The Spill Prevention, Control, and Countermeasure (SPCC) rule under 40 CFR Part 112 requires facilities that store oil to develop, maintain, and implement SPCC plans. Regular inspections are a critical component of every plan: they verify that storage containers, containment systems, and associated equipment remain in good working condition and capable of preventing oil discharges to navigable waters. This guide covers each inspection type, its frequency, documentation requirements, and how SPCC software streamlines the entire process.
Common SPCC Inspection Challenges
Who Must Comply?
Facilities must comply with SPCC inspection requirements if they meet all three criteria under 40 CFR § 112.1(d):
SPCC Applicability Criteria
- Non-transportation-related facility
- Aggregate aboveground oil storage capacity greater than 1,320 gallons, or completely buried oil storage exceeding 42,000 gallons
- Could reasonably be expected to discharge oil to navigable waters or adjoining shorelines
Covered facilities include industrial plants, manufacturing facilities, utilities and power generation, agricultural operations, military bases, commercial warehouses, and any other operation storing petroleum products in regulated quantities.
Visual Inspections (40 CFR § 112.8(c)(6))
Frequency and Scope
Visual inspections should be performed regularly, often daily or weekly, depending on the facility size, quantity of oil stored, and spill risk. The specific frequency should be documented in your SPCC plan based on facility-specific risk assessment.
- Inspect tanks, containers, pipes, and fittings for signs of damage, leaks, corrosion, or deterioration
- Check secondary containment systems (berms, dikes, liners) for cracks, erosion, or accumulated water
- Verify drainage valves are in the correct position (closed unless actively draining accumulated precipitation)
- Inspect loading/unloading areas for signs of spills or equipment wear
- Check security measures including fencing, lighting, and locks (40 CFR § 112.7(g))
Formal Integrity Testing (40 CFR § 112.8(c)(6))
Testing Standards and Methods
Formal integrity testing evaluates the structural soundness of storage tanks using industry-standard methods. The testing interval depends on tank type, age, condition, and the standard applied:
- STI SP001 - Standard for the Inspection of Aboveground Storage Tanks. Establishes inspection intervals based on tank construction, protection, and condition (ranges from 5 to 20 years)
- API 653 - Tank Inspection, Repair, Alteration, and Reconstruction. Applies primarily to large field-erected tanks and defines external/internal inspection intervals
- Non-destructive testing (NDT) - Ultrasonic thickness testing, radiographic testing, magnetic particle inspection, and other methods to assess wall thickness, welds, and structural integrity
- Hydrostatic testing - Filling the tank with water to test for leaks and structural integrity under pressure
Integrity Testing Documentation
- Date of each test and next scheduled test date
- Test method used and applicable standard (STI SP001, API 653, etc.)
- Inspector name, qualifications, and certifying organization
- Detailed findings including measurements (wall thickness readings, etc.)
- Any maintenance, repairs, or corrective actions performed
- Pass/fail determination and recommendations for future testing intervals
Secondary Containment Inspections
Containment System Checks
Secondary containment is your last line of defense against oil reaching navigable waters. Inspections must verify:
- Structural integrity - Berms, dikes, and walls free of cracks, gaps, or erosion
- Adequate capacity - Containment holds at least the volume of the largest container plus sufficient freeboard for precipitation. Use our Containment Volume Calculator to verify
- Drainage valve position - Valves must be maintained in the closed position unless actively draining accumulated stormwater under supervised conditions
- Liner condition - Synthetic liners free of tears, punctures, or UV degradation
- Accumulated water - Precipitation must be removed promptly to maintain containment capacity
Documentation Requirements (40 CFR § 112.7(e))
What Records Must Be Maintained
- Inspection logs - Date, time, inspector name, and findings for every inspection
- Maintenance records - Date, type of work performed, who performed it, and materials used
- Test results - Complete integrity testing reports with measurements and conclusions
- Corrective actions - Description of issues found, actions taken, timelines, and responsible personnel
Qualified Inspector Requirements
The SPCC rule requires that inspections and tests be conducted by qualified personnel with the necessary training, knowledge, and experience to accurately assess oil storage container integrity (40 CFR § 112.8(c)(6)). Routine visual inspections can typically be performed by trained facility personnel. Formal integrity testing usually requires third-party inspectors or specialized testing companies certified in NDT methods, STI SP001 evaluations, or API 653 assessments.
Best Practices for SPCC Inspections
Recommendations for Compliance
- Develop a detailed inspection schedule based on facility-specific risks, container types, and regulatory requirements
- Use standardized checklists to ensure consistency and completeness across all inspections
- Train all inspection personnel on SPCC requirements, inspection techniques, and proper documentation
- Address findings promptly with tracked corrective actions and verified completion dates
- Review and update the SPCC plan at least every five years, or whenever facility changes affect spill potential (40 CFR § 112.5(b))
- Use SPCC software to automate scheduling, notifications, and documentation to eliminate missed deadlines
Frequently Asked Questions
What needs to be inspected under the SPCC rule?
The SPCC rule requires inspection of the elements that keep oil out of navigable waters: bulk storage container shells and supports, secondary containment structures including dikes, berms, and liners, drainage valves and their closed position, piping, valves, and transfer areas, oil-filled operational equipment, and loading and unloading racks. Facilities must also verify that accumulated stormwater inside containment is uncontaminated before it is released.
How often must SPCC inspections be performed?
Visual inspections should be performed regularly, often daily or weekly, depending on the facility size, oil storage quantity, and spill risk. Formal integrity testing is required at intervals determined by industry standards such as STI SP001 or API 653, typically ranging from annual to every 20 years depending on tank type and condition. Secondary containment must be inspected frequently enough to ensure it functions properly at all times.
What should an SPCC inspection checklist include?
An effective SPCC inspection checklist covers container condition (corrosion, coating failure, leaks, deformation, foundation and support integrity), secondary containment integrity and available freeboard, drainage valve position and lock status, the presence of sheen or accumulated water inside containment, condition of piping, flanges, and valves, security items such as lighting and fencing, and the status of spill response equipment. Each item needs a pass or fail result, and every failure needs a corrective action with an owner and a due date.
What must be documented during SPCC inspections?
Documentation must include the inspection date, inspector name, findings, and any corrective actions taken. For formal integrity testing, records must also include the test methods used, results, and any maintenance or repairs conducted. All records must be maintained for at least three years and be readily available for EPA inspection under 40 CFR 112.7(e).
Who is qualified to perform SPCC inspections?
The SPCC rule requires inspections and tests be conducted by qualified personnel with the necessary training, knowledge, and experience to assess the integrity of oil storage containers. Routine visual inspections can typically be performed by trained facility personnel. Formal integrity testing often requires third-party inspectors or specialized testing companies certified in methods like ultrasonic testing or STI SP001 evaluations.
What is EPA's SPCC Guidance for Regional Inspectors?
The SPCC Guidance for Regional Inspectors is EPA's internal reference document explaining how the agency interprets and applies 40 CFR Part 112 during facility inspections. It is not a regulation and does not create obligations on its own, but it is the clearest available window into how EPA evaluates containment sizing, integrity testing, qualified facility eligibility, and plan adequacy. Facilities frequently use it to anticipate inspector expectations before an EPA visit.
What facilities must comply with SPCC inspection requirements?
Facilities must comply if they are non-transportation-related, have aggregate aboveground oil storage capacity greater than 1,320 gallons or completely buried storage exceeding 42,000 gallons, and could reasonably be expected to discharge oil to navigable waters or adjoining shorelines. This includes industrial plants, utilities, agricultural facilities, military bases, and commercial operations with oil storage.
What are the penalties for failing to perform SPCC inspections?
EPA can assess civil penalties for SPCC noncompliance under the Clean Water Act on a per-day, per-violation basis. The statutory amounts are adjusted for inflation each year under EPA's Civil Monetary Penalty Inflation Adjustment Rule, so the current maximums are meaningfully higher than the figures written into the statute. If a discharge occurs at a facility with incomplete inspections or missing records, penalty exposure and cleanup liability both increase substantially. Complete inspection records are primary evidence of due diligence during EPA audits and enforcement actions.
Ecesis SPCC Software
SPCC Software
Centralize container data, automate inspections, and generate SPCC plans.
Inspection Software
Configurable checklists, mobile field inspections, and automated scheduling.
Preventive Maintenance
Schedule and track tank maintenance, repairs, and equipment work orders.
Employee Training
Track SPCC training compliance and inspector certifications.
Task Management
Assign and track corrective actions from inspection findings to completion.
Mobile EHS App
Complete field inspections with barcode scanning, photos, and GPS.
