Counting oil in an SPCC Plan

Someone asked me the other day if he needed to count the fuel oil in his backup generator towards the 1320 storage threshold for preparing an SPCC.

My answer was yes – if the “oil capacity” in his generator is 55 gallons or more and he is the “owner and operator” of the generator. Note that in SPCC, the term “capacity” refers to the shell capacity – not the actual amount of oil in the container.

See tables below. They are taken from EPA’s Guidance for Regional SPCC Inspectors.


Leave a Reply

Fill in your details below or click an icon to log in: Logo

You are commenting using your account. Log Out / Change )

Twitter picture

You are commenting using your Twitter account. Log Out / Change )

Facebook photo

You are commenting using your Facebook account. Log Out / Change )

Google+ photo

You are commenting using your Google+ account. Log Out / Change )

Connecting to %s