If your facility stores petroleum aboveground in California, two different inspection regimes apply to your SPCC obligations. Knowing which one you are facing changes what you need to have ready.
The first is the inspection program you run on yourself. Monthly visual checks and an annual comprehensive review, documented on logs kept at the facility. That is what 40 CFR Part 112 calls for, and it is self-managed.
The second is the inspection that comes to you. A CUPA inspector (your local CUPA is may be a county environmental health department, fire department, or another local agency depending on jurisdiction) shows up under the Aboveground Petroleum Storage Act (APSA) to audit whether your SPCC plan exists, is current, matches what they see on the ground, and is being implemented. This is enforcement. Violations get classified Minor, Class II, or Class I, and citations are issued.
This piece walks through how to prepare for the second kind. For the broader regulatory picture, see our SPCC plan development and certification services in California overview.
What an APSA Inspector Is Actually Checking
When we walk a facility ahead of a CUPA visit, the first thing we look for is whether the paper record matches the yard. Inspectors do the same thing in reverse. They cross-reference the SPCC plan against what petroleum is actually on site, where it sits, and how it is contained.
Based on statewide CERS data published by the Office of the State Fire Marshal, the most-cited APSA violations year after year fall into three buckets:
- Documentation gaps in the SPCC plan itself (missing sections, outdated information, not on site)
- Inspection and testing records (not signed, not retained, integrity tests not performed by a qualified person)
- Training (no annual spill prevention briefing, no training program described in the plan)
The single most-cited APSA violation in recent CalEPA reporting periods is failure to keep written records of inspections and tests under 40 CFR §112.7(e) and §112.8(c)(6). The second and third are employee training requirements and annual spill prevention briefings under §112.7(f).
That tells you where to focus.
Pre-Inspection Checklist
Use this before any APSA inspection. The same checklist applies whether you are facing a routine CUPA visit or responding to a complaint-driven inspection.
SPCC plan and certification
– [ ] Current PE-certified SPCC plan kept on site (or at the nearest field office if the facility is attended fewer than four hours per day)
– [ ] Last 5-year review documented in the plan’s record of revision (per 40 CFR §112.5(b))
– [ ] Any technical amendments since the last certification reviewed and recertified by a PE within six months of the change (tanks added or removed, containment altered, oil type changed)
– [ ] Administrative amendments (contact name and phone changes) are current
Tank facility statement and CERS
– [ ] Annual Tank Facility Statement filed in CERS (the state’s online environmental reporting portal), or a current Hazardous Materials Business Plan submittal that covers the same data under APSA (per Health and Safety Code §25270.6)
– [ ] Aboveground petroleum storage flagged “Yes” in the CERS facility information element
– [ ] Total aboveground petroleum capacity and date of SPCC plan certification or 5-year review entered correctly
Inspection records
– [ ] Monthly STI SP001 visual inspection logs for the last three years on file, signed by the inspector
– [ ] Annual STI SP001 (or API 653, where applicable) inspection records on file, performed by an appropriately qualified person
– [ ] Integrity testing records for each bulk storage container at the interval the plan specifies
– [ ] Records of any corrective action taken after inspection findings
Training
– [ ] Annual spill prevention briefing documented for all oil-handling personnel (date, topics covered, attendees)
– [ ] Training records reference known discharges, malfunctioning components, and recently developed precautionary measures (the three items §112.7(f)(3) requires)
– [ ] Person designated as accountable for discharge prevention named in the plan
Physical conditions
– [ ] Secondary containment intact, drain valves closed and in good working order
– [ ] Containment free of standing oil, debris, and accumulated rainwater
– [ ] Overfill prevention equipment functional (high-level alarms, shutoff valves)
– [ ] Tank labels and capacity placards legible
– [ ] Spill response equipment (absorbents, booms) present at the locations the plan specifies
Notice of inspection in the mail, or a CUPA visit already scheduled? Call (925) 551-7300 or request a consultation. We can walk your facility before the inspector does and identify gaps you can correct in advance.
What Happens During the Walk-Through
A CUPA inspection typically opens with paperwork. The inspector will ask for the SPCC plan, the inspection logs, training records, and (if requested ahead of time) the Tank Facility Statement or APSA submittal in CERS. They are checking that the plan exists, is current, and is kept where the regulation requires.
The field walk follows. Inspectors verify that every petroleum container 55 gallons or larger is accounted for in the plan, that capacities match, that secondary containment meets §112.8(c)(2) for bulk storage (capacity for the largest single container plus sufficient freeboard for precipitation), and that piping, transfer areas, mobile refuelers, and oil-filled equipment have appropriate containment and are addressed in the plan.
Two distinctions trip facilities up:
General versus sized containment. Under 40 CFR §112.7(c), every petroleum source needs general containment (the ability to address the most likely discharge before it leaves the regulated area). Bulk storage containers additionally need sized containment under §112.8(c)(2). Drums on pallets may satisfy one and not the other.
Tank in Underground Area (TIUGA). A petroleum tank located in a basement, vault, or similar underground area at a facility below the 1,320-gallon threshold can still trigger APSA under Health and Safety Code §25270.2. Inspectors look for these specifically.
If the plan does not match the yard, the inspector documents the discrepancy. If a technical change happened more than six months ago without recertification, that is a citable amendment violation.
After the Inspection
You will receive an inspection report listing any violations, their classification, corrective action requirements, and a deadline to establish compliance. Class I violations are the most serious and often carry penalties. Class II and Minor violations may be resolved through documented correction.
Most APSA citations come back to one of these root causes: a plan that was written years ago and never revisited, an inspection program that was never set up, or training that nobody documented (see SPCC training requirements for facility personnel). Fixing the underlying gap, not just the cited deficiency, is what keeps the violation from recurring at the next inspection cycle.
The 5-year review cycle is the natural moment to catch all three at once. The CDMS compliance calendar tracks that date for clients on our SPCC plan service, and an inspection-prep walk-through can be scheduled ahead of any known CUPA visit.
For related preparation, see our SPCC inspection requirements guide on what the monthly and annual self-inspection program should look like, and our SPCC vs APSA in California breakdown if you are still sorting out which regulation applies. Inspection findings that reveal broader compliance gaps often lead to an EHS gap assessment covering the rest of the facility’s programs. You can start with the EHS compliance audit checklist.
Getting Ready
Have a CUPA inspection scheduled, or want a mock walk-through before one happens? Call (925) 551-7300 or request a consultation. We will review your current SPCC plan, walk your facility, identify deficiencies against the same items inspectors cite, and tell you what to correct before the inspector arrives.
