Biosolids Management System (BMS)
City of Santa Rosa Water
Subregional Laguna Wastewater Treatment Facility
Fall 2015 - Internal Audit Report
Draft Completed 12/11/2015
References
National Biosolids Partnership (NBP) Third Party Verification Auditor Guidance
NBP National Manual of Good Practice
City of Santa Rosa BMS Manual
Table of Contents
INTRODUCTION ............................................................................................................................................. 1
AUDIT SCOPE................................................................................................................................................. 1
DOCUMENT REVIEW & INTERVIEWS ............................................................................................................ 2
Reviewed documents................................................................................................................................ 2
Individuals Interviewed............................................................................................................................. 2
AUDIT RESULTS ............................................................................................................................................. 3
Non-conformances ................................................................................................................................... 3
Opportunities for Improvement ............................................................................................................... 3
Positive Observations ............................................................................................................................... 4
OUTCOMES ................................................................................................................................................... 5
2015 Goals & Objectives ........................................................................................................................... 5
CONCLUSIONS ............................................................................................................................................... 5
INTRODUCTION
The City of Santa Rosa Subregional Water Resource Recovery System is responsible for
conducting an annual Internal Biosolids Management System (BMS) Audit to maintain third
party certification of the City’s BMS Program through the National Biosolids Partnership (NBP).
The City also conducts Interim audits in years that a third party audit is not required.
The purpose of BMS program audits is to identify areas of improvement within our system prior
to and/or in between third party audits. The goal is to collect objective evidence that the City’s
BMS is performing as intended, that procedures are being performed as documented, and that
our BMS conforms to the NBP’s Code of Good Practice and internal audit program
requirements.
This audit was conducted against the standards presented by the National Biosolids Partnership
(NBP) through their Biosolids Management Program. In order to meet the NBP Requirements
the 2015 Fall Internal BMS Audit followed the procedure defined in Element 16 of the BMS
manual for this audit.
AUDIT SCOPE
The City’s BMS Fall 2015 Internal Audit of the Utilities Subregional System was conducted from
November 9 - December 4, 2015. The audit team was comprised of the following City of Santa
Rosa employees:
• Sean McNeil, Environmental Specialist (Lead Auditor)
• Shawn Sosa, Water Resources Technician
• Michelle Benson, Lab Analyst
The scope of the 2015 Internal Audit included the review of the following elements:
• Element 5: Goals & Objectives
• Element 6: Public Participation & Planning
• Element 9: Communication
• Element 14: Non-conformances – Preventive & Corrective Action
• Element 15: Biosolids Management Program Report
• Element 17: Management Review
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To determine the effectiveness of the City’s Biosolids Program the BMS, auditors reviewed the
following activities related to the identified core element requirements:
1. Progress Towards Goals and Objectives
2. Response to Non-Conformances
3. Management Review
4. Public Participation
5. Contractor Activities
DOCUMENT REVIEW & INTERVIEWS
Documents were reviewed as necessary during the audit for compliance with requirements in
the NBP’s Third Party Verification Auditor Guidance Manual, as well as conformance to the
City’s BMS Manual. The following documents were reviewed during the audit.
Reviewed documents
• City of Santa Rosa Biosolids BMS Manual
• NBP Third Party Auditors Guidance
• Biosolids Standard Operation Procedures
• Code of Good Practices
• 2015 BMS Goals & Objectives
• BMS Performance Report, March 2015
• BMS Agreements and Contracts (Poncia Fertilizer; Total Waste Systems; Jacobsen
Ranches, Inc.)
• City of Santa Rosa BMS website http://ci.santarosa.ca.us/departments/utilities/Projects/BMS/PR/Pages/default.aspx
• BMS resource flier
• General BMS flyer for events and tours
• City of Santa Rosa internal (SharePoint) Biosolids/Compost web pages
http://cityweb.srcity.org/departments/utilities/subreg/bio/Pages/default.aspx
Individuals Interviewed
City Staff
• Zach Kay, Biosolids Coordinator
• Edward Garcia, Utilities Technician
• Denise Cadman, Environmental Specialist
• Mike Prinz, Deputy Director Utility Operations
• Kathy Stokes, Principal Laboratory Analyst
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Regulators
• None
Contractors
• Andy Poncia, Poncia Fertilizer Spreading - Biosolids Spreading Contractor
• Brian Gilardi, Jacobsen Ranches Inc. - Biosolids Spreading Contractor
AUDIT RESULTS
The results of the document review and audit are described in three categories: nonconformances, opportunities for improvement, and positive observations. Non-conformances
occur when the organization has not documented a procedure sufficiently, when it cannot
demonstrate effective implementation of a procedure, when the non-conformances point to
the possibility of a systematic failure, and when isolated problems that impact the
implementation of the BMS occur. Opportunities for improvement are those that are not
sufficiently problematic to be labeled as a non-conformance but that represent potential areas
of improvement. Positive observations are made for those instances found throughout the
course of the audit that deserve recognition.
Non-Conformances
None identified.
Opportunities for Improvement
Communications
• Links in BMS manual need to be updated and point to new iNet webpage. The SOPs in
the Table 3-4 and 3-5 do not link to the documents.
• The Environmental Compliance Quality Assurance Plan that is linked in the BMS manual
is not current.
Audit Process
• Staff conducting audits for the first time should be provided a tour of the Biosolids
Program. Training should ensure that all auditors have a good understanding of the
system that they are auditing.
• Review SOPS and make sure all are current. Consider putting a last revised date on each.
In particular, the Septage Receiving SOP may need to be updated.
• May need to create a new SOP for the high strength waste program, or have it listed as
an objective under a goal.
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Public Participation
• Consider posting advertisements for the compost material in the Press Democrat and
make more compost fliers available at City sponsored events.
Positive Observations
Critical Control Points:
• The biosolids value chain is well defined in the BMS manual and staff involved in the
control points along the chain are knowledgeable about their role and how it fits into
the larger program.
• The management is highly supportive of the BMS program and is genuinely proud of the
efforts that the City takes to protect the environment and recycle the water and solids
from the wastewater system.
Public Participation:
• Public input is received via email or phone call (this information found on the public
BMS website) or at the ends of tours given either of the plant (ending at belt press cake
with a discussion of the BMS program) or the compost facility itself. There are forms
online which can be filled out in the event of a grievance, however, there has been one
in the last two years and once the customer spoke with the BMS team leaders and
became more well-informed, she no longer had any complaint and actually prefers
compost from the facility to any other.
Communications:
• Staff that were interviewed were knowledgeable about the BMS Program and were all
aware to find any necessary information such as emergency preparedness plans, critical
control points, performance points and objectives, BMS goals and objectives, and how
to track any non-conformances.
• When any employee starts employment at the Llano treatment facility, they must take a
class about BMS. Mandatory refresher courses on the BMS system are done each year
to communicate updates and insure staff remain knowledgeable about the system.
• In addition to staff, outside contractors such as haulers and farmers- are contracted to
attend a yearly BMS training. This training not only includes even the smallest detail in
updates for the year but an emergency preparedness plan and their specific
responsibilities.
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OUTCOMES
In 2015, the City’s BMS program established two goals and four objectives within those goals.
The goals and objectives were developed by the Biosolids BMS Manager and the BMS Team and
in consideration of potential public concerns. A critical component of the BMS program is to
make progress towards accomplishing a significant measure of goals and objectives. The Santa
Rosa BMS goals were established to increase energy capture from local waste streams and
increase the number of acres of farmland fertilized with biosolids. In addition, the 2014 goals
were established using Specific, Measurable, Achievable, Relevant, and Time Bound (SMART)
criteria. The City’s performance relative to each of the above outcome groups is addressed
below.
2015 Goals & Objectives
GOAL 1: Increase energy capture from community waste streams.
Objective
Status
1.1 - Design and build a high strength waste
Under construction. Commissioning is
receiving station to receive waste streams for
scheduled for April 2016.
direct injection to anaerobic digesters by January
2016.
1.2 - Install SCR emissions systems on at least
one CHP engines by July 2016.
1.3 - Upgrade digester gas flare to light
automatically when gas is being flared by
December 2014. This objective has been met.
Project is in early design stage. Construction
is expected before the end of 2016.
Complete.
GOAL 2: Increase farmland acreage by at least 75 acres for land application.
Objective
2.1 - Locate and establish agreements with
property owners to increase acreage of farmland
for land application by December 2015.
Status
Timeline extended for one more year. City hired a
Right of Way Agent to support this goal.
CONCLUSIONS
The City’s BMS team continues to make strides to improve their program. The next step is to
correct the non-conformance identified in this report. Building on the many successes of this
program and continuing to increase communication to staff and the general public should be
continuous goals for 2016. Once corrective actions have been taken, the City will verify the
results and continue to improve the BMS program.
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