The URL can be used to link to this page

Browse Search

Home My WebLink About20160202.tiff CDPHE COLORADO 13. CO vi Department of Public • I Health€r Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150O St PO Box 758 RECEIVED Greeley, CO 80632 January 5, 2016 JAN 1 2 2016 WELD COUNTY COMMISSIONERS Dear Sir or Madam: On January 6, 2016, the Air Pollution Control Division will begin a 30-day public notice period for Bonanza Creek Energy Operating Company LLC - Antelope 13-21 Central Production Facility. 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 beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, i, /1 14.441 , LIT'L �.k.C2,; Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure R- 2016-0202 Y�o� cc r? ;PW, lei, lip, ,, ..,, I -I G 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.govfcdphe '�` . John W. Hickenlooper, Governor ' Larry Wolk,MD,MSPH,Executive Director and Chief Medical Officer I '.� i*1 CDPHE Air Pollution Control Division CO Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Bonanza Creek Energy Operating Company LLC - Antelope 13-21 Central Production Facility - Weld County Notice Period Begins: January 6, 2016 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: Bonanza Creek Energy Operating Company LLC Facility: Antelope 13-21 Central Production Facility Oil and Gas Production Facility NESW of Section 21, Township 5N, Range 62W Weld County The proposed project or activity is as follows: Source proposes to operate a new 12.0 MMscf per day TEG dehydrator at a new synthetic minor oil and gas production facility. 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): • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 15WE1001 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 https://www.colorado.gov/pacific/cdphe/air-permit-public-notices 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: Harrison Slaughter Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us 1 ®V COLORADO I x= vs STATE OF COLORADO COz COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT >+ AIR POLLUTION CONTROL DIVISION 4ye a TELEPHONE: (303) 692-3150 • *1876* CONSTRUCTION PERMIT PERMIT NO: 1 5WE1001 Issuance 1 DATE ISSUED: ISSUED TO: Bonanza Creek Energy Operating Company LLC THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the Antelope 13-21 Central Production Facility, located in the NESW of Section 21, Township 5N, Range 62W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID One (1) Triethylene glycol (TEG), natural gas dehydration unit (make, model, serial number: TBD) with a design capacity of 12.0 MMscf per day. This emissions unit is equipped with two (2) Kimray, model 21015, gas-glycol pumps with a design capacity of 3.5 gallons per minute. Only one Kimray gas-glycol pump will be DEHY-1 001 operated at any given time. The second Kimray gas-glycol pump serves as a back-up only. This unit is equipped with a flash tank, reboiler and still vent. Stripping gas is not used. Emissions from the still vent are routed to an air-cooled condenser and then to a flare with a minimum control efficiency of 95%. Emissions from the flash tank are 100% recycled to the sales gas line or to the fuel gas system. 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. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at https://www.colorado.gov/pacific/cdphe/other-air- permitting-notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. AIRS ID: 123/9DF2 Page 1 of 11 Dehy SM/M Version 2012-1 WrZMWA, Co do p; rhe' o,,Public Health and Environment Air Pollution Control Division 2. Within one hundred and eighty days (180) of the latter of commencement of operation or 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, I II.G.2). 3. 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; (iii) 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.) 4. 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.) 5. The following information shall be provided to the Division within fifteen (15) days of the latter of commencement of operation or issuance of this permit. • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 6. 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 7. 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) Monthly Limits: Facility AIRS Pounds per Month Emission Type Equipment ID Point NOX VOC CO DEHY-1 001 --- 558 --- Point (Note: Monthly limits are based on a 31-day month.) The owner or operator shall calculate monthly emissions based on the calendar month. Facility-wide emissions of each individual hazardous air pollutant shall be less than 1,359 lb/month. Facility-wide emissions of total hazardous air pollutants shall be less than 3,398 lb/month. AIRS ID: 123/9DF2 Page 2 of 11 IICo A do I p e o Public Health and Environment I Air Pollution Control Division Annual Limits: Facility AIRS Tons per Year Equipment ID Point NO), VOC CO Emission Type DEHY-1 001 --- 3.3 --- Point 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. Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. During the first twelve (12) months of operation, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. 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. 8. Compliance with the emission limits in this permit shall be demonstrated by running the GRI GlyCalc model version 4.0 or higher on a monthly basis using the most recent extended wet gas analysis and recorded operational values (including gas throughput, lean glycol recirculation rate, and other operational values specified in the O&M Plan). Recorded operational values, except for gas throughput, shall be averaged on a monthly basis for input into GRI GlyCalc and be provided to the Division upon request. 9. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID DEHY-1 001 Air-cooled condenser and enclosed flare for the still VOC & HAPs vent 10. 100% of emissions that result from the flash tank associated with this dehydrator shall be recycled to the sales gas line or fuel gas system. AIRS ID: 123/9DF2 Page 3 of 11 Co do p e o PubD lic PollutionHealth Controland DivisionEnvironment PROCESS LIMITATIONS AND RECORDS 11. 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) Process/Consumption Limits Facility AIRS Annual Monthly Limit Equipment Point Process Parameter Limit (31 days) ID DEHY-1 001 Natural gas throughput 4,380 372 MMscf/yr MMscf/month The owner or operator shall monitor monthly process rates based on the calendar month. During the first twelve (12) months of operation, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. 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. 12. This unit shall be limited to the maximum lean glycol circulation rate of 3.5 gallons per minute. The lean glycol recirculation rate shall be recorded daily in a log maintained on site and made available to the Division for inspection upon request. (Reference: Regulation No. 3, Part B, II.A.4) STATE AND FEDERAL REGULATORY REQUIREMENTS 13. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 14. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 15. This equipment is subject to the control requirements for glycol natural gas dehydrators under Regulation No. 7, Section XII.H. Beginning May 1, 2005, uncontrolled actual emissions of volatile organic compounds from the still vent and vent from any gas- condensate-glycol (GCG) separator (flash separator or flash tank), if present, shall be reduced by at least 90 percent through the use of air pollution control equipment. This source shall comply with all applicable general provisions of Regulation 7, Section XII. 16. The flare covered by this permit is subject to Regulation No. 7, Section XVII.B General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed, have no visible emissions during normal operations, and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare AIRS ID: 123/9DF2 Page 4 of 11 IICo A do p e o Public Health and Environment Air Pollution Control Division or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. The operator shall comply with all applicable requirements of Section XVII. 17. This equipment is subject to the control requirements for glycol natural gas dehydrators under Regulation No. 7, Section XVII.D (State only enforceable). These requirements include, but are not limited to: XVII.D.3. Beginning May 1, 2015, still vents and vents from any flash separator or flash tank on a glycol natural gas dehydrator located at an oil and gas exploration and production operation, natural gas compressor station, or gas-processing plant subject to control requirements pursuant to Section XVII.D.4., shall reduce uncontrolled actual emissions of hydrocarbons by at least 95 percent on a rolling twelve-month basis through the use of a condenser or air pollution control equipment. If a combustion device is used, it shall have a design destruction efficiency of at least 98% for hydrocarbons. XVII.D.4. The control requirement in Section XVII.D.3. shall apply where: XVII.D.4.a. Uncontrolled actual emissions of VOCs from a glycol natural gas dehydrator constructed on or after May 1, 2015, are equal to or greater than two (2) tons per year. Such glycol natural gas dehydrators must be in compliance with Section XVII.D.3. by the date that the glycol natural gas dehydrator commences operation. 18. This source is subject to the requirements of 40 CFR, Part 63, Subpart HH - National Emission Standards for Hazardous Air Pollutants for Source Categories from Oil and Natural Gas Production Facilities including, but not limited to, the following: • §63.764 -General Standards o §63.764 (e)(1) -The owner or operator is exempt from the requirements of paragraph (d) of this section if the criteria listed in paragraph (e)(1)(i) or (ii) of this section are met, except that the records of the determination of these criteria must be maintained as required in §63.774(d)(1). ■ §63.764 (e)(1)(ii) — The actual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere are less than 0.90 megagram per year, as determined by the procedures specified in §63.772(b)(2) of this subpart. • §63.772 - Test Methods, Compliance Procedures and Compliance Demonstration o §63.772(b) - Determination of glycol dehydration unit flowrate or benzene emissions. The procedures of this paragraph shall be used by an owner or operator to determine glycol dehydration unit natural gas flowrate or benzene emissions to meet the criteria for an exemption from control requirements under§63.764(e)(1). • §63.772(b)(2) - The determination of actual average benzene emissions from a glycol dehydration unit shall be made using the procedures of either paragraph (b)(2)(i) or (b)(2)(ii) of this section. Emissions shall be determined either uncontrolled, or with federally enforceable controls in place. AIRS ID: 123/9DF2 Page 5 of 11 Co do I p e o Pu Environment D Airblic PollutionHealthand Control Division • §63.772(b)(2)(i) — The owner or operator shall determine actual average benzene emissions using the model GRI- GLYCaIc TM , Version 3.0 or higher, and the procedures presented in the associated GRI-GLYCaIc TM Technical Reference Manual. Inputs to the model shall be representative of actual operating conditions of the glycol dehydration unit and may be determined using the procedures documented in the Gas Research Institute (GRI) report entitled "Atmospheric Rich/Lean Method for Determining Glycol Dehydrator Emissions" (GRI-95/0368.1); or • §63.772(b)(2)(ii) - The owner or operator shall determine an average mass rate of benzene emissions in kilograms per hour through direct measurement using the methods in §63.772(a)(1)(i) or (ii), or an alternative method according to §63.7(f). Annual emissions in kilograms per year shall be determined by multiplying the mass rate by the number of hours the unit is operated per year. This result shall be converted to megagrams per year. • §63.774 - Recordkeeping Requirements o §63.774 (d)(1) - An owner or operator of a glycol dehydration unit that meets the exemption criteria in §63.764(e)(1)(i) or §63.764(e)(1)(ii) shall maintain the records specified in paragraph (d)(1)(i) or paragraph (d)(1)(ii) of this section, as appropriate, for that glycol dehydration unit. ■ §63.774 (d)(1)(ii) - The actual average benzene emissions (in terms of benzene emissions per year) as determined in accordance with §63.772(b)(2). OPERATING & MAINTENANCE REQUIREMENTS 19. Upon startup of this point, 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 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.) 20. The condenser outlet temperature shall be recorded as per the frequency required in the approved O&M Plan. This information shall be maintained in a log on site and made available to the Division for inspection upon request. The condenser outlet temperature shall not exceed 160 °F on a monthly average basis. COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 21. The owner or operator shall demonstrate compliance with opacity standards, using EPA Method 22 to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one (1) minute in any fifteen (15) minute period during normal operation. (Reference: Regulation No. 7, Section XVII.A.II) 22. The owner or operator shall complete the initial annual extended wet gas analysis testing required by this permit and submit the results to the Division as part of the self- AIRS ID: 123/9DF2 Page 6 of 11 Cold do p °ene a o Public Health and Environment Air Pollution Control Division gat't magg certification process to ensure compliance with emissions limits. (Reference: Regulation No. 3, Part B, Section III.E.) Periodic Testing Requirements 23. The owner or operator shall complete an extended wet gas analysis prior to the inlet of the TEG dehydrator on an annual basis. Results of the extended wet gas analysis shall be used to calculate emissions of criteria pollutants and hazardous air pollutants per this permit and be provided to the Division upon request. ADDITIONAL REQUIREMENTS 24. 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 e. No later than 30 days before the existing APEN expires. 25. Federal regulatory program requirements (i.e. PSD, NANSR) 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). 26. MACT Subpart HH - National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities major stationary source requirements shall apply to this stationary source at any such time that this stationary source becomes major solely by virtue of a relaxation in any permit limitation and shall be subject to all AIRS ID: 123/9DF2 Page 7 of 11 Co do p e o Public Health and Environment Air Pollution Control Division appropriate applicable requirements of Subpart HH. (Reference: Regulation No. 8, Part E) GENERAL TERMS AND CONDITIONS 27. 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. 28. 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. 29. 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. 30. 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. 31. 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 of a source may request a hearing before the AQCC for review of the Division's action. 32. 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. AIRS ID: 123/9DF2 Page 8 of 11 Co do p e o` Pue D Airblic PollutionHalth ControlandEnvironment Division 33. 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: Harrison Slaughter Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Bonanza Creek Energy Operating Company LLC Permit for a TEG Dehydration unit at a synthetic minor oil and gas facility. I I AIRS ID: 123/9DF2 Page 9 of 11 4 Co do p e o Public Health and Environment I 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: https://www.colorado.gov/pacific/cdphe/aqcc-regs 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. Uncontrolled Emission Are the Controlled AIRS Rate emissions Emission Rate Point Pollutant CAS# (lb/yr) reportable? (Ib/yr) Benzene 71432 33,441 Yes 1,245 Toluene 108883 39,487 Yes 1,129 Ethylbenzene 100414 9,129 Yes 174 001 Xylenes 1330207 35,314 Yes 622 n-Hexane 110543 7,911 Yes 114 2,2,4- 540841 12 No 1 Trimethylpentane 5) The emission levels contained in this permit are based on information provided in the application and the GRI GlyCalc 4.0 model. The model assumed the inlet gas temperature of 120°F and pressure of 800 psig. The permitted glycol recirculation rate is 3.5 gallons per minute. The source specified flash tank operation at a temperature of 150°F and a pressure of 125 psig, with 100% recompression/recycle of flash gas emissions. Still vent vapors are routed to an air-cooled condenser permitted at a maximum outlet temperature of 160°F at a pressure of 12.24 psia. Condenser emissions are controlled by an enclosed combustor. The enclosed combustor is granted a 95% reduction for the control of uncondensed vapors. Uncontrolled emission factors are based on the sum of the flash tank and still vent emissions from the Glycalc report. Controlled emissions are based on 100% recompression/recycle of the flash tank emissions and a 95% control of vapors from the condenser effluent stream. 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 AIRS ID: 123/9DF2 Page 10 of 11 Co A do p e , o Public Health and Environment Air Pollution Control Division 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 Status Requirement Operating Permit Synthetic Minor Source of: VOC, Benzene, Toluene, Xylene, Total HAPs NANSR Synthetic Minor Source of: VOC, Benzene, Toluene, Xylene, Total HAPs PSD True Minor Source MACT HH Area Source Requirements: Applicable 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 Subpart A—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) A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification AIRS ID: 123/9DF2 Page 11 of 11 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Bonanza Creek Energy Operating Company LLC Permit Number: 15WE1001 Source Name: Antelope CPF 13-21 Source Location: NESW of Section 21, Township 5N, Range 62W Equipment Description: 12.0 MMscf/day TEG Dehydration Unit("DENY-1") AIRS ID: 123-9DF2 Date: 12/2/2015 Review Engineer: Harrison Slaughter Control Engineer: Chris Laplante Section 2—Action Completed Grandfathered Modification APEN Required/Permit Exempt X CP1 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? Yes X No If you answered "no"to any of the above, when did you mail an Original application was missing the Information Request letter to the source? "Input Summary" sheet from the Glycalc model. I emailed Jerry Dismukes on 12/2/2015. I received the summary sheet on 12/2/2015. On what date was this application complete? 12/2/2015 Section 4—Source Description AIRS Point Equipment Description One (1) Triethylene glycol (TEG), natural gas dehydration unit (make, model, serial number: TBD)with a design capacity of 12.0 MMscf per day. This emissions unit is equipped with two (2) Kimray, model 21015, gas-glycol pump with a design capacity of 001 3.5 gallons per minute (one pump used as a backup). This unit is equipped with a flash tank, reboiler and still vent. Stripping gas is not used. Emissions from the still vent are routed to an air-cooled condenser and then to a flare with a minimum control efficiency of 95%. Emissions from the flash tank are 100% recycled to the sales gas line or to the fuel gas system. Is this a portable source? Yes X No Is this location in a non-attainment area for any criteria Yes No pollutant? If"yes", for what pollutant? PM10 CO X Ozone Page 1 Is this location in an attainment maintenance area for Yes X No any criteria pollutant? If"yes", for what pollutant? (Note: These pollutants are subject to minor source N/A PM10 N/A CO N/A Ozone RACT per Regulation 3, Part B, Section III.D.2) Is this source located in the 8-hour ozone non- attainment region?(Note: If"yes" the provisions of X Yes No Regulation 7, Sections XII and XVII.C may apply) Section 5—Emission Estimate Information AIRS Point Emission Factor Source 001 GRI Gly-Calc v4.0 (Refer to Section 14 for calculations) Did the applicant provide actual process data for the emission inventory? Yes X No Basis for Potential to Emit(PTE) AIRS Point Process Consumption/Throughput/Production 001 4,380 MMSCF per year, 3.5 gallons per minute glycol circulation rate Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory) AIRS Point Process Consumption/Throughput/Production Data Year 001 N/A-Since this is a new source, no actual emissions are reported N/A Basis for Permitted Emissions(Permit Limits) AIRS Point Process Consumption/Throughput/Production 001 4,380 MMSCF per year, 3.5 gallons per minute glycol circulation rate Does this source use a control device? X Yes No % Reduction AIRS Point Process Control Device Description Granted Flash Gas Recompression and Recycle 100 Still Vent Enclosed Combustor 95 001 01 Still Vent Condenser(maximum outlet temp. = 160°F) 44 Still Vent Condenser and Enclosed Combustor Combined 98.81 (VOC) 8.81 Destruction Efficiency (modeled by Glycalc) 96.28—(HAPs) Section 6—Emission Summary (tons per year) Point NOX VOC CO Single HAP Total HAP PTE: 001 0.1 276.1 0.5 19.74 62.7 (Toluene) Uncontrolled point 001 0.1 276.1 0.5 19.74 62.7 source emission rate: (Toluene) Controlled point 001 0.1 3.3 0.5 0.7 1.7 source emission rate: (Benzene) Total APEN Reported 001 N/A—no actual emissions reported (new source) emissions: Section 7—Non-Criteria/ Hazardous Air Pollutants Uncontrolled Are the Controlled Emission Pollutant CAS# Emission Rate emissions Rate I r (Ib/yr) reportable? ( y ) Benzene 71432 33,441 Yes 1,245 Toluene 108883 39,486.2 Yes 1,128.2 Page 2 Ethylbenzene 100414 9,128.6 Yes 173.6 Xylenes 1330207 35,313.2 Yes 621.6 n-Hexane 110543 7,910.4 Yes 113.4 2,2,4-Trimethylpentane 540841 11.4 No 0.2 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 X Yes No standard? If"yes", complete the information listed below AIRS Point Process Pollutant Regulatory Basis Test Method 001 01 Opacity Regulation No. 7 Section XVII EPA Method 22 001 01 VOC, Regulation No. 3, Part B. Section III.E Extended wet gas HAPs analysis Section 9—Source Classification Is this a new previously un-permitted X Yes No source? What is this facility classification? True X Synthetic Major Minor Minor Classification relates to what X Title V PSD X NA NSR X MACT programs? Is this a modification to an existing permit? Yes X No If"yes"what kind of modification? N/A Minor N/A Synthetic N/A Major Minor Section 10— Public Comment Does this permit require public comment per CAQCC Regulation 3? X Yes No If"yes", for which pollutants?Why? Synthetic minor for VOC For Reg. 3, Part B, III.C.1.a (emissions increase> 25/50 tpy)? Yes X No For Reg. 3, Part B, III.C.1.c.iii (subject to MACT)? (MACT HH Area X Yes No Source) For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)? X Yes No Section 11 —Modeling Is modeling required to demonstrate compliance with National Ambient Yes X No Air Quality Standards (NAAQS)? If"yes", for which pollutants?Why? AIRS Point Section 12—Regulatory Review Regulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide Page 3 Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15-second intervals for six minutes. The approved reference test method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A(July, 001 1992)) in all subsections of Section II. A and B of this regulation. Section II.A.5 -Smokeless Flare or Flares for the Combustion of Waste Gases No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. Regulation 2—Odor 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 001 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 Part A-APEN Requirements 001 Applicant is required to file an APEN since emissions exceed 1 ton per year VOC in a nonattainment area for ozone. Part B—Construction Permit Exemptions 001 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 ll.D.2.a) Regulation 6-New Source Performance Standards 001 None Regulation 7—Volatile Organic Compounds Is this source subject to the control requirements of MACT HH? (Regulation 8-Hazardous Air Pollutants review). No Is this source subject to the exemptions under MACT HH (i.e. throughput exemption less than 3 MMSCFD or benzene exemption of less than 1984 Ib/yr)? Yes (controlled 001 benzene emissions= 1,245 Ib/yr) Even though this source is subject to some requirements of MACT HH, it is not subject to control requirements. Therefore, it can also be subject to Regulation 7 control requirements. Section XII.H: Is this source located in the non-attainment area? Yes 001 This source is subject to Regulation 7, Section XII.H. Uncontrolled actual emissions of volatile organic compounds from the still vent and vent from any gas-condensate-glycol (GCG) separator (flash separator or flash tank), if present, shall be reduced by at least 90 percent through the use of air pollution control equipment. Section XVII.D (State only enforceable). 001 Applicant is required to reduce VOC emissions from this dehydrator by at least 95% since uncontrolled VOC emissions are greater than the 2.0 TPY threshold. Regulation 8—Hazardous Air Pollutants Page 4 MACT HH: If facility is MAJOR source for HAP (summation of HAPS of dehydrators and fugitives greater than 25 TPY total or 10 TPY single HAP),then all glycol dehydrators at this facility are subject to MACT HH. If facility is an area source of HAP, only TEG dehydrators are subject to MACT HH. 1.Is facility a production field facility per 63.761 (Refer to Section 14 for definition)? Yes 2.If facility is defined as a production facility, then is it a major source of HAPS when summing up dehydrator and flash tank emissions? No 3.If facility is NOT a production field facility(i.e. natural gas processing plant), then is it a 001 major source of HAPS when summing all HAP emissions from ALL HAP emitting units? N/A—as indicated above this facility is considered a production field facility 4.Is this facility considered MAJOR for HAPS? No 5.Is this source subject to MACT HH? Yes 6.WHY? This facility is an area source of HAP and MACT HH area source requirements apply to this TEG dehydrator. However,since benzene emissions from each unit will be less than 1984 Ib/yr,this source is only required to calculate and keep records demonstrating that benzene emissions stay below this level. Section 13—Aerometric Information Retrieval System Coding Information Point Process Process Throughput Emission Pollutant/ Fugitive Emission Control Description limit Factor CAS# (Y/N) Factor Source (%) 126.08 VOC No GlyCalc 4.0 98.81 lb/mmscf 7.63 Benzene/ No GlyCalc 4.0 96.28 lb/mmscf 71432 9.01 Toluene/ No GlyCalc 4.0 97.14 lb/mmscf 108883 Glycol 4,380 2.08 Ethylbenzene 01 Dhdt MMSCF per lb/mmscf / 100414 No GlyCalc 4.0 98.10 eyraor 001 year 8.06 Xylenes/ lb/mmscf 1330207 No GlyCalc 4.0 98.24 1.80 n-Hexane/ No GlyCalc 4.0 98.57 lb/mmscf 110543 2.6 x 10' 2,2,4-TMP/ No GlyCalc 4.0 98.81 lb/mmscf 540841 SCC 31000227: Glycol Dehydrator: reboiler still stack Page 5 Section 14—Miscellaneous Application Notes AIRS Point 001 12.0 MMscf/day TEG Dehydration Unit("DEHY-1") A permit will be issued because the uncontrolled VOC emissions are greater than 1 TPY(APEN threshold) and greater than 2 TPY (permit threshold). In order to determine emissions, the operator used GRI GlyCALC 4.0. The source assumed the inlet gas temperature of 120°F and pressure of 800 psig. The permitted glycol recirculation rate is 3.5 gallons per minute. The source specified flash tank operation at a temperature of 150°F and a pressure of 125 psig, with 100% recompression/recycle of flash gas emissions. Still vent vapors are routed to an air-cooled condenser permitted at a maximum outlet temperature of 160°F at a pressure of 12.24 psia. Condenser emissions are controlled by an enclosed combustor. The enclosed combustor is granted a 95% reduction for the control of uncondensed vapors. Uncontrolled emission factors listed in Section 13 (AIRS Coding Information) of this analysis are based on the sum of flash tank and still vent emissions from the Glycalc report. Controlled emissions are based on 100% recompression/recycle of the flash tank emissions and a 95% control of vapors from the condenser effluent stream. The GlyCalc model was based off of an extended gas analysis with a sample date of 08/27/2014. The gas analysis was performed within a year of submittal. However, an updated extended gas analysis will be required because: I -This is a new source and a site-specific sample was not available for emission calculations. As a result, the source will be required to complete an initial site-specific extended wet gas analysis to ensure compliance with emission limits. Gly-Calc-Uncontrolled Emission factors VOC = ((158.2603 tpy+117.8574 tpy)*(20001b/ton))/(4,380 mmscf/yr) = 126.08 lb/mmscf Benzene = ((1.2584 tpy+15.4621 tpy)*(2000lb/ton))/(4,380 mmscf/yr) = 7.63 lb/mmscf Toluene = ((1.0528 tpy+18.6903 tpy)*(20001b/ton))/(4,380 mmscf/yr) =9.015 lb/mmscf Ethylbenzene= ((0.1546 tpy+4.4097 tpy)*(20001b/ton))/(4,380 mmscf/yr) = 2.08 lb/mmscf Xylenes = ((0.4232 tpy+17.2334 tpy)*(20001b/ton))/(4,380 mmscf/yr) = 8.06 lb/mmscf N-hexane = ((2.6595 tpy+1.2957 tpy)*(20001b/ton))/(4,380 mmscf/yr) = 1.806 lb/mmscf 2,2,4-TMP = ((0.0039 tpy+0.0018 tpy)*(2000lb/ton))/(4,380 mmscf/yr) = 0.0026 lb/mmscf MACT HH includes requirements for both major and area sources of HAPs. The definition of major source for MACT HH (63.761) states: (3) For facilities that are production field facilities, only HAP emissions from glycol dehydration units and storage vessels with the potential for flash emissions shall be aggregated for a major source determination. For facilities that are not production field facilities, HAP emissions from all HAP emission units shall be aggregated for a major source determination. The following definitions from 63.761 are also needed to determine major source applicability: Production field facilities means those facilities located prior to the point of custody transfer Custody transfer means the transfer of hydrocarbon liquids or natural gas: after processing and/or treatment in the producing operations, or from storage vessels or automatic transfer facilities or other such equipment, including product loading racks, to pipelines or any other forms of transportation. For the purposes of this subpart, the point at which such liquids or natural gas enters a natural gas processing plant is a point of custody transfer. Natural gas processing plant(gas plant) means any processing site engaged in the extraction of natural gas liquids from field gas, or the fractionation of mixed NGL to natural gas products, or a combination of both. Page 6 Based on the definitions above, this source qualifies as a production field facility. Thus, HAP emissions from the glycol dehydration unit and storage vessels with potential for flash emissions will be aggregated for major source determination. Currently the points for which permits have been applied at the site only include three engines and this TEG Dehydrator. As such, only the HAP emissions associated with the dehydrator were used to determine major source applicability at this time. Does this dehydrator have a reboiler? Yes If Yes, what is the reboiler rating? 0.50 mmbtu/hr-The reboiler is APEN-exempt(Regulation No. 3, Part A, II.D.1.k), and is therefore also exempt from construction permitting requirements (Regulation no. 3, Part B, II.D.1.a). The combustion emissions associated with the enclosed flare were calculated using the AP-42 emission factors for NOx and CO from Table 13.5-2 in conjunction with data taken from the condenser vent stream in the Glycalc streams report. The following table contains the critical information used to calculate NOx and CO emissions: Gas flow rate to combustor 187 scf/hr Combustor Heat Content 1,786 Btu/scf NOx Emission Factor 0.068 lb/MMBtu CO Emission Factor 0.310 lb/MMBtu With the above information, the following equation was used to determine the NOx and CO emissions associated with the TEG dehydration unit: 187 scf 8760 hr 1,786 Btu 1 MMBtu EF,lb 1 ton Emissions (tpy) = * hr yr scf 1.0x106Btu MMBtu 2000 lbs Using the above equation, the NOx and CO emissions were determined to be 0.10 and 0.45 tpy respectively. These emissions are not APEN reportable, and thus there will not be permit limits associated with these pollutants in the permit. Additional Notes: 1. The monitoring frequencies in the submitted O&M plan are based on a permitted facility VOC emissions<80 tpy. With the current sources at the facility, the VOC emissions are less than this threshold. The operator further expressed that the permitted VOC emissions are expected to be < 80 tpy once the facility is fully built out. 2. In the original application, only emissions associated with the still vent were included in the uncontrolled emissions and thus the calculation of the emission factor. I expressed to the operator that the flash tank emissions should also be included in this calculation, even though the intention is to recycle the entirety of the flash tank emissions. The operator agreed with this proposal. As such, the uncontrolled emission factors and resulting emissions were updated to include both the modeled still vent and flash tank emissions. The information utilized to determine the uncontrolled emission factors was obtained from the"Combined regenerator vent/flash gas emission control report" on page three (3) of the GlyCalc Aggregation Calculations report provided in the application. The control percentages represented in Section 13 above were obtained from this section of the report as well. 3. It was determined that an initial stack test would not be required because the operator is only requesting a 95% control efficiency associated with the enclosed flare being used to control the still vent emissions after they have passed through the air cooled condenser. 4. The central production facility receives produced oil and natural gas from multiple wells located at a remote well pad (i.e. well pad and central production facility are not at the same site). The first separation step occurs in high-low pressure separators that are located at the remote well pad. In this separation step oil and water are separated from the natural gas. These separated components are sent to the central production facility via pipeline. Further separation and processing occurs at the central production facility. Based on this information, it was determined that the central production facility operated similar to a midstream gathering facility. As a result, monthly throughput and emission limits were included in the permit. Page 7 5. During the review of this permit, the operator submitted an updated O&M plan. This update requested that the daily Method 22 reading required, be updated to a daily visible smoke reading followed by a Method 22 reading if smoke is visible. Since this is the direction we are moving as a Division in the update of our O&M plans, the request was approved. The operator included the following language in the updated O&M plan "In lieu of weekly 15-minute Method 22 readings, BCE will perform daily smoke/no smoke readings to be logged using a check box on our daily inspection forms. If smoke is observed, a 15 minute Method 22 reading will be completed to assess if visible emissions are present for at least 1 minute. If visible emissions are present, documentation of the event and its resolution, as well as the date range that the control device was improperly operating will be recorded as required." 6. The operator was provided with a draft permit to review. They reviewed the draft and expressed they did not have any comments. I Page 8 ..y aJ .� N 5 5L. ed O - o Q ca T h "G 'h CU a' o ai O b `` = ❑ O Q Q C� E W ctn N y,+ N N N V 0 .0 Cl II cn En �I o a� C ¢ � A " a 000 VI° ° ° >' !1 d a W (9 o W U < ❑ _ FE DI DI g ch ^ G . `� t' O N C O i- a y O O O Q c,=. C O -.- b N a s Q c u o G o 0. o .' a Z Z Z .O a ❑ a w i w O N a ? Q a x A G �' Lo co o N <0 < g br z14 CU oco 3 0 0 0 o x c G v b ', U G N p a 9 y 3 5 V co M .i: .a d y .C sue. o G V V V a. C O o R. .C .� C a) to 'd o O U H . .. .N U T •C U .O 7 :ii p .C A >> A MF�� O v J~ y, d ao O a C%� E .. p~ -o I 0 0 0 la � R d ❑ CI. a a 8 G ila 3 C A o Ca a >, a, m >, 3 ° C ° a° w° > c c °J Y 3 0 •y .c 0 Cr c. V .� b H a a b o o f o V .c 6i O GT. S1 'O 0 id A R' ra > a' C L L N CO Q O O I U o o_ a .. 0 °3 .b o > w~ 7 E a U 000 C U y G 0 0 y Q ; .. V •- Z . >, b .N. a.. b I. '•" >, V C N V� ° c z g- a W °' . O o o A CO L O o G G a .. o o O V • 3 °o ro G I. b °o y o d U • o .� LI C p >, a.) L H o v i) •o o o 'y a r I. A z .� U U ., .� G N d' y .... a cad N Fa ti 9 U a V L. ^� O > CM a 3 v W W" a s ° c ;, b " . � ' UdvA w Q � 0 El W z al u a, E w 'C ro z t.) q L 0 b0 to CL, ,b O C Imi y GJ w ro A .O„ Qi N a �+ N C 9 A '� o T C G can 2 �" d ayi U U v v H aVi C7 a v w w z z -54- : C o C C O U ,... W - a 2 U U C O Q _I,CS o- or c a o 3 'c cn Q ❑ E b CC a ❑ ❑ GC 40 ❑ c O C •N o N If' t aNi a o Eo O ¢ •9 = vZ w a c N C.., C7 ® ❑ 0 d y 09 E 0 to oo F o -� o o a i '� 3 °' > o w a Z O w u a °c 3 '- A p a N o �, a.) o C E.A., .'W dt a o o o a cu In 0 G' oc-n o v _o o vi *" ❑ Pd o 000 d d a Z ❑ E 3 a0i 1 Q� �>, r1 "'. b © M .-- O Y �, p U .. N cC �0. �0, cd N C7 ,.i y el y �d f3. O >_ p, a 'al rn er o00 O O a) (� a) G C T �" C �' i.. co in N �; .C C c O M o cd N •+ N �cii V .FO, o W m c © N 3 b C C. c a Q a s ❑�❑ Pi .C Q' p 'O [ •p ,b M r co C U• icd W •.[ .J O.i o o " cd A LEI [n o 7 ,E Ui. b O r d F F F o O U �, U U U © V V co 0 ix •, O to G aai x W '� U W N .0 > Z p T o d G 71 60 VI Z 0.°` > k E.W., '^ a o b U b CID d Aon Z CI o Al rip ® b 13 E o so NI 0 `° G bN a " I U ." o 0 7 'a 0 e. El L r,4 w M C/� U a cd b E N ❑ cG 0,0 CO U 9 N �. p k O C W •, N W 00 00 G. >i W _ n C7 V a' W v' o '�? �" a a a eo °co O C 0O) U a d o ¢ 0 24" co 4) v b �, = 0 3 en ��. 'a+ y ,—, �.00 N4 141 C Op, V o0 'Z' Q G O ® �"' N .co0 +r+ U .b �.i E W M F." V] ^p C C 7 O 'C cCd p •� >' O N N en ,_) N ,� ,G�,r�r �. ." C C o a 0 G N Ca C7 N U 00 'r ." p C7 V' i ,z 0 40 N 0 6 W�\ O C 27 C O W O •Y p ❑ a !y� - i 0.,i v � O V cd G O C 't7 �' .,... -' C c) fro. .. b0 v7 a F4 O h�1 (, (, y +' . E v C7 0 p +' \' 6 C b T !. C C 0... cC H O, cd r.,-, a'C.., O W 0 V z U Y 0 4)i o " v o D ,S W a • P C, C C7 ,, a, o v .o U W A c c 3 r y." A ' c o a�i E us a a v p W a i V Coi z00 o d d C C CQ N > r, E c""' a ,p•, 0 C O ,n o % ❑ 0.r O 2 2 . 2 Z 1 1 4 �i �, o U °�,' v� o o y - 4 9 0 E y N C .z F" °..° P. 3 a a .0 .. d N ., „ o c C .. w--i ,-4 C a d Z m. A ,- 0 7 a ° o E v ,d G4 v0i ® 3 N a�2 lc [- o ® a ❑®® A V N ai 0 0 y N _gyp w •o -^ °' 0 co .C 9 o ,�cd C V ' Z Z v b o b ° N _ •- 0 o =I v a • o .. J..; $ .o f� y .d.02" + O V ‘ 1 >, 0 W d U Q c� a[ o z 0 «. •- a er v E = H c Se c C7 -...2. i Z W o C I.. oz o o c .d C `C C 0 2c4 N o ,o, o p, eoo � Z 1 . •+ p a o O H C C7 ;� .- = .0 b C . a C- ( c� c, v G �. .o w e a,pi • o E cn 9 :� o E o •K �a , 'E c 9 o 0.Z 0000 o C7 cn 'a -o o d p., u. CA a o.) w° z O ♦ ♦ ♦ vp rx C70 ( 6 ,93 w u cC �+ G O o y. O O O O O O 'O O 0. +�.. I e• 7 'a• 7 7 4 z _ 4. 0 r. E W U U I o U U U U U t py �'•' on ccl c y >, ,}_, W v c.4 as N ca o as ca ca O+ H i on m I at p C $. 1, U Gy U U U U U �; GO �p o co U Ooi w •y V] 0 ¢ C7 C7 C7 C? U s., boo v c 1 oon wA ° O 4 s r� o 0 0 0 U •O °r° o F,, W C7 C7 C7 C7 C7 C7 v./ u Ll eii 1 0' a. a"i .r ... C o In N �+ "' y 0 C • co aa �a> �O O� N R sD cA O M O �' L R ON O d a~i ° `" y E' C o e•i O O O O o O d C O 6 L ` ih aU i N 11 ! C cy O •� v> V ° vi •y w 4'1ai Q ,s o e b KJ s S o 0 40 - O E O r E� - c o c9- NI u o R 'C - �k o o m w .a '� LL CJ M ''' ❑ � d G e.) y N C u ••w, ai ^4n CI CI aY I -5c 0 33an n en o a� , dm ' a II o °� c C `°CI _' o a A E ° ` o a0l a I > = O F = Itil .a '' v C = Y O y al u o O O I C ❑ " o cA a z w .0 — Eal CL C d d y ° '° t o Q• Jr:: 8 o a N V u cis " U U ,I_:, g4 p ❑ o w U . C d E0. E C 55' N+ I O C p `r o o .a 0 o o h an u y u cn 5 y O O N U w ti o C 0 (4 v a C ° c v o c E U = O d a ice+ _ UOr V O C O L 0 < c vI wv G b11 .� ea E M U 0 w o Q v G C y fV L .fir w on .p L=, ® C• o O 0 N O C/� of i... y 4 a� v > O b 0 C a L'i W Inv I Ca Tri °° L. W •U a O u p O O C C7 u ° as d o w 7 w w '''.4 w w .0 a� E. 'O >4 w C O Nqq 'fl > p 0.q ..t k. s r.0 u u u u u Q a C EQ3 ea A A U cc v La o . . `° o a Z cV QN ri) a. al .. a o o ¢� o .0 az .0 s O O t = w E d0.0 c .c a3 9 .a o i., a o[ A' era E p U [ y d 10 N.° °4 on = o , O o o 0 v .0 ca. I Q 8 O P. S U U F-I > U U A A d o c °i °' ❑ es Z y Y O o O �, 0'� s L is O i.. W ti O �..i O W �, O tV O �p tai ti 1'K O� �i� o ++ W U w U ►C.1 L C ?? M O it) O ao I as - y R o �? a� •o ° o v o t cG enS (.4.: o Y N Uy j • o 15 O 0 0 R v `- w A C u O U > A O , I `' °= a ' a> ° o°'n U P o s� R �' O R C O C Z U .+ C O¢ c� [�. Q 4.4 R �.o U �Q wi ai �••� u� u a w • E o cp tai r/� 40 W >, w U a o as i A V� x A V +' `° r c v abi y W 9 H-- > ❑ S d v CA U U c RR. a E ❑ C C U p U c ccn ., 7 0 V U,0 S o u ^u Or OD o U U �. p O� 4) AN C U ►1 6) 5 W a>—y p ea CG ^' w , ::E p ce n. ^O N v m C N Z o A mo " c u C ° E a a n A `4 �+ EiJ '+ y u ,Y U y ° A U U .0 d o d .5 W Q 4 8 E v'xC7 s cn .; a o .� > E 'C 40 y O A 8 '0 v, e p o w 00 U a C °> C CL w .. a? 00 g 6 0 ,6 o a g a ►► cA O.� N a .a O 0 a U U U '7 .0. O AN = V v1 �W .. " U F u '� -c, E W e U � � d N I w °' I d i y a � ! I h „ ° U I o CZ ,i o r-., c o n. E a, .r 4 c a c E Ox UO O O 7 T. c i; °se o v >, a> a� C W U la > °� C C Ow z + cOd O U H (� Gl+ O a '� '7 0.1 F°, q a+ ❑ • v av)� w v ® 0 V W a) bA O A A W ® 7) V) Hello