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.

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