Page 1 of 42 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Permit to Operate

*****DRAFT*****

United States Environmental Protection Agency, Region IX

Air Division

75 Hawthorne Street

San Francisco, CA 94105

DRAFT TITLE V PERMIT TO OPERATE

Permit Number: GU-OP 10-01

In accordance with the provisions of Title V of the Clean Air Act and 40 CFR Part 71 and 

applicable rules and regulations, 

Mobil Oil Guam, Inc.

Piti, Guam

is authorized to operate air emission units and to conduct other air pollutant emitting 

activities in accordance with the permit conditions listed in this permit. Terms and 

conditions not otherwise defined in this permit have the meaning assigned to them in the 

referenced regulations. All terms and conditions of the permit are enforceable by EPA and 

citizens under the Clean Air Act.

If any proposed control measure and/or equipment is not installed or properly operated and 

maintained, this will be considered a violation of the permit.

This permit is valid for a period of five (5) years and shall expire at midnight on the date five 

years after the issuance date unless a timely and complete renewal application has been 

submitted at least six months but not more than eighteen months prior to the date of 

expiration. The permit number cited above should be referenced in future correspondence 

regarding this facility.

Date Deborah Jordan

Director, Air Division

EPA Region IX
Page 2 of 42 Mobil Oil – Cabras Terminal Prepared: _DATE_

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Abbreviations and Acronyms

The Act Clean Air Act

bbl barrel (one petroleum barrel = 42 U.S. gallons)

CFR Code of Federal Regulations

EPA United States Environmental Protection Agency

EU emission unit

gal U.S. gallon

GEPA Guam Environmental Protection Agency

HAP hazardous air pollutant

ICE internal combustion engine

IEU insignificant emission unit

IFR internal floating roof

kPa kilopascal

L liter

mg milligram

MMBtu million British Thermal Units

MSDS material safety data sheet

MVAC motor vehicle air conditioners

NESHAP National Emission Standard for Hazardous Air Pollutants

PM particulate matter

ppm parts per million

psia pounds per square inch absolute

psig pounds per square inch, gauge pressure

RICE Reciprocating Internal Combustion Engine

SIP State Implementation Plan

SO2 sulfur dioxide

TOC total organic compounds

VFR vertical fixed roof

VOC volatile organic compounds

VOL volatile organic liquids
Page 3 of 42 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Permit to Operate

Table of Contents

Cover Page

Abbreviations and Acronyms

Contents

I. Source Information and Emission Units......................................................................................5

A. Source Information...................................................................................................................5

B. Emission Units...........................................................................................................................5

II. Standard Terms and Conditions ..................................................................................................6

A. Duty to Comply .......................................................................................................................6

B. Permit Shield ...........................................................................................................................6

C. Credible Evidence ...................................................................................................................6

D. Permit Actions and Expiration ..............................................................................................7

E. Changes not Requiring Permit Modification .......................................................................8

F. Inspection and Entry ..............................................................................................................8

G. Fragmentation.........................................................................................................................8

H. Property Rights.......................................................................................................................9

I. Severability ..............................................................................................................................9

J. Fees...........................................................................................................................................9

K. Document Submittal ...............................................................................................................9

L. Circumvention.........................................................................................................................9

III. General Requirements.................................................................................................................11

A. Work Practice Requirements...............................................................................................11

B. Monitoring and Testing........................................................................................................11

C. Record Keeping.....................................................................................................................13

D. Notification and Reporting...................................................................................................13

E. Payment of Fees and Reporting of Actual Emissions........................................................16

IV. Facility Specific Requirements ...................................................................................................19

A. Facility-wide Requirements from 40 CFR Part 63, Subpart R.........................................19

B. Requirements from Guam’s State Implementation Plan ..................................................19

Table IV.B.6 Particulate Matter Stack Emission Rate.............................................................21

Table IV.B.7 Particulate Matter Combustion of Fuel Emission Rate.....................................21

V. Emission Unit Specific Requirements: Summary Table ..........................................................25

Table V.1: Emission Units and Applicable Regulations/Summary Table ..............................25

VI. Emission Unit Specific Requirements: Floating Roof Storage Vessels...................................26
Page 4 of 42 Mobil Oil – Cabras Terminal Prepared: _DATE_

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A. Work Practices and Standards............................................................................................26

B. Monitoring and Testing........................................................................................................26

C. Recordkeeping and Reporting .............................................................................................26

VII. Emission Unit Specific Requirements: Fixed Roof Storage Tanks .........................................28

VIII. Emission Unit Specific Requirements: Truck Loading Racks.................................................29

A. Work Practices and Standards............................................................................................29

B. Monitoring and Testing........................................................................................................30

C. Recordkeeping and Reporting .............................................................................................34

IX. Emission Unit Specific Requirements: Internal Combustion Engines....................................37

A. Work Practices and Standards............................................................................................37

B. Recordkeeping and Reporting .............................................................................................38

X. Emission Unit Specific Requirements: Marine Tank Vessel Loading ....................................40

A. Work Practices and Standards............................................................................................40

B. Recordkeeping and Reporting .............................................................................................40

XI. Emission Unit Specific Requirements: Equipment Leaks........................................................41

A. Monitoring and Testing........................................................................................................41

B. Recordkeeping and Reporting .............................................................................................41
Page 5 of 42 Mobil Oil – Cabras Terminal Prepared: _DATE_

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I. Source Information and Emission Units

A. Source Information

Applicant Name Mobil Oil Guam, Inc.

Mailing Address 642 East Marine Corps Drive

Hagatna, Guam 96910

Facility Name Cabras Terminal

Facility Location 1189 Cabras Highway

Piti, Guam 

Responsible Official Charles Ewart, President, (671) 648-3653

Facility Contact Garet Olivares, Upper Pacific Islands Operations Manager, (671) 479-3256

SIC Code 5171, Petroleum Bulk Stations and Terminals

2007 NAICS Code 424710, Petroleum and Petroleum Products Bulk Stations and Terminals

Process Description Bulk Gasoline Terminal for distribution of gasoline and distillate products

Source Category Facility is classified as a major source for HAPs and VOCs

B. Emission Units

Location EU # Description Products 

Controlled Controls

Area A EU-1 ICE-3: 300 kW Cummins 

emergency diesel 

generator

Diesel None

Area C EU-2 Tank 20: IFR tank Gasoline and 

Distillate Fuel

Double wiper seal

EU-3 Tank 22: VFR tank Distillate Fuel None

EU-4 Tank 24: IFR tank Gasoline and 

Distillate Fuel

Double wiper seal

EU-5 Tank 25: VFR tank Distillate Fuel None

EU-6 Tank 28: VFR tank Distillate Fuel None

EU-7 Tank 29: IFR tank Gasoline and 

Distillate Fuel

Double wiper seal

EU-8 Three-bay truck loading 

rack with Vapor 

Collection System (VCS)

Gasoline and 

Distillate Fuel

John Zink carbon 

adsorption vapor 

recovery unit (VRU)

EU-9 ICE-1: 300 kW Caterpillar 

emergency diesel 

generator

Diesel None

D Lot EU-10 ICE-2: 300 kW Caterpillar 

emergency diesel 

generator

Diesel None

Golf Pier EU-11 Submerged fill loading of 

gasoline and distillate fuel 

to local coastal tankers

Gasoline and 

Distillate fuel

None

FacilityWide

EU-12 Equipment in gasoline 

service

None
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II. Standard Terms and Conditions

A. Duty to Comply

1. The permittee must comply with all conditions of this permit. Any permit noncompliance 

constitutes a violation of the Act and is grounds for enforcement action; for permit 

termination, revocation and reissuance, or modification; or for denial of a permit renewal 

application. [40 CFR § 71.6(a)(6)(i)]

2. It shall not be a defense for a permittee in an enforcement action that it would have been 

necessary to halt or reduce the permitted activity in order to maintain compliance with the 

conditions of this permit. [40 CFR § 71.6(a)(6)(ii)]

B. Permit Shield

1. Compliance with the conditions of this permit shall be deemed compliance with the 

applicable requirements, specifically identified in the permit and on which the conditions 

were based, as of the date of permit issuance. [40 CFR § 71.6(f)(1)(i)]

2. The permittee has requested and EPA is granting a permit shield for the following 

requirements which are deemed inapplicable at the time of permit issuance:

[40 CFR § 71.6(f)(1)(ii)]

a. 40 CFR part 60, subpart IIII: Standards of performance for Stationary 

Compression Ignition Internal Combustion Engines does not apply to EU-1, EU9, EU-10, and other existing compression ignition internal combustion engines at 

the permitted facility for which construction, modification, or reconstruction 

commenced prior to July 11, 2005; and

b. 40 CFR part 63, subpart BBBBBB: NESHAP for Source Category: Gasoline 

Distribution Bulk Terminals, Bulk Plants, and Pipeline Terminals does not apply 

facility-wide.

3. Nothing in this permit shall alter or affect the following: [40 CFR § 71.6(f)(3)]

a. The provisions of section 303 of the Act (emergency orders), including the 

authority of the Administrator under that section;

b. The liability of an owner or operator of a source for any violation of applicable 

requirements prior to or at the time of permit issuance;

c. The applicable requirements of the acid rain program, consistent with section 

408(a) of the Act; or

d. The ability of EPA to obtain information from a source pursuant to section 114 of 

the Act.

C. Credible Evidence
Page 7 of 42 Mobil Oil – Cabras Terminal Prepared: _DATE_

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1. For the purpose of submitting compliance certifications in accordance with Condition 

III.D.3 of this permit, or establishing whether or not a person has violated or is in 

violation of any requirement of this permit, nothing shall preclude the use, including the 

exclusive use, of any credible evidence or information relevant to whether a source would 

have been in compliance with applicable requirements if the appropriate performance or 

compliance test or procedure had been performed. 

[Sections 113(a) and 113(e)(1) of the Act, 40 CFR §§ 51.212, 52.12, 52.33, 60.11(g), and 

61.12]

D. Permit Actions and Expiration

1. This permit may be modified, revoked, reopened and reissued, or terminated for cause. 

The filing of a request by the permittee for a permit modification, revocation and 

reissuance, or termination, or of a notification of planned changes or anticipated 

noncompliance does not stay any permit condition. [40 CFR § 71.6(a)(6)(iii)]

2. This permit may be reopened and revised by EPA following the procedures specified in

40 CFR § 71.7(f)(2) and (3) under any of the following circumstances: [40 CFR § 

71.7(f)(1)]

a. Additional applicable requirements under the Act become applicable and the 

remaining permit term is three or more years.

b. Additional requirements (including excess emissions requirements) become 

applicable to an affected source under the acid rain program.

c. EPA determines that the permit contains a material mistake or that inaccurate 

statements were made in establishing the emissions standards or other terms or 

conditions of the permit.

d. EPA determines that the permit must be revised or revoked to assure compliance 

with the applicable requirements.

3. This permit is issued for a fixed term and will expire five years from the date of signature 

unless it is revoked or superseded by another permit issued by EPA or an approved or 

delegated authority. [40 CFR § 71.6(a)(11)(ii)-(iii)]

4. Permit expiration terminates the permittee’s right to operate the source unless a complete

permit renewal application has been submitted at least six months but not more than 18 

months prior to the expiration date listed on the signature page of this permit. If a 

complete permit renewal application has been submitted in a timely manner, then the 

permit and any permit shield that may have been granted shall not expire but shall remain 

in effect until the renewal permit is issued or the renewal application is denied. 

[40 CFR §§ 71.5(a)(1)(iii), 71.7(b), 71.7(c)(1)(ii), and 71.7(c)(3)]
Page 8 of 42 Mobil Oil – Cabras Terminal Prepared: _DATE_

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E. Changes not Requiring Permit Modification

1. The permittee may make certain changes not addressed or prohibited by the permit 

provided the following requirements are met: [40 CFR § 71.6(a)(12)]

a. Each change meets all applicable requirements and does not violate any existing 

permit term or condition;

b. The permittee provides written notice as required by Condition III.D.5;

c. The change shall not qualify for the shield under 40 CFR § 71.6(f) and Conditions 

II.B.1, II.B.2, and II.B.3; and

d. The permittee keeps a record required by Condition III.C.2.

2. The permittee is allowed to make section 502(b)(10) of the Act changes without requiring 

a permit revision, if the changes are not modifications under any provision of title I of the 

Act and the changes do not exceed the emissions allowable under the permit. For each 

such change, written notification as required by Condition III.D.6 shall be submitted to 

EPA. Such changes are not covered by a permit shield provided under 40 CFR § 71.6(f) 

and Conditions II.B.1 through II.B.3. [40 CFR § 71.6(a)(13)(i)]

3. No permit revision shall be required under any approved economic incentives, 

marketable permits, emissions trading and other similar programs or processes for 

changes that are provided for in this permit. [40 CFR § 71.6(a)(8)]

F. Inspection and Entry

1. Upon presentation of credentials and other documents as may be required by law, the 

permittee shall allow EPA, GEPA, or authorized representatives to perform the 

following:

[40 CFR § 71.6(c)(2)]

a. Enter upon the permittee's premises where a part 71 source is located or 

emissions-related activity is conducted, or where records must be kept under the 

conditions of the permit;

b. Have access to and copy, at reasonable times, any records that must be kept under 

the conditions of the permit;

c. Inspect at reasonable times any facilities, equipment (including monitoring and air 

pollution control equipment), practices, or operations regulated or required under 

the permit; and

d. As authorized by the Act, sample or monitor at reasonable times substances or 

parameters for the purpose of assuring compliance with the permit or applicable 

requirements.

G. Fragmentation
Page 9 of 42 Mobil Oil – Cabras Terminal Prepared: _DATE_

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1. Fragmentation, which divides ownership of an operation within the same facility among 

various owners where there is no real change in control, will not affect the applicability

of the provisions of 40 CFR part 63. [40 CFR § 63.4(c)]

H. Property Rights

1. This permit does not convey any property rights of any sort or any exclusive privilege. 

[40 CFR § 71.6(a)(6)(iv)]

I. Severability

1. The provisions of this permit are severable, and in the event of any challenge to any 

portion of this permit, or if any portion is held invalid, the remaining permit conditions 

shall remain valid and in force. [40 CFR § 71.6(a)(5)]

J. Fees

1. The permittee shall pay annual fees in accordance with Condition III.E.1. 

[40 CFR §§ 71.6(a)(7) and 71.9(a)]

K. Document Submittal

1. Any document required to be submitted under this permit shall contain a certification by 

a responsible official of truth, accuracy, and completeness. This certification and any 

other certification required under this part shall state that, based on information and belief 

formed after reasonable inquiry, the statements and information in the document are true, 

accurate, and complete. Unless otherwise specified in this permit, any document required 

to be submitted under this permit shall be submitted to: [40 CFR §§ 71.5(d), 71.6(c)(1)]

Director, Enforcement Division (Attn: ENF-2-1)

U. S. Environmental Protection Agency, Region IX

75 Hawthorne Street

San Francisco, CA 94105

L. Circumvention

1. The permittee shall not build, erect, install, or use any article, machine, equipment, or 

process to conceal an emission that would otherwise constitute noncompliance with a 

relevant standard. Such concealment includes, but is not limited to: [40 CFR §§ 60.12 

and 63.4(b)]

a. The use of diluents to achieve compliance with a relevant standard based on the 

concentration of a pollutant in the effluent discharged to the atmosphere; and
Page 10 of 42 Mobil Oil – Cabras Terminal Prepared: _DATE_

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b. The use of gaseous diluents to achieve compliance with a relevant standard for 

visible emissions.
Page 11 of 42 Mobil Oil – Cabras Terminal Prepared: _DATE_

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III. General Requirements

A. Work Practice Requirements

1. The permittee shall: [40 CFR § 71.6(c)(3)]

a. Continue to comply with all applicable requirements with which the permittee is 

in compliance at the time of permit issuance; 

b. Comply on a timely basis with all applicable requirements that become effective 

during the permit term; and

c. Comply with applicable requirements with which the permittee is not in 

compliance at the time of permit issuance according to the schedule in the permit 

application.

2. The permittee shall comply with 40 CFR part 61, subpart M for asbestos removal and 

disposal when conducting any renovation or demolition at the facility. 

[40 CFR part 61, subpart M]

3. The permittee shall comply with the chemical accident release provisions of 40 CFR part 

68 no later than the following dates: [40 CFR § 68.10]

a. Three years after the date on which a regulated substance is first listed under 40 

CFR § 68.130; or

b. The date on which a regulated substance is first present above a threshold quantity 

in a process.

4. Except as provided for motor vehicle air conditioners (MVACs) in 40 CFR part 82, 

subpart B, the permittee shall comply with the stratospheric ozone and climate protection 

standards for recycling and emissions reduction pursuant to 40 CFR part 82, subpart F.

[40 CFR part 82, subpart F]

5. When service on motor vehicles involves ozone-depleting substances in MVACs, the 

permittee shall comply with all the applicable requirements for stratospheric ozone and 

climate protection as specified in 40 CFR part 82, subpart B. [40 CFR part 82, subpart B]

B. Monitoring and Testing

1. In addition to the specific testing requirements contained in the emission unit sections of 

this permit, the permittee shall comply with the following generally applicable testing 

requirements unless otherwise specified in the applicable regulation or emission unit 

specific condition requiring the test, or EPA determines otherwise in writing:

[40 CFR §§ 60.8(b)-(g), 63.7(b)-(g), 71.6(a)(3) and 71.6(c)(1)]

a. Testing shall be performed according to an EPA approved test plan that includes 

and addresses the following elements:
Page 12 of 42 Mobil Oil – Cabras Terminal Prepared: _DATE_

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1. Purpose and scope of testing;

2. Source description and mode of operation during the test;

3. Schedules and dates of testing;

4. Process data to be collected during the test;

5. Sampling and analysis procedures;

6. Sampling locations;

7. Test methods;

8. Analysis procedures and laboratory identification;

9. Quality assurance;

10. Calibration procedures and frequency;

11. Sample recovery and field documentation;

12. Chain of custody procedures;

13. QA/QC project flow chart;

14. Data processing and reporting

15. Description of data handling and QC procedures; and

16. Report content and timing.

b. The source shall be operated at a capacity at least 90 percent but no more than 100 

percent of design capacity during each test run.

c. All performance tests and data reduction shall be conducted in accordance with 

the procedures in the appendices of 40 CFR part 51, 60, 61, or 63.

d. Only regular operating staff may adjust the processes or emission control device 

parameters during a compliance source test. No adjustments are to be made 

within two hours of the start of the tests. Any operating adjustments made during 

a source test, that are a result of consultation during the tests with source testing 

personnel, equipment vendors, or consultants, may render the source test invalid.

e. Each source test shall consist of at least three test runs and the emission results 

shall be reported as the arithmetic average of all valid test runs and in the terms of 

the emission limit. There must be at least two valid test runs for the test to be 

considered valid.

2. The permittee shall provide performance testing facilities as follows:

[40 CFR §§ 60.8(b)-(g), 63.7(b)-(g), 71.6(a)(3) and 71.6(c)(1)]

a. Sampling ports adequate for test methods applicable to such source. This 

includes:

1. Constructing the air pollution control system such that volumetric flow 

rates and pollutant emission rates can be accurately determined by 

applicable test methods and procedures; and

2. Providing a stack or duct free of cyclonic flow during performance tests, 

as demonstrated by applicable test methods and procedures;

b. Safe sampling platform(s);

c. Safe access to sampling platform(s);

d. Utilities for sampling and testing equipment; and
Page 13 of 42 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Permit to Operate

e. Any other facilities that the Administrator deems necessary for safe and adequate 

testing of a source.

C. Record Keeping

1. The permittee shall keep records of required monitoring information that include the 

following: [40 CFR § 71.6(a)(3)(ii)(A)]

a. The date, place as defined in the permit, and time of sampling or measurements;

b. The date(s) analyses were performed;

c. The company or entity that performed the analyses;

d. The analytical techniques or methods used;

e. The results of such analyses; and

f. The operating conditions as existing at the time of sampling or measurement.

2. The permittee shall keep a record describing off-permit changes allowed by Condition 

II.E.1 made at the source that result in emissions of a regulated air pollutant subject to an 

applicable requirement, but not otherwise regulated under the permit, and the emissions 

resulting from those changes. [40 CFR § 71.6(a)(12)(iv)]

3. The permittee shall retain records of all required monitoring data and support information 

for a period of at least 5 years from the date of the monitoring sample, measurement, 

report, or application. Support information includes all calibration and maintenance 

records and all original strip-chart recordings for continuous monitoring instrumentation, 

and copies of all reports required by the permit.

[40 CFR §§ 60.7(f), 60.116b(a), 60.505(d) and (f), 63.4(a)(2), 63.10(b)(1), 63.567(j)(2),

63.6660, and 71.6(a)(3)(ii)(B)]

D. Notification and Reporting

1. The permittee, upon becoming aware that any relevant facts were omitted or incorrect 

information was submitted in the permit application, shall promptly submit such 

supplementary facts or corrected information. [40 CFR §§ 63.9(j) and 71.5(b)]

2. The permittee shall submit to EPA reports of any required monitoring for each six month 

period from January 1 to June 30 and from July 1 to December 31. Such reports shall be 

uploaded and electronically submitted to EPA no later than the 30th day following the 

end of the reporting period. The reports must be submitted to EPA through EPA's 

WebFire database by using the Compliance and Emissions Data Reporting Interface 

(CEDRI) that is accessed through the EPA's Central Data Exchange (CDX) Webpage 

located at www.epa.gov/CDX. The permittee is required to register at the CDX Webpage 

for CDX/CEDRI access to submit reporting data electronically for EPA's review and 

approval. The permittee is required to maintain registration at the CDX Webpage for 
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submittal of electronic reports as a requirement of this permit. The permittee must use the 

appropriate electronic reporting form in CEDRI or provide an alternative electronic 

reporting form consistent with the EPA reporting form output format. All deviations from 

permit requirements must be clearly identified in such reports. However, if the 

appropriate electronic reporting form specified herein is not available in CEDRI at the 

time that the report is due, the written report must be submitted to the Administrator at 

the appropriate address. [40 CFR § 71.6(a)(3)(iii)(A)]

3. The permittee shall submit to EPA an annual certification of compliance with permit 

terms and conditions, including emission limitations, standards, or work practices, 

electronically through the CDX/CEDRI Webpage as outlined in Condition III.D.2. The 

annual certificate of compliance shall be uploaded and submitted electronically through 

the CDX/CEDRI Webpage no later than January 30 of each year and covering the permit 

or permits in effect during the previous calendar year. However, if the appropriate 

electronic reporting form specified herein is not available in CEDRI at the time that the 

report is due, the written report must be submitted to the Administrator at the appropriate 

address. The annual certificate of compliance shall include the following: [40 CFR §§

63.9(h)(3), 63.428(c)(2) and 71.6(c)(5)]

a. The identification of each term or condition of the permit that is the basis of the 

certification;

b. The identification of the method(s) or other means used by the permittee for 

determining the compliance status with each term and condition during the 

certification period. Such methods and other means shall include, at a minimum, 

the monitoring required by this permit; and

c. The status of compliance with the terms and conditions of the permit for the 

period covered by the certification, including whether compliance during the 

period was continuous or intermittent. The certification shall be based on the 

method or means designated in Condition III.D.3.b. The certification shall 

identify each deviation and take it into account in the compliance certification.

4. The permittee shall promptly report to EPA deviations from any permit requirements, as 

defined in 40 CFR § 71.6(a)(3)(iii)(C), including those attributable to upset conditions as 

defined in the permit, the probable cause of such deviations, and any corrective actions or 

preventive measures taken. Where the underlying applicable requirement contains a 

definition of prompt or otherwise specifies a time frame for reporting deviations, that 

definition or time frame shall govern. Where the underlying applicable requirement fails 

to address the time frame for reporting deviations, reports of deviations shall be 

submitted to the permitting authority based on the following schedule:

[40 CFR § 71.6(a)(3)(iii)(B)]

a. For emissions of a hazardous air pollutant or a toxic air pollutant (as identified in 

an applicable regulation) that continue for more than an hour in excess of permit 

requirements, the report must be made with 24 hours of the occurrence.
Page 15 of 42 Mobil Oil – Cabras Terminal Prepared: _DATE_

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b. For emissions of any regulated air pollutant, excluding hazardous or toxic air 

pollutants (as identified in an applicable regulation), that continue for more than 

two hours in excess of permit requirements, the report must be made within 48 

hours.

c. If any of the conditions are met as described in Condition III.D.4.a or III.D.4.b, 

the permittee must notify EPA by telephone or facsimile based on the timetable 

listed in these conditions. A written notice, certified consistent with 40 CFR 

§71.5(d), must be submitted within ten (10) working days of the occurrence.

d. For all other deviations from permit requirements, the report shall be contained in 

the semiannual monitoring report submitted in accordance with the timeframe 

given in Condition III.D.2.

5. The permittee shall provide contemporaneous written notice to EPA of each off-permit 

change allowed by Condition II.E.1, except for changes that qualify as insignificant 

under 40 CFR § 71.5(c)(11). Such written notice shall describe each such change, 

including the date, any change in emissions, pollutants emitted, and any applicable 

requirement that would apply as a result of the change. [40 CFR § 71.6(a)(12)(ii)]

6. For each section 502(b)(10) of the Act change allowed by Condition II.E.2, the permittee

shall provide written notification to EPA at least seven days before the proposed change 

which includes a brief description of the change within the permitted facility, the date on 

which the change will occur, any change in emissions, and any permit term or condition 

that is no longer applicable as a result of the change. [40 CFR § 71.6(a)(13)(i)]

7. The permittee shall furnish to EPA, within a reasonable time, any information that EPA 

may request in writing to determine whether cause exists for modifying, revoking and 

reissuing, or terminating the permit, or to determine compliance with the permit. Upon 

request, the permittee shall also furnish to EPA copies of records that are required to be 

kept pursuant to the terms of the permit, including information claimed to be confidential. 

Information claimed to be confidential must be accompanied by a claim of confidentiality 

according to the provisions of 40 CFR part 2, subpart B. 

[40 CFR §§ 71.6(a)(6)(v) and 71.5(a)(3)]

8. The permittee shall submit the following notifications and reports, in a timely manner, or 

a compliance test, including monitoring system performance test, may be considered 

invalid: [40 CFR §§ 60.8(b)-(g), 63.9(e) and (g), 63.10(d)(2), 71.6(a)(3) and 71.6(c)(1)]

a. Written notification of the intention to perform a compliance test at least 60 days 

before the test is schedule to begin;

b. A written test plan that addresses the elements in Condition III.B.1 at least 60 

days before the test is scheduled to begin; and

c. A test report that addresses adherence to the written test plan submitted in 

accordance with Condition III.B.1 and includes records of data required to be 

monitored during the test by the test plan, applicable regulation, or emission unit 
Page 16 of 42 Mobil Oil – Cabras Terminal Prepared: _DATE_

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specific conditions submitted electronically through the CDX/CEDRI Webpage 

no later than 60 days after completion of the test. However, if the reporting form 

specified herein is not available in CEDRI at the time that the report is due, the 

written report must be submitted to the Administrator at the appropriate address.

E. Payment of Fees and Reporting of Actual Emissions

1. The permittee shall pay annual fees and submit actual emission reports in accordance 

with the procedures described below. Failure to pay fees in a timely manner shall subject 

the permittee to assessment of penalties and interest in accordance with 40 CFR § 71.9(l):

[40 CFR §§ 71.9(a), 71.9(h)(1)-(3), 71.9(j), 71.9(k), and 71.9(l)]

a. The permittee shall pay the annual permit fee and submit the fee filing form by 

October 22 of each year.

b. The fee payment shall be in United States currency and shall be paid by money 

order, bank draft, certified check, corporate check, or electronic funds transfer 

payable to the order of the U.S. Environmental Protection Agency and sent to one 

of the two addresses below:

Address for regular mail through US Postal Service

U.S. Environmental Protection Agency

FOIA and Miscellaneous Payments

Cincinnati Finance Center

PO Box 979078

St. Louis, MO 63197-9000

Address for Express Delivery (or when a physical address is required)

U.S. Bank 

Government Lockbox 979078 US EPA FOIA & Misc. Payments 

1005 Convention Plaza

Mail Station SL-MO-C2GL 

St. Louis, MO 63101

c. The permittee shall send an updated fee calculation worksheet and confirmation 

of fee payment to EPA Region 9 simultaneous with fee payment at the following 

address:

Director, Air Division (Attn: AIR-3)

U.S. Environmental Protection Agency, Region IX

75 Hawthorne Street

San Francisco, CA 94105
Page 17 of 42 Mobil Oil – Cabras Terminal Prepared: _DATE_

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d. If EPA determines that a source has completed the fee calculation work sheet 

incorrectly, the permitting authority shall bill the applicant for the corrected fee or 

credit overpayments to the source’s account.

e. The permittee shall calculate the fee using the following method:

1. The annual emissions fee shall be calculated by multiplying the total tons 

of actual emissions of all “regulated pollutants (for fee calculation)” 

emitted from the source by the presumptive emissions fee (in dollars/ton) 

in effect at the time of calculation.

a. “Actual emissions” means the actual rate of emissions in tpy of 

any regulated pollutant (for fee calculation), as defined in 40 CFR 

§ 71.2, emitted from a Part 71 source over the preceding calendar 

year. Actual emissions shall be calculated using each emissions 

unit’s actual operating hours, production rates, in-place control 

equipment, and types of materials processed, stored, or combusted 

during the preceding calendar year.

b. Actual emissions shall be computed using methods required by the 

permit for determining compliance, such as monitoring or source 

testing data.

c. If actual emissions cannot be determined using the compliance 

methods in the permit, the permittee shall use other federally 

recognized procedures.

2. The permittee shall exclude the following emissions from the calculation 

of fees:

a. The amount of actual emissions of each regulated pollutant (for fee 

calculation) that the source emits in excess of 4,000 tons per year;

b. Actual emissions of any regulated pollutant (for fee calculation) 

already included in the fee calculation; and

c. The quantity of actual emissions (for fee calculation) of 

insignificant activities defined in 40 CFR § 71.5(c)(11)(i) or of 

insignificant emissions levels from emissions units identified in the 

permittee’s application pursuant to 40 CFR § 71.5(c)(11)(ii).

d. Fee calculation worksheets shall be certified as to truth, accuracy, 

and completeness by a responsible official.

e. If the permittee is notified by EPA of additional amounts due, the 

permittee shall remit full payment within 30 days of receipt of the 

invoice.

f. If the permittee thinks that the assessed fee is in error, the 

permittee shall provide a written explanation of the alleged error to 

EPA along with the assessed fee.
Page 18 of 42 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Permit to Operate

g. The permitting authority shall, within 90 days of receipt of the 

correspondence, review the data to determine whether the assessed 

fee was in error. If an error was made, the overpayment shall be 

credited to the account of the part 71 source.

2. The permittee shall retain, in accordance with Condition III.C.3, all work sheets and other 

materials used to determine fee payments. Records shall be retained for 5 years following 

the year in which the emissions data is submitted. [40 CFR § 71.9(i)]
Page 19 of 42 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Permit to Operate

IV. Facility Specific Requirements

A. Facility-wide Requirements from 40 CFR Part 63, Subpart R

1. The permittee shall not allow gasoline to be handled in a manner that would result in 

vapor releases to the atmosphere for extended periods of time. Measures to be taken 

include, but are not limited to, the following: [40 CFR § 63.424(g)]

a. Minimizing gasoline spills

b. Cleaning up spills as expeditiously as practicable;

c. Covering all open gasoline containers with a gasketed seal when not in use; and

d. Minimizing gasoline sent to open waste collection systems that collect and 

transport gasoline to reclamation and recycling devices, such as oil/water 

separators.

2. At all times, including periods of startup, shutdown and malfunction, the permittee must 

operate and maintain any affected source, including associated air pollution control 

equipment and monitoring equipment, in a manner consistent with safety and good air 

pollution control practices for minimizing emissions. [40 CFR §§ 63.6(e)(1)(i) and 

63.6605(a)]

3. Operation and maintenance requirements established pursuant to section 112 of the Act 

are enforceable independent of emissions limitations or other requirements in relevant 

standards. [40 CFR § 63.6(e)(1)(iii)]

B. Requirements from Guam’s State Implementation Plan

1. GEPA may require the owner or operator of any air contaminant source to install, use, 

and maintain such monitoring equipment, sample such emissions with methods as GEPA 

shall prescribe, establish and maintain such records, and make such periodic emission 

reports as required in Condition IV.B.2. [Guam SIP Reg. 4.1, 46 FR 26303, 05/12/1981]

2. Stationary source emission reporting procedure to GEPA:

[Guam SIP Reg. 4.2(a)-4.2(c), 46 FR 26303, 05/12/1981]

a. The owner or operator of any stationary source shall, upon notification from 

GEPA, maintain records of the nature and amounts of emissions from such source 

and/or any other information as may be deemed necessary by GEPA to determine 

whether such source is in compliance with applicable emissions limitations or 

other requirements.

b. The information recorded shall be summarized each month and reported to GEPA 

on forms furnished by GEPA and shall be submitted within fifteen (15) days after 

the end of the month, except that the initial reporting period shall commence on 

the date GEPA issues notification of the record-keeping requirement.
Page 20 of 42 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Permit to Operate

c. Information recorded by the owner or operator and copies of the summarizing

reports submitted to GEPA shall be retained by the owner or operator for two 

years after the date on which the pertinent report is submitted.

3. In the case of shutdown of air pollution control equipment for necessary scheduled 

maintenance, the intent to shutdown such equipment shall be reported to GEPA in writing 

at least twenty-four (24) hours prior to the planned shutdown. Such prior notice shall 

include, but is not limited to the following: [Guam SIP Reg. 4.3, 46 FR 26303, 

05/12/1981]

a. Identification of the specific facility to be taken out of service as well as its 

location and permit number.

b. The expected length of time that the air pollution control equipment will be out of 

service.

c. The nature and quantity of emissions of air contaminants likely to occur during 

the shutdown period.

d. Measures such as the use of off-shift labor and equipment that will be taken to 

minimize the length of the shutdown period.

e. The reasons that it would be impossible or impractical to shut down the source 

operation during the maintenance period.

4. In the event that any emission source, air pollution control equipment, or related facility 

malfunctions, breaks down or will be shut down in such a manner as to cause excess 

emission of air contaminants, it is a violation of Guam’s regulations and subject to 

prosecution. In order to enable GEPA to carry out their statutory duties, the owner or 

operator of the stationary source is required to furnish GEPA with the following 

information within ten (10) days: (1) identification of emission points; (2) the magnitude 

of the excess emissions; (3) the identity of the process or control equipment causing the 

excess emissions; (4) the cause and nature of excess emissions; and (5) a description of 

the steps taken by the owner or operator of the subject stationary source to remedy the 

situation causing the excess emissions, prevent a recurrence and limit the excess 

emissions. Nothing in this condition relieves the source of the obligation to attain and 

maintain the national ambient air quality standards nor precludes GEPA from initiating 

any appropriate actions under sections 57106, 57107, and 57108 of the Guam Air 

Pollution Control Act.

[Guam SIP Reg. 4.4, 46 FR 26303, 05/12/1981]

5. No person shall dispose of combustible refuse by open burning or cause, suffer, allow, or 

permit open burning of refuse including grass, weeds, wire, twigs, branches, insulation, 

vehicle bodies and their contents, paper, garbage, tires, waste materials, tar products, 

rubber products, oil, and similar smoke producing materials, within the territorial limits 

of Guam. [Guam SIP Reg. 6.1, 37 FR 10842, 05/31/1972]
Page 21 of 42 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Permit to Operate

6. No person shall cause, suffer, allow or permit the emission of particulate matter in any 

one hour from any process industry in excess of the amount show in Table IV.B.6 for the 

process weight allocated to such source. For the purpose of this condition, the total 

process weight from all similar process units at a plant or premises shall be used for 

determining the maximum allowable emission of particulate matter that passes through a 

stack or stacks. [Guam SIP Reg. 7.1 and 7.4, 46 FR 26303, 05/12/1981]

Table IV.B.6 Particulate Matter Stack Emission Rate

Process weight rate (lbs/hr) Emission rate (lbs/hr)

50 0.36

100 0.55

500 1.53

1,000 2.25

5,000 6.34

10,000 9.73

20,000 14.99

60,000 29.60

80,000 31.19

120,000 33.28

160,000 34.85

200,000 36.11

400,000 40.35

1,000,000 46.72

Interpolation: E = 3.59 P0.62, P ≤ 30 or E = 17.31 P0.16, P > 30; 

where E = emissions in lbs/hr and P = process weight rate in tons per hour

7. No person shall cause, suffer, allow or permit the emission of particulate matter resulting 

from the combustion of fuel in excess of the quantity set forth in the Table IV.B.7. 

[Guam SIP Reg. 7.5, 46 FR 26303, 05/12/1981]

Table IV.B.7 Particulate Matter Combustion of Fuel Emission Rate

Operating rate in MMBtu/hr Allowable particulate emission rate in 

lb/MMBtu

5 0.70

10 0.60

100 0.35

250 0.28

500 0.24

1,000 0.21

Interpolation: Y = 1.02X – 0.231, 1 ≤ X ≤ 1,000; 

where Y = allowable particulate emission rate in lb/MMBtu and X = operating rate in MMBtu/hr

8. No person shall cause, suffer, allow or permit the emission of fugitive dust from any 

source, in an amount which violates the Standards and Regulations. 

[Guam SIP Reg. 8.1, 43 FR 48638, 12/19/1978]
Page 22 of 42 Mobil Oil – Cabras Terminal Prepared: _DATE_

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9. No person shall cause or permit the discharge of visible emissions beyond the lot line of 

the property, or the boundaries of the buffer zone if applicable, on which the emissions 

originate. [Guam SIP Reg. 8.2, 43 FR 48638, 12/19/1978]

10. GEPA may approve alternate controls for fugitive dust other than those specified in the 

following conditions upon the written request of the owner or operator and upon a 

determination of the adequacy of any such alternative controls. Applications shall 

describe the proposed alternative controls and demonstrate that applicable regulations and 

standards will not be violated. [Guam SIP Reg. 8.3, 46 FR 26303, 05/12/1981]

11. When dust, noxious gas or vapor, odor or any combination thereof escape from the 

processing, handling, or storage of any material in a quantity as to cause a nuisance or to 

cause or contribute to a violation of any applicable regulation or ambient air quality 

standard, GEPA may order that the source of these emissions be tightly enclosed and that 

the venting of such enclosure be controlled to the extent necessary to meet the Standards 

and Regulations. Alternate control measures submitted to GEPA in compliance with such 

orders shall comply with Condition IV.B.10. [Guam SIP Reg. 8.4(a), 46 FR 26303, 

05/12/1981]

12. All crushing, aggregate screening and conveying operations of material likely to become 

airborne shall be enclosed and the venting of such enclosure shall be controlled to the 

extent necessary to prevent visible emissions or the violation of any Standard or 

Regulation. 

[Guam SIP Reg. 8.4(b), 46 FR 26303, 05/12/1981]

13. Stockpiling of materials that are likely to become airborne shall be enclosed or the 

surface of such stockpiles stabilized through compacting, sprinkling with water, 

chemical, or asphalt sealing. [Guam SIP Reg. 8.4(c), 46 FR 26303, 05/12/1981]

14. All loads carried by motor vehicles shall be adjusted, secured, covered, contained or 

otherwise treated so as to prevent loss or spillage of such material and/or the generation 

of airborne dust. [Guam SIP Reg. 8.4(d), 46 FR 26303, 05/12/1981]

15. All construction operations including but not limited to the grading or leveling of land, 

earthmoving, excavation, demolition, or the movement of trucks or construction 

equipment over cleared land or temporary access or haul roads shall water all vehicle 

travel areas or roads at the site for dust suppression a minimum of the beginning of every 

two operating hours with a minimum watering rate for each application of 0.5 gallons per 

square yard, or other equivalent method approved by GEPA as needed to prevent visible 

emissions or contribute to the violation of applicable Standards or Regulations. 

[Guam SIP Reg. 8.5(a), 46 FR 26303, 05/12/1981]
Page 23 of 42 Mobil Oil – Cabras Terminal Prepared: _DATE_

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16. All sandblasting operations which [sic, that] can be conducted within an enclosed area 

shall be done so and the venting of such enclosure shall be controlled to the extent 

necessary to prevent visible emissions as prohibited by these Standards and Regulations. 

All sandblasting which [sic, that] cannot be done within an enclosure shall be conducted 

using wet sand. [Guam SIP Reg. 8.5(b) and (c), 46 FR 26303, 05/12/1981]

17. Use of vegetation, including planting, mulch or selective retention of natural vegetation, 

as ground cover, providing windbreaks, sprinkling with water, and covering or 

compacting the ground surface shall be used to prevent visible emissions or the violation 

of any ambient air quality Standard or Regulation where topsoil has been disturbed 

during the clearing of land. No owner, operator, or lessee of any real property in the 

Territory of Guam shall allow disturbed topsoil to remain undeveloped, unplanted, 

untreated, or otherwise uncovered for a period exceeding two months. [Guam SIP Reg. 

8.6, 46 FR 26303, 05/12/1981]

18. All roads, road easements, and parking lots, which are a source of fugitive dust creating 

violation of the ambient are quality standards for particulates, shall be treated or 

improved in a manner that is satisfactory to GEPA. Where permanent corrections 

(paving) are not undertaken, the schedule for treatment with water, oil, or emulsified 

asphalt shall be adjusted as necessary to maintain compliance. The following measures 

shall be taken for curtailment of fugitive dust: [Guam SIP Reg. 8.7, 46 FR 26303, 

05/12/1981]

a. All unpaved public and private roads within the Territory of Guam which average 

a vehicle load of 50 or more vehicles per day shall be paved.

b. All unpaved public and private roads within the Territory of Guam which average 

a vehicle load of 25 or more vehicles per day shall be sealed with oil at least every 

three months.

c. All paved public and private roads within the Territory of Guam which average a 

vehicle load of 100 or more vehicles per day shall have paved shoulders.

d. All public and private roads within the Territory of Guam which average a vehicle 

load of 50 or more vehicles per day shall have the shoulders oiled at least every 

three months.

e. Sprinkling with water, oil, or emulsified asphalt shall be used to control the 

emission of dust from the construction, maintenance, or use of unpaved roads or 

road shoulders.

f. All public and private road easements and storm drainage ditches shall be 

mulched and seeded.

g. Earth or other material which has been deposited on a paved road or road shoulder 

by trucking, earth moving equipment, erosion, or landslide shall be promptly 

removed.

h. All parking lots with an area exceeding one fifth of an acre shall be paved.

i. All other parking lots shall be oiled at least once every three months.
Page 24 of 42 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Permit to Operate

19. Visible emission restrictions for stationary sources:

[Guam SIP Reg.10.1, 46 FR 26303, 05/12/1981]

a. No person shall continuously discharge into the atmosphere from any single 

source of emissions whatsoever any air contaminant of a shade of density equal to 

or darker than that designated as No. 1 on the Ringelmann Chart or 20 percent 

opacity.

b. No person may discharge into the atmosphere from any single source of emission, 

for a period or periods aggregating more than three minutes in any 60 minutes, air 

contaminants of a shade of density darker than No. 3 on the Ringelmann Chart or 

60 percent opacity, except for operations specifically authorized by the board 

through a Variance as provided by the Air Pollution Control Act.

20. No person shall discharge into the atmosphere, or cause to be discharged into the 

atmosphere, from any source whatsoever any quantity of odorous or gaseous emission, 

material, or air contaminant of any kind or description, which is injurious or detrimental 

to repose, health, and safety, or which in any way unduly interferes with or prevents the 

comfortable enjoyment of life or property. [Guam SIP Reg. 11.1, 37 FR 10842, 

05/31/1972]

21. No person shall cause or permit the burning of fuel with a sulfur content greater than 

3.14% at any time and in no event shall the average over the immediate past twelve 

month period, including the latest month reading, exceed 2.84% by weight provided the 

stacks are of sufficient height, as determined by modeling techniques approved by GEPA, 

to prevent aerodynamic downwash and provide for good dispersion of emissions. 

[Guam Sip Reg. 13.1, 46 FR 26303, 05/12/1981]

22. No person shall cause or permit the emission of sulfur dioxide from any stationary source 

in excess of 1.34 pounds of sulfur dioxide per million Btu’s of heat input to the 

installation. [Guam Sip Reg. 13.2, 46 FR 26303, 05/12/1981]

23. No person shall cause or permit the installation or use of any device or any means which, 

without resulting in reduction in the total amount of air contaminant emitted, conceals or 

dilutes an emission of air contaminant which would otherwise violate these regulations. 

This provision does not prohibit recycling, burning as fuel or otherwise further 

processing a material which would violate an emission regulation if released to the 

atmosphere, so long as the facility in which the material is used does not violate 

applicable emission regulations. [Guam SIP Reg. 17.2, 47 FR 43054, 09/30/1982]
Page 25 of 42 Mobil Oil – Cabras Terminal Prepared: _DATE_

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V. Emission Unit Specific Requirements: Summary Table

Table V.1: Emissions Units and Applicable Regulations/Summary Table lists the applicable 

requirements for this facility at the time this permit was issued. The permittee shall comply 

with these requirements as described in Sections VI through XI. Any portion of a standard not

specified under VI through XI does not relieve the permittee from compliance of any 

requirements under Table V.1.

Table V.1: Emission Units and Applicable Regulations/Summary Table

Emission 

Unit # Applicable Regulations

EU-1, EU-9, 

EU-10

40 CFR Part 63, Subpart A: General Provisions;

40 CFR Part 63, Subpart ZZZZ: National Emission Standards for Stationary 

Reciprocating Internal Combustion Engines (RICE).

EU-2, EU-4, 

EU-7

When containing, storing, or transferring VOL:

40 CFR Part 60, Subpart A: General Provisions;

40 CFR Part 60, Subpart Kb: Standard of Performance for Volatile Organic Liquid 

Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, 

Reconstruction, or Modification Commenced After July 23, 1984;

40 CFR Part 63, Subpart A: General Provisions;

40 CFR Part 63, Subpart R: National Emission Standards for Gasoline Distribution 

Facilities.

When containing, storing, or transferring distillate or residual fuel:

40 CFR Part 71, Subpart A: Title V Operating Permit Program

EU-3, EU-5, 

EU-6

At all times:

40 CFR Part 71, Subpart A: Title V Operating Permit Program

EU-8

&

Associated 

Air Pollution 

Control 

Device

(VCS)

40 CFR Part 60, Subpart A: General Provisions;

40 CFR Part 60, Subpart XX: Standards of Performance for Bulk Gasoline Terminals

40 CFR Part 63, Subpart A: General Provisions;

40 CFR Part 63, Subpart R: National Emission Standards for Gasoline Distribution 

Facilities.

Vapor Collection System (VCS) shall be operated in a manner not to exceed 10 mg of 

total organic compounds per liter of gasoline loaded; and not to exceed a six hour 

average of 0.41 percent organic compounds by volume, as measured by the CEMS.

EU-11

(excluding 

ballasting 

operations)

40 CFR Part 63, Subpart Y: National Emission Standards for Marine Tank Vessel 

Loading Operations

EU-12

40 CFR Part 60, Subpart XX: Standards of Performance for Bulk Gasoline Terminals;

40 CFR Part 63, Subpart R: National Emission Standards for Gasoline Distribution 

Facilities.
Page 26 of 42 Mobil Oil – Cabras Terminal Prepared: _DATE_

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VI. Emission Unit Specific Requirements: Floating Roof Storage Vessels

The conditions in this section apply to Tanks 20, 24, and 29 (EU-2, EU-4, and EU-7) when 

containing, storing or transferring VOL.

A. Work Practices and Standards

1. At all times, including periods of startup, shutdown, and malfunction, the permittee shall, 

to the extent practical, maintain and operate all VOL storage vessels in a manner 

consistent with good air pollution control practice for minimizing emissions. [40 CFR §§

60.11(d), 63.6(e)(1)(i)]

2. Each VOL storage vessel shall be equipped with a fixed roof in combination with an 

internal floating roof meeting the specifications in 40 CFR § 60.112b(a)(1). 

[40 CFR §§ 63.423(a) and 60.112b(a)(1)]

B. Monitoring and Testing

1. After installing the fixed external roof and internal floating roof the permittee shall:

a. Visually inspect the internal floating roof, the primary seal, and the secondary seal 

through manholes and roof hatches on the fixed roof at least once every 12 

months.

b. Visually inspect the internal floating roof, the primary seal, the secondary seal, 

gaskets, slotted membranes and sleeve seals (if any) each time the storage vessel 

is emptied and degassed, but at least every five years.

c. Inspections shall be conducted and remedial action taken according to the 

procedures and schedules in 40 CFR § 60.113b(a)(2)-(a)(4).

[40 CFR §§ 63.425(d) and 60.113b(a)(2)-(a)(4)]

C. Recordkeeping and Reporting

1. The permittee shall notify EPA in writing at least 30 days prior to the filling or refilling 

of each storage vessel for which an inspection is required by Condition VI.B.1.a or 

VI.B.1.b to afford the EPA the opportunity to have an observer present. If the inspection 

required by paragraph Condition VI.B.1.b of this section is not planned and the permittee 

could not have known about the inspection 30 days in advance of refilling the storage 

vessel, the permittee shall notify EPA at least 7 days prior to the refilling of the storage 

vessel. Notification shall be made by telephone immediately followed by written 

documentation demonstrating why the inspection was unplanned. Alternatively, this

notification including the written documentation may be made in writing and sent by 

express mail so that it is received by EPA at least 7 days prior to the refilling. [40 CFR §§

63.4(a)(2), 63.425(d) and 60.113b(a)(5)]
Page 27 of 42 Mobil Oil – Cabras Terminal Prepared: _DATE_

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2. After installing the fixed external roof and internal floating roof the permittee shall:

a. Keep a record of each inspection performed as required by Condition VI.B. Each 

record shall identify the storage vessel on which the inspection was performed 

and shall contain the date the vessel was inspected and the observed condition of 

each component of the control equipment (seals, internal floating roof, and 

fittings).

b. If any of the conditions described in 40 CFR § 60.113b(a)(2) are detected during 

the annual visual inspection required by Condition VI.B.1.a, a report shall be 

furnished to EPA within 30 days of the inspection. Each report shall identify the 

storage vessel, the nature of the defects, and the date the storage vessel was 

emptied or the nature of and date the repair was made.

c. After each inspection required by Condition VI.B.1.b that finds holes or tears in 

the seal or seal fabric, or defects in the internal floating roof, or other control 

equipment defects listed in 40 CFR § 60.113b(a)(4), a report shall be furnished to 

EPA within 30 days of the inspection. The report shall identify the storage vessel 

and the reason it did not meet the specifications required by Condition VI.A.2 and 

list each repair made.

[40 CFR §§ 63.4(a)(2), 63.428(d), 63.428(g)(2), 63.10(b)(2)(iii) and 

60.115b(a)(2)-(4)]

3. The permittee shall: [40 CFR §§ 63.4(a)(2), 63.427(c) and 60.116b(b)-(e)]

a. Keep readily accessible records showing the dimension of each storage vessel and 

an analysis showing the capacity of each storage vessel.

b. Maintain a record of the VOL stored, the period of storage, and the maximum true 

vapor pressure of that VOL during the respective storage period.

c. Notify EPA within 30 days when the maximum true vapor of stored VOL exceeds 

the respective maximum true vapor pressure values for each volume range 

specified in 40 CFR § 60.116b(d).

d. Available data on Reid vapor pressure and the highest expected calendar-monthly 

average temperature of the stored product may be used to determine the maximum 

true vapor pressure from nomographs contained in API Bulletin 2517 unless the 

permittee chooses to sample the stored liquid and take actual temperature 

measurements.
Page 28 of 42 Mobil Oil – Cabras Terminal Prepared: _DATE_

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VII. Emission Unit Specific Requirements: Fixed Roof Storage Tanks

The conditions in this section apply to Tanks 22, 25, and 28 (EU-3, EU-5, and EU-6) at all 

times and Tanks 20, 24, and 29 (EU-2, EU-4, and EU-7) when containing distillate or residual 

fuel.

1. The permittee shall maintain a record of the liquid stored, the period of storage, and the 

vapor pressure of that liquid during the respective storage period. For diesel and other 

distillate fuels and fuel oils, vapor pressure from a supplier’s MSDS is acceptable.

[40 CFR § 71.6(a)(3)(i)(B)]
Page 29 of 42 Mobil Oil – Cabras Terminal Prepared: _DATE_

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VIII. Emission Unit Specific Requirements: Truck Loading Racks

The conditions in this section apply to the truck loading rack (EU-8) and associated air 

pollution control equipment (Vapor Collection System (VCS)) and monitoring equipment.

A. Work Practices and Standards

1. At all times, including periods of startup, shutdown, and malfunction, the permittee shall, 

to the extent practical, maintain and operate the truck loading racks and associated air 

pollution control equipment and monitoring equipment in a manner consistent with good 

air pollution control practice for minimizing emissions. [40 CFR §§ 60.11(d), 

63.6(e)(1)(i) and 63.8(c)(1)]

2. The truck loading rack shall be equipped with a vapor collection system designed to 

collect the total organic compounds vapors displaced from tank trucks during product 

loading that meets the following:

[40 CFR §§ 63.422(a) and (b), 60.502(a) and (b), 60.502(d), 60.502(h), and 60.502(i)]

a. Emissions to the atmosphere from the vapor collection and processing systems 

due to the loading of gasoline cargo tanks shall not exceed 10 milligrams of total 

organic compounds per liter of gasoline loaded.

b. Each vapor collection system shall be designed to prevent any total organic 

compounds vapors collected at one loading rack from passing to another loading 

rack.

c. The vapor collection and liquid loading equipment shall be designed and operated 

to prevent gauge pressure in the delivery tank from exceeding 4,500 pascals (450 

mm of water) during product loading. This level is not to be exceeded when 

measured by the procedures specified in Condition VIII.B.13.

d. No pressure-vacuum vent in the bulk gasoline terminal's vapor collection system 

shall begin to open at a system pressure less than 4,500 pascals (450 mm of 

water).

3. Loadings of liquid product into gasoline tank trucks shall be limited to vapor-tight 

gasoline tank trucks using the following procedures: [40 CFR §§ 63.422(a), 63.422(c) 

and 60.502(e)]

a. The permittee shall obtain the vapor tightness documentation described 

in Condition VIII.C.1 for each gasoline tank truck which is to be loaded at the 

affected facility.

b. The permittee shall require the tank identification number to be recorded as each 

gasoline tank truck is loaded at the affected facility.

c. The permittee shall cross-check each tank identification number obtained in 

Condition VIII.A.3.b with the file of tank vapor tightness documentation within 2 
Page 30 of 42 Mobil Oil – Cabras Terminal Prepared: _DATE_

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weeks after the corresponding tank is loaded, unless either of the following 

conditions is maintained:

1. If less than an average of one gasoline tank truck per month over the last 

26 weeks is loaded without vapor tightness documentation then the 

documentation cross-check shall be performed each quarter; or

2. If less than an average of one gasoline tank truck per month over the last 

52 weeks is loaded without vapor tightness documentation then the 

documentation cross-check shall be performed semiannually.

d. If either the quarterly or semiannual cross-check provided in Condition 

VIII.A.3.c.1 or VIII.A.3.c.2 reveals that vapor tightness conditions were not 

maintained, the source must return to biweekly monitoring until such time as 

these conditions are again met.

e. The permittee shall notify the owner or operator of each nonvapor-tight gasoline 

tank truck loaded at the affected facility within 1 week of the documentation 

cross-check in Condition VIII.A.3.c.

f. The permittee shall take steps assuring that the nonvapor-tight gasoline tank truck 

will not be loaded at the affected facility until vapor tightness documentation for 

that gasoline tank truck is obtained which documents that:

1. The tank truck meets the test requirements in Condition VIII.B.14; or

2. For each tank truck failing the test requirements in Condition VIII.B.15 or 

16, the tank truck either meets the Condition VIII.B.16 or 17 before repair 

work is performed on the tank truck, or meets Condition VIII.B.14 after 

repair work is performed on the tank truck.

4. The permittee shall act to assure that:

a. Loadings of gasoline tank trucks at the affected facility are made only into tanks 

equipped with vapor collection equipment that is compatible with the terminal's 

vapor collection system; and [40 CFR §§ 63.422(a) and 60.502(f)]

b. The terminal's and the tank truck's vapor collection systems are connected during 

each loading of a gasoline tank truck at the affected facility. Examples of actions 

to accomplish this include training drivers in the hookup procedures and posting 

visible reminder signs at the affected loading racks. [40 CFR §§ 63.422(a) and 

60.502(g)]

B. Monitoring and Testing

1. The permittee shall install, calibrate, certify, operate, and maintain, according to the 

manufacturer's specifications, a Continuous Emissions Monitoring System (CEMS) 

capable of measuring organic compound concentration in the exhaust air stream of the 

carbon adsorption system. [40 CFR § 63.427(a)(1)]

2. At least every (5) years, after the issuance date of this permit, and whenever required by 

EPA to conduct a performance test of the carbon adsorption system to verify compliance 
Page 31 of 42 Mobil Oil – Cabras Terminal Prepared: _DATE_

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with the emission limit in Condition VIII.A.2.a, the permittee shall comply with the 

following requirements. The permittee shall use reference test methods from appendix A 

of 40 CFR Part 60 unless otherwise indicated or approval is granted in advance by EPA.

[40 CFR §§ 60.8(b)-(g), 60.503(a) and (c), 63.425(a), 63.7(e)(1) and (2)]

a. Immediately before the test, the permittee shall use Method 21 to monitor for 

leakage of vapor all potential sources in the terminal's vapor collection system 

equipment while a gasoline tank truck is being loaded. All leaks with readings of 

500 ppm (as methane) or greater shall be repaired before conducting the 

performance test.

b. The permittee shall determine compliance with the emission limit in Condition 

VIII.A.2.a using the test methods and procedures in 40 CFR § 60.503 as modified 

in 40 CFR § 63.425(a).

3. For each performance test conducted under Condition VIII.B.2, the permittee shall 

determine a monitored operating parameter value for the vapor processing system using 

the following procedure: [40 CFR § 63.425(b), 63.8(b)(1)-(3)]

a. During the performance test, continuously record the concentration of organic 

compounds measured by the CEMS installed at the carbon adsorption system 

outlet;

b. Determine an operating parameter value for the CEMS based on the parameter 

data monitored during the performance test, supplemented by engineering 

assessments and the manufacturer's recommendations; and

c. Provide for EPA's approval the rationale for the selected operating parameter 

value, and monitoring frequency and averaging time, including data and 

calculations used to develop the value and a description of why the value, 

monitoring frequency, and averaging time demonstrate continuous compliance 

with the emission standard in Condition VIII.A.2.a.

4. For performance tests performed after the initial test, the permittee shall document the 

reasons for any change in the operating parameter value since the previous performance 

test. [40 CFR § 63.425(c)]

5. The permittee much check the zero (low-level) and high-level calibration drifts at least 

once daily. The zero (low-level) and high-level calibration drifts must be adjusted, at a 

minimum, whenever the 24-hour zero (low-level) drift exceeds two times the limits of the 

applicable performance specification(s) specified in the relevant standard. The system 

shall allow the amount of excess zero (low-level) and high-level drift measured at the 24-

hours interval checks to be recorded and quantified whenever specified. [40 CFR §

63.8(c)(6)]

6. The CEMS is out of control if: [40 CFR § 63.8(c)(7)]
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a. The zero (low-level), mid-level (if applicable), or high-level calibration drift (CD) 

exceeds two times the applicable CD specification in the applicable performance 

specification or in the relevant standard; or

b. The CEMS fails a performance test audit (e.g., cylinder gas audit), relative 

accuracy audit, relative accuracy test audit, or linearity test audit.

7. The permittee shall develop and implement a CEMS quality control program to ensure 

compliance with the applicable provisions of 40 CFR § 63.8. [40 CFR § 63.8(d)]

8. The permittee must keep the necessary parts for routine repairs of the affected CEMS

equipment readily available. [40 CFR § 63.8(c)(1)(ii)]

9. All CEMS must be installed such that representative measures of emissions or process 

parameters from the affected source are obtained. In addition, CEMS must be located 

according to the procedures contained in the applicable performance specification(s). [40 

CFR § 63.8(c)(2)(i)]

a. When the emissions from two or more vapor processing systems are combined 

before being released to the atmosphere, the permittee may install an applicable 

CEMS for each emission stream or for the combined emission streams, provide 

the monitoring is sufficient to demonstrate compliance with the Condition 

VIII.B.11. [40 CFR § 63.8(b)(2)(i)]

b. If the relevant standard is a mass emission standard and the emissions from the 

vapor processing systems are released to the atmosphere through more than one 

point, the permittee must install an applicable CEMS at each emission point 

unless the installation of fewer systems is: [40 CFR § 63.8(b)(2)(ii)]

1. Approved by EPA; or

2. Provided for in the relevant standard (e.g., instead of requiring that a 

CEMS be installed at each emission point before the effluents from those 

points are channeled to a common control device, the standard specifies 

that only one CEMS is required to be installed at the vent of the control 

device).

c. When more than one CEMS is used to measure the emissions from one vapor 

processing systems (e.g., multiple breechings, multiple outlets), the permittee 

shall report the results as required for each CEMS. However, when one CEMS is 

used as a backup to another CEMS, the permittee shall report the results from the 

CEMS used to meet the monitoring requirements. If both such CEMS are used 

during a particular reporting period to meet the monitoring requirements, then the 

permittee shall report the results from each CEMS for the relevant compliance 

period. [40 CFR § 63.8(b)(3)]

10. The permittee must ensure the read out (that portion of the CEMS that provides a visual 

display or record), or other indicator of operation, from any CEMS required for 
Page 33 of 42 Mobil Oil – Cabras Terminal Prepared: _DATE_

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compliance with the emission standard is readily accessible on site for operational control 

or inspection by the operator of the equipment. [40 CFR § 63.8(c)(2)(ii)]

11. The permittee shall operate the vapor processing system in a manner not to exceed 0.41 

percent organic compounds by volume, averaged over six hours, as measured by the 

CEMS required by Condition VIII.B.1. [40 CFR § 63.427(b)]

12. Except for system breakdowns, out-of-control periods, repairs, maintenance periods, 

calibration checks, and zero (low level) and high-level calibration drift adjustments, all 

CEMS shall be in continuous operation and shall meet minimum frequency of operation 

requirements as follows: [40 CFR § 63.8(c)(4)]

a. All CEMS for measuring emissions shall complete a minimum of one cycle of 

operation (sampling, analyzing, and data recording) for each successive 15-

minute period.

13. When required by EPA, the permittee shall determine compliance with the standard in 

Condition VIII.A.2.c as follows: [40 CFR § 60.503(b) and 60.503(d)]

a. Immediately before the performance test, use Method 21 to monitor for leakage of 

vapor all potential sources in the terminal's vapor collection system equipment 

while a gasoline tank truck is being loaded. The permittee shall repair all leaks 

with readings of 10,000 ppm (as methane) or greater before conducting the 

performance test.

b. A pressure measurement device (liquid manometer, magnehelic gauge, or 

equivalent instrument), capable of measuring up to 500 mm of water gauge 

pressure with ±2.5 mm of water precision, shall be calibrated and installed on the 

terminal's vapor collection system at a pressure tap located as close as possible to 

the connection with the gasoline tank truck.

c. During the performance test, the pressure shall be recorded every 5 minutes while 

a gasoline tank truck is being loaded; the highest instantaneous pressure that 

occurs during each loading shall also be recorded. Every loading position must be 

tested at least once during the performance test.

14. The annual certification test for gasoline tank trucks shall consist of the following test 

methods and procedures: [40 CFR § 63.425(e)]

a. Method 27, appendix A, 40 CFR part 60: determination of vapor tightness of 

gasoline delivery tank using pressure-vacuum test. Conducted as described in 40 

CFR § 63.425(e)(1).

b. Pressure test of the gasoline tank truck's internal vapor valve as follows:

1. After completing the tests under Condition VIII.B.14.a, use the procedures 

in Method 27 to repressurize the tank to 460 mm H2O (18 in. H2O), gauge. 

Close the tank's internal vapor valve(s), thereby isolating the vapor return 

line and manifold from the tank.
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2. Relieve the pressure in the vapor return line to atmospheric pressure, then 

reseal the line. After 5 minutes, record the gauge pressure in the vapor 

return line and manifold. The maximum allowable 5-minute pressure 

increase is 130 mm H2O (5 in. H2O).

15. A vapor-tight gasoline tank truck shall have no leaks at any time when tested according 

to the following procedures. The leak detection test shall be performed using Method 21, 

appendix A, 40 CFR part 60, except omit section 4.3.2 of Method 21: [40 CFR § 

63.425(f)]

a. The leak definition shall be 21,000 ppm as propane. Use propane to calibrate the 

instrument, setting the span at the leak definition. The response time to 90 percent 

of the final stable reading shall be less than 8 seconds for the detector with the 

sampling line and probe attached.

b. In addition to the procedures in Method 21, include the following procedures:

1. Perform the test on each compartment during loading of that compartment 

or while the compartment is still under pressure.

2. To eliminate a positive instrument drift, the dwell time for each leak 

detection shall not exceed two times the instrument response time. Purge 

the instrument with ambient air between each leak detection. The duration 

of the purge shall be in excess of two instrument response times.

3. Attempt to block the wind from the area being monitored. Record the 

highest detector reading and location for each leak.

16. For cargo tanks with manifolded product lines, the permittee shall conduct the test 

procedure on each compartment as described in 40 CFR § 63.425(g)(1)-(5): [40 CFR § 

63.425(g)]

17. The continuous performance pressure decay test shall be performed using Method 27, 

Appendix A, 40 CFR Part § 60. Conduct only the positive pressure test using a time 

period (t) of 5 minutes. The initial pressure (Pi) shall be 460 mm H2O (18 in. H2O), 

gauge. The maximum allowable 5-minute pressure change (∆ p) which shall be met at 

any time is shown in the third column of Table 2 of § 63.425(e)(1). [40 CFR § 63.425(h)]

C. Recordkeeping and Reporting

1. The permittee shall keep records of the test results for each gasoline cargo tank loading at 

the facility as follows: [40 CFR §§ 63.428(b), 60.505(a) and (b), and 60.7(f)]

a. Annual certification testing performed under Condition VIII.B.14.

b. Continuous performance testing performed at any time at that facility under

Conditions VIII.B.15, VIII.B.16, and VIII.B.17.

c. The documentation file for each gasoline tank truck shall be kept up-to-date. This 

documentation shall include, as a minimum, the following information:
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1. Name of Test: Annual Certification Test- Method 27 (40 CFR § 

63.425(e)(1)); Annual Certification Test- Internal Vapor Valve (40 CFR § 

63.425(e)(2)); Leak Detection Test (40 CFR § 63.425(f)); Nitrogen 

Pressure Decay Field Test (40 CFR § 63.425(g)); Continuous Performance 

Pressure Decay Test (40 CFR § 63.425(h)).

2. Tank owner and address.

3. Tank identification number.

4. Testing location.

5. Date of test.

6. Tester name and signature.

7. Witnessing inspector, if any: Name, signature, and affiliation.

8. Test results: test pressure; pressure or vacuum change, mm of water; time 

period of test; number of leaks found with instrument; and leak definition.

9. Vapor tightness repair: Nature of repair work and when performed in 

relation to vapor tightness testing.

2. The permittee shall keep an up-to-date, readily accessible record of the continuous 

monitoring data required under Condition VIII.B.1. This record shall indicate the time 

intervals during which loadings of gasoline cargo tanks have occurred or, alternatively, 

shall record the operating parameter data only during such loadings. The date and time of 

day shall also be indicated at reasonable intervals on this record. [40 CFR § 63.428(c)(1), 

63.8(c)(2)(ii)]

3. The permittee shall maintain records of: [40 CFR §§ 60.7(b), 63.8(c)(2)(ii), 63.10(b)(2), 

63.10(c), 60.505(f)]

a. All required CEMS measurements (including monitoring data recorded during 

unavoidable CEMS breakdowns and out-of-control periods);

b. The date and time identifying each period during which the CEMS was 

inoperative except for zero (low-level) and high-level checks;

c. The date and time identifying each period during which the CEMS was out of 

control, as defined in the quality control program required by Condition VIII.B.6;

d. The specific identification (i.e., the date and time of commencement and 

completion) of each period of excess emissions and parameter monitoring 

exceedances, as defined in the relevant standard(s), that occurs during startups, 

shutdowns, and malfunctions of the vapor collection system;

e. The specific identification (i.e., the date and time of commencement and 

completion) of each time period of excess emissions and parameter monitoring 

exceedances, as defined in the relevant standard(s), that occurs during periods 

other than startups, shutdowns, and malfunctions of the affected source;

f. The nature and cause of any malfunction (if known);

g. The corrective action taken or preventive measures adopted;
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h. The nature of the repairs or adjustments to the CEMS that was inoperative or out 

of control;

i. All replacements or additions of components performed on an existing vapor 

processing system;

j. The total process operating time during the reporting period; 

k. All procedures that are part of a quality control program developed and 

implemented for CEMS by Condition VIII.B.7; and

l. All required maintenance preformed on the air pollution control and monitoring 

equipment.

4. The permittee shall include in the semiannual monitoring report required by Condition 

III.D.2, a report of each loading of a gasoline cargo tank for which vapor tightness 

documentation had not been previously obtained by the facility. [40 CFR § 63.428(g)(1)]

5. The permittee shall include in the semiannual monitoring report required by Condition 

III.D.2, the following: [40 CFR §§ 63.10(e)(3)(v)-(viii)]

a. The information required by Condition VIII.C.3.b through VIII.C.3.j; and

b. The information required by 40 CFR 63.10(e)(3)(vi).

c. If the total duration of excess emissions or process or control system parameter 

exceedances for the reporting period is less than 1 percent of the total operating 

time for the reporting period, and CEMS downtime for the reporting period is less 

than 5 percent of the total operating time for the reporting period, only the 

summary report shall be submitted, and the full excess emissions and continuous 

monitoring system performance report need not be submitted unless required by 

the Administrator. Otherwise, both the summary report and the excess emissions 

and continuous monitoring system performance report must be submitted.

6. The permittee shall submit permit deviation reports as specified in Condition III.D.4

when the following events occur: [40 CFR §§ 63.10(e)(3) and 63.428(h)(1)-(h)(3)]

a. Each exceedance of the monitored operating parameter value determined under

Condition VIII.B.3, including the monitoring data for the days on which 

exceedances occurred and a description and timing of the steps taken to repair or 

perform maintenance on the vapor collection and processing systems or the 

CEMS.

b. Each instance of a nonvapor-tight gasoline tank truck loading at the facility in 

which the permittee failed to take steps to assure that such gasoline tank truck

would not be reloaded at the facility before vapor tightness documentation for that

gasoline tank truck was obtained.

c. Each reloading of a nonvapor-tight gasoline tank truck at the facility before vapor 

tightness documentation for that gasoline tank truck is obtained by the facility in 

accordance with Condition VIII.A.3.f.
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IX. Emission Unit Specific Requirements: Internal Combustion Engines

The conditions in this section apply to the Cummins emergency generator engine (EU-1), the

two Caterpillar emergency generator engines (EU-9 and EU-10), and other existing, 

stationary, diesel-fired, emergency diesel engines, including insignificant emission units.

A. Work Practices and Standards

1. At all times the permittee must operate and maintain the stationary internal combustion 

engines, including associated air pollution control equipment and monitoring equipment, 

in a manner consistent with safety and good air pollution control practices for minimizing 

emissions, and according to the manufacture’s emission-related written instructions. [40 

CFR §§ 63.6605(b), 63.6625(e), and 63.6640(a)]

2. The permittee shall comply with the following operational requirements: [40 CFR § 

63.6602 and 63.6625(i)]

a. Change the oil and filter every 500 hours or annually, whichever comes first;

b. Inspect air cleaner every 1,000 hours of operation or annually, whichever comes 

first, and replace as necessary;

c. Inspect all hoses and belts every 500 hours of operation or annually, whichever 

comes first, and replace as necessary.

d. As an alternative to the oil change requirement, the permittee may utilize an oil 

analysis program as described in 40 CFR § 63.6625(i).

3. The permittee must install a non-resettable hour meter on each emergency diesel engine 

if one has not already been installed. [40 CFR § 63.6625(f)]

4. The permittee shall minimize each emergency diesel engine’s time spent at idle during 

startup and minimize the engine's startup time to a period needed for appropriate and safe 

loading of the engine, not to exceed 30 minutes. [40 CFR § 63.6625(h)]

5. Operation of each emergency diesel engine shall be in accordance with the following 

requirements: [40 CFR § 63.6640(f)]

a. Emergency situations and there is no time limit on the use during emergency 

situations;

b. Limited to 100 hours per year for any combination of the following uses;

1. For maintenance checks and readiness testing, provided that the tests are 

recommended by federal, state or local government, the manufacturer, the 

vendor, the regional transmission organization or equivalent balancing 

authority and transmission operator, or the insurance company associated 

with the engine;
Page 38 of 42 Mobil Oil – Cabras Terminal Prepared: _DATE_

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2. For emergency demand response for periods in which the Reliability 

Coordinator under the NERC Reliability Standard EOP-002-3, Capacity 

and Energy Emergencies (incorporated by reference, see § 63.14), or 

other authorized entity as determined by the Reliability Coordinator, has 

declared an Energy Emergency Alert Level 2 as defined in the NERC 

Reliability Standard EOP-002-3; and

3. For periods where there is a deviation of voltage or frequency of 5 percent 

or greater below standard voltage or frequency.

4. The permittee may petition the Administrator for approval of additional 

hours to be used for maintenance checks and readiness testing, but a 

petition is not required if the permittee maintains records indicating that 

federal, state, or local standards require maintenance and testing of 

emergency RICE beyond 100 hours per calendar year.

c. Up to 50 hours per year for other non-emergency situations, but those 50 hours 

are counted towards the 100 hours per year as listed in Condition IX.A.5.b. The 

50 hours per year for non-emergency situations cannot be used:

1. For peak shaving;

2. To generate income for a facility to supply power to an electric grid;

3. For non-emergency demand response; or

4. Otherwise supply power as part of a financial arrangement with another 

entity.

d. Any engine which fails to comply with these operational limits may be 

reclassified as a non-emergency engine and may be subject to additional 

requirements.

B. Recordkeeping and Reporting

1. The permittee shall maintain records of: [40 CFR § 63.6655(e) and (f)]

a. Maintenance required to comply with the work practice standards in Condition 

IX.A.2; and

b. The hours of operation for each emergency diesel engine recorded through the 

non-resettable hour meter. The permittee must document how many hours are 

spent for emergency operation, including what classified the operation as 

emergency operation, and how many hours are spent for non-emergency 

operation. 

2. The permittee must submit each report as required by Table 7 of 40 CFR § Part 63, 

Subpart ZZZZ. Unless the Administrator has approved a different schedule for 

submission of reports under § 63.10(a), the permittee must submit each report by the date 

in Table 7 and according to the requirements in § 63.6650(b)(1) through (b)(9). [40 CFR 

§ 63.6640(f), 63.6650(a) and (b)]
Page 39 of 42 Mobil Oil – Cabras Terminal Prepared: _DATE_

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3. For all emergency stationary RICE with a site rating of more than 100 brake HP that 

operates or is contractually obligated to be available for more than 15 hours per calendar 

year for the purposes specified in 63.6640(f)(2)(ii) or (iii), you must submit an annual 

report according to the following requirements: [40 CFR § 63.4(a)(2), 63.10(d)(1), 

63.6650(h)(1)-(3)]

a. Company name and address where the engine is located.

b. Date of the report and beginning and ending dates of the reporting period.

c. Engine site rating and model year.

d. Latitude and longitude of the engine in decimal degrees reported to the fifth 

decimal place.

e. Hours operated for the purposes specified in 63.6640(f)(2)(ii) and (iii), including 

the date, start time, and end time for engine operation for the purposes specified in 

63.6640(f)(2)(ii) and (iii). 

f. Number of hours the engine is contractually obligated to be available for the 

purposes specified in 63.6640(f)(2)(ii) and (iii).

g. The first annual report must cover the calendar year 2015 and must be submitted 

no later than March 31, 2016. Subsequent annual reports for each calendar year 

must be submitted no later than March 31 of the following calendar year.

h. The annual report must be submitted electronically using the subpart specific 

reporting form in the Compliance and Emissions Data Reporting Interface 

(CEDRI) that is accessed through EPA’s Central Data Exchange (CDX) 

(www.epa.gov/cdx). However, if the reporting form specific to this subpart is not 

available in CEDRI at the time that the report is due, the written report must be 

submitted to the Administrator at the appropriate address.
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X. Emission Unit Specific Requirements: Marine Tank Vessel Loading

The conditions in this section apply to marine vessel loading operations (EU-11) except 

ballasting operations.

A. Work Practices and Standards

1. The discharge point of a cargo tank filling line must be no higher above the bottom of the 

cargo tank or sump than 10 cm or the radius of the filling line, whichever is greater. 

[40 CFR § 63.560(a)(4)]

B. Recordkeeping and Reporting

1. The permittee shall calculate an annual estimate of HAP emissions from marine tank 

vessel loading operations, excluding products with vapor pressures less than 10.3 

kilopascals (kPa) (1.5 pounds per square inch, absolute) (psia) at standard conditions, 20 

°C and 760 millimeters Hg (mm Hg). Emission estimates and emission factors shall be 

based on test data, or if test data is not available, shall be based on measurement or 

estimating techniques generally accepted in industry practice for operating conditions at 

the source.

[40 CFR § 63.560(a)(3), 63.565(l)]

2. The permittee shall retain records of the emission estimates required by Condition X.B.1

and actual throughput by commodity, including exempt commodities. 

[40 CFR § 63.560(a)(3) and 63.567(j)(4)]
Page 41 of 42 Mobil Oil – Cabras Terminal Prepared: _DATE_

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XI. Emission Unit Specific Requirements: Equipment Leaks

The conditions in this section apply to all equipment in gasoline service (EU-12). Equipment in 

gasoline service is defined as each valve, pump, pressure relief device, sampling connection 

system, open-ended valve or line, and flange or other connector in the gasoline liquid transfer 

and vapor collection systems, including the entire vapor processing system (carbon adsorption 

system) and each loading rack handling gasoline, except the exhaust vent. [40 CFR §§ 63.421, 

63.424(a) and 60.502(j)]

A. Monitoring and Testing

1. The permittee shall perform a monthly leak inspection of all equipment in gasoline 

service. For this inspection, detection methods incorporating sight, sound, and smell are 

acceptable. Each piece of equipment shall be inspected during the loading of a gasoline 

cargo tank.

[40 CFR §§ 63.424(a) and 60.502(j)]

2. A log book shall be used and shall be signed by the permittee at the completion of each 

inspection. A section of the log shall contain a list, summary description, or diagram(s) 

showing the location of all equipment in gasoline service at the facility.

[40 CFR §§ 60.505(c) and 63.424(b)]

3. Each detection of a liquid or vapor leak shall be recorded in the log book. When a leak is 

detected, an initial attempt at repair shall be made as soon as practicable, but no later than 

5 calendar days after the leak is detected. Repair or replacement of leaking equipment 

shall be completed within 15 calendar days after detection of each leak, except as 

provided in Condition XI.A.4. [40 CFR §§ 63.424(c) and 60.502(j)]

4. Delay of repair of leaking equipment will be allowed upon a demonstration to the 

Administrator that repair within 15 days is not feasible. The permittee shall provide the 

reason(s) a delay is needed and the date by which each repair is expected to be 

completed. [40 CFR § 63.424(d)]

5. As an alternative to compliance with Conditions XI.A.1 through XI.A.4, the permittee 

may implement an instrument leak monitoring program that has been demonstrated to the 

Administrator as at least equivalent. [40 CFR § 63.424(f)]

B. Recordkeeping and Reporting

1. The permittee shall record the following information in the log book required by 

Condition XI.A.2: [40 CFR §§ 60.505(c) and 63.428(e)]

a. The equipment type and identification number;
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b. The date of inspection;

c. The inspector’s name and signature;

d. If applicable, an indication that no leaks were discovered, or if a leak was 

discovered;

e. The location of the leak;

f. The nature of the leak (i.e., vapor or liquid) and the method of detection (i.e., 

sight, sound, or smell);

g. The date the leak was detected and the date of each attempt to repair the leak;

h. The severity of each leak;

i. Repair methods applied in each attempt to repair the leak;

j. “Repair delayed” and the reason for the delay if the leak is not repaired within 15 

calendar days after discovery of the leak;

k. The expected date of successful repair of the leak if the leak is not repaired within 

15 days; and

l. The date of successful repair of the leak.

2. A report of the number of equipment leaks not repaired within five days after detection 

shall be included in the semiannual monitoring report required by Condition III.D.2. The 

permittee shall submit permit deviation reports when an equipment leak is detected for 

which no repair was attempted within 5 days or completed within 15 days. The reports

shall include the following information: [40 CFR § 63.428(g)(3) and 63.428(h)(4)]

a. The date on which the leak was detected,

b. The date of each attempt to repair the leak,

c. The reason for the delay of repair, and

d. The date of successful repair.