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Virginia

Project Summary

Project Title: Auto Body Registration Process and Environmental Results Project
Agency: Virginia Department of Environmental Quality (DEQ)
Project Contact:
Richard Rasmussen, Manager of the Small Business Assistance Program; Virginia Department of Environmental Quality; 629 East Main Street; Richmond, VA 23219; Phone: (804) 698-4394; Fax: (804) 698-4264; Email: rgrasmussen@deq.state.va.us

The Virginia Department of Environmental Quality's (DEQ) Air Program is considering the development of a registration process that will be used with this proposal for an EPA performance-based Environmental Results Program (ERP). The Northern Virginia Region (NVR) has been designated as a severe non-attainment area for volatile organic compounds (VOCs). To help the state meet the USEPA's requirement to achieve attainment in NVR, DEQ has recently adopted rules for various VOC sources. These rules will require many types of sources to register and comply with specific requirements. One of these rules apples to auto body shops. The project will gauge not only the effectiveness of an ERP but also the effectiveness of the auto body shop rule.

It is estimated that the regulation of the auto body shops in northern Virginia will reduce VOC emissions approximately two (2) tons per day. Rule 9 VAC 5 Chapter 40 Article 48 was adopted to provide for this daily reduction. The very first step to comply with the regulation is a registration process. Since the vast majority of auto body shops are small businesses and there are a great many in the NVR (over 230 known facilities), DEQ would like to make the registration process as customer friendly as possible while protective of the environment.

The registration process will be accomplished through the use of the ERP. This grant will provide the funding for the development and implementation of the ERP and the registration process. The registration process and the ERP for the auto body shops will include an annual compliance certification from each facility. The forms for the registration process, the assistance tools, and the ERP instructions on how to complete the ERP certifications will be found in the workbook that will be developed. The workbook will describe not only the requirements of the rule but the requirements of the water and waste programs and how compliance can be maintained for each media. The ERP will be user-friendly and lead to improved multi-media compliance and improved air quality.

The ERP development process will include participation by the various trade groups for the auto body shop sector. Project materials such as fact sheets, guidance documents and annual certifications will be designed to be easily understood. The DEQ will also do extensive outreach using trade associations and vendors to explain how the registration process/ERP will benefit the facilities. The expected project outcome includes understandable compliance, and use of various pollution prevention options. DEQ intends to utilize the nationally recognized and experienced services and resources of the Iowa Waste Reduction Center to provide spray painting training and innovative techniques. DEQ also intends to develop a data information system for the ERP that will be interactive and user-friendly.

Summary of Budget Information

Virginia Department of Environmental Quality
Auto Body Registration Process and Environmental Results Project

<Budgetary Information Withheld by EPA>

Project Narrative

The auto body sector in Northern Virginia is subject to federal and state environmental regulations for air, water, waste. Since most of the sector is small businesses, the facilities are not necessarily aware of all the environmental regulations. Their shortcoming usually is not willful, but the result of the day to day pressures of operating a small business coupled with the myriad of rules and regulations such as taxation, social services, employment, environmental, health, and safety.

Through the use of the Environmental Results Program this project will help ease the environmental burden on auto body facilities by providing an easy way to register with the Department of Environmental Quality and comply with 9 VAC 5 Chapter 40 Article 48 . The registration and annual certification will be compulsory for the auto body shops in the Northern Virginia area. Participation in the ERP will be voluntary. The ERP will be comprised of compliance assistance that will provide workshops, supporting materials, inspector checklists, P2 options, a workbook, and spray technique training. The ERP will provide those facilities that volunteer to participate with a dedicated approach to compliance with the new air regulation. The ERP will also provide an additional environmental benefit by including not only compliance information for the other media requirements, but also training in the use of state of the art spray equipment. For those shops that participate in this voluntary ERP, the ERP will essentially result in a small business environmental management system. Participating facilities will be encouraged to become part of the Virginia Environmental Excellence Program (VEEP), a voluntary, incentive-based program that promotes environmental results through the implementation of environmental management systems and pollution prevention. VEEP is aligned with EPA's National Environmental Performance Track Program. Those facilities choosing not to participate will be subject to the same regulations and requirements, but will be expected to reach compliance on their own volition or ask to receive compliance assistance through the Small Business Assistance Program. The DEQ believes that with adequate outreach and information dissemination the ERP will actually be a tool through which we will be able to measure the true acceptance and desire of this impacted business sector to comply with environmental requirements. The ERP will provide an understandable, concise and clear explanation of the registration process and the rule requirements.

The registration process/ERP will require each participant to provide DEQ with an annual certification of compliance. This will be done by completing a user-friendly self-certification report (possibly computerized) that will separate and list the multi-media requirements that an auto body facility has to achieve to be in compliance. Through the registration process/ERP Virginia will be in a position to more accurately assess the emissions and waste generated from this sector. The use of random pre-inspections and post-inspection ERP site visits will enable the comparison of the effectiveness of the ERP materials and the registration process. Thus, we should be able to measure the reduction in VOC emissions.

The registration process/ERP (registration form, fact sheets, guidance documents, checklists, the annual compliance certification, and training) will be developed by DEQ with support from an outside contractor(s). The DEQ will solicit assistance and input from various trade groups, business groups, government entities, and other interested parties. Some of these partners may include vocational schools, community colleges, the Automotive Service Excellence (ASE) Program in conjunction with the National Automotive Technician Educational Foundation (NATEF), the Virginia Small Business Assistance Compliance Advisory Board, and the Iowa Waste Reduction Center. Prior to implementing the actual program the DEQ will test a draft of the ERP materials with actual facilities to assure that they are understandable and user-friendly. Implementation will provide outreach and training to the auto body sector about the registration process/ERP. The training will explain what the project is, and how the project will benefit the facility and the environment.

The DEQ and its contractor(s) will evaluate, adapt and use information from the various projects that have or are now working with an environmental results program. These include the Massachusetts Environmental Results Project, the Rhode Island Auto Body Certification Program, Maryland's Park Heights Project, Washington DC's EE-Cars Project, Florida's Compliance Certification Program for Auto Repair Facilities, and Delaware's Auto Body Certification Project. DEQ plans to adapt portions of these programs to fit the needs of Virginia. This will necessitate an on-going communication and networking with these and other states that have similar programs/projects to gain from their experience.

The project will expand upon the other states' programs by including the opportunity for auto body shop staff to receive additional training in pollution prevention techniques. This could include demonstrations in painting techniques using new laser technology and high velocity low pressure (HVLP) spray guns, and gun cleaning. This will be accomplished in cooperation with the Iowa Waste Reduction Center's Painting and Coating Compliance Enhancement (PACE) program including the Spray Technique Analysis and Research (STAR ® ) program and possible certification of a local vocational school or community college program.

The project will explore various methods of technology-driven information management of the inspection/site visit checklists and the annual certification. This information technology will complement DEQ's Comprehensive Environmental Data System (CEDS). CEDS is DEQ's electronic data system for maintaining databases on sources of pollutants in all media. Use of technology will allow DEQ staff to quickly evaluate compliance, the reduction of emissions and waste by the individual facilities. Technology as a component of the ERP could provide the reduction in standard compliance resources - staff hours, time, and money. The project will also enhance the ability to move toward electronic and internet submission of compliance materials and reports.

If this model of the registration process/ERP for the auto body sector is successful, it could easily be applied to other sectors of area sources (dry cleaners, printers, gas stations, etc.) that will/may be or have been required to register and achieve specific emission requirements. The model will also be easily adaptable for other states to implement.

The Auto Body Registration Process and Environmental Results Project is compatible with and will promote the long term and short term objectives of DEQ's Strategic Plan. As a consequence, it will also promote the strategic plan adopted by EPA Region III and the EPA Headquarters. Additionally, the project will foster goals found in the Areas of Emphasis within the DEQ/EPA Region III Performance Partnership Agreement.

Specifically with respect to DEQ's Strategic Plan, the project will enhance DEQ's long-term objective of "Program Capability " by enhancing the short-term goal of effective program development that provides a more efficient air quality plan and program to meet or exceed the environmental standards . It will strengthen the long-term objective of " Community " by enhancing the agency's short-term goal of increased education and outreach through the development of technical outreach capabilities that will use a proactive approach to deal with the high interest issue of non-attainment in Northern Virginia. Finally, it will help to attain the long-term objective of optimal use of " Financial Resources" by enhancing the short-term goal of maximizing the efficient use of current resources , and aligning resources with priorities . The project will enhance the short-term goal of maximizing the use of technology by creating an additional efficient electronic document management system .

The enhancement of our Performance Partnership Agreement will take place within the following Areas of Emphasis:

  1. Identify and determine feasibility of strategies (e.g., regulatory flexibility and/or non-traditional incentives) for encouraging voluntary environmental improvement and moving beyond compliance.
  2. Support of on-line receiving and processing of certain environmental data.

The project is good for DEQ, good for EPA Region III, and good for EPA Headquarters.

The project will take two years to complete, followed by a three-month period for completion and submittal of a final report on the project. The workplan for the project is outlined below. Dates are approximations based on grant award in June 2004:

Phase I - Development [June 04 - Jan 05]

It will include the exploration and beginning of the development and programming of an electronic database: forms, registration form, inspection checklists, annual certification, and information gathered throughout the project. This electronic database development will at completion include an interactive ability to use all the information gathered from the registration forms, site visits, compliance assistance visits, inspections, and self-certification reports. The identification of all potential auto body facilities will be developed using various government and private lists. A contractor(s) will be hired to assist in this project. The contractor(s) will begin the development of the registration form, inspection checklists, annual certification, guidance materials, fact sheets, information system, and training resources. The contractor(s) will aid in planning of the outreach workshops for the auto body sector that will explain the environmental requirements, the registration form, the annual certification, pollution prevention opportunities, and training.

Phase II - Implementation [Jan 05 - Feb 06]

Some of the tasks in this phase could begin late in Phase I. DEQ and its contractor (s) will determine and identify the number of auto body shops that are a representative sample of the sector in the NVR. DEQ will visit this group of shops to determine initial compliance. The information collected during these visits will be used to develop a baseline for compliance data. DEQ will assure the sampled shops that the initial compliance assessment visits are not official compliance inspections and that any violations discovered will be considered under Virginia's Small Business Assistance Compliance Response Policy.

The registration form, inspection checklists, annual certification, guidance materials, fact sheets, as well as the workshop and database development started in Phase I, will be completed early in Phase II. Data accumulated will be entered into the data information system. It is important to note that the development of the ERP data system will enable the future use of this system for other sectors.

Once all the necessary steps above are completed, program implementation will begin. The workshops will include explaining the registration process/ERP effort, the components of the registration process/ERP, the goal of the project, the materials development process and the materials provided at the workshop, along with the identification of any compliance assistance options and pollution prevention opportunities and strategies. The training will include actual application of various pollution prevention opportunities. Additional on-site assistance visits will be available upon request as resources allow. These activities and responses will be tracked.

Near the end of this phase, follow-up inspections of a random sample of auto body shops will be completed. The results of these inspections will be compared to the initial visits to provide a statistical measurement of pre- and post- improvements of compliance and emissions reduction within this sector.

Phase III - Self-Certification [Feb 06 - June 06]

The auto body facilities will file their first self-certification report of compliance. The program will then be in full operation and fully implemented. The air permit program will be responsible for inputting and quality assuring the registration process information into the data system. The air compliance program will be responsible for inputting and quality assuring the self-certification reports into the data system.

The annual compliance certification will continue to be submitted and will be an on-going workload item for DEQ. The air compliance program will also follow up on violations reported in the self-certification reports and do random inspections of those affirming their compliance in their annual certification. As mentioned above, it is expected that there will be a recognizable reduction in staff hours needed to verify compliance of this sector compared to traditional compliance verification through the inspection process.

Phase IV - Wrap-up [Jun 06 - Sep 06]

DEQ will analyze the data from the project to quantify the improvement to the environment by reduced emissions and increased compliance. A final report will be written on this project and submitted to the USEPA.

Timeline

It is anticipated that this project will begin in June 2004, dependent upon the date of award from the USEPA.

June 04- January Phase I [Development]
January 05 - February 06 Phase II [Implementation]
February 06 - June 06 Phase III [Self-Certification]
June 06 - September 06 Phase IV [Wrap-up]

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