Spill prevention is a fundamental responsibility for any facility that stores, handles, or transfers oil and hazardous substances. The EPA's Spill Prevention, Control, and Countermeasure (SPCC) rule requires facilities with aboveground oil storage capacity exceeding 1,320 gallons (or underground storage exceeding 42,000 gallons) to develop and implement SPCC plans that include regular inspections of storage equipment and containment systems. This checklist provides a thorough framework for conducting spill prevention inspections that satisfy regulatory requirements and protect the environment from damaging releases.
Why Spill Prevention Inspections Matter
Oil and chemical spills can cause devastating environmental damage to soil, groundwater, surface water, and ecosystems. Under the Clean Water Act and CERCLA, responsible parties face cleanup costs that routinely reach millions of dollars, plus civil penalties and natural resource damage assessments. The SPCC rule specifically requires regular inspections and testing of containment and diversion structures, and facilities that fail to conduct these inspections face enforcement action regardless of whether a spill has occurred. Regular inspections catch equipment deterioration, containment failures, and procedural gaps before they result in a release, saving organizations from the financial, environmental, and reputational consequences of a spill event.
Spill Prevention & Containment Inspection Checklist
1. SPCC Plan Review and Administrative Requirements
The SPCC plan is a living document that must accurately reflect current facility conditions, storage configurations, and operating procedures. An inspection should verify that the plan is current and that administrative requirements are being met.
- Verify the SPCC plan has been reviewed and certified by a Professional Engineer (PE) as required, and that the most recent amendment date is within five years
- Confirm the plan accurately reflects current tank configurations, capacities, and contents
- Check that the plan includes current facility diagrams showing all oil storage containers, transfer stations, and drainage pathways
- Verify that all spill event records, including any reportable discharges, have been documented and the plan amended accordingly
- Confirm that the facility has designated an SPCC coordinator who understands their responsibilities
2. Aboveground Storage Tank Integrity
Aboveground storage tanks (ASTs) are subject to corrosion, mechanical damage, and structural degradation over time. Regular integrity inspections identify problems before they progress to tank failure and uncontrolled releases.
- Conduct visual inspections of all AST shells, roofs, and foundations for signs of corrosion, distortion, leaks, or structural damage
- Check tank fittings, valves, gaskets, and piping connections for leaks, corrosion, and proper operation
- Verify that tank level gauging equipment, overfill alarms, and automatic shutoff devices are functional and calibrated
- Review tank inspection records to confirm that formal integrity assessments (API 653 or STI SP001) are performed on schedule
- Inspect tank vents and pressure/vacuum relief devices for obstructions and proper operation
3. Secondary Containment Systems
Secondary containment is the last line of defense against oil reaching navigable waters. Containment systems must have sufficient capacity, structural integrity, and impermeability to capture the contents of the largest tank plus precipitation.
- Verify that all regulated containers have secondary containment sized to hold the volume of the largest tank plus sufficient freeboard for precipitation
- Inspect containment walls, berms, and floors for cracks, deterioration, erosion, or evidence of leakage
- Check that containment drain valves are in the closed and locked position and that accumulated stormwater is properly managed before draining
- Test containment liner integrity if synthetic liners are used, and verify that concrete or earthen containment has not developed seepage pathways
- Remove accumulated debris, vegetation, and stored materials from within containment areas that could compromise capacity
4. Transfer Operations and Piping Systems
Oil transfer operations, including loading, unloading, and inter-tank transfers, represent periods of elevated spill risk. Piping systems must be maintained to prevent leaks, and transfer procedures must include spill prevention safeguards.
- Inspect all oil transfer piping, hoses, and connections for leaks, corrosion, mechanical damage, and proper support
- Verify that transfer operations are conducted under the supervision of trained personnel and that communication protocols are followed
- Check that loading and unloading areas have adequate containment, including drip pans, catch basins, or curbed pads
- Confirm that emergency shutdown procedures and equipment are in place and functional at all transfer points
- Inspect buried piping for cathodic protection functionality and review leak detection monitoring records
5. Spill Response Equipment and Preparedness
Despite the best prevention efforts, spill response readiness is essential. Having the right equipment immediately available and personnel trained to use it can mean the difference between a minor cleanup and a major environmental incident.
- Inventory all spill response equipment including absorbent materials, booms, overpack drums, drain covers, and personal protective equipment
- Verify that spill kits are fully stocked, clearly marked, and strategically positioned near storage tanks, transfer areas, and high-risk locations
- Confirm that emergency contact information (National Response Center, state agencies, cleanup contractors) is posted prominently and included in the SPCC plan
- Check that facility personnel know the location of spill response equipment and understand initial response procedures
6. Training and Drills
SPCC regulations require that facility personnel involved in oil handling operations receive spill prevention and response training. Regular drills test the effectiveness of response procedures and identify areas for improvement.
- Verify that all oil-handling personnel have completed initial SPCC training and annual refresher training
- Review training records for completeness, including attendee names, dates, topics covered, and trainer qualifications
- Confirm that spill response drills are conducted at least annually and that drill results are documented
- Assess whether after-action reviews from drills and actual spill events have been used to update procedures and training
7. Stormwater and Drainage Controls
Facility drainage systems can become pathways for oil to reach navigable waters if not properly managed. SPCC plans must address how stormwater is managed in tank areas and how drainage controls prevent oil discharges.
- Inspect drainage ditches, culverts, and outfall structures for accumulated oil, sheen, or blockages
- Verify that oil-water separators are functioning properly and are maintained on a regular service schedule
- Check that diversion structures (booms, berms, valves) can be deployed quickly to prevent oil from reaching drainage pathways
- Confirm that facility drainage maps in the SPCC plan accurately show flow paths, discharge points, and proximity to navigable waters
- Test retention pond or basin capacity and verify that oil skimming or recovery systems are operational
Best Practices for Spill Prevention Inspections
- Conduct routine visual inspections of oil storage areas monthly at a minimum, with more frequent checks for high-risk areas
- Perform formal SPCC inspections annually with comprehensive documentation that demonstrates regulatory compliance
- Address identified deficiencies promptly and track corrective actions to completion with target dates and responsible parties
- Test overfill prevention equipment and level alarms regularly to verify they function when needed most
- Integrate spill prevention inspections with other facility inspection programs to improve efficiency and consistency
- Maintain photographic documentation of inspections to provide visual evidence of equipment and containment conditions over time
How Checksheets Helps
Checksheets transforms spill prevention inspections from paper-based checklists into a streamlined digital process. Inspectors can complete detailed inspections on any mobile device, capture photographic evidence of tank conditions and containment integrity, and flag deficiencies for immediate corrective action. The platform maintains a complete, searchable history of all inspections, making it easy to demonstrate compliance during regulatory audits and track equipment condition trends over time.
Spill prevention is a responsibility that demands consistent vigilance and thorough documentation. By using a structured inspection checklist with Checksheets, your facility can maintain the rigorous inspection program that SPCC regulations require, catch potential problems before they become environmental incidents, and protect both your organization and the surrounding environment from the consequences of uncontrolled oil releases.