While excavation of the soil will provide an immediated and cost effective solution, its location to the building makes this alternative undesirable. Depending on the soil type and permeability, I would probably try and bioremediate the soil, if possible. TPH is amenable to bioremediation, but...
Since SPCC/FRP issues are heating up, I think I will start a Forum for us to share information. The de-rated capacity you mention is another issue for discussion. As for the U.S. EPA's reviewer's comments about having adequate equipment avaialble to respond to the 100(x) spill, which in ou...
I have a question regarding Worst Case Discharge (WCD)calculations in a Facility Response Plan. Once you have determined the worstc case volume, you are suppose to use Attachment E-1 of 40 CFR 112 to calcualte the response capacity - or the required capability of equipment to recovery the WCD...
Since 112.7(c) is designed to prevent releases from entering a watercourse and therefore the risk factor, the proximity to a watercourse would probably be the critical factor for the design basis. If the distribution or substation was built adjacent to a watercourse, I think 100% plus freeboard...
Secondary containment for electrical transformers is governed by the general containment rule, 40 CFR 112.7, not 112.8 - which deals more or less with bulk storage containers. Therefore, the size of a containment or processing of that containment is not required to be the volume of the largest...
I have spoken to US EPA Region 4's SPCC Program Administer about that. While US EPA will basically accept the approach signed off by the PE, in the event that oil reaches a watercourse, the utility and signing PE can expected to be held accountable during the penalty phase of the response. In...
I am reviewing the retrofitting of remote electrical transformer substations for compliance with the SPCC rules and have a couple of questions. First, containment structures for new transformers are easily built during the station construction, but for retrofitting – a complete concrete...
