Wastewater Plant Biosolids EMS Internal Audit Report City of Richmond, Virginia Wastewater Treatment Plant The wastewater treatment facility operates along the south bank of the James River. The facility is permitted to treat 45 MGD dry weather flow and a minimum of 75 MGD wet weather flow. Richmond's wastewater treatment facility serves customers in the city, Henrico, Chesterfield, and Goochland counties. The facility is one of the largest of its kind in Virginia. The wastewater utility also operates and maintains 1,500 miles of sanitary sewer, pumping stations, 38 miles of intercepting sewer lines, the Shockoe Retention Basin and McCloy Tunnel, and operates the combined sewer overflow (CSO) control program. The facility has Pretreatment, Laboratory, Technical Services, Engineering, and Financial/Administrative sections to support plant operations and maintenance.
Audit Performed By:
Audit Dates:
Wastewater Plant Internal Audit Team - Grace Lerose - Compliance Manager - Jan Wyatt - Program Manager - Donald Carter - Project Management Analyst November 4th & November 5th, 2009
Report Date:
April 23rd 2010
References:
NBP EMS Elements National Manual of Good Practice for Biosolids NBP – third Party Verification Auditor guidance – November 2002 Wastewater Plant Biosolids Environmental Management System (EMS)
List of Auditees:
Biosolids Team Biosolids Supervisor Chief Chemist Operator Superintendant II City Communications Department Facilities Superintendant Contractor
Introduction:
The Internal Audit Team investigated whether the City of Richmond's Wastewater Treatment Plant's EMS Biosolids System supports improvements in four key outcome areas. Those areas are: Quality Management Practices, Relations with Interested Parties, Regulatory Compliance & Environmental Performance. The Internal Audit Team verified those areas by performing the following: Document and Records Review, Interviews & Direct Observation.
Scope & Objectives:
The Audit Scope applies to the entire Biosolids value chain and the EMS. Our objective was to determine wheher the City of Richmond's Wastewater Treatment Plant is effectively meeting its Biosolids Management Policy, program requirements, program goals and objectives.
Wastewater Plant Biosolids EMS Internal Audit Report City of Richmond, Virginia Wastewater Treatment Plant Methodology:
Overall Evaluation:
We followed the guidelines provided in the NBP Third Party Verification Auditor Guidance Manual. We reviewed each of the EMS Elements and determined if they conformed to the NBP Elements for an EMS. We used a Question Checklist Document to cover all of the EMS Elements. The Questions came from the NBP Third Party Verification Auditor Guidance Manual. Based on our Audit Results we feel that the City of Richmond's Wastewater Treatment Plant is in material conformance with its Biosolids Management Policy, program requirements, program goals and objectives. There are opportunities for improvement that the facility representatives acknowledge and have committed to addressing. Continuous improvement is a vital part of the Biosolids EMS System and the Internal Audit Team agrees that the Biosolids EMS System is continually improving.
Element 1: Documentation Finding: The Internal Audit Team agrees that Element 1 - Documentation is in Conformance. The Biosolids Team has prepared a well written and thorough Manual. The Team has a Hard Copy as well as a Electronic Copy on the common P: Drive. Recommendation: Migrate all of the EMS documents to Sharepoint. Recommendation: Convert the entire EMS Biosolids Manual to PDF Format.
Element 2: Biosolids Management Policy Finding: The Internal Audit Team agrees that Element 2 - Biosolids Management Policy is in Conformance. The Biosolids Management Policy follows the guidelines set forth by the NBP Code of Good Practice and is communicated to employees, contractors and interested parties thru safety meetings, posters and Utility Review. Recommendation: Continue to improve our Communication efforts for the Biosolids EMS.
Element 3: Critical Control Points Finding: The Internal Audit Team agrees that Element 3 - Critical Control Points is in Conformance. The Critical Control Points are regularly reviewed, updated and tracked in a Table. Recommendation: Organize Electronic Files with a regimented File Naming Convention so that they are easy to find & organize.
Element 4: Legal and Other Requirements Finding: The Internal Audit Team agrees that Element 4 - Legal and Other Requirements is in Conformance. The Legal and other Requirements are regularly reviewed, updated and tracked in a Table. The Deputy Director & Utility Plant Superintendant are responsible for identifying & tracking the requirements. Recommendation: No formal recommendation other than continuous improvement.
Wastewater Plant Biosolids EMS Internal Audit Report City of Richmond, Virginia Wastewater Treatment Plant
Element 5: Goals and Objectives for Continuous Improvement Finding: The Internal Audit Team agrees that Element 5 - Goals and Objectives for Continuous Improvement is in Conformance. The Goals and Objectives have been identified and met. They are regularly reviewed, updated and tracked in a Table and Chart. Recommendation: Make Annual Report available to the Public by posting on the City Website or by requesting a copy.
Element 6: Public Participation Planning Finding: The Internal Audit Team agrees that Element 6 - Public Participation Planning is in Conformance. Nutriblend assists in this Element and the goals are communicated thru the City Website, Annual Reports and Utility Review. Recommendation: No formal recommendation other than continuous improvement.
Element 7: Roles and Responsibilities Finding: The Internal Audit Team agrees that Element 7 - Roles and Responsibilities is in Conformance. Roles and Responsibilities are documented in a table. Sufficient resources, funds and technical skills have been allocated to the Biosolids EMS. Recommendation: Obtain updated outreach information from Nutriblend. Recommendation: Add photos to EMS folder to better document problems.
Element 8: Training Finding: The Internal Audit Team agrees that Element 8 - Training is in Conformance. Training is performed and documented for exisiting & new employees. We also saw evidence of Contractor Training documents. The Documentation is kept in a Training Log. Recommendation: Keep training Log up to date.
Element 9: Communication and Outreach Finding: The Internal Audit Team agrees that Element 9 - Communication and Outreach is in Conformance. This is accomplished thru the City's Communication Division and the efforts of Nutriblend. Recommendation: Keep training Log up to date.
Element 10: Operation Control of Critical Points Finding: The Internal Audit Team agrees that Element 10 - Operation Control of Critical Points is in Conformance. SOP's are complete for Dewatering. Preventive and Corrective Maintenance activities are handled by Mainsaver (Maintenance System). Minor Non-Conformance: SOP's are not complete for Pre-Treatment and the Septage Hauler system. Recommendation: Complete all relevant SOP's and train accordingly.
Wastewater Plant Biosolids EMS Internal Audit Report City of Richmond, Virginia Wastewater Treatment Plant Element 11: Emergency Prepardness and Response Finding: The Internal Audit Team agrees that Element 11 - Emergency Prepardness and Response is in Conformance. SOP's are complete for Emergencies and Sewer Maintenance has the equipment ready. Nutriblend also has a spill response manual and equipment for their emergencies. Recommendation: No formal recommendation other than continuous improvement.
Element 12: EMS Documentation, Document Control & Record Keeping Finding: The Internal Audit Team agrees that Element 12 - EMS Documentation, Document Control & Record Keeping is in Conformance. All relevant Documents are written and available on the P:\ Drive. Recommendation: Organize Electronic Files with a regimented File Naming Convention so that they are easy to find & organize.
Element 13: Monitoring and Measurement Finding: The Internal Audit Team agrees that Element 13 - Monitoring and Measurement is in Conformance. Monitoring and Measurement is captured on LIMS, OP10 and various Excel Spreadsheets. Nutriblend, Microbac and other contractors records were also verified. Recommendation: No formal recommendation other than continuous improvement.
Element 14: Nonconformance - Preventive & Corrective Action Finding: The Internal Audit Team agrees that Element 14 - Nonconformance - Preventive & Corrective Action is in Conformance. Verified that procedures are being followed and corrective actions are initiated when required. Recommendation: No formal recommendation other than continuous improvement.
Element 15: Performance Report Finding: The Internal Audit Team agrees that Element 15 - Performance Report is in Conformance. Verified that procedures are being followed and corrective actions are initiated when required.
Element 16: Internal EMS Audit Finding: The Internal Audit Team agrees that Element 16 - Internal EMS Audit is in Conformance. The Internal Audit Checklist helped us verify that the Internal Audit Team covered every Element. Recommendation: Formally train at least one Internal Auditor.
Wastewater Plant Biosolids EMS Internal Audit Report City of Richmond, Virginia Wastewater Treatment Plant Element 17: Periodic Management Review of Performance Finding: The Internal Audit Team agrees that Element 17 - Periodic Management Review of Performance is in Conformance. The Internal Audit Team verified that regular Periodic Management Reviews took place. Reviewed meeting minutes & sign-in sheets. Recommendation: No formal recommendation other than continuous improvement.
Internal Audit Conclusion The Internal Audit Team reviewed the Biosolids EMS Manual and all of the 17 Elements. We have concluded that the Biosolids EMS System is in compliance. We have presented recommendations and noted minor nonconformances. Corrective actions will be initiated to correct these nonconformances.
