“Back in the day, we put leaking pots in a trash bag, and we were good to go!”
For hundreds of Incident Prevention readers, that remark isn’t totally unheard of. And in reality, it’s not far off from what some do when leaking transformers are transported or stored prior to reclamation or disposal. However, that will not save a utility from the fines and reclamation actions it could face if transportation or environmental regulatory authorities get involved.
Utilities fall under numerous environmental regulations, including the Toxic Substances Control Act of 1976. Since the 1970s, public demand for environmental safety also has led to numerous additional requirements. The problem is that the various agencies, with their overlapping environmental requirements, don’t specifically or clearly detail the issues that utilities face with aerial and padmount transformers and other line equipment that are insulated with a variety of fluids or oils. Individual states also may have regulations that exceed federal standards, potentially increasing utility exposures. What is clear is that if you dump oil, no matter what kind it is, you will face fines and reclamation costs far beyond what the cost of compliance would have been.
Ultimately, utilities must be concerned about the greatest exposure to environmental enforcement, and that is field-employed transformers and switchgear that contain chemicals. Transportation and storage of fluid-insulated apparatus are covered by numerous U.S. Environmental Protection Agency standards, including the Resource Conservation and Recovery Act, as well as standards from the U.S. Department of Transportation and the Pipeline and Hazardous Materials Safety Administration. But even more important than regulations may be your customers’ impressions of your environmental stewardship. These days, the public has become more sensitive to environmental risk exposures. Oil dripping from trucks or apparatus impacts the public perception of a utility.