A plan on the shelf and no signed monthly log is the deficiency inspectors write up most often, and it is the one nobody notices until somebody asks. Walk the checklist on your phone, sign the record on the spot, and carry every failed item through to a closure note.
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Tank exterior, secondary containment, piping and transfer, overfill and spill equipment, site and access. Nineteen items in the order you walk them, each taking Pass, Fail or N/A. The annual pass adds training, documentation review, containment capacity and the five-year plan review.
Every inspection captures the inspector name, the date, a typed signature and a confirmation that the yard was physically walked. No Fail saves without a written note, so the record you print is the record you can stand behind.
A failed item becomes an open deficiency with severity, corrective action and target close date, running open to action taken to closed. Closing requires a note. The dashboard lists what is still open across every facility, oldest first.
Next monthly due, next annual due, and colour-coded overdue flags. Then the part that matters: exactly which of the last 36 months have no inspection on file, so you can see your retention window the way an inspector will.
Under 40 CFR 112.7(e), inspections must follow written procedures, be signed by the appropriate supervisor or inspector, and be kept with the SPCC plan for at least three years, with 112.8(c)(6) adding regular integrity testing of bulk containers. Consultants report the same finding over and over: a current plan with nothing behind it. Clean Water Act penalties are assessed per day and per violation and adjusted annually for inflation — and the whole remedy is a dated log with a signature on it.
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This is a recordkeeping aid, not a substitute for a PE-certified SPCC plan, and it does not file anything with the EPA, a state agency or a CUPA. Inspection scope and frequency are set by your own written plan under 40 CFR 112.7(e) and 112.8(c)(6); container integrity testing follows the standard and interval your plan adopts. Verify all scope, intervals and applicability against the regulation and your plan conditions.