Recycling site operators in various sectors currently have the opportunity to consider waste material storage guidelines proposed by the Environment Agency as part of a consultation on the Fire Prevention Plan (FPP) permit requirements set to close on March 4.
The FPP guidance sets out different restrictions for different waste materials. Anaerobic digestion facilities, for example, are effectively exempt from having to draw up an FPP, but for operators dealing with waste wood, tyres, scrap metal and WEEE, it is a different story.
As a result, fire tests are currently being carried out at Cory Environmental’s Barling site in East London with the aim of providing scientific data on the fire risk posed by waste materials (see letsrecycle.com story).
However, the results of these tests are not expected until after the EA consultation closes, with testing of scrap metal only having started last week. Instead the results are expected to feed into the EA decision-making process on how it will handle permits in the future.
Earlier this month, the Wood Recyclers Association urged its members to both respond individually to the current EA consultation and write to their local MPs about the FPP plans, claiming there is “no scientific evidence” to support waste wood storage restrictions proposed by the EA.
This would appear to echo comments last year from WISH (Waste Industry Safety & Health) forum chair Chris Jones, who admitted that there was “no pure or hard science to stack measurements or separation distances” (see letsrecycle.com story).
The WRA, which claims to represent 80% of UK wood recyclers, said it has a number of concerns after having “extensively reviewed” the EA’s proposed Fire Prevention Plan (FPP) guidance.
Besides calling on its members to write to their local MPs over the issue, it is also submitting a formal response to the Agency consultation on the plans which closes on March 4.
According to the WRA, the Agency has “no scientific backing” to support the proposed FPP requirements for waste wood stock to be rotated on a 3-6 month basis, nor for the stipulated “unreasonable and unnecessary” aim of extinguishing any fire that might occur within 3-4 hours.
The proposed 3-4 hour burn time does not take into account individual site circumstances such as tonnage, material types, weather conditions and local fire-fighting strategies, the WRA said, and in any case tactics to tackle a fire should be decided by fire and rescue services rather than the Agency.
Meanwhile, the Association claims the Agency has taken no consideration of the seasonality of the waste wood market, which “has always operated” with considerable fluctuations in stock demand and storage needs between summer and winter.
Stockpile rotation requirements in the FPP guidance therefore “prevent bespoke storage capacity within wood supply chains and would require every load of recycled wood to have an age audit trail which would be impossible for anyone involved to police” the WRA said.
Elsewhere, the Association reiterated its concern that stockpile size restrictions for both internal and external wood stacks “will make many businesses unviable because they will not be able to physically store the amount of material they require to operate on the land they have available”.
Furthermore, the WRA said it “fundamentally disagrees” with any assumption that stockpiling of waste wood for more than a short period presents an unacceptable fire risk, calling for each site to be “considered on its individual off-take requirements”.
FPP guidance restricts waste wood piles to three metres high and five metres long with a minimum separation distance of six metres between piles.
However, such restrictions, the WRA said, are a “considerable reduction” on what has previously been set out by the EA and “will result in an increase in landfill” unless the FPP regulations “allow for deviations”.
Chairman of the WRA and head of alternative fuels at Suez, Andy Hill, said: “The WRA is committed to safety, professionalism and protecting the environment and we agree fundamentally that operators should have Fire Prevention Plans in place.”
He added that he was concerned that the FPP guidance and consultation were issued before the results of fire tests currently being undertaken by the WRA in partnership with the Chief Fire Officers Association aimed at providing scientific evidence on the combustibility of waste wood (see letsrecycle.com story).
Mr Hill said: “Many of our members have already invested heavily to improve fire detection and prevention and other health and safety measures on their sites. We are the first waste stream to hold fire tests to help inform this process and we have helped and encouraged that process and are now awaiting the results.
“We are contacting all our members to support them in understanding the EA guidance and the consultation and encourage them to take part in the consultation to ensure our industry’s feedback is heard. We are also encouraging our members to write to their own local MPs to raise the issues that concern them about the draft FPP.”
Tests of materials linked to the metals recycling sector, of shredder (fragmentister) residue or fluff and also of tyres are also taking place at Barling with metals recycling giant EMR suppying the shredder residue for the tests. Issues surrounding residue include the fact that shredder residue can generate heat itself with the potential for self-combustion.
Howard Bluck, technical director of the British Metals Recycling Association, said: “The fire tests are of considerable interest to our sector and we are watching what happens very keenly. We have 45 shredder sites. Historically we have always made the point that metals don’t burn but of course there are some flammables involved though.”
Mr Bluck added: “We will be interested in what the results are and will discuss this with the Agency and the fire officers association.”
For organics recyclers, however, the overall picture is somewhat brighter. Action will not be needed for compost material but will be for dealing with oversize material when bespoke environmental permits are involved.
Oversze is part of the production process and typically from 40-100mm in size or more. It is a woody material and in the past was often used as a daily cover for landfill sites and today use as biomass for burning is favoured. Jeremy Jacobs, technical director of the REA’s Organics Recycling Group, has estimated that 10-15% of the inputs to a commercial composting system will be classified as ‘oversize’.
Writing in the latest edition of the Organics Recycling magazine, Mr Jacobs said: “With over seven million tonnes of green and food waste being processed, you can see that the volume of this material is not insignificant.”
The need to conform to permit rules linked to fire prevention is likely to apply primarily to operators of in-vessel composters (IVC) and open windrows. Operators will need to draw up an FPP for storing oversize material along the same restrictions as for waste wood.
According to the Agency, most compost fires have occurred when stockpiling this oversize material for re-processing at compost sites.
However, FPPs will nevertheless only be a requirement for organic biowaste sites seeking a bespoke environmental permit, and not for standard permits. On this point, the Organics Recycling Group said it was “pleased to see common sense prevail”.
Environment Agency consultation on fire prevention plans