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 CAFO, HWRT replaced the seals on the external floating roof that were in non-compliance. The Consent Agreement and Final Order (CAFO) will require HWRT to pay a civil penalty of $33,889.
A concurrent ACO will require HWRT to develop a standard operating procedure for HWRT personnel to conduct seal inspections required by NSPS Ka.