# **Maine Department of Environmental Protections** 

# **Office of Innovation and Assistance** 

# **Final Proposal for the State Innovation Grants 2004**

# 

# **PROJECT TITLE:** Implementation of a Voluntary Automotive Body and Automotive Repair Environmental Results Program

1.  **APPLICANT INFORMATION:**

> **Applicant Name:** State of Maine Department of Environmental
> Protection (DEP), Office of Innovation and Assistance (OI&A)
>
> **Project Contact:** Julie. M. Churchill, Maine DEP, Office of
> Innovation and Assistance

**Address:** 17 State House Station, Augusta, Maine 04330-0017

####  Phone: (207) 287-7881 

####  Fax: (207) 287-2814

**Email:** <julie.m.churchill@maine.gov>

2.  **FUNDING REQUESTED: [\[Financial information redacted\]]{.mark}**

3.  **PROJECT PERIOD: [August 2004 -- August 2006 (may be adjusted
    dependent ]{.underline}**

> **[on EPA award date]{.underline}**

4.  **NARRATIVE WORKPLAN**

> DEP proposes to pilot a voluntary innovative environmental permitting
> system based on the

Environmental Results Program (ERP) model for a currently non-permitted
sector. Maine contains over 4,000 registered motor vehicle auto body and
repair shops in accordance with 1997 U.S. Economic Census
(www.census.gov). This is a significant amount of facilities and many
are located in our densely populated areas that are classified in
accordance with air quality non-attainment areas. The Maine Department
of Environmental Protection Office of Innovation and Assistance proposes
to conduct a focused Environmental Results Program including compliance
and pollution prevention assistance effort targeting the auto body and
auto repair Industry. The projected impact of this project will be a
significant increase in compliance and a cumulative increase in
hazardous waste compliance and reduction in air emissions particularly
in the Southern Maine region. The goals will be to measurably reduce
environmental impacts from this sector and allow the sector and DEP to
jointly initiate a self-sustaining ERP certification program. We will
measure these outcomes by compliance numbers and volumes of air
emissions.

> The main issues and focus of our project include:

-   Undertake a voluntary Environmental Results Program (ERP) to
    administer targeted assistance, implement a self certification
    program and measure the compliance results

-   Research and develop a comprehensive list of Maine auto-body and
    auto-repair facilities

-   Use voluntary incentive tools includingMaine's STEP-UP program to
    certify facilities that wish to go beyond compliance with a tiered
    certification program that includes performance measurements.
    Introduce Environmental Management System concepts by utilizing
    EPA's Practical Guide to Environmental Management for Small
    Businesses Target air quality non-attainment areas

-   Focus on reducing VOC's that lead to ground level ozone

-   Focus on energy reductions to reduce green house gas emissions by
    referrals to Public Utilities Commisson's small business energy
    assistance program

-   Focus on proper handling of all materials to eliminate potential
    release to the environment

-   Focus on worker exposure, health and safety including the life cycle
    of materials at the work place and reducing those contaminants being
    carried home.

-   Focus on alternative proven pollution prevention technologies
    including parts washers, cleaners, cleaning methods, HVLP guns and
    down draft booths

-   Measure Air compliance

-   Measure key hazardous waste management compliance requirements.

-   Measure VOC emission reduction in pounds

-   Measure groundwater discharge compliance in relationship to car
    washing and Maine Waste discharge permit requirements

The vehicles we are considering to use for technical assistance purposes
could include:

-   Review existing ERP models from states including Rhode Island,
    Delaware, Colorado, Florida and Massachusetts

-   Review existing best management practices guides and tailor to meet
    EPA and Maine DEP's regulations which will include a compliance
    checklist and some beyond compliance pollution prevention
    information

-   Develop a focussed subset of Environmental Best Practices
    Indicators.

-   Develop a Green Certification utilizing Maine Step-Up certification
    Program Commitment Track (refer to
    <http://www.state.me.us/dep/oc/stepup/index.htm>)

> The project will build on lessons EPA and Maine Small Business
> Assistance Program has learned regarding innovation assistance
> activities including the following most recent pollution prevention
> and compliance outreach projects:

-   Boat Building Compliance and P2 Project (2001-on going)

-   Auto Salvage/Auto Repair Compliance and BMP Outreach (2002- on
    going)

```{=html}
<!-- -->
```
-   Massachusetts, Florida, Delaware and Rhode Island's ERP Models

-   Governor's Awards for Environmental Excellence (Annual -- P2
    Celebration)

```{=html}
<!-- -->
```
-   Maine DEP Step-Up Program , P2 and sustainability focus (2001- on
    going)

-   Maine Smelter ERP Project, MACT compliance outreach focus (2002- on
    going)

> This project will include the following major elements of a new
> permitting model which presents the framework for environmental
> innovation including:

-   Targeting this sector for the ERP model due to localized impacts
    including, Air and groundwater issues

-   Differing in approach as we will use an outside small business
    assistance provider in identifying geographical areas with
    environmental justice and non-attainment issues or classifications

-   Focusing on environmental issues including greenhouse gases, smog
    reduction, and improving water quality.

-   Diversifying environmental protection tools and approaches by
    providing clear compliance information, resources and pollution
    prevention technologies through the ERP model and EMS guidance

-   Fostering a new innovative licensing process through the ERP model
    in Maine by encouraging pollution prevention and sector compliance
    based on sector specific information and not size or amount of waste
    or air emissions emitted.

> This ERP pilot project differs from other approaches, as we will do
> extensive training, outreach and manage self-certification through
> Maine auto associations. Maine DEP's Office of Innovation and
> Assistance learned a number of educational implementation strategies
> based on the success of the Boat Building and Repair (BBR) initiative
> and therefore will work with the Auto associations to adopt similar
> approaches.
>
> [Improved Efficiencies]{.underline}**:** Licensing through an ERP
> certification will increase administrative efficiencies by decreasing
> DEPs staff time reviewing manifest data and compliance site visits.
> This also will increase efficiencies for both businesses and the
> department by providing a multi-media one-stop place for business to
> have questions answered.
>
> [Reduced Regulatory Burden]{.underline}**:** For businesses, a
> reduction in environmental liability, manifest and shipping costs,
> switching to alternative non-hazardous parts washer will reduce
> potential of filing for an abbreviated license and/or filing for an
> air permit.
>
> [Reduced Emissions and Worker Exposure]{.underline}**:** Expected
> measure of quantifiable environmental improvements will be decreases
> in air emissions and reduction in worker exposure incidents.
>
> [Increased Compliance Rates]{.underline}: Measure increased compliance
> rates based on baseline inspections utilizing key best practice
> compliance indicators
>
> [Increased Pollution Prevention]{.underline}: Measure increase in
> pollution prevention.
>
> [Improved Innovative Outreach]{.underline}**:** Office of Innovation
> staff will collaborate to understand business and enviirnmental/human
> health protection needs by working closely with the association
> members, Coastal Enterprises Inc. (CEI), businesses, stakeholders and
> DEP compliance staff and getting their input regarding certification
> format, content, workshop design and implementation.
>
> [Improved knowledge and tracking of environmental performance within
> Sector]{.underline}: Development of Environmental Best Practice
> Indicators (EBPIs) in coordination with Stakeholders, Association
> members and department licensing/enforcement staff including:

Develop Environmental Business Practice Indicators including:

> [Regulatory Indicators]{.underline}

-   Is the facility in compliance with quantity and time limits for
    hazardous waste storage

```{=html}
<!-- -->
```
-   Does the facility have floor drains and are they capped or properly
    licensed with a holding tank (UIC)

-   Does the wash cars and trigger the Bureau of Land and Water
    Quality's waste discharge program license

```{=html}
<!-- -->
```
-   Does the facility exceed potential to emit Air Quality standards (10
    lb/hr or 100 pounds a day of regulated VOCs)

```{=html}
<!-- -->
```
-   Does the facility have a parts cleaner which is registered with DEP
    Bureau of Air Quality.

-   Does the facility have a spray booth, compliance coatings and HVLP
    spray guns

> [Beyond Compliance Indicators]{.underline}

-   Information and utilization of environmentally preferable products

```{=html}
<!-- -->
```
-   Recycling of Waste Oil and Solvents

-   Health and Safety Signage

-   Reduction in greenhouse gases

-   Reduction in worker health/safety incidents

> [Increased Sector Environmental Awareness]{.underline}: Provide plain
> language guidance of our data results for stakeholders to understand
> the reporting and tracking of their environmental results measures.
> Therefore, the tracking, measuring, reporting and evaluating of the
> environmental results data will be readily transferable. Information
> from baseline inspections will be communicated to facilities. DEP's
> OI&A has been calculating pollution prevention in pounds and has
> recorded such information in benchmark studies. Since the early 1990s
> we have been measuring and tracking detailed outreach assistance.
>
> [Increasing Sustainable Practices:]{.underline} The long-term results
> of this project will be to successfully move this sector towards
> improved efficiency and sustainability through Maine DEP's STEP-UP
> Program. Other long-term results expected will be improved compliance,
> reduction in the volume of hazardous chemical use and waste
> generations, reduction in air emissions, reduction in worker exposure
> to chemicals, improved working conditions, improved environmental
> quality of the surrounding community.

######### Transferring Innovation 

> The innovation of this project will be transparent and readily
> transferred to other states and the EPA by Maine having all
> certification and guidance documents electronically available. We will
> utilize the small business assistance programs and pollution
> prevention list serves to notify all states of the availability of the
> ERP documents including our Web site link address. The specific
> potential for widespread application or use of the ERP approach as a
> model for next generation is high based on the feedback we have
> received from our stakeholders and DEP Senior Management. Promotion of
> compliance assistance by peers and mentors through the sector
> association will further guarantee this success. Our experience
> delivering compliance and pollution prevention assistance with other
> sector industry associations has confirmed that technical information
> is more readily disseminated and accepted when promoted through
> sector's trade association(s). We will promote organization system
> change opportunities at the DEP by piloting the ERP model and
> instituting the self-certification concept to auto body/auto repair
> businesses. This will foster an innovative environmental problem
> solving mechanism both internally and externally. Businesses will have
> a better venue to have compliance and pollution prevention information
> in a plain language format that they will be able to certify they
> meet. Plain language compliance information will also be presented
> through training, on-sites, mentors, compliance videotape, green
> shop/clean shop guide and an audit/EMS guidebook with checklist.
>
> [Sustainable Funding Opportunities:]{.underline}
>
> Funding of this program will set up an innovative yet sustainable
> regulatory process that can be used repeatedly within the Department
> when licensing other Maine Sectors. The ERP model will increase the
> number of licensed facilities and broaden the scope of licensed
> facilities, which will increase the level of regulatory fairness.

#### Maine DEP Quality Management Plan

#### Maine DEP Office of Innovation and Assistance has educated senior management on issues related to establishing a pilot Voluntary Environmental Results Program as specified and aligned with our quality management plan. The Maine DEP seeks to maintain the highest appropriate standard of quality in each aspect of its operations in order to meet its obligation to protect Maine's natural environment and the health of Maine citizens. To this end, Maine DEP operates under a Quality Management System (QMS). As part of its QMS, our Quality Management Plan (QMP) provides the guidance Maine DEP uses to establish and maintain consistent and appropriate QA/QC/QI operations agency-wide. The individuals served by the implementation of Maine DEP's QMP and all other resulting quality efforts include: our agency's staff; Maine citizens; non-governmental interest groups; federal, state and local government administrative agencies; and, Congress and the Maine State Legislature. Maine DEP is committed to serving these customers with the highest appropriate standard of quality in our services.

All managers are responsible for maintaining QA/QC/QI for the area
within their span of

control. As such, commitment to and responsibility for the quality
objectives and operations detailed in our QMP and any Quality Assurance
Project Plan (QAPP) or Standard Operating Procedure (SOP) in place at
Maine DEP begins with the commissioner and continues through all levels
of management and staff. The State's Performance Management Plan for
managers includes performance standards consistent with our Quality
Management Plan, which provides guidance for implementation. Likewise,
managers should include appropriate responsibility for maintaining
QA/QC/QI in the performance expectations and review of their staff. The
Maine DEP's ongoing implementation of its QMS uses the auditing regime
established in Element Nine of our QMP to annually target areas of
interest identified by the agency's Quality Management Steering
Committee (QMSC) for improvement. Managers assure that Corrective Action
Requests and Plans resulting from such audits are responded to and
implemented in a timely manner by supervisors and employees in their
units.

**B. Maine Department of Environmental Protection Office of Innovation
and Assistance Implementation of a Voluntary Automotive Body and
Automotive Repair**

# **Environmental Results Program Quality Assurance Project (Workflow) Plan** 

#### Overall Project Goals, Objectives, Questions and Issues

> The main goals of this project is to promote pollution prevention
> concepts , increase public and industry awareness of environmental
> health concerns particularly in environmental justice, and measure
> increased environmental compliance. Because there are at least 4,000
> auto body/auto repair businesses in Maine, it is anticipated a large
> impact will be made on the aggregate reductions in hazardous waste and
> air emissions. The focus area of our outreach will begin with the most
> populated areas in Maine (southern coastal), which also includes air
> pollution non-attainment areas. \[I think it would be helpful to be
> clear that, for the purposes of this project, Southern Maine is the
> focus. This and earlier language seemed to suggest that the whole
> state will ultimately be a part of this particular project that is
> being funded.\] The aggregate reduction impact in the Southern Maine
> region will not only improve the environment but also reduce exposures
> to the mass public to air toxins from both point source and fugitive
> emissions.
>
> The measures we will be using to evaluate the project will include:

-   Quantity of Air pollution reduced or mitigated including VOCs and
    HAPS through proper use of paints and cleaners. Changes in practices
    to high efficiency/transfer paint techniques and use of alternative
    cleaners.

```{=html}
<!-- -->
```
-   Rate of compliance with key Hazardous Waste regulations through
    manifest tracking and compliance checks.

```{=html}
<!-- -->
```
-   Quantity of water pollution reduced or mitigated- this will include
    compliance with the underground injection control program, waste
    water discharge licenses issued and possibly secondary data from the
    program.

-   Compliance rate will be assessed through initial and final
    compliance site assessments.

-   Resource savings to the sectors on average by use of accounting
    practices including pollution prevention cost accounting such as
    E2/FINANCE. Because this may be considered confidential business
    information, we will look for average estimates and calculate for
    the entire sector.

-   Reduction in risk to the community focused in environmental justice
    neighborhoods within the Southern Maine regional air non-attainment
    region.

-   work with RCRA compliance staff on streamlining two existing
    hazardous waste policies/licenses (abbreviated license and
    rag/wipes)

> If resources allow, the data collected will be used to evaluate the
> baseline compliance, end of project compliance, and the delta between
> the two. The information will also be used to evaluate if the self
> compliance certification results increased awareness and compliance It
> also will allow us to work on streamlining existing policies and
> licenses that have been documented to discourage pollution prevention
> and provide the opportunity to improve upon these. The long term
> consequences maybe if this project can demonstrate self certification
> through the ERP model increases compliance rates and reduces
> administration time and effort the department may look for
> opportunities of adopting ERP as a licensing option. Please refer to
> the attached logic flow model which is the basis for our milestones
> and timelines of this project.

**II. Milestones and Timelines**

> The following timelines are based on EPA's estimated final award date
> of August 2004:
>
> \[you'll probably want a step below for the revision of the QAPP, most
> likely after database development and statistical methodology are
> finished\]

+--------------------------------------+----------------+--------------+
| ### **Milestones**                   | ### **Be       | ### **En     |
|                                      | gin Timeline** | d Timeline** |
+--------------------------------------+----------------+--------------+
| ### Receive EPA grant funding        | #              | ###          |
|                                      | ## August 2004 |  August 2004 |
+--------------------------------------+----------------+--------------+
| ### Hire Staff                       | #              | ### Se       |
|                                      | ## August 2004 | ptember 2004 |
+--------------------------------------+----------------+--------------+
| ### Coo                              | #              | ### Se       |
| rdinate and implement a multi-state  | ## August 2004 | ptember 2004 |
| Workshop for compliance staff and st |                |              |
| ates awarded State Innovation Grants |                |              |
+--------------------------------------+----------------+--------------+
| ### Train Staff in Mu                | ###            | ###          |
| lti-media training. This will be an  | September 2004 | October 2005 |
| ongoign process throughout the year. |                |              |
+--------------------------------------+----------------+--------------+
| ### Develop a Gantt chart d          | ###            | ###          |
| etailing flow of work and timelines  | September 2004 | October 2004 |
+--------------------------------------+----------------+--------------+
| ### Dev                              | ###            | ### D        |
| elop list of ERP candidates '(target | September 2004 | ecember 2004 |
| ed facilities) through research and  |                |              |
| development and input into database. |                |              |
+--------------------------------------+----------------+--------------+
| ### Con                              | ###            | ### D        |
| vene Stakeholders (Compliance Adviso | September 2004 | ecember 2004 |
| ry Panel) Meeting and review process |                |              |
+--------------------------------------+----------------+--------------+
| ### Develop Incent                   | ###            | ###          |
| ives to attract volunteers into ERP. | September 2004 |  March 2005  |
|  Work with staff and senior manageme |                |              |
| nt as well as outside agencies inclu |                |              |
| ding sector associations and insuran |                |              |
| ce carriers. Outreach to trade assoc |                |              |
| iations, suppliers and distributors. |                |              |
+--------------------------------------+----------------+--------------+
| Develop 10-20 Environmental Business | ###            | ###          |
| Practice Indicators (EBPIs) in       | September 2004 |  March 2005  |
| coordination with key DEP compliance |                |              |
| representatives                      |                |              |
|                                      |                |              |
| -   Regulatory indicators            |                |              |
|                                      |                |              |
| ### Beyond Compliance Indicators     |                |              |
|                                      |                |              |
| \- High priority OHSA standards that |                |              |
| would indicate a need for a referral |                |              |
| to DOL Safetyworks to conduct a      |                |              |
| compliance assistance site visit.    |                |              |
+--------------------------------------+----------------+--------------+
| Development of multi-media           | ###            | March 2005   |
| compliance checklist for             | September 2004 |              |
| certification                        |                |              |
+--------------------------------------+----------------+--------------+
| Develop an ERP database to house the | March 2005     | #            |
| indicator data.                      |                | ## July 2005 |
|                                      | ###            |              |
+--------------------------------------+----------------+--------------+
| Revise QAPP                          | ### July 2005  | ###          |
|                                      |                |  August 2005 |
+--------------------------------------+----------------+--------------+
| Review existing compliance records   | ##             | ### D        |
| within the department to avoid       | # October 2004 | ecember 2004 |
| inspections at facilities with       |                |              |
| recent or ongoing compliance issues. |                |              |
+--------------------------------------+----------------+--------------+
| Design a sampling approach such that | March 2005     | #            |
| we can determine if there are any    |                | ## July 2005 |
| statistical significant changes in   | ###            |              |
| environmental compliance performance |                |              |
| as a result of using ERP             |                |              |
+--------------------------------------+----------------+--------------+
| Develop and complete a draft         | ##             | ###          |
| compliance workbook                  | # October 2004 |  April 2005  |
+--------------------------------------+----------------+--------------+
| Prior to ERP outreach and education, | ###            | ### May 2005 |
| conduct inspection at random auto    |  December 2004 |              |
| body & auto repair facilities in     |                |              |
| order to attain baseline compliance  |                |              |
| data.                                |                |              |
+--------------------------------------+----------------+--------------+
| Conduct baseline inspection data     | ### May 2005   | ###          |
| analysis.                            |                |  August 2005 |
+--------------------------------------+----------------+--------------+
| Develop and complete a final         | ### May 2005   | ###          |
| compliance workbook                  |                |  August 2005 |
+--------------------------------------+----------------+--------------+
| Community awareness workshops        | ### June 2005  | ###          |
| conducted through town meetings      |                |  August 2005 |
| and/or civic groups in the southern  |                |              |
| Maine region.                        |                |              |
+--------------------------------------+----------------+--------------+
| Conduct two workshops in the         | ###            | ###          |
| Southern Maine Regional Area to      | September 2005 | October 2005 |
| educate regarding ERP                |                |              |
| workbooks/checklists and distribute  |                |              |
| workbooks to targeted facilities.    |                |              |
+--------------------------------------+----------------+--------------+

+-------------------------------------+----------------+--------------+
| ### **Milestones**                  | ### **Be       | ### **En     |
|                                     | gin Timeline** | d Timeline** |
+-------------------------------------+----------------+--------------+
| ### E                               | #              | ###          |
| RP information and Compliance guide | ## August 2005 |  August 2005 |
| books made available on Maine DEP W |                |              |
| eb site for easy access and increas |                |              |
| ed transferability to other States. |                |              |
+-------------------------------------+----------------+--------------+
| Certification process period for    | ##             | ##           |
| facilities conducted                | # October 2005 | # March 2005 |
+-------------------------------------+----------------+--------------+
| Review of self certifications by    | ### March 2005 | ### May 2005 |
| staff                               |                |              |
+-------------------------------------+----------------+--------------+
| Follow up post certification        | ### May 2005   | ### N        |
| compliance site visits conducted    |                | ovember 2005 |
| targeting self-certified            |                |              |
| facilities.                         |                |              |
+-------------------------------------+----------------+--------------+
| Identify and assist in developing   | ### 2004       | ### 2005     |
| suggestions andstreamlines on HW    |                |              |
| RCRA policy issues developed and    |                |              |
| drafted: 1. Wipes/rags treatment    |                |              |
| options & 2. licensing technology.  |                |              |
+-------------------------------------+----------------+--------------+
| Initiate contacts to facilities who | ###            | ##           |
| are high performers interested in   |  February 2006 | # March 2006 |
| beyond compliance educat through a  |                |              |
| workshop on Maine DEP STEP-UP       |                |              |
| program                             |                |              |
+-------------------------------------+----------------+--------------+
| Tabulate Scores for EBPIs and total | ###            | ### May 2006 |
| compliance per:                     |  February 2006 |              |
|                                     |                |              |
| \- Facility (aggregate EBPIs)       |                |              |
|                                     |                |              |
| \- Industry (aggregate EBPIs)       |                |              |
+-------------------------------------+----------------+--------------+
| Tabulate accuracy analysis scores   | ### March 2006 | ### May 2006 |
| for self certification vs.          |                |              |
| Inspections                         |                |              |
+-------------------------------------+----------------+--------------+
| Auto body & repair facilities begin | ### May 2006   | ###          |
| the sign up process with the        |                |  August 2006 |
| STEP-UP Program                     |                |              |
+-------------------------------------+----------------+--------------+
| Track streamlines on HW RCRA policy | ### May 2006   | ###          |
| issues developed and assist in the  |                |  August 2006 |
| deparment in carrying the policies  |                |              |
| forward.                            |                |              |
+-------------------------------------+----------------+--------------+
| Develop and Complete Case study of  | ### June 2006  | ###          |
| ERP project (final report)          |                |  August 2006 |
+-------------------------------------+----------------+--------------+

### 

**III. Resources:**

> Please refer to the budget and resume of staff. In addition, staff and
> management assigned to this project will also rely on supporting
> information provided in the EPA ERP road map and Region I technical
> support.

**IV. Applicable Requirements:**

We will notify facilities of their compliance responsibilities in a good
faith letter and will include incentives to do so.

#####  

##### V. Data Required and Data Support of Objectives

The data our project analyst will collect and assess are anticipated to
include:

-   Compliance rate through initial base line assessments and final
    compliance site assessments utilizing EBPIs.

-   Resource savings through pollution prevention methods and planning
    including

-   Number of floor drains and/or systems brought into compliance
    through UIC

-   Number of facilities who obtain EPA Hazardous Waste Generator IDs

-   Number of OSHA issues referred to Department of Labor SafetyWorks

-   Reduced risk, utilizing existing approved EPA risk models calculate
    risk reduced to community and

-   Pounds of VOC and Hazardous Air pollutants reduced estimated through
    existing models, known volumes reduced through incorporating P2
    technologies including alternative parts cleaners, high transfer
    efficiency painting techniques.

######## VI. Quantity and Quality of Data Required {#vi.-quantity-and-quality-of-data-required .unnumbered}

> The quantity of the data will include data items applicable to all
> facilities. The sampling approach will be designed in order to be able
> to determine is there are any statistically significant changes in
> environmental compliance performance as a result of using ERP.
>
> The quality and quantity of the data will be sampled and analyzed in
> order to maximize its statistical significance, within resource
> constraints. We will be relying on existing ERP Models as well as the
> EPA ERP advisory documents, including the Road Map and *Generic Guide
> to Statistical Aspects of Developing and Environmental Results
> Program* (2003). .

##### VII. Data Collection and constraints

> Our primary data will be derived from inspections at randomly picked
> facilities who volunteer to participate in the program. We anticipate
> reviewing and using secondary data including existing air models as
> well as hazardous waste and air compliance rates for the auto body and
> auto repair industry. The secondary data may be used to link
> compliance measures to environmental outcomes.

######## VIII. QA/QC Activities to Assess the Acceptance Criteria  {#viii.-qaqc-activities-to-assess-the-acceptance-criteria .unnumbered}

> Data including the baseline, self certification, and follow up
> compliance assessments will be assessed by DEP's Office of Innovation
> and Assistance technical staff assigned to the project as well as the
> project manager. Consistent methods for review of baseline data and
> follow up compliance assessments will be employed by technical staff
> followed by spot checks and oversights by the Project Manager.
>
> The information will be collected and organized in a dedicated secure
> project database, which will be backed up daily. At the end of the
> project the data will be evaluated to determine if facilities who
> participated in ERP's compliance rates improved as well as a holistic
> overview of the sector to determine if an overall increase in
> compliance rates has occurred. Links to environmental outcomes listed
> in the logic model will be attempted.

5.  **QUALIFICATIONS:**

Julie Churchill who has over 16 years of experience in the environmental
field as well as project management will conduct the management and
oversight of this project. Please refer to Julie's attached résumé for
an overview of her qualifications and experience. In addition, either an
engineer or an environmental scientist with engineering coursework
and/or air emission experience will conduct the direct day to day tasks
of the project as well as undergo multi-media compliance inspection
training. We are in the process of undertaking the hiring process for
this candidate.

6.  **TOTAL PROJECT COSTS**

**[\[Financial information redacted\]]{.mark}**

7.  **DETAILED ITIMIZED BUDGET**

**[\[Financial information redacted\]]{.mark}**

8.  **REPORTING REQUIRMENTS**

Quarterly reports will be submitted based on a schedule, which will be
established by the EPA. A case study report will be submitted following
the completion of the project. The report will include:

-   Summary of the project

-   Reductions achieved

-   Rates of compliance achieved

-   Cost analysis

-   Problems

-   Successes

-   Lessons Learned