ON JULY 19, 2006 AN AUTHORIZED REPRESENTATIVE OF EPA, CONDUCTED AN SPCC INSPECTION AT DANBURY DEPARTMENT OF PUBLIC WORKS. ALTHOUGH DANBURY DPW STORES OIL IN AMOUNTS ABOVE THE THRESHOLDS REQUIRING THE PREPARATION AND IMPLEMENTATION OF SPCC PLAN UNDER 40 CFR 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.