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Home My WebLink About20140908.tiff STATE OF COLORADO John W.Hickenlooper,Governor Larry Wolk,MD,MSPH �.0cc,°vop� Executive Director and Chief Medical Officer e ,S Dedicated to protecting and improving the health and environment of the people of Colorado .q 4300 Cherry Creek Dr.S. Laboratory Services Division raga s Denver,Colorado 80246-1530 8100 Lowry Blvd. Phone(303)692-2000 Denver,Colorado 80230-6928 Colorado Department Located in Glendale.Colorado (303)692-3090 of Public Health www.colorado.gov/cdphe and Environment Weld County -Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 RECEIVED March 18,2014 MAR 2 1 2C14 WELD COUNTY COMMISSIONERS Dear Sir or Madam: On March 21,2014, the Air Pollution Control Division will publish a public notice for Hudson Terminal Railroad Company—Transloading Facility, in the The Greele> I ribunc. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30)days from the date the public notice is published. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health & Environment A PC D-S S-B l 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, /I Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure Rath( ) utEv> Ce . PL I Pw 3 31 H h -at 2014-0908 STATE OF COLORADO John W.Hickenlooper,Governor Larry Wolk,MD,MSPH .0? cot° Executive Director and Chief Medical Officer ti� 90 Dedicated to protecting and improving the health and environment of the people of Colorado 4300 Cherry Creek Dr.S. Laboratory Services Division Y/896 Denver,Colorado 80246-1530 8100 Lowry Blvd. Phone(303)692-2000 Denver,Colorado 80230-6928 Colorado Department Located in Glendale,Colorado (303)692-3090 of Public Health www.colorado.gov/cdphe and Environment Website Title: Hudson Terminal Railroad Company—Transloading Facility— Weld County Released To: The Greeley Tribune On: March 18, 2014 Published: March 21, 2014 PUBLIC NOTICE OF A PROPOSED PROJECT OR ACTIVITY WARRANTING PUBLIC COMMENT Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: Hudson Terminal Railroad Company Facility: Transloading Facility Crude oil transloading facility 22400 1-76 Access Road, Hudson, CO 80642 Weld County The proposed project or activity is as follows: The applicant proposes to operate a crude oil transloading facility with an annual capacity of 10,357,205 barrels. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section II1.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 13WE2019 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at www.colorado.gov/cdphe/AirPublicNotices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Any such comment must be submitted in writing to the following addressee: Michael Harris Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South,APCD-SS-B 1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us D RAFT STATE OF COLORADO a�rF � COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT e AIR POLLUTION CONTROL DIVISION a^ ` TELEPHONE: (303) 692-3150 . r • */876' CONSTRUCTION PERMIT PERMIT NO: 13WE2019 YY E201 9 Issuance 1 DATE ISSUED: ISSUED TO: Hudson Terminal Railroad Company THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Crude oil transloading facility, owned and operated by Hudson Terminal Railroad Company. located at 22400 1-76 Access Road, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID Transloading of crude oil from tanker trucks to rail cars. Product from tanker trucks will be transferred to rail cars using either an on board Transloading 002 pump located on the tanker truck or a portable skid-mounted pump. Operation Volatile Organic Compound (VOCs) emissions shall be controlled with a vapor balancing system to allow transfer and capture of VOC vapors from the rail car to the tanker truck during product transfer. 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 APPROVAL 1. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days after commencement of operation under this permit by submitting a Notice of Startup (NOS) form to the Division. The Notice of Startup (NOS)form may be downloaded online at www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of the permitted source is a violation of 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) after commencement of operation, compliance with the conditions contained on this permit shall be demonstrated to the Division. It is the permittee's responsibility to self certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit or enforcement action by the Division. Information on how to certify compliance was mailed with the permit or can be obtained from the Division. (Reference: Regulation No. 3, Part B, III.G.2). AIRS ID: 123/0248/002&003 Page 1 of 9 Version 2009-1 D RAFT Colorado Department of Public Health and Environment Air Pollution Control Division Hudson Terminal Railroad Co Permit No. 13WE2019 Issuance 1 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. Within one hundred and eighty days (180) after commencement of operation, 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. Within thirty(30) days after commencement of operation, the permit number shall be posted in a visible location for ease of identification. (Reference: Regulation No. 3, Part B, III.E.) (State only enforceable) EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations (as calculated using the emission factors included in the Notes to Permit Holder section of this permit). Annual records of the actual emission rates shall be maintained by the applicant and made available to the Division for inspection upon request. (Reference: Regulation No. 3, Part B, Section II.A.4) Monthly Limits: Facility AIRS Tons per month (1) Emission Equipment ID Point PM PM�a PMZ_5 NO, SO2 VOC CO Type 002 0.8 ---- Point TOTAL ---- 0.8 ---- Point (1) The monthly limits included in this permit were derived based on a 31-day month. The owner or operator shall calculate monthly emissions based on the calendar month. Annual Limits: Facility AIRS Tons per Year(2) Emission Equipment ID Point PM PK') PM2.5 NO, SO2 VOC CO Type 002 9.6 ---- Point 003 27.0 6.84 0.7 ---- Fugitive TOTAL 27.0 6.84 0.7 ---- ---- 9.6 (2)Annual limits am derived as 12 times the monthly limit See "Notes to Permit Holder #3" for information on emission factors and methods used to calculate limits. AIRS ID: 123/0248/002&003 Page 2 of 9 DRAFT Colorado Department of Public Health and Environment Air Pollution Control Division Hudson Terminal Railroad Co Permit No. 13WE2019 Issuance 1 Compliance with the fugitive emission limits shall be demonstrated by not exceeding the production limits in condition 8 and by following the attached particulate emissions control plan. 7. The following control equipment shall be maintained and operated to ensure satisfactory performance. The owner or operator shall monitor compliance with this condition through the results of approved compliance tests (when required), compliance with the Operating and Maintenance Plan, compliance records, and other methods as approved by the Division. (Reference: Regulation No. 3, Part B, Section III.E.) Facility AIRS Controlled Control Device Equipment ID Point Pollutants Transloading 001 Vapor Balance System VOC operations As defined in Regulation 7, Section VI.A.2.i., a Vapor Balance System is, "a combination of pipes or hoses that create a closed system between the vapor spaces of an unloading tank and a receiving tank such that vapors displaced from the receiving tank are transferred to the tank being unloaded. " PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum consumption, processing and/or operational rates as listed below. Annual records of the actual process rate shall be maintained by the applicant and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4). Process/Consumption Limits Facility AIRS Process Parameter Annual Limit Equipment ID Point Transloading 001 Throughput of crude oil 10,357,205 operations barrels STATE AND FEDERAL REGULATORY REQUIREMENTS 9. 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 ° more thansix minutes in any sixty consecutive visible emissions shall not exceed 30/° opacity for t a minutes. Opacity shall be determined using EPA Method 9. (Reference: Regulation No. 1, Section II.A.1. &4.) 10. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable). 11. This source is subject to requirements to Control Emissions of Volatile Organic Compounds as contained in Regulation No. 7, Section VI. "Storage and Transfer of Petroleum Liquid" including but not limited to §VI.C.4. Transport Vehicles AIRS ID: 123/0248/002&003 Page 3 of 9 D RAFT Colorado Department of Public Health and Environment Air Pollution Control Division Hudson Terminal Railroad Co Permit No. 13WE2019 Issuance 1 §VI.C.4.a Rail cars shall be loaded only at facilities which allow for the following: §VI.C.4.a(i)A submerged fill pipe which reaches within 15.24 cm (6 in) of the bottom of the tank or tank cars equipped for bottom loading. §VI.C.4.a(ii) Vapor collection and/or disposal equipment designated and operated to recover vapors displaced during the loading of the rail car. §VI.C.4.a(iii)A vapor-tight seal around the tank car hatch and the loading equipment 12. The petroleum transport trucks transferring products are subject to the requirements contained in Regulation No. 7, Section VI. "Storage and Transfer of Petroleum Liquid" including but not limited to:: §VI.C.4.b(i) Dry-break loading and unloading nozzles are used and are compatible with those required at the loading facilities. §VI.C.4.b(ii)Vapor recovery hoses are connected at all times during unloading or loading of petroleum distillate. §VI.C.4.b(iii) Transport trailers and vehicle tanks are operated and maintained to prevent detectable hydrocarbon vapor loss during loading and delivery. §VI.C.4.b(iv) Compartment dome lids are closed and locked during transfers of petroleum liquid. Such lids may be opened for the purpose of certifying the accuracy of a delivery only prior to and after such delivery. §VI.C.4.b(v) Hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or vapor loss during loading or unloading 13. This source is located in an ozone non-attainment or attainment-maintenance area and subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.b. The requirements of condition number 6, 7, 8, 11 and 12 above were determined to be RACT for this source. OPERATING & MAINTENANCE REQUIREMENTS 14. This source is not required to follow a Division-approved operating and maintenance plan. COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. There are no initial testing requirements Periodic Testing Requirements 16. There are no periodic testing requirements. AIRS ID: 123/0248/002&003 Page 4 of 9 D RAFT Colorado Department of Public Health and Environment Air Pollution Control Division Hudson Terminal Railroad Co Permit No. 13WE2019 Issuance 1 ADDITIONAL REQUIREMENTS 17. The permit number shall be posted in a visible location for ease of identification. (Reference: Regulation No. 3, Part B, III.E.) (State only enforceable) . 18. The particulate emission control measures listed on Attachment A (as approved by the Division) shall be applied to the particulate emission producing sources as required by Regulation No. 1, Section III.D.1.b 19. A Revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, Section II.C.) • • a. Annually 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 tons per year or more, above the level reported on the last APEN submitted; or For volatile organic compounds (VOC) and nitrogen oxide (NOx) sources in an ozone non-attainment area emitting less than 100 tons of VOC or nitrogen oxide per year, a change in actual emissions of one ton per year or more or five percent, whichever is greater, above the level reported on the last APEN submitted; or For sources emitting 100 tons per year or more of a criteria pollutant, 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 sources emitting any amount of lead, a change in actual emissions, above the level reported on the last APEN submitted, of fifty(50) pounds of lead 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. 20. The requirements of Colorado Regulation No. 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Colorado Regulation No. 3, Part D, Section V.A.7.B). AIRS ID: 123/0248/002&003 Page 5 of 9 D RAFT Colorado Department of Public Health and Environment Air Pollution Control Division Hudson Terminal Railroad Co Permit No. 13WE2019 Issuance 1 With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Facility Emissions -tons per year Equipment AIRS Equipment Pollutant ID Point Description Threshold current permit limit 002 Transloading VOC 100 9.6 GENERAL TERMS AND CONDITIONS: 21. 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 Division as provided in 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. 22. If this permit specifically states that final approval has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit is considered initial approval and does not provide "final" approval for this activity or operation of this source. Final approval 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 approval 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 approval. Details for obtaining final approval to operate are located In the Requirements to Self-Certify for Final Approval section of this permit. The operator shall retain the permit final approval letter issued by the Division after completion of self- certification with the most current construction permit. 23. This permit is issued in reliance upon the accuracy and completeness of information supplied by the applicant 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 applicant or applicant's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. By: By: Michael Harris, P. E. R K Hancock III, P.E. Permit Engineer Construction Permits Unit Supervisor AIRS ID: 123/0248/002&003 Page 6 of 9 D RAFT Colorado Department of Public Health and Environment Air Pollution Control Division Hudson Terminal Railroad Co Permit No. 13WE2019 Issuance 1 Permit History Issuance Date Description Initial Approval This Issuance Issued to Rocky Mountain Transloading, Inc Notes to Permit Holder(as of date of permit issuance): 1) The production or raw material processing limits and emission limits contained in this permit are based on the production/processing rates requested in the permit application. These limits may be revised upon request of the permittee providing there is no exceedence of any specific emission control regulation or any ambient air quality standard. A revised air pollutant emission notice (APEN) and application form must be submitted with a request for a permit revision. 2) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The permittee shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See: http://www.cdphe.state.co.us/regulations/airregs/5CC R1001-2.pdf. 3) The emission levels contained in this permit are based on the following emission factors: Point 002: Loading facility VOC emissions (AIRS point 001) based on the loading loss equation (AP 42, Section 5.2 ) with the parameters as listed below, and 98.7% control for vapor balancing: Parameter Condensate S- saturation factor 1.0 P—true vapor pressure 2.8 M—molecular weight 50 T—temperature (degrees R) 520 LL- loading loss lb/1000 gal(uncontrolled) 3.3546 LL—loading loss lb/1000 gal (controlled) 0.0436 4) 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. 5) This facility is classified as follows: AIRS ID: 123/0248/002&003 Page 7 of 9 D RA F T Colorado Department of Public Health and Environment Air Pollution Control Division Hudson Terminal Railroad Co Permit No. 13WE2019 Issuance 1 Applicable Status Requirement Operating Permit Synthetic minor for VOC NANSR Synthetic minor for VOC 6) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.qpoaccess.qov/ r.q poaccess.q ov/ 7) 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.) 8) If this permit specifically states that final approval 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 approval of the permit must be secured from the Division in writing in accordance with the provisions of 25-7-114.5(12)(a)C.R.S. and Regulation No. 3, Part B, Section III.G. Final approval cannot be granted until the operation or activity commences and has been verified by the Division 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 approval. Details for obtaining final approval to operate are located in the Requirements to Self-Certify for Final Approval section of this permit. 9) Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the Division to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 10) 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 Division on grounds set forth in the Colorado Air Pollution Prevention and Control Act and regulations of the 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 applicant, or the Division revokes a permit, the applicant or owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 11) Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollutant 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: 123/0248/002&003 Page 8 of 9 D RAFT Colorado Department of Public Health and Environment Air Pollution Control Division Hudson Terminal Railroad Co Permit No. 13WE2019 Issuance 1 12) 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. ATTACHMENT A PARTICULATE EMISSIONS CONTROL PLAN FOR MATERIAL PROCESSING ACTIVITIES THE FOLLOWING PARTICULATE EMISSIONS CONTROL MEASURES SHALL BE USED FOR COMPLIANCE PURPOSES ON THE ACTIVITIES COVERED BY THIS PERMIT, AS REQUIRED BY THE AIR QUALITY CONTROL COMMISSION REGULATION NO.1, Section III.D.1.b. THIS SOURCE IS SUBJECT TO THE FOLLOWING EMISSION GUIDELINES: a. Processing Activities -Visible emissions not to exceed 20% opacity, no off-property transport of visible emissions. b. Haul Roads -No off-property transport of visible emissions shall apply to on-site haul roads, the nuisance guidelines shall apply to off-site haul roads. c. Haul Trucks -There shall be no off-property transport of visible emissions from haul trucks when operating on the property of the owner or operator. There shall be no off-vehicle transport of visible emissions from the material in the haul trucks when operating off of the property of the owner or operator. Control Measures 1. Unpaved haul roads shall be watered as often as needed to control fugitive particulate emissions such that the above guidelines are met. AIRS ID: 123/0248/002&003 Page 9 of 9 AIR POLLUTION CONTROL DIVISION PRELIMINARY ANALYSIS PERMIT NUMBER: 13WE2019 DATE: March 18, 2014 APPLICANT: Hudson Terminal Railroad Company REVIEW ENGINEER: Michael J. Harris, P.E. CONTROL ENGINEER: R. K. Hancock III, P.E. PROJECT DESCRIPTION Hudson Terminal Railroad Company is proposing to operate a crude oil transloading facility located at 22400 1-76 Access Road, Weld County, Hudson, Colorado. The facility would allow crude oil to be transferred from tanker trucks to rail tank cars for shipment. Estimated Emissions The resulting estimated controlled emissions from permit 13WE2019 are listed below: Controlled emissions in tons per year PM PM10 PM2.5 VOC NOx CO 27.0 6.84 0.7 9.6 0 0 SOURCE CLASSIFICATION This source is considered a synthetic minor source according to the Air Quality Control Commission regulations. Emissions of Volatile Organic Compounds (VOCs) could exceed 100 tons per year if Hudson Terminal Railroad Company management did not accept federally enforceable limits on production throughput and installation and operation of air pollution control equipment. The company has made an application for issuance of a federally enforceable synthetic minor source permit limiting the potential to emit to below the major source thresholds. Therefore, this source is considered a synthetic minor source and not subject to NANSR, MACT or Operating permit requirements. The Division has determined that the proposed source will comply with all applicable regulations and standards of the Colorado Air Quality control Commission and has made a preliminary determination of approval of the application. Page 1 of 1 Y C ❑ '! _77 ! ! M M _ n U G E [U V V 9 m ti 71N N - - L - U J O : �..� G l� ^ _ n .1r. = j F rr . L. u v O _ m - F - - P _ C O .G ;I- G 5:,fj _7 a. L _ _ ..L = C p >" = _ -0 U G C a ` C C ` < _ t - _ _ J C J - 6 Y i _ - C - u u 0_ u N 0: G < _ ,, - -7 CO _G • V c - o o - t J c '. 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