When you call 911 and the teams show up to put the Wet stuff on the Red stuff your last thought is pollution, but regardless if the teams are successful in controlling the fire risks, you need to think about Pollution Containment
Minimizing the severity of a pollution claim requires contingency planning and an immediate response. While many commercial general liability policies do not cover pollution, some insurers offer in-house expertise in emergency response, environmental remediation and applicable regulations. Quite simply, pollution spreads. Depending on where an environmental incident occurs, it can spread even more rapidly, causing both physical environmental and financial damages to climb. For instance, a fuel oil spill in a paved parking lot may not pose a costly threat. But say that contaminant trickles from the parking lot into a storm sewer, which, in turn, discharges into a stream several hundred metres away.
The resulting damage – which could include clean-up, fine, public relations and national resource restoration expenses, among others – can grow by a factor of 10.
Firewater containment is the process of containing (fire water) the run-off from fighting fires. Firewater contains many hazardous substances which are the by-products of combustion which turns normally safe materials into toxic, polluting and environmentally damaging substances. The preferred method of firewater containment is to use pneumatic bladders / drain stoppers that block the outflow from the drain or pneumatic non-return valves both of which can convert the drains into containment vessels from which the firewater can be pumped away into tankers for safe disposal. Typically follow a pollution incident. Those tasks include the following:
- understanding the dynamics of all the parties involved and then dealing with them to meet local, provincial and national environmental oversight and regulatory requirements;
- choosing an appropriate and cost-effective remediation method;
- assessing environmental/natural resource damages;
- monitoring long-term clean-up costs and progress;
- handling local stakeholders, from homeowners to grassroots environmental activists; and
- providing legal defence support.
Our Pollutants may escape from the site into the water environment by a number of pathways. These include:- i. the site’s surface water drainage system, either directly or via off-site surface water sewers. ii. direct run-off into nearby watercourses or onto ground, with potential risk to groundwaters. iii. via the foul drainage system, with pollutants either passing unaltered through a sewage treatment works or affecting the performance of the works, resulting in further environmental damage. iv. through atmospheric deposition, such as vapour plumes.
Firewater runoff risk assessment includes the following aspects: − An assessment of the composition and quantity of contaminated firewater predicted to be generated from fighting fires on site − An assessment of the contained practices employed by the site and the possible routes for firewater runoff − Identifying sensitive environmental receptors and migration pathways − A review of the potential environmental impacts associated with loss of firewater from the site − Identifying improvement opportunities and recommendations for impact reductions
Benefits − Avoidance of significant firewater clean-up costs − Cost-effective firewater runoff risk assessments − Preparedness for a variety of incidents − Full understanding of how to manage firewater in the event of an on-site incident
Many industries routinely store and use large quantities of potentially polluting substances within their sites. In case of a spillage and particularly in the case of a fire, these substances could rapidly be transmitted to the nearest water course where they may give rise to a severe pollution problem.
It is therefore very important to develop a site emergency plan, which, among other things, considers the actions to be taken to control run-off of water used to fight any fire on site.
Sites, which are subject to the Environmental Acts and Regulations required by the regulations to make arrangements for water used to fight fires on their sites. They are required to make plans for dealing with emergencies (including fire) as a condition of the grant of the permit.
Water is the most commonly used medium for fire fighting. However, several major pollution incidents have occurred when water used for fighting fires has been allowed to reach nearby rivers or water courses.
Fire fighting run-off may be polluting due to the actual materials on site, their combustion products and/or the use of fire-fighting foam.
Polluting a water course is an offence under the Water Resources Act.
Polluting a sewer by discharging material without the prior consent of the water undertaking is an offence under the Act. In addition to prosecution, the Environment Agency can serve a works notice requiring environmental clean up, or require repayment of clean up costs the Agency incur. Regulations adopt a “polluter pays” principle and extend this legal duty further including “strict” as opposed to “fault based” liability in certain circumstances. Under these Regulations the financial penalties can also extend beyond traditional clean up (or primary) costs to include complimentary and compensatory remediation. Costs of such incidents can run into many millions of pounds and are not covered as part of normal insurance policies.
Mitigating the Effect of Fire Water Run-Off
The first step is to assess the likely route of any run off from the site, then to calculate the likely volumes of fire water, which might result from any incident. The Environment Agency will be able to advise on the likely routes to surface and groundwaters, in conjunction with the Water Company who will be able to advise on sewerage routes. The Fire Services should be involved in the volume estimation and will advise on the quantities and the volume of containment required, based on fire-fighting best practice.
Fire fighting water containment should be considered and may be required to protect both surface and foul water drainage systems. WASTE MANAGEMENT Measures should be in place to dispose of, as soon as possible, any spillage, contaminated material or fire fighting water. Where re-use is possible, the spilled material should be returned to storage on site. If off-site disposal is required, a registered waste carrier should be used, although if a foul sewer is available it may be possible to discharge to it with the approval of the local sewerage undertaker. It may be possible to treat hydrocarbon contaminated water using site oil separators, but the presence of foam can adversely affect their efficiency.
Containment Lagoons and Sacrificial Areas
Lagoons should be constructed which are of a capacity for retention of the area concerned. Areas such as car parks, ornamental gardens or sports fields may be appropriate, providing that they are isolated from the drainage system, can be made secure, and are designed to avoid contamination of groundwater.
Permanent or portable tanks are another option for fire water retention. They must be constructed of a material resistant to the substances retained and tanks should be vented.
Penstocks and Shut-off Valves
Shut off valves or penstocks that can isolate parts of the site in an emergency are another alternative to prevent contaminated water reaching a drain or surface water.
Once the method has been chosen, the authorities should be informed in case there are any fundamental problems arising from this decision. Keep adequate plans of your emergency arrangements and ensure that site personnel are aware of them.
Potentially environmentally damaging materials should always be stored in adequately bunded areas. Bunds are normally arranged to hold the total of the tank volume, plus 10%, this being the volume of the initial fire- fighting or fire protection water or foam. However, much more than this volume would be required to fight a fire. Therefore bunds cannot normally be relied on as fire water protection, but they may be able to provide temporary containment to gain time.
Fire fighting strategies and Run-off Management
The emergency plan may consider fire fighting strategies and possible ways to reduce the amount of fire water run-off generated.
Letting the Authorities Know
As in all emergencies, the first step is to carry out appropriate evacuation systems and call in the Fire Agency. Then call in the Environment Agency. The Environment Agency is committed to the prevention of catastrophic pollution as a result of fire and will usually attend an incident in order to ensure, as far as is practicable, the protection of the aquatic environment from the results of the incident. The Environment Agency also keeps stocks of appropriate equipment and materials to minimise the effects of an incident.
Key Action Steps
Yet regardless of a company’s size, an environmental incident has the potential to pose a bigger financial loss and more reputational damage if not handled properly.
Many facility operations are legally required to prepare response plans in the event of a spill situation. As environmental incidents require instant attention, these plans help set responses in motion quickly. This is critical to reducing costs and controlling liability when a disaster takes place.
- Examine, and where necessary develop, your emergency plan to take account of the potential polluting effects of any water used in fighting a fire at your premises
- Involve the Emergency Services and Environment Agency in the development of your plans
- Hold regular practices of these emergency plans
- Make sure that the plans are reviewed and revised regularly
Ensure that the Environment Agency Emergency telephone number is readily available and that they are contacted in an incident.