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
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.
