Wood recyclers have launched a last-minute appeal for clarification on new standards for storing combustible material, fearing the proposals will hit businesses that have to hold large quantities, such as biomass.
The move from the Wood Recyclers Association (WRA) follows a briefing from the Environment Agency (EA) ahead of updated guidance on fire prevention plans (FPP), which are required as part of the permitting regime. Some plans are ‘bespoke’ for individual sites and permits.
The briefing indicated there would be a number of changes to the proposed FPP guidance version three, due to be published at the end of July, following input from independent fire experts at BRE Global.
They include lower stack heights for combustible material and a maximum storage time of six months for all materials.
WRA chair Andy Hill said such moves would “seriously threaten” some parts of the industry, including the biomass sector, which store large quantities of materials to feed power plants.
“We believe prevention is the key, combined with high standards of site management and the ability for operators to quickly isolate material to cut off the fuel supply in the event of a fire breaking out. With the right measures in place we would like to see the allowance of higher stack sizes in bespoke permits.
“Our worry is not that standard permit rules won’t work for small-scale operators. The problem lies in the fact EA officers then use these guidelines as the benchmark when considering bespoke permits, and that is where the danger is.”
He also argued that a proposal for a maximum of six months’ storage time for materials was unnecessary for unprocessed wood, had no scientific evidence to support it and did not take into account the seasonal impact in the waste wood industry.
“The EA has a duty to ensure their activities support those that they regulate not only to comply but to grow,” he added.
The EA briefing also set out potential savings to the emergency services from fighting fewer fires. Of 126 major waste fires on permitted sites since 2012, fire and rescue services spent 4,045 hours tackling incidents, an average of 35 hours per incident.
“The cost of these fires has totalled £4,715,290, with the average cost per incident of £81,298. If the objectives of the FPP guidance had been achieved, then the total time spent at these incidents should have been 452 hours, with each incident averaging 3.61 hours. The total cost would have been £606,908, with an average cost per incident of £9,633 and a total saving of £4.11m,” the EA said.
Hill questions the calculations: “The fire service is on call 24 hours a day, seven days a week. So it is not credible to count these hours as a direct cost saving. It is purely playing with numbers.”
“We have offered the EA the opportunity to visit some of our members’ sites to gain an understanding of what we want to achieve with them and we are willing to make that offer again now, before the new FPP is published and we are back to square one.”
Fire Prevention Plans
A waste site FPP is a document required and enforced by the EA as a condition of an Environmental Permit. The plan is a detailed document and management system used by site operators to effectively manage site fire risk and its impact on the environment. FPPs are intended to provide a management framework to:
- Prevent fires
- Identify and restrict the size and duration of fires
- Deal with situations that have the potential to cause fires, such as elevated temperatures in stacks
- Respond effectively and appropriately to fires on site in liaison with the fire service
- Protect the environment from the impact of fires; normally the environmental impact firewater run off (which is typically highly polluting)
Source: 360 Environmental