ON JULY 18, 2005, AN AUTHORIZED REPRESENTATIVE OF EPA, CONDUCTED AN SPCC INSPECTION AT H.G. NELSON, INC. ALTHOUGH H.G. NELSON & SON, INC. STORES OIL IN AMOUNTS ABOVE THE THRESHOLDS REQUIRING PREPARATION AND IMPLEMENTATION OF A SPCC PLAN UNDER 4O C.F.R. PART 112, IT DID NOT HAVE AN ADEQUATE SPCC PLAN. BECAUSE OF THE SIZE OF THE FACILITY AND OTHER FACTORS, EPA IS UTILIZING THE ESA ENFORCEMENT TOOL.