From: Gary Jones (firstname.lastname@example.org )
Date: Fri, 26 Dec 2003 21:57:24
I am responding to the same inquiry that you posted on PNEAC and sent to Paul Gutkowski at Printing Industries of Minnesota regarding SPCC plans for black ink stored in quantities greater than 1,320 gallons. The short answer to your question is that an SPCC plan is required if the total of all petroleum containing and petroleum derived products stored in above ground containers of 55 gallons or more exceeds 1,320 gallons. Since lithographic ink contains either ink oil or vegetable oil (e.g. soya), the entire quantity of the ink is counted toward the total. While vegetable oils are not considered petroleum oils, they were specifically added to the list of covered substances several years ago. It is important to understand that even if the quantity threshold is exceeded, the second part of the applicability criteria must be met before a SPCC plan must be developed and implemented. This second criteria involves the fate of the released petroleum or vegetable oil product. If the material, once released, could not contaminate a waterway, then a plan is not necessary.