ON MAY 14, 2009, AN AUTHORIZED REPRESENTATIVE OF EPA CONDUCTED AN INSPECTION AT H.BULLUKIAN & SONS INC. ALTHOUGH H BULLUKIAN SONS INC STORES OIL IN AMOUNTS ABOVE THE THRESHOLDS REQUIRING THE PREPARATION AND IMPLEMENTATION OF A SPCC PLAN UNDER 40 C.F.R. PART 112, IT FAILED TO IMPLEMENT ITS SPCC PLAN. BECAUSE OF THE SIZE OF THE FACILITY AND OTHER FACTORS, EPA IS UTILIZING THE ESA ENFORCEMENT TOOL.