Guidance

Metals manufacturing: examples for your adapting to climate change risk assessment

Updated 17 May 2023

Applies to England

Possible impacts and mitigation measures to consider when preparing your climate change risk assessment.

Summer daily maximum temperature

This may be around 7°C higher compared to average summer temperatures now, with the potential to reach extreme temperatures as high as over 40°C with increasing frequency based on today’s values.

Impact 1

Potential increase in temperature may result in expansion and stress of plant, pipework and fittings such as extraction or cooling fans that may become ineffective through excessive expansion.

The mitigation for this could be:

• regular inspection and preventative maintenance on site of plant and equipment
• review of fan design parameters

Impact 2

Potential increase in dust emissions from site.

The mitigation could include regular site cleaning and use of dust suppression systems.

Impact 3

Potential increase in odour from site.

The mitigation for this could include making sure:

• appropriate abatement is in place and maintained effectively
• an appropriate odour management plan is in place

Impact 4

Potential increase in fugitive and diffuse emissions off site.

Make sure appropriate fugitive and diffuse emission plans are in place.

Impact 5

Could result in more water being consumed for cooling purposes.

Consider how water can be cleaned and recirculated for reuse on site as well as alternative cooling systems.

Impact 6

Possible increase in energy consumption due to increased pumping of cooling water around site.

The mitigation for this could include assessing how efficient the current cooling system is and proposing upgrades and modifications where necessary.

Impact 7

Possible impact on employees and productivity through heat stress.

The mitigation for this could include:

• introducing additional breaks
• providing additional cooling and water supplies
• reviewing of shift patterns to avoid some activities taking place at the hottest times of day

Winter daily temperatures

This could be 4°C more than the current average with the potential for more extreme temperatures, both warmer and colder than present.

Impact 1

In extreme cold weather:

• risk of failure of trace heating systems
• freezing of cooling water resulting in blockages, particularly on long pipelines
• storage in exposed areas could also lead to process failures

The mitigation for this could include regularly inspecting and maintaining insulation, particularly on pipework and equipment in exposed areas of the site.

Impact 2

Increased risk of water pipework ruptures affecting:

• boiler condensate
• process water
• cooling water
• effluent systems

This in turn may lead to process interruption.

The mitigation for this could include:

• considering additional insulation on water-containing pipework
• reviewing operating procedures to make sure pipework is not left full of static water if not in use
• identifying any potential deadlegs where static water may be held up

Impact 3

Failure of pH control due to caustic systems solidifying for process and effluent treatment control.

The mitigation for this could be to review capability of caustic systems to remain liquid at anticipated colder temperatures.

Impact 4

Frozen onsite roadways may restrict access for staff and emergency vehicles.

The mitigation for this could be to:

• regularly inspect and maintain roadways during winter and remove any standing water
• ensure grit is available to treat road surfaces

Impact 5

Damage to site infrastructure from snow-loading over extended periods.

The mitigation of this could be to:

• review design of structures to withstand increased loading
• make sure that critical items such as transformers or gas inlets are protected from roof collapse due to weight of snow

Daily extreme rainfall

Daily rainfall intensity could increase by up to 20% on today’s values.

Impact 1

Potential for increased site surface water and flooding.

The mitigation for this could include making sure:

• suitable measures are in place for the management of anticipated surface water and flood waters
• drainage systems are inspected and maintained
• external areas where wastes are handled or stored are provided with contained drainage
• site drainage system and effluent treatment plant has sufficient storage and treatment capacity

Average winter rainfall

Average winter rainfall may increase by over 40% on today’s averages.

Impact 1

Potential for increased site surface water and flooding.

Mitigation for this would be to prepare flood plan with reference to the guidance Preparing for flooding: A guide for sites regulated under EPR and COMAH.

This should include:

• identification and risk assessment of process equipment and services at greatest risk from flooding
• provision of emergency pumps to remove floodwater and identification of lowest risk location for discharge of floodwaters
• protection of control and electrical systems
• identification and protection of flat bottom tanks at risk of floating in floodwater

Impact 2

Potential for drainage systems and interceptors to be overwhelmed.

The mitigation for this could be making sure:

• suitable measures are in place for the management of flood waters, where relevant
• drainage systems are inspected and maintained
• external areas where wastes are handled or stored are provided with contained drainage
• the site drainage system and effluent treatment plant has sufficient storage and treatment capacity

Impact 3

Potential for overland flow or groundwater flooding.

The mitigation for this could include making sure suitable measures are in place for the management of anticipated overland flow or groundwater flooding.

Impact 4

Impact on access or egress from site due to flooding which may affect supplies of critical raw materials and abatement chemicals.

Make sure there are suitable alternative transport routes to and from site.

Sea level rise

Sea level rise which could be as much as 0.6m higher compared to today’s level.

Impact 1

If a site is located near the coast there is potential increased risk of flooding.

The mitigation for this would be to review flood defences around coastal landfill sites and to produce a flood plan with reference to the guidance Preparing for flooding: A guide for sites regulated under EPR and COMAH.

This should include:

• identification and risk assessment of process equipment and services at greatest risk from flooding
• provision of emergency pumps to remove floodwater and identification of lowest risk location for discharge of floodwaters
• protection of control and electrical systems
• identification and protection of flat bottom tanks at risk of floating in floodwater

Impact 2

Impacts to wider supply chain infrastructure for critical emissions control plant by docks and road access flooding.

Make sure there are suitable alternative transport routes to and from site.

Drier summers

Summers could see potentially up to 40% less rain than now.

Impact 1

Potential increased use and reliance on mains water for dust suppression, cleaning and fire water.

The mitigation for this would be to make sure:

• measures are in place to review and minimise water use and to maximise collection and use of rainfall
• mains water capacity is adequate, taking into account reduced availability of rainwater for activities such as dust suppression, cleaning and fighting fires

Impact 2

Potential increase in dust emissions from a site.

Mitigation for this would include regular site cleaning and use of dust suppression systems.

River flow

The flow in the watercourses could be 50% more than now at its peak, and 80% less than now at its lowest.

Impact 1

There is potential increased impact of discharge to watercourse from on-site drainage systems where connected to water courses.

The mitigation would include:

• reviewing environmental risk assessment undertaken for discharge to water from on-site drainage
• checking existing environmental risk assessment to make sure low river flow used in assessment remains valid – if not, discuss with the Environment Agency (local site inspector and water quality team) and do an updated environmental risk assessment
• reviewing and improving discharge parameters if the additional impact is predicated upon a receiving watercourse

Impact 2

Increased risk of water course flows being too high to allow discharge and drainage backs up on site.

The mitigation for this could include checking the potential for high flows in the receiving watercourse to cause surface water backing up and flooding the site.

Impact 3

Drought restrictions on abstractions may affect availability of water leading to reduced water for process use and dust control at a time when most required.

The mitigation for this could include:

• reducing reliance on abstracted water for dust suppression
• investigating other sources of process water
• investigating additional water minimisation measures
• considering alternative sources of water such as use of quarry water, roof water, groundwater from non-sensitive sources, noting that an EPR abstraction permit may be required for some sources of water

Storms

Storms could see a change in frequency and intensity. The unique combination of increased wind speeds, increased rainfall, and lightning during these events provides the potential for more extreme storm impacts

Impact 1

Storms and high winds could damage buildings, site fencing and other structures, such as tall chimneys, with the potential to increase fugitive dust emissions through loss of containment and control systems.

The mitigation for this could include:

• reviewing the design of vulnerable structures and buildings
• reviewing wind loading calculations, providing reinforcement if necessary
• maintaining building integrity and ensuring timely maintenance and repairs
• making sure that buildings are able to be secured against driving winds by means of closing all side openings, doors and windows
• making sure that perimeter fencing is maintained in good condition as are any brick walls and similar
• reviewing adequacy of lightening protection
• reviewing mitigations for extreme daily rainfall