EPA enforcement activities related to oil containment and SPCC compliance have intensified in recent years, with 2025 seeing a 23% increase in SPCC-related enforcement actions compared to 2024. Industrial facility operators should take note of current enforcement priorities and ensure their containment systems meet regulatory requirements.
Recent Enforcement Actions#
Recent enforcement actions provide insight into where regulators are focusing their attention:
Manufacturing Facilities#
In Q4 2025, EPA Region 5 announced a $2.1 million penalty against a Michigan automotive parts manufacturer for failure to maintain adequate secondary containment for hydraulic oil storage. The violation involved secondary containment structures that had deteriorated to the point of being non-functional, and an SPCC plan that had not been updated in seven years.
Transportation Facilities#
A multistate trucking company agreed to pay $1.4 million and implement a comprehensive environmental management system after EPA Region 3 inspectors found multiple SPCC violations across 12 terminal facilities. Primary violations included undersized containment berms and missing inspection records.
Common Compliance Deficiencies#
Based on EPA inspection data for 2025, the most common SPCC deficiencies at industrial facilities include: secondary containment structures with inadequate capacity (37% of violations), missing or inadequate inspection records (29%), outdated SPCC plans not reflecting current facility conditions (18%), inadequate drainage controls (11%), and insufficient personnel training documentation (5%).
Self-Audit Checklist#
Facility operators should conduct a self-audit addressing the following questions at minimum:
- Has your SPCC plan been amended to reflect all facility modifications in the past 12 months?
- Are all secondary containment structures intact and at their designed capacity?
- Are inspection records current and properly filed?
- Have all oil-handling personnel received documented SPCC training in the past 12 months?
- Are emergency contact and spill response procedures current?
