Attero has in place an EHSMS certified to ISO 14001 and OHSAS 18001 standards, which is consistent with Indian regulatory EHS requirements. Further, the Company has presented plans to ensure that Attero’s operations will upon implementation of the specific agreed measures, address its environmental and social impacts and comply with environmental and social requirements including: all applicable host country laws and regulations; IFC’s Performance Standards; and the World Bank Group (WBG)/IFC environmental, health and safety guidelines. The information about how these potential impacts will be addressed is summarized in the paragraphs that follow. Further information is provided in the attached Environment and Social Action Plan.
Social and Environmental Assessment
Attero has, to meet regulatory requirements, prior to construction of the e-waste recycling facility (“recycling plant”) completed an Environmental Impact Assessment (EIA) in September 2008.The Company was accorded appropriate regulatory approvals to establish and commence operation of the recycling plant based on the EIA. The EIA encompasses the entire proposed recycling plant operations including shredding, plastic recovery, glass recovery and metals recovery. The EIA addresses key social and environmental impacts associated with the recycling plant operation including those pertaining to: emission to air, air quality and ambient conditions; noise; sourcing of water, water consumption and wastewater; solid waste; hazardous materials and hazardous wastes; biodiversity; traffic management; disaster and emergency response; and monitoring and reporting. Further, aspect and impact assessment was also undertaken as part of the development and implementation of the EHSMS. However, Attero will, as per an Action Plan agreed with IFC, implement additional mitigation/management measures consistent with good international industry practices including those discussed below to undertake all of its and the recycling plant’s operations in accordance with IFC Performance Standards.
Social and Environmental Management System (SEMS)
Attero has put in place an ISO 14001 and OHSAS 18001 certified EHSMS. The Company has defined and allocated EHS responsibility as part of the management system. The EHSMS includes procedures: for ensuring compliance with applicable legal, regulatory and other requirements; environmental, occupational health and safety training of employees; recording, investigation and reporting of social, environmental, occupational health and safety incidents; periodic monitoring and assessment of social, environmental, occupational health and safety performance; internal and external audits and implementation of corrective action; management review of the management system; and periodic reporting of social, environmental, occupational health and safety performance to the Company’s management. While the EHSMS is in place there are opportunities for further enhancing its implementation on the ground including those with respect to: obtaining, and ensuring at all times availability and currency of all permits/licenses/authorizations/consent; EHS training; incident reporting and investigation; and monitoring plan. The Company will incorporate IFC Performance Standard provisions into the EHSMS and further strengthen the EHSMS including: on engagement with affected communities in accordance with IFC Performance Standard provisions; by extending the provisions of EHSMS to its contractors, aggregators and LSP; and ensuring that contractors, aggregators and the LSP meet relevant provisions of Attero’s EHSMS.
Labor and Working Conditions
Attero has employed about 70 persons on its rolls and has engaged 20 contract workers for material loading/unloading as also 15 outsourced security staff. The Company signs an employment agreement with each employee which broadly outlines the terms of employment. However, Attero, to meet statutory requirements, is in the process of drafting Standing Orders (that detail the conditions of work and terms of employment for workers), which the Company will get approved and certified by appropriate labor regulatory authorities. The Company will display the certified standing orders and also abstracts of applicable labor laws in the local language in accordance with the provisions of these laws. Attero’s human resource policies and procedures are yet to be formalized. The Company will however develop and implement documented Human Resource Policies and Procedures consistent with IFC Performance Standard provisions. Further, Attero currently does not have procedures in place to ensure that contractors (including security service providers), aggregators and LSP meet all applicable labor laws. Accordingly, the Company will: ensure that its contractors (including security service providers), aggregators and LSP are in full compliances with applicable labor laws. Moreover, Attero will put in place procedures to obtain assurance on an ongoing basis on contractor, security service provider, aggregator and LSP compliance with applicable labor laws.
The Company has in place an occupational health and safety (OHS) management system certified to OHSAS 18001 standards and its effectiveness is expected to improve as it matures. Use of basic personal protective equipment (PPE), procedures for accident/incident reporting and investigation, safety signage, safety committee, medical checkup of employees and contract workers, fire safety equipment and plan and emergency response plans are in place. However, there are opportunities for further improving implementation of the OHS management system including with respect to: detailed hazard identification and risk assessment; workplace air quality monitoring (for presence of various metal dusts, fumes, acid mists, VOCs) and targeted exposure reduction program, where required; targeted medical surveillance program for workers and increased training and awareness on occupational health and safety both for employees and contract workers. The Company recognizes that there are labor working conditions, health and safety and environmental pollution related issues in the informal e-waste collection, dismantling and recycling sector, which the Company hopes to ameliorate within the limits of its influence including by sourcing and recycling PCB’s in a safe manner. Accordingly, besides requiring its aggregators, from whom Attero directly sources material, to fully comply with applicable labor laws and Attero’s EHS policies, the Company will also develop and implement a program to address labor working condition, environmental, occupational health and safety aspects, to the extent of its influence, in the supply chain beyond its aggregators.
Pollution Prevention and abatement
The objective of e-waste recycling plant is resource conservation and pollution reduction. The Company is collecting data to demonstrate that its recycling process is more energy efficient than the other known similar processes. The Company will manage environmental risks and impacts under the ISO 14001 certified EHSMS and will implement a continual improvement program on an ongoing basis.
The primary source of energy is grid electricity but the Company also has two DG sets with a total 1500 KVA as backup source of electricity. Furnace Oil is used as fuel in the furnace and smelter. The key sources of emission to air include the shredder, plastic extruder, furnaces, smelter and electro refining process. The key stack emissions are expected to include PM, SO2, NOx, CO, Dioxins & Furans, VOCs, Acid Mist/Gases, Arsine, TOC, Ammonia, chlorine, mercury. The Company has put in place air pollution control equipment (wet scrubber) to meet national requirements. However, the Company will: (a) undertake a benchmark monitoring of process stack emissions from furnaces and smelters, plastic pyrolysis unit, electro-refining unit, mechanical separation units including for all parameters indicated in the applicable IFC EHS Guidelines; and (b) for parameters that exceed IFC EHS Guideline limits, install appropriate upgraded air pollution control equipment. The Company has provided acoustic treatment to the DG set room in accordance with applicable regulatory requirements. Material impact on ambient air quality and ambient noise levels is not expected on account of the recycling facility. The Company will ensure that the refrigerant used in air conditioning system, and gases in fire extinguishers comply with the Ozone Depleting Substances Rules set by the GOI under Montreal Protocol requirements.
While currently the Company is drawing 5 m3/day groundwater, at peak production 100 m3/day of process water will be required and sourced from municipal supply. Currently, raw groundwater is treated through reverse osmosis (RO) plant to be used for process purposes. For potable use groundwater is treated through aqua guard (filtration and UV irradiation process). The Company will implement a drinking water quality monitoring and also a ground water quality surveillance program. The Company will generate 60 m3/day of process effluent and about 10 m3/day of sewage at peak production. Sewage is disposed through septic tank and soak pit and process effluent (including RO concentrate) treated through a 70 m3/day capacity effluent treatment plant (ETP). While electrolyte from electro-refining/winning process (which are essentially inorganic salts and acid based electrolytes) is recycled for 15 cycles, spent electrolyte about 45 m3 is also sent to the ETP. Wet scrubber wash, tank and equipment wash water and floor wash water from process areas is led to ETP. Though the treated effluent parameters are within national requirements, the ETP will be upgraded to meet IFC EHS guideline norms including for TSS, cadmium, copper, zinc, nickel concentrations in the treated effluent. While the Company is currently using the entire treated effluent on land, it proposes to implement programs to reduce fresh water intake by recycling the treated effluent. The Company has also installed a rain water harvesting system.
The process generates several hazardous wastes including used batteries, ETP sludge, used oil, electro-refining sludge, furnace slag, solids from bag filter and wet scrubber all of which are being stored on the plant premises. The Company is in the process of finalizing a contract with an authorized hazardous waste treatment, storage and disposal facility (TSDF) being set up near Roorkee in Uttarakhand, for ultimate disposal of all hazardous wastes from its operations. Till such time that the TSDF becomes operational, the Company will segregate, label and store all hazardous wastes under containment within its premises. The Company also receives dry batteries as part of the e-waste, which it is storing on premises till such time the Government of India identifies authorized recyclers of dry batteries, through whom these batteries will be disposed.
Attero also handles and stores hazardous materials including hazardous products, acids, e-waste, electro-refining intermediate stage process chemicals/solutions/material, other chemicals, oils and lubricants. The Company has procedures to label, segregate (taking into account their compatibility) and store all hazardous materials within secondary containment and will provide acid resistant lining in acid storage and handling areas. In addition, the Company will further upgrade the PPE made available to workers handling hazardous materials, enforce the use of PPE, provide training to employees handling hazardous materials, and provide washing stations in material handling areas. The Company will ensure that relevant material safety data sheets are posted at appropriate locations and necessary antidotes for accidental exposure are available and readily accessible. The Company will also further improve spill containment and runoff management through provision of peripheral spill and storm water containment bund around the processing facility and draining all flows from within this contained area into the ETP.
Community Health, Safety and Security
Attero has constructed the infrastructure and is using equipment that meets good industry practices. The Company will operate, maintain and monitor the recycling plant to ensure minimal community, environment, health and safety impacts. The Company will, as part of the EHSMS, put in place procedures to mitigate risk of uncontrolled release of hazardous materials and wastes. With increasing volumes, truck traffic is expected to increase. The facility is close to the main highway and the nearest residential community is 2 km away. Significant increase in truck traffic is not expected on account of the plant and the Project. Moreover, the Company will ensure that trucks bringing material are parked within the plant premises and Attero will provide appropriate facilities and amenities for truck drivers and helpers within the plant. Further, the Company will develop and require its transporters to put in place a safe transport procedure including provision of training to drivers in defensive driving and handling transport emergencies. The Company will review hazardous waste transport procedures adopted by the TSDF operator for conformance to Attero’s EHS policies and national regulatory requirements including those pertaining to: labeling and packing; transport emergency; manifests.
Attero has engaged a security service provider that deploys security personnel who are not armed. The Company will however upgrade its security personnel procedure and implement documented procedures for demonstrating that: past records of security personnel employed are screened; security personnel have clear objectives and permissible actions laid out; security personnel are trained in avoidance of human rights violations and handling various situations with clear procedures; security incidents are recorded, investigated and corrective action implemented; bona fide complaints against security personnel are investigated/disciplinary actions implemented; and there is a grievance mechanism for aggrieved members of community or employees in the event of a violation of the code for security personnel.
The Company has prepared an emergency response plan (ERP), which it will further upgrade and detail. Attero will also include in the disaster and emergency plan measures to address offsite emergencies. The Company will: communicate the ERP to stakeholders and also link the ERP to the district/local government ERP; undertake drills on emergency response and participate in drills conducted by the district emergency authorities; and continually improve the ERP based on outcome of the drills.
