SPCC inspection: what the plan requires you to inspect, and who decides how

SPCC stands for Spill Prevention, Control, and Countermeasure. It is a federal rule, codified at 40 CFR part 112, that applies to facilities storing oil above a capacity threshold set in the rule and located where a discharge could reach navigable waters. A facility that falls under it must prepare and follow a written plan. Inspections are part of that plan, and an SPCC inspection usually means one of two things: the facility’s own inspections, or a regulator’s inspection of the facility.

The rule points to industry standards

The SPCC rule does not write its own tank inspection procedure. It requires bulk storage containers to be tested and inspected in accordance with industry standards, and it leaves the facility, and the engineer who certifies its plan, to choose and document the standard. In practice, field erected tanks are commonly inspected to API 653 and shop built tanks to STI SP001. Which category your tanks fall into is the subject of which SP001 category is your tank.

Two layers of inspection

The standards combine routine inspections done by facility personnel, typically visual checks on a short cycle, with formal inspections done by a certified inspector on a longer cycle set by the standard and by the tank’s condition. The plan should state both, who performs them and how they are recorded. A plan that names a standard but no schedule is a plan the facility cannot show it follows.

What an EPA inspector looks at

When a regulator inspects an SPCC facility, the questions are documentary as much as physical: is the plan current and certified, does it match what is on site, are the inspections it promises actually done, and are the records kept. Secondary containment, overfill prevention and drainage practices are looked at on site. A missing inspection record is a finding even if the tank is in good condition.

Records are part of the inspection

The rule requires records of inspections and tests to be kept with the plan for a period it specifies. Records made under the facility’s usual procedures are generally accepted if they contain what the rule needs. The practical point is simple: an inspection that was done but not recorded is, from a compliance point of view, an inspection that was not done.

When the plan has to be reviewed

An SPCC plan is reviewed on a periodic cycle set in the rule, and amended when the facility changes in a way that affects discharge potential, such as adding or replacing a tank. A tank added since the last review is a common gap: it is on site, it holds oil, and nothing in the plan says how it is to be inspected. The inspection planning page covers how to keep a tank list and a schedule aligned.

Who certifies the plan

Most plans are certified by a licensed Professional Engineer. Smaller facilities that meet the rule’s qualified facility criteria may self certify under conditions set in the rule. Either way, the certification covers the plan, not the condition of each tank. A tank’s condition is established by the inspections the plan calls for, done by someone qualified for the standard named, as described on the API 653 inspection page.

Where facilities usually fall short

Not on the big tanks. The usual gaps are small: a day tank for a generator nobody listed, a monthly checklist that stopped being filled in when the person who did it left, a formal inspection that slipped a year because a contractor was not available. Each one is easy to fix before an inspection and awkward to explain during one.

A short annual review against the tank list is enough to catch most of them. Walk the site, compare what you see with what the plan lists, and check that each listed tank has the inspection records the plan promises. It takes a morning, and it is the exercise a regulator will do for you otherwise.