HomeMy WebLinkAbout20151251.tiff 'TN. CDPHE COLORADO
Co -If-► Department of Public
Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board • " -' a r
1150O St
PO Box 758 MH !i i fop)
Greeley, CO 80632 bVELD CrOj,,",NTY
April 28, 2015 COtUPv1issfoi^JERs
Dear Sir or Madam:
On April 29, 2015, the Air Pollution Control Division will begin a 30-day public notice period for
Bonanza Creek Energy Operating Company LLC - State Pronghorn CPF 41-32. 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 e Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
Rte,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
2015-1251
Co -
41,0
43 0 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.colorado.govicdphe o
John W. Hickentooper, Governor Larry Wolk,MD.MSPH, Executive Director and Chief Medical Officer „
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CDPHE Air Pollution Control Division
co Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Bonanza Creek Energy Operating Company LLC - State Pronghorn CPF 41-32 - Weld County
Notice Period Begins: April 29, 2015
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: State Pronghorn CPF 41-32
Oil Et gas production facility
NENE of Section 32 of T5N R61 W, approx. 18 miles E of Kersey
Weld County
The proposed project or activity is as follows: The applicant proposes to construct and operate a 12.0
MMscf/day triethylene glycol dehydrator. to remove water from the gas stream.
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 14WE1760 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:
Andy Gruel
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
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COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION �e�
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO: 14W E1760
1 760
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 State Pronghorn CPF 41-32, located in the NENE of Section
32, Township 5N, Range 61W, 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. Each gas-glycol pump is
permitted to operate at the maximum design capacity, a lean
glycol recirculation rate of 3.5 gallons per minute. Only one
Kimray gas-glycol pump will be operated at any given time; the
DEHY-1 001 second gas-glycol pump is used as backup only. This gas
dehydration unit is equipped with a flash tank, reboiler and still
vent. Emissions from the still vent are routed to an air-cooled
condenser and then to a combustor with a design destruction
efficiency of at least 98%. Vapors from the flash tank are routed
to a vapor recovery unit (VRU) and recompressed to the sales gas
line, and as a backup are routed to the onsite fuel system.
Stripping gas is not used.
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, la
submitting a Notice of Startup form to the Division. The Notice of Startup form may be
AIRS ID: 123-9D48 Page 1 of 11
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downloaded online at https//www.colorado.00v/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.
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, III.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 fora 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. Point 001: 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; and
• 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
Equipment ID Point NO, VOC CO Emission Type
DEHY-1 001 --- 347 --- Point
(Note: Monthly limits are based on a 31-day month.)
The owner or operator shall calculate monthly emissions based on the calendar month.
AIRS ID: 123-9D4B Page 2 of 11
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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.
Annual Limits:
Facility AIRS Tons per Year Emission Type
Equipment ID Point NO, VOC CO
DEHY-1 001 --- 2.1 --- 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 wet gas
analysis and recorded operational values(including gas throughput, lean glycol recirculation
rate, VRU downtime 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
DENY-1 001 Condenser, flare, and recycle of flash tank vapors VOC
10. 100% of emissions that result from the flash tank associated with this dehydrator shall be
recompressed and recycled to the sales gas line. As an alternative, the flash tank vapors
may be routed to the reboiler fuel system.
AIRS ID: 123-9D4B Page 3 of 11
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Air Pollution Control Division
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 Process Parameter
Point Limit (31 days)
ID Y )
DEHY-1 001 Natural gas throughput 4,380 372
MMscf/yr MMscf/month
The owner or operator shall calculate 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(i.e., 123/9D4B/001) shall be marked on the
subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.)
(State only enforceable)
14. 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.2.b shall have no visible emissions. (Reference: Regulation No. 1,
Section II.A.1. & 4.)
15. This source is subject to the odor requirements of Regulation No.2. (State only enforceable)
16. 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.
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17. 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 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.
18. This equipment is subject to the control requirements for glycol natural gas dehydrators
under Regulation No. 7, Section XVII.D (State only enforceable). 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 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.
This source shall comply with all applicable general provisions of Regulation 7, Section XVII.
19. 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.
• §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 TMTechnical 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
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Air Pollution Control Division
(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
20. 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 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.)
21. 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
22. 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)
23. A source initial compliance test on emissions point 001 shall be conducted within two
hundred and seventy(270)days after commencement of operation to measure the emission
rate(s)for the pollutants listed below in order to demonstrate compliance with the emission
limits contained in this permit.
Volatile Organic Compounds using EPA approved methods.
The operator shall measure and record, using EPA approved methods, the VOC mass
emission rate at the outlet of the enclosed combustor used to control air-cooled condenser
emissions to demonstrate compliance with the emission limits contained in this permit. For
the purpose of the test, process models shall not be used to determine the mass flow rate or
AIRS ID: 123-9D4B Page 6 of 11
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composition of the gas at the enclosed combustion device being tested. The dehydration
unit must be operating at the lean glycol recirculation rate capacity as stated in this permit,
plus or minus 10%, for the duration of the test. The condenser outlet temperature shall be
160 degrees Fahrenheit, plus or minus 10%, for the duration of the test. The natural gas
throughput, lean glycol recirculation rate, condenser outlet temperature, and flash tank
temperature and pressure shall be monitored and recorded during the test.
The test protocol shall be in accordance with the requirements of the Air Pollution Control
Division Compliance Test Manual and shall be submitted to the Division for review and
approval at least thirty (30) days prior to testing. No compliance test shall be conducted
without prior approval from the Division.Any compliance test conducted to show compliance
with a monthly or annual emission limitation shall have the results projected up to the
monthly or annual averaging time by multiplying the test results by the allowable number of
operating hours for that averaging time (Reference: Regulation No. 3, Part B., Section
III.G.3)
Periodic Testing Requirements
24. 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 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
25. 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(NO,) in ozone
nonattainment areas emitting less than 100 tons of VOC or NOx 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.
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26. 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).
27. 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 appropriate applicable
requirements of Subpart HH. (Reference: Regulation No. 8, Part E)
GENERAL TERMS AND CONDITIONS
28. 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 'LB upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
29. 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.
30. 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.
31. 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.
32. 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.
33. 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
AIRS ID: 123-9D4B Page 8 of 11
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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.
34. 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:
Andy Gruel, P.E.
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to Bonanza Creek Energy Operating
Company LLC.
AIRS ID: 123-9D4B Page 9 of 11
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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.qov/pacific/cdohe/aqcc-reqs
4) The following emissions of non-criteria reportable air pollutants (NCRPs) 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
Point Pollutant CAS# (lb/yr) reportable? Rate (Ib/yr)
Benzene 71432 16,899 YES 737
Toluene 108883 14,941 YES 629
001 Ethylbenzene 100414 2,184 YES 84
Xylenes 1330207 6,842 YES 257
n-Hexane 110543 5,484 YES 76
Emission Factors for reportable NCRPs in the table above:
Benzene: 3.858 lb/MMscf
Toluene: 3.411 lb/MMscf
Ethylbenzene: 0.499 lb/MMscf
Xylenes: 1.562 lb/MMscf
n-Hexane: 1.252 lb/MMscf
AIRS ID: 123-9D4B Page 10 of 11
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jlk Cok w do Dipertene F of Public Health and Environment
S fir * .. H, Air Pollution Control Division
- b t: Nil
day :
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 1000
psig. The permitted lean glycol recirculation rate is 3.5 gallons per minute. The applicant specified flash
tank operation at a temperature of 150.0°F and a pressure of 125.0 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 160.0°F at a pressure of 12.2 psia. Condenser emissions are controlled
by an enclosed combustor. The enclosed combustor is granted a 95% reduction for the control of
uncondensed vapors. Emission factors 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.
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 Status
Requirement
Operating Permit Synthetic Minor source of: VOC, HAPs (total)
NANSR Synthetic Minor source of: VOC, HAPs (total)
PSD Minor Source
MACT HH Area Source Requirements: Applicable
NSPS KKK Not 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: 123-9D4B Page 11 of 11
Construction Permit Application
Preliminary Analysis Summary
Section 1 —Applicant Information
Company Name: Bonanza Creek Energy Operating Company LLC
Permit Number: 14WE1760
Source Location: State Pronghorn CPF 41-32—NENE SEC 32 T5N R61 W, Weld County
Equipment Description: 12 MMscf/day TEG dehydration unit, "DENY-1"
AIRS ID: 123-9D4B-001
Date: 04/13/2015
Review Engineer: Andy Gruel
Control Engineer: Stefanie Rucker
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 app was missing "Input
Information Request letter to the source? Summary" sheet from Glycalc model.
Emailed Jerry Dismukes 3/27/2015.
Received Input Summary sheet on
3/31/2015. Redlined the APEN to
match GlyCalc output.
On what date was this application complete? 3/31/2015
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 3.5 gallons per
001 minute (one pump used as 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 a
condenser and then to a flare. Emissions from the flash tank are routed directly to the
sales gas line, and as a backup are routed to the onsite fuel 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? PM1O CO X Ozone
Is this location in an attainment maintenance area for Yes X No
any criteria pollutant?
Page 1
If"yes", for what pollutant?
(Note: These pollutants are subject to minor source PM10 CO 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—neww source—no actual emissions reported
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
AIRS Point Process Control Device Description % Reduction Granted
95%for combustor;
Condenser and combustor(for still with recycle of flash vapors, overall
001 01 vent), and recycle (to sales line)of control modeled by Glycalc is 98.9%
vapors from flash tank (VOC), and 95.6% -98.5% (HAPs)
[see Section 13]
Section 6—Emission Summa (tons per year)
Point NO„ VOC CO Single HAP Total HAP
PTE: 001 0.07 184.22 0.35 8.45 (benzene) 23.2
Uncontrolled point 001 0.07 184.22 0.35 8.45 (benzene) 23.2
source emission rate:
Controlled point 001 0.07 2.03 0.35 0.37 (benzene) 0.89
source emission rate:
Total APEN Reported 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 Ibl r
(lb/yr) reportable? Rate( Y)
Benzene 71432 16,899 Yes 737
Toluene 108883 14,941 Yes 629
Ethylbenzene 100414 2,184 Yes 84
Xylenes 1330207 6,842 Yes 257
n-Hexane 110543 5,484 Yes 76
Page 2
Note: Regulation 3, Part A, Section I1.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 Yes X No
standard?
If"yes", complete the information listed below
AIRS Point Process Pollutant Regulatory Basis Test Method
Section 9—Source Classification
Is this a new previously un-permitted source? X Yes No
What is this facility classification? True X Synthetic Major
Minor Minor
Classification relates to what programs? X Title V PSD X NA NSR X MACT
Is this a modification to an existing permit? Yes X No
If"yes"what kind of modification? Minor Synthetic 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)? HH X Yes No
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
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.
Re•ulation 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.
Page 3
Requlation 3-APENs,Construction Permits, Operatinq Permits, PSD
Part A-APEN Requirements
001 Applicant is required to file an APEN since emissions exceed 1 ton per year VOC in an 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 II.D.3.a)
Requlation 6- New Source Performance Standards
001 None
Requlation 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
001 than 3 MMSCFD or benzene exemption of less than 1984 Ib/yr)? Yes
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 actual VOC emissions are greater than or equal to 6 tons per year. (XVII.D.3)
Requlation 8—Hazardous Air Pollutants
MACT HH:
1.1s 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
major source of HAPS when summing all HAP emissions from ALL HAP emitting
001 units? N/A—facility is a production field facility
4.Is this facility considered MAJOR for HAPS? No
5.Is this source subject to MACT HH? Yes
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 1984 Ib/yr,
this source is only required to calculate and keep records demonstrating that benzene
emissions stay below this level.
Page 4
Section 13—Aerometric Information Retrieval System Coding Information
Process Throughput Emission Pollutant/ Fugitive Emission Control
Point Process
Description limit Factor CAS# (Y/N) Factor Source (%)
84.12 VOC No GlyCalc 4.0 98.89
lb/MMscf
3.858 Benzene/ No GlyCalc 4.0 95.64
lb/MMscf 71432
3.411 Toluene/
4,380 No GlyCalc 4.0 95.79
Glycol Ib/MMscf 1O8883
01 MMscf per
001 Dehydrator 0.499 Ethylbenzene No GlyCalc 4.0 96.16
lb/MMscf / 100414
1.562 Xylenes/ No GlyCalc 4.0 96.24
lb/MMscf 1330207
1.252 n-Hexane/ No GlyCalc 4.0 98.61
lb/MMscf 110543
SCC 31000227: Glycol Dehydrator: reboiler still stack
Page 5
Section 14—Miscellaneous Application Notes
AIRS Point 001 Glycol Dehydrator
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 1000 psig. The permitted glycol recirculation rate is 3.5 gallons per
minute.
The GlyCalc model was based off of an extended gas analysis of gas sampled 4/16/2014. The gas
analysis was perfomed less than a year of submittal.An updated extended gas analysis will not be
required because an extended gas analysis was performed within a year of this submittal and included
with this package.
A pollutant control efficiency of greater than 95% is granted, based on GlyCALC output. 100% of the
flash tank vapors are sent to the sales gas line; as a backup the flash tank vapors are sent to the fuel
system. A condenser is also used to further control the still vent. The control efficiencies listed in Section
13 are based on the GlyCALC modeled controlled emissions from the unit, accounting for these factors.
Gly-Calc-Uncontrolled Emission factors
pollutant = (flash tank emissions tpy + still vent emissions tpy) * (2000 lb/ton)/ (4380 MMscf/yr)
VOC = (135.7926+48.4302) *2000/4380 = 84.12 Ib/MMscf
Benzene = (0.7525 +7.6969) *2000/4380 = 3.858 Ib/MMscf
Toluene = (0.4716 +6.9987) *2000/4380 = 3.411 Ib/MMscf
Ethylbenzene= (0.0440 + 1.0480) *2000/4380 = 0.499 lb/MMscf
Xylenes = (0.0979+ 3.3231) *2000/4380 = 1.562 Ib/MMscf
N-hexane = (1.9600 + 0.7820) *2000/4380 = 1.252 Ib/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.
Based on the definitions above, this source qualifies as a production field facility. Thus, HAP
emissions from the dehy unit and storage vessels with potential for flash emissions will be aggregated for
major source determination. At the time of this preliminary analysis (April 2015), the only points for which
permits have been applied for are this TEG dehydration unit and two (2) engines (under GP02). Thus, at
this point, the major source applicability depends only on the TEG dehy emissions, which are below
major source levels.
Does this dehydrator have a reboiler?Yes
If Yes, what is the reboiler rated? 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).
Page 6
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