Consultation on fire prevention plan in EA permits

Consultation on new Fire Prevention Plan for EA Permits:

The Environment Agency has released a consultation on proposed changes to a Fire Prevention Plan. A Fire Prevention Plan (FPP) is already required if you have a permit issued by the Environment Agency to store or treat combustible waste on your site, for example to compost green waste. The permit will specify that a FPP is required. The advice can also provide guidance for those with a waste exemption.

The NFU welcomes any responses from members who also undertake a permitted waste operation on the proposed changes. Please send comments to Martin Rogers at bWFydGluLnJvZ2Vyc0BuZnUub3JnLnVr.

New proposed changes to Fire Prevention Plans:

The Environment Agency wants to introduce measures to ensure that the maximum duration of any fire is 3-4 hours. This would mean having techniques in place for active firefighting such as water and soil for suppression, equipment to break burning piles apart and to remove unburnt material. A suitable volume of water must be accessible to extinguish the fire, with information on how fire water will be contained to minimise impact to the environment e.g. through bunds or drainage.

To prevent fires lasting more than 3-4 hours, maximum permitted pile sizes have been updated, for example a compost pile could not be longer than 20m or taller than 5m.

The FPP of a new site, or a site undertaking a permit variation, would have to be approved by the EA before the permit is issued. The FPP would be a standalone document and evidence would need to be provided that all staff on site follow this.

A scaled map must be produced showing the location of all sensitive receptors within a 1km radius. The relative risk of each receptor being affected must also be recorded, e.g. through consideration of weather conditions. Sensitive receptors include:

  • human: schools, hospitals, nursing and care homes, residential areas, workplaces
  • critical infrastructure: roads, railways, bus stations, pylons, utilities, airports
  • environmental: surface and groundwater, protected habitats and air quality management areas

The site map for the site would still need to contain many points such as layout of buildings, water supplies, all access routes, areas of permeable and impermeable surfaces and drainage systems as well as:

  • processing equipment e.g. shredders/bailers;
  • weighbridge/wheel wash;
  • layout of waste piles/bays;
  • fire walls (optional);
  • quarantine areas;
  • detection and suppression equipment (optional);
  • boundary fencing;
  • CCTV (optional);
  • Extent of permitted area;

The consultation proposes retaining most of the information already required within a FPP, for example:

  • The amount and type of waste received, and how it is stored;
  • The locations and sizes of waste piles on the site;
  • The fire prevention techniques in place- such as monitoring and recording the pile temperatures and moisture, actions to take in response to a fire outbreak, separation distances of waste piles, location of materials such as water and soil to suppress a fire;
  • For combustible waste to not be stored for greater than 3 months, or 6 months for compost;
  • A quarantine area would still be required, with a minimum separation distance of 10m from all other waste piles. This area must always be retained with the intention that unburnt waste can be moved to this area during a fire outbreak. The quarantine area must be large enough to contain the largest waste pile. The location of the quarantine area could change.

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