24 JUN 2020

CIRIA CONSULTATION ON POLLUTION CONTAINMENT SYSTEMS

CIRIA is currently consulting the industry in order to develop the scope of a supplement to its guidance on containment systems, writes Shirly Miles.

CIRIA first produced guidance on the design of containment systems for the prevention of water pollution in 1997. This came to be widely used.  Although produced for new construction, the principles were applied to existing sites. Due to changes in legislation, advances in construction design and lessons learned from incidents such as Buncefield, near misses and inspections, the second edition was developed and was issued in 2014. The release of the second edition accelerated its uptake by the industry. Regulators are increasingly requiring operators to demonstrate compliance with this guidance.

The guidance has informed the approaches adopted by many operators and their advisors over the past six year with its focus on pragmatic and cost-effective solutions to risk management. However, as with any topic, it is important that guidance keeps apace with latest development. The supplement will therefore capture experience in the application and interpretation of the guide, identify advances in materials and technologies and report on case studies, particularly those that have yielded cost-effective innovation solutions.

Following preliminary consultation with users of the guide, the survey identified a number of areas that could be expanded or updated and seeks views on how the risk-based approach set out in the guide can be better promoted. 

For instance, the first part of the document takes the reader through a risk-based approach to identifying storage needs and options by which this can be achieved. However, anecdotal evidence suggests that too often this is overlooked, with operators and their advisors referring to latter parts of the document for guidance on conventional predetermined solutions. Failure to consider the problem and opportunities holistically can lead to a sub-optimal solution in terms of operation and cost.

In terms of advances, new methods of testing the integrity of such structures have been developed that are acceptable to regulators. Likewise, advances in sealant systems are leading to solutions that provide improved fire resistance.

Given the range of sectors and sites, particularly those that have involved a change in use, other scenarios are emerging that could be captured in a supplement. These include instances where tanks are built on pre-existing concrete slabs.

The survey will be open throughout June and CIRIA is organising a webinar to discuss some of the findings and present a number of case studies in mid-July. 

Click here to view the survey.

Shirley Miles is head of environmental services at Darcy Group.

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