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Submission for: Kariong Sand and Soil Supplies Facility


Fire and Rescue NSW

Greenacre, New South Wales


It has been the experience of FRNSW that waste recycling facilities pose
unique challenges to firefighters when responding to and managing an
incident. Factors such as high and potentially hazardous fuel loads,
facility layout, and design of fire safety systems have a significant
impact on the ability to conduct firefighting operations safely and
effectively. Consultation with organisations such as FRNSW throughout
the development process enables the design and implementation of more
effective fire safety solutions that help to mitigate the impact of
incidents when they occur.

Waste facilities present `special problems of firefighting' that
warrant classification as `special hazards', and consideration of
provision for special hazards under Clause E1.10 and E2.3 of the NCC.

Fires in waste facilities present specific issues for firefighting,
a) the physical nature of combustible waste and waste by-products,
including fire properties and ignition potential of both unsorted and
sorted materials
b) unsuitable storage method, stockpile size, separation distances and
c) mechanised waste handling, sorting and processing systems,
including vehicles
d) poor emergency vehicle and/or firefighter access for firefighting
e) facilities having an inadequate or no fire hydrant system,
including water capacity
f) facilities having an inadequate automatic fire suppression system
g) buildings having an inadequate smoke hazard management system
installed, and
h) facilities having inadequate provision to contain fire water

Following a review of the Environmental Impact Statement (EIS) report
FRNSW provides the following recommendations for your consideration:

* Consent authorities should issue a condition on the development
consent requiring Clause E1.10 and E2.3 of the NCC be complied with to
the satisfaction of FRNSW, achieved through either providing an
acceptable solution or through direct consultation with FRNSW.
* The waste facility is to provide safe, efficient and effective
access for emergency vehicles as detailed in FRNSW guideline Access
for emergency vehicles. Aerial appliance access is to be provided if
the facility is located within a fire district covered by an aerial
* The waste facility is to have a fire hydrant system installed
appropriate to the risks and hazards for the facility. FRNSW
recommends a fire hydrant system designed and installed to Australian
Standard AS 2419.1-2017 and have an enhanced standard of performance
appropriate to special hazards.
* The waste facility is to have an automatic fire sprinkler system
installed if the building has a floor area greater than 1000 m² or
contains 200 m³ or more of combustible waste material. FRNSW
recommends the fire sprinkler system be installed to Australian
Standard AS 2118.1-2017.
* The waste facility is to have a fire detection and alarm system
installed appropriate to the risks and hazards identified for each
area of the facility. FRNSW recommends a fire detection and alarm
system installed to Australian Standard AS 1670.1-2015 Fire detection,
warning, control and intercom systems - system design, installation
and commissioning.
* Buildings containing combustible waste material are to have an
automatic smoke hazard management system appropriate to the potential
fire load and smoke production rate installed within the building.
* The waste facility is to have effective and automatic means of
containing fire water run-off, with primary containment having a net
capacity not less than the total hydraulic discharge of the worst-case
fire scenario. The total hydraulic discharge is the discharge from
both the fire hydrant system and automatic fire sprinkler system for a
duration of four hours. Failure to contain fire water run-off can
result in pollution of the environment and require a protracted
hazardous materials response.
* The owner is encouraged to engage a fire safety engineer or other
suitably qualified consultant to develop a performance design specific
to the facility and its operations. The performance-based design
should consider all possible fire scenarios.
* The occupier/operator is to develop an emergency plan for the waste
facility to AS 3745-2010 Planning for emergencies in facilities. An
external consultant should be engaged to provide specialist advice and
services in relation fire safety planning and developing an emergency

Consultation with FRNSW be undertaken by way of the fire engineering
brief questionnaire (FEBQ) process prior to the issue of the relevant
construction certificate.

While there is currently no requirement for a fire safety study, FRNSW
may request one be undertaken at a later stage should information be
provided such it is deemed that the development poses unique
challenges to the response to and management of an incident.

Please see the FRNSW fire safety guideline for Fire Safety in Waste
Facilities that includes legislated requirements and development
considerations (planning).