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Baker, Lydia From: Reich, Peter <Reich.Peter@epa.gov> Sent: Friday, May 24, 2019 8:45 AM To: Deporto, Courtney Subject: RE: Cutback Oil Tanks Hi Courtney, Thanks for checking in on this. Heated products would not be subject to APSA, however, they remain subject to the Federal SPCC Rule, unless, it is "Hot-Mix" Asphalt and their containers, which have been exempted from the Rule. I have input some details below. Call me Tuesday or next week if you would like to discuss in more detail. Otherwise, have a good holiday weekend. Pete Reich In General, From the SPCC Guidance for Regional Inspectors: Chapter 2 on Applicability: 2.2.1 Petroleum Oils and Non-Petroleum Oils The SPCC rule applies to both petroleum oils and non-petroleum oils. Petroleum oils include, but are not limited to, crude and refined petroleum products, asphalt, gasoline, fuel oils, mineral oils, naphtha, sludge, oil refuse, and oil mixed with wastes other than dredged spoil. Nonpetroleum oils and greases include coal tar, creosote, silicon fluids, pine oil, turpentine, and tall oils. (67 FR 47075, July 17, 2002). Subpart B of 40 CFR part 112 covers both "petroleum oils and non-petroleum oils..." Petroleum oils and non-petroleum oils, including synthetic oils, share common physical properties and produce similar environmental effects. Petroleum and non-petroleum oils can enter all parts of an aquatic system and adjacent shoreline, and similar methods of containment, removal and cleanup are used to reduce the harm created by spills of both types of oils. And more specifically: 2.2.4 Asphalt Asphalt is a thermoplastic material, composed of unsaturated aliphatic and aromatic compounds, that softens when heated and hardens upon cooling. Within a certain temperature range, it exhibits viscoelastic properties with viscous flow behavior and elastic deformation. All types of asphalt are petroleum oil products, and its composition depends on the source of the crude oil and the process used to manufacture it. The SPCC rule applies to asphalt cement(AC), as well as to asphalt derivatives such as cutbacks and emulsions. Because of the operational conditions under which AC, cutbacks and emulsions are used and stored, they do pose a risk of being discharged into navigable waters or adjoining shorelines. Although AC) is semi- solid or solid at ambient temperature and pressure, it is generally stored at elevated temperatures. Hot AC is liquid— similar to other semi-solid oils, such as paraffin wax and heavy bunker fuels—and therefore is capable of 1