Paul Downing, Environmental Consultant provides us with information on the requirements of managing storage of both un-depolluted and depolluted ELVs with regard to FPPs.
Under the current environmental permitting regime regulated by the Environment Agency, there is a requirement to manage storage volumes of un-depolluted and depolluted ELVs held on-site in accordance with the current Fire Prevention Plan guidance. An environmental permit cannot be issued until the FPP has been approved.
The guidance states maximum volumes for pile sizes and for the number of ELVs and how they are stored. The guidance states that a 6m boundary around each waste pile or ELV rack is required (no more than 3 cars high and 2 abreast in a row – see point 10.1 above).
Whilst this 6m clearance around waste piles (and the perimeter of the yard) may be ok for larger sites, for smaller ELV operators it is causing a headache. You can minimise the clearance space by installing specifically designed fire-resistant fire bays (the 6m clearance applies within buildings too) but again this is adding additional cost to an already expensive process of compliance and in some cases, the installation of fire bays within a building is not practical due to operational issues.
In many smaller yards by the time you have taken into account 6m clearance around the perimeter and around buildings, 6m clearance around the quarantine area, 6m clearance around waste piles, there is very little space – if any – left for the storage of waste & ELV’s.
Many small operators have found that due to the size limitations imposed by the FPP guidance, the business becomes commercially unviable even if they can meet all of the conditions of the standard rules permit. For example, standard rules permit SR 2015 No13 which allows a throughput of 75kT per annum – allows no more than 50t of hazardous waste & 50t of tyres on-site at any one time. Many small operators may think that they can apply for this permit as their business will be way below these thresholds, however, if the yard is not large enough to accommodate even 20% of these volumes under the FPP guidance then it is not the permit conditions becoming the limiting factor but the FPP itself.
A row of 30 depolluted ELV’s 2 cars wide, 3 high and 5 cars long will take up about 20m x 4m square = approx. 80 Metres Square. Add in a 6m clearance around it and you need 512 Metres Square area just for this one storage area. You then, of course, need another area with 6m clearance around it for tyres, undepolluted ELVs and any other combustible waste you want to store on the yard.
In short – if you want to comply with the FPP guidance and the conditions of the environmental permit then you will need a relatively large yard even for a modest waste operation. You will need to supply scaled drawings of the layout of your yard as part of the FPP and permit application as well as demonstrating that you have access to enough water to fight the fire and also retain it on site after the fire brigade. You will not be able to allow it to discharge it to surface water systems.
If you need help with FPPs or environmental permit applications, please call Paul on 07790147084 or visit www.pauldowningltd.co.uk