The Company has presented plans to address these impacts to ensure that the proposed project will upon implementation of the specific agreed measures, comply with the environmental and social requirements including: the host country laws and regulations; IFC’s Performance Standards; and the relevant World Bank Group (WBG)/IFC environmental, health and safety guidelines. The information about how these potential impacts will be addressed by the Company is summarized in the paragraphs that follow.
PS 1: Social and Environmental Assessment and Management System
IFC’s assessment considered the ATL’s management of its EHS performance in the establishment and operation of its facilities; compliance with national and local permit requirements; and ATL’s engagement with local communities as well as its suppliers, regarding EHS performance. - Environmental & Social Assessment:
As a unit manufacturing rubber based products in an established industrial zone, ATL’s greenfield facility near Chennai was exempted by India’s national environmental protection rules from undertaking a formal Environmental Impact Assessment of its construction and operations. However, in accordance with the requirements the Tamil Nadu Pollution Control Board (TNPCB), ATL commissioned an Environmental Management Plan (EMP) in 2008 to assess the characteristics of the plant’s resource requirements and waste streams (emissions to air, waste water and solid waste) and ensure that operations meet standards prescribed by TNPCB.
The expansion in Vadodara facility was within ATL’s existing premises and necessary environmental clearances and permits were duly procured prior to the beginning of construction and operations respectively.
- Management Systems:
ATL has articulated its Integrated Management System (IMS) policy at corporate level that encompasses quality, safety, health and environmental aspects for all its operations. All of ATL’s existing facilities have implemented an IMS and have procured third party certifications for ISO/TS16949:2009 (quality management system standard for automotive industry); ISO14001:2009 and OHSAS 18001:2007.
For the upcoming facility near Chennai, products certification as per Indian and EC standards is currently in process. Also the plant is expected to be certified compliant with the requirements of ISO/TS16949:2009 by end-2010 and ISO14001 and OHSAS 18001 in 2011. As a part of Environmental and Social Action Plan (ESAP) disclosed together with this documentation, ATL shall submit to IFC the copies of IMS certifications by end-2011.
- Organization:
All the ATL facilities have full-time dedicated teams in place to manage the EHS related issues, with their well defined roles and responsibilities. Currently for the Chennai facility, the Corporate Projects team is responsible for procuring all the environmental clearances and managing the EHS aspects of project construction and commissioning. The safety officer from ATL works closely with the safety officers of each contractor for the site safety management.
Monitoring & Reporting:
ATL has a comprehensive and well documented monitoring program for the EHS aspects of their operations. Regular monitoring of process effluents, domestic effluents, stack emissions, workplace (temperature, noise and humidity), indoor air quality and ambient air quality as per its legal register and monitoring calendar for each facility. In addition, specific water and energy consumption are regularly monitored and reports are submitted to the management. Adequate monitoring and analysis capability (including equipment) is available in-house, in addition to the monitoring services provided by external vendors.
- Community Engagement: As in the case of new facility near Chennai ATL’s operations are located in industrial zones surrounded by other industrial units.
For its existing facilities, the company has an extensive engagement with the nearby communities through a wide range of CSR activities in the areas of health, education and livelihood. In addition, ATL has won several accolades for its pioneering work in the area of HIV-AIDS for the trucker community, including initiatives in partnership with IFC. These initiatives are described in detail in the subsequent sections.
PS 2: Labor and Working Conditions
ATL has a total of 10,200 employees across all its facilities, comprising full-time regular staff (approx 6,000) as well as contract workers. The regular employees comprise blue collar workmen, operators/team members/associates (engineering diploma holders) and management.
- Human Resource Policy, Management
ATL’s corporate HR department oversees the HR management across all its facilities, supported by the HR teams at each facility. Guiding principles, policies and operational procedures have been articulated and documented in the corporate HR manual. These are implemented across all the facilities with some localization to meet the specific needs.
The HR manual specifies the types and terms of employment, service conditions including procedures for hiring, probation, compensation and benefits, training, performance review, promotion, leave and vacation, etc. which are consistent with the national labor laws. The terms of employment and other details about the HR policies are communicated to the employees through a formal appointment letter.
Trade unions for the workmen exist at all the operational ATL facilities. These unions negotiate the long term wage agreements with the management of respective ATL facilities. The executives and officers are not unionized, but ATL does not prevent any efforts to form workers’ organization.
For workmen, Standing Orders have been developed and displayed at all facilities, in accordance with the local labor regulations. For the executives and staff, ATL has developed internal Service Rules on the lines of the Standing Orders and the same are displayed adequately at all its facilities. Both Standing Orders and the Service Rules articulate the formal grievance mechanisms in place for workmen and operators respectively.
For the senior management, ATL’s Code of Conduct provides the guidance on do’s and don’ts as well as the formal grievance mechanism. In addition to the formal grievance mechanisms are in place, ATL’s HR department as well as operational management has put in place several other means (such as open houses, help desks etc.) for the employees to communicate their concerns and issues, if any.
- Training and Human Resources Development
All the new employees at the Chennai facility undergo extensive 150 days induction training at ATL’s Limda facility. New recruits for other facilities undergo around 90 days induction training at its operational facilities; this covers all the aspects of the ATL’s operations – including environment, health and safety (EHS).
ATL has an extensive human resource development process for its employees, which is managed by a dedicated unit under the corporate HR department. This unit has developed several structured training programs for different levels of employees and covers behavioral/leadership aspects as well as technical/functional training. Many of these training programs are conducted by ATL’s in-house Apollo Laureate Academy as well as some of India’s top schools such as National Institute for Training in Industrial Engineering (NITIE), Indian Institute of Management (IIM), Ahmedabad, and IIM, Bangaluru among others.
In addition to the corporate training department, each facility has its own training units, which conduct regular skill upgradation program for the employees. Moreover, a separate Quality Training Cell is responsible for ongoing training of the key staff on the issues related to quality management; and a highly specialized domain-specific training activity is managed by the Research and Development department for its own team.
- Temporary Workers
With respect to the temporary workers and contract workers associated with activities such as construction or transportation, ATL ensures that the respective contractor complies with all the applicable regulations and good HR management practices, including adequate occupational health and safety measures. The contracts issued by ATL articulate these requirements and ATL’s staff through regular monitoring, ensures that the contractors adhere to these requirements. Site visits to the Chennai facility showcased the good safety practices by the construction contractors (such as access control, use of PPE by the workforce, adequate safety signage and good housekeeping) under the supervision of ATL’s safety and projects teams.
- Occupational Health and Safety
ATL has put in place elaborate safety management system at its existing facilities. For instance, the Limda facility has safety committees across the departments. A Work Permit System has been put in place and is strictly adhered to. Area wise Personal Protective Equipment (PPE) matrix has been developed and accordingly PPE is provided to, and worn, by all employees. ATL conducts ergonomic survey for work stations and necessary design modifications are made. Elaborate safety training is provided to employees & contract labor, which includes general safety training, work-area specific training, and emergency preparedness training
Safety monitoring is regularly conducted which includes monthly PPE audit, workplace monitoring of noise levels, illumination etc. Quarterly audits, including those carried out by technical teams from ATL’s other facilities, is an important tool to identify potential safety concerns and necessary remedial measures are implemented accordingly. ATL has also instituted Near Miss Reporting System, and these are displayed on the shop floor for creating safety awareness among its employees.
Adequate fire detection and suppression fighting equipment is fitted across the facility in accordance with the potential fire risks. This includes smoke detectors, central control room, sirens, PA system, fire extinguishers, fire hydrants as well as sprinkler system. Fire exits and the locations of fire extinguishers are clearly marked.
- On-site Emergency Response Plan:
Based on the Hazard Identification of Risk Analysis (HIRA), on-site emergency response plan has been developed for all the facilities – including its upcoming facility near Chennai. Accordingly, potentially hazardous areas have been identified and evacuation routes and assembly points have been designated and clearly marked. Regular mock drills are conducted to ensure the emergency preparedness. Based on one of its past experiences, ATL’s Limda facility has developed a flood management plan.
PS3: Pollution Prevention and Abatement
IFC’s assessment considered the Company’s operations with regard to resources consumption (water, energy, fuel), efforts to optimize resource inputs, waste minimization and management practices as well as the storage, handling hazardous materials used in the construction and operations of facilities.
The first step of radial tyre manufacturing processes is compounding and mixing elastomers, carbon black, and other chemicals such as vulcanizing agents, accelerators, plasticizers, and initiators. The mixture is extruded between pairs of large rollers to prepare it for the feed mill. As a result of the extrusion process, tread, sidewall and liner materials are prepared. The fabric and steel cord are coated with rubber. Bead wires are then processed and coated with rubber in extrusion process, followed by cutting and cooling of the various extruded and rubber-coated outputs. All the components (bead wires, coated fabrics, treads, etc.) are assembled on a tire-building machine, which is the followed by curing process, where the tyre undergoes heat and pressure treatment, before the final product is ready for final testing.
Tyre manufacturing process does not result in high volumes of wastewater. The air emissions from tyre manufacturing operations consist of dust from mixing processes, fume from vulcanization and emissions of combustion products from the steam boilers. The solid waste generated during the manufacturing process includes: non-vulcanized rubber waste, scrap rubber tyres, household waste and other waste such as packaging material, empty oil drums etc.
- Pollution Prevention and Resource Conservation:
As ATL has commissioned its new facilities, pollution prevention and resource conservation has been an important focus. Energy savings and sustainable water use are being adopted in the design of the facility and are further reduced in a systematic manner through continual improvements.
To achieve such reductions, key process parameters are regularly monitored, documented and internally reported. In addition, thermal, electrical and water audits are conducted by external parties as needed, which provide useful ideas for further improvements. For instance, following are some of the energy conservation measures envisaged/implemented by ATL:
Installation of solar street lights / solar heaters in bathrooms & kitchens
Use of energy efficient T5 lights in the plant
High efficiency hot insulation for piping and superior cold insulation for chilled water piping
De-centralization of utility systems to reduce the energy loss in transportation of the various utility services
Installation of energy efficient, imported, centrifugal compressors with high end technology for compressed air system and centrifugal chiller compressors for refrigeration system
Provision of state-of-the-art Building Management System (BMS) for the optimization of energy consumption in Heating, Ventilation & Air-conditioning (HVAC) system.
Variable Frequency Drives (VFDs) for the equipments with variable load patterns and Efficiency Class I motors for the equipments with major electrical power consumption.
Waste heat recovery from the boiler flue gas through systems like air pre-heater and economizer, Optimization of heat loss due to boiler blows down by using auto blow down system and recovery of waste heat from boiler blow down water through blow down heat recovery system.
Optimization of heat loss through excess air in boiler combustion process by using automatic excess air control system.
Implementation of profit centre concept for various Business Units (BUs) for the effective & efficient utilization of various utility services
As a result of such efforts and achievements, ATL has received several awards from state, central governments as well as industry associations. Similar best practices have been implemented in the greenfield facility near Chennai, which would make it a very efficient state-of-the art facility in not only India, but amongst the best in the world.
- Water Supply and Effluent:
The daily water consumption for ATL’s Limda plant is 2,200 cu.m/day. The raw water is supplied by the state government from the nearby Narmada river project and is then stored in a 37,500 cu.m storage reservoir. The process as well as domestic wastewater is treated in the effluent treatment plant on site (capacity - 800 cu.m/day) and the treated water is stored in fire-fighting sump and/or used for gardening. As a result Limda facility is a zero discharge facility.
For the greenfield facility near Chennai, the total demand for water will be 1,500 cu.m/ day which will be supplied by SIPCOT. The wastewater generated from the domestic use and process shall be treated and reused on-site (51,300 sq.m Greenbelt area shall be available for disposal of treated effluent – thus making it also a zero-discharge facility).
Both Limda and Chennai facilities practice rainwater harvesting.
- Solid and Hazardous Waste:
ATL complies with all relevant regulations for the storage, handling and disposal of hazardous materials used in the production process. The notified hazardous wastes are disposed of through licensed waste management contractors, as per the regulatory authorizations. Adequate controls during the storage and handling are in place and the quantities of solid waste thus generated and disposed of are regularly monitored and documented.
For its Chennai facility, majority of the waste is non-vulcanized rubber waste, which can be to large extent recycled within the plant. Scrap rubber tyres will be delivered to specialized companies to be re-used as construction material. Household waste and production waste that is not suitable for recycling will be disposed of in accordance with regulatory requirements. Hazardous waste management will be outsourced to licensed companies. Used oils will be collected into the waste storage facility located in the garage complex. Waste storage or handling will not have a significant effect on the environment outside the plant''s territory.
- Electrical Power Sources and GHG Emissions:
The daily power requirement for the Limda facility is 350,000 kWh of electricity, half of which is met with the supply from the grid, while the balance half (175,000 kWh) is met from captive power generation – using diesel generators (75,000 kWh) and gas turbines (100,000 kWh). As a part of this Project, ATL is planning to purchase steam from GAIL, which will be produced in boilers in the vicinity of Limda facility. These boilers will use the waste heat from the GAIL’s booster operations, which is currently flared away. Steam turbines (4MW and 350 kW capacities) will be installed to produce electricity with this waste heat-based steam to replace the diesel generator sets. This would result in equivalent LNG fuel saving of 87,000 scm/day and thus reduction in GHG emissions by approximately 50,000 t/annum. The purchased steam shall also be used in process, thus further reducing the fuel consumption.and associate GHG emissions.
The greenfield facility in Chennai has secured grid connection to meet its power demand. However, in order to ensure economical and reliable power supply, ATL is planning to establish a coal-based cogeneration system to produce 60 tons of steam /hr (to meet the entire process steam demand as well as 15 MW electricity). The overall thermal efficiency of steam and power generation through this cogeneration system is expected to be much better than obtained by separately buying electricity and generating steam in boilers.
This cogeneration system will use boilers based on Atmospheric Fluidized Bed Combustion (AFBC) technology, which is one of the most efficient and environment-friendly technologies for coal based power generation and considered as Best Available Technology as per the IPPC – Reference Document on Best Available Techniques for the Large Combustion Plants (July 2006). In order to further minimize GHG emissions, the Company shall explore the possibility of partially substituting the coal with biomass fuel in the CPP. AFBC technology can provide the necessary flexibility with regard to the fuel use.
- Air Emissions
Dust emissions from the process will be efficiently mitigated and controlled through ventilation and filtration systems. Solvent fume (Volatile Organic Compound) emissions will be negligible due to minimized use of solvents. Fugitive emissions from tyre vulcanization will be limited. However, because there are no permanent residential areas within the vicinity of the plant, this will not cause significant nuisance to local population. The main sources of emissions are the process areas and boilers. Adequate air pollution control equipment for controlling the air emissions from boiler sets and dust collector (comprising of dust collectors, scrubbers) will be provided for process emissions control. ATL has confirmed that it will meet the IFC’s relevant EHS Guidelines with regard to air emissions – including those from the proposed captive power plant at the Chennai facility.
PS4:– Community Health, Safety and Security
The Chennai site is located in an industrial area, far away from the nearby residential communities with 6 lane highways on its 2 sides. Similarly Limda facility is also located close to the national highway and far away (4-5 km) from the nearest Limda village. Hence the impact of vehicular movement on surrounding communities is expected to be minimal.
The Company contracts with a nationally certified security agency for 24 hour surveillance of the facility, with unarmed security guards.
While the impacts on the nearby communities due to ATL operations are expected to be minimal, all the facilities have developed detailed emergency response plans for their respective operations.
On the basis of the above information, and by implementing the Environmental and Social Action Plan it is concluded that the Project has been designed and will be operated in compliance with IFC’s PS and relevant environmental, health and safety guidelines.
