CFR 112.1b Secondary containment of oil filled transformers

[OffTap2020]

I have searched for like threads, but have not found anything current.

Based on the current CFR Title 40 dated February 12, 2012, if a transformer of sufficient size is located in an area that is miles from a navigable water source ( city area), would a SPCC still be sufficient?

The document still says " reasonably be expected to discharge......into navigable waterways, shorelines etc.."

If this is NOT the case, how are most of the utilities you work for or deal with, handling secondary containment?

I see no evidence of the 2 major utilities in my area ( SCE and PG&E ) installing secondary containment on any of their existing substations, at least in the city.

Thoughts or opinions appreciated,


OffTap

 

[bacon4life]

In the past at some of our substations, the secondary containment is the miles of dirt before reaching navigable water. In these existing subs we have estimated the potential cost of extensive soil removal for a low probability spill & cleanup versus the actual costs of moderate substation excavation to install oil containment. I the last year or so the rules have changed in Washington, so I am not sure what the current guidelines require.

Although some of our urban area is a long way from navigable water, we do have to also prevent oil from entering the storm drain system.

In new substations we install large oil containment vaults similar to oil/water separators.

 

[stevenal]

When I read the section, I see nothing that relates to miles; only to the reasonableness of a discharge reaching navigable water. Since city storm drains ultimately discharge into navigable water, I fail to see any exclusion here.

I'm not sure that secondary containment is the only acceptable countermeasure.

 

[OffTap2020]

" I'm not sure that secondary containment is the only acceptable countermeasure. ".

Could you elaborate on that?


OT2020

 

[stevenal]

http://ilta.org/LegislativeandRegulatory/SPCC/SPCCInspectorCheckList_2012.pdf

Might need map to get through all the exceptions, but 112.7(c) apparently allows diversion dikes, berms, etc.

I'm not sure why you expect to see recent construction. The SPCC rule may have been modified recently, but it has been around for a while now; and containment or equivalent was considered good engineering practice prior to that.

Containment is generally underground, and not very visible from outside the fence.

 

[rterickson]

" I'm not sure that secondary containment is the only acceptable countermeasure. ".

Could you elaborate on that?

(c) Provide appropriate containment and/or diversionary structures or equipment to prevent a discharge as described in §112.1(b), except as provided in paragraph (k) of this section for qualified oil-filled operational equipment, and except as provided in §112.9(d)(3) for flowlines and intra-facility gathering lines at an oil production facility. The entire containment system, including walls and floor, must be capable of containing oil and must be constructed so that any discharge from a primary containment system, such as a tank, will not escape the containment system before cleanup occurs. In determining the method, design, and capacity for secondary containment, you need only to address the typical failure mode, and the most likely quantity of oil that would be discharged. Secondary containment may be either active or passive in design. At a minimum, you must use one of the following prevention systems or its equivalent:

(1) For onshore facilities:

(i) Dikes, berms, or retaining walls sufficiently impervious to contain oil;

(ii) Curbing or drip pans;

(iii) Sumps and collection systems;

(iv) Culverting, gutters, or other drainage systems;

(v) Weirs, booms, or other barriers;

(vi) Spill diversion ponds;

(vii) Retention ponds; or

(viii) Sorbent materials.

(2) For offshore facilities:

(i) Curbing or drip pans; or

(ii) Sumps and collection systems.

 

[OffTap2020]

"I'm not sure why you expect to see recent construction. The SPCC rule may have been modified recently, but it has been around for a while now; and containment or equivalent was considered good engineering practice prior to that.

Containment is generally underground, and not very visible from outside the fence. "


The reason why I mention "recent", is that I have worked in 3 very large SCE substations with in the last 3 months, and I know for a fact that they have no secondary containment of any kind.

I have also worked in quite a few PG&E substations, most in the central valley, and only saw 2 with secondary containment berms. They both were fairly new built.

OT2020