SPCC Oil Spill Prevention Control and Countermeasure Plan Compliance Checklist

Facilities storing oil in aboveground containers with a combined capacity above 1,320 gallons (or in underground containers above 42,000 gallons), with a reasonable expectation of discharge to navigable waters, must prepare and implement a Spill Prevention, Control, and Countermeasure (SPCC) Plan under EPA 40 CFR Part 112.3 before commencing operations. The Plan must be certified by a licensed Professional Engineer unless the facility qualifies for the self-certification tier under 40 CFR 112.6.

  • Industry: Waste Management
  • Frequency: Monthly Inspection / Annual Review
  • Estimated Time: 45-60 minutes
  • Role: Environmental Compliance Manager
  • Total Items: 19

SPCC Plan Currency and Professional Engineer Certification (40 CFR 112.3 / 112.5)

Verify the SPCC Plan is prepared, signed, and certified, addresses all oil storage containers and transfer operations at the facility, and has been reviewed and updated within the required 5-year interval. An outdated or PE-uncertified Plan is itself a 40 CFR Part 112 violation.

  • Is the SPCC Plan fully prepared, signed and certified by a licensed Professional Engineer (or self-certified where the facility meets all Tier I or Tier II qualified facility criteria), and physically available at the facility?
  • Has the SPCC Plan been reviewed and evaluated by a PE (or qualified self-certifier) within the most recent 5-year calendar year, with the review documented in the Plan?
  • Has the SPCC Plan been amended within 6 months of any change in facility design, construction, operation, or maintenance that materially affects the potential for discharge or the applicable prevention measures?
  • Does the Plan accurately identify all oil storage containers (above 55 gallons) at the facility, their capacities, their types of oil, and their location on the facility site map?

Bulk Storage Tank Inspections and Integrity Testing (40 CFR 112.8(c))

Verify that aboveground bulk storage tanks are inspected per 40 CFR 112.8(c) at the required frequencies and that integrity testing results are on file. EPA references API Standard 653 (Tank Inspection, Repair, Alteration, and Reconstruction) as the applicable standard for bulk storage tank inspection.

  • Are aboveground storage tanks inspected for deterioration and compliance with 40 CFR 112 by a qualified inspector at regular intervals per industry standards (API 653 for steel tanks), with inspection records on file?
  • Have all bulk storage tanks been integrity tested at regular intervals per industry standards (acoustic emission testing, ultrasonic thickness measurement, or hydrostatic testing), and are integrity test records on file?
  • Are all aboveground tanks equipped with high-level alarms or other mechanical, electrical, or visual indicators that alert operators to impending overfill before the tank reaches its maximum designed capacity?
  • Do tanks and piping show no visible evidence of oil leaks, staining, corrosion, structural deformation, or deterioration of coating systems, and are found defects corrected and documented?

Secondary Containment Design and Integrity (40 CFR 112.7(c) / 112.8(c)(2))

Inspect secondary containment structures per 40 CFR 112.7(c), which requires containment or diversion structures sufficient to hold the contents of the largest single tank plus sufficient freeboard for precipitation. Secondary containment is the most commonly deficient element in EPA SPCC inspections.

  • Is secondary containment provided for all bulk storage tanks, with capacity sufficient to contain the contents of the largest single container within the containment area (110% of the largest tank capacity per EPA guidance)?
  • Are secondary containment walls, berms, and floors free of cracks, erosion, penetrations, and deterioration that would allow spilled oil to escape the containment area before cleanup?
  • Is accumulated rainwater in the containment area managed through a manually operated valve, oil-water separator, or equivalent control to ensure oil is not inadvertently discharged with released stormwater?
  • Are transfer operations (filling, offloading, internal transfer) conducted with containment for the transfer connection, and is an operator physically present during all transfers to observe for spills?

Inspection, Testing, and Maintenance Records (40 CFR 112.7(e))

Verify that inspection, testing, and maintenance records are complete, signed, dated, and retained for a minimum of 3 years per 40 CFR 112.7(e). Incomplete records are evidence that the SPCC Plan is not being implemented and constitute an independent 40 CFR 112 violation.

  • Are records of all inspections and tests required by 40 CFR Part 112 signed, dated, and retained for at least 3 years, with records accessible to EPA inspectors on demand?
  • Does the facility conduct and document the inspection items required by 40 CFR 112.7(e), including: tank and secondary containment inspections, discharge detection equipment tests, and transfer operation inspections?

Personnel Training and Spill Response (40 CFR 112.7(f)-(g))

Verify that all oil-handling personnel have been trained in the SPCC Plan procedures, spill prevention measures, and emergency response requirements per 40 CFR 112.7(f). The SPCC Plan must designate a person responsible for oil spill prevention and response.

  • Has the owner/operator designated a single accountable person (by name or title) as responsible for oil spill prevention who is familiar with the SPCC Plan and present at the facility or reachable by phone at all times when oil transfer operations are conducted?
  • Are all personnel who handle, transfer, or manage oil operations trained in the SPCC Plan procedures (including secondary containment operation, reporting requirements, and spill response) at the time of assignment and annually thereafter, with training records retained?
  • Are spill response materials (absorbents, containment booms, drain covers, or equivalent) staged at or near all storage tanks and transfer areas, and is their condition and quantity adequate for the largest credible spill scenario?

Security and Facility Access Controls (40 CFR 112.7(g))

Inspect facility security measures per 40 CFR 112.7(g). EPA requires facilities to prevent unauthorized access to storage areas, oil handling areas, and controls that could cause a discharge. Security requirements apply to both the physical structures and the valve and pump operating controls.

  • Are all oil storage and oil handling areas secured against unauthorized access by fencing, locked gates, locked valve handles, or equivalent physical security measures?
  • Are all vehicles, equipment, and mobile containers present on the facility grounds authorized and accounted for in the SPCC Plan or facility records, with visitor access logged when oil handling areas are accessed?

Related Waste Management Checklists

Related Hazardous Waste Checklists

Why Use This SPCC Oil Spill Prevention Control and Countermeasure Plan Compliance Checklist?

This spcc oil spill prevention control and countermeasure plan compliance checklist helps waste management teams maintain compliance and operational excellence. Designed for environmental compliance manager professionals, this checklist covers 19 critical inspection points across 6 sections. Recommended frequency: monthly inspection / annual review.

Frequently Asked Questions

What does the SPCC Oil Spill Prevention Control and Countermeasure Plan Compliance Checklist cover?

This checklist covers 19 inspection items across 6 sections: SPCC Plan Currency and Professional Engineer Certification (40 CFR 112.3 / 112.5), Bulk Storage Tank Inspections and Integrity Testing (40 CFR 112.8(c)), Secondary Containment Design and Integrity (40 CFR 112.7(c) / 112.8(c)(2)), Inspection, Testing, and Maintenance Records (40 CFR 112.7(e)), Personnel Training and Spill Response (40 CFR 112.7(f)-(g)), Security and Facility Access Controls (40 CFR 112.7(g)). It is designed for waste management operations and compliance.

How often should this checklist be completed?

This checklist should be completed monthly inspection / annual review. Each completion takes approximately 45-60 minutes.

Who should use this SPCC Oil Spill Prevention Control and Countermeasure Plan Compliance Checklist?

This checklist is designed for Environmental Compliance Manager professionals in the waste management industry. It can be used for self-assessments, team audits, and regulatory compliance documentation.

Can I download this checklist as a PDF?

Yes, this checklist is available as a free PDF download. You can also use it digitally in the POPProbe mobile app for real-time data capture, photo documentation, and automatic reporting.

Browse More Checklists

POPProbe