biosolids ems internal audit report - Encina Wastewater Authority

Encina Wastewater Authority
BIOSOLIDS EMS INTERNAL AUDIT REPORT
Audit Dates: March - May 2012
Audit Conducted by:
Celeste Biles, Industrial Waste Control Inspector
Doug Campbell, Laboratory Manager
Joe Cipollini, Shift Supervisor
Will Harris, Operator
Justin Law, Associate Chemist
Kevin Smith, Maintenance Planner
Leeann Warchol, Administrative Services Manager
Audit Report Date: July 20, 2012
Audit Report Prepared by:
Debbie Biggs, EMS Coordinator
Doug Campbell, Laboratory Manager

Encina Wastewater Authority
BIOSOLIDS EMS INTERNAL AUDIT REPORT
Table of Contents
I. EXECUTIVE SUMMARY.….………………………………..………………....3
II. AUDIT SCOPE AND METHODOLOGY………………………………….…..3
III. SUMMARY OF AUDIT FINDINGS……………………………..………..……4
A. EMS Strengths……………………..……………………………….….…...4
B. Findings Needing Correction...…………………………….….….….…...4
C. Opportunities for Improvement…………………..………….…..………...4
IV. AUDIT DETAILS………………………………...…………………….…..........5
A. Wastewater Treatment/Solids Generation/Solids Stabilization…..........5
B. Storage/Transportation………………………………..……….....…..……7
C. Beneficial Reuse…………………………………………………..….…….8
D. Pretreatment………………………………………………….…..……......10
E. Laboratory…………………………………………………...……………..11
F. Information Technology……………………………………..……....…....13
G. Management……………………………….………………….…………...14
H. EMS Awareness………………………………………….…..……………15
V. AUDIT CONCLUSIONS…………………………….…………….……….….16
A. Conformance with EWA’s Biosolids Management Policy…….…....…16
B. Conformance with NBP Code of Good Practice……….……...........…16
C. Achievement of Biosolids Program Goals & Objectives……..…..……19
2

I. EXECUTIVE SUMMARY
The Encina Wastewater Authority (EWA) conducted an internal audit of its
Biosolids Environmental Management System (EMS) between March and May of
2012. The purpose of the audit was to determine if EWA is complying with its
Biosolids Management Policy, the National Biosolids Partnership (NBP) Code of
Good Practice, and program requirements as found in EWA’s EMS Manual. The
audit was conducted in accordance with protocol developed by EWA and
covered the entire biosolids value chain including wastewater treatment, solids
generation and stabilization, biosolids storage and transportation, beneficial
reuse and pretreatment, as well as laboratory operations, information technology
and management.
The audit identified four strengths in EWA’s EMS program, one items needing
correction, and five opportunities for improvement. Corrective action plans have
been developed for the items needing correction. The opportunities for
improvement will be considered during the annual Management Review meeting.
Based on the results of the audit, EWA’s EMS Coordinator finds that the
agency’s Biosolids EMS complies with its Biosolids Management Policy, the NBP
Code of Good Practice and EWA’s program requirements. EWA continues to
make progress in accomplishing its goals and objectives, and is achieving
positive outcomes in the areas of regulatory compliance, environmental
performance, relations with interested parties and quality biosolids practices. As
a result, EWA’s Biosolids EMS is considered to be an effective program.
II.
AUDIT SCOPE AND METHODOLOGY
The internal audit was conducted in accordance with protocol developed by
EWA, which has been deemed a “best practice” by EWA’s third-party auditor.
The audit team consisted of eight staff members selected by EWA’s EMS
Coordinator. These individuals were chosen based on their knowledge of the
organization and/or their ability to gather and analyze objective evidence.
The audit covered the elements of the biosolids value chain, as well as laboratory
operations, information technology and management. Assignments were made
so that no one audited biosolids activities within their workgroup. The following
list identifies the areas audited and assigned auditors.
Area Audited
Wastewater Treatment/Solids Generation/
Solids Stabilization
Storage/Transportation
Beneficial Reuse
Pretreatment
Laboratory
Information Technology
Management
Audit Team Members
Celeste Biles\Justin Law
Celeste Biles\Kevin Smith
Leeann Warchol\Will Harris
Leeann Warchol\Joe Cipollini
Kevin Smith\Will Harris
Justin Law\Joe Cipollini
Doug Campbell
3

The individual audits consisted of interviews with EWA staff members working in
each area and a review of applicable records. Audit questions were developed
by the EMS Coordinator to address EMS awareness, as well as departmentspecific
issues, including areas of concern identified by the Management Review,
third-party audit, or previous internal audits.
In addition to the aforementioned audits, EWA regularly inspects its biosolids
contractors. During the last twelve months, EWA staff visited the CEMEX
cement kiln that utilizes EWA’s biosolids as a biofuel and one Terra Renewal’s
land application sites. The results of these inspections have been incorporated
into the assessment of EWA’s transportation and beneficial reuse processes.
III.
SUMMARY OF AUDIT FINDINGS
The internal audit identified a number of strengths in EWA’s Biosolids EMS
program, one finding needing correction and five opportunities for improvement,
which are summarized below. Corrective action plans have been developed for
the items needing correction. The opportunities for improvement will be
evaluated during the annual Management Review meeting.
A. EMS Strengths
1. Use of multiple employee committees is enhancing EWA’s ability to meet
Biosolid Management Goals and EMS program directives.
2. EWA’s pellet product quality became more consistent due to operational
adjustments in 2011, enhancing marketability.
3. Interagency communication, training and positive relations are helping
EWA fulfill its mission of to protecting the Pacific Ocean and enhancing its
ability for resource recovery.
4. EWA is proactively conducting condition assessments of underground
infrastructure to prevent catastrophic failures.
B. Findings Needing Correction
1. Vendors performing research or studies onsite should go through formal
safety training and facility orientation. Staff contact and emergency contact
information should be shared by both parties to reduce risk. Training
documentation should be maintained.
C. Opportunities for Improvement
1. Sodium hypochlorite and ferric chloride vendors should be added to the
chemical section of the emergency phone list.
2. A semiannual review of the Emergency Phone List should be entered into
MUNIS to help ensure it is up-to-date.
4

3. A Dust Control SOP for the heat dryer building will help ensure continued
implementation of current practices, which help provide a safe work
environment for staff.
4. Development of an internal policy will provide guidance to staff on training
and work assignments.
5. Organization of all of EWA’s SOPs should be evaluated to ensure they are
readily available to appropriate staff.
IV.
AUDIT DETAILS
A. Wastewater Treatment/Solids Generation/Solids Stabilization
This audit was conducted on April 12 and May 7, 2012 by Celeste Biles and
Justin Law. EWA staff members interviewed were: Shift Supervisor Fran
Deleonardis, Operator Jimmy Madrigal, Maintenance Manager John Fetu and
Maintenance Technician Jim English.
Records reviewed include:
Odor complaint reports, (2 in 2011; 5 in 2010)
Training records,
Daily checksheets & Master log,
Heat dryer checksheets,
Raceway Pump Station checksheets,
Chemical spill reports,
Emergency phone list,
Operations department schedule,
Unknown substance reports,
Chemical delivery log,
Biosolids hauling log,
Fuel usage log for engines,
Employee training records,
Flow meter calibration records,
pH meter calibration records,
Thermocouple calibration records,
Dissolved oxygen probe maintenance records,
Cogen gas meter calibration records,
Central vacuum maintenance records,
CMMS scheduled maintenance tasks,
SOP #2 – Odor Complaints,
SOP #18 – Bulk Chemical Handling Procedure,
SOP #19 – Biosolids Guidelines Reuse Compliance
SOP #56 – Raceway Pump Station standard operating procedure, and
SOP #44 – Spill Reporting Procedures.
5

The following operational controls were verified during the audit:
Staff was knowledgeable of the requirements for biosolids to meet both
Class B and Class A standards. A review of heat dryer checksheets
showed that the exit temperature averages >200˚F, well above the
minimum requirement of 176˚F for Class A. Class B requirements were
also maintained with the following information being verified, 95-98 O F
digester temperature, 15 day minimum retention and 38% reduction of
volatile solids.
SOP #2 contains procedures for investigating odor complaints. A review
of the two complaint reports from 2011 showed that they were properly
completed. The investigation procedure includes documentation of
weather conditions. The recent procurement of an onsite weather station
will provide more accurate information about weather impacts.
Additionally, an Air Quality Committee has been formed that meets
quarterly to address odor issues. (See Section III.A.1. EMS Strengths)
SOP #18 contains procedures for dealing with chemical spills. An incident
report is completed for such occurrences and an investigation is
conducted to identify the cause(s) and ways to prevent a recurrence. An
investigation of a 10/7/2011 sodium hypochlorite spill that was caused by
a structural failure of the drain revealed that the containment structure had
some cracks. The structure was repaired and tested, and the tank
replaced.
EWA has an SOP for operation and maintenance of each pump station
that staff has responsibility for. A review of checksheets for the Raceway
Pump Station showed that required activities are being completed.
Our contracts with chemical suppliers state that if they cannot provide a
chemical delivery, they are responsible for paying any cost difference for
us to get it from another supplier. Phone numbers for backup suppliers of
polymer, nitrogen and biodiesel are included on EWA’s emergency phone
list. Alternate suppliers of sodium hypochlorite and ferric chloride should
also be added to the chemical section of the emergency phone list. (See
Section III.C.1. Opportunities for Improvement)
An in-house Heat Dryer Operations Committee meets quarterly to discuss
product quality and heat dryer optimization. As a result of their efforts,
operational changes have been made, resulting in a more consistent
product and enhancing marketability. (See Section III.A.1and 2. EMS
Strengths)
The Operations Department hosted a Heat Dryer Forum in December
2011 to share lessons learned from start-up of new facilities. The meeting
was attended by three agencies that operate a heat dryer or will be
installing one in the future.
As required by the State of California, EWA’s Chief Plant Operator holds a
Grade V operator certification. EWA requires that Shift Supervisors have
at least a Grade III certification. A review of the current schedule showed
that there is always at least a Grade III operator onsite.
The use of digester gas and natural gas is limited by EWA’s air permits.
This information is recorded in the operations daily logbook and
6

transferred to the Flows & Monthly Reports spreadsheet. A review of
sample data showed that information is being properly recorded.
A Dust Mitigation Committee was formed to address safety concerns
related to the heat dryer facility. Staff has developed a regular cleaning
and maintenance schedule including logging of vacuum run hours and
maintaining photographic documentation. Development of a Dust Control
SOP would ensure continued implementation of these procedures. (See
Section III.C.3. Opportunities for Improvement )
Professional Qualification Standards documentation was reviewed for both
operations and maintenance, which demonstrates the comprehensive
training provided to new employees. Currently there are three staff
members from General Services and one from Operations enrolled. No
policy has been developed for new interns. (See Section III.C.4.
Opportunities for Improvement )
A review of records showed that all flow meters used to determine influent
and effluent flow were calibrated in the last year.
Preventative maintenance pit stops have improved the efficiency of the
heat dryer maintenance.
Validated that the UPS circuits in cogeneration were updated during FY
2012 in response to the October 2010 SDG&E power outage and lack of
ability to black start.
During 2011, 5,316 work orders were completed by the General Services
department. Of these, 74% were planned or preventive maintenance
tasks.
B. Storage/Transportation
This audit was conducted on March 29, 2012 by Kevin Smith and Celeste Biles.
Shift Supervisor Joe Cipollini and Operator Nick Lalonde were interviewed.
Records reviewed include:
Recycle bin/storage silo checksheet,
Trailer inspection checksheets,
Biosolids hauling manifests,
Biosolids hauling and trailer return reports,
Driver training records and training on spill reponse,
Employee respirator training and fit test records,
Employee hearing conservation training and audiogram records,
SOP #07 – Contractor Biosolids Hauling,
SOP #20 – Emergency Storage of Digested Sludge,
SOP #32 – Biosolids Spill Response Plan,
SOP #62 – Heat Dryer System Operation,
SOP #64 – Biosolid Loading Procedures.
7

The following operational controls were verified during the audit:
Pellet heating and smoldering events have been reduced by taking a more
proactive approach to mitigating problems before heating occurs. Based
on information obtained from visiting another heat drying facility, EWA
conducted a test where the silos were continuously purged with nitrogen,
which enabled pellets to be stored for seven days.
EWA maintains two backup trailers onsite, which provide for additional
pellet storage. In case of an emergency, an offline digester could also be
used to store digested sludge.
An in-house modification to the centrifuges has extended the life span of
the stators saving money, operational down time and maintenance costs.
Operations staff conducts inspections of contractor’s trailers prior to
leaving the site to ensure they are in good condition, which is documented
on checksheets.
Personal protective equipment (PPE) requirements for biosolids handling
include wearing hearing protection in the dryer building, and a Tyvek suit
and respirator when loading biosolids. A review of records showed that all
O&M staff has completed the required hearing/respirator training.
An automated system was installed by the nitrogen vendor to signal them
when the nitrogen level reaches 50%, which should initiate delivery within
48 hours.
Terra Renewal’s contract requires that all biosolids hauling trucks carry a
copy of their emergency response plan. During the audit, a copy of the
plan was produced by both Apex’s and Terra Renewal’s drivers.
EWA’s contract with Terra Renewal requires them to provide driver
training on emergency response procedures. In 2011 EWA began training
drivers and keeping records in response to Terra Renewal’s lack of follow
through on training efforts.
Non-hazardous material manifests are completed for each load of
biosolids hauled. A review of records showed that completed manifests
matched the weight on the invoice from Apex.
C. Beneficial Reuse
This audit was conducted at the EWPCF on May 3, 2012 by LeeAnn Warchol
and Will Harris, who interviewed EWA Resource Recovery Manager Octavio
Navarrete and Miguel Gutierrez. Also incorporated in this process audit were the
findings of site visits to CEMEX and two of Terra Renewal’s land application
sites.
Records reviewed include:
Heat dryer data sheet,
Biosolids feedback information,
2011 Annual Biosolids Report
Contractor inspection reports,
Ostara Struvite Recovery System proposal,
8

Terra Renewal’s monthly biosolids report,
Lab data for biosolids cake and pellets,
Biosolids hauling manifests,
Fertilizer registration renewal,
Biosolids fertilizer label, and
Terra Renewal insurance information.
The following operational controls were verified during the audit:
Communication with both CEMEX and Terra Renewal remain challenging.
The contracts specify various requirements in regards to billing (CEMEX)
and hauling needs (Terra) that are not always followed. Continued
implementation of EWA’s Biosolid Management Plan may reduce the
need for their services.
Ostara provided EWA with a preliminary design and cost analysis for their
struvite recovery process. The payback on this investment is very long,
thus other options are being investigated.
An inspection of CEMEX was conducted on November 22, 2011.
Housekeeping in the biosolids use area was satisfactory. Air permits and
employee training records were reviewed and found to be in order. There
were no records of public complaints.
EWA staff conducted inspections at one of Terra Renewal’s land
application sites in Arizona (June 28, 2012). Housekeeping practices and
public communication records were found to be acceptable.
Terra Renewal provides reports to EWA for each month in which biosolids
are land applied. These reports include: the amount of biosolids applied
to each field, field maps, lab analysis data and cumulative pollutant
loadings for each field. A review of this information verified that they are in
compliance with allowable agronomic rates.
EWA provides bimonthly biosolids testing results to Terra Renewal
including percent solids, arsenic, cadmium, copper, lead, mercury,
molybdenum, nickel, selenium, zinc, total nitrogen, ammonia nitrogen,
organic nitrogen and nitrate-nitrite nitrogen. A review of results show that
metal levels in EWA’s biosolids are well below the ceiling concentrations
found in Table 1 of 40 CFR Part 503.13, and are considered exceptional
quality.
Prior to being able to use biosolids as a fertilizer, the California
Department of Food & Agriculture requires the material to be registered
with the State. EWA completed this application and was issued a license
on March 23, 2011. The Resource Recovery Manager completed the
registration renewal 1/31/2012.
Terra Renewal’s contract requires them to maintain general liability,
automobile, worker’s compensation, pollution liability and environmental
impairment insurance. A review of documentation showed that current
policies are in effect.
9

D. Pretreatment
This audit was conducted on March 27, 2012 by LeeAnn Warchol and Joe
Cipollini. EWA Industrial Waste Control Inspectors Celeste Biles and Stacey
Spangler were interviewed.
Records reviewed include:
Pretreatment Ordinance,
Review of monthly business license report,
Significant Industrial User (SIU) permit,
EWA Class I, II and III industrial user listing,
Industry records in LINKO database,
Industry self-monitoring report,
Best Management Practices (BMP) industry list,
SOP #1- Wastewater Sampling Procedures for Member Agencies,
SOP #34 – Auto-sampler Maintenance,
Sample chain-of-custody documentation,
Enforcement Response Plan,
Sample enforcement case, and
Industry inspection form and BMP checksheet.
The following operational controls were verified during the audit:
EWA’s Pretreatment Ordinance gives the agency authority to implement
the Pretreatment Program throughout the service area. This was recently
updated on February 22, 2012 and became effective March 14, 2012. The
updated ordinance can be found on EWA’s website. The revised
Pretreatment Ordinance was approved by the Regional Water Quality
Control Board in April 2012. All Significant Industrial User permits have
been reissued to incorporate the revised local limits.
EWA controls industrial discharges through the issuance of wastewater
discharge permits. Permittees may be issued a Class I, II, or III permit
depending on the nature of their discharge. Review of a sample permit
showed that it contains information about the industry’s operations,
sampling and reporting requirements, discharge limits and sampling
location.
To verify compliance, EWA conducts annual inspections of permitted
industries and quarterly wastewater monitoring of Significant Industrial
Users (SIUs – those subject to federal categorical pretreatment standards
or that discharge >25,000 gallons per day). More frequent inspections
and sampling are conducted in response to violations. A review of the
LINKO database confirmed that the minimum inspection and sampling
frequency is being met.
A chain of custody (COC) form is completed for all wastewater samples
collected. Review of a typical COC form showed that it was properly
completed.
10

pH meters are calibrated each day they are used. Review of the
calibration log showed that this is being done as required using standards
with a pH of 4, 7 and 10.
SOP #34 contains maintenance procedures for auto-samplers to help
prevent contamination of wastewater samples. This includes specific
cleaning procedures, semiannual QA/QC testing for seven metals, and
replacement of bottles and tubing as necessary. Review of the
maintenance log showed that these activities are being conducted in
accordance with the SOP. This SOP is numbered differently and not
located with other department SOPs. (See Section III.C.5. Opportunities
for Improvement )
In response to an industry violation, the first step is issuance of a Notice of
Violation (NOV) which requires the industry to: investigate the cause for
the violation; take actions to prevent a recurrence; and submit a letter to
EWA by a specific date describing their findings and resulting actions. A
review of an industry file showed that they submitted their report by the
due date shown in the NOV.
EWA has an Enforcement Response Plan that describes actions that may
be taken in response to noncompliance. Enforcement actions are
escalated if violations continue. This document was last updated on
February 2, 2011 and is available on EWA’s website.
Interagency communication regarding slug discharges has been effective
since EWA conducted Member Agency training on procedures for
reporting and sampling of unknown substances in the collection system. In
response to a report from the City of Vista regarding petroleum odors in
the collection system, an investigation was conducted by EWA staff, which
successfully identified the source. The business was issue a Notice of
Violation and required to clean their clarifier (See Section III.A.3. EMS
Strengths)
Permitted industries must submit semiannual reports to EWA that contain
lab data, a COC form, a Compliance Status Report cover sheet and
certification statements. A sample report was reviewed, which showed
that it contained all the required information. Review of data entered into
the LINKO database was consistent with the industry report.
EWA staff conducts public outreach at street fairs and other public events
to reduce the discharge of pollutants from nonindustrial sources.
Residents are encouraged not to flush unwanted medications, and instead
to either take them to the San Diego County Sheriff’s office or render them
unusable and throw them in the trash.
E. Laboratory
This audit was conducted on April 30, 2012 by Kevin Smith and Will Harris. EWA
staff members interviewed were Chemists Rachael Morgan and Therese
Littlefeather.
Records reviewed include:
Environmental Laboratory Accreditation Program (ELAP) certification,
11

Lab proficiency testing results,
EWA pellet log,
Chain-of-custody documentation,
Biosolids testing data,
Balance calibration records,
Glassware QC records,
Thermometer calibration records,
Bimonthly biosolids report (NANI – Notice and Necessary Information),
and
SOP #57 – Biosolids Sampling.
The following operational controls were verified during the audit:
EWA’s lab is certified by the State of California Department of Health
Services ELAP. The current certificate was issued on 3/1/11 and expires
2/28/13.
As part of the ELAP program, staff must analyze performance evaluation
samples each year to demonstrate proficiency for each test method that
the lab is certified to test for. EWA last participated in this study in June
2011 and passed 100% of the samples tested. Certified methods include
fecal coliform and total solids, which are required to demonstrate biosolids
meet Class A standards.
Lab staff was knowledgeable on the requirements to demonstrate
compliance with Class A biosolids standards including: total solids >90%;
fecal coliform 176˚F. A review of data confirmed EWA’s biosolids meet
Class A standards.
SOP #57 documents procedures for sampling biosolids, as well as the
sampling frequency and type of analysis required. Sampling is conducted
by lab and operations staff. A log is completed for individual pellet
samples that are used to generate a composite sample. Review of the log
showed that the monthly composites are collected within the allowed 14
day period.
Balances must be calibrated annually by a third-party and monthly inhouse
using validated weights. A review of calibration records showed
this activity is being completed as required.
With the exceedences of EWPCF NPDES 6-month median performance
goal in 2008 and 2010 operations has implemented a limit for 3WHP
chlorine level not to exceed 5ppm. Lab staff checks the outfall chlorine
meter once a day (weekdays) and the lab manager checks the data
recorder weekly for outfall chlorine levels. VWD also dechlorinates
Meadowlark WRF failsafe flow. If the failsafe levels are elevated and the
3WHP levels are low the Lab Manager calls VWD staff to check the
dechlorination system.
Staff conducts semiannual calibrations and notes any variation from the
certified thermometer reading. This variation is corrected for in future
reads and noted on thermometer checksheets.
12

Required equipment maintenance is scheduled in the LIMS as
recommended by last year’s internal audit.
When the heat dryer is running, operations collects a daily pellet sample
and provides them to the laboratory staff for a monthly composite. This
composite is tested for heat value (BTU) and % total solids as required by
the CEMEX contract. The Lab Manager then provides the results to the
Resource Recovery Manager for billing purposes.
Oil and grease analysis results received from an outside lab are entered
into the LIMS database. Review of sample data in the LIMS showed that
it was correctly entered.
Monthly flow reports and raw ADS flow data were matched. Laboratory
staff interviewed did not know where the information was, but did know
who to ask.
2011 issues with failed CBOD and BOD analysis have not been solved. DI
tanks are now replaced around every 40 days. In addition, the lab has
increased the number of analyses to avoid reporting deficiencies.
Lab staff posted new NPDES permit requirements next to the daily testing
bench. VWD was e-mailed changes to sampling and testing requirements
in the new permit. The Laboratory Manager also reviewed it with their
Operations Superintendent.
Routine lab results are entered into an Excel spreadsheet on the O: drive
for use by operators. In case of an exceedence, notifications are made in
person after a second verification test has occurred.
F. Information Technology
This audit was conducted on April 11, 2012 by Celeste Biles and Fran
Deleonardis. EWA staff members interviewed were Systems Manager David
Ummel and Systems Technician James Harris.
Records reviewed include:
Biosolids Management Policy,
2011 Annual Biosolids Program Report,
2011 internal audit report,
2010 third-party audit report,
EMS Manual,
LIMS backup records,
MIS Password Procedure, and
EWA’s Site Security Procedure.
The following operational controls were verified during the audit:
EWA recently updated its website and incorporated the former standalone
EMS website. Review of the website showed that it contains the
Biosolids Management Policy, 2011 Annual Biosolids Program Report,
2011 internal audit report, EMS Manual and FY 2012 goals.
13

Laboratory data stored in the LIMS is incrementally backed up every 15
minutes. Full back-ups are done weekly and monthly. Proof of these
activities was confirmed.
EWA’s MIS Password Procedure requires computer users to change their
password at least quarterly. The system starts notifying users 15 days
prior to the due date. After four months, users are locked out of the
system if they do not modify their password.
Thumb drives on the SCADA computers were disabled to protect the
network. This is considered industry best practices to reduce tampering
risk. Access is limited to IT personnel.
EWA’s Site Security Procedure requires that door/gate codes be changed
every six months and/or when an employee leaves EWA. A review of
records showed that all department codes have been changed in the last
year.
The Technology Master Plan update committee has received RFPs from
five vendors. FY 2013 contains capital funds for the Technology Master
Plan update.
The server room is secured by three sets of locked doors that have
different keys. The doors remain locked when no one from IT is on site.
There is no remote access to the servers.
The IT group has developed and begun implementation of a plan to
consolidate its servers. This change will benefit EWA through: reduced
costs for hardware and support; lower energy costs; less heat output;
reduced storage space; and improved disaster recovery time.
The IT group keeps up with security measures by receiving e-mail
newsletters from the Department of Homeland Security. Staff also attends
conferences and is provided vendor sponsored training.
G. Management
This audit was conducted on April 19, 2012 by Doug Campbell. EWA staff
members interviewed were Assistant General Manager Michael Steinlicht,
Director of Environmental Compliance Debbie Biggs, Director of Operations John
Jardin, Director of General Services and Engineering Manager Duane Larson.
The following operational controls were verified during the audit:
EWA obtains public input about its biosolids program through multiple
avenues: questions through the EWA’s website; feedback from outreach
programs; survey results from customers; input from the Board of
Directors who are the public’s representatives; conference participation;
and interaction with peers. EWA has developed a relationship with
CSUSM utilizing graduate students as interns. This input is considered in
the management review process.
In response to two emergency projects during 2010, EWA is proactively
assessing the condition of aging infrastructure. The influent channels were
recently inspected and deemed in need of rehabilitation or replacement,
and thus will be included in the influent junction structure design. The
14

aeration airline was relined, with two other smaller airlines to follow. A
condition of the primary and secondary effluent lines is scheduled for this
fall. The E-CAMP captures other underground piping and structural
evaluations to be performed in the near future. (See Section III.A.4. EMS
Strengths)
When outside organizations propose studies or research using the facility,
the executive team reviews the proposals with the final approval coming
from the General Manager. The executive team considers matters such as
potential effects on plant processes, staff and biosolids quality; however,
no formal safety orientation is conducted or emergency phone lists
provided by EWA. (See Section III.B.1. EMS Findings needing Correction)
Implementation of EWA’s Energy & Emissions Strategic Plan to-date has
accomplished: lining the aeration air piping; evaluating other leaking air
pipes; studying variable frequency drives (VFDs) for the use on the
cogeneration engines; evaluating a waste to energy program; and using
SDG&E’s energy efficiency program to evaluate equipment efficiency.
EWA has completed an organizational risk assessment to identify the top
five to six risks the agency faces. Contingency plans will be developed for
the identified risks and appropriate items incorporated into the Tactical
Plan.
EWA has formed an internal biosolids marketing committee to help ensure
EWA achieves its Biosolids Management Plan goals. Efforts are being
made to increase Tier II marketing efforts, which provide a greater source
of revenue. The committee has developed a product name “Pure Green”
and is working on a marketing strategy. A logo is being finalized, which
can then be trademarked. The Biosolids Management Plan is scheduled
to be updated in 2015. (See Section III.A.1. EMS Strengths)
An Air Quality Committee was formed to address odor issues. This
committee conducts quarterly inspections to identify deficiencies for
correction. In addition twelve SOPs have been modified to incorporate
odor mitigation measures. (See Section III.A.1. EMS Strengths)
H. EMS Awareness
All interviewees were asked the same questions to assess overall EMS
awareness. The following observations were made:
Employees understand that the purpose of the EMS Program is to
establish standard practices that help ensure biosolids quality.
Staff cited numerous benefits to EWA from implementation of the EMS
including: improved documentation, increased awareness about biosolids
and the role of different departments; identification of back-up plans; and
national recognition.
Specific changes that have been made as a result of the EMS include:
adding the EMS to job descriptions; requiring a higher level of
accountability for contractors; implementing additional security measures;
and incorporating the EMS into public outreach activities.
15

V. AUDIT CONCLUSIONS
A. Conformance with EWA’S Biosolids Management Policy
EWA’s biosolids practices conform with its Biosolids Management Policy as
detailed below:
1. Pursue sustainable biosolids reuse options that protect human health and
environmental quality, are fiscally responsible and provide flexibility with
respect to end use. – In December 2008, EWA brought online a new heat
drying facility that produces Class A biosolids pellets and provides more
options for beneficial reuse. Due to the reduction in volume of biosolids
produced, EWA’s budget for biosolids disposal has been reduced from
just over $2 million dollars in FY 2008 to $202,000 in FY 2012. In
addition, over $43,750 in revenue was generated during FY 2012 from
selling the pellets for use as a biofuel and as a soil amendment.
2. Follow the Code of Good Practices for biosolids developed by the National
Biosolids Partnership. – See Section B below.
3. Implement the Encina Wastewater Authority’s Biosolids Management
Plan. – EWA’s Biosolids Management Plan, which was finalized in April
2008, establishes a long-term strategy for marketing EWA’s biosolids.
Plan goals include securing beneficial reuse outlets for 100% of the
material within five years and disposal outlets for 200% of the material
within two years. These goals were met in the first year. EWA currently
has an agreement with CEMEX for utilizing the biosolids as a biofuel. In
addition, 728 tons were utilized as a soil amendment during FY 2012.
Backup plans include a contract with Terra Renewal, which hauls EWA’s
biosolids to Yuma, Arizona for land application or to the Otay Landfill.
B. Conformance with NBP Code of Good Practice
EWA’s biosolids practices conform with the NBP Code of Good Practice as
detailed below:
1. Compliance: 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 – This commitment is contained in EWA’s
Biosolids Management Policy. Implementation was verified through a
review of:
Laboratory data,
SOPs,
Operations’ checksheets, and
Contractor site inspections and records review.
16

2. Product: To provide biosolids that meet the applicable standards for their
intended use or disposal – This was confirmed through a review of:
Laboratory data (metals, total solids, fecal coliform), and
Heat dryer checksheets (dryer outlet temperature).
3. Environmental Management System: To develop an EMS for biosolids
that includes a method of independent third-party verification to ensure
effective on-going biosolids operations. – A reverification audit of EWA’s
EMS was conducted in 2010 by KEMA-Registered Quality, Inc. No major
nonconformances were found. All minor nonconformances identified
were addressed through EWA’s corrective action procedure. The audit
verified that EWA’s biosolids program meets the expectations and
requirements of the NBP.
4. Quality Monitoring: To enhance the monitoring of biosolids production and
management practices – The heat dryer temperature is continuously
monitored by EWA’s SCADA system, which is equipped with alarms to
notify operators if problems occur. Readings are also taken manually and
recorded on checksheets every hour. Metal levels are monitored monthly,
although 40 CFR Part 503 regulations only require bimonthly testing.
Total solids and fecal coliform testing are performed monthly to confirm
compliance with Class A requirements.
5. Quality Practices: To require good housekeeping practices for biosolids
production, processing, transport, and storage, and during final use or
disposal options. – EWA has monthly checksheets for the digester and
dewatering areas that require certain housekeeping activities. A
centralized vacuum system was installed in the heat dryer building to help
control dust. Housekeeping has improved with the formation of the Dust
Mitigation Committee (See Section III.A.4. EMS Strengths). Terra
Renewal’s contract requires that trucks be tarped to prevent the release of
biosolids during transportation and then washed prior to being used again.
Biosolids are transported to CEMEX in enclosed trailers. Routine
inspections of EWA’s land application sites and the CEMEX facility found
general site conditions and housekeeping to be acceptable.
6. Contingency & Emergency Response Plans: To develop response plans
for unanticipated events such as inclement weather, spills, and equipment
malfunctions – EWA has developed SOP #20 for emergency storage of
digested sludge in case of an earthquake, severe weather or other
unplanned event. Terra renewal has a spill response plan that addresses
what drivers should do in case of a spill, and contains notification and spill
clean-up procedures. Training was provided for EWA Member Agency
staff regarding slug response procedures. The annual spill drill was
performed at BVPS and included four of five member agencies. (See
Section III.A.3. EMS Strengths)
17

7. Sustainable Management Practices and Operations: To enhance the
environment by committing to sustainable, environmentally acceptable
biosolids management practices and operations through an EMS – This
commitment is contained in EWA’s Biosolids Management Policy. During
2011 and to-date in 2012, 100% of EWA’s biosolids were beneficially
reused as a biofuel, a soil amendment or for land application on farm
fields in Arizona. In addition, EWA maintained its EMS certification by
completing a reverification audit in September 2010.
8. Preventive Maintenance: To prepare and implement a plan for preventive
maintenance for equipment used to manage biosolids and wastewater
solids – Plant assets used for biosolids processing and treatment are
managed through EWA’s Enterprise Resourse Planning or MUNIS.
Preventive maintenance for each asset is regularly scheduled through the
MUNIS to ensure operational reliability of the biosolids processing system.
In addition, Operations staff has the ability to generate maintenance
service requests when they determine an asset needs additional attention.
Approximately 76% of work orders completed are for planned and
preventive maintenance.
9. Continual Improvement: To seek continual improvement in all aspects of
biosolids management – This is demonstrated via EWA’s tactical planning
process and progress on achieving its biosolids-related goals and
objectives during fiscal year 2012. EWA developed a biosolids marketing
committee that has been working on developing a a product name and
marketing strategy. In addition, one staff member has been focusing fulltime
on marketing efforts, which has produced positive results. During the
first six months of 2012, 18.3% of EWA’s biosolids were used in Tier II
markets. See Section C below.
10. Communications: To provide methods of effective communication with
gatekeepers, stakeholders, and interested citizens regarding the key
elements of each EMS, including information relative to system
performance – EWA maintains a website where it posts internal and
external audit reports, the Annual Biosolids Program Report, EWA’s
Biosolids Management Policy and the EMS manual. Copies of audit
reports and the Annual Biosolids Program Report are emailed to
interested parties, as are notifications of upcoming third-party audits and
the opportunity to provide input. EWA established a Facebook page and
regularly post items of interest to the public. EWA publishes an e-bulletin
entitled RenEWAble News that provides information about ongoing
resource recovery projects, including biosolids reuse. Employees receive
regular email communications containing annual reports, audit results,
information about EWA awards, articles of interest or progress on tactical
goals. Staff distributes packets of biosolids pellets and talks to people
about EWA’s heat drying operations at various locations throughout the
service area, including member agency offices and street fairs.
18

C. Achievement of Biosolids Program Goals & Objectives
EWA is making good progress in achieving its biosolids program goals. In FY
2012 EWA established the following nine objectives related to the biosolids
program:
1. Maintain certification of Biosolids Environmental Management System
(EMS). EWA’s EMS was reverified in September 2010. In 2011, an
internal audit was substituted for a third-party audit to maintain NBP
certification. A third party audit will be conducted in September 2012. -
EWA’s EMS was reverified in September 2010. In 2011, an internal audit
was substituted for a third-party audit to maintain NBP certification. A
third-party audit will once again be conducted in September 2012.
2. Implement Tier II biosolids research and demonstration projects. - EWA
developed a Biosolids Marketing Committee that has been working on
developing a product name and marketing strategy. In addition, one staff
member has been focusing full-time on marketing efforts, which has
produced positive results. During the first six months of 2012, 18.3 % of
EWA’s biosolids were used in Tier II markets.
3. Develop commercial marketing name for Class A biosolid pellets. - The
Biosolids Marketing Committee came up with the name “Pure Green” for
EWA’s biosolids pellets. A logo is being finalized, which can then be
trademarked.
4. Initiate odor minimization effort. - An Air Quality Committee was formed,
which conducts quarterly inspections to identify odor issues. In addition
12 SOPs were modified to incorporate odor mitigation measures.
5. Develop Encina Professional Qualification Standards for maintenance
personnel. - This program was completed in October and three staff are
currently enrolled in the program.
6. Update Pretreatment Ordinance to incorporate revised technically based
local limits that protect biosolids quality. - The revised Pretreatment
Ordinance was approved by the Regional Water Quality Control Board in
April.
7. Amend industrial user permits to incorporate revised local limits. - All
Significant Industrial User permits have been reissued to incorporate the
revised local limits.
8. Develop targeted social media presence. - EWA established a Facebook
page and regularly posts items of interest to the public.
19

9. Hold Biosolids Dryer Operations Forum. - The Operations Department
hosted a Heat Dryer Forum in December 2011 to share lessons learned
from start-up of the new facilities. The meeting was attended by three
agencies that operate a heat dryer or will be installing one in the near
future.
20