Smithfield Foods Environmental Conference Omaha, NE September 14, 2010

1. Smithfield Foods Environmental ConferenceOmaha, NESeptember 14, 2010 Environmental Calendar Be Organized, Do the Routine and Stay Compliant

2. Feds are Getting Out There: • EPA Chief Lisa Jackson is ramping up inspections and enforcement • Ammonia Refrigeration Systems – PSM/RMP • Air Permit Inspections • Wastewater Permit Inspections • Storm Water Permit Inspections • SPCC Plan Inspections

3. Professional Ethics: • Criminal indictment for “Knowing and Willful” violations • Review permit & compliance documents frequently • Identify deficiencies • Report violations immediately to plant management and regulatory agencies • Be open and honest during inspections • Answer the questions in full, but do not ramble • Show inspector only what they ask to see

4. Compliance Assistance: • Environmental Compliance Assessment Program • EMS – Annual Internal Audits and WebEMS • Smithfield Annual Environmental Training Conference – Here We Are! • Smithfield Corporate Environmental and Subsidiary Environmental Coordinators – at your service!

5. ECAP Improvement Categories • Read and Follow Permit Requirements • Storm Water and SPCC Plan Requirements • Documentation of Training • Record Keeping • Materials Management (First Impressions)

6. Whose Permit Is It ???? YOURS! • Helpful Hits: • Keep current copies of all permits and plans (hard copies and on WebEMS) • Summarize all requirements (Permit Tracking Form) • Document Requirements – “Monitoring Data” in “Documentation” section of WebEMS • Designate requirements to responsible team members as appropriate • Establish electronic PMs for all permit/plan requirements • Assure compliance (follow up with delegee) • Assure permits are renewed on time

7. Wastewater • Document Permit issue and expiration date • Document permit requirements • If discharge to city, review Sewer Use Ordinance requirements • Review Discharge Monitoring Reports (DMR) for accuracy prior to submittal • Ensure Signatory Authorization Form is current and accurate • Review control instrument (pH) calibration records • Assure operators log book is being kept and operational details recorded • Assure operator certification requirements are kept current • Spill/Slug Control Plan (up to date?) • Sewer line drawings (up to date?) • Assure that all applicable records are kept for the required time (3 years)

8. Storm Water • Review Storm Water Permit • Is SW sample collection and analysis required? • Are Visual Observations at Outfalls During Rain required? • Assure SW Pollution Prevention Plan is up to date (names current) • Assure Non-Storm Water Discharge Certification is complete • Assure SW Site Inspections are completed at required frequency • Assure Annual SW Comprehensive Site Compliance Evaluation is completed • Assure Annual Storm Water Training is completed • Assure all required records are kept for the required time (3 years)

9. SPCC • Secondary containment drainage records • Quarterly tank and transformer inspection reports • Annual training records • Periodic spill prevention briefings • Keep all records for at least 3 full years • Review SPCC Plan annually and keep current

10. Drinking Water • Document annual backflow preventer certification completion • If own wells servicing over 25 people, Non-Transient, Non-Community Water System Requirements apply - Lead/Copper - Disinfection/Disinfection Byproduct - Groundwater withdrawal reporting - Operator license requirements • Keep current drawing of water distribution system

11. Air • Compare all air pollution sources to existing air permits (gap analysis) • For emission sources without permits – assure that exemption requirements are met and documented • Document permit issue and expiration date • Document permit requirements and responsible party • Document actual emissions and PTE annually • Ensure you have copies of all air permit applications • Ensure all documentation and reporting requirements are being met • Ensure all required maintenance and inspection records for air pollution control devices are being kept • Document if NSPS requirements are applicable (>10 MMBtu/hr and constructed after 1985) • Ensure opacity requirement are met (as applicable) • Keep records for at least 3 years

12. EPCRA – Sections 311 & 312 • Submit Tier II form to by March 1st annually • Send “Return Receipt” to document receipt by agency • Keep signed Tier II submittals and return receipt records for at least 3 years – best place: scan into WebEMS as a “Record”

13. EPCRA – Section 313 • Submit Form R report by July 1st annually (if required) • Document Form R backup calculations • If Form R is not required, document why not • Keep records for at least 3 years

14. RMP/PSM • Risk Management Plan re-submit every 5 years • Review worst case and alternative release scenarios every 5 years • Document accident history, keep for at least 5 years • Document PHA – due every 5 years • Document Mechanical Integrity Assessment – due every 3 years • Document PSM/RMP Compliance Audit – due every 3 years • Document review and certification of SOPs - annually • Document review of training program - annually • Document Process/SOP Refresher training – due every 3 years

15. RMP/PSM • Document review of maintenance procedures - annually • Document review of Emergency Action Plan - annually • Document review of Respiratory Protection Plan - annually • Document review of Hazard Communication Plan - annually • Document change out of all safety relief valves – every 5 years • Document Management of Change (MOC) – all system changes • Document pre-startup safety review – all system changes • Document incident investigations • Document employee participation written plan • Keep hot work permit records • Keep contractor training records