SPCC Plans for Electrical Substations....General Question 1

[WLGiii]

I am currently preparing Substation SPCC plans for some clients and am interested on input from others on the subject. I have been preparing SPCC plans for 3 years now, but that is not my specialty. I recently read that secondary oil containment (other than conrete O.C. basins) was defined as structures such as berms and dikes, or on-site absorption materials (PIG barrel, etc.) adequate enough to handle a spill from that site. Is that true ?

What I often run across is that some believe that 6" of gravel in the substation is considered secondary containment, and it may have been true in the past. But I do not think that is the case anymore. I have read thru the CFR code and the EPA scripts and there is not a definitive answer as I could see. I have been keeping up with all the deadline changes and such over the past several years, this is just a question I never really had anyone that I could ask.

 

[4tuna]

EPA OSWER memo 9360.8-38 to EPA Oil National Policy Managers in regions 1-10 lists the acceptable forms of secondary containment, citing previous SPCC regulations.

http://www.epa.gov/oilspill/pdfs/contain.pdf

Also check out the text of EPA final revised SPCC rule, 40 CFR 112. See section B 112.7(c), which spells out similar types of secondary containment. Also, section B 112.8(c)(11) discusses means of containment in more general terms for onshore facilities.

In any event, 6" of gravel is not sufficient unless it is underlain by an impermeable material and designed to convey spilled material to a retention pond or sump.

 

[boo1]

The substations i have built used pads with curbs for transformer oil containment.

 

[rlg001]

EPA has distinguished bulk storage of oil from the operational use of oil. Oil-filled electrical operating or manufacturing equipment is not classified as a “bulk storage container”. This distinction is important because the owner is not required to provide secondary containment as described in the regulation for oil-filled electrical equipment. Secondary containment as described in the SPCC regulations must be a containment system capable of containing the entire capacity of the largest single container and sufficient freeboard for precipitation. Additionally, discharge of accumulated precipitation must be inspected prior to discharge.

However, although not required to provide secondary containment, oil-filled equipment must meet other SPCC requirements and provide “appropriate” containment and/or diversionary structures to prevent discharged oil from reaching a navigable watercourse.

Also, check out the following two industry standards:

IEEE Guide for Containment and Control of Oil Spills in Substations (IEEE Std 980-1994)

USDA Design Guide for Oil Spill Prevention and Control at Substations (Bulletin 1724E-302)

I'm currently working on this issue with a large utility company with hundreds of substations who put this off way too long. Not fun.

 

[amann20]

Hello,

In addition to the list provided in this thread of approved secondary containment systems, we have used the BaySaver Separation System on several projects in the Southeast. This technology was taken from the stormwater treatment industry and found a niche for spill control in rural areas.

 

[ajoven]

Yes, I understand that 6" gravel is not a "containment" but will it not impede the flow of any spilled fluids? Also, a tranformer that has lost its fluid would create a electric transmission interruption therefore a substaion crew would probably be out almost immediately to find the problem adn address the spill. I am working on SPCC plans for substations that have both containment and no containment. No problem with the ones with containment but I am looking for inexpensive ways to address the ones without containment. Berms can be built around the equipment or the whole substation but will this be acceptable? The ground itself is not impermeable. The oil will soak in but will probably take a long time to migrate to a waterway! Any thoughts or comments out there? Thanks in advance for any response.