Spill Prevention, Control and Countermeasure (SPCC) plans have become routine for operational facilities, but they are often unheeded during construction phases, opening contractors to unnecessary liabilities. These plans are critical to the construction phase and can slow a project's timeline if they aren't incorporated into the early phases of planning.

In general, the EPA requires a facility to have an SPCC plan when there will be more than 1,320 gallons of oil stored above ground in containers 55 gallons or larger at a job site. The regulation was designed so that any potential oil spill — whether from a diesel fuel tank, emergency generator or some other oil source — can be contained and properly stored to prevent any spillage from reaching a navigable body of water.

However, the requirement can often be overlooked during construction, particularly if owners believe a high quantity of oil will only be present temporarily. The Environmental Protection Agency (EPA) does grant a six-month grace period to amend an SPCC plan for existing sites; however, failing to create a plan both for new construction or an existing project creates a liability that could expose an owner to unwanted risk. If there is an oil release, the first thing the EPA will ask for is a copy of the SPCC plan, and without a well-thought-out plan, the EPA's involvement can significantly slow a project's timeline.

The discussion of SPCC plans should start as early as the contracting phase. Before agreements are reached, team leaders need to ask each subcontractor how much oil will be on a site and estimate if an SPCC plan may be needed.

During construction, Burns & McDonnell often approaches these plans by creating a laydown area where pre-filled equipment is stored, assessed and regularly evaluated in an SPCC plan. Then, as the tanks and equipment on a job site are filled during the construction process, the information is added to the existing SPCC plan. By a job's completion, a carefully crafted, customized SPCC plan is ready to be handed over to the owner to guide operations.

Once construction is complete, new facilities will need to put procedures in place to make sure all oil storage areas are inspected monthly and oil-handling personnel are well-trained — initially and during yearly supplemental sessions — on the importance of the plan and the potential liability a facility faces if a spill occurs.

The EPA has made its expectations clear. Those facilities who address them early and consistently throughout the construction and operation process will be better served.

Amy Reed, PE, is an associate environmental engineer, compliance audit team member and project manager at Burns & McDonnell. A chemical engineer by training with over 20 years of experience, she specializes in helping industrial and utility clients comply with EPA regulations.