I’ll Have a Shot of SPCC in My Latte

There is much confusion surrounding the applicability of SPCC requirements. A question that recently came across the desk of one environmental expert involved oil in flavorings. The person asked if flavorings that contain small amounts of oil (for example, almond and hazelnut oil) count towards an inventory to determine SPCC applicability if they are stored in 55-gallon (gal) drums or larger?

The answer is Yes. Under the SPCC regulations, the term “oil” is very broad and includes all kinds of oils, such as animal fats and vegetable oils. To make it a bit more onerous, the rule also does not define a percentage of oil in a mixture for the purpose of defining if a mixture is an oil for regulatory applicability purposes. Therefore, if you have nut oils as part of a flavoring mixture in drums with a capacity of 55 gal or greater, and because nut oils are considered oil under the SPCC regulations, the entire flavoring mixture that includes such oils as additives is considered to be an oil. As a result, the capacity of these drums toward the facility’s aboveground threshold capacity must be counted for SPCC purposes.

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Oils under SPCC

Oils are generally broken down into two main groups: petroleum and nonpetroleum types. Petroleum oils are broken down into both crude and refined oils.

Examples of crude petroleum oils include light volatile oils, nonsticky oils, heavy sticky oils, and nonfluid oils. Examples of refined petroleum oils include gasoline, kerosene, different weights of fuel oil, and lubricating oils.

A nonpetroleum oil is any kind of oil 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 oil from seeds, nuts, fruits, and kernels. Animal fats and vegetable oils are broken down into three groups depending on their specific gravity—less than 0.8, equal to or greater than 0.8 but less than 1.0, and equal to or more than 1.0.

Each type of oil has different characteristics, so contingency, response, and cleanup plans will vary depending on the type of oil stored. In particular, the density of the oil is an indicator to whether the oil will sink or float on the surface of water. These are important considerations in determining the best methods of responding to and containing spills.

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Note about SPCC applicability

The SPCC regulations apply to non-transportation-related facilities with a total aboveground oil storage capacity of greater than 1,320 gal or buried oil storage capacity greater than 42,000 gal. , and that because of their locations, these facilities could reasonably be expected to discharge oil into navigable waters of the United States or adjoining shorelines. Farms are subject to different applicability provisions.

SPCC capacity tip

As a general rule of thumb, the propensity to have an oil spill, the severity of the spill, and the cost of cleaning up the spill go up with the total amount of:

• Oil storage capacity of the facility;
• Number of tanks at the facility; and
• Throughput and transfer of oil at the facility.

As such, it would be a good idea for you to reduce, where possible, these items at your facility.