“SPCC inspection” means two different things, and both matter on a production lease. The first is the inspections the SPCC rule requires you to do: regular looks at tanks, containment, drainage, transfer piping and flowlines, done to written procedures and recorded. The second is a visit from an EPA inspector, who walks the site with a federal checklist and reads your records. If the first kind is done and documented, the second is mostly a matter of showing your work.
This page covers onshore oil production facilities under 40 CFR 112.9. If you aren’t sure the rule applies to your lease, start with does my site need secondary containment.
The inspections the SPCC rule requires you to do
Who sets the schedule
EPA says plainly that the SPCC rule “does not prescribe a specific frequency or methodology” for the required inspections of aboveground containers. The certifying PE sets the program in the Plan, using good engineering practice and industry standards (EPA points to the American Petroleum Institute and the Steel Tank Institute). For a self-certified qualified facility, the owner or operator sets it. Either way, the schedule written in your Plan is the schedule you’ll be held to.
How it has to be recorded
Section 112.7(e) is short and does most of the work. You conduct the required inspections “in accordance with written procedures.” You keep “these written procedures and a record of the inspections and tests, signed by the appropriate supervisor or inspector, with the SPCC Plan for a period of three years.” Records “kept under usual and customary business practices will suffice.” A pumper’s route sheet can count, as long as it actually records the required checks and someone signs it.
What has to be inspected on a production lease
Section 112.9 lists the specific inspections for onshore production. EPA’s inspection checklist (Attachment B) asks to see documentation for each one:
| Rule | What gets inspected | What the rule says |
|---|---|---|
| 112.9(b)(1) | Rainwater in diked areas before it’s drained | Inspect and remove oil before draining. Keep records of drainage |
| 112.9(b)(2) | Field drainage: ditches, road ditches, oil traps, sumps, skimmers | Inspect “at regularly scheduled intervals” and promptly remove any oil |
| 112.9(c)(3) | Each oil container, including its foundation and supports | Visual inspection “periodically and upon a regular schedule” for deterioration |
| 112.9(c)(5)(i) | Flow-through process vessels (separators, heater-treaters), if using the alternative to sized containment | Inspect and/or test vessels and components such as dump valves |
| 112.9(c)(6)(ii) | Produced water containers, if using the alternative | Inspect and/or test containers and piping for leaks and corrosion |
| 112.9(d)(1) | Aboveground valves and piping at transfer operations | Flange joints, valve glands and bodies, drip pans, pipe supports, polish rod stuffing boxes, bleeder and gauge valves |
| 112.9(d)(2) | Saltwater disposal facilities | Inspect “often, particularly following a sudden change in atmospheric temperature” |
| 112.9(d)(4)(ii) | Flowlines and intra-facility gathering lines | Visual inspection and/or testing on a regular schedule |
Two of these catch people out. The flow-through vessel and produced-water alternatives only hold while you actually run the inspection program. If a vessel or produced-water container then has a discharge over 1,000 gallons, or more than 42 gallons twice in twelve months, the rule pushes you back to sized containment within six months.
Training goes with it
Section 112.7(f) requires training oil-handling personnel on equipment operation and maintenance, discharge procedures, the applicable rules and the contents of the SPCC Plan. You also need a designated person accountable for discharge prevention, and discharge prevention briefings “at least once a year.” Inspectors ask about all three.
What an EPA inspector looks at
EPA inspectors use a standard form: the SPCC Field Inspection and Plan Review Checklist for onshore oil drilling, production and workover facilities. It runs through the rule section by section and records whether each requirement is met in the Plan and in the field. Knowing what’s on it is the best way to prepare.
The paperwork
Expect the inspector to check that:
- The Plan is certified by a PE, or properly self-certified if the facility is a qualified facility.
- The Plan is on site if the facility is attended at least four hours a day. Otherwise it’s at the nearest field office.
- The Plan was reviewed at least once every five years, and the review is documented.
- Changes that affect discharge potential were written into the Plan within six months.
- The facility diagram shows containers, transfer stations and connecting piping.
- Inspection, drainage and training records are there for the past three years.
- Reportable discharges were handled. The checklist asks about more than 1,000 gallons in one discharge, or more than 42 gallons in each of two discharges within 12 months, reaching navigable water or shorelines.
The field walk
Attachment A of the checklist tells inspectors what to look for. For containers and piping: “drip marks, discoloration of tanks, puddles containing spilled or leaked material, corrosion, cracks, and localized dead vegetation.” For foundations: settling, gaps and cracks. For secondary containment: whether walls and floor will hold oil until cleanup, “proper sizing, cracks, discoloration, presence of spilled or leaked material (standing liquid), erosion, corrosion, penetrations in the containment system, and valve conditions.”
For dikes and berms specifically, inspectors check “level of precipitation in dike/available capacity” and “operational status of drainage valves (closed).” They also look at berm impermeability, debris, erosion and pipes running through the walls. If you rely on active measures like spill kits or mats, they check that the amount in the Plan is actually on site and that the deployment procedure is realistic.
The containment defects that get written up
From the checklist and EPA’s own inspector guidance, these are the problems that show up again and again on production sites:
- Drain valve open or unsealed. Under 112.9(b)(1), dike drains stay closed and sealed except while you drain uncontaminated rainwater.
- Berm full of rain or silt. That capacity is gone. Inspectors compare available capacity with what the Plan claims.
- Salt and oil stains outside the berm. EPA’s guidance tells inspectors that oil stains or “white salt crystal deposits on the outside of berm walls” may mean oil and produced water “flowed through the secondary containment.”
- No drainage records after rain. EPA notes that if a facility never drains its containment, the inspector may ask how rainwater leaves. The worry is that it’s escaping through the walls or floor.
- Liner damage and unsealed penetrations. Pipes cut through the berm or liner without a proper seal.
- Equipment added inside the berm. New tanks or vessels eat containment volume that the Plan’s sizing didn’t account for.
- Oil in the road ditch. Section 112.9(b)(2) puts field drainage on the inspection list for exactly this reason.
A walk-the-pad checklist before anyone else walks it
Run this on each tank battery, and record it with a date and signature:
- Tanks: no weeps, drip marks, corrosion or bulging; foundations level, no gaps
- Separators, heater-treaters, gun barrels: dump valves and fittings dry
- Containment: walls intact; liner uncut; no standing oil; capacity not eaten by rain, silt or new equipment
- Drain valve closed and sealed; drainage log current
- Penetrations through walls sealed
- Load-out: hose connection over containment; drip pans emptied; caps on
- Valves, flanges, bleeders, gauge valves and the polish rod stuffing box dry
- Flowlines: supports sound, no stains or dead vegetation along the route
- Ditches, sumps and oil traps checked; any oil removed
- Ground outside the berm: no stained soil, salt crust or dead vegetation
- Spill kit and mats on site in the amounts the Plan lists
Fix what you find and write down that you fixed it. A record of a defect that was found and repaired shows an inspection program working. A berm with a defect and no record shows one that isn’t.
Getting containment ready for inspection
Site Safe Solutions designs and installs containment systems on Permian leases, including primary pads, high-wall systems and HDPE liners, and handles equipment cleaning for oily equipment and mats. We don’t write or certify SPCC Plans. That’s your PE’s job. Where an inspection turns up a liner that’s past it, a berm that’s too small or containment that needs rebuilding, send us the site details and we’ll scope the fix.
