This week, we’re sharing a SPCC Q&A from our companion site, Enviro.BLR.com.
Should oil mixed with absorbent (from spill cleanup) be included in a facility’s oil inventory for SPCC purposes? Would it be considered as oil during an inspection?
Here’s the answer:
Under the federal Spill Prevention, Control and Countermeasure (SPCC) regulations, oil mixed with absorbent falls under the definition of “oil,” and must be included in a facility’s oil inventory.
The SPCC regulations define “oil” extremely broadly, and this material would be considered regulated “oil” by an EPA SPCC inspector.
However, remember that only containers with a capacity of 55 gallons or more are counted toward SPCC capacity, so if such materials are stored in containers that have a capacity of less than 55 gallons, they will not be counted toward the 1,320 SPCC regulatory threshold.
Containers less than 55 gallons also do not need to be identified on the SPCC plan facility diagram.