SPCC Containment Stormwater Discharge

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?
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Both for new installations and for retrofitting we attach a liner to the
transformer pad. The liners drain to gravity oil separation tanks.

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?


From the originalgatevalve
.