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SMS Manual Page No. 1
Revision No. 7 10/24/2012
K e n t C o u n t y R e g i o n a l W a s t e w a t e r 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 Wastewater Treatment Facility
Approval date 10/24/2012 Approved by Kent County SMS Core Team
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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
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Table of Contents
Preamble .........................................................................................................................................6
1. SMS Introduction and Overview .....................................................................................61.1 Purpose, Authority, Scope, Authorizations.................................................................61.2 Policy, planning, planned arrangements ....................................................................61.3 SMS Flowchart .............................................................................................................7
Figure 1.3 SMS Flowchart .....................................................................................................71.4 Lines of Authority .........................................................................................................8
Figure 1.4 KCRWTF Organizational Chart .........................................................................81.5 Roles and Responsibilities ...........................................................................................8
2. Control of Operations .....................................................................................................10
2.1 Significant Aspects and Risks.....................................................................................11Figure 2.1 Significant Aspects and Risks Process Flow Chart ..........................................11
2.2 Compliance with Legal and Other Requirements ...................................................122.3 Critical Control Points ..............................................................................................122.4 Operational Controls ................................................................................................132.5 Control of Contractors and Suppliers ......................................................................142.6 Competency, Awareness and Training.....................................................................142.7 Accidents and Incidents .............................................................................................152.8 Emergency Preparedness ..........................................................................................162.9 Document Control and Recordkeeping ...................................................................17
3. Communication ...............................................................................................................19
3.1 Internal Communication ...........................................................................................193.2 External Communication ..........................................................................................193.3 KCRWTF Performance Report ...............................................................................21
4. Improvement Processes ...................................................................................................22
4.1 Goals, Targets and Management Plan .....................................................................22Figure 4.1 Goals and Targets Process Flow Chart .............................................................23
4.2 Internal Audits ..........................................................................................................234.3 Corrective and Preventive Action .............................................................................24
Figure 4.3 Corrective and Preventive Action Process Flow Chart ...................................25
5. Management Involvement ..............................................................................................26
5.1 Management of Change .............................................................................................265.2 Management Review ..................................................................................................26
Figure 5.1 Management Review Process Flow Chart.........................................................27
SMS Glossary ................................................................................................................................28
Appendixes .....................................................................................................................................36
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Preamble
This manual describes the Kent County Regional Wastewater Treatment Facility’s (KCRWTF) 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 KCRWTF SMS Manual has been approved by the Public Works Director and the Kent County SMS Core Team.
1.2 Policy, planning, planned arrangements
Policy The Kent County Regional Wastewater Treatment Facilities (KCRWTF) Sustainability Policy was approved by the Kent County Levy Court. A copy of the current policy is included on the back page of the cover to this document. A summary of the commitments is presented below:
1. Comply with applicable Sustainability 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 Practice.
3. Improve continually its Sustainability performance.
4. Readily communicate with interested stakeholders about its Sustainability performance.
5. Promote pollution prevention, energy conservation, and effective health and safety practices, including the prevention of injury and ill-heath.
6. Support sustainability efforts that follow the four system conditions in The Natural Step framework.
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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 KCRWTF 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
Figure 1.3 SMS Flowchart
Purpose
To show the interaction between the processes of the SMS.
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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.
Figure 1.4 Department of Public Works Organizational Chart
1.5 Roles and Responsibilities
Purpose To define the roles and responsibilities of individuals associated with the KCRWTF SMS. Kent County Levy Court – provides ultimate direction and funding for all activities
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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.
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 KCRWTF 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.
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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 Significant Aspects and Risks
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
1. Identify units and activities of the Department of Public Works. The Environmental Program Manager shall prepare the initial list, and after review and discussion with the Core Team a final aspect list shall be prepared.
2. For each unit and activity, relate the following possible environmental impacts: • surface water pollution • nuisance (odor, noise, etc.) • air pollution • energy use • ground water pollution • soil pollution • use of natural resources • frequency/probability • others
3. For each unit and activity, consider the following potential health and safety hazards:
• biohazard • noise • reactivity • water/drowning • atmosphere/oxygen deficiency • vehicle accidents • fire • physical • chemical • frequency/probability • electricity • other
4. Rate environmental impacts based on a reasonable scale for determining risks that includes
likelihood and severity as criteria. Ratings shall be on a 0-5 scale with 0 having no impact and 5 having the greatest impact.
5. Conduct a health and safety risk analysis utilizing a “what if” scenario.
6. Determine what significant environmental impacts and significant occupational health and safety hazards are by reviewing ratings and using professional judgment. Each Core Team member shall rate the impacts and hazards and the average of all ratings shall be the ratings used to determine significance.
Figure 2.1 Significant Aspects and Risks Process Flow Chart
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7. Determine aspects (i.e. cause) for significant environmental impacts and risks for significant occupational health and safety hazards.
8. Document significant aspect and risk analysis.
Reference
Appendix
Table 2 “What If” Summary Table
Table 3 Impact Analysis Summary Table
Table 4 Significant EHS Risks
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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 5 List of sources of regulations and other requirements
Appendix
Table 6 Regulations applicable to the KCRWTF and Other Requirements
Appendix
Table 7 KCRWTF Compliance Assessment Checklists 2.3 Critical Control Points
Purpose To identify points within the Department of Public Works where legal compliance, biosolids quality, significant environmental impacts, and health and safety risks can be controlled.
Responsibilities
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Managers – determine critical control points.
Process Description
1. Consider environmental aspects/impacts, health and safety risks, legal and other requirements, NBP Manual of Good Practice, and input from interested parties to determine critical control points of the Department of Public Works.
2. Identify critical control points where the outcomes of units and activities that have significant environmental impacts and occupational health and safety hazards can be changed.
3. Document identified critical control points. 4. Measure performance at critical control points.
Reference 2.4 Operational Controls
Purpose To determine operational controls that can change outcomes at specific critical control points to meet legal requirements and manage significant environmental aspects and health and safety risks.
Responsibilities Managers –implement operational controls that coincide with legal and other requirements, significant environmental aspects, and significant occupational health and safety risks at the critical control point pertaining to respective areas of responsibility. Contractors –implement operational controls for significant environmental aspects and significant occupational health and safety risks in their areas of service. Operators and Maintenance Staff – monitor and report operational parameters and results.
Process Description 1. For identified critical control points, identify and determine possible administrative and
engineered operational controls that can change or influence each outcome. 2. Determine if a standard operating procedure is necessary for an operational control
and document the SOP through document control procedures. 3. Determine the resources (means) required to implement the operational control. Evaluate
the feasibility and value of implementation. 4. Determine relative value and risk with performing the operational control internally or by
outsourcing. 5. For reasonable and effective operational controls, adopt, implement, or modify existing plans,
programs, projects, standard operating procedures, communications, training, or other methods. • Track preventive maintenance • Track laboratory analysis • Track operational data and trends using the OPS32 software package.
6. Establish normal operational parameters and compare actual operational results with those parameters
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7. Train staff on operational controls as well their related significant aspects and regulatory requirements per Section 2.6
8. Track effectiveness of operational controls to meet targets related to goals through the management review process, adjusting the operational controls as needed.
9. Document operational controls. Reference
Appendix Table 8 Critical Control Points and Operational Controls
2.5 Control of Visitors, Contractors and Suppliers
Purpose To evaluate and ensure that the services provided by visitors, contractors and suppliers result in positive outcomes.
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 9 Contractor Roles and Responsibilities for Compliance with the SMS
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2.6 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 1. Identify competency requirements for each job and communicate to staff. 2. Identify training needs necessary to maintain an acceptable level of staff
competency. 3. Evaluate staff competency using the Kent County GAUGE Performance Review and
Development Plan. 4. New employees will be evaluated by area supervisors to determine when they are
competent to perform their duties. Each employee will be evaluated for all areas of work using checklists included in Appendix J
5. Identify inadequacies in competency and correct the inadequacies through additional training, evaluations, and other methods.
6. Training is done using the following methods: • On-the-Job 1-on-1 training • Formal classroom training • Self-training • Other methods
7.. The following training is mandatory for all Department of Public Works staff: • Job responsibilities • Environmental Impacts • Occupational Health and Safety Hazards • Lawrence Wastewater Management System training • Emergency Preparedness training • Legal and Other Requirements
Appendix Table 10 Minimum Expected Qualifications Table 11 Training Matrix Table 12 New Operations Employee Checklist Table 13 New Biosolids Employee Checklist Table 14 New Maintenance Employee Checklist 2.7 Accidents and Incidents
Purpose To limit the negative impacts of accidents and incidents and prevent recurrence.
Responsibilities
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Assistant Director-Wastewater – reports accidents and incidents to the Risk Manager-Administrative Services Department; aids in the investigation of accidents or incidents. Managers – investigate and report accidents and incidents to the Assistant Director-Wastewater. Department of Public Works Personnel – report accidents, incidents, and near-misses to a supervisor or manager.
Process Description 1. Accidents and incidents are reported to the supervisor or manager and to the Personnel
Director. 2. Staff involved completes the report form and submits to manager. 3. Manager completes report, submits it to the Assistant Director-Wastewater to be
forwarded on to the Personnel Director. 4. Accident or incident is investigated internally through the Corrective and Preventive
Action Development Process. 5. Accident or incident enters High Priority Corrective Action Process if it includes:
• Lost time • Property damage • As management deems necessary
6. Accident and corrective action are tracked by the Safety Committee
Reference
Appendix
Table 15 Incident Investigation Form
Table 16 Definition of an Incident
2.8 Emergency Preparedness
Purpose To effectively prepare for and/or respond to emergencies.
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. Contractors – maintain Emergency Preparedness and Response procedures for their area of service to the Department of Public Works.
Process Description 1. Review and train Department of Public Works staff on the following emergency plans on a
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routine basis: • KCRWTF Spill Prevention, Containment and Countermeasure Plan (SPCC) • Kent County Safety Handbook • Kent County Emergency Response Information • Kent County Standard Operating Procedures – Maintenance and Agricultural
Operation • Kent County Standard Operating Procedures – Operations and Laboratory • Kent County Sludge Management Manual
2. Identify the emergency using professional judgment and categories including: • Natural hazards: severe storms, flood, tornadoes, earthquakes, heavy snowfalls • Credible threats or breaches of security • Fire or explosion • Loss of power • Major chemical release • Major physical damage • Drowning in the basins or clarifiers • Contractor emergencies at the KCRWTF
3. Prepare for any emergency or incident by revising the appropriate plans at least once every two years and training employees on the elements of the plans. 4. Report emergencies to the manager or supervisor in charge. 5. Assess severity of emergency. 6. Develop and implement response action plan to include available resources and
mitigation efforts. 7. Review and investigate the emergency through the High Priority Corrective and
Preventive Action Process for effectiveness and to prevent recurrence. 8. Test annually through:
• Review of the High Priority Corrective Action Process for each emergency response
Or • Drill emergency responses if emergency operation plans are not tested sufficiently
by actual emergency responses or when significant changes to emergency operation plans have occurred.
Reference
Appendix
Table 17 Emergency Response Summary Table
2.9 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.
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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. 7. For each controlled record, follow retention requirements.
Reference
Appendix
Table 18 Documents Requiring Control
Table 19 Documents of External Origin Requiring Control
Table 20 Records Requiring Control
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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. KCRWTF 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. KCRWTF 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.
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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 KCRWTF 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
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• Educational information about the SMS provided by the KCRWTF. • 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 21 Complaint/Inquiry Response Form Table 22 Current Outreach Activities
3.3 KCRWTF Performance Report
Purpose To communicate Department of Public Works 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.
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Appendix
Table 23 List of Key Performance Measures
Reference
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4. Improvement Processes
4.1 Goals and Targets
Purpose To establish means to measure progress and prioritize effort towards continual improvement.
Responsibilities Public Works Director – approves the adoption of goals and targets; reviews performance toward goals and targets. Core Team – establishes, monitors, and tracks performance toward goals and targets.
Process Description
1. Set relevant goals in consideration of County Commission goals. 2. Determine appropriate targets based on significant aspects, significant occupational health
and safety risks and associated critical control points using SMART criteria. Consider: • legal and other requirements • SMS policy • best management practices • interested party input • technological options • financial, operational and business requirements
4. Assign responsibility for each target. 5. Develop a progressive step by step action plan for each target outlining the timeline and
responsibilities for each step of the action plan. 6. Monitor, measure, and review target progress at least annually during management review
meetings or other meetings or methods. 7. If progress is determined to be inadequate, the management team may use the Corrective
and Preventive Action Process to evaluate the problem. 8. If the pursuit of a goal or target has a negative impact on service, management team may
modify or eliminate that target. Appendix Table 24 Wastewater Monitoring Flowchart Table 25 Biosolids Monitoring Flowchart Table 26 SMS Management Plan
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Figure 4 .1 Goal s and Target s Process F low Chart
4.2 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.
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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.
Appendix Table 27 Internal Audit Checklist
4.3 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
1. Identify problems or potential problems by using audits, experience, inspections, or other methods. 2. Notify appropriate manager of the problem. 3. Develop a corrective action plan. 4. Evaluate the cause or root cause of the problem or issue. 5. Evaluate priority of the problem or issue, or its root cause to determine necessity of issuing a high
priority corrective and preventive action plan. 6. Consider as high priority any issue caused by the following:
• SMS Non-conformance • Regulatory Non-compliance • Public Complaints • Emergency Incidents • Accident reports • Permit exceedances • Others as determined by management
7. Monitor and review progress toward resolution and effectiveness of solution of corrective and preventive action through management review.
8. Consider employee suggestions for inclusion within the process depending upon complexity of suggestions.
9. Under the management of change process, the Core Team will determine if a revised EHS risk analysis is required and include this in the CAPA process.
Appendix Table 28 Corrective and Preventative Action report
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Figure 4.3 Corrective and Preventive Action Process Flow Chart
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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 KCRWTF 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 KCRWTF 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.
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Process Description
Detailed Management Review 1. Schedule detailed management review meetings at least annually to review and assess the
performance of the KCRWTF 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.
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Figure 5.1 Management Review Flow Chart
Appendix
Table 29 Management of Change Form Table 30 Core Team Meeting Record Form
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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
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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 KCRWTF 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.
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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 (EHS) 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. An aspect is an element that causes an impact to the environment or employee health and safety.
Sustainability (EHS) Impact – any change to the environment or employee health and safety (positive or negative) 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.
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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 KCRWTF 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
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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, KCRWTF employees, and contractors operating at the KCRWTF. External stakeholders may include local farmers who use Kentorganite, residents surrounding the KCRWTF, 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. KCRWTF – an acronym for the Kent County Regional Wastewater Treatment 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.
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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
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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 KCRWTF 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 KCRWTF, 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.
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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 KCRWTF 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 EHS Aspect – An EHS 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 KCRWTF without physically entering the SMS fenceline.
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.
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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.
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APPENDICES
Table 1 SMS Manual and Planned Arrangements Cross-Reference
Table 2 Determination of Significant EHS Hazards
Table 3 EHS Aspects Table
Table 4 EHS Significant Aspects/Risks
Table 5 List of Sources of regulations and other requirements
Table 6 Regulations applicable to KCRWTF
Table 7 KCRWTF Compliance Assessment Checklists
Table 8 Critical control points and operational controls
Table 9 Contractor Roles and Responsibilities for Compliance with the SMS
Table 10 Minimum expected qualifications
Table 11 Training Matrix
Table 12 New Operations Competency Checklist
Table 13 New Biosolids Operations Competency Checklist
Table 14 New Maintenance Competency Checklist
Table 15 Incident investigation form
Table 16 Definitions of an incident
Table 17 Emergency response summary table
Table 18 Documents Requiring Control
Table 19 Documents of External Origin Requiring Control Table 20 Records Requiring Control Table 21 Complaint/Inquiry Response Form Table 22 Current outreach activities Table 23 List of Key Performance Measures Table 24 Wastewater monitoring flowchart Table 25 Biosolids monitoring flowchart Table 26 SMS Management Plan Table 27 Internal audit checklist Table 28 Corrective and preventative action report Table 29 Management of change form Table 30 Core Team meeting record
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SMS-Manual Page 42 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
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Table 2. Determination of Significant Environmental Impacts and Occupational Health and Safety Hazards
H&S Risk What If? Consequence Operational Control
Stations flood, work in wet well
Sewage in creeks and on ground; electrocution of staff; drown in wet well
SCADA wet well alarms; lock out-tag out procedure, elevate electrical controls
Hydrogen sulfide buildup Asphyxiation Confined space procedure and Thiogard H2S suppression
Fall into wet well; fall off of ladder
Drown in wet well; physical injury from falls off ladders
Guard rails around wet wells, proper use of ladders and stairs; training, harness use
Fall into dry well Physical injury Guard rails around dry wells, proper use of ladders and stairs; training, harness use
Pump stations (Maintenance activities)
Chemical exposure Injuries due to chemical exposure Proper training; portable eye washes, gas detection on entering
PV Solar Farm Wiring breaks Electrocution SOP and limited need for maintenance Falls on stairs Injuries from falls on stairs Heating of area during winter; keeping
area dry and clean Fall into 10’ deep wastewater channel
Physical injury Secure top metal plates at one end, keep area dry and clean
Getting caught in moving equipment
Injuries from being pinched by equipment
Machine guards
Exposure to electrical equipment
Electrocution Keep areas dry and maintain electrical integrity, cross connection by-pass of screen
Influent screening
Heater malfunction Fire Keep areas dry and maintain electrical integrity, cross connection by-pass of screen
Fall on stairs, wastewater flooding chambers
Physical injury, drowning Guard rails and keeping stairs clean and dry, lock out/tag out procedure, use all safety equipment
Grit chambers
Fall into chambers Drowning Decking and harness use Fall off boat Drowning Wear life jackets and work in pairs Fall into basin from edge Drowning Life rings and rope guard Noise exposure from blowers Hearing loss Signage, wear ear muffs in blower
building
Aeration basins
Getting caught in blowers, contact with hot wire or equipment
Physical injury, electrocution Proper training; lock out-tag out procedure
Fall into full clarifiers Drowning Guard rails, harnesses, training, investigate remote cleaning system, look at design of outlets to reduce algae buildup
Fall into empty clarifier Physical injury Confined space procedure , harness training and use
Clarifiers
Exposure to electrical wires Electrocution Lock out-tag out procedure Exposure to chemicals Impaired health MSDS and training Laboratory Sampling Drowning Employee training
UV Disinfection Exposure to UV light Blindness Post signs and offer shaded glasses, covers and training
Exposure to electricity Electrocution Training design of wiring Fall into chambers Drowning Guard rails and life rings& harness
training and use Fall on stairs Physical injury Guard rails, keeping stairs dry and clean
Biosolids storage
Fall into empty chamber Physical injury Confined space procedure; proper training on scaffolding and ladders
Getting caught in system Physical injury Lock out-tag out procedure; training; signage on pinch points, machine guarding
Filter presses
Falls on stairs and off platform
Physical injury Training; keeping stairs clean and dry; guard rails
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H&S Risk What If? Consequence Operational Control Chemical exposure Chemical injury from ferric chloride
and polymers on skin and in eyes
Eye wash and shower nearby; HAZCOM training, remove wet, slippery polymer
H&S Risk
What If? Consequence Operational Control
Lime addition Lime exposure Chemical burns Operate bag house; HAZCOM training Getting caught in machine Physical injury Lock out-tag out procedure Conveyors Hitting head on conveyor Physical injury Signage & padding Exposure to thermal fluids Chemical & Physical burns Training, safety glasses or goggles Hot piping Physical burns Signage & barriers
Thermal fluid heaters
Natural gas fire Fire Natural gas system; nearby fire hydrants Exposure to solar panel parts Physical burns Design of system and training Solar dryers Exposure to odors Physical nuisance Add lime Exposure to thermal fluids Physical burns Signage; training, safety glasses or
goggles Exposure to moving parts Physical injury Lock out-tag out procedure Falls from top of dryer Physical injury Guard rails
Dryers
Falls from stairs Physical injury Guard rails; keeping stairs dry and clean Kentorganite storage Getting hit by loader Physical injury Proper training Kentorganite transportation Truck accident Physical injury, spills Proper training; accident reporting
system, spill plan Kentorganite application Loader accident Physical injury Proper equipment training Applicator accident Physical injury Proper equipment training Kentorganite Landfill Unloading accident Physical Injury Proper equipment training
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SMS-Manual Page 45 Table 3 EHS Aspects Table
Process
Environmental Impacts
Safety Impacts Other
Wat
er
Air
Solid
Was
te
Nui
sanc
e
Ene
rgy
Ele
ctro
cutio
n
Con
fined
Spa
ce
Slip
s, tr
ips a
nd fa
lls
Mov
ing
Equ
ipm
ent
Asp
hyxi
atio
n
Hea
t
Che
mic
al E
xpos
ure
Dro
wni
ng
Reg
ulat
ed
Pretreatment 2 1 1 1 2 1 1 1 1 2 1 2 1 4 Pump Stations/Collection System (Maintenance) 2 1 2 2 4 3 3 3 1 3 1 2 3 3 PV Solar Farm 0 0 0 1 2 2 0 2 0 0 2 0 0 1 Influent Screening 1 1 3 3 1 2 1 3 2 1 1 1 1 2 Grit Chamber 1 1 2 3 2 1 2 2 1 1 1 1 1 1 Aeration Basins 3 3 2 1 5 2 2 3 1 2 1 2 4 3 Clarifiers 2 2 1 1 2 1 3 3 1 1 1 1 3 2 UV Disinfection 2 2 0 0 3 1 0 2 0 0 1 0 1 3 Biosolids storage 1 2 1 3 1 1 3 3 1 2 1 1 3 2 Filter presses 1 1 2 2 3 2 1 2 3 1 1 3 0 2 Lime addition 1 2 2 2 2 1 2 1 2 1 1 3 0 2 Passive Solar Dryers 1 1 1 1 2 1 0 1 2 0 2 1 0 1 Conveyors 1 2 2 1 2 1 1 2 2 1 1 2 0 1 Thermal heaters 1 3 1 2 4 2 3 3 2 2 4 3 0 3 Dryers 1 3 2 3 2 2 3 3 2 2 4 3 0 3 Kentorganite storage 1 2 2 4 1 1 1 1 1 1 2 3 0 2 Kentorganite transportation 2 2 2 2 1 1 1 2 1 1 1 2 0 2 Kentorganite application 2 2 2 3 1 1 1 2 1 1 1 2 0 4 Kentorganite landfilling 1 1 2 1 1 0 0 1 3 0 0 2 0 0 Laboratory 1 1 1 0 1 1 0 2 1 1 1 3 1 1
Significant
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Table 4 Significant EHS Aspects/Risks
Process Significant EHS Risks Pretreatment Regulated by EPA (R) Pump Stations/ Collection System Energy use (E) Aeration Basins Energy use (E) Aeration Basins Drowning (S) Thermal heaters Energy use (E) Thermal heaters Heat (S) Dryers Heat (S) Kentorganite storage Nuisance issues (E) Kentorganite application Regulated by DNREC (R)
(E) – Environmental (R) – Regulated (S) – Health and Safety
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Table 5 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/ Trade Organizations: Air and Waste Management Association, http://www.awma.org/
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SMS-Manual Page 48 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/
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Table 6 Regulations applicable to the KCRWTF
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
Revision No. 7 10/24/2012
SMS-Manual Page 50 Table 7. KENT COUNTY REGIONAL WASTEWATER TREATMENT
FACILITY and BIOSOLIDS PROCESSING ENVIRONMENTAL TECHNOLOGIES
COMPLIANCE ASSESSMENT CHECKLISTS
Date Conducted: Auditor:
Revision No. 7 10/24/2012
SMS-Manual Page 51
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 Registered with DNREC Permit Required BIOSOLIDS PROCESSING Scrubber
Registered with DNREC Permit Required Permit Conditions Lime Silo Registered with DNREC Permit Required Permit Conditions Comments:
Revision No. 7 10/24/2012
SMS-Manual Page 52
MEDIA: WATER Regulatory Requirements
Auditor Checks In Compliance
Not In Compliance
N/A
NPDES Permit Required Permit Conditions met 503 BIOSOLIDS Marketing Permit Required Permit Conditions met Application Permit Required Permit Conditions met 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:
Revision No. 7 10/24/2012
SMS-Manual Page 53
MEDIA: NON-HAZARDOUS WASTE Regulatory Requirements
Auditor Checks In Compliance
Not In Compliance
N/A
Scrap Metal Registered with DNREC Permit Required Permit Conditions Lab Waste Registered with DNREC Permit Required Permit Conditions Disposed per regs Screenings/Grit Registered with DSWA Approved by DSWA Approval conditions met Sampling current Comments:
Revision No. 7 10/24/2012
SMS-Manual Page 54
MEDIA: HAZARDOUS WASTE Regulatory Requirements
Auditor Checks In Compliance
Not In Compliance
N/A
Title V Permit Required Permit Conditions met 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 Storage area labeled Lab Waste Properly collected Properly labeled Properly disposed Storage area labeled Other Comments:
Revision No. 7 10/24/2012
SMS-Manual Page 55
MEDIA: AST Regulatory Requirements
Auditor Checks In Compliance
Not In Compliance
N/A
ASTs Diesel Fuel Registered with DNREC Permit Required Permit Conditions Gasoline Registered with DNREC Permit Required Permit Conditions Comments:
Revision No. 7 10/24/2012
SMS-Manual Page 56
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:
Revision No. 7 10/24/2012
SMS-Manual Page 57
MEDIA: OSHA Regulatory Requirements Auditor Checks In
Compliance Not In
ComplianceN/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
Revision No. 7 10/24/2012
SMS-Manual Page 58
MEDIA: Other Requirements Regulatory Requirements Auditor Checks In
Compliance Not In
ComplianceN/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:
Revision No. 7 10/24/2012
SMS-Manual Page 59 Table 8 Critical control points and operational controls
EHSA’s Critical
Control Points Operational Controls
Industrial – Significant Industrial User discharges Sewer use ordinance and regulations – Kent County Code Chapter 180, Section 180-12. Pretreatment Standard Operating Procedures Issue SIU permits
Commercial user discharges Sewer use ordinance and regulations – Kent County Code Chapter 180, Section 180-13. Fats, Oils and Grease (FOG) workshops Food Service Facility Permits
Wastewater Collection (Pump Stations) and Pretreatment
Pump Stations Preventive maintenance Maintenance SOP’s
Solids screening / grit collection Operator skills, training and licenses Operations Standard Operating Procedures SCADA
Wastewater Treatment, specifically: aeration basins
Aeration Basins
Operator skills, licenses and training Operations Standard Operating Procedures Lab operations SCADA
Revision No. 7 10/24/2012
SMS-Manual Page 60
EHSA’s Critical
Control Points Operational Controls
Dewatering – Class A product - “End product” meets specifications/
percent solids
BIOSOLIDS PROCESSING Standard Operating Procedures 40 CFR 503 regulations DNREC Marketing and Distribution Permits
Lime stabilization - Quality of add mix of chemicals / lime - Mixture consistency - Mixture pH and temperature - Mixture detention time - “End product” meets regulatory
requirements - Any regulatory/permit requirements that
identify specific locations/activities that need to be managed
Operator skills and training Biosolids Standard Operating Procedures 40 CFR 503 regulations DNREC Air Permits DNREC Biosolids Marketing and Distribution Permits
Thermal heating and drying systems – Class A Product
- Temperature - Detention time - Stack emissions - “End product” meets regulatory
requirements - Any regulatory/permit requirements that
identify specific locations/activities that need to be managed
Operator skills and training BIOSOLIDS PROCESSING Standard Operating Procedures DNREC Air Permits 40 CFR 503 regulations DNREC Marketing and Distribution Permits
Solids Stabilization, Conditioning and Handling, specifically thermal heaters and dryers and solar dryers
Solar Dryers – Class A Product
- “End product” meets specifications/percent solids
BIOSOLIDS PROCESSING Standard Operating Procedures 40 CFR 503 regulations
Solids Storage and Transportation
Solids storage - Any regulatory/ permit requirements that
identify specific locations/activities that need to be managed
Operator skills and training All Kentorganite storage is on site and under cover until it is moved to local farms Agricultural Operations Standard Operating Procedures 40 CFR 503 regulations DNREC Marketing and Distribution Permits
Revision No. 7 10/24/2012
SMS-Manual Page 61
EHSA’s Critical
Control Points Operational Controls
Solids transportation - Truck - Truck cover - Transportation route - Truck cleaning facilities - Any regulatory/permit requirements that
identify specific locations/activities that need to be managed
Operator skills and training Agricultural Operations Standard Operating Procedures 40 CFR 503 regulations DNREC Marketing and Distribution Permits
Biosolids End Use or Disposal: land application
Land application – Class A - Application site location - Location of off loading from trucks - Interim storage/staging area - Agronomic rate - Truck cleaning on site - Any regulatory/permit requirements that
identify specific locations/activities that need to be managed
Operator skills, training and certifications Agricultural Operations Standard Operating Procedures 40 CFR 503 regulations DNREC Marketing and Distribution Permits
Biosolids End Use or Disposal when Class A product cannot be produced.
Land application – Class B - Application site location - Location of off loading from trucks - Interim storage/staging area - Perimeter of biosolids application site-
setback distances from surface water/neighbors/wells
- Depth to groundwater - Agronomic rate - Truck cleaning on site - Any regulatory/permit requirements that
identify specific locations/activities that need to be managed
Operator skills, training and certifications Agricultural Operations Standard Operating Procedures 40 CFR 503 regulations DNREC Marketing and Distribution Permits DNREC Biosolids Land Application AGU Permits (Class B)
Biosolids End Use or Disposal when land application is not possible
Landfilling - Location of offloading - Landfill location - Landfill operation (DSWA)
DSWA approval letters
Revision No. 7 10/24/2012
SMS-Manual Pa e 62 g
Table 9 Contractor Roles and Responsibilities for Compliance with the Sustainability Management System (SMS)
Contractors are required to: Policy Requirements– Understand the EHS Biosolids Policy •
SMS Policy Conform to the NBP’s Code of Good Practice and the SMS • • Planning Req. - Understand the environmental impacts of activities performed. • Environmental Understand the occupational health and safety hazards and risks involved
Aspects/Occupational with the activities performed. Health and Safety Understand the environmental impacts of the critical control point in the •
Risks/Critical Control area of contracted services. • Points Perform applicable monitoring and measurement of performance toward
environmental and occupational health and safety. • Legal Compliance and Remain in compliance with all applicable federal, state, and local legal other Requirements 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 KCRWTF 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 Be prepared to participate in public participation activities at the request of in Planning and the KCRWTF, including information meetings/hearing,
presentations/questions from Levy Court and other officials, and Communication other circumstances as deemed necessary and beneficial by the KCRWTF
• Communicate SMS requirements to contractor’s staff. • Effectively communicate with KCRWTF staff regarding details of
the applicable activities. • Ensure staff receives accurate information from the KCRWTF. • Communicate the records and reporting requirements with KCRWTF 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, KCRWTF, or applicable County program or project.
• Understand that all relevant information applicable KCRWTF 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 & Clearly understand contractor’s roles and responsibilities as it relates to Operation – SMS requirements and the contracted activity, including record Roles & keeping, communication, safety, emergency response, legal obligations, Responsibilities and other requirements.
Revision No. 7 10/24/2012
SMS-Manual Pa e 63 g
• Competence, Ensure that contractor’s staff learn, disseminate, and apply to daily Training, and operations the following: Awareness 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 KCRWTF to field staff. 5. Emergency response and spill response procedures. 6. Operational recordkeeping and data logging activities. 7. The KCRWTF’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, Apply a document control system to contractors SOPs and comply with Document Control, & Wastewater Utility’s requirements for all records and reports. Recordkeeping Record, maintain, and control all documents applicable to KCRWTF 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 Document the training of their staff and, if appropriate, conduct drills, Preparedness & especially on the following: Response 1. Applicable emergency preparedness and response procedures
2. Spill response procedures and training. 3. Other specified training.
• Checking, Maintain procedure for the prevention and corrective actions for Measurement, and nonconformance with the SMS, service agreements, operational Corrective Action – controls, legal and other requirements, emergency situations, this Preventive and document, and other requirements as deemed necessary by KCRWTF
management Corrective Actions • Internal Audit Understand that your performance as it relates to conformance with the
SMS may be audited internally by KCRWTF staff or individuals as designated by management. The internal audit shall allow the KCRWTF 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 Understand the KCRWTF management may review contractor’s Periodic Management performance as it relates to SMS requirements and project Review of performance measurements. Performance
Table 10 Minimum Expected Qualifications
Position Education Experience Special Requirements Plant Secretary High School/GED 1 year None Mechanic I High School/GED 1 year None Mechanic II High School/GED 1 year None Electrician I High School/GED 1 year Basic Electrical License Electrician II High School/GED 1 year Master Electric License Wastewater Operator High School/GED 1 year Operator’s Level I
License Heavy Equipment Operators
High School/GED 2 years CDL, Class A driver’s license Weighmaster’s License
Engineering Technician High School/GED 1 year CET Environmental Technician
High School/GED 1 year CET
Laboratory Technician High School/GED 1 year None Operations Supervisor High School/GED 4 years Operator’s Level IV
license Maintenance Supervisor High School/GED 4 years Operator’s Level IV
license Laboratory Foreman BS Chemistry or
Engineering 4 years None
Operations Superintendent
High School/GED 4 years Operator’s Level IV license
Environmental Program Manager
BS in Environmental or Engineering
4 years PE license
Assistant PWD BS in Environmental or Engineering
4 years PE license
Revision 1 10/21/2010
Table 11 Training Matrix
Job
Title
EMS
Aw
aren
ess
Lock
out
/Tag
out
Con
fined
Spa
ce
Haz
ard
com
mun
icat
ion
RM
P
Blo
od B
orne
Pat
hoge
ns
Exca
vatio
n an
d tre
nchi
ng
Acc
iden
t pre
vent
ion
CPR
/Firs
t aid
Emer
genc
y re
spon
se
PPE
Spill
Con
trol
Fall
prot
ectio
n
Fire
pre
vent
ion
and
resp
onse
Hea
ring
cons
erva
tion
Flam
mab
le/C
ombu
stib
le L
iqui
ds
Hot
wor
k
Pest
icid
es
Uni
vers
al W
aste
Res
pira
tors
Environmental Program Manager
X X X X X X X X X X X
Assistant PWD - Wastewater
X X X X X X X X X X X
WWF Facilities Superintendent
X X X X X X X X X X X
WWF Operations Foreman
X X X X X X X X X X X X X X X X
WWF Maintenance Foreman
X X X X X X X X X X X X X X X X X
Laboratory Foreman X X X X X X X X X X X X X Electrician X X X X X X X X X X X X X WWF Plant Operator X X X X X X X X X X X X X X X Laboratory Technician X X X X X X X X X X X X X Engineering/ Environmental Technician
X X X X X X X X X X X X X X
Heavy Equipment Operator
X X X X X X X X X X X X X X X
Maintenance Mechanic X X X X X X X X X X X X X X X X X X Plant Secretary X X X X X
Table 12 New OJT Employee Checklist - Operations Employee Name:
Task Approved by Date Cleaning influent screens Completing checklists Responding to alarms Adjusting blowers Measuring sludge blankets
Revision 1 10/21/2010
SMS-Manual Page 67
Revision No.7 10/24/2012
Table 13 New Biosolids Operator Competency Checklist New Employee Name:
Task Approved by Date Starting Sludge Pump Stopping Sludge Pump Starting Plant Water Booster Pumps Stopping Plant Water Booster Pumps Starting Filter Press #1 Stopping Filter Press #1 Starting Filter Press #2 Stopping Filter Press #2 Starting filter presses #3 Shutting down filter presses #3 Ferric Dilution Water Starting Ferric Pump Stopping Ferric Pump Mixing polymers Starting polymers Dosing Pump Stopping Polymer Dosing Pumps Responding to alarms Starting lime auger Shutting down lime auger Starting Lime Vibrator Stopping Lime Vibrator Starting conveyors Shutting down conveyors Expansion Tank Level and Fill Pump Starting Boiler Circulation Pump Stopping Boiler Circulation Pump Starting boiler Burner/Blower Shutting down boilers Burner/Boiler Starting Scrubber Water Supply Stopping Scrubber Water Supply Starting Scrubber Blower Stopping Scrubber Blower Starting dryers Shutting down dryers Emergency shutdown procedures Completing checklists
SMS-Manual Page 68
Revision No.7 10/24/2012
Table 14 New OJT Employee Checklist – Maintenance (including Plant Maintenance) Employee Name:
Task Approved by Date Starting pumps Shutting down pumps Isolating pumps Cleaning pumps Responding to alarms Responding to customer complaints Cleaning air relief valves Replacing pumps
SMS-Manual Page 69
Revision No.7 10/24/2012
Table 15 INCIDENT INVESTIGATION FORM Date of Incident: Time of Incident: Date Reported: Reported to: Reported by: Type of Incident: Other (specify) ڤ Accident ڤ SSO ڤ Release ڤ Fire ڤ Spill ڤ Describe Incident: Describe Response to Incident: Describe Suspected Cause of Incident: Root Cause: Human Error Mechanical Failure Inadequate Design Inadequate Training Mgt. System Failure Incorrect Procedures Weather Act of God Suggested Corrective Action(s): Time Frame and Expected Costs for Corrective Actions: Department Supervisor Asst. Public Works Director Wastewater Date Date
SMS-Manual Page 70
Revision No.7 10/24/2012
Table 16 Definition of an Incident
Incident
Accident Other events
• Personal injury • Personal illness • Events resulting
in property damage
• Events resulting in economic loss
Near Misses
• Violation of permits • Constituent complaint • Sanitary sewer overflow • Environmental release/spill • Safety violation • Pump station alarms that
set off claxon in Admin. Bldg.
• Fire • Force main break • Biosolids quality event
involving any of the major production components
• Major WTF component equipment failures
SMS-Manual Page 71
Revision No.7 10/24/2012
Table 17 EMERGENCY RESPONSE SUMMARY TABLE
Type of Emergency Applicable Emergency Plan Latest Revision Date
Last Tested Date
Fire/Explosion KC Safety Handbook 2/27/2003 Petroleum/Liquid Hazardous Material Spill
SPCC Plan
Sanitary Sewer Overflow SOP – M & AOps 11/01/2005 Chlorine Release RMP 9/2006 SO2 Release RMP Kentorganite Spill SOP – M & AOps 11/01/2005 Accidents KC Safety Handbook 2/27/2003 Unable to Process Kentorganite
SOP – M & AOps, KC Sludge Mgt. Manual
11/01/2005 11/2007
Power Failure SOP – Operations/Lab SOP – M & AOps
11/01/2005
SMS-Manual Page 72
Revision No.7 10/24/2012
Table 18 Documents Requiring Control
Document Name Master Copy Location Responsible Person
SMS Manual SMS Files Environmental Program Manager
SOP’s for Operations Operations Supervisor Operations Supervisor files 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
Plant Secretary’s files As assigned Contractor Service Agreement SCADA Network Server Electrical Foreman SMS Policy SMS Manual Environmental Program ManagerEmergency Action Plan Plant Secretary’s files Operation Superintendent
Plant conference room Operations Superintendent Process Drawings/ equipment info
SMS files and Plant Secretary’s files
Environmental Program Manager Compliance/inspection reports Safety Programs Plant Secretary’s files Operations Superintendent
SMS-Manual Page 73
Revision No. 7 10/24/2012
Table 19. Documents of External Origin Requiring Control
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 20 Records Requiring Control SMS-Manual Page 74
Revision No. 7 10/24/2012
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 75
Revision No. 7 10/24/2012
Table 21 Complaint/Inquiry Response Form
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 76
Revision No. 7 10/24/2012
Table 22 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 77
Revision No. 7 10/24/2012
Table 23 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 78
Revision No. 7 10/24/2012
SMS-Manual Page 79
Revision No. 7 10/24/2012
SMS-Manual Page 80
Revision No. 7 10/24/2012
Table 26 SMS Management Plan
Obj
ectiv
e
Tar
get
EH
S M
gt.
Prog
ram
T
ask
Res
pons
ibl
e Pa
rty
Prop
osed
D
ate
Dat
e
Com
plet
ed
a. Reduce air pollution Reduce Greenhouse Gas
(GHG) emissions by 25% from CY 2010 levels
12/31/2015
Issue Annual report Jim Newton
3/31/2013
Develop GHG emission reduction strategy
Jim Newton
12/31/2013
Develop budget to meet strategy
Hans Medlarz
12/31/2014
Implement GHG reduction strategy
Keith Powell
12/31/2015
b. Reduce fossil fuel usage Reduce natural gas
usage by 30% from CY 2008 levels
12/31/2017
Design complete solar biosolids dryer system
Hans Medlarz
12/31/2014
Install complete solar biosolids dryer system.
Hans Medlarz
12/31/2017
Switch to 25% renewable energy sources
12/31/2015
Study blower energy efficiency options
Hans Medlarz
12/31/2013
Implement Blower energy efficiency options
Keith Powell
12/31/2015
c Remain below Title V threshold Reduce NOx air
emissions from dryers by 80% from CY2010 levels
12/31/2017
Design additional Parkson Thermo-System solar dryers and updated thermal dryers
Hans Medlarz
12/31/2014
Obtain financing for additional dryers
Hans Medlarz
12/31/2015
Construct additional solar dryers and next generation of thermal dryers
Hans Medlarz
12/31/2017
d. Meet publicly accepted TMDL and consequently improve biosolids quality
12/31/2015
Meet phosphorus TMDL limits in new permit, 95% of time
12/31/2015
Construct new clarifiers and phosphorous removal filters
Hans Medlarz
12/31/2014
Conduct PCB Pollution Minimization Plan
Jim Newton
12/31/2014
SMS-Manual Page 81
Revision No. 7 10/24/2012
Obj
ectiv
e
Tar
get
EH
S M
gt.
Prog
ram
T
ask
Res
pons
ible
Pa
rty
Prop
osed
D
ate
Dat
e
Com
plet
ed
Establish SIU phosphorous local limits
Jim Newton
12/31/2013
Continue to acquire land around site for land application
Hans Medlarz
12/31/2015
Study using treated water for irrigation on nearby farms
Hans Medlarz
12/31/2015
e. Develop and implement a long range biosolids strategy
12/31/2017
Switch 30% of the biosolids generated by the KCRWTF from land application on farmland to either wood pellet substitute or as a biofuel in a cement kiln
Modify distribution and marketing permit to allow these options
Keith Powell
12/31/2013
Test wood/biosolid pellet concepts at plant
Jim Newton
12/31/2013
Design full solar biosolids dryer system
Hans Medlarz
12/31/2013
Install full scale system Hans Medlarz
12/31/2017
Solicit farmer cooperation in land applying Kentorganite
Nyle Callaway
12/31/2017
Solicit cooperation of wood pellet distributors
Keith Powell
12/31/2017
f. Reduce the use of man-made chemicals
12/31/2017
Reduce the use of lime by 30% from CY 2008 levels
Install passive solar biosolids drying system and send product to cement kiln as coal substitute or use as wood pellet substitute
Hans Medlarz
12/31/2017
Reduce the use of ferric chloride in biosolids processing area by 90% from CY 2008 levels
Install passive solar biosolids drying system and send product to cement kiln as coal substitute
Hans Medlarz
12/31/2017
g. Reduce the use of electricity 12/31/2015 Reduce overall electric
usage for the plant by 25% from CY 20010 levels
Study blower energy efficiency options
Hans Medlarz
12/31/2013
Implement blower energy efficiency options
Keith Powell
12/31/2015
Install induction lights in Biosolids
Billy Vincent
12/31/2013
SMS-Manual Page 82
Revision No. 7 10/24/2012
O
bjec
tive
Tar
get
Env
iron
men
tal
Man
agem
ent
Prog
ram
Res
pons
ible
Pa
rty
Prop
osed
Dat
e
Dat
e
Com
plet
ed
h. Improve employee health and safety
12/31/2013
Reduce the total recordable case incident rate to below the industry average of 4.0
12/31/2013
Reduce the use of man-made chemicals
Keith Powell
12/31/2013
Investigate all safety accidents and determine appropriate preventive actions
Keith Powell
12/31/2013
Continue to evaluate safety at pump stations
Al Porreca 12/31/2013
Reduce exposure to excessive heat in biosolids area
Install passive solar biosolids drying system and send product to cement kiln as coal substitute or wood pellet substitute and new thermal dryers
Hans Medlarz
12/31/2017
Eliminate exposure to natural gas in biosolids area
Install passive solar biosolids drying system and send product to cement kiln as coal substitute or wood pellet substitute and install new thermal dryers
Hans Medlarz
12/31/2017
i. Improve stakeholder involvement 12/31/2016 Build environmental and
energy education center
Determine feasibility of center
Jim Newton
12/31/2013
Design center Hans Medlarz
12/31/2014
Obtain sponsorship Jim Newton
12/31/2014
Build center Hans Medlarz
12/31/2016
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Revision No. 7 10/24/2012
Table 27 Internal Audit Checklist
Date of audit: Auditors:
Item Suitable Adequate Effective Have the significant environmental aspects been re-evaluated this year?
Have the significant health and safety aspects been re-evaluated this year?
Have the critical control points been re-evaluated this year?
Have there been changes to the operations that have required the management of change procedure?
Have all employees received annual EMS training?
Are environmental objectives on schedule? Have environmental targets been met or modified with a logical explanation given for missed dates?
Are health and safety objectives on schedule? Have health and safety targets been met or modified with a logical explanation given for missed dates?
Are biosolids objectives on schedule? Have biosolids targets been met or modified with a logical explanation given for missed dates?
Are EMP tasks assigned? Have EMP tasks been met? Have EMP tasks been modified, if appropriate? Has the Core Team conducted a management review this year?
Have the legal requirements been re-evaluated this year?
Have other requirements been re-evaluated this year?
Is the current EHS policy effective wrt? Compliance Consistent with NBP Code of Good Practices
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Revision No. 7 10/24/2012
Item Suitable Adequate Effective Promotes continual improvement Readily communicated Promote pollution prevention, energy conservation and effective H&S practices
Has a compliance assessment been conducted in the past year?
Is the NBP Code of Good Practice posted? Is each principle of the NBP Code of Good Practice followed?
Compliance Product that meets 503 Class A definition EMS operating as intended Quality monitoring conducted Good housekeeping in biosolids area Emergency plans Commitment to sustainable and environmentally acceptable biosolids management practices
Preventive maintenance practiced Continually improved Effective communications Are efforts made to continually improve the SMS process?
Is the SMS information readily shared? Are pollution prevention, energy conservation and employee health and safety practices followed?
Have all corrective actions been completed or are on schedule?
Is the Pretreatment Program working to protect the WWTP?
Are all SIUs permitted and inspected at least annually?
Are all SIUs monitored monthly? Are all restaurant inspected annually and properly permitted?
Notes:
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Revision No. 7 10/24/2012
Table 28 Corrective and Preventive Action Report (CPAR) CPAR No. PART A Initiation Initiator: Date: PART B Corrective Action (immediate action to fix problem):
Completed by: Date: PART C Cause of Problem (if system problem exists) Equipment Failure
Incorrect Procedure
Procedure Not Followed
Maintenance Failure
Contractor or Supplier Error
Design Failure
Management Error
External Conditions
Act of God
Communications Failure
Other Factors:
Determined by: Date: PART D: Corrective Action Plan Actions: Responsible party Timing PART E Closure Action taken is effective Yes No Verified by: Date:
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Revision No. 7 10/24/2012
Table 29 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 Foreman Date: Assistant Public Works Dir. – Wastewater Date: Environmental Program Manager
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Revision No. 7 10/24/2012
Table 30 CORE TEAM MEETING RECORD Date: Attendance: Al Porecca Hans Medlarz Chris Austin Jim Newton Billy Vincent Keith Powell 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: