Environmental attorneys spend 6-8 hours manually researching 40 CFR Part 112 requirements, cross-referencing EPA templates, compiling facility data, and formatting SPCC plans. Each section requires verification against current regulations, and any missed requirement can result in costly non-compliance penalties for clients.
Creating a comprehensive SPCC Plan that meets 40 CFR Part 112 requirements is complex, time-consuming, and requires detailed knowledge of EPA regulations. Facilities risk non-compliance penalties, environmental damage, and operational delays when plans are incomplete or outdated. Manual drafting can take weeks and requires coordination between engineers, environmental specialists, and legal counsel.
CaseMark automates SPCC Plan generation with AI-powered drafting that incorporates all regulatory requirements from 40 CFR Part 112. Simply upload your facility information, storage inventory, and site details to generate a comprehensive, PE-certification-ready plan in minutes. Our system ensures all required sections, technical specifications, and regulatory citations are included and properly formatted.
This workflow is applicable across multiple practice areas and use cases
Energy facilities including oil and gas operations, refineries, and power plants require SPCC plans for compliance with federal regulations governing petroleum storage and handling.
Energy law practitioners regularly advise clients on regulatory compliance for oil storage facilities, making SPCC plan preparation a core deliverable in this practice area.
Commercial real estate transactions involving industrial properties require SPCC plan review and preparation to ensure EPA compliance and avoid environmental liability transfers.
Real estate attorneys handling industrial property sales or leases must verify environmental compliance including SPCC plans as part of property due diligence and closing requirements.
During M&A due diligence for industrial facilities, buyers need to verify SPCC plan compliance to assess environmental liabilities and regulatory risks before closing.
Environmental compliance documentation, including SPCC plans, is critical in M&A transactions involving facilities with oil storage to identify potential liabilities and ensure regulatory compliance.
Commercial litigation involving environmental contamination or regulatory enforcement actions requires analysis of SPCC plans to establish compliance status and liability defenses.
Litigators defending against EPA enforcement actions or environmental damage claims need to review and potentially prepare SPCC plans to demonstrate compliance efforts and mitigate penalties.
Your facility needs an SPCC Plan if it has aggregate aboveground oil storage capacity greater than 1,320 gallons or completely buried storage capacity greater than 42,000 gallons, and could reasonably discharge oil into navigable waters or adjoining shorelines. This applies to facilities storing petroleum products, non-petroleum oils, animal fats, and vegetable oils. CaseMark helps you determine applicability and generate compliant plans for qualifying facilities.
Yes, if your facility has aggregate aboveground oil storage capacity greater than 10,000 gallons (excluding containers under 55 gallons), EPA requires Professional Engineer certification. CaseMark generates PE-certification-ready documentation that meets all technical and regulatory requirements, streamlining the certification process. Smaller facilities may qualify for self-certification under specific conditions outlined in 40 CFR 112.3(d).
EPA requires SPCC Plans to be reviewed and evaluated at least once every five years. Plans must be amended within six months of any facility changes that materially affect spill potential or response procedures, such as new storage tanks, modified containment systems, or operational changes. CaseMark makes amendments quick and efficient, ensuring your plan remains current and compliant.
Operating without a required SPCC Plan exposes your facility to significant EPA penalties, which can reach tens of thousands of dollars per day of violation. Beyond financial penalties, you face increased liability for cleanup costs, potential criminal charges for willful violations, and reputational damage. An inadequate or missing plan also complicates emergency response and can worsen environmental impacts during an actual spill event.
Yes, CaseMark supports both initial SPCC Plan creation and amendments to existing plans. Upload your current plan along with updated facility information to generate compliant amendments that reflect operational changes, new equipment, or regulatory updates. The system ensures amendments maintain consistency with your existing plan structure while incorporating all necessary revisions and updated certification requirements.