The SPCC rule requires inspections but does not publish a checklist. Section 112.7(e) of 40 CFR Part 112 requires written inspection procedures, signed records, and three-year retention, and leaves the specific items to the facility to define in its plan in accordance with industry standards. This page provides a practical starting checklist you can adapt, organized by the areas an EPA inspector will look at.
Where Checklists Usually Fall Down
Bulk Storage Container Items
Shell, heads, and coating
- Visible corrosion, pitting, blistering, or coating failure on the shell and heads
- Dents, bulges, or deformation suggesting overpressure or impact damage
- Active leaks, weeping seams, or staining on the exterior surface
- Legible container identification and product labeling matching the plan inventory
Foundation and supports
- Cracking, spalling, settlement, or washout of the foundation or pad
- Corrosion at saddle or leg supports and at the container-to-support contact points
- Standing water or debris accumulation under or against the container
- Evidence of tank movement or tilting since the last inspection
Appurtenances
- Vents clear and unobstructed
- Gauges and level indicators functioning and readable
- Overfill prevention devices present and operable
- Fill ports, hatches, and manways closed and secured
- Ladders, platforms, and railings sound where present
Secondary Containment Items
Structural condition
- Cracks, gaps, erosion, or animal burrows in dikes, berms, or walls
- Liner condition: tears, exposure, UV degradation, or displacement
- Penetrations through the containment wall sealed and intact
- Vegetation or root intrusion compromising the containment barrier
Available capacity
- Accumulated rainwater, snow, or ice reducing available freeboard
- Debris, stored materials, or equipment placed inside the containment area that displaces volume
- Containment still sized correctly if containers have been added, resized, or relocated since the last inspection
Where containers have changed, re-run the calculation rather than assuming the original design still holds. Our containment volume calculator and the secondary containment guide cover the sizing rule.
Drainage valves
- Valve in the closed position and secured or locked
- Manual open-and-closed design, not a flapper-type valve that can fail open
- Valve body and seat free of corrosion, and the valve operable
- Accumulated water inspected for sheen or oil before any release, with the inspection recorded
- Valve returned to closed and secured immediately after draining
Piping, Valves, and Transfer Areas
- Corrosion, damage, or leaks at piping, flanges, unions, and valves
- Pipe supports and hangers intact, with no unsupported spans
- Buried piping: no surface staining, wet spots, or vegetation die-off along the route
- Out-of-service piping capped or blank-flanged
- Transfer and loading areas: containment present, drip pans in place, hoses and couplings sound
- Loading and unloading racks: warning system, barrier, or interlock in place to prevent premature drive-away
- Stains, sheen, or evidence of past releases anywhere in the transfer area
Security and Response Readiness
- Master flow and drain valves locked when in non-operating or standby status
- Starter controls on oil pumps secured against unauthorized use
- Loading and unloading connections capped or blank-flanged when not in service
- Lighting adequate for the site and for discovery of discharges during hours of darkness
- Fencing and gates intact where the plan relies on them
- Spill kits and sorbents stocked, accessible, and within any shelf-life limits
- Emergency contact and notification information posted and current
Annual and Periodic Review Items
Beyond the routine visual round, a set of items belongs on a longer cycle:
- Container inventory reconciled against the plan: additions, removals, and capacity changes reflected
- Facility diagram still accurate for container locations, containment areas, and drainage paths
- Integrity testing status current for every bulk storage container, with next-due dates confirmed
- Personnel training and discharge prevention briefings completed and documented
- Open corrective actions from prior inspections reviewed and closed
- Plan amendment triggers evaluated, and the five-year review scheduled or completed
What Every Inspection Record Must Capture
Section 112.7(e) is about the record as much as the inspection. Each completed inspection should carry:
| Field | Why it matters |
|---|---|
| Date and time | Establishes the interval was met and the record is contemporaneous. |
| Inspector name and signature | Section 112.7(e) requires signed records; anonymous forms are not sufficient. |
| Specific container or area inspected | Ties the finding to an identified asset in the plan inventory, not a generic location. |
| Result per item | A pass or fail on each line, rather than a single overall verdict. |
| Description of any deficiency | Gives the corrective action something specific to resolve. |
| Corrective action, owner, and due date | Turns a finding into a tracked commitment instead of an observation. |
| Closure date and verification | Demonstrates the loop was actually closed, which is what an auditor tests. |
Frequently Asked Questions
What should an SPCC inspection checklist include?
An effective SPCC inspection checklist covers bulk storage container condition including corrosion, coating failure, leaks, deformation, and foundation and support integrity; secondary containment structural condition and available freeboard; drainage valve position and lock status; the presence of sheen or accumulated water inside containment; piping, flange, and valve condition; transfer and loading area containment; security items such as valve locks and lighting; and spill response equipment readiness. Each item needs a pass or fail result, and every failure needs a corrective action with an owner and a due date.
Does EPA publish an official SPCC inspection checklist?
EPA does not publish a mandatory checklist that facilities must use. Section 112.7(e) requires written inspection procedures and signed records but leaves the specific items to the facility to define in its plan in accordance with industry standards. EPA does publish inspection-related material in its SPCC Guidance for Regional Inspectors, which shows how the agency evaluates compliance and is a useful reference when building your own form.
How often should SPCC inspections be performed?
The rule does not set one universal interval. Facilities define frequencies in their plan based on facility size, oil volume, container type, and spill risk, and in accordance with industry standards. In practice, monthly visual rounds of containers and containment are common, with more frequent checks after significant rainfall, and formal integrity testing on the multi-year intervals set by STI SP001 or API 653.
What is the most common SPCC inspection finding?
Open or unsecured secondary containment drainage valves are among the most frequently cited deficiencies. An open dike drain valve converts engineered containment into a direct pathway to the environment and is immediately visible to an inspector. Missing or incomplete inspection records are the other common category, since the rule requires signed records retained for three years.
Who can perform SPCC inspections?
Routine visual inspections can typically be performed by trained facility personnel who understand what they are looking at and what constitutes a deficiency. Formal integrity testing is different and generally requires certified third-party inspectors, such as STI-certified SP001 inspectors or API 653-certified inspectors, along with technicians certified to appropriate ASNT levels for non-destructive testing methods.
How long must SPCC inspection records be kept?
At least three years under 40 CFR 112.7(e). Records must be signed and readily available for on-site review by the EPA Regional Administrator. Retrieval matters as much as retention in practice, since an inspector will typically ask for a specific container's or containment area's history rather than for the file as a whole.
Should containment be re-measured if a tank is added?
Yes. Adding, resizing, or relocating a container changes both the displacement volume inside the containment area and potentially the capacity of the largest single container, which is the basis for the sizing requirement under 40 CFR 112.8(c)(2). The containment calculation should be re-run rather than assumed still valid, and a change of this kind is also likely to trigger a technical amendment to the SPCC plan.
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