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 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
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 or requirement every minute of every day.
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
INSPECTION TRIGGERS � Unannounced – Hazardous Waste, Complaint, Incident � Scheduled – Associated with Permits
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
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
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