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Small Tank Closure Program - Online Application

State: NY Type: Promising Practice Year: 2021

Located in Mineola, New York the Nassau County Department of Health (NCDOH) serves Nassau County on Long Island and its' population of approximately 1.36 million. The population is dense with over 4,700 constituents per square mile to a land area of approximately 284 square miles. A town like Levittown, the first truly mass-produced suburb, has a land area of just 7 square miles but holds over 16,000 residential homes for its' population of approximately 51,000. The county is diverse, with many residents identifying as Hispanic/Latino (17.5%), black/African American (13.1%) and Asian (10.9%). There is a significant population of older adults, with over 18% of residents age 65 or older.

Nassau County has over 470,000 housing units or residences. Many residences were constructed in the mid-1900s with steel underground fuel oil storage tanks (USTs) to heat the residence. Over time these tanks were found to corrode in the ground and leak, impacting the groundwater and surrounding environment. In 1986, Article XI of Nassau County Public Health Ordinance Article XI was adopted. It regulates the storage of toxic and hazardous materials, including petroleum, to protect the groundwater. It states, [New York State] designated best use of all groundwaters of Nassau County is as a source of drinking water. The federal government…officially designated Nassau County groundwaters as sole source aquifers for water supply.” This article included regulations for petroleum tanks with capacities over 1,100 gallons and was amended in 1990 to include requirements for the thousands of tanks (USTs and aboveground tanks or ASTs) with smaller capacities typically found at residences. These provisions provided homeowners with guidance for proper closure of these tanks, either through removal or closure in place, to prevent leaks from impacting groundwater. The NCDOH also started maintaining a registry of these tank closures, with over 89,700 recorded entries as of December 2020. In 2005, the original Small Heating Oil Tank Abandonment Program was awarded a NACCHO Model Practice.

The success of the program, and staff reductions due to retirements, necessitated program updates to improve efficiency. In 2017 and 2018, a respective 3,076 and 3,162 tank closures were completed, an average of 60 closures per week. Documentation, nearly all in paper form, was required from homeowners/contractors, and department staff would then review the documentation, and enter information before and after the tank closure job. Proper information on tank closure procedures was also tough for the public to access, adding to already large call volumes regarding closures.

The online small petroleum tank closure application was implemented in 2018 to remedy these issues. Department supervisors and an IT specialist held trainings to familiarize staff with the program. The goals and objectives of the application are to streamline the tank closure process for the public and increase the efficiency of the departments' sanitarians. The public can now schedule and pay for jobs online and obtain tank closure completion certificates once inspected by the department. Information on proper tank closure procedures is available through an FAQ page. Staff fill out inspection forms in the field electronically using iPads and move the tank closure information to a public database where the certificates can be accessed by the public. Staff spends less time processing paperwork, performing data entry, mailing tank closure documents and answering phone calls.

As intended, the online small petroleum tank closure application has streamlined the tank closure process for the public and increased efficiency for department staff. Of the 2,911 small tank closures through the middle of December 2019, 838 were created by the public through the online application (28.8% of all to-date 2019 closure jobs). This percentage increased significantly in 2020, as 1,318 completed closures were filed by the public online out of 2,082 total completed closures, or 63.3%, an increase of over 30% from 2019. The application has allowed the program to remain safe and efficient through the COVID-19 pandemic, as face-to-face contact between department staff and the public being minimized and foot traffic to the office decreased. Since New York State Governor Andrew Cuomo's stay at home shutdown order on March 20th, 2020, 1,025 completed closures have been filed by the public out of 1,531 total, or 67.0%, an increase over the 63.3% for 2020 overall. A count of public searches on the application maintained since September 2019 shows over 35,000 searches (primarily to look-up/obtain tank closure certificates) have been conducted through December 21st, 2020. For 2020, each inspector was estimated to save a minimum 1 hour and 15 minutes per week. Clerical staff was also expected to see significant time savings.

All the online application goals have been met, as the tank closure process has been streamlined for the public and made staff more efficient through significant time savings. This is evidenced by the high amount of job filings by the public and the time savings for staff through considerably reduced paperwork, data entry, mailings and phone responsibilities.

The significance for public health is that tank closures will continue yet allow inspectors more time to conduct important field work and inspections related to regulated toxic and hazardous materials, including petroleum. The public also has a direct hand in public health, as approximately 60 of the 2,365 completed closures filed through the online application by the public were assigned NYSDEC spill numbers. Closure of old tanks significantly decreases the risk of the county's drinking water supply from becoming contaminated with petroleum.

The application addresses and reduces health inequities, as it is free to the public and easily accessible anyone with internet access can use the program to file work and/or obtain completion certificates. 93% of households in the county have a computer, so a majority of residents are able to utilize the application regardless of their race/ethnicity, socioeconomic status and town/village of residence. When individuals cannot access the internet, the department can mail copies of certificates or provide them at our office. The 7% of residents in households without a computer and 5.6% of residents in poverty can readily receive documentation from the online application. 

Website: https://www.nassaucountyny.gov/1652/Health-Department 

Nassau County's groundwater is at risk for contamination due to the release of toxic and hazardous materials, including petroleum, into the environment. All of the county's approximately 1.36 million constituents are impacted by problem of groundwater contamination, as both New York State and the federal government took measures designating the best use of the county's groundwater is to supply the drinking water. Since Article XI was amended in 1990 to include small tank closures, the Nassau County Department of Health registry has over 89,000 recorded closures to date. The addition of the online application to the NCDOH's small petroleum tank closure program has improved the program to the benefit of the public (residents, contractors, realtors, etc.) and the department, key community stakeholders in public health, and allows both to directly address the threat of contamination to the county's groundwater/drinking water supply.

The online application for the small tank closure program reduces health inequities in Nassau County. The application allows all residents to participate directly in protecting their environment and living conditions, as closing old tanks removes or significantly reduces the likelihood of contaminating the drinking water supply with petroleum. The tank closure protocols, and issuance of completion certificates do not vary based on socioeconomic status or any other demographic factors, making the process uniform for all residents throughout the county. The application also allows the department to easily provide tank closure completion certificates to the approximately 7% of residents living in households without a computer and any residents who may not have access to or be fluent in navigating the internet.  

The addition of the online application to the small tank program has improved and bettered the program overall. The direct improvement to the department is increased efficiency of department staff. Inspectors can better use their time to perform critically important fieldwork such as physical verification of small tank closures and inspections of toxic and hazardous materials storage facilities, as opposed to time consuming and inefficient paperwork, data entry and phone duties. Each inspector was estimated to save at least 1 hour and 15 minutes per week as a result. Clerical staff was also expected to see significant time savings. 

The program is innovative because it gives key community stakeholders, such as county residents, a streamlined method to close potentially hazardous tanks and directly participate in public health. Through the middle of December 2019, nearly 30% of all completed closure jobs in for the 2019 year were scheduled by the public – a total of 838 jobs. As of December 15th, 2020, 1,318 completed tank closure jobs were filed by the public through the online application out of 2,082 total completed jobs for the 2020 year, or 63.3%. Approximately 60 completed closures of the 2,365 completed closures filed by the public since the inception of the application were assigned spill numbers by the New York State Department of Environmental Conservation (NYSDEC), indicating that some amount of oil leaked from the tanks. Closure certificates for respective properties are obtained from the online small petroleum tank closure database, and nearly 6,200 searches have been conducted by the public since September 2019. For the 2020 year, nearly 29,000 such searches have been conducted by the public. This data illustrates public participation in a public health program, and success in job scheduling and certificate searches encourages further and future participation. 

Along with improved efficiency of department staff, a goal of the online application was to streamline the tank closure process for the public, namely homeowners, contractors and prospective home buyers. The public is now able to look-up small tank closure completion certificates and schedule tank closure jobs, all through use of the internet.

Department supervisors worked with county information technology (IT) specialists to determine the necessary components of, existing databases to merge into and final implementation of the program. Supervisors and IT personnel then held multiple trainings with staff, and supervisors did field training and practice inspections with individual staff. This included creating and accessing tank closure jobs and the use of iPads to conduct and complete field inspections of tank closures. This familiarized staff with the program ahead of finalization and making it accessible to the public. Upon implementation of the program, staff instructed public callers and walk-in tank closure jobs on how to schedule such jobs and obtain completion certificates. This provided stakeholders, the public, with knowledge of the new program and helped spread awareness of its' existence. This rollout of the application to the public ensured equity to all Nassau County residents in that information was provided to the public regardless of their demographics and made available online to all residents, including the over 93% of residents in households with computers. The nearly 7% in households without computers and those unable to access the application online could be provided information by telephone or in person at the department office. Residents, contractors and additional stakeholders come from all demographic backgrounds and areas within the county, and all are provided the exact same information on the small tank closure program and its' online application.

Supervisors welcomed in a reputable local contractor who has been performing small tank closures for years to familiarize him with and receive feedback on the online application. Educating homeowners and contractors on the program fosters collaboration with community stakeholders, allowing them to actively participate in and assist their local health department with improving public health by continuing to properly close small oil tanks and protect the county's groundwater. This also improves the efficiency of department staff, as the public using the online application saves time staff spends processing paperwork, performing data entry, mailing tank closure documents and answering phone calls.

The department had a Master of Public Health student intern develop a Frequently Asked Questions” page online for the small tank closure program. The intern also collected, analyzed and graphically represented data newly accessible through the online program, such as the amount of residential closures by town over periods of time. She was able to complete this due to the successful merging of the existing small tank closure registry with the online application. Future interns and summer aides will be easily trained by department staff on the basic functions of online application and use of the iPads to complete field inspections.

Program director Robin Putnam, the supervisor who worked with county IT's Neil Williams to develop the online application, provided estimates of the program's costs and budget breakdown. Over the course of 4 years, Robin estimated that 15% of her time and 25% of Neil's time were dedicated to the design, production and testing of the application. Those percentages extrapolated from their respective work hours and salaries was estimated to cost between $100,000 and $150,000 over the 4 years, or between $25,000 and $37,500 per year. For reference, the small tank closures program revenue for 2017 and 2018 were $251,360 and $259,560, respectively and for 2019 revenue was $278,990. As of December 18th, 2020, the program generated

$226,570 in revenue for the 2020 year. The scheduling of closure jobs was halted for approximately two months from late March/early April until June 1st due to the COVID-19 pandemic, and revenue for 2020 would have likely exceed or been in line with revenue from past years otherwise. These figures were accessed directly through an application page not available to the public and do not include significant additional program revenue sources, including those generated from regulated USTs and ASTs.

The objectives of the online application integrated into the small tank closures program have been met, as the application has streamlined the small tank closure process for the public and improved efficiency for department staff. The practice has been evaluated using both process and outcome evaluation measures.

The main primary data source is the online application itself. The application has a job revenue and statistics page that provides for much of the data used in this report. Additional data is obtainable through knowledge of the functions of the application, such as determining counts of jobs created by the public. The application is programmed to store this data and is able to be collected, retrieved and interpreted by department staff.

The process evaluation measures used to evaluate the practice include supervisors holding staff trainings on the application and conducting practice and field inspections using iPads. Staff were familiarized with the program, using iPads and the electronic field inspection form. By the time the program was made available to the public, staff was adequately trained in the program and ready and able to assist and guide the public in navigating the application. This process evaluation measure allowed for health equity to be achieved, as staff could readily assist all members of the public in scheduling closures and obtaining completion certificates. Closures are handled the same regardless of location of the job and socioeconomic status, race/ethnicity and age of the resident involved with the closure. A reputable small tank closure contractor was also invited to the department to receive training and provide his own feedback on the practice. These process evaluation measures have been a success, as shown by data collected on public use of the online application.

Much of the data used for outcome evaluation measures for the application came directly from the program itself. The program allows staff to sort by who created the job, whether it be an individual inspector or the public. The public job creation sort returned 838 results, and the total small tank closures listed under the completed sort gave 2,911 results. Dividing the public job creation results by the total completed closures (838/2,911) shows that 28.8% of all completed 2019 small tank closure jobs were created by the public. Using the same procedure to obtain 2020 data returned 1,318 jobs created by the public of 2,082 total jobs filed through December 15th, 2020, showing 63.3% (1,318/2,082) of all completed small tank closure jobs were created by the public. This is an increase of over 30% from 2019. A count of public searches available through the program maintained since September 2019 shows approximately 6,200 searches have been conducted through December 9th, 2019. A count of such searches for the 2020 year indicates nearly 29,000 public searches have been performed. Outcome evaluation measures demonstrate health equity through the high usage of the online application since it's inception, 2,365 jobs have been created by the public in towns/villages all throughout Nassau County. Both the 93% of county residents in households with a computer and 7% of residents in households without have been able to participate in the program. These public tank closure job creation and search data evaluation outcome measures demonstrate a high volume of public use of the program, showing stakeholders having direct participation in public health and groundwater protection.

Time savings for department staff was another outcome evaluation for the online small petroleum tank closure practice. Using the 2017 and 2018 small tank closure data, each field inspector going forward is estimated to save about 1 hour and 15 minutes of time per week, at a minimum. Of the approximately 60 closures per week (approx. 3,100 closures on average in 2017 & 2018 divided by 52 weeks), an estimated 20 were handled by inspectors, with the remaining 40 being handled by department clerical staff. Data entry, mailings and calls averaged about 15 minutes per job, leaving inspectors with a minimum 300 minutes (15 minutes multiplied by 20 closures) of work per week handling these closures in 2017 and 2018. For both of those years, the department was operating mostly with 6 field inspectors and 2 secretaries. However, only 1 secretary and 4 field inspectors were on hand for fall/winter 2019 with no additional staff expected for 2020. For fall/winter 2019 and the 2020 year, the estimated 1 hour and 15 minutes of time savings comes from dividing the estimated 300 minutes of office work by the 4 inspectors who handle tanks (300 min./4 insp. = 75 min. per inspector, 75 min./60 min per hr = 1.25 hr or 1 hr 15 min). Substituting the 40 closures per week previously handled by clerical staff in for the 20 handled by inspectors, shows 10 hours per week clerical staff spent on processing small tank closures (40 tank closures x 15 min per closure = 600 min./60 min per hour = 10 hours). Clerical staff will not save the full 10 hours of time, however, the time spent on processing paperwork, performing data entry, mailing tank closure documents and answering phone calls will be significantly reduced. No modifications have been made to the practice as the result of the data findings, however, the department supervisors are able to contact and work with the county IT specialists to make changes if deemed necessary.

A lesson learned in relation to the practice is that technologies such as the internet and iPads can be used to protect public health, in this case Nassau County's groundwater that is the drinking water supply. Public health officials can use limited available resources to build on an existing or a create a program that protects public health, streamlines and encourages stakeholder participation and improves the efficiency of an entity. The application has been adaptable to changing circumstances, as it remained responsive and efficient throughout the COVID-19 pandemic because the scheduling of jobs and issuance of completion certificates can be handled completely online. Since New York Governor Cuomo's March 20th, 2020 shutdown order, 67% of all completed closures have been filed by the public, up from over 63% for 2020 overall.

Regarding partner collaboration, a lesson learned is that stakeholders in public health want to participate in protecting their environment and are encouraged and satisfied when that process, in this case small tank closures, is streamlined. The public, namely homeowners, contractors, realtors and home buyers and sellers, has given a great deal of positive feedback regarding the online application to department supervisors and staff/field inspectors. This also helps to improve the perception of not just the Nassau County Department of Health's work but government work overall. The application has also kept department staff and the public/stakeholders safe throughout the COVID-19 pandemic, as its online features have allowed for reduced face-to-face contact and decreased foot traffic to the department's office.

Based on estimates provided by the small petroleum tanks closure program director, the department supervisor who worked with IT specialists to develop the application, design, production and testing of the application cost between $100,000 and $150,000 over 4 years of development, or between $25,000 and $37,500 per year. Data taken from the application shows that the small tank closure program brought in $251,360, $259,560 and $278,700 in 2017, 2018 and 2019, respectively. As of December 18th, 2020, the program has generated $226,570 in revenue for the 2020 year. These figures do not include significant revenues generated by regulated facilities that are also part of the large tanks program at the NCDOH. The costs of developing the practice are low compared to the revenue of the small tank closure and overall tanks program, the benefit of streamlined small tank closure process for the public (significant stakeholders in public health) and time savings by department staff that can now be used for additional field inspections to protect the county's groundwater.

Sufficient stakeholder commitment exists to sustain the practice. Many of the county's 470,000-plus residences were constructed with small underground fuel oil storage tanks, and over 89,700 small tank closure jobs have been recorded since the 1990 amendment of Nassau County Public Health Ordinance Article XI to provide regulations and guidance for petroleum tanks under 1,100 gallons. Of these 89,700 closures, data collected by the department's Master of Public Health student intern shows approximately 30,000 ASTs and 5,000 USTs were installed in place of the closed small tanks. Over 45,000 small tank closures were conversions to natural gas, with no new AST or UST installed. This data indicates that tens of thousands of small petroleum tanks, at a minimum, still exist with potential for removal in Nassau County. In addition to actually closing small tanks, completion certificates are being sought by home buyers and sellers and realtors. These certificates (over 89,700 to date) are available, upon field inspection by the department, through the online small tank closure search feature. A count of public searches on the online application shows over 35,000 searches since September 2019. Actual closure of small tanks and lookup of small tank closure certificates by the public shows sufficient stakeholder commitment to sustain the practice and continue groundwater protection by stakeholders in Nassau County.