Facilities with aboveground oil storage above SPCC thresholds — more than 1,320 gallons aggregate aboveground capacity, or more than 42,000 gallons in underground storage — must maintain an active SPCC plan under 40 CFR Part 112. That plan isn’t a document you write once and file away. It requires an ongoing inspection program: daily visual inspections of active oil storage containers, monthly facility-level inspections, and annual comprehensive reviews.
The gap between having a SPCC plan and demonstrating that you’re actually implementing it is exactly where EPA enforcement actions originate. Manual inspection logs stored in binders don’t prove that inspections happened — they prove that paperwork was filed. EHSTracks SPCC inspection software closes that gap with mobile, GPS-verified inspections that produce audit-ready documentation every time an inspector completes their rounds.
An effective SPCC inspection program requires consistency: the same checklist, the same inspection points, the same documentation standard — regardless of which inspector is on shift or which containment structure they’re checking. EHSTracks configures that consistency into the software itself.
- Configurable inspection templates for daily visual inspections, monthly facility inspections, and annual SPCC reviews — each template scoped to the inspection requirements that apply at that frequency
- Templates cover all required inspection points: aboveground storage tanks (ASTs), drums, totes, intermediate bulk containers, secondary containment structures, diking, spill response equipment, and stormwater management controls
- GPS location verification confirms the inspector was physically present at each inspection point — the same standard that distinguishes a real inspection from a desk entry
- Photo documentation attached directly to inspection items for condition issues: a cracked containment wall, a missing drain plug, degraded dike integrity
- Deficiencies logged during an inspection automatically create corrective action records — no separate data entry step required
Every completed inspection produces a timestamped, GPS-verified record that demonstrates actual implementation of the SPCC plan — not just a plan on a shelf.
Under 40 CFR 112.8(c)(2), facilities must maintain secondary containment structures capable of containing the entire contents of the largest single container in the diked area, plus sufficient freeboard for precipitation. Containment that is cracked, full of accumulated rainwater, or degraded doesn’t meet that standard — and if a release occurs, the inadequate containment becomes the first thing an EPA inspector examines.
EHSTracks tracks secondary containment condition systematically:
- Document the condition of each secondary containment structure during every applicable inspection: integrity status, drainage condition, accumulated liquid level, structural concerns
- Flag containment that is damaged, at capacity due to precipitation accumulation, or otherwise insufficient
- Log corrective actions directly: drain the containment, schedule structural repair, document the timeline
- Track corrective action status from open to verified-closed, with documentation that demonstrates the containment was restored to sufficiency before the next inspection cycle
- Generate a containment status summary across all structures at the facility — the view that a compliance coordinator needs to understand program health at a glance
Secondary containment is the last line of defense before a release reaches navigable waters. The inspection records that demonstrate it was maintained are what you show when that defense is tested.
Your SPCC plan is built around a specific inventory of oil containers. When containers are added, removed, or reconfigured, the SPCC plan may need to be amended and the facility’s tier status may change. A Tier I qualified facility has different plan requirements than a Tier II or a facility requiring a Professional Engineer-certified plan — and crossing a threshold without updating the plan is a violation even if no spill has occurred.
EHSTracks oil container inventory tracking keeps that information current:
- Maintain a current inventory of all regulated oil containers: type (AST, drum, tote, IBC), contents, volume, location, and SPCC applicability status
- Monitor aggregate aboveground oil storage volumes across the facility — with alerts when volumes approach the Tier I or Tier II thresholds that affect plan requirements
- Flag containers that are added or decommissioned, prompting a review of whether the SPCC plan needs amendment
- Link containers to their associated secondary containment structures — so that a containment inspection record is automatically connected to the containers it protects
- Track API 653 or STI SP001 integrity testing schedules for large aboveground storage tanks subject to integrity testing requirements
When the aggregate volume changes, EHSTracks changes the record. When an inspector asks for your current container list, you export it directly.
A deficiency found during a SPCC inspection — a cracked containment wall, a missing secondary containment drain plug, degraded tank pad integrity, a malfunctioning spill response kit — doesn’t become a regulatory problem on its own. It becomes a problem when the deficiency is documented and then left unresolved. EPA inspectors routinely look for open corrective actions from past inspection records that were never closed.
EHSTracks corrective action tracking prevents that exposure:
- Every deficiency logged during a SPCC inspection automatically generates a corrective action record
- Assign corrective actions to responsible parties with specific due dates and priority classifications
- Track status through the full lifecycle: open → in progress → pending verification → verified closed
- Attach completion documentation (photos, contractor invoices, re-inspection records) to the corrective action record
- Overdue corrective action reports flag items that have passed their due date — visible to both field personnel and EHS management
- Management dashboard shows all open SPCC corrective actions across the facility, with aging and priority indicators
The ability to show that every deficiency found during an inspection was tracked, assigned, and resolved is what distinguishes a defensible compliance program from a paper exercise.
For companies operating multiple facilities subject to SPCC — petroleum refineries, pipeline terminals, utility substations, agricultural operations, industrial manufacturing complexes — managing SPCC programs site by site with different systems creates exactly the kind of inconsistency that increases enforcement exposure across the portfolio.
EHSTracks supports enterprise-scale SPCC program management:
- Manage SPCC programs across multiple facilities from a single platform, with role-based access that gives site personnel visibility into their facility and corporate EHS visibility across all sites
- Standardize inspection templates across the facility portfolio while preserving site-specific configurations where facility layouts or SPCC plan requirements differ
- Aggregate compliance status across all sites for corporate EHS reporting — open corrective actions, inspection completion rates, recent findings, and upcoming inspection due dates all visible at the portfolio level
- Identify systemic issues that appear across multiple sites — a corrective action category that keeps recurring is a program gap, not an isolated finding
For organizations operating under a single corporate SPCC program framework, EHSTracks provides the operational layer that makes that framework work consistently across facilities.
SPCC plan documentation requirements under 40 CFR Part 112 include maintaining inspection records and the SPCC plan itself for at least 3 years, with the plan subject to a 5-year review cycle and amendment requirements when facility conditions change. When EPA or a state agency requests SPCC records, that documentation must be produced promptly.
EHSTracks generates that documentation from the operational data collected during normal inspections:
- Export inspection records in PDF or CSV — formatted with all required fields: date, inspector, inspection type, findings, and corrective action status
- Full corrective action log with resolution documentation for each item
- Container inventory reports current as of any date in the inspection record history
- Documentation package formatted to support an EPA SPCC inspection response — everything the inspector will ask for, organized and ready to produce
SPCC applies across a wide range of facility types and sizes — from a single 10,000-gallon aboveground diesel storage tank at a rural electric cooperative to a multi-tank petroleum terminal with millions of gallons of aggregate capacity. EHSTracks is configured to match your facility’s actual SPCC program, not a generic template:
- Suitable for Tier I and Tier II qualified facilities as well as larger facilities requiring PE-certified SPCC plans
- Cloud-based, mobile-first — no on-premise IT infrastructure required; inspectors use their iOS or Android devices
- Configurable inspection templates that reflect your existing SPCC plan’s specific inspection requirements
- Built by EHS professionals who have written and managed SPCC plans — the platform reflects how SPCC inspection programs actually operate
Facilities subject to SPCC typically operate under several additional environmental programs simultaneously. EHSTracks covers the full compliance stack:
See all EHSTracks products to review the complete compliance program suite.
What types of SPCC inspections does EHSTracks support?
EHSTracks supports the full range of SPCC inspection types required under 40 CFR Part 112, including daily visual inspections of active oil containers, monthly facility-level inspections covering ASTs, secondary containment, and spill response equipment, and annual comprehensive SPCC inspections. Inspection templates are configurable to your facility’s specific SPCC plan requirements — if your plan calls for weekly inspections of certain structures or additional inspection points beyond the regulatory minimums, those requirements can be built directly into the EHSTracks template for that inspection type.
Does EHSTracks help with multi-facility SPCC programs?
Yes. EHSTracks is designed to support multi-facility SPCC programs from a single platform. Corporate EHS teams can manage inspection programs, review corrective action status, and generate compliance reports across an entire facility portfolio, while site-level personnel access only their facility’s records. Inspection templates can be standardized across similar facilities for program consistency, with site-specific variations available where facility layouts or SPCC plan requirements differ. This is particularly relevant for companies managing SPCC programs at pipeline terminals, bulk liquid storage facilities, or distributed industrial operations.
How does EHSTracks handle SPCC corrective action documentation?
Every deficiency identified during an SPCC inspection in EHSTracks automatically generates a corrective action record — there is no separate data entry step. Each corrective action captures the deficiency description, the inspection it was identified in, the assigned responsible party, the due date, and the priority classification. Corrective actions are tracked through completion, with the ability to attach completion documentation (photos, repair records, re-inspection results) to the record. The full corrective action history — open, in progress, and closed — is available as an exportable report at any time, providing the complete documentation trail that demonstrates corrective actions are being managed and resolved.
Can EHSTracks help us prepare for an EPA SPCC inspection?
Yes. The primary value of EHSTracks during an EPA SPCC inspection is the ability to produce complete, organized documentation on demand. When an inspector arrives and requests inspection records, container inventory, and corrective action documentation for the past 3 years, EHSTracks generates that package from the operational data already in the system. GPS verification on every inspection record demonstrates that inspections were conducted at the actual location. Corrective action records demonstrate that deficiencies were identified, tracked, and resolved. The documentation package is in the format inspectors expect — not a folder of handwritten logs that requires explanation.
Ready to modernize your SPCC inspection program? Schedule a demo with the EHSTracks team and walk through a configuration built for your facility.