Q. Is it a correct interpretation that the hydraulic oil in a boom lift is exempt from all Spill Prevention, Control, and Countermeasure (SPCC) requirements because it is an ancillary onboard oil-filled operational equipment?
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A. Your interpretation is correct. 40 CFR 112.1(d)(7) exempts motive power containers from regulation under the SPCC regulations, with 112.1(d)(2)(ii) excluding the capacity of these containers from facility capacity calculations. According to the EPA, motive power containers include the fuel tanks that are used primarily to power a motor vehicle’s movement and the on-board hydraulic and lubrication containers used for ancillary functions of the motor vehicle. Therefore, the hydraulic oil in the boom lift is exempt because it is in the boom lift, a piece of ancillary oil-filled operational equipment.