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SPCC Plans for Electrical Substations....General question

SPCC Plans for Electrical Substations....General question

SPCC Plans for Electrical Substations....General question

(OP)
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.

RE: SPCC Plans for Electrical Substations....General question

(OP)
now that I think about it, I'm gonna toss this one into the Environmental Forum as well

RE: SPCC Plans for Electrical Substations....General question

The last time I looked (a couple years ago), there was, as you indicate, no definitive answer as to what is required for containment.  It is related to what action is to be taken as outlined in the SPCC plan.  Incomplete containment may be acceptable if the SPCC plan sufficiently addresses cleanup before any oil reaches a waterway.
 

RE: SPCC Plans for Electrical Substations....General question

Please check the site:
http://www.epa.state.oh.us/derr/ersis/er/SPCC/spccfly.pdf

"...the volume of containment must be adequate to contain the volume of the largest tank plus have sufficient freeboard for a 100 year storm event. This is usually measured as 110% the volume of the largest tank."

RE: SPCC Plans for Electrical Substations....General question

RE: SPCC Plans for Electrical Substations....General question

I'd call "incomplete containment" an oxymoron. It either is or it isn't contained. Substation gravel is for step an touch potentials. The high wet resistivity rock used is not very porous, so oil runs right through.

RE: SPCC Plans for Electrical Substations....General question

By "incomplete" I meant containment that would not contain a spill indefinitely.  An example would be berms that keep oil from immediately spilling outside the station area, but allow the oil to soak into the soil.  The SPCC would have to give procedures to clean up the spill before the oil could reach a navigable waterway.

Gravel alone would not slow the oil spill significantly.

RE: SPCC Plans for Electrical Substations....General question

1. Determine the volume (VO) of oil and rainwater.
2. Assume gravel porosity (P) of 0.35.
3. VO/P=V, where V is the volume of containment.

RE: SPCC Plans for Electrical Substations....General question

(OP)
Good stuff folks , thanks for the replies.  

RE: SPCC Plans for Electrical Substations....General question


In some respects, environmental law can be interpreted differently, possibly leading to some creative regional approval and enforcement mechanisms.  Spill-containment regs can manifest in varying iterations, though seemingly based on the same set of regulatory concepts.  

For instance, some grades of mineral oil are intended for human consumption, but all of it is considered toxic to fish.
    

RE: SPCC Plans for Electrical Substations....General question

I think one of the problems with oil, even an edible one, is it can eventually suffocate the fish.

RE: SPCC Plans for Electrical Substations....General question

I think that gravel used in substation is meant to maintain a damp area under it so that a low resistance would be present for earthing purposes.  it is not my belief that this gravel is intended to absorp oil.

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