Substation transformer failures have the potential to release large amounts of oil, which can pollute the environment and damage plant and animal life. Any incident of this nature draws negative media coverage and results in costly cleanup operations. A power utility in Brooklyn experienced this firsthand in 2017 when a catastrophic transformer failure released an estimated 37,000 gallons of dielectric fluid. The oil seeped into the East River requiring a significant cleanup operation.
Besides the negative publicity and costly cleanup and reclamation following an oil spill, utility companies also face federal and state fines and years of lengthy litigation. Learn the transformer oil containment requirements and how to comply.
SPCC Requirements: The Primary Legislation
The overarching body of legislation related to oil spills is U.S. Code of Federal Regulations (CFR), Title 40. It aims to protect the environment by preventing spills from affecting navigable waters.
40 CFR 112.7 establishes the rules for Spill Prevention, Control and Countermeasure (SPCC), specifically General Secondary Oil Containment requirements. Owners and operators of oil-filled equipment must access their potential risks of an oil release migrating offsite and into the navigable waters of the U.S. This assessment may require an SPCC plan.
SPCC Requirements: Standards for Electric Utility Companies
In 1973, the Institute of Electrical and Electronic Engineers (IEEE) established a working group to apply SPCC to substation transformers, which resulted in the development of IEEE Standard 980 – Guide for Containment and Control of Oil Spills in Substations.
The 980 Standard provides an overview of the SPCC requirements and application for substation transformers. It details site risk assessment and evaluation parameters as well as options and alternative solutions for spill control and countermeasures within substations.
SPCC Requirements – Three Important Questions to Ask
1. Do You Need an SPCC Plan?
SPCC applies to facilities that have more than 1,320 gallons of above-ground oil storage or more than 42,000 gallons below ground. Since transformers are considered oil-filled equipment, most substations fall into this category.
2. Can You Self-Certify Your SPCC Plan?
There are two criteria for self-certification. First, the above ground oil storage capacity in the substation transformer must be 10,000 gallons or less. Second, companies must have a good environmental track record.
The limit is only one spill into navigable waters greater than 1,000 gallons in the previous three years. There is also a maximum of two spills greater than 42 gallons in any 12-month period during that time.
Companies that fail to meet these criteria must use a Professional Engineer to certify their SPCC plan.
3. What Should an SPCC Plan Include?
SPCC plans list oil spill sources. IEEE 980 highlights oil filled equipment like substation transformers. Other sources for potential spills include cables, oil-handling equipment, reactors, oil circuit breakers, pots and storage tanks.
A plan is required to describe the probability of a failure and the size of spill that could result. Operational and inspection procedures help identify early warning signs to prevent spills.
SPCC plans cover general containment of the entire facility, including specific measures taken for individual pieces of oil filled equipment. The regulations provide numerous alternatives and methods for secondary oil containment.
C.I. Agent Solutions supplies multiple secondary containment options for the power utility sector. Our patented oil filtration technology captures hydrocarbons present in water as it evacuates from the containment area, without the aid of valves or pumps. It instantly and completely shuts off in the event of an oil release.
Finally, remember that no SPCC plan is complete without having countermeasures specified and in place. Facilities must prepare to respond to a spill when it happens. Speed of response is critical to prevent pollution to navigable waters.
Contact C.I.Agent Solutions for Help Meeting SPCC Requirements
C.I.Agent Solutions prides itself on being a global leader in providing secondary containment solutions for substation transformers. We deliver technical solutions that meet and usually exceed EPA and SPCC requirements. Contact us today for all your secondary containment needs.
- EPA. Overview of the Spill Prevention, Control, and Countermeasure (SPCC) Regulation
- ECO Watch. ‘Catastrophic’ Failure at Brooklyn Con Ed Spills 37,000 Gallons of Transformer Oil