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HomeMy WebLinkAbout20131081.tiffSTATE OF COLORADO John W. Hickenlooper, Governor Christopher E. Urbina, MD, MPH Executive Director and Chief Medical Officer Dedicated to protecting and improving the health and environment of the people of Colorado 4300 Cherry Creek Dr. S. Denver, Colorado 80246-1530 Phone (303) 692-2000 Located in Glendale, Colorado http://www.cdphe.state.co.us Weld County Clerk & Recorder 1402 N 17th Ave Greeley, CO 80631 April 25, 2013 Laboratory Services Division 8100 Lowry Blvd. Denver, Colorado 80230-6928 (303) 692-3090 BEcovED wino COELD 0- M M1SSI 0NERS Colorado Department of Public Health and Environment Dear Sir or Madam: On April 29, 2013, the Air Pollution Control Division will publish a public notice for Kerr-McGee Oil and Gas Onshore LP — 35029745, in the The Greeley Tribune. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the date the public notice is published. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health & Environment APCD-S S -B 1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure L 1Wvrr,GJ 5Neh3 ?l r �41-I 13 2013-1081 STATE OF COLORADO John W. Hickenlooper, Governor Christopher E. Urbina, MD, MPH Executive Director and Chief Medical Officer Dedicated to protecting and improving the health and environment of the people of Colorado 4300 Cherry Creek Dr. S. Denver, Colorado 80246-1530 Phone (303) 692-2000 Located in Glendale, Colorado http://www.cdphastate.co.us Laboratory Services Division 8100 Lowry Blvd. Denver, Colorado 80230-6928 (303) 692-3090 Colorado Department of Public Health and Environment Website Title: Kerr-McGee Oil and Gas Onshore LP — Natural gas wellhead site — Weld County Released To: The Greeley Tribune On: April 25, 2013 Published: April 29, 2013 PUBLIC NOTICE OF A PROPOSED PROJECT OR ACTIVITY WARRANTING PUBLIC COMMENT Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: Kerr-McGee Oil and Gas Onshore LP Facility: 35029745 Natural gas wellhead site SWSE Section 5, Township 3 North, Range 63 West Weld County The proposed project or activity is as follows: Oil and gas wellhead site permitting a truck loadout and associated fugitive emissions The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.I.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area) The Division has made a preliminary determination of approval of the application. A copy of the application, including supplemental information, the Division's analysis, and a draft of Construction Permit 12WE1578 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at www.colorado.gov/cdphe/AirPublicNotices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Any such comment must be submitted in writing to the following addressee: Stephanie Chaousy Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B 1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us Construction Permit Application Preliminary Analysis Summary Section 1 — Applicant Information Company Name: Kerr-McGee Oil and Gas Onshore LP Permit Number: 12WE1578 Source Name: 35029745 Source Location: SWSE Section 5, T3N, R63W, Weld County (non -attainment) Equipment Description: Point 008: Truck loadout Point 009: Fugitives AIRS ID: 123-9393 Review Date: July 26, 2012 Review Engineer: I Stephanie Chaousy, PE Section 2 — Action Completed X CP1 Modification APEN Required/Permit Exempt Final Approval Transfer of Ownership APEN Exempt/Permit Exempt Section 3 — Applicant Completeness Review Was the correct APEN submitted for this source type? X Yes No Is the APEN signed with an original signature? X Yes No Was the APEN filled out completely? X Yes No Did the applicant submit all required paperwork? X Yes No Did the applicant provide ample information to determine emission rates? X Yes No If you answered "no" to any of the above, when did you mail an Information Request letter to the source? Please see Section 14 On what date was this application complete? April 25, 2012 Section 4 — Source Description AIRS Point Equipment Description 008 Truck condensate loadout. 009 Fugitive emission leaks. Is this a portable source? Yes : X No Is this location in a non -attainment area for any criteria pollutant? X Yes No If "yes", for what pollutant? PM1U CO X Ozone Is this location in an attainment maintenance area for any criteria pollutant? I Yes ; X No If "yes", for what pollutant? (Note: These pollutants are subject to minor source RACT per Regulation 3, Part B, Section III.D.2) PM10 CO Ozone Is this source located in the 8 -hour ozone non - attainment region? (Note: If "yes" the provisions of Regulation 7, Sections XII and XVII.C may apply) X Yes No Pagc: l Point 008: Is this source located at an oil and gas exploration site? X Yes No Point 008: If yes, does this source load less than 10,000 gallons of crude oil per day on an annual average, splash fill less than 6750 bbl of condensate (hydrocarbons that have an API gravity of 40 degrees or greater) per year or submerged fill less than 16,308 bbl of condensate per year? Yes X No Point 008: Is this source located at a facility that is considered a major source of hazardous air pollutant (HAP) emissions? Yes X No Point 008: Does this source load gasoline into transport vehicles? Yes X No Section 5 — Emission Estimate Information AIRS Point Emission Factor Source 008 AP -42: Chapter 5.2, Equation 1 L = 12.46*S*P*M/T L = loading losses in lb per 1000 gallons loaded S = Saturation Factor P = true vapor pressure of liquid loaded [psia] M = molecular weight of vapors [lb/lb-mole] T = temperature of bulk liquid loaded [deg. R] 009 EPA -4531R-95-017, Table 2-4 Did the applicant provide actual process data for the emission inventory? X Yes No Basis for Potential to Emit (PTE) AIRS Point Process Consumption/Throughput/Production 008 400,000 BBL per year condensate loaded 009 Equipment Type Gas Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) Water/Oil Connectors 5580 --- 1956 306 Flanges 54 --- 13 0 Open -Ended Lines 2 --- 8 3 Pump Seals 0 --- 0 0 Valves 569 --- 351 55 Other 84 --- 20 5 Basis for Permitted Emissions (Permit Limits) AIRS Point Process Consumption/Throughput/Production 008 400,000 BBL per year condensate loaded 009 Equipment Type Gas Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) Water/Oil Connectors 5580 --- 1956 306 Flanges 54 --- 13 0 Open -Ended Lines 2 --- 8 3 Pump Seals 0 --- 0 0 Valves 569 --- 351 55 Other 84 --- 20 5 Does this source use a control device? Yes X No Section 6 — Emission Summary (tons per year) Point NO„ VOC CO Single HAP HAP Page 2 PTE: 008 --- 22.3 --- 0.5 (n -hexane) 0.6 009 --- 30.2 --- 1.3 (n -hexane) 2.7 Total --- 24.4 --- 0.8 (n -hexane) 2.6 Uncontrolled point source emission rate: 008 --- 22.3 --- 0.5 (n -hexane) 0.6 009 --- 30.2 --- 1.3 (n -hexane) 2.7 Permitted point source emission rate: GP01 --- 39.0 --- 8.0 20.0 008 --- 22.3 --- 0.5 (n -hexane) 0.6 009 --- 30.2 --- 1.3 (n -hexane) 2.7 Total --- 91.5 --- 9.8 (n -hexane) 23.3 Section 7 — Non -Criteria / Hazardous Air Pollutants Pollutant CAS # BIN Uncontrolled Emission Rate (Ib/yr) Are the emissions reportable? Controlled Emission Rate (Ib/yr) Point 008 Benzene 71432 A 153 Yes N/A n -Hexane 110543 C 944 No N/A Point 009 Benzene 71432 A 524 Yes N/A Toluene 108883 C 1026 Yes N/A Xylenes 1330207 C 1146 Yes N/A n -Hexane 110543 C 3134 Yes N/A Note: Regulation 3, Part A, Section II.B.3.b APEN emission reporting requirements for non -criteria air pollutants are based on potential emissions without credit for reductions achieved by control devices used by the operator. Section 8 —Testing Requirements Will testing be required to show compliance with any emission rate or regulatory standard? Yes X No Section 9 — Source Classification Is this a new previously un-permitted source? X Yes No What is this point classification? X True Minor Synthetic Minor Major What is this facility classification? True Minor X Synthetic Minor Major Classification relates to what programs? X Title V PSD X NA NSR MACT Is this a modification to an existing permit? Yes X No If "yes" what kind of modification? Minor Synthetic Minor Major Section 10 — Public Comment Does this permit require public comment per CAQCC Regulation 3? X Yes No If "yes", for which pollutants? Why? For Reg. 3, Part B, III.C.1:a (emissions increase > 25/50 tpy)? X Yes No Page 3 For Reg. 3, Part B, III.C.1.c.iii (subject to MACT)? Yes X No For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)? Yes X No Section 11 —Modeling Is modeling required to demonstrate compliance with National Ambient Air Quality Standards (NAAQS)? Yes X No AIRS Point Section 12 — Regulatory Review Regulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide 008, 009 Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, oor adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.1. & 4.) Regulation 2 - Odor 008, 009 Section I.A - No person, wherever located, shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven (7) or more volumes of odor free air. Regulation 3-APENs, Construction Permits, Operating Permits, PSD 008, 009 Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for: each individual emission point in a non -attainment area with uncontrolled actual emissions of two tons per year or more of any individual criteria pollutant (pollutants are not summed) for which the area is non -attainment. (Applicant is required to file an APEN since emissions exceed 1 ton per year VOC) Part B — Construction Permit Exemptions Applicant is required to obtain a permit since uncontrolled VOC emissions from this facility are greater than the 2.0 TPY threshold (Reg. 3, Part B, Section 11.D.2.a) 009 Part B, III.D.2 - RACT requirements for new or modified minor sources This section of Regulation 3 requires RACT for new or modified minor sources located in nonattainment or attainment/maintenance areas. This source is located in the 8 -hour ozone nonattainment area. The date of interest for determining whether the source is new or modified is therefore November 20, 2007 (the date of the 8 -hour ozone NA area designation). Since the tank battery from which loadout is occurring has been in service after the date above, this source is considered "new or modified." Operator is using 0.6 saturation factor (submerged fill), therefore, RACT requirements are satisfied. Regulation 6 - New Source Performance Standards 008 No applicable subpart. This facility is not a bulk gasoline terminal. 009 NSPS KKK: Equipment Leaks of VOC from onshore natural gas processing plants. Affected facilities at onshore natural gas facilities (any processing site engaged in the extraction of natural gas liquids from field gas, fractionation of mixed natural gas liquids (NGLs) or both). Is this source at a "natural gas processing plant?" No Is this source subject to NSPS KKK? No WHY? Facility is not a "natural gas processing plant," therefore, not meeting the criteria of this regulation. Therefore, source not subject. Regulation 7 -Volatile Organic Compounds 008 No sections apply. This facility is neither a terminal, nor a bulk plant per definitions in Reg 7, Section VI.C. 009 Section XII.G: If facility is a natural gas processing plant located in non -attainment area, then subject to Section XII.G. Facility not a natural gas processing plant, therefore, not subject. Regulation 8 — Hazardous Air Pollutants 008 MACT EEEE: Not subject because minor source of HAPs Page 4 009 MACT HH: If facility is MAJOR source for HAP (summation of HAPS of dehydrators and fugitives), then fugitive emissions are subject to MACT HH. Is this facility considered MAJOR for HAPS? No Is this source subject to MACT HH? No WHY? Facility is considered area source MACT HH. Only TEG dehydrators are subject to area source MACT HH (no dehydrators at this facility). Section 13 — Aerometric.Information Retrieval System Coding Information Point Process Process Description Process/ throughp ut Limit Emission Factor Pollutant / CAS # Fugitive (YIN) Emission Factor Source Control (%) 008 01 2.66 lb/1,000 gallon throughput VOC No AP -42 0 Truck Condensate Loadout 200,000 BBL/yr 0.0091 lb/1, 000 gallon throughput benzene No AP -42 0 0.0562 lb/1,000 gallon throughput n -hexane No AP -42 0 SCC 40600132: Crude Oil: Submerged Loading (Normal Service) 009 01 Fugitive VOC Leak Emissions VOC Yes EPA -453/R-95-017, Table 2-4 NA SCC 31000220: All Equip. Leak Fugitives (Valves, flanges, connections, seals, drains) Page 5 Section 14 — Miscellaneous Application Notes AIRS Point 008 Truck Condensate Loadout Units Basis S 0.6 Submerged loading: dedicated normal service P 4.6 Psia Based on EPA TANK M 41 Lb/lb-mole Based on E&P TANK run T 531 Deg R Based on source's knowledge of bulk liquid temperature L 2.66 Lb/10^3 gal 0.112 Lb/bbl This value is used to calculate annual emissions AP -42: Chapter 5.2 Equation 1 L = 12.46*S*P*M/T S 0.6 Submerged loading: dedicated normal service P 4.6 Psia, M 41 lb/lb-mole T 531 deg. R L 2.66Ib/10^3 gal 1.12E-01Ib/bbl Annual requested Throughput 16800000gal/yr Annual requested VOC emissions 446091b/yr 22.3tpy Operator calculated HAPS by representative benzene and n -hexane loading emission composition (mol%) Benzene n -hexane W&S Gas Mol% 0.18 1.00 Lb/Ib-mol (M) 78.11 86.8 Benzene (152.98 Ib/yr) / (400000 bbl/yr) = 0.00038 lb/bbl = 0.009106 lb/1000 gal n -hexane = (944.41 Ib/yr) / (400000 bbl/yr) = 0.00236 lb/bbl = 0.0562 lb/1000 gal Page 6 AIRS Point 009 Fugitive VOC Leak Emissions A permit will be issued because the uncontrolled VOC emissions are greater than 2 TPY (permit threshold). Operator requested a 20% safety factor for their fugitive emission limits. Operator provided a gas analysis dated 7/30/11 with the application. This is within 1 year of the application submittal and review, so I will not request a new gas analysis. I worked with the operator to determine RACT for this facility. I emailed KMG a condition based on AVO that might be sufficient for RACT on 7/19/12. Kerr-McGee did not think that the Division's condition was applicable to their facility because KMG felt that if they were to follow this condition, they should receive control credit since they felt it was a smaller version of a LDAR program. We had several back and forth email conversations regarding this. Some suggestions KMG brought up to satisfy RACT were: 1. The O&M plan: The Division felt that the O&M did not fully meet all the criteria for RACT. 2. 2. Using screening factors: Chris emailed KMG on 3/14/13 saying that the Division will not accept screening emission factors to represent uncontrolled fugitive emissions. KMG must use the average emission factor approach to calculate uncontrolled emissions from fugitive sources. Carissa Money emailed me on 3/20/13 (per meetings and emails with KMG): Please move forward with processing the Kerr McGee E&P site applications that were on hold due to the minor source RACT condition for fugitives. Kerr McGee has been notified that we are moving forward with existing applications using our standard language for minor source RACT. For these applications, we will use our standard emission calculation methodology for fugitives and we will not be assigning a control efficiency for implementing the minor source RACT requirements. if Kerr McGee has not yet seen a draft of the permits and requested to see a draft, please do send them the draft but we will not modify the minor source RACT condition for fugitives. If you have any questions, let me know. AIRS Point Facility Notes The Operator provided a NOS for the loadout and fugitives with the application (operations began June 29, 2011). Therefore, I am not going to require a NOS in the permit. Page 7 STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: 12WE1578 Issuance 1 DATE ISSUED: ISSUED TO: Kerr-McGee Oil and Gas Onshore LP THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as 35029745, located in the SWSE of Section 5, Township 3 North, Range 63 West, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description TL1 008 Truck loadout of condensate. Emissions from the loadout are not controlled. FUG1 009 Equipment leaks (fugitive VOCs) from a wellhead site. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. Within one hundred and eighty days (180) after issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, II.G.2). 2. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (Hi) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) AIRS ID: 123/9393 Page 1 of 10 Condensate Loadout TM Version 2012-1 Collli'ido fpai4?ne a Public Health and Environment #- Air Pollution Control Division 3. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 4. The operator shall retain the permit final authorization letter issued by the Division after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type VOC TL1 008 22.3 Point FUG1 009 30.2 Fugitive See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 6. Point 008: The operator shall calculate actual emissions from this emissions point based on representative component counts for the facility with the most recent gas analysis, as required in the Compliance Testing and Sampling section,of this permit. The operator shall maintain records of the results of component counts and sampling events used to calculate actual emissions and the dates that these counts and events were completed. These records shall be provided to the Division Upon request. PROCESS LIMITATIONS AND RECORDS 7. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) AIRS ID: 123/9393 Page 2 of 10 Process/Consumption Limits oPPublic Health and Environment Air Pollution Control Division IRS Point Process Parameter Annual Limit 008 Condensate Loading 400,000 BBL The owner or operator shall calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 8. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.1.c shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. & 4.) This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 10. Point 008: This source is located in an ozone non -attainment or attainment - maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. The requirements of condition number 10 below were determined to be RACT for this source. 11. Point 008: Condensate loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation 3, Part B, III.E) 12. Point 009: This source is subject to Regulation No. 7, Section XII.C General Provisions (State only enforceable). All condensate collection, storage, processing and handling operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. The operator shall comply with all applicable requirements of Section XII. 13. Point 009: Minor sources in designated nonattainment or attainment/maintenance areas that are otherwise not exempt pursuant to Section II.D. of Regulation No. 3, Part B, shall apply Reasonably Available Control Technology for the pollutants for which the area is nonattainment or attainment/maintenance (Reference: Regulation No. 3, Part B, III.D.2.a). The requirements of condition number 13 below were determined to be RACT for this source. The requirements of condition number 14 below were determined to be RACT for this source. AIRS ID: 123/9393 Page 3 of 10 rhe -i. or Public Health and Environment Air Pollution Control Division 14. Point 009: Minor sources in designated nonattainment or attainment/maintenance areas that are otherwise not exempt pursuant to Section II.D. of Regulation No. 3, Part B, shall apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is nonattainment or attainment/maintenance (Reference: Regulation No. 3, Part B, III.D.2.a). This requirement to apply RACT shall be satisfied by installing/implementing the following emission controls: a. Directed Inspection & Maintenance as described below shall satisfy the requirement to apply RACT. For leak screening, auditory/visual/olfactory inspection (AVO) will be performed twice a year. H. For each leak found in the AVO inspection, use either optical gas imaging (i.e. IR camera) or portable VOC measurement instrument (i.e. a Method 21 instrument) calibrated and maintained per the manufacturer's recommendations to monitor for leaks. Hi. If Method 21 is used, component leaks greater than 10,000 ppm shall be managed in accordance with Item (vi) below, unless it is unfeasible to make the repair without shutting down the affected operation of the facility. For such component leaks that require a shutdown to be repaired, repair shall occur during the first shutdown of the affected operation after the leak is discovered. If optical gas imaging is used, a component shall be considered leaking if any visible emissions are monitored and shall be managed in accordance with Item (vi) below, unless it is unfeasible to make the repair without shutting down the affected operation of the facility. For such component leaks that require a shutdown to be repaired, repair shall occur during the first shutdown of the affected operation after the leak is discovered." iv. For repair, valves adjacent to the equipment to be repaired will be closed if practicable, minimizing the volume released. v. Repaired components shall be re -screened to determine if the leak is repaired. vi. The following records shall be maintained fora period of two years: • The name of the site screened via AVO inspection and the name of the inspector. • Components evaluated with the gas detector. • Repair methods applied. • Dates of the AVO screenings, gas detector calibrations, attempted repairs, successful repairs, repair delays, and post -repair screenings. vii. Leaks shall be repaired as soon as practicable, but no later than 15 calendar days after detection, unless it is technically or operationally infeasible to make the repair within 15 calendar days. Records documenting the rationale shall be maintained if it is technically or operationally infeasible to make the repair within 15 calendar days. OPERATING & MAINTENANCE REQUIREMENTS 15. Point 009: Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the AIRS ID: 123/9393 Page 4 of 10 o Public Health and Environment Air Pollution Control Division requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. Point 009: Within one hundred and eighty days (180) after commencement of operation, the operator shall complete a hard count of components at the source and establish the number of components that are operated in "heavy liquid service", "light liquid service", "water/oil service" and "gas service". The operator shall submit the results to the Division as part of the self -certification process to ensure compliance with emissions limits. Periodic Testing Requirements 17. Point 009: On an annual basis, the owner or operator shall complete an extended gas analysis of gas samples that are representative of volatile organic compounds (VOC) and hazardous air pollutants (HAP) that may be released as fugitive emissions. This extended gas analysis shall be used in the compliance demonstration as required in the Emission Limits and Records section of this permit. ADDITIONAL REQUIREMENTS 18, A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOx) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or AIRS ID: 123/9393 Page 5 of 10 oYPublic Health and Environment Air Pollution Control Division e. No later than 30 days before the existing APEN expires. 19. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS: 20. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 21. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self - Certify for Final Authorization section of this permit. 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 23. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 24. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator or owner or operator of a source may request a hearing before the AQCC for review of the Division's action. AIRS ID: 123/9393 Page 6 of 10 Public Health and Environment Air Pollution Control Division 25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Stephanie Chaousy, P.E. Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Kerr-McGee Oil and Gas Onshore LP. Newly permitted loadout and fugitives at a synthetic minor facility. AIRS ID: 123/9393 Page 7 of 10 Cori' do e or Public Health and Environment Air Pollution Control Division Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See: http://www. cdphe.state. co. us/requ lations/ai rregs/100102agcccom monprov isi onsreq. pdf. 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # BIN Uncontrolled Emission Rate (lb/yr) Are the emissions reportable? Controlled Emission Rate (Ib/yr) 008 Benzene 71432 A 153 Yes N/A n -Hexane 110543 C 944 No N/A 009 Benzene 71432 A 524 Yes N/A Toluene 108883 C 1026 Yes N/A Xylenes 1330207 C 1146 Yes N/A n -Hexane 110543 C 3134 Yes N/A 5) The emission levels contained in this permit are based on the following emission factors: Point 008: CAS Pollutant Emission Factors Ib/BBL loaded - Uncontrolled Source VOC 0.112 AP -42 71432 Benzene 0.00038 Engineering Calculation 110543 n -hexane 0.0024 Engineering Calculation The uncontrolled VOC emission factor was calculated using AP -42, Chapter 5.2, Equation 1 (version 1/95) using the following values: L = 12.46*S"P*M/T S = 0.6 (Submerged loading: dedicated normal service) AIRS ID: 123/9393 Page 8 of 10 f P (true vapor pressure) = 4.6 psis Public Health and Environment Air Pollution Control Division M (vapor molecular weight) = 41 Ib/Ib-mol T (temperature of liquid loaded) = 531 °R The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP in the vapors by the VOC emission factor. Point 009: Component Gas Service Heavy Oil Light Oil SWater/Oil ervi Service Connectors 5580 --- 1956 306 Flanges 54 --- 13 0 Open-ended Lines 2 --- 8 3 Pump Seals 0 --- 0 0 Valves 569 --- 351 55 Other* 84 --- 20 5 VOC Content (wt. fraction) 23.6 --- 100 100 Benzene Content (wt. fraction) 0.0716 --- 1.2453 1.2453 Toluene Content (wt. fraction) 0.0782 -- 2.6146 2.6146 Ethylbenzene (wt. fraction) - __ _ ___ ___ Xylenes Content (wt. fraction) 0.0268 --- 3.0912 3.0912 n -hexane Content (wt. fraction) 0.3822 --- 7.5781 7.5781 *Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms, drains, dump arms, hatches, instrument meters, polish rods and vents TOC Emission Factors (kg/hr-component): Component Gas Service Heavy Oil Light Oil Water/Oil Service Connectors 2.0E-04 7.5E-06 2.1E-04 1.1E-04 Flanges 3.9E-04 3.9E-07 1.1E-04 2.9E-06 Open-ended Lines 2.0E-03 1.4E-04 1.4E-03 2.5E-04 Pump Seals 2.4E-03 NA 1.3E-02 2.4E-05 Valves 4.5E-03 8.4E-06 2.5E-03 9.8E-05 Other 8.8E-03 3.2E-05 7.5E-03 1.4E-02 Source: EPA -453/R95-017 Note that the emission limits included in this permit are derived by multiplying the equipment counts in the table above by a factor of 1.2 to accommodate other minor changes to the facility and to provide a conservative estimate of facility -wide emissions. AIRS ID: 123/9393 Page 9 of 10 of Public Health and Environment Air Pollution Control Division Compliance with emissions limits in this permit will be demonstrated by using the TOC emission factors listed in the table above with representative component counts, multiplied by the VOC content from the most recent gas analysis. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -hexane NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End SubpartA— Subpart KKKK NSPS Part 60, Appendixes Appendix A — Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A — Subpart Z MACT 63.600-63.1199 Subpart AA — Subpart DDD MACT 63.1200-63.1439 Subpart EEE — Subpart PPP MACT 63.1440-63.6175 Subpart QQQ — Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ — Subpart MMMMM MACT 63.8980 -End Subpart NNNNN — Subpart XXXXXX 9) An Oil and Gas Industry Construction Permit Self -Certification Form is included with this permit packet. Please use this form to complete the self -certification requirements as specified in the permit conditions. Further guidance on self -certification can be found on our website at: http://wvvw.cdphe.state.co.us/ap/oilgaspermittind.html AIRS ID: 123/9393 Page 10 of 10 0 P In n m N ▪ a 6 M c o y O 3 X \ o • N 'E .4.1 S -m V CY 01 7 ti=kd� 3 C v J 0`o2!L� ® 31111. .C m d •E m a) ▪ E u 0. a • W:o ye o, U y 45' V . E y re • o. a = • C '3 O To Y O -09 Z ®,Ew C i_ W ' � N 5 CLd 2o E Cd1 Q y a TV • c Gdf = N 6. 6 O a # n C in y 2 =•E € 3 'ii O a 0 d U Em H a 0 v o v m ▪ c T O E d c ti Uy v rn 7g' .Mi 2 c L 5 uOa1 j c • O W V a to u Z Z ua LL boy C � 2ru o d UE > W � N Z U }i Z• W 4 3 J ▪ " O. • is 0 p a J4 E E , Z 0 a .� W C E 2 6 u. istrative Information Kerr-McGee Oil and Gas Onshore LP N N Z ,. O VI 01 01 7 7 0.1 01 e: a: L 7 a N O In M Nto z z c u CO E ,n U al 6 Ill tin a O C E no ma c • v E 2 m C Y E o e 0 O • o m —y .0 O • 4-2 C • ra c e 0 v >41 .C L s Y a y ▪ 9 .C v W V E .c a• o = c 3 a O m y O E . 9 S 8 E p o v E Z a a — 6 00) 0) ....• • Q CC N N I0 CU 41 V V 3 7 W• O LL sit County: Weld T: 3N. II: 63W Source Location: 0 LL Elevation: 4865 LL Zip Code: 80217-3779 Mailing Address: PO Box 173779 O C C Phone Number: (720) 929-6511 Person To Contact: Katherine Doolittle z o. E v c L a c Q 4 av Ln a to to t a a L a" „0 O Z Fax Number: (720) 929-7511 E-mail Address: Katherine.Doolittle@anadarko.com ew u 3 0 0 operation began on: cal N N 9 r. N L N Normal Hours of Source Operation: v General description of equipment and purpose: Truck Loadout of Conden A OC 0 3 3 3 3 o O o 0 ggg O 0 0 0 O OOO Z Z Z Z Z O 0 •O• a O O Y � >->- } O O8O i 0 fa T a a Ca m• U y, 0 a ai J C m O 0 a - N. 0 1/40 m go m 5M �� 4 N c c _ O N a o In m to 6 w a^ a, EE, v U m u m E c ja ? m ai c L `o a a 9 CO T Q • 0 m v a Y m ya v '_✓, .O m 0 O • 'O O u Id 2 al o - m a p O) N w m o o v ao_ g w -e G ct m c tav, a O y 2 m O 0 1.. 2 0 L '� Z Z :MO.,— 0 - 9 u) > ,b�yy .o D O O� O) c a t-' ri w O. C O - Z O Up 01 Cn i dJ m Q 1n Z a s' a) C CO. iy, m CO CO .2225 a -0 U) > a£ C 0 o 0) 0 o. it m m L , o C= N r Q 10 in .1O O C at , a a a• O • O • .a 10 a) C' 0 N N a • Q Q v L 1a o= 0 2' C O N a .9 E U" ,n 2 3 0 L '00 0 3 .5 o«� Y .n J = O > O' V1 in in in m 1 y.Ta y. 0 t a . . C `o o /�/'ter an�v 0, W " v C E ¢ aa, a 'Ef - o� o Min v =• o IC- 3.,0\ W U V L N O CU Q " C C N W > 9 o, m L a U N" V .2 m • Q m .ob �ww dO t ' o mL E s_ a y 2 o c Tp'9 ma u o d ao Cr? --0 at o 2 to a (=> 4--,° C a. c.. 0 ti. 20 :>171 c 8 o• warm= of ®m 3btmn Oo Q =0:C l0 t am.N .C b P • >cct, E a,- CO C O v"i o o u c • a 1 O Vl N U c o rn o ' ='O M U ,: 2 2 m =Ea) `IaOOa mo= ,VL1 'xX b 2 U O c d m 1- N '.C-- E G U Q@ G La Q Vn downloadforms.html www.cdnhe.state.co.us E r U " U) N a n Li E o o 'to it -a a. Q Q .S E V d n m C c m 'a a a a L h am U IL C 0 m C v i U7 a7 ra c a o O O 3 C B Lowi e a V .. V c U m 5 a Loadout trucks 2 In C 9 0 0 v !? = oa m u. 0 Do U) _4 ? p a s d o E in a H Z CO a O O 7 n al m O a a C 0 O. m J a S �-n O Ls - 0 o d Lcn ) 2 o. m e a F o rn z 2 Ci 0 c) H W 2 O W O 0 'o o a a cr m O1 C a N Z 6 a N y n :14 Ft'/truckload Load Line Volume': ; O 0 C • 8, ai A S m a Z g e € E P 6 gcie r, E " u a 3 4 av a E = 0 U]) C op N w C O 0 m m rn m N U - FORM APCD-208 tt to W elj °iv; C M fa V E a. o ra U V a o?S O z ® w N Ya O J Permit Number: '.i (Datum & either Lat/Long or UTM) Q 0 if no combusti U) U) 0 0 Section 05 - Stack Information Q 1p z '.0 0 u ,0. O Width (inches) Length (inches) = .173 O z L co c •� II env CL � c rO N 0 C L ro U U v L r. n u a) o V d V Direction of stack outlet Exhaust Opening Shape & Size (Indicate if a control device controls the flash tank and/or regenerator emissions) Section 07 - Control Device Information Section 08 - Emissions Inventory Information & Emission Control Information N 0 0 N d O U) o. DI O es O a Ls �p wa w to 1• CI : Esbmation Method aor Emission actor „ Source • IAP-42 (Ch.5.2, Eqn. 1, V 1195)11 c ti > C w n' Li t 0 0. { AP -4z (Ch.5.2, Eqn. 1, V 1/95) e Air Pollutant Addendum form to report pollutants not listed above. q .RegilestedPermittedEmissions� :O, p _O 10 22.30 152.98 lb/yr 944.41 lb/yr 8'0) Actual Calendar'Year , Controlled Unoohtrolled (Tons year)' up 2.21 lb/yr (De Min 260.62 lb/yr Emission".Factor , 21 to Uncontrolled Basis I 0.000382 I I 1 -Criteria Reportabl I .a I. N M NO O O O I 1 `: fix`-. n.'` ' s: rx',; ng`a 4••. p ;. Please use the APCD No :..�'� �, vf. e�� 1�+.x �• yr S r? ' «Control' Device_ Description ,' i k �#'`•�`�,,•���k-=§�'� use ,q ri `4O "A=•j�tr^max .'a '-x �'" rim xr,v°},,.• Yr�z 4'�A�T�ZZ�: 0 0: Z V0C CO Benzene Toluene Ethylbenzene Xylene n -Hexane U 5 U a) E U N trt i6 m f6 N cu t v 0 l0 fo La Q!. 1 0 O W 15. ingAPEN-Ver.9-9-2010.doc 8-Hydrocarbontiqui Q V10 nn M 0 rn 2 E N M 2 Y U2 NI 7 'q Cr u f0 1, .,g • n C a d o_ -*It7'A _ C 0 0 .= E o S VN O N O c p E L. u a 0 or U 6-a ' 3 T T 9 c c 3 m • N LL c Wrea E N W n It 0- a) th ao CO c 0 c O m 9 � CO - C m In n - .C'a LOd C a tu tu O C O E L O. O w N LT Company Name: Kerr-McGee Oil and Gas Onshore LP n m co 0 m .0 n u a) -C .ui rn X Y 0 5 C O N 0' Source Name: 36022613 O L E m.- Cu, Ccu C n o O o 0 o ) C m F- L U m cr a • y o E 1n = @ E n CU CU 6 C • 0 m L9 m L SWSE, S: 5. T: 3N, R: 63W Source Location: Ln '0 CO n- Zip Code: 80217-3779 PO Box 173779 O E a O O 0 a 0 0 To u E Q o cll • 117 7 a in I'a O O d 0 d m 0 cn Q U 0 • r a Katherine Doolittle Fax Number: (720) 929-7511 E-mail Address: Katherine.Doolittle@anadarko.com Section 03 - General- Information 0 0 For existing sources, operation began on: CO CU Y CU T -o n m 0 0 t N Normal Hours of Source Operation: Brief description of equipment associated with these components: O a) m c E ii -O a) 0 m u a al a; C L m a II: ci O :5▪ .8 rik,QO m m Q , 6 ACC--Nw c m u an o m .4 td alt S bi j'uL O O N m Iti Y x ag • =E to o r O U T O a m 9 C m v o D• O O. W n .. E ., o E m a_ o > Pte] o o um v a ✓ `o `m a dm.o 3!' O ¢ a TO mt' �N L o- CU 0o vhf '00 m> j E a VTco Cp 0c L `tn o y p 2 o. E 0.1 m G O U c m in 71 o� 6 s g N U y :2 2 a c row =_ia 8 `, oz. Z .`a n'85 ?UO C q w Fvcc 2.U4a0 uo..cn .°;.=to Z Lu Q In 0 r N E Ln m m m - cn CO m 0 RP M 9 .cdohe.state.co.us Application status: o 0 Z Z Information Section 04-Reaulato >-• CIJ O O Is this equipment subject to NSPS 40 CFR Part 60, Subpart KKK? Is this equipment subject to NESHAP 40 CFR Part 63, Subpart HH? List any other NSPS or NESHAP Subpart that applies to this equipment: Section 05 -Stream Constituents Identify the VOC & HAP content of each applicable (Li C U a 0 0 `0 CU CT 0 o O 0 O • O .0 .0 Y Y 0' d U U 123-9393-009—APEN-2012-04-25-01 a LL FORM APCD-203 k Emissions d M C OMd da E CO o LLa I E C O C N t W a+ C C Ir 0 C ® d U •a c ® 0 J J z LU Nd U Q." O z w.. z 3 O H U, O LU F J C Permit Number: Control Information Section 07 Leak Detection Re 06 - Location Information c m N 0 C E a Eal E 0 n LL G! 0 < a co p -I a EZ IT'zO y Y a N N T OG a y 'O Z C O SO 0. 0. a D! OJ ro a ���0��� 0 l U d n o. n v— = o .0 L m .2- t o0 .1 O > > 0 a . 0 c E d - aLO Y o 0 N n b >) > > :3 E > > 0 n a Ln o 0 C) o o "O o n - .. O +L+ 2 C^ C �+ o U c a Y U 0 O' o Y -a E } tn O in a O L N Z E E o T N T a5. m'E Co O O 02 a 0 to Lit E a c N .2 a E N E u, E i E O C C o N E W = 0 C J J cu _c C N L E a �J w C O N LL0 • u LL O w o N a oI E 01 c C 0 4 tn CL w y 4- i o -p E o C4 0 0 N Ol O 2 a (13 v A l d C j O CO . Ox w 0 CO v ® aJ's e u 0 V G ���o� Vl 9 i≥. 0 5 9 8 a I 8 `L& e � O 8 O' s ° C Z U 9 C n 0 y $ E g 41 y o m E E n ` a C §. `o }�i C = c N pE 8 0 I, 2 fn 0 V.. Emission Factor Documentation attached vi 0 E N p o N N C O C O at N d c a a v a a j N o d._ N e o N C E w m .c c O CO N C c0 N 9 0 NINIi E H O va m L 3 o= v = 0. .2a E N c 0 m c o0.1 a '(n CO o_ .0 g a 'E w 3 v N 9 O N N 0 Fr ce Q ertify that all APEN - Ver.9-10-2008.doc Hello