SPCC Containment Stormwater Discharge
SPCC Containment Stormwater Discharge
(OP)
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 structure is not practical. I am aware of options presented in 112.7(c), but what seems to be the precedent in the utility industry? Concrete curbing?
Secondly, in the regulations “Section by Section Analysis”, in 112.8(b)(2) – EPA says ”This rule does not preclude innovative devices..” regarding the use of imbiber beads, or assumingly chemical check valves, for discharging accumulated stormwater from containment structures. It is the manufactures opinion that chemical check-valves can be used to passively discharge accumulated stormwater from containment structures, but the rules specially state that “you must inspect and may drain accumulated stormwater” and keep adequate records of that event, which is not feasible using these passive drainage devises. Bottom line, it seems that EPA is saying that you can install the innovative devise, but you must operate it like a manual open/close valve. The valve manufactures say they are selling the valves for SPCC compliance but that seems contrary to what the regs allow, unless, the users are proposing this under the exception portion of the rule. Any thoughts?
Secondly, in the regulations “Section by Section Analysis”, in 112.8(b)(2) – EPA says ”This rule does not preclude innovative devices..” regarding the use of imbiber beads, or assumingly chemical check valves, for discharging accumulated stormwater from containment structures. It is the manufactures opinion that chemical check-valves can be used to passively discharge accumulated stormwater from containment structures, but the rules specially state that “you must inspect and may drain accumulated stormwater” and keep adequate records of that event, which is not feasible using these passive drainage devises. Bottom line, it seems that EPA is saying that you can install the innovative devise, but you must operate it like a manual open/close valve. The valve manufactures say they are selling the valves for SPCC compliance but that seems contrary to what the regs allow, unless, the users are proposing this under the exception portion of the rule. Any thoughts?






RE: SPCC Containment Stormwater Discharge
RE: SPCC Containment Stormwater Discharge
RE: SPCC Containment Stormwater Discharge
The requirement for manual valves is waived if water is directed to a wastewater treatment facility. But what other treatment is needed for oil contaminated water other than oil removal. I guess I would suggest that the chemical check valve itself constitutes the treatment facility. Anyone buying?
RE: SPCC Containment Stormwater Discharge
stevenal, are the oil/water separators adequate to contain oil from the single largest container volume? That would make for an extremely large tank for sites with large transformers. If not, is the maximum expected size of an oil discharge reduced through operational procedures (early notification by SCADA, etc.)?
RE: SPCC Containment Stormwater Discharge
RE: SPCC Containment Stormwater Discharge
Yes, we completely contain the volume of the single largest transformer at the site. A big tank isn't needed, a number of smaller ones will do. We series up the number required. I'm not sure you could rely on operational procedures to limit the spill in this regard. You could isolate the radiators, but what if they shoot the main tank? Several times. What flow rate and response time do you design for? Don't forget about vacations.
RE: SPCC Containment Stormwater Discharge
What logic is generally used to design retention systems for a volume of oil that is less than the largest transformer? Are oil retention volumes based primarily on historical precedence and utility experience in these cases?
RE: SPCC Containment Stormwater Discharge