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Region 1: EPA New England

Common Violations: SPCC

Common SPCC (Spill Prevention Controls & Countermeasures) Violations

This page provides useful information to help colleges and universities comply with some basic environmental regulatory requirements. This page, however, does not list all the applicable regulatory requirements that might apply to your campus. Please be sure to comply with all applicable requirements.
  • No Plan at all. [40 CFR 112.3 (a) or (b)]
  • Failure to prepare and implement SPCC plan, specifically failed to include all elements of a complete plan as required by SPCC regulations. [40 CFR 112.3 (c)]
  • Plan not PE certified. [40 CFR 112.3 (d)]
  • Plan not reviewed/updated every three years. [40 CFR 112.5 (b)]
  • Plan does not include all oil on facility, i.e., transformers, hydraulic systems, emergency generators, drum storage, etc. [40 CFR 112.7 (e)(2)]
  • Plan does not accurately identify, from each oil storage location, the detailed path spilled oil would take to reach a waterway, i.e., a typical campus is so wide, drainage may flow in different directions, to different receptors, especially in urban locations. Drains not traced out. [40 CFR 112.7 (e)(1)]
  • Designated staff do not conduct regular walk-through inspections of teaching and research locations to be aware of oil use by professors, TAs, graduate students, and other non-maintenance staff. [40 CFR 112.7 (e)(8)]
  • Small, scattered Above-ground Storage Tanks (ASTs), especially in dormitory locations, are not adequately protected from tampering/vandalism. A transient student population presents unique hazards not encountered with supervised adults in an industrial setting. Students are not employees, are not OSHA trained, and have no stake in paycheck protection through preservation of an employer's image or goodwill. [40 CFR 112.7 (e)(9)]

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