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NBP EMS Workshop #3

Summary Report

Prepared by

November 13-14, 2007

Nashville, TN

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Table of Contents Introduction .....................................................................................................................3

Objectives .......................................................................................................................4

The EMS Development Process ......................................................................................5

NBP EMS Outcomes .......................................................................................................5

NBP Framework and the 17 Elements .............................................................................6

17 Elements in an EMS Chart ..........................................................................................6

NBP EMS Elements 14, 15, 16, and 17 ...........................................................................8

Summary and Recommendations ....................................................................................10

Certificates .......................................................................................................................10

Appendix A – Attendee List ......................................................................................11

Appendix B – H.W. Assignement # 3........................................................................13

Appendix C – Agenda ................................................................................................15

Appendix D – Exercices ............................................................................................17

Appendix E – Internal Audit Review .........................................................................19

Appendix F – Transaction Testing .............................................................................23

Appendix G – Audit Demonstration ..........................................................................24

Appendix H – Audit Checklist ...................................................................................27

Appendix I – Summary of Evaluations ......................................................................37

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INTRODUCTION The NBP is a nonprofit alliance formed in 1997 by the National Association of Clean Water Agencies (NACWA), Water Environment Federation (WEF) and the U.S. Environmental Protection Agency (USEPA). The NBP is committed to developing and advancing environmentally sound and sustainable biosolids management practices that go beyond regulatory compliance. The NBP promotes public participation in biosolids programs to enhance the credibility and public acceptance of beneficial reuse of biosolids. The University of Florida Center for Training, Research and Education (UF/TREEO) in conjunction with the National Biosolids Partnership (NBP) conducted a two-day Environmental Management Systems (EMS) workshop in Nashville, Tennessee on November 13-14, 2007. This workshop was an opportunity for these agencies to interact together both in the classroom and via webcast. This workshop (EMS Workshop #3) is the third course in the series. The primary focus of this workshop was Auditing, specifically Internal Auditing. Thanks are extended to:

• CH2M Hill for preparing the initial workshop materials. • UF/TREEO and Ross & Associates for updating the materials.

This report is intended to highlight some key topics covered during the workshop and serve as a high-level summary for those either unable to attend or interested in reviewing some of the workshop’s key learning objectives. It is not intended to substitute for attending nor does it present all the material that was covered in the workshop. There were 8 utilities represented by 26 attendees. The list of attendees is shown in Appendix A, pages 11-12. NBP and WEF coordinated a webcast. There were four individuals that participated and they received their manuals prior to the workshop and were given a phone number and website, which allowed them to participate. The instructional team consisted of Peter Machno, Project Manager NBP EMS Project, William T. Engel, Director, UF/TREEO and Douglas Dean, Adjunct Professor UF/TREEO and President Matrix Compliance Services. The participants were given the following assignments at the conclusion of Workshop #2:

• H.W. Assignment Sheet #2 (see Appendix B, page 13) • Reading Assignment - NBP EMS Guidance Manual, Elements 14, 15, 16, and 17.

The agenda for the workshop is shown in Appendix C, pages 15-16. The workshop was designed to engage attendee participation. This was accomplished through guided discussions, role playing and question and answer opportunities. During the workshop Mike Taylor, from Columbus Georgia, participated. They are a Certified NBP Agency. His presentation focused on the Internal Audit and the Third-Party Audit. He provided helpful

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suggestions to the class as well as a willingness to answer questions once the folks start on the audit process. To improve the implementation and public acceptance of environmentally sound biosolids management practices, the NBP has developed a voluntary EMS certification program for the biosolids industry. The 17 agencies that are currently certified include:*

• East Bay Municipal Utilities District, California

• Encino WW Authority, California • Orange County Sanitation District, California • City of Los Angles Department of Public

Works, California • Metro WW Reclamation, Colorado • Kent County Public Works Department,

Delaware • District of Columbia Water and Sewer

Authority, Washington, DC • Madison Metropolitan Sewerage District,

Wisconsin

• Columbus Water Works, Georgia • City of Lawrence Department of

Utilities, Kansas • City of Grand Rapids, Michigan • City of Raleigh Public Utilities

Department, North Carolina • Butler County Department of

Environmental Services, Ohio • City of Albany, Oregon • City of Fort Worth Water District, Texas • King County Division of Wastewater

Treatment, Washington • Tri-City Service District, Oregon City,

OR

*see www.biosolids.org for details of each facility’s EMS

OBJECTIVES The instructional team developed the following objectives for the workshop. The intent was for the participants to be able to accomplish these objectives over the two-day training period.

Identify NBP expectations (i.e., minimum conformance requirements) for Elements 14–17 Identify, document and address nonconformances through preventive and corrective action Develop a biosolids program and EMS performance report Identify the steps in preparing for and conducting an audit Describe why audits are important Plan a management review Understand EMS status, remaining tasks and schedules

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Understand process and requirements for third party verification The EMS Development Process is shown as a timeline below. This gives the schedule for the 18 Month program.

NBP EMS OUTCOMES

An EMS is a management framework for reducing environmental impacts and improving organizational performance over time. Implementing an EMS is voluntary; therefore, the EMS framework can be adapted to support the organization’s needs, priorities, and circumstances. The NBP EMS framework supports continual improvement in four key outcome areas that will help an organization foster public acceptance.

• Regulatory compliance • Quality management practices • Improved relations with interested parties • Environmental performance

The EMS framework is based on the “plan-do-check-act” continual improvement cycle of total quality management (TQM) and involves a set of planning activities, procedures, performance monitoring, and review to allow an organization to improve business processes over time.

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NBP FRAMEWORK AND THE 17 ELEMENTS The NBP developed a framework that consists of 17 building blocks, or elements (see below) for developing and implementing an EMS.

There Are 17 Elementsin an EMS

Measurement and Corrective Action

Planning

5 Major Groupings –correspond to P-D-C-A

Implementation

Management Review

Overview and Policy

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Taken together, these elements provide a structure for helping the organization:

• Establish guiding principles for your biosolids management program • Set goals for continual improvement • Implement procedures for ensuring consistent product and service quality • Engage stakeholders to demonstrate that your program is committed to protecting the

environment and carrying out your stated mission • Correct and prevent problems • Measure and report performance improvements, and act on lessons learned and opportunities for

additional improvements The 17 elements, shown on page 6, are grouped into five categories.

• Overview and Policy • Planning • Implementation • Measurement and Corrective Action • Management Review

Participants in the NBP EMS program will be evaluated on whether their EMS actually supports real performance improvements in these areas. In other words, outcomes matter. The workshop covered the four outcomes that the EMS promotes. It also emphasized the importance of focusing on the biosolids value chain when developing an EMS. Eight Elements were covered in Workshop #1. Five elements were covered in Workshop #2, and four elements were covered in Workshop #3. The breakdowns are shown below.

EMS Element Workshop 1 Workshop 2 Workshop 3 1 – EMS Manual X 2 – Biosolids Management Policy X 3 - CCPs X 4 – Legal/Other Requirements X 5 – Goals & Objectives X 6 – Public Participation X 7 – Roles & Responsibilities X 8 - Training X 9 - Communications X 10 – Operational Control X 11 – Emergency Preparedness X 12 – Documentation/Doc. Control X 13 – Monitoring & Measuring X 14 - Nonconformances X 15 – Performance Report X 16 – Internal Audit X 17 – Management Review X

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NBP/EMS Elements 14, 15, 16 and 17 Following is a listing of NBP expectations also referred to as Minimum Conformance Requirements (MCR). Element 14: Nonconformances: Preventative and Corrective Action

NBP MCR will:

Develop and implement a procedure to: Investigate any noncompliance with applicable regulatory requirements and/or

nonconformance with internal EMS procedures identified during routine monitoring and measurement or periodic internal EMS audits

Identify the cause and take actions to correct the nonconformance Document the necessary corrective actions taken to prevent a recurrence

Develop corrective action plans to address nonconformances identified during routine monitoring and measurement and identify the nonconformance, the root cause(s) and the corrective action being taken

Include recommended changes to policies, programs, plans, operational controls and monitoring/measurement procedures

Document changes in the corrective action plan and in the EMS Manual Track progress in completing the corrective actions and periodically update to reflect completion

Exercise 1 (Appendix D, pages 17-18) was conducted as a class exercise. A couple of Corrective and Preventative Action Forms were also provided to the class.

Element 15: Biosolids Program and EMS Performance Report NBP MCR will:

Complete a periodic written Biosolids Management Program Performance Report (at least annually)

Summarize the performance of the biosolids management program Include summaries of monitoring, measurement and other results that demonstrate the

performance of the biosolids program relative to its goals, objectives and legal requirements

Include those biosolids activities conducted by contractors Include summaries of performance relative to other voluntarily adopted requirements and

progress toward goals and objectives Include a summary of the third party EMS verification audit results

Make the periodic Biosolids Management Program Report available to the public Have the flexibility of using other methods, including electronic methods such as a biosolids

program web page, in addition to or in lieu of a written periodic performance report Several Performance Reports were provided to the class. There was a group discussion, followed by a question and answer period.

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Element 17: Management Review

NBP MCR will: At intervals the management determines appropriate, review the EMS and its performance

relative to policy commitments, goals, objectives and established performance measures to ensure its continuing stability, adequacy and effectiveness

The management review shall address the possible need for changes to policy, goals and objectives, the biosolids management program and other EMS elements based on internal EMS results, external verification EMS audits by third parties, changing circumstances and the commitment to continual improvement

Any changes to policies, plans, procedures and work practices that are made as a result of the review shall also be documented

Maintain, at a minimum, the following: A schedule and scope for review Documentation of findings, evaluation and follow-up actions Documentation of changes to policies, plans, procedures, practices and other EMS

elements that occur as a result of the findings of the management review, evaluation or follow up actions

Assign a lead person or persons to be responsible for organizing and conducting the review

Element 16: Internal EMS Audit NBP MCR will:

Establish and maintain an internal audit program to periodically analyze the Biosolids EMS and determine whether it is effectively meeting its biosolids management policy, program requirements and biosolids program objectives

The internal EMS audit program shall define the scope, frequency and methodology of the audits, assign responsibility for conducting the audits and communicating their findings and designate individuals to whom these findings are to be conveyed

The internal audit shall also evaluate the organization’s performance relative to established biosolids program goals, objectives and performance measures

The internal EMS audit program shall cover all the organization’s biosolids management program activities, including those performed by contractors

Report internal EMS audit results to the organization’s management in a way that they can take action to make necessary modifications to the EMS and biosolids management program

Maintain at a minimum the following documents and records, as applicable, relating to its audit program:

Description of audit methodology, protocol, scope and schedule Identification of lead auditor(s); qualifications and description of roles and

responsibilities of the auditors; management representatives and others that may participate in, review or be expected to act upon the audit

Corrective and/or preventive action plans prepared resulting from an audit and any related changes made to policies, plans, procedures and work practices that occur as a result of an audit’s findings, evaluation or follow up actions

There was a class discussion on an Internal Audit Report, (see Appendix E, pages 19-22) The following three sections all dealt with Auditing. The first was a discussion on Auditing Approach and Methodology. The concept of Transaction Testing was introduced, several examples were

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discussed. An exercise on Transaction Testing was conducted, (see Appendix F, page 23) An Audit Demonstration was also conducted. Class volunteers participated and that role playing information is included in Appendix G, pages 24-26. The second was a discussion on planning and conducting the audit and post audit activities. The exercise involved the development of a check list. After the development of a check-list, there was a group discussion on the Example Audit Schedule, and the EMS Audit Report. (see Appendix H, pages 27-36) The third was a discussion on the Third Party Audit program. The discussion concluded with a summary of the roles and responsibilities of the client and NBP. SUMMARY AND RECOMMENDATIONS Participants are invited to share their thoughts and comments both during and after the workshop. This feedback is part of the continual improvement process of presenting training courses. The instructional team makes every effort to incorporate suggestions in future training courses. Input was received in an open forum after days one and two. At the conclusion of the class, written evaluations were collected and summarized. A summary of the written evaluations as well as a blank evaluation form is shown in Appendix I, pages 37-40. As a result of reviewing the evaluations, having discussions with NBP personnel and the instructional team, the following recommendations are being made.

• Continue the meetings with technical assistants as part of the workshop. • Continue to have at least one, possibly two Case Study Presentation(s). • Review agenda and possibly modify times.

CERTIFICATES UF/TREEO will award 1.4 CEU’s to those that attended the entire 2 day workshop.

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Appendix A: List of Attendees

NBP Workshop #3 Attendees - Nashville, TN – November 13-14, 2007 Clark Annis Crossville WWTP 468 Sparta Hwy Crossville TN 38572 (931) 484-6257 clark.annis@veoliawaterna.com Ned Beecher NEBRA/CDM PO Box 422 Tamworth NH 03886 (603) 323-7654 ned.beecher@nebiosolids.org Craig Brymer Athens Utilities Board PO Box 689 Athens TN 37371 (423) 745-4501 cbrymer@aub.org David Coe Louisville & JEfferson County MEtropolitan Sewer District Morris Forman WWTP Louisville KY (502) 540-6730 coe@msdlouky.org Kenneth W. Cox Metro Water Services - Dry Creek 1600 2nd Ave North Nashville TN 37208 (615) 862-7233 ken.cox@nashville.gov Roy Denney Metro Water Services 1600 2nd Ave N Nashville TN 37208 (615) 862-4885 roy.denney@nashville.gov Glenn Fraley Superintendent City of Dayton WWTP PO Box 226 Dayton TN 37321 (423) 775-8409 gfraley@bellsouth.net Terry E. Highsmith

Noelle Anuszkiewicz Anne Arrundel Co. 1640 Professional Blvd Crofton MD 21114 (410) 222-7931 pwnoel00@aacounty.org William Bryant Metro Water Services 1600 2nd Ave N Nashville TN 37208 (615) 862-4590 william.bryant@nashville.gov Michael Butler City of Portland WWTP 100 S Russell St Portland TN 37148 (615) 325-6989 portlanc@bellsouth.net Peter Coleman Erving Center Wastewater Treatment Plant 97 E Main St Erving MA 01344 /413) 422-2700 peter@erseco.com Jill Davis Athens Utility Board PO Box 689 Athens TN 37371 (423) 745-4501 jdavis@aub.org Bob Forbes CH2M Hill 4824 Parkway Plaza Blvd, 200 Charlotte NC 28127 (704) 329-0072 (678) 579-8143 bob.forbes@ch2m.com Scott Freeman Crossville WWTP 468 Sparta Hwy Crossville TN 38572 (931) 484-6257

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Metro Water Services 1600 2nd Ave North Nashville TN 37208 (615) 862-4885 terry.highsmith@nashville.gov Peter Maynard Consultant CDM 50 Hampshire St Cambridge MA 02143 (617) 452-6370 (617) 452-8370 maynardpt@cdm.com Tony Mencome City of Raleigh PO Box 590 Raleigh NC 27602 Tom Schultz Mechanic Fall Sanitary Dist. PO Box 556 Lewiston St Mechanic Falls ME 04256 (207) 245-3077 ts27748@aol.com Ron Taylor Metro Water Services 1600 2nd Ave N Nashville TN 37108 (615) 862-4584 ron.taylor@nashville.gov Mary Waring NE Organics 135 Presumpscot St, Unit 1 Portland ME 04103 (207) 781-5011 (207) 781-5794 mary.waring@casella.com

Brett Jutras Resource Management, Inc. PO Box 1081 Ashland NH 03217 (603) 536-8900 brett.jutras@rmirecycles.com Jeff McBurnie Solid Preparation PO Box 158 Plymouth ME 04969 (207) 257-2525 (207) 257-2637 jeff.mcburnie@wecarecompanies.com Angie D. Moore Metro Water Services 1600 2nd Ave North Nashville TN 37208 (615) 862-4885 Stacey Servo CH2M Hill 401 W Main St #500 Louisville KY 40202 (502) 584-6052 stacey.servo@ch2m.com David M. Tucker Metro Water Services 1600 2nd Ave N Nashville TN 37208 (615) 862-4885 david.tucker@nashville.gov Edward J. White Metro Water Services 1600 2nd Ave North Nashville TN 37208 (615) 862-4885 (615) 862-4966 joe.white@nashville.gov

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Appendix B: Homework Assignment #3

NBP EMS Workshop Instructions Please complete the following in preparation for the upcoming Workshop #3. Please answer each item as specifically as you can. If you have any questions, please contact your Account Executive or Pete Machno (peterm7@prodigy.net).

Assignment

EMS Status/Progress 1. Which elements have you completed so far? _________________________ 2. What seems to be your most difficult challenge to EMS development progress? ____ ____________________________________________________________________________________________________________________________________________ 3. When was the last time you worked/interacted with your Account Executive? Was it helpful? Do you have any recommendations for improvement? ____________________ ____________________________________________________________________________________________________________________________________________ 4. When is your projected date for EMS completion? Once you complete your draft manual, your Account Executive will schedule your EMS Status Review, after which you can begin your operational phase.___________________________________________

Biosolids Quality/Critical Control Points 5. Have you had any difficulties with producing consistent quality biosolids, and managing your process/critical control points? If yes, please explain. _______________ ________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________ Relations with Interested Parties 6. Who is your state regulator responsible for your biosolids management operations? When was the last time you spoke with him/her? ______________________________ ______________________________________________________________________ ____________________________________________________________________________________________________________________________________________

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Workshop 3 Preparation 7. Since you are getting ready for your status review, please download the NBP EMS Status Review Protocol from the NBP website. Review this protocol prior to the workshop. Also, since Workshop #3 places heavy emphasis on internal auditing, it would benefit you if you reviewed the Minimum Conformance Requirements for each of the elements either from the latest NBP EMS Guidance Manual (March 2006) or from your NBP EMS Workshop 1 and 2 manuals. List 3 specific questions that you would like answered at Workshop #3. _____________________________________________ ______________________________________________________________________ _____________________________________________________________________

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Appendix C: Agenda

National Biosolids Partnership - EMS Workshop #3

November 13-14, 2007 Nashville, TN

Day 1 – Tuesday, November 13 8:30-9:30 AM Welcome and Introductions

Workshop Agenda and Objectives Session 1 (William T. Engel and Peter Machno) 9:30-9:45 AM Break 9:45-10:30 AM Nonconformance Session 2 Element 14 (Doug Dean)

Exercise 1 10:30-11:15 AM Performance Report Session 3 Element 15 (Doug Dean) Review of Examples 11:15- 12:00 PM Management Review Session 4 Element 17 (Doug Dean) 12:00-1:00 PM Lunch 1:00-2:15 PM Internal Audit Session 5 Element 16 (Doug Dean) Review of Examples 2:15-2:30 PM Break 2:30-3:30 PM Case Study – Mike Taylor, Columbus, GA 3:30-4:00 PM Wrap-up 4:00 PM Adjourn for the day

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Day 2 – Wednesday, November 14 8:30-10:00 AM Auditing Approach: Session 6 Framework and Methodology Key Areas of Focus Interpretations, Process, Scope, Schedule, Team and Methodology (RE: Transaction Testing) Exercise 2 (Doug Dean) 10:00-10:15 AM Break 10:15-12:00 PM Audit Planning: Session 7 Creating an Audit Checklist, Conducting the Audit and Post Audit Activities Exercise 3 (Doug Dean) 12:00-1:00 PM Lunch 1:00-2:00 PM Introduction to Third Party Audit Program Session 8 (Doug Dean) 2:00-2:30 PM Wrap-up 2:30 PM Adjourn

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Appendix D: Exercises

NBP EMS Workshop #3 Exercise 1: Analyzing Audit Evidence (i.e., Spotting EMS

Deficiencies) You have been asked to conduct an EMS audit of the biosolids value chain at the City of Paradise Municipal Plant. Indicate which elements(s) of the NBP EMS might apply in each of the situations described below:

1. While touring the Paradise treatment facilities, you notice a sandblasting operation to remove old paint from metal railings being refurbished. The spent sandblast grit is lying on the ground and storm water from the grit pile is draining into the chlorine contact chamber. When asked, the Plant Supervisor is not aware is this situation.

2. In discussions with the Plant Supervisor, it is discovered that operators are trained in the

operation of the digesters and sludge drying equipment through on-the-job training. There are no records documenting the date of training or topics covered. The basis of the training is reportedly the Plant Operation and Maintenance manuals delivered when the plant was first constructed in 1975, kept in the Plant’s library.

3. Inspection of the plant’s emergency response plan identifies the Public Works Director as the

Emergency Coordinator responsible for implementing response measures in the event of a release. During an interview, the Director indicates that he is mainly a “figurehead” and that the lead operator of the wastewater treatment facility is actually the person who will provide “hands-on” response to a gaseous chlorine release. During an interview, the lead operator replied that he was transferred to the position about two months ago and was not aware of this assignment.

4. You are unable to identify any procedure that enables the Municipal managers to identify

applicable environmental laws and regulations. The EMS Coordinator assures you that she reviews several publications and the internet each month to ensure that the Plant personnel are always aware of their legal requirements.

5. While examining a complaints file you notice several requests for information from the

environmentalists concerned about the land application of biosolids. You are not able to find any correspondence or method to respond to these requests. The EMS Coordinator and Plant Supervisor are not aware of whether the utility has responded.

6. In the biosolids loading area, you notice what seems to be a good procedure to require the

signature of the drivers receiving the load, as well as acknowledging the receipt of the utility’s spill reporting procedures. The loading operator states that the procedure has a few “bugs” in it and is being ignored until it is revised by the EMS Coordinator.

7. A review of a folder containing corrective actions resulting from previous audits revealed several

corrective actions that did not appear to be closed out. The EMS Coordinator reported that they had been closed but the forms were not signed off.

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Corrective and Preventive Action Plan Form CPAP No.: Issue Date: Solution

Due Date: Issued to: Department:

Phone:

Closed by: Closing Date:

Requested by: Phone: Non-conformance Type:

Legal & Other Requirements Operational: _____________ Documentation

Monitoring & Measurement Policy Other: _________________

Non-conformance Problem Statement: ___________________________________________________________________ ___________________________________________________________________ ___________________________________________________________________ ___________________________________________________________________ ___________________________________________________________________ Most Likely Cause: ___________________________________________________________________ ___________________________________________________________________ Implemented Solution: ___________________________________________________________________ ___________________________________________________________________ Results (confirming effectiveness of solution): ___________________________________________________________________ ___________________________________________________________________

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Appendix E: Internal Audit Report

Environmental Management System

{Contractor} EMS for Biosolids Final Audit Report

Date of Audit: July 29, 2003 Report Prepared by: Rebecca Brooks Lead Auditor Rebecca Brooks, P.E., C.P.E.A.

Environmental Compliance and Monitoring

Date of Report: September 4, 2003 ______________________________________________________________________

Executive Summary An audit for the Environmental Management System (EMS) for biosolids was conducted for the Orange County Sanitation District (FACILITY) vendor on July 29, 2003. The audit was performed as a new contractor application site for FACILITY biosolids and in preparation of NBP’s Third party certification audit to be conducted 2004. The auditor was Rebecca Brooks of the Environmental Compliance and Monitoring (ECM). Areas examined during the audit included EMS policy and procedures and compliance of vendor personnel. Overall, the auditor found five minor Audit Findings, all of which are Policy/Management Practice conformance issues. The minor Audit Findings include:

• Expand and re-label emergency response plans in the {Contractor} Management • Document a procedure to update Standard Operating Procedures (SOPs) and include document

destruction due dates, if appropriate • Document the public outreach program and include as a section in the {Contractor} Management

Plan • Establish a safety training program for field and other personnel who deal with biosolids • Verify that {Contractor} subcontractors provide safety training to their drivers.

To date, the minor Audit Findings have been acknowledged and are currently being addressed by {Contractor}. On the basis of this audit, the auditor believes that {Contractor} is in conformance with the FACILITY EMS for Biosolids Manual.

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Background Purpose of the Audit

The purpose of this audit was to review the land application operations at {Contractor}’ Nevada facility to determine its adherence to regulatory compliance and the minimum requirements for the EMS for biosolids as stated in the FACILITY EMS for Biosolids Manual. The FACILITY EMS for Biosolids Manual is based on requirements of the EMS Guidance Manual prepared by the National Biosolids Partnership (NBP). The audit was performed as a new contractor application site for FACILITY biosolids and in preparation of NBP’s Third party certification audit to be conducted 2004.

Conducting the Audit

The conformance and compliance audit was conducted July 29, 2003. The auditor based the audit questionnaire on compliance and minimum conformance requirements identified by the National Biosolids Partnership and good management practices for biosolids management. The audit was performed and the draft audit questionnaire submitted to Chris Marks of {Contractor} for comments. The Audit Finding forms were then completed by the auditor and submitted to Mr. Marks for response and e-mail signature. After a short review period, the draft audit questionnaire and signed Audit Findings were returned to the auditor and this final report summary was prepared.

Audit Scope

The audit reviewed the land application operations at {Contractor}’ facility to determine its adherence to compliance and the minimum requirements for the EMS for biosolids. The audit lasted approximately three hours.

Scope of the Report

The purpose of this report is to communicate all findings noted throughout the course of the audit and to provide the status of the corrective results for nonconformances identified during the audit performed July 29, 2003.

Findings and Corrective Actions Taken The auditor identified five minor Audit Findings, all of which are Policy/FACILITY Management Practice conformance issues. Minor Audit Findings are seen as not significantly affecting the EMS for biosolids, but requiring corrective action. These minor Audit Findings have been acknowledged and are currently being resolved by {Contractor}.

Audit Findings FINDING 1: Element 11, Section 4.G. of the FACILITY EMS Guidance Manual, requires that

vendors establish and maintain their own Emergency Response Preparedness and Response Plans. {Contractor} maintains emergency plans as part of their

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management plan, but the plans are not labeled as “emergency response.” Because of the importance of identifying emergency responses quickly in a true emergency, FACILITY is requesting that the plans be expanded and relabeled as “emergency response plans.”

ACTION 1: Expand and re-label emergency response plans in the {Contractor} Biosolids

Management Plan. STATUS 1: The expansion and re-labeling of the emergency response plans in the

{Contractor} Management Plan are currently in the process of being updated. FINDING 2: Element 12, Section 5.E. of the FACILITY EMS for Biosolids Manual,

requires that vendors review and update SOPs. {Contractor} lacks a procedure to update SOPs and currently does not address document destruction dates.

ACTION 2: Document a procedure to update SOPs. Include document destruction due

dates, if appropriate. STATUS 2: The document to create a procedure to update SOPs is currently in the

development process. FINDING 3: Element 9, Section 4.C. of the FACILITY EMS for Biosolids Manual, requires

that vendors establish a Community Relations and Communications Plan. Chris Marks of {Contractor} is currently working on an SOP addressing the public outreach program, but there is presently no “tab” in their management plan for public outreach.

ACTION 3: Document the public outreach program and include as a section in the

{Contractor} Management Plan. STATUS 3: The document to create a public outreach program in the Solids Solutions

Management Plan is currently in the process of being developed. FINDING 4: Element 8, Section 5.A.(5) of the FACILITY EMS for Biosolids Manual,

requires that vendors provide safety training for their employees and sub-contractors and maintain training records for these training activities. Field personnel for {Contractor} currently do not receive regular safety training. Chris Marks is presently working on an operations SOP that will include safety training, including documentation of the training.

ACTION 4: Establish a safety training program for field and other personnel who deal with

biosolids. Include training documentation, such as sign-in sheets. STATUS 4: The safety training program for field and other personnel who deal with biosolids

is currently in the process of being developed.

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FINDING 5: Element 8, Section 5.A.(5) of the FACILITY EMS for Biosolids Manual, requires that vendors provide safety training for the safe operation of trucks and equipment used for the management of biosolids. Chris Marks is presently working on an operations SOP that will include safety training for field personnel, but {Contractor} has never verified that the trucking subcontractors are actually providing safety training for their drivers.

ACTION 5: Verify that {Contractor} subcontractors provide safety training to their drivers. STATUS 5: Documentation to verify that {Contractor} subcontractors have been provided

safety training will be obtained as soon as a meeting is set up with the drivers.

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Appendix F: Transaction Testing NBP EMS Workshop #3

Exercise 2: Transaction Testing

TRANSACTION TESTING--EXERCISE

Pick one of the “triggering” changes listed in the shaded areas. Then check off what NBP EMS elements you think might require action based on the change, and describe the actions that need to be taken as a result of the change. TRIGGERING EVENTS Personnel Change The Plant Supervisor who had supported the EMS leaves. A

new Supervisor is hired that has very little EMS background. Contractor Change A new Contractor is hired. Your service agreement specifies

that the Contractor is required to have EMS awareness training, an emergency response program, and public participation program. You have no knowledge of what they are doing.

New Regulation Your County has passed a new law restricting routes of transport and areas in County where biosolids can be applied.

Equipment/Process Change A new drying process and new equipment has been added to produce Class AA biosolids.

Spill/Accidental Release A biosolids spill occurs along a public highway, resulting in a traffic delay of three hours and negative press in the newspaper.

NBP EMS ELEMENT ACTIONS TAKEN/DOCUMENTATION PRODUCED EMS Manual Policy Critical Control Points Legal/Other Requirements Goals and Objectives Public Participation/Planning Roles and Responsibilities Training Communication Operational Controls Emergency Preparedness Documentation/Control Monitoring/Measurement Corrective/Preventive Action Biosolids Management Report EMS Audit Management Review

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Appendix G: Audit Demonstration 1

Auditor: Hi, my name is ___________________. I’m here as part of the ISO 14000 audit. I see you have our agenda. I will be asking you a few questions and will be taking a few notes. Do you have any questions before we start? Auditee: No. Auditor: OK. Why don’t you describe to me what you do in this department. Auditee: This department cleanses and polishes several advanced technology fittings and components. Auditor: OK. What are the environmental aspects that are connected with what you do? Auditee: We need to flush out cleaning solvent through a filter to remove the metal particles after cleaning. Auditor: HMMM, interesting. What’s this? (Auditor grabs a piece of paper off the Auditee’s desk). Auditee: That’s our process checklist. Auditor: What’s the checklist used for? Auditee: We fill out the checklist after we filter and check the filter after each cycle. Auditor: Does everyone complete this checklist? Auditee: No. Auditor: Oh! You say you have a checklist, but not everyone uses it. Why is that? Auditee: Because the checklist is cumbersome and the operators do not like to use it. We use it if we have to. Auditor: Auditor smiles, raises and eyebrow. Smugly writes a deficiency while the auditee watches. Now, obviously, if you’re not using this checklist you must feel competent to do the job without it. What makes you so sure that you’re people are qualified? Auditee: We’re trained to do it. Auditor: So you were trained. Can I take a look at the training records? Auditee: My manager has them, I think. But he’s in a meeting right now.

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Auditor: In a meeting. (Looking at watch) Darn it, that figures. Never around when you need them (writes another note). OK, I saw from an earlier procedure that you calibrate this instrument. Auditee: That’s correct. Auditor: Can you demonstrate for me how you calibrate it? Auditee: I don’t know how yet. I haven’t been trained to do it. Auditor: What?! You’ve been here, what 3 months, and haven’t been trained. That should have been completed day one! (Writes more notes). Well, I thank you very much for you’re time. Can you recommend a restaurant?

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AUDIT DEMONSTRATION 2

Auditor: Hi, my name is ___________________. (Holds out hand to shake but auditee doesn’t move from crossed arm position). I’m here as part of the ISO 14000 audit. I hope you received our agenda. Auditee: Yeah, I got it! Auditor: OK. I’m going to be asking a few questions and taking some notes. Auditee: What’s with this ISO stuff anyway? What good is all of this doing? Auditor: Well, part of what I’m doing is to verify the effectiveness of your EMS. An effective EMS should lead to improved environmental performance. Now, I see that you’re company offers EMS awareness training. Have you had the chance to attend one of these? Auditee: No. Auditor: I see. Scheduling problems? Auditee: No. I just didn’t think it was important enough. Auditor: Well, I hope you’ll try and attend one of those classes sometime soon. Anyway, I’ll just ask a couple of questions and move on. Please tell me briefly what you do in this department. Auditee: We make sure the right materials are delivered to the floor at the right time. If we get the materials wrong then our supervisor blows a fuse and there’s a chance something bad could happen to the environment. Auditor: How does what you do potentially impact the environment? Auditee: Well, if the wrong materials get into the process it shuts the whole thing down and the raw materials have to get shipped out as a waste. Auditor: I see. Well, that sounds pretty serious. How do you ensure that people do the right thing and avoid this? Auditee: We’re trained on the job, and have to take a competency test. Auditor: OK. Where are the records for this training kept? Do you have a certificate? Auditee: I haven’t a darn clue! Why don’t you check with human resources? Auditor: That’s a good suggestion. Well, I appreciate your explaining to me how things work in the department. Thanks again for your time.

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Appendix H: Audit Checklist

Reference Requirement: Look For/Evidence: Auditor Notes:

Madison Element 5 Procedure, Goals and Objectives

Page 2, says goals and strategies are supposed to be finalized by February 15th of each year

Ask the EMS Coordinator for goals/strategies from last year. Check date (finalized by February 15). Ask how goals/strategies have been used to set existing goals and objectives.

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EXAMPLE AUDIT SCHEDULE Scope of Work The scope of work is includes:

Overall review of Biosolids EMS Manual; Desktop audit prior to visit; In-depth auditing of Facility and selected Contractor evaluating conformance with EMS

documentation (Elements 1 and 12), roles/responsibility and competency (Elements 7 and 8), goals and objectives progress, management review process, communications program, corrective and preventive action process and resolution of last year’s non-conformances.

Schedule March 29th, 10:00-Noon.

Review of records and documents with EMS Coordinator, Inspector. March 29th, 1:00-4:00.

Audit of two treatment plants. March 30th, 8:30-Noon.

Completion of treatment plant audits. March 30th, Noon to 3:00.

Audit of Contractor operations. March 31st, 8:00-Noon.

Contingency and wrap-up of outstanding audit issues.

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NBP ENVIRONMENTAL MANAGEMENT SYSTEM

AUDIT REPORT

Prepared For:

Prepared By:

Douglas Dean, P.E., CHMM

March 31st, 2007

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Table of Contents Audit Summary 1 EMS Findings -- Attachment 1: Positive Practices -- Attachment 2: Observations -- Attachment 3: Auditor Checklist --

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AUDIT SUMMARY

Areas Within Facility EMS Visited: Auditor: Douglas Dean, P.E., CIH Dates:

ELEMENT NUMBER AND DESCRIPTION

AUDIT RESULTS

No. of Majors / No. of Minors

A, N, or X*

POLICY 1 EMS Manual 0/0 2 Biosolids Management Policy 0/0 PLANNING 3 Critical Control Points 0/0 4 Legal and Other Requirements 0/0 5 Goals and Objectives 0/0 6 Public Participation in Planning 0/0 IMPLEMENTATION/OPERATION 7 Roles and Responsibilities 0/0 8 Training 0/0 9 Communication 0/0 10 Operational Controls of Critical Points 0/0 11 Emergency Preparedness and Response 0/0 12 Documentation/Document Control/Records 0/0 MEASUREMENT/CORRECTIVE ACTION 13 Monitoring and Measurement 0/6 14 Corrective & Preventive Action 0/0 15 Biosolids Management Program Report 0/0 16 EMS Audit 0/0

MANAGEMENT REVIEW

17 Management Review 0/0

TOTAL Legend: A = Acceptable: Interviews and objective evidence indicates that the EMS meets all the requirements of that section of the standard. N = Not Acceptable: The auditor has made the judgment that, based on the number and type of nonconformances, the requirements of that the section of the standard are not being met. X = Not Audited

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EMS AUDIT FINDINGS FORM

Type of Finding (circle one): Nonconformance: Major Minor Positive Practice Observation Description (include where in the organization it was found): NBP EMS Reference:

Date:

Finding Number:

Auditor: Douglas Dean

Auditee’s Representative:

Corrective Action Plan (including time frames):

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ELEMENT 1: EMS MANUAL STANDARD REQUIREMENTS CONFORMS (Y/N)

The EMS Elements describe an organization’s requirements for establishing and maintaining a comprehensive environmental management system (EMS) for biosolids that covers its biosolids management activities at all critical control points throughout the biosolids value chain. The EMS system for biosolids (including the other 16 EMS elements) shall be documented in an EMS Manual or equivalent set of program documents that describe, at least at a general level, the applicable policies, programs, plans, procedures and management practices in the EMS. The EMS Manual shall: 1. Be approved at a level of the organization’s management with the authority

to commit people and resources to biosolids management activities.

2. Contain the organization’s biosolids management policy and EMS

procedures required by the EMS Elements.

3. Contain or cross-reference public participation in planning, communication, and emergency preparedness and response programs and plans required by the EMS Elements.

4. Cover all critical control points for its biosolids management activities throughout the biosolids value chain.

5. Include or cross-reference all operational controls, procedures, processes, and other management methods used to achieve and maintain compliance with legal and other requirements.

6. Describe those biosolids management activities assigned to and performed by contractors.

OVERALL CONFORMANCE: YES NO

Notes:

ELEMENT 2: BIOSOLIDS MANAGEMENT POLICY STANDARD REQUIREMENTS CONFORMS (Y/N)

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1. The organization shall establish a biosolids management policy (biosolids policy) that commits the organization to following the principles of conduct set forth in the National Biosolids Partnership’s Code of Good Practice and may include other biosolids commitments the organization chooses to adopt.

2. The organization’s biosolids management policy shall be communicated to employees, contractors, and all interested parties and be incorporated into the organization’s biosolids programs, procedures, and practices.

OVERALL CONFORMANCE: YES NO

Notes:

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ELEMENT 3: CRITICAL CONTROL POINTS STANDARD REQUIREMENTS CONFORMS (Y/N)

1. The organization shall identify and document the critical control points of its biosolids management activities throughout the biosolids value chain. The organization shall also identify potential or actual environmental impacts at each critical control point.

2. The organizations’ s critical control points shall be consistent with those identified in the NBP’s Manual of Good Practice and other authoritative sources on biosolids management.

3. The information on the organization’s critical control points shall be kept up-to-date and the records shall link each critical control point and its potential environmental impacts with the corresponding operational control(s).

4. Organizations that have successfully completed a third-party verification audit shall provide notification to the NBP (and third-party verification auditor) after any operational change that requires a change to the identified critical control points or to environmental impacts associated with critical control points.

OVERALL CONFORMANCE: YES NO

Notes:

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ELEMENT 4: LEGAL AND OTHER REQUIREMENTS STANDARD REQUIREMENTS CONFORMS (Y/N)

1. The organization shall establish a procedure for identifying and tracking legal (federal, state and local) and other requirements applicable to its biosolids management activities. The procedure shall include a management process for incorporating changes and new requirements into the elements of its EMS.

2. The organization shall establish and maintain records of applicable legal and other requirements.

OVERALL CONFORMANCE: YES NO

Notes:

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Appendix I: Summary of Evaluations

National Biosolids Partnership Biosolids Environmental Management System Workshop

November 2007 ~ Workshop #3 PROGRAM Poor Excellent Course content met expectations 1 2 3 4 5 Level of content was appropriate 1 2 3 4 5 Course was relevant to job needs 1 2 3 4 5 Time allocated for coverage of topics 1 2 3 4 5 Effectiveness of audio visuals 1 2 3 4 5 Usefulness of course materials/handouts 1 2 3 4 5 Accomplishment of learning objectives 1 2 3 4 5 PRESENTATIONS Interesting 1 2 3 4 5 Responses to questions 1 2 3 4 5 Emphasis on important topics 1 2 3 4 5 Clarity of presentation 1 2 3 4 5 Enthusiasm and energy 1 2 3 4 5 Knowledge of the subject 1 2 3 4 5 Group discussions 1 2 3 4 5 Breakout Session 1 2 3 4 5 OVERALL RATING OF COURSE Course 1 2 3 4 5 Instructor(s) 1 2 3 4 5 Organization of program 1 2 3 4 5 Facility used/meeting room 1 2 3 4 5 Break functions/lunch functions 1 2 3 4 5 Hotel accommodations 1 2 3 4 5

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GENERAL COMMENTS

___________________________________________________________________________

___________________________________________________________________________

___________________________________________________________________________

___________________________________________________________________________

WRITTEN COMMENTS 1. Describe the most valuable portion of the course. ___________________________________________________________________________

___________________________________________________________________________

___________________________________________________________________________

___________________________________________________________________________

2. Describe the least valuable portion of the course. ___________________________________________________________________________

___________________________________________________________________________

___________________________________________________________________________

___________________________________________________________________________

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University of Florida National Biosolids Partnership EMS Workshop # 3

November 13-14, 2007 in Nashville, Tennessee

PROGRAM Poor Excellent 1 2 3 4 5 Course content met expectations 4.35 Level of content was appropriate 4.41 Course was relevant to job needs 4.44 Time allocated for coverage of topics 4.18 Effectiveness of audio visuals 4.00 Usefulness of course materials/handouts 4.18 Accomplishment of learning objectives 4.47 PRESENTATIONS Interesting 4.00 Responses to questions 4.35 Emphasis on important topics 4.41 Clarity of presentation 4.47 Enthusiasm and energy 4.35 Knowledge of the subject 4.65 Group discussions 4.31 Breakout Session 3.90 OVERALL RATING OF COURSE Course 4.29 Instructor(s) 4.41 Organization of program 4.29 Facility used/meeting room 4.65 Break functions/lunch functions 4.56 Hotel accommodations 4.09

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WRITTEN COMMENTS 1. General Comments

A. Overall valuable information relayed. B. Example at end of sections very helpful; case study – extremely useful-good to hear challenges

& successes. C. Mike Taylor’s presentation was great! Tempo of this session was better than the others. Food

was very good. D. Great participation. E. The room was too cold on Tuesday; Tuesday did not start off following the agenda

time table F. Very good. G. Very informative. Good resource for program checklist.

2. Describe the most valuable portion of the course.

A. The case study was excellent; discussions were good. B. Examples & case studies. C. Being introduced to the EMS program. D. Interaction with others and hearing the experiences. E. Hands-on/ applied info. F. “17 folders and a box” get organized & keep it simple. G. Good instructor – will be able to get greater results from program because of

the interaction. H. The case study. I. Breakdown a complicated process info manageable system. J. How’s & whys of audits. Importance of instructors/audit term. K. Bouncing ideas off each other; comments from certified agencies and current auditors.

3. Describe the least valuable portion of the course.

A. Longer breaks – recommend speeding up workshop, shortening breaks; including more group discussions.

B. Review of previous topics (more than one time is too much) C. All portions were valuable. D. N/A – good info was put out over the entire 2- day session.