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Home My WebLink AboutRESPONSE - RFP - 8437 NATIONAL BIOSOLIDS PARTNERSHIP AUDITOR & ISO 14001 ENVIRONMENTAL MANAGEMENT SYSTEM AUDITORNSF International Strategic Registrations National Biosolids Partnership and ISO 14001 Audit Proposal RFP 8437 City of Fort Collins, Colorado NSF –ISR Proposal to Provide Third-party Audits of the Ft. Collins EMS and Biosolids Programs I. Proposal Evaluation Categories A. Executive Summary NSF-ISR is pleased to provide the following proposal to provide to the City of Fort Collins the professional services required to perform the initial and annual independent third-party audits of the Fort Collins Biosolids Management Program and its Environmental Management System (EMS) for the Water Reclamation and Biosolids Division (WRB). Specifically NSF-ISR will perform verification and interim EMS audits to ensure that WRB’s Biosolids Program adheres to the standards proscribed by the National Biosolids Partnership (NBP). The purpose of the NSF-ISR verification audit is to collect and evaluate objective evidence that determines whether the WRB biosolids EMS is functioning as intended, that practices and procedures are conducted as documented, and that the EMS as implemented conforms to the NBP’s Biosolids Management Program Elements, the Code of Good Practice and the program goals and objectives. NSF-ISR’s approach consists of two stages: documentation review (combined with a short field visit) called operational readiness review (ORR) to determine the readiness of Ft. Collins to receive the verification audit. This is followed by the official verification audit to determine certification. Emphasis will be placed on verifying activities are implemented in practice; assuring environmentally sound performance of the biosolids management program and increasing the public trust and confidence in biosolids management practices. All biosolids program audits are conducted following the NBP auditor guidance, as published August 2011. With respect to the interim audits, the NBP auditor guidance indicates that individual interim audits only cover a portion of the BMP. However, over the course of the four interim audits conducted between verification audits the entire BMP (i.e. all 17 elements) must be covered. To that end, individual elements that will be audited in their entirety during each interim audit will be identified in the audit plan prepared before the audit emphasizing the needs based on the results of the previous audit, and insuring that all elements are audited over the course of the four-year interim period. The lead auditor for these audits will be Dr. William R. Hancuff, a registered professional civil engineer, who specializes in the water and wastewater field. He is an NBP certified auditor for both Biosolids Management and Environmental Management Systems. He has served as the lead auditor for all of the verification audits performed by NSF-ISR since the beginning of the program in 2004. NSF-ISR is available to participate in the interviews/demonstrations on the proposed dates tentatively scheduled for the week of 6 February 2017. 2 NSF –ISR Proposal to Provide Third-party Audits of the Ft. Collins EMS and Biosolids Programs B. Consultant Information NSF International is headquartered at 789 North Dixboro Road, Ann Arbor Michigan 48105. The primary contact for this proposal is Jeanette Halliday, Senior Business Development Manager who can be reached at 734-827-3804 or halliday@nsf.org. NSF-ISR draws upon more than 40 years of expertise in environmental management systems. We helped develop the first ISO 14001 standard in 1996; we are a global leader in supporting clients from around the world transition to ISO-14001:2015. NSF-ISR continues to be actively involved in global environmental standards and are proud to be a WEF preferred NBP Verifier. As your registrar, NSF-ISR can put this expertise to work for The City of Fort Collins, providing meaningful feedback for system improvements which will help unify your Environmental and Biosolids Management Systems goals with your overall growth and business strategies. NSF partners with a broad spectrum of organizations requiring independent third party certification services offering comprehensive management systems registrations to internationally accepted standards for quality assurance and environmental protection for government, automotive, aerospace, forestry, chemical, e-scrap, medical, mining and manufacturing industries. Exhibit A – Proposal acknowledgement not required per Pat Johnson 1/11/2017 C. Scope of Proposal NSF will conduct all biosolids EMS audits using the protocols described in the NBP Audit Guidance Document (Auditor Guidance), as amended and posted at www.wef.org/biosolids and according to ISO 17021 rules for accredited registration services. We understand that The City of Fort Collins is looking for a certification body who can provide support on the differences between the ISO 14001:2004 and ISO 14001:2015 standards, with the option to perform a gap assessment audit and then conduct the ISO 14001:2015 upgrade recertification and subsequent maintenance audits for a three year period. We are the gold standard certification body to partner with you to achieve these performance objectives. NSF-ISR has unparalleled technical expertise in environmental and safety standards. Our team of environmental experts recognized the need to develop strong communication tools to assist in the ISO 14001:2004 to ISO 14001:2015 transition. As a result, we have created a variety of helpful transition tools, including a Transition Guide, On-line Readiness Tool, ISO 14001:2015 Upgrade Planner & Delta Checklist and ISO 14001:2015 Transition Readiness/GAP Assessment Checklist to support our customers as they take on the task of 3 NSF –ISR Proposal to Provide Third-party Audits of the Ft. Collins EMS and Biosolids Programs preparing their environmental management system for upgrade to ISO 14001:2015 As understood in the RFQ, Fort Collins plans to transfer 3 existing ISO 14001:2004 registration certificates for Re-certification Upgrade Audits to ISO 14001:2015 in Q3 of 2017. Audit duration is 4 days per department/division registered currently based upon provided data; however, NSF-ISR plans to conduct these 4 day Re- certification Audits with the team of 2 auditors: Dr. William Hancuff (Lead Auditor) and Jack McVaugh (Team Auditor) over the course of 2 consecutive calendar days each. Upon completion of the audits, Dr. Hancuff will issue the final audit reports to The City of Fort Collins along with any findings. If findings are issued, The City of Fort Collins will address those findings on or before the expiration of their existing ISO 14001:2004 certificates. If no findings or once response to findings are approved, The City of Fort Collins will receive new ISO 14001:2015 certificates. Consistent with the NBP third party verification auditor guidance NSF-ISR uses a two-tier approach for its NBP verification audits. The first step is the BMP documentation review (desk audit), in which NSF-ISR compares the Ft. Collins biosolids management program’s procedures with the requirements of the NBP standard for each of the 17 elements. Observations are prepared and used during the on-site segment of this stage. NSF-ISR refers to this step as the Operational Readiness Review (ORR). During this phase the auditor interviews the biosolids management representative and/or member of the BMP team to determine what additional information is available to address the results of the desk audit observations. At the same time a field review is made of the areas that historically have been the most frequent cause of delays in the certification process so they can be addressed before the next stage, which is the official verification (certification) audit. A letter report is prepared containing “observations” as opposed to “major” and “minor” nonconformances so that these can be substantially addressed before the verification audit takes place. This two-step approach has demonstrated significant advantages to the organization being audited because it gives the auditor and auditee the opportunity to work with one another, and if the auditor has findings that might otherwise be “show-stoppers” in a certification audit it provides the organization the opportunity to address these findings before the official certification audit takes place. The complete verification audit will review all seventeen NBP BMP elements, including the overall performance of the BMP relative to the four outcomes: environmental performance, regulatory compliance, quality management practices and relation with interested parties. In general terms, the scope of the NSF-ISR audit encompasses the entire biosolids value chain (pretreatment, collection and treatment, through final end use) with 4 NSF –ISR Proposal to Provide Third-party Audits of the Ft. Collins EMS and Biosolids Programs special attention on those practices and management activities that directly support biosolids-related operations, processes, and activities within the biosolids value chain. Objective evidence will be gathered through document review, interviews, and field activity observations and evaluations. As was mentioned previously Dr. William R. Hancuff will be the lead auditor and will have responsibility for the timely and professional completion of the audits and communication with the City’s Project Manager. The proposed agenda for the ORR is as follows: Day 1 7:45 AM Arrival 8:00 – 8:30 Opening Meeting (All EMS management personnel) 8:30 – 9:00 Management Interview (Ft. Collins WRB Manager) 9:00 – 11:00 Discuss Results of Documentation Review (BMP Coordinator) 11:00 – 12:00 Examination of Performance Report and Management Review Documentation (BMP Coordinator) 12:00 – 1:00 Lunch 1:00 – 3:00 Review Critical Control Points, Tour Wastewater Treatment Plant and Interview Key Operations Personnel. (TBD) 3:00 – 4:00 Review Operational Controls and Monitoring and Measurement (Operational personnel) 4:00 – 4:30 Prepare Auditor Notes 4:30 – 5:00 Daily Debrief (BMP Coordinator) 5:00 Departure Day 2 8:00 – 8:45 Review Legal Requirements (including pretreatment program) (BMP Coordinator) 8:45 – 11:15 Review Goals and Objectives (BMP Coordinator) 11:15 – 12:00 Evaluate Outcomes (BMP Coordinator) 12:00 – 1:00 Lunch 1:00 – 3:00 Visit Land Application Site(s) 3:00 – 4:00 Review Communications and Public Outreach (BMP Coordinator) 4:00 – 4:30 Prepare auditor notes 4:30 – 5:00 Daily Debrief 5:00 Departure Day 3 8:00 – 10:00 Review Training Records 5 NSF –ISR Proposal to Provide Third-party Audits of the Ft. Collins EMS and Biosolids Programs 10:00 – 11:00 Review Emergency Response program 11:00 – 12:00 Prepare Auditor notes 12:00 – 1:00 Lunch 1:00 – 2:30 Prepare Summary Report on Observations 2:30 – 3:00 Closing Meeting 3:00 Departure The results of the ORR will be presented in the form of a letter report to the City’s Project Manager, with the findings identified as “observations,” within one week of completion of the ORR. While there may be some opportunities for improvement identified, the focus will be on items that should be corrected before the verification audit takes place. The results of the ORR will also allow the auditor and auditee the opportunity to discuss how long it should take to correct those items that need to be addressed, and agree on a date when it would be most convenient for the verification audit to be completed. (Note that elements of the standard that were audited in the ORR will be considered to be substantially complete and only if there have been findings will they be audited again during the verification audit. This eliminates duplication of auditing the same activities twice and results in the most cost- effective and efficient audit process.) The final verification audit plan will be prepared and submitted to City’s Project Manager one month before that audit is to take place. The contents of that plan will complete the evaluation of those elements of the standard not addressed in the ORR, follow-up on the observations made during the ORR, and on-site evaluation of the system performance relative to progress on goals and objectives with emphasis on outcomes. The estimated number of hours for both the ORR and verification audit are presented below in Section F – Cost and Work Hours. It is not anticipated that any software or other analytical tools will be used on this project; and none of the work will be subcontracted. NSF-ISR requests that the following be made available to be used for the audit:  A reserved space to be used for audit purposes  An organization chart with full names of personnel  The full names of our points of contact for each element in the audit plan  Facility layouts, where appropriate  A master list of all documented procedures with current revisions  Access to a copier and the possible use of an HP Laser Printer Also, WRB must provide representatives to accompany team members during the entire audit. 6 NSF –ISR Proposal to Provide Third-party Audits of the Ft. Collins EMS and Biosolids Programs (Note: Interested parties are encouraged to attend any portion of the audit in which they may have an interest. According to NBP requirements in person or telephone interviews with regulators must be included as part of the audit.) Samples of clear well-prepared audit plans with schedules are presented as Attachment D for a simple system and a complex system; verification audit reports are presented for each of these examples. NSF-ISR does not issue certificates of completion for this standard. The Certification Body is the National Biosolids Partnership, which issues the certificates based on the recommendation of NSF-ISR, acting as the officially approved NBP third party auditor. D. Assigned Personnel NSF-ISR has three certified NBP auditors: Dr. William R. Hancuff, NBP certified lead auditor for both EMS and biosolids, Jack McVaugh, NBP certified auditor for both EMS and biosolids, and Alan Cassel, NBP certified auditor for biosolids. For this project we propose the use of Dr. Hancuff. Dr. Hancuff has over 30 years of diversified environmental engineering and management experience. His expertise is based on both national and international work in all aspects of environmental engineering including: environmental management system (EMS) development, environmental compliance services, public works water and wastewater planning and design, environmental and health impact analyses, technical and economic feasibility studies, regional framework strategies for water quality, hazardous waste management cost modeling, and air quality assessments. Project management includes: EMS audits, federal environmental regulation development, hazardous waste site investigations, environmental regulatory compliance audits, pollution prevention through waste minimization, energy recovery from solid waste, biosolids treatment and disposal, toxic and hazardous waste studies, environmental impact assessments, storm water management, water resources investigations, potable water system planning, and numerous municipal and industrial waste treatment feasibility and cost studies. Dr. Hancuff has gained extensive experience in environmental auditing over the past 20 years and is a registered Lead Auditor with Registration Accreditation Board (RABQSA/Exemplar Global) in the United States and a Principal Auditor with the internationally recognized IEMA-Environmental Auditors Registration Association (EARA) based in London, England. He has also received the certified lead auditor training for conversion certification as an ISO 50001 Energy Management System Lead Auditor and ISO14001:2015 lead auditor. Dr. Hancuff has served on over a hundred environmental audit/assessment teams conducting environmental compliance evaluations on facilities and systems 7 NSF –ISR Proposal to Provide Third-party Audits of the Ft. Collins EMS and Biosolids Programs throughout the world. He has also served as NSF-ISR’s lead auditor on all NBP verification and interim audits for the past 15 years. He has experience with biosolids regulatory standards as established by the EPA based on his work throughout the US on biosolids certifications; and is also familiar with the Colorado regulations based on his biosolids certification work with Denver and his extensive work with Air Force Bases throughout the state. He has extensive experience with organizations that perform solids air-drying and produce both class A and class B biosolids for land application on farm and pasture land for grazing. E. Sustainability/TBL Methodology NSF International demonstrates its commitment to sustainability by upholding numerous sustainable practices throughout the organization including: • We undergo regular water quality assessments to verify that no harmful pollutants are discharged into waterways • Our drinking water treatment lab, which tests residential and commercial water treatment and filtration products, recycles more than 2 million gallons of water annually. • We encourage employees to participate in the company’s sustainability initiatives. Our Sustainability Committee focuses on recycling and employee education, and our organic garden has produced more than 2,000 pounds of fresh produce for donation to area food kitchens. • We practice regular recycling and waste reduction including purchasing recycled-content products and incorporating these practices into our policies. We recycle an average of 51,882 pounds of metals (copper, brass and stainless steel) annually. NSF International has earned Silver LEED certification (Leadership in Energy and Environmental Design) from the U.S. Green Building Council for its laboratory addition. NSF also has earned ISO 14001 environmental management system certification, which demonstrates the organization’s overall commitment to environmental stewardship. NSF also developed an environmental management systems (EMS) policy that includes these core values: • NSF International is committed to providing environmental leadership in all aspects of its work. • NSF considers the environmental impact of its operations activities and takes appropriate steps to minimize or prevent environmental pollution. 8 NSF –ISR Proposal to Provide Third-party Audits of the Ft. Collins EMS and Biosolids Programs • NSF strives to go beyond compliance in meeting relevant environmental laws, regulations and other applicable requirements. • NSF conducts its operations in a manner that is designed to minimize the impact on the environment and the people who live and work in that environment. • NSF is dedicated to conformance with the requirements of ISO 14001, and to the continual improvement of its environmental management system by establishing and meeting environmental targets and objectives. F. Cost and Work Hours NSF-ISR, a fully accredited certification body for ISO 14001:2004 and ISO 14001:2015, bases its quotation practices from IAF Mandatory Document 5 (MD 5), which all certification bodies adhere to in order to ensure continuity in the quotation process amongst accredited certification bodies. Audit durations as captured on the attached quotation for ISO 14001 Audit Services (Attachment A) were confirmed utilizing the MD 5 audit duration table for ISO 14001and key information provided within the ISO 14001 Request for Quotation. The request for proposal identifies two distinctly different NBP service activities: verification audits and interim audits. Because these services are different they have separate cost estimates. The following present the estimates for each activity. The scope of the verification audit specifically includes a comprehensive review and evaluation of all BMP Elements to determine the extent to which they meet the minimum conformance standards presented in the NBP Third Party Verification Auditor Guidance. It also involves the evaluation of the effectiveness of the implementation of each of the procedures designed to meet the NBP standards. Work involves document review, interviews and field observations. The most critical component of the audit is the determination of the BMP effectiveness and performance, which involves review of the organizations progress towards goals and objectives; BMP outcomes (environmental performance regulatory compliance, interested party relations, and quality practices.); actions taken to correct minor nonconformances (and opportunities for improvement, as appropriate); corrective action requests and responses and preventive actions. The audit consists of two stages: 1)the Operational Readiness Review (ORR), which includes the document review desk audit and 2) the on-site verification audit. The scope of the interim audit includes a review of areas related to the organization’s progress toward goals and objectives; BMP outcome requirements for environmental performance, regulatory compliance, relations with interested parties, and quality biosolids management practices; actions taken to correct minor non-conformances; the management review process; and corrective and preventive action notices and responses. The review of these areas is generally 9 NSF –ISR Proposal to Provide Third-party Audits of the Ft. Collins EMS and Biosolids Programs covered in Elements 5, 14, 16 and 17. In addition, other BMP components that are typically audited include Elements 1, 2, 6, 9, 14, 15, and 16. Specific elements that are audited in-depth vary from interim audit to interim audit such that over the course of the four interim audits between re-verification audits all elements are addressed. Work involves document review, interviews, and field observations. G. Firm Capability National Biosolids Partnership NSF-ISR was one of the three original audit companies selected by the National Biosolids Partnership (NBP) in 2003 to provide professional audit services to perform verification and interim audits for the Biosolids Management Program and its Environmental Management Systems. Over the past 12 years NSF has performed verification audits for over half of all the organizations certified by NBP. We have performed audits for both the largest system (Metropolitan Water Reclamation District of Greater Chicago) and smallest system (Central Davis Sewer District - Kaysville, UT) in the US. In addition to the above two locations, NSF-ISR has conducted EMS verification and interim audits for the NBP Biosolids Management System certification program for the following locations throughout the US:  Fort Worth, TX  Waco, TX  San Francisco, CA  Santa Rosa, CA  Atlantic County, NJ  King County, WA (Seattle)  Louisville, KY  Madison, WI  Butler County, OH  Greenville, SC  Denver, CO  Albany, OR  Grand Rapids, MI  Columbus, GA  Alexandria, VA  Richmond, VA  St. Cloud, MN  Moorehead, MN In summary, NSF-ISR has more experience in auditing for the NBP EMS certification program than any other company. 10 NSF –ISR Proposal to Provide Third-party Audits of the Ft. Collins EMS and Biosolids Programs ISO 14001 NSF-ISR draws upon more than 40 years of expertise in environmental management systems and helped develop the first ISO 14001 standard in 1996. NSF-ISR maintains accreditation by ANAB to 18 standards, including ISO 14001. NSF-ISR, and our dedicated technical team, continues to support global environmental initiatives. Please see Appendix A for a copy of NSF-ISR’s ANAB Certificate of Accreditation. We have significant experience in working with local to regional to global companies on their initial, transfer, and ongoing audit requirements. As a testament to our relevant experience, NSF-ISR has successfully partnered with many public utility and transit agencies as they sought to certify and strengthen their EMS systems. Below is a summary from a few of those transit or public sector organizations that we’ve partnered with for their ISO 14001 certification needs.  City of Asheville, Asheville Redefines Transit (ART) In early 2015, NSF-ISR was contracted by City of Asheville’s Asheville Redefines Transit (ART) for their Environmental Management Systems certification process. In October 2015, the City of Asheville ART achieved certification to ISO 14001. When asked why a city transit system would want to adopt an EMS, a representative from the City of Asheville ART responded “as you can imagine, large buses running all day long can have a pretty big impact on the environment. Following an EMS has the potential to reduce emissions, increase fuel economy, and limit oil in wastewater. The [ISO 14001] certification shows our commitment to prioritizing environmental sustainability for the ART service.”  Maryland Port Administration (MPA) MPA recertified with NSF-ISR in May 2014. MPA’s Environmental Management System approach touches on everything from cargo handling and facility management to its automotive and marine fleet, regulatory requirements and purchasing practices. Throughout its certification, MPA has continued to reduce air emissions from MPA sources, has phased out underground storage tanks to reduce the potential of petroleum leaks, improve storm water management practices, ensure on-going spill prevention and response plans are practiced, improve recycling and waste management practices, reduce energy consumption and increase efficiencies in use of raw materials, reduced waste and cost and improved compliance with environmental regulations. H. Additional Information - References Metropolitan Water Reclamation District of Greater Chicago Chicago, IL Dan Collins 708-588-4300 Central Davis Sewer District Kaysville, UT 11 NSF –ISR Proposal to Provide Third-party Audits of the Ft. Collins EMS and Biosolids Programs Leland Myers 801-560-3938 St. Cloud Public Utilities St. Cloud, MN Emma Larson 320-650-2960 City of Asheville Asheville Redefines Transit (ART) Asheville, NC Mr. Yuri Koslen 828-232-4522 Maryland Port Administration Baltimore, MD Barbara McMahon 410-633-1147 12 NSF –ISR Proposal to Provide Third-party Audits of the Ft. Collins EMS and Biosolids Programs APPENDICES Appendix A – NSF-ISR ANAB Certificate of Accreditation Appendix B- ISO 14001 Quotation Appendix C- NBP Verification Quotation Appendix D- Sample Audit Plans with Schedules and Verification Audit Reports Appendix E- Auditor Resumes We appreciate the opportunity to propose our services as ISO 14001 & NBP verifiers and look forward to continuing to work with you. Sincerely, Jeanette Halliday Senior Business Development Manager NSF International Strategic Registrations 13 NSF –ISR Proposal to Provide Third-party Audits of the Ft. Collins EMS and Biosolids Programs Appendix A NSF-ISR ANAB Certificate of Accreditation 14 NSF –ISR Proposal to Provide Third-party Audits of the Ft. Collins EMS and Biosolids Programs Appendix B ISO 14001 Quotation Date: 1/11/2017 Rev: Contact: Company: Phone: Address: E-mail: Standard I: Standard II: Hourly Rate: $163 $1,300 Personnel: Streets Department = 60 employees Personnel Range: 26-45 Water Production Division = 39 employees 46-65 Water Reclamation and Biosolids Division = 43 employees Type: Set Up: Year: 2017 Year: 2018 Year: 2019 At No Charge - - 1.0 Day NSF Account Manager $1,300 - - 1.0 Day Dr. Hancuff $1,300 - - 4.0 Days Dr. Hancuff $5,200 - - 3.5 Days Dr. Hancuff $4,550 - - 3.5 Days Dr. Hancuff $4,550 - - 2.0 Days Dr. Hancuff - $2,600 - 2.0 Days Dr. Hancuff $2,600 2.0 Days Dr. Hancuff - $2,600 - 2.0 Days Dr. Hancuff - - $2,600 2.0 Days Dr. Hancuff $2,600 2.0 Days Dr. Hancuff - - $2,600 0.5 Day NSF Account Manager $650 $650 $650 $650 $650 $650 Review of corrective plans, if needed, will be charged at $162.50/hour $18,200 $9,100 $9,100 NSF International Strategic Registrations, Ltd (2) This Quotation is for and based upon the current, effective International Standard(s) selected by your Organization. CLIENT understands and acknowledges that there are regular revisions to International Standards (typically every 5 to 8 years). These revisions, along with NSF accreditation body requirements, may require NSF-ISR to modify its activities and the associated pricing herein. As such, CLIENT expressly consents to pricing adjustments to reflect changes from time to time in the International Standards and accreditation body requirements. (1) NSF-ISR does not charge for Accreditation Marks. Notes: Customer Acceptance and Agreement (3) This Quotation incorporates by reference the required Terms and Conditions for accredited NSF-ISR Registration 734-827-3804 789 North Dixboro Road, Ann Arbor, MI 48105 - USA NSF International Strategic Registrations, Ltd Jeanette Halliday Signature, Title, Date Pat Johnson 970-221-6816 purchasing@fcgov.com Water Production Division ISO 14001:2015 Upgrade Recertification Audit Transfer Single Site 1 Transfer 3 existing single site ISO 14001:2004 registrations for Fort Collins' Streets Department, Water Production Division & Water Reclamation and Biosolids Division Water Reclamation and Biosolids Division ISO 14001:2015 Surveillance Audit #1 Water Reclamation and Biosolids Division ISO 14001:2015 Surveillance Audit #2 Annual Audit Related Costs, Excluding Travel Expense: Auditor meals will be billed at $40 per diem in lieu of actual meal costs Auditor Travel Expense Billed At Cost per Fort Collins Expense Guidelines with Receipts Provided 15 NSF –ISR Proposal to Provide Third-party Audits of the Ft. Collins EMS and Biosolids Programs Appendix C NBP Verification Quotations Date: 1/11/2017 Rev: Contact: Company: Phone: Address: E-mail: Standard I: Standard II: Hourly Rate: $163 $1,300 Type: Set Up: Year: 2017 Year: 2018 Year: 2019 1.5 Days Dr. Hancuff $1,950 - - - - 0.5 Days Dr. Hancuff $650 - - 2.0 Days Dr. Hancuff $2,600 - - 0.5 Days Dr. Hancuff $650 - - Auditor Travel Time Dr. Hancuff $600 Verification Audit Office Audit 1 Day Dr. Hancuff $1,300 Treatment and biosolids operations evaluation 1 Day Dr. Hancuff $1,300 Evaluation of representative application site 1 Day Dr. Hancuff $1,300 Preparation, Scheduling, Coordination, and Report Creation 1.5 Day Dr. Hancuff $1,950 Dr. Hancuff $600 - Interim Audits 0.5 Days Dr. Hancuff $650 $650 0.5 Days Dr. Hancuff - $650 $650 1 Day Dr. Hancuff $1,300 $1,300 1.0 Day Dr. Hancuff - $1,300 $1,300 0.5 Days Dr. Hancuff $650 $650 Preparation of final report 1.0 Day Dr. Hancuff $1,300 $1,300 Dr. Hancuff - $600 $600 $3,500 $1,900 $1,900 $16,400 $8,350 $8,350 NSF International Strategic Registrations, Ltd (1) Review of corrective plans, if needed, will be charged at $162.50/hour Notes: Customer Acceptance and Agreement 734-827-3804 789 North Dixboro Road, Ann Arbor, MI 48105 - USA NSF International Strategic Registrations, Ltd Jeanette Halliday Signature, Title, Date Pat Johnson 970-221-6816 purchasing@fcgov.com Interviews and tour of treatment plant/biosolids processes Transfer Single Site 2 Establish a new Biosolids Management Program Verification for the City of Fort Collins per National Biosolids Partnership Requirements. Office Audit – review of corrective actions Auditor Travel Time Annual Audit Related Costs, Including Estimated Travel Expense: Auditor meals will be billed at $40 per diem in lieu of actual meal costs Auditor Travel Expense Billed At Cost per Fort Collins Expense Guidelines with Receipts Provided (Estimated) NSF International Strategic Registration Management Systems Registration Proposal for Registration Services ("Quotation") (This is a confidential Quotation intended for the purposes of the issued client only and valid for 90 days from issuance.) ORR summary report and observations preparation City of Fort Collins ISO 14001:2004 - Medium Risk 16 NSF –ISR Proposal to Provide Third-party Audits of the Ft. Collins EMS and Biosolids Programs Appendix D Sample Audit Plans, Schedules and Verification Audit Reports Simple Audit plan - 1 - NATIONAL BIOSOLIDS PARTNERSHIP EMS VERIFICATION AUDIT PLAN (NAME REDACTED) JULY 1 – JULY 2, 2013 Company / Client: (name redacted) Public Utilities Street/P.O. box: (redacted) City / State / post code: (redacted) Type of Audit: Verification Audit Standard / Date of issue: National Biosolids Partnership BMP Standard – July 2011 Verification Auditor Guidance November 2001 (Latest Revision August 2011) Audit Dates (on site): July 1 – July 2, 2013 Management Representative: (redacted) Telephone (redacted) Email (redacted) Lead Auditor: William R. Hancuff Cell phone 703-585-4799; whancuff@aol.com Auditor: NA We request that the following be made available to be used for the audit:  A reserved space to be used for audit purposes  An organization chart with full names of personnel  The audit plan with full names of our points of contact for each element  Facility layouts, where appropriate  A master list of all documented procedures with current revisions  Access to a copier and the possible use of an HP Laser Printer Should you have any questions, please don’t hesitate to contact me at: (703)585-4799 Thank you!!! Bill Hancuff The organization must provide representatives to accompany team members during the entire audit. Note: Interested parties are encouraged to attend any portion of the audit in which they may have an interest. In person or telephone interviews with regulators will be included as part of the audit. DAY 1 Simple Audit plan - 2 - Date Time 1) Auditor Elemt. Activity / Element Department Name 2) Comment 7/1/13 Monday 8:00 – 8:15 Bill Arrival, Introductions, General Orientation Operations (redacted) 8:15 - 8:30 Bill Opening Meeting Implementation Team (redacted)& team 8:30 – 11:00 Bill Var (w/14 & 16 Review PA & CA from ORR Operations (redacted) 11:00 – 12:00 Bill 5 Goals and Objectives Operations (redacted) 12:00 – 1:00 Bill Lunch NA 1:00 – 1:45 Bill 1, 2, 7, 15, & 17 Policy, Roles and Responsibilities, & Mgmt Executive Director 1:45 – 4:00 Bill 8, 10, & 13 Evaluate WWTP Operational Controls and Monitoring and Measurement, Training, etc. Operations Personnel (redacted) 4:00 – 4:30 Bill Prepare auditor notes NA 4:30 – 5:00 Bill Summarize days activities Operations DAY 2 Date Time 1) Auditor Elemt. Activity / Element Department Name 2) NATIONAL BIOSOLIDS PARTNERSHIP VERIFICATION AUDIT REPORT (name redacted) Wastewater Treatment Facility Audit conducted by NSF-International Strategic Registrations William R. Hancuff, Lead Auditor References: National Biosolids Partnership (NBP) EMS Elements NBP Third Party Verification Auditor Guidance – November 2001 (Latest Revision August 2011) NBP Code of Good Practice City of (redacted), (redacted) Wastewater Treatment Facility Biosolids Management Program Environmental Management System Manual 2013 Final Report – July 26, 2013 2 INTRODUCTION The purpose of the Biosolids Environmental Management Program (BMP) Third Party Verification audit is to verify the City of (redacted), (redacted) Wastewater Treatment Facility; Biosolids Management Program (BMP) conforms to National Biosolids Partnership (NBP) requirements. The goal of the Third Party Verification audit is to collect and evaluate objective evidence that determines whether the facility BMP is functioning as intended, that practices and procedures are conducted as documented, and that the BMP as implemented conforms to the NBP’s BMP Elements, the Code of Good Practice and the BMP program objectives. RECOMMENDATION The results of the (redacted) verification audit and review of their corrective action plans are positive, and it is the recommendation of the audit team that the (redacted) Wastewater Treatment Facility BMP receive “Certification” status. Certification is not the end, but rather the beginning of a continuously improving biosolids management program. AUDIT SCOPE In general terms, the scope of the Third Party Verification audit encompasses the entire biosolids value chain (pretreatment, collection and treatment, solids processing through final end use or disposal) with special attention on those practices and management activities that directly support solids and biosolids-related operations, processes, and activities within the wastewater treatment plant’s functions. The NSF- International Strategic Registrations, Ltd. (NSF-ISR) conducted a third party verification audit of the (redacted) Wastewater Treatment Facility BMP. The verification began with a documentation desk audit and on-site readiness review (ORR) conducted from 27 November 2012 to 28 November 2012 with the results presented to (redacted) in a letter report on 28 November 2012. The process continued with an on-site verification audit from 1 July 2013 to 2 July 2013. The on-site audit team consisted of Dr. William R. Hancuff, Lead Auditor. The physical biosolids facilities included in the audit and visited during the operational readiness review and verification audit were the (redacted) wastewater treatment facilities, including the laboratory, headwork’s bar screens, vortex grit removal, primary clarifiers, activated sludge (BNR) units, secondary clarifiers, gravity belt thickeners, anaerobic digesters, boilers (digester gas, natural gas, fuel oil), heat exchangers, solids storage tanks (6), ultraviolet light disinfection and a land application farm site. The following individuals were interviewed as part of the audit process: 3 - (name redacted) – Public Services Director - (name redacted) – Assistant Public Utilities Director - (name redacted) – Wastewater Services Superintendent - (name redacted) – Environmental Compliance, EMS Coordinator - (name redacted) – Water Quality Coordinator - (name redacted) – Utilities Maintenance Mechanic - (name redacted) – Utilities Maintenance Mechanic - (name redacted) - Operations - (name redacted) – Lab Technician - (name redacted) – Equipment Operations - (name redacted) – Land owner and farmer - (name redacted) – Senior Pollution Control Specialist – Resource Management and Assistance Division, (redacted) Pollution Control Agency DOCUMENTATION REVIEW Documentation review was conducted in two parts, the desk audit combined with the ORR, and the verification audit. During each of these activities various documents were reviewed to verify conformance with the National Biosolids Partnership (NBP) BMP Elements using the NBP Third Party Verification Auditor Guidance. Additionally interviews were conducted with various personnel to obtain supplemental objective evidence on the effectiveness of the implementation of the BMP. Attachment 1 summarizes the documents and other objective evidence associated with each element that was considered during the above-mentioned audit steps. DESK AUDIT/OPERATIONAL READINESS REVIEW A complete document review was performed as a desk audit. The principal focus was on the BMP Element procedures contained in the 2012 and 2013 (redacted) EMS Manual. The ORR involved assessment of supplemental information such as cross referenced procedures, monitoring and measurement records, background reference information, summary of goals and objectives related to outcomes, and various public outreach and communication materials. It also entailed an overview of the biosolids value chain critical control points. The results of the desk audit/ORR provided a number of observations and opportunities for improvement. This initial effort resulted in 20 observations, 14 opportunities for improvement, and 6 positive finding. Detailed results from the desk audit/ORR are provided in Attachment 2. The majority of the observations identified during the desk audit/ORR were addressed by the time of the on-site verification audit. Significant improvements in the BMP were made as a result of these efforts and there were only a few shortcomings that required corrective actions (CA) or CA plans before certification could be recommended. VERIFICATION AUDIT FINDINGS 4 The verification audit supplemented the desk audit and ORR such that all elements of the standard were addressed in considerable detail. The verification audit included review of the latest version of the (redacted) Biosolids Environmental Management System Manual dated 2013 containing the current element procedures, and utilized the most recent version of the NBP Third Party Verification Auditor Guidance dated August 2011. The verification audit found 5 minor non-conformances and 6 opportunities for improvement, as well as 7 commendations or positive observations, the latter including those observed during the initial phases of the audit. The following is a review of the positive observations made during the audit process. Minor non-conformances and opportunities for improvement follow and are presented in the sequence of the NBP standard elements listed by requirement number. These numbers correspond to the Element minimum conformance requirements. Positive Observation Overall – (redacted) maintains exceptionally clean and well-maintained wastewater treatment facilities – Best in Class. Element 1 – The EMS manual has an excellent introductory section that provides a detailed description of the overall wastewater treatment facilities operations; critical control points and biosolids value chain. Element 3 – Table 3.1 provides an exemplary description of Potential Significant Impacts associated with each of the critical control points. Element 4 – The EMS team has provided a good summary of the regulatory requirements including specific standards, limits, reports, records, and due dates. Element 11 – Facility personnel have developed the first MSDS for Biosolids observed by the auditor. Element 12 – (redacted) has created a model template for use in capturing documentation review and revision history records. Element 14 – (redacted) has proven to be a leader in establishing a program to verify the effectiveness of corrective actions subsequent to their implementation in the Non- conformances: Preventive Action and Corrective Action Procedure Minor Nonconformances Requirement 5.5 – Not all of the Goals and/or Objectives were specifically measureable using traditional units of measure such as pounds, cubic yards, concentration, percent solids, frequency of occurrences, number of events, etc. (as opposed to yes/no measurability). 5 Requirement 6.5 – There was no specific information available demonstrating that input (either direct or indirect) from interested parties was considered in updating goals and objectives. Requirement 10.4 – Not all appropriate preventive maintenance procedures and work management systems for maintaining equipment, instrumentation, vehicles, and other treatment technology and process control system associated with biosolids management activities have been addressed in the EMS. Requirement 11.2 – The review and evaluation of the emergency preparedness and response procedures have not yet been tested as identified in the procedure; i.e. there have been no table top exercises or spill drills. Requirement 12.2 – The Documentation, Document Control and Record Keeping Procedure does not clearly describe the system used for marking each page of each procedure with a version number and date. Opportunities for Improvement Element 1 – Consider referencing the Master Calendar for the EMS program in the Element 1 – Documentation of Environmental Management System for Biosolids. Requirements 5.1 and 13.1 – There is an inconsistency between Element 4 - Goals and Objectives for Continual Improvement procedure # 8, and Element 13 – Monitoring and Measurement procedure # 3, which address the frequency of tracking progress towards accomplishment of the goals and objectives. Requirement 9.5 – The Communication Procedure does not currently reference that the Element 8 – Training procedure section 8.1 and 8.2 is used to communicate relevant information about biosolids management activities and all 17 EMS elements to employees. Requirement 12.2 – Consider including a footer on each page of any printed EMS procedure that reflects it is an un-controlled document and should not be used, but the current version is available …. Requirement 14.1 – Clarify how the Non-conformances: Preventive Action and Corrective Action Procedure addresses the identification, investigation, root cause analysis, development of corrective and preventive actions and tracking of all forms of noncompliance and nonconformance including audit findings, operational and maintenance findings, routine monitoring and measurement findings, regulatory findings and any other source of findings. Element 15 – Consider including the total cost savings associated with accomplishment of each goal and objective in the annual performance report to demonstrate the economic benefits attributable to the EMS. 6 The hard work and dedication of the BMP Team must be acknowledged. While attainment of the BMP verification goal is obviously a team effort, the hard work and dedication of (name redacted), (name redacted) , (name redacted) , (name redacted) must be recognized. Also, the encouragement, support and active participation of (name redacted) , Public Services Director and (name redacted) , Assistant Public Utilities Director ensure the success of this program. For the non-conformances, the (redacted) BMP Team will prepare Corrective Action/Improvement Forms and implement corrective actions according to their BMP procedures to provide continual improvements to their biosolids program. The corrective action/Improvement Forms will be presented to the lead auditor within 30 days. All corrective actions for minor nonconformities must be corrected within 30 days of the audit, or within the extensions beyond 30 days found to be acceptable and approved by the lead auditor. As a further measure to demonstrate continual improvement the opportunities for improvement will be addressed to the maximum extent possible. The final report and recommendation for verification will be submitted to NBP within two weeks following approval of the corrective actions for the minor nonconformities submitted to the lead auditor. CITY OF (name redacted) WASTEWATER TREATMENT FACILITY COMMENTS The City of (redacted) Biosolids Management Program staff agrees with the findings of this audit and believe it accurately reflects the status of the program. With the continued dedication of the EMS team and all Public Utilities staff, the goal is to maintain the high standard that has been set. The City has already seen improvement in the Biosolids Management Program as a result of the development of the EMS and are hopeful the positive results will continue to occur. OUTCOMES MATTER The City of (redacted)s Wastewater Treatment Facility Biosolids Management Program initially established three biosolids BMP goals and 9 objectives within those goals. The BMP Team developed the goals and objectives. The goals and objectives for its BMP considered each of the four outcome areas of the NBP program as identified below: 1. Environmental Performance, 2. Regulatory Compliance, 7 3. Relations with Interested Parties, and 4. Quality Biosolids Management Practices. While it is not a requirement to attain all objectives established, it is a critical component of the system to make progress towards accomplishing the overall goals. The initial goals were established to a limited degree using Specific, Measurable, Achievable, Relevant, and Time Bound (SMART) criteria, while later modifications to the goals were developed specifically using that criteria. Although the initial goals and objectives were focused on outcome areas they could have been more specifically identified as to how they related to each of the areas. The facility’s performance relative to each of the above outcome groups is addressed below. In the Environmental Performance outcome area, (redacted) established two goals with six related objectives. Goal 1 for 2013 was to optimize the gravity belt thickener to improve overall quality of biosolids. Within that goal were three objectives: namely, to obtain and average of 9% total solids cake at the end of the gravity belt table. Keeping the GBT operating at 9% +/- 1% optimizes the performance of the system and maintains the desired quality of the product. Generating a minimum concentration of 9% product will ensure adequate storage capacity during none land application periods, but producing concentrations above 10% causes pumping issues. The first objective is to maintain the GBT product to between 8.5 % and 9.5% for 100% of the time. The second objective is to install a second GBT by June 2014 to provide redundancy in the process, reducing operational down time and guaranteeing consistent quality while meeting potential future demands for the product. The third objective is to fine-tune the continuous operation of the GBT. By using a total solids analyzer the fluctuation of the solids concentration can be determined on an hourly basis throughout the pumping cycle and adjustments can be made to operational controls quickly. The evaluation of this degree of control will be made from July 2013 through July 2014 and the results will be used to implement the determined controls. The second goal for 2013 is related to the expansion and upgrade of the biosolids value chain through a technical evaluation of future biosolids management alternatives. The first objective is to finish the on-going investigation of options being conducted by a consultant, with the resultant product being a Biosolids Roadmap by the end of December 2013. The next two objectives are better described as action plans along the way to determining more precisely measurable targets. The first is to evaluate the variety of options developed in the formation of the Biosolids Roadmap to select the most promising option or options. And the third objective is to select at least one option for further refinement through a pilot study by the end of 2014. In the Regulatory Compliance outcome area, the second goal described above in the Environmental Performance outcome area and involves the expansion and upgrade of the biosolids value chain through evaluation of future biosolids management alternatives. One of the key criteria of the investigation is the constraints placed on each of the potential options by regulations. Those regulations having the greatest potential for 8 defining options include land application rules, air pollution control regulations and biosolids stabilization criteria. Goal number 3 – maintaining and improving training of biosolids staff also impacts the regulatory outcome area. The regulations in the state of (redacted) require Type IV Waste Disposal Operator or Inspector Certificate for land application of biosolids. The ultimate objective of this goal is to maintain at least 70% of the biosolids employees qualified by type IV training. The intermediate steps or objectives are to develop and implement a new record form to track new employees and staff members re-assigned to the biosolids management program to be used to ensure the completion of biosolids related training during the employee’s probationary period. The second objective is to establish an annual review method (similar to one currently used for laboratory SOPs and safety updates) to keep all staff up to date on biosolids management program procedures. In the Relations with Interested Parties outcome area, there is some overlap with the goals and objectives discussed above in the Environmental Performance Outcome area. Specifically, the second goal for 2013, which is related to the expansion and upgrade of the biosolids value chain through evaluation of future biosolids management alternatives takes into consideration the concerns of a multitude of interested parties including the regulators, farmers, local citizen concerns and indirectly relates to reducing operating costs, which always has high public interest. In the Quality Biosolids Management Practices outcomes area, all of the goals and objectives discussed above in the Environmental Performance Outcome area and regulatory compliance area overlap with this outcome. Specifically, Goal 1 related to optimizing the operation of the gravity belt thickener will result in a higher quality and more reliable biosolids product through implementation of the objectives dealing with biosolids management practices. Goal 2 has the greatest potential impact in this outcome area because all options considered for evaluation will result in improvements in quality practices. And Goal 3 related to training is in itself a quality practice. CONCLUSIONS AND RECOMMENDATIONS (TO BE MADE) The results of the verification audit show the (redacted) Wastewater Treatment Facility has a strong Biosolids Environmental Management Program. The NSF lead auditor reviewed and approved the corrective action plans for each of the minor non- conformances identified during the verification audit. Therefore the “Certification” recommendation for the Wastewater Treatment Facilities Biosolids Management Program (BMP), (redacted), (redacted) is made to the NBP. The full implementation of the corrective actions for the minor nonconformances will be accomplished according to the schedule proposed in the corrective action worksheets. It is expected that the opportunities for improvement will each be addressed although they do not require formal closure. 9 As was mentioned previously, a BMP is a continuous improvement process, and certification is not the end -- it is the beginning. The results of this and future audits will provide value added to the system and should be viewed as an overall opportunity to improve. Every audit is a snapshot in time, and does not, or cannot, identify each and every area for improvement. And yet, while no single audit identifies all of the areas for improvement the results of each audit provide an additional incremental step in the overall system’s improvement. Each internal or interim audit will include a review of: the organization's progress toward goals and objectives; EMP outcomes (environmental performance; regulatory compliance; interested party relations; quality practices); actions taken to correct minor nonconformances; the management review process; corrective action requests and responses; and preventive actions. In addition to the above, all of the elements will be audited individually over the four-year interim period between certification audits, such that all elements are addressed. 10 Attachment 1 Documents and Other Objective Evidence Reviewed During the Desk Audit/On-Site Readiness Review And Verification Audit Element 1. BMP Manual - Interview with (name redacted) – Public Services Director - Interview with (name redacted) – Assistant Public Utilities Director - Interview with (name redacted) – Wastewater Services Superintendent - Interview with (name redacted) – Environmental Compliance, EMS Coordinator - Interview with (name redacted) – Utilities Maintenance Mechanic - Interview with (name redacted) – Lab Technician - Interview with (name redacted) – Equipment Operations - BMP Manual including all element procedures – November 2012 and July 2013 - BMP manual elements approvals by (name redacted) – Public Service Director - Element 1: City of (redacted) Biosolids EMS Manual, Version 1, dated 1/16/2013 - Attachment 1.1 – Table 1.1 – Dates of Importance - Attachment 10.1 – Letter of Expectations – identifying all (redacted)s EMS expectations for contractors working on biosolids critical control points (to be signed by contractors) - Element 2: Biosolids Management Policy, Version 0, created August 2011 Element 2. Biosolids Management Policy - Interview with (name redacted) – Public Services Director - Interview with (name redacted) – Assistant Public Utilities Director - Interview with (name redacted) – Wastewater Services Superintendent - Interview with (name redacted) – Environmental Compliance, EMS Coordinator - Interview with (name redacted) – Utilities Maintenance Mechanic - Interview with (name redacted) – Lab Technician - Element 2: Biosolids Management Policy, Version 0, created August 2011 - Attachment 2.1: NBP Code of Good Practice - Attachment 2.2: (redacted) Biosolids Mission Statement Poster - Policy incorporating the Code of Good Practice City of (redacted) and Resolution Adopting the NBP Code of Good Practice for the City’s Biosolids Management Program – January 7, 2013 - Wastewater Treatment Facility & Biosolids Master Calendar 2013 Element 3. Critical Control Points - Interview with (name redacted) – Wastewater Services Superintendent - Interview with (name redacted) – Environmental Compliance, EMS Coordinator 11 - Interview with (name redacted) – Water Quality Coordinator - Interview with (name redacted) – Utilities Maintenance Mechanic - Interview with (name redacted) – Utilities Maintenance Mechanic - Interview with (name redacted) – Lab Technician - Interview with (name redacted) – Equipment Operations - Element 3 – Process Control Points, Version 1, dated 4/09/2013. - Table 3.1: Process Control Points, Operational Controls, SOPs, Monitoring/Measurements and Potential Significant Impacts, undated. - (redacted) Wastewater Treatment Facilities, Process Flow and Biosolids Diagram. Element 4. Legal and Other Requirements - Interview with (name redacted) – Assistant Public Utilities Director - Interview with (name redacted) – Wastewater Services Superintendent - Interview with (name redacted) – Environmental Compliance, EMS Coordinator - Interview with (name redacted) – Water Quality Coordinator - Interview with (name redacted) – Utilities Maintenance Mechanic - Interview with (name redacted) – Utilities Maintenance Mechanic - Interview with (name redacted) – Lab Technician - Interview with (name redacted) – Equipment Operations - Interview with (name redacted) – Land owner and farmer - Interview with (name redacted) – Senior Pollution Control Specialist – Resource Management and Assistance Division, (redacted) Pollution Control Agency - Element 4: Legal and Other Requirements, Version 1, dated 6/12/2013. - Table 4.1:Legal Requirements and Guidance Specific to the City of (redacted) Biosolids Land Application Program. - Table 4.2: NPDES Permit Reporting Requirements and Related Reports Submitted - NPDES/SDS SCWWTF Permit dated 4/15/2013 - Review of Industrial Waste Pretreatment program (26 significant industrial users) - (redacted) Pretreatment Program – 2011 Annual Report – Feb 24, 2012 - (redacted) Pretreatment Program – 2012 Annual Report – Feb 20, 2013 - State of MN – Land Application of Biosolids – General Management Requirements for Agricultural Sites. - NPDES Permit No. MN0040878 – City of (redacted) Biosolids Management Program Annual Report for Cropping Year 2011 - NPDES Permit No. MN0040878 – City of (redacted) Biosolids Management Program Annual Report for Cropping Year 2012 Element 5. Goals and Objectives - Interview with (name redacted) – Assistant Public Utilities Director - Interview with (name redacted) – Wastewater Services Superintendent - Interview with (name redacted) – Environmental Compliance, EMS Coordinator - Interview with (name redacted) – Utilities Maintenance Mechanic - Interview with (name redacted) – Lab Technician 12 - Element 5:Goals and Objectives for Continual Improvement, Version 1, dated 5/30/2013. - Table 5.1 - Goals and Objectives Template - 2012 and 2013 Biosolids Management System Goals and Objectives - Action Plans contained in Table 5.1 – Goals and Objectives, updated for 2013 Element 6. Public Participation in Planning - Interview with (name redacted) – Wastewater Services Superintendent - Interview with (name redacted) – Environmental Compliance, EMS Coordinator - Interview with (name redacted) – Utilities Maintenance Mechanic - Interview with (name redacted) – Lab Technician - Element 6: Public Participation in Planning, Version 1, dated 1/16/2013. - Table 6.1 City of (redacted) Biosolids Management Program Public Participation Mechanisms - Attachment 6.2 Letter to interested parties – open invitation to observe verification audit. - Completed letter to interested parties dated June 11, 2013 - (name redacted) Website Element 7. Roles and Responsibilities - Interview with (name redacted) – Public Services Director - Interview with (name redacted) – Assistant Public Utilities Director - Interview with (name redacted) – Wastewater Services Superintendent - Interview with (name redacted) – Environmental Compliance, EMS Coordinator - Interview with (name redacted) – Water Quality Coordinator - Interview with (name redacted) – Utilities Maintenance Mechanic - Interview with (name redacted) – Lab Technician - Interview with (name redacted) – Equipment Operations - Element 7: Roles and Responsibilities, Version 1, dated 6/03/2013 - Attachment 7.1 Table 7.1 EMS Team Members 2011 – Present - Attachment 7.2 Table 7.2 (redacted) Biosolids Management Program Roles and Responsibilities - Biosolids management program weekly status report 5-9-13 and 5-16-13 - Public Services Section – Public Utilities Department Organization Chart, undated - Attachment 10.1 – Letter of Expectations – identifying all (redacted)s EMS expectations for contractors working on biosolids critical control points (to be signed by contractors). Element 8. Training - Interview with (name redacted) – Wastewater Services Superintendent - Interview with (name redacted) – Environmental Compliance, EMS Coordinator - Interview with (name redacted) – Water Quality Coordinator 13 - Interview with (name redacted) – Utilities Maintenance Mechanic - Interview with (name redacted) – Utilities Maintenance Mechanic - Interview with (name redacted) - Operations - Interview with (name redacted) – Lab Technician - Interview with (name redacted) – Equipment Operations - Element 8:Training, Version 1, dated 5/22/2013 - Attachment 8.1 Employee Capability Sheet - Attachment 8.2 (redacted) Biosolids Management Program Training Requirement Matrix - Prehauling meeting – operations staff and contractors training - (redacted) BMP General Training Materials (power point slides – printed July 2013) - (redacted) BMP Training Material for collection and distribution personnel (power point slides – printed July 2013) - Type IV – Land Application Certificate Training conducted for the State of (redacted) (power point slides) - Attachment 10.1 – Letter of Expectations – identifying all (redacted)s EMS expectations for contractors working on biosolids critical control points (to be signed by contractors) Element 9. Communications - Interview with (name redacted) – Assistant Public Utilities Director - Interview with (name redacted) – Wastewater Services Superintendent - Interview with (name redacted) – Environmental Compliance, EMS Coordinator - Interview with (name redacted) – Utilities Maintenance Mechanic - Interview with (name redacted) – Utilities Maintenance Mechanic - Interview with (name redacted) - Operations - Interview with (name redacted) – Lab Technician - Interview with (name redacted) – Equipment Operations - Interview with (name redacted) – Land owner and farmer - Interview with (name redacted) – Senior Pollution Control Specialist – Resource Management and Assistance Division, (redacted) Pollution Control Agency - Element 9: Communication, revision 1, dated 3/04/2013 - Attachment 9.1 – Interested Parties Lists (Township Boards, County Boards, Application Site Landowner’s & Farmers Contacts, Other interested parties) - Table 6.1 City of (redacted) Biosolids Management Program Public Participation Mechanisms - Attachment 6.2 Letter to interested parties – open invitation to observe verification audit. - Completed letter to interested parties dated June 11, 2013 - Attachment 10.1 – Letter of Expectations – identifying all (redacted)s EMS expectations for contractors working on biosolids critical control points (to be signed by contractors) - (name redacted) Website - Biosolids Management Program Performance Report for 2012. 14 Element 10. Operational Control of Critical Control Points - Interview with (name redacted) – Wastewater Services Superintendent - Interview with (name redacted) – Environmental Compliance, EMS Coordinator - Interview with (name redacted) – Water Quality Coordinator - Interview with (name redacted) – Utilities Maintenance Mechanic - Interview with (name redacted) – Utilities Maintenance Mechanic - Interview with (name redacted) - Operations - Interview with (name redacted) – Lab Technician - Interview with (name redacted) – Equipment Operations - Element 10: Operational Controls, Version 1, dated 5/30/2013 - Attachment 10.1 – Letter of Expectations – identifying all (redacted)s EMS expectations for contractors working on biosolids critical control points (to be signed by contractors) - Attachment 10.2 – End of Recycling Season Checklist - Element 3 – Process Control Points, Version 1, dated 4/09/2013. - Table 3.1: Process Control Points, Operational Controls, SOPs, Monitoring/Measurements and Potential Significant Impacts, undated. - Element 13 – Monitoring and Measurement, Version 1, dated 5/30/2013 - Equipment Maintenance Request Form - City of (redacted) Biosolids Management Program Standard Operating Procedure Manual – 2013 - Wastewater Collection and Pretreatment SOP - Wastewater Stabilization and Solids Generation SOP - Solids Stabilization, Conditioning and Handling SOP - Biosolids Storage, Loading and Transportation SOP - Biosolids Beneficial Re-use (Recycling) SOP Element 11. Emergency Preparedness and Response - Interview with (name redacted) – Wastewater Services Superintendent - Interview with (name redacted) – Environmental Compliance, EMS Coordinator - Interview with (name redacted) – Utilities Maintenance Mechanic - Interview with (name redacted) – Lab Technician - Interview with (name redacted) – Equipment Operations - Element 11 – Emergency Response Plan, Version 1, dated 5/22/2013 - Attachment 11.1 – City of (redacted) Biosolids Management Program Emergency Response Plan, undated. - Attachment 11.2 – Emergency Numbers Cards for Vehicles - Attachment 11.3 – On the Spot Commercial Fleet Accident Report - Attachment 11.4 – City of (redacted) Biosolids Product Safety Data Sheet - Attachment 11.5 – (redacted) Biosolids Management Program Emergency Response Inventory - Attachment 11.6 – Public Relations and Communications 15 - Attachment 10.1 – Letter of Expectations – identifying all (redacted)s EMS expectations for contractors working on biosolids critical control points (to be signed by contractors) Element 12. BMP Documentation and Document Control - Interview with (name redacted) – Wastewater Services Superintendent - Interview with (name redacted) – Environmental Compliance, EMS Coordinator - Interview with (name redacted) – Utilities Maintenance Mechanic - Interview with (name redacted) – Lab Technician - Element 12: Documentation, Document Control and Record Keeping, Version 1, dated 3/05/2013. - Attachment 10.1 – Letter of Expectations – identifying all (redacted)s EMS expectations for contractors working on biosolids critical control points (to be signed by contractors) - Element 1: City of (redacted) Biosolids EMS Manual, Version 1, dated 1/16/2013. - Element 2: Biosolids Management Policy, Version 0, created August 2011 - Attachment 2.1: NBP Code of Good Practice - Policy incorporating the Code of Good Practice City of (redacted) and Resolution Adopting the NBP Code of Good Practice for the City’s Biosolids Management Program – January 7, 2013 Element 13. Monitoring and Measurement - Interview with (name redacted) – Wastewater Services Superintendent - Interview with (name redacted) – Environmental Compliance, EMS Coordinator - Interview with (name redacted) – Utilities Maintenance Mechanic - Interview with (name redacted) – Utilities Maintenance Mechanic - Interview with (name redacted) - Operations - Interview with (name redacted) – Lab Technician - Interview with (name redacted) – Equipment Operations - Interview with (name redacted) – Land owner and farmer - Interview with (name redacted) – Senior Pollution Control Specialist – Resource Management and Assistance Division, (redacted) Pollution Control Agency - Element 13 – Monitoring and Measurement, Version 1, dated 5/30/2013 - Element 10: Operational Controls, Version 1, dated 5/30/2013 - Element 3 – Process Control Points, Version 1, dated 4/09/2013. - Table 3.1: Process Control Points, Operational Controls, SOPs, Monitoring/Measurements and Potential Significant Impacts, undated. - Attachment 10.1 – Letter of Expectations – identifying all (redacted)s EMS expectations for contractors working on biosolids critical control points (to be signed by contractors) - City of (redacted) Biosolids Management Program Standard Operating Procedure Manual – 2013 - Wastewater Collection and Pretreatment SOP - Wastewater Stabilization and Solids Generation SOP 16 - Solids Stabilization, Conditioning and Handling SOP - Biosolids Storage, Loading and Transportation SOP - Biosolids Beneficial Re-use (Recycling) SOP Element 14. Nonconformances: Preventive and Corrective Action - Interview with (name redacted) – Wastewater Services Superintendent - Interview with (name redacted) – Environmental Compliance, EMS Coordinator - Interview with (name redacted) – Utilities Maintenance Mechanic - Interview with (name redacted) – Lab Technician - Element 14:Nonconformance: Preventive Action and Corrective Action, Version 1, dated 5/30/2013. - Attachment 14.1 – Corrective Action/Preventive Action Forms, undated - Attachment 14.2 – Corrective Action Plan Template, undated - Equipment Maintenance Request Form - (redacted) Biosolids Management System Corrective Action Plan table (ORR specific, updated monthly) - Internal Audit Report for audit conducted on June 18, 2012 report dated July 18, 2012. Element 15. Biosolids Management Program Report - Interview with (name redacted) – Wastewater Services Superintendent - Interview with (name redacted) – Environmental Compliance, EMS Coordinator - Interview with (name redacted) – Utilities Maintenance Mechanic - Interview with (name redacted) – Lab Technician - Element 15 – Biosolids Management Report, Version 1, dated 6/04/2013 - City of (redacted) Biosolids Management Report for 2012 - City of (redacted) Biosolids Management Report for 2013 - Biosolids Management Report for 2012 - website Element 16. Internal BMP Audit - Interview with (name redacted) – Wastewater Services Superintendent - Interview with (name redacted) – Environmental Compliance, EMS Coordinator - Interview with (name redacted) – Lab Technician - Element 16: Internal Biosolids Management Program Audit, Version 1, dated 6/05/2013 - Attachment 16.1 – Internal Audit Team Details, Lead Auditors Qualifications, Training and Responsibilities. - Attachment 16.2 – (redacted) Biosolids Management Program Internal EMS Audit Schedule - Internal Audit Report for audit conducted on June 18, 2012 report dated July 18, 2012. - Desktop Review conducted June 12, 2012 17 Element 17. Management Review - Interview with (name redacted) – Public Services Director - Interview with (name redacted) – Assistant Public Utilities Director - Interview with (name redacted) – Wastewater Services Superintendent - Interview with (name redacted) – Environmental Compliance, EMS Coordinator - Interview with (name redacted) – Lab Technician - Element 17: Management Review, Version 1, dated 5/29/2013 - Attachment 17.1 – (redacted) Biosolids Management Program, Management Review Agenda - Attachment 17.2 - (redacted) Biosolids Management Program, Management Review Report - Monthly Wastewater Services Leadership Team meeting minutes – June 4, 2013 - Attachment 17.3 – Biosolids Management Program Weekly Status Report, Management Review minutes, dated 4/15/2013 18 Attachment 2 Detailed Findings of the Desk Audit/On-site Readiness Review Positive Findings Element 1 – Excellent introductory material contained in the background section of the EMS manual. Element 3 – Exemplary description of Potential Significant Impacts associated with critical control points in Table 3.1. Element 4 – Good summary of the regulatory requirements for reporting and due dates. Element 11 – Development of the first MSDS for Biosolids. Element 12 – Model template for use of Documentation Review and Revision History Records. Element 14 – (redacted) is a leader in verifying the effectiveness of corrective actions subsequent to their implementation in the Non-conformances: Preventive Action and Corrective Action Procedure. Observations Item 2.1 – The City of (redacted) Council has not explicitly or by reference committed to the NBP Code of Good Practice. Item 4.2 – In the legal and other requirements element Table 4.1 presents general broad regulations and a permits list. The information given does not clearly include or cross- reference what specific standards, limits, reports, records, etc. the City must meet in order to be in compliance; i.e. the system has not established a record of applicable legal and other requirements. Item 5.1 – The Goals and Objectives for Continual Improvement Procedure does not clearly establish or define the frequency of periodically reviewing the progress on the biosolids program goals and objectives. Item 5.5 – Not all of the Goals and/or Objectives were measureable. Item 5.6 – Several of the City’s EMS goals and objectives have been accomplished, but the goals and objectives have not yet been updated. 19 Item 6.2 – The Public Participation in Planning Procedure does not address the organization’s method for notifying interested parties about their intent to receive an independent third party audit, or include a discussion of approaches for observing the audit. Item 7.1 – The Roles and Responsibilities Procedure does not currently identify the members of the EMS Team, and there is no description or summary of the roles and responsibilities of this team in performing biosolids management activities and EMS functions. Item 7.4 – The roles and responsibilities of the contractor retained to perform biosolids management activities his/her EMS functions are not clearly defined in Roles and Responsibilities Procedure. Those EMS activities related to the contractor which must be addressed are included in several elements: 1. Element 8.4 – in the contractor service agreement, contractors must establish their own training programs consistent with their roles and responsibilities in biosolids management activities. 2. Element 10.5 – contractors are required to establish their own operational controls consistent with their roles and responsibilities. 3. Element 11.4 – contractors are required to establish and maintain Emergency Preparedness and Response Plans and Procedure to assure effective response to accidents and emergency situations associated with biosolids management activities. 4. Element 12.4 – contractors are required to establish documentation, document control and record keeping requirements for biosolids activities in service agreements and incorporate these into the EMS for biosolids. 5. Element 13.3 – contractors are required to establish and maintain regular monitoring and measurement procedures and practices for all their assigned biosolids management activities, as defined in their service agreements. Item 8.1 – The EMS training program does not currently reference all of the training requirements for operations and maintenance personnel with respect to their responsibilities for specific biosolids management activities. Item 9.5 – The Communication Procedure does not currently identify how relevant information about biosolids management activities and all 17 EMS elements are to be communicated to employees. Item 10.1 – Not all the required standard operating procedures (SOPs), work management practices or other appropriate methods at all critical control points throughout the biosolids value chain to effectively manage potential environmental impacts have been developed and implemented. Item 10.4 – Not all appropriate preventive maintenance procedures and work management systems for maintaining equipment, instrumentation, vehicles, and other 20 treatment technology and process control system associated with biosolids management activities have been addressed in the EMS. Item 11.2 – The review and evaluation of the emergency preparedness and response procedures have not yet been tested as identified in the procedure; i.e. there have been no table top exercises or spill drills. Item 12.4 – The Documentation, Document Control and Record Keeping Procedure does not clearly describe the method of initial document development, review and change. Item 13.1 – The Monitoring and Measurement Procedure does not clearly establish or define the frequency of periodically reviewing the progress on the biosolids program goals and objectives. Item 14.1 – The Non-conformances: Preventive Action and Corrective Action Procedure does not address investigation of nonconformance with internal EMS procedures identified during routine monitoring and measurement by operation and maintenance personnel. Item 14.4 – The Non-conformances: Preventive Action and Corrective Action Procedure does not address development of corrective action plans to address nonconformances identified during routine monitoring and measurements. Item 14.6 – The Non-conformances: Preventive Action and Corrective Action Procedure does not presently address the tracking of progress of corrective action, and periodically update the status to reflect completion. Item 16.3 – The Internal Biosolids Management Program Audit Procedure does not address identification of internal auditor qualifications in the audit records. Item 17.1 – The Management Review Procedure does not currently capture all of the management review activities required by the Standard. Opportunities for Improvement Overall – Consider developing a Biosolids Master Calendar, which identifies all of the planned EMS activities and expected dates of accomplishment. Element 3 – Consider explaining in the Process Control Points Procedure the intent of the priority risk matrix scoring system and its function/use in the biosolids EMS. Item 5.5 – Consider including a SMART criteria narrative supplement associated with each set of goals and/or objectives. Item 6.5 – Consider how to describe the proactive public participation methods used to obtain input from interested parties when updating goals and objectives. 21 Item 9.1 – Clarify the identification of interested parties in the Communications Procedure. Item 10.2 – Not all legal requirements are currently incorporated into operational controls of the digesters. Element 11 – Consider referencing the Emergency Preparedness and Response Attachments in the text of the Emergency Response Plan Procedure. Item 11.3 – Consider identifying all on-site emergency response equipment (inventory) that is readily available for response. Item 12.3 – Revise the record retention section of the Documentation, Document Control and Record keeping Procedure so that it reflects the current approach. Element 14 – In the Non-conformances: Preventive Action and Corrective Action Procedure consider identifying all those persons and/or positions that have the responsibility for preparing CAPAs. Element 14 – Review the Non-conformances: Preventive Action and Corrective Action Procedure item 2(e) “issues identified outside of audits” to determine if this could be better placed in a separate section. Element 14 – Reference CAPA tracking table (form) in the Non-Conformance: Preventive Action and Corrective Action Procedure. Element 15 – Include the metals concentrations in the biosolids in some format in the biosolids management program report. Item 17.2 – The management review meeting agenda and management review minutes templates are not currently referenced in the Management Review Procedure. 22 Attachment 3 National Biosolids Partnership Appeals Process To obtain Gold-level Recognition or Platinum-level Certification by the National Biosolids Partnership (NBP) Biosolids Management Program (BMP), biosolids organizations are required to undergo a BMP verification audit by an independent, third party auditor and yearly interim audits. The purpose of the audit is to determine whether or not the organization’s BMP conforms to the NBP program, as defined in the BMP Elements. The spirit of these requirements includes a well-documented program and meaningful opportunities for interested party involvement. The NBP provides an appeals process for biosolids organizations and interested parties that disagree with the findings of a third party BMP audit. The verification appeals process involves an Appeals Board; representing a balance of biosolids management interested parties and wastewater industry professionals. To warrant an appeals action before the Board, the party brining an appeal must set forth the specific BMP element(s) that they contend have not been evaluated and/or implemented consistent with NBP expectations and requirements as reflected in the BMP Elements, along with the objective evidence to support that claim. For example, a petitioner may believe that a major nonconformance exists but was not found by the auditor. In this case, the petitioner would need to identify in the petition the specific BMP element believed to be out of conformance and why. To submit an appeal, petitioners must fill out and submit the standardized appeals petition form that is available on the NBP website at http://www.wef.org/biosolids. A notice of intent to appeal must be submitted within 30 days, and a formal appeal must be submitted within 60 days, of the public release of the third party audit report containing the verification decision or interim audit decision by the audit company. The Appeals Board’s Administrative Officer receives all appeals petitions on behalf of the Board and conducts a basic completeness check. Upon completion of this check, the petition is either forwarded to Appeals Board members or back to the petitioner with incomplete areas documented. Petitions should be sent via certified, return receipt requested mail to: The NBP Appeals Board, Attention: Board Administrative Officer, c/o Water Environment Federation, 601 Wythe Street, Alexandria, VA 22314. The Appeals Board will examine the facts, interview parties involved, deliberate the case, and then make a determination as to whether a major nonconformance does or does not exist. Appeals cases vary in complexity. As a result, the time required for the Board to evaluate a case and make a decision might vary. However, the overall Board target for processing an appeal is approximately four months. Appeal of minor nonconformances is through the third party audit company’s internal appeals process. To place a minor nonconformance appeal the organization should provide the audit company with documentation or other objective evidence explaining why the finding at issue does not exist. These appeals are reviewed and resolved by an audit company representative who was not part of the third party audit team. Audit plan - 1 - NATIONAL BIOSOLIDS PARTNERSHIP EMS VERIFICATION AUDIT PLAN (name redacted) September 12 – September 16, 2011 Company / Client: (name redacted) Sewer Authority Street/P.O. box: (redacted) City / State / post code: (redacted) Type of Audit: Verification Audit Standard / Date of issue: National Biosolids Partnership EMS Program: November 2002 Verification Auditor Guidance November 2001 (Latest Revision August 2007) Audit Dates (on site): September 12 – September 16, 2011 Management Representative: (name redacted)– Operations Manager - Solids Telephone: ( redacted) Email (redacted) Lead Auditor: William R. Hancuff Cell phone 703-585-4799 Auditor: NA We request that the following be made available to be used for the audit:  A reserved space to be used for audit purposes  An organization chart with full names of personnel  The audit plan with full names of our points of contact for each element  Facility layouts, where appropriate  A master list of all documented procedures with current revisions  Access to a copier and the possible use of an HP Laser Printer Should you have any questions, please don’t hesitate to contact me at: (703)585-4799 Thank you!!! Bill Hancuff The organization must provide representatives to accompany team members during the entire audit. Note: Interested parties are encouraged to attend any portion of the audit in which they may have an interest. In person or telephone interviews with regulators will be included as part of the audit. DAY 1 Audit plan - 2 - Date Time 1) Auditor Elemt. Activity / Element Department Name 2) Comment 9/12/11 Monday 8:00 – 8:15 Bill Arrival, Introductions, General Orientation Operations Mgr - Solids (name redacted) 8:15 - 8:45 Bill Opening Meeting Biosolids EMS Team 8:45 – 12:00 Bill Various Review Preventive & Corrective Actions from ORR Operations Mgr - Solids (name redacted) 12:00 – 1:00 Bill Lunch NA 1:00 – 1:45 Bill 1, 2, 7, & 17 Policy, Roles and Responsibilities, & Management Executive Director (name redacted) 1:45 – 2:30 Bill 7, 8, 12, 13 Review contractor service agreement Operations Mgr - Solids (name redacted) 2:30 – 4:00 Bill 1, 2. 7, 8, 9, 10, 11, 12,13, 16 Review integration of contractors roles and Audit plan - 3 - DAY 3 Date Time 1) Auditor Elemt. Activity / Element Department Name 2) Comment 9/14/11 Weds. 8:00 – 12:00 Bill 3, 5, 7, 8, 10, 11, 13 Visit (name redacted), (name redacted) (name redacted), & (name redacted) – reverse flow Plant managers (name redacted)& others 12:00 – 1:00 Bill Lunch NA 1:00 – 2:00 Bill 8 Training (including records review) Administration 2:00 – 3:30 Bill 11 Emergency Preparedness and Response Emergency Team 3:30 – 4:30 Bill 12 EMS Documentation & Document Control Operations Mgr - Solids (name redacted) 4:00 – 5:00 Bill Summarize days activities Operations Mgr - Solids (name redacted) DAY 4 Date Time 1) Auditor Elemt. Activity / Element Department Name 2) Comment 9/15/11 Thursday 8:00 – 9:00 Audit plan - 4 - DAY 5 Date Time 1) Auditor Elemt. Activity / Element Department Name 2) Comment 9/16/11 Friday 8:00 – 9:00 Bill 5, 10, 13 Outcomes – regulatory compliance Operations Mgr - Solids (name redacted) 9:00 – 10:00 Bill 5, 10, 13 Outcomes – relations with interested parties Operations Mgr - Solids (name redacted) 10:00 – 12:00 Bill 15 & 17 Periodic Program Review and EMS Performance Report Operations Mgr - Solids (name redacted) 12:00 – 1:00 Bill Lunch 1:00 – 2:30 Bill Prepare draft audit results NA 2:30 – 3:30 Bill Pre-closing Meeting Operations Mgr - Solids (name redacted) 3:30 – 4:00 Bill Closing Meeting EMS Team 1) Changes possible 2) To be determined by the client Distribution: Auditee Representatives NATIONAL BIOSOLIDS PARTNERSHIP VERIFICATION AUDIT REPORT (Name redacted) Audit conducted by NSF-International Strategic Registrations William R. Hancuff, Lead Auditor References: National Biosolids Partnership (NBP) EMS Elements NBP Third Party Verification Auditor Guidance – November 2001 (Latest Revision August 2011) NBP Code of Good Practice (name redacted) Environmental Management System Manual (Revised – September 9, 2011) Final Report – October 28, 2011 2 INTRODUCTION The purpose of the Biosolids Environmental Management Program (BMP) Third Party Verification audit is to evaluate the (name redacted) BMP to determine its conformance with the biosolids management standard of the National Biosolids Partnership (NBP). The goal of the Third Party Verification audit is to collect and evaluate objective evidence that determines whether (name redacted)’s BMP is functioning as intended, that practices and procedures are conducted as documented, and that the BMP as implemented conforms to the NBP’s BMP Elements, the Code of Good Practice and the BMP objectives. RECOMMENDATION Based on the results of the (name redacted) verification audit it is the recommendation of the audit team that (name redacted)’s Biosolids Management Program receive “Verification” status. Verification is not the end, but rather the beginning of a continuously improving biosolids management program. AUDIT SCOPE In general terms, the scope of the Third Party Verification audit encompasses the entire biosolids value chain (pretreatment, collection and treatment, through final end use) with special attention on those practices and management activities that directly support biosolids-related operations, processes, and activities within the Wastewater Treatment Plants’ operations. The NSF-International Strategic Registrations, Ltd. (NSF-ISR) conducted a third party verification audit of the (name redacted) Management Program. The verification began with a document review desk audit and on-site readiness review (ORR) completed in early May with the results presented to (name redacted) on 9 May 2011. The process continued with an on-site verification audit from 12 September 2011 through 16 September 2011. The on-site audit team consisted of Dr. William R. Hancuff, Lead Auditor. The physical biosolids facilities included in the audit and visited during the operational readiness review and verification audit included (name redacted) WWTP, (name redacted) WWTP, (name redacted) WWTP, (name redacted) WWTP, (name redacted) WWTP, (name redacted) WWTP, and (name redacted) WWTP. The critical control points of the biosolids value chain at these various plants were: influent pump stations, solids screens, grit collection, primary treatment, secondary treatment, thickening, aerobic digestion, anaerobic digestion, dewatering, biosolids storage, cake transfer, truck biosolids loading facilities, truck cleaning, and land application. The following land application sites were observed: (name redacted) – Site GV-11, Field 02 (30.1 acres – fescue and Bermuda grass); (name redacted) (hay); and (name redacted) – Site SC-LA-39-01 thru 05 (131 acres) 3 The following individuals were interviewed as part of the audit process: (name redacted) Executive Director (name redacted) Director of Operations (name redacted) Director Technical Services (name redacted) Director Human Resources (name redacted) Solids Manager (name redacted) Process Control (name redacted) Environmental Engineer (name redacted) Customer Service (name redacted) Administrative Assistant (name redacted) PR/Customer Service/Contract Manager (name redacted) Manager Domestic Wastewater Permit Section – Bureau of Water – (name redacted) Staff Engineer – (name redacted) Pretreatment Program Manager (name redacted) Senior Construction Inspector (name redacted) Industrial Pretreatment Inspector (name redacted) Operations Foreman –WWTP (name redacted) Operator II – (name redacted)WWTP (name redacted) Operator II – (name redacted)WWTP (name redacted) Operator II – (name redacted)WWTP (name redacted) Operator I – (name redacted)WWTP (name redacted) Operator I – (name redacted)WWTP (name redacted) Operator I –(name redacted)WWTP (name redacted) Operations Manager – East Side (name redacted) (name redacted) Operator II – (name redacted)WWTP (name redacted) Operations Foreman – (name redacted) WWTP (name redacted) Operator II – (name redacted) WWTP (name redacted) Operator II – (name redacted) WWTP (name redacted) Operator I – (name redacted) WWTP (name redacted) Operator I – (name redacted) WWTP (name redacted) Operator II – (name redacted)WWTP (name redacted) Operator I – (name redacted)WWTP (name redacted) Operator I – (name redacted)WWTP (name redacted) Operator II – (name redacted)WWTP (name redacted) Operations Foreman – (name redacted)WWTP (name redacted) Operations Foreman – (name redacted)WWTP (name redacted) Operator II – (name redacted)WWTP (name redacted) Operator II – (name redacted)WWTP (name redacted) Tech Services Manager – (name redacted) (name redacted) Field Manager – (name redacted) (name redacted) Lead Operator, Field Crew – (name redacted) (name redacted) Field Crew – (name redacted) (name redacted) Truck Driver - (name redacted) 4 (name redacted) Truck Driver – (name redacted) (name redacted) Truck Driver - (name redacted) DOCUMENTATION REVIEW Document review was conducted during the two phases of the audit process, in the desk audit/on-site readiness review and in the verification audit. During each of these activities various documents were reviewed to verify conformance with the National Biosolids Partnership (NBP) BMP Elements using the NBP Third Party Verification Auditor Guidance. Additionally interviews were conducted with various personnel to obtain supplemental objective evidence on the implementation effectiveness of the BMP. Attachment 1 summarizes the documents and other objective evidence associated with each element that was considered during the above-mentioned reviews. DESK AUDIT/ON-SITE READINESS REVIEW A complete document review was performed as a desk audit. The principal focus was on the (name redacted) Management Program Manual. The on-site readiness review (ORR) involved assessment of supplemental information such as cross referenced standard operating procedures, management review records, background reference information, training records, summary of outcomes, and various public outreach and communication materials. It also entailed evaluation of a biosolids land application site. The results of the desk audit/ORR provided a number of observations and opportunities for improvement. This initial effort resulted in 22 observations and 16 opportunities for improvement and four positive commendations. Detailed results from desk audit/ORR are provided in Attachment 2. Most, but not all, of the observations identified during the desk audit/ORR were found corrected at the time of the verification audit. In addition, almost all of the opportunities for improvement identified during the initial audit/review were also addressed. VERIFICATION AUDIT FINDINGS The verification audit covered all elements of the standard in considerably greater detail than the desk audit/ORR and was performed by one auditor over a period of five days. The verification audit found no major non-conformances, 11 minor non- conformances, 7 opportunities for improvement and 6 commendations or positive observations. The following is a review of the positive observations made during the verification audit. Minor non-conformances and opportunities for improvement follow and are listed by requirement number in the sequence of the NBP standard elements. 5 Positive Observations The (name redacted) Value Chain personnel involved in the biosolids management program development should be recognized for their outstanding achievements, and the exceptional features of their BMP. The following are those observations made during the audit that deserve commendations.  The (name redacted) Element 1: Biosolids Management Documentation procedure contains an excellent outline and summary of the purpose of each element of the Biosolids Management Program.  The program makes excellent use of laminated cards for communicating the BMP policy to all employees.  In last column of Table 3.01 – Critical Control Points not only are the actual and potential environmental impacts associated with each critical control point presented, but the potential operational impacts, which could indirectly result in an adverse environmental consequences are also identified.  (name redacted) has comprehensively developed Standard Operating Procedures for the critical control points in the biosolids value chain.  The (name redacted) WWTP maintains excellent housekeeping.  Although not fully implemented yet, (name redacted) utilizes an exemplary format for the annual Biosolids Performance Report, including progress on Goals and Objectives and improvements in the four outcome areas. Minor Non-conformances  Requirement 4.2 – In EMS Document 4.1 – Federal and State Requirements a list of Biosolids related regulation section numbers are presented, but there is no indication as to what those regulations specifically apply.  Requirement 5.7 – Not all of the Goals and Objectives had a detailed project management plan (action plan) identifying the specifics of what, how, who and when the activities and milestones would be accomplished. Also, the description or title of some of the goals and objectives could be more clearly stated and the outcome(s) impacted by each goal could include more than one outcome area.  Requirement 6.2 – The Element 6: Public Participation in Planning procedure did not clearly present that the biosolids organization must notify interested parties about their intent to receive an independent third party audit and build into their BMP planning a discussion with interested parties about approaches for observing the third party audit. Additionally, interested parties were not contacted regarding the conduct of the third party verification audit. 6  Requirement 6.4 – In the “Additional Participation Opportunities” Section of Element 6 the list of activities does not describe specifically how the listed activity will receive input from interested parties related to biosolids.  Requirement 11.3 – Not all wastewater treatment plant sites have emergency response equipment on the site or readily available within a minimum response time. Additionally Element 11 procedure does not identify specifically what emergency response equipment should be available at each specific wastewater treatment plant.  Requirement 12.1 – Several of the BMP Element Procedures refer to documents, tables, lists or other materials but did not provide a link or identify them in the Reference section of the element procedure. For example, the stakeholder list discussed in element 9 was not linked. The stakeholder list was not included in element 6 related to public participation in planning. Attachment B was not included in list of references in Element 16 procedure. Element 16 did not include a reference to an audit checklist. Element 9 did not link to “Responding to Biosolids Inquiries in Non-Emergencies,” etc.  Requirement 12.2 – The 17 copies of the (name redacted) Emergency Operations Manual are uncontrolled, and there are no procedures for controlling hard copies.  Requirement 12.2 – Element 12 procedure does not describe the method used to ensure uncontrolled documents are properly identified, such as printed versions of electronically controlled documents. Additionally there is no description of who has the ultimate authority for changing controlled documents and procedures.  Requirement 14.2 – Element 14 procedure does not address the frequency of tracking corrective actions to closure.  Requirement 14.5 – Although corrections have been implemented, not all findings from the third party desk audit and on-site readiness review (ORR) have been formally closed.  Requirement 16.3 – Element 16 procedure does not specifically define the qualifications and training required for the internal lead auditor. Opportunities for Improvement  Element 1 – Consider including a narrative reference to the BMP schedule in Element 1: Biosolids Management Documentation procedure and a link to the table entitled BMP Schedule. Also consider including the required information on this table to demonstrate that it is a controlled document. 7  Element 5 – Consider including goals and objectives for individual specific projects identified in the budget process (i.e. those that have an impact on the biosolids value chain, environmental performance, quality of product, etc.)  Requirement 9.1 – Consider including in the Element 9 procedure a description of providing information to property owners having land adjacent to land application sites.  Requirement 11.2 – Consider implementing spill drills to evaluate the effectiveness of emergency preparedness and response procedures.  Requirement 12.2 – Consider revising and simplifying the Document Control Log  Requirement 16.1 – Consider including in Element 16 procedure a description of an audit plan that defines a time schedule, scope and specific responsibilities for individual auditors.  Requirement 16.3 – Consider establishing the internal audit schedule, resolution of non-conformances and communication of BMP audit results to management to be compatible with the overall BMP schedule diagram. (name redacted) personnel addressed the foregoing nonconformances by completing their Nonconformance/Noncompliance action work order forms with schedules, and will implement corrective actions according to their BMP procedures. There have been notable improvements in the facility’s BMP over the past months as observed by the lead auditor during the verification audit. This level of improvement will undoubtedly continue into the future. And finally, the hard work and dedication of the BMP Team must be acknowledged. While attainment of the BMP verification goal is obviously a team effort the guidance provided by the Operations Manager/Biosolids Manager and the management support of the Executive Director to ensure accomplishment of this goal must be recognized. (name redacted) COMMENTS As an agency, (name redacted) believes that the BMP is a powerful tool that will help to improve our biosolids management activities, promote continuous improvement and improve public relations. We believe in this program, and already see benefits from it. We are excited to be a part of this program and look forward to more good things to come. Dr. Hancuff was very professional and a pleasure to work with. The audit process was efficient, productive and educational. 8 OUTCOMES MATTER (name redacted) Biosolids Management Program established four broad long-term goals for 2009, 2010 and 2011. These goals included: identifying micro constituents of concern; reducing hauling costs, educating state legislators, improving relations with interested parties, and evaluating the feasibility of converting to Class A biosolids production at (name redacted) WWTP. Substantial progress has been made on all these fronts and new goals and objectives have been developed during 2011. The goals and objectives were developed by the Biosolids EMS coordinator and the Biosolids Team considering public interest. The wastewater treatment plant biosolids goals for its EMS was established cognizant of each of the four outcome focal points of the NBP program as identified below:  Environmental Performance,  Regulatory Compliance,  Relations with Interested Parties, and  Quality Biosolids Management Practices. While it is not a requirement to fully attain all objectives established, it is a critical component of the system to make progress towards accomplishing the overall goal. The early goals and objectives did not fully utilize the Specific, Measurable, Achievable, Relevant, and Time Bound (SMART) criteria; however the system is currently incorporating this approach in development of objectives. It should be noted that the above-mentioned goals may fulfill the needs of different outcome areas. The facilities’ performance relative to each of the four outcome areas is summarized below. In the Environmental Performance outcome area, the goal is to reduce the transportation costs for biosolids. The approach used is to conduct a field study on the effects of liquid application of biosolids on grass and hay fields at varying percent total suspended solids concentrations. The objective was to determine the maximum concentration of land application without causing any adverse environmental impact. Transportation at the highest solids concentration minimizes fuel costs and energy consumption. The study was scheduled to be conducted at (name redacted) WWTP and associated land application site field # 1, a Fescue/Bermuda grass mix. Four test plots were planned for the study: Plot #1: controlled area where no biosolids are to be applied; Plot # 2 apply approximately 5% total suspended solids concentration; Plot #3 apply approximately 6% total suspended solids concentration; and Plot #4 apply normal rates of 3.5% - 4%. Two application were planned during the growing season at the recommended nitrogen application rate for fescue/Bermuda grass of 160 – 200 pounds per acre. The first application was to be at half the loading rate early in the season and the second application was to be at the same rate after the first cutting of hay in the middle of the growing season. The plot size was to be one or two tanker loads and the parameters monitored were biosolids content (NH3, NO3, TKN, and PO4), soil type, soil samples 9 per and post application at 4-foot level, weather conditions, crop growth, grass density measurements, crop samples, pre and post application, and aesthetics. The preliminary results of this goal demonstrated that solids could be applied to fields up to 5% total suspended solids concentrations with no adverse environmental impacts. This represents a transportation cost savings of 20% to 25%. Additional data is being gathered in 2011 and the goal will be completed after one more quarter of data is collected. In the Regulatory Compliance outcome area, (name redacted) established the goal of identifying pollutants of concern. The objective of this goal is to conduct a headworks analyses for each of the following plants: (name redacted) WWTP, (name redacted) WWTP, (name redacted) WWTP, (name redacted) WWTP, and (name redacted) WWTP. Historically, no micro constituents have had an adverse environmental impact in concentrations typically found in wastewater. However, standards and regulatory requirements are continuing to evolve. The objective of the headworks analysis is to provide initial sampling of the WWTPs influent to determine what pollutants are present through sampling priority pollutants and heavy metals (Cd, Cr, Cu, As, Ag, Hg, CN, Pb, Ni, Zn). Additionally the sampling involves testing for any other pollutant reasonably expected to be discharged to WWTPs in quantities, which could pass through or interfere, contaminate solids, or jeopardize treatment plant worker health or safety. Once the constituents have been determined a whole plant analysis including influent, primary effluent, secondary effluent/plant effluent and biosolids is conducted. The results of the sampling are used to obtain information on individual process removals, overall treatment plant removal, solids concentration, and perform a mass balance. Ultimately this information is used to develop headworks loadings and local limits to be used in the pretreatment program. Pollutant by pollutant, treatment plant data are used to calculate removal efficiencies, before applying the most stringent criteria such as water quality, solids quality, NPDES permit limits, or pollutant inhibition levels to back calculate the maximum allowable headworks loadings. By subtracting out contributions from domestic sources, the available industrial loading is then either evenly distributed among the industrial users, or allocated on an as needed basis to those industrial users discharging the pollutant above background levels. (name redacted) has scheduled performance of the headworks analysis and determination of headworks loading pending the re-issuance of the NPDES permits for each of the above referenced plants. The renewal of the permits has been postponed and is now scheduled for issuance in 2012. Therefore without the required information related to the NPDES permits progress on this goal has been delayed. In the Relations with Interested Parties outcome area, (name redacted) established two goals: one of was to educate state legislators regarding the benefits of land application of biosolids to the states agri-business and the second was to increase public education and awareness of biosolids. 10 The objective of the first goal was to contact county extension agents to learn about opportunities for effectively engaging the state legislature. No progress has been made on this goal because a detailed plan of approach has not yet been developed. The initial efforts to increase public education and awareness related to biosolids was completed through developing a biosolids fact sheet for (name redacted)’s biosolids product and program in 2011. The fact sheet was transformed into a brochure to be mailed to those who participate in the land application program and made available to the general public on request. Additionally in 2011 (name redacted) initiated a significant effort in the relations with interested parties outcome area by forming a biosolids marketing feasibility group consisting of an agricultural economics professor from Clemson University, a Clemson Cooperative Extension horticultural agent, a Clemson Cooperative Extension livestock agent, a Gwinnett County Georgia Water Resource Center Superintendent and a professional engineer with Camp Dresser and McKee. The results of this effort resulted in a list of proposed ideas directed at the beneficial use of biosolids. In the Quality Biosolids Management Practices outcomes area, established an objective of evaluating the feasibility of converting to Class A biosolids production at (name redacted) WWTP, including the development of options for meeting this objective. A consultant was retained to perform the required study. A report was prepared in March 2011 concluding that there were regulatory or public relations drivers to pursue Class A biosolids at this time. Subsequent to this conclusion an additional effort was established to seek input from interested parties to identify ideas for alternative approaches to beneficial biosolids use. This effort resulted in identification of numerous ideas for biosolids projects related to quality biosolids management practices, which will be used to formulate future goals and objectives for the biosolids management program. An additional quality biosolids management practice that was established in 2010 and completed in 2011 was the installation of new magnetic flow meters at all biosolids truck loading stations to ensure accurate measurement of biosolids and that all tankers are loaded to the maximum extent legally permitted. This goal also addresses the environmental performance goal of reducing the transportation costs since (name redacted) is charged by the tanker load. Seven new meters were installed and this objective was accomplished. Another (name redacted) program development for 2011 was an initiative to formulate a biosolids business plan. CONCLUSIONS AND RECOMMENDATIONS The results of the verification audit are positive. The review and approval of the corrective action plans for each of the minor non-conformances identified during the verification audit has been completed. The full implementation of the corrective actions 11 for the minor findings will be accomplished according to the schedule proposed in the corrective action work orders and it is the recommendation of the audit team that (name redacted)’s Biosolids Management Program receive “Verification” status. As was mentioned previously, a BMP is a continuous improvement process, and verification is not the end -- it is the beginning. The results of this and future audits will provide value added to the program and should be viewed as an overall opportunity to improve. Every audit is a snapshot in time, and does not, or cannot, identify each and every area for improvement. And yet, while no single audit identifies all of the areas for improvement the results of each audit provide an additional incremental step in the overall program’s improvement. Discussions between the (name redacted) manager and the third party auditor resulted in agreement to the following proposed interim audit approach. Each interim audit will include a review of: the organization's progress toward goals and objectives; EMS outcomes (environmental performance; regulatory compliance; interested party relations; quality practices); actions taken to correct minor non-conformances; the management review process; corrective action requests and responses; and preventive actions. In addition to the above, the following elements will be audited according to the following tentative schedule: Year 1 (third party) – Elements 3, 10, 12, 13 Year 2 (third party/internal) – Elements 1, 8, 15, 17 Year 3 (third party) – Elements 5, 6, 9, 14, 16 Year 4 (third party/internal) – Elements 2, 4, 7, 11 Year 5 (third party) Re-verification 12 Attachment 1 Documents and Other Objective Evidence Reviewed During the Desk Audit/Operational Readiness Review And Verification Audit Element 1. BMP Manual - (name redacted) Biosolids Environmental Management System – revised 9 September 2011, approved by Executive Director. - Element 1: Biosolids Management Documentation, Version EMS 002, issued 06/27/08, revised 08/11/11. - EMS Document 1.1 EMS for Biosolids Element Descriptions. - Element 2 – Biosolids Management Policy, Version EMS001, dated 06/27/08, revised 05/31/11. - Interviews with (name redacted), Executive Director; (name redacted), Director of Operations; (name redacted), Director Technical Services; (name redacted), Solids Manager; (name redacted), Process Control; (name redacted), Environmental Engineer; (name redacted), Customer Service and (name redacted), Administrative Assistant. - Biosolids Management Policy signed by (name redacted), Executive Director on 31 May 2011. (Includes commitment to NBP Code of Good Practice) - Element 3: Critical Control Points, Version EMS002, issued 06/27/08, revised 09/08/2011. - Element 4: Legal and Other Requirements, Version EMS003, issued 06/27/08, revised 08/26/11. - Element 6: Public Participation in Planning, Version EMS002, issued 06/27/08, revised 09/08/11. - Element 7: Roles and Responsibilities, Version EMS004, issued 06/27/08, revised 08/26/11. (Contractors responsibilities for hauling and land application defined) - Element 9 – Community and Public Outreach, Version EMS003, issued 06/27/08, revised 09/08/11. - Element 10: Operational Control of Critical Control Points, Version EMS003, issued 06/27/08, revised 09/08/11. - Element 11: Emergency Preparedness and Response, Version EMS002, issued 06/27/08, revised 09/08/11. - Letter of Commitment to NBP program signed by Ray Orvin 2 May 2000. - (name redacted) Request of Competitive Sealed Technical Proposals for Biosolids and Wastewater Residuals Management Services, August 2007. - Biosolids and Wastewater Residuals Management Services Agreement, 5 August 2008. - First Amendment to Biosolids and Wastewater Residuals Management Services Agreement, 5 August 2011. 13 Element 2. Biosolids Management Policy - Element 2: Biosolids Management Policy (referencing Code of Good Practice), Version EMS001, issued 06/27/08, revised 05/31/2011. - Interviews with (name redacted), Executive Director; (name redacted), Director of Operations; (name redacted), Solids Manager; (name redacted), Process Control; (name redacted) (name redacted), Environmental Engineer; (name redacted), Customer Service and (name redacted) (name redacted), Administrative Assistant. - Element 9 – Community and Public Outreach, Version EMS003, issued 06/27/08, revised 09/08/11. - Interview with (name redacted), Director Human Resources regarding training program. - Policy available on (name redacted) Environmental Management System web page (http://www.(name redacted)online.org/environmental-management-system.php) - Laminated 8 ½ x 11 card containing Biosolids Management Policy and Biosolids Mission Statement and Code of Good Practice – posted at various locations throughout the plant. - Verified employees and contractors received awareness training through interviews. - Checked employees’ biosolids policy on personal laminated cards. - Policy displayed throughout wastewater treatment plant on laminated posters. - Biosolids and Wastewater Residuals Management Services Agreement, 5 August 2008. - First Amendment to Biosolids and Wastewater Residuals Management Services Agreement, 5 August 2011. Element 3. Critical Control Points - Element 3: Critical Control Points, Version EMS002, issued 06/27/08, revised 09/08/2011. - Table 3.01- Critical Control Points – Overall Critical Control Points – Revision date 09/02/11 (including critical control point operational areas, key processes, operational control, responsibilities, potential operational and environmental impacts.) - Table 3.02 – Critical Control Points – (name redacted) WWTP – revised 09/02/11 (including critical control point operational areas, key processes, operational controls, monitoring and measurement, and responsibilities.) - Table 3.03 – Critical Control Points – (name redacted) WWTP – revised 09/02/11 (including critical control point operational areas, key processes, operational controls, monitoring and measurement, and responsibilities.) - Table 3.04 – Critical Control Points – (name redacted) WWTP – revised 09/02/11 (including critical control point operational areas, key processes, operational controls, monitoring and measurement, and responsibilities.) - Table 3.05 – Critical Control Points – (name redacted) WWTP – revised 09/02/11 (including critical control point operational areas, key processes, operational controls, monitoring and measurement, and responsibilities.) 14 - Table 3.06 – Critical Control Points – (name redacted) WWTP – revised 09/02/11 (including critical control point operational areas, key processes, operational controls, monitoring and measurement, and responsibilities.) - Table 3.07 – Critical Control Points – (name redacted) WWTP – revised 09/02/11 (including critical control point operational areas, key processes, operational controls, monitoring and measurement, and responsibilities.) - Table 3.08 – Critical Control Points – (name redacted) WWTP – revised 09/02/11 (including critical control point operational areas, key processes, operational controls, monitoring and measurement, and responsibilities.) - Table 3.09 – Critical Control Points – (name redacted) Road WWTP – revised 09/02/11 (including critical control point operational areas, key processes, operational controls, monitoring and measurement, and responsibilities.) - Table 3.10 – Critical Control Points – (name redacted) WWTP – revised 09/02/11 (including critical control point operational areas, key processes, operational controls, monitoring and measurement, and responsibilities.) - Table 3.11 – Critical Control Points – (name redacted) WWTP – revised 09/02/11 (including critical control point operational areas, key processes, operational controls, monitoring and measurement, and responsibilities.) - Comparison of Critical Control Points with those contained in Appendix F of the National Manual of Good Practice. - Spot-checked operational SOPs with critical control points. - Interviews with BMP team: (name redacted), Solids Manager; (name redacted), Process Control; (name redacted), Environmental Engineer; (name redacted), Customer Service; (name redacted), Administrative Assistant. - Interviews with critical control point personnel: (name redacted), Pretreatment Program Manager; (name redacted), Industrial Pretreatment Inspector; (name redacted), Operations Foreman – (name redacted), Operator II – (name redacted), Operator II – (name redacted), Operator II – (name redacted), Operator I – (name redacted), Operator I – (name redacted), Operator I – (name redacted), Operations Manager – (name redacted), Operations Foreman –(name redacted), Operator II (name redacted), Operator II – (name redacted), Operations Foreman – (name redacted), Operator II – (name redacted), Operator II – (name redacted), Operator I – (name redacted), Operator I – (name redacted), Operator II – (name redacted), Operator I – (name redacted), Operator I – (name redacted), Operator II – (name redacted), Operations Foreman – (name redacted), Operations Foreman – (name redacted), Operator II – (name redacted), Operator II – (name redacted), Tech Services Manager – (name redacted), Field Manager – (name redacted), Lead Operator-(name redacted), Field Crew – (name redacted), Truck Driver – (name redacted), Truck Driver – (name redacted), Truck Driver – (name redacted). - Field review of biosolids value chain critical control points. - Viewed various land application sites including: (name redacted)County – Site GV-11, Field 02 (30.1 acres – fescue and Bermuda grass); (name redacted) County (hay); and (name redacted) County – Site SC-LA-39-01 thru 05 (131 acres) Element 4. Legal and Other Requirements 15 - Element 4: Legal and Other Requirements, Version EMS003, issued 06/27/08, revised 08/26/11. - EMS Document 4.1: Federal and State Requirements. - Interviews with BMP team: (name redacted), Solids Manager(name redacted), Process Control; (name redacted), Environmental Engineer; (name redacted), Customer Service; (name redacted), Administrative Assistant. - Interviews with pretreatment personnel: (name redacted), Pretreatment Program Manager; (name redacted), Senior Construction Inspector, and (name redacted), Industrial Pretreatment Inspector. - Interviews with contractor staff ((name redacted)): (name redacted), Tech Services Manager; (name redacted), Field Manager; (name redacted), Lead Operator-Field Crew; (name redacted), Field Crew; (name redacted), Truck Driver; (name redacted), Truck Driver; and (name redacted), Truck Driver. - Interview with state regulators: (name redacted), Manager Domestic Wastewater Permit Section – Bureau of Water –and (name redacted), Staff Engineer –. - Discussed other requirements to which subscribed: Voluntary participation in biosolids operator certification program sponsored by the (name redacted). - Reviewed (name redacted) intranet site used to maintain regulatory requirements. - (name redacted) land application site books with plans. - Reviewed Surface Water Discharge Permit (name redacted) Permit # SC0048381; effective Dec 1, 2010, expires Nov 30, 2015 for land application of sludge associated with 10 outfalls. - Reviewed (name redacted) Water Pollution Control Permits Regulation 61-9. - (name redacted) Standard Operating Procedure – (name redacted) Water Resources Permit Summary Sheet 7/25/11. - Reviewed the following EMS Procedures for inclusion of legal requirements: (name redacted) WWTP – Anaerobic Digester standard operating procedure version # SOP001, issued 02/18/09. - (name redacted) WWTP – Aerobic Digesters 1 & 2 standard operating procedure # SOP001, issued 02/19/09. - (name redacted) WWTP – Anaerobic Digester standard operating procedure # SOP001, issued 02/25/09. Element 5. Goals and Objectives - Element 5: Goals and Objectives for Continual Improvement, Version EMS003, issued 06/27/08, revised 09/09/11. - EMS Document 5.1: Biosolids Management Program Goals and Objectives Version 1, Issue date 9/6/11. (Form) - EMS Document 5.2: Action Plan for Goals - Interviews with top management: (name redacted), Executive Director and (name redacted), Director of Operations. - Interviews with BMP team: (name redacted), Solids Manager; (name redacted), Process Control; (name redacted), Environmental Engineer; (name redacted), Customer Service; (name redacted), Administrative Assistant. - Evaluated 2010 and 2011 Goals and Objectives for use of SMART criteria. 16 - Reviewed progress meeting agenda for progress and status of Goals and Objectives 9/2/10. - (name redacted) Biosolids Business Plan Focus Elements updated Sept 12, 2011. - (name redacted) EMS Biosolids Team Meeting May 20,2011. - Biosolids Marketing Feasibility Group Workshop Report, June 27, 2011. - EMS for Biosolids – Meeting Notes of the Annual Management Review – Monday April 4 th , 2011. Element 6. Public Participation in Planning - Element 6: Public Participation in Planning, Version EMS002, issued 06/27/08, revised 09/08/11. - Interviews with BMP team: (name redacted), Solids Manager; (name redacted), Process Control; (name redacted), Environmental Engineer; (name redacted), Customer Service; (name redacted), Administrative Assistant. - Interviews with (name redacted), Customer Service (name redacted), PR/Customer Service/Contract Manager. - Interview with state regulators: (name redacted), Manager Domestic Wastewater Permit Section – Bureau of Water –(name redacted), Staff Engineer – (name redacted). - Interviews with contractor staff ((name redacted)): (name redacted), Tech Services Manager; (name redacted), Field Manager; (name redacted), Lead Operator-Field Crew; (name redacted), Field Crew; (name redacted), Truck Driver; (name redacted), Truck Driver; and (name redacted), Truck Driver. - (name redacted) Biosolids brochure. - (name redacted) wastewater treatment plant tour brochure. - Reviewed (name redacted) Environmental Management System web page (http://www.(name redacted)online.org/environmental-management-system.php) Element 7. Roles and Responsibilities - Element 7: Roles and Responsibilities, Version EMS004, issued 06/27/08, revised 08/26/11. - EMS Document 7.1: EMS Roles and Responsibilities. - Element 7 – Item 10 identifies contractor’s roles and responsibilities. - Internal Memo from (name redacted), Director of Operations appointing EMS Team dated 2 March 2009. - Interviews with BMP team: (name redacted), Solids Manager; (name redacted), Process Control; (name redacted), Environmental Engineer; (name redacted), Customer Service; (name redacted), Administrative Assistant. - Interviews with various (name redacted) staff: (name redacted), Pretreatment Program Manager; (name redacted), Industrial Pretreatment Inspector; (name redacted), Operations Foreman – (name redacted) WWTP; (name redacted), Operations Manager – (name redacted), Operations Foreman – (name redacted), Operations Foreman – (name redacted), Operator II – (name redacted); (name 17 redacted), Operations Foreman – (name redacted) WWTP; and (name redacted), Operations (name redacted) WWTP. - Interviews with contractor staff (name redacted): (name redacted), Tech Services Manager; (name redacted), Field Manager; (name redacted), Lead Operator-Field Crew; (name redacted), Field Crew; (name redacted), Truck Driver; (name redacted), Truck Driver; and (name redacted), Truck Driver. - Biosolids and Wastewater Residuals Management Services Agreement, 5 August 2008. - First Amendment to Biosolids and Wastewater Residuals Management Services Agreement, 5 August 2011. Element 8. Training - Element 8: Training, Version EMS001, issued 06/27/08, revised 05/31/11. - EMS Document 8.1: Training Requirements by Job Title. - Interview with (name redacted), Director Human Resources. - Interviews with BMP team: (name redacted), Solids Manager; (name redacted), Process Control; (name redacted), Environmental Engineer; (name redacted), Customer Service; (name redacted), Administrative Assistant. - Interviews with contractor staff ((name redacted)): (name redacted), Tech Services Manager; (name redacted), Field Manager; (name redacted), Lead Operator-Field Crew; (name redacted), Field Crew; (name redacted), Truck Driver; (name redacted), Truck Driver; and (name redacted), Truck Driver. - Contract haulers and (name redacted)(name redacted) internal training record, given 3-30-11. - Process/EMS Training spreadsheet Feb 2011. - Biological wastewater operator licenses. - Voluntary Biosolids Certifications. Element 9. Communications - Element 9 – Community and Public Outreach, Version EMS003, issued 06/27/08, revised 09/08/11. - EMS Document 9.1: Biosolids Inquiries Log Sheet Template. - Interviews with BMP team: (name redacted), Solids Manager; (name redacted), Process Control; (name redacted), Environmental Engineer; (name redacted), Customer Service; (name redacted), Administrative Assistant. - Interviews with public relations personnel: (name redacted), Customer Service and (name redacted), PR/Customer Service/Contract Manager. - Interviews with contractor staff ((name redacted)): (name redacted), Tech Services Manager; (name redacted), Field Manager; (name redacted), Lead Operator-Field Crew; (name redacted), Field Crew; (name redacted), Truck Driver; (name redacted), Truck Driver; and (name redacted), Truck Driver. - Reviewed Inquiry Log in access database. - Reviewed Contractor Communication plan. - Reviewed use of Element 8 Training to address internal communication. 18 - Reviewed SOP on Responding to Inquiries. - (name redacted) Biosolids brochure. - (name redacted) Environmental Management System web page (http://www.(name redacted)online.org/environmental-management-system.php) - (name redacted)’s Community Inquiry Response Program. - (name redacted) wastewater treatment plant tour brochure. - Viewed Biosolids Performance Reports on website. - Reviewed Biosolids EMS web page and links. - Interview with state regulators: (name redacted), Manager Domestic Wastewater Permit Section – Bureau of Water –(name redacted) and (name redacted), Staff Engineer – (name redacted). Element 10. Operational Control of Critical Control Points - Element 10: Operational Control of Critical Control Points, Version EMS003, issued 06/27/08, revised 09/08/11. - EMS Document 10.1: Operational Control Review/Change form, version 002, issue date 04/02/09, revised 07/21/11. - Interviews with BMP team: (name redacted), Solids Manager; (name redacted), Process Control; (name redacted), Environmental Engineer; (name redacted), Customer Service; (name redacted), Administrative Assistant. - Interviews with critical control point personnel: (name redacted), Pretreatment Program Manager; (name redacted), Industrial Pretreatment Inspector; (name redacted), Operations Foreman – (name redacted), Operator II – (name redacted), Operator II – (name redacted), Operator II – (name redacted), Operator I – (name redacted), Operator I – (name redacted), Operator I – (name redacted), Operations Manager – (name redacted), Operations Foreman – (name redacted), Operator II – (name redacted), Operator II – (name redacted), Operations Foreman – (name redacted), Operator II – (name redacted), Operator II – (name redacted), Operator I – (name redacted), Operator I – (name redacted), Operator II – (name redacted), Operator I – (name redacted), Operator I – (name redacted), Operator II – (name redacted), Operations Foreman – (name redacted), Operations Foreman – (name redacted), Operator II – (name redacted), Operator II – (name redacted); - Interviews with contractor staff ((name redacted)): (name redacted), Tech Services Manager; (name redacted), Field Manager; (name redacted), Lead Operator-Field Crew; (name redacted), Field Crew; (name redacted), Truck Driver; (name redacted), Truck Driver; and (name redacted), Truck Driver. - (name redacted) Regional Sewer Authority Request of Competitive Sealed Technical Proposals for Biosolids and Wastewater Residuals Management Services, August 2007. - Biosolids and Wastewater Residuals Management Services Agreement, 5 August 2008. - First Amendment to Biosolids and Wastewater Residuals Management Services Agreement, 5 August 2011. - (name redacted) Standard Operating Procedure – (name redacted) Buffer Zone and Spreader Operator Instruction Sheet 7/26/11. 19 - (name redacted) Standard Operating Procedure – (name redacted) Water Resources Permit Summary Sheet 7/25/11. - (name redacted) Standard Operating Procedure – Calibration Procedure (Liquid). - (name redacted) Standard Operating Procedure – (name redacted) Land Application Daily Field Inspection form – 16 June 2008. - (name redacted) Standard Operating Procedure – Spill Control Plan. - (name redacted) Standard Operating Procedure – Odor Control Plan. - (name redacted) Standard Operating Procedure – Incident Notification Procedure 1/24/11. - (name redacted) Standard Operating Procedure – Site Suitability Checklist. - (name redacted) Permit/Application/Map Book Manual (All (name redacted) documentation) - (name redacted) monitoring PAN – Plant Available Nitrogen. - (name redacted) – Residual Application Summary (for metals tracking). - (name redacted) – Rainfall monitoring and measurement. - (name redacted) – Soil Monitoring. - (name redacted) Monthly PM sheets. - (name redacted) WWTP – Anaerobic Digester standard operating procedure version # SOP001, issued 02/18/09. - (name redacted) WWTP – WAS Thickening standard operating procedure, version #SOP001, issued 02/10/09. - (name redacted) WWTP – Biosolids Storage and Loading standard operating procedure # SOP001, issued 02/18/09. - (name redacted) WWTP – Aerobic Digesters 1 & 2 standard operating procedure # SOP001, issued 02/19/09. - (name redacted) WWTP – Anaerobic Digester standard operating procedure # SOP001, issued 02/25/09. Element 11. Emergency Preparedness and Response - Element 11: Emergency Preparedness and Response, Version EMS002, issued 06/27/08, revised 09/08/11. - Table 11.1: Emergency Preparedness and Response Plan Matrix. - Interviews with: (name redacted), Solids Manager; (name redacted), Process Control; (name redacted), Environmental Engineer; (name redacted), Customer Service. - Reviewed (name redacted) Emergency Operations Manual, undated. - Reviewed Solid Management Department - Spill Response Plan and Procedures, version 003, issued 1 January 1999, revised 4 April 2009. - WCRSA Biosolids Incident Report on biosolids spill on highway from overturned truck, 19 March 2007. - Spill Procedure (SOP) version # SP001, issued 5/1/2006, revised 3/4/10. - Interviews with contractor staff ((name redacted)): (name redacted), Tech Services Manager; (name redacted), Field Manager; (name redacted), Lead Operator-Field Crew; (name redacted), Field Crew; (name redacted), Truck Driver; (name redacted), Truck Driver; and (name redacted), Truck Driver. 20 - Reviewed (name redacted) Spill Plan. - Reviewed (name redacted) Incident Notification Procedure. - Inspected mulch and dirt piles and other equipment available for spill control and cleanup at various wastewater treatment plants. Element 12. BMP Documentation and Document Control - Element 12: EMS Documentation and Document Control, version EMS002, issued 06/27/08, revised 09/09/11. - Document Control Log (for tracking all BMP procedure document changes.) - Interviews with: (name redacted), Solids Manager; (name redacted), Process Control; (name redacted), Environmental Engineer; (name redacted), Customer Service. Element 13. Monitoring and Measurement - Element 13: Monitoring and Measurement, version EMS001, issued 06/27/08, revised 02/11/09. - Interviews with: (name redacted), Solids Manager; (name redacted), Process Control; (name redacted), Environmental Engineer; (name redacted), Customer Service. - Interviews with critical control point personnel: (name redacted), Pretreatment Program Manager; (name redacted), Industrial Pretreatment Inspector; (name redacted), Operations Foreman – Mauldin Road WWTP; Fred Nesbitt, Operator II – (name redacted)(name redacted), Operator II – (name redacted), Operator II – (name redacted), Operator I – (name redacted), Operator I – (name redacted), Operator I – (name redacted), Operations Manager – (name redacted), Operations Foreman – (name redacted), Operator II – (name redacted), Operator II – (name redacted), Operations Foreman (name redacted), Operator II – (name redacted); (name redacted), Operator II – (name redacted), Operator I – (name redacted), Operator I – (name redacted), Operator II – (name redacted), Operator I – (name redacted)(name redacted), Operator I – (name redacted), Operator II – (name redacted), Operations Foreman – (name redacted)(name redacted), Operations Foreman – (name redacted), Operator II – (name redacted), Operator II – (name redacted), Tech Services Manager – (name redacted); (name redacted), Field Manager – (name redacted); (name redacted), Lead Operator-Field Crew – (name redacted); (name redacted), Field Crew – (name redacted); (name redacted), Truck Driver – (name redacted); (name redacted), Truck Driver – (name redacted); (name redacted), Truck Driver – (name redacted). - (name redacted) Regional Sewer Authority Request of Competitive Sealed Technical Proposals for Biosolids and Wastewater Residuals Management Services, August 2007. - Biosolids and Wastewater Residuals Management Services Agreement, 5 August 2008. - First Amendment to Biosolids and Wastewater Residuals Management Services Agreement, 5 August 2011. 21 - (name redacted) Standard Operating Procedure – (name redacted) Buffer Zone and Spreader Operator Instruction Sheet 7/26/11. - (name redacted) Standard Operating Procedure – (name redacted) Water Resources Permit Summary Sheet 7/25/11. - (name redacted) Standard Operating Procedure – Calibration Procedure (Liquid). - (name redacted) Standard Operating Procedure – (name redacted) Land Application Daily Field Inspection form – 16 June 2008. - (name redacted) Standard Operating Procedure – Spill Control Plan. - (name redacted) Standard Operating Procedure – Odor Control Plan for (name redacted), undated. - (name redacted) Standard Operating Procedure – Incident Notification Procedure 1/24/11. - (name redacted) Standard Operating Procedure – Site Suitability Checklist. - (name redacted) Permit/Application/Map Book Manual (All (name redacted) documentation) - (name redacted) monitoring PAN – Plant Available Nitrogen. - (name redacted) – Residual Application Summary (for metals tracking). - (name redacted) – Rainfall monitoring and measurement. - (name redacted) – Soil Monitoring. - Land application record sheet form. - Surface Water Discharge Permit (name redacted) Permit # SC0048381 – First quarter monitoring report – 19 April 2011. - Sampling results for first quarter 2011: metals, pathogens, vector attraction. - Annual Report for 2010 – Soil Analysis Reports (multiple fields) – organic P, K, Mg, Ca, Na, pH, Acidity, cation exchange capacity, & percent saturation. Additionally, Hg, metals, semi-volatiles, herbicides, PCBs, pesticides, volatiles, and TCLP. - (name redacted) Scorecard – Measures, Reporting Frequency, and Key Tracker – 2011. - Checked periodic progress reviews on goals and objectives. Element 14. Nonconformances: Preventive and Corrective Action - Element 14: Nonconformance – Preventive and Corrective Action, version EMS003, issued 06/27/08, revised 07/05/11. - EMS Document 14.1: Nonconformance/Non-Compliance Action Work Order, version 004, issue date3 4/1/09, revised 06/08/11. - EMS Document 14.2: Nonconformance/Noncompliance Action Work Order Tracking Log. - Reviewed electronic folder containing open Action Work Orders. - Interviews with: (name redacted), Solids Manager; (name redacted), Process Control; (name redacted), Environmental Engineer; (name redacted), Customer Service. - Reviewed all corrective action work orders and correction status for findings identified in the ORR. 22 Element 15. Biosolids Management Program Report - Element 15: Periodic Biosolids Program Performance Report, version EMS 002, issued 06/27/08, revised 09/08/11. - Interviews with: (name redacted), Solids Manager; (name redacted), Process Control; (name redacted), Environmental Engineer; (name redacted), Customer Service. - Reviewed 2009 Biosolids Performance Report. - Reviewed 2010 Biosolids Performance Report. - Reviewed 2011 Biosolids Performance Report. - Viewed Biosolids Performance Reports on website. Element 16. Internal BMP Audit - Element 16: Internal EMS Audit, version EMS003, issued 06/27/08, revised 09/09/11. - Interviews with: (name redacted), Solids Manager; (name redacted), Process Control; (name redacted), Environmental Engineer; (name redacted), Customer Service. - Biosolids EMS Internal Audit Report, February 24, 2010 (audit dates March – Dec 2009) - EMS Internal Audit Executive Summary March 24, 2010. - EMS Biosolids Internal Audit Scope, Work Plan and Procedures for first internal audit. - (name redacted) Biosolids EMS Internal Audit Checklist – completed forms. Element 17. Management Review - Element 17: Periodic Management Review of Performance, version EMS002, issued 06/27/08, revised 09/09/11. - Interviews with top management: (name redacted), Executive Director and (name redacted), Director of Operations - Interviews with: (name redacted), Solids Manager; (name redacted), Process Control; (name redacted), Environmental Engineer; (name redacted), Customer Service. - EMS for Biosolids – Meeting Notes of the Annual Management Review – Monday April 4 th , 2011. - EMS Schedule of EMS Activities throughout the year. 23 Attachment 2 Detailed Results From Desk Audit/On-Site Readiness Review Observations  EMS overall – All elements that require involvement of contractor activities were either not addressed in the contractor service agreement or were otherwise not adequately addressed in the relevant procedures. (See Elements 1, 2, 7, 8, 9, 10, 11, 12, 13, and 16)  Requirement 1.7 – The contractor responsibility section of (name redacted)’s Element 1 Procedure does not describe the activities assigned to and performed by the contractor.  Requirement 2.1 – The Biosolids Management Policy and Biosolids Mission Statement are undated.  Requirement 2.2 – The organization is required to communicate the policy to all interested parties. The method of communicating the policy to these individuals is reported to be through posting it on the (name redacted) web page. This posting was not accessible.  Requirement 4.2 – EMS Document 4.1 presents general broad regulations and permits without reference to how they apply to (name redacted), or what specifically is required. The information given does not clearly include or cross- reference what specific standards, limits, reports, records, etc. the facility must meet in order to be in compliance; or the operational controls, procedures, processes, and other management methods used to achieve and maintain compliance. Additionally there is no reference to the NPDES pretreatment program specifics, the NPDES No. SC0048381 permit details, biosolids requirements of R.61-9 and the land application permit.  Requirement 5.1 – The Element 5 procedure does not describe an approach used to periodically review the progress made on goals and objectives throughout the year.  Requirement 5.3 – There was no evidence to demonstrate that input from interested parties developed through proactive public participation was considered in developing goals and objectives.  Requirement 5.5 – Not all goals and objectives used the SMART criteria in their development. 24  Requirement 5.7 – The goals and objectives action plans do not adequately address detailed actions, schedules, milestones, resources, and responsibilities for achieving goals and objectives.  Requirement 6.1 – A proactive public participation program has not been fully developed.  Requirement 6.5 – Input from interested parties was not considered in updating goals and objectives.  Requirement 7.1 – The detailed and specific roles and responsibilities of the EMS Team are not adequately defined (including participation in regularly scheduled EMS meetings).  Requirement 7.3 – There has not been an adequate upper management level (tech services division and operations division) involvement or responsibility for ensuring the biosolids management program and EMS are implemented and maintained.  Requirement 10.2 – The legal requirements for meeting Class B biosolids through the anaerobic and aerobic digestion processes are not specifically incorporated into the SOPs for these processes.  Requirement 12.2 – The procedure does not adequately address the approach for development of and changes to EMS procedures and SOPs, the method of properly marking procedures, the electronic method used for document control, the method used to ensure uncontrolled document are properly identified and not used, the method of archiving EMS materials, etc.  Requirement 12.3 – The procedure does not adequately address the methods for maintaining records and retention times for EMS activities, including regulation required records, operational records, laboratory records, training records, maintenance records, etc.  Requirement 13.1 – There is presently inadequate tracking of progress on accomplishment of goals and objectives.  Requirement 14.3 – EMS Document 14.1: Nonconformance/Non-Compliance Action Work Order does not contain a section/space to identify the corrective actions taken to prevent a recurrence.  Requirement 14.6 – While the procedure indicates that the progress on closing major nonconformances will be every week and tracking of the progress on closing minor nonconformances will be every two weeks; there is no evidence that this procedure is followed. 25  Requirement 15.1 – There has been no Biosolids Program and EMS Performance Report prepared for 2010.  Requirement 16.2 – The internal audit procedure specifies times for completion of the audit, resolution of the nonconformances, and communication of the results to the executive director. These time requirements were not met.  Element 17 – The procedure requires that the biosolids program performance reported at the management review will include financial information related to biosolids management activities. No financial information related to the total cost of biosolids management has been reported. Opportunities for Improvement  EMS Manual and other documents – Consider employing the terms “solids” and “biosolids” in place of the term “sludge” throughout all documents.  EMS Overall – Consider preparing an EMS schedule that includes milestone dates for each of the activities addressed in the system, such as: EMS team meetings, quarterly management briefings, annual internal audits, annual performance report preparation, annual management review meeting, formulation of goal and objectives, budgeting, etc.  Element 1 – The (name redacted) Element 1: Biosolids Management Documentation procedure contains in its concluding paragraph information related to a GAP analysis and activities that will be performed; however these activities have already been completed.  Requirement 3.2 – Consider using the title “Potential Operational and Environmental Impacts” for the last column in Table 3.01 – Critical Control Points.  Element 4 – Consider including (name redacted)’s participation in the voluntary biosolids operator certification program of the (name redacted) Water Environment Association as “other requirements” in element 4.  Element 4 – The Element 4: Legal and Other Requirements procedure indicates a hard file of regulations and their updates will be maintained by the biosolids staff. This tracking procedure has been replaced by an electronic intranet web site.  Element 5 – Consider establishing goals and objectives giving consideration to all critical control points throughout the entire biosolids value chain.  Requirement 7.1 – Review the EMS roles and responsibilities for all (name redacted) positions to determine if they should be included in the EMS and/or their responsibilities more clearly defined. 26  Element 9 – Review this procedure to determine if it can be updated, simplified or streamlined.  Requirement 9.2 – Consider defining more clearly what a “timely manner” is when responding to requests, complaints and inquiries.  Requirement 10.4 – Consider how preventive maintenance procedures, and work management systems for maintaining equipment, instrumentation, vehicles, and other treatment technology and process control systems associated with biosolids management activities can be addressed in SOPs and included in the biosolids EMS.  Element 14 – Consider the extent to which corrective action plans should be used by maintenance shop personnel for preventive and corrective maintenance activities and/or equipment repairs.  Element 14 – There is no reference in the procedure to Document 14.3 and how it will be used.  Requirement 14.1 – Consider identifying in the purpose and the scope sections of the procedure that corrective and preventive actions include compliance with regulations.  Requirement 15.1 – Consider including the results of the vector attraction reduction tests for producing Class B biosolids through both anaerobic and aerobic digestion in the Performance Report.  Requirement 16.3 – Consider more clearly defining the qualifications and training for EMS internal auditors. Positive Commendations  Element 1 – The (name redacted) Element 1: Biosolids Management Documentation procedure contains an excellent outline and summary of the purpose of each element of the Environmental Management System.  Element 2 – Excellent use of laminated cards for communicating the policy to all employees.  Element 10 – (name redacted) has a comprehensive development of Standard Operating Procedures (SOPs) for the critical control points in the biosolids value chain. 27  Element 15 – Exemplary format for the annual Biosolids Program and EMS Performance Report prepared for 2009. Attachment 3 National Biosolids Partnership Appeals Process Biosolids organizations that participate in the National Biosolids Partnership (NBP) Biosolids Management Program (BMP) are required to undergo a BMP verification audit by an independent, third party auditor assigned by the NBP and yearly interim audits. The purpose of the BMP audit is to determine whether or not the organization’s BMP conforms with -- that is, meets the minimum requirements of -- the NBP program, as defined in the BMP Elements1. The spirit of these requirements includes a well-documented program and meaningful opportunities for interested party involvement. The NBP provides an appeals process for biosolids organizations and interested parties that disagree with the findings of a third party BMP audit. The verification appeals process involves an Appeals Board; representing a balance of biosolids management interested parties, including an environmental advocacy group, and wastewater industry professionals. An appeal must be submitted within 30 days of the audit company’s official verification decision or interim audit decision. To submit an appeal before the Appeals Board, the petitioner must set forth the specific BMP element(s) and requirements that are believed to have not been evaluated and/or implemented consistent with NBP requirements as reflected in the BMP Elements, along with the objective evidence to support that claim. For example, a petitioner may believe that a major nonconformance exists but was not found by the auditor. In this case, the petitioner would need to identify in the petition the specific BMP element believed to be out of conformance and why. To submit an appeal, petitioners must fill out and submit the standardized appeals petition form that is available on the NBP website at http://www.biosolids.org. A formal appeal must be submitted within 30 days of the verification decision or interim audit decision by the audit company. The Board’s Administrative Officer receives all appeals petitions on behalf of the Board and conducts a basic completeness check. Upon completion of this check, the petition is either forwarded to Appeals Board members or back to the petitioner with incomplete areas documented Petitions should be sent via certified, return receipt requested mail to: The NBP BMP Appeals Board, Attention: Board Administrative Officer, c/o Water Environment Federation, 601 Wythe Street, Alexandria, VA 22314 The Appeals Board will examine the facts, interview parties involved, deliberate the case, and then make a determination as to whether a major nonconformance does or does not exist. Appeals cases vary in complexity. As a result, the time required for the Board to evaluate a case and make a decision might vary. However, the overall Board target for processing an appeal is approximately four months. 1 The EMS Elements and other program materials are available on the NBP website at http://www.biosolids.org. 17 NSF –ISR Proposal to Provide Third-party Audits of the Ft. Collins EMS and Biosolids Programs Appendix E Auditor Resumes NSF International 789 N. Dixboro Rd. | Ann Arbor, MI 48105 William Hancuff, Jr RESTON, VA, USA PROFILE: Dr. Hancuff has over 25 years of diversified environmental engineering and management experience. His expertise is based on both national and international work in all aspects of environmental engineering including: environmental compliance services, public works water and wastewater planning and design, environmental and health impact analyses, technical and economic feasibility studies, regional framework strategies for water quality, hazardous waste management cost modeling and air quality assessments. Project management includes: federal environmental regulation development, hazardous waste site investigations, environmental regulatory compliance audits, pollution prevention through waste minimization, energy recovery from solid waste, biosolids treatment and disposal, toxic and hazardous waste studies, environmental impact assessments, storm water management, water resources investigations, potable water system planning, and numerous municipal and industrial waste treatment feasibility and cost studies. EDUCATION: University of Texas at Austin Ph.D., Environmental Health Engineering Stanford University M.S., Engineering Economic Planning Engineer Degree, Sanitary Engineering Loyola University B.S., Civil Engineering EXPERIENCE: NSF International Strategic Registrations Lead Auditor for NSF-ISR Dr. Hancuff has worked both directly as an employee of major municipal wastewater treatment plants as well as a consulting engineer for numerous biosolids projects. He has the practical experience of working directly with biosolids management associated with his employment at two of the largest municipal wastewater treatment plants in the United States -- the City of Los Angeles' Hyperion Wastewater Treatment Plant and the Los Angeles County Sanitation Districts Joint Disposal Plant. (1.5 years). In addition to this his most relevant experience as a consultant on projects that involved biosolids processing are as follows: Served as the principal-in-charge (2 years) on the design and construction management of the Williamsburg, VA wastewater treatment facilities expansion for the Hampton Roads Sanitation District. Design modifications included addition of intermediate oxidation towers, additional 2 clarification facilities and supplemental sludge handling equipment. The new sludge processing equipment consisted of plate and frame filter presses with landfilling or optional land application of biosolids products. Served as project director (1 year) providing engineering services in connection with the preparation of the wastewater plant operation and maintenance manual and operator training for Howard County, Maryland's Savage Wastewater Treatment Facility. Solids handling included dissolved air floatation, aerobic digestion, gravity thickening and belt filter presses. Served as an expert witness (0.5 years) relative to the proper operation of a biosolids and refuse co-composting facility. In a suit and countersuit involving the District of Columbia's Blue Plains Wastewater facility Dr. Hancuff was called on to represent and defend against testimony regarding what constitutes a technically and legally correct operation of a composting facility. This technical assistance was provided to prove that the client had provided and maintained composting conditions that were consistent with both scientifically demonstrated methods of effectiveness and in accordance with the State of Maryland regulations. Served as an environmental compliance auditor (8 years) for the Environmental Compliance Assessment Monitoring Program (ECAMP) for U.S. Air Force bases throughout the United States. Of the 17 major environmental protocols, Dr. Hancuff's has had exclusive responsibility for evaluation of facilities for compliance with the Clean Water Act and the Safe Drinking Water Act. During this period he has provided over 75 week long audits for compliance, which includes facilities with a variety of biosolids processes and land application disposals. The focus of the later evaluation has been on compliance with 40 CFR 503. NSF International 789 N. Dixboro Rd. | Ann Arbor, MI 48105 John McVaugh HOUSTON, TX, USA EDUCATION: University of Delaware BChE, Chemical Engineering MS, Civil (Environmental) Engineering EXPERIENCE: NSF International Strategic Registrations Lead Auditor for NSF-ISR INDUSTRY EXPERIENCE/HIGHLIGHTS: Over 21 years of environmental, business and operations management experience gained at the corporate, business unit and plant levels. Established and directed cross-functional organizations to reduce waste, operating costs, compliance costs and improve product quality. Implemented environmental management, total quality management and ISO 9000 quality systems. • Consulted with petrochemical, oil and gas, automotive and other clients in optimizing environmental management system effectiveness. • Managed environmental affairs group, for a large chemical company, responsible for regulatory compliance auditing and consulting, pre-acquisition site assessments and environmental control system engineering. • Participating in the U.S. Technical Advisory Group developing the ISO 14000 International Environmental Management Standards. • Formed and led cross-functional team which reduced compliance costs by over $600 thousand per year. • Developed and presented critically acclaimed ISO 14000 courses and training programs, including a graduate level course in EMS implementation at the University of Houston - Clear Lake School of Business And Public Administration. CERTIFICATIONS: ISO 14001 Lead Auditor RC 14001 Lead Auditor Bill 7 Roles and Responsibilities Operations Mgr - Solids (name redacted) 9:00 – 10:00 Bill 6 & 9 Public Part. & Communication program review Public Relations 10:00- 11:00 Bill 16 Internal EMS Audit Internal Auditors 11:00 – 12:00 Bill 14 Review Nonconformances: Preventive & Corrective Action from Internal Audit Operations Mgr - Solids (name redacted) 12:00 – 1:00 Lunch 1:00 – 2:00 Bill 5, 10, 13 Review Goals/Objectives Operations Mgr - Solids (name redacted) 2:00 – 3:00 Bill 5, 10, 13 Outcomes – environmental performance Operations Mgr - Solids (name redacted) 3:00 – 4:00 Bill 5, 10, 13 Outcomes – quality biosolids management practices Operations Mgr - Solids (name redacted) 4:00 – 4:30 Bill Prepare auditor notes NA 4:30 – 5:00 Bill Summarize days activities Operations Mgr - Solids (name redacted) responsibilities in mgmt. (name redacted) Manager TBD 4:00 – 4:30 Bill Prepare auditor notes NA 4:30 – 5:00 Bill Summarize days activities Operations Mgr - Solids (name redacted) DAY 2 Date Time 1) Auditor Elemt. Activity / Element Department Name 2) Comment 9/13/10 Tuesday 8:00 – 9:30 Bill 4 Legal and other requirements Review – Surface Water Discharge Permit & land application permit Operations Mgr - Solids (name redacted) 9:30 – 10:30 Bill 4 Land application records and reports Operations Mgr - Solids (name redacted) 10:30 – 11.00 Bill 4, 6 & 9 Legal, Public Part & Communication Regulators - (name redacted) TBD 11:00 – 12:00 Bill 3, 4, 7, 10, 13 Industrial Waste Operations Pretreatment Staff (name redacted) 12:00 – 1:00 Bill Lunch NA 1:00 – 4:00 Bill 3, 5, 7, 8, 10, 11, 13 Visit Plants – (name redacted)& (name redacted) WWTP Plant managers (name redacted) & others 4:00 – 4:30 Bill Prepare auditor notes NA 4:30 – 5:00 Bill Summarize days activities Operations Mgr - Solids (name redacted) Comment 7/2/13 Tuesday 8:00 – 9:30 Bill 4 Legal and other requirements Review – Surface Water Discharge Permit & Air Permit Operations (redacted) 9:30 – 10:30 Bill 3, 4, 7, 10, 13 Industrial Waste Operations Pretreatment Staff 10:30 – 11.00 Bill 4, 6 & 9 Legal, Public Part & Communication Regulators – (redacted) 11:00 – 12:00 Bill 12 Documentation and Document Control (redacted) 12:00 – 1:00 Bill Lunch NA 1:00 – 2:30 Bill Prepare draft audit results NA 2:30 – 3:30 Bill Pre-closing Meeting Operations Mgr - Solids 3:30 – 4:00 Bill Closing Meeting EMS Team 1) Changes possible 2) To be determined by the client Distribution: Auditee Representatives Auditor Travel Time On-Site Readiness Review Desktop Audit, Detailed EMS Manual review/interviews Biosolids Verification Auditor Daily Rate: 215 North Mason St., 2nd floor, Fort Collins, Colorado 80524 EMS manual review, scheduling, preparation, and coordination Scheduling, preparation, and coordination Evaluation of Goals & Objectives & Outcomes Interim Audit Scope of Work The scope of each interim audit specifically includes a review of the requirements of Elements 5, 14, and 17; namely the organization’s progress toward goals and objectives; BMP outcomes (environmental performance, regulatory compliance, interested party relations, and quality practices); actions taken to correct minor non-conformances; the management review process; and corrective and preventive action requests and responses. Because other system elements interact with the above specific requirements this audit will also include partial auditing of activities found in elements 1, 2, 4, 6, 9, 15, and 16. The NBP auditor guidance indicates that individual interim audits only cover a portion of the BMP. However, over the course of the four interim audits conducted between verification audits the entire BMP (i.e. all 17 elements) must be covered. To that end, four or five individual elements will be audited in their entirety during each interim audit. Work will involve document review, interviews, and field activity evaluations. Total 3-Year Audit Related Costs, Including Estimated Travel Expense: Currency: Manual Element Reviews $33,100 US Dollar Treatment/Biosolids/Application site(s) evaluation AESOP 10750; ISSUE 16; STATUS-PUBLISHED; EFFECTIVE 06 NOV 2015; AUTHORITY CARL BLAZIK 1/11/2017 BDM - CSS ProposalPage 1 of 1 NSF International Strategic Registration Management Systems Registration Proposal for Registration Services ("Quotation") (This is a confidential Quotation intended for the purposes of the issued client only and valid for 90 days from issuance.) Water Reclamation and Biosolids Division ISO 14001:2015 Upgrade Recertification Audit City of Fort Collins ISO 14001:2004 - Medium Risk Streets Department ISO 14001:2015 Surveillance Audit #1 ISO 14001:2015 Pre-Assessment Audit (Optional Service) Streets Department ISO 14001:2015 Upgrade Recertification Audit Biosolids Verification Auditor Daily Rate: 215 North Mason St., 2nd floor, Fort Collins, Colorado 80524 Management Transfer Review Application Water Production Division ISO 14001:2015 Surveillance Audit #1 Water Production Division ISO 14001:2015 Surveillance Audit #2 Team Management Meetings (Optional Service) ISO 14001 Annual Registration Maintenance Total 3-Year Audit Related Costs, Excluding Travel Expense: Currency: Streets Department ISO 14001:2015 Surveillance Audit #2 $36,400 US Dollar AESOP 10750; ISSUE 16; STATUS-PUBLISHED; EFFECTIVE 06 NOV 2015; AUTHORITY CARL BLAZIK 1/11/2017 BDM - CSS ProposalPage 1 of 1