ECAP “BE PREPARED” Eric Lassalle Smithfield Foods, Inc. Environmental Training San Antonio, TX August 2011
What is ECAP? Environmental Compliance Assessment Program (ECAP) Third Party Audit Team –Smithfield Foods, Inc. –Hunton & Williams, LLP –ERM or Gannett Flemming Program is confidential “Attorney Client Privileged” & not for external use outside the company.
Our Mission To be a trusted, respected, and ethical food industry leader that excels at bringing delicious and nutritious meat and specialty food products to millions every day while setting industry standards for corporate social responsibility.
Our Core Values We will constantly strive: –To produce safe, high quality, nutritious food. –To be an employer of choice. –To advance animal welfare. –To protect the environment. –To have a positive impact on our communities.
ECAP Focus Areas 1.Wastewater 2.Storm Water 3.Drinking Water 4.Water Rights 5.Air 6.RCRA Non-hazardous, Hazardous and Universal Waste 7.Community Right-to-Know 8.Material Management 9.FIFRA Pesticides 10.Polychlorinated Biphenyl (PCB) Materials 11.Asbestos - Disposal 12.Superfund 13.Wetlands 14.Lead-based Paint 15.Groundwater Monitoring and Underground Injection Wells 16.Risk Management Planning 17.Medical Waste 18.Spill Prevention Control and Countermeasure (SPCC) Planning 19.OSHA’s Hazardous Waste Operations Requirements 20.Regulated Refrigerant (CFC/HCFC) Management 21.Environmental Management System Practices 22.Facility, Food & Bio Security 23.Greenhouse Gases
Why ECAP? Assess Compliance Status –Find and correct non-compliance –Implement best practices Benchmark Performance Training Mechanism Goal –100% Compliance, 100% of the Time!
When – ECAP Cycle Year 1 – ECAP Year 2 & 3 – OFF Year 4 – ECAP ~Schedule may be adjusted by Smithfield Foods, Inc. for extenuating circumstances.
ECAP Process Pre-Assessment Questionnaire Site Visit Final draft of Finding & Recommendations –All ducuments shall be maintained only on the Hunton & Williams workroom –Documentation is not permitted to be transmitted by email, fax, & other electronic media. Report & Score (for internal use only) Follow-up (provided as needed)
ECAP Scoring Areas Each facility is scored based directly on the number and priority of findings Scores from Each Section% of Score I.Wastewater2.0/4.050% II.Storm Water1.0/4.025% III.Drinking Water & Water Rights4.0/4.0100% IV.Air and Regulated Ref. Management3.0/4.075% V.RCRA, Superfund, & PCB2.0/4.050% VI.Community Right-to-Know3.0/4.075% VII.Material Storage & SPCC1.0/4.025% VIII.Asbestos2.0/4.050% IX.Risk Management Plan4.0/4.0100% X.Miscellaneous3.0/4.075% a. Wetlands and waterways b. Lead-based paint c. Groundwater monitoring d. Medical waste e. OSHA's Haz. Wst. Op. Requirements f. FIFRA Average Facility Score:2.5/4.063%
ECAP Scoring Criteria 4Absence of any priority A, B or C findings. 3Absence of any priority A and not more than one priority B findings. 2At least one priority A finding and/or more than one priority B findings. 1More than one priority A finding, or at least one significant priority A finding (e.g., missing permit or plan; reportable violation(s)).
#1. SPILL PREVENTION CONTROL & COUNTERMEASURE (SPCC) UPDATE & IMPLEMENT - Incomplete Plans TRAINING - Records SPILLED MATERIALS INSPECTIONS & TESTING
#2. STORMWATER (SW3P) UPDATE & IMPLEMENT - Incomplete Plans FOLLOW PERMIT REQUIREMENTS BEST MANAGEMENT PRACTICES (BMP’s) TRAINING - Records INSPECTIONS RECORDKEEPING UDATE SITE DRAWINGS with STORMWATER FEATURES
#3. COMMUNITY RIGHT TO KNOW (EPCRA) TIER II & FORM R INACCURATE REPORTING - Sodium Nitrate? MISSING RECORDS/RECORDS RETENTION REVISE DESIGNATE EMERGENCY COORDINATOR
#4. RISK MANAGEMENT PLAN UPDATE & IMPLEMENT PROCESS HAZARD ANALYSIS (PHA’s) TRAINING RECORDKEEPING COMPLIANCE AUDIT STANDARD OPERATING PROCEEDURES (SOP’s)
#5. AIR INCONSISTENT PERMIT FOLLOW PERMIT REQUIREMENTS OPACITY LACKS PERMIT/REGISTRATION TRAINING RECORDKEEPING REPAIR & MAINTAIN EQUIPMENT REGULATED REFRIGERANTS
#6. WASTEWATER FOLLOW PERMIT REQUIREMENTS UPGRADE & REPAIR NEED PERMIT SYSTEM DRAWINGS PROCEEDURES ACCIDENTAL RELEASE/SLUG CONTROL PLANS
HOW TO “BE PREPARED”! 1.READ YOUR PERMITS & PLANS (e.g., NPDES, Pretreatment, AIR Permits, SPCC Plan or SW3P) and understand WHAT, WHEN, WHO, & HOW is required! 2. MAINTAIN UPDATED & IMPLEMENTED PLANS 3. TRAIN, RE-TRAIN & DOCUMENT 4. Maintain, Document, Communicate & VERIFY!!! –Keep detailed and organized files –Communicate – no surprises, ask for help, follow-up