ON MARCH 11, 2008, AN AUTHORIZED REPRESENTATIVE OF EPA, CONDUCTED A SPCC INSPECTION AT BLANCHARD OIL COMPANY INC. ALTHOUGH BLANCHARD OIL COMPANY INC STORES OIL IN AMOUNTS ABOVE THE THRESHOLDS REQUIRING THE PREPARATION AND IMPLEMENTATION OF A SPC PLAN UNDER 40 CFR 112, IT DID NOT HAVE AN ADEQUATE SPECC PLAN. BECAUSE OF THE SIZE OF THE FACILITIES AND OTHER FACTORS, EPA IS UTILIZING THE ESA ENFORCEMENT TOOL.