HWRT operated an external floating roof on a storage tank with a primary seal that did not meet the gap requirements specified at 40 C.F.R. ? 60.112a(a)(1)(i)(A). Prior to issuing this ACO, HWRT replaced the seals on the external floating roof that were in non-compliance. A Consent Agreement and Final Order (CAFO) is also being issued that will require HWRT to pay a civil penalty of $33,889.
This ACO requires HWRT to develop a standard operating procedure for HWRT personnel to conduct seal inspections required by NSPS Ka and addresses the violations set forth in the Finding of Violation issued to HWRT on February 17, 2022.