Applicability of the SPCC Requirements to Electrical Utilities

Applicability of the SPCC Requirements to Electrical Utilities
reposted from EPA region 6 website January 23, 2008

EPA’s SPCC requirements (40 CFR Part 112.1 through 112.7) apply to nontransportation-related facilities that could reasonably be expected to discharge oil into or upon the navigable waters of the United States or adjoining shorelines, and that have (1) a total underground buried storage capacity of more than 42,000 gallons; or (2) a total aboveground oil storage capacity of more than 1,320 gallons, or (3) an aboveground oil storage capacity of more than 660 gallons in a single container.

Some facilities may not be regulated if, due to their location, they could not reasonably be expected to discharge oil into navigable waters of the U.S. or adjoining shorelines. SPCC-regulated facilities must also comply with other federal, state, or local laws, some of which may be more stringent.

This guide is intended for SPCC-regulated facilities engaged in the generation, transmission, and/or distribution of electric power, and that use equipment (e.g., transformers and circuit breakers) which contain dielectric fluid (mineral oil) for insulation, compressor oil, and hydraulic oil. These facilities include power plants (including hydroelectric and cogeneration facilities), substations, switching stations, customer installations, test facilities, and equipment storage and maintenance facilities.

Operations related to SPCC at these facilities include the transfer of oil for maintenance activities, the storage of fuel oil for powering generators during emergencies or for power plant startup, and the storage of insulation (dielectric) oil in electrical equipment (e.g., transformers, oil circuit breakers, capacitors, regulators). Some facilities are moving towards using sulfur hexafluoride (SF6) gas for insulating circuit breakers. These circuit breakers do not contain oil for insulation purposes, but they do contain small amounts (e.g., two gallons) of compressor oil.

Many electrical utilities are subject to the SPCC regulation, and some utilities may be subject to the Facility Response Plan (FRP) requirements under 40 CFR 112.20 and 112.21 and associated appendices. All owners or operators of SPCC-regulated facilities should determine whether the facility poses a threat of substantial harm to the environment. All facilities must document this determination by completing the “Certification of the Applicability of the Substantial Harm Criteria Checklist,” provided as Attachment C-II in Appendix C of 40 CFR 112. This certification should be kept with the facility’s SPCC Plan.

As outlined in 40 CFR 112.20(f)(1), a facility has the potential to cause substantial harm and, therefore, must prepare an FRP if:

The facility transfers oil over water to or from vessels and has a total oil storage capacity, including both aboveground storage tanks (ASTs) and underground storage tanks (USTs), greater than or equal to 42,000 gallons; or
The facility’s total oil storage capacity, including both ASTs and USTs, is greater than or equal to one million gallons, and one of the following is true:
The facility lacks secondary containment that is able to contain the capacity of the largest AST within each storage area plus freeboard to allow for precipitation;
The facility is located at a distance such that a discharge from the facility could cause injury to an environmentally sensitive area;
The facility is located at a distance such that a discharge from the facility would shut down a public drinking-water intake; or
The facility has had a reportable spill greater than or equal to 10,000 gallons within the last five years.
Many power-generating facilities are located adjacent to or over water; so if their aggregate storage (including oil-filled electrical equipment, fixed and mobile storage tanks, etc.) is more than one million gallons, they are likely to be subject to the FRP requirements as well. These facilities are likely to be required to prepare an FRP because a discharge from the facility has a high potential to cause injury to an environmentally sensitive area or shut down a public drinking water intake.
To read further on this subject please visit:
http://www.epa.gov/earth1r6/6sf/sfsites/oil/elecutil.htm