While fires are an all too frequent hazard for waste facilities around the world, regulations aimed at reducing this are surprisingly thin on the ground. In a bid to reduce fires by 50% from 2011 levels, in UK Environment Agency has introduced mandatory Fire Prevention Plans for new permits.
Over the last decade or so there have been huge changes in the way waste in the UK is managed. As the country seeks to meet recycling and landfill diversion targets there has been a significant increase in the level of material processing. While this is a good thing, it also means that those materials present a fire risk for a longer period of time. When fires do occur they can endanger the health of nearby residents and the lives of employees and firefighters – they also pose a significant threat to the environment.
In a bid to reduce the number of incidents in March 2015 the Environment Agency, issued the Fire Prevention Plan Guidance document in England. It was prepared by the Waste Industry Safety and Health (WISH) Forum with input and support from ESA (Environmental Services Association), the Chief Fire Officers Association (CFOA), CIWM (Chartered Institution of Wastes Management) and other bodies.
Who Needs an FPP
While existing facilities are not currently obliged to obtain an approved FPP, on 1 March 2016 it became a requirement to have an approved FPP for all applications for Standard Rules Environmental Permits in England. It also became a requirement for applications for a significant variation.
Sophie Crosswell, permitting expert at environmental consultancy firm Eunomia, which has worked with a number of clients to develop compliant FPPs, explains that this is likely to be where a site was either increasing the number of combustible waste streams or introducing one for the first time. Sites planning a significant increase in capacity of combustible materials may also require an FPP, as will any facility which has had a fire.
However, according to Crosswell there are a number of reasons for those sites not currently required to have an Environment Agency approved FPP to become early adopters.
“If you think about the Guidance now, while the EA aren’t breathing down your neck to implement an FPP, then there’s more time to think about your options. You’re not under pressure to deliver a system within a certain timeframe because you need to become operational,” she says.
Other key benefits include the potential to reduce insurance premiums and to reduce the site’s Operational risk appraisal (Opra) score. It can also reduce the social and environmental impact and preserve corporate reputation.
The roll out of the system got off to a mixed start, with some expressing concern about a lack of flexibility and the low pass rate for applications. To guide operators through the process, following significant public consultation, in July 2016 a revised document was published with improved advice and guidance.
The guidance applies to operators that store any amount of combustible waste and offers operators advice on preparing an FPP which meets the three core objectives:
- Minimise the likelihood of a fire happening
- Aim for a fire to be extinguished within 4 hours
- Minimise the spread of fire within the site and to neighbouring sites.
Crosswell explains that in regard to the first objective the most important thing to consider is the way in which waste is received and managed at the site: “Ultimately you’re trying to reduce the amount of combustible material you have on the site at any one time and having a plan for how quickly you’re moving it on.”
“In terms of the day to day running of the site the Guidance is fundamentally asking operators to look at how they use space,” Crosswell tells WMW. “Traditionally, large piles have been regarded as more convenient, but come with greater risk. The guidance has put limits on the size of the piles and asked for the introduction of separation distances. For a lot of operators the thought of having 6 metres between each pile is a barrier, so to reduce the fire risk they can use a firewall which is generally 40-80 cm thick.”
That’s a point reinforced by Jon Tomkins, senior consultant at Axion Consulting. “You’re looking at whether you’ve got CCTV, whether you’ve separation distances are 6 metres and whether your pile height is no more than 4 metres,” he tells WMW. “You can imagine there’s not a lot of room for maneuver, especially at smaller sites.”
“But what the agency has said is that if you can come up with evidence which provides some mitigation against those criteria, for example if the Fire Service has agreed that it’s low risk, and you’re storing piles higher than 4 metres they may accept that,” he continues.
With regards to pile size the Guidance states that No individual stack of stored waste should be of a size that means it can continue to burn and pose a significant threat to human health or the environment for more than 24 hours.
For windrow composting plants an FPP will be required but adherence to the stack sizes and distances for the active composting stage will not apply as long as the windrows or vessels can be reached for firefighting purposes. This is because the composting process requires that the waste needs to be kept moist and so compost is regularly monitored for moisture and temperature as part of the composting process. Therefore the risk of fire in a well-managed compost windrow or vessel is minimal.
It is also a requirement to have fire detection and suppression systems proportionate to the nature and scale of waste management activities. These can include smoke and heat detectors, visual flame detection systems and spark, infrared and ultraviolet detectors. If waste is being stored inside there must also be a fire suppression system such as a sprinkler installed. At Mechanical Biological Treatment (MBT) plants and similar the Guidance suggests that carbon monoxide sensors in air outlets may be suitable for detection.
However, when it comes to fire detection and suppression technology Crosswell says that finding the right option is site specific.
To be approved by the EA an FPP must provide details of the different types of activities conducted at the site, including waste management activities as well as any other activities that could be a fire risk. It must also include a site plan drawn to scale, showing the layout of buildings as well as the location of hazardous materials, gas cylinders and fuel tanks as well as main access routes for fire engines etc.
According to Crosswell the first thing to consider when starting an FPP is where the potential ignition sources are on the site.
“It’s easy to think about the ones you come across day after day and you’ve probably already got practices in place to deal with those,” she says. “But you need to take a step back and be objective... Look at different ignition sources. We all know there’s self ignition and you’ve also got arson and hot works, but there are also ignition sources that are a little bit more obscure.”
“What if you’re storing materials outside and its either fireworks night or Chinese New Year and a firework or lantern falls on your waste pile? Within the English Guidance there’s quite an extensive list of ignition sources, but that doesn’t stop you going above and beyond if there’s a particular risk due to the location of your site,” continues Crosswell.
Once the ignition sources have been identified the next task is to think about the control measures which could be implemented to mitigate each of them. Crosswell explains that for arson this could be as simple as improving security, while for things like self combustion it could mean looking at how materials are stored and monitored.
According to Tomkins while the process of producing an FPP can be daunting at first, it can be broken down into manageable steps. “You need to look at what is in place in the first instance, whether there is a routine, whether there’s CCTV in place, what the stack sizes are like, what separation distances are like, what firefighting equipment is in place – have you got a ring main system? Have you got interceptors? Have you got access to water if there was to be a fire?”
Other aspects to consider are the location of the site, whether there’s an evacuation plan in place and what plant equipment is on the site which may be put to use in the event of a fire. Staff training is also key to successfully implementing an FPP is both in terms of fire prevention and actions to take if a fire does break out onsite.
“Because each FPP has got to be designed for your site and take into account your risks, it’s not so easy to apply a one size fits all approach,” adds Crosswell. “Part of the problem of getting a plan approved is that every operator could come up with a slightly different solution. You’re not only coming up with a solution to keep the EA happy, but it’s got to work for you.”
"There’s no point in having a system that is so expensive to implement that it fundamentally undermines your business model. It’s about working within the guidance to find a balance,” she concludes.