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SPCC Plan Basics: What Is Oil?

Posted on 7/16/2018 by Roger Marks and James Griffin, CDGP

When viewed through the lens of environmental and safety compliance, even simple questions often have complicated answers. When we talk about “oil” and oil spills, we can’t always rely on our own knowledge and experience for the answers.

Instead, we must look to US EPA’s official definition of oil—and some other key terms—when determining whether programs like the Spill Prevention, Control, and Countermeasure (SPCC) requirements apply to our facilities.

New! The Developing an SPCC Plan Online Course guides EHS managers and engineers through the EPA regulations at 40 CFR Part 112 to determine which facilities must create an SPCC Plan, how to create or certify a plan, and what’s required to maintain compliance.

SPCC Plans: Basic Applicability

shutterstock_339937214.jpgEPA lays out the applicability of its SPCC Plan rules at 40 CFR 112.1(b), as follows:
The SPCC Plan requirements apply to any “owner or operator of a non-transportation-related onshore and offshore facility engaged in drilling, producing, gathering, storing, processing, refining, transferring, distributing, or consuming oil and oil products, and which, due to its location, could reasonable be expected to discharge oil in harmful quantities, as defined in part 110 of this chapter, into or upon the navigable waters of the United States or adjoining shorelines…”

Quite a mouthful. We know from this applicability statement that, in general, the SPCC rules apply to facilities that deal with large volumes of oil.

But what is oil when it comes to SPCC Plans?

Students of Latin may know that petroleum translates to “rock oil.” But it doesn’t take a classical education to know that the word “oil” typically describes viscous liquids burned for fuel.

While petroleum fuel oils come to mind first, SPCC planning applies to all kinds of oils--including foods.like vegetable oil, peanut oil, or castor oil and products like baby oil. Are facilities that store those oils subject to SPCC planning and preparedness requirements? What other types of oil can subject a facility to the SPCC requirements? Let’s find out.

EPA’s Definition of Oil for SPCC Planning

Oil_Refinery_68568742.jpgA look at EPA’s definition of oil in 40 CFR 112 shows us just how broadly the Federal government interprets the word. Within the SPCC requirements, EPA defines oil as:

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.” [40 CFR 112.2]

Exceptions to SPCC Plan Requirements

So, if you could potentially release a harmful amount of any oil, you need an SPCC Plan—right?

Not so fast! The SPCC requirements include a plethora of exemptions and exclusions that cover all kinds of materials and facilities. Let’s take a look at three of the biggest ones.  

SPCC Plans are not required for:
  • A “facility, that due to its location, could not reasonably be expected to have a discharge as described in paragraph (b) of this section…” In other words, if your facility is far enough from any protected water of the United States (e.g. in the middle of the desert), you are not subject to SPCC planning. 
  • Equipment or operation of vessels already subject to control of US DOT or US EPA (see 40 CFR 112.11(d)(ii) and (iii). In other words, discharges covered by a Clean Water Act permit or other EPA or DOT regulatory program are not subject to SPCC rules when certain conditions are met. 
  • Facilities with a completely buried oil storage capacity of 42,000 US gallons or less and an aggregate aboveground oil storage capacity of 1,320 US gallons or less*. SPCC planning is required for facilities that store oil in large volumes. Of course, having a plan to deal with spills makes sense for smaller facilities too, even if its not required under this program. 
*When calculating aboveground oil storage capacity, only containers with capacity of 55 gallons or more must be counted.  

We Know We Need an SPCC Plan. Now What?

Oil-350.jpgAll that said, determining that your site needs an SPCC Plan is only the first step to achieving compliance. Once you know you’re covered, you must develop a plan, have the plan certified by a professional engineer (or self-certify the plan, if you’re a “qualified facility”), implement the plan, and understand your reporting and recordkeeping responsibilities.

Depending on the type of oil you deal with, the SPCC requirements you must follow will vary. For a full guide on how to develop and implement a fully compliant SPCC Plan, check out the Developing an SPCC Plan Online Course, available now.

EHS e-Learning: SPCC Plan Online Course

The moment a spill occurs can be confusing and stressful for workers. Having a clear, easy-to-follow SPCC Plan in place to deal with oil spills not only helps facilities eliminate panic and efficiently address the spill, it’s also required under the Clean Water Act.

This in-depth online course guides EHS managers and engineers through the EPA regulations at 40 CFR Part 112 to determine which facilities must create an SPCC Plan, how to create or certify a plan, and what’s required to maintain compliance.

Check out the Developing an SPCC Plan Online Course today to get a handle on what’s required for your facility, and how to stay in compliance.

Tags: Act, 'Clean, environmental compliance, EPA, oil spill, SPCC Plan, Water

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