# Mobil Oil Guam Inc.

November 7, 2014 

# 4449-1/ otyt4



### 642 EAST MARINE CORPS DRIVE 

# phis statir TEL. (671) 648-3600 HAGATNA, GUAM 96910 FACSIMILE (671) 648-3780 

# r jvky h- it —7 4411-1-



# 7 AN Herr-4

11i Geoffrey Glass Permit Engineer U.S. Environmental Protection Agency 75 Hawthorne Street Mail Code: Air - 3 San Francisco, CA 94105 Re: Changes to Federal Operating Permit (Title V) Application Mobil Oil Guam Inc., Cabras Terminal 

## Dear Mr. Glass: 1:> 

# V 1 0 2014 Guam Environnientel Pfalatfkm Agency
Mobil Oil Guam Inc. (Mobil) owns and operates a bulk petroleum products terminal in Piti, Guam (Cabras Terminal) located at 1189 Cabras Highway, Piti, Guam. Cabras Terminal operates under the jurisdiction of U.S. Environmental Protection Agency (U.S. EPA) Region 9 and Guam Environmental Protection Agency (GEPA). In September 2010, Mobil submitted an initial Title V permit application for the Cabras Terminal to the U.S. EPA Region 9 pursuant to 40 Code of Federal Regulations (40 CFR) Part 71 requirements. The U.S. EPA Region 9 is currently in the process of reviewing the Title V permit application. During a recent internal assessment, Mobil identified a few items, which require minor changes to the previously submitted Title V permit application. As discussed on a phone call with U.S. EPA Region 9 on September 18, 2014, Mobil is requesting that the following changes be incorporated in the draft Title V permit soon to be issued by U.S. EPA.' 

# PROPOSED CABRAS TERMINAL TITLE V REVISIONS Mobil is requesting the following revisions to the Title V permit application for Cabras Terminal. These revisions will ensure the Title V permit to be issued for Cabras Terminal is reflective of the most current operations. Update of Oil Water Separator Location 

## In the initial permit application, the oil water separator (OWS) location was incorrectly stated to be in Area A. The OWS is currently located in Area C. Therefore, Mobil requests that the location of the OWS to be changed from Area A to Area C. Also the throughput of the OWS should be updated to a conservative estimate of 1008,000 gallons per day. Please note that this OWS is still listed as an insignificant source. Inclusion of Stratospheric Ozone Protection Regulations 

## Currently Cabras Terminal operates comfort cooling units containing less than 50 pounds of coolants on-site and is therefore subject to certain applicable requirements of Title VI of the Clean Air Act (CAA)

— Stratospheric Ozone Protection, 

## contained in 40 CFR 82. Subparts A through E, and Subparts G through I of 40 CFR 82 are currently not applicable to Cabras Terminal as Mobil does not perform any of the activities or use any substances regulated under these subparts. Subpart F, Recycling and Emissions Reduction requirements may potentially apply if Cabras Terminal operates, maintains, repairs, services, or disposes of
Personal Communication - Geoffrey Glass (U.S. EPA Region 9) and Pragya Sharma (Trinity Consultants) had a call on September 18, 2014 to address changes at the terminal that have occurred since the initial submittal of the Title V application. As discussed during the call, Mobil is submitting this letter to formally request the changes. An ExxonMobil Subsidiary

# Mobil

appliances that utilize Class I or Class II ozone depleting substances. Subpart F generally requires persons completing maintenance, repairs, service, or disposal to be properly certified. All maintenance, repairs, service, and disposal of ozone depleting substances from such equipment (e.g., air conditioners) at the subject facility must be completed by a certified technician. Mobil requests that a reference to the applicable CAA Title VI regulations be included in the Title V permit. Specifically, Mobil requests that the permit state generically that Cabras Terminal is required to conduct servicing by certified technicians only. Refrigerant service technician certificates and signed statements for disposal of small appliances, Motor Vehicle Air Conditioners (MVAC) and MVAC — like appliances are to be maintained on-site. 

## Removal of Tanks 2 and 4 Tank 2 (source ID: T-2) and Tank 4 (source ID: T-4), located in Area A, have been decommissioned since the submittal of the initial Title V permit application. As such, Mobil is requesting that any reference to these tanks be removed fromthe Title V permit. Mobil understands that new source review requirements may apply in future if these tanks are recommissioned. 

## Revision of the Permitting Shield Mobil has identified two additional regulations that do not apply to Cabras Terminal that were not addressed in Section 4.2 — Non-Applicable Federal Regulations of the initial Title V permit application. These nonapplicable federal regulations are the following: 40 CFR Part 60 Subpart JJJJ — Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (NSPS Subpart JJJJ) and 40 CFR Part 63 Subpart GGGGG — National Emission Standards for Hazardous Air Pollutants: Site Remediation (MACT GGGGG). Please refer to the following sections for a summary of non-applicability. Mobil requests a permit shield for these two regulations. NSPS Subpart JJJJ NSPS Subpart JJJJ establishes requirements for manufacturers, owners, and operators of stationary spark (SI) internal combustion engines (ICE). Cabras Terminal does not currently own or operate any SI ICEs. As 

## such, the requirements of NSPS Subpart JJJJ do not apply to the Cabras Terminal and Mobil requests inclusion of NSPS Subpart JJJJ in the Title V permit shield. 

## MACT GGGGG MACT GGGGG establishes national emission limitations and work practice standards for hazardous air pollutants (HAPs) emitted from site remediation activities. Cabras Terminal does not currently operate any regulatory-enforced site remediation activities or foresee the need to do so in the future. As such, the requirements of MACT GGGGG do not apply to the Cabras Terminal and Mobil requests inclusion of MACT GGGGG in the Title V permit shield. Please review these suggested changes to the Title V permit to be issued for Mobil's Cabras Terminal. Should you have any questions or comments about the information presented in this letter, please call Analissa Mercado, Regulatory Compliance Advisor at (671) 479-3240 or via email at analissa.mercado@exxonmob i I .com .

An ExxonMobil Subsidiary

# Mobil

Sincerely, MOBIL OIL GUAM INC. 

# geed

Charles E. Ewart President
cc: Eric M. Palacios, Guam EPA Administrator Garet Olivares, UPI Operations Manager Maria Kemp, CNMI Field Operations Manager

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