Wednesday, January 31, 2018

Do Electric Transformers Need To Be In SWPPP and SPCC Plan?

Electric transformers are found at almost every larger commercial, institutional and industrial facility. Sometimes this equipment is owned by the facility owner and sometimes by the power company. For some facilities, it is not always clearly understood who owns and is responsible for transformers.

Can Electric Transformers Leak Oil?

Yes, electric transformers can leak oil, but only if they actually contain oil.

How Can I Tell If Electric Transformer Contains Oil?

For newer transformers, the quantity of oil in the unit is usually found on the label. For older equipment, this information may not be on the label, or the label may have been removed or is illegible. In this case, a visual inspection of the equipment by a knowledgeable person can usually determine if it contains oil or not.     Not sure?   Send Caltha a photo and we may be able to determine this - send to

Who Is Responsible To Clean Up Leaks From Transformers?

This will depend on State laws. In general, the Owner of the equipment is responsible. However, for a property owner whose property has been impacted by a leaking transformer, the issue could affect the value of the property and they may voluntarily elect to clean up leaks.

What Are The Environmental Risks For Electric Transformers?

A risk for oil spills exists for any oil-filled transformer. Older transformers commonly contained PCB oils. Use of PCB oils has been phased out and newer equipment is often labeled "No PBC"; however older electric transformers could still contain PCBs which makes clean up more involved.

Leaks can occur over long periods and accumulate slowly. The other risk is an emergency spill caused by a fire or the transformer being damaged by vehicles, etc. These risks are minimized by ensuring equipment is included in pollution prevention plans and spill plans (such as SWPPP, SPCC Plan or other spill plans) and is regularly inspected and maintained.

Typical Leaking Electric Transformer

Sunday, January 28, 2018

Action On Waters of US At Supreme Court

On January 22, 2018, the Supreme Court unanimously decided a procedural issue determining the court in which challenges to the meaning of the term “Waters of the United States” (WOTUS) may be brought. The choice of court is significant because it affects the resources needed to litigate the merits of challenges, sets the statute of limitations for filing lawsuits and helps determine whether actions can be challenged in subsequent civil or criminal proceedings.

Immediate Impact of Waters of US Decision

The decision requires that any challenge to the current meaning of WOTUS must be brought in the federal district court rather than in the federal court of appeals and allowed pending litigation in the district courts to continue. Lifting the stay puts the Obama-era WOTUS definition back into effect and forces any future litigation to occur throughout the United States wherever there is a challenge to the WOTUS definition, unless it is able to get a stay in the pending litigation.

Why is Waters of the US Definition Important?

WOTUS is a key term impacting the scope of Clean Water Act. The EPA and Corps of Engineers issued the definition in May 2015. The rule was widely criticized, with many, such as farmers, home builders, and developers, claiming that the rule impermissibly allowed EPA to regulate private land. Others felt the rule narrowed federal jurisdiction. In the Supreme Court, the current Administration argued that any challenges to the meaning of WOTUS must be brought in a court of appeals; this argument was rejected in the court decision.

Under the Clean Water Act, the uncertainty as to the scope of the WOTUS rule affects whether a Federal discharge permit (NPDES permit) is required and the scope of permits needed to discharge wastewater and storm water. It also impacts whether real estate contains federally-regulated wetlands.

Saturday, January 20, 2018

SPCC Five Year Review and Spill Plan Update In Superior, WI

Caltha LLP Project Summary

Project: SPCC Plan 5-Year Review, Plan Update & Management Compliance Training 
Client: Transportation Terminal
Location: Wisconsin

Key Elements: Regulatory compliance training, SPCC Plan

Overview: Caltha LLP was retained by this multimodal transportation terminal to conduct the five-year review of its Spill Prevention, Control & Countermeasure (SPCC) Plan. Under 40 CFR 112, SPCC Rule regulated facilities are required to conduct and document a review of their SPCC Plan at least every five years, independent of the requirement to keep the facility SPCC Plan updated to reflect changes at the facility. In conjunction with this review, Caltha staff provided ad hoc compliance training to selected facility staff on SPCC Rule requirements. Finally, Caltha prepared an updated facility SPCC Plan to reflect administrative changes at the facility.

 Click here for more Caltha project examples related to SPCC compliance, including spill plans and SPCC annual training. Click here to review more project examples for facilities located in Wisconsin and Wisconsin regulatory updates.

Monday, January 15, 2018

Stormwater Discharge From Recycling Facility To Georgia Impaired Stream

Caltha LLP Project Summary

Project: Industrial Storm Water Permitting, SWPPP Certification & Compliance with Impaired Waters Requirements
Client: Scrap Metal Recycling facility
Location(s): Georgia

Key Elements: SWPPP preparation, Stormwater monitoring, Compliance plan, Impaired waters consulting

Overview: Caltha LLP has provided consulting services to this scrap metal recycling facility to meet the Georgia industrial storm water rules and the Georgia Environmental Protection Division of the Department of Natural Resources general industrial discharge permit. Services included preparing facility stormwater pollution prevention plan using Caltha’s Georgia SWPPP template, preparation of site-specific inspection checklists to comply with State inspection requirements, preparation of site-specific stormwater monitoring plan to meet State requirements applicable to this industrial sector, including additional requirements for discharges to listed impaired waters. Caltha then provided ad hoc technical support to facilities to address questions during roll-out of the compliance programs.

 Example Of Industrial Waste Being Discharged 
To Storm Sewer

For more information on Caltha LLP SWPPP services, go to the Environmental Health & Safety Plan | Spill Plan Information Request Form.

Click here to review other example Caltha industrial stormwater projects. Click here to review other Caltha projects in Georgia and GA regulatory updates.