On September 19, 2013, an authorized respresentative of EPA conducted an SPCC inspection at VIP Tour and Charter Bus Company, a charter bus tour company and bus storage and maintenance facility. Although VIP Tour and Charter Bus Company 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 an adequate SPCC plan. Because the size of the facility and other factors, EPA is utilizing the ESA enforcement tool.