SPCC plan template › SPCC inspection checklist
SPCC inspection checklist
The SPCC rule makes you inspect tanks, containment and aboveground piping on a regular schedule set by an industry standard, write that schedule into your plan, and keep signed records for three years. For small shop-built tanks and drums with containment, that usually means a visual check every month plus a few yearly items. The checklist below follows EPA's own template.
What the rule actually requires
- Integrity testing (112.8(c)(6)). Test or inspect each aboveground container on a regular schedule and after material repairs. The frequency, type of test and who may do it come from an industry standard, chosen for the container's size and design. Inspect supports and foundations, and keep comparison records.
- Frequent outside checks (same paragraph). Look at the outside of each container for deterioration, discharges, or oil collecting inside the dike.
- Piping (112.8(d)(4)). Regularly inspect aboveground valves, piping and fittings: flange joints, valve glands and bodies, catch pans, supports, valve locks and metal surfaces. Integrity and leak test buried piping whenever it's installed, modified, relocated or replaced.
- Overfill devices. Test liquid-level devices regularly (112.8(c)(8)); at a Tier I site, test whatever system or procedure your plan describes (112.6(a)(3)(iii)).
- Records (112.7(e)). Follow written procedures, and keep a record of each inspection and test, signed by the supervisor or inspector, with the plan for three years. Records kept as part of normal business practice count.
The rule never says "monthly." It says "regular" and "frequent," and the standard you cite fills in the numbers. Once your plan sets a schedule, EPA's inspectors check whether you follow it.
EPA's minimum schedule for small shop-built containers
EPA's Tier I template (Table G-17) gives the minimum for the containers a Tier I site can have, all 5,000 gallons or less:
| Container | Minimum inspection |
|---|---|
| Drums, totes, other portable containers | Visual inspection every month |
| 55 to 1,100 gal with sized containment | Monthly visual, plus annual elements from your inspection standard |
| 1,101 to 5,000 gal with sized containment and leak detection | Monthly visual, plus annual elements from your inspection standard |
| 1,101 to 5,000 gal with sized containment, no leak detection | Monthly visual, annual elements, plus any other integrity tests the standard requires |
EPA's tank inspection page names Steel Tank Institute standard SP001 as one way to meet the testing rule for shop-built tanks, small field-erected tanks and portable containers; API 653 covers large field-erected tanks.
How SP001 sets the bigger tests
SP001 sorts tanks into three categories by size, whether the tank touches the ground, whether it has spill control, and whether it has a continuous release detection method (CRDM). The owner does monthly and annual checklists on every tank; certified inspectors do the formal inspections, at intervals that depend on the tank's size and category. EPA's guidance works an example under the 2011 (5th) edition for 40,000-gallon and 10,000-gallon shop-built tanks, larger than any Tier I container:
Category 1 (the 10,000-gallon tank, with spill control and a CRDM): beyond the owner's periodic checks, a certified inspector does a formal external inspection at most every 20 years; no internal inspection or leak test.
Category 3 (the 40,000-gallon tanks, with neither): a formal external inspection plus an owner's leak test at most every 5 years, and a formal internal inspection every 10 years.
If a tank's build date and last inspection are unknown, EPA's guidance starts the clock at the facility's compliance date (in its example, the date the plan was amended): the first formal inspection within 5 years of it, sooner if a PE judges the risk higher.
EPA's guidance notes that SP001 accepts visual inspection alone for some smaller shop-built containers, such as drums and totes with secondary containment. For your tanks, get the current edition (the 6th, 2018) from STI and look up your tanks' category and size before you write the schedule into your plan. Its table governs, not this example.
Monthly checklist
Built on Table G-17, the rule's piping and security items, and the owner's tank checklist in Appendix F of 40 CFR 112 (reproduced as Table 7-4 of EPA's guidance). Walk each tank, drum area and transfer point:
- Tank and drum shells: drip marks, discoloration, puddles, corrosion, cracks, dents, bulging, and dead vegetation nearby.
- Water in the tank: SP001's monthly check looks for water at the bottom, which feeds corrosion; drain it if found.
- Foundations and supports: cracks, settling, gaps between tank and foundation, root damage, staining.
- Containment: oil or sheen in the dike or spill pallet, cracks or holes in walls and floor, debris taking up room, standing rainwater that needs a supervised, logged release.
- Drain valves: dike drain valve closed and sealed; no flapper valves.
- Piping and fittings: drips at flanges and valve glands, bowing between supports, corroded pipe, catch pans that need emptying.
- Interstitial space (double-walled tanks): monitor or gauge shows no liquid.
- Overfill gauges and alarms: readable and working; vents clear.
- Security: valves and pump starters locked when not in use, idle connections capped, lighting working.
- Spill kit: where the plan says, stocked, sized for the most likely spill.
Yearly checklist
- The annual inspection elements your standard lists for each tank (SP001 has an Annual Inspection Checklist).
- A functional test of each high-level alarm, pump cutoff or other overfill device.
- The discharge prevention briefing for oil-handling staff, logged (see SPCC training).
- The contact list in the plan: names, numbers and the cleanup contractor still current.
- A walk-through against the facility diagram: any new tank, drum area or equipment means a plan amendment within six months.
- Your next formal inspection and five-year plan review dates.
What a record should show
EPA's template log (Table G-16) has six columns: date, the container, piping or equipment checked, the scope (or the industry standard you followed), what you observed, and the inspector's name and signature, plus a box if records are kept elsewhere. Write down what you fixed, too. A log that says "OK" every month for three years while the dike holds oil is the first thing an EPA inspector notices.
ePlan's SPCC draft includes an inspection schedule and log for the containers you list; you set the standard and the dates, and you sign the records.
Questions
How often are SPCC inspections required?
The rule says regularly and frequently; the industry standard in your plan sets the interval. EPA's Tier I template sets a minimum of a monthly visual inspection for drums and small shop-built tanks, plus annual items from the standard.
How long do I keep SPCC inspection records?
Three years, signed, with the plan (112.7(e)). Records kept under usual business practices count.
Do I need a certified inspector?
For monthly visual checks, no: the owner or trained staff do them. Formal inspections under a standard such as SP001 or API 653 are done by inspectors certified under that standard.