2. Environmental Training
ECAP “BE PREPARED”
Eric Lassalle
Smithfield Foods, Inc.
Environmental Training
San Antonio, TX
August 2011

3. 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.

4. 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.

5. 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.

6. 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

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

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

9. 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 , fax, & other electronic media.
Report & Score (for internal use only)
Follow-up (provided as needed)

10. 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%

11. 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)).

13. TOP 10 FINDINGS

14. #1. SPILL PREVENTION CONTROL & COUNTERMEASURE (SPCC)
UPDATE & IMPLEMENT
- Incomplete Plans
TRAINING
- Records
SPILLED MATERIALS
INSPECTIONS & TESTING

15. #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

16. #3. COMMUNITY RIGHT TO KNOW (EPCRA) TIER II & FORM R
INACCURATE REPORTING
- Sodium Nitrate?
MISSING RECORDS/RECORDS RETENTION
REVISE
DESIGNATE EMERGENCY COORDINATOR

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

18. #5. AIR INCONSISTENT PERMIT FOLLOW PERMIT REQUIREMENTS OPACITY
LACKS PERMIT/REGISTRATION
TRAINING
RECORDKEEPING
REPAIR & MAINTAIN EQUIPMENT
REGULATED REFRIGERANTS
Moved from #7 to #6

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

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

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

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

23. #10 Ozone Depleting Substances (ODS)
Recordkeeping
Contractor Certification
Leak Rate Calculations
Follow-up Verification Testing

24. 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!
MAINTAIN UPDATED & IMPLEMENTED PLANS
TRAIN, RE-TRAIN & DOCUMENT
Maintain, Document, Communicate & VERIFY!!!
Keep detailed and organized files
Communicate – no surprises, ask for help, follow-up

25. Thank You!
Questions?
Comments?