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EPA Issues Firewater Guidance


The EPA has published a guidance note on the Retention Requirements for Firewater Run-off. This document replaces the 1995 “Draft Guidance Note to Industry on the Requirements for Fire-Water Retention Facilities”. The guidance is aimed mostly towards industry but may prove to be useful for a broad range of activities. The types of sites which generally require firewater run-off retention include waste facilities, pharmaceuticals facilities, activities that involve the processing and storage of chemicals, fuels and particular types of food and drink manufacturing.

Within the document the term ‘firewater’ refers to any liquid used for firefighting, whether it be foam, rainwater, water or other substances. This liquid has polluting potential, especially when in contact with combustion products. It therefore has the potential to seriously harm the aquatic environment as well as polluting soils, aquifers and surface waters. The impact on effluent treatment works should also be taken into consideration. Should there be an incident involving the release of firewater to the environment, the impacts can be severe and long-lasting.

The new guidance requires that any facility that qualifies through certain criteria must have firewater retention. If a site meets either of the two criteria listed below, fire-water retention is required:

  • Environmentally Hazardous Substance Storage Thresholds.This relates to the amount of substances on site that have certain environmental H-Statements;
  • Environmental Receptor Criteria for sites whose activities involve potentially polluting substances. The criteria relates to sites that have a direct stormwater discharge to any of the following:
    • Municipal drinking water intake points;
    • Designated bathing waters;
    • Freshwater pearl mussel rivers;
    • Designated shellfish waters;
    • Water bodies characterised as High Status under the WFD;
    • Special Areas of Conservation (SAC), Special Protection Areas  (SPA)  and Natural Heritage Areas (NHA).

If a licensee does not meet any of these criteria, they are still required to carry out a firewater risk assessment to determine if firewater retention is required and which type of retention would be appropriate. The EPA recommends that a risk assessment workshop be held between the appropriate site personnel and possibly external experts to determine the potential hazards that firewater run-off would pose. At this time the following should also be reviewed to inform the assessment:

  • Environmental Liability Risk Assessment (ELRA);
  • Bund Integrity Assessment Reports;
  • Control of Major Accident Hazard (COMAH) assessment;
  • Any documents/assessments that relate to fire compartmentalisation;
  • Fire Risk Assessments and Waste Storage Plans (for certain waste facilities).

Before the commencement of the risk assessment, the site can be divided into separate assessment zones based on distance and/or fire containment properties. The guidance provides the methodology for compartmentalisation of a site, by logically divided the site into distinct assessment areas based on distance and/or fire containment properties. The FWRA tool, which is available to download from the EPA website, has been designed to help users to navigate through the risk assessment process. The inputs that are required for the tool are:

  • Significance of Fire Event;
  • Environmental Hazard Potential.

Retention Capacity must also be calculated for the site. The Guidance includes three methods of calculating this; Warehouse Retention Calculation, Tank Farm/Process Plant Retention Calculation and General Retention Calculation.

There is a requirement on licensees to test the integrity of all retention facilities on site every three years, or as is required as per their licence. Subsequent to  the completion of the firewater risk assessment, the FWRA tool must be submitted to the Agency with a Firewater Risk Assessment Report. If there is a condition in your licence requiring you to carry out a firewater risk assessment, you are now required to carry out a new firewater risk assessment in accordance with the new guidance document. The new firewater risk assessment report must be submitted to the Agency, as a new licensee return on EDEN, by the 31st July 2020.

Environet Solutions can assist with Firewater Risk Assessments should your company require it. For any assistance or to get more information please contact us.

To view the EPA Guidance note click here.

August 2019