Kent County Regional Resource Recovery Facility Sustainability ... · energy sources to the maximum extent technically and economically feasible; 6. Promote effective health and safety

SMS Manual Page No. 1

Revision No. 11 10/09/2014

K e n t C o u n t y R e g i o n a l R e s o u r c e R e c o v e r y F a c i l i t y

S u s t a i n a b i l i t y M a n a g e m e n t S y s t e m ( S M S ) M a n u a l

Kent County Regional Resource Recovery Facility

Approval date 4/30/2015

Approved by Kent County SMS Core Team

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Revision No. 12 4/30/2015

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Revision History

Revision

No.

Date Reason For Revisions Revised by

0 5/31/09 First Issue Jim Newton

1 04/16/10 Revised to reflect auditor comments Jim Newton

2 11/06/10 Revised to account for new projects Jim Newton

3 05/01/11 Revised based on interim audit results Jim Newton

4 10/21/11 Updated in response to 2011 internal audit Jim Newton

5 01/12/12 Add visitors to supplier/contractor section Jim Newton

6 04/20/12 Revise text based on audit comments Jim Newton

7 10/24/12 Revised based on Core Team meeting Jim Newton

8 11/15/2012 Revised based on surveillance audit Jim Newton

9 12/20/2012 Revised based on surveillance audits Jim Newton

10 04/30/2014 Revised based on surveillance audit Jim Newton

11 10/09/2014 Revised O’s and T’s Jim Newton

12 4/30/2015 Revised based on 2014 recertification audit Jim Newton

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Table of Contents

Preamble ......................................................................................................................................... 6

1. SMS Introduction and Overview .................................................................................... 6

1.1 Purpose, Authority, Scope, Authorizations................................................................. 6

1.2 Policy, planning, planned arrangements .................................................................... 7

1.3 SMS Flowchart ............................................................................................................. 7

Figure 1.1 SMS Flowchart ..................................................................................................... 8

1.4 Lines of Authority ......................................................................................................... 8

Figure 1.2 KCRRRF Organizational Chart .......................................................................... 9

1.5 Roles and Responsibilities ........................................................................................... 9

2. Control of Operations .................................................................................................... 11

2.1 Significant Aspects and Risks, CCPs, OCs ............................................................... 11

Figure 2.1 Significant Aspects and Risks Process Flow Chart .......................................... 11

2.2 Compliance with Legal and Other Requirements ................................................... 12

2.3 Control of Visitors, Contractors and Suppliers ....................................................... 12

2.4 Competency, Awareness and Training ..................................................................... 13

2.5 Emergency Planning, including Incidents and Accidents ...................................... 14

2.6 Document Control and Recordkeeping ................................................................... 16

3. Communication .............................................................................................................. 16

3.1 Internal Communication ........................................................................................... 16

3.2 External Communication .......................................................................................... 17

3.3 KCRRRF Sustainability Performance Report ....................................................... 18

4. Improvement Processes .................................................................................................. 20

Figure 4.1 Goals and Targets Process Flow Chart ............................................................. 20

4.1 Goals, Objectives and Targets ....................................................................... 20 4.2 Monitoring and Measuring ........................................................................................ 20

4.3 Internal Audits .......................................................................................................... 21 4.4 Corrective and Preventive Action ............................................................................. 21

5. Management Involvement ............................................................................................. 22

5.1 Management of Change ............................................................................................. 22

5.2 Management Review .................................................................................................. 22

Figure 5.1 Management Review Process Flow Chart ......................................................... 23

SMS Glossary ................................................................................................................................ 25

Appendixes ..................................................................................................................................... 34

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Preamble

This manual describes the Kent County Regional Resource Recovery Facility’s (KCRRRF)

Sustainability Management System (SMS) that encompasses the Wastewater Collection and

Treatment Facilities and subsequent activities, the individual SMS processes and

procedures, and their interactions.

1. SMS Introduction and Overview

1.1 Purpose, Scope, Authorizations

Purpose and Applicability

The purpose of this Sustainability Management System (SMS) is to improve

performance in the areas of the environment, employee health and safety, and biosolids

throughout the Wastewater Facilities in an integrated manner.

Scope

The scope of this SMS covers the collection and treatment of wastewater and the

generation of treated water and biosolids. Key definitions are included in the Glossary

included in this manual. Table 1 included in Appendix A to this manual relates the

ISO 14001, OHSAS 18001 and NBP elements to specific sections in this manual.

Authorizations

Under authority provided by the Kent County Levy Court, the KCRRRF SMS Manual

has been approved by the Public Works Director and the Kent County SMS Core

Team.

1.2 Vision/mission, planning, planned arrangements

Vision/Mission

The Kent County Regional Wastewater Treatment Facilities (KCRRRF)

Sustainability Vision/Mission statement was approved by the Kent County Director

of Public Works. A copy of the current vision/mission statement is included in this

document. A summary of the commitments is presented below:

1. Comply with applicable environmental, health and safety laws and regulations and appropriate

occupational health and safety practices;

2. Have practices that are consistent with the principles of the National Biosolids Partnership’s Code

of Good Practices;

3. Improve continually its environmental, health and safety performance;

4. Readily communicate with interested stakeholders about its sustainability, environmental, health

and safety performance;

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5. Promote pollution prevention activities, energy efficiency and conservation, the use of renewable

energy sources to the maximum extent technically and economically feasible;

6. Promote effective health and safety practices including the prevention of injury and ill-health; and

7. Support sustainability efforts that reduce the facility’s dependence on fossil fuels and man-made

chemicals.

8. Endeavor to achieve zero net energy at the facility by producing sufficient onsite energy at the

facility to offset any energy purchased from offsite non-renewable sources.

Planning

The management review process is used to plan the management system. This process

reviews the public’s perspective. Managers bring the public

’s perspective to the

management review for consideration. The Environmental Programs Manager

implements, monitors, and reports on the performance of the management system. The

management system is intended to produce outcomes in the following areas: (1)

Regulatory Compliance, (2) Environmental Performance, (3) Biosolids Quality Practices,

(4) Interested Party Relations, and (5) Occupational Health and Safety.

Planned Arrangements

The KCRRRF SMS is intended to be consistent with the ISO 14001:2004 Standard, the

OHSAS 18001:2007 Specification and the National Biosolids Partnership (NBP) EMS

for Biosolids.

Reference

Appendix

Table 1. SMS Manual and Planned Arrangements Cross-Reference

1.3 SMS Flowchart

Purpose

To show the interaction between the processes of the SMS.

Description

The SMS process consists of three main elements: planning, support and core processes. The

planning process includes the significant risk analyses, determination of process (critical) control

points, establishing the mission/vision statement, detailing legal and other requirements, setting

goals, objectives and targets, developing the SMS management plan and assigning roles and

responsibilities. The core processes include operational controls, monitoring and measuring, and

emergency preparedness. The support processes include: awareness, competency and training,

communications, and document and record controls.

I

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nputs to the SMS process include: management direction, management of change and improvement

processes including: internal audits, management review and corrective and preventive actions.

The outcomes or results of the SMS includes: regulatory compliance, interested party relations,

wastewater and biosolids quality and employee and community health and safety.

Figure 1.1 SMS Flowchart

1.4 Lines of Authority

Purpose

To demonstrate the lines of authority from the Department of Public Works’ top management to

staff using the Department of Public Works organizational chart.

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1.5 Roles and Responsibilities

Purpose

To define the roles and responsibilities of individuals associated with the KCRRRF

SMS.

Kent County Levy Court – provides ultimate direction and funding for all activities

within the County, including budget approval, issuing of bonds, legal requirements,

and direction for the SMS, and provides public comment on all portions of the

SMS during public meetings.

Sewer Advisory Board (SAB) – provides public input into both the biosolids

aspects of the SMS and the ISO/OHSAS activities. Reviews and comments on

selected portions of the SMS, principally with respect to aspects, objectives and

targets, and reviews and recommends the annual budget for Levy Court approval.

Figure 1.2 Department of Public Works Organizational Chart

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Public Works Director – manages the Department of Public Works and all activities

associated with the department, including budgeting, resource allocation, lines of

authority, and mission and vision. Assigns duties for the SMS and issues the

authorization letter for the SMS, participates in management review as a member of

the SMS Core Team and defined as top management for the Department of Public

Works.

Assistant Public Works Director-Wastewater Facilities- manages the Wastewater

Facilities and the interaction of the facilities and personnel with the KCRRRF SMS.

Environmental Program Manager/Environmental Management Representative (EMR) -

implements the SMS, facilitates the understanding of the SMS and its applications;

monitors the effectiveness and continual improvement of the SMS; reports on the

performance of the SMS for the management review process and participates in the

management review as a member of the SMS Core Team; manages the pretreatment,

septic hauler and FOG programs. The duties of the EMR apply to both the

environmental and the health and safety aspects of the SMS.

Maintenance Supervisor – manages the maintenance of the wastewater treatment plant

and lift stations; provides resources essential to the implementation, control and

improvement of occupational health and safety for the maintenance staff; participates in

management review as a member of the SMS Core Team; implements processes,

programs and methods contained in this manual for the maintenance of the wastewater

treatment plant and lift stations.

Operations Supervisor – manages the wastewater operations program; provides resources

essential to the implementation, control and improvement of occupational health and safety

for the water quality staff; participates in management review as a member of the SMS

Core Team; implements processes, programs and methods contained in this manual for the

wastewater operations program.

Operations Superintendent - manages the wastewater operations, laboratory operations

and maintenance programs; provides resources essential to the implementation, control

and improvement of occupational health and safety for the water quality staff; participates

in management review as a member of the SMS Core Team; implements processes,

programs and methods contained in this manual for all areas of responsibility.

Contractors – provide service to or on behalf of the Department of Public Works; comply

with relevant policies and procedures of the Department of Public Works.

Suppliers – provide materials and supplies for the effective operation and maintenance of

the Department of Public Works; comply with relevant policies and procedures of the

Department of Public Works.


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2. Control of Operations

2.1 Determining Significant Environmental, Health and Safety and Security Risks,

Setting Objectives and Targets, Establishing the EHSS Management Plan, Critical

Control Points and Operational Controls

Purpose

To determine and assess what aspects, risks, and regulatory requirements are most significant to

the Department of Public Works.

Responsibilities Managers –identify environmental aspects and health and safety risks.

Process Description

Figure 2.1

The work instruction that describes the process for determining environmental, health and safety,

and security (EHSS) risks, determining the significant EHSS risks and setting objectives and

targets, the EHSS management plan, identifying critical control points and operational controls can

be found in Work Instruction SMS-1


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2.2 Compliance with Legal and Other Requirements

Purpose

To ensure the Department of Public Works provides services that comply with laws, regulations,

codes, mandates, and other requirements that apply to the Department of Public Works.

Responsibilities

Environmental Program Manager – identifies and tracks legal and other requirements and

conducts the annual compliance assessment.

Managers – identify and track compliance with legal and other requirements for respective areas of

responsibility.

Contractors – track, evaluate, and implement regulatory requirements for their area of service.

Process Description

1. Track legal and other requirements via networking, communications with regulatory agencies,

professional organizations, and any other available means.

2. Review other requirements through management review process.

3. Identify critical control points where legal and other requirements apply.

4. Document legal and other requirements.

5. Monitor, record, and identify compliance or noncompliance by inspection, data review,

regulatory audits, management review, and other means.

6. Address all noncompliances through the Corrective and Preventive Action Process.

7. Conduct the annual compliance assessment.

Reference

Appendix

Table 2 List of sources of regulations and other requirements

Table 3 Regulations applicable to the KCRRRF and Other Requirements

Table 4 KCRRRF Compliance Assessment Checklist

2.3 Control of Visitors, Contractors and Suppliers

Purpose

To evaluate and ensure that the services provided by visitors, contractors and suppliers result in

positive outcomes.


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Responsibilities

Assistant Director-Wastewater – reviews outcomes of contractor and supplier service,

approves purchase order requisitions, oversee visitors to the facility.

Managers – oversee visitors, contractors and suppliers in respective areas.

Process Description

1. Escort all visitors onsite and ensure that they follow all environmental, health and

safety (EHS) requirements of the facility after conducting a briefing of the EHS

requirements and what is expected from them during their visits.

2. Use Kent County purchasing procedures to identify, select, and approve contractors

and suppliers.

3. Inform the contractor and/or supplier by contract, service agreement, memorandum,

pamphlet, and/or verbal communication of their responsibilities in providing their services.

4. Evaluate the contractor or supplier’s performance and quality of work. Communicate the result

of evaluation to the contractor or supplier. For contractors and/or suppliers performing

inadequately, consider requiring them to submit corrective and preventive action plans for

review and approval.

5. Determine relative value and risk of the service provided through outsourcing versus

internally.

6. If it is determined to be of more value to perform the service internally, determine who will

perform the service.

Reference

Appendix

Table 5 Contractor Roles and Responsibilities for Compliance with the

SMS

2.4 Competency, Awareness and Training

Purpose

To describe methods used to ensure that staff is competent and capable of performing assigned

responsibilities safely and effectively.

Responsibilities

Managers – evaluate competency and awareness of the staff under respective area of responsibility

and assign appropriate training.

Process Description

The work instruction for the competency, awareness and training process is included in SMS

Procedure 2 (SMS-2).


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2.5 Emergency Planning, including Incidents and Accidents

Purpose

To effectively prepare for and/or respond to emergencies and to limit the negative impacts of

accidents and incidents and prevent recurrence

Responsibilities

Responding Employee – identifies emergencies, contacts emergency personnel and/or

supervisor or manager.

Manager – prepares for, assesses and assigns additional resources as necessary to mitigate harm or

damages due to an incident or emergency, investigate and report accidents and incidents to the

Assistant Director-Wastewater.

Contractors – maintain Emergency Preparedness and Response procedures for their area of

service to the Department of Public Works.

Assistant Director-Wastewater – reports accidents and incidents to the Risk Manager-

Administrative Services Department; aids in the investigation of accidents or incidents.

Department of Public Works Personnel – report accidents, incidents, and near-misses to a

supervisor or manager.

Process Description

The work instruction for the emergency planning process can be found in SMS Procedure 3 (SMS-

3)

2.6 Document Control and Recordkeeping

Purpose

To identify and control important documents used for managing Department of Public Works

activities and records required to demonstrate Department of Public Works performance.

Responsibilities

Responsible Person – ensures the document or record is effectively controlled.

Process Description

1. Identify documents used for managing Department of Public Works activities and records

required to demonstrate Department of Public Works performance that require control and

where to store them.

2. Determine individual responsible for the controlled document or record.

3. (For controlled documents) Maintain a master copy on the County EMS website as an Adobe

Acrobat file, taking appropriate steps to ensure it is approved for adequacy, identified, dated,

readily available, reviewed to ensure it is correct, complete and current.

4. Communicate approved changes in controlled documents to persons affected by the change.

5. Destroy or archive obsolete versions of controlled documents.

6. (For controlled records) Take steps to ensure it is identifiable, legible, secure, readily

accessible, and changed only under the authority of the responsible person.


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7. For each controlled record, follow retention requirements.

Reference

Appendix

Table 6 Documents Requiring Control

Table 7 Documents of External Origin Requiring Control

Table 8 Records Requiring Control



3. Communication

3.1 Internal Communication

Purpose

To describe the process of internal communication with Department of Public Works staff.

Public Works Director (or designee) – determine and communicate relevant and required

information to staff.

Environmental Programs Manager – communicates relevant management system

information and SMS performance to staff.

KCRRRF Staff – determine and communicate relevant and required information to

supervisor, or manager.

Safety Committee Members – provide input and comment, including health and safety matters,

through safety committee participation.

Process Description

1. Communicate any relevant or required information to staff via, staff meetings, e-mail,

postings, or other methods.

2. Communicate the following items to staff via staff meetings, e-mail, postings, or other

methods:

SMS Policy

Significant environmental aspects

Significant occupational health and safety risks

Goals and targets

Performance in achieving outcomes

Legal compliance requirements

Any changing circumstance and its results

3. KCRRRF staff communicates any relevant or required information to supervisor or manager

via e-mail, verbal, staff meetings, or other methods.

4. Obtain employee input and provide consultation on matters related to health and safety,

through the Safety Committee.

5. Managers bring suggestions and input from the Safety Committee or other employee ideas,

including those related to the SMS, to the management review process for consideration.

6. All employees shall receive direct annual training about the SMS

7. Periodic articles about the SMS will be included in the monthly Kent County newsletter

8. Information about the SMS will be kept current on the Dept. of Public Works website at

www.co.kent.de.us

9. All employees shall assist with the development of the SMS objectives and targets and assist

with the accomplishment of corrective actions under this program.

10. Key performance measures (KPMs) will be decided by the appropriate area supervisors and

communicated via the Sewer Advisory Board monthly operations report and made available to

employees on the appropriate bulletin boards. Table 22 provides a current list of KPMs.

http://www.co.kent.de.us/



3.2 External Communication

Purpose

To describe the process of external communication to interested parties, contractors, and

suppliers.

Responsibilities

Manager (or designee) - communicates relevant information to interested parties in respective

areas of responsibility or interest.

Process Description

1. Identify interested parties which may include:

The public

Contractors or suppliers

Regulatory Agencies

2. Communicate, at minimum, the following to interested parties:

SMS Policy

Legal and other requirements

Goals and targets

Wastewater Performance Report (including Biosolids Annual Report)

Third Party Audit Summary

Other information as necessary

3. Inform interested parties using the following methods:

Website(s)

Other forms of communication, i.e. verbal, written, or electronic.

4. Provide opportunities for interested parties to communicate their input on environmental

impacts, program performance, and areas in which the Department of Public Works can

improve.

5. Respond to requests for information or other inquiries in a timely manner, or if necessary,

refer the inquiry to the individual with authority or knowledge to respond.

6. Bring significant exchanges of communications, determined by receiving or

responding manager, to management review for documentation and follow-up response.

7. Refer any interested party complaints to the Corrective and Preventive Action

Process.

8. The Sewer Advisory Board will be used as an extension of public input with respect

to all portions of the SMS. The SAB monthly operations report will provide KPM

information for the use of the general public.

9. No contractors or suppliers shall be directly involved in external communications

except t provide information to help KCRRRF staff prepare documents and

presentations.

10. External communication shall include the following:

Regulatory correspondence (specifically from DNREC and the US EPA)

shall be recorded on the Regulatory Response Log kept on the V Drive under

the Correspondence/WTF Correspondence folder.

Determination of the objectives and targets outlined in the SMS

Verbal/written communication from the public, including neighbors, local

farmers, environmental groups and the local media; and



Educational information about the SMS provided by the KCRRRF.

Third party audits

11. Inquiry response communications

All verbal or written complaints, call-outs or inquiries shall be logged by the

plant secretary on the SMS Complaint/Inquiry Response (CIR) Form

Responses shall be either in writing or verbal and completed using the CIR

Form

The Assistant Public Works Director – Wastewater (or designee) shall

investigate the complaint/inquiry and prepare the CIR Form and corrective

action, if any.

The Environmental Programs Manager shall monitor the corrective actions

and report to the Core Team progress and completion details.

12. Third Party Audit

The public shall be notified of any third party audits via the County website,

notification of the Sewer Advisory Board and discussions with the Kent

County Levy Court Commissioners during their public meetings.

SAB members and Levy Court Commissioners will be made available to the

auditors for interviews, as desired.

Appendix

Table 9 Complaint/Inquiry Response Form

Table 10 Current Outreach Activities

3.3 KCRRRF Sustainability Performance Report

Purpose

To communicate Department of Public Works sustainability performance to interested parties.

Responsibilities

Environmental Program Manager – generates and communicates the Department of Public

Works Performance Report to interested parties.

Process Description

1. Compile the Department of Public Works Performance Report annually to include

the following:

Performance toward goals and targets

Performance toward compliance

Productivity

Contractor performance

Biosolids activities

Third Party Audit Summary

Other relevant information as deemed necessary by management

2. Communicate the contents of the Department of Public Works Performance Report using

methods described in 3.1 Internal Communication and 3.2 External Communication of this

manual.



Appendix

Table 11 List of Key Performance Measures

Reference



4.0 Improvement Processes

4.1 Goals, Objectives and Targets

4.2 Monitoring and Measuring

Purpose

In order to ensure that the SMS is effective, it is essential to monitor and measure appropriate

information. This information is used to make corrections within the SMS and ensure that that

SMS is operating properly.

Responsibilities

Core Team – Determine the information necessary to be monitored and measured..

Environmental Program Manager – Ensure that the information is being monitored and

measured in accordance with the SMS and prepare the appropriate reports to ensure that only the

necessary information is being monitored and measured

Fig ure 4 .1 Object ive s and Targ et s Process F low Chart



Area Supervisors – To determine the information necessary to be monitored and measured and

that staff properly records information on forms and/or electronically, such as through the

SCADA.

Staff – Record appropriate information as determined by the area supervisors.

Process

1. Area supervisors, Core team and Environmental Program Manager determine what

information is to be monitored and measured following the flowcharts included in Tables 12

and 13 of the Appendix to this SMS.

2. Ensure staff record necessary information

3. Review all information for effectiveness and determine if additional information is needed to

be recorded or should be deleted from being recorded if it is no longer necessary.

4. Determine the effectiveness of the SMS through interpretation of the information being

recorded.

4.3 Internal Audits

Purpose

To complete an internal evaluation of the performance of the Kent County Sustainability

Management System (SMS) at least annually, identify nonconformances and opportunities for

system improvement.

Responsibilities

Core Team – Determine the purpose and scope of the internal audit.

Environmental Program Manager – Coordinate, train, and assist auditors with the performance

of an internal audit. Compile findings and report to management regarding the performance and

effectiveness of the management system.

Internal Audit Team – Conduct annual internal audit given the purpose and scope provided by

the Core Team, write report and provide recommendations and corrective actions

Process Description

1. Core Team determines the purpose and scope of the internal audit.

2. Identify and train the internal audit team.

3. Compare the SMS with the requirements of other planned arrangements based on the audit’s

purpose and scope.

4. Submit results of the internal audit to the management team for review.

5. Develop action plans as appropriate using the Corrective and Preventive Action Process to

address nonconformances.

4.4 Corrective and Preventive Action (CAPA)

Purpose

To identify the root cause of problems and issues, develop action plans to correct the negative

impacts, and to prevent recurrence.



Responsibilities:

Managers –perform routine corrective and preventive actions.

Core Team –determines and reviews high priority corrective and preventive actions.

Environmental Program Manager – analyzes and tracks trends; maintains database of

corrective and preventive actions.

Process Description

The process description for the corrective and preventative action program can be found

in work instruction SMS-4.

Table 12 Wastewater Monitoring Flowchart

Table 13 Biosolids Monitoring Flowchart

Table 14 Internal Audit 3 Year Schedule



5. Management Involvement

5.1 Management of Change

Purpose

To identify and react to changing conditions and requirements that require modifications to the

operations of the Department of Public Works.

Responsibilities

Manager (or designee) – plans, implements and completes management of change that may

affect significant environmental aspects, significant occupational health and safety risks, or legal

requirements.

Process Description

1. Monitor the following for changes that may affect the function of the SMS or

Department of Public Works performance:

Environmental impacts

Occupational health and safety risks

Critical control points

Legal and other requirements

Organizational changes and structure

Other changes identified by management review

2. Receive pertinent information regarding changing conditions or requirements, i.e.

notification of new regulation or information from manufacturer.

3. Assess each SMS process for those affected by the changing condition or

requirement and document using the Management of Change Form which could also

include a new or revised EHS risk analysis..

4. Assign responsibilities to KCRRRF staff.

5. Obtain adequate resources to respond to changing conditions or requirements.

6. Execute the change.

7. Notify certifying agency and the assigned third party auditor of significant process or

equipment changes that may warrant a change in the defined critical control points and other

areas of the SMS.

5.2 Management Review

Purpose

To evaluate the function of the KCRRRF Sustainability Management System (SMS) and its

processes as they affect the value of service to the customer.

Responsibilities

Core Team – reviews the performance, effectiveness, and adequacy of the SMS and its

processes.

Environmental Program Manager – evaluates and reports SMS performance and effectiveness

to management review.



Process Description

Detailed Management Review

1. Schedule detailed management review meetings at least annually to review and assess the

performance of the KCRRRF and the SMS, using the following as a topical agenda:

Follow-up from previous reviews

Performance results

Changing circumstances

Goals and targets

Audits, assessments and compliance

Corrective and preventive action status from prior audits, and other CPARs

Community and public relations Community and public relations

2. Prepare, store, and communicate detailed management review meeting agendas and minutes

using the Core Team Meeting Record Form.

3. Determine action items, and refer appropriate findings of the management review to the

Corrective and Preventive Action Process.

Periodic Management System Evaluation

1. Schedule periodic management system evaluation meetings to review the management system

for suitability, adequacy, and effectiveness, using the following as a topical agenda:

SMS activities that are working well

SMS activities that are not working well

Areas that need improvement

Interactions between the various processes

Comparisons to past reviews and anticipated performance

2. Prepare, store, and communicate management system evaluation meeting minutes.

3. As required, recommendations for changes or modifications to the SMS may be addressed

through the Corrective and Preventive Action Process or through the Management of Change

process as appropriate.



Figure 5.1 Management Review Flow Chart

Appendix

Table 15 Management of Change Form

Table 16 Core Team Meeting Record Form


SMS Manual Page No.26

Accident – undesired event related to environmental aspects or occupational health and

safety risks giving rise to death, ill health, injury, or damage resulting in lost time or

workmen compensation.

Action Plan – process used in the management system to achieve goals and targets, to

identify resources, deadlines, responsible parties, and other details; required to effect a

change or an improvement.

Activity – Something that occurs at the wastewater facility in order to transport

wastewater, produce transport and apply biosolids (Kentorganite) or produce clean

wastewater.

Audit – a systematic investigation to identify deficiencies to be corrected or resolved.

Auditor – competent person(s) conducting an audit.

Awareness – mindful and conscious of the implication of each action or activity

Awareness Training - Training involving an overview of the purpose, scope, SMS process

and importance of specific operating procedures and work instructions required under the

SMS. The training will address the importance of conformance with the

environmental/biosolids policy and SMS procedures and requirements, a clear

understanding of their roles and responsibilities in achieving conformance, including

emergency response and planning, and the awareness of significant environmental impacts

of their work activities and the potential consequences of departure from specified

operating procedures.

Baseline – the starting point from which the meeting of an objective can be measured,

such as the number of kilowatt hours of electricity used to run the basin blowers during

any given year.

Biosolids – solid organic matter recovered from a wastewater treatment process and used

especially as fertilizer, usually referred to in the plural.

Biosolids Management Activities – a wide range of activities that impact quality of

wastewater solids and biosolids, that include pretreatment activities, wastewater treatment

processes, solids stabilization processes, conditioning and dewatering processes,

transportation, storage, and beneficial use or disposal.

Calibration – the act of ensuring that data from environmental monitoring equipment used

to support the SMS are accurate and reliable by comparing the readings against an

established standard and adjusting the instrument to read the result accurately.

Code of Good Practice – broad framework of goals and commitments to guide the

production, management, transportation, storage, and use or disposal of biosolids



Competency – the ability to use knowledge effectively and readily in execution or

performance of tasks and activities; a developed aptitude or ability; the ability to do

tasks competently.

Competency Training – Training involving details of the requirements for each specific

job function as required under the SMS, such as SOPs, emergency response procedures,

etc. to ensure that personnel performing tasks which can cause significant environmental

impacts are competent

Continual Improvement – a management system process for systematically improving

the SMS to achieve Department of Public Works goals and targets set forth in the City of

Lawrence Administrative Policy 101: Lawrence Wastewater Management System Policy.

Core Team – The team of managers who have the ultimate responsibility for the direction

and operation of the SMS. This team shall include the Public Works Director, the

Assistant Public Works Director –Wastewater, the Environmental Program Manager, the

Treatment Plant Superintendent, the Operations Supervisor, and the Maintenance

Supervisor.

Contractors – a company that provides labor, materials and other resources under

contract to KCRRRF to install, repair, or otherwise service operational equipment located

within the fenceline covered by the SMS.

Corrective Action - an action taken to eliminate the causes of an existing nonconformity, a

deficiency in a product, service, policy, procedure, work instruction, process, or the EMS,

or other undesirable situation in order to prevent recurrence.

Corrective & Preventive Action Request (CPAR) - a record of each unique

nonconformity, including a description of the problem, the root causes of the

nonconformity, the corrective and preventive actions necessary to prevent recurrence, and

the information relevant to the implementation and tracking of the actions to completion.

Critical Control Points – an activity that is considered critical to ensuring a quality

biosolids product or clean wastewater as required under the SMS..

Corrective Actions – specific actions and steps taken to correct any SMS

noncompliance with legal and other requirements or nonconformance with processes,

programs or procedures, to mitigate any resultant impacts to the environment, health and

safety, or to public perception.

Documents – information and its supporting medium (paper, magnetic, electronic,

computer disc, photograph, or combination thereof). For the purpose of the SMS, it is the

various documents that collectively comprise management system documentation, including

the SMS policy, program, procedures, processes, operating instruction, and other supporting

documents required by the SMS and applicable laws and regulations.



Emergency – any situation that may go offsite, or required emergency personnel

intervention to control.

Emergency Preparedness – an emergency planning process to ensure that emergency

situations affecting the Department of Public Works have been identified, response plans

and procedures have been developed, and training emergency response personnel and

equipment are ready and available for use.

Emergency Response - specific emergency plans and activities that are initiated to

contain an emergency situation and bring it under control in order to minimize

environmental and occupational health and safety impacts.

Emergency Response Planning – The activity of anticipating emergencies and

planning how to respond to such events, including developing Standard Operating

Procedures (SOPs), response training, and establishment of requisite communication

channels.

Environment – surrounding in which the Department of Public Works operates,

including air, water, land, natural resources, flora, fauna, humans, and other

interrelation.

Environmental – where referenced throughout this manual, includes all Department of

Public Works activities: the collection and treatment of wastewater and the control and

return of treated water and biosolids to the environment.

Sustainability Aspect – element of the Department of Public Works’ activities, products,

or services that can interact with the environment, pose occupational health or

employee safety risks or promote sustainability. An aspect is an element that causes an

impact to the environment or employee health and safety.

Sustainability Impact – any change to the environment or employee health and

safety (positive or negative) or sustainability wholly or partially resulting from the

wastewater facility’s activities and/or aspects and including public health, public

nuisance issues.

Environmental Health and Safety/Biosolids Policy – the statement of purpose that is

signed by the Kent County Levy Court and distributed to all employees to ensure that all

activities comply with all federal state Sustainability laws, rules and regulations, the

National Biosolids Partnership’s Code of Good Practice and the Natural Step’s

sustainability conditions.

Environmental Health and Safety (EHS) Management Program – The tasks and

activities required to ensure that the SMS objectives and targets are met.



Environmental Health and Safety Management System (SMS) – the system of

procedures, operational controls and work instructions designed to comply with the ISO

14001:2004 standard, the OHSAS 18001:2007 specification and the NBP EMS

requirements.

External Communication – External communication involves presenting an overview of

the purpose, scope, and SMS process to stakeholders outside the fenceline in order to

promote the program, improve understanding of the SMS and seek assistance in

developing key elements of the SMS program. In addition, external communication

includes the process by which KCRRRF receives, documents, and responds to relevant

communications from external parties

Fenceline – the physical or institutional boundaries where the SMS covered activities occur.

Finding - is defined as a deficiency or lack of conformance with any element of an SMS

or a positive accomplishment of the program. Findings may be major nonconformance

that requires immediate correction, minor nonconformances, that require correction before

the next audit or merely an observation that requires no corrective action, but may result in

a system improvement. All findings must be formally resolved to assure effective

correction of the observed condition and the adoption of system improvements or

preventive measures to reduce or preclude the likelihood of recurrence.

Frequency/Probability – The number of times an environmental, health or safety aspect

occurs (e.g. daily, monthly, annually, etc.) or the likelihood of the aspect occurring (very, not

very).

Goals (Objectives) – environmental and occupational health and safety performance

improvement goals that are consistent with the Department of Public Works policy to

ensure activities comply with applicable laws and regulations meet quality and public

acceptance requirements and prevent other unregulated adverse Sustainability impacts by

effectively managing all environmental aspects, health and safety hazards/risks, and

critical control points. Goals may include, but are not limited to, compliance with specific

regulatory requirements, improving quality, improving public acceptance, and reducing or

eliminating direct or indirect negative environmental impacts. NOTE: The SMS has

adopted the term “goals

”. This term is used in the same manner as

“objectives

” is used in

ISO 14001:2004 Standard and OHSAS 18001:2007 Specification.

Hazard – source of situation with a potential for harm in terms of human injury or ill

health, damage to property, damage to the workplace environment, or a combination

thereof.

Hazard Identification – process of recognizing, identifying and defining a hazard and its

characteristics.



Incident – event that may give rise to an accident or has the potential to lead to an

accident. An incident where no ill health, injury, damage, or other loss occurs; also

referred to as a “near-miss

”. The term

“incident

” may include

“near-misses,

” emergency

situations, and accidents. An incident diagram is included in Appendix of this manual.

Interested Parties – individuals or organizations, public or private, affected by Department

of Public Works activities, those expressing interest in Department of Public Works

activities, or those the Department of Public Works believes would be interested in its

activities. Internal stakeholders may include the Kent County Levy Court, KCRRRF

employees, and contractors operating at the KCRRRF. External stakeholders may include

local farmers who use Kentorganite, residents surrounding the KCRRRF, local

environmental groups, DNREC, Kent County residents, residents of the State of Delaware,

local media, etc.

Internal Audit – a systematic internal investigation process for objectively evaluating the

Department of Public Works’ conformance to the requirements of the Lawrence

Wastewater Management System and identifying deficiencies to be corrected or resolved.

Internal Communication – Internal communication involves presenting an overview of

the purpose, scope, SMS process and specific operating procedures required under the

SMS in an effort to obtain participation in the program to employees of the facility,

contractors involved with the operation and other Kent County employees.

ISO 14001 :2004 Standard – acronym for the International Standards Organization

environmental management system standard.

KCRRRF – an acronym for the Kent County Regional Resource Recovery Facility

Legal Requirements - the environmental and occupational health and safety federal, state,

and local laws and regulations that are applicable to the Department of Public Works’

activities.

Management of Change – the process of conducting an evaluation of proposed changes in

operations, maintenance and equipment covered under the SMS and developing any

necessary changes to the SMS to continuously improve its effectiveness.

Management Review - the process of conducting a periodic evaluation of the SMS and

developing any necessary changes to the SMS to continuously improve its effectiveness

Measurement – the systematic method of estimating, testing, or otherwise evaluating key

parameters and characteristics of a department’s management activities to determine

conformance with a specific standard or other performance requirement.

Monitoring – the systematic process of watching, checking, observing, inspecting,

keeping track of, regulating, or otherwise controlling key parameters and characteristics of



the City’s activities to determine compliance with a specific standard, regulatory or other

performance requirement, or to measure progress toward goals and targets.

NBP – acronym for National Biosolids Partnership which is a not-for-profit alliance

between the Water Environment Federation (WEF), the Association of Metropolitan

Sewerage Agencies (AMSA), and the US Environmental Protection Agency (EPA) whose

purpose is to promote safe and environmentally sound biosolids management.

National Manual of Good Practice – detailed set of guidance on the identification of

critical control points and the selection of appropriate management practices published by

the National Biosolids Partnership.

Near-miss – an unexpected or undesirable event that fails being defined as an accident or

incident by a very small margin; determined by management and reported to management

review.

Noncompliance – a deviation from federal, state, and local laws; regulations; and other

compliance requirements applicable to the Department of Public Works’ activities.

Nonconformance – a deviation from the established program and management system

requirements that has the potential to create a noncompliance situation, significant

environmental impact, occupational health and safety hazard or risk, or public perception

issue.

Occupational Health and Safety – conditions and factors that affect the well-being of

employees, temporary workers, contractor personnel, visitors, and any other person in the

workplace.

Occupational Health and Safety Management System – a management system that

facilitates the management of occupational health and safety risks associated with the

business of the organization, see OHSAS 18001:2007.

OHSAS 18001:2007 – acronym for the Occupational Health and Safety Assessment

Series; uses a similar management system to International Standards.

Operational Controls – ordinances, regulations, standard operating procedures,

practices, technology, instrumentation and process controls, monitoring and other

criteria developed, implemented and maintained by the Department of Public Works to

ensure effective management of all critical control points; including conformance with

policy requirements; and achievement of goals and targets.

Other Requirements – other non-binding practices, rules, codes and environmental

requirements to which the Department of Public Works subscribes as part of the SMS.

Examples include binding agreements with customers, suppliers, public organizations,

and commitments to “beyond compliance

” performance.



Performance – measurable results of the SMS, related to the Department of Public

Works’ control of environmental impacts, health and safety risks, and biosolids activities

based on its policy, goals, and targets.

Pollutants – materials such as heavy metals, cyanides, solvents, and others that make

wastewater and biosolids physically impure if present at certain concentrations.

Prevention of Pollution – use of processes, practices, techniques, materials, products,

services or energy to avoid, reduce, or control (separately or in combination) the creation,

emission, or discharge of any type of pollutant or waste in order to reduce adverse

environmental impacts.

Preventive Action – specific actions and steps taken to identify, analyze, and eliminate the

root causes of noncompliance and/or nonconformance and to put into place solutions that

prevent a recurrence.

Public – see Interested Parties.

Public Education – systematic public communications program for educating interested

parties and other stakeholders on the Department of Public Works’ activities and the

KCRRRF Sustainability Management System.

Public Outreach – communications of current and future biosolids plans and

operations.

Public Participation – The direct involvement of the general public in the development

and implementation of the SMS through organizations such as the Sewer Advisory Board,

local environmental action groups, state agencies, local farmers, local news media, and

other similar organizations.

Records – various records or reports of activities required by the management system and

applicable laws and regulations, including, but not limited to records or reports of

equipment calibration, monitoring, measurement, laboratory testing, inspections, operating

logs, emergency response, incidents, outside party inquiries, public participation meetings,

audits, corrective and preventive actions, management reviews, and periodic performance

reports. Records describe the results of specific activities for a prescribed event, activity

and/or period of time.

Regulations – the set of rules and legal requirements that apply to the operations of

the KCRRRF, as developed by the US EPA, DNREC and Kent County Levy

Court.

Responsibilities – specific tasks that an individual performs in either a lead or

supporting role that accomplishes and/or supports goals and targets.



Risk – combination of the likelihood, severity and consequence(s) of a specified

hazardous event occurring.

Risk Assessment – process of estimating the magnitude of risk and deciding whether or not

the risk is tolerable.

Role – the activity that an individual performs as a part of the SMS.

Safety – freedom from unacceptable risk of harm.

Safety Committee – the Public Works Director, one representative from the Operations

Dept., One representative from Laboratory Operations, one representative from the

Maintenance Dept., the Environmental Program Manager, one representative from the Kent

County Dept. of Public Safety, and the Treatment Plant Superintendent to represent the

KCRRRF in matters of health and safety. The Department of Public Works Safety

Committee assists the Public Works Director in developing and maintaining health and

safety training and competency.

Service Agreement – the contract between the Department of Public Works and other

person(s) to perform specific activities.

Sewer Advisory Board (SAB) – the board appointed by the Kent County Levy Court

Commissioners to advise the Levy Court on sewer related matters. Membership on the SAB

shall be from contract users of the sewer system, DNREC, and members of the public.

Significant Sustainability Aspect – An aspect that the Core Team has determined to be

serious enough to be included in the SMS program’s objectives and targets in order to ensure

that it is properly controlled.

SMART Criteria – The criteria that define and evaluate the suitability of a practical goal or

target. A goal or target is specific, measurable, achievable, relevant, and time-bounded.

Standard Operating Procedure (SOP) – standard work instructions and practices for

employees describing the “how to” steps in managing the aspects, risks, and critical control

points of a specific management activity affecting Department of Public Works activities,

compliance with legal and other requirements, and health and safety risks.

Supplier (Vendor) – a company or organization that provides services, materials or

equipment to the KCRRRF without physically entering the SMS fenceline.

Sustainability – the commitment made by the KCRRRF to reduce the use of fossil fuels

and man made chemicals as a part of its ongoing operations.



Target(s) – a detailed performance improvement requirement, applicable to Department of

Public Works or parts thereof, that arises from goals, and that needs to be set and met in

order to achieve overall goal. NOTE: The SMS has adopted the term “targets

”. This term is

used in the same manner as “objectives,

” used in the NMB EMS Standard.

Third Party Verification Audit – a systematic, structured audit of the Department of

Public Works’ management system; performed by a qualified independent third party

auditor using a standardized protocol for verification.

Top Management – for the purposes of this manual, top management is the Public Works

Di rector.

Training – teaching to make fit, qualified, or proficient; preparation for a test of skill or

knowledge; instruction in disciplines and techniques.



APPENDICES

Table 1 SMS Manual and Planned Arrangements Cross-Reference

Table 2 List of Sources of regulations and other requirements

Table 3 Regulations applicable to KCRRRF

Table 4 KCRRRF Compliance Assessment Checklists

Table 5 Contractor Roles and Responsibilities for Compliance with the SMS


Table 7 Documents of External Origin Requiring Control



Table 10 Current outreach activities

Table 11 List of Key Performance Measures

Table 12 Wastewater monitoring flowchart

Table 13 Biosolids monitoring flowchart

Table 14 Internal Audit 3 year Schedule

Table 15 Management of change form

Table 16 Core Team meeting record


SMS-Manual Page 36

Table 1 SMS Manual and Planned Arrangements Cross-Reference

SMS Manual

ISO14001:2004

OHSAS 18001:1999

NBP EMS for Biosolids

Section # Section # Section # Element #

Preamble 4.1 4.1 1

Section 1.1 4.1, 4.4.1, 4.4.4, 4.1 1, 1A

Section 1.2 4.2, 4.4.4 4.2 1B, 1C, 1.2, 6

Section 1.3 4.3.1, 4.3.2, 4.5.1, 4.5.3, 4.6 4.3.1, 4.3.2, 4.3.3, 4.3.4, 4.4.6, 4.5.2, 4.6 3, 4, 5, 10, 14, 17

Section 1.4 4.4.1 4.4.1 7

Section 1.5 4.4.1 4.4.1 1F, 7

Section 2.1 4.3.1 4.3.1 3, 10

Section 2.2 4.3.2, 4.5.2 4.3.2, 4.5.1 1D, 4, 10, 13

Section 2.3 4.3.1 4.3.1 1E, 3, 10, 13

Section 2.4 4.4.6, 4.5.1 4.3.1, 4.4.6 3, 10

Section 2.5 4.4.2, 4.4.6 10

Section 2.6 4.4.1, 4.4.2 4.3.1, 4.4.2 8

Section 2.7 4.4.7 4.4.7, 4.5.1, 4.5.2

Section 2.8 4.4.7 4.4.7 1C, 11

Section 2.9 4.4.1, 4.4.2, 4.4.4, 4.4.5, 4.5.2, 4.5.4 4.3.1, 4.4.4, 4.4.5, 4.5.3 4, 8, 12, 13

Section 3.1 4.2, 4.4.3 4.2, 4.3.2, 4.4.3 1C, 2, 9

Section 3.2 4.2, 4.4.2, 4.4.3 4.2, 4.3.2, 4.4.3 1C, 2, 6, 9, 15

Section 3.3 1C, 15

Section 4.1 4.3.3, 4.4.4, 4.5.1 4.3.1, 4.3.3, 4.3.4, 4.5.1 5, 6

Section 4.2 4.5.5 4.5.4 16

Section 4.3 4.5.3 4.5.2 14, 16

Section 5.1 4.4.3 3, 4

Section 5.2 5.2 4.6 17

Appendix A 4.2, 4.4.4 4.2 1B, 2

Appendix B 4.4.4 4.4.4 12

Appendix C 4.3.1 4.3.1, 4.3.2

Appendix D 4.3.1, 4.3.2, 4.5.2 4.3.1, 4.3.2, 4.5.2 1D

Appendix E 4.3.1. 4.3.2, 4.4.6, 4.5.2 4.3.1, 4.3.2, 4.4.6 1E, 10

Appendix F 4.4.1 4.4.1 7

Appendix G 4.4.4, 4.4.5, 4.5.4 4.4.5, 4.5.3 4, 12


SMS-Manual Page 37

Table 2 List of sources of regulations and other requirements

Current Regulations (Program and website location)

US EPA http://www.epa.gov/epahome/cfr40.htm

Occupational Safety and Health Administration (OSHA) http://www.osha.gov/pls/oshaweb/owastand.display_standard_group?p_toc_level=1&p_part_number=1910

Delaware Dept. of Natural Resources and Environmental Control (DNREC) http://www.dnrec.state.de.us/dnrec2000/Rules.asp

Proposed regulations

Federal Register http://www.access.gpo.gov/nara/cfr/index.html

Delaware Regulations www.delaware.gov

Newsletters:

Enflex Weekly (Federal Register and State Register announcements)

Business and Legal Review’s Environmental Manager’s Compliance Advisor (New and proposed

regulations and topics of interest)

Water Environment Federation’s This Week Worldwide (International topics of interest related to water

and wastewater), http://www.wef.org/

Water Environment Federation’s This Week Washington (US topics of interest related to water and

wastewater), http://www.wef.org/

National Biosolids Partnership Weekly Biosolids Update (Biosolids topics of interest), www.biosolids.org

American City and County’s Local Government Update (Topics of interest) www.americancityandcounty.com

Trade magazines:

American City and County (free), http://americancityandcounty.com/index.htm

Environmental Protection (free), http://www.eponline.com/

Occupational Health and Safety (free), http://www.ohsonline.com/

Pollution Engineering (free), http://www.pollutionengineering.com/

Public Works (free), http://www.pwmag.com/

Water and Wastewater Products (free), http://www.wwp-online.com/

http://www.epa.gov/epahome/cfr40.htm

http://www.osha.gov/pls/oshaweb/owastand.display_standard_group?p_toc_level=1&p_part_number=1910

http://www.dnrec.state.de.us/dnrec2000/Rules.asp

http://www.access.gpo.gov/nara/cfr/index.html

http://www.delaware.gov/

http://www.wef.org/

http://www.wef.org/

http://www.biosolids.org/

http://www.americancityandcounty.com/

http://americancityandcounty.com/index.htm

http://www.eponline.com/

http://www.ohsonline.com/

http://www.pollutionengineering.com/

http://www.pwmag.com/

http://www.wwp-online.com/


SMS-Manual Page 38

Trade Organizations:

Air and Waste Management Association, http://www.awma.org/

American Academy of Environmental Engineers, http://www.enviro-engrs.org/

American Public Works Association, http://www.apwa.net/

American Water Works Association, http://www.awwa.org/

Association of Metropolitan Sewerage Agencies, http://www.amsa-cleanwater.org/

Global Environment and Technology Foundation, http://www.getf.org/

Local Government Environmental Assistance Network, http://www.lgean.org/

National Association of Counties, http://www.naco.org/

National Association of Local Government Environmental Professionals, http://www.nalgep.org/

National Biosolids Partnership, http://www.biosolids.org/

National Registry of Environmental Professionals, http://www.nrep.org/

Public Entity Environmental Management System Resource Center, http://www.peercenter.net/index.cfm

Water Environment Federation, http://www.wef.org/

http://www.awma.org/

http://www.enviro-engrs.org/

http://www.apwa.net/

http://www.awwa.org/

http://www.amsa-cleanwater.org/

http://www.getf.org/

http://www.lgean.org/

http://www.naco.org/

http://www.nalgep.org/

http://www.biosolids.org/

http://www.nrep.org/

http://www.peercenter.net/index.cfm

http://www.wef.org/


SMS-Manual Page 39

Table 3 Regulations applicable to the KCRRRF

Law/Program Program Element Regulatory

Agency

Regulation Status

Clean Air Act

Standby generators DNREC, AWM Division 2 Permitted

Title V operating permit DNREC, AWM Division 30 Exempt

New source review DNREC, AWM Division 20 N/A

Burning fossil

fuel/biodiesel

DNREC, AWM Division 2 Permitted

Hazardous air pollutants DNREC, AWM Division 21,38 N/A

Clean Water Act

Industrial pretreatment USEPA, Kent

County

40 CFR, Subchapter N,

Chapter 180-12 Sanitary

Code

Approved

SPCC USEPA 40 CFR, Subchapter D Approved

Wastewater discharge DNREC, WR Water pollution control Permitted

Biosolids application DNREC, WR 40 CFR 503 Permitted

Septic tanks DNREC, WR On-site systems N/A

Stormwater DNREC, WR Stormwater Plan Approved

SARA – RTK (EPCRA)

Accidental release DNREC, AWM Accidental release Permitted

Tier II Reporting DNREC, Annual Tier II report

RCRA

Hazardous waste DNREC, AWM Hazardous waste Conditionally

Exempt

Hazardous waste DNREC, AWM Universal wastes - Aerosol

cans, mercury ballasts,

fluorescent tubes, batteries

Coastal Zone

Coastal zone DNREC, WR Coastal zone management

Aboveground Tanks

ASTs DNREC, AWM AST Approved

Drinking Water

Well water treatment DHS Drinking water operations N/A

Organization Requirements

National Biosolids

Partnership

Code of Good Practice

OSHA

1910.38 Employee

emergency plans

1910.134 Respiratory

protection

1910.146 Permit required

confined spaces

1910.147 The control of

hazardous energy

1910.1200 Hazard

communication


SMS-Manual Page 40

Table 4. KENT COUNTY REGIONAL RESOURCE RECOVERY

FACILITY and BIOSOLIDS PROCESSING ENVIRONMENTAL

TECHNOLOGIES

COMPLIANCE ASSESSMENT CHECKLISTS

Date Conducted:

Auditor:


SMS-Manual Page 41

MEDIA: AIR

Regulatory

Requirements

Auditor Checks In

Compliance

Not In

Compliance

N/A

Title V

Permit Required

Permit Conditions

Emergency Generators

1 MW (Blowers) Registered with DNREC

Permit Required

Permit Conditions

400 KW (Solids) Registered with DNREC

Permit Required

250 KW (RAS 2) Registered with DNREC

Permit Required

250 KW (RAS 1) Registered with DNREC

Permit Required

250 KW (Influent) Registered with DNREC

Permit Required

250 KW (UV) Registered with DNREC

Permit Required

Boiler 1

Registered with DNREC

Permit Required

Boiler 2


Permit Required

BIOSOLIDS

PROCESSING

Scrubber


Permit Required

Permit Conditions

Lime Silo


Permit Required

Permit Conditions

Comments:


SMS-Manual Page 42

MEDIA: WATER

Regulatory

Requirements

Auditor Checks In

Compliance

Not In

Compliance

N/A

NPDES

Permit Required

Permit Conditions met

503 BIOSOLIDS

Marketing Permit Required


Application Permit Required


STORMWATER

Stormwater plan in place

Training current

Inspections conducted as

required

SPCC

Plan in place

Training current

Inspections conducted as

required

PRETREATMENT

Annual report filed

Local limits current

SU inspections current

SIU sampling

Comments:


SMS-Manual Page 43

MEDIA: NON-HAZARDOUS WASTE

Regulatory

Requirements

Auditor Checks In

Compliance

Not In

Compliance

N/A

Scrap Metal


Permit Required

Permit Conditions

Lab Waste


Permit Required

Permit Conditions

Disposed per regs

Screenings/Grit

Registered with DSWA

Approved by DSWA

Approval conditions met

Sampling current

Comments:


SMS-Manual Page 44

MEDIA: HAZARDOUS WASTE

Regulatory

Requirements

Auditor Checks In

Compliance

Not In

Compliance

N/A

Title V

Permit Required


Universal Wastes

Used Oil Registered with DNREC

Properly disposed

Tank labeled

Aerosol Cans

Properly punctured

Properly collected

Placed in scrap metal bin

Batteries

Properly collected

Properly disposed

Storage area labeled

Mercury

Properly collected

Properly disposed


Lab Waste

Properly collected

Properly labeled

Properly disposed


Other

Comments:


SMS-Manual Page 45

MEDIA: AST

Regulatory

Requirements

Auditor Checks In

Compliance

Not In

Compliance

N/A

ASTs

Diesel Fuel


Permit Required

Permit Conditions

Gasoline


Permit Required

Permit Conditions

Comments:


SMS-Manual Page 46

MEDIA: Hazardous Materials

Regulatory

Requirements

Auditor Checks In

Compliance

Not In

Compliance

N/A

HAZCOM

Written

MSDS Files

Training

TSCA

Pesticides Properly applied

Trained personnel

Asbestos

Identified

Tested

Labeled

PCB

Identified

Tested

Labeled

DRBC Sampling

Current

Submitted

PMP in place

EPCRA

Tier II report submitted

Comments:


SMS-Manual Page 47

MEDIA: OSHA

Regulatory Requirements Auditor Checks In

Compliance

Not In

Compliance

N/A

OSHA, 1910

Record keeping (1904)

Log 300 on file

Records injuries and

illnesses

Written instructions

Housekeeping (.23)

Hazards controlled

Area neat and clean

No physical hazards

Emergency Action Plan (.38)

Written

Training

In Practice

Compressed gases (.101)

Storage

Labels

In Practice

PPE (.132-136)

Available

Training

Used

Respiratory Protection (.134)

Available

Used

Training

Machine guarding (.212)

Available

In Practice

Confined Space (.146)

Written

Training

In Practice

Lock Out/Tag Out (.147)

Written

In Practice

Training


SMS-Manual Page 48

MEDIA: Other Requirements

Regulatory Requirements Auditor Checks In

Compliance

Not In

Compliance

N/A

NBP

EMS in place

Follow Manual of Good

Practice

Currently certified

ISO 14001

Currently certified

Internal audit conducted

Corrective actions

underway

OHSAS 18001

Currently certified

Internal audit conducted

Corrective actions

underway

Comments:


SMS-Manual Page 49

Table 5 Contractor Roles and Responsibilities for Compliance with the Sustainability Management

System (SMS)

Contractors are required to:

Policy Requirements– SMS Policy

•

•

Understand the EHS Biosolids Policy Conform to the NBP’s Code of Good Practice and the SMS

Planning Req. -

Environmental

Aspects/Occupational Health and Safety

Risks/Critical Control Points

•

•

•

•

Understand the environmental impacts of activities performed.

Understand the occupational health and safety hazards and risks involved with the activities performed.

Understand the environmental impacts of the critical control point in the

area of contracted services. Perform applicable monitoring and measurement of performance toward

environmental and occupational health and safety.

Legal Compliance and

other Requirements

•

•

Remain in compliance with all applicable federal, state, and local legal

requirements, including the SMS and the service agreement. Perform applicable monitoring and measurement of performance toward

legal and other requirements.

Goals & Targets • Understand that the KCRRRF may have goals and targets

associated with the contractor’s activities in which performance indicators may be measured to determine effectiveness, timeliness, and quality of

work completed.

Public Participation

in Planning and Communication

•

•

•

•

•

•

•

•

Be prepared to participate in public participation activities at the request of

the KCRRRF, including information meetings/hearing, presentations/questions from Levy Court and other officials, and

other circumstances as deemed necessary and beneficial by the KCRRRF Communicate SMS requirements to contractor’s staff.

Effectively communicate with KCRRRF staff regarding details of the applicable activities.

Ensure staff receives accurate information from the KCRRRF.

Communicate the records and reporting requirements with KCRRRF staff on a timely and accurate basis.

Refer all communication with interested parties to Utility staff, including media, complaints, publicity, handouts, and other communication

regarding or which may affect the County, KCRRRF, or applicable

County program or project. Understand that all relevant information applicable KCRRRF

activities and contractor requirements are reflected in Service Agreements and contracts with the contractor.

Report on specific performance measurements with appropriate summaries

of monitoring, measurement, and other results that demonstrate the performance of the project relative to applicable goals and targets, and

legal requirements

Implementation &

Operation – Roles &

Responsibilities

• Clearly understand contractor’s roles and responsibilities as it relates to

SMS requirements and the contracted activity, including record keeping, communication, safety, emergency response, legal obligations,

and other requirements.


SMS-Manual Page 50

Competence, Training, and

Awareness

• Ensure that contractor’s staff learn, disseminate, and apply to daily

operations the following: 1. All federal, state, and local requirements/laws and other

requirements.

2. The correct and safe operation of equipment used in the conducting of contracted activities.

3. General information on the SMS and is informed of its requirements.

4. Communicate relevant information from the KCRRRF to field staff. 5. Emergency response and spill response procedures.

6. Operational recordkeeping and data logging activities.

7. The KCRRRF’s expectations for response to public inquiry.

•

•

•

Assure contractor staff competence in performing tasks Allow Wastewater staff to train the Contractor’s staff on the SMS

and expectations for the contracted services to be provided. Perform applicable monitoring and measurement of performance toward

competence, training, and awareness.

Documentation,

Document Control, & Recordkeeping

•

•

Apply a document control system to contractors SOPs and comply with Wastewater Utility’s requirements for all records and reports.

Record, maintain, and control all documents applicable to KCRRRF activities

and as it pertains to all legal and other requirements.

Operational Controls •

•

Maintain all applicable operational controls for all environmental aspects,

occupational health and safety, and critical control points that pertain to

contractor activities. Perform applicable monitoring and measurement of performance toward

operational controls.

Emergency

Preparedness & Response

• Document the training of their staff and, if appropriate, conduct drills,

especially on the following: 1. Applicable emergency preparedness and response procedures

2. Spill response procedures and training.

3. Other specified training.

Checking,

Measurement, and

Corrective Action – Preventive and

Corrective Actions

• Maintain procedure for the prevention and corrective actions for

nonconformance with the SMS, service agreements, operational

controls, legal and other requirements, emergency situations, this document, and other requirements as deemed necessary by KCRRRF

management

Internal Audit •

•

Understand that your performance as it relates to conformance with the

SMS may be audited internally by KCRRRF staff or individuals as designated by management. The internal audit shall allow

the KCRRRF to review project activities as necessary. Participation consists of attendance at audit meetings (if necessary),

including allowing key staff to be available and sharing pertinent

documentation at the request of auditors, and providing follow-up information at the auditor’s request.

Periodically contractor’s participation will be requested in external audits by an independent audit firm to verify SMS requirements are being met.

Management Review Periodic Management

Review of

Performance

• Understand the KCRRRF management may review contractor’s

performance as it relates to SMS requirements and project performance measurements.

SMS-Manual Page 51

Revision No.12 4/30/2015


Document Name Master Copy Location Responsible Person

SMS Manual SMS Files Environmental Program Manager

SOP’s for Operations Operations Supervisor files Operations Supervisor

SOP’s for Maintenance Maintenance Supervisor files Maintenance Supervisor

SOP’s for Laboratory Laboratory Foreman files Laboratory Foreman

SOP’s for Agricultural Ops Maintenance Supervisor files Maintenance Supervisor

Goals & Targets SMS Files Environmental Program Manager

Contractor Service

Agreement

Plant Secretary’s files As assigned

SCADA Network Server Electrical Foreman

SMS Policy SMS Manual Environmental Program Manager

Emergency Action Plan Plant Secretary’s files Operation Superintendent

Process Drawings/

equipment info

Plant conference room Operations Superintendent

Compliance/inspection

reports

SMS files and Plant Secretary’s files Environmental Program Manager

Safety Programs Plant Secretary’s files Operations Superintendent

SMS-Manual Page 52


Document Description Control Agent Method of Controlling

NPDES Permit WWTF Supervisor Locked file cabinet in front office

Emergency Gen. Air Permit Env. Program Mgr. File cabinet in EPM office

Scrubber Air Permit BIOSOLIDS

PROCESSING VP

File cabinet in trailer

Marketing/Distribution Permit Ag Ops Foreman File cabinet in office

Studies related to O’s and T’s Env. Program Mgr. Book shelf in EPM office

Studies related to NPDES permit WWTF Supervisor Book shelf in main office

Studies related to air emissions Env. Program Mgr. Book shelf in EPM office

Biosolids data and studies WWTF Supervisor File cabinet in front office and

book shelf in EPM office

NBP-related guidance documents Env. Program Mgr. Book shelf in EPM office and

computer CD’s

EMS-guidance documents Env. Program Mgr. Book shelf in EPM office and

computer CD’s

Pretreatment related guidance

documents

Env. Program Mgr. Book shelf in EPM office and

computer CD’s

Job descriptions Personnel manager Personnel files

Table 7. Documents of External Origin Requiring Control

SMS-Manual Page 53


Type of Record Processes

Covered

Location

of

Records

Person

Responsible

Retention

Time

Wastewater Operations

Operations Log Sheet

Daily Shift Procedures Aeration System

Checklist

Solids Handling Building Monitoring

Grit Removal

DMR

Operator’s Logbook

Blower Logbook Equipment Calibration records

Operator licenses,

OJT checklists

Wastewater Plant Offices Assistant Public Works

Director-Wastewater

At least 10 years

Biosolids Operations

Biosolids Scrubber Log

Biosolids Production

Sheet Biosolids D&M Daily

Test Sheet

Biosolids Production Test Records

Natural gas Readings

Kentorganite Application Log

Biosolids Logbook

Equipment calibration records

OJT checklists

Biosolids Plant Office Assistant Public Works Director-Wastewater

At least 10 years

Lab Operations

Solids balance Analysis Biosolids Samples

Plant Samples

COD Analysis BOD Analysis

Enteroccocus Analysis

CBOD Analysis Solids Analysis

Balance Calibration

Microscope Examination Laboratory Logbook

Wastewater and

Biosolids

Plant Lab Lab Supervisor At least 10 years

SMS System

CPARs Complaint logs

SMS training logs. records,

Internal audits External audits

Compliance assessments

SMS Manual\ Incident/accident re

ports/logs

Management reviews Public information

requests

Public comments Award information

Annual biosolids report

SMS EPM Office,

Kent County Website and

V drive

Environmental Program

Manager

5 Years

For the SMS manual,

until replaced by a

later revision


SMS-Manual Page 54



Name of Individual/Company:

Date and Time Received:

How did it come in:

Phone

Letter

Personal visit

Other

Nature of Complaint/Inquiry:

Name of person responding:

Date and Time of response:

How did the response occur?

Phone

Letter

Personal visit

Other

Response summary:

SMS-Manual Page 55


Table 10 Current Outreach Activities

Public Works Web Site

1. Kent County EMS Page

2. Wastewater Treatment Facility Page

3. All SMS documents available for down load on the site

4. The Annual Biosolids Report

Newsletters and other Print outlets

1. County Newsletter Focus

2. Employee monthly newsletter

3. Mailings to sewer users

4. County press releases

5. Public Notices in local papers

6. Flyers given out at the Delaware State Fair and Milford Riverwalk Freedom Festival

soliciting comments on SMS and participants in the 3rd

Party audit

Personal Contact

1. Plant tours

2. Work with farmers to ensure proper amount of Kentorganite is applied

3. Participate on Murderkill Tributary Action Team

4. Provide information to Sewer Advisory Board

Other Means

1. SMS Magnets

2. SMS Mugs

3. Build and operate Environmental/Energy Education Center

SMS-Manual Page 56


Table 11 KEY PERFORMANCE MEASURES

No. of Incidences Electric Usage

Natural Gas Usage Biosolids Produced

PM Hours Annual Pretreatment Rating

No. of Odor Complaints

SMS-Manual Page 57


SMS-Manual Page 58


SMS-Manual Page 59


Table 14 Internal Audit 3-year Schedule

Year 1 Year 2 Year 3

Element Audit 1 Audit 2 Audit 1 Audit 2 Audit 1 Audit 2

O’s & T’s X

Communication X

Training X

Management Review

X

Records X

Management of Change

X

Mission/Vision X

Aspect Analysis X

LOR X

Operational Controls

X

Emergency Planning

X

Document Control

X

Measurement X

Interested Parties

X

CAPA X

Safety X

Security X

SMS-Manual Page 60


Table 15 Management of Change Form

Description of proposed change, modification or new process, procedure or equipment:

Is this process a change involving:

Change in materials New process New equipment

Equipment modifications Change in organization Other (describe below)

Describe the following:

Significant sustainability risks and critical control points associated with the process and whether a risk analysis has been

completed

The legal and other requirements review that applies

Changes in training, internal and external communications required

A list of responsibilities associated with the required tasks

Any SMS procedures, work instructions, or SOPs modified or developed

Timing of all major events

Stake holders consulted and any resulting comments

Pre-startup safety review

Approvals:

Date:

Area Supervisor

Date:

Assistant Public Works Dir. – Wastewater

Date:

Environmental Program Manager

SMS-Manual Page 61


Table 16 CORE TEAM MEETING RECORD

Date:

Attendance:

Colby Harrington Andrew Jakubowitch

Chris Austin Jim Newton

Billy Vincent Keith Powell

Dave Whitney Diana Golt

Topics: EHS/Biosolids Policy changes necessary

Significant aspects/critical control point and objectives and targets review

Outstanding regulatory issues

OHS and environmental performance review

EMP review

Status of employee training

Recent complaints and their response status

External and interested party communications

Annual compliance assessment and biosolids annual report

EMS audit results (internal and external}

Nonconformances observed

Corrective and Preventive Actions status

Outstanding management review items

Identified improvement opportunities

Changing circumstances that affect the SMS

New SOP’s required

New or revised SMS Procedures for approval or revisions (see below)

Other

SMS Procedures approved:

Notes: