The transformer counts toward SPCC.
EPA treats transformers as oil-filled operational equipment, counts any unit of 55 gallons or more toward the SPCC threshold, and applies 40 CFR part 112 to a facility with more than 1,320 U.S. gallons of aggregate aboveground oil. A facility that relies on the qualified oil-filled operational equipment alternative to secondary containment must document inspection procedures or a monitoring program to detect equipment failure or a discharge, and it keeps that status only while it has had no single discharge over 1,000 gallons and no two discharges over 42 gallons in any twelve months over three years (40 CFR 112.7(k)).





