environmental management system manual · the ccmua’s ems manual and its associated referenced...

ENVIRONMENTAL MANAGEMENT SYSTEM

MANUAL

CAMDEN COUNTY

MUNICIPAL UTILITIES AUTHORITY

MARCH, 2010

CAMDEN COUNTY UTILITIES AUTHORITY

ENVIRONMENTAL MANAGEMENT SYSTEM MANUAL

TABLE OF CONTENTS

Description

CAMDEN COUNTY MUA BIOSOLIDS POLICY 1 No. of Pages

ELEMENTS 1 EMS MANUAL ............................................................................. 2

ATTACHMENT: October 19, 2009 CCMUA Resolution regarding

NBP Code of Good Practice

2 EMS MANAGEMENT POLICY ..................................................... 2

ATTACHMENT: NBP Code of Good Practice

3 CRITICAL CONTROL POINTS .................................................... 1

TABLE 1 ....................................................................................... 7

TABLE 2 ....................................................................................... 1

4 LEGAL AND OTHER REQUIREMENTS ...................................... 2

5 GOALS AND OBJECTIVES ......................................................... 1

6 PUBLIC PARTICIPATION ............................................................ 2

7 ROLES AND RESPONSIBILITIES ............................................... 2

8 TRAINING .................................................................................... 2

9 COMMUNICATION ...................................................................... 2

10 OPERATIONAL CONTROL OF CRITICAL CONTROL POINTS . 1

11 EMERGENCY PREPAREDNESS ................................................ 2

12 EMS DOCUMENTATION AND DOCUMENT CONTROL ............ 2

13 MONITORING AND MEASUREMENT ........................................ 2

14 NONCONFORMANCES (PREVENTATIVE AND CORRECTIVE) 3

15 ENVIRONMENTAL MANAGEMENT SYSTEM PERFORMANCE

REPORTS .................................................................................... 1

16 INTERNAL EMS AUDIT ............................................................... 2

17 MANAGEMENT REVIEW ............................................................ 2

CAMDEN COUNTY MUA BIOSOLIDS POLICY

Approved by: AK Date approved: 08/26/09 Previous revision dates: N/A The Camden County MUA’s biosolids policy is to: 1) maximize the quantity of dry biosolids captured by its wastewater

treatment plant, thereby optimizing the quality of the effluent discharged to the Delaware River.

2) process biosolids within the treatment plant as rapidly and efficiently as

possible to reduce the corresponding odor potential within the plant. 3) maximize dewatering of biosolids to reduce the quantity of wet tons

required for offsite disposal (currently), or for drying through the sludge dryer that will be completed in 2010. This will reduce off-site hauling costs (currently), and energy costs from the sludge dryer in the future.

4) dispose of biosolids whether dewatered sludge cake (currently), or dried

biosolids when the sludge dryer is completed, in accordance with all rules and regulations.

5) operate at all times in a manner that minimizes the potential for odor

emissions to the surrounding neighborhood.

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ELEMENT 1 – EMS MANUAL

Created/Approved: 3/1/2008 By: AK Date issued: 7/1/2008 Date last reviewed: 3/9/2010 By: AK Date last revised: 3/9/2010 By: AK

The Camden County Municipal Utilities Authority (CCMUA), provides wastewater treatment services to the 37 municipalities of Camden County, NJ. The CCMUA operates an 80 million gallon per day (MGD) wastewater treatment plant called the Delaware No. 1 Water Pollution Control Facilities (WPCF). The Delaware No. 1 WPCF operates under auspices of NJPDES Permit No. NJ0026182. It is a pure oxygen activated sludge wastewater treatment plant. The wastewater treatment process is accomplished by ten primary sedimentation tanks, eight aeration tanks and eight final sedimentation tanks. Treated effluent is then disinfected with sodium hypochlorite and then discharged to the Delaware River.

General

Primary sludge is removed from the primary sedimentation tanks and secondary sludge is removed from the secondary sedimentation tanks. Secondary sludge is then thickened through three gravity belt thickeners. Then the thickened secondary sludge is blended with the primary sludge and fed into the plant’s seven belt filter presses for dewatering.

The dewatered sludge is stored in the sludge storage building for hauling off-site. Some of this sludge is hauled by the CCMUA’s own truckers to neighboring municipal entities for incineration. The rest of the sludge is hauled by private contractors to approved landfills and/or land distribution sites.

However, the CCMUA is in the process of constructing an indirect sludge drying facility. The sludge drying facility is expected to be completed by January 2011. When it is completed, all of the dewatered sludge (currently about 160 wet tons per day) will go through a conveyor from the sludge dewatering building to the new sludge drying building. The dewatered sludge will then be dried to a 90-95% dry Class A biosolids product.

The CCMUA plans to retain a contractor to operate and maintain the new sludge drying facility (a Request for Proposals process is underway to procure this contractor). The contractor’s responsibilities will include distribution of the Class A dried biosolids byproduct to legally allowable endpoints.

The CCMUA is committed to three main goals:

1) optimize water quality 2) optimize odor control performance 3) cost minimization

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The CCMUA believes that an Environmental Management System is a valuable tool to harness and direct its existing wherewithal to optimize its water quality, odor control and cost minimization performance. Accordingly, the CCMUA implemented an Environmental Management System in 2006. In addition, in 2006, the CCMUA signed a memorandum of agreement with the National Biosolids Partnership to develop and implement a biosolids EMS.

This EMS manual describes the CCMUA’s Environmental Management System for its plant operations including biosolids. The EMS manual and associated EMS elements and activity have been developed using the general framework that was developed by the National Biosolids Partnership. All of the CCMUA’s biosolids requirements, from a regulatory, operational and procedural perspective, are included in the CCMUA’s EMS Manual and its associated referenced documents.

Procedures

1) The EMS manual will be a living document. As the CCMUA makes changes to its operations or procedures, the EMS manual will be updated correspondingly.

2) Revisions to the EMS manual will be made by the EMS Implementation Team. 3) The EMS Coordinator will advise the Executive Director and CCMUA Board of

Commissioners of significant revisions to the EMS manual. Revised manuals will be transmitted to all pertinent employees.

4) The EMS Coordinator will provide notification of significant revisions to other

interested parties through one or more of the communication tools listed in Element 9 of this EMS manual.

fl i6,tun

Tte*sLutisnsf

THE CAUEIEN CC'UNTY TTJNICIPAL IJTILITIES AL'THGIFIITYAFFIRJTII}{G THE CAMDEN COUI{TY MUA'S COMMITMENT TO FOLLOWING THE

NATIONAL BIOSOLIDS PARTI{ERSHIP'S @DE OF GOOD PRACTICES FORBrosouDs (SLUDGE) TREATMENT AND DTSPOSAL

#R-09:10- lZ6

WHEREAS, the Camden County MUA has committed to the United StatesEnvi ron menhl Protection Agency, New Jercey Depaffnent of Envi ronmenta I Protection a ndthe National Biosolids Partnership to implement and sustain an Environmenbl ManagementSystem (EMS) for its wastewater freatment plant operations; and

WHEREAS, as paft of the EMS certiftcation process, the Authority must formallyaffirm 'rts ongoing commitmentto follow the National Biosolids Partnership's Code of GoodPractices for Biosolids Treatment and Disposal.

NOW, THEREFORE BE IT RESOLVED by the CCMUA Board of Commissioners thatit formally affirms the Authority's ongoing commitment to continue to follow the NationalBiosolids Paftnership's Code of Good Pnctices for Biosolids Treatment and Disposal.

ADOPTED: October 19, 2009

I hereby certiff that the above is a true copy of the resolution adopted by themembers of the C-amden County Municipal Utilities Authority at a meeting held on October19,2009.

A. Troxell

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ELEMENT 2 – EMS MANAGEMENT POLICY


General

In 2002, the CCMUA Board of Commissioners adopted the following Environmental Management System management policy. The policy establishes the Guiding principles for the CCMUA’s wastewater treatment and biosolids management programs.

EMS MANAGEMENT POLICY

The CCMUA will do its utmost to: 1) optimize the quality of its effluent 2) minimize adverse impact from odors emanating from the wastewater treatment and sludge disposal processes. 3) minimize cost impacts to ratepayers. The CCMUA will achieve these objectives by: 1) maintaining its wastewater treatment and biosolids processing facilities properly in order to keep facilities available for operation.

2) following the Code of Good Practice for biosolids developed by the National Biosolids Partnership (see attached).

3) maintaining an industrial pretreatment program in accordance with state

and federal regulations. 4) participating in source reduction programs such as the PCB Trackdown

Program. 5) operating the plant in a manner which will optimize the water quality of the

effluent. 6) operating the plant in a manner which will minimize the potential for odors

from the wastewater treatment and sludge thickening, dewatering and drying processes.

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7) periodically circulate all administrative, operations and maintenance procedures and practices for potential for improvement.

8) implementing and maintaining a comprehensive record keeping and

reporting system that tracks water quality, odor minimization and cost minimization efforts.

9) implementing and maintaining a comprehensive environmental program

that exceeds regulatory requirements to the maximal extent practicable. 10) providing regular training opportunities to personnel associated with the

wastewater treatment and biosolids management program.

1) The EMS Coordinator is responsible for ensuring that the EMS

Procedures

management policy is communicated to employees, contractors and other interested parties, using one or more of the communication tool’s listed in Element 9.

2) Methods used to accomplish Step 1 include, but are not limited to the Following: a) Providing a copy of the EMS Management Policy to the EMS Implementation Team and plant supervisors. b) Providing a copy of the EMS Management Policy to the CCMUA Board of Commissioners, Executive Director and employees. c) Posting a copy of the EMS Management Policy on the CCMUA’s website.

3) If revisions to the current policy statement are deemed necessary by the EMS Implementation Team, the EMS Coordinator will bring the revisions to the Executive Director, and then Board of Commissioners for approval.

4) Once approved, the EMS Coordinator will communicate the revised policy

as per Step 1 above. The EMS Coordinator will also place the revised policy in the EMS Manual.

CCooddee ooff GGoooodd PPrraaccttiiccee The Code of Good Practice ("the Code") is a broad framework of goals and commitments to guide the production, management, transportation, storage, and use or disposal of biosolids -- in short, a comprehensive environmental management system (EMS) for biosolids. Those who embrace the Code and participate in the EMS commit to "do the right thing." Code subscribers and EMS participants pledge to uphold the following principles of conduct: CCOOMMPPLLIIAANNCCEE:: To commit to compliance with all applicable federal, state, and local requirements regarding production at the wastewater treatment facility, and management, transportation, storage, and use or disposal of biosolids away from the facility. PPRROODDUUCCTT:: To provide biosolids that meet the applicable standards for their intended use or disposal. EENNVVIIRROONNMMEENNTTAALL MMAANNAAGGEEMMEENNTT SSYYSSTTEEMM:: To develop an environmental management system for biosolids that includes a method of independent third-party verification to ensure effective ongoing biosolids operations. QQUUAALLIITTYY MMOONNIITTOORRIINNGG:: To enhance the monitoring of biosolids production and management practices. QQUUAALLIITTYY PPRRAACCTTIICCEESS:: To require good housekeeping practices for biosolids production, processing, transport, and storage, and during final use or disposal operations.

CCOONNTTIINNGGEENNCCYY AANNDD EEMMEERRGGEENNCCYY RREESSPPOONNSSEE PPLLAANNSS:: To develop response plans for unanticipated events such as inclement weather, spills, and equipment malfunctions. SSUUSSTTAAIINNAABBLLEE MMAANNAAGGEEMMEENNTT PPRRAACCTTIICCEESS AANNDD OOPPEERRAATTIIOONNSS:: To enhance the environment by committing to sustainable, environmentally acceptable biosolids management practices and operations through an environmental management system. PPRREEVVEENNTTIIVVEE MMAAIINNTTEENNAANNCCEE:: To prepare and implement a plan for preventive maintenance for equipment used to manage biosolids and wastewater solids. CCOONNTTIINNUUAALL IIMMPPRROOVVEEMMEENNTT:: To seek continual improvement in all aspects of biosolids management. CCOOMMMMUUNNIICCAATTIIOONN:: To provide methods of effective communication with gatekeepers, stakeholders, and interested citizens regarding the key elements of each environmental management system, including information relative to system performance.

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ELEMENT 3 – CRITICAL CONTROL POINTS


General

Critical control points are defined as:

“locations, unit processes, events and activities throughout the value chain under the organization’s control or influence that require effective policies, programs , procedures, practices, monitoring, and measurements to ensure the activities meet legal, quality and public acceptance requirements and do not have undesirable environmental impacts. Critical control points include all management activities that are covered under applicable legal and other requirements.”

The critical control points were selected based on CCMUA’s three main goals of optimizing water quality and odor control performance and cost minimization. These goals encompass all aspects of the CCMUA wastewater treatment plant and therefore the control points reflect all activities that can impact the quality of the CCMUA’s water quality, odor control performance and cost. Table 1 identifies the value chain, critical control points, operational controls (Element 10), SOPs/process documents, Monitoring and Measurements (Element 13) and the environmental impacts that could result from inadequate control of these points. The CCMUA management team was involved in the review and acceptance of the critical control points, operational controls and the SOPs and process documents associated with them. Table 2 identifies staff that is responsible for the general management of the critical control points.

Procedures for Review and Update:

1. The Authority’s EMS review team will review the information in Table 1 on an annual basis, and when regulatory and operational changes occur. The annual review will occur by April 30th

2. Changes will be notated and documented by the EMS Coordinator, as needed.

of each year.

3. Other Elements will be revised accordingly to reflect the changes identified in Step 2.

ELEMENT 3: CRITICAL CONTROL POINTSTABLE 1

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Value ChainCritical Control Points

Operational Controls SOPs/ Process Documentation Monitoring and Measuring Environmental Impacts

Wastewater Collection and Pretreatment

Pumping Stations and pipeline

Operational check and maintenance

▪ SOPs Interceptor Department (Road Crew)

Work orders through Maximo System.

Improper and/or inadequate operation and maintenance of the interceptor system could result in pipe corrosion, sewer overflows and manhole overflows, infiltration and inflow problems.

▪ SOPs - Operation of the Camden City Gate Weekly Pump Station Report

During wet weather improper operation of the collection system could cause flooding of public streets, health and safety issues, and pollution of receiving streams.

▪ SOPs Corrosion Reduction Pumping Station Monthly Safety Checklist

▪ SOPs I/I removal ProgramReport form to Camden Water regarding Flow Variations

▪ SOPs Inspection of Regional Sewer System

CCMUA 32nd St. CSO Inspection

▪ SOPs Sewer Overflows / Manhole overflows

CCTV of regional sewer system to check for corrosion

▪ SOPs Baldwin's Run CSO Chamber

Improper cleaning and maintenance of the netting systems could result in a hydraulic backup leading to flooding in upstream portions of the Camden City sewer collection system.

▪ Annual R&R Report

▪ Wet Weather Operation Plan

Sewer Use Ordinance

▪ SOPs - Identification of New Industrial Dischargers

▪ SIU Permits

Industrial User self sampling and self monitoring reports. CCMUA industrial sampling program.

Commercial user discharges

▪ SOPs - Emergency Call Procedures to Industrial Pretreatment

PCB Minimization ProgramSampling at the most significant sources of PCBs.

Non-Point Discharger

PCB transformer survey for all industries in Camden County.

Improper identification and control of PCB sources may contaminate CCMUA's sludge or discharge of PCBs to the Delaware River.

Septage HaulersSeptage Hauler Permits Application/permit

▪ SOPs - Screening Septage Haulers

CCMUA monitoring of Septage Haulers; data results summarized on spread sheet and PACS

Waste Hauler Rules

Improper notification to Industrial Pretreatment Section regarding emergency calls involving discharge of excessive or abnormal industrial discharges may cause upset to the plant or pass through to the receiving stream.

Industrial - Significant Industrial User discharges

Annual Inspection of the interceptor system and treatment plant for renewal and replacement report to identify any required improvements for the year.

Any septage that does not meet the CCMUA requirements could potentially pass through or interfere with the plant processes. Proper certification, inspection and sampling is required to prevent plant upset and/or pollutant discharge to the river.

Inadequate control of Industrial/commercial discharges could result in plant upset, pollutant pass through to river and sludge; odor problems; health and safety issues.


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Wastewater Treatment and Solids Generation

Preliminary Treatment

Solids Screening / Grit Collection

Operational checks and maintenance ▪ SOPs - Barscreen Operation

Laboratory Data from Influent Sampling for NJPDES requirements.

Improper preliminary treatment could lead to damage of downstream equipment which could lead to plant upset or pollution discharge to the receiving stream.

▪ SOPs - Raw Sewage Pumping

▪ SOPs - PTF Channel Aeration System Sampling for Process control.

Grit Collection

Operational checks and maintenance

▪ SOPs - Grit Collection Operation Relevant computer screens

Scum Concentration

Operational checks and maintenance -

▪ SOPs - Scum Collection System Operation (adjusting scum removal) DMR reporting requirements

Primary Treatment


▪ SOPs - Primary Sludge Pumping

reports for settable solids, suspended solids and BOD testing.

▪ SOPs - Primary Sedimentation Tank Operation (Sludge Blanket & Density Pump)

Hydraulic Loading▪ SOPs - Primary Tank Optimization and Calculations

Visual observation of tanks and equipment.

Sludge Blanket and Density

Sludge pumping

Equipment maintenance

Scum Blanket

Improper primary treatment including inadequate removal of settleable and floatable solids could overload secondary treatment causing upset or interference or pass through and reduce water quality. It could also impact sludge handling processes; increase the cost of treatment and disposal; and, cause odor prolems at the plant and surrounding communities.


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Wastewater Treatment and Solids Generation

Secondary Treatment - Aeration Tanks


▪ SOPs - Aeration Tank Operation

Visual observation of tanks and equipment.

Hydraulic and Organic Loading

Daily process monitoring and control

Flow - manually operated Return sludge distribution; DO levels Relevant computer screens

Secondary Treatment - Oxygen Generation


▪ SOPs - Oxygen Generation Process

Visual observation of tanks and equipment

Hydraulic Loading▪ SOPs - Final Sedimentation Tank Operation Relevant computer screens

Improper levels of dissolved oxygen in the aeration tanks will impact biomass and treatment and effluent quality. Potential for odors can occur as well.

Sludge Blankets ▪ SOPs - Return RatesDaily process monitoring and control

Scum Blankets

Pump Flows (Return Sludge)

Disinfection


▪ SOPs - Disinfection System Operation

Chlorine residual and chlorine demand.

Disinfectant dosage

▪ SOPs - Failure of Chlorination System, Plant Effluent Relevant computer screens

ORP System ▪ SOPs - ORP System Operation NJPDES permit sampling

Disinfecting Chemical Inventory

Visual observation of tanks and equipment

Secondary Treatment - Sedimentation Tanks

Improper operation of disinfectant process could lead to inadequate reduction in coliform bacteria which could lead to permit violations and poor effluent quality and an adverse impact on the receiving stream.

Inadequate control of aeration and mixing can impact the biomass inventory of the system leading to an impact on sludge production and effluent quality. Improper treatment increases cost. It could also impact sludge handling processes; increase the cost of treatment and disposal; and, cause odor prolems at the plant and surrounding communities.


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Odor ControlOdor Control Systems:


Community notification system - 24 hr. telephone reporting

Air permit monitoring and reporting

Improper operation of odor control systems could cause odor problems affecting the health and safety of the treatment plant workers and surrounding communities.

▪ SOPs - Odor Scrubber Reading Requirements

Daily report for Odor Control Systems

▪ SOP Environmental Hotline Relevant computer screens

▪ SOPs - Weekend and Holiday Operations (to reduce Odor)

Visual observation of tanks, equipment and instrumentation

Carbon SystemsEquipment Maintenance

▪ SOPs - Scum Concentration Carbon Odor Control System Operation 7 Air Permits

Pump flows Chemical inventory

Stack emissions

BiofilterEquipment maintenance

▪ SOPs - Junction Chamber Biofilter Odor Control System Operation

Stack emissions

▪ SOPs - Manhole Carbon Filter for Dewatering Building Filtrate Line

ChemicalChemical Inventory SOPs - PTF Odor Scrubbers

Pump flows

▪ SOPs - Calvert Odor Scrubbers for Sludge Storage Tanks and Dewatering Building

Equipment maintenance

▪ SOPs - ERA Odor Scrubber for Thickening and Dewatering Building

Stack emissions

▪ SOPs - Quad Chemtact Odor Scrubbers for Sludge Storage Bldg


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Solids HandlingGravity belt thickening

Sludge Flow and Ratio

▪ SOPs - Gravity Belt Thickening System Operation Operational data reports

Inadequate operation and treatment of solids can result in increased biosolids volume that need to be transported and managed and increased potential for odors effecting the health and safety of treatment plant works and the community. Also, inadequate operation and treatment can increase cost of chemical usage.

Polymer DosageVisual observation of tanks, equipment and instrumentation

Percent Solids - influent and Relevant computer screensEquipment Maintenance

Monitoring of sludge flows and levels

Dewatering Sludge Flow and Ratio ▪ SOPs - BFP Loadings Polymer inventory

Polymer Dosage

Percent Solids ▪ SOPs - BFP OperationEquipment Maintenance ▪ Checklist for Operators

▪ SOPs - Mass Balance, Wasting Rates; Optimization of Primary and Secondary Ratio; Maintaining Appropriate Sludge Levels


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Sludge Storage and Transportation

Sludge Storage Tanks

Sludge level/mixture ratio

Visual observation of equipment, trucks and instrumentation.

Inadequate storage and transportation capacity may result in unnecessary spills or releases of sludge.

Solids Storage Building

Sludge Building Recirculation Pumps

Sludge hauling and disposal reports.

Solids Transportation

Truck maintenance

▪ SOPs - Vehicle Maintenance Requirement Relevant computer screens

Improper route selection may result in road damage, traffic, noise and safety issues. Potential odors may be a problem.

Truck coverTransportation route Truck cleaning facilities

Truck Loading▪ SOPs - Trailer Loading - Dewatering Truck Station.

Truck Unloading▪ SOPs - Rules for Unloading Tank Trucks

Any regulatory / permit requirements that identify specific locations/activities that need to be managed

PLANTWIDE SamplingImproper sampling may lead to laboratory errors and/or permit violations.

SOP - Lab Morning Sample Collection

SOP - pH Sampling Procedure

SOP - Monthly Maintenance Schedule for Plant Samplers

NJDEP Report of Exceedance Form

▪ SOPs - Effluent Monitoring (north and south side)

Event Log and State Reporting Log

▪ SOPs - Effluent Monitoring Toxicity Sampling; Temperature Monitoring; pH Monitoring


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PLANTWIDE Security `▪ SOPs - Revised Security Procedures

▪ SOPs - Emergency Situations

▪ SOPs - Security Incident Report

▪ SOPs - Weeknight and Weekend Security Procedures

▪ SOPs - Security Procedures - Security Level Red

▪ SOPs - Security Procedures - Security Level Orange Emergency Response Plan

Chemical Storage▪ SOPs - Daily Chemical Storage Tank/System Inspection Hazardous Spill Report

Improper storage of chemicals could risk a release to the environment and discharge to the receiving stream.

▪ DPCC Plan (Distribution List)

Lab▪ SOPs - Review of Lab Results for Process Control

Daily O&M meeting includes review of lab results

Process

Operating Budget Review of Cost Control Measures

Inadequate security procedures can risk damage to the treatment plant and could send untreated sewage to the receiving stream and or toxic chemicals to the environment.

ELEMENT 3: CRITICAL CONTROL POINTSTABLE 2: Roles and Responsibilities Matrix

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Workgroup: EMS Program Manager, Chief Engineer, Director O&M , Assistant Director of O&M, Chief Operator, Regulatory Compliance Officer, Sludge Distribution Coordinator Collection

Pre-treatment

Wastewater Treatment

Solids Handling

Odor Control

Sludge Storage and

Transporation Plantwide

EMS Progam Manager X X X X X X X

Chief Engineer X X X X X X X

Director O&M L L L L L L L

Assistant Director O&M X X X X X X

Chief Operator X X X X X X

Regulatory Compliance Officer X X X X X X X

Sludge Distribution Coordinator X X

L = LeaderX = Staff

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ELEMENT 4 – LEGAL AND OTHER REQUIREMENTS

Created/Approved: 3/1/2008 By: AK Date issued: 7/1/2008 Date last reviewed: 3/9/2010 By: AK Date last revised: 3/9/2010 By: AK General

It is extremely important to identify existing legal, and other requirements, that impact the various aspects of the CCMUA’s wastewater treatment and biosolids handling processes. In addition, it is essential to keep track of new regulatory, legal and legislative initiatives that could impact the CCMUA’s operations. Accordingly, this element of the EMS (1) identifies all current rules and regulations, (2) describes the CCMUA’s process for track, all new regulatory, legal and legislative initiatives and (3) describes the CCMUA’s process for modifying its EMS to reflect regulatory legal and legislative changes that have actually been enacted. Procedures

The CCMUA will use the following procedure to identify, track and assess the impact of regulatory, legal and legislative initiatives that may impact our wastewater treatment and biosolids handling.

• 1) The CCMUA’s Solicitor and Chief of Regulatory Compliance will continually check for new regulatory, legal or legislative initiatives that could impact the plant process. The Authority maintains an annual subscription to the Bureau of National Affairs online internet based regulation library. The subscription allows online access to regulations for all Federal Environmental Regulation and all New Jersey Environmental Regulations. In addition to the online access we also maintain subscription to (instant, daily, weekly and quarterly…where appropriate) notification of pending, proposed and recently approved environmental regulation. These notifications are sent as appropriate to the Regulatory Compliance Officer. This officer reviews the regulations for relevance and forwards to effected departments or management teams where appropriate.

• • In addition to Bureau of National Affairs online subscription the Regulatory

Compliance Officer maintains notifications from NJDEP Advisory Alerts, New Jersey Water Environment Association, as well as regular communication with NJDEP case management staff to stay current on changing regulatory requirements

• • 2) If any such initiatives are found, they will be transmitted to the EMS

Coordinator.

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• • 3) The EMS Coordinator will call a meeting of the EMS

Implementation Team to discuss the applicability and potential impact on the plant process.

• • 4) If necessary, the EMS Coordinator will modify the EMS manual and

send copies of the change to the EMS Implementation Team, the CCMUA Executive Director and Board of Commissioners. Depending on the magnitude of the change, it may also be sent to all CCMUA employees and other interested parties urging one or more of the communication methods described in Element 9.

• Table 4-1 Governing Environmental Statutes and Regulations

New Jersey Water Pollution Control Act

NJSA 58:10A-1.1, et. seq. with implementing regulations NJAC 7:14A-1.1, et. seq.

New Jersey Solid Waste Management Act

NJSA 13:1E-1, et. seq.

New Jersey Air Pollution Control Act

NJSA 26:2C-1, et. Seq with implementing regulations, NJAC 7:27-1, et. Seq thru NJAC 7:27B-1 et.seq.

Federal Pretreatment Regulations

40 CFR 403


NJSA 58:10A

New Jersey Pollution Discharge Elimination System

NJAC 7:14A-19


NJAC 7:14-8

New Jersey Sludge Quality Assurance Regulations

NJAC 7:14C

New Jersey Discharge Prevention DPCC

NJAC 7:1E

New Jersey Storm Water Management

NJAC 7:8

New Jersey Safe Drinking Water –Potable Wells

NJAC 7:10

New Jersey Wastewater Treatment Operator

NJAC 7:10A

New Jersey Governing of Certified Laboratories

NJAC 7:18

New Jersey Air Pollution NJAC 7:27 Federal Sludge Quality Assurance Regulations

40 CFR 503

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Element 5 – Goals and Objectives

Created/Approved: 3/1/2008 By: AK Date issued: 7/1/2008 Date last reviewed: 3/9/2010 By: AK Date last revised: 3/9/2010 By: AK The Camden County MUA has the following goals and objectives for its wastewater treatment plant:

1) Optimize the quality of its effluent.

2) Comply with all existing local, state and federal regulations, at a minimum, and seek to exceed environmental performance to the maximal extent possible.

3) Help to promote best environmental practices at the CCMUA, and in the wastewater industry as a whole in any way possible.

4) Minimize adverse impact from odors emanating from the wastewater treatment and sludge disposal process.

5) Be a good neighbor to the surrounding community with a view to not only “do no harm,” with respect to odor impacts, but also undertake initiatives to improve the quality of life for our neighbors.

6) Minimize cost impacts to ratepayers, without sacrificing environmental performance.

7) Maintain wastewater treatment and biosolids process facilities properly in order to ensure sustainable operations.

8) Replace capital on an as-needed basis in order to optimize performance, minimize O&M cost and ensure sustainability.

9) Ensure full cost pricing in order to achieve long term sustainability.

10) Follow the Code of Good Practice for biosolids developed by the National Biosolids Partnership.

11) Capture institutional knowledge through memorializing standard operating procedures (SOP’s), and continually updating SOP’s as circumstances change.

12) Provide proper training for all employees and encourage them to continually improve and realize their professional self-actualization goals.

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ELEMENT 6 – PUBLIC PARTICIPATION

Created/Approved: 4/5/2008 By: AK Date issued: 7/1/2008 Date last reviewed: 3/9/2010 By: AK Date last revised: 3/9/2010 By: AK The CCMUA has a multipronged approach to encouraging public participation and public input, including the following:

1) The CCMUA maintains a website which provides information regarding the CCMUA’s industrial pretreatment program, environmental performance, bid openings and other ongoing information.

2) The CCMUA also issues a newsletter updating all employees, and other interested stakeholders, on progress made on construction projects, regulatory performance, etc.

3) The CCMUA also has an open public meeting every month during which all of its business, contract transactions etc., are discussed and acted upon.

4) The CCMUA also conducts special public hearings every time it adopts a new budget, changes its connection fee rates or changes it user fee rate schedule. It also conducts a public hearing to present all major construction projects to the public.

5) The CCMUA’s Deputy Executive Director also is very closely involved with the neighborhood community groups. Specifically, he serves on the Waterfront South Science Advisory Board, a group that provides free scientific advice to the community regarding environmental concerns that they may have. He also serves on the Community Advisory Panel for the neighborhood. The CCMUA’s participation in these community groups gives the neighborhood direct access to discuss the CCMUA’s progress with its odor minimization goals.

6) The CCMUA also maintains an internal email correspondence system for its employees, through which pertinent information about the Authority’s activities are transmitted.

7) The CCMUA also works cooperatively with the media should they contact us for information regarding the Authority’s activities.

8) The CCMUA provides plant tours to a wide variety of schools, community groups and other interested parties. The CCMUA also sends

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representatives to schools to make environmental presentations to science classes, on Earth Day, etc.

9) Interested parties include ratepayers, neighbors, community groups, regulatory agencies, (USEPA, NJDEP, DRBC), recipients of our final biosolids products, environmental groups, fellow wastewater utilities.

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Element 7 – Roles and Responsibilities


The EMS Manual assigns roles and responsibilities to the critical members of the EMS Project Team, as follows: 1) EMS Program Manager – The EMS Program Manager is responsible to push for continual improvement toward the CCMUA’s main goals of optimizing water quality, odor control performance and minimizing costs. These duties include:

• scheduling regular meetings with the EMS Committee team.

• followup on all cost saving or environmental improvement Initiatives

• initiate regular “brainstorming” sessions to identify new

opportunities to improve performance and/or reduce costs.

• continually track the CCMUA’s progress toward its top EMS priorities and continually seek opportunities toward continual improvement.

• report EMS progress to the CCMUA Board of Commissioners,

the EMS Implementation Team, and all CCMUA employees.

• take the necessary steps to obtain the approvals from the CCMUA Board of Commissioners required to implement EMS improvement projects.

2) Chief Engineer – The Chief Engineer is responsible for the CCMUA’s capital improvement program and its renewal and replacement program. Thus, the Chief Engineer is responsible to make sure that the CCMUA has the best possible capital for its operations. The Chief Engineer is also responsible to obtain regulatory approvals for all new capital, and to procure financing for new capital projects. 3) Director of Operations and Maintenance – The Director of Operations and Maintenance is responsible for the operation and maintenance of the wastewater treatment. The Director of O&M is also responsible for the laboratory, industrial pretreatment and regulatory compliance programs. The O&M Director is responsible to implement best practices that optimize environmental performance and reduce costs. The O&M Director is also responsible to advise the EMS Program Manager and the Chief Engineer when underperforming capital is identified and needs to be replaced.

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4) Chief Operator – The Chief Operator is the licensed operator for the wastewater treatment plant and has the direct responsibility to ensure that the treatment plant is in compliance with all regulations, and to ensure that the plant is operating optimally. 5) Regulatory Compliance Officer – The Regulatory Compliance Officer is responsible to make sure that the CCMUA is in compliance with all federal, state and local regulations. In addition, the Regulatory Compliance Officer is responsible to keep track of new regulatory requirements and be sure that all members of the EMS Team are aware of upcoming changes to regulations. 6) Sludge Distribution Coordinator – Responsible for accounting for all sludge generated by the wastewater treatment plant on a daily basis and distributed to various disposal outlets under contract with the CCMUA. 7) Current EMS Project Team names and titles: Andrew Kricun, PE, EMS Program Manager and Chief Engineer Robert Cornforth, Director of Operations and Maintenance Jack Connolly, Assistant Director of Operations and Maintenance Steve Lee, Chief Operator Tom Mount, Assistant Chief Operator Gayle Pagano, Regulatory Compliance Officer Jeff Wilson, Sludge Distribution Coordinator

Oleg Zonis and Janet Miles, CCMUA Wastewater Treatment Plant Consultants (serve on the committee to assist with various issues and opportunities to enhance performance)

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ELEMENT 8 – TRAINING Created/Approved: 4/5/2008 By: AK Date issued: 7/1/2008 Date last reviewed: 3/9/2010 By: AK Date last revised: 3/9/2010 By: AK General A training program has been established to maintain and ensure that CCMUA employees are responsible for all activities that affect CCMUA’s three main goals of optimizing water quality, optimizing odor control performance and cost minimization at the Delaware No. 1 Water Pollution Control Plant. Additionally a training program has been established to assist employees in implementing various EMS functions. All training will ensure that employees implementing these functions are competent in performing these assigned tasks and duties. The training will include providing employees with the general awareness of how their roles and responsibilities affect the entire CCMUA’s goals and value chain. The program will train new and reassigned employees. CCMUA will maintain records of individual employee training delivered and completed. When applicable, contractors will be required through its service agreement with the CCMUA to provide training consistent with the role and responsibilities required by CCMUA. CCMUA has established structured training programs including:

• Wastewater Operators Training • Safety, Emergency Response Training, Confined Space Entry • New Employees: Right-to-know training for new employees and Critical

Rules and Safety Rules Orientation. Handouts include: New Jersey Right to Know Pamphlet; Confined Space Entry Awareness and Operations ) and Control of Hazardous Energy AKA “Lockout/tagout”.

• Specific training – New equipment, new processes or upgrades to equipment or processes. The manufacturer of the equipment or process conducts the training at the plant.

• Maintenance Repair and Electrical Certification

Training also occurs through less formal or classroom training settings such as:

• Daily Plant Operations Meetings • On the job training

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• Attendance at professional association conferences and specialty seminars (NJWEA, WEF)

Procedures

1. Structured training programs are offered on a scheduled basis:

COURSE SCHEDULE First Aid - C.P.R. with A.E.D. Training

Annually with refresher course every two years thereafter.

Confined Space Entry Training Along with a Confined Space Rescue Drill.

Annually

Lockout – Tagout Training

Annually

HAZ-MAT Operation Level Training for Operation and Maintenance Personnel

Annually

HAZ-MAT Technician Level Training for Supervisors and selected Operation and Maintenance Personnel

Annually

Right to Know refresher training Every 2 years Defensive Driving Every 3 years

2. Formal training for each employee is filed and tracked. For the

wastewater operators’ licenses, the Assistant Chief Operator maintains the database on all the licensed operators and tracks their training requirements to keep licenses current. For all the annual training, a calendar is maintained and a paper record is kept to document all training completed to date.

3. For EMS training, the EMS Coordinator will be responsible for:

a. Setting up at least one formal presentation annually on the EMS. b. Notifying contractors of their requirements for EMS implementation. c. Providing new CCMUA employees on EMS training.

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Element 9 – Communication Created/Approved: 4/5/2008 By: AK Date issued: 7/1/2008 Date last reviewed: 3/9/2010 By: AK Date last revised: 3/9/2010 By: AK A)

General

The Camden County MUA is committed to communicating its environmental goals both internally to its employees and externally to its stakeholders – regulatory agencies, municipalities, ratepayers and concerned citizens. B) Internal Communication

1) The EMS team meets on a regular basis to followup on the status of improvement projects and to brainstorm for new opportunities for improvement.

2) A monthly report is issued by the EMS Project Manager to the CCMUA

Board of Commissioners, which describes the plant’s performance, both from the perspective of water quality and odor control, during the previous thirty days. The report also updates the Board on the progress of improvement initiatives.

3) The aforementioned EMS monthly report is also then transmitted to all

members of the EMS Management Team, the Chief Financial Officer, Solicitor and all senior operators.

4) Finally, a more general report/newsletter with an “EMS Update” column is

sent out on a quarterly basis to all CCMUA employees and interested stakeholders.

C)

External Communication

1) Regulatory Agencies – The CCMUA regularly submits all required reports to the USEPA and the NJDEP for water quality performance, air quality performance, sludge quality performance and industrial pretreatment program performance.

In addition, the CCMUA also maintains regular contact with USEPA, NJDEP, the Delaware River Basin Commission and other such agencies to discuss its water quality, odor control, sludge quality performance and industrial pretreatment program performance and its initiatives to improve its performance.

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2) Public Meetings – The CCMUA holds its regular monthly meeting during which all formal business of the Authority is undertaken. This meeting is a public meeting and is advertised in local newspapers and on the CCMUA’s website.

3) Public Communication – In addition, the CCMUA regularly receives letters,

phone calls, e-mails, etc., from the public. The CCMUA is committed to respond to all public inquiries in a professional way, and as quickly as possible, based on the level of complexity and the detail required.

4) Website – The CCMUA also maintains a website that provides information

to citizens and all interested parties, including information about the plant, the results of improvement initiatives, upcoming events, bids and requests for proposals, etc. The website also gives citizens the opportunity to send in questions to the CCMUA.

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ELEMENT 10 – OPERATIONAL CONTROL OF CRITICAL CONTROL POINTS


General

Operational controls include documents, standard operating procedures, work practices, instrumentation/process controls, preventative maintenance, monitoring, inspections, measurements or other activities that ensure that critical control points are being effectively managed and maintained according to legal and other requirements. Element 3 and Element 10 are similar in that Element 3 provides detailed information on the critical control points, related operational controls, monitoring and measurements and the environmental impacts that could result from inadequate control of these points. Operational Controls are listed in Element 3, Table 1.

Procedures

1. The operational controls were identified by the CCMUA’s EMS team’s though internal meetings and discussions based on their in-house knowledge, Operation and Maintenance manuals, current practices and procedures, current industry standards, information contained in WEF Manuals of Practice and similar literature. Current operational procedures and be found in Table 1 of the EMS Manual.

2. Operational controls will be reviewed by CCMUA’s EMS team on an annual basis or whenever changes there are changes in plant processes and/or operational procedures. The EMS Coordinator will make the appropriate revisions to Tables 1 and 2 as well as SOPs and process documentation following the reviews.

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ELEMENT 11 – EMERGENCY PREPAREDNESS


General

It is essential to have a complete and well defined Emergency Prepared and Response Plan for the wastewater treatment plan. This plan will contain procedures that will minimize both the probability of an adverse consequence occurring and also the risk of adverse impact to the public health and the environment.

Procedures

1) The CCMUA has developed an NJDEP-approved Emergency Response Plan for its wastewater treatment plant. This plan is formally reviewed and updated at least every two years. In addition, modifications will be made to the Plan on an as-needed basis as changed circumstances arise. The Operations and Maintenance Director is responsible for coordinating the regular, formal reviews of the Plan, as well as the required updates. 2) The CCMUA also has an NJDEP-approved Discharge Prevention, Containment and Countermeasures Plan related to spills within the plan. This plan is required to be fully revised and resubmitted to NJDEP for approval every five years. The plan is also required to be updated in accordance with implementing any changes relevant to the plant facilities. The Operations and Maintenance Director and the Regulatory Compliance Officer will be responsible for maintaining and updating this plan. 3) The CCMUA also has a wet weather operating plan that defines the way in which the plant will be operated in the case of an extreme wet weather event. This plan is needed because the City of Camden has a combined sewer system which conveys stormwater to the wastewater treatment plant. The Operations and Maintenance Director and Chief Operator are responsible to ensure that the requirements of this Plan are properly followed. 4) The CCMUA is also in the process of developing a vulnerability assessment for the treatment plant, in accordance with homeland security requirements. The Operations and Maintenance Director and the Communications/Security Officer are responsible for developing, implementing, maintaining and updating this plan. 5) Each of the EMS Team members have and have access to copies of each of the four plans described in items 1-4.

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6) Important emergency contact information is provided to all operations and maintenance personnel and to contractors. 7) Safety and emergency training is to be conducted on a regular basis. The CCMUA’s Safety Director and his supervisor, the Chief of Communications, Safety and Security, are responsible for implementing the necessary training. 8) The Safety Director also maintains contact with Camden County and Camden City Emergency Response Teams and Fire Departments in order to ensure the timely availability of these entities should the need arise.

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ELEMENT 12 – EMS DOCUMENTATION AND DOCUMENT CONTROL


The Authority has established and maintains documentation for its biosolids management program, including the seventeen (17) elements of its EMS. Procedures have been established to ensure that the biosolids management program documentation is readily available, has been created following established document creation protocols, is kept up to date through periodic reviews and revision (if applicable), and is properly documented with version information, effective dates and references to replaced or superceded versions. Record retention periods are also established.

General

1) The following documents related to the District’s EMS program or relevant biosolids management activities are considered “controlled” documents:

Procedures

a) EMS Manual b) EMS Policy Statements c) Standard Operating Procedures – Appendix 2) The master document is the controlled document and will be maintained in an electronic format. The master document will contain a header or a footer stating that printed versions are uncontrolled. 3) Standard operating procedures and the EMS manual will contain the following document control information. Created/Approved: By: Date Issued: Dated last reviewed: By: Date last revised: By: 4) Policy statements will contain the following document control information: Approved by: Date approved: Previous revision dates: 5) The EMS manual, standard operating procedures and policy statements will be maintained in the Authority’s document management system.

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6) Version and revision history will be maintained for all controlled documents. 7) Record retention periods will be consistent with those contained in the Authority’s policy which is based on governing federal and state regulations. 8) Data resulting from monitoring and measurement activities is retained by Operations. This information is retained in accordance with No. 7 above, although it may be passed to history files and stored off-line to ensure efficient operation of servers. 9) The EMS Program Manager has sole responsibility for updating/revising the EMS manual to reflect current practices. The EMS Program Manager will notify the EMS team regarding significant changes to the EMS manual through team meetings, letter or email. Minor grammatical edits, links to new or revised documents, etc., are not considered significant changes. Updates/revisions will generally be made in response to one or more of the following: a. Internal audits b. External audits c. Operational changes, either due to capital improvements or changes to SOPs

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ELEMENT 13 – MONITORING AND MEASUREMENT


Monitoring and measurement activities conducted by the Authority generally fall into one of the following three categories:

General

• Activities conducted to demonstrate compliance with legal/regulatory requirements

• Activities conducted to document performance at critical control and operational control points

• Activities conducted to track progress toward achieving EMS program goals and objectives, such as optimizing effluent quality and minimizing odor potential

The Authority’s NJPDES discharge permit identifies monitoring, measurement and reporting requirements specified by NJDEP and EPA. The Authority also conducts additional monitoring to measure performance at critical control points. The Authority uses a computerized data management and reporting system which has been customized to meet the specific needs of the Authority. This system consists of three distinct but inter-related databases: Operations Reporting/Process Control System, Laboratory Information System and Maintenance Tracking System.

Procedure

1. Monitoring and measurement activities will be reviewed by the Authority’s internal EMS team on an annual basis or whenever significant changes

in plant processes and/or operations occur, or should permit conditions change. Revisions to associated SOP’s and monitoring/measurement documents will be made by the EMS Program Manager.

2. Analytical or instrumentation data is stored electronically in relevant databases as follows:

a. Operations reporting/process control system – The Authority

employs a sophisticated computerized control system to collect real time information from instruments and sensors located throughout the treatment plant. The process control system is maintained by the Operations and Maintenance Director and the Assistant Operations and Maintenance Director, with assistance provided by

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Information Systems Staff. Revisions to the system are made by the operations staff and/or Information Systems staff.

b. Laboratory data system – Pertinent information associated with samples analyzed by the Authority’s laboratory is stored in the Laboratory Information System. This includes, but is not limited to: raw data, analyst information and analytical methodologies. The Laboratory data system is maintained by the Regulatory Compliance Officer, with assistance provided by Information Systems Staff.

c. Maintenance Tracking System – The Authority also uses a maintenance tracking system that tracks the status of preventative maintenance work, generates maintenance work orders as needed and tracks the progress of work orders. This system is critical to maintaining critical treatment process units and ensuring their optimal performance and maximizing equipment reliability.

3. Progress towards meeting goals and objectives (Element 5) will be

tracked at intervals deemed appropriate by the EMS Program Manager.

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ELEMENT 14 – NONCONFORMANCES (PREVENTATIVE AND CORRECTIVE)


General

The purpose of this element is to establish, document and maintain procedures for investigating noncompliance with legal/regulatory and other requirements, including conformance issues that may arise from monitoring/measurement activities, EMS protocols, or nonconformances noted as a result of internal or external EMS audits.

Procedures

1) NJPDES Discharge Permit Related Legal/Regulatory Nonconformances Legal/Regulatory Requirements are either specifically identified in the Authority’s NJPDES Discharge Permit or are incorporated by reference. The following table identifies the general areas and responsible person(s) for investigating nonconformances in these areas.

General Area Responsible Person(s)Pretreatment Regulatory Compliance Officer

Operations – Wastewater Operations & Maintenance Director Treatment Asst. Operations & Maintenance Director Biosolids Treatment & Operations & Maintenance Director Distribution Asst. Operations & Maintenance Director and

Sludge Distribution Coordinator 2) EMS Nonconformances Identified During Internal Audits

i. Internal audits will be conducted in accordance with procedures developed under Element 16.

ii. An audit worksheet will be completed for each element audited.

The worksheet will contain the following information: a. Element # b. Audit type (e.g. internal or external audit) c. Auditor’s name d. Period being audited f. Summary of findings g. Nonconformances (if any) and cause

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h. Corrective actions already taken (if any) i. Recommended additional corrective actions (if any) j. Person(s) responsible for implementing corrective (action(s)

k. Changes in policies, programs, plans, operational controls and monitoring/measurements needed to prevent reoccurrence (if any) l. Estimated completion date m. Required resources n. Method of tracking progress

iii. The auditor will complete (a) through (f) above, as well as all

specific questions contained in the worksheets. The NBP Third Party Auditor’s Guidance document will be available as a resource to the audit team.

iv. Completed worksheets will then be submitted to the EMS Program

Manager. The EMS Manager will complete (g) through (n) on the worksheet. This may be done by completing the appropriate sections directly on the worksheet or addressing them through a separate written report.

v. The EMS Manager is responsible for tracking progress. Progress

will be tracked using methods that the EMS Manager deems appropriate. For minor nonconformances, progress will be tracked every two weeks. For major nonconformances, progress will be checked every 4 weeks. Tracking will be documented by completing the tracking sheet which is included as part of the audit worksheet.

vi. The EMS Manager will prepare and submit a written report to the

internal EMS team and the Authority’s Executive Director and Board of Commissioners by April 30th of each year, summarizing the internal audit results and corrective actions (if necessary) that have already been taken or will be taken to address any nonconformances. The audit report may be a stand alone document or may be included as part of other prepared reports (e.g. the Biosolids Management Performance Report). The audit report will be available electronically on the Authority’s website

.

3) EMS Nonconformances Identified During 3rd

Party Audits

i. 3rd

party audits will be conducted in accordance with the procedures identified by the National Biosolids Partnership.

ii. Audit reports will be submitted to the Authority’s EMS Program Manager.

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iii. If the auditor identifies nonconformances, the Authority’s EMS

Program Manager will follow the steps listed under 2(ii-vi). iv. Minor nonconformances will be corrected with a 30 day period and

major nonconformances will be corrected within a 90 day period, unless the auditor and the Authority agree that these timeframes need to be extended.

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Element 15 – Environmental Management System Performance Reports

Created/Approved: 5/7/2008 By: AK Date issued: 7/1/2008 Date last reviewed: 3/9/2010 By: AK Date last revised: 3/9/2010 By: AK 1) The EMS Program Manager will prepare monthly reports to the CCMUA Board of Commissioners describing:

– the treatment plant’s water quality performance during the previous month

– the treatment plant’s odor control performance during the previous month

– the status of all environmental improvement and cost saving initiatives being implemented through the EMS program

2) The EMS Program Manager will also prepare a written paper on an annual basis that summarizes the performance of the Authority with respect to its Environmental Management System goals and objectives (Element 5). This performance report will be completed by April 30th of each year and will be available on the CCMUA’s website.

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ELEMENT 16 – INTERNAL EMS AUDIT


The Authority will conduct periodic internal audits of the EMS program in order to maintain the elements of the system and to make sure necessary changes and updates are included.

General

1) The Authority will conduct internal audits of the EMS program on an annual basis, except in those years when a formal 3

Procedures

rd

2) Internal audits will be completed by March 31 of each year and will address program activities completed during the previous calendar year.

party audit is conducted.

3) The audit will be conducted by the Authority’s internal personnel under the direction of the EMS Program Manager. The audit will evaluate performance relative to all 17 elements of the Program Manager’s EMS program and will include any applicable contractor activities. EMS outcomes will be evaluated.

4) Each member of the Authority’s internal EMS team will be responsible for auditing selected elements of the EMS. Audit responsibilities will be assigned by the Authority’s EMS Program Manager.

5) No individual will be assigned audit responsibilities for an area that they manage as part of their day to day activities.

6) Each internal auditor will be given a sheet listing the minimum conformance requirements for the elements that they are auditing.

7) All documents and records related to internal audits will be maintained in the Authority’s internal document management system.

8) The NBP Third Party Auditor’s guidance document and other appropriate documents will be made available as a resource to the audit team. Auditors will utilize one or more of the objective methods listed in the Third Party Auditor’s Guidance document to evaluate conformance. The objective methods listed in the Auditor’s Guidance are as follows:

a) Document and records review b) Interviews c) Direct observation

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9) Auditors will complete an audit worksheet

that is specific to each element. The worksheets request basic information and also identify he minimum conformance requirements for each element based on information contained in the National Biosolids Partnerships Third Party Auditors guidance document. Specific information contained in the worksheets include:

a) Element being audited b) Audit type (e.g. internal or external audit) c) Auditor’s name d) Period being audited e) Audit date(s) f) Summary of findings g) Nonconformances (if any) and cause h) Corrective actions already taken (if any) i) Recommended additional corrective actions (if any) j) Person(s) responsible for implementing corrective action(s) k) Changes in policies, programs, plans, operational controls and monitoring/measurements needed to prevent reoccurrence (if any) l) Estimated completion date m) Required resources n) Method of tracking progress 10) The auditors will complete (a) through (e) above as well as all specific questions contained in the worksheets. Completed worksheets will then be submitted to the EMS Coordinator. 11) The EMS Program Manager will complete (f) through (n). This may be done by completing the appropriate sections directly on the worksheet or addressing them through a separate written report.

12) Nonconformance will be addressed using the procedure identified in Element 14. 13) The EMS Program Manager will prepare and submit a written report to the internal EMS team and the Authority’s Executive Director and Board of Commissioners by April 30th of each year, summarizing the internal audit results and corrective actions (if necessary) that have already been taken or will be taken to address any nonconformances. The audit report may be a stand alone document or may be included as part of other prepared reports (e.g. the Biosolids Management Performance Report). The audit report will be available electronically on the Authority’s website

.

14) The EMS Program Manager will periodically evaluate the need to provide training or guidance to the internal auditors. The EMS Program Manager will be responsible for coordinating any subsequent activities related to training or guidance.

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ELEMENT 17 – MANAGEMENT REVIEW


General

The Authority will conduct a management review of its EMS program on an annual basis. The purpose of this review will be to address the possible need for changes to policy, the goals and objectives, the biosolids management program and other EMS elements based on internal EMS audit results, third party verification audit results, changing regulatory requirements, other changing circumstances, and the Authority’s commitment to continual improvement.

Procedures

1) The EMS team members will review EMS program management activities on an annual basis. This review will be coordinated by the EMS Program Manager. 2) The review will be conducted by April 30th

of each year and will cover activities conducted during the previous year.

3) The scope will include:

a. Review monitoring data and other measurements that demonstrate the performance of the Authority’s program relative to established goals, objectives and legal requirements.

b. Review progress towards achieving goals and objectives. c. Review internal audit results. d. Review of performance relative to each of the 17 elements of the EMS. e. Review 3rd

f. Review the need for changes in existing policy or the adoption of new policy to support the EMS and related activities.

party audit results.

4) To facilitate management review, the EMS Program Manager will prepare

a written report that addresses each of the above areas. The report will include recommendations (if any) for changes that should be considered by the EMS Team. 5) The report and management review will be carried out in close coordination with the Environmental Management Program Performance Report (Element 15) and the internal EMS audit (Element 16). To the extent practicable, an effort will be made to develop a single report on an annual basis that addresses Element 15, 16 and 17. 6) The EMS Program Manager will schedule a follow-up meeting with the EMS Team to discuss the report.

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7) Any changes to policies, goals/objectives, plans, procedures, work practices and other EMS elements deemed necessary as part of the management review will be documented in writing by the EMS Program Manager. 8) The EMS Program Manager will develop a schedule and action plan to address recommendations from the management review. 9) The report, follow-up recommendations (if any) and associated schedules/action plans will be provided to both the internal and external EMS advisory committees. They will also be made available electronically on the Authority’s website.

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