Respondent accumulated organic hazardous waste on-site in one above ground carbon steel storage tank greater than 90 days, in violation of 40 CFR 262.17(a). EPA issued NOPVOC on April 1, 2021 offering pre-filing settlement of matter. Facility began negotiations with EPA thereafter. In the CA/FO facility agreed to store hazardous waste no greater than 90 days. Penalty reduced, owing to litigation risk.