On May 14, 2007, and July 16, 2007, authorized representatives of EPA, conducted SPCC inspections at Pandolf-Perkins plant, and E.H. Perkins Construction, Inc. respectively. Although E.H. Perkins Construction, Inc. the owner of both facilities, 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 adequate SPCC plans. Because of the size of the facilities and other factors, EPA is utilizing the ESA enforcement tool.