five ems bridges to utility sustainability

8/14/2019 Five EMS Bridges to Utility Sustainability

1/19

Five EMS Bridges to Utility SustainabilityWater Environment Federation Technical Exhibition and Conference, October 13, 2009

WEFTEC09, Orlando, Florida

Caroline G. Hemenway*

Hemenway [email protected]

Lori A. Stone, PEBlack & [email protected]

James HorneUS Environmental Protection [email protected]

AbstractWith utilities facing significant water and climate challenges, regulatory demands, tighteningbudgets, energy constraints, urban growth, increasing pollution, and aging infrastructure,traditional planning approaches fall short. How can utilities build the bridge to sustainability,and balance these competing demands, set and achieve critical program goals, and align thosegoals with programs that are perhaps already in place within their organization?

There are at least five paths utilities can take to help them along the road to sustainability andsucceed with their version of the triple-bottom-line (people, planet, profit): implement anenvironmental management system (EMS), applied in one of at least three ways ISO 14001,National Biosolids Partnership EMS, or do-it-yourself; implement a management systemdesigned to achieve outcomes based on the key attributes of sustainable utilities, endorsed bythe US EPA, WEF, and several other major water sector associations; work with state

environmental programs that often are founded on an EMS.

These approaches provide a link between a utilitys status quo and a chosen destination,building on existing practices and focusing on continual improvement. They have provenresults in the water/wastewater sector, and they fit the budget, size, and management style ofalmost any utility. Many agencies already may be on one of these paths and can access myriadresources, several available only in the last year.

KEY WORDS: Sustainability, environmental management systems, effective utilities

IntroductionWith utilities facing significant water and climate challenges, regulatory demands, tightening

budgets, energy constraints, urban growth, increasing pollution, and aging infrastructure,traditional planning approaches fall short. Time and resources can easily be depleted building abridge to nowhere. So how can utilities build the bridge to sustainability, and balance thesecompeting demands, set and achieve critical program goals, and align those goals withprograms that are perhaps already in place within their organization?


2/19

FIVE EMS BRIDGES TO UTILITY SUSTAINABILITY PAGE 2

The Process Drives EMS

Challenges Can Be Overcome Determine Your Route

There are at least five paths utilities can take to help them along the road to sustainability andsucceed with their version of the triple-bottom-line (people, planet, profit) to help them decidehow to spend their next dollar, their next man-hour, and their next commitment:

1. Utilities can implement an environmental management system (EMS), applied in one of atleast three ways: ISO 14001, National Biosolids Partnership EMS, or do-it-yourself.

2. They can implement a management system design to achieve outcomes based on the keyattributes of sustainable utilities, endorsed by the US EPA, WEF, and several other majorwater sector associations.

3. They can work with state environmental programs that often are founded on an EMS.

These approaches provide a link between the status quo and a chosen destination. They haveproven results in the water/wastewater sector, and they fit the budget, size, and managementstyle of almost any utility. Many agencies already may be on one of these paths and can accessmyriad resources, several available only in the last year.

Any approach can and should be interwoven with existing undertakings, including assetmanagement, risk management, and health and safety management. All these approaches canhelp utility staff from the top down rest better knowing they have prioritized their tasksappropriately and are better environmental stewards as a result.

The routes described in this paper will help utilities understand and access the latest tools andresources available so they can get started in a way most sensible to them, and it will providerepresentative examples of agencies that have successfully adopted the approaches. A journeyof a thousand miles must begin with a single step.

Outcome

Performance

Improvement

Objective/Target &

Action Plan

EMS

ExistingProcesses

Improve existing practices:

Identify current processes Define best practices Prioritize

Set actionable goals and measure

progress.

Begin with the end in mind.


3/19


What is Sustainability?

There are thousands of papers and presentations related to this question, and definitions ofsustainability vary widely. We will not dwell on a definition here, except to present one thatserves to frame the discussions and case studies in this paper. The UN Conference onEnvironment and Development (1992), otherwise known as the Earth Summit in Rio de

Janeiro, Brazil, essentially reaffirmed the following definition of sustainability:

A balance of economic, social, and environmental systems that meet the changing needs of thecurrent generation without compromising the ability of future generations to meet their ownneeds.

Embedded here are the ideas of endurance, interdependent systems, the progressivetransformation of economy and society, and the carrying capacity of supporting ecosystems.

A similar definition is used in the UN report, Our Common Future: Report of the World Commissionon Environment and Development, June, 1987, http://www.un-documents.net/wced-ocf.htm, andby organizations like the World Bank and the Interamerican Development Bank.

Environmental Management Systems (EMSs)An EMS is a process-efficiency approach to sustainability a way to manage practices to get themost out of an organizations resources and achieve desired outcomes. It is a dynamic methodfor evaluating processes and procedures to identify and manage the environmental footprintof an organization. Utilities use this method to look at critical operations square in the face andmake them visible warts, halos, and all. When operations are visible, they are measurable,manageable, and therefore subject to improvement.

EMS implementation and maintenance is generally done in a set of steps, often tailored toindividual business sectors, including utilities. Agencies are encouraged to become certified toan EMS by undergoing a third-party audit because it is a good way to help them maintain it.But many agencies choose to implement an EMS and conduct internal audits. Here is thestandard implementation model for an EMS:

Regardless of the EMS approach, the plan-do-check-act cycle in EMSs must be integrated intoeveryday operations to be effective, providing order and consistency in organizational methodsby allocating resources, assigning responsibility, and continually

evaluating and improving practices, procedures, and processes. An EMSdoes not impose new technical or performance requirements, but it is avoluntary tool aimed at improving overall environmental performanceand compliance with regulatory requirements. The organization can seekthird-party verification that its EMS meets objective criteria.

The most effective management systems are nearly invisible toemployees. Theyre integrated into daily life, staff meetings,management reviews, professional development, and general operations.The system and its policies and procedures are explained to staff and to the public in simple,

EMS GapsAssessment

EMS Development EMS StatusReview

EMSVerification

Audit

EMSInternal

Audit

EMSImplementation


4/19


straightforward terms. The term EMS isnt even used in many places. Documentation is keptto a useful minimum and document control is as easy as possible so the system can bemaintained. Over time, most organizations find they jettison a great deal of the wishfulthinking plans and procedures they started with and pare them down to what workseffectively. On the other hand, most organizations find they have to create written proceduresthey never had, which they often resist at first. However, they frequently find thisdocumentation improves consistency in operations and helps with training, retaininginstitutional memory, and succession planning.

It also becomes clear that there are several commonalities among organizations that successfullymaintain management systems over time: top management support based on open, multi-levelcommunication, a thoughtful environmental policy that forms the basis of the system and ofdecisionmaking, procedures to implement policyrequirements that are based on reality and are easyto understand, reasonable goals that are measurableand achievable, and an unrelenting focus oncontinual improvement.

The benefits of an EMS have been reported bygovernment, industry, and non-profit organizationsof all sizes in numerous studies worldwide:Reducing costs, boosting competitiveness,minimizing risk and maximizing environmentalperformance, improving government/publicrelations, improving operations.

It is fair to suggest that most utilities have the basicsin place, and simply need to apply EMS or similarmethods to making the system work as a whole intheir favor.

Bridge 1: ISO 14001One of the best-known EMS standards is ISO 14001,published in 1996 after undergoing an internationalconsensus process. Thousands of organizationsworldwide are certified to this standard (updated in2004), hundreds implement it without going throughcertification, and several utilities have put it intopractice, including in the entire city of Dallas TX, andthe water/wastewater utilities in Charleston SC,Lawrence, KS, and Palm Bay, FL. It is perhaps the

most prestigious of all the existing EMS standards,and has an enormous body of knowledge andtraining to support it that organizations can drawupon. Most organizations implement this standardfor entire facilities, or groups of facilities.

Because this is the most widely accepted EMSstandard upon which others are based, it is worthreviewing what its requirements are. It is also worth

Palm Bay, FL, Utilities DepartmentBond Rating Raised; Attributed to EMS

From a June 2009 Palm Bay statement:

Standard and Poors, the worlds foremost source

of credit ratings, announced in June 2009 thatPalm Bays Water and Sewer Improvement bondrating was raised from A- to A.

The higher credit rating means the utility canborrow at a lower interest rate. Jason

Yarborough, utilities director, said the creditrating can be attributed to the organizations ISO14001 environmental management systemcertification and commitment to continualimprovement.

The utility states that a structured EMS hasproduced efficiencies in sustainability in at leasttwo ways.

First, a documented lifecycle EMS fostersproactive management of environmental issuesby identifying, preventing, and correcting or

mitigating negative environmental impacts thatcan reduce risk and operational cost, and helppreserve the environment.

Second, the EMS plays an integral role in betterresource management and performance, which

has had a noticeable impact on the departmentsbottom line. The utilitys credit rating was raisedwithin one year of becoming certified to ISO14001.

The EMS also has helped the UtilitiesDepartment attain and maintain compliance with

environmental requirements and accomplish itsmission and strategic planning objectives.

The Palm Bay Utilities Department operatesthree water treatment facilities, a wastewaterfacility, and a water reclamation facility, serving

30,000 customers.


5/19


describing how it can be implemented without too much trauma, as Dallas did in three years.Below are the major components of the standard:

Dallas, Texas

We turn to the City of Dallas, which in 2008 was the first in the nation to achieve ISO 14001certification for broadscale operations. Its website details the EMS requirements in a wayanybody can understand (http://www.dallascityhall.com/oeq/ems.html):

PlanningThe overall goal of EMS planning is to set objectives and targets forimproving environmental performance. The City does this by analyzing allof the possible impacts City operations could have on the environmentand then selecting the highest priority items to focus on. An objective, forexample, might be reducing air emissions; a target (something that canbe quantified and measured) would be to reduce these emissions by,say, 10 percent per year. Along with this comes a commitment from Citymanagement to provide the resources necessary to achieve these

objectives and targets.

DoingNow comes the implementation phase. First, someone is appointed tomanage the EMS (in the Citys case, its the director of the Office ofEnvironmental Quality). This manager and others create a structure, which becomes the mechanismfor telling employees citywide about the EMS, helping them understand that their jobs have impactson the environment, and then helping them implement EMS procedures and goals in their variousworkplaces. This doing phase also includes communicating EMS goals to the community at large,having clearly written policies, procedures and records, and finally developing procedures for anyemergencies that may occur: spills, emissions, accidents and such.

CheckingFrom time to time, the City will measure how successfully it is achieving its environmental objectives.

Trained EMS auditors will routinely check the EMS to ensure that procedures are being followed andgoals met. They will bring discrepancies to appropriate managers and employees. The idea here isnot to punish, but to correct any problems and continually improve operations (a process of perpetual

learning). It also recognizes good performance and anticipates problems before they occur.

ActingThere is a formal annual review of the EMS by senior management. The process depends onmanagers asking key questions: Are we meeting our objectives and targets? Are we saving money?What changes seem necessary to help the EMS function better? They may decide that changes tothe EMS need to be made and Act to make improvements. These questions bring the entire processback again to the planning phase, and the cycle begins anew.

ISO 14001 Requirements 4.1 General Requirements

4.2 Overview and Policy 4.3 Planning

4.3.1 Environmental Aspects

4.3.2 Legal and Other Requirements

4.3.3 Objectives, Targets, andProgramme(s)

4.4 Implementation and Operation

4.4.1 Resources, Roles, Responsibility,

and Authority

4.4.2 Competence, Training, and

Awareness

4.4.3 Communication

4.4.4 Documentation

4.4.5 Control of Documents

4.4.6 Operational Control

4.4.7 Emergency Preparedness andResponse

4.5 Checking

4.5.1 Monitoring and Measurement

4.5.2 Evaluation of Compliance

4.5.3 Nonconfomirty, CorrectiveAction, and Preventive Action

4.5.4 Control of Records

4.5.5 Internal Audit

4.6 Management Review


6/19


Dallas journey began after a terrible drought in the 1950s, when it had to face the need for long-range water storage and conservation. In the 1990s, it developed a fleet of environmentalfriendly vehicles, and from there adopted strategies to promote LEED-certified greenbuildings. (LEED stands for Leadership in Energy and Environmental Design). The next stepwas to implement an EMS.

According to Grady Coomes, environmental project coordinator for Dallas Water Utilities(DWU), and Laura Fiffick, formerly director of the Office of Environmental Quality (OEQ) andnow senior sustainability programs manager with Gresham, Smith, and Partners in Dallas, thecity committed to implementing the EMS in less than three years by working backward fromthe city managers office to 11 city departments. DWU was one of them, serving 2.3 millioncustomers from two wastewater treatment plants and three water treatment plants. Thepurpose of the EMS was to:

Improve the environmental performance of the city

Enhance accountability for environmental compliance and stewardship

Drive an environmental cultural change throughout the organization

As Coomes and Fiffick describe it in a paper delivered at WEFTEC07, Implementing ISO 14001EMS Working Backward from 11 City Departments to a Water Utility at the City of Dallas , In 2002,the City of Dallas was like most other major metropolitan cities in how it focused onenvironmental issues. Each city department was individually responsible for environmentalcompliance, tracking new environmental regulations was limited and only conducted throughthe state and federal legislative process. Voluntary compliance auditing of facilities was leftto each individual facility manager but was either not conducted or only on a sporadic basis.

Following are the key components of Dallas EMS success, as related by Coomes and Fiffick.

1. Top-down management commitment In late 2002, the assistant city manager attended astate environmental agency training class on EMSs and, intrigued by the principles of the

approach, she brought the idea back to the city and got authority to begin implementing ISO14001.

2. Establishing common ground The Office of Environmental Quality (OEQ) was tasked withmaking sure there was consistency among all the departments because the idea was to receive asingle ISO 14001 certification. OEQ became responsible for developing citywide procedures,training, setting and tracking due dates, developing templates, maintaining the website,disseminating information to the public, and reporting to the city managers office. Anenvironmental policy was adopted by the city mayor, council, and manager, committing thecity to a clean, safe and healthy environment.

3. Making it manageable Each department then had to establish a fenceline within which

the EMS would operate, and allocate staff to get it done. In this pre-plan step, DWU formed acore team and allocated one environmental management representative (EMR) to work halftime on the effort (since expanded to fulltime) and liaise with the OEQ and DWU divisions. Thefenceline included the entire department and 18 divisions but mainly focused on field andtreatment operations. Support operations like material services and capital improvements wereadded later.

A gap analysis provided a baseline that revealed DWU met partial requirements of ISO 14001,but significant deficiencies existed, especially in lack of cohesion among existing environmentalactivities.


7/19


4. Creating a can-do plan All of the department EMRs met with the OEQ to develop a plan forimplementing the EMS. They looked first at current activities to determine which were mostenvironmentally significant, breaking down inputs, processes, and outputs creating processflow diagrams to identify them. Environmental aspects were scored based on their degree ofpotential for negative impacts. DWU originally identified more than 870 aspects and identified12% as being significant. It also reviewed all environmental legal requirements to evaluate riskand deficiencies in compliance. According to Coomes and Fiffick, This process allowed DWUto reduce risk with operations and come into compliance with specific air quality, waste, andworker safety requirements.

5. Establishing realistic goals The next step was to do something about the impacts anddeficiencies found during this analysis. The city developed objectives and targets andestablished management programs for all departments, and DWU identified its own 75objectives and targets, including reducing sanitary sewer overflows, increasing leak detectionprograms, decreasing emissions from vehicles, reducing water and energy consumption,reducing hazardous waste generation, preventing chemical spills, and using nonpotable waterfor irrigation. All of these were measurable.

6. Acting in unison toward desired outcomes Now that impacts and deficiencies wereidentified, a system was implemented for addressing them: evaluating performance, assigningresponsibilities, controlling operations, conducting training, and ensuring employeecompetence. A key factor in this success was a substantial training and outreach program, forwhich Dallas created an EMS logo to help brand the effort and raise awareness.

7. Measuring success The city and DWU measured key performance indicators, andconducted internal audits and complianceassessments to check on progress anddetermine if the EMS was working asintended. A reporting system maintained

inter-departmental communication and keptexecutive management in the loop. Data hadto be tracked to monitor and measure suchactivities as water use, electricalconsumptions, spills and releases, wastegeneration, recycling, air emissions, andoperational efficiencies. System audits and compliance evaluations helped close gaps andidentify areas for improvement.

8. Closing the loop A management review process that focused on senior city managementinvolvement and feedback from various staff levels provided opportunity for continualimprovement, corrective and preventive action, and appropriate resource allocation. This step

ensured top-down management commitment to the system, and brought the spiral ofimprovement up and around to the next level.

In their report, Coomes and Fiffick say that DWU estimated a cost of $141,400 and 4,620personnel hours for EMS implementation in FY 2005/2006. Realized benefits for the sameperiod included: a savings of $372,175; 240 million gallons of water; 5,125,305 KwH ofelectricity; 50 tons and 100 cubic yards of material recycled; 81 million gallons of water recycled;and reduced 792 tons of emissions.


8/19


A third-party auditor who came back a couple of years after its first certification audit would belooking at how Dallas manages change over time. The most noteworthy benefit of an EMS may beits ability to ensure agencies continuously and appropriately adjust to changing circumstances. Theprocess of continuous review requires that goals be reviewed or newly set when, inevitably,activities change or unexpected events occur. At some point in this spiral, most organizationsfind theyve moved from reactive mode to preventive mode, to the Shangri-La of executinglong-range plans.

Dallas approach is rare so far and most water and wastewater utilities are not in a positionto ask that their entire cities become certified. But it is worth noting that the method DallasDWU used was basically the same used by other departments and agencies until the entire citycomplied. And it is a common and practical method. ISO 14001 implementation is scaleable!

Charleston, South Carolina

Charleston, South Carolina Water System is a case in point. According to Rick Bickerstaff andKanwal Oberoi, Commissioners of Public Works in Charleston, in June, 1999, the utility becamethe first public utility in the nation to achieve ISO 14001 certification.

(http://www.charlestonwater.com/envrmnt_iso14001.htm)The utility appointed an EMS manager to develop an implementation plan, beginning with apolicy and procedures that drove the rest of the effort. The key people involved receivedextensive training and visited other organizations certified to the standard. The WaterDistribution Department was chosen because it had been through a re-engineering process thatrequired reviewing and revising standard operating instructions, records, and job roles, whichmeant it had much of the basis of the standard in place.

To successfully implement anyproject, you have to generateexcitement and buy-in from thoseaffected, they report. They broadcastmanagements commitment to successand provided awareness and EMStraining. They broke the project intosmall attainable goals, using tools likebulletin boards and progress charts,and posting the policy everywhere.Teamwork was essential, withstructured agendas minutes, andprogress tracking. Teams workedsimultaneously, and numerouscommunication tools such as web

pages and electronic files were used.Contractors and vendors wereincluded and new contracts includedEMS requirements.

Among the surprises was that some legal requirements they thought the utility had to subscribeto did not apply. Most of the standard procedures were already in place, but needed bettercontrol and a centralized filing location. Training programs were already in place, and regularstaff meetings were already being held. It was a matter of better organizing everything theyalready did, and filling in gaps that made sense to do anyway.


9/19


They report that ISO 4001 principles increase efficiencies, increase environmental compliance,reduce hazard liabilities, and promote technological advances. ISO 14001 also demonstrates tostakeholders its commitment to environmental stewardship.

Lets look at another case where just the utility became certified to ISO 14001, and review how itbuilt on what it already had to get started, what its immediate benefits were, and what it might

have done differently. In this case, the jumping-off point for ISO 14001 was the NationalBiosolids Partnerships EMS.

Bridge 2: National Biosolids Partnership EMSUtilities may choose to begin an EMS by implementing it in a portion of their operations:biosolids. This is an easy way to get started, and can have immediate and visible benefits, at lowcost. It can also provide an important stepping stone to an EMS that includes all wastewateroperations, providing even greater benefits to the operation.

In August 1997, the US Environmental Protection Agency (EPA), the National Association of CleanWater Agencies (NACWA, formerly AMSA), and the Water Environment Federation (WEF) joinedto form the National Biosolids Partnership (NBP), now in its 12th year. (http://www.biosolids.org)

One of the NBPs goals is to help plan and implement environmentally sound managementprograms to promote public acceptance of biosolids. Its major effort has been to develop avoluntary EMS program for wastewater agencies: a sector-specific EMS. NBP provides a large setof tools for getting started, called the NBP EMS Blueprint. It includes templates, detailedguidance documents that interpret the requirements of the program, a status review questionnaire,audit guidances, a manual of good practice, workshop summary reports, and detailed informationfrom and about utilities that have gone through the program.

This EMS differs slightly from ISO 14001 by addressing challenges specific to the biosolidscommunity. The NBP uses the term biosolids value chain to describe the sequence of eventsfrom pretreatment through final disposition of biosolids. The focused evaluation of the criticalcontrol points in a biosolids value chain is essential to developing a practical and implementableEMS. In addition, public acceptance of biosolids is crucial to a programs success, so there is arequirement for public participation that does not exist in ISO 14001. Like ISO 14001, the NBPEMS program also allows an agency to be certified based on successful completion of anindependent third-party audit. Below are the major components of the NBP program:

Today, more than 100 utilities or contractors in 35 states are participating in the NBP EMSprogram. The Department of Utilities in Lawrence, KS, Encina Wastewater Authority in Carlsbad,CA, and the District of Columbia Water and Sewer Authority are three of them. Encina and DCWASA have been certified for several years and have seen significant benefits from their biosolidsEMSs. But the Department of Utilities in Lawrence, Kansas took its program several steps

NBP Requirements Overview and Policy

Element 1 EMS ManualElement 2 Biosolids Management Policy

Planning

Element 3 Critical Control Points

Element 4 Legal and Other

Requirements

Element 5 Goals and Objectives

Element 6 Public Participation andPlanning

Implementation

Element 7 Roles and Responsibilities

Element 8 Training

Element 9 Communication

Element 10 Operational Control ofCritical Control Points

Element 11 Emergency Preparednessand Response

Element 12 EMS Documentation andDocument Control

Measurement and Corrective Action

Element 13 Monitoring and Measurement

Element 14 Nonconformances: Preventiveand Corrective Action

Element 15 Periodic BiosolidsManagement ProgramPerformance Report

Element 16 Internal EMS Audit

Management Review

Element 17 Periodic Management Review

of Performance


10/19


11/19


NBP EMS program, according to Debbie Biggs, EMS coordinator. Implementation frombeginning to certification took about four years. http://www.encinajpa.com/ems/

The biosolids EMS became a framework that focused on improved biosolids managementplanning and design and delivery of a Class A heat drying system. Enhanced operationalperformance means that EWAs cogeneration plant can reliably generate about 80 percent of its

own electricity needs, resulting in more than $1million per year in reduced utility costs.

Featured in WEFs Biosolids Technical Bulletin, Jul/Aug 2009, the Encina Wastewater Authorityis one of the first producers of biosolids pellets on the West Coast. It plans to sell the pellets to alocal cement company to be used as a biofuel. Testing has placed the value of the pellets at 60-65percent of the BTU value of coal. Biggs says the wastewater treatment process optimizationattributed to the EMS also has reduced odor complaints.

District of Columbia

In 1996, the District of Columbia Water and Sewer Authority (DC WASA) faced the dauntingtask of upgrading an enormous and complex facility, posing huge challenges for its biosolidsprogram. The agency had just assumed management of the Blue Plains Advanced WastewaterTreatment Plant from the Washington, DC government. The facility treated about 360,000 wettons per year of biosolids (1998 figures); 84 percent was lime-stabilized and land-applied, andthe rest was anaerobically digested and mostly co-incinerated. Much of the plant equipmentwas old, in disrepair, and often out of service. (Today, the agency treats more than 370 milliongallons of wastewater a day, and serves more than two million customers.)

In 1999 DC WASA adopted a 20-year master facilities plan and a 10-year, $1.6 billion capitalimprovement plan. As part of these plans, in 2001 it launched an integrated, three-phasebiosolids management program focusing on end-use options for biosolids, including odorcontrol.

The agency turned to the NBP program, then being piloted. The biosolids manager, Chris Peot,

established a cross-functional team that included members from other departments, contractors,and other stakeholders. Through the EMS, formal meetings generated goals and milestones,action items, and a tracking system for these activities. Immediate improvements includedidentifying critical operational, management, and environmental impact areas that needed to becontrolled and then were. Hauling costs were reduced to the tune of $4M a year throughprocess efficiencies that raised solids percentages. DC WASA was among the very first utilitiesto track greenhouse gas emissions and work on major reductions. (It prevents more than 25,000metric tons of CO2 emissions a year)

One of the first significant positives was that monthly meetings immediately brought togethercontractors, operators, and management in discussions and revelations that never might haveoccurred otherwise. As a result, root causes of problem trends became a focus, and it wasnt

long before priority issues were managed routinely. One of the most critical early successes wasthat public input and outreach vastly improved.


12/19


Today, DC WASA istaking an aggressive, pro-active approach,addressing lifecycleadministration ofbiosolids, pursuingresearch to addressanticipated issues,collaborating with otheragencies, and alwaysworking to educate andheed its public. Amongimprovements since 2004,most of which go wellbeyond environmentalconsiderations:

Focusing on businesscontinuity and riskissues that require advanced planning, such as preparing for new state phosphorus loadingrate requirements that could reduce field availability, preparing for a new Cambi anaerobicdigestion process for Class A biosolids and energy production to replace the current lime-stabilization process, and for new enhanced nitrogen removal facilities.

Working more closely than ever with other departments, which resulted, for example, inimproving average percent solids from 23 to 28 percent, which saves about $1M a year inhauling costs for each percentage solids raised.

An improved lime mixing process with a reduction in lime use from 25 percent to 15 percentwith a total savings of nearly $1 million annually.

An automated truck scales operation with improved hauling and invoice efficiencies,paying for themselves in less than a year.

Implementing staggered loading windows to reduce truck loading time to no more than onehour at peak times and ten minutes at best.

New silo operations that will allow drivers to load their own trucks, increasing efficiencies.

Use of facility process data for predicting odors and preventing problems; for example, atemperature-infrared alarm system was developed for the lime operation, flowmeters wereput on centrifuges to help predict output in advance for land application planning, andreduced-sulfur monitoring devices were installed in the conveyor system to provide on-linemonitoring data before liming.

A field inspector database and GIS tracking system so that odorous material rarely makes itonto fields, nearly eliminating the need for landfilling.

Identifying, implementing, and tracking SMART goals tied to short- and long-term biosolidsprogram objectives, and linking high-level organizational goals to them.

A training program that includes haulers, inspectors, and government employees.

Legal and other requirements tracked and addressed in concert with other affected utilities.

Involvement as founding member of the Virginia Biosolids Council to influence changes inlocal ordinances and state laws that are favorable to biosolids recycling.


13/19


Extensive outreach to interested parties, with inspector contacts earning much greaterpublic acceptance of biosolids.

Diversification of reuse options, including silviculture, mine reclamation, and landapplication permits in more states; a composting program onsite; and a plan for usingbiosolids for soybean crops to create biodiesel that the agency can use.

A leading-edge research program with more than a dozen biosolids activities each yearsince 2005.

Continuing a nutrient rebate program that draws in more than $225,000 a year.The story to date is of continuing success the biosolids program is now at NBP platinumlevel, having successfully gone through four third-party audits. But lets look at some things itmight have done differently.

It took too long to implement the NBP program, even given it was brand-new and untested.Before long, the EMS became a Christmas tree repository of all the dreams and idealspeople had for a perfect system. Begin with the end in mind went a bit too far!

Documentation often is a challenge when organizations start off. In this case, probably too

much time was spent developing a manual early on instead of just key procedures to get theprogram in gear. The manual doesnt have to be a single document, and it can be developedas procedures are developed and implemented over time. Also, more information thanneeded was drummed up about every document and record and too much thought wasspent on creating procedures that didnt exist for processes that were not critical.

Activities not directly related to environmental management crept in, such as risk andhealth and safety management all valuable, but not the focus at this stage of development.

The fenceline nudged wider, to processes not under the control of the biosolids division,and had to be corralled in.

More focus should have been put into EMS awareness training, and top managementsupport, while it existed, was not promoted the way it could have been.

Change management procedures could have been developed earlier on to help speed upprogress from reactive to preventive to pro-active modes of operation.

All of these challenges, however, are typical of what industries new to EMSs face when theybegin implementation. This was the case with ISO 14001 in such areas as the auto industry,forestry products, electronics, service industries such as hotels, and others. There is a learningcurve related to the specifics of the industry in question. In this case, enough utilities havebroken the barrier, and now there is an enormous amount of information to help them avoidpitfalls.

DC WASA was using a common model: develop a plan, then implement it. But we now know

that may not be the most effective approach. It is too easy to lose momentum with too muchplanning. And an EMS is ideally suited for multi-tasking. Below is a model that has documentdevelopment as an ongoing task done as the need arises.


14/19


Louisville, Kentucky

One example of immediate benefits from simultaneous development and implementation camenot long after the Louisville and Jefferson County Metropolitan Sewer District decided todevelop an EMS and pursue the NBP certification. (It achieved certification in July 2008 afterabout 18 months of work.) A core team began to meet that had not exchanged information asformally before. At the time, plant personnel had literally been fighting small fires because dustfrom the heat-dried pelletized Class A biosolids became flammable. But if moisture is too high,pellets can develop storage problems and smell. As a result of the initial EMS meetings, theteam worked on a solution that tweaked the process by optimizing the feed characteristics andapplying a fine mist of oil to reduce dust, and by adding ferric chloride to reduce odor potential.

Among the teams very first tasks was reviewing process flow diagrams so everyone was on thesame page and the fenceline was understood. David Coe, who managed EMS implementation,said it required a change in culture to move from the idea of solids as waste to solids asbeneficial fertilizer, and from taking responsibility only for what happened inside the plantboundaries to how the product was used and viewed at its end point. But Louisville Green isnow a proudly accepted revenue stream in great demand.

Measurement,Corrective Action

Development,Implementation (simultaneous)

Status Review,Policy

Review

Current practices Policy Legal Rqmnts Other Rqmnts

Establish team Agendas/minutes ID critical control

points ID environmental

impacts Est. operational

controls Monitoring &

measurementmethods

Incident re orts

Roles &responsibilities

Training Communication Public

participation Emergency

preparedness Contractors

Review CCPs, opctrls, M&M

Establish goalsand objectives

Action plans toachieve goals andfix root causes

Program report Internal audit plan

& implement Corrective actions Mgt review of EMS

Action Plan Documentation Document Control Records Meetings Workshops Training

12-Month EMS Implementation Plan

An EMS can be substantially implemented in 12 months if the focus is on aligning current practices with EMSrequirements, minimizing wishful thinking, and going after immediate and visible benefits early on. Highlights:

Establish effective, ongoing communication with all team members and others.

Identify where current processes and documents meet EMS requirements or could with little adjustment, such as

training, job descriptions (roles and responsibilities), SOPs, operational records, regulatory reporting, emergency plansand tests, department goals, public outreach, meeting notes, action plans.

Immediately put into practice any EMS components developed, such as communication procedures, incident reporting,new goals and action plans associated with reducing environmental impacts.

Establish goals that are already in line with existing organization goals.

Focus on fixing root causes of priority problems and on identifying positive and negative trends.

Resolve issues right away and communicate accomplishments widely.

Establish appropriate documentation and records as the need is identified.


15/19


A list of potential environmental impacts and critical control points was identified, and the teamreviewed all existing SOPs to determine where the gaps might lie. Critical SOPs weredeveloped, but the rest were put on a timeline for development part of the continualimprovement process. As procedures were developed, they were put into practice right away,including a public input procedure that generated a useful survey of end users. Within a year,an internal audit team was convened, and before the end of the three-day training, the deskaudit was complete. Other training modules were implemented as soon as they weredeveloped.

Coe organized the electronic documentation not according to the ubiquitous EMS standardelements, but according to how the plant operates and the documents are accessed and used.The manual exists but in the form of procedures and supporting documents in an electronichierarchy.

Bridge 3: DIYAgencies can choose the Do It Yourself (DIY) approach and adopt their own version of anEMS, pulling from the myriad helpful resources available for this. The US EPA has a sector-

specific guidance calledAchieving Environmental Excellence: An Environmental ManagementSystems Handbook for Wastewater Utilities, based on the elements of ISO 14001, along with othermore specific EMS guidance. This handbook was a collaborative effort between the Office ofWater at US EPA and the Global Environment and Technology Foundation (GETF). SeveralWEF EMS Committee members provided valuable input to the handbook.

EPA also has developed an excellent clearinghouse of EMS and other utility managementinformation for public entities located at http://www.peercenter.net/. PEER stands for PublicEntity EMS Resource Center, and provides a large range of tools for sustainability management.More resources are listed at the end of this paper.

The handbook is based on real-life experiences from many public agencies on how toimplement an EMS because the benefits exist without the need for third-party verification,many organizations pursue all or part of an official EMS, or they integrate it with othersystems that are already in place, such as risk or asset management systems. Finally, WEF hasan EMS committee that is working on compiling a set of resources, including workshops andpresentations, for utilities.

One example of a DIY utility is the Camden County, NJ Municipal Utilities Authority(CCMUA). Not only did Camden County develop an EMS for the entire utility, but it also isfocusing on biosolids improvements via the NBP EMS model.

Camden County, New Jersey

According to Andy Kricun, PE, deputy executive director and chief engineer at CCMUA, ,

Before CCMUA began its EMS efforts, it had the makings of a perfect storm a proposed rateincrease of over 22 percent, numerous odor complaints from neighbors, and difficulty meetingstate discharge limits even though the plant was receiving 70 percent of its rated capacity. Anattitude of just enough is good enough prevailed.

Using the US National Enforcement Investigations Center (NEIC) EMS requirements(http://www.epa.gov/compliance/neic/index.html), CCMUA embarked on its EMS journeybeginning with a gap analysis.


16/19


Kricun says a consensus for change was one of the immediate benefits. This turning point andnew route was maintained by focusing on team chartering to ensure ownership of the EMS andto make it part of members day-to-day routine.

Benefits included: Reduced O&M costs by 25% within three years, annual savings of $5M peryear, $50,000,000 saved since 1999, and no rate increases since 1996 in fact, rates have been cut

CCMUA started with three core goals to transform they way it did business: compliance,communication, and continual environmental improvement. CCMUA joined the NBP in March2006 and continues to use the EMS in meeting and achieving energy savings by focusing onenergy management at the wastewater treatment plant. In April 2009, CCMUA received theGovernment Award from the Water Resources Association of the Delaware River basin fordevelopment and implementation of its EMS to optimize its waste treatment systemsperformance and promote sustainability in its operation.

Bridge 4: Ten Attributes of Effectively Managed UtilitiesIn 2006, the Association of Metropolitan Water Agencies, the American Public WorksAssociation, the American Water Works Association, NACWA, the National Association of

Water Companies, EPA, and WEF organized a committee to develop a joint strategy toidentify, encourage, and recognize excellence in water and wastewater utility management.

The committee explored barriers that can inhibit improved utility management and hasdeveloped a set of resources to help utilities concentrate on priority areas for improvement,called the Ten Attributes of Effectively-Managed Water Sector Utilities. (Available at the PEERwebsite, noted above.) These attributes, thecommittee says, can be viewed as acontinuum of, or a set of building blocksfor, management improvementopportunities.

In 2007, EPA, WEF and these otherorganizations signed an historic agreementpledging to work together to supportimproved utility management based on theattributes. In addition to the attributes, theinitiative includes Five Keys to ManagementSuccess leadership, strategic businessplanning, organizational approaches,measurement, and continual improvementmanagement systems -- provideconsistent management approaches andsystems that have been shown to fosterutility management success and provide animportant framework for using theattributes. One of these keys tomanagement successcontinualimprovement management systemsessentially endorses the process used to develop an EMS.

In 2008, these organizations developed the Effective Utility Management Primer, which helpsutilities assess their operations based on the attributes and develop strategies, includingperformance measures, to improve the management of their operations.


17/19


Water and wastewater utilities can use the attributes, keys, and primer to select priorities forimprovement, based on each organizations strategic objectives and the needs of the communityit serves. Resources for accomplishing this include a self-assessment tool to help utilities easilyidentify needs and opportunities and several sample performance measures for each of theattributes. EPA considers these attributes to be the cornerstone of its efforts to help promotesustainable utility operations and infrastructure.

The handbook and primer provide step-by-stepguidance on how to go about improving utilityperformance that has been tested by severalorganizations. Tools include templates for identifyingand ranking attributes, developing and implementingan improvement plan, and establishingmeasurements. Because the focus is on utilities andwas developed with substantive input from utilities this set of resources can be a valuable addition to theexisting generic guidances for industry or for small-to-medium organizations.

Bridge 5: State EnvironmentalProgramsAs of August 2008, 22 states had adopted their ownEMS, environmental stewardship, or similarleadership programs. Many offer training and otherassistance, but most important, they can offerregulatory relief.

For example, in 2005, the Virginia General Assemblypassed a law establishing the Virginia Environmental

Excellence Program (VEEP)(www.deq.virginia.gov/veep). Any Virginiaorganization that impacts the environment canparticipate at four levels. Level E2 mainly requiresthat organizations establish a prevention program.Level E3 requires that the organization have an EMSin place, and level E4 that its EMS is verified by athird party. Participants at any level must have arecord of sustained regulatory compliance. To date,some 55 organizations are participating in the E2program, and about a dozen are being renewed or

pending approval at that level. The SpotsylvaniaCounty Utilities Department has adopted an EMSunder this program.

According to the Code of Virginia, benefits can include alternative compliance methods to theregulations, changes to monitoring and reporting requirements and schedules, streamlinedsubmission requirements for permit renewals, the ability to make certain operational changeswithout prior approval, and other changes that would not increase a facilitys impact on theenvironment. Under consideration today is regulatory relief for nutrient managementrequirements.

VEEP FrameworkE2: For those facilities interested in beginningor are in the early stages of implementing anEMS and pollution prevention program andhave a record of sustained compliance withenvironmental regulation. Membership criteria:

Environmental policy statement Identification of environmental impacts Establishment of targets Pollution prevention program Record of sustained compliance

Annual reporting (on at least oneenvironmental measure)

E3: For those facilities with a fully-implemented EMS and a pollution preventionprogram with documented results and a recordof sustained compliance with environmentalregulations. Membership criteria:

All of the above and: Fully implemented EMS EMS self-assessment Procedures for communicating

environmental information to public Annual reporting (on at least two

environmental measures)

E4: For those facilities with a fullyimplemented EMS (that has been verified byan independent third party) that havecommitted to measures for continuous andsustainable environmental progress andcommunity involvement. Membership criteria:

All of the above and: Third-party EMS audit One Full EMS cycle implemented Annual reporting (on at least three

environmental measures)


18/19


Spotsylvania County, Virginia

The Spotsylvania County Utilities Department has achieved level E2 participation and isworking on E3, according to EMS Coordinator Mark Van Devender. The staff who implementedthe EMS are no longer there, but he inherited a well-run program and discovered that the utilityhad all the elements in place to qualify for E3, which is more in line with ISO 14001-type EMS

requirements, but the components had to be located and coordinated into an EMS format.

For example, it has been tracking three environmental measures: reducing use of white paper, ofbatteries, and of mercury. The original staff that launched the E2 program focused on chlorinereduction, and now bleach is used for effluent treatment. It has been tracking biosolids end use somore is composted and less is landfilled. It has annual EMS awareness training, but VanDevender is posting reminders of the recycling and other environmental programs all over thefacility and more robust training is scheduled. It has almost all the SOPs required, but they arescattered around.

Most of the stuff theyre asking for in the 100-page E3 EMS application weve already got. Itsjust a matter of getting it all together, Van Devender said. He observed that most utilities are

probably in the same situation.

ResourcesThere are hundreds of guidebooks, training programs, webinars, and other material availablefor any utility to access, but the Water Environment Federations EMS Committee keeps a list ofthe latest tools and websites that are specifically helpful to water/wastewater utilities. Here area few of them:

US EPA Energy and water management activities. Over the last two years, EPAs Office ofWater, with WEF associations, sponsored a highly successful series of energy managementworkshops whose focus was on explaining how the Plan-Do-Check-Act methodologyembodied in environmental management systems can be used to help utilities identify and

manage their energy challenges, using the Energy Management Guidebook for Wastewater andWater Utilities developed by EPA with significant input from members of the WEF EMSCommittee and other utilities. More workshops are planned.http://www.epa.gov/waterinfrastructure/bettermanagement_energy.html

The WEF Utility Management Committee has posted numerous EMS resources on itswebsite, including presentations from webcasts, the EPA handbook on sustainability, anEMS and asset management pamphlet, case studies, and other tools.http://www.wef.org/ScienceTechnologyResources/AccessWaterKnowledge/UtilityManagement/UM-EMSResources.htm

PEER center clearinghouse of EMS information. US EPA, in partnership with the Global

Environment and Technology Foundation (GETF), has developed a national clearinghouseof EMS information for public entities, including water and wastewater organizations. Theclearinghouse provides a wide array of case studies, guides, protocols, and other usefulinformation to help public entities understand what an EMS is , how to implement one, andwhat the benefits of an EMS can be. The clearinghouse is located athttp://www.peercenter.net/


19/19


Water Associations, US EPA case studies for effective utility management practices. Sixassociations representing the US water and wastewater sector, in collaboration with the USEPA, have released Effective Water and Wastewater Utility Management Case Studies, acompanion document to 2008s Effective Utility Management: A Primer for Water andWastewater Utilities. http://www.watereum.org

EMS case studies from Virginia utilities. The Center for Organizational and TechnologicalAdvancement at Virginia Tech (COTA) hosted a series of four ISO 14001 EMSimplementation workshops in 2007-2008 at which representatives from utilities throughoutVirginia participated to develop their EMSs. Case studies were compiled from the workshopparticipants, providing commonly shared lessons learned and insight into EMSimplementation for anyone developing an EMS for the first time.http://www.peercenter.net

National Biosolids Partnership Resource Clearinghouse NBP is a goldmine ofmanagement resources for agencies that generate biosolids or otherwise are engaged inbiosolids management. http://www.biosolids.org.

On-Line EMS Tutorial The USEPA has completed an On-line EMS Tutorial for WastewaterUtilities based on its earlier EMS Implementation Guide for Wastewater Utilities. The on-linetutorial takes a utility through all the steps necessary to put an EMS in place for itsoperations, including a large number of examples and other tips from utilities that havesuccessfully implemented EMSs. http://www.peercenter.net/index.cfm under theFeatured Tool section

Effective Utility Management Initiative Primer and Toolbox WEF, USEPA, and fiveother national associations (AWWA, (APWA, AMWA, NACWA, and NAWC) representingthe US water and wastewater sector have released two products designed to help water andwastewater utilities manage their operations to help ensure long-term sustainability. Thistool is designed to help water and wastewater utility managers assess their operations basedon the attributes, set priorities, establish performance measures, and make practical,systematic changes to achieve excellence in utility performance.http://www.epa.gov/waterinfrastructure/bettermanagement.html

Conclusion Many Bridges To Your DestinationAgencies have several ways to become more effective and implement sustainable practices.They can choose among sector-specific, process-specific, or holistic approaches. They can takeadvantage of intrinsic program benefits or of external regulatory relief. They can self-certify, orgain the credibility of third-party certification. They can certainly take advantage of theexperience, now plentiful, of other utilities. But key to success in any of these approaches is thewillingness of agency leaders to look to the future, decide to build a bridge to somewhere, and

make the necessary changes for arriving at their destination achieving the highest levels ofenvironmental stewardship.