A program for conducting corrective actions at operating industrial facilities

The purpose of this paper is to present a proactive, comprehensive program to assist industries in gaining control over the corrective actions required to address historic contaminant releases (such as oil spills fuel distribution times, and other contaminants such as diesel and jet fuels) while at the same time minimizing their impact on facility operations. In contrast to the approach used by many industries, this program emphasizes a proactive approach in which a strategy is developed to meet the needs of both the facility and the regulators. Development of the strategy includes: conducting a comprehensive self-evaluation of environmental problems; identifying applicable corrective action regulations; developing a risk-based priority ranking of sites requiring corrective actions; preparing an overall strategy/schedule to perform the corrective actions; and obtaining the support/approval of corporate management and the regulators. The program meets the needs of the regulators in that it presents a long-term commitment by the facility to assure the protection of public health and the environment, thereby minimizing enforcement need for regulatory oversight and delays caused by the need for regulatory approvals