Page 1 of 24 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Statement of Basis

*****DRAFT*****

Part 71 Federal Operating Permit

Draft Statement of Basis

for

Mobil Oil – Cabras Terminal

Piti, Guam

Issued by

United States Environmental Protection Agency, Region IX

75 Hawthorne Street

San Francisco, California 94105

Permit No. GU-OP 10-01

Date: _DATE_
Page 2 of 24 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Statement of Basis

Abbreviations and Acronyms

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

BTEX benzene, tolune, ethylbenzene, and xylenes

CAA Clean Air Act (also called “the Act”)

CAM Compliance Assurance Monitoring

CFR Code of Federal Regulations

CO carbon monoxide

DOJ United State Department of Justice

EPA United States Environmental Protection Agency

EU emission unit

gal U.S. gallon

GEPA Guam Environmental Protection Agency

HAP hazardous air pollutant

IEU insignificant emission unit

IFR internal floating roof

km kilometer

kPa kilopascal (SI unit of pressure)

kW kilowatt

L liter

LDAR leak detection and repair

mg miligram

NAAQS national Ambient Air Quality Standard

NESHAP National Emission Standards for Hazardous Air Pollutants

NOx reactive oxides of nitrogen

NSPS New Source Performance Standards

NSR New Source Review 

PM particulate matter

PM10 particulate matter with an aerodynamic diameter less than 10 microns

PM2.5 particulate matter with an aerodynamic diameter less than 2.5 microns

PSD Prevention of Significant Deterioration

psig pounds per square inch, gauge pressure

PTE potential to emit

RICE reciprocating internal combustion engine

SI Système Internationale d’Unités (Fr. International System of Units)

SIP State Implementation Plan

SO2 sulfur dioxide

TOC total organic compounds

tpy tons per year

VFR vertical fixed roof

VOC volatile organic compounds

VOL volatile organic liquids
Page 3 of 24 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Statement of Basis

Table of Contents

1. EPA Authority to Issue Part 71 Permits in Guam 5

2. Regional Information 6

3. Facility Information 7

4. Emission Units and Emissions 8

5. Regulatory Analysis 11

6. Permit Content 18

7. Public Participation 23
Page 4 of 24 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Statement of Basis

Disclaimer:

This document is for purposes of background information only and is not directly enforceable. 

Applicable requirements, including emission limits and monitoring, record keeping, and 

reporting requirements, are contained in the associated part 71 operating permit.
Page 5 of 24 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Statement of Basis

1. EPA Authority to Issue Part 71 Permits in Guam

Major sources of air pollution – as well as some other sources identified by the Administrator –

are required by title V of the Clean Air Act (the Act) to obtain air operating permits, legally 

enforceable documents that contain all applicable requirements relevant to the source. Most title 

V air operating permits are issued by state and local agencies that have permitting programs 

meeting the requirements of 40 CFR part 70, State Operating Permits. Such permits are called 

part 70 permits.

On most tribal lands, on the outer continental shelf, and in certain other situations as specified by 

the Act, air operating permits are issued by EPA under 40 CFR part 71, Federal Operating 

Permits. Such permits are called part 71 permits.

Guam is generally treated as a state under the Act. Subpart A of 40 CFR part 69, Special 

Exemptions from Requirements of the Clean Air Act, however, exempts Guam from the 

requirement to develop a title V operating permit program under 40 CFR part 70, instead 

allowing an alternative operating permit program meeting the requirements of part 69. Such 

permits are called part 69 permits.1

Owners and operators of major sources of hazardous air pollutants (HAP) located in Guam are 

not subject to the Guam administered part 69 alternative operating permit program, but must 

apply for and obtain part 71 federal air operating permits from EPA. (vide 40 CFR § 69.13(a))

The Cabras Terminal has historically been a major source of HAP and did not obtain a voluntary 

limit on HAP emissions before the compliance date of the major source National Emission 

Standard for Hazardous Air Pollutants (NESHAP) for gasoline distribution facilities (40 CFR 

part 63, subpart R). Because of EPA’s once in always in policy regarding major source 

NESHAPs, the Cabras Terminal is considered a major source of HAP and is subject to the part 

71 air operating permit program, consistent with the requirements of title V of the Act.

For the purposes of this document, the terms operating permit, title V permit, and part 71 permit

are used interchangeably with respect to the Cabras Terminal. 

 1 EPA granted approval to Guam’s part 69 alternative operating permit program on February 27, 2006 (71 FR 9716)
Page 6 of 24 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Statement of Basis

2. Regional Information

2.1. Guam

Guam is the southernmost and largest island in the Mariana chain located about three quarters of 

the way from Hawaii to the Philippines in the western Pacific Ocean (13° 28’ N, 144° 47’ E).

The island has an area of 544 square kilometers (210 square miles), about the same area as 

Chicago, IL, and a population of 183,000 (est. July 2011), similar to Salt Lake City, Utah.

Since the Guam Organic Act of 1950, Guam has been an organized, unincorporated territory of 

the United States. Movements to form a commonwealth, establish statehood, or declare 

independence have been inconclusive. 

The word Guam is used interchangeably in this document to refer to both the Island of Guam and 

the U.S. Territory of Guam. The meaning should be clear from the context.

About 37 percent of Guam’s current population are Chamorros, the native Guamanian people 

who constitute the largest single ethnic group on the island. (Filipinos, the second largest group, 

are about 26 percent of the population.) Over 80 percent of the population resides in the capital 

of Hagatna and over 90 percent of the population is classified as urban. The average annual 

household income is $49,293. Guam has two official languages, English and Chamorros. The 

Chamorros language is a Malayo-Polynesian language with Spanish and Filipino influences.

2

Since English is also consider an official language of Guam, unless an interpretation of the draft 

permit and statement of basis is requested during the public comment period, EPA will issue 

these documents in English only.

This permit issuance does not allow or authorize additional air pollution from existing units at 

the facility, and consequently will not result in additional health impacts. The Mobil Oil 

Company has operated the facility in its current location since the 1950s. This permit requires the 

facility to operate their processes in compliance with Federal and local clean air regulations 

which promotes EPA’s goal to improve air quality in and around the facility.

2.2. Local Air Quality and Attainment Status

According to EPA’s Green Book, those portions of Guam within 3.5 km of either the Piti or 

Tanguisson power plant are classified as nonattainment areas for sulfur dioxide. The rest of 

Guam is either in attainment or unclassified for sulfur dioxide. All of Guam is either in 

attainment or unclassified for all other criteria pollutants.

Because the Cabras Terminal lies within 3.5 km of the Piti Power Plant, it is located in an area 

that is designated nonattainment for sulfur dioxide and attainment or unclassified for all other 

criteria pollutants.

 2 Geographic and demographic information from the CIA World Fact Book and the US Census Bureau 2010 Census

https://www.cia.gov/library/publications/the-world-factbook/, www.census.gov.
Page 7 of 24 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Statement of Basis

3. Facility Information

3.1. Location

The Cabras Terminal is located on Cabras Island, a low lying reef which forms the northern 

shore of Apra Harbor, Guam’s primary commercial and naval port, south of Hagatna on the 

western side of the island. The street address is 1189 Cabras Highway, Piti, Guam.

3.2. Contact Information

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

Responsible Official: Charles Ewart, President, (671) 648-3655

3.3. Description of Operations

Mobil Oil Guam, Inc. (Mobil) owns and operates a bulk petroleum products terminal on Apra 

Harbor in Piti, Guam. Refined petroleum products – gasoline and distillate fuels – are delivered 

by transoceanic tanker ships, stored on site at a tank farm, and delivered to trucks and local 

coastal tankers for local and regional distribution. The Cabras Terminal operates under standard 

industrial classification (SIC) code 5171, Petroleum Bulk Stations and Terminals. The 2007 

North American Industry Classification System (NAICS) code for the facility’s operation is 

424710, Petroleum and Petroleum Products Bulk Stations and Terminals.

3.4. Facility History

The Cabras Terminal was constructed in the 1950s, predating the Clean Air Act. Mobil reports 

never having applied for a new source review permit.

On July 27, 2010, Mobil entered into a Consent Decree with the U.S. Department of Justice 

(DOJ) on behalf of the EPA. The Consent Decree required Mobil to comply with 40 CFR part 

60, subparts A, Kb, and XX and 40 CFR part 63, subparts A and R; comply with a set of binding 

obligations; and apply for and obtain a title V operating permit from EPA to ensure that certain 

Consent Decree requirements survive the termination of the Consent Decree.
Page 8 of 24 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Statement of Basis

4. Emission Units and Emissions

4.1. Emission Units

The air emission sources identified by Mobil located at the Cabras Terminal include gasoline and 

distillate fuel storage tanks, diesel-fired emergency engines, delivery of petroleum products to 

trucks and ships, and leaks from pumps, valves, and other equipment in gasoline service.

Mobil identified 13 significant emission units in its title V permit application. In addition, EPA 

has determined that a 300 kW Cummins emergency generator identified by Mobil as an 

insignificant emission unit in the permit application, is a significant emission unit.

Since submitting its title V permit application in 2010, Mobil has decommissioned two storage 

tanks, storage tank 2 and 4, in Area A, eliminating two of the previously identified emission 

units. The emergency generator in Area A remains in place and has been identified by EPA has a 

significant emission unit.

Table 4.1: Emission Units

Location EU # Description Controls

Area A EU-1 ICE-3: 300 kW Cummins emergency diesel generator None

Area C EU-2 Tank 20: internal floating roof (IFR) tank storing gasoline and distillate 

fuel

Double wiper seal

EU-3 Tank 22: vertical fixed roof (VFR) tank storing distillate fuel only None

EU-4 Tank 24: IFR tank storing gasoline and distillate fuel Double wiper seal

EU-5 Tank 25: VFR tank storing distillate fuel only None

EU-6 Tank 28: VFR tank storing distillate fuel only None

EU-7 Tank 29: IFR tank storing gasoline and distillate fuel Double wiper seal

EU-8 Three-bay truck loading rack John Zink carbon 

adsorption unit

EU-9 ICE-1: 300 kW Caterpillar emergency diesel generator None

D Lot EU-10 ICE-2: 300 kW Caterpillar emergency diesel generator None

Golf Pier EU-11 Submerged fill loading of gasoline and distillate fuel to local coastal 

tankers

None

Facility-wide EU-12 Fugitive emissions from equipment in gasoline service None

4.2. Insignificant Emission Units

In addition to categorically insignificant activities, Mobil identified 15 pieces of equipment in its

title V permit application for the Cabras Terminal that are defined as insignificant emission units 

as per 40 CFR 71.5(c)(11)(ii) based on potential to emit.3 As stated in 4.1, EPA has determined 

that one of these pieces of equipment is a significant emission unit.

Table 4.2: Insignificant Emission Units

Location IEU # Description

Area A IEU-1 280 kW diesel-fired firewater pump

IEU-2 500 gallon VFR diesel tank supplying IEU-1

IEU-3 150 gallon VFR diesel tank supplying EU-10 and IEU-1

IEU-4 Oil water separator with a maximum annual throughput of 431,000 gallons

 3 No more than 1,000 lbs of any HAP and no more than 2 tons of any other regulated air pollutant on an annual basis.
Page 9 of 24 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Statement of Basis

Location IEU # Description

Area C IEU-5 13 kW diesel-fired portable light tower

IEU-6 13 kW diesel-fired portable light tower

IEU-7 22.5 kW diesel-fired Kubota transfer pump

IEU-8 9 kW portable diesel-fired compressor

IEU-9 250 gallon VFR Jet A additive tank

IEU-10 150 gallon VFR gasoline additive tank

IEU-11 150 gallon VFR diesel tank supplying EU-10

Golf Pier IEU-12 Distillate fuel bunkering to local ships

D Lot IEU-13 182 kW diesel-fired firewater pump

IEU-14 250 gallon VFR diesel tank supplying IEU-13

4.3. Emission Calculation Methodology

4.3.1. Criteria Pollutants

In general, Mobil used emission factors and calculation methodologies from EPA’s AP-42 

Clearinghouse except when an applicable limit or standard requires lower emissions.

Most of the emission units at the facility are evaporative sources that only emit VOC.

Combustion of diesel fuel, however, results in the emission of CO, NOx, PM, and SO2 in 

addition to VOC. Particulate matter emitted from combustion sources may be conservatively 

estimated to be PM10 and PM2.5.

Table 4.3: VOC and Criteria Pollutant Emission Factors and Calculation Methodologies

Source Type Emission Factor and Calculation Methodology Source

Storage tanks EPA Tanks 4.0.9d program

Truck loading Gasoline loading: NESHAP limit

Distillate fuel loading: AP-42, Chapter 5.2, Equation 1

Marine loading Gasoline loading: AP-42, Table 5.2-2 (cleaned vessels)

Distillate fuel loading: AP-42, Table 5.2-6 (ships/ocean barges)

Tank landings & cleaning Assumed three landings and one cleaning per year. Methodology from AP-42 Section 7.1 

and Evaporative Loss from Storage Tank Floating Roof Landings, Technical Report 2567, 

American Petroleum Institute, April, 2005.

Fugitives 1995 Protocol for Equipment Leak Emission Estimates, EPA, OAQPS, EPA-453/R-95-017, 

Table 2-3: Marketing Terminal Average Emission Factors.

Generators AP-42, Table 3.3-1 (lb/bhp-hr factors)

4.3.2. Hazardous Air Pollutants

Mobil calculated HAP emissions from evaporative sources by multiplying the vapor mass 

fraction of each compound, which were obtained from several EPA-approved resources, (see 

Table 4.3 of this document), by the total VOC emissions. HAP emissions from diesel 

combustion were calculated using the factors in AP-42, Table 3.3-2 and the conversion from 

engine horsepower to fuel consumption in the footnote in AP-42, Table 3.3-1.

4.3.3. Greenhouse Gases

Mobil did not calculate greenhouse gas (GHG) emissions as a part of the Cabras permit 

application. As Mobil submitted this application in 2010, before GHG emission calculations 

were required, and since no additional applicable requirements would be triggered, EPA did not 
Page 10 of 24 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Statement of Basis

require Mobil to calculate GHG emissions and resubmit the application. 

EPA may require Mobil to submit GHG emission calculations in the future if the data were 

needed to determine the applicability of future requirements.

4.4. Potential to Emit

The term potential to emit is defined as: the maximum capacity of a stationary source to emit any 

air pollutant under its physical and operational design. Any physical or operational limitation on 

the capacity of a source to emit an air pollutant, including air pollution control equipment and 

restrictions on hours of operation or on the type or amount of material combusted, stored, or 

processed, shall be treated as part of its design if the limitation is enforceable by the 

Administrator.

In the title V application for the Cabras Terminal, Mobil used historical data to estimate likely

higher-end limit throughputs of gasoline and distillate fuel. For this reason, the potential to emit 

VOC and HAP in the following table should be considered to be estimates, and, unless

enforceable limits are taken, the terminal should be considered to be a major source of VOC and

organic HAP.

The facility’s potential to emit CO, NOx, PM, and SO2, on the other hand, is highly conservative. 

These pollutants are emitted by the facility’s emergency generators, which were assumed to 

operate during the entire typhoon season rather than the typical 500 hours per year.

Because all PM is a result of combustion, PM was conservatively assumed to be PM10 and PM2.5.

Table 4.4: Potential to Emit in Tons per Year (from Application)

CO NOx PM/PM10/PM2.5 SO2 VOC HAP

8 40 3 3 108 9

4.5. Actual Emissions

Mobil reported 2009 actual emissions for the Cabras Terminal with their 2010 operating permit 

fee submittal. Reported actual emissions of VOC and HAP exceed the potential to emit included 

in the title V permit application because some required controls were not yet in place in 2009.

Table 4.5: 2009 Actual Emissions in Tons per Year (Reported with Mobil’s 2010 Fee 

Submittal)

CO NOx PM/PM10/PM2.5 SO2 VOC HAP

1 2 0 0 188 12
Page 11 of 24 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Statement of Basis

5. Regulatory Analysis

The following table summarizes the applicability of federal regulations to the facility. The 

applicability of these regulations may change given new information about the facility’s 

operations or if the facility is reconstructed or modified. 

Table 5.1: Applicability of Regulatory Programs to Cabras Terminal

Program

Applicable

Yes No

If 

Triggered

40 CFR Part 71: Title V Operating Permit Program X

40 CFR § 52.21: PSD Program X

40 CFR Part 60 Subpart A: General Provisions X

40 CFR Part 60 Subpart K: Standards of Performance for Storage Vessels for Petroleum 

Liquids for which Construction, Reconstruction, or Modification Commenced after 

June 11, 1973 and prior to May 19, 1978

X

40 CFR Part 60 Subpart Ka: Standards of Performance for Storage Vessels for 

Petroleum Liquids for which Construction, Reconstruction, or Modification 

Commenced after May 18, 1978 and prior to July 23, 1984

X

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

Storage Vessels (including Petroleum Liquid Storage Vessels) for which Construction, 

Reconstruction, or Modification Commenced after July 23, 1984

X

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

40 CFR Part 60 Subpart IIII: Standards of Performance for Stationary Compression 

Ignition Internal Combustion Engines

X

40 CFR Part 61 Subpart M: National Emission Standards for Asbestos X

40 CFR Part 63 Subpart A: General Provisions X

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

Facilities

X

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

Loading Operations

X

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

Reciprocating Internal Combustion Engines (RICE)

X

40 CFR Part 63 Subpart BBBBBB: National Emission Standards for Hazardous Air 

Pollutants for Source Category: Gasoline Distribution Bulk Terminals, Bulk Plants, and 

Pipeline Facilities

X

40 CFR Part 63 Subpart CCCCCC: National Emission Standards for Hazardous Air 

Pollutants for Source Category: Gasoline Distribution Facilities

X

40 CFR Part 64: CAM Rule X

40 CFR Part 68: Chemical Accident Release X

40 CFR Parts 72 – 76: Acid Rain Program X

40 CFR Part 82: Stratospheric Ozone Protection X

Guam SIP X

5.1. Title V Air Operating Permit Program (40 CFR Part 71)

The Cabras Terminal is subject to the permitting requirements of title V of the Act because it has 

the potential to emit at least 100 tons per year of VOC and had the potential to emit at least 25 

tons per year HAP on December 14, 1995, the initial compliance date of 40 CFR part 63, subpart 

R. The facility is subject to 40 CFR part 71, the federal air operating permit program, because 

major HAP sources on Guam are ineligible for Guam’s alternative operating program as 

described in 40 CFR § 69.13(a)(4).

5.2. Prevention of Significant Deterioration (PSD) (40 CFR § 52.21)
Page 12 of 24 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Statement of Basis

The PSD program applies additional review to construction and modification of major sources of 

air pollution in areas where NAAQS are not exceeded. Because the application for a title V 

permit does not result in an increase in emissions, PSD applicability is not being reviewed at this 

time. There are no existing PSD permits with conditions that apply to the facility.

5.3. New Source Performance Standards (40 CFR Part 60)

5.3.1. Subpart A

The provisions of Subpart A, the General Provisions of 40 CFR part 60, apply to any affected 

source, defined as any group of equipment that emits or may emit any air pollutant and is subject 

to a standard in 40 CFR part 60. At the Cabras Terminal, the affected sources include those 

storage tanks that contain volatile organic liquids and the truck loading racks.

5.3.2. Subpart K

Subpart K, Standards of Performance for Storage Vessels for Petroleum Liquids for which 

Construction, Reconstruction, or Modification Commenced after June 11, 1973 and prior to May 

19, 1978, does not apply to any of the storage tanks at the Cabras Terminal because the tanks are 

subject to Subpart Kb.

5.3.3. Subpart Ka

Subpart Ka, Standards of Performance for Storage Vessels for Petroleum Liquids for which 

Construction, Reconstruction, or Modification Commenced after May 18, 1978 and prior to July 

23, 1984, does not apply to any of the storage tanks at the Cabras Terminal because the tanks are 

subject to Subpart Kb.

5.3.4. Subpart Kb

Tanks 20, 24, and 29 are subject to Subpart Kb, Standards of Performance for Volatile Organic 

Liquid Storage Vessels (including Petroleum Liquid Storage Vessels) for which Construction, 

Reconstruction, or Modification Commenced after July 23, 1984. Since submitting its title V 

permit application in 2010, Mobil has decommissioned two storage tanks, storage tank 2 and 4, 

in Area A, eliminating two of the previously identified emission units.

Owners and operators of storage vessels larger than 75 m3 (about 20,000 gal or 472 bbl) that 

contain gasoline must comply with subpart Kb by either:

1. Installing an internal floating roof and external fixed roof,

2. Installing an external floating roof, or

3. Operating a closed vent system and control device.

Those gasoline storage tanks at the Cabras Terminal that already comply with Subpart Kb are 

fitted with internal floating roofs with dual wiper seals and external fixed roofs.

Subpart Kb specifies inspection schedules and procedures for the required control equipment and 
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Draft Statement of Basis

associated recordkeeping and reporting requirements. 

The tanks at the Cabras Terminal that are subject to subpart Kb are also subject to 40 CFR Part 

63, subpart R, National Emission Standards for Gasoline Distribution Facilities. Applicable 

requirements from the two standards have been streamlined and included in the air operating 

permit in Condition VI.

5.3.5. Subpart XX

The Cabras Terminal is subject to subpart XX, Standards of Performance for Bulk Gasoline 

Terminals.

Subpart XX applies to the truck loading racks. Mobil will comply with the subpart by only 

loading gasoline into vapor-tight trucks and operating a vapor collection system controlled by 

carbon adsorption unit.

As the truck loading racks are also subject to 40 CFR Part 63, subpart R, National Emission 

Standards for Gasoline Distribution Facilities, applicable requirements from the two standards 

have been streamlined and included in the air operating permit in Condition VIII.

5.3.6. Subpart IIII

Subpart IIII, Standards of Performance for Stationary Compression Ignition Internal 

Combustion Engines, applies to stationary compression ignition engines constructed after July 

11, 2007 or reconstructed or modified after July 11, 2005. Because the compression ignition 

engines at the Cabras Terminal were constructed before the applicability date and have not been 

reconstructed or modified, subpart IIII does not apply.

The applicant has requested a permit shield for this subpart. Because EPA agrees that the subpart 

does not apply, a shield has been granted.

5.4. National Emission Standards for Asbestos (40 CFR Part 61, Subpart M)

A condition requiring compliance with the National Emission Standard for Asbestos has been 

included in the General Requirements section of the air operating permit so that a permit 

modification will not be required if demolition or renovation at the facility results in the removal 

of asbestos containing material.

5.5. National Emission Standards for Hazardous Air Pollutants (40 CFR Part 63)

5.5.1. Subpart A

The provisions of subpart A apply to any source subject to a standard in 40 CFR part 63 as 

referenced in the applicable subpart. At the Cabras Terminal, the affected sources include those 

storage tanks that contain gasoline, truck loading racks, stationary internal combustion engines, 

and equipment in gasoline service subject to the leak detection and repair program.
Page 14 of 24 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Statement of Basis

5.5.2. Subpart R

The Cabras Terminal is subject to subpart R, National Emission Standards for Gasoline 

Distribution Facilities.

Subpart R applies to all gasoline containing tanks, truck loading racks, and equipment in gasoline 

service subject to a leak detection and repair program (e.g. valves, connectors, flanges). The 

facility will comply with the subpart by implementing the operating permit requirements of 

Condition VI for storage vessels, Condition VIII for loading racks, and Condition XI for the leak 

detection and repair program for equipment in gasoline service.

Applicable requirements from subpart R have been streamlined with applicable requirements 

from subparts Kb and XX of 40 CFR part 60 as appropriate and included in the air operating 

permit in Conditions VI, VIII, and XI.

5.5.3. Subpart Y

Because of actual loading volumes, marine tank vessel loading equipment at the Cabras Terminal 

does not meet the definition of an affected source in 40 CFR § 63.561. Nevertheless, 

subpart Y, National Emission Standards for Marine Tank Vessel Loading Operations, does 

require submerged fill loading of marine tank vessels and applies emission calculation and 

recordkeeping requirements. These requirements are included in the air operating permit in 

Condition X.

The applicant has requested a permit shield for this subpart. Although tank vessel loading 

equipment at the Cabras Terminal does not meet the definition of an affected source, this subpart 

does contain applicable requirements. Therefore a shield has not been granted. As long as actual 

volumes remain below 10 million barrels per year of gasoline and 200 million barrels per year of 

crude oil, compliance with the conditions in Condition X will assure compliance with the 

subpart.

5.5.4. Subpart ZZZZ

Subpart ZZZZ, National Emission Standards for Stationary Reciprocating Internal Combustion 

Engines (RICE), applies to new and existing stationary RICE. Because all of the RICE are 

emergency-use, compression ignition engines rated less than 500 brake-horsepower, subpart 

ZZZZ applies only work practice standards. These standards are included in the air operating 

permit in Condition IX.

5.5.5. Subpart BBBBBB

According to 40 CFR § 63.11081(a)(1), subpart BBBBBB, National Emission Standards for 

Hazardous Air Pollutants for Source Category: Gasoline Distribution Bulk Terminals, Bulk 

Plants, and Pipeline Facilities, does not apply to facilities that are subject to subpart R.
Page 15 of 24 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Statement of Basis

The applicant has requested a permit shield for this subpart. Because EPA agrees that the subpart 

does not apply, a shield has been granted.

5.5.6. Subpart CCCCCC

Subpart CCCCCC, National Emission Standards for Hazardous Air Pollutants for Source 

Category: Gasoline Dispensing Facilities, does not apply because the facility does not meet the 

definition of a gasoline dispensing facility in 40 CFR § 63.11132.

5.6. Compliance Assurance Monitoring (CAM) (40 CFR Part 64)

The CAM Rule applies additional monitoring requirements on pollutant specific emission units 

that:

1. Are subject to an emission limit for a federally regulated pollutant (or a surrogate 

thereof),

2. Use a control device to meet this limit, and

3. Have a pre-control potential to emit such a pollutant equal to or greater than the title V 

major source threshold, unless the pollutant specific emission unit is exempted from the 

CAM Rule under 40 CFR § 64.2(b).

Subpart R of 40 CFR part 63 limits TOC emissions from gasoline loading at the truck loading 

racks to 10 mg/L. This emission limit has been streamlined with a higher emission limit from 40 

CFR part 60, subpart XX. These are the only explicit emission limits at the Cabras Terminal. A 

control device, a carbon adsorption system, is used to meet this limit. Without controls, the truck 

loading racks could emit more than 100 tons of VOC per year.

According to 40 CFR § 64.2(b)(1)(i), the CAM Rule does not apply to emission limits proposed 

by the Administrator after November 15, 1990 pursuant to section 112 of the Act. Subpart R of 

40 CFR part 63 is a NESHAP that was proposed by the Administrator pursuant to section 112 of 

the Act in 1994. Therefore, the CAM Rule does not apply to the NESHAP limit.

The NSPS limit was proposed by the Administrator before November 15, 1990. However, 

according to 40 CFR § 64.2(b)(1)(vi), the CAM Rule does not apply to emission limits when a 

part 70 or 71 permit specifies a continuous compliance demonstration method as defined in 40 

CFR § 64.1. 

Condition VIII.B of the Cabras Terminal’s part 71 air operating permit requires the permittee to 

install, calibrate, certify, operate, and maintain according to the manufacturer's specifications, 

a continuous emissions monitoring system capable of measuring organic compound 

concentration in the exhaust air stream of the carbon adsorption system. Furthermore, Condition 

VIII.B.3 requires the permittee to determine an operating parameter to monitor in order to verify 

continuous compliance with the emission standard. Therefore, the CAM Rule does not apply at 

this time.

The applicant has requested a permit shield for the CAM Rule. Because the requirement to 

submit a CAM plan is determined upon renewal or at the time of a significant revision, EPA has 
Page 16 of 24 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Statement of Basis

not granted a permit shield for the CAM Rule.

5.7. Chemical Accident Prevention (40 CFR Part 68)

Although Mobil does not store any of the chemicals subject to the Chemical Accident Prevention 

program at the Cabras Terminal, a general requirement to comply with 40 CFR part 68 has been 

included in the air operating permit so a permit modification will not be immediately required 

should the program become applicable.

The applicant has requested a permit shield for this part. Because this part can be incorporated by 

reference at a high level into the permit without creating any obligation to the permittee beyond 

an annual certification of compliance, a permit shield is not necessary.

5.8. Acid Rain Program (40 CFR Parts 72 – 76)

The Cabras Terminal is not a power generating facility and is not subject to the Acid Rain 

Program. Furthermore, the Acid Rain Program only applies to units in the continental United 

States.

5.9. Stratospheric Ozone Protection (40 CFR Part 82)

Mobil identified the Stratospheric Ozone Protection Program as an inapplicable requirement in 

the title V permit application for the Cabras Terminal. Nevertheless, a generic condition 

requiring compliance with the program was included in the air operating permit so a permit 

modification would not be required if any on-site maintenance required handling of ozone 

depleting substances.

The applicant has requested a permit shield for this part. Because this part can be incorporated by 

reference at a high level into the permit without creating any obligation to the permittee beyond 

an annual certification of compliance, a permit shield is not necessary.

5.10. Federally Enforceable Local Regulations (Guam SIP)

Air quality regulations that have been included in the State Implementation Plan and approved 

by the Administrator are federally applicable requirements that must be included in a part 71 

permit. Often, the current version of the local air quality regulations has not yet been approved or 

has not been submitted to the Administrator for approval. When this is the case, a “SIP gap” 

results and the conditions in a facility’s air operating permit, which are enforceable by EPA and 

any citizen, differ from the local regulations enforced by the local authority (i.e., GEPA).

Applicable requirements in Guam’s SIP have been included in Condition IV of the operating 

permit and are identified with a SIP citation and the date of publication in the Federal Register. 

When the term Administrator appears in a regulation in Guam’s SIP, it has been replaced with 

the term GEPA to make it clear that the Administrator is the local permitting authority and not 

EPA. In some cases, SIP requirements have been paraphrased to better fit the format of the air 

operating permit.
Page 17 of 24 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Statement of Basis

EPA has no authority to enforce Guam’s local regulations that are not in the SIP and these 

regulations are not included in the operating permit. Compliance with the conditions of the

operating permit does not relieve Mobil of the responsibility to comply with any of Guam’s 

environmental regulations that are not in the SIP. 

5.11. Other Federal Regulations

5.11.1. Endangered Species Act (ESA)

Pursuant to Section 7 of the Endangered Species Act (ESA), 16 U.S.C. § 1536, and its 

implementing regulations at 50 C.F.R. Part 402, EPA is required to ensure that any action 

authorized, funded, or carried out by EPA is not likely to jeopardize the continued existence of 

any Federally-listed endangered species or threatened species or result in the destruction or 

adverse modification of such species’ designated critical habitat. The title V permit EPA is 

issuing to Mobil does not authorize the construction of new emission units, or emission increases 

from existing units, nor does it otherwise authorize any other physical modifications to the 

facility or its operations. Therefore, EPA has concluded that the issuance of this permit will have 

no effect on listed species or their critical habitat.
Page 18 of 24 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Statement of Basis

6. Permit Content

EPA is required by 40 CFR part 71 to include in an operating permit all emission limits and 

standards that apply to a facility as well as monitoring, testing, record keeping, and reporting 

requirements adequate to determine compliance. Where existing monitoring, testing, record 

keeping, and reporting requirements are not adequate to determine compliance, EPA is obligated 

to fill these gaps.

Although, part 71 specifies required permit content it does not specify any required permit 

format. In this case, EPA has determined that a format that organizes requirements by emission 

unit would be easiest to understand and most likely to result in compliance with the applicable 

requirements.

Multiple emission limits that apply to the same emission unit may be streamlined into a single 

limit if compliance with such a limit can ensure compliance with all of the subsumed limits. 

Streamlining, which may be proposed by either the applicant or the authority, requires the 

consent of the applicant. After consultation, Mobil agreed with EPA that the permit should 

streamline emission limits based on federal regulations (e.g. NSPS and NESHAP standards) but 

leave local standards separate because of the SIP gap on Guam. When emission limits and 

standards are streamlined, all subsumed limits are explicitly included in the regulatory basis for 

the condition.

Part 71 specifically allows the streamlining of multiple sets of similar monitoring or testing 

requirements provided the specified monitoring or testing is adequate to assure compliance at 

least to the same extent as the monitoring or testing applicable requirements that are not included 

in the permit as a result of such streamlining. 

In some cases, parts of applicable regulations have been incorporated into the permit by 

reference. In general, incorporation by reference has been used for verbose definitions, test 

methods, design criteria, and requirements that the permittee must include in written plans.

The following is a discussion of the organization of the permit. Although some permit conditions 

are discussed individually, these conditions should not be misunderstood to be “more important” 

than other conditions and the permittee is required to comply with all permit conditions.

6.1. Source Information

This section includes general information about the facility and a summary of emission units. 

Any emission units, except insignificant emission units identified in the application, not listed in 

this section were not reviewed as a part of this permitting action. 

6.2. Standard Terms and Conditions

This section contains standard terms and conditions that must be included in all title V permits. 

The permittee does not need to annually certify compliance with the provisions of this section. 

However, if the permittee is aware of any information that indicates noncompliance with these 
Page 19 of 24 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Statement of Basis

provisions, that must be reported in the annual compliance certification required by Condition 

III.D.3.

Condition II.B includes a permit shield which states that, at the time of permit issuance,

compliance with the terms of the permit is deemed compliance with the underlying requirements

and also identifies particular requirements that are not applicable to the facility. It is the 

responsibility of the permittee to comply with any applicable requirements that may have been 

inadvertently omitted from the permit or that become applicable after permit issuance, including 

requirements that were covered by the permit shield at the time of issuance.

The applicant requested a permit shield for the following regulations:

1. 40 CFR part 60, subpart IIII: Standards of Performance for Stationary Compression 

Ignition Internal Combustion Engines

2. 40 CFR part 63, subpart Y: National Emission Standards for Marine Tank Vessel 

Loading Operations

3. 40 CFR part 63, subpart BBBBBB: National Emission Standards for Hazardous Air 

Pollutants for Source Category: Gasoline Distribution Bulk Terminals, Bulk Plants, and 

Pipeline Facilities

4. 40 CFR part 64: Compliance Assurance Monitoring

5. 40 CFR part 68: Chemical Accident Prevention Provisions

6. 40 CFR part 82: Stratospheric Ozone Protection

EPA determined that only items 1 and 3 should be covered by a permit shield for reasons given 

in section 5 of this Statement of Basis.

6.3. General Requirements

This section contains additional standard terms and conditions. However, the permittee must 

annually certify compliance with the terms and conditions in this section consistent with 

Condition III.D.3.

Condition III.A.2 requires the permittee to comply with 40 CFR part 61, subpart M when 

conducting demolition and renovation activities that could disturb asbestos containing materials. 

This permit condition does not relieve the permittee from obtaining any required local permits 

when engaging in these activities, but a title V permit modification would not be required.

Condition III.A.3 summarizes applicability deadlines related to the Chemical Accident 

Prevention Program. Although EPA is not aware of any regulated substances stored at the Cabras 

Terminal above the threshold quantities, the permittee is obligated to submit a risk management 

plan should this situation change. Including this condition reduces the likelihood of having to

hastily reopen the permit should the permittee become subject to this program.

Conditions III.A.4 and III.A.5 address 40 CFR part 82, Stratospheric Ozone and Climate 

Prevention. The permittee has an ongoing requirement to ensure that any equipment on site that 

use or contain materials, such as refrigerants, that is subject to this program is maintained by 

certified individuals.
Page 20 of 24 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Statement of Basis

Condition III.B sets general minimum testing requirements. If there is a conflict between these 

requirements and the requirements found in emission unit-specific conditions, the permittee must 

comply with the emission unit-specific condition.

Condition III.C sets general minimum record keeping requirements. If there is a conflict between 

these requirements and the requirements found in emission unit-specific conditions, the permittee 

must comply with the emission unit-specific condition.

Condition III.D requires submittal of semiannual reports that include summaries of all required 

monitoring and instances of permit deviations. This condition requires submittal of annual 

compliance certifications and requires prompt reporting of permit deviations, where a deviation

is defined as any situation in which an emissions unit fails to meet a permit term or condition. 

These reports and certifications must be certified as true, accurate, and complete by a responsible 

official, typically a corporate officer or designated representative.

Condition III.D requires some of the reports required by the permit to be submitted electronically 

(e-reporting) by the permittee through EPA’s Central Data Exchange/Compliance and Emission 

Data Reporting Interface (CDX/CEDRI) Webpage. The CDX/CEDRI Webpage however does 

not accept all of reports required by the permit. Whichever compliance report formats available 

for the permittee to use through the website should be submitted electronically. Otherwise, the 

permittee is required to submit the reports to the Administrator at the appropriate address.

Condition III.E requires the payment of fees and, as fee amounts are based on reporting of annual 

emissions, requires the submittal of actual emission reports. The official fee calculation and 

submittal forms can be downloaded from: http://www.epa.gov/air/oaqps/permits/p71forms.html.

6.4. Facility Specific Requirements

This section contains applicable requirements that would not necessarily apply to all title V 

facilities regulated by EPA Region 9 but which apply facility-wide or to multiple, dissimilar 

emission units.

Condition IV.A is a facility-wide requirement originating in 40 CFR part 63, subpart R to 

minimize releases of gasoline vapors to the environment.

Condition IV.B incorporates Guam’s SIP requirements into the permit. These conditions include 

fugitive dust emission rules, general limits on particulate loading and visible emissions, and 

notification requirements to the Guam Administrator.

Because Guam has not submitted a SIP revision for EPA approval for some time, these 

conditions may, in some cases, be significantly different from Guam’s current local regulations.

6.5. Unit Specific Requirements

6.5.1. Floating Roof Storage Tanks
Page 21 of 24 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Statement of Basis

Any storage tank at the Cabras Terminal that is used to store gasoline must meet the 

requirements of 40 CFR part 60, subpart Kb and 40 CFR part 63, subpart R. From the several 

compliance options, Mobil has chosen to comply with these standards by equipping tanks that

contain gasoline with an internal floating roof and an external fixed roof (these are called IFR 

tanks). 

Condition VI includes the applicable subparts that apply to IFR tanks and include design criteria, 

inspection procedures and schedules, remedial actions, and record keeping and reporting 

provisions. Because of lengthy descriptions of design criteria and inspection procedures, much of 

the subparts are incorporated by reference.

6.5.2. Fixed Roof Storage Tanks

Mobil may not store gasoline in vertical fixed roof (VFR) tanks that are not fitted with internal 

floating roofs. Condition VII contains a gap-filling condition requiring the permittee to keep 

records of VFR tank contents in order to verify that gasoline has not been stored in VFR tanks. 

6.5.3. Truck Loading Racks

Loading of gasoline into tanker trucks is subject to 40 CFR part 63, subpart R and 40 CFR part 

60, subpart XX which allow loading into vapor tight trucks and collection and control of gasoline 

vapors. Mobil uses a carbon adsorption system to control emissions of gasoline vapors.

The conditions in this section set the work practice standards and related testing, monitoring, 

record keeping, and reporting requirements pursuant to these subparts.

Condition VIII.A.2 sets the emission limit for the vapor collection system at 10 mg of total 

organic compounds per liter of gasoline delivered.

Conditions VIII.A.3 and VIII.A.4 require the permittee to ensure that gasoline is only loaded into 

vapor tight trucks with vapor collection equipment compatible with the terminal’s vapor 

collection system.

Condition VIII.B requires the permittee to install and operate a continuous emission monitoring 

system (CEMS) for the carbon adsorption system and develop monitoring criteria through source 

testing for assuring continuous compliance with the emission limit in Condition VIII.A.

According to the facility’s most recent source test, the monitoring criterion is a measured 

hydrocarbon concentration of 0.41 percent, as propane, six-hour average, at the carbon adsorber 

outlet stack.

Because of complex testing and monitoring requirements pursuant to these subparts, testing and 

monitoring methods are incorporated by reference.

6.5.4. Internal Combustion Engines

Pursuant to 40 CFR part 63, subpart ZZZZ, Mobil is required to change the engine oil and filter 
Page 22 of 24 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Statement of Basis

and perform engine inspections on a regular basis, install a non-resettable hour meter, minimize 

idle time, limit engine use to emergency operations and up to 100 hours of nonemergency 

operation per year, and maintain records adequate to verify compliance. These requirements are 

incorporated into Condition IX.

6.5.5. Marine Tank Vessel Loading

Although marine tank vessel loading equipment at the Cabras Terminal does not meet the 

definition of an affected source in 40 CFR § 63.561, 40 CFR part 63, subpart Y requires the 

terminal to fill tankers and barges by submerged loading, to keep records of materials loaded into 

marine tank vessels and to estimate HAP emissions. These requirements are incorporated into 

Condition X.

6.5.6. Equipment in Gasoline Service

The conditions in this section require Mobil to implement a leak detection and repair program for 

all equipment used to store or transport gasoline and maintain a log of inspections performed and 

actions taken as required by 40 CFR part 63, subpart R. These requirements are incorporated into 

Condition XI.
Page 23 of 24 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Statement of Basis

7. Public Participation

7.1. Public Notice

As described in 40 CFR 71.11(a)(5), all Part 71 draft operating permits shall be publicly noticed 

and made available for public comment. The public notice of permit actions and public comment 

period is described in 40 CFR 71(d).

There is a 30-day public comment period for actions pertaining to a draft permit. Public notice 

will be given for this draft permit by mailing a copy of the notice to the permit applicant and

GEPA. A copy of the notice will also be provided to all persons who have submitted a written 

request to be included on the mailing list. Public notice will also be published in the Marianas 

Variety-Guam Edition News.

7.2. Opportunity for Comment

Members of the public may review a copy of the draft permit prepared by EPA, this statement of 

basis for the draft permit, the application, and all supporting materials submitted by the source at 

the address listed below. Copies of the draft permit and statement of basis can also be obtained 

from EPA’s website (http://www.epa.gov/caa-permitting/caa-permitting-epas-pacific-southwestregion), or by contacting Lornette Harvey at the EPA address, phone number, or email address 

listed below. All documents will be available for review at the EPA Region 9 office, during 

regular business hours. Copies of the public notice package will also be available in Guam, USA 

at the Mobil Oil Guam facility and the Guam Environmental Protection Agency (Guam EPA). 

The contact information for both locations are as follows:

Mr. Garet Olivaries, Upper Pacific Islands Operations Manager

1-671-479-3256

Mobil Oil Guam, Inc.

1189 Cabras Highway

Piti, Guam 96925

Mr. Roland Gutierrez, EHS Supervisor

1-671-300-4751/52/53

Guam Environmental Protection Agency

Administration Building

Building 17-3304, Mariner Avenue

Tiyan, Barrigada, Guam 96921

If you believe that any condition of the draft permit is inappropriate, you must raise all 

reasonably ascertainable issues and submit all arguments supporting your position during the 30-

day public comment period. Any supporting documents must be included in full and may not be 

incorporated by reference, unless they are already part of the administrative record for this 

permit or consist of tribal, state or federal statutes or regulations, or other generally available 

referenced materials.
Page 24 of 24 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Statement of Basis

All comments received during the public comment period and all comments made during any 

public hearing will be considered in arriving at a final decision on the permit. The final permit is 

a public record that can be obtained by request. A statement of reasons for changes made to the 

draft permits and responses to comments received will be sent to all persons who commented on 

the draft permit.

7.3. Opportunity to Request a Hearing

Any person may submit a written request for a public hearing to Lornette Harvey, at the address 

listed below, by stating the nature of the issues to be raised at the public hearing. EPA shall hold 

a public hearing if EPA finds, on the basis of requests, a significant amount of public interest in 

the draft permit. If a public hearing is held, EPA will provide public notice of the hearing and 

any person may submit oral or written statements and data concerning the draft permit.

7.4. Mailing List

If you would like to be added to our mailing list to be informed of future actions on this or other 

EPA-issued CAA permits issued on Guam, please send your name and address to Lornette 

Harvey at the address listed below. Be aware, however, that most CAA permits on Guam are 

issued by GEPA and not US EPA.

7.5. Contact Information

Lornette Harvey

US Environmental Protection Agency

Air Permits Office (AIR-3)

75 Hawthorne Street

San Francisco, CA 94105

Phone: 415-972-3498

Email: harvey.lornette@epa.gov
Page 1 of 17 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Statement of Basis

Appendix 1

Appendix 1

Cross-referencing of Permit Conditions with Part 60 and Part 63 Requirements 
Page 2 of 17 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Statement of Basis

Appendix 1

40 CFR part 60, subpart Kb: Standards of Performance for Storage Vessels for Petroleum 

Liquids for which Construction, Reconstruction, or Modification Commenced after July 23, 1984

Citation Description Requirements

60.110b Applicability and designation of affected facility No applicable requirements

60.111b Definitions No applicable requirements

60.112b(a)(1) Control option 1: fixed roof with internal floating roof Condition VI.A. Design specifications 

incorporated by reference. Streamlined 

with 63.423(a)

60.112b(a)(2) Control option 2: external floating roof No applicable requirements. Control 

option not selected.

60.112b(a)(3) Control option 3: closed vent system and control device No applicable requirements. Control 

option not selected.

60.112b(a)(4) Control option 4: equivalent method No applicable requirements. Control 

option not selected.

60.112b(b) Control requirements for tanks at least 75 m3 total volume 

containing volatile organic liquids with a vapor pressure greater 

than 76.6 kPa

No applicable requirements. Terminal 

did not apply to store liquids this 

volatile

60.112b(c) Site specific standards No applicable requirements. Terminal 

not identified in this paragraph.

60.113b(a)(1) Initial inspection requirements for control option 1 Not ongoing

60.113b(a)(2)-

(4)

Continuing inspection requirements for control option 1 Condition VI.B. Details about 

inspections and remedial actions 

incorporated by reference. Streamlined 

with 63.425(d)

60.113b(a)(5) Notification requirements prior to tank filling Condition VI.C.1. Streamlined with 

63.425(d)

60.113b(b) Testing procedures for control option 2 No applicable requirements. Control 

option not selected.

60.113b(c) Testing procedures for control option 3 (except flares) No applicable requirements. Control 

option not selected.

60.113b(d) Testing procedures for control option 3 (flares) No applicable requirements. Control 

option not selected.

60.114b Alternative means of emission limitation No applicable requirements. Applicant

has not applied for an alternative

60.115b(a)(1) Initial notification requirements for control option 1 Not ongoing

60.115b(a)(2)-

(4)

Ongoing notification requirements for control option 1 Condition VI.C.2. Inspection criteria 

incorporated by reference. Streamlined 

with 63.428(d) and 63.428(g)(2)

60.115b(b) Notification requirements for control option 2 No applicable requirements. Control 

option not selected.

60.115b(c) Notification requirements for control option 3 (except flares) No applicable requirements. Control 

option not selected.

60.115b(d) Notification requirements for control option 3 (flares) No applicable requirements. Control 

option not selected.

60.116b(a) Required records must be kept for at least 2 years Record keeping requirement subsumed 

by Condition III.C.3

60.116b(b)-(e) Requires records of storage vessel dimensions and liquids 

stored. Requires notification when maximum vapor pressures 

are exceeded.

Condition VI.C.3. Maximum vapor 

pressures incorporated by reference. 

Streamlined with 63.427(c)

60.116b(f) Monitoring requirements for waste-containing tanks Permittee does not maintain any waste 

containing tanks

60.116b(g) Monitoring exemption when an add-on control device is used Permittee does not control tank 

emissions with an add-on control 

device

60.117b Delegation of authority No applicable requirements
Page 3 of 17 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Statement of Basis

Appendix 1

40 CFR part 60, subpart A: General Provisions (as applied to IFR tanks)

Citation Description Requirements

60.1 Applicability No applicable requirements

60.2 Definitions No applicable requirements

60.3 Units and abbreviations No applicable requirements

60.4 Address No applicable requirements

60.5 Determination of construction or modification Applies to Administrator

60.6 Review of plans Applies to Administrator

60.7(a) Requires notifications related to startup and initial compliance 

demonstrations

Not ongoing

60.7(c)&(d) Requires semiannual reporting of excess emissions detected by 

CMS

Part 60 does not require a continuous 

monitoring device for the IFR tanks

60.7(e) Allows reduction in frequency of reporting when an applicable 

subpart requires quarterly (or more frequent) reporting

Permittee is subject to no such subpart

60.7(f) Requires maintaining records of all measurements needed to 

maintain compliance with applicable subparts for at least two 

years

Subsumed by Condition III.C.3

60.7(g) Allows substantially similar notification from state requirements 

to satisfy requirements of 60.7(a)

60.7 is not an ongoing requirement

60.7(h) States that individual subparts may clarify requirements No applicable requirements

60.8(a) Requires initial performance testing Not ongoing

60.8(b)-(g) Establishes testing requirements Testing not required for tanks

60.9 Availability of public information No applicable requirements

60.10 State authority Applies to States

60.11(a) States that compliance with standards in part 60 will be 

determined through testing established by 60.8

Not an applicable requirement

60.11(b) States that method will be used to determine compliance with 

opacity standards in part 60

No sources at facility are subject to 

opacity standards from part 60

60.11(c) Opacity standards in part 60 apply at all times unless otherwise 

specified

No sources at facility are subject to 

opacity standards from part 60

60.11(d) Requires affected facilities to be properly operated at all times Condition VI.A.1

60.11(e) Establishes requirements for demonstrating compliance with 

opacity standards in part 60

No sources at facility are subject to 

opacity standards from part 60

60.11(f) States that special provisions in applicable subparts may 

supersede general compliance provisions

Not an applicable requirement

60.11(g) Allows credible evidence to determine compliance Included in Condition II.C.1

60.12 Prohibits circumvention Condition II.L

60.13 Establishes monitoring standards for continuous monitoring 

systems

Part 60 does not require a continuous 

monitoring device for the IFR tanks

60.14&15 Modification and Reconstruction No applicable requirements

60.16 Priority list Applies to Administrator

60.17 Incorporation by reference No applicable requirements

60.18 Contains work practice standards for flares and alternative leak 

detection methods

Facility does not operate a flare and has 

not requested alternative leak detection 

methods

60.19 Applies general notification and reporting requirements No applicable requirements
Page 4 of 17 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Statement of Basis

Appendix 1

4u0 CFR part 60, subpart XX: Standards of Performance for Bulk Gasoline Terminals

Citation Description Requirements

60.500 Applicability and designation of affected facility No applicable requirements

60.501 Definitions No applicable requirements

60.502(a) Requires a vapor collection system for truck loading racks Condition VIII.A.2. Streamlined with 

63.422(a)

60.502(b) Limits TOC emissions from new sources to 35 mg/L gasoline Streamlined with 63.422(b), Condition 

VIII.A.2

60.502(c) Limits TOC emissions from existing sources to 80 mg/L 

gasoline

No existing sources as defined in 

subpart

60.502(d) Requires vapor collection systems to be designed so that vapors 

collected at one loading rack cannot pass to another

Condition VIII.A.2. Streamlined with 

63.422(a)

60.502(e) Establishes procedures for loading gasoline into tank trucks Condition VIII.A.3. Streamlined with 

63.422(a) & (c)

60.502(f) Allows gasoline to be loaded only into tank trucks with a vapor 

collection system compatible with the terminal’s system

Condition VIII.A.4. Streamlined with 

63.422(a).

60.502(g) Requires the truck’s and terminal’s vapor collection systems to 

be connected before loading gasoline

Condition VIII.A.4. Streamlined with 

63.422(a).

60.502(h) Limits delivery tank pressure to less than 4,500 pascals Condition VIII.A.2. Streamlined with 

63.422(a).

60.502(i) Prohibits pressure-vacuum vents in the vapor collection system 

from opening at a system pressure of less than 4,500 pascals

Condition VIII.A.2. Streamlined with 

63.422(a).

60.502(j) Requires inspection and repair of the vapor collection system Subsumed by more detailed part 63 

requirements, Conditions XI.A

60.503(a) Requires test methods from part 60 appendix A Condition VIII.B.2, test methods 

incorporated by reference, streamlined 

with 63.425(a) and 63.7(e)

60.503(b) Requires a method 21 leak test before performance tests 

required by subpart

Condition VIII.B.13

60.503(c) Establishes testing procedure for determining compliance with 

vapor collection system emission limits

Condition VIII.B.2, incorporated by 

reference and streamlined with 

63.425(a) and 63.7(e)

60.503(d) Establishes testing procedures for determining compliance with 

tank trunk pressure limit

Conditions VIII.B.13

60.503(e)&(f) Alternative testing requirements for flares No applicable requirements. Facility 

does not operate a flare.

60.504 Reserved No applicable requirements

60.505(a)&(b) Requires recordkeeping related to gasoline tank truck testing Condition VIII.C. Streamlined with 

60.7(f) and 63.428(b)

60.505(c) Requires recordkeeping related to inspection and repair of vapor 

collection system

Subsumed by more detailed part 63 

requirements, Conditions XI.A.2 & 

XI.B.1

60.505(d) Notifications must be maintained for at least 2 years Record keeping requirement subsumed 

by Condition III.C.3

60.505(e) Allows electronic records to be kept As applicable.

60.505(f) Records of vapor collection system repairs must be maintained 

for at least three years

Record keeping requirement subsumed 

by Condition III.C.3 and VIII.C.3

60.506 Reconstruction No applicable requirements. Defines 

when reconstruction occurs.
Page 5 of 17 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Statement of Basis

Appendix 1

40 CFR part 60, subpart A: General Provisions (as applied to gasoline loading racks)

Citation Description Requirements

60.1 Applicability No applicable requirements

60.2 Definitions No applicable requirements

60.3 Units and abbreviations No applicable requirements

60.4 Address No applicable requirements

60.5 Determination of construction or modification Applies to Administrator

60.6 Review of plans Applies to Administrator

60.7(a) Requires notifications related to startup and initial compliance 

demonstrations

Not ongoing

60.7(b) Requires records of startups, shutdowns, and malfunctions Condition VIII.C.3

60.7(c)&(d) Requires semiannual reporting of excess emissions detected by 

CMS

No subpart of part 60 requires a 

continuous monitoring device

60.7(e) Allows reduction in frequency of reporting when an applicable 

subpart requires quarterly (or more frequent) reporting

Permittee is subject to no such subpart

60.7(f) Requires maintaining records of all measurements needed to 

maintain compliance with applicable subparts for at least two 

years

Streamlined with part 63 requirements, 

Conditions III.C.3 and VIII.C.1

60.7(g) Allows substantially similar notification from state requirements 

to satisfy requirements of 60.7(a)

60.7(g) is not an ongoing requirement

60.7(h) States that individual subparts may clarify requirements No applicable requirements

60.8(a) Requires initial performance testing Not ongoing

60.8(b)-(g) Establishes testing requirements Subsumed by Conditions III.B.1 & 2,

III.D.8, and VIII.B.2

60.9 Availability of public information No applicable requirements

60.10 State authority Applies to States

60.11(a) States that compliance with standards in part 60 will be 

determined through testing established by 60.8

Not an applicable requirement

60.11(b) States that method will be used to determine compliance with 

opacity standards in part 60

No sources at facility are subject to 

opacity standards from part 60

60.11(c) Opacity standards in part 60 apply at all times unless otherwise 

specified

No sources at facility are subject to 

opacity standards from part 60

60.11(d) Requires affected facilities to be properly operated at all times Conditions VI.A.1 and VIII.A.1. 

Streamlined with 63.6(e)(1)(i)&(ii). 

60.11(e) Establishes requirements for demonstrating compliance with 

opacity standards in part 60

No sources at facility are subject to 

opacity standards from part 60

60.11(f) States that special provisions in applicable subparts may 

supersede general compliance provisions

Not an applicable requirement

60.11(g) Allows credible evidence to determine compliance Included in Condition II.C.1

60.12 Prohibits circumvention Condition II.L.

60.13 Establishes monitoring standards for continuous monitoring 

systems

No subpart of part 60 requires a 

continuous monitoring device for this 

facility

60.14&15 Modification and Reconstruction No applicable requirements

60.16 Priority list Applies to Administrator

60.17 Incorporation by reference No applicable requirements

60.18 Contains work practice standards for flares and alternative leak 

detection methods

Facility does not operate a flare and has 

not requested alternative leak detection 

methods

60.19 Applies general notification and reporting requirements No applicable requirements
Page 6 of 17 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Statement of Basis

Appendix 1

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

Citation Description Requirements

63.420 Applicability No applicable requirements

63.421 Definitions No applicable requirements

63.422(a) Requires truck loading racks to comply with 60.502 (40 CFR 

part 60, subpart XX), except paragraphs (b), (c), and (j)

See table for 40 CFR part 60, subpart 

XX (above). Streamlined with 

Condition VIII.A

63.422(b) Limits TOC emissions from loading rack vapor collection 

systems to 10 mg/L gasoline

Condition VIII.A

63.422(c) Establishes procedures for loading gasoline into tank trucks Condition VIII.A. Streamlined with 

60.502(e) and 63.422(a)

63.422(d) Requires compliance with this paragraph upon startup Not ongoing, establishes compliance 

date

63.422(e) Allows alternative leak checking No applicable requirements. Permittee 

has not applied to use alternative 

methods

63.423(a) Requires gasoline storage tanks to be controlled by a method in 

in 40 CFR part 60, subpart Kb

Condition VI.A.2. Design specifications 

incorporated by reference. Streamlined 

with 60.112b(a)(1)

63.423(b) Establishes a requirement for external floating roof tanks No applicable requirements. Tanks 

equipped with internal floating roofs

63.423(c) Requires compliance with this paragraph upon startup Not ongoing, establishes compliance 

date

63.424(a) Requires monthly inspections of all equipment in gasoline 

service

Condition XI.A.1

63.424(b) Requires a log book to be used for leak inspections Condition XI.A.2

63.424(c) Requires recording leaks in the log book and prompt repairs Condition XI.A.3

63.424(d) Establishes when repairs can be delayed Condition XI.A.4

63.424(e) Requires compliance with this paragraph upon startup Not ongoing, establishes compliance 

date

63.424(f) Allows instrumental leak detection as an alternative Condition XI.A.5

63.424(g) Prohibits handling gasoline that would result in vapor releases Condition IV.A.1

63.425(a) Requires performance testing of the loading rack vapor 

collection system

Condition VIII.B.2. Streamlined with 

63.7(e)(1)&(2)

63.425(b) Requires establishment of a monitoring parameter of VOC 

CEMS during any loading rack vapor collection system test

Condition VIII.B.3. 

63.425(c) Requires permittee to justify any change of the monitoring 

parameter

Condition VIII.B.4.

63.425(d) Requires tanks subject to the subpart to comply with 60.113b Streamlined with 60.113b, Conditions 

VI.B and VI.C.

63.425(e) Establishes procedures for certifying gasoline tank trucks Condition VIII.B.14

63.425(f) Establishes procedures for leak tests Condition VIII.B.15

63.425(g) Establishes procedures for nitrogen decay field test Condition VIII.B.16.

63.425(h) Establishes procedures for continuous performance pressure 

decay tests

No applicable requirements

63.425(i) Railcar bubble test procedure No applicable requirements. Facility 

does not load rail cars.

63.426 Alternative means of emission limitation Permittee has not applied for alternative 

means of emission limitation

63.427(a)(1) Requires a VOC CEMS for monitoring carbon adsorption 

systems

Condition VIII.B.1

63.427(a)(2)-

(5)

Establishes monitoring systems to be used for control devices 

other than carbon adsorption

Permittee uses carbon adsorption

63.427(b) Requires operation of the vapor recovery system so the 

operating parameter is not exceeded

Condition VIII.B.11

63.427(c) For gasoline storage tanks, requires records from 40 CFR part 

60, subpart Kb

Condition VI.C.3. Streamlined with 

60.116(b)-(d)

63.428(a) Initial notification Not ongoing
Page 7 of 17 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Statement of Basis

Appendix 1

63.428(b) Requires records of tank truck certification Condition VIII.C.1, streamlined with 

60.7(f) and 60.505(a)&(b)

63.428(c)(1) Requires records of CEMS data Condition VIII.C.2. Streamlined with 

63.7(f)

63.428(c)(2) Requires reporting of compliance status Condition III.D.3. Reporting condition 

subsumed by standard title V reporting. 

See 63.9(h)(3).

63.428(d) Requires recordkeeping and reporting from 60.115b except that 

reports must be kept at least five years

See table for 40 CFR part 60, subpart 

Kb (above). Condition VI.C.2

63.428(e) Requires records of leaks detected Condition XI.B.1

63.428(f) Requires a report listing equipment in gasoline service upon 

startup or applicability

Not ongoing

63.428(g)(1) Requires reports of gasoline loading into uncertified tank trucks Condition VIII.C.4

63.428(g)(2) Requires reports already required under 63.428(d) See table for 40 CFR part 60, subpart 

Kb (above). Condition VI.C.2

63.428(g)(3) Requires semiannual reporting of leaks not promptly repaired Condition XI.B.2

63.428(h)(1)-

(3)

Defines certain excess emissions events from loading gasoline 

into tank trucks and requires prompt reporting

Condition VIII.C.6

63.428(h)(4) Defines certain excess emissions events from leaking equipment 

in gasoline service and requires prompt reporting

Condition XI.B.2

63.428(i)&(j) Requires certain records to demonstrate exemption from the 

NESHAP

Facility is not exempt from the 

NESHAP

63.428(k) Allows electronic records As applicable

63.429 Implementation and enforcement No applicable requirements
Page 8 of 17 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Statement of Basis

Appendix 1

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

Operations

Citation Description Requirements

63.560(a)(1) MACT standards apply to 10/25 sources (sources with marine 

tank vessel loading emissions of at least 10 tpy for any 

individual HAP or 25 tpy of total HAP)

Facility is not a 10/25 source

63.560(a)(2) MACT standards do not apply to sources that are not 10/25 

sources

No applicable requirements

63.560(a)(3) Requires calculation of emission estimates based on marine tank 

loading and retention of related records

Condition X.B.1 (streamlined with 

63.565(l)) and Condition X.B.2

(streamlined with 63.567(j)(4))

63.560(a)(4) Requires cargo tank filling from the bottom Condition X.A.1

63.560(b) RACT standards apply to 10/200 sources (sources having an 

aggregate throughput from marine tank vessel loading of at least 

10 million barrels of gasoline or at least 200 million barrels of 

crude oil)

Facility is not a 10/200 source

63.560(c) Sets applicability of general provisions to affected sources Facility does not contain an affected 

source

63.560(d) Exemptions from MACT and RACT standards No applicable requirements, though 

ballasting operations are exempt

63.560(e) Sets compliance dates Not ongoing

63.561 Definitions No applicable requirements

63.562 Sets MACT and RACT standards for 10/25 and 10/200 sources Facility is not a 10/25 or 10/200 source

63.563 Sets compliance and performance testing requirements for 

facilities subject to MACT or RACT requirements

Facility not subject to MACT or RACT 

requirements

63.564 Sets monitoring requirements for facilities subject to MACT or 

RACT requirements

Facility not subject to MACT or RACT 

requirements

63.565(a)-(e) Establishes testing requirements for affected sources Facility does not contain an affected 

source

63.565(f)-(k) Establishes procedures for setting baseline parameters at 

affected sources

Facility does not contain an affected 

source

63.565(l) Establishes emission estimation procedures for sources that are 

not 10/25 or 10/200 sources

Condition X.B.1. Streamlined with 

63.560(a)(3)

63.565(m) Allows alternative test procedures Testing not required

63.566 Construction and reconstruction No applicable requirements

63.567(a)&(b) Applies recordkeeping, reporting, and notification requirements 

to owners and operators of affected sources

Facility does not contain an affected 

source

63.567(c) Allows requests for extensions of compliance Permittee has not made such a request

63.567(d) Sets reporting requirements for flares Facility does not operate a flare.

63.567(e) Requires summary and excess emissions reports Facility does not have an emission limit 

under the standard and does not use a 

control device

63.567(f)-(i) Applies recordkeeping, reporting, and notification requirements 

to owners and operators of affected sources

Facility does not contain an affected 

source

63.567(j)(1) Requires records to identify exempt commodities Permittee has not sought an exemption 

based on commodities loaded

63.567(j)(2) Requires records to be kept for five years Record keeping requirement subsumed 

by Condition III.C.3

63.567(j)(3) Requires an annual report of HAP control efficiency Permittee does not operate a control 

device to reduce HAP emissions from 

marine vessel loading

63.567(j)(4) Requires records of emission estimates Condition X.B.2. Streamlined with 

63.560(a)(3)

63.567(k) Requires records of leak detection and repair activities of vapor 

collection system

Permittee is not required by the subpart 

to operate a vapor collection system

63.567(l) Requires owners and operators of equipment subject to 

63.562(d) to develop a communication program increasing the 

Facility is not subject to 63.562(d)
Page 9 of 17 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Statement of Basis

Appendix 1

proportion of loading in controlled berths

63.567(m) Requires reporting of malfunctions leading to exceedance of an 

emission limit required by the subpart

The subpart does not set an emission 

limit

63.567(n) Establishes testing reporting requirements The subpart does not require testing

63.568 Implementation and enforcement No applicable requirements

63.569-63.599 Reserved No applicable requirements
Page 10 of 17 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Statement of Basis

Appendix 1

40 CFR Part 63 Subpart ZZZZ: National Emission Standards for Hazardous Air Pollutants for 

Stationary Reciprocating Internal Combustion Engines (RICE)

Citation Description Requirements

63.6580 Purpose No applicable requirements

63.6585 Am I subject to this subpart No applicable requirements

63.6590 What parts of my plants does this subpart cover? No applicable requirements, but defines 

which engines are subject

63.6595 When do I have to comply with this subpart No applicable requirements, but sets 

initial compliance date

63.6600 Establishes emission limits for RICE rated > 500 hp located at 

major sources of HAP

The permittee does not operate any 

engines rated > 500 hp

63.6601 Establishes emission limits for new or reconstructed 4SLB 

RICE rated ≥ 250 hp and ≤500 hp at major source of HAP

The permittee does not operate any 

stationary 4SLB

63.6602 Establishes emission limits for existing RICE rated ≤ 500 hp at 

major sources of HAP

Condition IX.A.2

63.6603 Establishes emission limits for existing RICE at area sources The facility is not an area source

63.6604 Establishes fuel requirements for existing compression ignition 

RICE

This requirement does not apply to 

RICE located in Guam, American 

Samoa, CNMI, or remote parts of 

Alaska

63.6605(a) Requires compliance with emission limitations and operating 

limitations at all times

Subsumed by Conditions II.D.1,

III.D.3, and IV.A.2

63.6605(b) Requires proper operation and maintenance of any affected 

source at all times

Subsumed by Condition IV.B.1, 

IV.A.2, and IX.A.1

63.6610 Establishes initial performance test date for RICE rated > 500 

hp located at major sources of HAP

The permittee does not operate any 

engines rated > 500 hp

63.6611 Establishes initial performance test date for new or 

reconstructed 4SLB RICE rated ≥ 250 hp and ≤500 hp at major 

source of HAP

The permittee does not operate any 

stationary 4SLB

63.6612 Establishes initial performance test date for existing RICE rated 

≤ 500 hp at major sources of HAP

No performance test is required for

emergency engines

63.6615 Establishes dates for subsequent performance tests No performance test is required for 

emergency engines

63.6620 Establishes testing requirements No performance test is required for 

emergency engines

63.6625(a) Establishes requirements for CEMS The subpart does not require CEMS for 

emergency engines

63.6625(b) Establishes requirements for CPMS The subpart does not require CPMS for 

emergency engines

63.6625(c) Requires separate fuel meters for to measure usage of each fuel 

when digester or landfill gas is combusted

Permittee does not combust digester or 

landfill gas

63.6625(d) Requires a non-resettable hour meter on new or reconstructed 

4SLB RICE rated ≥ 250 hp and ≤500 hp at major source of 

HAP

The permittee does not operate any 

stationary 4SLB

63.6625(e) Establishes required monitoring for after-treatment control 

devices

Permittee does not operate an aftertreatment control device

63.6625(f) Requires a non-resettable hour meter on emergency RICE rated 

≤ 500 hp at major sources of HAP

Condition IX.A.3

63.6625(g) Establishes limits on crankcase emissions from non-emergency 

CI engines rated ≥ 300 hp 

Permittee does not operate nonemergency stationary RICE 

63.6625(h) Requires minimization of idle time Condition IX.A.4.

63.6625(i) Allows an oil analysis program to extend time between oil 

changes in emergency and small non-emergency CI RICE

Not an applicable requirement, but 

allowed as an option in Condition 

IX.A.2

63.6625(j) Allows an oil analysis program to extend time between oil 

changes in other engines

Covered by 63.6625(i). Condition 

IX.A.2

63.6630 Establishes criteria for initial compliance demonstration with Applies only to non-emergency engines
Page 11 of 17 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Statement of Basis

Appendix 1

emission limits

63.6635 Establishes criteria for continuing compliance demonstration 

with emission limits

Applies only to non-emergency engines

63.6640(a) Requires operating emergency RICE rated ≤ 500 hp at major 

sources of HAP according to manufacturer’s operation and 

maintenance instructions or according to a plan consistent with 

good air pollution control practice for minimizing emissions

Subsumed by Condition IX.A.1

63.6640(b) Requires reporting of failure to meet operating limitations Subsumed by standard title V reporting 

requirements: Condition IX.B.2

63.6640(c) Reserved No applicable requirements

63.6640(d) Deviations during new engine burn-in period are excusable Engines are not new engines

63.6640(e) Requires reporting of deviations from applicable general 

provisions of part 63

Subsumed by standard title V reporting 

requirements: Condition IX.B.2

63.6640(f)(1) Establishes operating requirements for emergency RICE except 

emergency RICE rated > hp at a major source of HAP installed 

prior to June 12, 2006

Condition IX.A.5

63.6640(f)(2) Establishes operating requirements for emergency RICE rated > 

hp at a major source of HAP installed prior to June 12, 2006

The permittee does not operate any 

engines rated > 500 hp

63.6645(a) Requires certain notifications from the general requirements of 

part 63

Engines with no numerical emission 

limit are exempt from this requirement

63.6645(b)-(f) Establishes initial notification requirements Not ongoing

63.6645(g)-(h) Establishes notification requirements for performance tests Subpart does not require performance 

tests

63.6650(a)-(e) Requires certain reports from owners and operators on nonemergency RICECondition IX.B.2

63.6650(f) All deviations from requirements of the subpart must be 

reported as part of title V reporting

Subsumed by standard title V reporting 

requirements: Condition IX.B.2

63.6650(g) Requires additional reporting when digester or landfill gas 

combusted

Permittee does not combust digester or 

landfill gas

63.6655(a)-(d) Establishes recordkeeping requirements None of these apply except for records 

of malfunctions (63.6655(a)(2)), which 

is subsumed by permit Condition 

IV.B.3

63.6655(e)&(f) Requires records to be kept of required maintenance and hours 

of operation 

Condition IX.B.1

63.6660 Requires records to be maintained for at least 5 years in an 

accessible format

Record keeping requirement subsumed 

by Condition III.C.3

63.6665 Describes which parts of the general requirements of part 63 

apply 

No applicable requirements

63.6670 Implementation and enforcement No applicable requirements

63.6675 Definitions No applicable requirements
Page 12 of 17 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Statement of Basis

Appendix 1

40 CFR Part 63 Subpart A: General Provisions (as applied to IFR tanks)

Citation Description Requirements

63.1 Applicability No applicable requirements

63.2 Definitions No applicable requirements

63.3 Units and abbreviations No applicable requirements

63.4(a)(1) States that no owner or operator must act in violation and that 

those in compliance with extensions or exemptions are in 

compliance

Applies to those subject to exemptions 

or extensions

63.4(a)(2) States that it is prohibited to fail to keep records or submit 

reports required by part 63

Compliance with conditions requiring 

record keeping and reporting 

guarantees compliance with this 

paragraph, subsumed by Conditions 

VI.C.1, VI.C.2, and VI.C.3.

63.4(a)(3)-(5) Reserved No applicable requirements

63.4(b) Prohibits circumvention of a standard Condition II.L

63.4(c) Prohibits fragmentation to avoid an applicable requirement Condition II.G

63.5 Preconstruction review Not an ongoing requirements

63.6(a)-(c) Establishes applicability and initial compliance dates with 

standards in part 63

No applicable requirements

63.6(d) Reserved No applicable requirements

63.6(e)(1)(i) Requires affected facilities to be properly operated at all times Condition VI.A.1. Streamlined with 

60.11(d)

63.6(e)(1)(iii) States that operation and maintenance requirements 

established under section 112 are enforceable independent of 

any emission limit

No applicable requirements

63.6(e)(2) Reserved No applicable requirements

63.6(f) Establishes criteria for determining compliance with 

nonopacity emission limits

Applies to Administrator

63.6(g) Allows use of an alternative nonopacity standard No applicable requirements

63.6(h) Establishes criteria for determining compliance with opacity 

standards

Part 63 does not apply an opacity 

standard at the facility

63.6(i)&(j) Allows extension of or exemption from compliance with a 

standard

Permittee has not applied for an 

extension or exemption beyond 

requirements of consent decree

63.7(a) Requires initial performance testing Not ongoing

63.7(b)-(g) Establishes testing requirements Subsumed by Conditions III.B.1 and 

III.B.2

63.7(h) Allows Administrator to waive test requirements Applies to Administrator

63.8 Sets monitoring requirements for CMS No applicable requirements

63.9(a) Applicability of notification requirements No applicable requirements

63.9(b) Sets requirements for initial NESHAP notifications Not ongoing

63.9(c) Allows owners and operators of affected sources to request an 

extension of compliance

Permittee has not requested an 

extension of compliance

63.9(d) Requires notification by owners or operators that a source is 

subject to special compliance requirements

Permittee is not subject to special 

compliance requirements

63.9(e) Requires notification to permit authority of upcoming 

performance tests at least 60 days in advance

Subsumed by Condition III.D.8

63.9(f) Requires notification to the permit authority before 

performing opacity testing

Permittee not subject to an opacity 

standard by part 63

63.9(g)(1) Requires notification of CEMS performance tests No applicable requirements

63.9(g)(2) Requires notification of COMS performance tests Permittee not required to operate a 

COMS by part 63

63.9(g)(3) Requires notifications of an alternative to RATA testing No applicable requirements

63.9(h) Requires notifications of compliance status Reporting Condition subsumed by 

standard title V reporting. See 

63.9(h)(3). Condition III.D.1

63.9(i) Allows owners or operators of affected sources to request to Permittee has not requested such a 
Page 13 of 17 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Statement of Basis

Appendix 1

modify reporting timelines modification

63.9(j) Requires reporting to the Administrator within 15 days 

whenever any information already provided under this part 

has changed

Superseded by title V notification 

provisions. Condition III.D.1

63.10(a) Applicability and general information about recordkeeping 

and reporting

No applicable requirements

63.10(b)(1) Requires files to be maintained for at least five years Superseded by title V recordkeeping 

requirements Condition III.C.3

63.10(b)(2)(i)&(ii) Requires records to be kept related to startup, shutdown, and 

malfunctions 

No applicable requirements

63.10(b)(2)(iii) Requires records to be kept related to maintenance of control 

equipment

Compliance with recordkeeping 

requirements from the subpart 

guarantee compliance with this 

paragraph. Condition VI.C.2

63.10(b)(3) Requires records of NESHAP inapplicability determinations If triggered

63.10(c) Applies additional recordkeeping requirements for CEMS CEMS are not required for IFR tanks

63.10(d)(1) Requires permittee to submit reports required by subparts Redundant requirement subsumed by 

title V reporting requirements

63.10(d)(2) Requires reporting of test results Subsumed by permit Condition III.D.8

63.10(d)(3) Requires reporting of opacity testing Permittee not subject to an opacity 

standard by part 63

63.10(d)(4) Requires submittal of progress reports Permittee has not applied for an 

extension of compliance

63.10(e) Additional reporting requirements for facilities with 

continuous monitoring systems

No CMS on IFRs

63.10(f) Allows the permittee to apply for a waiver from 

recordkeeping requirements

Permittee has not applied for a waiver

63.11 Contains control device and work practice standards that 

apply when referenced by an applicable subpart

This section has not been referenced 

by an applicable subpart

63.12 State authority and delegation No applicable requirements

63.13 Addresses No applicable requirements

63.14 Incorporation by Reference No applicable requirements

63.15 Availability of Information and Confidentiality No applicable requirements

63.16 Performance Track Provisions No applicable requirements
Page 14 of 17 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Statement of Basis

Appendix 1

40 CFR Part 63 Subpart A: General Provisions (as applied to gasoline loading racks)

Citation Description Requirements

63.1 Applicability No applicable requirements

63.2 Definitions No applicable requirements

63.3 Units and abbreviations No applicable requirements

63.4(a)(2) Prohibited activities Condition III.C.3

63.4(b) Prohibits circumvention of a standard Conditions II.L and VIII.A.1. 

Streamlined with circumvention 

prohibition from part 60

63.4(c) Prohibits fragmentation to avoid an applicable requirement Condition II.G

63.5 Preconstruction review Not an ongoing requirement

63.6(a)-(c) Establishes applicability and initial compliance dates with 

standards in part 63

No applicable requirements

63.6(d) Reserved No applicable requirements

63.6(e)(1)(i) Requires affected facilities to be properly operated at all times Conditions IV.A.2 and VIII.A.1. 

Streamlined with 60.11(d)

63.6(e)(1)(iii) States that operation and maintenance requirements established 

under section 112 are enforceable independent of any emission 

limit

Condition IV.A.3

63.6(e)(2) Reserved No applicable requirements

63.6(f) Establishes criteria for determining compliance with nonopacity 

emission limits

Applies to Administrator

63.6(g) Allows use of an alternative nonopacity standard No applicable requirements

63.6(h) Establishes criteria for determining compliance with opacity 

standards

Part 63 does not apply an opacity 

standard at the facility

63.6(i)&(j) Allows extension of or exemption from compliance with a 

standard

Permittee has not applied for an 

extension or exemption beyond 

requirements of consent decree

63.7(a) Requires initial performance testing Not ongoing

63.7(b)-(g) Establishes testing requirements Subsumed by Conditions III.B.1, 

III.B.2, and VIII.B.2

63.7(h) Allows Administrator to waive test requirements Applies to Administrator

63.8(a) Applicability No applicable requirements

63.8(b) Conduct of Monitoring Condition VIII.B.9

63.8(c)(1)-(8) Operation and Maintenance of CMS Conditions VIII.A.1, VIII.B.5-12, 

VIII.C.2 and VIII.C.3

63.8(d) Quality Control Program of CMS Condition VIII.B.7

63.8(e) Performance Evaluation of CMS No applicable requirements. Permittee 

is required, instead, to submit a 

performance test plan.

63.8(f) Use of an alternative monitoring method No applicable requirements. Permittee 

has not requested an alternative 

monitoring method.

63.8(g) Reduction of monitoring data No applicable requirements.

63.9(a) Applicability of notification requirements No applicable requirements

63.9(b) Sets requirements for initial NESHAP notifications Not ongoing

63.9(c) Allows owners and operators of affected sources to request an 

extension of compliance

Permittee has not requested an 

extension of compliance

63.9(d) Requires notification by owners or operators that a source is 

subject to special compliance requirements

Permittee is not subject to special 

compliance requirements

63.9(e) Requires notification to permit authority of upcoming 

performance tests at least 60 days in advance

Subsumed by Condition III.D.8

63.9(f) Requires notification to the permit authority before performing 

opacity testing

Permittee not subject to an opacity 

standard by part 63

63.9(g)(1) Requires notification of CEMS performance tests Subsumed by Condition III.D.8

63.9(g)(2) Requires notification of COMS performance tests Permittee not required to operate a 

COMS by part 63
Page 15 of 17 Mobil Oil – Cabras Terminal Prepared: _DATE_

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Appendix 1

63.9(g)(3) Requires notifications of an alternative to RATA testing Permittee does not use an alternative to 

RATA testing

63.9(h) Requires notifications of compliance status Reporting Condition subsumed by 

standard title V reporting. See 

63.9(h)(3). Condition III.D.3

63.9(i) Allows owners or operators of affected sources to request to 

modify reporting timelines

Permittee has not requested such a 

modification

63.9(j) Requires reporting to the Administrator within 15 days 

whenever any information already provided under this part has 

changed

Superseded by title V notification 

provisions

63.10(a) Applicability and general information about recordkeeping and 

reporting

No applicable requirements

63.10(b)(1) Requires files to be maintained for at least five years Superseded by title V recordkeeping 

requirements. Condition III.C.3

63.10(b)(2)(iii) Requires records to be kept on maintenance performed on air 

pollution control and monitoring equipment

Conditions VIII.C.3

63.10(b)(3) Requires records of NESHAP inapplicability determinations If triggered

63.10(c) Applies additional recordkeeping requirements for CEMS Condition VIII.C.3

63.10(d)(1) Requires permittee to submit reports required by subparts Redundant requirement subsumed by 

title V reporting requirements

63.10(d)(2) Requires reporting of test results Subsumed by permit Condition III.D.8

63.10(d)(3) Requires reporting of opacity testing Permittee not subject to an opacity 

standard by part 63

63.10(d)(4) Requires submittal of progress reports Permittee has not applied for an 

extension of compliance

63.10(e)(1) Requires reporting of CEMS data from each CEMS when more 

than one CEMS is used

Permittee only operates one CEMS

63.10(e)(2)(i) Requires reporting of CEMS performance evaluations with 

source test reports

Superseded by title V source test 

reporting requirements

63.10(e)(2)(ii) Requires reporting of COMS performance evaluation results Permittee not subject to an opacity 

standard by part 63

63.10(e)(3)(i) Requires CEMS excess emissions reports Condition VIII.C.6

63.10(e)(3)(ii) Allows permittees subject to quarterly or more frequent CEMS 

reporting to apply to reduce the reporting frequency

Permittee not subject to quarterly or 

more frequent CEMS reporting

63.10(e)(3)(iii) Sets criteria for the Administrator to apply to applications to 

reduce CEMS reporting frequency

Applies to the Administrator

63.10(e)(3)(iv) Requires CEMS reporting to revert to original frequency if, 

after the Administrator allows less frequent monitoring, the 

source is found not to be in compliance. 

Permittee not subject to quarterly or 

more frequent CEMS reporting

63.10(e)(3)(v)-

(viii)

Establishes content for semiannual CEMS summary reporting Condition VIII.C.5, some details 

incorporated by reference

63.10(e)(4) Requires COMS data to be collected during performance tests 

to be reported

Permittee not required to operate a 

COMS by part 63

63.10(f) Allows the permittee to apply for a waiver from recordkeeping 

requirements

Permittee has not applied for a waiver

63.11 Contains control device and work practice standards that apply 

when referenced by an applicable subpart

This section has not been referenced by 

an applicable subpart

63.12 State authority and delegation No applicable requirements

63.13 Addresses No applicable requirements

63.14 Incorporation by Reference No applicable requirements

63.15 Availability of Information and Confidentiality No applicable requirements

63.16 Performance Track Provisions No applicable requirements
Page 16 of 17 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Statement of Basis

Appendix 1

40 CFR Part 63 Subpart A: General Provisions (as applied to stationary IC engines)

Citation Description Requirements

63.1 Applicability No applicable requirements

63.2 Definitions No applicable requirements

63.3 Units and abbreviations No applicable requirements

63.4(a)(1) States that no owner or operator must act in violation and that 

those in compliance with extensions or exemptions are in 

compliance

Applies to those subject to exemptions 

or extensions

63.4(a)(2) States that it is prohibited to fail to keep records or submit

reports required by part 63

Compliance with conditions requiring 

record keeping and reporting 

guarantees compliance with this 

paragraph, subsumed by Conditions 

III.C.3 and IX.B

63.4(a)(3)-(5) Reserved No applicable requirements

63.4(b) Prohibits circumvention of a standard Condition II.L

63.4(c) Prohibits fragmentation to avoid an applicable requirement Condition II.G

63.5 Preconstruction review Not an ongoing requirement

63.6(a)-(c) Establishes applicability and initial compliance dates with 

standards in part 63

No applicable requirements

63.6(d) Reserved No applicable requirements

63.6(f) Establishes criteria for determining compliance with 

nonopacity emission limits

Applies to Administrator

63.6(g) Allows use of an alternative nonopacity standard No applicable requirements

63.6(h) Establishes criteria for determining compliance with opacity 

standards

Part 63 does not apply an opacity 

standard at the facility

63.6(i)&(j) Allows extension of or exemption from compliance with a 

standard

Permittee has not applied for an 

extension or exemption beyond 

requirements of consent decree

63.7(a) Requires initial performance testing Not ongoing

63.7(b)-(g) Establishes testing requirements NESHAP does not require testing for 

existing emergency RICEs

63.7(h) Allows Administrator to waive test requirements Applies to Administrator

63.8 Sets monitoring requirements for CMS NESHAP does not require CMS for 

existing emergency RICEs

63.9(a) Applicability of notification requirements No applicable requirements

63.9(b) Sets requirements for initial NESHAP notifications Not ongoing

63.9(c) Allows owners and operators of affected sources to request an 

extension of compliance

Permittee has not requested an 

extension of compliance

63.9(d) Requires notification by owners or operators that a source is 

subject to special compliance requirements

Permittee is not subject to special 

compliance requirements

63.9(e) Requires notification to permit authority of upcoming 

performance tests at least 60 days in advance

NESHAP does not require testing for 

existing emergency RICES

63.9(f) Requires notification to the permit authority before performing 

opacity testing

Permittee not subject to an opacity 

standard by part 63

63.9(g)(1) Requires notification of CEMS performance tests NESHAP does not require CEMS

63.9(g)(2) Requires notification of COMS performance tests Permittee not required to operate a 

COMS by part 63

63.9(g)(3) Requires notifications of an alternative to RATA testing NESHAP does not require CEMS

63.9(h) Requires notifications of compliance status Reporting condition subsumed by 

standard title V reporting. See 

63.9(h)(3).

63.9(i) Allows owners or operators of affected sources to request to 

modify reporting timelines

Permittee has not requested such a 

modification

63.9(j) Requires reporting to the Administrator within 15 days 

whenever any information already provided under this part has 

changed

Superseded by title V notification 

provisions

63.10(a) Applicability and general information about recordkeeping and No applicable requirements
Page 17 of 17 Mobil Oil – Cabras Terminal Prepared: _DATE_

Draft Statement of Basis

Appendix 1

reporting

63.10(b)(1) Requires files to be maintained for at least five years Superseded by title V recordkeeping 

requirements. Condition III.C.3

63.10(b)(3) Requires records of NESHAP inapplicability determinations If triggered

63.10(c) Applies additional recordkeeping requirements for CEMS NESHAP does not require CEMS

63.10(d)(1) Requires permittee to submit reports required by subparts Condition IX.B.3

63.10(d)(2) Requires reporting of test results NESHAP does not require testing for 

existing emergency RICEs

63.10(d)(3) Requires reporting of opacity testing Permittee not subject to an opacity 

standard by part 63

63.10(d)(4) Requires submittal of progress reports Permittee has not applied for an 

extension of compliance

63.10(e) Additional reporting requirements for facilities with 

continuous monitoring systems

No CMS on RICE

63.10(f) Allows the permittee to apply for a waiver from recordkeeping 

requirements

Permittee has not applied for a waiver

63.11 Contains control device and work practice standards that apply 

when referenced by an applicable subpart

This section has not been referenced by 

an applicable subpart

63.12 State authority and delegation No applicable requirements

63.13 Addresses No applicable requirements

63.14 Incorporation by Reference Condition IX.A.5.b.2

63.15 Availability of Information and Confidentiality No applicable requirements

63.16 Performance Track Provisions No applicable requirements