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Presenter. Eric Lassalle 111 N. Church St. Smithfield, VA 23430 (757) 356-6703 Cell (757) 613-1287. What is ECAP?. E nvironmental C ompliance A ssessment P rogram ( ECAP ) Third Party Audit Team Smithfield Foods, Inc. Hunton & Williams, LLP Third Party Compliance Assessor.

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  1. Presenter Eric Lassalle 111 N. Church St. Smithfield, VA 23430 (757) 356-6703 Cell (757) 613-1287

  2. What is ECAP? • Environmental Compliance Assessment Program (ECAP) • Third Party Audit • Team • Smithfield Foods, Inc. • Hunton & Williams, LLP • Third Party Compliance Assessor

  3. Wastewater Storm Water Drinking Water Water Rights Air RCRA Non-hazardous, Hazardous and Universal Waste Community Right-to-Know Material Management FIFRA Pesticides Polychlorinated Biphenyl (PCB) Materials Asbestos - Disposal Superfund Wetlands Lead-based Paint Groundwater Monitoring and Underground Injection Wells Risk Management Planning Medical Waste Spill Prevention Control and Countermeasure (SPCC) Planning OSHA’s Hazardous Waste Operations Requirements Regulated Refrigerant (CFC/HCFC) Management Environmental Management System Practices Facility, Food & Bio Security Greenhouse Gases ECAP Focus Areas

  4. Why ECAP? • Assess Compliance Status • Find and correct non-compliance • Implement best practices • Benchmark Performance • Training Mechanism • Goal • 100% Compliance, 100% of the Time!

  5. When – ECAP Cycle • Year 1 – ECAP • Year 2 & 3 – OFF • Year 4 – ECAP Schedule may be adjusted by Smithfield Foods, Inc. for extenuating circumstances.

  6. ECAP Process • Pre-Assessment Questionnaire • Site Visit • Final draft of Finding & Recommendations • Report & Score (for internal use only) • Follow-up (provided as needed)

  7. ECAP Scoring Areas • Each facility is scored based directly on the number and priority of findings

  8. ECAP Scoring Criteria

  9. TOP 10 FINDINGS

  10. #1. SPILL PREVENTION CONTROL & COUNTERMEASURE (SPCC) • UPDATE & IMPLEMENT • TRAINING • RECORDKEEPING • DEVELOP & IMPLEMENT • SPILLED MATERIALS • INSPECTIONS & TESTING

  11. #2. STORMWATER (SW3P) • UPDATE & IMPLEMENT • FOLLOW PERMIT REQUIREMENTS • BEST MANAGEMENT PRACTICES (BMP’s) • TRAINING • INSPECTIONS • RECORDKEEPING • DRAWINGS

  12. #3. COMMUNITY RIGHT TO KNOW (EPCRA) • INACCURATE REPORTING • MISSING RECORDS • REVISE • DESIGNATE EMERGENCY COORDINATOR

  13. #4. RISK MANAGEMENT PLAN • UPDATE & IMPLEMENT • PROCESS HAZARD ANALYSIS (PHA’s) • TRAINING • RECORDKEEPING • COMPLIANCE AUDIT • STANDARD OPERATING PROCEEDURES (SOP’s)

  14. #5. AIR • INCONSISTENT PERMIT • FOLLOW PERMIT REQUIREMENTS • OPACITY • LACKS PERMIT/REGISTRATION • TRAINING • RECORDKEEPING • REPAIR & MAINTAIN EQUIPMENT • REGULATED REFRIGERANTS

  15. #6. WASTEWATER • FOLLOW PERMIT REQUIREMENTS • UPGRADE & REPAIR • NEED PERMIT • SYSTEM DRAWINGS • PROCEEDURES • ACCIDENTAL RELEASE/SLUG CONTROL PLANS

  16. #7. RESOURCE CONSERVATION & RECOVERY ACT (RCRA) • WASTE CHARACTERIZATION • MANAGE & PROPERLY DISPOSE • LABELING & DATING • FLOURESCENT LAMPS • TRAINING • RECORDKEEPING • PERMITS/REGISTRATION • CORPORATE POLICY

  17. #8. MATERIAL MANAGEMENT • PERMIT/REGISTRATION (Tanks) • LABELING • SPILLED MATERIALS • PARTS WASHERS • TRAINING & RECORDS

  18. #9. USED OIL • NOT LABELED • IMPROPERLY STORED

  19. #10 Universal Waste • NOT LABELED • IMPROPERLY STORED

  20. Follow Permit Requirements

  21. HOW TO PASS! • UPDATE & IMPLEMENT PLANS • TRAIN, RE-TRAIN & DOCUMENT • READ YOUR PERMITS & PLANS (e.g., NPDES, Pretreatment, AIR Permits, SPCC Plan or SW3P) and understand WHAT, WHEN, WHO, & HOW is required! • IMPLEMENT & MAINTAIN Stormwater BMP’s • Maintain, Document,Communicate& VERIFY!!! • Keep detailed and organized files • Communicate – no surprises, ask for help, follow-up

  22. Thank You! Questions? Comments?

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