3rd Party Audit Results - MSD

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3rd Party Audit Results - MSD

NATIONAL BIOSOLIDS PARTNERSHIPTHIRD INTERIM AUDIT REPORTLouisville and Jefferson CountyMetropolitan Sewer DistrictLouisville Green Management SystemLouisville, KentuckyAudit conducted byNSF-International Strategic RegistrationsWilliam R. Hancuff, Lead AuditorReferences:National Biosolids Partnership (NBP) EMS ElementsNBP Third Party Verification Auditor Guidance – November 2001(Latest Revision August 2007)NBP Code of Good PracticeLouisville Green Management System Manual(Rev 9 – November 23, 2010)Draft Report – June 13, 2011


INTRODUCTIONThe purpose of the Biosolids Environmental Management System (EMS) interimaudits are to verify through regular reviews the system’s health and effectiveness betweenverification audits. The third party on-site interim audits provide independent reviews andsupport credibility between re-verification audits. The goal of the third party interim auditis to collect and evaluate objective evidence related to a portion of the EMS such thatover the course of the four interim audits conducted between verification audits all 17elements are covered. The audits determine whether the Louisville and Jefferson CountyMetropolitan Sewer District Louisville Green Management System (LGMS) isfunctioning as intended, that practices and procedures are conducted as documented, andthat the EMS as implemented conforms to the NBP’s Code of Good Practice and EMSprogram objectives.RECOMMENDATIONThe results of the LGMS interim audit and review of corrective action notices arepositive, and it is the recommendation of the audit team that the Louisville and JeffersonCounty Metropolitan Sewer District biosolids EMS maintain its “Verification” status.AUDIT SCOPEThe NSF- International Strategic Registrations, Ltd. (NSF-ISR) conducted a thirdparty interim audit of the Louisville and Jefferson County Metropolitan Sewer District’sLGMS for Biosolids from June 7, 2011 through June 10, 2011. The on-site interim auditteam consisted of Dr. William R. Hancuff, Lead Auditor.The scope of the third interim audit included a review of areas generally related to theorganization’s progress toward goals and objectives; EMS outcome requirements forenvironmental performance, regulatory compliance, relations with interested parties, andquality biosolids management practices; actions taken to correct minor nonconformances;the management review process; and corrective and preventive action requests andresponses. This review generally included requirements found in elements 1, 2, 5, 6, 9,14, 15, 16 and 17. The specific elements that were audited in their entirety were 1, 4, 7,and 11.The following individuals were interviewed as part of the audit process:Alex NovakSaeed AssefRobert BatesDavid CoeJoseph FalleriRobin BurchJenni SchellingDirector of OperationsDirector Infrastructure and Flood ProtectionProcess ManagerEMS CoordinatorOperations Project SpecialistProcess Support TechnicianMSD Internal Auditor2


Lisa GausDamon TalleyScott PorterZonetta EnglishAllen AdamsJared BishopRichard GalardiRichard WarmanTony GloreDavid RothMcKinley ReedRob RoyJames EmilyRobert BarkerVic DwyerPaul GermanAaron SmithElbert BledshawStephen SarverTravis CrabtreeJoseph DownsKerry GreenwellEric BeanClark FenimoreKen StewartTony BellMichael HomRobert BicknerEmergency Response Pretreatment AdministratorRegulatory EngineerEnvironmental Regulatory AttorneyLaboratory ManagerHealth and Safety AdministratorEmergency Response CoordinatorProcess ManagerMaintenance SupervisorTraining and Performance AdministratorSenior Trainer: OperationsMaintenance ManagerMaintenance PlannerControl System SupervisorProcess Technician IIIProcess Technician IIIProcess Technician IIIProcess Technician IIIProcess Technician IIIProcess Technician IIndustrial Maintenance MechanicMaster Maintenance MechanicMaster Maintenance MechanicMaster Maintenance MechanicA.J. Inc. – president (sales contractor)B&H – Facility Maintenance - contractorB&H – Dispatcher – contractorUS EPA Region IV – Environmental Engineer, BiosolidsData Management System (BDMS)Kentucky Division of Waste ManagementINTERIM AUDIT FINDINGSThe interim audit included review of the latest versions of relevant LGMS manualelement procedures and employed the most recent version of the NBP Third PartyVerification Auditor Guidance dated August 2007. The interim audit found 7 positiveobservations, no major non-conformances, 12 minor non-conformances and 7opportunities for improvement.The NBP Third Party Verification Auditor Guidance indicates that when the auditorhas identified minor nonconformances during the on-site audit, the organization mustresolve the nonconformances and provide documentation to the auditor within 30 days ofthe audit. NBP acknowledges that biosolids organizations may not be able to fully correctsome minor nonconformances within 30 days, in which case NBP requires that theaudited organization develop an action plan with time frames. This plan and schedule forcorrecting minor nonconformances must be approved by the lead auditor. Correctiveaction plans were prepared and submitted to the lead auditor and the approach and time3


frame for implementation were approved. Field verification of the closure of all minorfindings will be finalized during the next scheduled interim audit.The following is a review of the positive observations made during the interim audit.The minor non-conformances and opportunities for improvement follow, and are listedby item number, which correspond to the element minimum conformance requirementsfound in the NBP Third Party Verification Auditor Guidance. These findings arepresented in the sequence of the NBP standard elements.Positive ObservationsThe MSD management and all plant personnel involved in the biosolidsenvironmental management system development should be recognized for theiroutstanding achievements, and the exceptional features of their Louisville GreenManagement System. The following is a summary of those positive observations madeduring the third interim audit.MSD consistently meets its Louisville Green Management Policy by producingExceptional Quality biosolids and promoting beneficial reuse. The final LouisvilleGreen Organic Fertilizer is the highest quality marketable biosolids product everobserved by the auditor, and the aggressive sales program has shown continualimprovement year after year resulting in 99.8% beneficial reuse of material in2010.MSD maintains a strong pretreatment program that works effectively with thebiosolids EMS program to maintain a consistent and reliable Exceptional Qualitybiosolids product.LGMS has set the standard in its use of the SMART criteria in developingobjectives.The EMS has developed and maintains a comprehensive public participationprogram procedure covering a wide variety of methods, which provides manyopportunities to receive input from the public.Working hand in glove with the public participation program the EMS’communication program provides for a multitude of avenues for distributinginformation to the public on biosolids and its value as a natural resource.MSD has set a new benchmark in annual Biosolids Management PerformanceReports by presenting not only its accomplishments in the four outcome areas, butby presenting specific cost savings information directly resulting from optimizingbiosolids value chain operations. This example should be followed by all certifiedagencies.4


The exemplary internal audit program provides detailed and comprehensiveevaluation of conformance with the NBP EMS standard, including compilation ofan internal audit binder for use by auditors.And finally, the hard work and dedication of the Core EMS Team must beacknowledged. Maintaining the EMS verification goal is obviously a team effort, but theguidance and direction provided by the EMS Coordinator, David Coe and the support ofRobert Bates, Joseph Falleri and Robin Burch to ensure continuous improvement must berecognized. Additionally, the support, encouragement and active participation of theDirector of Operations, Alex Novac, in the EMS process has guaranteed the continuedsuccess of the program.Minor NonconformancesRequirement 4.2 – A record of the specific legal requirements and otherrequirements has not been established and maintained; i.e. the detailedidentification of the specific regulation and permits related to each critical controlpoint has not been identified. Additionally, the specific other requirements relatedto each critical control point has not been identified. Requirement 4.3 – The legal and other requirements section of Chapter 4 –Compliance does not provide a description of the process for incorporating legalchanges and new requirements into the elements of the EMS, such as operationalcontrols procedure and monitoring and measurement procedure.Requirement 5.7 – Detailed action plans which describe improvement activities toachieve program goals and objectives have not been adequately developed foreach of the current objectives.Requirement 9.2 – Within the Public Participation and Communication procedureof Chapter 5 it states that if possible all inquiries will be responded to within 24hours of receipt of the inquiry. More complex inquiries or requests may requireadditional response time. Within the same procedure it indicates that a record ofpublic input and inquiries is maintained by the EMS coordinator in Appendix 9A– Record of Public Input and Inquiries. There is no record documenting theresponse time for any inquiries making it impossible to verify the response time tothe inquiries.Requirement 9.4 – The environmental management system procedures do notspecifically define each contractor’s roles and responsibilities in thecommunication program. Requirement 10.1 – Compliance with MSD’s internal specification for product %dry solids is not clearly being met. The specification is not clear with regard to thesales agent contract, the dryer SOP, the truck loading and weighing SOP, and in5


the Louisville Green Tracking Spreadsheet. The sales agent and EMS coordinatorwere aware of these issues; however, the issues had not been addressed properly.Requirement 10.1 – Not all standard operating procedures or work managementpractices have been fully developed for each critical control point operation.Requirement 10.2 – The procedure addressing the process of preparingoperational controls at each critical control point does not specify that all legaland other requirements will be incorporated into the operational controls.Requirement 11.1 – The emergency preparedness and response procedure doesnot address the approach currently used to contain and clean-up commonincidents of biosolids value chain spills and releases associated with sewage,solids and biosolids.Requirement 14.4 – The Scope section of the Nonconformance and CorrectiveAction procedure contained in Chapter 5 indicates that the corrective actionprocess is used for nonconformances discovered through day-to-day monitoringand measurement activities. This scope has not yet been completely implementedrelative to operational failures at critical control points within the biosolids valuechain. Requirement 16.1 – The internal audits procedure contained in Chapter 5 –Improvement and Communication does not accurately reflect the currentmethodology used to prepare for and conduct internal audits. Additionally, thereferenced Appendix 16A – Internal Audit Findings Worksheet is no longer used.Requirement 16.1 – The internal audit procedure does not currently address all ofthe requirements that must be met when the internal audit is used to fulfill therequirements of an interim audit. These requirements are described in Section 5.2of the NBP Third Party Auditor Guidance – August 2007.Opportunities for ImprovementRequirement 3 – Review the Legal Requirements and Other Requirementscolumn in the Appendix 3A table to ensure that correct requirements areidentified for the operational controls associated with each critical control point.Also, consider adding “public acceptance requirements” at an appropriate locationin the appendix 3A table.Requirement 5.1 – Consider establishing more challenging objectives to attaincontinual improvement.Requirement 5.6 – Consider removing objectives that have been satisfactorilyaccomplished from the active list.6


Requirement 7.1 – Consider clarifying in the roles and responsibilities procedurewithin the “Process Supervisors – Operations” description that there are two sidesof operations; the wet side and the dry side.Requirement 8.1 – Consider including in the Training procedure that refreshertraining on the LGMS is provided at least annually.Requirement 12 – Consider creating a more detailed Manual Revision Log thatwill contain more specific information regarding details on how each procedure inthe manual has been revised in each revision.Requirement 16.3 – Consider defining the qualifications of the auditor(s)conducting the internal audits within the internal audit procedure.For the minor non-conformances, MSD personnel prepared Corrective Action Plans,and will implement corrective actions according to their EMS procedures to providecontinual improvements to their biosolids program. All proposed corrective action workplans were reviewed by the auditor and found to be acceptable and final closure will beverified during the next external third party audit. As a further measure to demonstratecontinuous improvement the opportunities for improvement will be addressed to themaximum extent possible.Metropolitan Sewer District CommentsThis audit varied in style and procedure from previous audits performed at MetropolitanSewer District (MSD). Previous audits were very process oriented, taking into accountNBP EMS elements, while this audit focused more so on conformance to individualrequirements stipulated in the elements. The combination of the two approaches has beenbeneficial: ensuring the facility can fulfill both its process requirements and its adherenceto the NBP elements. This audit met all expectations and the auditor was thorough andfair. – Robert BatesI found the audit to be very beneficial. In a word, it was value added. It challenged meto look deeper into the standard than I previously had. I thought we had the standardcovered very well; however, the lead auditor pointed out some things from the standardthat had been over looked and will be of value to us from an operations perspective. Ialso have given some serious thought to the way we conduct management system trainingand plan to do this differently in the future. – David CoeOUTCOMES MATTER7


The Louisville Green Management System of the Louisville and Jefferson CountyMetropolitan Sewer District attained an enviable goal of distributing 99.8 percent of itsbiosolids product for beneficial reuse. They are unique in that they annually report onsome of their financial savings resulting from their EMS. In 2010 they reported on twomajor areas of cost savings, namely:$663,500 landfill cost avoidance$750,000 Natural gas savingsThe LGMS established four individual goals using the title of each outcome area as agoal. Therefore, using the present approach MSD will always be four goals, specificallyidentified to address each of the following:1. Environmental Performance,2. Regulatory Compliance,3. Relations with Interested Parties, and4. Quality Biosolids Management Practices.Several objectives are established within each goal. The objectives were developed bythe EMS coordinator and the EMS Core Team considering public input.While it is not a requirement to fully attain all objectives established, it is a criticalcomponent of the system to make progress towards accomplishing the overall goals. Theobjectives within each goal were established using Specific, Measurable, Achievable,Relevant, and Time Bound (SMART) criteria.The Policy of the LGMS is simply summarized as “MSD will produce ExceptionalQuality (EQ) biosolids and promote beneficial reuse.” The final Louisville Green OrganicFertilizer has consistently attained an Exceptional Quality and generated a highlymarketable biosolids product. As a result of the aggressive marketing campaign and salesprogram the beneficial reuse of material in 2010 was 99.8%.The facility’s performance relative to each of the above listed outcome groups isaddressed below.In the Environmental Performance outcome area and goal, LGMS established sixobjectives for 2010:1) 100 percent of the product distributed each month will meet EPA EQ standardsfor metals. The entire product distributed in 2010 met this objective, and thetarget was carried over as an objective for 2011. To date in 2011 this objectivecontinues to be attained.8


2) 65 percent of product produced each month will meet MSD’s qualityspecifications. Over 65 percent of product produced each month (except forJanuary 2010) though calendar year 2010 exceeded MSD’s qualityspecification. In January 55.9 percent of the product met the specification. Thebalance of the months substantially exceeded the objective, so that by the endof the year 76.7 percent exceeded the requirement. The target was carried overin 2011 and increased slightly to 68 percent. To date in 2011 the lowest onspecproduction level has been 78.1 percent.3) 75 percent of dryer heat demand each month will be provided by digester gas.Although the monthly dryer heat demand supplied by digester gas was notreviewed the total dryer demand supplied by digester gas for 2010 was 86percent, with 14 percent being supplied by natural gas. As a side note, 72percent of all the digester gas produced was used in the dryer trains, while 28percent was burned in a flare. The identical target was carried over as anobjective in 2011. Through April of this year, the digester gas had beenproviding an average of 93 percent of the dryer heat requirements.4) On an annual basis reduce the solids disposed at a landfill and wastemanagement dependency to less than 8 percent of material produced. The totalamount of solids disposed at a landfill through October 2011 was 0.24 percentof the material produced. The identical target was carried over as an objectivein 2011. There had been no solids required to be disposed in a landfill as of thedate of the interim audit.5) In 2010 develop an unusual discharge protocol to identify the top five industrialdischargers to the MSD system. This objective was not accomplished due toproblems with the data management system. Therefore this objective wascarried forward as a goal for 2011.6) In 2010 perform an investigation to quantify greenhouse gases at thewastewater treatment facilities. This objective was not accomplished but wascarried forward for completion in 2011.In the Regulatory Compliance outcome area and goal, LGMS established fourobjectives for 2010:1) Meet regulatory standards (monthly and daily where applicable) for wastewater,biosolids and air throughout 2010. MSD met all regulatory requirements forbiosolids and air pollution control. There was however a wastewater dischargepermit violation. The identical target was carried over as an objective in 2011.2) Conduct 6 random land application site inspections per year. Nine end userinspections were conducted in 2010. The identical target was carried over as anobjective in 2011. As of the date of the interim audit 4 end user inspections hadbeen conducted.9


3) Perform an average of 4 random inspections of Louisville Green contractorhauling per month. This objective was met from May through December 2010,and was carried over as an objective in 2011 but increased to 5 randominspections per month and continued to be met through May 2011.4) Limit significant nonconformance level of Significant Industrial Users (SIUs) toless than 8 percent per year. The track record of percent significantnoncompliance shows 3.5 percent in 2009 and 4.7 percent in 2010. The identicaltarget was carried over as an objective in 2011. No data was reviewed todetermine the current status of this objective in 2011.In the Relations with Interested Parties outcome area and goal, LGMS establishedfive objectives for 2010:1) Fewer than 10 product odor complaints per year. For the entirety of the year 2010there were 2 odor complaints. The same target was carried forward into 2011 butwas reduced to 9 product odor complaints for the year, and thus far in the yearthere have been no complaints.2) Fewer than 10 product quality complaints per year. For the entirety of the year2010 there were 3 other than odor complains, 2 related to storage and 1 related tothe product quality. The same target was carried forward into 2011 but wasreduced to 9 product quality complaints per year.3) At least 4 public outreach events per year. MSD conducted 11 public outreachevents in 2010. And the same target was carried forward into 2011 with theincrease of public outreach events being increased to 5. Thus far in 2011therehave been 14 such events.4) Greater than 80 percent saleable product distributed in 2010. As was previouslyreported 99.78 percent of Louisville Green was beneficially reused, but 100percent of all saleable pellets were land applied. The same target was carriedforward into 2011 but distribution level was increased to 84 percent. Thus far in2011 the percentage of Louisville Green distributed has been 100 percent.5) Conduct internal communications quarterly with plant personnel. There were 2internal communication meetings held in the last two quarter of 2010. This targetwas carried over into 2011 but the frequency of these meeting was reduced to oneevery 4 months. One such meeting has been held thus far in 2011.In the Quality Biosolids Management Practices outcomes area and goal, LGMSestablished three objectives for 2010:1) Fully implement standard operating procedures (SOPs) for waste activated sludge(WAS), dewatering, and digestion critical control points by January 31, 2011.10


Also revise, retrain, and redistribute the Truck Loading and Weighing SOP andDryers SOP. The above referenced SOPs have generally been updated, however afurther revision and updating is underway for the first three mentioned. A similartarget was developed for 2011, which involves development and implementationof SOPs for Primary and Secondary Treatment. This is a work in progress.2) Have two additional operators obtain wastewater II licenses each year. At thebeginning of 2010 there were 18 process technician IIs and 10 process technicianIIIs; by the end of 2010 there were a total of 11 process technician IIs and 18process technician IIIs. Eight operators were reported to have received theirwastewater II certifications and 2 received their wastewater III certifications. Asimilar goal was established for 2011, i.e., two operators were to obtain orupgrade their wastewater licenses. Thus far in 2011 seven operators have obtainedor upgraded licenses.3) Achieve annual average preventive maintenance completion of 84 percent. In2010 the facility had attained an 89.8 percent preventive maintenance (PM)completion rate and a 97.8 percent corrective maintenance completion rate. Theidentical target was carried over as an objective in 2011. Through April 2011 thePM completion rate was 87.2 percent and the corrective maintenance was 93.3percent.CONCLUSIONS AND RECOMMENDATIONSThe results of the third party interim audit show the Louisville and Jefferson CountyMetropolitan Sewer District has a fundamentally strong Environmental ManagementSystem. The NSF lead auditor reviewed and approved the corrective action plans for theminor nonconformances associated with the third interim audit. Therefore, it is therecommendation of the audit team that the Louisville Green Environmental ManagementSystem of Louisville, Kentucky retain its “verification” status.As was mentioned previously, an EMS is a continuously improving process, andretention of verification status is not the end. The results of this and future audits willprovide value added to the system and should be viewed as an overall opportunity toimprove. Every audit is a snapshot in time, and does not, or cannot, identify each andevery area for improvement. And yet, while no single audit identifies all of the areas forimprovement the results of each audit provide an additional incremental step in theoverall system’s improvement.The scope of each interim audit must include a review of the organization’s progresstoward goals and objectives; EMS outcomes (environmental performance, regulatorycompliance, interested party relations, and quality practices); actions taken to correctminor nonconformances; the management review process; and corrective and preventiveaction requests and responses. This review generally includes requirements found inelements 1, 2, 5, 6, 9, 14, 15, 16 and 17.11


Based on discussions between the facility’s EMS Coordinator and the third partyauditor the following interim audit schedule shows the interim audit record along with theindividual elements to be the focus of the audit proposed for next year:Year 1 (third party) – Elements 5, 6, 9, 10, 13 and 15 (completed)Year 2 (internal) – All Elements (completed)Year 3 (third party) – Elements 1, 4, 7, 8, 11 and 17 (completed)Year 4 (internal or third party) – Elements 2, 3, 12, 14, and 16.12


Attachment 1Documents and Other Objective EvidenceReviewed During the Third External Interim AuditElement 1. Documentation of EMS for Biosolids- Louisville Green Management System (LGMS) Manual, Rev 9 – November 23,2010.- Interviews with Robert Bates, Process Manager; David Coe, EMS Coordinator;Joseph Falleri, Operations Project Specialist; and Robin Burch, Process SupportTechnician.- LGMS Manual – Table of Contents.- LGMS Manual – Appendices.- LGMS Manual – Manual Revision Log.- LGMS Manual – Chapter 2 – Management Direction, Louisville GreenManagement Policy.- LGMS Manual – Chapter 2 – Management Direction, Management of Change.- LGMS Manual – Chapter 5 – Improvement and Communication, PublicParticipation and Communication.- LGMS Manual – Chapter 5 – Improvement and Communication, identification ofcontractors’ activities.- LGMS Manual – Appendix 3A – List of Critical Control Points and OperationalControls.- Summary sheet of contractor requirements related to LGMS for biosolids.Element 2. Biosolids Management Policy- LGMS Manual – Chapter 2 – Management Direction, Louisville GreenManagement Policy.- Interview with Alex Novak, Director of Operations.- Interview with Saeed Assef, Director Infrastructure and Flood Protection.- Interviews with Robert Bates, Process Manager; David Coe, EMS Coordinator;Joseph Falleri, Operations Project Specialist; and Robin Burch, Process SupportTechnician.- December 14, 2009 MSD Board Meeting Minutes documenting approval of thenew LGMS Policy, dated October 19, 2009.- MSD – Louisville Green Management System website(http://www.msdlouky.org/programs/envir_man_sys.htm).- EMS Employee Master Training List.Element 3. Critical Control Points- LGMS Manual – Chapter 6 – Operational Control – Critical Control Points.- LGMS Manual – Appendix 3A – List of Critical Control Points and OperationalControls.13


- Liquid Processing flow diagram.- Solids processing flow diagram.- Expanded versions of solids drying flow diagram.- Interviews with Robert Bates, Process Manager; David Coe, EMS Coordinator;Joseph Falleri, Operations Project Specialist; and Robin Burch, Process SupportTechnician.- Field observation of primary treatment, secondary treatment, digestion,dewatering, drying, silo storage and truck loading and weighting facilities.- Interviews with Richard Galardi, Process Manager; Richard Warman,Maintenance Supervisor; McKinley Reed, Maintenance Manager; Rob Roy,Maintenance Planner; James Emily, Control System Supervisor; Robert Barker,Process Technician III, Vic Dwyer, Process Technician III; Paul German, ProcessTechnician III; Aaron Smith, Process Technician III; Elbert Bledshaw, ProcessTechnician III; Stephen Sarver, Process Technician I; Travis Crabtree, IndustrialMaintenance Mechanic; Joseph Downs, Master Maintenance Mechanic; KerryGreenwell, Master Maintenance Mechanic; and Eric Bean, Master MaintenanceMechanic.Element 4. Legal and Other Requirements- LGMS Manual – Chapter 4 – Compliance – Legal and Other Requirements.- Appendix 4A – List of Legal and Other Requirements.- LGMS Manual – Chapter 6 – Operational Control – Critical Control Points.- Interviews with Robert Bates, Process Manager; David Coe, EMS Coordinator;Joseph Falleri, Operations Project Specialist; and Robin Burch, Process SupportTechnician.- Interviews with Lisa Gaus, Emergency Response Pretreatment Administrator;Damon Talley, Regulatory Engineer; Scott Porter, Environmental RegulatoryAttorney; and Zonetta English, Laboratory Manager.- MSD Wastewater/Storm water Discharge Regulations Effective: March 9, 2009.- Appendix 6A – List of Interested Parties for pretreatment and hazardous materialsprogram.- Interviews with regulators - Michael Hom, US EPA Region IV – EnvironmentalEngineer, Biosolids Data Management System (BDMS) and Robert Bickner,Kentucky Division of Waste Management.Element 5. Goals and Objectives for Continual Improvement- LGMS Manual – Chapter 5 – Improvement and Communication – Goals andObjectives.- Appendix 5A – Goals and Objectives – List of Goals and Objectives – 12/7/2010.- Appendix 5A – Goals and Objectives – List of Goals and Objectives – 1/24/2011.- Appendix 5A – Goals and Objectives - Goals and Objectives Revision Log.- Appendix 9A – Record of Public Input and Inquiries, Rev 28, 5/27/2011.- Interview with Alex Novak, Director of Operations.- Interview with Saeed Assef, Director Infrastructure and Flood Protection.14


- Interviews with Robert Bates, Process Manager; David Coe, EMS Coordinator;Joseph Falleri, Operations Project Specialist; and Robin Burch, Process SupportTechnician.- Progress toward Goals and Objectives dated January 12, 2011.- Progress toward Goals and Objectives dated June 6, 2011.- Louisville Green Program Performance Report dated 2/18/2011.Element 6. Public Participation in Planning- LGMS Manual – Chapter 5 – Improvement and Communication – PublicParticipation and Communication.- LGMS Manual – Chapter 5 – Improvement and Communication – LouisvilleGreen Sales Agent and MSD’s Communication Plan.- Appendix 6A – List of Interested Parties for pretreatment and hazardous materialsprogram.- Appendix 6A – List of Interested Parties for Louisville Green Fertilizer.- Appendix 9A – Record of Public Input and Inquiries, Rev 28, 5/27/2011.- Appendix 9B – Form for Public Input and Inquiries, Rev 2, 4/10/2009.- Notification to interested parties dated February 21, 2011 providing opportunitiesfor observation of third party interim audit.- Interviews with Robert Bates, Process Manager; David Coe, EMS Coordinator;Joseph Falleri, Operations Project Specialist; and Robin Burch, Process SupportTechnician.- MSD – Louisville Green Management System website(http://www.msdlouky.org/programs/envir_man_sys.htm).- Multi-color single sheet presentation of MSD Policy and Code of Good Practice.- Multi-color single sheet presentation of Louisville Green Management SystemFour Key Outcome Areas.- Pocket version of above two information sheets.- Louisville Green Program Performance Report for public distribution dated2/18/2011.- Various color flyers presenting the benefits of the Louisville Green organic basedfertilizer.- Louisville Green customer list dated 5/2/2011.Element 7. Roles and Responsibilities- MSD Louisville and Jefferson County Metropolitan Sewer District OrganizationalChart dated April 16, 2011.- LGMS Manual – Chapter 3 – Roles, Responsibilities, and Competency – Rolesand Responsibilities.- EMS Coordinator formal position description dated December 2005.- Interviews with Robert Bates, Process Manager; David Coe, EMS Coordinator;Joseph Falleri, Operations Project Specialist; and Robin Burch, Process SupportTechnician.15


- Interviews with Emergency Preparedness and Response personnel: Allen Adams,Health and Safety Administrator and Jared Bishop, Emergency ResponseCoordinator.- Interviews with MSD regulatory personnel: Lisa Gaus, Emergency ResponsePretreatment Administrator; Damon Talley, Regulatory Engineer; Scott Porter,Environmental Regulatory Attorney; and Zonetta English, Laboratory Manager.- Interviews with operations and maintenance personnel: Richard Galardi, ProcessManager; Richard Warman, Maintenance Supervisor; McKinley Reed,Maintenance Manager; Rob Roy, Maintenance Planner; James Emily, ControlSystem Supervisor; Robert Barker, Process Technician III, Vic Dwyer, ProcessTechnician III; Paul German, Process Technician III; Aaron Smith, ProcessTechnician III; Elbert Bledshaw, Process Technician III; Stephen Sarver, ProcessTechnician I; Travis Crabtree, Industrial Maintenance Mechanic; Joseph Downs,Master Maintenance Mechanic; Kerry Greenwell, Master Maintenance Mechanic;and Eric Bean, Master Maintenance Mechanic.- Interviews with training personnel: Tony Glore, Training and PerformanceAdministrator and David Roth, Senior Trainer: Operations.- Interviews with contractors: Clark Fenimore, A.J. Inc. (sales contractor); KenStewart, B&H (hauler) – Facility Maintenance; Tony Bell, B&H (hauler) –Dispatcher.Element 8. Training- LGMS Manual – Chapter 3 – Roles, Responsibilities, and Competency –Training.- Interviews with training personnel: Tony Glore, Training and PerformanceAdministrator and David Roth, Senior Trainer: Operations.- Interviews with Robert Bates, Process Manager; David Coe, EMS Coordinator;Joseph Falleri, Operations Project Specialist; and Robin Burch, Process SupportTechnician.- Reviewed various training sign-in sheets for EMS training.- Observed functioning of IT employee date base management system.- Reviewed Job Performance Factors training variables.- Focus Group Agenda on Dryer Issues, dated 2/14/2008.- EMS training power point presentation.- Interviews with operations and maintenance personnel: Richard Galardi, ProcessManager; Richard Warman, Maintenance Supervisor; McKinley Reed,Maintenance Manager; Rob Roy, Maintenance Planner; James Emily, ControlSystem Supervisor; Robert Barker, Process Technician III, Vic Dwyer, ProcessTechnician III; Paul German, Process Technician III; Aaron Smith, ProcessTechnician III; Elbert Bledshaw, Process Technician III; Stephen Sarver, ProcessTechnician I; Travis Crabtree, Industrial Maintenance Mechanic; Joseph Downs,Master Maintenance Mechanic; Kerry Greenwell, Master Maintenance Mechanic;and Eric Bean, Master Maintenance Mechanic.16


- Interviews with contractors: Clark Fenimore, A.J. Inc. (sales contractor); KenStewart, B&H (hauler) – Facility Maintenance; Tony Bell, B&H (hauler) –Dispatcher.Element 9. Communications- LGMS Manual – Chapter 5 – Improvement and Communication – PublicParticipation and Communication.- LGMS Manual – Chapter 5 – Improvement and Communication – LouisvilleGreen Sales Agent and MSD’s Communication Plan.- LGMS Manual – Chapter 5 – Improvement and Communication – InternalCommunications.- LGMS Manual – Chapter 5 – Improvement and Communication – Pretreatmentand Hazardous Materials Program Communication.- Appendix 6A – List of Interested Parties for pretreatment and hazardous materialsprogram.- Appendix 6A – List of Interested Parties for Louisville Green Fertilizer.- Appendix 9A – Record of Public Input and Inquiries, Rev 28, 5/27/2011.- Appendix 9B – Form for Public Input and Inquiries, Rev 2, 4/10/2009.- Notification to interested parties dated February 21, 2011 providing opportunitiesfor observation of third party interim audit.- Interviews with Robert Bates, Process Manager; David Coe, EMS Coordinator;Joseph Falleri, Operations Project Specialist; and Robin Burch, Process SupportTechnician.- MSD – Louisville Green Management System website(http://www.msdlouky.org/programs/envir_man_sys.htm).- Multi-color single sheet presentation of MSD Policy and Code of Good Practice.- Multi-color single sheet presentation of Louisville Green Management SystemFour Key Outcome Areas.- Pocket version of above two information sheets.- Louisville Green Program Performance Report for public distribution dated2/18/2011.- Various color flyers presenting the benefits of the Louisville Green organic basedfertilizer.- Louisville Green customer list dated 5/2/2011.Element 10. Operational Control of Critical Control Points- LGMS Manual – Chapter 6 – Operational Control – Operational Controls- LGMS Manual – Appendix 3A – List of Critical Control Points and OperationalControls.- Standard Operating Procedure for Digestion.- Standard Operating Procedure for Dewatering.- Standard Operating Procedure for Dryers, Rev 5, dated 10/7/2010.- Standard Operating Procedure for Waste Activated Sludge Thickening.17


- Standard Operating Procedure for Truck Loading and Weighing, Rev 5, dated10/7/2010.- Interviews with Robert Bates, Process Manager; David Coe, EMS Coordinator;Joseph Falleri, Operations Project Specialist; and Robin Burch, Process SupportTechnician.- Interviews with operations and maintenance personnel: Richard Galardi, ProcessManager; Richard Warman, Maintenance Supervisor; McKinley Reed,Maintenance Manager; Rob Roy, Maintenance Planner; James Emily, ControlSystem Supervisor; Robert Barker, Process Technician III, Vic Dwyer, ProcessTechnician III; Paul German, Process Technician III; Aaron Smith, ProcessTechnician III; Elbert Bledshaw, Process Technician III; Stephen Sarver, ProcessTechnician I; Travis Crabtree, Industrial Maintenance Mechanic; Joseph Downs,Master Maintenance Mechanic; Kerry Greenwell, Master Maintenance Mechanic;and Eric Bean, Master Maintenance Mechanic.- Interviews with contractors: Clark Fenimore, A.J. Inc. (sales contractor); KenStewart, B&H (hauler) – Facility Maintenance; Tony Bell, B&H (hauler) –Dispatcher.Element 11. Emergency Preparedness and Response- LGMS Manual – Chapter 7 – Emergency Procedures – Emergency Preparednessand Response.- Emergency Response Manual.- Interviews with Emergency Preparedness and Response personnel: Allen Adams,Health and Safety Administrator and Jared Bishop, Emergency ResponseCoordinator.- Interviews with Robert Bates, Process Manager; David Coe, EMS Coordinator;Joseph Falleri, Operations Project Specialist; and Robin Burch, Process SupportTechnician.- Interviews with contractors: Clark Fenimore, A.J. Inc. (sales contractor); KenStewart, B&H (hauler) – Facility Maintenance; Tony Bell, B&H (hauler) –Dispatcher.Element 12. EMS Documentation and Document Control- LGMS Manual – Chapter 8 – Document Control and Record Keeping – Controlof Documents, Control of Records.- LGMS Manual – Chapter 2 – Management Direction, Management of Change.- Interviews with Robert Bates, Process Manager; David Coe, EMS Coordinator;Joseph Falleri, Operations Project Specialist; and Robin Burch, Process SupportTechnician.- Interviews with contractors: Clark Fenimore, A.J. Inc. (sales contractor); KenStewart, B&H (hauler) – Facility Maintenance; Tony Bell, B&H (hauler) –Dispatcher.18


Element 13. Monitoring and Measurement- LGMS Manual – Chapter 6 – Operational Control – Monitoring andMeasurement.- LGMS Manual – Appendix 3A – List of Critical Control Points and OperationalControls.- Quality Assurance Process for Louisville Green, Rev 8, dated 12/7/2010.- Standard Operating Procedure for Digestion.- Standard Operating Procedure for Dewatering.- Standard Operating Procedure for Dryers, Rev 5, dated 10/7/2010.- Standard Operating Procedure for Waste Activated Sludge Thickening.- Standard Operating Procedure for Truck Loading and Weighing, Rev 5, dated10/7/2010.- Interviews with Robert Bates, Process Manager; David Coe, EMS Coordinator;Joseph Falleri, Operations Project Specialist; and Robin Burch, Process SupportTechnician.- Interviews with operations and maintenance personnel: Richard Galardi, ProcessManager; Richard Warman, Maintenance Supervisor; McKinley Reed,Maintenance Manager; Rob Roy, Maintenance Planner; James Emily, ControlSystem Supervisor; Robert Barker, Process Technician III, Vic Dwyer, ProcessTechnician III; Paul German, Process Technician III; Aaron Smith, ProcessTechnician III; Elbert Bledshaw, Process Technician III; Stephen Sarver, ProcessTechnician I; Travis Crabtree, Industrial Maintenance Mechanic; Joseph Downs,Master Maintenance Mechanic; Kerry Greenwell, Master Maintenance Mechanic;and Eric Bean, Master Maintenance Mechanic.Element 14. Nonconformances: Preventive and Corrective Action- LGMS Manual – Chapter 5 – Improvement and Communication –Nonconformances and Corrective Action.- Appendix 16A – Internal Audit Findings Worksheet, Rev 3, 4/10/2009.- Appendix 14B – Corrective Action Plan Form, Rev 1, 4/10/2009.- Interviews with Robert Bates, Process Manager and David Coe, EMSCoordinator.- Interviews with internal audit team members: Robin Burch, Process SupportTechnician; Joseph Falleri, Operations Project Specialist; and Jenni Schelling,MSD Internal Auditor- National Biosolids Partnership Louisville Green Management System InternalAudit Report #6, audit dates June 21-24, 2010.- Appendix 14A – Corrective/Preventive Action Plan Spreadsheet for open findingsas of 12/11/2010.- Appendix 14A – Corrective/Preventive Action Plan Spreadsheet for all internaland external findings from 2008 through 2010.19


Element 15. Periodic Biosolids Program and EMS Performance Report- LGMS Manual – Chapter 5 – Improvement and Communication – LouisvilleGreen Program Performance Report.- Interviews with Robert Bates, Process Manager; David Coe, EMS Coordinator;Joseph Falleri, Operations Project Specialist; and Robin Burch, Process SupportTechnician.- Louisville Green Program Performance Report, 2/18/2011.Element 16. Internal EMS Audit- LGMS Manual – Chapter 5 – Improvement and Communication – InternalAudits.- Appendix 16A – Internal Audit Findings Worksheet, Rev 3, 4/10/2009.- Appendix 14B – Corrective Action Plan Form, Rev 1, 4/10/2009.- NBP Guidance for Biosolids EMS Interim Audits, last revised May 19, 2006.- Interviews with Robert Bates, Process Manager and David Coe, EMSCoordinator.- Interviews with internal audit team members: Robin Burch, Process SupportTechnician; Joseph Falleri, Operations Project Specialist; and Jenni Schelling,MSD Internal Auditor.- National Biosolids Partnership Louisville Green Management System InternalAudit Report #6, audit dates June 21-24, 2010.- Internal Audit Scope for 2010 summary sheet.- Comprehensive Internal Audit Scope for 2009 and 2010, including auditchecklist.- Audit Binder containing all necessary audit materials.Element 17. Periodic Management Review of Performance- LGMS Manual – Chapter 2 – Management Direction – Management Review.- Appendix 17A – Management Findings, Decisions, and Action Items, Rev 3,4/6/2009.- Interview with Alex Novak, Director of Operations.- Interview with Saeed Assef, Director Infrastructure and Flood Protection.- Interviews with Robert Bates, Process Manager; David Coe, EMS Coordinator;Joseph Falleri, Operations Project Specialist; and Robin Burch, Process SupportTechnician.- Reviewed Minutes of Management Review Team Meeting held May 7, 2009.- Reviewed Minutes of Management Review Team Meeting held April 28, 2010and updated on September 15, 2010 to reflect status of management action items.- Reviewed Minutes of Management Review Team Meeting held March 7, 2011.20


Attachment 2Appeals Process National Biosolids PartnershipBiosolids organizations that participate in the National Biosolids Partnership (NBP)Environmental Management System (EMS) Program are required to undergo an EMSverification audit by an independent, third party auditor assigned by the NBP and yearlyinterim audits. The purpose of the EMS audit is to determine whether or not theorganization’s EMS conforms with -- that is, meets the requirements of -- the NBP program,as defined in the EMS Elements1. The spirit of these requirements includes a welldocumentedprogram and meaningful opportunities for interested party involvement.The NBP provides an appeals process for biosolids organizations and interested parties thatdisagree with the findings of a third party EMS audit. The verification appeals processinvolves an Appeals Board; representing a balance of biosolids management interestedparties, including an environmental advocacy group, and wastewater industry professionals.An appeal must be submitted within 30 days of the audit company’s official verificationdecision or interim audit decision.To submit an appeal before the Appeals Board, the petitioner must set forth the specific EMSelement(s) and requirements that is believed to have not been evaluated and/or implementedconsistent with NBP requirements as reflected in the EMS Elements, along with the objectiveevidence to support that claim. For example, a petitioner may believe that a majornonconformance exists but was not found by the auditor. In this case, the petitioner wouldneed to identify in the petition the specific EMS element believed to be out of conformanceand why.To submit an appeal, petitioners must fill out and submit the standardized appeals petitionform that is available on the NBP website at http://www.biosolids.org. A formal appeal mustbe submitted within 30 days of the verification decision or interim audit decision by the auditcompany.The Board’s Administrative Officer receives all appeals petitions on behalf of the Board andconducts a basic completeness check. Upon completion of this check, the petition is eitherforwarded to Appeals Board members or back to the petitioner with incomplete areasdocumented Petitions should be sent via certified, return receipt requested mail to:The NBP EMS Appeals Board, Attention: Board Administrative Officer, c/o WaterEnvironment Federation, 601 Wythe Street, Alexandria, VA 22314The Appeals Board will examine the facts, interview parties involved, deliberate the case,and then make a determination as to whether a major nonconformance does or does not exist.Appeals cases vary in complexity. As a result, the time required for the Board to evaluate acase and make a decision might vary. However, the overall Board target for processing anappeal is approximately four months.1 The EMS Elements and other program materials are available on the NBP website athttp://www.biosolids.org.21

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