The revised Firewater Retention Guidelines from the Environmental Protection Agency (EPA) presents key changes relating to to qualifying criteria. The revised qualifying criteria will need to be considered when undertaking your firewater retention assessment:
- Environmentally hazardous substance storage thresholds are now based on hazard statements instead of risk phases.
- Environmental receptors are now an explicitly stated qualifying criteria.
The new risk assessment outlined in the Draft Guidelines is focused on consequence rather than likelihood. The risk assessment is used to determine whether firewater retention is required for a facility that does not necessarily fall within the two qualifying criteria noted above.
The new Guidance requires a consideration of the significance of the fire event (S) versus the environmental hazard potential (H). A prescriptive risk assessment formula is set out in the new Guidance.
The FWRA tool (excel spreadsheet) details the methods for calculating the firewater from each different site area or ‘type’ of area including a new that is required to be completed.
A list of the industrial operations that are considered to have significant potential for the release of contaminated firewater is provided in Appendix A of the guidance note .
- If your industrial facility has an operation listed in Appendix A, a firewater retention facility will generally be required.
- If the operations listed in Appendix A do not take place at your facility, but potentially polluting substances are handled, then a risk assessment and management programme should be completed.
A risk assessment will typically include the following:
- Identification of existing and potential hazards
- Identification of existing control measures
- Assessment of the hazards with regard to the:
- probability of an incident occurring
- the impact of an incident on the environment on-site and offsite (soil, water and air)
- the impact of an incident on sensitive receptors in the area
The completion of a risk assessment will provide an industrial facility with the information required to determine the need for a firewater retention facility.
Please feel free to contact us to discuss how you can determine and manage your firewater retention requirements.
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