Zenith Energy Cleveland Terminal (Zenith) owns and operates a bulk petroleum storage terminal
in Cleveland, Ohjo. Though there are a number of storage tanks at the site, Zenith owns thiree
internal floating roof gasoline storage tanks (Tanks 120, 121, and 122) that are subject to the
New Source Performance Standards for Storage Vessels for Petroleum Liquids for wnich
Construction, Reconstruction, or Modification Commenced after July 23, 1984 (NSPS Subpart
Kb). .Among other requirements, NSPS Subpart Kb requires owners and operators of storage
vessels with petroleum liquids with an internal floating roof that were constructed, reconstructed,
or modified after July 23, 1984 to form a continuous seal between the roof and the wall of the
tank. During an on-site inspection on August 29, 2018, EPA discovered excess emissions
escaping from the three storage tanks with the most from Tank 120. Further inspection by Zenith
revealed that Tank 120 had a missing seal around a portion of the intemal floating roof in
violation of NSPS Subpart Kb requirements. This CAFO assesses a penalty of $20,000 based on cooperation and Zenith's agreement to improve their floating roof checklist.