New EPA Guidance on Retention Requirements for Firewater Runoff has recently been published
The EPA Guidance on Retention Requirement for Firewater Runoff was finalised in 2019. A number of IE licensed facilities have already been contacted by the EPA (Agency) requesting a firewater risk assessment (FWRA) in accordance with the new guidance. If your licence contains a firewater retention condition (see Condition 3.10 of your licence or similar) then a firewater risk assessment will need to be completed. The Agency is requesting the FWRA to be submitted via the EDEN portal by the end of July 2020.
So what does this mean for your facility? Will you need firewater retention now?
A key change in the Agency's approach is the firewater retention qualifying criteria. There are now two qualifying criteria:
1. Environmentally Hazardous Substance Storage Thresholds
Substance storage thresholds are now based on hazard statements instead of risk phrases. If the quantity of H400+ chemicals is at or above the thresholds specified in the Agency guidance then firewater retention facilities will be required.
2. Environmental Receptor Criteria
Whilst consideration of environmental receptors has always been required in firewater retention risk assessments, this is now an explicitly stated qualifying criterion. If the facility has a direct stormwater discharge connection to one of the specified receiving waters then firewater retention facilities will be required.
Even if the facility doesn't meet these two qualifying criteria, firewater retention may still be required based on the assessment of Zones. The site is divided up into Zones based on distance and/or fire containment properties. AWN Consulting is able to advise on this.
Each Zone is assessed against two key criteria:
1. Significance of Fire Event (S)
This is an assessment of the amount of flammable materials stored, the level of fire detection and the level of fire suppression. Zones with large quantities of flammable materials or without automated fire detection and suppression systems may require firewater retention.
2. Environmental Hazard Potential (H)
This is an assessment of the amounts of hazardous chemicals stored. Zones with large quantities of hazardous chemicals, or with GMO laboratories, may require firewater retention facilities. Licensed hazardous waste facilities require firewater retention.
The Zones approach will help determine if firewater retention is needed for the whole site or just one or more of the Zones.
Once it is determined whether the site needs firewater retention as a whole or for a specific Zone(s), an assessment is made using one of the Agency's three new methodologies for calculating firewater. This will determine the volume of containment required. AWN Consulting can discuss feasible options with you to ensure your facility meets the Agency's requirements.
AWN Consulting has a wealth of experience completing FWRA's and is available to assist with your reporting requirements to ensure compliance with the new guidance. Please contact one of our risk assessment specialists if you require any further information or assistance.
The EPA Guidance on FWRA may be found at the Agency's website here.