ON JULY 21, 2005, AN AUTHORIZED REPRESENTATIVE OF EPA, CONDUCTED AN SPCC INSPECTION AT BUTTERWORTH & SCHECK, INC. ALTHOUGH BUTTERWORTH & SCHECK, INC. STORES OIL IN AMOUANTS ABOVE THE THRESHOLDS REQUIRING THE PREPARATION AND IMPLEMENTATION OF A SPCC PLAN UNDER 40 CFR PART 112, IT DID NOT HAVE AN ADEQUATE SPCC PLAN.