One Game, Three Players and Everyone Wins Automotive Salvage Yards Sara J. Johnson, M.S. [email protected] 603-271-6460 N.H. Department of Environmental Services Pollution Prevention Program May 2008 National Environmental Partnership Summit
Dec 26, 2015
One Game, Three Players and Everyone Wins
Automotive Salvage Yards
Sara J. Johnson, [email protected]
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…
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