1 / 13

INCIDENT NOTIFICATION WHO YOU GONNA CALL?

INCIDENT NOTIFICATION WHO YOU GONNA CALL?. Environmental Conference June 4, 2012. When to Call . Spills, Releases, Emergencies Ditches, Culverts, Stormwater Drains, Wastewater Drains, Atmosphere Anything that leads to ‘waters of the state’ and/or off the property

greg
Download Presentation

INCIDENT NOTIFICATION WHO YOU GONNA CALL?

An Image/Link below is provided (as is) to download presentation Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author. Content is provided to you AS IS for your information and personal use only. Download presentation by click this link. While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server. During download, if you can't get a presentation, the file might be deleted by the publisher.

E N D

Presentation Transcript

  1. INCIDENT NOTIFICATIONWHO YOU GONNA CALL? Environmental Conference June 4, 2012

  2. When to Call • Spills, Releases, Emergencies • Ditches, Culverts, Stormwater Drains, Wastewater Drains, Atmosphere • Anything that leads to ‘waters of the state’ and/or off the property • Chemicals, Oils, Fuels, Ingredients, Gases • Immediately, Immediately, Immediately

  3. Who to Call (External) • National Response Center • State Environmental Response Center • LEPC • Fire Department • Coast Guard • POTW • Water and Sewer Authority

  4. Who to Notify (Internal) • Environmental Coordinator • Subsidiary Coordinator • Plant Engineer • Plant Manager • Plant Security • Smithfield Foods Environmental Affairs • Smithfield Foods Legal

  5. Use the System • www.smithfieldwebmetrics.com • Login • Report an Incident • Provide what info you can • Link to guidelines for reference • Keep distribution up to date

  6. What to Know • What material was spilled/released • What time was the incident discovered • Any injuries • Where did the material go • Facility address • Who (by name) you called & when • Any tracking numbers you are given • Quantity can come later

  7. Penalty Exposures Under CERCLA/EPCRA • Depends on amount, and significant penalty exposure begins after 15 minutes from discovery of the release • $32,500 exposure per violation depending on timing and amount of release

  8. Penalty Exposures Under CERCLA/EPCRA • Four potential violations (notifications to NRC, SERC, LEPC, written follow up) • Do the math - $130,000 possible per incident • Aggravating factors – if the Company is determined to have prior violations, penalties can be tripled • More math - $390,000 per incident

  9. Examples: • EPA Consent Decree Entered, and Civil Penalty of $17,875 paid, for delay in contacting SERC of 3 hours. NRC and locals notified promptly. Difficulty experienced in contacting subsidiary coordinator. • CANNOT RELY ON SUBSIDIARY COORDINATOR TO MAKE CALLS – MUST BE MADE IMMEDIATELY BY FACILITY PERSONNEL.

  10. Examples: • EPA Consent Decree Entered, and Civil Penalty of $83,000 (delayed reporting of four hours to NRC, delayed reporting to state, and failure to notify local authorities); claim that should have notified neighboring county too, based on proximity • MUSTCALLALLAGENCIES, EVENIFTHEYSAYITISNOTNECESSARY.

  11. Examples: • Criminal investigation for delay in reporting to NRC and failure to report to State and Locals for approximately one week; • MUSTREPORTIMMEDIATELYEVENIFTHEQUANTITYISUNKNOWNIFITCOULDBEOVER100 LBS., IFYOUDONOTHAVETHEEXACTNUMBERS; CANFOLLOWUPWITHTHESPECIFICS

  12. Takeaways • When in doubt, CALL • Contact ALL agencies • LIST and POST all contact numbers • Notifications must be IMMEDIATE • IMMEDIATE means less than 15 minutes • Use a WRITTEN procedure and form • TRAIN, TRAIN, TRAIN

  13. Emergency Release Reports and Environmental Incidents: Follow-up with Environmental Affairs Environmental Affairs 4 In accordance with federal, state, and local regulations, facilities are required to make immediate reports to the government of specified spills, releases, or other emergencies. Each facility manager and/or designated subsidiary environmental manager is responsible (a) to ensure that his or her staff is familiar with the release report requirements, (b) to develop a comprehensive written release report procedure with includes appropriate National Response Center, state environmental release report, and local environmental release report contact information, and (c) to follow through with that procedure for each required release report. At a minimum, such procedures shall include prior planning for releases for all hazardous substances handled at the facility, including evaluation of circumstances likely to cause a release of reportable quantities. Environmental Affairs and the Legal Department will be available to assist the subsidiary environmental personnel in determining the reporting requirements in general and in response to particular incidents if needed. After the notification to government agencies has been completed, subsidiary environmental personnel are expected to promptly notify Environmental Affairs and any designated subsidiary environmental manager of reportable releases. In the event of significant spills, discharges, or other incidents that may not be required to be reported to government agencies, subsidiary personnel should take appropriate steps to ensure the safety of any individuals that might be affected and initiate appropriate steps to address the immediate issue, and then as soon as possible contact Environmental Affairs. Smithfield Foods, Inc. Environmental Affairs Guidelines June 30, 2004

More Related