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Components
DEVELOPING AN ENVIRONMENTAL MANAGEMENT SYSTEM FOR IMPROVED PUBLIC UTILITY PERFORMANCE
Andrew Kricun, P.E.
Deputy Executive Director
Camden County Municipal Utilities Authority
1645 Ferry Avenue
Camden, NJ 08101
and
Tom Pedersen
Camp Dresser & McKee Inc.
One Cambridge Place
Cambridge, MA 02139
EMS COMPONENTS
The NEIC guideline identifies 12 key elements that are to be included in an EMS and describes components that must be documented in an EMS manual. This section provides a brief overview of some of those elements as implemented in CCMUA's EMS.
- Environmental Policy
- Environmental Requirements
- Assessment, Prevention, and Control
- Environmental Incident and Noncompliance Investigation
- Environmental Training, Awareness, and Competence
- Environmental Planning and Organizational Decision-Making
- Pollution Prevention Program
- Continuing Program Evaluation and Improvement
Environmental Policy
The cornerstone of CCMUA's EMS is its environmental policy. This written statement addresses the organization's public commitment to environmental compliance, continual improvement, and general environmental performance.
Camden County Municipal Utilities Authority Environmental Policy
The mission of the Camden County Municipal Utilities Authority employees is to be committed to our customers, the public health, and quality wastewater management. The Camden County Municipal Utility Authority Environmental Policy supports the CCMUA's mission through a proactive commitment to:
- Compliance with applicable federal, state and local environmental permits, regulations, laws, and statutes.
- Continual improvement of:
- Pollution prevention activities
- Environmental performance
- Communicating environmental matters to all employees, site visitors, and neighbors.
The CCMUA commissioners adopted the environmental policy on June 19, 2000. To conform to the NEIC EMS guideline requirements that environmental policy should be communicated to all employees and available to other interested stakeholders, such as neighbors, suppliers and vendors, and regulatory agency personnel, each CCMUA employee received a copy of the environmental policy and it is posted on the CCMUA Web site ( http://www.ccmua.org) for reference.
Environmental Requirements
The CCMUA EMS relies on the EMS implementation team, through monthly meetings, to identify opportunities for improving environmental performance. The EMS implementation team meeting notes are used to communicate progress to the EMS steering committee, and the EMS program manager provides a monthly report to the CCMUA Board of Commissioners that addresses environmental performance. The CCMUA EMS Manual provides for explicit identification of responsibilities for regulatory reporting requirements are identified in the New Jersey Discharge Elimination System (NJDEP) renewal permit and other regulatory agencies' requirements. This ensures that the Board of Commissioners' environmental performance goals for the company are disseminated throughout the organization from top to bottom and that the Board is kept apprised concerning the extent to which these policies are being implemented.
Assessment, Prevention, and Control
The CCMUA EMS involves all staff implementing corrective actions on a continual basis to address problems identified during the course of normal operations. Corrective actions include immediate actions to stop the problem; interim actions put in place until permanent action can be implemented; remedial actions to address other affected areas; and preventive actions to prevent the problem from recurring. Continual observation and monitoring of wastewater treatment processes ensures continual performance improvement. Operators provide feedback following shifts changes to allow for effective and timely communication of important information between critical staff functions.
The CCMUA EMS Manual also describes use its Operations and Maintenance Department's computer system and scratch-pad to track work order status and specific communication protocols for sewage treatment plant operators on shift change. The process provides continual communication and tracking of performance assessment over the three WPCF operational shifts. Standard operating procedures contained in the CCMUA Operation and Maintenance Manual (CCMUA, 1999) and in unit-specific manuals are not reproduced in the CCMUA EMS Manual but incorporated by reference. The EMS does however provide a forum for discussion of SOP development needs by the EMS implementation team. The EMS implementation team also evaluates on an ongoing basis the need for new or modified SOPs for each new process or equipment changes made.
EMS implementation team members are responsible for developing checklists that are used to conduct self-assessments of duties and responsibilities as a way to look for opportunities to improve environmental performance. The completed self-inspection checklists are reviewed and discussed by the EMS implementation team as a means to review operator feedback and for facilitating and communicating these opportunities to supervisors and subordinates.
Environmental Incident and Noncompliance Investigations
The CCMUA EMS Manual identifies reporting requirements and procedures for environmental incidences and compliance issues. The EMS implementation team investigates emergency condition occurrences and potential violations of environmental regulation and permit requirements and reports findings to the EMS implementation team and EMS steering committee. The EMS implementation team designates an individual responsible for each investigation and will monitor the schedule for conducting the investigation and reporting findings to the EMS implementation team and EMS steering committee. The designated lead investigator is responsible for identification of the root cause(s) of the potential violation and for developing a corrective action plan that includes actions to prevent recurrence of the potential violation.
The EMS implementation team conducts quarterly assessments of the effectiveness of each corrective action put in place as a means of continual performance improvement. The EMS implementation team recommends actions to be taken to modify the corrective actions as needed and then checks these actions in a continual plan-do-check-act cycle. The corrective actions are reviewed on a regular basis until such time that the corrective action is determined to meet its intended purpose. The EMS Implementation Team uses trend analyses to assess operational data and to assess the effectiveness of corrective actions implemented. For every corrective action taken, and for each piece of new or repaired equipment installed, and for each new or revised process or procedure instituted, the EMS implementation team assigns an individual the responsibility for monitoring and reporting on its effectiveness.
Environmental Training, Awareness, and Competence
Each employee of the CCMUA has received a copy of the environmental policy and new CCMUA employees are provided a copy of the environmental policy as part of their orientation. Awareness training is conducted by EMS implementation team and EMS steering committee members. Continual learning is the responsibility of each employee of the CCMUA and each employee is expected to identify to their supervisors training that they feel would help to improve their performance.
Environmental Planning and Organizational Decision-Making
The EMS implementation team and EMS steering committee provide input for the annual capital budgeting process, and the EMS program manager includes capital budget and planning issues on the agenda for he EMS implementation team meetings that take place during the budget planning period. The EMS program manager is also responsible to ensure that the input of the EMS implementation team and EMS steering committee is integrated at the earliest stage and throughout all planning phases for all study, design, construction, and operations project.
Pollution Prevention Program
The EMS Manual describes CCMUA's internal program for preventing, reducing, recycling, reusing and minimizing waste and emission, including their Industrial Pretreatment Program (IPP), odor control systems improvements, and the sludge management program. The Delaware No. 1 WPCF is a pollution prevention facility and as such efforts are made to optimize plant performance and prevent pollution. CCMUA employees are encouraged o identify ways to minimize waste emissions and to look for ways to improve operations. These pportunities for improvement are discussed in the daily operations and maintenance staff meetings, as well as at the regular EMS implementation team meetings.
Continuing Program Evaluation and Improvement
The EMS steering committee conducts internal annual assessments. The findings from the Assessment are summarized in a report and submitted to the CCMUA Board of Commissioners. The annual assessment provides for a systematic examination of conformance to the environmental policy and the EMS Manual and the evaluation of system effectiveness. As part of this annual assessment the EMS steering committee considers the following questions:
- Are policies and procedures implemented and proactive?
- Is preventive action approach providing early warning of potential compliance violations and supporting continual environmental performance improvement objectives?
- What motivates staff to help maintain compliance and improve environmental performance?
The EMS steering committee will use the annual evaluation to review the effectiveness of systems, policies, and procedures; consider opportunities for environmental improvement; communicate to the CCMUA Board of Commissioners progress made and to seek support in solving problems; demonstrate ongoing senior management commitment to the environmental policy and the EMS; and to recognize the contributions made by staff and the community. The CCMUA is still considering whether a third-party audit of the EMS will be beneficial in improving EMS effectiveness.
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