Do dry type transformers require a Spill Prevention, Control and Countermeasure (SPCC) plan per 40 CFR part 112?

A Spill Prevention, Control and Countermeasure (SPCC) plan per 40 CFR part 112 is typically required for many liquid cooled transformer installations. The purpose of the Spill Prevention, Control, and Countermeasure (SPCC) rule is to help facilities prevent a discharge of oil into navigable waters or adjoining shorelines. Dry type transformers do not require an SPCC plan.