Consolidated Edison of New York, Inc. Oil Spill Contingency Plans for Electric Substations
Posted on July 14, 2015
Client: Consolidated Edison of New York, Inc.
Location: New York Metropolitan Area
Project Type: Oil Spill Contingency Plans for Electric Substations
- Development of a Risk Assessment
- Preparation of Oil Spill Contingency Plans
- Preparation of Drainage Maps using GIS
- Indentification of Receiving Treatment Facilities and/or Water Bodies
The firm was retained by The Consolidated Edison Company of New York, Inc. (Con Edison) to provide multimedia environmental compliance support by preparing Oil Spill Contingency Plans (Contingency Plans) for 278 Con Edison electric substations in accordance with the requirements found at 40 CFR Parts 109 and 112 for 278 Con Edison electric substations located in the five boroughs of New York City, as well as in Dutchess, Rockland and Westchester Counties.
Con Edison is a regulated utility company that provides electric service primarily to New York City and Westchester County. The substations that comprise the electric distribution system include numerous Area, Transmission and Unit Substations as well as High Tension Vaults and Public Utility Refrigeration Systems. All of these facilities include
oil-filled equipment subject to the requirements of the United States Environmental Protection Agency (USEPA) Oil Pollution Prevention regulations (40 CFR Part 112).
40 CFR Part 112 requires that the owner or operator of a regulated facility where secondary containment for oil-filled equipment is determined to be impracticable, to prepare an Oil Spill Contingency Plan in addition to a Spill Prevention, Control and Countermeasure (SPCC) Plan. The Oil Spill Contingency Plan must meet the minimum requirements outlined in 40 CFR Part 109 and include a written commitment of manpower, equipment and materials required to expeditiously control and remove any quantity of oil that may be harmful.
Although the Con Edison electric substations are in compliance with the regulations in that these facilities meet the general secondary containment requirements for the oil-filled equipment, Con Edison enlisted D&B to provide technical assistance in preparing Contingency Plans for these locations as an additional precautionary measure. The Contingency Plans ensure a supplementary level of protection to respond to a spill or release of oil from these facilities due to a catastrophic event, such as a major fire or explosion.
In accordance with the requirements of 40 CFR Part 109, the Contingency Plans provide the following information:
• Authorities, Responsibilities and Duties of all persons, organizations or agencies which are to be involved or could be involved including Con Edison and federal, state and local authorities.
• Spill Notification Procedures to be initiated upon discovery of an oil spill including identification of critical water use areas, emergency contacts and required notifications, communication system and requesting outside assistance.
• Resource capability, including an inventory and the location of equipment, materials and supplies available for emergency spill cleanup, an estimate of resources required for the maximum discharge and response agreements for the acquisition of equipment, materials and supplies for responding to the discharge.
• Spill Containment and Cleanup Procedures that include the identification of a spill response team, designation of a response coordinator, logistics for a response operations center, provisions for varying degrees of response efforts, and prioritization for protecting water uses.
• Recovery Procedures to facilitate recovery of damages and enforcement measures provided for by state and local statues and ordinances.
Site-Specific Oil Spill Contingency Plans
In order to prepare the site-specific Contingency Plans, a risk assessment was conducted for each of the electric substations. The risk assessment consisted of a review of records and pertinent information, as well as a field inspection to determine the following:
• Site Drainage Patterns;
• Potentially Impacted Resources;
• On-site and Locally Available Oil Spill Response Resources;
• Local Jurisdiction Information; and
• Other Pertinent Site-Specific Information.
The findings of the assessment were utilized to determine the potential impacts of an oil discharge from each of the electric substations and the potential for the off-site drainage to enter a nearby waterbody and/ or drainage structure (i.e., catch basins, storm drains, etc.). Drainage maps and information were obtained from each of the respective municipalities to identify the potential pathway in the combined sewer system or Municipal Separate Sewer Systems (MS4s). Subsequently, the receiving wastewater treatment plant and/or receiving waterbodies were identified.
Spill response deployment areas were identified for each of the potential oil discharge pathways. These deployment areas included specific locations for spill response actions such as covering storm drain inlets, deploying containment to outfalls/ downstream locations/storm water regulators and contacting the receiving wastewater treatment plant. The spill response deployment actions were prioritized based on the different scenarios identified addressing varying degrees of impact.
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