Membership Application Print/View

OMB No. 2010-0032
Expiration Date 08/30/06

Performance Track Membership Application

Covanta Montgomery, Inc.
Covanta Energy Corporation

A030078

CONTACT INFORMATION


	Name of your facility:
	Covanta Montgomery, Inc.
	Name of your parent company (if any):
	Covanta Energy Corporation
	Facility location
	Street Address:	21204 Martinsburg Road
	Address Cont:
	City:	Dickerson
	State:	MD
	Zip Code:	20842
	If your facility has multiple street addresses, please list any other addresses for its sites or buildings.

	Contact Information
	Name:	Mr. Steve Jenness
	Title:	Environmental Compliance Specialist
	Phone:	(301) 916-3031
	Fax:	(301) 349-5309
	Email:	sjenness@covantaenergy.com
	Facility/Company Website:	www.covantaenergy.com/facilities/wte/montgomery.asp
	Mailing Address (if different from facility location)
	Street Address:
	Address Cont:
	City:
	State:
	Zip Code:

SECTION A: TELL US ABOUT YOUR FACILITY


1.	How did you learn about Performance Track? (select all that apply)
	Internally within your company From a peer in your sector Environmental consultant
2.	What do you do or make at your facility?
	The Montgomery County Resource Recovery Facility (MCRRF) is a municipal waste-to-energy facility operated by Covanta Montgomery Inc., on behalf of the Northeast Maryland Waste Disposal Authority (NMWDA) and the Montgomery County Department of Public Works and Transportation (DPWT). The MCRRF consists of three independent combustion trains that have a total design capacity of 1,800 tons/day with an average heating value of 5,500 Btu/lb of municipal solid waste (MSW) combusted. The thermal output from the facility is used to generate up to 63 megawatts of electricity.
3.	List the North American Industrial Classification System (NAICS) codes that you use to classify business at your facility.
	562213
4.	Number of employees (full-time equivalents) who currently work in the facility:
	50-99
5.	Identify the environmental requirements that apply to your facility by completing the Environmental Requirements Checklist following Section E of this application. If there is something else that you would like to tell us about your facility, e.g, receipt of environmental awards, participation in other voluntary programs at the local, tribe, state, or Federal level, please describe them in the space below.
	1977 - Outstanding Civil Engineering Project awarded by the National Capital Section of the American Society of Civil Engineers 1998 - Excellence in Environmental Engineering for Operations/Management Grand Prize from the American Academy of Environmental Engineers 1998 - Waste-to-Energy Gold Excellence in Municipal Solid Waste Management from the Solid Waste Association of North America 2000 - Outstanding Waste-to-Energy Facility of the Year Award, Solid Waste Processing Division, from the American Society of Mechanical Engineers 2005 - Waste to Energy Gold Award, Excellence in Municipal Solid Waste Management from the Solid Waste Association of North America 2006 - Awarded Maryland Occupational Safety and Health Voluntary Protection Program (VPP) Star Status
6.	Is your facility currently a member of a state voluntary environmental leadership program?
	No
	If yes: What is the name and level of the program?

SECTION B: ENVIRONMENTAL MANAGEMENT SYSTEM

Are you a Responsible Care certified facility?


	If yes, please answer these supplementary questions regarding your Responsible Care certification:
	Please indicate whether your certification is to

	Are you a member of the American Chemistry Council (ACC)?

	Are you a member of the Synthetic Organic Chemical Manufacturers Association (SOCMA)?

	RC-certified facilities may now skip to Section C.

No (Please continue with question 2.)

Tell us if your Environmental Management System meets these requirements for:

Environmental policy:

Yes

Planning:

Yes

Implementing and operation:

Yes

Checking and corrective action:

Yes

Management review:

Yes

Have you done a comprehensive review of all activities conducted at your facility that could impact the environment (i.e., have you done an aspect analysis)?

Yes

Have you classified your aspects based on their potential harm to the environment, on community concerns, and/or on other objective factors (i.e., have you determined your significant aspects)?

Yes

When did you last update your aspect analysis? (mo/yr):

October 06

Have you completed at least one EMS cycle (plan-do-check-act)?

Yes

Did this cycle include both an EMS and a compliance audit?

Yes

Have you completed an independent assessment of your EMS in conformance with the Performance Track Independent EMS Assessment Criterion?

Yes

If yes, what method of EMS assessment did you use?

NEPT Independent Assessment Protocol

What was the date of your last independent EMS assessment? (mo/yr):

September 06

10.

Who performed the independent assessment?

William H. Barnes, Avogadro Environmental Corporation, 1350 Sullivan Trail, Easton, PA 18040

SECTION C: PAST ACHIEVEMENTS

First Achievement
1a.	What category have you selected from the Environmental Performance Table?
	Energy Use
1b.	What indicator have you selected from the Environmental Performance Table?
	Transportation energy use
1c.	Please provide any additional detail to describe your indicator (e.g., specific hazardous waste component, specific chemical that was reduced)
	The MCRRF utilizes a fleet of diesel-powered vehicles to move trash, yard waste, and ash containers from the plant rail yard to the tipping floor, ash handling facility, and the adjacent compost facility. An investigation was undertaken in 2004/2005 to identify a fuel additive that would optimize fuel economy, increase engine efficiency, and minimize pollutant emissions.
1d.	What activities or process changes did you undertake at your facility to accomplish your commitment e.g., technology changes in a particular process line, employee training?
	The ILFC TEN35 diesel fuel additive has been in active use at the MCRRF since 2005. Annual fuel records for 2006 indicate that the facility used a total of 55,400 gallons of diesel. Based on the 2004/2005 efficiency testing (hard carbon deposits and CO emission results) on a representative fleet vehicle indicated that fuel consumption decreased by >10% under ideal conditions, it is estimated that annual fuel usage has been reduced by at least 1,100 gal/yr (using a conservative 2% fuel economy improvement factor) and that CO emissions have decreased by approximately 500 lbs/year.


		Past	Current
2a.	Please provide information for these calendar years.	2003	2005
2b.	List the past annual quantity of the indicator (from two years ago) and the current annual quantity of the indicator (from the most recent year for which you have data).	56,500	55,400
2c.	What units are you using to quantify this indicator?	gallons
2d.	Estimate your past normalizing factor.	1	1.0
2e.	What is your normalizing factor based on? (e.g., production, employment)	MWh of Electricity Produced
2f.	Normalized Quantities	56,500.00	55,400.00

Second Achievement
1a.	What category have you selected from the Environmental Performance Table?
	Material Procurement
1b.	What indicator have you selected from the Environmental Performance Table?
	Hazardous/toxic components
1c.	Please provide any additional detail to describe your indicator (e.g., specific hazardous waste component, specific chemical that was reduced)
	In an attempt to minimize the amount of universal waste generated internally at the facility, regular fluorescent bulbs (4-ft and u-shape) were replaced with a low-mercury alternative manufactured by GE (Ecolux). In addition to being TCLP compliant (therefore allowing used bulbs to be disposed of as a nonhazardous waste), it also minimized the potential release of mercury.
1d.	What activities or process changes did you undertake at your facility to accomplish your commitment e.g., technology changes in a particular process line, employee training?
	The replacement of regular fluorescent and high pressure sodium (HPS) tubes with the low-mercury/TCLP compliant type has been completed, eliminating approximately 350 bulbs from the universal waste stream. This replacement has reduced the mercury content of installed fluorescent/HPS lamps by 80%, and minimizing the amount of leachable mercury upon lamp disposal.


		Past	Current
2a.	Please provide information for these calendar years.	2003	2005
2b.	List the past annual quantity of the indicator (from two years ago) and the current annual quantity of the indicator (from the most recent year for which you have data).	0.0325	0.0083
2c.	What units are you using to quantify this indicator?	Pounds
2d.	Estimate your past normalizing factor.	1	1.0
2e.	What is your normalizing factor based on? (e.g., production, employment)	MWh of Electricity Produced
2f.	Normalized Quantities	0.03	0.01

SECTION C: Application Commitments

Commitment 1

1a	What category have you selected from the Environmental Performance Table?	Air Emissions
1b	What indicator have you selected from the Environmental Performance Table?	CO
1c	Does your commitment include everything covered by the indicator (e.g., all VOCs, all non-hazardous waste), or a specific substance or component (e.g., ethane, cardboard)? All measurements should represent the performance level for the indicator across the entire facility. For many indicators, however, you may choose to focus your commitment on a specific subset of the indicator, e.g. a specific material, a specific group of toxic air emissions, a particular waste component, a specific VOC, etc.	All
1d	What activities or process changes do you plan to undertake at your facility to accomplish your commitment e.g., technology changes in a particular process line, employee training?	During calendar years 2005-2006, the MCRRF experienced a significant increase in the number and severity of tube failures in the evaporative section of the boilers. In an effort to reduce these events, improve boiler availability, and reduce resultant emissions from these malfunctions, the MCRRF proposes to perform a thorough evaluation of evaporation tube condition and develop an action plan for repair and/or replacement. CO emissions reflect both stationary and mobile source emissions from the facility.
2	Are you proposing this as a Challenge Commitment?	No
3a	Does this commitment address a significant aspect in your EMS?	Yes
3b	If no, please explain why you believe this indicator should be included as a performance commitment.

Baseline Future

4a Please provide information for these calendar years. 2005 2009

4b What units are you using to quantify this indicator? Tons

4c List the baseline annual quantity of the indicator and the annual quantity you are commited to achieve by the future year. 81 76

5 Does the quantity presented in the future quantity column represent an absolute goal or a normalized goal? Normalized goal (i.e. indexed to level of business in
baseline year)

6 Whether your goal is absolute or normalized, in your annual performance reports you will need to provide normalizing factors and normalized quantities of your annual data.

In the textbox to the right, please briefly describe your basis for normalizing. Examples of potential normalizing bases include:
-gallons of paint produced
-square feet of circuit boards sold
-number of patients seen
-dollars of sales adjusted for inflation
-number of employees (for R&D and administrative sites only)

MWh of Electricity Produced

7a Are you subject to Federal, State, Tribal, or local regulatory requirements for this indicator? Yes

7b If yes, please list those requirements, including the quantitative limits and compliance deadlines that apply to you. Explain how your commitment exceeds requirements.
The MCRRF maintains a Title V Permit (24-031-01718) and is subject to 40 CFR 60 Subparts Cb and Ea and COMAR Title 26, Subtitle 11 (air Quality) that limit CO emissions from municipal waste combustor (MWC) facilities. By implementation of these efforts, tube failures will be reduced resulting in improved production and reduced pollutant emissions. The facility's annual stationary CO emission limit listed in the Title V Permit is 180 tons/year.

Commitment 2

1a What category have you selected from the Environmental Performance Table? Material Use

1b What indicator have you selected from the Environmental Performance Table? Hazardous materials used

1c Does your commitment include everything covered by the indicator (e.g., all VOCs, all non-hazardous waste), or a specific substance or component (e.g., ethane, cardboard)? All measurements should represent the performance level for the indicator across the entire facility. For many indicators, however, you may choose to focus your commitment on a specific subset of the indicator, e.g. a specific material, a specific group of toxic air emissions, a particular waste component, a specific VOC, etc.
Specific

If your commitment is to a specific substance or component, please provide additional detail on your indicator (e.g., specific chemical to be reduced, specific waste component).
Petroleum distillate (cold cleaning solvent)

1d What activities or process changes do you plan to undertake at your facility to accomplish your commitment e.g., technology changes in a particular process line, employee training?
The MCRRF currently uses a typical cold cleaning solvent in its maintenance operations. This material is supplied by Safety Kleen and enters into the annual calculation of hazardous waste generated at the facility. The facility proposes to perform an evaluation of solvent cleaning options to minimize or eliminate the use of hazardous materials and/or generation of hazardous waste. This commitment involves the reduction of new cold cleaning solvent used by the facility.

2 Are you proposing this as a Challenge Commitment to reduce the use of Priority Chemicals?

If yes, what Priority Chemical are you committing to reduce? No

3a Does this commitment address a significant aspect in your EMS? Yes

3b If no, please explain why you believe this indicator should be included as a performance commitment.

Baseline Future

4a Please provide information for these calendar years. 2005 2009

4b What units are you using to quantify this indicator? Pounds

4c List the baseline annual quantity of the indicator and the annual quantity you are commited to achieve by the future year. 800 720

5 Does the quantity presented in the future quantity column represent an absolute goal or a normalized goal? Absolute goal (i.e., demonstrates improvement even if
       production increases)

6 Whether your goal is absolute or normalized, in your annual performance reports you will need to provide normalizing factors and normalized quantities of your annual data.

In the textbox to the right, please briefly describe your basis for normalizing. Examples of potential normalizing bases include:
     -gallons of paint produced
-square feet of circuit boards sold
-number of patients seen
-dollars of sales adjusted for inflation
-number of employees (for R&D and administrative sites only)

MWh of Electricity Produced

7a Are you subject to Federal, State, Tribal, or local regulatory requirements for this indicator? Yes

7b If yes, please list those requirements, including the quantitative limits and compliance deadlines that apply to you. Explain how your commitment exceeds requirements.
The MCRRF holds a Maryland Discharge Permit (01-DP-2844) and NPDES Permit (MD0065447) that requires the implementation of a Storm Water Pollution Prevention Plan (SWPPP) and a Spill Prevention Control and Countermeasure (SPCC) Plan to address prevention of spills and storm water contamination. By implementation of these control measures, the facility will minimize sediment runoff from the facility.

Attachments (if applicable) :

SECTION D: Tell us about your public outreach and reporting.

1. How do you identify and respond to the community's environmental concerns?

Few concerns have been raised in recent history. Community concerns are usually first directed through the Montgomery County DEP. State agency notifications are done properly and in a timely manner. Anticipated malfunctions or CEM analyzer outages are communicated to MDE.

The Dickerson Area Facility Implementation Group (DAFIG) and the Solid Waste Advisory Committee (SWAC) are two organizations that the facility actively participates in to maintain strong channels with the community for voicing any concerns.

2. How do you inform community members of important environmental matters that affect them?

Recently, CMI has implemented several communications programs that go well beyond permit or contract requirements including daily e-mail notification of any air permit exceedances to Montgomery County officials, and website access to hourly emissions data by the general public.The Dickerson Area Facility Implementation Group (DAFIG) and the Solid Waste Advisory Committee (SWAC) are two organizations that the facility actively participates in to maintain strong channels with the community for communicating important environmental matters.

3. How will you make the Performance Track Annual Performance Report available to the public?

Web Site
URL: http://www.covantaenergy.com/facilities/wte/montgomery.asp

Please Specify Other:Annual report to the community which includes environmental issues

4. Are there any ongoing citizen suits against your facility?

No

If yes, describe briefly below:

5. List references below:

Representative of a Community/ Citizen Group

  Organization: Dickerson Area Facility Implementation Group (DAFIG) and Solid Waste Advisory Committee (SWAC)

  Name: Walt Sonneville

  Phone: (301) 869-4460

State/tribal/local regulator

  Organization: Maryland Department of the Environment, Air and Radiation Management Administration (ARMA)

  Name: Steve Lang

  Phone: (410) 537-3944

Other community/local reference
(e.g., emergency management official or business associate)

  Organization: Private citizen (retired Montgomery County DPWT employee)

  Name: Dr. Ramana Rao

  Phone: (301) 972-3514

SECTION E: Application and Participation Statement

On behalf of Covanta Montgomery, Inc., I certify that:

I have read and agree to the terms and conditions for Application and Participation in the National Environmental Performance Track, as specified in the National Environmental Performance Track Program Guide and in the Application Instructions;

I have personally examined and am familiar with the information contained in this Application, including the Environmental Requirements Checklist. The information contained in this Application is, to the best of my knowledge and based on reasonable inquiry, true, accurate, and complete, and I have no reason to believe the facility would not meet all program requirements;

My facility has an environmental management system (EMS), as defined in the Performance Track EMS requirements, including systems to maintain compliance with all applicable Federal, State, tribal, and local environmental requirements in place at the facility, and the EMS will be maintained for the duration of the facility's participation in the program;

My facility has conducted an objective assessment of its compliance with all Federal, State, tribal, and local environmental requirements, and the facility has corrected all identified instances of potential or actual noncompliance;

Based on the foregoing compliance assessment and subsequent corrective actions (if any were necessary), my facility is, to the best of my knowledge and based on reasonable inquiry, currently in compliance with applicable Federal, State, tribal, and local environmental requirements.

I agree that EPA's decision whether to accept participants into or remove them from the National Environmental Performance Track is wholly discretionary, and I waive any right that may exist under any law to challenge EPA's acceptance or removal decision.

I am the senior facility manager and fully authorized to execute this statement on behalf of the corporation or other legal entity whose facility is applying to this program.

Signature/Date: ______________________________________________________

Name: Mr.  Mark Freedman

Title: Facility Manager

Phone Number: (301) 916-3031

E-Mail Address: mfreedman@covantaenergy.com

Facility Name: Covanta Montgomery, Inc.

Facility Street Address: 21204 Martinsburg Road
Dickerson, MD 20842

Mailing Address:

Address cont:

City, State Zip: ,

ENVIRONMENTAL REQUIREMENTS CHECKLIST

Facility Identification Information

1.
Do you have a RCRA identification number?
(A RCRA number is used in the RCRA Info for Resource Conservation and Recovery Act (RCRA) programs).

Yes

RCRA ID: MDR000513036

2.
Do you have a TRI identification number?
(A TRI number is used in the Toxics Release Inventory (TRI) for Emergency Planning and Community Right-to-Know Act).

No

3.
Do you have an AFS identification number?
(An AFS number is used in the AIRS Facility Subsystem of the Aerometric Information Retrieval System (AIRS) for Clean Air Act programs).

Yes

AFS ID: 2403101718

4.
Do you have a PCS/NPDES identification number?
(A PCS/NPDES number is used in the Permit Compliance System (PCS) for Clean Water Act programs monitoring National Pollutant Discharge Elimination System (NPDES) permits).

Yes

PCS/NPDES ID: MD0065447

5.
Do you have a FIFRA identification number?
(A FIFRA number is given to facilities regulated by the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)).

No

Air Characteristics

1. Is your facility a State Air Permit Holder?

Yes

2. Is your facility a Clean Air Act Major Source?

Yes

3. Is your facility a Clean Air Act Synthetic Minor Source?

No

4. Is your facility a Clean Air Act Minor Source?

No

5. Is your facility subject to New Source Performance Standards (NSPS)?

Yes

If so, which NSPS are you subject to? 40 CFR Part 60, Subparts Cb and Ea

6. Is your facility subject to National Emissions Standards for Hazardous Air Pollutants (NESHAPS)?

No

7. Is your facility subject to Section 112/Maximum Achievable Control Technology (MACT) standards?

Yes

If so, which MACT standard(s) are you subject to?40 CFR Part 60, Subparts Cb and Ea

8. Is your facility subject to SIP (State Implementation Plan) requirements (including Reasonably Available Control Technology (RACT))?

No

If so, which SIP requirement(s) are you subject to?

9. Is your facility a Title V permit holder?

Yes

10. Is your facility subject to Section 129 combustion requirements?

No

11. Is your facility subject to National Ambient Air Quality Standards (NAAQS)?

Yes

If so, which NAAQS are you subject to?NOx, SO2, CO, PM10, PM2.5, O3, and Pb

12. List relevant state/local/tribal/other air requirements:

40 CFR Part 60, Subpart Db
Code of Maryland Regulations (COMAR) Title 26, Subtitle 11
Title V Permit 24-031-01718

Water Characteristics

1. Is your facility a State Water Permit Holder?

Yes

2. Is your facility Required to Pretreat?

Yes

3. Is your facility a National Pollutant Discharge Elimination System (NPDES) Permit Holder?

Yes

4. Is your facility subject to Phase I of the NPDES Storm Water Program?

Yes

5. Is your facility subject to Phase II of the NPDES Storm Water Program?

No

6. Is your facility subject to the Spill Prevention Control and Counter Measure (SPCC) requirements of the Clean Water Act?

Yes

7. Is your facility subject to industry specific effluent guidelines and standards?

No

If so, which guidelines and standards are you subject to?

8. List relevant state/local/tribal/other water requirements:

Clean Water Act (CWA) Sections 402(b) and 316(b)
COMAR Title 26, Subtitles 6, 8, and 17
Maryland Discharge Permit 01-DP-2844
NPDES Permit MD0065447

Hazardous Waste Characteristics

1. Is your facility a Large Quantity Generator?

No

2. Is your facility a Small Quantity Generator?

No

3. Is your facility a Conditionally Exempt Small Quantity Generator?

Yes

4. Is your facility a Treatment, Storage, or Disposal (TSD) Facility?

No

5. List relevant state/local/tribal/other hazardous waste requirements:

40 CFR Parts 261, 262, and 274
COMAR Title 26, Subtitles 13-15
EPA ID Number MDR 000 513 036
Maryland Permit 2003-WTE-0538

Environmental Clean-Up, Restoration, and Corrective Action Characteristics

1. Is your facility a Potentially Responsible Party under CERCLA or Superfund for onsite clean-up?

No

If so, please provide Record of Decision date:

2. Is your facility a Potentially Responsible Party under CERCLA or Superfund for offsite clean-up?

No

If so, please provide Record of Decision date:

3. Is your facility a Potentially Responsible Party in a federal or state clean-up of hazardous waste and/or oil?

No

4. Is your facility Engaged in RCRA corrective action?

No

5. List other relevant federal/state/tribal/local environmental clean-up, restoration, or corrective actions not listed above. Please include date(s) of any remedy decisions.

None

Other Environmental Characteristics

1. Is your facility a Toxic Release Inventory (TRI) Reporter?

No

2. Is your facility regulated under the Safe Drinking Water Act?

Yes

3. Is your facility subject to Underground Storage Tank (UST) Regulations?

No

4. Is your facility regulated under Toxic Substances Control Act (TSCA)?

No

5. Is your facility subject to Worker Right-to-Know Regulations?

Yes

6. Is your facility required to file an emergency management plan under the Emergency Planning and Community Right-to-Know Act (EPCRA)?

Yes

7. Is your facility regulated under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)?

No

8. List relevant state/local/tribal/other requirements:

40 CFR Part 141
COMAR Title 26, Subtitles 4 and 6
Maryland Permit M090G011(04)

Commitment 1

Commitment 2

Commitment 3

Commitment 4

		Baseline	Future
4a	Please provide information for these calendar years.	2005	2009
4b	What units are you using to quantify this indicator?	Tons
4c	List the baseline annual quantity of the indicator and the annual quantity you are commited to achieve by the future year.	81	76

1a	What category have you selected from the Environmental Performance Table?	Material Use
1b	What indicator have you selected from the Environmental Performance Table?	Hazardous materials used
1c	Does your commitment include everything covered by the indicator (e.g., all VOCs, all non-hazardous waste), or a specific substance or component (e.g., ethane, cardboard)? All measurements should represent the performance level for the indicator across the entire facility. For many indicators, however, you may choose to focus your commitment on a specific subset of the indicator, e.g. a specific material, a specific group of toxic air emissions, a particular waste component, a specific VOC, etc.	Specific
	If your commitment is to a specific substance or component, please provide additional detail on your indicator (e.g., specific chemical to be reduced, specific waste component).	Petroleum distillate (cold cleaning solvent)
1d	What activities or process changes do you plan to undertake at your facility to accomplish your commitment e.g., technology changes in a particular process line, employee training?	The MCRRF currently uses a typical cold cleaning solvent in its maintenance operations. This material is supplied by Safety Kleen and enters into the annual calculation of hazardous waste generated at the facility. The facility proposes to perform an evaluation of solvent cleaning options to minimize or eliminate the use of hazardous materials and/or generation of hazardous waste. This commitment involves the reduction of new cold cleaning solvent used by the facility.
2	Are you proposing this as a Challenge Commitment to reduce the use of Priority Chemicals? If yes, what Priority Chemical are you committing to reduce?	No
3a	Does this commitment address a significant aspect in your EMS?	Yes
3b	If no, please explain why you believe this indicator should be included as a performance commitment.

1a	What category have you selected from the Environmental Performance Table?	Discharges to Water
1b	What indicator have you selected from the Environmental Performance Table?	Sediment from Runoff
1c	Does your commitment include everything covered by the indicator (e.g., all VOCs, all non-hazardous waste), or a specific substance or component (e.g., ethane, cardboard)? All measurements should represent the performance level for the indicator across the entire facility. For many indicators, however, you may choose to focus your commitment on a specific subset of the indicator, e.g. a specific material, a specific group of toxic air emissions, a particular waste component, a specific VOC, etc.	All
1d	What activities or process changes do you plan to undertake at your facility to accomplish your commitment e.g., technology changes in a particular process line, employee training?	The MCRRF has a storm water collection system that directs rainwater from roadways, parking lots, roof drains, rail yard, and other locations to a storm water pond at the southwest corner of the facility. This pond eventually discharges to a unnamed tributary of the Potomac River. The facility proposes to reduce sediment runoff at two selected locations that have shown to have significant impact on storm water quality. These efforts will focus on sediment filters and curbing. This committment focuses on the reduction of sediment discharged from these two selected locations. Annual quantities reflect a total of all sediment discharges to the storm water collection system at the facility.
2	Are you proposing this as a Challenge Commitment?	No
3a	Does this commitment address a significant aspect in your EMS?	No
3b	If no, please explain why you believe this indicator should be included as a performance commitment.	Sediment at this facility has the potential to include MWC ash that contains several heavy metals. Minimizing sediment runoff will therefore minimize possible heavy metal introduction to the environment.


1.	How do you identify and respond to the community's environmental concerns?
	Few concerns have been raised in recent history. Community concerns are usually first directed through the Montgomery County DEP. State agency notifications are done properly and in a timely manner. Anticipated malfunctions or CEM analyzer outages are communicated to MDE. The Dickerson Area Facility Implementation Group (DAFIG) and the Solid Waste Advisory Committee (SWAC) are two organizations that the facility actively participates in to maintain strong channels with the community for voicing any concerns.
2.	How do you inform community members of important environmental matters that affect them?
	Recently, CMI has implemented several communications programs that go well beyond permit or contract requirements including daily e-mail notification of any air permit exceedances to Montgomery County officials, and website access to hourly emissions data by the general public.The Dickerson Area Facility Implementation Group (DAFIG) and the Solid Waste Advisory Committee (SWAC) are two organizations that the facility actively participates in to maintain strong channels with the community for communicating important environmental matters.
3.	How will you make the Performance Track Annual Performance Report available to the public?
	Web Site
	URL: http://www.covantaenergy.com/facilities/wte/montgomery.asp
	Please Specify Other:Annual report to the community which includes environmental issues
4.	Are there any ongoing citizen suits against your facility?
	No
	If yes, describe briefly below:

5.	List references below:
	Representative of a Community/ Citizen Group
	Organization:	Dickerson Area Facility Implementation Group (DAFIG) and Solid Waste Advisory Committee (SWAC)
	Name:	Walt Sonneville
	Phone:	(301) 869-4460
	State/tribal/local regulator
	Organization:	Maryland Department of the Environment, Air and Radiation Management Administration (ARMA)
	Name:	Steve Lang
	Phone:	(410) 537-3944
	Other community/local reference (e.g., emergency management official or business associate)
	Organization:	Private citizen (retired Montgomery County DPWT employee)
	Name:	Dr. Ramana Rao
	Phone:	(301) 972-3514

Signature/Date:	______________________________________________________
Name:	Mr. Mark Freedman
Title:	Facility Manager
Phone Number:	(301) 916-3031
E-Mail Address:	mfreedman@covantaenergy.com
Facility Name:	Covanta Montgomery, Inc.
Facility Street Address:	21204 Martinsburg Road Dickerson, MD 20842
Mailing Address:
Address cont:
City, State Zip:	,


Facility Identification Information
1.	Do you have a RCRA identification number? (A RCRA number is used in the RCRA Info for Resource Conservation and Recovery Act (RCRA) programs).
	Yes
	RCRA ID: MDR000513036
2.	Do you have a TRI identification number? (A TRI number is used in the Toxics Release Inventory (TRI) for Emergency Planning and Community Right-to-Know Act).
	No
3.	Do you have an AFS identification number? (An AFS number is used in the AIRS Facility Subsystem of the Aerometric Information Retrieval System (AIRS) for Clean Air Act programs).
	Yes
	AFS ID: 2403101718
4.	Do you have a PCS/NPDES identification number? (A PCS/NPDES number is used in the Permit Compliance System (PCS) for Clean Water Act programs monitoring National Pollutant Discharge Elimination System (NPDES) permits).
	Yes
	PCS/NPDES ID: MD0065447
5.	Do you have a FIFRA identification number? (A FIFRA number is given to facilities regulated by the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)).
	No
Air Characteristics
1.	Is your facility a State Air Permit Holder?
	Yes
2.	Is your facility a Clean Air Act Major Source?
	Yes
3.	Is your facility a Clean Air Act Synthetic Minor Source?
	No
4.	Is your facility a Clean Air Act Minor Source?
	No
5.	Is your facility subject to New Source Performance Standards (NSPS)?
	Yes
	If so, which NSPS are you subject to? 40 CFR Part 60, Subparts Cb and Ea
6.	Is your facility subject to National Emissions Standards for Hazardous Air Pollutants (NESHAPS)?
	No
7.	Is your facility subject to Section 112/Maximum Achievable Control Technology (MACT) standards?
	Yes
	If so, which MACT standard(s) are you subject to?40 CFR Part 60, Subparts Cb and Ea
8.	Is your facility subject to SIP (State Implementation Plan) requirements (including Reasonably Available Control Technology (RACT))?
	No
	If so, which SIP requirement(s) are you subject to?
9.	Is your facility a Title V permit holder?
	Yes
10.	Is your facility subject to Section 129 combustion requirements?
	No
11.	Is your facility subject to National Ambient Air Quality Standards (NAAQS)?
	Yes
	If so, which NAAQS are you subject to?NOx, SO2, CO, PM10, PM2.5, O3, and Pb
12.	List relevant state/local/tribal/other air requirements:
	40 CFR Part 60, Subpart Db Code of Maryland Regulations (COMAR) Title 26, Subtitle 11 Title V Permit 24-031-01718
Water Characteristics
1.	Is your facility a State Water Permit Holder?
	Yes
2.	Is your facility Required to Pretreat?
	Yes
3.	Is your facility a National Pollutant Discharge Elimination System (NPDES) Permit Holder?
	Yes
4.	Is your facility subject to Phase I of the NPDES Storm Water Program?
	Yes
5.	Is your facility subject to Phase II of the NPDES Storm Water Program?
	No
6.	Is your facility subject to the Spill Prevention Control and Counter Measure (SPCC) requirements of the Clean Water Act?
	Yes
7.	Is your facility subject to industry specific effluent guidelines and standards?
	No
	If so, which guidelines and standards are you subject to?
8.	List relevant state/local/tribal/other water requirements:
	Clean Water Act (CWA) Sections 402(b) and 316(b) COMAR Title 26, Subtitles 6, 8, and 17 Maryland Discharge Permit 01-DP-2844 NPDES Permit MD0065447
Hazardous Waste Characteristics
1.	Is your facility a Large Quantity Generator?
	No
2.	Is your facility a Small Quantity Generator?
	No
3.	Is your facility a Conditionally Exempt Small Quantity Generator?
	Yes
4.	Is your facility a Treatment, Storage, or Disposal (TSD) Facility?
	No
5.	List relevant state/local/tribal/other hazardous waste requirements:
	40 CFR Parts 261, 262, and 274 COMAR Title 26, Subtitles 13-15 EPA ID Number MDR 000 513 036 Maryland Permit 2003-WTE-0538
Environmental Clean-Up, Restoration, and Corrective Action Characteristics
1.	Is your facility a Potentially Responsible Party under CERCLA or Superfund for onsite clean-up?
	No
	If so, please provide Record of Decision date:
2.	Is your facility a Potentially Responsible Party under CERCLA or Superfund for offsite clean-up?
	No
	If so, please provide Record of Decision date:
3.	Is your facility a Potentially Responsible Party in a federal or state clean-up of hazardous waste and/or oil?
	No
4.	Is your facility Engaged in RCRA corrective action?
	No
5.	List other relevant federal/state/tribal/local environmental clean-up, restoration, or corrective actions not listed above. Please include date(s) of any remedy decisions.
	None
Other Environmental Characteristics
1.	Is your facility a Toxic Release Inventory (TRI) Reporter?
	No
2.	Is your facility regulated under the Safe Drinking Water Act?
	Yes
3.	Is your facility subject to Underground Storage Tank (UST) Regulations?
	No
4.	Is your facility regulated under Toxic Substances Control Act (TSCA)?
	No
5.	Is your facility subject to Worker Right-to-Know Regulations?
	Yes
6.	Is your facility required to file an emergency management plan under the Emergency Planning and Community Right-to-Know Act (EPCRA)?
	Yes
7.	Is your facility regulated under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)?
	No
8.	List relevant state/local/tribal/other requirements:
	40 CFR Part 141 COMAR Title 26, Subtitles 4 and 6 Maryland Permit M090G011(04)