This procedure applies to the activities, products, and services of all
departments and operations of Covanta Fairfax. It describes the
assessment programs in place to evaluate conformance with legal and
other requirements, and to verify that the facility's EMS is fully
functional and conforms to the requirements of United States
Environmental Protection Agency's (USEPA's) National Environmental
Performance Track (NEPT) program and the Virginia Environmental
Excellence Program (VEEP).

1.  Environmental Compliance Audits

    1.  Covanta Corporate environmental compliance audits are performed
        to assess compliance status with respect to applicable legal and
        Covanta policy requirements.

    2.  Corporate environmental compliance audits are conducted on a
        four-year schedule (or more frequently if deemed necessary). The
        audits are performed by Covanta Corporate personnel and
        third-party contractors.

    3.  Identified audit findings are recorded and corrective actions
        are assigned and tracked using a form included in the audit
        report. Work orders may be generated to resolve some issues.

    4.  The Corporate compliance audit consists of the following major
        components:

-   Opening meeting;

-   Facility tour;

-   Document and records review;

-   Interviews;

-   Findings development;

-   Closing meeting;

-   Draft and final reports issuance; and

-   Corrective actions and tracking.

    1.  Results of environmental compliance audits can be discussed
        during the facility's management reviews.

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    1.  Environmental Quality Management (EQM) "Walkdowns"

        1.  EQM walkdowns of the facility are performed by the Covanta
            Regional Environmental Manager and the Environmental
            Specialist at a minimum of twice a year.

        2.  Walkdowns address conformance to environmental requirements
            that may be verified by visual inspection.

        3.  Identified EQM walkdown findings are identified and
            discussed during a meeting following the walkdown.
            Corrective actions are tracked using a dedicated form. Work
            orders may be generated to resolve some issues.

    2.  TS-204 Status Reports

        1.  Compliance with the Corporate technical standard (TS-204) is
            verified on a quarterly basis by the Environmental
            Specialist. This is accomplished by completing a TS-204
            compliance checklist, which is then sent to the Corporate
            Regional Environmental Manager.

        2.  Findings from TS-204 reviews are generally handled either
            verbally or through issuance of work orders. Corrective
            actions are tracked on the TS-204 status form.

    3.  Other Internal Compliance Reviews

        1.  A daily Continuous Emissions Monitoring System (CEMS) review
            is conducted by the Chief Engineer, Shift Supervisor,
            Control Room Operator, and Environmental Specialist to
            verify compliance with the facility's air permit emission
            limits.

        2.  The Environmental Specialist conducts weekly walkthroughs of
            the facility to evaluate compliance with environmental
            requirements that may be verified through visual inspection.

        3.  Monthly inspections of petroleum/all storage tanks are
            conducted by the Environmental Specialist.

        4.  Quarterly storm water evaluations are performed by the
            Environmental Specialist or an operator to verify compliance
            with the facility's Storm Water Pollution Prevention Plan
            (SWPPP).

    4.  EMS Audits

        1.  The Regional Environmental Manager oversees the EMS audit
            function including the coordination and scheduling of audit
            activities, identification of areas/operations to be
            audited, and designation of auditors.

        2.  All elements of the facility's EMS are audited a minimum of
            one time per year; all elements, however, do not necessarily
            have to be audited at the same time. The EMS audit includes
            a review of the facility's EMS Manual, procedures, plans,
            and other related documents and records, as well as an
            assessment of system implementation, to verify conformance
            with VEEP and NEPT EMS criteria as well as the facility's
            internal EMS requirements.

        3.  It is important that internal audits of the EMS be conducted
            in an objective and non-biased manner.  To ensure this
            objectivity, either the Regional Environmental Manager will
            personally conduct the audit or select appropriate personnel
            to conduct the EMS audit based on a combination of knowledge
            of NEPT EMS criteria and the facility's EMS, good
            communication skills, prior auditing experience, and a
            thorough understanding of the facility's activities,
            products, and services. The auditors may include
            Environmental Specialists from other NEPT facilities or
            internal facility personnel. In the event that internal
            facility personnel perform the system audits, they will not
            audit their own areas of responsibility or work products for
            which they are responsible for developing or supervising.

        4.  Personnel performing the EMS audit may audit directly from
            source documents or may develop and utilize checklists or
            protocols that capture the audit criteria relevant to the
            audit scope.

        5.  EMS audit results are recorded. Corrective actions related
            to audit-identified non-conformities are tracked and closed.

2.6 Results from the EMS audits are discussed during the facility's
management reviews.

Corrective and Preventive Actions Procedure (EMS-013)

Management Review Procedure (EMS-014)

The Regional Environmental Manager is responsible for overall
coordination and management of the environmental compliance audits, and
the semi-annual environmental walkdowns.

The Regional Environmental Manager is responsible for overall
coordination and management of the EMS audit process.

All facility personnel are responsible for cooperating with
environmental compliance and EMS auditors, as required, to ensure the
effective and efficient performance of assessments.

Facility Management and staff are responsible for closing out
environmental compliance audit findings/recommendations as soon as
possible following audit report issuance.

Facility Management and staff are responsible for timely resolution of
environmental walkdown findings.

Environmental Compliance Audit Reports

Daily CEMS Compliance Reports

Weekly Environmental Walkdown Forms

Semi-Annual EQM Walkdown Forms

Quarterly TS-204 Status Updates

EMS Audit Reports

None