Q: Our environmental compliance department has advised us that the US EPA considers all oil to be equal - with common compliance requirements. Is that right?
A: Not exactly. There are different requirements for different jurisdictions of the EPA. For example, FR3 fluid would be exempt from the Federal Regulation of Used Oils. Furthermore, within the 2002 edition of the SPCC (Spill Prevention Control and Countermeasures), two of the three key requirements are the same: "volume threshold for compliance" and the "minimum response time."
The EPA is considering further revisions as well as different remediation actions depending on the volume and site specifics. Remember: SPCC is only applicable to installations where there is exposure to navigable waters.
Q: Why should my company use FR3 fluid in place of mineral oil if there is no significant relief from the US EPA SPCC rules?
A: Since FR3 fluid-filled transformers have a favorable life cycle cost and a virtually non-existent potential for oil fires, why not use a fluid that is much more friendly to the environment? In a very sensitive OECD test method, trout fry were exposed to FR3 fluid for 96 hours; the mortality rate was zero. The biodegradability rate meets the highest EPA classification, while mineral oil has the lowest.
The US EPA has verified our environmental claims. Their document states: "These select mineral oil-based fluids listed a hydrotreated light naphthenic petroleum distillate, which is an IARC confirmed carcinogen."
Because FR3 fluid is biobased and made of edible oils, it meets the intent of the Edible Oil Act of 1995. This supports current and future environmental regulatory relief.
However, spill reporting and remediation may still be required by the authorities having jurisdiction, particularly for large volume spills into surface water.
Q: One of the conditions needed to meet SPCC requirements for remediation is that there must be a visible iridescent sheen on the water. Does FR3 fluid create a sheen similar to petroleum oils?
A: FR3 fluid does not create an iridescent sheen. Unlike mineral oil, it also tends to break up and disperse rather than maintaining a large-area sheen; it also biodegrades much faster than mineral oil. FR3 fluid is so safe that fish farms actually use similar edible vegetable oils for feeding.
Q: Which environmental tests for FR3 fluid were verified by the US EPA?
Table 1: Evaluations of Envirotemp® FR3 fluid environmental properties and associated test methods.
| Property |
Test |
Method |
|
| ENVIRONMENTAL HAZARD |
|
|
| Toxicity Acute Aquatic |
OECD 203 |
| Acute Lethality using |
Environment Canada |
| Rainbow Trout Biodegradation |
|
| Aquatic Biodegradation |
| Aerobic Aquatic |
| Biodegradation |
| Ready Biodegradation |
| Biochemical Oxygen |
| Demand (BOD5) |
| CEC L-33-A-93 OPPTS 835.3100 |
| OPPTS 835.3110 SM5210B |
|
| SITE ASSESSMENT |
|
|
| Total Petroleum Hydrocarbons |
|
| Fuel Hydrocarbons | SW-846 Modified 8015B |
| Total Recoverable Petroleum | |
| Hydrocarbons Spectrophotometric |
600/4-79/020 418.1 |
| Total Recoverable Oil and Grease |
|
| Gravimetric |
|
| Spectrophotometric |
600/4-79/020 413.1 |
| Target Compound List |
600/4-79/020 413.2 |
| Semi-Volatile Organics |
SW-846 Method 8270C |
| Volatile Organics |
SW-846 Method 8260B |
| Toxicity Characteristic |
|
| Leaching Procedure |
|
| 7000 series |
SW-846 Method 1311, |
| 3510, 8270 |
SW-846 Method 1311, |
| 5030, 8260 |
SW-846 Method 1311, |
| Total Threshold Limit Concentration |
|
| 7000 series |
SW-846 Methods 6010 |
|
| ASSESSMENT-RELATED PROPERTIES |
| Heat of Combustion |
|
ASTM D240 |
| Ignitability |
Pensky-Martens Flash Point |
SW-846 Method 1010 |
| Setaflash Flash Point |
|
SW-846 Method 1020A |
| Total Organic Halides |
(TOX) |
|
| Extractable Organic Halides |
SW-846 Method 9020B |
|
| Leachable Fluoride |
|
600/4-79/020 340.2 |
| Cyanides |
Reactive Cyanide |
SW-846 7.3.37 |
| Cyanides in Waste |
ASTM D5049T |
|
| Sulfides |
Reactive Sulfide |
SW-846 7.3.4s |
| Sulfides in Waste |
ASTM D4978 |
|
| Soil and Waste pH |
|
SW-846 Method 9045C |
| Specific Gravity |
|
SM 2710F |
| Odor, Color, Appearance |
ASTM D4979 |
ASTM D4979 |
Q: Do any states provide preferential relief for FR3 fluid spills that are not under SPCC jurisdiction?
A: Most states do not officially address edible oil spills to soil. Several use "total petroleum hydrocarbon" (TPH) levels as the basis for remediation requirements. FR3 does not register or test as a TPH. Mineral oil does. While several state agencies will selectively consider allowing FR3 fluid spills to biodegrade naturally, there are some states that regulate edible oils and petroleum products equally.
Q: Is there anything in FR3 fluid that would negatively impact ground water quality?
A: Although it's unlikely that the fluid would ever reach ground water, because of viscosity and other characteristics, there is nothing that will significantly affect the quality of the ground water. In fact, the USDA has conducted studies using vegetable oils to remediate fertilizer-contaminated well water.
Q: How long will it take for FR3 fluid to "disappear" if it is spilled?
A: In EPA testing, FR3 fluid completely biodegraded within 28 days. It's important to note however, as with any biodegradable material, biodegradation rate is dependent upon climatic and environmental conditions.
Q: Does the FM Global Loss Prevention Sheet for transformers actually differentiate containment requirements for FR3 fluid?
A: Yes, with FR3 fluid, as well as other fluids that are non-toxic and quick to biodegrade, FM allows a doubling of the threshold volume of other fire-resistant fluids before containment is required (sites under SPCC jurisdiction excluded). The US EPA "ETV" logo on FR3 fluid-filled transformers assures compliance with the FM requirement.
