Caltha receives this question often as facility operators or owners are determining if the SPCC Rule applies to their site. The SPCC Rules define “oil” broadly, and also differentiate between “oil” and “non-petroleum oil”. Petroleum oils, fuels, etc are regulated, as are synthetic oils, and oily wastes. In general, materials that can create a surface sheen or an emulsion in water are likely regulated as oil under the SPCC rules.
40 CFR 122.2:
"Oil means oil of any kind or in any form, including, but not limited to: fats, oils, or greases of animal, fish, or marine mammal origin; vegetable oils, including oils from seeds, nuts, fruits, or kernels; and, other oils and greases, including petroleum, fuel oil, sludge, synthetic oils, mineral oils, oil refuse, or oil mixed with wastes other than dredged spoil."
"Non-petroleum oil means oil of any kind that is not petroleum-based, including but not limited to: Fats, oils, and greases of animal, fish, or marine mammal origin; and vegetable oils, including oils from seeds, nuts, fruits, and kernels."
On April 18, 2011, EPA published a final rule amending the SPCC regulations to exempt milk and milk product containers, associated piping and appurtenances. EPA believes that certain specific construction and sanitation standards and requirements address the prevention of oil discharges in quantities that may be harmful. The capacity of the exempt milk and milk product containers, piping and appurtenances does need not be included in a facility's total oil storage capacity calculation to determine if the facility is subject to SPCC.
SPCC Rules apply to oil-filled operational equipment. Oil-filled operational equipment means equipment that includes an oil storage container (or multiple containers) in which the oil is present solely to support the function of the apparatus or the device. Oil-filled operational equipment is not considered a bulk storage container, and does not include oil-filled manufacturing equipment (flow-through process). Examples of oil-filled operational equipment include hydraulic systems, lubricating systems, gear boxes, machining coolant systems, heat transfer systems, transformers, circuit breakers, electrical switches, and other systems containing oil solely to enable the operation of the device.
FAQ: Does an SPCC Plan Expire? How often must I update my SPCC Plan?
Caltha LLP provides specialized expertise to clients nationwide in the preparing PE certified and self-certified SPCC Plans, developing emergency preparedness procedures, and preparing cost-effective EHS management programs.
For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website
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