' HEN the National Biosolids Pa r tne r sh ip (NBP) was formed in 1997, its mission was to advance environ- mentally sound and accept- ed biosolids management practices -to i l n ~ l e m e n t

Blueprint For Biosolids

DEMONSTRATION PHASE programs that build public confidence and go beyond regulatory requirements. From the beginning, the partnership focused on developing an Environmental Management System (EMS) model. based on IS0 14001 NATIONAL BIOSOLIDS p;inciples for biosolids that would build in improved management practices tailored to meet the needs of the community (see "En- vironmental Management System Initia- tive," Se~tember. 1999). PARTNERSHIP EMS

P he partnership i s kn alliance between the Association of Metropolitan Sewerage Agencies (AMSA), the Water Environment Federation (WEF). and the U.S. Environ- UPDATE menta l protection Agency (EPA). I t is housed a t the WEF offices in Alexandria, Virginia. Biosolids producers, service con- tractors and users - together with stake- holders from regulatory agencies, universi- ties, public heal th departments, media, water quality professionals, the farming community, and environmental organiza- tions - have input into shaping the NBP priorities both through committees and meetings. The partnership has been funded in part by a Congressional appropriation.

There are five components to the NBP's EMS Blueprint. The first, developed by the partnership itself, is a Code of Good Practice that lays out the commitments that facilities need to make to participate in the EMS pro- gram. Contracts were given to several con- sulting firms to help the NBP develop the o ther four components of t h e EMS Blueprint. They include the Common Ele- ments of an EMS for Biosolids -17 svstem requirements for effectively managing biosolids activities a t all critical control points (the accompanying article, "The Mak- ing of an Environmental Management SYS- Keu documents o f the Environmental

J tem," explains the elements in Gore detGl); J

the National Manual of GOO^ Practice for Management System for biosolids have been Biosolids - one-volume, "how-to" document designed around the critical control points completed in an interim form and are being "beta for managing biosolids, from pretreatment through public acceptance strategies; the tested" by 27 wastewater treatment agencies. EMS Guidance Manual - detailed manual with step-by-step guidance on how to imple- ment the 17 elements; and the Independent Nora Goldstein Third-Party Verification Recommendations highly variable in size, from New York City - guidance for developing a program to ver- to the small town of Omak, Washington," ify and certify that organizations have im- says James Horne, a special assistant to the plemented EMS programs consistent with director of EPA's OEce of Wastewater Man- the Common Elements. agement and the U.S. EPA representative to

The Code of Good Practice and interim the NBP. The goal is for all of them to have drafts of Blueprint documents are available completed their EMS in early 2002, after on the NBP's website (www.biosolids.org). which they would go through the third par- Before finalizing the Blueprint, 27 waste- ty audit, which is necessary in order to be water treatment agencies (see sidebar), re- Lori Stone of CH2M Hill was certified by the NBP. ferred to as Demonstration Organizations, one ,f the consultants at a A workshop was held in March for the 27 are pilot testing the documents -- essential- workshop held in March for agencies. Consultants who had worked on ly using them to create an EMS for their staff from the demonstration the EMS Elements, the Manual of Good biosolids management programs. "The agencies to explain various Practice and the Third Party Verification agencies in this demonstration program are aspects of the EMS Blueprint. program (PA ConsultingICH2M Hill, The

ORGANIZATIONS

T HERE are 27 publicly owned wastewater treatment agen- cies participating in the Nation-

al Biosolids Partnership's Environ- mental Management System demonstration program. These agencies are "pilot testing" the EMS Blueprint documents and are expected to have a completed EMS in early 2002. The 27 partici- pating agencies are as follows: Al- bany, OR; Appleton, WI; Town of Brattleboro, VT; Chicago, IL;

Columbus, GA; Denver, CO; Enci- na, CA; Fort Worth, TX; Greenville, SC; Kansas City, MO; King County, WA; Lawrence, KS; Lewiston- Auburn, ME; Los Angeles,CA; Town of Merrimack, NH; Milwau- kee, WI; Montgomery, AL; New York City, NY; Omak, WA; County of OnondagalSyracuse, NY; Or- ange County Sanitation District, CA; Philadelphia, PA; San Diego, CA; Tacoma,WA; Warren, OH; Washington, DC; Wyoming, MI.

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The NBP is developing the final component of the EMS program - the guidance for the auditors who will conduct the third party verification.

Sear-Brown Group, Ross and Associates En- vironmental Consulting, Ltd.) were on hand to explain those components and answer questions. "Most of the agencies, with the exception of the Orange County, California Sanitation District and San Diego, are in the early stages of the EMS development pro- cess," says Horne. "That is essentially the planning stages, or the first six to eight ele- ments of the 17 total elements that have to be included in an EMS."

Peter Machno, the EMS coordinator on the NBP staff who is working closely with the 27 Demonstration Organizations, emphasizes that most of these agencies have the work- ings ofmany of the elements in place already. "Whether they are organized into a real EMS envisioned by the NBP is the question," he says. "For example, they may have various policies, a training program and so forth, but they may not all be working in a systematic way together toward the same goal of public acceptance of biosolids."

Consultants to the NBP worked with the 27 agencies to assess what procedures exist and what needs to be developed to complete the coinponents of each element - to give thein a sense of what had to be done during the life of the demonstration. It also con- firmed to agency staff that they didn't have to s tar t entirely from scratch to put the EMS together. "Hopefully the EMS assess- ments, if looked a t objectively, showed that," says Horne.

INDEPENDENT AUDIT While the agencies are working with the

Blueprint documents, the NBP is develop- ing the final coinpoilent of the EMS program - the guidance for the auditors who will conduct the third party verification. The NBP will hire a certified EMS audit compa- ny with five years iuiiliinuin of wastewater experience, and that can provide individual auditors who have such qualifications. Ross & Associates has been retained by the NBP to facilitate discussions with the Advisory and Developnlent Groups, comprised of stakeholders in the biosolids management

community and specialists in the EMS field, as they prepare the auditor guidance. The firm also facilitated the process to develop the third party verification program. Most of the stakeholders who worked on third party verification are volunteering again to help develop the auditor guidance.

"The guidance will be used by the auditing firm contracted by the NBP to go on site and evaluate the EMS at the wastewater treat- ment agencies," says Horne. "It will lay out in detail how the audit will be conducted, qualifications of the auditors, types of ques- tions that will be asked and so forth." Anoth- er reason for developing the guidance is to de- mystify the auditing process for the agencies to be audited. The participating organiza- tions will know what the auditor will be look- ing for in their EMS. "They will know what to expect and the auditors will operate with- in certain guidelines that the partnership will develop," he adds. "If it is done right, people will understand that the third party auditing process isn't a 'gotcha,' but instead is designed to point out both the strengths and areas for improvement with their EMS."

At the workshop in March, Chris Toth from the city of San Diego - the first to have its wastewater facility EMS certified by IS0 14001, and now one of the 27 demonstration agencies in the NBP program - shared the audit experience with the others. "It will be like taking an exam," he said. "You won't get a perfect score but the goal is to get a pass- ing score and then see where you need to im- prove. Think of the auditor as your friend."'

Representatives from about ten of the 27 demonstration organizations have agreed to be part of the auditor guidance Development Group. "The goal is to have the auditor guid- ance completed and accepted by the NBP Management Coininittee this fall, and the auditing program in place by the time the demonstration agencies complete and imple- ment their EMS," says Machno. Adds Horne: "Step 1 for the agencies is to make sure they have all 17 of the common eleinents of the EMS in place; Step 2 is to have the EMS op- erational; and Step 3 is to go through the au- dit, which typically happens six months af- t e r implementat ion. Following t h a t schedule, the third party audits would begin to take place in early 2002." The audit guid- ance will be the basis of an RFP to contract with a certification company and will be used by that company to perform the audits.

The overall purpose of the third party au- dit is to verify if a local agency is actually im- pleinenting its EMS consistent with the NBP EMS Blueprint. It also serves to teach agen- cy staff and all other involved or impacted parties about elements of the systein that they didn't know before. "The audit identifies strengths and weaknesses and helps every- one involved follow the continuous iinprove- inent philosophy," explains Horne. If and when the auditor determines that the local organization meets the blueprint require- ments, they will be certified by the NBP. Identifying the specific criteria for determin- ing if those requirements have been met are

part of the task of the auditor guidance De- velopment and Advisory Groups.

Wastewater treatinent agencies that go through the audit and receive the certifica- tion will get official recognition from the NBP. "The certification will be similar to the Good Housekeeping Seal of Approval ," says Machno. "It ineans that the local organiza- tion has a good biosolids management sys- tem in place that controls potential environ- mental impact well and will help with public acceptance. The public will be more apt to 'trust' a local organization's biosolids pro- gram because it has been through an inde- pendent third party review like the Good Housekeeping Seal of Approval. The part- nership is designing an insignia that the lo- cal organization would be able to use on its letterhead, facility decals and so forth. As of now, however, they would not be able to put the insignia on their product, e.g. on a bag of composted or pelletized biosolids. This sum- mer, the NBP's Advisory Group will be work- ing on what it would take to allow a 'stamp of approval' to be used on the product."

EMS DEVELOPMENT PROGRESS The majority of the 27 agencies involved

in the demonstration program land apply the biosolids generated; a few rely on land- filling or incineration. In 16 of the 27 orga- nizations, the lead person putting the EMS in place is on the agency's managementlad- ministrat ive staff; 11 agencies have a biosolids person in the lead. These individu- als have put together a team comprised of representatives from the entire organiza- tion, including people with responsibilities for pretreatment, treatment plant opera- tions and biosolids handling. "Establishing the EMS involves documenting how the solids and biosolids are being managed, which ineans that a fair ainount of time is needed to write everything down, as well as sort out where it is necessary to update pro- cedures and make sure the procedures com- plement each other and are leading to the common goal of producing biosolids prod- ucts that meet the quality requirements for their intended markets," explains Machno. "That is why the EMS has to be a commoil effort within an organization. Everyone needs to buy into the 'systematic approach' to inanaging the solids/biosolids. The writ- ing should be a shared experience among an organization's staff in order to achieve that 'buying into' of the EMS." This also estab- lishes "facility-wide ownership" for the EMS, adds Horne.

Both large and smaller agencies can fol- low the principles of the NBP EMS, but the ainount of information to define their EMS will be different. For example, the required documentation inay be perceived as over- whelming for a small agency with a small staff or the treatment plant manager re- sponsible for pretreatment, treatment and biosolids handling. A large agency, on the other hand, may hire temporary staff or a consultant to help staff with that work. "The NBP is working with small agencies in the

delnonstration program to assure that the -1 EMS Blueerint is aeelicable to sinall oraa- n iza t ion~,~not just %e large and medi;in Common element size facilities," adds Machno. Adjustinents can be made where appropriate, says Horne. number 6 requires FORMALIZED PUBLIC INVOLVEMENT public involvement

Nuinber 6 of the coininon elements, Public Participation in Planning, requires public in- in the EMS process. volvement in the EMS process. Institutional- izing public involvement, especially for wastewater treatinent agencies managing biosolids via land application, is an extreme- ly important asset of an EMS, but also one of the most challenging to develop. At the work- shop in March, the demonstration agencies

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participated in an cxcrcisc to come up with a public participation programs in place and . . .. . . . - ~

"The audit is like taking an exam,'' says Chris Toth of San Diego. "You won't get a perfect score but the goal is to get a passing score and then see where you need to improve."

draR public participation plan. Each group had a hypothetical situation, for example, a large utility that land applies its biosolids and a) has significant opposition or b) has no opposition. Who are the stakeholders to talk to, what is the message the agencies want to send to those people and how do they get their involvement in the EMS process?

"This was the introduction of public par- ticipation training for the Demonstration Organizations," says Machno. "Exactly what the auditors will use to assess imple- mentation of this element is one of the 'ar- eas of definition' the NBP and the auditor guidance Development and Advisory Groups will be working on this summer. The recommendations in the third party verifi- cation blueprint document with regard to public participation will be the starting point for the work group. One of the chal- lenges is that we will need to define what the auditor will look for and what the partici- pating organization needs to do so there will be no surprises when the auditor is asking questions of a local organization."

In general, the NBP will not dictate how agencies should carry out element 6. In- stead, it will explain that they must deinon- strate that stakeholders have been given the opportunity to provide input into the EMS. Machno points out that most biosolids pro- grams will not be starting from scratch on this element either. "There are many good

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ALL AROUND LEARNING EXPERIENCE The NBP and its consultants are providing

ongoing technical assistance to the Deinon- stration Organizations as they continue de- veloping their EMS. It's a learning experi- ence for all parties involved, and will serve to clarify and s t rengthen both the EMS blueprint and the overall strategy for taking the EMS initiative full-scale to the biosolids management industry. The NBP expects that 40 organizations will have received its "stamp of certification" by 2003. I t also has a goal of 100 organizations being part of the EMS program by that point (meaning that they have embraced the NBP Code of Good Practice). Another goal by 2003 is to have support for the NBP EMS program by na- tional environmental organizations.

The five coinponents of t h e EMS Blueprint will be integrated into a single program following the pilot testing by the 27 pioneering public organizat ions. The demonstration program will be expanded to include 13 additional projects, with the em- phasis on smaller agencies. Workshops will be used to encourage at least 60 additional organizations to sign up for what the NBP is calling the "Code of Good Practice Club."

Concludes Machno: "The overall goal of the NBP is to gain public acceptance of the use and disposal of biosolids. The NBP said early on that the way we were working to achieve public acceptance in the past was not really working in all areas. Public controversy was continuing to show up around the country. Being reactive rather than proactive was not working and we had to find a way to be proac- tive. The EMS with its third party verifica- tion is a proactive approach. The public doesn't trust most public agency biosolids program managers. There is the perception that they have a waste from society that must be gotten rid of the cheapest way possible.

"The private sector developed programs such as the 'Underwriters Laboratory' third party stamp of approval on electrical appli- ances and the 'Good Housekeeping Seal of Approval.' The NBP believes that this same approach should work for public agencies. The public is more apt to give a public agen- cy the benefit of a doubt if they have an in- dependent third party verification and stamp of approval process.

"In addition, the EMS offers a systematic approach to management. This approach is going to avoid the 'dumb' mistakes that have been made in the past, mistakes have typically resulted in major public accep- tance problems in areas around the coun- try. This is not to say the EMS will catch ev- erything. Things like extreme weather events do happen!

"I like to refer to the Demonstration Or- ganizations as the pioneers that are paving the way for the rest of the 15,973 public wastewater organizations around the Unit- ed States to assure public acceptance of their biosolids programs."