Improving Our Performance
At Covanta, we know that maintaining our environmental performance—and exceeding, where possible, the expectations of our stakeholders—is critical to protecting our planet, our people and the prosperity of our business. We are committed to a goal of sustaining past emissions performance gains while maintaining 100 percent compliance with all discharge limits, including stack tests and the requirements of our continuous emission monitoring systems (CEMS). Our challenge is not only to meet these goals, but to meet them efficiently and consistently in the pursuit of continuous improvement.
We manage our environmental performance through a collaborative effort of our Operations and Environmental departments. Responsible for the day-to-day functioning of our facilities, the Operations department is ultimately responsible for operating our facilities in accordance with our permits and other requirements. The Environmental department is responsible for each facility’s understanding and compliance with all permit conditions. We manage compliance through a combination of our Environmental Management Information System (EMIS), technical standards, environmental procedures and a vertically integrated team of environmental professionals located at both the facilities and corporate headquarters. EMIS allows us to track timely completion of compliance requirements and manage associated compliance data. Our environmental performance is reviewed monthly with senior management.
Air emissions from EfW facilities are heavily regulated by both the U.S. EPA and state environmental agencies. Emissions from EfW facilities are determined both through routine stack tests (performed at least once a year) and through continuous emissions monitoring systems (CEMS). CEMS monitor flue gases continuously for carbon monoxide (CO), nitrogen oxides (NOx), sulfur dioxide (SO2), opacity, and carbon dioxide and/or oxygen. Facility operators monitor these parameters and adjust as needed to ensure proper operation and compliance. For example, monitoring CO levels continuously allows operators to respond to changes in the waste (e.g. wetter than normal waste that may have been collected during a rainstorm) to ensure complete and efficient combustion.
Other regulated pollutants are checked through a rigorous stack testing program performed by a regulator-approved third-party. The operating parameters under which the stack test is conducted (e.g. activated carbon addition rate, steam flow rate) set the standard for the facility’s operation until the next stack test is completed. Operating the combustion process and air pollution control equipment in accordance with these standards ensures compliance. These tests are scheduled well in advance of their performance, and contrary to myth, facility operators do not remove plastics from the waste stream or alter operations in any way to improve emissions performance during the test.
EfW Continuous Emission Monitoring System Compliance Performance
Our North American EfW facilities’ performance, as measured by CEMS, averaged 99.96 percent compliance in 2018 and 2019. Our stack test compliance rate in 2018 and 2019 was 100 percent and 99.93% respectively. In 2019, cadmium results from one of three units at our Camden facility exceeded the limit by 5.4% due to a malfunction event. The average cadmium emissions across all three units was less than 50% of the limit. Within a week of the initial testing we took Unit #3 down for maintenance and fixed the malfunction. A second test performed the following month was 40% below the limit.
Our Covanta Environmental Solutions wastewater operations, which pre-treat water prior to discharging to a publicly owned treatment works (POTW), achieved a 99.8 and 99.0 percent compliance rate with pre-treatment permit limits in 2018 and 2019 respectively.
Occasionally, we are subject to proceedings and orders that pertain to environmental permitting and other regulatory requirements, potentially resulting in fines or penalties. Our total environmental-related fines and penalties at our facilities were $169,522 and $30,422 in 2018 and 2019, respectively. Since our last disclosure, the fines in 2018 have been updated to include a $65,600 assessment finalized in 2020 for the failure to demonstrate operation of a dust collector installed at our Essex County WTE facility. The dust collector is separate from the main air pollution control equipment and no emissions exceedance was observed at the time of a state regulatory inspection. In addition, our Covanta Environmental Solutions New Castle facility was fined $400,000 in 2019 for alleged violations of waste tracking requirements from 2016 to 2017 that resulted from a management process established by the former owner. There was no allegation of environmental harm in the consent assessment finalizing the fine.
We have successfully maintained overall emissions reductions at our facilities: since the announcement of our first sustainability program in 2007, emissions are down by up to 72%. Today, we are finding ways to sustain our levels of emissions performance more efficiently by optimizing our operations.
To us, environmental excellence means that every Covanta facility meets or exceeds our strict standards for environmental performance, which we measure and track through continuous emissions monitoring systems, stack tests and discharge limits.