An SPCC compliance audit verifies that a facility’s Spill Prevention, Control, and Countermeasure Plan — required under 40 CFR Part 112 for facilities storing oil above regulatory thresholds — is accurate, enforceable, and ready for a regulator’s visit. Since 2020, a Northern Illinois natural gas utility has relied on A3 Environmental Consultants (A3E) to run both its SPCC program and its Underground Storage Tank (UST) compliance audits across a statewide facility portfolio. The goal is simple: stay on the right side of the regulatory agencies and avoid the cost and disruption of a failed inspection. This project profile explains how the program works and what a compliance audit engagement looks like for your facilities.
What Is an SPCC Compliance Audit?
A Spill Prevention, Control, and Countermeasure (SPCC) Plan is required by the USEPA oil spill prevention regulations (40 CFR Part 112) for facilities that store oil in aboveground containers above the regulatory threshold and could reasonably be expected to discharge oil to navigable waters. An SPCC compliance audit checks that the written Plan still matches reality on the ground: aggregate oil storage capacity, secondary containment integrity, discharge history, inspection and integrity-testing logs, spill contingency procedures, and personnel training records.
For the utility client, A3E prepares and audits SPCC Plans across storage sites, compressor stations, LNG/RNG and propane plants, and service and fleet maintenance centers — anywhere oil-filled equipment, generators, and aboveground storage tanks are present. A3E evaluates each facility’s layout and storage capacity to determine and document Tier I or Tier II qualified facility status and self-certification eligibility, then keeps every Plan current through required five-year reviews and technical amendments when facilities change.
UST Compliance Audits Ahead of OSFM Inspections
UST fill ports and monitoring equipment reviewed during a pre-inspection audit.
In Illinois, the Office of the State Fire Marshal (OSFM) inspects facilities that operate underground storage tanks. A3E’s UST compliance audits are pre-inspections: before the OSFM ever arrives, A3E reviews the paperwork, hardware, and software required to operate USTs in the state — tank registration, release detection, spill and overfill prevention, corrosion protection, financial responsibility, and operator training records — so each facility is prepared well ahead of the real inspection.
That preparation matters because UST problems get expensive fast. A failed inspection can mean fines and red-tagged tanks; a missed release can mean a full leaking underground storage tank removal and closure. A3E has seen the downstream costs firsthand on projects like the Evanston apartment UST removal and the Rand River Auto UST removal — and even documented widespread errors in the state’s own records in our review of the Illinois UST database.
Project Snapshot
- Client: Northern Illinois natural gas utility provider
- Location: Illinois (statewide portfolio), served from A3E’s headquarters at 3030 Warrenville Rd, Lisle, IL
- Services: UST compliance audits; SPCC Plan preparation and compliance audits
- Key staff: David McCoy, P.G.; Nicole Axtolis
- Duration: 2020–present
- Value: Ongoing, multiple facilities
What to Expect From an SPCC Compliance Audit Program
A first engagement usually starts with a records review and a site walk at each facility, followed by either a new SPCC Plan or an audit of the existing one. From there the program becomes a maintenance rhythm: five-year Plan reviews, amendments after facility changes, annual inspection log checks, and training documentation updates. Deliverables are a written audit findings memo per facility, updated or newly certified SPCC Plans, and a pre-inspection punch list your operations team can actually close out. Pricing scales with facility count and complexity — a single-site audit is a modest line item; a portfolio program like this client’s is scoped as an ongoing services agreement. A3E has run this program continuously since 2020, alongside standalone work like our 2022 UST removal and compliance audit project.
Frequently Asked Questions
What triggers the need for an SPCC Plan?
A facility needs an SPCC Plan when its aggregate aboveground oil storage exceeds 1,320 gallons (or 42,000 gallons underground) and a discharge could reasonably reach navigable waters or adjoining shorelines. Oil-filled transformers, generators, and hydraulic equipment all count toward the threshold — not just tanks.
How often should an SPCC Plan be reviewed?
At least every five years, and any time the facility changes in a way that affects oil storage — new tanks, removed equipment, or modified containment. Amendments generally must be certified, either by a Professional Engineer or through self-certification if the facility qualifies as Tier I or Tier II. Many operators sync an SPCC compliance audit to that five-year clock so the review and the recertification happen in one visit.
What does the OSFM inspect at UST facilities in Illinois?
Tank registration, release detection, spill and overfill prevention equipment, corrosion protection, financial responsibility documentation, and operator training records. A3E’s pre-inspection audit walks the same checklist the inspector will, so nothing is a surprise.
Can one firm handle both UST and SPCC compliance?
Yes — and it usually should. The same site visit covers both programs, the records overlap heavily, and a single audit calendar keeps every facility’s UST and SPCC obligations synchronized instead of scattered across vendors.
Keep Your Facilities Inspection-Ready
A3E runs SPCC compliance audit and UST audit programs for utilities and industrial operators across Illinois. Request a compliance audit quote or call us at (888) 405-1742.
We Fix Gnarly Environmental Problems
Reviewed by David McCoy, P.G.
