### Page 1 of 24 Mobil Oil

– Cabras Terminal Prepared: _DATE_

Draft Statement of Basis 

# *****DRAFT*****



# Part 71 Federal Operating P ermit

Draft Statement of B asis

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 Monitor ing

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 pol lutant

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

NO
x 

## reactive oxides of nitrogen

NSPS New Source Performance Standards

NSR New Source Review

PM particulate matter

PM 10 

## particulate matter with an aerodynamic diameter less than 10 microns

PM 2.5 

## particulate matter with an aerodynamic diameter less than 2.5 microns

PSD Prevention of Significant Deterioration psi g 

## pounds per square inch, gauge pressure

PTE potential to emit

RICE reciprocating internal combustion engine

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

SIP State Implementation Plan

SO 2 

## 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 1 8
7. Public Participation 23

### Page 4 of 24 Mobil Oil

– Cabras Terminal Prepared: _DATE_

Draft Statement of Basis 

# Disclaimer:

T his docume nt 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

M ajor 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 doc uments 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 permit s 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 p art 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 C FR 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 ( N ESHAP ) for gasoline distribution facilities (40 CFR part 63, subpart R) . Because of EPA’s once in always in policy r egarding 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 operati ng permit

, title V permit

, and part 71 pe r mit are used interchangeably with respect to the Cabras Terminal.

1 

### EPA granted approval to Guam’s part 69 alternativ e 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 eth nic 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

hou sehold 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 interpr etation of the draft permit and statement of basis is requested during the public comment period , EPA will issue these documents in English only.

T his permit issuance does not allow or authorize additional air pollution from existing units at the facility , and consequently will not result in addition al 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 clea n 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, t hose portions of Guam within 3.5 km of either the Piti or Tanguisson power plant are cl assified 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 l i e s 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: G aret Olivares

, Upper Pacific Islands Operations Manager, (671) 479

- 32 56

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

- 365 5

3.3. Description of Operations

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

H arbor 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 T erminal 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 B ulk 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 Justi ce (DOJ) on behalf of the EPA

. The Consent Decree required Mobil to comply with 40 CFR part
60, s ub parts A, Kb, and XX and 40 CFR part 63, s ubparts A and R; comply wi th a set of binding obligations; and app ly for and obtain a title V operat ing 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 inclu de gasoline and distillate fuel storage t anks, 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 app lication 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 dist illate 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

- 1 0 ICE

- 2: 300 kW Caterpillar emergency diesel generator None

Golf Pier EU

- 1 1 Submerged fill loading of gasoline and distillate fuel to local coastal

tankers None

Facility

- wide EU

- 1 2 Fugitive emissions from equipment in gasoline service None



## 4.2. Insignificant Emissio n 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)(i i) based on potent ial to emit. 3 

## As stated in 4.1, EPA has determined

that one of the se 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 gallo n VFR diesel tank supplying IEU

- 1

IEU

- 3 150 gallon VFR diesel tank supplying EU

- 1 0 and IEU

- 1

IEU

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

3 

### No more than 1,00 0 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

- 1 3



## 4.3. Emission Calculation Methodology

4.3.1. Criteria Pollutants

In general, Mobil used emission fac tors 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, howe ver, results in the emission of CO, NO
x 

## , PM, and SO 2 

## in

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

estimated to be PM 10 

## and PM 2.5



## .

Table 4.3: VOC and Criteria Pollutant Emission Factors and Calculation Method ologies

Source Type Emission Factor and Calculation Methodology Source Storage t anks 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, Ta ble 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 re sources, (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 cal culate greenhouse gas (GHG) emissions as a part of the Cabras permit application. As Mobil submitted this application in 2010, before GHG emis si on 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 

## r equire 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 p ote ntial to emit is defined as: t he 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 polluti on 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

enf orceable limits are taken, the terminal should be considered to be a major source of VOC and
organic HAP.

The facility’s p otential to emit CO, NO
x 

## , PM, and SO 2 

## , on the other hand, is highly conservative. These pollutants are emitted by the facility’s emerg ency 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 PM 10 

## and PM 2.5



## .

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

CO NO
x PM /PM 10 /PM 2.5 SO 2 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 t he 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 NO
x PM/PM 10 /PM 2.5 SO 2 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 feder al regulations to the facility. The applicability of these regulations may change given new information about the facility’s operations or if the facility is rec onstructed 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: Sta ndards of Performance for Storage Vessels for Petroleum Liquids for which Construction, Reconstruction, or Modification Commenced after May 1 8 , 1978 and prior to July 23, 1984 X

40 CFR Part 60 Subpart Kb: Standards of Performance for Volatile Organic Li quid 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 Reciprocatin g 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 CC CCCC : 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 T erminal is subject to the permitting requirements of title V of the Act because it has the potential to emit at least 100 tons per yea r 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

. T he facility is subject to 40 CFR part 71, the federal air operating permit program

, because major HAP sour ces 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 s ources 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 ai r pollutant and is s ubject to a standard in 40 CFR p art 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 Stor age 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 1 8 , 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 Construct ion, 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 s torage vessels larger than 75 m 3 

## (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 in spection schedules and procedures for the required control equipment and

### Page 13 of 24 Mobil Oil

– Cabras Terminal Prepared: _DATE_

Draft Statement of Basis 

## associated recordkeeping and reporting requirements.

T he 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 V I

.

5.3.5. Subpart XX

The Cabras Terminal is subject to subpart XX, Standards of Performa nce 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 a lso subject to 40 CFR Part 63, s ubpart R, National Emission Standards for Gasoline Distribution Facilities , a pplicable requirements from the two standards

have been streamlined and include d 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. Bec ause 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 Re quirements 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, tr uck 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 Fa cilities

.

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 implementi ng the operating permit requirements of Condition VI for storage vessels, Condition VIII for loading racks, and Condition X I for the leak detection and repair program for equipment in gasoline service

.

Applicable requirements from subpart R have been stre amlined with applicable requirements from subparts Kb and XX of 40 CFR part 60 as appropriate and included in the air operating permit in Condition s V I , VI II , and XI

.

5.5.3. Subpart Y

Because of actual loading volumes, marine tank vessel loading equipment at th e 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 d oes 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 o f crude oil, compliance with the conditions in Condition X will assure compliance with the

s ubpart.

5.5.4. Subpart ZZZZ

Subpart ZZZZ, National Emission Standards for Stationary Reciprocating Internal Combustion Engines (RICE) , applies to new and existing statio nary RICE. Because all of the RICE are

emergency

- use, compression ignition engines rated less than 500 brake

- horsepower, subpart ZZZZ applies only work pra ctice standards . These standards are included in the air operating permit in Condition IX

.

5.5.5. Subpart B BBBBB

According to 40 CFR § 63.11081(a)(1), s ubpart 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 sub ject 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 S ource 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 additiona l 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 pol lutant 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 loadi ng racks to 10 mg/L. This emission limit has been streamlined with a higher emission limit from 40 CFR part 60, subpart XX. The s e are the only explicit emission limit s at the Cabras Terminal. A control device, a carbon adsorption system, is used to meet th is limit. Without controls, the truck loading racks could emit more than 100 tons of VOC per year.

A ccording 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 sectio n 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 befor e 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 Cab ras 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 c apable of measuring organic compound

concentr ation in the exhaust air stream of the carbon adsorption sy stem. Furthermore, Condition

VIII.B.3 requires the permittee to determine an operating parameter to monitor in order to verify continuous complia nce with the emission standard. Therefore, the CAM R ule 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 CA M Rule.

5.7. Chemical Accident Pr e vention (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 necessar y.

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 P rogram 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 h andling 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 certific ation of compliance, a permit shield is not necessar y.

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 requirem ents 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 condit ions in a facility’s air operating permit, which are enforceable by EPA and any citizen, differ from t he local regulations enforced by the local authority (i.e.

, GEPA).

Applicable requirements in Guam’s S IP have been included in Condition IV of the operat ing 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

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Draft Statement of Basis 

## EPA has no authority to enforce Guam’s local regulations that are not in the SIP and these regulati ons are not included in the operating permit. Complianc e 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. Endanger ed 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 auth orize 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, an d 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 p ermit 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 requirement s.

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 t he 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

req uirements 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 pl ans

.

The following is a discussion of the organization of the permit. Although s ome permit conditions are discussed individually, these conditions should not be misunderstood to be “more important” than other conditions and the permittee is required to co mply 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 se ction 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

r esponsibility 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 A ssurance 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 t he 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 relat ed to the Chemical Accident

Prev ention Program. Although EPA is not aware of any regulated substances stored at the Cabra s 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 bec ome 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 refrigeran ts, that is subject to this program is maintained by

certified individuals.

### Page 20 of 24 Mobil Oil

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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 p ermittee 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 permit tee 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 complianc e 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, an d 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 t o use through the website s hould be submit ted electronically . Otherwise, the permittee is re quired 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 , req uires 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 Specif ic 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 c urrent 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 seve ral compliance options, Mobil has chosen to comply with these stand ards by equipping tanks that contain gasoline with an internal floating roof and an external fixed roof (these are called IFR tanks).

C ondition VI includes the applicable subparts that ap ply to IFR tanks and include design criteria, inspection procedures and schedules, remedial actions, and record keeping and r eporting provisions. Because of lengthy descriptions of design criteria and inspection procedure s, much of the subparts are incorpo rated 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 t ank 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 re quirements 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 c arbon 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 hydro carbon 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. Inte rnal 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 emergen cy 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 t he 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 submer ged loading, to keep records of materials loaded into

marine tank vessels and to e stimate 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 ope rating permits shall be publicly noticed

and mad e available for public comment. The public notice of permit actions and public comment

per iod is described in 40 CFR 71(d).

There is a 30

- day public comment period for actions pertaining to a draft p ermit. P ublic 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 not ice will also be pub lished 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 m aterials 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://ww w.epa.gov/caa

- permitting/caa

- permitting

- epas

- pacific

- southwest

region ) , 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:

M r. Garet Olivaries , Upper Pacific Islands Operations Manager

1

- 671

- 479

- 32 56

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, Ma riner 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 availa ble

referenced materials.

### Page 24 of 24 Mobil Oil

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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 p ermit. 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 Informati on

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 R equirements

### 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 Applic ability 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 n ot 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 m 3 total volume containing volatile organic liquids with a vapor pressure greate r 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 require ments 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 app licable 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 requir ements. 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 subs umed 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 wi th 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 a pplicable 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) Re quires 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) Allo ws 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 applicabl e 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 cl arify 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) R equires 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

60.1 1(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 C ondition I I.C.1

60.12 Prohibits circumvention Cond ition 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

meth ods

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 

## 4 u 0 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 source s 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 vap ors 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 g asoline 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 openi ng 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) Es tablishes 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 complianc e 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 recordkeepin g 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 b e 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 start ups, 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 app licable 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,

Condition s 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 C onditions 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 co mpliance 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 fro m part 60 60.11(d) Requires affected facilities to be properly operated at all times Condition s 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 N o 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 co mpliance Included in C ondition 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 Modific ation 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 Facilit y 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 Distributio n 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 V III.A

63.422(c) Establishes procedures for loadin g 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 requir ements. 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 60.112 b(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 estab lishment 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 t o 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. F acility

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

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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 re porting. 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 Cond ition 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 alre ady 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 loadi ng 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 re cords 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

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Draft Statement of Basis
Appendix 1 

## 40 CFR Part 63 Subpart Y: National Emission Stand ards 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) Facil ity 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 Cond ition X.B.1 (streamlined with 63.565(l)) and C ondition 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 a ffected

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 sta ndards 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 mon itoring 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) Esta blishes 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 affect ed 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 s ummary 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 Fac ility 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 su bsumed 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 equipm ent subject to 63.562(d) to develop a communication program increasing the Facility is not subject to 63.562(d)

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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 requir ements

### Page 10 of 17 Mobil Oil

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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 su bject 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 rat ed ≥ 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 existi ng 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) Re quires compliance with emission limitations and operating

limitations at all times Subsumed by C onditions 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 C ondition 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

reconstructe d 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 req uirements 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

whe n 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 after

treatment control device 63.6625(f) Requires a non

- resettable hour meter on emergency RICE rated ≤ 500 hp at major sour ces 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 non

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

63.6 625(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 bet ween 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

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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 consiste nt with good air pollution control practice for minimizing emissions Subsumed by C ondition I X.A.1

63.6640(b) Requires reporting of failure to meet operating limitations Subsumed by standard title V reporting requirements: C ondition IX.B.2 63.6640(c) Res erved 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 repor ting requirements: C ondition 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 requir ements 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 num erical 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 non

emergency RICE Condition 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: C ondition 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 malfunc tions (63.6655(a)(2)), which is subsumed by permit C ondition

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

accessibl e 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 Definition s No applicable requirements

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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 abbreviat ions 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) Rese rved 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 s 63.6(a)

- (c) Establish es 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) Establishe s 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

standa rds 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 ini tial performance testing Not ongoing
63.7(b)

- (g) Establishes testing requirements Subsumed by C onditions 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 a pplicable 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 o f 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) Requi res notification to permit authority of upcoming performance tests at least 60 days in advance Subsumed by C ondition III.D. 8

63.9(f) Requires notification to the permit authority before performing opacity testing Permittee not subject to an opacity

standa rd by part 63 63.9(g)(1) Requires notification of CEMS performance tests No applicable requirement s 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 al ternative to RATA testing No applicable requirements 63.9(h) Requires notifications of compliance status Reporting C ondition 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

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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 notificati on 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 requireme nts 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 reco rdkeeping 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 applica ble 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

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Draft Statement of Basis
Appendix 1 

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

Citati on 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 circumve ntion of a standard Condition s 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 Condition s IV.A.2 a nd 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 C onditions 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) Applicabilit y 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) Perf ormance 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 meth od. 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 operator s 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 tes ting 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 p art 63

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Draft Statement of Basis
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 leas t 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 Condition s VIII.C.3

63.10(b)(3) Requires records of N ESHAP 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 report s 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 r eports 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) R equires 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 appl icable 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

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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) Sta tes 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 Condition s III.C.3 and IX.B 63.4(a)(3)

- (5) Reserved No applicable requirements 63.4(b) Prohibits circumv ention 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

standard s 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 h as 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

6 3.9(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 ow ners 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 do es 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) Require s 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

modificati on 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

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Draft Statement of Basis
Appendix 1 r eporting
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 t esting 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 requirement s
63.14 Incorporation by Reference C ondition IX.A.5.b.2

63.15 Availability of Information and Confidentiality No applicable requirements

63.16 Performance Track Provisions No applicable requirements