Paul Downing, Environmental Consultant provides ATF Professional with an update on the Environment Agency’s (EA) Fire Prevention Plan (FPP) guidance and what ATFs need to consider especially where water on or near the site is concerned.
Since 2016, all companies wishing to apply for a vehicle breakers permit (ELV Permit) have been required to submit a fire prevention plan (FPP) with their environmental permit application.
The requirements on ATFs have been onerous with regards to separation distances, how large pile sizes (Un-Depolluted & Depolluted Vehicles) can be, and the volume of water required to be available for a specific waste pile size. It is not unusual to submit several amendments to the FPP before the EA approves the plan. Approval of the plan is a pre-requisite for getting the environmental permit issued.
A recent update to the fire prevention plan guidance by the Environment Agency on the 11th of January this year has made this process a little clearer, especially with regards to end of life vehicles (ELVs).
For whole ELVs or un-depolluted vehicles, the guidance stays the same, i.e. two vehicles wide and three high but no maximum pile size or length.
For depolluted ELVs or classed as baled ELVs, these can now be stored up to a 450 metre cubed capacity. The requirement for a six-metre distance between blocks of ELVs still stands.
The requirements for a sealed drainage system for both stay the same, i.e. a concrete pad for undepolluted vehicles and drainage system.
The most significant change in the new guidance for ATFs is in the amount and availability of water that is now required to be available to fight fires.
Hydrants should now be within 100m of the site boundary, and if no hydrants are close by, a water tank should be installed.
Water volumes required are now stated as 1800L per each ELV stored on site. This is somewhat relaxed compared to the previous requirement for a water supply by at least 2,000 litres a minute for a minimum of three hours. When calculated under the old guidance, this could lead to some rather large volumes of water being held in tanks on sites without nearby hydrants.
It is possible to state that you could have access to a nearby pond or lake if it is feasible. You should demonstrate that the water is available all year round, doesn’t suffer from clogging up with mud or solids if being pumped through pipes, and that you routinely check availability and volumes to ensure it doesn’t dry up or get over abstracted by someone else.
Other noticeable additions in the updated guidance include the requirement to ensure that groundwater will not be impacted by your operation (by allowing polluting materials to seep downwards) and also to be aware that persistant organic pollutants (POPS) are not allowed to enter the incoming waste stream. These tend to be organic chemicals used in fertilisers or pesticides and probably do not apply to ATFs as much as other industries.
The clarifications in the guidance make it slightly easier for companies to comply with the guidance, however, the overall process is still quite an arduous task.
If you would like more information on fire prevention plans or applying for an environmental permit, Paul can be contacted on 07790147084 or through his website www.pauldowningltd.co.uk