ON AUGUST 24, 2006 AN AUTHORIZED REPRESENTATIVE OF EPA CONDUCTED AN SPCC INSPECTION AT RUMFORD FALLS HYDRO LLC. ALTHOUGH RUMFORD FALLS HYDRO LLC STORES OIL IN AMOUNTS ACOVE 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.