DEVELOPMENT OF THE PLANNING PRINCIPLE OF THE ISO 14001 ENVIRONMENTAL MANAGEMENT SYSTEM STANDARD AT THE WORSLEY ALUMINA REFINERY, COLLIE, WESTERN AUSTRALIA
P.B. Johnston and R.F. Wright
Worsley Alumina Pty Ltd, Collie, Western Australia, 6225
One of the statutory requirements of the Worsley Expansion is the development and implementation of an environmental management system (EMS) in accordance with the principles of the ISO 14001 EMS standard. The development of the planning phase from the standard has involved the formalisation of environmental teams to facilitate the environmental compliance assurance program, develop and achieve environmental objectives, targets and action plans, and report environmental performance within a comprehensively structured system as required under ISO 14001.
Cross-functional environmental teams, consisting of personnel with engineering, environmental and operations backgrounds, are involved in the planning, implementation and review phases of the environmental management programs in each business management area. This has created a greater sense of ownership, awareness and responsibility for the environmental aspects in each area.
A comprehensive environmental compliance assurance program is being developed to provide the framework required for Worsley to monitor progress and compliance against the 120 environmental commitments and conditions binding the project, and another estimated 280 clauses of legislation relevant to the environmental aspects of the project. The program provides for the allocation of responsibility for each legal requirement, the means of achieving compliance and an auditing function to monitor compliance.
Identification of environmental aspects and environmental impacts from the refinery has been a difficult and time-consuming process. Area environmental teams with their cross-functional expertise have proven to be essential in the process of developing the environmental aspects and impacts register.
Development of environmental objectives, targets and action plans from significant environmental impacts that have been subjected to a risk rating process by the area environmental teams has provided a focus on the environmental aspects that have the most significant implications to the project. This ensures that resources are allocated appropriately to environmental management programs.
environmental compliance, environmental management systems, ISO 14001
DEVELOPMENT OF THE PLANNING PRINCIPLE OF THE ISO 14001 ENVIRONMENTAL MANAGEMENT SYSTEM STANDARD AT THE WORSLEY ALUMINA REFINERY, COLLIE, WESTERN AUSTRALIA
Johnston, P.B Wright, R.F
Worsley Alumina Pty Ltd (WAPL) is a management company for the Worsley Bauxite/Alumina Joint Venture. The current participants in the Joint Venture and their respective interests are Reynolds Australia Alumina Pty Ltd (56%), Billiton Australia Pty Ltd (30%), Kobe Alumina Associates (Australia) Pty Ltd (10%) and Nissho Iwai Alumina Pty Ltd (4%).
The Worsley Project lies in the Darling Plateau, which forms the south-western margin of the Great Plateau of Western Australia. Bauxite Mining occurs near Boddington, mainly in State Timber Reserves on the eastern edge of the Darling Range in the northern jarrah forest. Crushed bauxite is transported 51 km by a two-flight conveyor belt system to the refinery site near the Worsley siding, 20 km northwest of the town of Collie. The Worsley refinery lies within the Augustus River Catchment in an area of historically logged jarrah forest. Raw materials and alumina are shipped through the port of Bunbury, 45 km to the southwest
The Alumina Refinery (Worsley) Agreement Act 1973 ratified the Agreement between the State Government and Joint Venturers, which provided the basis for the Worsley Project to proceed. This required the Joint Venturers to prepare and submit an Environmental Review and Management Program (ERMP) before project operations could commence. The final ERMP for the Worsley Alumina Project was submitted to the Government in October 1979. The Joint Venturers received environmental approval from the Government to proceed in 1980.
The bauxite mine was commissioned in 1983 and the refinery in 1984. The production of alumina reached 1.0 million tonnes per annum (Mt/a) in 1985. Refinement of operating procedures and a "debottlenecking" of the project increased production to 1.75 Mt/a in 1995. In October 1995 Worsley proposed a two-stage expansion. The first stage was an increase in the production of alumina from 1.75 Mt/a to 2.0 Mt/a with minor modifications to the refinery plant. The proposal was referred to the Environmental Protection Authority (EPA) in accordance with the provisions of the Environmental Protection Act 1986 (WA). The proposal was the subject of a works approval application to the Department of Environmental Protection (DEP). Approval to proceed with the proposal was given by the DEP in December 1995 (Worsley, 1995).
The second stage of the Expansion was an increase in the production of alumina from 2.0 Mt/a to 3.5 Mt/a by a major upgrade of existing plant facilities and the introduction of new process technology to increase efficiency. The proposal was referred to the EPA and the EPA determined that the level of assessment for the proposed Stage 2 Expansion was a Consultative Environmental Review. Worsley submitted the Consultative Environmental Review Proposed Expansion to 3.5 million tonnes per annum Alumina Production to Government in December 1995. Federal and State Government environmental approval to proceed with the project was given in July 1996. Stage 1 of the Expansion commenced in February 1996. Stage 2 of the Expansion commenced in October 1997. Commissioning of the expanded plant is scheduled for June 2000.
Stage 2 of the Expansion resulted in a total of 10 ministerial conditions (Minister for the Environment (Western Australia)) and 110 environmental management commitments that now binding the Project. One of the environmental management commitments requires Worsley to develop and implement an Environmental Management System (EMS) in accordance with the principles of the ISO 14001 standard prior to commissioning of the upgraded plant.
ISO 14001 was published as an international standard in September 1996 and has been adopted in Australia and New Zealand, where it is known as AS/NZS ISO 14001 (1996). The system provides a framework within which organisations can establish environmental policy and identify their obligations, set objectives and targets and establish a comprehensive structure to achieve the objectives and targets. The system enables organisations to facilitate planning, control, monitoring, corrective action, and review activities to ensure policy is complied with and the environmental management system remains relevant.
There are five principles of the ISO 14001 Standard
1 Commitment and Policy the organisation must have an environmental policy and commitment for the EMS by senior management.
2 Planning the organisation must determine and document all the environmental aspects and impacts and environmental requirements, establish objectives and targets and designate responsibilities and time frames over which the objectives are to be achieved.
The scope of this paper is focused on the strategies that Worsley is developing for the planning phase of the ISO 14001 standard.
The approach taken by Worsley in the development and implementation of an ISO 14001 EMS is to utilise the existing cross-functional team structures that have been developed for other business purposes. Environmental Practitioners along with Production Co-ordinators, Operators, Process, Chemical and Maintenance Engineers form environmental teams representative of each Production Management area of the Refinery. These teams have the responsibility for the development and achievement of environmental objectives and targets and are required to meet on a regular basis (eg monthly/quarterly). Three types of teams are recognised in Worsleys EMS;
The refinery environmental team comprises senior management involved in the production, engineering and environmental aspects of the business. Meetings are held on a quarterly basis. The role of the refinery environmental team is detailed below:
Area environmental teams comprise a cross functional group of production, engineering and environmental personnel. The production component of the team is generally very experienced in the business processes of the area and includes Area Co-ordinators (middle management), Facilitators and Operations personnel. Every team has a minimum of two operators. One or two engineers with expertise in process, chemical, maintenance or civil engineering and one environmental practitioner are involved in the team. A typical environmental team composition is given below:
- Area Coordinator
- Facilitator (2)
- Operators (2)
- Environmental Practitioner
Area environmental teams represent distinct business management areas of the operation and during the development and implementation phases of the EMS meet on a monthly basis. Each member of the team receives 12 hours EMS training. The role of the area environmental team is described below:
- Develop and maintain an environmental aspects and impacts register
- Identify the significant environmental impacts
- Ensure compliance is maintained with statutory conditions and commitments
- Set and achieve environmental objectives and targets
- Report performance against objectives and targets to the refinery environmental team.
A total of eight area environmental teams in various stages of development have been identified to date.
Some of the environmental aspects at the refinery are best managed at a site level rather than a management area level. Cross-functional teams are formed from personnel throughout the operation. Bauxite residue rehabilitation, energy efficiency and solid waste management are examples of environmental aspects that are currently addressed by issue environmental teams.
The Worsley Project is subject to a number of statutory environmental commitments, conditions, and clauses of legislation. A listing of the more relevant environmental legal requirements are listed below:
- Worsley State Agreement Act 1973
- Environmental Review and Management Program 1979
- Consultative Environmental Review 1995, Environmental Commitments (110)
- Consultative Environmental Review 1995, Ministerial Conditions (10)
- Environmental Protection Act 1986
- Environmental Protection Act 1986 Licence Conditions (30)
- Environmental Protection Act 1986 Works Approval Conditions (15)
Under the ISO 14001 standard Worsley is required to establish and maintain a procedure to identify and have access to legal and other requirements to which Worsley subscribes that are applicable to the environmental aspects of the operation.
Worsley contracted the services of a legal firm to identify the requirements imposed by the law on its activities as they relate to the environment. An estimated 400 environmental legal requirements were identified during the process. An Environmental Legislative Review Manual has been produced and circulated to all managers to ensure each manager is aware of their departmental responsibilities for maintaining compliance
The next step in the process was to incorporate all of the environmental legal requirements onto Microsoft Word documents, which are linked, to an integrated database system (SAP R3). The responsibility for ensuring compliance with environmental legal requirements was determined and allocated to the appropriate manager. Some of the environmental legal requirements were given dual or multiple managerial responsibility. Responsibility for CER environmental commitments and EPA licence conditions was delegated to the middle management level (Area Coordinators, Environmental Coordinator and Senior Engineers).
Compliance procedures have been developed for the CER environmental commitments and EPA licence conditions. These procedures identify the environmental legal requirement, who has responsibility for ensuring the requirement is complied with, and a list of tasks that are undertaken within a specific timeframe to ensure compliance is maintained. The system has been developed so that anyone that has responsibility for an environmental legal requirement can readily identify their responsibilities and the means of carrying out the tasks required for compliance.
Currently under development is an internal auditing system that will be designed to monitor performance against the CER commitments and licence conditions. The proposed system will involve notifying personnel with responsibilities for CER commitments and EPA licence conditions on a quarterly basis and requesting information relevant to the work undertaken against that commitment or condition during the reporting period. A series of questions for each commitment or condition will be developed and require specific short answer responses. The responses for each commitment and condition will be collated by an environmental practitioner and entered into the database. This information can be used to identify where environmental performance needs to improve and will be incorporated into the annual statutory reporting to the State.
The term environmental aspect is defined in the ISO 14001 standard as an element of an organisations activities, products or services that can interact with the environment. An environmental impact is defined as any change to the environment, whether adverse or beneficial, wholly or partially resulting from an organisations activities, products or services.
The term environmental aspect often gets confusing for people developing environmental management systems based on ISO 14001. Traditionally the terms environmental impact or environmental effects have been used to describe an organisations interaction with the environment. Within the standard environmental aspects and environmental impacts have a relationship of cause and effect. ISO 14001 focuses on the environmental aspects because this is the cause of the problem, and by identifying and rectifying the cause, the impact is mitigated or eliminated.
ISO 14001 requires an organisation to identify the environmental aspects of its operation that it can control and over which it can be expected to have an influence, in order to determine those which have or could have a significant environmental impact on the environment.
The strategy implemented by Worsley to identify the environmental aspects and impacts of its operation has been to initially identify the operational activities from each management area. For each activity, the environmental aspect(s) are determined along with the associated environmental impacts. An environmental practitioner and a member of the area environmental team, who are experienced and very familiar with the operation, carry out this process. The draft list of activities, aspects and impacts is then scrutinised by the area environmental team, amended accordingly and transferred onto the Environmental Aspects and Impacts Register for the Refinery. An example of some the activities, aspects and impacts listed on the Register is given below in Table 1
Activities, Aspects and Impacts at the Refinery
|Facility||Activity||Environmental Aspect||Environmental Impact|
|Bauxite Grinding||Convey Bauxite||Dust Emissions||Air Pollution|
|Desilication||Pump Slurry||Spillage||Soil Contamination|
|Overland Conveyor||Convey Bauxite||Noise Emissions||Noise Pollution|
|Residue Disposal Area||Rehabilitation||Revegetation||Restore Biodiversity|
|Powerhouse||Burn Coal||Particulate Emissions||Air Pollution|
The next step in the process is to determine the significance of each environmental impact. Significance is dependent on the severity of impact and the likelihood of occurrence of the impact. The severity of impact is based on the level of public relations impact, legal liability and impact on the environment. All area environmental team members are required to assess the criteria used for determining the severity of impact and make an informed judgement (1-4) for public relations impact, legal liability and impact on the environment. The scores from each team member are averaged to give a severity of impact score for each environmental impact. The data is entered onto a form as illustrated in Figure 1 below.
Severity of Impact Scoring Form
|Severity of Impact||Negligible
|Level of Public Relations Impact||x|
|Level of Legal Liability||X|
|Level of Impact on the Environment||x|
Each environmental impact is rated, based on the likelihood of occurrence. An impact that occurs rarely (< 1 per year) gets a score of one, occasionally (1-6 per year) two, frequently (6-12 per year) three and very frequently (>12 per year) four. Team members scores are averaged and together with the severity of impact score applied to the risk-rating matrix, which is shown below in Figure 2.
Environmental Impact Risk Rating Matrix
Severity of Impact
|2||Very Low||Medium||High||Very High|
Under Worsleys EMS an environmental impact is defined as significant, if it has a medium to severe risk rating and not significant if the risk rating is negligible to low.
ISO 14001 requires Worsley to develop environmental objectives and targets, at each relevant function and level within the organisation. The basis of developing objectives is to consider the organisations legal and other requirements and the significant environmental impacts. Consideration of the organisations, technological, financial, operational and business requirements and the views of other parties is also required under ISO 14001.
A program designed to achieve the objectives and targets is required under ISO 14001. The program must designate the responsibility for achieving objectives and targets and specify the means and time frame by which they are to be achieved. The program needs to be amended if the project relates to new developments or there are changes to the operation that affect the environmental aspects of the project.
The Refinery Environmental Team is responsible for developing the corporate environmental goals (objectives) and targets. The corporate environmental goals take into account the most significant environmental aspects and legal requirements that are relevant to the Worsley project. Environmental goals relating to ISO 14001 certification, greenhouse gas emissions, solid waste management, air quality, rehabilitation, workforce education and statutory compliance have been developed and applied to the project.
Area environmental teams are responsible for developing environmental objectives and targets for their area of responsibility. The development of an environmental aspects and impacts register and applying the risk-rating matrix to determine significant environmental impacts enables area environmental teams to prioritise the list of aspects with significant environmental impacts. Starting with the top priority environmental aspect, opportunities for improving the current management practice of that aspect are identified. Where an opportunity for improvement can be identified, an objective is developed with a number of targets and an action plan.
Environmental performance against the corporate environmental goals is monitored, updated and reviewed on a monthly basis by the Refinery Environmental Team and reported to the Joint Venturers on a quarterly basis. Environmental performance is communicated to area environmental teams and all levels of the organisation. All employees have electronic access to the environmental performance of the organisation.
Area environmental teams are required to develop detailed action plans in order to achieve the environmental objectives and targets. Progress against the action plans is reported to the Site Environmental Team on a quarterly basis. An example of an action plan that was developed from one objective is shown below in Table 4
Objective, Targets and Action Plan for a Significant Environmental Aspect
|Aspect and Objective||Target||Date||Tasks||Responsibility|
Prevent contamination of soil and groundwater from caustic unloading
|Confirm membrane integrity and extent of potential contamination||31-07-98||Meet with contractors/consultants
to plan exploratory dig
|Reprogram train times and confirm
|Expose membrane and inspect||PMc|
|Investigate the possibility of deeper contamination below membrane by drilling next to the membrane||07-08 98||Drill and collect samples at depth||KMc|
|Analysis of samples||BM|
|Interpret results and determine
|Redesign caustic control system above membrane||15-09-98||Preliminary design for WAPL approval||PJJ|
|Aspect and Objective||Target||Date||Tasks||Responsibility|
|Implement designed system||31-12-98||Assess inventory buildup logistics||PMc, PP, BH|
|Construction plan and tenders for contract||PJJ|
|Handover and commission||PJJ, PMc|
|Operational control||31-12-98||Develop and implement operating procedure||PJJ, GK, RZ|
|Communicate procedure to Raw
|Monitoring||31-12-98||Include monitoring requirements
(ie visual inspection and soil analysis)
in operating procedure
|PMc, GK, RZ|
The integration of existing environmental programs with the programs being developed as a requirement of ISO 14001 is a complex and time consuming task. It is envisaged that at a later date, environmental management plans incorporating objectives, targets and action plans from environmental teams in addition to the programs developed from the projects statutory environmental commitments and conditions will be prepared and updated on an annual basis. It is also proposed, that in addition to the statutory annual environmental reporting requirements, a report detailing the environmental achievements of the organisation against the annual environmental plan be prepared on an annual basis.
The development of the planning phase from the ISO 14001 EMS standard at the Worsley Refinery has involved the formalisation of environmental teams to facilitate the environmental compliance assurance program, develop and achieve environmental objectives, targets and action plans, and report environmental performance within a comprehensive structured system. Conclusions drawn from the EMS development and implementation project to date are:
- Utilisation of cross-functional environmental teams enables all of the key personnel relevant to the environmental aspects of a management area to be involved in the planning, implementation and review phases of the environmental management programs. This has created a greater sense of ownership, awareness and responsibility for the environmental aspects in each area. It is envisaged that environmental performance will continue to improve.
- Development of a comprehensive environmental compliance assurance program will provide the framework required for Worsley to monitor progress and compliance against the 120 environmental commitments and conditions binding to the project, and another estimated 280 clauses of legislation relevant to the environmental aspects of the project. The program provides for the allocation of responsibility for each legal requirement, the means of achieving compliance and an auditing function to monitor compliance.
- Identification of environmental aspects and environmental impacts from the refinery has been a difficult and time-consuming process. Area environmental teams with their cross-functional expertise have proven to be essential in the process of developing the environmental aspects and impacts register.
- Development of environmental objectives, targets and action plans from significant environmental impacts that have been subjected to a risk rating process by the area environmental teams. This has provided a focus on the environmental aspects that have the most significant implications for the project and ensures that resources are allocated appropriately to environmental management programs.
Standards Australia, (1997). Standards Australia Collections, Environmental and other management Standards, Standards Australia Publishing, Strathfield, New South Wales, Australia.
Worsley Alumina Pty Ltd. (1995). Consultative Environmental Review, Proposed Expansion to 3.5 million tonnes per annum Alumina Production, Perth, Western Australia, Australia.