It has always been challenging for wastewater treatment agencies to run sound biosolids management programs. The regulations are strict, the processing technologies sometimes carry a learning curve, and public acceptance is often a hurdle.
The National Biosolids Partnership (NBP) has a remedy that growing numbers of agencies, large and small, are adopting. Called an Environmental Management System (EMS), it’s a tool that helps agencies develop exemplary programs by following proven procedures and adopting best biosolids management practices.
NBP leaders say that working within the EMS and achieving certification demonstrates to the community a commitment to producing and managing high-quality biosolids in an environmentally sound way. The program helps operators, managers and administrators prevent problems or violations before they occur, improve plant efficiency, and optimize treatment performance. Return on the investment in the EMS comes in improved community relations, operational cost savings and enhanced communication among all parties.
The NBP is a not-for-profit alliance formed by the National Association of Clean Water Agencies, the Water Environment Federation and U.S. EPA to advance sound biosolids management practices. Sam Hadeed, communications director, shared his thoughts on the benefits of the EMS in an interview with Treatment Plant Operator.
TPO: What exactly is the Environmental Management System?
Hadeed: It is a standardized and complete framework designed to assure that biosolids activities are managed effectively. It’s based on a set of principles and strategic water quality management goals that emphasize quality biosolids management practices, better relations with interested parties, regulatory compliance and environmental performance.
TPO: Does this program follow any pre-existing standards?
Hadeed: Our EMS is based on ISO 14001 international standards for environmental management systems, but it actually goes a couple of steps further, in that it includes requirements for public participation and communication, and it emphasizes outcomes over simply documenting processes.
TPO: Why did the Partnership establish this program?
Hadeed: The EPA issued the Part 503 regulations in 1993. Then later they classified biosolids management as a low-risk activity and not an enforcement or regulatory priority. There was a public perception that the EPA walked away from the regulations and that there was a lack of oversight.
There was also a concern that issues the public had with biosolids were not part of the regulations. People were asking: What about odor? What about this truck traffic coming through my neighborhood? What about the noise? The EMS was a response to those concerns. It was a way for treatment agencies to standardize their processes and do a better job of managing the residuals that come from cleaning dirty water.
TPO: What does the EMS consist of?
Hadeed: The program has 17 elements grouped into five categories: Policy, planning, implementation, measurement and corrective action, and management review.
In essence the goals are quality management to produce a consistent product, better relations with interested parties, regulatory compliance that goes well beyond the minimum requirements, and environmental performance, in terms of reducing carbon dioxide, reducing pollutant emissions, and making beneficial use of biosolids as a nutrient to improve the soil.
TPO: How does an agency achieve certification under the EMS?
Hadeed: It’s a process with four levels of recognition. First, they commit to a Code of Good Practice with the ultimate goal of certification. Second, they put the elements of an EMS in place and operate under it for six months. Third, they go through an independent, third-party audit and receive certification if successful. Finally, they complete interim audits to maintain certification.
TPO: Why does NBP require an independent third-party certification process?
Hadeed: We wanted the process to be more than having a consulting engineer or someone in the profession conduct a review and say, “You are fine — here’s your certification.” We realized that to have credibility, we needed to raise the bar.
We work with two audit firms: NSF International and KEMA Strategic Registrations. They are both internationally recognized certification agencies. We require them to have certified biosolids authorities on staff.
Once you become certified, that doesn’t mean it’s the end of the journey. Actually, it’s the beginning. It’s a continuous improvement process. You pass your initial audit with the 17 elements, but then the auditor comes back the next year and looks at perhaps seven or eight of those elements to see if you’ve made progress.
TPO: How many agencies have become certified?
Hadeed: We have 22 agencies certified so far. A good number of them are large agencies that helped us start the program — agencies with enough resources and management support to get their staffs involved in the effort. The first agency certified was Orange County Sanitation District in Fountain Valley, Calif. Other large agencies include the City of Los Angeles Bureau of Sanitation, the Metro Wastewater Reclamation District in Denver, the District of Columbia Water and Sewer Authority, and the Metropolitan Water Reclamation District of Greater Chicago.
TPO: Is it difficult for smaller agencies to become EMS certified?
Hadeed: We’re trying to make it easier for them by creating a small-agency template. We have posted examples of EMS manuals, audit reports, policies and other materials. We’re trying to make the process streamlined so it’s not a daunting task. A number of medium-sized and smaller agencies have become certified. They include Louisville, Ky.; Lawrence, Kan.; Grand Rapids, Mich.; Butler County, Ohio; Albany, Ore.; Madison, Wis.; and Kent County, Del.
TPO: How exactly does the EMS help agencies improve their processes?
Hadeed: It helps them look at their processes holistically, instead of as individual pieces. In a typical situation, people show up for work, do their jobs and go home, and as long as the plant is in compliance, that’s considered good enough. But then, if something goes wrong, what is the response?
An EMS ensures that they have a plan in place to deal with things, instead of putting out fires and making foolish mistakes. It’s designed to help them connect the dots — to look at how they do business at every step.
Suppose a batch of biosolids comes out with an odor. With a process in place, the person responsible for biosolids may be able to discern that someone upstream used a different polymer that caused the odor. And now that you have an odor, what do you do? Do you continue to land-apply the material? Or do you decide maybe that batch should go to a landfill instead? Your process gives you that kind of guidance.
If you don’t document how the pieces fit in a management system, you can have chaos. For example, suppose a truck spills a load of material. You don’t have an emergency response plan, and now the media is there. What matters is not so much the fact that there was a spill — it’s how you react. If you have a system in place, you know exactly whom to contact and what to do to minimize the damage.
TPO: How is the Partnership promoting participation in the EMS process?
Hadeed: We’re embarking on a new initiative — the Biosolids Best Practices Network — to encourage more agencies to join the program. It’s essentially for agencies that for now are renters, not buyers.
They’re not sure they want to make the investment to go through the audit process, but they do want to implement best practices from their peers in the water quality profession. Here’s a way for them to get into the program. There are some requirements they have to meet to be in the network. Once there, they have access to tools and incentives that can help them move toward becoming certified. It helps them improve their biosolids processes, and at some point we hope they become buyers.
TPO: What about an agency that is already functioning well? Why should they pursue certification?
Hadeed: They may want to demonstrate a commitment to becoming better environmental stewards. They may want to be perceived as a progressive agency. Or they may perceive that they have succession planning issues.
Maybe they don’t have their standard operating procedures documented, and if they start losing key people to retirement, then they may start having compliance issues, and problems with the public. In time everything goes downhill because they failed to plan. The EMS helps provide a big-picture vision.
TPO: How can agencies get more information about the EMS?
Hadeed: There is abundant information on our Web site at www.biosolids.org. It includes case studies in which agencies describe how certification benefits them. I am always happy to talk with anyone who would like more information. Just give me a call at 703/684-2418.
