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Five EMS Bridges to Utility Sustainability

Water Environment Federation Technical Exhibition and Conference, October 13, 2009
WEFTEC’09, Orlando, Florida
Caroline G. Hemenway*
Hemenway Inc.
chemenway@hemenwayinc.com
Lori A. Stone, PE
Black & Veatch
stonela@bv.com
James Horne
US Environmental Protection Agency
Horne.James@epamail.epa.gov

Abstract
With 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. How can utilities build the “bridge to sustainability,”
and balance these competing demands, set and achieve critical program goals, and align those
goals 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 and
succeed with their version of the triple-bottom-line (people, planet, profit): implement an
environmental management system (EMS), applied in one of at least three ways – ISO 14001,
National Biosolids Partnership EMS, or do-it-yourself; implement a management system
designed to achieve outcomes based on the key attributes of sustainable utilities, endorsed by
the 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 utility’s status quo and a chosen destination,
building on existing practices and focusing on continual improvement. They have proven
results in the water/wastewater sector, and they fit the budget, size, and management style of
almost any utility. Many agencies already may be on one of these paths and can access myriad
resources, several available only in the last year.

KEY WORDS: Sustainability, environmental management systems, effective utilities

Introduction
With 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 a
“bridge to nowhere.” So how can utilities build the “bridge to sustainability,” and balance these
competing demands, set and achieve critical program goals, and align those goals with
programs that are perhaps already in place within their organization?
FIVE EMS BRIDGES TO UTILITY SUSTAINABILITY – PAGE 2

Challenges Can Be Overcome – Determine Your Route


There are at least five paths utilities can take to help them along the road to sustainability and
succeed with their version of the triple-bottom-line (people, planet, profit) – to help them decide
how 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 at
least 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 key
attributes of sustainable utilities, endorsed by the US EPA, WEF, and several other major
water 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 have
proven results in the water/wastewater sector, and they fit the budget, size, and management
style of almost any utility. Many agencies already may be on one of these paths and can access
myriad resources, several available only in the last year.
Any approach can – and should – be interwoven with existing undertakings, including asset
management, risk management, and health and safety management. All these approaches can
help utility staff from the top down rest better knowing they have prioritized their tasks
appropriately and are better environmental stewards as a result.
The routes described in this paper will help utilities understand and access the latest tools and
resources available so they can get started in a way most sensible to them, and it will provide
representative examples of agencies that have successfully adopted the approaches. “A journey
of a thousand miles must begin with a single step.”

The Process Drives EMS


Improve existi ng practices: Set acti o nabl e goals and measure
 Identify current processes progress.
 Define best practices
Objective/Target &
 Prioritize
Action Plan

Performance
Existing Improvement
Goal
Processes
Outcome
EMS
Begin with the end i n mind.
FIVE EMS BRIDGES TO UTILITY SUSTAINABILITY – PAGE 3

What is “Sustainability?”
There are thousands of papers and presentations related to this question, and definitions of
sustainability vary widely. We will not dwell on a definition here, except to present one that
serves to frame the discussions and case studies in this paper. The UN Conference on
Environment 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 the
current generation without compromising the ability of future generations to meet their own
needs.

Embedded here are the ideas of endurance, interdependent systems, the progressive
transformation 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 Commission
on Environment and Development, June, 1987, http://www.un-documents.net/wced-ocf.htm, and
by 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 the
most out of an organization’s resources and achieve desired outcomes. It is a dynamic method
for evaluating processes and procedures to identify and manage the environmental “footprint”
of an organization. Utilities use this method to look at critical operations square in the face and
make 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 to
individual business sectors, including utilities. Agencies are encouraged to become certified to
an 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 the
standard implementation model for an EMS:

EMS EMS
EMS Gaps EMS Development EMS EMS Status Internal Verification
Assessment Implementation Review Audit
Audit

Regardless of the EMS approach, the “plan-do-check-act” cycle in EMSs must be integrated into
everyday operations to be effective, providing order and consistency in organizational methods
by allocating resources, assigning responsibility, and continually
evaluating and improving practices, procedures, and processes. An EMS
does not impose new technical or performance requirements, but it is a
voluntary tool aimed at improving overall environmental performance
and compliance with regulatory requirements. The organization can seek
third-party verification that its EMS meets objective criteria.
The most effective management systems are nearly invisible to
employees. They’re 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,
FIVE EMS BRIDGES TO UTILITY SUSTAINABILITY – PAGE 4

straightforward terms. The term “EMS” isn’t even used in many places. Documentation is kept
to a useful minimum and document control is as easy as possible so the system can be
maintained. Over time, most organizations find they jettison a great deal of the “wishful
thinking” plans and procedures they started with and pare them down to what works
effectively. On the other hand, most organizations find they have to create written procedures
they never had, which they often resist at first. However, they frequently find this
documentation improves consistency in operations and helps with training, retaining
institutional memory, and succession planning.
It also becomes clear that there are several commonalities among organizations that successfully
maintain management systems over time: top management support based on open, multi-level
communication, a thoughtful environmental policy that forms the basis of the system and of
decisionmaking, procedures to implement policy
requirements that are based on reality and are easy Palm Bay, FL, Utilities Department
to understand, reasonable goals that are measurable Bond Rating Raised; Attributed to EMS
and achievable, and an unrelenting focus on
From a June 2009 Palm Bay statement:
continual improvement.
Standard and Poor’s, the world’s foremost source
The benefits of an EMS have been reported by of credit ratings, announced in June 2009 that
government, industry, and non-profit organizations Palm Bay’s Water and Sewer Improvement bond
rating was raised from ‘A-‘ to “A.”
of all sizes in numerous studies worldwide:
Reducing costs, boosting competitiveness, The higher credit rating means the utility can
minimizing risk and maximizing environmental borrow at a lower interest rate. Jason
Yarborough, utilities director, said the credit
performance, improving government/public rating can be attributed to the organization’s ISO
relations, improving operations. 14001 environmental management system
certification and commitment to continual
It is fair to suggest that most utilities have the basics improvement.
in place, and simply need to apply EMS or similar
The utility states that a structured EMS has
methods to making the system work as a whole in produced efficiencies in sustainability in at least
their favor. two ways.

First, a documented lifecycle EMS fosters


Bridge 1: ISO 14001 proactive management of environmental issues
One of the best-known EMS standards is ISO 14001, by identifying, preventing, and correcting or
mitigating negative environmental impacts that
published in 1996 after undergoing an international can reduce risk and operational cost, and help
consensus process. Thousands of organizations preserve the environment.
worldwide are certified to this standard (updated in
Second, the EMS plays an integral role in better
2004), hundreds implement it without going through resource management and performance, which
certification, and several utilities have put it into has had a noticeable impact on the department’s
practice, including in the entire city of Dallas TX, and bottom line. The utility’s credit rating was raised
the water/wastewater utilities in Charleston SC, within one year of becoming certified to ISO
14001.
Lawrence, KS, and Palm Bay, FL. It is perhaps the
most prestigious of all the existing EMS standards, The EMS also has helped the Utilities
Department attain and maintain compliance with
and has an enormous body of knowledge and environmental requirements and accomplish its
training to support it that organizations can draw mission and strategic planning objectives.
upon. Most organizations implement this standard
The Palm Bay Utilities Department operates
for entire facilities, or groups of facilities. three water treatment facilities, a wastewater
facility, and a water reclamation facility, serving
Because this is the most widely accepted EMS 30,000 customers.
standard upon which others are based, it is worth
reviewing what its requirements are. It is also worth
FIVE EMS BRIDGES TO UTILITY SUSTAINABILITY – PAGE 5

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

ISO 14001 Requirements


• 4.4 Implementation and Operation • 4.5 Checking
• 4.1 General Requirements
4.4.1 — Resources, Roles, Responsibility, 4.5.1 — Monitoring and Measurement
• 4.2 Overview and Policy
and Authority 4.5.2 — Evaluation of Compliance
• 4.3 Planning 4.4.2 — Competence, Training, and 4.5.3 — Nonconfomirty, Corrective
4.3.1 — Environmental Aspects Awareness Action, and Preventive Action
4.3.2 — Legal and Other Requirements 4.4.3 — Communication 4.5.4 — Control of Records
4.3.3 — Objectives, Targets, and 4.4.4 — Documentation 4.5.5 — Internal Audit
Programme(s) 4.4.5 — Control of Documents
• 4.6 Management Review
4.4.6 — Operational Control
4.4.7 — Emergency Preparedness and
Response

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

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

Doing
Now comes the implementation phase. First, someone is appointed to
manage the EMS (in the City’s case, it’s the director of the Office of
Environmental Quality). This manager and others create a structure, which becomes the mechanism
for telling employees citywide about the EMS, helping them understand that their jobs have impacts
on the environment, and then helping them implement EMS procedures and goals in their various
workplaces. 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 any
emergencies that may occur: spills, emissions, accidents and such.

Checking
From 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 and
goals met. They will bring discrepancies to appropriate managers and employees. The idea here is
not 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.

Acting
There is a formal annual review of the EMS by senior management. The process depends on
managers 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 to
the EMS need to be made and “Act” to make improvements. These questions bring the entire process
back again to the planning phase, and the cycle begins anew.
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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 environmental
friendly vehicles, and from there adopted strategies to promote LEED-certified “green”
buildings. (LEED stands for Leadership in Energy and Environmental Design). The next step
was 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) and
now senior sustainability programs manager with Gresham, Smith, and Partners in Dallas, the
city committed to implementing the EMS in less than three years by working backward from
the city manager’s office to 11 city departments. DWU was one of them, serving 2.3 million
customers from two wastewater treatment plants and three water treatment plants. The
purpose 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 WEFTEC’07, Implementing ISO 14001
EMS – 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 on
environmental issues. Each city department was individually responsible for environmental
compliance, tracking new environmental regulations was limited and only conducted through
the state and federal legislative process. … Voluntary compliance auditing of facilities was left
to 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 a
state 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 ISO
14001.
2. Establishing common ground – The Office of Environmental Quality (OEQ) was tasked with
making sure there was consistency among all the departments because the idea was to receive a
single 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 manager’s office. An
environmental policy was adopted by the city mayor, council, and manager, committing the
city 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 a
core team and allocated one “environmental management representative” (EMR) to work half
time on the effort (since expanded to fulltime) and liaise with the OEQ and DWU divisions. The
fenceline included the entire department and 18 divisions but mainly focused on field and
treatment operations. Support operations like material services and capital improvements were
added 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 environmental
activities.
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4. Creating a can-do plan – All of the department EMRs met with the OEQ to develop a plan for
implementing the EMS. They looked first at current activities to determine which were most
environmentally significant, breaking down inputs, processes, and outputs – creating process
flow diagrams – to identify them. Environmental aspects were scored based on their degree of
potential for negative impacts. DWU originally identified more than 870 aspects and identified
12% as being significant. It also reviewed all environmental legal requirements to evaluate risk
and deficiencies in compliance. According to Coomes and Fiffick, “This process allowed DWU
to reduce risk with operations and come into compliance with specific air quality, waste, and
worker safety requirements.”
5. Establishing realistic goals – The next step was to do something about the impacts and
deficiencies found during this analysis. The city developed objectives and targets and
established management programs for all departments, and DWU identified its own 75
objectives and targets, including reducing sanitary sewer overflows, increasing leak detection
programs, decreasing emissions from vehicles, reducing water and energy consumption,
reducing hazardous waste generation, preventing chemical spills, and using nonpotable water
for irrigation. All of these were measurable.
6. Acting in unison toward desired outcomes – Now that impacts and deficiencies were
identified, a system was implemented for addressing them: evaluating performance, assigning
responsibilities, controlling operations, conducting training, and ensuring employee
competence. A key factor in this success was a substantial training and outreach program, for
which Dallas created an EMS logo to help “brand” the effort and raise awareness.
7. Measuring success – The city – and DWU
– measured key performance indicators, and
conducted internal audits and compliance
assessments to check on progress and
determine if the EMS was working as
intended. A reporting system maintained
inter-departmental communication and kept
executive management in the loop. Data had
to be tracked to monitor and measure such
activities as water use, electrical
consumptions, spills and releases, waste
generation, recycling, air emissions, and
operational efficiencies. System audits and compliance evaluations helped close gaps and
identify areas for improvement.
8. Closing the loop – A management review process that focused on senior city management
involvement and feedback from various staff levels provided opportunity for continual
improvement, corrective and preventive action, and appropriate resource allocation. This step
ensured top-down management commitment to the system, and brought the spiral of
improvement up and around to the next level.
In their report, Coomes and Fiffick say that “DWU estimated a cost of $141,400 and 4,620
personnel hours for EMS implementation in FY 2005/2006. Realized benefits for the same
period included: a savings of $372,175; 240 million gallons of water; 5,125,305 KwH of
electricity; 50 tons and 100 cubic yards of material recycled; 81 million gallons of water recycled;
and reduced 792 tons of emissions.”
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A third-party auditor who came back a couple of years after its first certification audit would be
looking at how Dallas manages change over time. The most noteworthy benefit of an EMS may be
its ability to ensure agencies continuously and appropriately adjust to changing circumstances. The
process 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 organizations
find they’ve moved from reactive mode to preventive mode, to the Shangri-La of executing
long-range plans.
Dallas’ approach is rare – so far – and most water and wastewater utilities are not in a position
to ask that their entire cities become certified. But it is worth noting that the method Dallas’
DWU used was basically the same used by other departments and agencies until the entire city
complied. 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 and
Kanwal Oberoi, Commissioners of Public Works in Charleston, in June, 1999, the utility became
the 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 a
policy and procedures that drove the rest of the effort. The key people involved received
extensive training and visited other organizations certified to the standard. The Water
Distribution Department was chosen because it had been through a re-engineering process that
required reviewing and revising standard operating instructions, records, and job roles, which
meant it had much of the basis of the standard in place.
“To successfully implement any
project, you have to generate
excitement and ‘buy-in’ from those
affected,” they report. They broadcast
management’s commitment to success
and provided awareness and EMS
training. They broke the project into
small attainable goals, using tools like
bulletin boards and progress charts,
and posting the policy everywhere.
Teamwork was essential, with
structured agendas minutes, and
progress tracking. Teams worked
simultaneously, and numerous
communication tools such as web
pages and electronic files were used.
Contractors and vendors were
included and new contracts included
EMS requirements.
Among the surprises was that some legal requirements they thought the utility had to subscribe
to did not apply. Most of the standard procedures were already in place, but needed better
control and a centralized filing location. Training programs were already in place, and regular
staff meetings were already being held. It was a matter of better organizing everything they
already did, and filling in gaps that made sense to do anyway.
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They report that ISO 4001 principles increase efficiencies, increase environmental compliance,
reduce hazard liabilities, and promote technological advances. ISO 14001 also demonstrates to
stakeholders its commitment to environmental stewardship.
Let’s look at another case where just the utility became certified to ISO 14001, and review how it
built 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 National
Biosolids Partnership’s EMS.

Bridge 2: National Biosolids Partnership EMS


Utilities 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 low
cost. It can also provide an important stepping stone to an EMS that includes all wastewater
operations, providing even greater benefits to the operation.
In August 1997, the US Environmental Protection Agency (EPA), the National Association of Clean
Water Agencies (NACWA, formerly AMSA), and the Water Environment Federation (WEF) joined
to form the National Biosolids Partnership (NBP), now in its 12th year. (http://www.biosolids.org)
One of the NBP’s goals is to help plan and implement environmentally sound management
programs to promote public acceptance of biosolids. Its major effort has been to develop a
voluntary EMS program for wastewater agencies: a “sector-specific” EMS. NBP provides a large set
of tools for getting started, called the “NBP EMS Blueprint.” It includes templates, detailed
guidance documents that interpret the requirements of the program, a status review questionnaire,
audit guidances, a manual of good practice, workshop summary reports, and detailed information
from and about utilities that have gone through the program.
This EMS differs slightly from ISO 14001 by addressing challenges specific to the biosolids
community. The NBP uses the term “biosolids value chain” to describe the sequence of events
from pretreatment through final disposition of biosolids. The focused evaluation of the critical
control points in a biosolids value chain is essential to developing a practical and implementable
EMS. In addition, public acceptance of biosolids is crucial to a program’s success, so there is a
requirement for public participation that does not exist in ISO 14001. Like ISO 14001, the NBP
EMS program also allows an agency to be certified based on successful completion of an
independent third-party audit. Below are the major components of the NBP program:

NBP Requirements
• Implementation • Measurement and Corrective Action
• Overview and Policy
Element 7 — Roles and Responsibilities Element 13 — Monitoring and Measurement
Element 1 — EMS Manual
Element 8 — Training Element 14 — Nonconformances: Preventive
Element 2 — Biosolids Management Policy
Element 9 — Communication and Corrective Action
• Planning
Element 10 — Operational Control of Element 15 — Periodic Biosolids
Element 3 — Critical Control Points Critical Control Points Management Program
Element 4 — Legal and Other Performance Report
Element 11 — Emergency Preparedness
Requirements and Response Element 16 — Internal EMS Audit
Element 5 — Goals and Objectives Element 12 — EMS Documentation and • Management Review
Element 6 — Public Participation and Document Control Element 17 — Periodic Management Review
Planning of Performance

Today, more than 100 utilities or contractors in 35 states are participating in the NBP EMS
program. 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 DC
WASA have been certified for several years and have seen significant benefits from their biosolids
EMSs. But the Department of Utilities in Lawrence, Kansas took its program several steps
FIVE EMS BRIDGES TO UTILITY SUSTAINABILITY – PAGE 10

further and moved beyond solids processing at the wastewater treatment plant to implement
ISO 14001 not only in its entire facility, but in its entire utility. We’ll begin with that story.

Lawrence, Kansas
Lawrence’s journey began when it joined the National Biosolids Partnership in May 2000 to
develop a biosolids-focused EMS that differentiated its program from national and regional
public perception problems experienced at the time. Its management was progressive, liked the
continual improvement philosophy, and wanted to learn more. Lawrence joined the NBP while
the EMS program was being developed and refined, so, according to Jeannette Klamm, Utilities
Program Manager, the agency felt “it would be easier to help set the standard than meet it after
someone else had set it.” Plus, funding and training was available from the NBP, so it seized the
opportunity. (http://www.ci.lawrence.ks.us/utilities/lums)
Focusing within a narrow fenceline – biosolids processing and end use – allowed the utility to
develop and test-run every aspect of an EMS at relatively little cost, and work out the kinks.
Making this somewhat easy was that the utility had a good, well-managed biosolids program
already. Among the challenges was that the NBP program did not have a steady-state model
since the program was in development. Consequently, there was a big learning curve to
overcome. Furthermore, Klamm says, “Everyone wanted to be the first certified, but no one
wanted to be the first audited.”
This initial funding and initiative paid off for Lawrence. In October 2005, Lawrence was the
10th agency to become certified to the NBP standard. It soon became clear that the biosolids
EMS was reproducible and it was a small step from that system to ISO 14001. Shortly afterward,
it pursued ISO 14001 and OHSAS 18001, (occupational health and safety management system),
and most recently became certified to ISO 9001, the quality management system.
Klamm admits to some periods of inertia, especially as they tried to integrate aspects of all of
the systems to eliminate redundant management processes. Although integrating the
environmental impact and hazard analyses with NBP’s critical control points was a complicated
process – including some wheel-spinning – she believes that the overall integration process was
beneficial. With the recent ISO 9001 certification and focus on product and service quality, the
integrated program has streamlined operating procedures and auditing processes, decreasing
the cost of audits while providing all the benefits of the individual systems.
Among the many other benefits so far, is improved quality of product (water and wastewater)
and services (delivery of water to the customer and conveying wastewater from homes and
businesses for treatment). Other benefits include enhanced health and safety awareness and
attitudes, improved knowledge capture and succession planning, better teamwork, and
improved O&M.
Klamm’s advice: Make it simple, you can always improve on anything, this isn’t a “project,” but
a way of doing business, it’s not a command-and-control system the way compliance systems
are, a third-party audit is not pass/fail, be patient because it involves a cultural change, and
make it work for you, because it’s yours. “Don’t wait to be perfect before you are audited. You
will go from nonconformances to opportunities over time,” she notes.

Encina, California
In August, 2005, the Encina Wastewater Authority’s biosolids management program became
certified to the NBP EMS. Although effective biosolids management practices were already in
place, various processes needed to be better documented and several practices conform to the
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NBP EMS program, according to Debbie Biggs, EMS coordinator. Implementation from
beginning to certification took about four years. http://www.encinajpa.com/ems/
The biosolids EMS became a framework that focused on improved biosolids management
planning and design and delivery of a Class A heat drying system. Enhanced operational
performance means that EWA’s 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 WEF’s Biosolids Technical Bulletin, Jul/Aug 2009, the Encina Wastewater Authority
is one of the first producers of biosolids pellets on the West Coast. It plans to sell the pellets to a
local cement company to be used as a biofuel. Testing has placed the value of the pellets at 60-65
percent of the BTU value of coal. Biggs says the wastewater treatment process optimization
attributed 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 daunting
task of upgrading an enormous and complex facility, posing huge challenges for its biosolids
program. The agency had just assumed management of the Blue Plains Advanced Wastewater
Treatment Plant from the Washington, DC government. The facility treated about 360,000 wet
tons per year of biosolids (1998 figures); 84 percent was lime-stabilized and land-applied, and
the rest was anaerobically digested and mostly co-incinerated. Much of the plant equipment
was old, in disrepair, and often out of service. (Today, the agency treats more than 370 million
gallons 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 capital
improvement plan. As part of these plans, in 2001 it launched an integrated, three-phase
biosolids management program focusing on end-use options for biosolids, including odor
control.
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 included
identifying critical operational, management, and environmental impact areas that needed to be
controlled – and then were. Hauling costs were reduced to the tune of $4M a year through
process efficiencies that raised solids percentages. DC WASA was among the very first utilities
to track greenhouse gas emissions and work on major reductions. (It prevents more than 25,000
metric tons of CO2 emissions a year)
One of the first significant positives was that monthly meetings immediately brought together
contractors, operators, and management in discussions and revelations that never might have
occurred otherwise. As a result, root causes of problem trends became a focus, and it wasn’t
long before priority issues were managed routinely. One of the most critical early successes was
that public input and outreach vastly improved.
FIVE EMS BRIDGES TO UTILITY SUSTAINABILITY – PAGE 12

Today, DC WASA is
taking an aggressive, pro-
active approach,
addressing lifecycle
administration of
biosolids, pursuing
research to address
anticipated issues,
collaborating with other
agencies, and always
working to educate and
heed its public. Among
improvements since 2004,
most of which go well
beyond environmental
considerations:

• Focusing on business
continuity and risk
issues that require advanced planning, such as preparing for new state phosphorus loading
rate requirements that could reduce field availability, preparing for a new Cambi anaerobic
digestion 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, in
improving average percent solids from 23 to 28 percent, which saves about $1M a year in
hauling costs for each percentage solids raised.
• An improved lime mixing process with a reduction in lime use from 25 percent to 15 percent
with 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 one
hour 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, a
temperature-infrared alarm system was developed for the lime operation, flowmeters were
put on centrifuges to help predict output in advance for land application planning, and
reduced-sulfur monitoring devices were installed in the conveyor system to provide on-line
monitoring data before liming.
• A field inspector database and GIS tracking system so that odorous material rarely makes it
onto fields, nearly eliminating the need for landfilling.
• Identifying, implementing, and tracking SMART goals tied to short- and long-term biosolids
program 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 in
local ordinances and state laws that are favorable to biosolids recycling.
FIVE EMS BRIDGES TO UTILITY SUSTAINABILITY – PAGE 13

• Extensive outreach to interested parties, with inspector contacts earning much greater
public acceptance of biosolids.
• Diversification of reuse options, including silviculture, mine reclamation, and land
application permits in more states; a composting program onsite; and a plan for using
biosolids for soybean crops to create biodiesel that the agency can use.
• A leading-edge research program with more than a dozen biosolids activities each year
since 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 “platinum”
level, having successfully gone through four third-party audits. But let’s look at some things it
might 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 ideals
people 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 the
program in gear. The manual doesn’t have to be a single document, and it can be developed
as procedures are developed and implemented over time. Also, more information than
needed was drummed up about every document and record and too much thought was
spent on creating procedures that didn’t exist for processes that were not critical.
• Activities not directly related to environmental management crept in, such as risk and
health 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 management
support, while it existed, was not promoted the way it could have been.

• Change management procedures could have been developed earlier on to help speed up
progress 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 they
begin 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 learning
curve related to the specifics of the industry in question. In this case, enough utilities have
broken the barrier, and now there is an enormous amount of information to help them avoid
pitfalls.
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 much
planning. And an EMS is ideally suited for multi-tasking. Below is a model that has document
development as an ongoing task done as the need arises.
FIVE EMS BRIDGES TO UTILITY SUSTAINABILITY – PAGE 14

12-Month EMS Implementation Plan


An EMS can be substantially implemented in 12 months if the focus is on aligning current practices with EMS
requirements, 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 plans
and 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.

Action Plan Documentation Document Control Records Meetings Workshops Training

Status Review, Development, Measurement, Review


Policy Implementation (simultaneous) Corrective Action

• Current practices • Establish team • Roles & • Review CCPs, op • Program report
• Policy • Agendas/minutes responsibilities ctrls, M&M • Internal audit plan
• Legal Rqmnts • ID critical control • Training • Establish goals & implement
• Other Rqmnts points • Communication and objectives • Corrective actions
• ID environmental • Public • Action plans to • Mgt review of EMS
impacts participation achieve goals and
• Est. operational • Emergency fix root causes
controls preparedness
• Monitoring & • Contractors
measurement
methods
• Incident reports

Louisville, Kentucky
One example of immediate benefits from simultaneous development and implementation came
not long after the Louisville and Jefferson County Metropolitan Sewer District decided to
develop an EMS and pursue the NBP certification. (It achieved certification in July 2008 after
about 18 months of work.) A core team began to meet that had not exchanged information as
formally before. At the time, plant personnel had literally been fighting small fires because dust
from 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, the
team worked on a solution that tweaked the process by optimizing the feed characteristics and
applying a fine mist of oil to reduce dust, and by adding ferric chloride to reduce odor potential.
Among the team’s very first tasks was reviewing process flow diagrams so everyone was on the
same 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 as
beneficial fertilizer, and from taking responsibility only for what happened inside the plant
boundaries to how the product was used and viewed at its end point. But “Louisville Green” is
now a proudly accepted revenue stream in great demand.
FIVE EMS BRIDGES TO UTILITY SUSTAINABILITY – PAGE 15

A list of potential environmental impacts and critical control points was identified, and the team
reviewed all existing SOPs to determine where the gaps might lie. Critical SOPs were
developed, but the rest were put on a timeline for development – part of the continual
improvement 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 desk
audit was complete. Other training modules were implemented as soon as they were
developed.
Coe organized the electronic documentation not according to the ubiquitous EMS standard
elements, 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 electronic
hierarchy.

Bridge 3: DIY
Agencies can choose the “Do It Yourself” (DIY) approach and adopt their own version of an
EMS, pulling from the myriad helpful resources available for this. The US EPA has a sector-
specific guidance called Achieving Environmental Excellence: An Environmental Management
Systems Handbook for Wastewater Utilities, based on the elements of ISO 14001, along with other
more specific EMS guidance. This handbook was a collaborative effort between the Office of
Water at US EPA and the Global Environment and Technology Foundation (GETF). Several
WEF EMS Committee members provided valuable input to the handbook.
EPA also has developed an excellent clearinghouse of EMS and other utility management
information for public entities located at http://www.peercenter.net/. PEER stands for Public
Entity 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 to
implement 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 other
systems that are already in place, such as risk or asset management systems. Finally, WEF has
an EMS committee that is working on compiling a set of resources, including workshops and
presentations, 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 is
focusing 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 rate
increase of over 22 percent, numerous odor complaints from neighbors, and difficulty meeting
state discharge limits even though the plant was receiving 70 percent of its rated capacity. An
attitude 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 journey
beginning with a gap analysis.
FIVE EMS BRIDGES TO UTILITY SUSTAINABILITY – PAGE 16

Kricun says a consensus for change was one of the immediate benefits. This turning point and
new route was maintained by focusing on team chartering to ensure ownership of the EMS and
to make it part of members’ day-to-day routine.
Benefits included: Reduced O&M costs by 25% within three years, annual savings of $5M per
year, $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 March
2006 and continues to use the EMS in meeting and achieving energy savings by focusing on
energy management at the wastewater treatment plant. In April 2009, CCMUA received the
Government Award from the Water Resources Association of the Delaware River basin for
development and implementation of its EMS to optimize its waste treatment system’s
performance and promote sustainability in its operation.

Bridge 4: Ten Attributes of Effectively Managed Utilities


In 2006, the Association of Metropolitan Water Agencies, the American Public Works
Association, the American Water Works Association, NACWA, the National Association of
Water Companies, EPA, and WEF organized a committee to develop “a joint strategy to
identify, encourage, and recognize excellence in water and wastewater utility management.”
The committee explored barriers that can inhibit improved utility management and has
developed 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 PEER
website, noted above.) These attributes, the
committee says, “can be viewed as a
continuum of, or a set of building blocks
for, management improvement
opportunities.”
In 2007, EPA, WEF and these other
organizations signed an historic agreement
pledging to work together to support
improved utility management based on the
attributes. In addition to the attributes, the
initiative includes Five Keys to Management
Success – leadership, strategic business
planning, organizational approaches,
measurement, and continual improvement
management systems -- provide
“consistent management approaches and
systems that have been shown to foster
utility management success and provide an
important framework for using the
attributes.” One of these keys to
management success—continual
improvement management systems—
essentially endorses the process used to develop an EMS.
In 2008, these organizations developed the Effective Utility Management Primer, which helps
utilities assess their operations based on the attributes and develop strategies, including
performance measures, to improve the management of their operations.
FIVE EMS BRIDGES TO UTILITY SUSTAINABILITY – PAGE 17

Water and wastewater utilities can use the attributes, keys, and primer to select priorities for
improvement, based on each organization’s strategic objectives and the needs of the community
it serves. Resources for accomplishing this include a self-assessment tool to help utilities easily
identify needs and opportunities and several sample performance measures for each of the
attributes. EPA considers these attributes to be the cornerstone of its efforts to help promote
sustainable utility operations and infrastructure.
The handbook and primer provide step-by-step
guidance on how to go about improving utility VEEP Framework
performance that has been tested by several E2: For those facilities interested in beginning
or are in the early stages of implementing an
organizations. Tools include templates for identifying EMS and pollution prevention program and
and ranking attributes, developing and implementing have a record of sustained compliance with
an improvement plan, and establishing environmental regulation. Membership criteria:
measurements. Because the focus is on utilities – and • Environmental policy statement
was developed with substantive input from utilities – • Identification of environmental impacts
this set of resources can be a valuable addition to the • Establishment of targets
existing generic guidances for industry or for small- • Pollution prevention program
to-medium organizations.
• Record of sustained compliance

Bridge 5: State Environmental Annual reporting (on at least one
environmental measure)
Programs E3: For those facilities with a fully-
implemented EMS and a pollution prevention
As of August 2008, 22 states had adopted their own program with documented results and a record
EMS, environmental stewardship, or similar of sustained compliance with environmental
leadership programs. Many offer training and other regulations. Membership criteria:
assistance, but most important, they can offer • All of the above and:
regulatory relief. • Fully implemented EMS
• EMS self-assessment
For example, in 2005, the Virginia General Assembly
passed a law establishing the Virginia Environmental
• Procedures for communicating
environmental information to public
Excellence Program (VEEP) • Annual reporting (on at least two
(www.deq.virginia.gov/veep). Any Virginia environmental measures)
organization that impacts the environment can E4: For those facilities with a fully
participate at four levels. Level E2 mainly requires implemented EMS (that has been verified by
that organizations establish a prevention program. an independent third party) that have
committed to measures for continuous and
Level E3 requires that the organization have an EMS sustainable environmental progress and
in place, and level E4 that its EMS is verified by a community involvement. Membership criteria:
third party. Participants at any level must have a • All of the above and:
record of sustained regulatory compliance. To date, • Third-party EMS audit
some 55 organizations are participating in the E2 • One Full EMS cycle implemented
program, and about a dozen are being renewed or
• Annual reporting (on at least three
pending approval at that level. The Spotsylvania environmental measures)
County Utilities Department has adopted an EMS
under this program.
According to the Code of Virginia, benefits can include “alternative compliance methods to the
regulations, … changes to monitoring and reporting requirements and schedules, streamlined
submission requirements for permit renewals, the ability to make certain operational changes
without prior approval, and other changes that would not increase a facility’s impact on the
environment.” Under consideration today is regulatory relief for nutrient management
requirements.
FIVE EMS BRIDGES TO UTILITY SUSTAINABILITY – PAGE 18

Spotsylvania County, Virginia


The Spotsylvania County Utilities Department has achieved level E2 participation and is
working on E3, according to EMS Coordinator Mark Van Devender. The staff who implemented
the EMS are no longer there, but he inherited a well-run program and discovered that the utility
had 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, of
batteries, and of mercury. The original staff that launched the E2 program focused on chlorine
reduction, and now bleach is used for effluent treatment. It has been tracking biosolids end use so
more is composted and less is landfilled. It has annual EMS awareness training, but Van
Devender is posting reminders of the recycling and other environmental programs all over the
facility and more robust training is scheduled. It has almost all the SOPs required, but they are
scattered around.
“Most of the stuff they‘re asking for in the 100-page E3 EMS application we’ve already got. It’s
just a matter of getting it all together,” Van Devender said. He observed that most utilities are
probably in the same situation.

Resources
There are hundreds of guidebooks, training programs, webinars, and other material available
for any utility to access, but the Water Environment Federation’s EMS Committee keeps a list of
the latest tools and websites that are specifically helpful to water/wastewater utilities. Here are
a few of them:

• US EPA Energy and water management activities. Over the last two years, EPA’s Office of
Water, with WEF associations, sponsored a highly successful series of energy management
workshops whose focus was on explaining how the Plan-Do-Check-Act methodology
embodied in environmental management systems can be used to help utilities identify and
manage their energy challenges, using the Energy Management Guidebook for Wastewater and
Water Utilities developed by EPA with significant input from members of the WEF EMS
Committee 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 its
website, including presentations from webcasts, the EPA handbook on sustainability, an
EMS and asset management pamphlet, case studies, and other tools.
http://www.wef.org/ScienceTechnologyResources/AccessWaterKnowledge/UtilityManag
ement/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 clearinghouse
of EMS information for public entities, including water and wastewater organizations. The
clearinghouse provides a wide array of case studies, guides, protocols, and other useful
information to help public entities understand what an EMS is , how to implement one, and
what the benefits of an EMS can be. The clearinghouse is located at
http://www.peercenter.net/
FIVE EMS BRIDGES TO UTILITY SUSTAINABILITY – PAGE 19

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

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

• National Biosolids Partnership Resource Clearinghouse – NBP is a goldmine of


management resources for agencies that generate biosolids or otherwise are engaged in
biosolids management. http://www.biosolids.org.

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

• Effective Utility Management Initiative Primer and Toolbox – WEF, USEPA, and five
other national associations (AWWA, (APWA, AMWA, NACWA, and NAWC) representing
the US water and wastewater sector have released two products designed to help water and
wastewater utilities manage their operations to help ensure long-term sustainability. This
tool is designed to help water and wastewater utility managers assess their operations based
on 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 Destination


Agencies have several ways to become more effective and implement sustainable practices.
They can choose among sector-specific, process-specific, or holistic approaches. They can take
advantage of intrinsic program benefits or of external regulatory relief. They can self-certify, or
gain the credibility of third-party certification. They can certainly take advantage of the
experience, now plentiful, of other utilities. But key to success in any of these approaches is the
willingness 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 of
environmental stewardship.