INSPECTIONS AND COMPLIANCE MANAGING THE FACILITY T. Alan Sprott - - PowerPoint PPT Presentation

inspections and compliance managing the facility t alan
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INSPECTIONS AND COMPLIANCE MANAGING THE FACILITY T. Alan Sprott - - PowerPoint PPT Presentation

INSPECTIONS AND COMPLIANCE MANAGING THE FACILITY T. Alan Sprott Vigor Industrial LLC PORTLAND SHIPYARD 57 acre industrial facility on Swan Island. Core business is ship repair and barge construction. REGULATED ACTIVITIES Ship and


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INSPECTIONS AND COMPLIANCE MANAGING THE FACILITY

  • T. Alan Sprott

Vigor Industrial LLC

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PORTLAND SHIPYARD

57 acre industrial facility on Swan Island. Core business is ship repair and barge construction.

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REGULATED ACTIVITIES Ship and Barge Dry Docking Vessel Sand Blasting and Coating Industrial Sand Blasting and Coating Waste Water Treatment Oil Processing and Sales Overwater Transfers of Fuel, Oil, and Slops Barge Construction Ship Scrapping Solid and Hazardous Waste Management and Disposal

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PERMITS AND REGULATIONS Compliance Drivers Title V Air Permit – 100+ compliance and monitoring requirements RCRA – 20+ requirements NPDES Individual and Stormwater Permits – 100+ compliance and monitoring requirements, and BMPs Title 33 – 100+ requirements Industrial Discharge Permit, Used Oil Rules, Various Operating Plans Virtually impossible to be in compliance with every regulation

  • r requirement every minute of every day.
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COMPLIANCE APPROACH Ethical Business Practices Know and Understand the Regulations Affecting the Business Know and Understand the Permits Issued to the Business Use Technical Assistance Programs and Invite Regulators to the Facility Educate Permit Managers on the Business Build Relationships with Agencies and Stakeholders

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INSPECTION TRIGGERS Unannounced – Hazardous Waste, Complaint, Incident Scheduled – Associated with Permits

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INSPECTION DAY First Impression Facility Appearance Documentation and Organization Controlling the Environment Learn and Teach Keep it Non-Confrontational Don’t be Afraid to Say I Don’t Know Follow Up

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DEALING WITH VIOLATIONS Admit it if you did it Document in writing Follow the procedures Resolve at settlement conference Avoid formal hearing Use Supplemental Environmental Project