Environmental Training 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 To produce safe, high quality, nutritious food. 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 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

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)

Scores from Each Section Average Facility Score: ECAP Scoring Areas Each facility is scored based directly on the number and priority of findings   Scores from Each Section % of Score I. Wastewater 2.0/4.0 50% II. Storm Water 1.0/4.0 25% III. Drinking Water & Water Rights 4.0/4.0 100% IV. Air and Regulated Ref. Management 3.0/4.0 75% V. RCRA, Superfund, & PCB VI. Community Right-to-Know VII. Material Storage & SPCC VIII. Asbestos IX. Risk Management Plan X. Miscellaneous 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: 2.5/4.0 63%

ECAP Scoring Criteria 4 Absence of any priority A, B or C findings. 3 Absence of any priority A and not more than one priority B findings. 2 At least one priority A finding and/or more than one priority B findings. 1 More than one priority A finding, or at least one significant priority A finding (e.g., missing permit or plan; reportable violation(s)).

TOP 10 FINDINGS

#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 Still #1

#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 Moved from #7 to #6

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

#7. RESOURCE CONSERVATION & RECOVERY ACT (RCRA) WASTE CHARACTERIZATION MANAGE & PROPERLY DISPOSE LABELING & DATING FLOURESCENT LAMPS TRAINING RECORDKEEPING PERMITS/REGISTRATION CORPORATE POLICY Unchanged #4 again

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

#9. USED OIL Unlabeled Containers Mislabeled Containers “Used Oil” not “Waste Oil”

#10 Ozone Depleting Substances (ODS) Recordkeeping Contractor Certification Leak Rate Calculations Follow-up Verification Testing

HOW TO “BE PREPARED”! 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

Thank You! Questions? Comments?