Some common SPCC violations are:
No plan at all; or plan was not updated/current.
Plan did not address all required components.
Plan was not implemented.
Inadequate record keeping by the facility.
Plan did not include all oil storage containers = or >55 gal.
Plan was not PE certified.
Failure to review and update plan every five years.
Plan failed to accurately identify the path oil would follow to waterways from each storage location.
Facility personnel were not properly trained on the proper spill prevention procedures.
No documentation of facility security measures in the plan (this may include fencing, gates, lighting, security personnel, etc.).