ON OCTOBER 20, 2004, AN AUTHORIZED REPRESENTATIVE OF EPA CONDUCTED AN SPCC INSPECTION AT NARRAGANSETT IMPROVEMENT COMPANY. ALTHOUGH NARRAGANSETT IMPROVEMENT COMPANY STORES OIL IN AMOUNTS ABOVE THE THRESHOLDS REQUIRING THE PREPARATION AND IMPLEMENTATION OF A SPCC PLAN UNDER 40 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.