What to Know about SPCC Violations
All facilities and farms that qualify for SPCC regulations must implement their plans to avoid potential fines and penalties. The cost of these violations can quickly escalate and may even include criminal penalties. In this article, we’ll walk through a few of the potential fines and penalties and then give a quick list of common deficiencies and violations that may affect your facility or farm.
SPCC Fines and Penalties
There are several types of fines and penalties the EPA can give to a non-compliant facility or farm, here are some examples:
- Failure to Notify violations are considered criminal violations. Administrative violations can be as little as $16,000 per violation to $16,000 per day, for each day. The violation continues to a maximum of $177,500.
- Judicial Enforcement Actions with Civil Judicial penalties can be up to $37,500 per day of violation with no cap.
- Spill penalties can be up to $37,500 per day of violation, and criminal penalties can also apply if the violation is considered negligent or knowing.
SPCC Common Deficiencies and Violations
In stormwater, we often don’t realize the common violations of the SPCC regulations we make all the time. Here are some examples:
- No SPCC plan
- No proper certifications
- No records
- No containment for oil storage tanks
- No other containment
- Inadequate containment
- No general containment for non-loading rack transfer areas
- Valve found open
- Container incompatibility (this isn’t a violation the way it’s worded… rephrase)
- Integrity issues
- No or inoperative overfill device
- No transfer procedure
- No inspection device
- No tank integrity testing program or no records
- Failure to address containers in buildings and required secondary containment
- Lack of proper maintenance and inspection of container structures