WHY MANAGING IT MATTERS
As supported by our recent materiality assessment, effective water management—both quantity and quality—is crucial for our manufacturing operations. Southwire uses water for our production activities. Water management is more critical in specific divisions and plants, such as the aluminum rod and copper rod mills, and is primarily used for contact and non-contact cooling. Given some Southwire locations’ proximity to creeks and rivers, storm runoff and wastewater discharges could impact nearby communities. Non-compliance with regulatory water quality requirements could have serious financial and reputational consequences for Southwire.
Southwire’s water management approach ensures we have an adequate supply of water within certain quality parameters from sustainable withdrawal sources to manufacture our products. Additionally, Southwire must comply with regulatory requirements—direct discharge permits for wastewater discharged to surface waters, local sewer ordinances for wastewater discharged to the sewer and stormwater permits for rainwater runoff.
While each Southwire site locally manages water use and wastewater discharge, ultimate accountability for our environmental performance rests with our executive vice president of international and operational development. In 2017, Southwire updated our performance management program so that, in 2018, incentive compensation for vice presidents and above will be tied to achieving certain performance metrics. Southwire’s senior vice president of sustainability, EHS & quality has compensation tied to our operational eco-efficiency targets (see below).
Our Environmental Policy and Principles guide Southwire’s responsible use of natural resources. While they historically did not explicitly mention water, we will revisit the policy in 2018 now that Water & Wastewater is a material topic. Locations having industrial activities exposed to stormwater contact, discharging wastewater to the sewer above certain thresholds, and/or are subject National Pollutant Discharge Elimination System (NPDES) requirements operate under state or local permits that specify appropriate compliance procedures. We also have facilities that are subject to surface water withdrawal permit requirements, groundwater protection obligations and/or stormwater no-exposure exemption certification procedures.
Environmental Management Systems
Southwire operates four facilities with third-party verified environmental management systems – our Huntersville, N.C., Plant, Hawesville, Ky., Plant and Carrollton, Ga., Utility Products Plant have achieved ISO 14001 registration, and our Tecate Plant is certified under Mexico’s Clean Industry Program. We are currently developing ISO-like environmental management systems (EMS) at all our other manufacturing operations. As part of the EMS process, each site conducts an “aspects and impacts” analysis to identify critical activities at the site and how these operations may affect the environment. Sites that identify Water & Wastewater as significant are required to develop a procedure, policy and/or plan to manage those aspects. Southwire is aiming to implement an EMS at all manufacturing sites by year-end 2021.
2021 SUSTAINABILITY GOALS & TARGETS
Southwire set an objective to eliminate all direct process water discharge from comingling with stormwater at our Carrollton wire mills. By successfully accomplishing this goal in 2017, we minimized impacts to surface water and eliminated this site’s need for an NPDES permit.
As part of our goal to achieve top decile operational eco-efficiency performance on the Dow Jones Sustainability Index, Southwire set a target to further reduce water intensity by 10 percent over our 2016 baseline by 2021. We report our progress toward this goal for the first time below. As indicated in the table, our performance declined by 4 percent due to operational and production factors.
2021 SUSTAINABILITY GOALS & TARGETS
|Water Reduction Goal||2016 BASELINE||2017||2021 TARGET|
|Further reduce water intensity by 10% over 2016 baseline by 2021||213 gal/ton||222 gal/ton||192 gal/ton|
Water & Wastewater Impacts
Southwire tracks the source of water used for our operations and works to minimize our impact in those areas. For municipal water sources, we obtain usage data from our utility bills. For rainwater and well water/groundwater use, we determine consumption volume based on internal meters where possible. However, this is not the case at our Building Wire Plant (BWP) and Utility Products Plant (UPP) in Carrollton, Ga.
At these plants, we have a stormwater collection system with a number of lift stations that pump water to a four million gallon stormwater storage tank, which is the primary source of cooling water for UPP and BWP. Currently, we do not have an accurate way to measure consumption of this water, so we estimate based upon cooling tower loss (the rainwater feeds the cooling towers). We use a standard calculation methodology to determine evaporation rate [Evaporation Rate = Circulation Rate x Delta T / 1000]. Circulation rate is the recirculation pump’s rated capacity. Delta T is set at 5°F, a best estimate for the average temperature drop for our cooling towers over the course of a year.
Water Withdrawal by Source
We also track water discharge by quality and destination for the three Southwire sites that require permits.
|Southwire Site||Destination||2017 Total Volume of Planned Water Discharges (gallons)||2017 Total Volume of Unplanned Water Discharges (gallons)||Treatment Method||Quality of Water||Water Reused by Another Organization|
|Copper Rod Mill||Buffalo Creek||33,528,410||0||Chemical and physical treatment||All discharge water quality met permit requirements||None|
|Kentucky Plant||Ohio River||21,939,263||0||Chemical and physical treatment||All discharge water quality met permit requirements||None|
|Carrollton Wire Mills||Buffalo Creek||3,315,532||7,350||None||All discharge water quality met permit requirements||None|
While Southwire does not maintain a central inventory, we identify the receiving stream in the Notice of Intent for permit coverage at our sites that require NPDES permits, which allow Southwire to discharge to a specific water body.
In Southwire’s history, there have been occasional incidents that have resulted in releases of process water, oils or other materials that triggered regulatory reporting requirements. These incidents are reported under Details of Regulatory Actions on our corporate website.
Southwire evaluates its management approach with biennial third-party EHS audits that verify we are in compliance with regulatory requirements and our own internal policies, and any non-conformances are remedied as expeditiously as possible. To further evaluate our performance, we engaged a third party to verify our 2016 and 2017 operational eco-efficiency data. The third party recommended Southwire change our scope and calculation methods for some of this data. Consequently, we restated our 2016 results, which were previously disclosed in our 2016 Sustainability Report. We referenced these changes in our general disclosure of 102-48: effect of restatements of information and reasons for them.