SPCC inspection checklist: building one that matches your plan and survives an audit

An SPCC plan is the document a facility prepares under the federal oil pollution prevention rule, 40 CFR part 112, when it stores oil above the thresholds that rule sets. The plan describes how spills are prevented and contained, and it commits the facility to inspections. The checklist is how those inspections are done and recorded. When an inspector from the agency visits, the first comparison is between what the plan says will be inspected and what the records show was inspected.

Start from the plan, not from a template

The rule requires inspections and tests in accordance with written procedures, and the plan is where those procedures live. A checklist copied from a template can list items the facility does not have, and miss items it does: a loading rack, a buried line, an oil filled transformer, a drum storage area. The useful exercise is to read the plan, list every container, every piece of secondary containment and every transfer area it names, and build the checklist from that list. The plan itself is covered in what the SPCC plan requires.

The containers

For each tank or container: signs of leakage at seams, fittings and the bottom; corrosion, blistering or coating failure on the shell; the condition of the supports and the foundation, including settlement and gaps; the legibility of the identification; and the condition of the vents. The question is not whether the tank looks old. It is whether anything has changed since the last check, which is why the previous sheet should be at hand.

Secondary containment

Dikes, berms, double walls and containment pallets are inspected as carefully as the tanks. Cracks or gaps in the walls, penetrations that were never sealed, accumulated water or oil inside, and the position of the drain valve. Drainage of rainwater from a dike is one of the items auditors read closely: the plan should say how the water is checked before release and who records it, and the checklist should have the line for it.

Piping, valves and transfer areas

Aboveground piping and valves are checked for leaks, corrosion and damaged supports. Transfer areas, where trucks load or unload, are checked for staining, for the condition of the containment and for spill kits that are actually stocked. Overfill alarms, high level shutoffs and gauges belong on the list where the plan relies on them, with a line for the date they were last tested.

Monthly checks and the formal inspection

Two layers usually coexist. The routine checks done by the facility’s own people, often monthly and annual, and the periodic formal inspection of the tanks by a qualified inspector under an industry standard. For shop built tanks the standard most often cited is STI SP001, which includes owner checklists of its own, explained in which SP001 category your tank falls in. For field erected tanks it is usually API 653. The checklist covers the first layer; it does not replace the second.

What makes a record usable

A date, the name of the person who did the check, a clear status for each item, a note for anything found, and a record of what was done about it. A checklist with every box ticked for three years and no finding ever noted reads as a form filled from memory. A finding with a follow up line reads as a program that works. Keep the records for as long as the rule requires, in a place the plan names.

Keeping the checklist current

When a tank is added, removed or changed in service, the plan is reviewed and the checklist with it. Planning the formal inspections across several tanks, so that their due dates are known in advance, is the subject of inspection planning. The checklist and the plan should never disagree. When they do, the record that was filled in is usually the one that wins the argument, and not in the facility’s favor.