Greenhouse gas reduction : Addressed in part through proper management of refrigerants from ELV air conditioning systems.
- Smog Reduction: Addressed in part through: 1) reduction of mercury at smelters by removing mercury-containing vehicle components at MVSYs; 2) control of aluminum sweat furnaces; and 3) promoting the use of clean cars and preparing MVSYs to support their use by providing related recycling/reuse services.
- Water Quality Maintenance and Restoration : Addressed through proper management of the many water pollutants associated with ELVs (e.g., hydrocarbons, heavy metals, acids, suspended solids, MtBE, etc.).
- Water Infrastructure Gap Closure : Addressed in part through: 1) closure of illegal floor drains and compliance with other waste water discharge requirements; 2) installation of closed wash water systems and other water conservation measures; and 3) installation of oil / water separators and other waste water treatment systems, where appropriate.
Likely Improvement in Results from Project Implementation:
- How does the proposed tool or approach differ from current methods (i.e. "uniqueness")?
- It uses ERP concepts for the first time to address MVSYs on a statewide basis with mandatory compliance certification.
- It builds on the standard ERP framework, by expanding it to include a distinctly separate and intensive education and compliance assistance component (Phase I).
- It assesses the impact of specific interventions by measuring performance at strategic project milestones, as shown in Figure 1 on page 4, (i.e., pre-Phase I implementation, post-Phase I/pre-Phase II, and post-Phase II). Other ERP states have wanted to understand the relative effectiveness of different interventions, but have not been able to separate the effects of various ERP interventions. By separating different interventions into different project phases, this project will offer important clues about what techniques work best in improving compliance at MVSYs.
- It develops performance measurement tools that: 1) build agency capacity to use statistical tools; 2) address the statistical challenges of measuring performance among a relatively small group of facilities; and 3) are effective for small "Mom & Pop" scale businesses.
- How does the project build on "lessons learned" from prior experience (not limited to the proposing State's own experience)?
- From prior experience with its solid waste permitting program, DES knows that it is very resource intensive to bring groups of existing facilities into compliance by requiring the operators to retroactively obtain traditional "command and control" permits. This is so, in part, because 1) there is no "buy in" by the affected group, and 2) the amount of paperwork required to support the permit application and permit maintenance system often becomes a barrier to performing the actual work that needs to be done to achieve compliance. DES has applied this lesson to developing the N.H. Green Yards Program. The program seeks to achieve better, more sustainable results by 1) teaching and promoting environmental stewardship (Phase I) and 2) streamlining regulatory processes and paperwork by using self-certification and statistical verifications as a substitute for issuing and maintaining permits (Phase II).
- The N.H. Green Yards Program incorporates lessons learned from and tools used by other states that have previously addressed environmental concerns at MVSYs, including MN, VT, FL, ME and CA.
- DES actively participates in conference calls of the National Auto Recycling Industry Compliance Assistance Workgroup, sponsored by EPA. The information shared during those calls is regularly used to develop, support, and refine the N.H. Green Yards Program.
- The N.H. Green Yards Program also is building on the experience, materials, and tools that other states and EPA have developed in designing and implementing ERPs. For example, DES intends to develop the performance measurement tools for the proposed project in consultation with an expert contractor that has ERP experience and can incorporate related "lessons learned".
- What are the quantifiable improvements in environmental outcomes expected to result from implementation of this innovation? The goal of the proposed project is to improve environmental practices at MVSYs for the purpose of protecting air, water and soil quality; reducing solid and hazardous waste generation; conserving natural resources; and protecting public health. Improvements will be measured using specific EBPIs that can be rationally linked to specific environmental outcomes. DES has tentatively selected 13 such EBPIs and compiled the related baseline data. For example, we know that prior to the start of Phase I, over 25% of all MVSYs in N.H. claimed to be dismantling vehicles out in the open, over bare ground. This practice is linked to groundwater, surface water, storm water, and soil contamination, and must be discontinued in order to meet the program goal. Thus, DES will track the number of facilities that discontinue this practice by the end of Phase II and will examine which interventions were most effective toward changing the behavior. Similar quantification will occur for all other selected EPBIs, and the information as a whole will be further used to evaluate overall industry performance and project successes/failures.
- What are the measurable improvements in administrative efficiency and program operational costs that may result from the program? DES expects the proposed project to require fewer personnel to administer and fewer operational resources to implement than would be needed to apply a more traditional "command and control" permit system / compliance inspection approach. For example, all of the work completed to date on this project has required less than 1.5 (largely state-funded) FTEs, over a two-year period. This is significantly less than the FTE requirements that might be normally needed to assure compliance at 200 facilities under the more traditional permitting and facility inspection system. Over the life of the project, the actual efficiencies and savings can be estimated by comparing the actual ERP program costs to the estimated costs of processing permit applications for and regularly conducting compliance inspections at the 200+/- target facilities.
- What are the quantifiable costs and efficiency improvements for the permit holders / regulated entities resulting from implementation of the innovation?
- Minimized or avoided site clean-up costs
- Protection of property values and improved borrowing capacity
- Reduced or avoided environmental and engineering consultant fees, normally incurred to complete more complicated permit application processes
- Reduced insurance rates
- Reduced or avoided fines and other enforcement action costs, including legal fees
- Possible increased business due to improved business image and better community standing/acceptance
- Business advantages over competitors, with both consumers and suppliers, resulting from advertising/marketing the facility's "Certified N.H. Green Yard" status
- Time management cost savings due to improved work practices and working conditions
- Reduced health/safety related costs due to improved work practices and working conditions
Measuring Improvement and Accountability:
- What are the goals for environmental improvement? The goal of the proposed project is to improve environmental practices at MVSYs, in order to protect air, water and soil quality; reduce solid and hazardous waste generation; conserve natural resources; and protect public health.
- What are the indicators that will be used to show environmental improvement? DES has tentatively selected 13 EBPIs whereby environmental improvements will be measured. The EBPIs include vehicle storage, dismantling, and crushing practices; fluid management; parts and scrap management; storm water management; tire management; and status of certain local, state, and federal permits.
- How and when will the baseline measurements be developed? Baseline measurements are already obtained from a questionnaire distributed to target facilities in August 2002. Some confirmation work remains to be done using grant supported inspectors and guidance by an ERP performance measurement consultant.
- What is the plan, timeline and commitment for measuring and evaluating how well the project meets its goals and objectives? In order to finish developing and undertake the performance measurement components of the proposed project, DES requires the services of an expert ERP performance measurement consultant and statistician. If the requested grant money is awarded, DES is fully committed to using the funds to obtain the required contractor and support services, and measuring performance as generally described above using repeat questionnaires, facility inspections, documentation from compliance certifications and return-to-compliance plans, and other available information. DES expects the performance measurement activities to occur over a 24 to 36 month period commencing just prior to the projected Phase II implementation date during the 3 rd quarter of 2004.
- What are the expected short-term (within one to three years) results to be obtained through this innovation and how will they be measured? The expected short-term results of the proposed project will include improvements in environmental practices at MVSYs, including vehicle storage, dismantling, and crushing practices; fluid management; tire management; mercury handling; refrigerant handling; storm water management; parts and scrap storage practices; and maintenance of certain requisite approvals. Those results will be measured as generally described above.
- What are the expected long-term results to be obtained through this innovation, how will they be measured, and what is the time span for those results? The expected long-term result of the proposed project is two-fold: 1) Sustained improvement in environmental practices at MVSYs; and 2) Enhanced understanding of the most effective interventions on changing environmental practices within small industry sectors. The compliance certification aspect of the N.H. Green Yards Program is designed to be on-going, i.e., MVSY operators will be expected to re-certify compliance at regular intervals (to be determined during the pending rulemaking process). Through this grant, DES will develop capacity to independently use statistical tools to monitor performance and assure compliance at MVSYs over the long-term. The manner of measurement will be generally the same as described above (use of EBPIs, field verifications at representative facilities, etc.). In addition, the ERP tools developed for this project will be available to transfer to new ERP projects by DES and others.
Transferring Innovation:
- What methods will be used to document the outcome and methods of this innovation and make the information available to other jurisdictions?
- DES will prepare a final project report and distribute it in both hard copy and electronic copy to interested parties as appropriate. DES will also post the information on the DES web site.
- DES will share all project information with the National Auto Recycling Industry Compliance Assistance Workgroup and other interested stakeholders.
- If sufficient interest exists, DES will conduct a conference call to discuss the project and will present the information at a conference, either remotely or in person, as appropriate
- What is the specific potential for widespread application or use of the tool/approach as a model for "next generation" environmental protection? The proposed project has the potential to:
- Serve as a model for other states using ERP tools to address environmental compliance at MVSYs.
- Provide information about the relative value of the different interventions on improving environmental practices at MVSYs and possibly other "Mom & Pop" scale businesses, including perspectives on the ability to instill environmental stewardship within industry sectors that previously may have lacked awareness of contemporary environmental concerns.
- Develop resources to help other states build capacity to use statistical tools and apply ERP concepts to various industry sectors, in particular "Mom & Pop" scale business sectors.
- How will the application of this innovation be used to promote organizational system change, or develop a culture of innovative environmental problem solving as a "way to doing business" within the State or more broadly? At this time, N.H., like many other states, is looking to "do more with less" by introducing new and more efficient, productive, and sustainable ways of accomplishing mandates and achieving desired outcomes. ERP initiatives offer this potential to "do more with less". Therefore, the proposed project will serve as a model for applying ERP concepts to other industry sectors in N.H., potentially including 1) electronics de-manufacturing facilities; 2) scrap metal facilities, 3) small quantity generators, 4) residuals management facilities, 5) household hazardous waste collection centers, 6) solid waste processing facilities; 7) composting facilities, 8) used oil collection centers, and 9) waste transfer stations.
- What commitments can the proposing State make to provide consultation and mentoring to other States wishing to adopt similar innovations? DES will provide consultation and mentoring to other States in appropriate forums on an as-needed basis, and as funding permits. Potential forums include teleconferences, regional conferences; website postings; e-mail; telephone, and regional/national work groups. DES will also provide electronic copies of all materials produced by the N.H. Green Yards Program, when requested, including workbooks, checklists, PowerPoint presentations, reports, BMP guide sheets, and the like.
[Budgetary information withheld by U.S. EPA]