ABSTRACT

The management system should provide a definition of environmental noncompliance. There are at least four different conditions, as follows, which constitute environmental noncompliance.

Environmental noncompliance exists in any case for which a lower tier environmental program document is inconsistent or incompatible with a higher tier document-as, for example, when a procedure for reporting environmental noncompliance to a regulatory agency does not enable the report to be made within the legal time limitation, or when an operating procedure is inconsistent with a provision of the plant operating license. A policy, requirements-type document, or procedural inadequacy may be the most serious type of noncompliance because the noncon1pliance is systematically repeated with each implementation of the document.