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NATIONAL BIOSOLIDS PARTNERSHIP LOUISVILLE GREEN MANAGEMENT SYSTEM INTERNAL AUDIT REPORT LOUISVILLE & JEFFERSON COUNTY METROPOLITAN SEWER DISTRICT LOUISVILLE, KY Audit Report Date June 13, 2017 Audit Conducted By Sandra Conner, CIA Jennifer Garland-Waters Audit Date June 6, 2017 Report Written By Sandra Conner, CIA

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Page 1: NATIONAL BIOSOLIDS PARTNERSHIP LOUISVILLE GREEN … · Partnership (NBP’s) Code of Good Practice, and NBP Minimum Conformance Requirements for the 17 Elements (“Elements”)

NATIONAL BIOSOLIDS PARTNERSHIP

LOUISVILLE GREEN MANAGEMENT SYSTEM INTERNAL AUDIT REPORT

LOUISVILLE & JEFFERSON COUNTY METROPOLITAN SEWER DISTRICT

LOUISVILLE, KY Audit Report Date June 13, 2017 Audit Conducted By Sandra Conner, CIA Jennifer Garland-Waters Audit Date June 6, 2017 Report Written By Sandra Conner, CIA

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LOUISVILLE GREEN MANAGEMENT SYSTEM FINAL AUDIT REPORT

Louisville and Jefferson County MSD Internal Audit #09

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TABLE OF CONTENTS

AUDITOR’S OPINION STATEMENT .............................................................................. 3

1. SUMMARY ............................................................................................................... 3

1A. AUDIT SCOPE ................................................................................................... 3

1B. SUMMARY OF AUDIT FINDINGS............................................................... 4

1C. REPORT DISTRIBUTION PLAN ................................................................. 5

2. AUDIT DETAILS ...................................................................................................... 5

2A. AGENCY DETAILS...................................................................................... 5

2B. DEFINITIONS .............................................................................................. 5

2C. REFERENCE MATERIALS ......................................................................... 6

3. EFFECTIVENESS REVIEW..................................................................................... 6

4. DETAILED AUDIT RESULTS .................................................................................. 9

5. APPENDICES ........................................................................................................ 16

5A. LIST OF REQUESTED RESOURCES ............................................................ 16

5B. LIST OF REVIEWED DOCUMENTS................................................................ 16

5C.AUDITOR QUALIFICATIONS .......................................................................... 19

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LOUISVILLE GREEN MANAGEMENT SYSTEM FINAL AUDIT REPORT

Louisville and Jefferson County MSD Internal Audit #09

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AUDITOR’S OPINION STATEMENT Louisville and Jefferson County Metropolitan Sewer District (MSD) continues its commitment to compliance with the Biosolids Management Policy, National Biosolids Partnership (NBP’s) Code of Good Practice, and NBP Minimum Conformance Requirements for the 17 Elements (“Elements”). MSD’s Louisville Green Management System (“LGMS” / “System”) appears well maintained and functioning at a mature level. The results of this audit did not identify any nonconformance issues. Since MSD received the NBP certification on July 31, 2008, MSD’s System has undergone seven (7) third-party external audits and twelve (12) internal audits. The Louisville Green Management Team has always taken conformance to NBP’s requirements seriously; they implement recommended corrective actions timely and manage the System optimally with available resources. 1. SUMMARY The Internal Audit Team conducted the twelfth internal audit of the System. MSD uses the system in managing its biosolids program at the Morris Forman Water Quality Treatment Center (MFWQTC). Internal Audit conducted the onsite portion audit on June 6, 2017. The objective of this internal audit is to evaluate the effectiveness of Metropolitan Sewer District’s Louisville Green Management System; compliance with MSD’s Biosolids Management Policy (effective August 25, 2014); and compliance with the National Biosolids Partnership’s Code of Good Practice.

1A. AUDIT SCOPE In accordance with NBP requirements for internal audits, this audit included a review of the following topics:

Progress Toward Goals and Objectives

LGMS Outcomes Environmental Performance Regulatory Compliance Relations with Interested Parties Quality Biosolids Management Practices

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LOUISVILLE GREEN MANAGEMENT SYSTEM FINAL AUDIT REPORT

Louisville and Jefferson County MSD Internal Audit #09

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Actions Taken to Correct Minor Nonconformance

Management Review Process

Preventive Action Requests and Responses

Corrective Action Requests and Responses

The NBP has developed a blueprint that sets forth the important principles and goals which govern the operation of environmentally sustainable biosolids management systems. The NBP developed 17 Biosolids Management System Elements to define the specific expectations and requirements; the performance of these activities the NBP believes to be important for ensuring that the performance of the biosolids management activities is environmentally sound and publicly accepted manner.

The following elements were reviewed to adequately address the NBP requirements included in the scope of the audit as listed above.

Element 1: Biosolids Management Program (BMP) Manual

Element 2: Biosolids Management Policy

Element 5: Goals and Objectives

Element 6: Public Participation in Planning

Element 7: Roles and Responsibilities

Element 9: Communications

Element 11: Emergency Preparedness and Response

Element 12: BMP Documentation and Document Control

Element 14: Nonconformances: Preventative & Corrective Action

Element 15: Biosolids Management Program Report

Element 16: Internal BMP Audits

Element 17: Management Review

1B. SUMMARY OF AUDIT FINDINGS This audit identified (1) positive observation, one (1) opportunity for improvement, and no (0) nonconformance. Audit results and management responses are in Section 4 of this report.

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Louisville and Jefferson County MSD Internal Audit #09

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1C. REPORT DISTRIBUTION PLAN Internal audit team members shall submit a Draft Internal Audit Report of their findings to the Process Support Supervisor within thirty (30) days completion of onsite audit work. The Process Support Supervisor shall provide a corrective action plan to the lead auditor within thirty (30) days of the receipt of the draft report. The Lead Auditor shall provide a Final Internal Audit Report including the corrective action plan and management comments within ten (10) days of receipt of the corrective action plan. The Process Support Supervisor may distribute the Draft and Final Internal Audit Report to members of MSD management and staff as appropriate.

2. AUDIT DETAILS 2A. AGENCY DETAILS

Agency Name: Louisville and Jefferson County MSD

Address: 4522 Algonquin Parkway, Louisville, KY Volume of Wastewater

Treated: 120 MGD Average, 330 MGD Peak

Biosolids Produced: 25,000 dry tons per year Number of Employees: 90

Contractors Audited: None MSD Internal Audit Team: Sandra Conner, CIA – Internal Auditor Jennifer Garland-Waters – Staff Auditor I Joe Falleri, Process Supervisor

Auditor Qualifications are in Appendix 5C.

2B. DEFINITIONS

Positive Observation: Recognition of an area in the biosolids management system that should be recognized for outstanding achievements and/or exceptional features.

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Louisville and Jefferson County MSD Internal Audit #09

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Opportunity for Improvement: A program element that conforms to requirements outlined in the Elements, but which may be improved by following suggestions, examples, or benchmarks cited by the auditor.

Major Nonconformance: An issue that occurs when one of the elements in the Elements has not been addressed or has not been addressed adequately. Major nonconformances can occur when an organization has documented a process or procedure, but has not implemented it or cannot demonstrate effective implementation; when a number of minor nonconformance’s in a given activity or element point to a systemic failure; when an element is being disregarded sufficiently during organization operations that it is having a noticeable effect on the organization's environmental compliance, environmental impacts, or the quality of the material being produced – there is a gap or problem that could lead to a systemic failure. Minor Nonconformance: An issue that, when taken by itself, does not indicate a systemic problem with the Program. It is typically a random or isolated incident. Minor Nonconformance involves discrepancies within an element of the Elements that do not significantly affect the implementation of the Program and commitment to conform to the Code of Good Practice – a systemic problem is not indicated.

2C. REFERENCE MATERIALS

The following materials were used as a reference by the auditors during the internal audit:

MSD LGMS Manual (2017 Version 1)

NBP Third Party Auditor Guidance Manual (effective August 2011)

Minimum Conformance Requirements for NBP Elements of a Biosolids Management Program (NBP Third Party Auditor Guidance Manual – August 2011)

NBP Biosolids Environmental Management System Guidance Manual (effective June 2011)

NBP National Manual of Good Practice for Biosolids (effective January 2005) 3. EFFECTIVENESS REVIEW In accordance with NBP audit requirements, the following topics were reviewed for the effectiveness of the System.

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Louisville and Jefferson County MSD Internal Audit #09

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Progress Toward Goals and Objectives The establishment and review of goals and objectives drive and guides the System’s continuous improvement efforts by defining the specific aspects performance that MSD, as well as its various interested parties, plan to target while aligning resources and efforts to maximize beneficial results. In developing program goals and objectives, the LGMS Management Team (“Management Team”) considers the critical control points of the biosolids management system, identified or potential environmental impacts, legal and other requirements, best management practices as defined by NBP, and input from interested parties. Goals and objectives are developed using SMART criteria (i.e., be Specific, Measurable, Achievable, Relevant, and Time-bounded), documented with an action plan, schedules, milestones, resources, and assigned responsibilities, and the Team meets monthly to evaluate progress and effectiveness. LGMS Outcomes The NBP has identified four areas where it has defined specific, auditable expectations for examining outcomes as important indicators of biosolids management program health. These four areas include environmental performance; regulatory compliance; relations with interested parties; and quality biosolids management practices.

Environmental Performance The System is required by NBP to identify goals and objectives to encourage continuous improvement. The Management Team redefines the goals and objectives to be consistent with the biosolids management policy as needed, assuring biosolids management activities comply with applicable laws and regulations, meet quality and public acceptance requirements, and prevent other unregulated adverse environmental and public health impacts by effectively managing all critical control points. Regulatory Compliance The System has established a robust compliance management system that effectively identifies and tracks regulatory compliance obligations, proactively identifies potential regulatory compliance issues, assures effective implementation of applicable compliance activities, quickly detects regulatory compliance problems, and addresses regulatory compliance problems in a timely fashion. Relations with Interested Parties The Management Team has set up quality, two-way flows of information with interested parties; giving the Team the capacity to understand the concerns and perspectives of interested parties. Conversely, this provides methods of effective communications to stakeholders and interested citizens regarding the key

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LOUISVILLE GREEN MANAGEMENT SYSTEM FINAL AUDIT REPORT

Louisville and Jefferson County MSD Internal Audit #09

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elements of the biosolids management system, including information about system performance. Quality Biosolids Management Practices In accordance with NBP’s Code of Good Practice, the System has implemented good housekeeping practices for biosolids production, processing, transport, and storage, and during final use or disposal operations. The Management Team has implemented sustainable, environmentally acceptable biosolids management practices and operations. The Team identified best practices in the NBP National Manual of Good Practice, and from other sources such as industry benchmarking.

Actions Taken to Correct Minor Nonconformance The Management Team is thorough in their efforts to document and address all noncompliance’s identified by internal and external auditors. The corrective action plans identify steps planned and taken to change policies, procedures, operational controls, and monitoring and measurement processes to prevent future nonconformance. Once the Team is satisfied that the corrective actions are sufficient to address the root-cause of the issue and prevent recurrence, the Team communicates the completed action plan with the internal or external auditor that issued the nonconformance to review and close out the nonconformance. Management Review Process The System undergoes annual Management Reviews conducted by members of MSD’s Executive Management Team. This review includes monitoring and measurement data, progress toward goals and objectives, internal and external audit results, conformance to NBP Conformance Requirements, and the Biosolids Management Policy. To date, the participants have consistently provided quality input and recommendations for the improvement of the System.

Corrective and Preventive Action Requests and Responses

The establishment of a systematic process for preventing and responding to nonconformance is crucial to the effectiveness of a biosolids management system; facilitating continuous improvement and helps prevent issues from occurring or recurring. The Management Team has recently improved this process by redesigning the tools used to record and track nonconformances and associated corrective action plans. The Team meets monthly to review and track the progress of any open corrective action plans.

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LOUISVILLE GREEN MANAGEMENT SYSTEM FINAL AUDIT REPORT

Louisville and Jefferson County MSD Internal Audit #09

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4. DETAILED AUDIT RESULTS

This section describes observations noted and categorized by Positive Observations, Opportunities for Improvement, Major Nonconformance, and Minor Nonconformance. The following observations were identified by the internal audit team while reviewing the Minimum Conformance Requirements outlined in the NBP Third Party Auditor Guidance Manual.

ELEMENT 2 – BIOSOLIDS MANAGEMENT POLICY

Element 2 addresses the importance for an organization to articulate and communicate clearly its vision for how the organization will conduct its biosolids management activities. An organization’s biosolids management policy establishes the guiding principles for the organization’s BMP and biosolids operations. The organization’s BMP goals and objectives, procedures and work practices, monitoring and measurement, internal auditing, and performance reporting should all align to support the organization’s efforts to meet the commitments and apply the principles established in its biosolids management policy. Opportunity for Improvement #1 The signature on the MSD Louisville Green Management System Policy is that of Greg Heitzman, previous Executive Director. Management should update the policy to reflect the signature of the current Executive Director, James Parrott. Further, upon a change in the Executive Director position, signature updates should be obtained. Management Response: Management contacted the Board Policy and Records Program Manager to request the Louisville Green Policy be reviewed. Management was informed it was already on the scheduled to be reviewed this year. The Louisville Green Policy will be presented at the July Policy Review Committee Meeting.

ELEMENT 14 – NONCONFORMANCES: PREVENTATIVE AND CORRECTIVE

ACTION

The establishment of systematic processes for preventing and responding to nonconformance’s is crucial to the effectiveness of an organization’s BMP. Such systems drive continual improvement and prevent problem situations from occurring and recurring. Element 14 outlines the requirements necessary to ensure that organizations are successful at preventing and correcting nonconformance situations.

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LOUISVILLE GREEN MANAGEMENT SYSTEM FINAL AUDIT REPORT

Louisville and Jefferson County MSD Internal Audit #09

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Positive Observation #1 The dedication of the Louisville Green Team to achieving LGMS goals and objectives is apparent in the corrective action process. The corrective action process shows a clear and concise plan to address the nonconformance in a thorough and expedient manner. Internal Audit noted the work the LGMS staff performs to keep the LGMS process effective and current.

THIRD PARTY EXTERNAL AUDIT FOLLOW-UP

1. Third Party External Audit - Minor Nonconformance Requirement 5.1

Objective 1: Implement an improved Preliminary Treatment System by December 31, 2016, to reduce the amount of debris sent to the anaerobic digesters by 10% by increasing the amount of screen and grit captured by 10% with data collection complete by December 31, 2018. Auditors Note: Objective 1 did not identify that the improvement of preliminary treatment was specifically for the Morris Forman Treatment Plant, and that the decrease of debris contributed to the digesters would be measured in tons per month of screenings and grit removed at the headworks compared with tons per month for a similar period or flow conditions. LG Team Meeting was held on 6-20-16 to discuss. The average number of tons removed over the past three years has been compiled. 500 tons is selected as the average tons per the data. Objective 1 will be changed to read:

At the Morris Forman Water Quality Treatment Center, implement an improved Preliminary Treatment System by December 31, 2016, to reduce the amount of debris sent to the anaerobic digesters by 500 tons by increasing the amount of screen and grit captured by 500 tons with data collection completed by December 31, 2018.

Objective 2: To maintain Secondary treatment characteristics of a plant effluent DO > 2.0 ppm, replace the failing High Purity Oxygen Generation System by March 31, 2017. Auditors Note: Objective 2 did not identify that the measurable target was “on no single day would the dissolved oxygen drop below 8.0 mg/l at the fourth stage of the oxygen batteries, without taking remedial measures that require supplemental oxygen.”

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LOUISVILLE GREEN MANAGEMENT SYSTEM FINAL AUDIT REPORT

Louisville and Jefferson County MSD Internal Audit #09

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LG Team meeting was held on 6-20-16 to discuss. Objective 2 changed to read:

At the Morris Forman Plant on no single day will the dissolved oxygen drop below 8.0 mg/l at the fourth stage of the oxygen batteries; without taking remedial measures that require supplemental oxygen

Objective 3: Installation of Dewatered Biosolids Conveyance System to provide for 100% redundancy by December 31, 2016. Auditors Note: Objective 3 did not specifically state that the capacity of the dewatering biosolids conveyance system would be increased by 6 dry tons per hour to provide a total capacity of 12 dry tons per hour. LG Team meeting was held on 6-20-16 to discuss. Objective 3 changed to read:

At the Morris Forman Regional Plant increase the dewatered biosolids conveyance system capacity by 6 tons per hour to provide a total capability of conveying 12 tons per hour by December 31, 2016.

Objective 4: Update the Louisville Green Website, “Home and About Us” pages, to update information to all Interested Parties by December 31, 2016 Auditors Note: Objective 4 did not meet the measurability criteria and will become reclassified as a corrective action plan for improvement. LG Team meeting was held on 6-20-16 to discuss. There is no measurable metric other than yes, or no the web page was updated. Therefore, this is not a valid goal for the management system. Objective 4 is being removed and tracked as a corrective action. Objective 5: Objective 5 was not reviewed during the External Audit as it has not been completely developed to date. Objective 5 did not meet the measurability criteria and will become reclassified as a corrective action plan for improvement. LG Team meeting was held on 6-20-16 to discuss. There is no measurable metric other than yes, or no the web page was updated. Therefore, this is not a valid goal for the management system. Objective 5 is being removed and tracked as a corrective action.

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LOUISVILLE GREEN MANAGEMENT SYSTEM FINAL AUDIT REPORT

Louisville and Jefferson County MSD Internal Audit #09

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Objective 6: Meet the Regulatory Goals for Wastewater, Biosolids, Preventable Bypasses and Stormwater Protection Plan, to include Morris Forman, Derek Guthrie, Floyds Fork, Cedar Creek and Hite Creek Water Quality Treatment Centers for the compliance period of July 1, 2015 through June 30, 2016. Auditors Note: Objective 6 did not specifically identify the objective as beneficially using 100 percent (as measured in dry tons) of the total biosolids produced. LG Team meeting was held on 6-20-1 to discuss. There is no measurable metric other than yes, or no the regulatory goals were met. Further discussion lead to the possibility of using the Environmental Management Utility goal for Biosolids beneficial use. Objective 6 will be changed to read:

At the Morris Forman Water Quality Treatment Center, send 90% of the total tons produced between January 1, 2016, and December 31, 2016, to beneficial use.

Objective 7 (new 4): Install a generator on the Final Effluent Pump Station to provide pumping capacity of 100 MGD in the event of a plant power failure when the effluent gate is closed by December 31, 2016. Auditors Note: Objective 7 did not specifically identify increasing the electrical energy supply for use at the plant by 3,000 kilowatts. (Note: the action plan required to accomplish this was determined to be the installation of a new generator.) LG Team meeting was held on 6-20-16 to discuss. Objective 7 changed to read: (This will become the new Objective 4)

To increase the resident electrical capacity of the Morris Forman Plant by 3,000 KW by December 31, 2016.

Objective 8: Install a new plant high voltage power distribution yard to provide for 100% redundancy by December 31, 2016. Auditors Note: Objective 8 did not meet the measurability criteria and will become reclassified as a corrective action plan for improvement. LG Team meeting was held on 6-20-16 to discuss.

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Louisville and Jefferson County MSD Internal Audit #09

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There measurability criteria of this objective were not adequate. Therefore, the objective is being removed and tracked as a corrective action. Noted Complete 06/22/2016

2. Third Party External Audit -Minor Nonconformance Requirement 8.1 There is no method of objectively verifying and documenting the effectiveness of operational documents training (e.g. computer software based Learning Management System).

Emailed to Third Party Auditor. The discussions with 360 Water and the decision to proceed or not to proceed will decide the time frame for the project. Not sure how long it will take 360 Water to develop this type of training and get it fully implemented. Six months to one year? Noted date: 06/27/2016 06/06/2017 UPDATE: On 5-2-17 a reorganization took place with Morris Forman Operational Staff. Staff is now dedicated to training documentation for Morris Forman. At this time it is unclear of the entire scope of their duties. It is anticipated their scope can be included to help this nonconformance. Noted date: 05/08/2017

3. Third Party External Audit -Minor Nonconformance Requirement 10.1

The Standard Operating Procedures (Operations Documents) for the Derek. R. Guthrie Waster Quality Treatment Center have not been completed.

Emailed to Third Party Auditor. The target date is an estimate based on past performance of engineering firm writing the SOPs. Timeline will be updated as progress is made.

Noted date: 06/27/2016

4. Third Party External Audit -Minor Nonconformance Element 14

The LGMS has not fully implemented identification of operational/upset occurrences at the operator level to allow preparation of corrective action plans (including root cause analyses (to be prepared).

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The current mechanism allows for anyone with Biosolids Responsibilities to submit a nonconformance, or what they believe to be a nonconformance to their direct supervisor. To help with this process, a form will be created so the operator can document the nonconformance and then submit to their supervisor. Emailed to Third Party Auditor Noted date: 06/27/2016

5. Third Party External Audit - Opportunity For Improvement Requirement 6.1 Consider developing a list of communication activities in which interested partied identified in Appendix 6A: List of Interested Parties can Participate.

Appendix 6B: List of Activities for Interested Parties has been developed. As additional opportunities arise for participation, they will be added to this list. Noted date: 06/21/2016

6. Third Party External Audit - Opportunity For Improvement Requirement 14.2

Requirement 14.2 – Opportunity for improvement – LGMS prepared a corrective action plan to address the level of Molybdenum that exceeded the federal limit required to meet exceptional quality(EQ) biosolids. This level of Molybdenum prevented the beneficial use of Louisville Green biosolids product during this timeframe. The corrective action plan (CA-62) calls for the Preparation of a Molybdenum brochure to be distributed to commercial operations to make them aware of the potential impact on the plant and the biosolids product, as well as the regulatory implications if it is not adequately controlled. It was also discussed that information seminars, or one on one discussions, be held with individual commercial customers to make them aware of what they can do to reduce the impact. The initial target deadline for the completion of the brochure was extended from March 4, 2016, to June 30, 2016. The high molybdenum levels are experienced in the spring (March) and late summer (August). The deadline for disseminating the information to reduce the spring impact was missed, and there is concern that missing another deadline will result in exceeding federal limits for molybdenum again in August of this year. Corrective action is required to be implemented immediately.

The Molybdenum Brochure is currently under design by Steve Tedders Group. Work on it has progressed but has been slow. A timeline, with the

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importance of having the brochure complete by the spring “historical flush”, was not communicated at the beginning of the project. The brochure could most likely be complete in a matter of weeks, the logistics of who, how, when and where to get the point across to the industrial users needs to be planned. Update: Sent email to Mike (Moore) asking for an update on the progress. 10-14-16 RRB. Emailed Mike to see if any feedback has been given from the industrial users concerning the brochure. RRB 11-8-16

7. Third Party External Audit - Opportunity For Improvement Element 16 Consider having a member of the operation staff participate as a member of the internal audit team.

A selection will be made before the fall internal audit. Noted Date: 06/28/2016

8. Third Party External Audit - Opportunity For Improvement Requirement 16.3 The standard requires the organization to maintain identification of the lead auditor qualifications. Element 16: Internal LGMS Audits references the responsibilities of a Certified Lead Internal Auditor in the internal audit process. Although well qualified the lead auditor who conducted the 2015 internal audit did not have the credentials of a “Certified Lead Internal Auditor.”

Until the Internal Auditor has the Certified Internal Auditor certification, Sandra Conner will be the lead auditor for the Louisville Green Management System internal audits. Internal Audit has been notified of the condition for the next Internal Audit. Noted date: 06/28/2016

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5. APPENDICES 5A. LIST OF REQUESTED RESOURCES

MSD LGMS Manual (2017 Version 1)

NBP Third Party Auditor Guidance Manual (effective August 2011)

Minimum Conformance Requirements for NBP Elements of a Biosolids Management Program (NBP Third Party Auditor Guidance Manual – August 2011)

NBP Biosolids Environmental Management System Guidance Manual (effective June 2011)

NBP National Manual of Good Practice for Biosolids (effective January 2005)

5B. LIST OF REVIEWED DOCUMENTS

Contractor Requirements – Revision 004 Source: W:\DATA\EMS\EMS Manual\6. Operational Control\Contractor

Control\Contractor LGMS Requirements

Contractor Safety Training Manual – 2015 Source: W:\DATA\EMS\EMS Manual\6. Operational Control\Contractor

Control\Contractor LGMS Requirements

Appendix 4A, List of Legal and Other Requirements – Revision 021 Source: W:\DATA\EMS\EMS Manual\4. Compliance

Appendix 4B, List of Permits and Licenses – Revision 013

Source: W:\DATA\EMS\EMS Manual\4. Compliance

Appendix 4C, List of Permit and License Due Dates – Revision 008 Source: W:\DATA\EMS\EMS Manual\4. Compliance

Appendix 4D, List of Information Sources – Revision 002

Source: W:\DATA\EMS\EMS Manual\4. Compliance

Appendix 5A, Goals and Objectives – Revision 017 Source: W:\DATA\EMS\EMS Manual\5. Improvement and

Communication\Goals and Objectives

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Appendix 6A, List of Interested Parties – Revision 012

Source: W:\DATA\EMS\EMS Manual\5. Improvement and Communication

Appendix 9A, Record of Public Input and Inquiries (04/18/2017) Source: W:\DATA\EMS\EMS Manual\5. Improvement and Communication

Appendix 3A, Critical Control Points – Revision 026

Source: W:\DATA\EMS\EMS Manual\6. Operational Control\Critical Control Points

LGMS Contractor Requirements (02/07/2017) Source: W:\DATA\EMS\EMS Manual\6. Operational Control\Contractor

Control\Contractor LGMS Requirements

Louisville Green Brochures – Updated February 2015 Source: W:\DATA\EMS\EMS Manual\5. Improvement and

Communication\Public Communication\Louisville Green Brochure\2015

http://www.louisvillegreen.com/

Appendix 14A, Corrective Action Plan Spreadsheet – Revision 84

Source: W:\DATA\EMS\EMS Manual\5. Improvement and Communication\Corrective Actions

Appendix 14B, Corrective Action Plan Form Operations Blank – Revision 002

Source: W:\DATA\EMS\EMS Manual\5. Improvement and Communication\Corrective Actions

Corrective Action Plans from External Audit #7 (#CA62-#CA70)

Source: W:\DATA\EMS\EMS Manual\5. Improvement and Communication\Corrective Actions\Active Corrective Actions

Louisville Green Program Performance Report for 2016 – Revision 001

Source: W:\DATA\EMS\EMS Manual\5. Improvement and Communication\Program Performance Reports\2016

LGMS Internal Audit Report #11 – Conducted December 2016

Source: W:\DATA\EMS Audit\2016 Audit

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LGMS Third-party Audit Report #7 – Conducted June 2016 Source: W:\DATA\EMS\EMS Manual\5. Improvement and Communication\Audits\3rd Party Audit\#7 – 3rd Party Audit – June 2016

Management Review Scope 2016

Source: W:\DATA\EMS\EMS Manual\2. Management Direction\Management Review Meetings\2017

Management Review Minutes – May 1, 2017

Source: W:\DATA\EMS\EMS Manual\2. Management Direction\Management Review Meetings\2017

Action Plan for 2016 Management Review – Revision 000

Source: W:\DATA\EMS\EMS Manual\2. Management Direction\Management Review Meetings\2017

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LOUISVILLE GREEN MANAGEMENT SYSTEM FINAL AUDIT REPORT

Louisville and Jefferson County MSD Internal Audit #09

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5C. AUDITOR QUALIFICATIONS

Sandra Conner: Internal Auditor Certified Internal Auditor

MSD Executive Offices Over 20 Years Internal Audit Experience

Jennifer Garland-Waters: Staff Auditor I MSD Executive Offices 9 Years Internal Audit Experience