Simon Walker, Founder and Director of SJW Enviro Consulting Ltd, provides us with his advice on why vehicle recyclers should consider site design to be FPP ready.
For several years now applications to the Environment Agency (EA) for environmental permits involving end-of-life vehicles (amongst other activities) require the production of a Fire Prevention Plan (FPP). FPPs are complex documents, and applicants for new permits should consider how their sites comply with their plan’s requirements.
As somebody who has completed permit applications that include FPPs for Authorised Treatment Facilities, it is fair to say that they are far easier to complete and implement when the operator is willing to incorporate FPP guidance requirements into the site’s design.
The objectives of an FPP are three-fold:
- Minimise the likelihood of a fire occurring
- Aim for a fire to be extinguished within four hours
- Minimise the spread of a fire within and beyond the site
The EA have produced a template for the production of an FPP. Many of the sections within the template are time-consuming to complete but generally straight forward. The most onerous sections relate to waste pile sizes, sources and quantities of firefighting water needed to extinguish a fire, and how firefighting water is managed.
There must be enough water available for firefighting to take place and to manage a worst-case scenario, such as the largest combustible waste pile catching fire. Depending on the site, this could be water in storage tanks or lagoons, or access to water bodies, hydrants or mains water supply. These are also the sections where the EA invariably require additional information and explanation.
A site would need a water supply of at least 2,000 litres a minute for a minimum of 3 hours for a 300 cubic metre pile of combustible material, or a total of 360,000 litres. When all this water has been used to extinguish the fire, it is the site’s responsibility to contain it to prevent pollution of the environment. In terms of volume, 1000 litres of water equates to one cubic metre so for the example above; the site would have to contain 360 cubic metres of water. This is where good site design can make the permitting process quicker and less demanding.
Ideally, all sites would be flat, have an impermeable surface throughout and a sealed drainage system. This way a simple sealed bund around the perimeter of the site would be sufficient to contain fire water and would be easy to prove to the EA that it was adequate. Unfortunately, most sites are not flat, and some have areas of unmade ground where fully depolluted vehicles can be stored. By thinking about aspects of the FPP right from the start, especially pile size and firewater retention, operators can get ahead of the legislation and permitting process.
Some variations to existing permits, especially involving increases in quantities of material allowed on-site or extra waste streams may also require the production of an FPP. Here the situation is more complicated as the infrastructure is already in place. In this case, the approach should be to assess where firewater can be retained and in what volumes, or what modifications can be made to assist in firewater retention. Here, site hollows, tanks and other containers should be considered along with bunding or other retention structures. This will then allow a calculation of the volume of water a site can retain, determine the maximum waste pile allowed on site, and how it will be laid out.
The emphasis is on the operator to meet the requirements laid down in the EA’s guidance document and comply with the FPP’s objectives. By careful consideration of how the site will be laid out and operated, this can be achieved without unnecessary additional cost and time wasted during the permitting process.
If you would like to find out more, please contact Simon on 07471 910102 or email him at email@example.com