SPCC Basics - Required Recordkeeping

SPCC plans are one of the most common - and most misunderstood - regulatory requirements in the bulk fuel industry. While the plan itself may seem straightforward, proving compliance is where things get complicated. 

In this episode, we kick off a new SPCC Basics series by breaking down one of the biggest pain points for facility operators: recordkeeping. From routine inspections to “as-needed” documentation, understanding what needs to be recorded - and when - is critical to staying compliant. 

We walk through how recordkeeping is typically structured by frequency (daily, monthly, annual), where facilities commonly miss the mark, and why simply having a checklist isn’t always enough. We also cover the often-overlooked records that don’t fall neatly into a form but are still expected during an audit. 

If you’re responsible for implementing an SPCC plan, this episode will help you better understand your role, reduce uncertainty, and avoid getting caught off guard when it’s time to prove compliance. 

🎧 Tune in as we break down the essentials and set the foundation for the rest of the SPCC Basics series. 

Shield Training

Transcript

Welcome And SPCC Plan Overview

Haley Hall 0:09

Welcome to Kate's Talk with Integrity Environmental. Join us as we sit down with founder, principal consultant, and bulk fuel storage expert Kenneth Olbers to explore regulations, safety, and essential tips for navigating the bulk fuel storage industry. Join us as we explore the unique joys of work and life in Alaska with industry experts, including our team, vendors we work with, and the companies we support.

SPEAKER_03 0:36

The most common plan type that we write at integrity is the spill prevention, control, and countermeasures plan, commonly referred to as the SPCC plan.

SPEAKER_01 0:46

Yep. It's popular for a reason, Haley. It has the smallest threshold of 1,320 gallons of total oil storage. Most industrial facilities qualify for this plan.

SPEAKER_03 0:58

Well, that makes sense why it is the source of so many of our questions. What would you think about a series on the SPCC specifically going over some of the essentials of that plan?

SPEAKER_01 1:09

Hmm, you know, I think that would be a good idea, Haley, because so many plans, they're written by a third party, and then operators are asked to read and implement the plan kind of in a vacuum. It would be good to go over some of the essential requirements for compliance so that if you, dear listener, are responsible for implementing and operating under an SPCC, you've got a good clear picture of what your role and your responsibilities are.

SPEAKER_03 1:32

Great.

SPEAKER_01 1:32

So where do you think we should start?

Why Record Keeping Trips People Up

SPEAKER_01 1:35

You know, let's start with record keeping, Haley, because that is definitely the number one source of confusion about implementing an SPCC plan.

SPEAKER_03 1:43

Wow. Imagine that. Confusion surrounding implementing an environmental plan or permit.

SPEAKER_01 1:49

I know, right? It does seem to be the recurring theme of this podcast, but hey, we wouldn't have jobs, Haley, if it was easy and straightforward. Everybody could just do it.

SPEAKER_03 1:58

So, Shaden, why start with record keeping? Can't you just make a checklist? That is the hundred dollar question right there.

SPEAKER_01 2:06

I want to start with record keeping because I think it's the biggest source of anxiety for most facility managers. There is record keeping that's easy to capture in a checklist, right? It happens on a routine basis. Everyone's familiar with your daily, monthly, annual forms. But there is also record keeping that happens on an as-needed basis. And that complicates things because some records just aren't required until they are required, which means you have to remember to do them and all the special circumstances triggering that record keeping.

SPEAKER_03 2:38

So I do have a list from our master record keeping list for our shield recording clients. List, list. Do you want to go through each type of record?

SPEAKER_01 2:48

Yes, I do. But for the purposes of this podcast, let's go through them by the frequency of completion. That's how the facility manager is thinking about performing them. So I think that would be most helpful to our listeners. Okay, great. Well, let's

Daily Logs And Routine Inspections

SPEAKER_01 3:03

just start with daily. Yeah. So for daily records, and it gets tricky right off the bat, 40 CFR 112, which is the regulation behind the SPCC plan, it only specifies that facility inspections have to occur on a routine basis. So routine facility inspections can fall under the daily category. And many companies choose to do it daily during operational days, but others do it monthly or even less frequently, like quarterly. And sometimes routine inspections only occur when a facility is occupied because they have some unmanned facility provisions. So you'll need to check your SPCC to see what it says for routine record keeping. And it's entirely possible that you do not have a daily record, but most people do. Also, under the daily category, there are secondary containment area drainage logs. Again, these can be combined with an existing daily or monthly record, but you will need to document when containment discharges occur and make sure that that secondary containment area drainage event is being recorded. And typically that includes a duration, a volume, and verifying that no sheen was observed. So for many of you, this may be daily. For some of you, this might be monthly. And for most of you, it'll be somewhere in the middle where you're not recording an SCA drainage event every day, but you do need to record it several times a week.

SPEAKER_03 4:22

Wow. So what needs to be done specifically for monthly?

SPEAKER_01 4:26

Ha. Facility inspections pops right back up again. Check your SPCC carefully because here some companies require dailies and monthlies, and there's different inspection items on each. So don't just assume that because you have a daily, you don't have a monthly. And then under the monthly banner, we also have tank and portable container inspections. So for tanks, both the Steel Tank Institute and the American Petroleum Institute, STI and API, they have monthly inspection components for tanks. And I want to make sure that if these are combined with your monthlies, that every checklist item from those STI and API monthly checklists are addressed. Some of our older SPCC plans have more general checklist entries, like one line that says tank condition, and you're supposed to put good or adequate or satisfactory, or they have is tank leaking? Yes or no. One-line entries like that will not meet the STI, SP001 or API 653 inspection standards. It's a common disconnect. It's kind of what people did in the 90s and early 2000s. But now, since the standards have changed so much, I mean STI I think has 17 checklist items for the monthly, and API has over 15. I don't, I don't actually know the exact number of that. So just pro tip if you've got a facility inspection that's daily or monthly and it only has one entry for your tank, you probably need to get it updated and have it be more robust. So STI also requires monthly inspections for portable containers. Make sure you are doing these. It's the most overlooked form requirement. And if you haven't listened to our podcast much, portable containers are drums and isotopes and sort of things that can be moved around but are bigger than 55 gallons. We have other podcast episodes. We've interviewed the engineers from the Steel Tank Institute, and we talk about how portable container inspections are performed in greater detail. So if you want to know more, go find that episode. Another monthly consideration is valves, piping, and appurtenances, Haley. Many of these facilities will have a basic monthly check of valves, piping, and appurtenances for gross damage, leaks, or weeps, et cetera. Again, the SPCC regulations just say regular inspections must occur. So pay attention to what your SPCC says here. But I would say the vast majority of facilities that we work with have some version of monthly check for your valves, your piping, and your appurtenances. And then in 40 CFR 112, there's this funny little clause that requires plan holders to keep a liquid level sensing device testing log, which is a heck of a mouthful. I know the liquid level sensing device testing log can be as simple as verifying your hand gauging matches your tank gauge. If you don't have a gauge on your tank, if all you're doing is manual, you do not have to keep this log, but you will need a hand gauging inventory log in its place. So if you do have a gauge, you got to test it for accuracy, basically. And again, 40 CFR 112 doesn't specify the frequency of this, but most facilities perform this log monthly because you're already doing this at the end of month inventory check. You're already gauging the tank, anyways. You might as well rectify that liquid level sensing device if you're already there taking a hand measurement for inventory. And then if your facility has cathodic protection and it's a specific kind of cathodic protection called an impressed current or hybrid or combined impressed current anodic system, you will have a piece of equipment at your facility called a rectifier. And that rectifier will have voltage and amperage readings on it. If your system is fully enodic, though, there's no rectifier, you won't have anything to log, just a big orange plastic pole called a big think.

SPEAKER_03 8:14

I'm sorry. Did you say it's a pole called a big think?

SPEAKER_01 8:17

Yeah, yeah, a big think. F-I-N-K. It's an odd name, Haley. I think it's from the original manufacturer of these poles in like the 1970s. I do not know the story about why it's called the Big Fink, but it is what it is. If any of our listeners know, let me know. I would love to hear the story of that. But if you have a big orange pole, you probably don't have a rectifier, although there are some systems that have both, just as an FYI. If you do have a rectifier, though, in this weird quirk, NACE SP0169 requires you to log rectifier readings every 60 days. And that's weird. So most facilities log it monthly just to make sure it gets done. So if you have a rectifier, you need to track the volt and amp reading on it every 60 days. But again, we recommend doing it monthly so you don't forget one month. And if you track this kind of data, we recommend tracking it on its own form so you can compare reading trends over time. All rectifier systems become less effective over time. And so if your reading is buried in a monthly form, you may not see that downward trend as easily as when it's on its own, in its own form. And that is hard experience there. So pro tip from integrity: if you've got a rectifier, log it in on its own form. And then you can see if it's failing much more easily.

SPEAKER_03 9:36

Wow.

Annual Inspections And Required Training

SPEAKER_03 9:37

Well, now we jump up to annual records.

SPEAKER_01 9:40

Happy New Year! Just kidding. I do think, since we are based in Alaska, that annual inspections should be done in the summer when everything is not covered in snow and ice and you're not on top of a tank freezing your nose, hairs, trying to inspect all the pieces, parts of your facility. But you can choose to do it anytime you'd like, as long as it's done around the same time each year. So, for annual inspections, we've got tanks. STI and API both have annual inspection requirements. And pay attention here because the annual inspections have different things to be looking at than the monthly inspections. You normally cannot just do another monthly. Again, I want to caution you to dig deeper if your inspection forms are very vague or broad. Both API and STI, like I mentioned before, have beefed up their annual inspection requirements in the last couple of years. And your inspection form, if it's older, it may not meet the standards anymore. So if you've got one-liners under annual that says tank condition good, that's not going to cut it either. Pipes, valves, and appurtenances typically also get an annual inspection. The SPCC 40 CFR 112 has some very specific requirements for this inspection. They require you to assess the general condition of flange joints, expansion joints, valve glands, and bodies, catch pans, pipeline supports, locking of valves, and all metal surfaces. So, like I mentioned before, many of you have like a monthly component that's sort of is the pipe good? Is the pipe leaking? Your annual inspection should have all of those things listed out on it. It should say general condition of flange joints, good, bad. Condition of expansion joints, good, bad. Condition of valve glands and bodies. And the reason is it's very specific regulatory language, and we know that's what the inspectors are looking for. So know that even if you have a daily or monthly check on your valves and piping, there's probably a more in-depth one that's an annual that is designed to meet this requirement of 40 CFR 112. Also under the SPCC, there's something called an annual discharge prevention training. And managers are required to give that to their staff that could respond to a spill. And pro tip, you also have to give this training upon hire. So if somebody's a new hire, they need to also have this discharge prevention training before they can respond to spills. And this should be given to all staff who could cause, stop, or respond to a spill at your facility. And this will vary in size and scope depending on if you also have a facility response plan at your facility. Read your SPCC and see what's required. If you're running a U.S. Coast Guard prep program, you can use those prep events to meet this requirement, but you have to keep records of it and be able to show it in case an inspector's asking for it. And then for annual, I've got two more things here, Haley. Oil water separators are part of some facilities' annual inspections. And let me digress because oil water separators are a little tricky. And we do have a podcast episode specifically about oil water separators that goes over this in more depth. But if you use an oil water separator as part of your secondary containment system, the EPA clarified in their 2013 guidance for regional inspectors that you have to document the maintenance and inspection of your oil water separator. So that part's pretty clear, but there aren't any hard and fast rules from the EPA other than it has to be done and written down and documented. Our firm has had experience with EPA compliance. We know that the EPA expects the oil water separator to be empty of excess oil. The water charge is okay, but if you crack it open and there's oil in there, that's going to be a violation. And then the EPA wants to see that your inspection is verifying that it's free of excess oil. The EPA also expects that all baffles and compartments are inspected and verified to be working and that all your inlet and outlet valves are in good working order. So we recommend performing an oil water separator inspection annually for two reasons. Because again, it doesn't say when, but we we say at least annually. And the first is that it's really smart to open up your oil water separator each year and just prove that it's empty, spill ready, and everything is functioning. Related to that, Haley, I have opened so many oil water separators over the years that were full of oil, insects, which was super gross, sand, ice. I've opened a bunch that have had broken baffles, busted valves, you name it. And when it happens, it's always a surprise to the crew, too, because oil water separators are really easy to overlook and forget about. They're typically buried. They typically work for a long time, even if you don't do anything to them. So it's smart to open them up each year just to show it's empty and then potentially do maintenance so it doesn't turn into some big disgusting tenure problem. I also think it's easier to remember to do an oil water separator inspection annually than it is to do it like, let's say, every five years. We have had clients that want to push it out to five. You can do that as long as it's written into your SPCC, but it's hard to remember to do it unless you've got a cadence to it. And then my last note on this is if you have an oil water separator that is frequently used for receiving oils, like you've got a real busy maintenance bay, you may decide to check your oil water separator more frequently, like quarterly, because it's gonna have oil in it, right? So if your oil water separator system is receiving a lot more oil, up the frequency. And just check your SPCC to see what your plan writer has determined for your oil water separator. And then for those of you thinking, ha, my oil water separator isn't used for my secondary containment, I am home free on this. It is exempt and outside of your SPCC, but it still needs annual inspection and maintenance. So don't leave your poor exempt oil water separator out in the cold all alone. Show it some love too. Oil water separators are important. Lastly, under the annual, the C your cathodic protection system needs to be inspected annually by a third party. It's part of the NACE SP0169 standard. This one gets overlooked a lot by our non-gas station clients. All gas stations know about and expect an annual CP test, but if you don't run a gas station, this is sometimes off your radar. Wow.

Shield Record Keeping System Pitch

Commercial 15:48

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SPEAKER_03 17:11

So,

As Needed Records And Spill Logs

SPEAKER_03 17:12

Shannon, earlier you mentioned as needed forms. Can you tell me more about what that means?

SPEAKER_01 17:19

Yeah, so this is the end of our easily checklistable items. And now we're starting to get into the complicated area of You'll need it when you need it. So there is a list of records that must occur as certain things happen, but they're not necessarily consistent. They don't happen all the time. And then I also want to point out that you do need to read your SPCC. It's really important because companies may have their own forms and requirements that are outside of the SPCC regulation. But if it's written into your SPCC, you are still responsible for them. Did you hear me use my mom voice, Maile?

SPEAKER_03 17:58

So what are some specific examples of these as needed forms?

SPEAKER_01 18:03

The most common one is like uh third-party inspections required under STI and API. So think of the 20-year formal external inspection for under STI or the five-year external under API 653, and then the 10 or 20-year internal inspection. So these are you're hiring a contractor to come to your facility and perform these inspections on your tanks. And then another example of this is the EPA spill log. It is a form that's required by the EPA for a single discharge exceeding 1,000 U.S. gallons or two discharges, each exceeding 42 U.S. gallons within any 12-month period. Because the EPA loves making things easy, right? And for those of you sweating a little right now, because you're thinking, oh no, I have had some discharges that maybe fit that criteria, and I did not fill out my EPA spillog. I do want to note that those discharges are defined as released to the environment. So anything to secondary containment or collected in an impermeable, like it hit asphalt, but you were able to pick it up, those maybe don't count. You can find the very complex definition in 40 CFR 112 of what is considered a release to the environment. But what I do know is that when you have a spill and it's significant in size, over a thousand US gallons, or you're kind of over that 42, which you know is a harder number to remember, but a lot of times during the frenzy of the spill and the aftermath of dealing with it and getting it all cleaned up, this EPA spill log gets overlooked. So this is when an annual or six-month review of your SPCC can help because you're gonna be like, oh, did I have any spills this year? I did. Let me write it down in my spill log. What a lot of people do is they'll write down every spill in the spill log, even if it was to containment, just to make sure that they are reporting, like putting everything in the same place, I guess. But it is important to note that the spill log only has to be filled out for things that are released to the environment.

SPEAKER_03 20:00

Oof, well, that's a whole lot. And I do feel a little crazy for asking this and a little nervous. But are there any other record keeping considerations that we should know about? Well,

Retention Rules And Hidden Documentation

SPEAKER_03 20:13

you are not crazy because yes, there is more, Haley.

SPEAKER_01 20:17

Uh so checklist items aside, there are a lot of things that you need to document as you operate and implement your SPCC plan that is record keeping, but it doesn't fall within a form you need to fill out so much. So I want to talk about these items to make sure that you understand, dear listener, that they need to happen, but they can vary pretty widely in how they're accomplished. So keep in mind, we've been through dozens of EPA audits here at Integrity. And these are the records that the EPA asks for to show compliance with the SPCC, the prove that you did it proof, right? But again, they don't necessarily fall within that standardized list of forms. So, first off, under the regulation, you need to retain routine records at least three years. But we recommend keeping them for five. And the reason for that is because when you renew your SPCC, the renewal contractor or PE is going to need some of those records to complete the renewal. The caveat to that is that third-party inspections for tanks, piping, and cathodic protection, those need to be kept for the life of the tank or component. The life. This goes for any construction or improvement documents, too. These are very important. Do not lose them. Don't leave them in your email as an unread message. Download and upload them to your files and save them. They are critical for so many things in the future. All right, getting off my soapbox. Another hard to remember one is that the SPCC requires all maintenance and operation actions related to the SPCC covered infrastructure to be documented. So this is things like filter changes, sump cleanouts, coding applications, liner repairs, all that falls under the MO banner. Some people document those in their dailies or monthly when they occur. Some have like an MO software. That kind of tracks all the maintenance and operation requests. But a whole lot of people, this stuff is silent. It just happens. You can see that the filter got changed within the last year, but they're not documenting it anywhere. There's also some employee records that are critical to document. So again, it is record keeping, but it is not on the checklist. So, like I mentioned before, the annual spill response training has to occur. The HasWhopper, a copy of their initial and eight-hour refresher. Some places require 24-hour HasWhopper initials, some require 40. And then that eight-hour annual refresher needs to be kept. And then this is another one that trips people up. On-the-job training for fuel transfers, for things like truck rack loading or tank transfers or barge offloading, all of those need to be documented too. The easiest way to do this is to take your transfer procedures, print a page off, and then have the supervisor and the trainee sign off on each individual line item of that transfer procedure, and then have the supervisor at the bottom write a statement that says, I verify that trainee John has learned and is able to be independent on all of these tasks due to on-the-job training. And then he signs it on the bottom, and then Bob signs it on the bottom. So it doesn't have to be super complicated, but it does have to be written down. And if you're out there saying, But Shannon, those transfer procedures in my SPCC are bunk. They're not even anything like what we do, then you need to get your SPCC updated. Get it updated so that that matches. That's important.

SPEAKER_03 23:35

So

SPCC Amendments And Five Year Review

SPEAKER_03 23:36

what about the SPCC itself? Isn't it a record on its own, right?

SPEAKER_01 23:41

Yeah, yeah, it is. And there are requirements for it to be updated. So the first, let me just review what they are and then I'll go just a little bit more in depth. Again, we have other podcast episodes on this, so I won't go too deep into it. But there is a six-month amendment rule. If anything changes at your plant or your facility, it needs to occur within six months of determining that that amendment needs to be made. And those amendments fall into two categories, non-technical and technical. And just as a reminder, non-technical amendments do not require a PE stamp. Examples of these are like changes to personnel names or contact information. Technical amendments require review and approval from a PE, professional engineer. And some examples of these include adding or removing a tank from service, changes to your drainage system, significant things that impact the ability to respond to a spill or the risk of a spill at your facility. And then lastly, the size of your facility can impact whether a PE needs to be involved or not. Just know that if your facility is over 10,000 gallons in size or total storage, a professional engineer, qualified contractor needs to be involved for most amendments. And then lastly, 40 CFR 112 requires a five-year review. It's typically done as a technical amendment for facilities over 10,000 gallons in size. And again, usually a PE is involved, but not always. And then there are some state-specific requirements for SPCCs. Washington has several. Hawaii and Alaska do not have any. The easiest way to know if your state requirements are also within your SPCC is to check the front for a cross-reference. I know we've got listeners all over the United States now. So if you're sitting in some states that are not Washington, Hawaii or Alaska, if you go to the front of your SPCC and there's a cross-reference for a state regulation, that tells you that there's some state regs you're going to need to meet too.

SPEAKER_03 25:31

Wow. Well, thank you so much for running us through all of that, Shannon. I have to admit the list is a lot longer than I thought it would be.

SPEAKER_01 25:39

I know. It is so long. Well, to show compliance with the SPCC, you have to keep a lot of records. I mean, the plan seems pretty simple at first, but documenting compliance with all the different pieces parts of it, it gets pretty complex. And I really think it causes a lot of friction between the main office and the facility management. Because when you look at an SPCC, on the surface, it just does not look like a massive amount of work to keep up on all those records. But proving that all the things are true requires a pretty heavy record lift on the staff, facility staff's part.

Where To Learn More And Training

SPEAKER_03 26:10

So where can our listeners go to learn more about SPCC record keeping?

SPEAKER_01 26:15

Well, your first stop would be your SPCC. Read that bad boy. Read the sections on record keeping and training. Review all the content with the idea that you may have to prove to an EPA inspector someday that you did it and you did what you were supposed to do. Like I mentioned before, we have some past episodes on record keeping and how to do it better. And I can provide a link to those in the show notes. Integrity has also developed an annual online training that takes you through your SPCC section by section. It helps make sure you've got all your records squared away and that you reviewed all the critical sections of your SPCC. It guides you through all of the things that we just talked about and more, and it makes sure you don't miss anything. So I narrate it, I kind of bring that straight talk and I describe common errors in every lesson. It's like the easy button for reviewing your SPCC. And we issue a certificate that can count towards your continuing education, and it fully meets the review requirements of the SPCC. We developed it based on lots of requests from our clients, and I think it's turned out pretty well. It just you pull your SPCC off the shelf, you go through the training with your SPCC, and at the end of it, you're done and covered, and you know exactly what you need to do.

SPEAKER_03 27:23

Great. And you can find that at www.integrity-env.com.

SPEAKER_01 27:28

Yeah, there's a tab on top that says services, and then you scroll down for shield training. We can also put the direct link to this training in the show notes too. It's not hard to find. Shannon, are we done now? Wait, there's more. Just kidding. We are. We are totally done with record keeping for the SPCC. But I do this is terrible. Haley, I feel compelled to remind our listeners, though, that there are many more records that are required to be kept at your facility for things like stormwater, the Coast Guard, on and on. So don't stop learning here. Keep going. But we are done for today with SPCC.

SPEAKER_03 28:03

Thank you so much. This was such a great start to this series. Tune back in as we publish more basics related to the SPCC. And thank you so much, everyone, for listening.

SPEAKER_01 28:14

Hi

Final Disclaimer And Consulting Offer

SPEAKER_01 28:15

there, this is Shannon Olkers. And as the owner of Integrity Environmental, I wanted to take a minute here at the end of the podcast to make sure that you knew the following. This podcast is for informational purposes only and should not be considered legal or regulatory advice. We are not responsible for any losses, damages, or liabilities that may arise from the use of this podcast. This podcast is not intended to replace professional, regulatory, or legal advice. And the views expressed in this podcast may not be those of the host. That would be me for integrity environmental. Thank you very much for listening. And if you do need professional regulatory advice, we'd be happy to help you as part of our consulting services.