Kent County Regional Wastewater Facility …SMS Manual Page No. 1 Revision No. 7 10/24/2012 Kent...

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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SMS-Manual


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

SMS Manual

Revision Number 7 10/24/2012

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



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



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



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



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



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



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.



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



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.

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



3.2 External Communication

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

Responsibilities Manager (or designee) - communicates relevant information to interested parties in respective areas of responsibility or interest.

Process Description 1. Identify interested parties which may include:

• The public • Contractors or suppliers • Regulatory Agencies

2. Communicate, at minimum, the following to interested parties: • SMS Policy • Legal and other requirements • Goals and targets • Wastewater Performance Report (including Biosolids Annual Report) • Third Party Audit Summary • Other information as necessary

3. Inform interested parties using the following methods: • Website(s) • Other forms of communication, i.e. verbal, written, or electronic.

4. Provide opportunities for interested parties to communicate their input on environmental impacts, program performance, and areas in which the Department of Public Works can improve.

5. Respond to requests for information or other inquiries in a timely manner, or if necessary, refer the inquiry to the individual with authority or knowledge to respond.

6. Bring significant exchanges of communications, determined by receiving or responding manager, to management review for documentation and follow-up response.

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

8. The Sewer Advisory Board will be used as an extension of public input with respect to all portions of the SMS. The SAB monthly operations report will provide KPM information for the use of the general public.

9. No contractors or suppliers shall be directly involved in external communications except t provide information to help 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



• 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.



Appendix

Table 23 List of Key Performance Measures

Reference



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



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.



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



Figure 4.3 Corrective and Preventive Action Process Flow Chart



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.



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.



Figure 5.1 Management Review Flow Chart

Appendix

Table 29 Management of Change Form Table 30 Core Team Meeting Record Form


SMS Manual Page No.32

Accident – undesired event related to environmental aspects or occupational health and safety risks giving rise to death, ill health, injury, or damage resulting in lost time or workmen compensation.

Action Plan – process used in the management system to achieve goals and targets, to identify resources, deadlines, responsible parties, and other details; required to effect a change or an improvement.

Activity – Something that occurs at the wastewater facility in order to transport wastewater, produce transport and apply biosolids (Kentorganite) or produce clean wastewater.

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

Auditor – competent person(s) conducting an audit.

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

Awareness Training - Training involving an overview of the purpose, scope, SMS process and importance of specific operating procedures and work instructions required under the SMS. The training will address the importance of conformance with the environmental/biosolids policy and SMS procedures and requirements, a clear understanding of their roles and responsibilities in achieving conformance, including emergency response and planning, and the awareness of significant environmental impacts of their work activities and the potential consequences of departure from specified operating procedures.

Baseline – the starting point from which the meeting of an objective can be measured, such as the number of kilowatt hours of electricity used to run the basin blowers during any given year.

Biosolids – solid organic matter recovered from a wastewater treatment process and used especially as fertilizer, usually referred to in the plural.

Biosolids Management Activities – a wide range of activities that impact quality of wastewater solids and biosolids, that include pretreatment activities, wastewater treatment processes, solids stabilization processes, conditioning and dewatering processes, transportation, storage, and beneficial use or disposal.

Calibration – the act of ensuring that data from environmental monitoring equipment used to support the SMS are accurate and reliable by comparing the readings against an established standard and adjusting the instrument to read the result accurately.

Code of Good Practice – broad framework of goals and commitments to guide the production, management, transportation, storage, and use or disposal of biosolids



Competency – the ability to use knowledge effectively and readily in execution or performance of tasks and activities; a developed aptitude or ability; the ability to do tasks competently.

Competency Training – Training involving details of the requirements for each specific job function as required under the SMS, such as SOPs, emergency response procedures, etc. to ensure that personnel performing tasks which can cause significant environmental impacts are competent

Continual Improvement – a management system process for systematically improving the SMS to achieve Department of Public Works goals and targets set forth in the City of Lawrence Administrative Policy 101: Lawrence Wastewater Management System Policy.

Core Team – The team of managers who have the ultimate responsibility for the direction and operation of the SMS. This team shall include the Public Works Director, the Assistant Public Works Director –Wastewater, the Environmental Program Manager, the Treatment Plant Superintendent, the Operations Supervisor, and the Maintenance Supervisor.

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



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.



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



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.



NBP – acronym for National Biosolids Partnership which is a not-for-profit alliance between the Water Environment Federation (WEF), the Association of Metropolitan Sewerage Agencies (AMSA), and the US Environmental Protection Agency (EPA) whose purpose is to promote safe and environmentally sound biosolids management.

National Manual of Good Practice – detailed set of guidance on the identification of critical control points and the selection of appropriate management practices published by the National Biosolids Partnership.

Near-miss – an unexpected or undesirable event that fails being defined as an accident or incident by a very small margin; determined by management and reported to management review.

Noncompliance – a deviation from federal, state, and local laws; regulations; and other compliance requirements applicable to the Department of Public Works’ activities.

Nonconformance – a deviation from the established program and management system requirements that has the potential to create a noncompliance situation, significant environmental impact, occupational health and safety hazard or risk, or public perception issue.

Occupational Health and Safety – conditions and factors that affect the well-being of employees, temporary workers, contractor personnel, visitors, and any other person in the workplace.

Occupational Health and Safety Management System – a management system that facilitates the management of occupational health and safety risks associated with the business of the organization, see OHSAS 18001:2007.

OHSAS 18001:2007 – acronym for the Occupational Health and Safety Assessment Series; uses a similar management system to International Standards.

Operational Controls – ordinances, regulations, standard operating procedures, practices, technology, instrumentation and process controls, monitoring and other criteria developed, implemented and maintained by the Department of Public Works to ensure effective management of all critical control points; including conformance with policy requirements; and achievement of goals and targets.

Other Requirements – other non-binding practices, rules, codes and environmental requirements to which the Department of Public Works subscribes as part of the SMS. Examples include binding agreements with customers, suppliers, public organizations, and commitments to “beyond compliance” performance.

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



Works’ control of environmental impacts, health and safety risks, and biosolids activities based on its policy, goals, and targets.

Pollutants – materials such as heavy metals, cyanides, solvents, and others that make wastewater and biosolids physically impure if present at certain concentrations.

Prevention of Pollution – use of processes, practices, techniques, materials, products, services or energy to avoid, reduce, or control (separately or in combination) the creation, emission, or discharge of any type of pollutant or waste in order to reduce adverse environmental impacts.

Preventive Action – specific actions and steps taken to identify, analyze, and eliminate the root causes of noncompliance and/or nonconformance and to put into place solutions that prevent a recurrence.

Public – see Interested Parties.

Public Education – systematic public communications program for educating interested parties and other stakeholders on the Department of Public Works’ activities and the 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.



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.



Third Party Verification Audit – a systematic, structured audit of the Department of Public Works’ management system; performed by a qualified independent third party auditor using a standardized protocol for verification.

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

Training – teaching to make fit, qualified, or proficient; preparation for a test of skill or knowledge; instruction in disciplines and techniques.



APPENDICES

Table 1 SMS Manual and Planned Arrangements Cross-Reference

Table 2 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 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


SMS-Manual Table 1 SMS Manual and Planned Arrangements Cross-Reference

SMS Manual

ISO14001:2004

OHSAS 18001:1999 NBP EMS for

Biosolids Section # Section # Section # Element # Preamble 4.1 4.1 1 Section 1.1 4.1, 4.4.1, 4.4.4, 4.1 1, 1A Section 1.2 4.2, 4.4.4 4.2 1B, 1C, 1.2, 6 Section 1.3 4.3.1, 4.3.2, 4.5.1, 4.5.3,4.6 4.3.1, 4.3.2, 4.3.3, 4.3.4, 4.4.6, 4.5.2, 4.6 3, 4, 5, 10, 14, 17 Section 1.4 4.4.1 4.4.1 7 Section 1.5 4.4.1 4.4.1 1F, 7 Section 2.1 4.3.1 4.3.1 3, 10 Section 2.2 4.3.2, 4.5.2 4.3.2, 4.5.1 1D, 4, 10, 13 Section 2.3 4.3.1 4.3.1 1E, 3, 10, 13 Section 2.4 4.4.6, 4.5.1 4.3.1, 4.4.6 3, 10 Section 2.5 4.4.2, 4.4.6 10 Section 2.6 4.4.1, 4.4.2 4.3.1, 4.4.2 8 Section 2.7 4.4.7 4.4.7, 4.5.1, 4.5.2 Section 2.8 4.4.7 4.4.7 1C, 11 Section 2.9 4.4.1, 4.4.2, 4.4.4, 4.4.5,4.5.2, 4.5.4 4.3.1, 4.4.4, 4.4.5, 4.5.3 4, 8, 12, 13 Section 3.1 4.2, 4.4.3 4.2, 4.3.2, 4.4.3 1C, 2, 9 Section 3.2 4.2, 4.4.2, 4.4.3 4.2, 4.3.2, 4.4.3 1C, 2, 6, 9, 15 Section 3.3 1C, 15 Section 4.1 4.3.3, 4.4.4, 4.5.1 4.3.1, 4.3.3, 4.3.4, 4.5.1 5, 6 Section 4.2 4.5.5 4.5.4 16 Section 4.3 4.5.3 4.5.2 14, 16 Section 5.1 4.4.3

3, 4 Section 5.2 5.2 4.6 17 Appendix A 4.2, 4.4.4 4.2 1B, 2 Appendix B 4.4.4 4.4.4 12 Appendix C 4.3.1 4.3.1, 4.3.2 Appendix D 4.3.1, 4.3.2, 4.5.2 4.3.1, 4.3.2, 4.5.2 1D Appendix E 4.3.1. 4.3.2, 4.4.6, 4.5.2 4.3.1, 4.3.2, 4.4.6 1E, 10 Appendix F 4.4.1 4.4.1 7 Appendix G 4.4.4, 4.4.5, 4.5.4 4.4.5, 4.5.3 4, 12


SMS-Manual

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


SMS-Manual Table 2. Determination of Significant Environmental Impacts and Occupational Health and Safety Hazards

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


SMS-Manual 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


SMS-Manual

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


SMS-Manual

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/

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

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

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

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

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

http://www.delaware.gov/

http://www.wef.org/

http://www.wef.org/

http://www.biosolids.org/

http://www.americancityandcounty.com/

http://americancityandcounty.com/index.htm

http://www.eponline.com/

http://www.ohsonline.com/

http://www.pollutionengineering.com/

http://www.pwmag.com/

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

http://www.awma.org/


SMS-Manual American Academy of Environmental Engineers, http://www.enviro-engrs.org/ American Public Works Association, http://www.apwa.net/ American Water Works Association, http://www.awwa.org/ Association of Metropolitan Sewerage Agencies, http://www.amsa-cleanwater.org/ Global Environment and Technology Foundation, http://www.getf.org/ Local Government Environmental Assistance Network, http://www.lgean.org/ National Association of Counties, http://www.naco.org/ National Association of Local Government Environmental Professionals, http://www.nalgep.org/ National Biosolids Partnership, http://www.biosolids.org/ National Registry of Environmental Professionals, http://www.nrep.org/ Public Entity Environmental Management System Resource Center, http://www.peercenter.net/index.cfm Water Environment Federation, http://www.wef.org/

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

http://www.apwa.net/

http://www.awwa.org/

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

http://www.getf.org/

http://www.lgean.org/

http://www.naco.org/

http://www.nalgep.org/

http://www.biosolids.org/

http://www.nrep.org/

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

http://www.wef.org/


SMS-Manual

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


SMS-Manual Table 7. KENT COUNTY REGIONAL WASTEWATER TREATMENT

FACILITY and BIOSOLIDS PROCESSING ENVIRONMENTAL TECHNOLOGIES

COMPLIANCE ASSESSMENT CHECKLISTS

Date Conducted: Auditor:


SMS-Manual

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:


SMS-Manual

MEDIA: WATER Regulatory Requirements


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:


SMS-Manual

MEDIA: NON-HAZARDOUS WASTE Regulatory Requirements


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:


SMS-Manual

MEDIA: HAZARDOUS WASTE Regulatory Requirements


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:


SMS-Manual

MEDIA: AST Regulatory Requirements


Not In Compliance

N/A

ASTs Diesel Fuel Registered with DNREC Permit Required Permit Conditions Gasoline Registered with DNREC Permit Required Permit Conditions Comments:


SMS-Manual

MEDIA: Hazardous Materials Regulatory Requirements


Not In Compliance

N/A

HAZCOM Written MSDS Files Training TSCA Pesticides Properly applied Trained personnel Asbestos Identified Tested Labeled PCB Identified Tested Labeled DRBC Sampling Current Submitted PMP in place EPCRA Tier II report submitted Comments:


SMS-Manual

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


SMS-Manual

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:


SMS-Manual 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


SMS-Manual

EHSA’s Critical


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


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


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


SMS-Manual

EHSA’s Critical


Solids transportation - Truck - Truck cover - Transportation route - Truck cleaning facilities - Any regulatory/permit requirements that


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


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


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


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.


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


X X X X X X X X X X X

Assistant PWD - Wastewater


WWF Facilities Superintendent


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

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


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


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


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


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



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


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


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


5 Years For the SMS manual, until replaced by a later revision

SMS-Manual


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


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


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


SMS-Manual


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


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


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

SMS-Manual


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

SMS-Manual


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:

SMS-Manual


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:

SMS-Manual


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

SMS-Manual


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:

Kent County Regional Wastewater Facility …SMS Manual Page No. 1 Revision No. 7 10/24/2012 Kent...

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