lter has developed a comprehensive environmental program to manage risks associated with environmental aspects of recycling scrap metal. To
standardize our systems and programs across our operating facilities, in 2006, Alter implemented an Environmental Management System ("EMS") based on
a continuous improvement model. Our EMS was certified to the internationally-recognized ISO 14001:2004 standard in
early 2007, demonstrating our strong commitment to our environmental responsibilities by our senior executives and throughout our facilities.
Some highlights of the major elements of our environmental program are as follows:
- We control what comes into our facilities through implementation of an Inbound Materials Source Control Program. Elements of this program include communicating by various media what we can and cannot accept to our suppliers, inspecting materials as they arrive, and responding to the discovery of unauthorized materials.
- We utilize state-of-the-art radiation detection systems for both inbound and outbound material to protect our consumers.
- We implement site-specific pollution prevention plans required by environmental regulations and corporate policies to further prevent pollution. Examples include Stormwater Pollution Prevention Plans, Spill Prevention Control and Countermeasure Plans, Wastewater Discharge Plans, and Engineered Barrier Maintenance Plans.
- We implement structural and management controls for recyclable materials deemed environmentally significant.
- We obtain required environmental permits, registrations, and licenses pertaining to our operations.
- We implement practices to minimize air emissions, including advanced water injection systems at our mills, high-efficiency cyclones and closed-looped air handling systems at our secondary separation plants, and fugitive dust control practices on our access roads and shredder fluff stockpiles.
- We minimize the use of water at our shredders by using computer-controlled water injection atomizer systems in the mill, dry secondary separation systems, air or closed-loop cooling systems, water capture and recirculation systems, and reuse of non-contact cooling water as dust control.
- We continue to implement strategies and explore opportunities to conserve energy, fuel, and oil used in our operations.
- We properly manage byproducts and wastes generated from our operations and in the spirit of our EMS, we continually explore ways to improve recovery and increase reuse and recycling opportunities.
- We perform environmental training to facility personnel through development of a computerized environmental training module system.
- To assure we are doing as we say, we regularly perform Environmental Compliance Verification Reviews at each of our operating facilities to assure compliance with environmental regulations, permits, and company policies and programs.
- We perform SREA compliance evaluations of significant consumers to whom we ship scrap metal to ensure they are in compliance with substantive provisions of environmental laws.
- To continually improve our environmental programs, we review the environmental aspects of our scrap metal recycling operations annually and develop new environmental programs and initiatives as emergent issues arise.