One Game, Three Players and Everyone Wins Automotive Salvage Yards Sara J. Johnson, M.S N.H. Department of Environmental Services Pollution Prevention Program May 2008 National Environmental Partnership Summit

Agenda History of auto salvage outreach and strategy Legislative changes Transition phase Recognition program Measurement Future plans

: 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…

25% – 30% reported they dismantled vehicles outside over bare ground

Less than 15% reported using leak containment systems for fluid storage.

Less than 10% reported protecting the ground when crushing.

Over 75% reported improperly stored tires

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 Strategy to 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 Requires Town Officials to have operators certify compliance with BMPs when applying annually for a local “License to Operate a Junkyard” (effective since 1965) 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 partnership 1.State DES 2.Salvage Yard Operators 3.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 ‘ ppb to Sept ‘06 7 ppb Facility (Goffstown): Oct ’02 69 ppb to June ’06 <1 ppb Facility (Pelham): Aug ’ ppb to June ’06 <3 ppb Mercury switches Started voluntary state collection program in 2003 National collection program started in ,558 switches = 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 3 rd party certification N.H. Municipal Association Encouraging annual workshops for municipal officials