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 

rjvky h- it —7 4411-1- 7 AN Herr-411i 

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 from 

the 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 

An ExxonMobil Subsidiary 
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