CDOIF Guidance

Safety and environmental standards for fuel storage sites

Final report

217

16 Scenario-based incident-specific emergency response plans can identify incident control

resources required for accidental release, spillages and fire and emergency response. They can

also provide guidance on control and deployment of the necessary resources and importantly,

can be used as a tool to exercise against, thus closing the loop from preparation to planned and

exercised response.

17 Sometimes a ‘controlled burn’ strategy may be appropriate. Controlled burn is where the

fire is not extinguished deliberately to allow the fuel to burn away in a controlled fashion. In such

cases, firefighting resources will still be required, primarily to cool adjacent tanks and facilities to

prevent escalation.

18 A controlled burn strategy may be appropriate if, for example:

firewater run-off or fuel would cause significant pollution to sensitive environmental receptors

■

such as surface and groundwater abstractions and/or designated habitats;

the site is remote from centres of population or a controlled burn is the best option for air

■

quality;

the site is not capable of containing the required quantities of firefighting water and foam; or

■

there is a significant risk to firefighter safety.

■

19 A controlled burn strategy may not be appropriate if:

smoke plumes could result in a risk to public health, and/or large areas require evacuation;

■

major transport routes require closing. If a transport route is threatened, a risk assessment will

■

be required to determine the consequences of environmental damage against the impact on

transport routes;

there is a significant risk of the fire escalating.

■

20 Such deliberations should form part of the environmental and safety risk assessment carried

out by the operator when producing the on-site emergency plan. This should be in consultation

with the environment agencies, the local authorities, the emergency services (particularly the Fire

and Rescue Service) and other stakeholders.

21 Further guidance on the use of controlled burn is available in the Environment Agency’s

PPG 28

129

and the Fire and Rescue Service’s

Manual on environmental protection

130

22 If it is decided to extinguish the fire then EI 19

Fire precautions at petroleum refineries and bulk

storage installations

is considered to be ‘relevant good practice’ under COMAH, and operators

should comply fully with this good practice. New sites should comply fully with EI 19. Existing

operators should comply with this relevant good practice where it is reasonably practicable to

do so. In effect, this means that existing operators should undertake a gap analysis between the

requirements in this code and those measures present on site. Any measures not in place but which

are specified in the code should be implemented if it is reasonably practicable to do so.

23 The following is a list of the steps needed to plan for tank related fire and emergency

scenarios, which have been drawn from EI 19 to aid operators. It states the questions that need

to be considered and points to the relevant section in the code for further detail.

Step 1

Determine the worst-case scenario for the fire event. For fuel depots this is considered

to be either the largest tank in a single bund, or the largest group of tanks in a single bund. If the

plan adequately covers the resources for the worst-case scenario, it can be considered capable of

dealing with lesser similar events, eg fires in smaller tanks etc. (EI 19 sections 2.5–2.7, section 3.2.)

Step 2

Assume a full surface tank fire and bund fire.