The URL can be used to link to this page

Browse Search

Home My WebLink About20142464.tiff STATE OF COLORADO John W.Hickenlooper,Governor Larry Wolk,MD,MSPH .of•cpto� Executive Director and Chief Medical Officer tie 90 Dedicated to protecting and improving the health and environment of the people of Colorado , ;� o ^>4 4300 Cherry Creek Dr.S. Laboratory Services Division y876 Denver,Colorado 80246-1530 8100 Lowry Blvd. Phone(303)692-2000 Denver,Colorado 80230-6928 Located in Glendale,Colorado (303)692-3090 Colorado Department 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 August 5, 2014 AUG 0 7 2014 WELD COUNTY Dear Sir or Madam: COMMISSIONERS On August 9, 2014, the Air Pollution Control Division will publish a public notice for Bill Barrett Corporation— 18492_Hawkins 5-61-21, in the The Greeley Tribune. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30)days from the date the public notice is published. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health & Environment APCD-SS-B I 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, /, 71 Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure llG�ia�/t�u� CttvI(MMnPw(tht Rs,3m')lit(Fe) S-13- 2oly B -7-2O14 2014-2464 STATE OF COLORADO John W.Hickenlooper,Governor Larry Wolk,MD,MSPH • oF cot° Executive Director and Chief Medical Officer /Fe To Dedicated to protecting and improving the health and environment of the people of Colorado w�;� h ® 4300 Cherry Creek Dr.S. Laboratory Services Division ..s y 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: Bill Barrett Corporation— 18492_Hawkins 5-61-21 — Weld County Released To: The Greeley Tribune On: August 5, 2014 Published: August 9, 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: Bill Barrett Corporation Facility: 18492_Hawkins 5-61-21 Oil and gas exploration and production facility NWSW Section 21, T5N, R61 W Weld County The proposed project or activity is as follows: New oil and gas exploration and production facility consisting of condensate and produced water tanks, truck loadout, associated fugitive emissions and a vapor recovery tower. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section 111.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No.3, Part B, Section III.C.I.a (25 tpy in a non-attainment area and/or 50 tpy in an attainment area) • the 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 Permits 14WE0430, 14WE043I, 14WE0432, 14WE0433 and 14WE0880 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-perm i t-public-not icess The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Any such comment must be submitted in writing to the following addressee: Stephanie Chaousy Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South,APCD-SS-B 1 Denver,Colorado 80246-1530- cdphe.commentsapcd@state.co.us Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Bill Barrett Corporation Permit Number: 14WE0430 Source Location: 18492 Hawkins 5-61-21 NWSW Section 21, T5N, R61W, Weld County (non-attainment) Equipment Description: Condensate tanks AIRS ID: 123-9COF-005 Date: May 7, 2014 Review Engineer: Stephanie Chaousy, PE 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? X Yes No If you answered "no"to any of the above, when did you mail an Information Request letter to the source? February 18, 2014. Updated APEN received On what date was this application complete? via mail 5/29/14. BBC made revisions and provided new calculations on 7/2/14 and supporting documentation 7/16/14. Section 4—Source Description AIRS Point Equipment Description 005 Six (6) above ground 400 bbl atmospheric condensate storage tanks. Emissions from these tanks are controlled by a combustor(3 total). Is this a portable source? Yes X No Is this location in a non-attainment area for any criteria X Yes No pollutant? If"yes", for what pollutant? PM10 CO X Ozone 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 PM,() 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) Page 1 Section 5—Emission Estimate Information AIRS Point Emission Factor Source 005 Source may provide site-specific emission factors using gas EPA Tanks. See Section 14 for calculations. Did the applicant provide actual process data for the emission inventory? Yes X No Basle for Potential to Emit(PTE} AIRS Point Process Consumption/Throughput/Production 005 299,382 BBL per year(249485 x 1.2) Basis for Actual Salesians Reported During this APEN Eilina/Reported to Inventorvj AIRS Point Process Consumption/Throughput/Production Data Year 005 249,485 BBL per year 2013 Basis for Permitted Emissions rennft Limits] AIRS Point Process Consumption/Throughput/Production 005 249,485 BBL per year Does this source use a control device? X Yes No AIRS Point Process Control Device Description °k Reduction Granted 005 01 Combustor(total of 3) 95 Section 6—Emission Summary (tons per year) Point NO, VOC CO Single HAP Total HAP PTE: 005 — 227.2 — 8.5(Hexane) 9.8 Uncontrolled point 005 — 189.3 — 7.0(Hexane) 8.2 source emission rate: Controlled point 005 --- 9.5 — 0.4 (Hexane) 0.4 source emission rate: Section 7—Non-Criteria/Hazardous Air Pollutants Uncontrolled Mtn. Controlled Emission Pollutant CAS# BIN Emission Rate Rate llbhri PbNr) Benzene 71432 A 2220 Yes 111 Toluene 108883 C 2179 Yes 109 Ethylbenzene 100414 C 353 Yes 18 Xylenes 1330207 C 670 Yes 33 n-Hexane 110543 C 14089 Yes 705 2,2,4-TMP 540841 C 2218 Yes 111 Note: Regulation 3, Part A, Section ll.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? Page 2 If"yes", complete the information listed below AIRS Point Process Pollutant Regulatory Basis Test Method 005 01 VOC, Regulation No. 7 Section XVII.AII Method 22 HAPS 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 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? For Reg. 3, Part B, III.C.1.a (emissions increase > 25/50 tpy)? X Yes No For Reg. 3, Part B, III.C.1.c.ii (subject to MACT)? Yes X 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 005 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, 1992)) in all subsections of Section II. A and B of this regulation. 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 005 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 Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for 005 each individual emission point in a non-attainment area with uncontrolled actual emissions of one ton per year or more of any individual criteria pollutant(pollutants are not summed) for which the area is non-attainment. (Applicant is required to file an APEN since emissions exceed 1 ton per year VOC) Part B—Construction Permit Exemptions 005 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 Page 3 NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84. Is this source greater than 19,800 gallons(471 bbl)? No 005 Is this source subject to NSPS Kb? No WHY?Tanks do not meet the criteria of this subpart(less than 19,800 gallons). Therefore, it is not subject. _Regulation 7—Votatlitptaanic Compounds XII.VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS (Applicant is subject to the emission control requirements for condensate tanks 005 since it is located in a non-attainment area.) XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS... (Applicant is currently subject to this since actual uncontrolled emissions are greater than 20 tpy of VOC.) Regulation 8—:I`haelous Air Pollutant MACT EEEE: Organic Liquids Distribution 005 This source is not subject to MACT EEEE because it is not located at a major source of HAP. 005 MACT HH This source is not subject to MACT HH because it is not located at a major source of HAP. Section 13—Aerometric Information Retrieval System Coding Information Point ProcessProcess Emission Pollutant/ Fugitive Emission Factor Source Control Description Factor CAS# (Y/N) (%) 8'7641 V0C No EPA Tanks and Promax 95 lb/1000 gal 0.0352 Benzene/ No EPA Tanks and Promax 95 lb/1000 qal 71432 0.1738 Toluene/ No EPA Tanks and Promax 95 lb/1000 gal 108883 01 E&P Condensate 0.0286 Ethylbenzene/ No EPA Tanks and Promax 95 005Storage Tanks lb/1000 gal 100414 0.0548 Xylenes/ No EPA Tanks and Promax 95 13302 lb/1000 gal 1330207 0.2297 n-Hexane/ No EPA Tanks and Promax 95 lb/1000 gal 110543 0.1762 2,2,4-TMP/ No EPA Tanks and Promax 95 lb/1000 gal 540841 SCC 40400311 —Fixed Roof Tank, Condensate,working+breathing+flashing losses Page 4 • Section 14—Miscellaneous Application Notes AIRS Point 005 Condensate Storage Tanks A permit will be issued because the uncontrolled VOC emissions are greater than 2 TPY(permit threshold). Original APEN included emissions from the condensate tanks as well as the VRT. The VRT should be on a separate APEN. I emailed the operator on 5/7/14 requesting a separate APEN. As a result, the emissions from the tank will decrease. These changes would remove the Promax(flashing)emissions and emission factor from the total condensate tank emissions and emission factors leaving only EPA tanks(working and breathing)for the condensate tanks. July 2, 2014: Per last week's discussion, we are requesting to change flash gas process from using the vapor recovery towers(VRTs)to using heated flash gas separators(HFGSs). There will be emissions increases to both the natural gas venting APEN for the HFGSs and to the condensate tank emissions due to a higher separator temperature(1300F)and pressure drop(20 psi) associated with the HFGSs. The condensate tanks will also be controlled with a dedicated VRU that will recycle the tank emissions back to the sales line. We are assuming a 10% downtime on this VRU when the tank emissions are routed to the combustors during downtime events. Attached are the revised APENS for the condensate tanks and natural gas venting(HFGSs). Backup documents including revisions to the emissions calculations, PROMAX model, Form 102 and process description are also included in the attachment I'd appreciate it if you could red line these two existingAPENs and revise draft permits 14WE0430 and 14WE0880 to reflect these changes. The EPA Tank model was run for 1 tank, so the emissions from the model were multiplied by six. Then it was multiplied by 0.10 for the 10%VRU downtime. The revised emissions for the condensate tanks are as follows: Facility County Software VOC(lb/bbl) Benzene(lb/bbl) n-hexane(lb/bbl) Weld EPA Tanks 0.022 0.00012 0.00077 Weld Promax 1.4957 0.0089 0.0564 Total 1.5177 0.0090* 0.057 `BBC calculated 0.0089 lb/bbl. Probably different as a result of rounding. Will use 0.0089 lb/bbl However, there were other HAP emissions generated from the Promax model: Component Software Emissions(TPY) Emissions(Ib/yr) Emission factor (lb/bbl) Toluene Promax 1.0853 2171 0.0073 Ethylbenzene Promax 0.1748 350 0.0012 Xylenes Promax 0.3373 675 0.0023 2,2,4-TMP Promax 1.109 2218 0.0074 Uncontrolled emission factors in lb/1000 gal are(multiplying lb/bbl by 1000/42): Component Emission factor(lb/bbl) Emission factor(lb/1000 gal) VOC 1.52 36.1905 Benzene 0.0089 0.2119 Toluene 0.0073 0.1738 Ethylbenzene 0.0012 0.0286 Xylenes 0.0023 0.0548 n-hexane 0.057 1.3571 2,2,4-TMP 0.0074 0.1762 I emailed the operator on 7/8/14 regarding the other HAPS generated from the Promax model. The operator/consultant agreed that the other HAPS should be listed. I received a non-reportable air pollutant emission notice addendum via email on 7/9/14. • • Page 5 STATE OF COLORADO 0F Cpk COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303)692-3150 + .� *1876+ CONSTRUCTION PERMIT PERMIT NO: 14WE0430 Issuance 1 DATE ISSUED: ISSUED TO: Bill Barrett Corporation THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the 18492 Hawkins 5-61-21, located in the NWSW of Section 21, Township 5 North, Range 61 West, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID Six (6) 400 BBL fixed roof storage tanks used to store Condensate 005 condensate. Emissions from these tanks are controlled by a Tank combustor(total of 3 combustors for controlling Points 005 and 008). 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 after issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup 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 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)after issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, 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 AIRS ID: 123/9C0F Page 1 of 9 Condensate Tank SM/M Version 2012-1 olo Depa e f bli Health and Environment it Pollution Control Division such construDf RA mme s 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 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 6. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility Tons per Year AIRS Equipment Point NO, VOC CO Emission Type ID Condensate 005 11.4 Point Tank See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits. 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. 7. 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.) AIRS Control Device Pollutants Point Controlled 005 Combustor(total of 3) VOC PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates 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 Equipment Point Process Parameter Annual Limit ID AIRS ID: 123/9COF Page 2 of 9 I: II Depa e f • bli t s it PollutionHealthand Control DivisionEnvironment Er SWat S Condensate ' is n.ensa e roug put 299,382 BBL/yr Tank The owner or operator shall calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. 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) 10. Visible emissions shall not exceed twenty percent(20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.1.c shall have no visible emissions. (Reference: Regulation No. 1,Section II.A.1. &4.) 11. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 12. The combustor covered by this permit is subject to Regulation No. 7, Section XII.C General Provisions (State only enforceable). If a combustion device is used to control emissions of volatile organic compounds to comply with Section XII.D, it shall be enclosed,have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device,or by other means approved by the Division, determine whether it is operating properly. The operator shall comply with all applicable requirements of Section XII. 13. This source is subject to the recordkeeping, monitoring, reporting and emission control requirements of Regulation 7, Section XII. The operator shall comply with all applicable requirements of Section XII. 14. The combustor 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. 15. The condensate storage tanks covered by this permit are subject to Regulation 7, Section XVII emission control requirements. These requirements include, but are not limited to: Section XVII.C. - Emission reduction from condensate storage tanks at oil and gas exploration and production operations, natural gas compressor stations, natural gas drip stations and natural gas processing plants. XVII.C.1. Beginning May 1, 2008, owners or operators of all atmospheric condensate storage tanks with uncontrolled actual emissions of volatile organic compounds equal to or greater than 20 tons per year based on a rolling twelve-month total AIRS ID: 123/9C0F Page 3 of 9 olo Depa e f li Health and Environment it Pollution Control Division sh a co •� men has an average control efficiency of at least 95% for VOCs on such tanks. XVII.C.3. Monitoring: The owner or operator of any condensate storage tank that is required to control volatile organic compound emissions pursuant to this section XVII.C. shall visually inspect or monitor the Air Pollution Control Equipment to ensure that it is operating at least as often as condensate is loaded out from the tank, unless a more frequent inspection or monitoring schedule is followed. In addition, if a flare or other combustion device is used,the owner or operator shall visually inspect the device for visible emissions at least as often as condensate is loaded out from the tank. XVII.C.4. Recordkeeping:The owner or operator of each condensate storage tank shall maintain the following records for a period of five years: XVII.C.4.a. Monthly condensate production from the tank. XVII.C.4.b For any condensate storage tank required to be controlled pursuant to this section XVII.C., the date, time and duration of any period where the air pollution control equipment is not operating.The duration of a period of non-operation shall be from the time that the air pollution control equipment was last observed to be operating until the time the equipment recommences operation. XVII.C.4.c. For tanks where a flare or other combustion device is being used, the date and time of any instances where visible emissions are observed from the device. OPERATING & MAINTENANCE REQUIREMENTS 16. 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.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 17. The owner or operator shall demonstrate compliance with Condition 10, 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.AlI) ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice(APEN)shall be filed: (Reference: Regulation No.3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or AIRS ID: 123/9C0F Page 4 of 9 olor.• Depa e •f bli Health and Environment a ,,, it Pollution Control Division For vo _ -ni • ,•• (V.• • ..troge ±es 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. 19. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit)shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS 20. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 21. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide"final"authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. AIRS ID: 123/9C0F Page 5 of 9 olo Depa e f li Health and Environment it Pollution Control Division 23. Unless specifi D g s onditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 24. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence,this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit,conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit,the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued,the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative,civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Stephanie Chaousy, PE Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Bill Barrett Corporation. Newly permitted condensate tanks at a synthetic minor facility. AIRS ID: 123/9C0F Page 6 of 9 ' 4 Color ' Depa . e Wf x bli "Health and Environment it Pollution Control Division Notes to Permit Holder .: "' e of ` per- <+an 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 maybe revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice(APEN)and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions.The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: http://www.colorado.gov/cs/Satellite?c=Document C&childpagename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&pagename=CBONWrapper 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 Point Pollutant CAS# BIN (Ib/yr) reportable? Rate(Ib/yr) Benzene 71432 A 2220 Yes 111 Toluene 108883 C 2179 Yes 109 Ethylbenzene 100414 C 353 Yes 18 005 Xylenes 1330207 C 670 Yes 33 n-Hexane 110543 C 14089 Yes 705 2,2,4-TMP 540841 C 2218 Yes 111 5) The emission levels contained in this permit are based on the following emission factors: Point 005: Emission Factors Emission Factors CAS# Pollutant Uncontrolled Controlled Source Condensate Condensate Throughput Throughput NOx 0.1381b/mmbtu --- TNRCC CO 0.2755 lb/mmbtu --- TNRCC VOC 0.1818 lb/bbl 0.0091 lb/bbl Engineering Calculation 71432 Benzene 0.0089 Ib/bbl 0.00045 lb/bbl Engineering Calculation 108883 Toluene 0.0073 Ib/bbl 0.00037 lb/bbl Engineering Calculation AIRS ID: 123/9COF Page 7 of 9 • olor Depa e f Ii Health and Environment it Pollution Control Division ' ct issio ors Uncontrolled Controlled CAS# Pollutant Condensate Condensate Source Throughput Throughput 100414 Ethylbenzene 0.0012 lb/bbl 0.00006 lb/bbl Engineering Calculation 1330207 Xylenes 0.0023 lb/bbl 0.00012 lb/bbl Engineering Calculation 110543 n-Hexane 0.057 lb/bbl 0.00285 lb/bbl Engineering Calculation 540841 2,2,4-TMP 0.0074 lb/bbl 0.00037 lb/bbi Engineering Calculation Note: The controlled emissions factors for point 005 are based on the combustor control efficiency of 95%. 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, n-hexane,total HAPS NANSR Synthetic Minor Source of: VOC MACT HH Area Source Requirements: 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 7777—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX AIRS ID: 123/9COF Page 8 of 9 , Color Depa e of rbli"'Health and Environment •it Pollution Control Division _r r � , 9) An Oil and Gas Ind >.:,„ .. tr „� • P....•• m if ",.. Form .• luded with this permit packet. Please use this form to complete the self-certification requirements as specified in the permit conditions. Further guidance on self-certification can be found on our website at: www.colorado.dov/cdphe/oildasperm its AIRS ID: 123/9COF Page 9 of 9 Division Information Engineer: Stephanie Chaousy.PE Control Engineer: Chns Laplente Review Date: 05/07/2014 Application Date: 02/18/2014 BCC Code 40600132:Crude Oil:Submerged Loading(Normal Service) Facility Identifiers Permit No. 14WE0431 County# 123 Weld AIRs Facility# 9COF Point# 006 Section 01: Administrative Information Company Name: Bill Barrett Corporation Source Name: 18492 Hawkins 5-61-21 NWSW Sec.21,T5N,R61 W Source Location: SIC: 1311 Elevation(feet)4666 Portable Source? Portable Source Homebase Mailing Address 1: Bill Barrett Corporation Address Address 2: 1099 18th Street,Suite 2300 City,State Zip: Denver,CO 80202 Name: Wesley Hill Person To Phone: 303-312-8546 Contact Fax: 303-291-0420 Email: whilleibillbarrettcom.com AP-42:Chapter 5.2 Equation 1 L=12.46'5'P-M1T L=loading losses in lb per 1000 gallons loaded S=Saturation Factor P=true vapor pressure of liquid loaded Ipsial M=molecular weight of vapors[lb/lb-mole] T=temperature of bulk liquid loaded[deg.R] 1 degree Fahrenheit=460.67 degree Rankine S 0.6 Submerged loading:dedicated normal service P 5.0032 psia (AP-42 Figure 7.1-13a) M 66 lb/lb-mole (Tanks 4.0.9d) T 512.5 deg.R (Operator's knowledge of annual avg temp.) L 4.82 lb/10A3 gal 2.02E-01 tb/bbl Annual requested Throughput 12574044 gal/yr Annual requested VOC emissions 60568 IbNr 30 28 tpy Regulatory Considerations This facility is not condisdered a terminal(in Reg.7)because average daily throughput will be below 20,000 gallons at 3,956 gallons per day. This facility is not considered a bulk plant(in Reg.7)because it does not disldbute gasoline. NCRPs emissions emission factor lb/1000 Component Mass Frac. (Ib/yr) gal Notes Benzene 0.0052 314.95 0.0250 In order to estimate NCRP emissions,I multiplied the mass fraction n-hexane 0.0347 2101.70 0.1671 of each component considered a non-cnteda reportable by the annual requested VOC emissions for tank loadout.Granted,the mass traction I used is for the liquid rather than the vapor.This is beacuse only the liquid mass fraction is readily available,and developing the vapor mass fractions would be overly arduous.n- Hexane is the only reportable for this point �. ...r., . ,. .,. STATE OF COLORADO OF'COO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT F„ NQ _, AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 »* f/876 CONSTRUCTION PERMIT PERMIT NO: 14WE0431 Issuance 1 DATE ISSUED: ISSUED TO: Bill Barrett Corporation THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the 18492 Hawkins 5-61-21, located in the NWSW of West,21, Township 5 North, Range 61 in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID Condensate 006 Truck loadout of condensate. Emissions from the loadout Loadout are not controlled. 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 after issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup 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 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) after issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, 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 AIRS ID: 123/9COF Page 1 of 7 Condensate Loadout TM Version 2012-1 Co do p e o Pu and Environment Airblic PollutionHealth Control Division 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 retain the permit final authorization letter issued by the Division after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility AIRS Tons per Year Equipment Point VOC Emission Type ID Condensate 006 30.3 Point Loadout See "Notes to Permit Holder for information on emission factors and methods used to calculate limits. 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. PROCESS LIMITATIONS AND RECORDS 6. 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 AIRS Process Parameter Annual Limit Point 006 Condensate Loading 299,382 BBL The owner or operator shall calculate monthly process rates based on the calendar month. AIRS ID: 123/9C0F Page 2 of 7 Co if; p e o Public Health and Environment 11 r Air Pollution Control Division Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 7. This source is located in an ozone non-attainment or attainment-maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation 3, Part B, III.E. 8. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 9. The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.E): a. Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. b. All compartment hatches (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. c. The owner or operator shall inspect loading equipment and operations onsite at the time of inspections to monitor compliance with Condition 9 (a) and (b) above. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. 10. All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. OPERATING & MAINTENANCE REQUIREMENTS 11. This source is not required to follow a Division-approved operating and maintenance plan. COMPLIANCE TESTING AND SAMPLING 12. This source is not required to comply with any testing and sampling requirements. ADDITIONAL REQUIREMENTS 13. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) AIRS ID: 123/9COF Page 3 of 7 Co do p e o Pu and Environment D Airblic PollutionHealth Control Division a. Annually by April 30 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,J 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. 14. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS: 15. 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. 16. 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 AIRS ID: 123/9C0F Page 4 of 7 Co do p e o Public Health and Environment Air Pollution Control Division 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. 17. 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. 18. 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. 19. 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. 20. 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. 21. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Stephanie Chaousy, PE Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Bill Barrett Corporation. Newly permitted truck loadout at a synthetic minor facility. AIRS ID: 123/9COF Page 5 of 7 DCo do p e o Public PollutionHealthand Control DivisionEnvironment Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See: http://www.colorado.aov/cs/Satellite?c=Document C&childoacename=CDPHE- Main°/02FDocument C%2FCBONAddLinkView&cid=1251599389641&paoename=CBONWrapper 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 Point Pollutant CAS# BIN (Ib/yr) reportable? Rate(Ib/yr) n-Hexane 110543 C 2104 YES N/A 006 Benzene 71432 A 317 YES N/A 5) The emission levels contained in this permit are based on the following emission factors: Emission Factors—Uncontrolled CAS Pollutant lb/1000 gal Source loaded VOC 4.82 AP-42 110543 n-hexane 0.1671 Engineering Calculation 71432 Benzene 0.0250 Engineering Calculation The uncontrolled VOC emission factor was calculated using AP-42, Chapter 5.2, Equation 1 (version 1/95) using the following values: L= 12.46*S*P*M/T • S =0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 5.0 psia M (vapor molecular weight)= 66 Ib/Ib-mol T(temperature of liquid loaded)= 512.5°R The uncontrolled non-criteria reportable air pollutant(NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP in the vapors by the VOC emission factor. AIRS ID: 123/9COF Page 6 of 7 • D. Colo do a p, e o Public Health and Environment II : I Air Pollution Control Division 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, n-hexane, total HAPS NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below- http.//ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End 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 SubpartA—SubpartZ MACT 63.600-63.1199 Subpart PA—Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ —Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN —Subpart XXXXXX 9) An Oil and Gas Industry Construction Permit Self-Certification Form is included with this permit packet. Please use this form to complete the self-certification requirements as specified in the permit conditions. Further guidance on self-certification can be found on our website at: www.colorado.gov/cdohe/oilqaspermits AIRS ID: 123/9COF Page 7 of 7 m 2 s m rrvm^m2°^o 0000o0oor a _mo^dm ,0 0 0000000000p a • U a _ c a F ° a0, u m c oa v o 2000 0,00 .0do0or O° o 02 !,-.1-go�om- ai°00000 0,000 0y m a 00S O u w a a i ' a m a - o m o N o o?'?0 0,0 0 °°°°°°°°002: O c ° z ° t- r°oo0oo N 0 000000000000 ° ° E a,-ma y O M x = o n L tl a . a -00000 y2j N O N o o O 0000000 O' 0 0 0 q u a f M2 tl v c N ° zrme-w00NroN000 00000000000m y c a- o aNm0000 00000000000e es 5 am E C U ^a E ` ° a n _ _ S = N m 2.M0- .0-,.N... �0..... .. ..g- Q r p o_ w Q o-O o 0 0 o N d O,e o o00000000000* 0,y A E v a. J - n y 8— d N O n a 5.0 0 0 0 0 0 0 0 0 0 0 0 0 0 o a¢ m a w .°-, D a ,r M o o,p N o N o o O .'o O o o o o O o o o o a E .0 U Z 9 v E E 8) ° L _ 2 0 v °' ° N m w0, - EndoMmo- -o 0000 :0,0000°00000 0000 o0000`� o< ° 2 ° a o g o- N N 0 0 0 6 00 0 0 0 0 o 'o o U LL „ 9 M >LL0, E S v egg R s c 0, - - c a o a `o a N o oi�o d 6 N 0 o w o 0 0 '0 o a 0 0 a o a 0 a o a 0,c 'm co m N a N C U v 204 ° E 0 412i c `a — w c 9 a °' Nr ma °°I a y o o N M o cj n E 0 0 0 0 0 0 0 0 0 o a^ m 0 0 0,'0 U E `<= M oa0000Nmoa000 ..odd0000000d 0, N C ^ r :0== ==060 cEc ; a o ¢c Sa 3 v „ a • A a C C E a F ° -1 u E = a0 000oo0oaoo'u u 000000 2Aom c 0 a 0, T 00NooN000000 .'-'.o ddod00000a a 4`00000 a2 _ wE - C y u i c o` U 0 or Ct' `o n C > 0 c a c cn - N a E w E T o o O O O W O N 0 0 o 10 0 0 0 0 o ro 2 N 0 M N — > - u w 000 0 000 000000000000''n v 0,-, OO°OONOOOOOO 0000000000n 06000000000 d 30000 '00 �9�j � °c a -00000 'u _ dE o m ` 0 c s a 2 0= E d z `a m 2 `w "-o o o o o o o'o o o'o a a S Sm 0 0 -_ _ E � �00000d000000 o.a00000000000o o,dd mdo u � °- - a o a Nr4s - wa 2 v W , 8000googoo999° oq^0oogg000 2 a N c 8600 CCo 2 WWWWWWWWWW www wwww Wowwwww drv2 „Z (0 03 N O2 aomo 0000 00000 E ca aN »' 0 • C 012028888P8" ?m a a r a r m .-,N N N a s N > >c X L 0,0 m _ Q°L¢ 0, ¢ O N aN rM �mN .Q of s.c — E o_ n o o2z M I m 'N c w2m�wx — `ng o. m M = ° E 'a a 0, 0,y MMNvvMMNN 002 22rev2Nooa � � � a' coiz— u co ¢ • E W ` � wwwwwwwwwwwww 0000wwowWLU - E2ymo '.- m j2cj LL 000 rvaoo'<v�m0oom `omoo`°rvom' o . ommaoq $ u `om 0 F y 0 2-a m Y 2 N-* M, r-m M N 2 M N m 2 c y Y 9 C `_Q N C o`R' -2 y o ' W — ¢ E9ay a wN m a.0;42,r o a C t .m0 0 0 0 C o ° `C m v n m¢ ¢v m J co 7o� 00o 000000000 coo ¢ NS85 ac? mttoyaaaoa U U m "' a 0,o- -- B o o c_ c a v_ w t - - a'0a oar_ =a - c as w y @ m v a� oa, ' 6002 `0,m ° '-" -` � t° C - 'U _a u 'c „U a _ N 0 C m o a m o a a o °a' aym JUI e o a tl1O a '.: u 0,X U2L'o:c ry O m a m m d m ,o< F¢ .?:< ¢ 'c > =38 O „ u y N`� C y 2 y y w n ` v m y d 5,°' y d v y v 0 f `m O F �n E O a z r c o ct-0 Nr0 tow 2A : : 2 : : Nj ya y� m o U a a' E a o W a > ≥ `o LL a m E o q a—' E `m a F' a F o m y °i a 'o w 0,2=2 y a r a 2 w o , 0 >A0Ou0>a00 o>200c0`,20OEO 3 yo rA �AzaE�N3in" "�3 a > Q Q Q o ^ v Q• 'rn U N ;' v 4 „ m m m 0 a v v Q w - € 0, a rc tt w w ti_ M 2 3 w 2 STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT Fe`` -k AIR POLLUTION CONTROL DIVISION °` TELEPHONE: (303)692-3150 I`tffirel `� 1816 CONSTRUCTION PERMIT PERMIT NO: 14WE0432 Issuance 1 DATE ISSUED: ISSUED TO: Bill Barrett Corporation THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the 18492_Hawkins 5-61-21, located in the SWNW Section 21, 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 Fugitives 007 Equipment leaks (fugitive VOCs) from a natural gas exploration and production facility. 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 after issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup 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 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) after issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, 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 for a period AIRS ID: 123/9C0F Page 1 of 9 Fugitive SM/M Version 2012-2 Depa en Ii Health andControl Environment it Pollution Division of eighteenDolor • (i n to c ction 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 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 6. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility AIRS Tons per Year Equipment ID Point VOC Emission Type Fugitives 007 20.2 Fugitive See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. 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. 7. The operator shall calculate actual emissions from this emissions point based on representative component counts for the facility with the most recent gas analysis, as required in the Compliance Testing and Sampling section of this permit. The operator shall maintain records of the results of component counts and sampling events used to calculate actual emissions and the dates that these counts and events were completed. These records shall be provided to the Division upon request. STATE AND FEDERAL REGULATORY REQUIREMENTS 8. Visible emissions shall not exceed twenty percent(20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.1.c shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. &4.) 9. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) AIRS ID: 123/9C0F Page 2 of 9 ID olor Depa € en`of di Health and Environment i• Control Division : rP0lhUJti0n 10. This source i n. o T. A, I *? >. 7 & , - XII.C,+� -ral Provisions (State only enforceable). All condensate collection, storage, processing and handling operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. The operator shall comply with all applicable requirements of Section XII. 11. Minor sources in designated nonattainment or attainment/maintenance areas that are otherwise not exempt pursuant to Section II.D. of Regulation No. 3, Part B, shall apply Reasonably Available Control Technology for the pollutants for which the area is nonattainment or attainment/maintenance (Reference: Regulation No. 3, Part B, III.D.2.a). The Directed Inspection & Maintenance (DI&M), detailed in Condition No. 12, shall satisfy the requirement to apply Reasonably Available Control Technology (RACT). 12. Pursuant to Regulation No. 3, Part B, III.D.2.a, the permittee shall satisfy Reasonably Available Control Technology requirements for this source by using the following inspection and maintenance procedure. Revisions to this proposed plan shall be submitted to the Division for approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.): 1) Operator shall conduct Audio, Visual, and Olfactory inspections (AVOs) on a semi-annual basis of all pumps, valves, connectors, and pressure relief devices at this source. 2) Components with readily detectable leaks using AVO inspections shall be repaired within five days, but no later than 15 days. Repaired components shall be re-screened within five days of repair to determine if the leak is repaired. If the rescreening shows that the leak was not repaired then another attempt to repair the leak shall be made as soon as possible, but no later than 15 days. The process shall be repeated until the rescreening shows no leak. o If a leak is detected but it is not possible to repair without a process unit shutdown, repair of this equipment shall be performed before the end of the next process unit shutdown. • Records shall be kept to document the delay in repair along with the estimated time the component will be repaired. 3) Leaking components shall be documented along with the date the leak is detected, date the leak is repaired, and date that the leak is rescreened. 4) The following records shall be maintained and kept onsite for two years: o List of equipment screened and associated dates; o List of currently leaking components; o List of repaired components along with the repair method and associated repair dates; o List of successful repairs, repair delays, and post-repair screenings and associated dates. OPERATING & MAINTENANCE REQUIREMENTS 13. This source is not required to follow a Division-approved operating and maintenance plan. AIRS ID: 123/9C0F Page 3 of 9 olor Depa en Ii Health and Environment it Pollution Control Division COMPLIANCE TED Initial Testing Requirements 14. Within one hundred and eighty days (180) after issuance of this permit, the operator shall complete a hard count of components at the source and establish the number of components that are operated in "heavy liquid service", "light liquid service", "water/oil service" and "gas service". The operator shall submit the results to the Division as part of the self-certification process to ensure compliance with emissions limits. Periodic Testing Requirements 15. On an annual basis, the owner or operator shall complete an extended gas analysis of gas samples that are representative of volatile organic compounds (VOC) and hazardous air pollutants (HAP) that may be released as fugitive emissions. This extended gas analysis shall be used in the compliance demonstration as required in the Emission Limits and Records section of this permit. ADDITIONAL REQUIREMENTS 16. 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. 17. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall AIRS ID: 123/9COF Page 4 of 9 • olor c$ Depa, en if v.li ^.°Health and Environment it Pollution Control Division not exceed th 4 ,fl l . ,e r„- + of- ermit N , anted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS: 18. 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. 19. 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. 20. 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. 21. 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. 22. 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. 23. 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. 24. 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. AIRS ID: 123/9C0F Page 5 of 9 olor Depa en Ii Health and Environment it Pollution Control Division By: Stephanie Chaousy, PE Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Bill Barrett Corporation. Newly permitted fugitive emissions at synthetic minor facility. AIRS ID: 123/9C0F Page 6 of 9 olor Depa en - ' :•Ii '-Health and Environment it Pollution Control Division Notes to Permit Holder - ' me o e a 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 emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day,followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See: http://www.colorado.gov/cs/Satellite?c=Document C&childpagename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&pagename=CBONWrapper 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 Controlled Emission Are the Emission AIRS Rate emissions Rate Point Pollutant CAS# BIN (Ib/yr) reportable? (Ib/yr) Benzene 71432 A 138 No 138 Toluene 108883 C 282 No 282 007 Ethylbenzene 100414 C 122 No 122 Xylenes 1330207 C 281 No 281 n-Hexane 110543 C 983 Yes 983 5) The emission levels contained in this permit are based on the following emission factors: Wil Component Gas Service Heavy Oil Light Oil Service Connectors 3535 0 917 0 Flanges 8 0 2 0 Open-ended Lines 6 0 2 0 Pump Seals 0 0 0 0 Valves 459 0 339 0 Other* 10 0 0 0 VOC Content(wt. 0.2975 0 1 0 fraction) Benzene Content(wt. 0.00040 0 0.0052 0 fraction) . Toluene Content(wt. 0.00027 0 0.012 0 fraction) Ethylbenzene (wt. 0 0 0.0055 0 fraction) Xylenes Content(wt. 0 0 0.0127 0 AIRS ID: 123/9C0F Page 7 of 9 olor Depa en li Health and Environment it Pollution Control Division fraction) n-hexane Content(wt. 0.0035 0 0.0347 0 fraction) *Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms, drains, dump arms, hatches, instrument meters, polish rods and vents TOC Emission Factors(kg/hr-component): Component Gas Service Heavy Oil Light Oil Water/Oil Service Connectors 2.0E-04 7.5E-06 2.1E-04 1.1E-04 Flanges 3.9E-04 3.9E-07 1.1E-04 2.9E-06 Open-ended Lines 2.0E-03 1.4E-04 1.4E-03 2.5E-04 Pump Seals 2.4E-03 NA 1.3E-02 2.4E-05 Valves 4.5E-03 8.4E-06 2.5E-03 9.8E-05 Other 8.8E-03 3.2E-05 7.5E-03 1.4E-02 Source: EPA-453/R95-017 Compliance with emissions limits in this permit will be demonstrated by using the TOC emission factors listed in the table above with representative component counts, multiplied by the VOC content from the most recent gas analysis. 6) In accordance with C.R.S. 25,7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, n-hexane, total HAPS NANSR Synthetic Minor Source of: VOC MACT HH Area Source Requirements: Not Applicable/ NSPS OOOO 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 AIRS ID: 123/9COF Page 8 of 9 olor Depa en . •. •liHealth and Environment 1 . *. �' _.. it Pollution Control Division x n�ti as Part 63: National ' fon -r az- • ' Poll ' . ''" for Source Categories MACT 63.1-63.599 Subpart A—Subpart Z MACT 63.600-63.1199 Subpart PA—Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX 9) An Oil and Gas Industry Construction Permit Self-Certification Form is included with this permit packet. Please use this form to complete the self-certification requirements as specified in the permit conditions. Further guidance on self-certification can be found on our website at: www colorado.gov/cdphe/oiloasoermits AIRS ID: 12319C0F Page 9 of 9 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Bill Barrett Corporation Permit Number: 14W0433 18492 Hawkins 5-61-21 Source Location: NWSW Section 21,T5N, R61 W, Weld County (non-attainment) Equipment Description: Produced water tanks AIRS ID: 123-9C0F-008 Date: May 7, 2014 Review Engineer: Stephanie Chaousy, PE Control Engineer Chris Laplante Section 2—Action Completed Grandfathered Modification APEN Required/Permit Exempt X CP1 Transfer of Ownership APEN Exempt/Pemiit Exempt Section 3—Applicant Completeness Review Was the correct APEN submitted for this source type? X Yes No Is the APEN signed with an original signature? X Yes No Was the APEN filled out completely? X Yes No Did the applicant submit all required paperwork? X Yes No Did the applicant provide ample information to determine emission rates? X Yes No If you answered "no" to any of the above, when did you mail an Information Request letter to the source? February 18, 2014. Updated APEN On what date was this application complete? received 5/29/14. Section 4—Source Description AIRS Point Equipment Description 008 Two (2) above ground 400 bbl atmospheric produced water storage tanks. Emissions from these tanks are controlled by a combustor(3 total). Are "flash" emissions anticipated from these tanks? X Yes No Is this tank located at an E&P site? X Yes No Is this tank located at a non-E&P, midstream or Yes X No downstream site? Is this a portable source? Yes X No Is this location in a non-attainment area for any criteria X Yes No pollutant? If"yes", for what pollutant? PM,() CO X Ozone 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 PM:0 CO Ozone RACT per Regulation 3, Part B, Section III.D.2) Page 1 Is this source claiming exempt status for this source based on the fraction of oil in the stored water(less than 1% by volume crude oil on an average annual Yes X No basis)? Are these produced water tanks located at a commercial facility that accepts oil production Yes X No wastewater for processing? Are these produced water tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)805 Yes X No Rule? Section 5—Emission Estimate Information AIRS Point Emission Factor Source 008 CDPHE Produced Water Storage Tank Emission Factors; CDPHE Memo 09-02 Did the applicant provide actual process data for the emission inventory? X Yes No Basis for Potential to Emit(PTEI AIRS Point Process Consumption/Throughput/Production 008 146,267 BBL per year(121,889 z 1.2)wastewater Basis for Actual Emissions Reported During this APEN (Reported to Inventory) AIRS Point Process Consumption/Throughput/Production Data Year 008 121,889 BBL per year wastewater 2013 Basis for Permitted Emissions(Permit Limits) AIRS Point Process Consumption/Throughput/Production 008 146,267 BBL per year Does this source use a control device? X Yes No AIRS Point Process Control Device Description °k Reduction Granted 008 0l Combustor(3 total) 95 Section 6—Emission Summary(tons per rear) Point NOa VOC CO Single HAP Total HAP PTE: 008 - 19.2 - 1.6 2.1 (Hexane) Uncontrolled point 008 - 16.0 - 1.3 1.8 source emission rate: (Hexane) Controlled point 008 - 0.8 --- 0.07 0.09 source emission rate: (Hexane) Section 7—Non-Criteria/Hazardous Air Pollutants Uncontrolled as Ma Controlled Emission Pollutant CAS# BIN Emission Rate a tlbtyri ',portable?ble? Rate(lb/yr) Benzene 71432 A 1024 Yes 51 n-Hexane 110543 C 3218 Yes 161 Note: Regulation 3, Part A, Section II.B.3.b APEN emission reporting requirements for non-criteria air pollutants are based on actual emissions without credit for reductions achieved by control devices used by the operator. • Page 2 Section 8—Testing Requirements Will testing be required to show compliance with any emission rate or regulatory Yes X No standard? 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 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? 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)? Yes X No For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)? total X Yes No facility 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 008 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, 1992)) in all subsections of Section II. A and B of this regulation. 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 008 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 Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for: 008 each individual emission point in a non-attainment area with uncontrolled actual emissions of one ton per year or more of any individual criteria pollutant (pollutants are not summed) for which the area is non-attainment. (Applicant is required to file an APEN since emissions exceed 1 ton per year VOC) • Part B—Construction Permit Exemptions 008 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.2.a) Regulation 6- New Source Performance Standards 008 None Page 3 $eaulation 7—Volatile Qcaanio.Comnound& 008 None Reputation 8-Hazardous Air Pollutants 008 None Section 13—Aerometric Information Retrieval System Coding Information Point Process Process Description Emission Pollutant/ Fugitive Emission Factor Control Factor CAS# (Y/N) Source (%) 6.2381 CDPHE PS 95 lb/1000 gal VOC No Memo 09-02 01 Produced Water Storage 0.1667 Benzene No CDPHE PS 95 008 Tanks lb/1000 gal Memo 09-02 0.5238 n-Hexane No CDPHE PS 95 lb/1000 gal Memo 09-02 SCC 40400315—Fixed Roof Tank, Produced Water,working+breathing+flashing losses Section 14—Miscellaneous Application Notes AIRS Point 008 Produced Water Storage Tanks A permit will be issued because the uncontrolled VOC emissions are greater than 2 TPY(permit threshold). State-Developed Emission factors in lb/1000 gal are: Produced Water Tank Default County Emission Factors(lb/1000 gal) VOC Benzene n-Hexane Ada der„Btwtrr(etd,Denver 6.2381 01667: 4 8 Garfield, Mesa, Rio Blanco and Moffat 4.2381 0.0952 0.2381 Remainder of Colorado 6.2381 0.1667 0.5238 Page 4 STATE OF COLORADO .ix .. :.. p6.Cpzo COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT Stets, AIR POLLUTION CONTROL DIVISION TELEPHONE: (303)692-3150 .k4„,,,ta'» •1876• CONSTRUCTION PERMIT PERMIT NO: 14WE0433 Issuance 1 DATE ISSUED: ISSUED TO: Bill Barrett Corporation THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the 18492_Hawkins 5-61-21, located in the NWSW of Section 21, Township 5 North, Range 61 West, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID Produced Two (2) 400 BBL fixed roof storage tanks used to store produced Water 008 water. Emissions from these tanks are controlled by a combustor Tank (total of 3 combustors for controlling Points 005 and 008). 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 sect),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 after issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup 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 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)after issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180'days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, 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 AIRS ID: 123/9C0F Page 1 of 8 Produced Water Tank SM/M Version 2012-1 oio Depa e f li Health and Environment it Pollution Control Division associated wit i • i e ion f riod 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 retain the permit final authorization letter issued by the Division, after completion of self-certification,with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility AIRS Tons per Year Emission Type Equipment ID Point NO, VOC CO Produced 008 0.5 Point Water Tank See'Notes to Permit Holder for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 6. 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 Produced 008 Combustor(total of 3) VOC Water Tank PROCESS LIMITATIONS AND RECORDS 7. This source shall be limited to the following processing rate as listed below.Annual 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 S Equipment Pant Process Parameter Annual Limit ID Produced Water 008 Produced water throughput 72,820 BBL/yr Tank AIRS ID: 123/9C0F Page 2 of 8 olor.:}, Depa e 3 .f ' bli `Health and Environment A , Y it Pollution Control Division The owner or *..C. h. cal;-„ •nt e ' •r-p s rat 1r ed on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months'data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 8. Records shall be kept in either an electronic file or hard copy provided that they can be promptly supplied to the Division upon request. All records shall be retained for a consecutive period of three years. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. 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) 10. 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 XVIl.B.1.c shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. &4.) 11. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 12. Minor sources in designated nonattainment or attainment/maintenance areas that are otherwise not exempt pursuant to Section II.D. of Regulation No. 3, Part B, shall apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is nonattainment or attainment/maintenance. This source shall meet the requirements to apply RACT and reduce emissions by installing and operating combustors(Reference: Regulation No. 3, Part B, III.D.2.a). OPERATING & MAINTENANCE REQUIREMENTS 13. Combustors shall be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustor,or by other convenient means approved by the Division, determine whether the combustor is operating properly. 14. If a control device is used to comply with the emission limits of this permit, the following conditions must be met: a. Leakage of VOCs to the atmosphere must be minimized as follows: (i) Thief hatch seals shall be inspected for integrity annually and replaced as necessary. Thief hatch covers shall be weighted and properly seated. (ii) Pressure relief valves (PRV) shall be inspected for proper operation annually and replaced as necessary. PRVs shall be set to release at a pressure that will ensure flashing, working and breathing losses are routed to the control device under normal operating conditions. (iii) Annual inspections of thief hatches and PRV shall be documented with an indication of status, a description of any problems found, and their corrective action. AIRS ID: 123/9COF Page 3 of 8 olo Depa e f bli Health and Environment it Pollution Control Division 15. Control devic a ig perat d maintained according to D manufacturer specifications to achieve a control efficiency of at least 95%, and to handle reasonably foreseeable fluctuations in emissions of VOCs. Fluctuations in emissions that occur when the separator dumps into the tank are reasonably foreseeable. 16. The owner or operator shall monitor and document the proper operation of the control device. Time intervals between monitoring shall not exceed 14 days. Indications of improper operation for a flare include, but are not limited to, absence of pilot light, malfunction of electronic ignition, and/or presence of smoke. A check box is suitable for recording proper operation. Improper operation of a control device shall be further documented with a description of the problem and its corrective action, the date range the control was inoperable, and the produced water production through the battery during the downtime. If the owner or operator cannot document the date that the control equipment became inoperable then downtime shall be assumed to have started directly after the last documented monitoring event. During control device downtime, emissions shall be considered to be uncontrolled. COMPLIANCE TESTING AND SAMPLING 17. No compliance requirements under this section. ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice(APEN)shall be filed: (Reference: Regulation No.3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5)tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than one hundred 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. 19. Federal regulatory program requirements(i.e. PSD, NANSR or Title V Operating Permit)shall apply to this source at any such time that this source becomes major solely by virtue of a AIRS ID: 123/9COF Page 4 of 8 . . a 1III Color P,, Depat e of bli'Health and Environment i ' A it Pollution Control Division �Ls Y � e relaxation in al.. ii -. ,a c+* ,+ +n A../... ela ,± k 3a",. incre : the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS 20. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 21. If this permit specifically states that final authorization has been granted,then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide"final"authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 23. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 24. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. AIRS ID: 123/9COF Page 5 of 8 Itolor Depa e f bli Health and Environment it Pollution Control Division By: Stephanie Chaousy, PE Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Bill Barrett Corporation. Newly permitted produced water tanks at a synthetic minor facility. AIRS ID: 123/9C0F Page 6 of 8 Color Depa e f bli Health and Environment it Pollution Control Division Notes to Permit Holder a of er an . 1) The permit holder is required to pay fees for the processing time for this permit.An invoice for these fees will be issued after the permit is issued.The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit(Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice(APEN)and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions.The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: http://www.colorado.gov/es/Satellite?c=Document C&childpaciename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&pagename=CBONWrapper 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 Point Pollutant CAS# BIN (Ib/yr) reportable? Rate(Ib/yr) Benzene 71432 A 1024 Yes 51 008 n-Hexane 110543 C 3218 Yes 161 5) The emission levels contained in this permit are based on the following emission factors. Point 008: Emission Factors Emission Factors CAS# Pollutant Uncontrolled Controlled Source lb/BBL Produced lb/BBL Produced Water Throughput Water Throughput VOC 0.262 0.0131 Source 110543 n-Hexane 0.022 0.0011 Source 71432 Benzene 0.007 0.0004 Source Note: The controlled emissions factors for point 008 are based on the flare control efficiency of 95%. 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: AIRS ID: 123/9COF Page 7 of 8 olor Depa e f bli it PoHealthllutionand ControlEnvironment Division Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, n-hexane,total HAPS NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40,Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfrapoaccess.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 SubpartA—SubpartZ 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 7777-Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXX( 9) An Oil and Gas Industry Construction Permit Self-Certification Form is included with this permit packet. Please use this form to complete the self-certification requirements as specified in the permit conditions. Further guidance on self-certification can be found on our website at: www.colorado.qov/cdphe/oilgasperm its AIRS ID: 123/9COF Page 8 of 8 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Bill Barrett Corporation Permit Number: 14WE0880 Source Location: 18492 Hawkins 05-61-21 NWSW Section 21,T5N, R61 W, Weld County (non-attainment) Description Heated flash gas separators/ECDs AIRS ID: 123-9C0F-010 Date: June 17, 2014 Review Engineer: Stephanie Chaousy 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? X Yes No If you answered "no" to any of the above, when did you mail an Information Request letter to the source? May 29, 2014. BBC provided revised On what date was this application complete? calculations/APEN via email on 7/2/14. Received revised calculations via email on 7/9/14. Section 4—Source Description AIRS Point Equipment Description 010 Heated flash gas separators and enclosed combustion device (ECD)for flashing and combusting vapors from liquid stream. 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? PM1p CO X Ozone 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 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) Page 1 Section 5—Emission Estimate Information AIRS Point Emission Factor Source . 010 Site-specific using Promax(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(PTEI AIRS Point Process Consumption/Throughput/Production 010 299,382 bbl per year Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory) AIRS Point Process Consumption/Throughput/Production Data Year 010 299,382 bbl per year 2014 Basis for Permitted Emissions(Permit Limits) AIRS Point Process Consumption/Throughput/Production 010 299,382 bbl per year Does this source use a control device? X Yes No AIRS Point Process Control Device Description %Reduction Granted 010 of Vapor recovery unit(VRU) 90 010 oz Enclosed combustor(for backup) 95 Section 6—Emission Summary (tons per year) Point NOa VOC CO SOx PM10 Single Total HAP HAP PTE: 010 0.8 286.9 4.3 -- 7.6 (n-hexane) 11.3 Uncontrolled point 010 0.8 286.9 4.3 — 7.6 11.3 source emission rate: (n-hexane) Controlled point 010 0.8 14.3 4.3 - ___ 0.4 (n- 0.6 source emission rate: - hexane) Section 7—Non-Criteria/Hazardous Air Pollutants Uncontrolled Ate the Controlled Emission Pollutant CAS# BIN Emission Rate awn-alone (ibh'r) reportable? Rate(Ibryr) Benzene 71432 A 2405 Yes 120 Toluene 108883 C 1995 Yes 100 Ethylbenzene 100414 C 339 No 17 Xylenes 1130207 C 661 No • 33 n-Hexane 110543 C 15271 Yes 764 2,2,4-Trimethylpentane 540841 C 2018 Yes 101 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 Page 2 AIRS Point Process Pollutant Regulatory Basis Test Method 010 01 VOC, State only requirement Site-specific gas HAPS analysis 010 ai Opacity Regulation No. 1, Section II.A.5 EPA Method 9 Section 9—Source Classification 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? VOC For Reg. 3, Part B, III.C.1.a (emissions increase > 25/50 tpy)?Total X Yes No facility modification For Reg. 3, Part B, III.C.1.c.iii (subject to MACT)? Yes X No For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)? 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? NOx emissions are less than 40 TPY. 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 010 A(July, 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. Requlation 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 010 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 •FK7.PP.Rnlf5 PBD:a...;'; n,....._.. ..` S is Part A-APEN Requirements Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for: 010 each individual emission point in a non-attainment area with uncontrolled actual emissions of one ton per year or more of any individual criteria pollutant(pollutants are not summed) for which the area is non-attainment. (Applicant is required to file an APEN since emissions exceed 1 ton per year VOC) Part B—Construction Permit Exemptions 010 Applicant is required to obtain a permit since uncontrolled VOC emissions from this facility are greater than the 2.0 TPY threshold iReg 3, Part B, Section II D 2 a) f rrty._ ,�rx,roe Pecfarsnat =k k 3 , , 010 None .,k.,.. _.._ °sR�iutation7-�VotatdeOmanici 010 None R " n ardou&Air'P 010 None Section 13—Aerometric Information Retrieval System Coding Information Point Process Process Description Emission Pollutant/ Fugitive Emission Factor Control Factor CAS# (YIN) Source (%) 45.6289 Engineering lb/1000 gal VOC No Calculation 95 0.068 NOx No AP-42, NA Ib/MMBtu Table 13.5-1 0.37 AP-42, lb/MMBtu CO No Table 13.5-1 NA 0.1912 Engineering lb/1000 gal Benzene No Calculation 95 01 Flare 0.1587 Toluene No Engineering 95 010 lb/1000 gal Calculation 0.0269 Ethlybenzene No Engineering 95 lb/1000 galCalculation 0.0526 Engineering lb/1000 gal Xylenes No Calculation 95 1.2145 n-hexane No Engineering 95 lb/1000 gal Calculation 0.1605 2 2 4-TMP No Engineering 95 lb/1000 gal Calculation SCC 31000205-Flares Page 4 Section 14—Miscellaneous Application Notes _ AIRS Point 010 Heated flash gas separator Operator used Promax to calculate emissions from the VRT. Promax was calculated with the basis of 1 bpd (barrels per day). It was also calculated that the VRT will have 10%downtime, the rest would be in a • closed loop system. Emissions are therefore 10% of what was calculated in Promax. July 2, 2014: Per last week's discussion, we are requesting to change flash gas process from using the vapor recovery towers(VRTs) to using heated flash gas separators (HFGSs). There will be emissions increases to both the natural gas venting APEN for the HFGSs and to the condensate tank emissions due to a higher separator temperature (130®F) and pressure drop (20 psi) associated with the HFGSs. The condensate tanks will also be controlled with a dedicated VRU that will recycle the tank emissions back to the sales line. We are assuming a 10% downtime on this VRU when the tank emissions are routed to the combustors during downtime events. Attached are the revised APENS for the condensate tanks and natural gas venting(HFGSs). Backup documents including revisions to the emissions calculations, PROMAX model, Form 102 and process description are also included in the attachment I'd appreciate it if you could red line these two existing APENs and revise draft permits 14WE0430 and 14WE0880 to reflect these changes. Throughput of 299382 bbl/yr= 820.22465 bbl/day Revised emissions and emission factors from the 7/2/14 email are calculated as follows: VOC = (0.79851428 Ib/hr)(8760)(820.22465)(0.1)/2000 = 286.87 TPY VOC E.F. = 286.87*2000/299382 = 1.9164 lb/bbl * 1000/42 = 45.6289 lb/1000 gal Benzene= (0.00334686 lb/hr)(8760)(820.22465)(0.1)/2000 = 0.1.202 TPY= 2404.78 lb/yr Benzene E.F. = 2404.78 lb/yr/299382 = 0.0080 lb/bbl * 1000/42 = 0.1912 lb/1000 gal Toluene= (0.00277688 lb/hr)(8760)(820.22465)(0.1)/2000 = 0.9976 TPY= 1995.23 lb/yr Toluene E.F. = 1995.23 lb/yr/299382 = 0.0067 lb/bbl * 1000/42 = 0.1587 lb/1000 gal Ethylbenzene= (0.000471554 lb/hr)(8760)(820.22465)(0.1)/2000 = 0.1694 TPY= 338.82 lb/yr Ethylbenzene E.F. = 338.82 lb/yr/299382 = 0.0011 lb/bbl * 1000/42 = 0.0269 lb/1000 gal Xylenes= (0.000920244 lb/hr)(8760)(820.22465)(0.1)/2000 = 0.3306 TPY= 661.2108 lb/yr Xylenes E.F. = 661.2018 lb/yr/299382 = 0.0022 lb/bbl * 1000/42 = 0.0526 lb/1000 gal n-hexane= (0.0212530 lb/hr)(8760)(820.22465)(0.1)/2000 = 7.635 TPY = 15270.64 lb/yr n-hexane E.F. = 15270.64 lb/yr/299382 = 0.051 lb/bbl * 1000/42 = 1.2145 lb/1000 gal 2,2,4-TMP = (0.00280840 Ib/hr)(8760)(820.22465)(0.1)/2000 = 1.0089 TPY= 2017.88 lb/yr 2,2,4 TMP E.F. = 2017.88 lb/yr/299382 = 0.0067 lb/bbl * 1000/42 = 0.1605 lb/1000 gal I emailed the operator on 7/8/14 regarding the other HAPS. Only benzene and n-hexane are listed on the APEN and I believe all the HAPS should be listed on the APEN as well as a non-reportable APEN form for 2,2,4-TMP. Page 5 STATE OF COLORADO naF.Cp� COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT ��'- AIR POLLUTION CONTROL DIVISION �� N TELEPHONE:(303)692-3150 +�� tfg76 CONSTRUCTION PERMIT PERMIT NO: 14WE0880 Issuance 1 DATE ISSUED: ISSUED TO: Bill Barrett Corporation THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the 18492 Hawkins 05-61-21, located in the NWSW of Section 21, Township 5 North, Range 61 West, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment ID Point Description Heated flash gas separators that are controlled by a vapor recovery unit (VRU). The VRU destruction efficiency is Heated flash gas 100% control for 90% of the time (assuming 10% separatorslECDS 01D downtime). For the remaining 10% of the time, emissions are controlled by three combustors with a minimum destruction efficiency of 95%. 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 after issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup 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 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) after issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, 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 AIRS ID: 123/9C0F Page 1 of 8 Wellhead Version 2012-1 DCol D men f Public PollutionHealthand ControlEnvironment Division 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 for all permitted equipment except fugitive emissions from equipment leaks shall be provided to the Division within fifteen (15) days after issuance of 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) Annual Limits: Facility Equipment AIRS Tons per Year Emission ID Point NO, VOC CO Type Heated flash gas 010 --- 14.3 4.3 Point separators/ECDS See "Notes to Permit Holder#4"for information on emission factors and methods used to calculate limits. 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. 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 Control Device Pollutants Equipment ID Point Controlled AIRS ID: 123/9C0F Page 2 of 8 3 d y}M'ess. v"9 Colet. D „ men .f Public Health and Environment Air Pollution Control Division Heated flash gas 010 Vapor recovery unit (VRU) and an enclosed VOC, HAPS separators/ECDS combustor for backup PROCESS LIMITATIONS AND RECORDS 9. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the throughput 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 Equipment AIRS Process Parameter Annual Limit ID Point Heated flash gas 001 Condensate throughput 229,382 BBL/yr separators/ECDs The owner or operator shall calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and AIRS ID number shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 11. 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. (Reference: Regulation No. 1, Section II.A.1. &4.) 12. 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. (Reference: Regulation No. 1, Section II.A.5.) 13. These sources are subject to the odor requirements of Regulation No. 2. (State only enforceable) OPERATING & MAINTENANCE REQUIREMENTS 14. Upon startup of these points,the applicant shall follow the 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.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements AIRS ID: 123/9COF Page 3 of 8 Col D men f Public Health and Environment Air Pollution Control Division 15. The operator shall complete an initial site specific extended gas analysis of the natural gas produced at this site in order to verify the VOC, benzene,toluene,ethylbenzene,xylenes, n- hexane,and 2,2,4-trimethylpentane content(weight fraction)of this emission stream used in the permit application. Results of testing shall be used to determine site-specific emission factors using Division approved methods. Results of site-specific sampling and analysis shall be submitted to the Division as part of the self-certification and used to demonstrate compliance with the emissions factors chosen for this emissions point. 16. The owner or operator shall demonstrate compliance with Condition 12 using EPA Method 9 to measure opacity from the flare. (Reference: Regulation No. 1, Section II.A.5). Periodic Testing Requirements 17. On an annual basis,the operator shall complete a site specific extended gas analysis of the natural gas produced at this site that is routed to the flare in order to verify the VOC content (weight fraction) of this emission stream used in the permit application. Results of testing shall be used to determine site-specific emission factors using Division approved methods. ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice(APEN)shall be filed: (Reference: Regulation No.3, Part A, 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 (5)tons per year or more, above the level reported on the last APEN; 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. 19. 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). GENERAL TERMS AND CONDITIONS 20. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. AIRS ID: 123/9C0F Page 4 of 8 b . rsCol . D4 a men ii Public Health and Environment Air Pollution Control Division 21. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide"final"authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the 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. 23. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 24. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the 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. 25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Stephanie Chaousy, PE Permit Engineer Permit History Issuance Date Description AIRS ID: 123/9COF Page 5 of 8 Col D men f Public Health and Environment D R Air Pollution Control Division Issuance 1 This Issuance Issued to Bill Barrett Corporation. Newly permitted vapor recovery tower at a synthetic minor facility. AIRS ID: 123/9C0F Page 6 of 8 } Col itlsj c. D t men•f Public Health and Environment Air Pollution Control Division Notes to Permit Holder 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 permittee 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 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 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.colorado.gov/cs/Satellite?c=Document C&childpaciename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&pagename=CBONWrapper 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 Point Pollutant CAS# BIN (Ib/yr) reportable? Rate(Ib/yr) Benzene 71432 A 2405 Yes 120 Toluene 108883 C 1995 Yes 100 Ethylbenzene 100414 C 339 No 17 010 Xylenes 1130207 C 661 No 33 n-Hexane 110543 C 15271 Yes 764 2,2,4- 540841 C 2018 Yes 101 Trim ethylpentane 5) The emission levels contained in this permit are based on the following emission factors: Point 010: Emission Factors Emission Factors CAS# Pollutant Uncontrolled Controlled Source NOx 0.068 lb/MMBtu 0.068 lb/MMBtu AP-42, Table 13.5-1 CO 0.37 Ib/MMBtu 0.37 lb/MMBtu AP-42, Table 13.5-1 VOC 45.6289a11 b/1000 Promax 2.2814 lb/1000 gal 71432 Benzene 0.1912 lb/1000 gal 0.0096 lb/1000 gal Promax 108883 Toluene 0.1587 lb/1000 gal 0.0079 lb/1000 gal Promax 100414 Ethylbenzene 0.0269 lb/1000 gal 0.0013 lb/1000 gal Promax 1330207 Xylenes 0.0526 lb/1000 gal 0.0026 lb/1000 gal Promax 110543 n-hexane 1.2145 lb/1000 gal 0.0607 lb/1000 gal Promax 540841 2,2,4-TMP 0.1605 lb/1000 gal 0.0080 lb/1000 gal Promax AIRS ID: 123/9COF Page 7 of 8 D Col D men f Public lt Air PollutionHeahand Control DivisionEnvironment Note: The controlled emissions factors for point 010 are based on the enclosed combustor control efficiency of 95%.These emission factors were developed using a pressurized liquids analysis from the Hawkins 5-61-3340 BH well sampled on January 14, 2014. 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, n-hexane,total HAPS NANSR Synthetic Minor Source of: VOC MACT HH Area Source Requirements: 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 DOD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY MACT 63.6580-63.8830 Subpart 7777—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX 9) An Oil and Gas Industry Construction Permit Self-Certification Form is included with this permit packet. Please use this form to complete the self-certification requirements as specified in the permit conditions. Further guidance on self-certification can be found on our website at: www.colorado.qov/cdphe/oilgaspermits AIRS ID: 123/9C0F Page 8 of 8 Air Pollutant Emission Notice (APEN)—and—Application for Construction Permit ' OIL AND GAS EXPLORATION AND PRODUCTION CONDENSATE STORAGE TANK BATTERY,% Current Status(Check all that apply) Reason for APEN Submittal(Check all that apply) T 9 91 AIRS ID#: 12.3- 9 C D F- oO5 ❑ APEN update only' N New or previously unreported battery El Modification to existing source" ," ❑ Previously grandfathered battery' ❑ Registration for coverage under general permit no. GP01 _ _ N Synthetic minor facility &cancellation request for individual permits: N Located in the S-hr Ozone Control Areal N Application for or Modification of an individual permit ❑ Registered under general permit no. GPOI ❑ Administrative permit amendment' E Permitted under individual permit: I'1 wa 0 93 0 ❑ Other: For individual permit applications,check if you want': ❑A copy of the preliminary analysis conducted by the Division N To review a draft of the permit prior to issuance Company Names: Bill Barrett Corporation OGCC Operator#: 10071 Mailing Address': 1099 18'h St., Suite 2300 City: Denver State: CO Zip: 80202 E-mail: whill@billbarrettcorp.com Contact Name: Wesley Hill Phone: (303)312-8546 Fax: (303)291-0420 Tank Battery Name10: 18492 Hawkins 5-61-21 Number of tanks: 6 Location" (QQ Sec.Twp.Range.): NWSW Sec.21,T5N,R61 W County: Weld Total tank capacity[bbl]: 2,400 Calendar year for which"Actual" data applies1s: 2014 Year(s)tank(s)were placed in service": 2014 I Control Description14: (3)Combustors Control Efficiency's: 95% Condensate Throughput16 [bbl/year]. Requested': 299,382 Maximum for PTE calculation": 299,382 Actual": 249,485 While Controls Operational20 249,485 Other equipment at facility21: Comments: APEN submitted to cover new facility.(2)Produced Water Storage Tanks,Tank Truck Loadout,Fugitives,(3)Engines Estimated emissions at throughputs listed above. Use N/A for requested throughput/emission values unless requesting an individual permit , ❑Check if the Division is to calculate emissions. N Check if site-specific emission factors provided to calculate emissions22. Emission Factor Battery Requested Emissions" Actual Emissions" Pollutant23 [lb/bbl] PTE24 Uncontrolled25 Controlled26 Uncontrolled Controlled VOC[tons/year] •=0:37 1, ))3,2 3srt 11.4 & (Eli 3—sr `i,' -- NOx[tons/year] CO[tons/year] Benzene[lbs/year] t:00T50,oci4II ,L0'I 412.4 133,7 22.43- 4 &o368a- 111 -1-8 4- n-Hexane[Ibs/year] 0,009600 dS Ib'ID4 i 8 7 "I1ySrf-M439 ttijitr 7,1406A- 4e4:54-2032' Wells serviced by this tank or tank battery" , API#: 05-123-37756 Name: Hawkins 5-61-21-3340BH N Newly Reported Well API#: 05-123-37755 Name: Hawkins 5-61-21-4841BH N Newly Reported Well API#: 05-123-37750 Name: Hawkins 5-61-21-4956BH N Newly Reported Well API#: 05-123-37751 Name: Hawkins 5-61-21-6457BH N Newly Reported Well API//: 05-123-38211 Name Kunsemiller 5-61-21-0108BH N Newly Reported Well API 1/: 05-123-38212 Name Kunsemiller 5-61-21-1609BH N Newly Reported Well API#: 05-123-38224 Name: Kunsemiller 5-61-21-1724BH N Newly Reported Well API#: 05-123-38223 Name: Kunsemiller 5-61-21-3225BH N Newly Reported Well The signature below indicates that I have knowledge of the facts herein set forth and that the same are true, accurate,and complete to the best of my knowledge and belief. If this is a registration for coverage under general permit GPOI,I further certify that this source is and will be operated in full co pliance with each condition of general permit GPOI. '^� v 05/2f2014 S gnature of Legally Authorized Person(not a vendor or consultant) Date Wesley Hill Air Quality Specialist Type or Print Name of Person Signing Above Official Title Submit this form,along with$152.90 for each Colorado Department of Public Health and Environment For information call: filing of up to 5 tank battery APENS. Include Air Pollution Control Division,APCD-SS-B 1 312186 (303)692-3150 $250 General Permit fee for each new GP 4300 Cherry Creek Drive South Page 1 of 2 18289_Greasewood 8-18H Condensate Storage Tank Battery APEN >cnnn,r A nr>n one I _ 3 T13 as \ @ O -O •2 \ . . o_ ; 2m <• O 2 � / m M CD v / Lu a 3 Z U O %( 2 CO CO . ) U S , N W c i I '0 ❑ q Q = §cn O 22 � ± < .. / .§ m « L % q 33Zw111 I W $ , S - Z a ® i- 2 g • - A \ / / S CO % < & w co o 'e E a _ ® & ! 2 2 a o Z m 5 q / , ' ' ® L Z � � � co o CL _ 4 - ° ± % 2 - E 2 / § CV 2 0 a) � 6 R E E c § , & ca % U = = a ° : 2 $ H • 3 2 2 § = x x x x I CO _ CO _ L1J © ' \ co EEEE i- k ca_ -E E Z E • < o 0 @ � 1 L \ t I I D § f D u I . _ = 0 5 a 3 17 J 4 .§ imi _ .4 _ _ O k \ / \ \ CL \ / ® o o / c \ o c g re f o d a o , a) ■ a , a) ^ 0 0 0 / I a) ' LLI $ E0 w W W w 2 CL % c a a a $ ± p m Ca o , 1- w o $ \ \ $ k 0 � - co E \ f ct ct i i � ft E [ \ ce 7 iri Iu) n O O / 8 O 9 i ? g f �� W - 2 , . a, q O re EL / _ lc) & k \ k -o k ® / / \ ( O # LLI / al $ \ _ @ k 2 — E I- _ ± » o « CC / i1 / j / / 0 - �J � -c rE / e E x . § a) < • f .c / @ Z O k § § k CO / < % O m Z \ � � 72 \ v/ >- _ = a_ § . @To . § c - / / ( ,- r » . f = 9 O > . E 2 O @ E % f § » & � . c 7 � a) : a) o 0 cE 0_c c 6 Q /. \ @ ) CO 2 a O L LL O / ,- \I2 , U y 2 � c 0, • c 4 \0 m 'a o 0 0 0 a E o m '° 0 •a 0 5 5 3� x u `0. = ec_n a >, E Z ° 0 _ m.m en m C J o 0 0 0 5 Cp •0W4,, �"cr4 / w ❑ o Q a Q o q >: i° ai c �' �'e a rz `. ,� m� �' �..�a E c 3 ?' cG v :C) c (a,,40.00 ¢ a, g' L a O a ❑ ❑ ❑ ❑ ❑ W 0 "aaU .> v Zr; c cy r m r ti 0 Ca a c y F > 0 , c .c c o c 'Witt PT- a ^o V co x c a c_ . ° o o o ° n C ? W . a W as C 0" xo - a T c c - .0 ,E 2 2 2 Z2. 'aH .g m 0 .Nn 2 0.J t p oo ei b a� co a a in o �° 'E 014 .= v. u ❑ ® ® ❑ �� x G V c d q tip a .o X C Q' o to as 0 t o5. a o a b 3 E Y x. c ° (4 as o, as oa y a o ro Ca ay y y c c 0 E u te a, 0 r v :a_ L ,., V E c ; w u a� as as v u C.' o N o a s — c _ c+o �, .0 i y, U c s 0 ? >^ >^ T. o c .n E '� E o c°`. c 3 c oo u CD� CID a Lo e. ❑ ❑ u a E 5 E ® ❑ ❑® ❑ E o V7 `• 0 3 ,o. i. En o Ca Z > ^ e° T 0 p m y c`a a C Q In 5 u r' R 0 C Ti .2 c� 3 &i C 0. V T C C on a' x 3 0 .y. Co' NI C L .. L v CD o . a .p o O E u `C O _ .. 4� C O "� T y O T 3 C 0 a! L j 'r R "i Y N a C Q Y C �. fi 11 b/, 0 ., 0 d 3 x E m a `� 0 a Q Q N 4, E 2.2- .. U ao o c.9 o =(�' y D.., E C 00➢ U../ L a a Co 0 a� u P' O td R ° 0. O Q �' L O ..°.. ' `L• O L a V L l n 2 o C y z a. r .. t E W « d T c `-' o y rig `l s U .6 7 c '° m E o o ad c ... c o ' c L P7 E A' 'u C o •E O ' E 3 0 " 6 0 m v - U E .u, _ � A o > m po, � 2 ' El 0 > u c yd C 0. ° a Vo c E. pwp.� a },i .°J. n t d C. d v • Q •o ° m `a E 0 o° y r-. v O F u o • - "a 6 Q We . 10 v '..' P. = o $ ? 5 a T.O of � UdeA w Qrn W a N W ri d 0 '+ Z 0 as in o m y a C p ,g c C . © m m E a' ' v o W s E `c E Ca x a .c u a' 'Q 52 d 0. 8 �„ a ,o .a L ;? I > > U U > > `a e Q u` C' o ,o o .o =. y 9 o d v d d ' .. Y cc m a C � ti E c ai CL ❑ ❑ fL ai O ❑ .°' '^u :, y oM ^^ a 0 C CI E c• V 'O r T C �_ C 4' C i� N b sa. w 2 a "a ® ❑ ❑ ❑ dal o v u t .5 p EFr. m ��(( « W vi ,o c u, _ P. X a. '0; W N O ° � o E 3 Y m a, E 0 E E t 0 a e'+ e a�ca -C100 6° e o 0 o D as -a L 0 N 'C" m0 v .c a a h aCa `c .a in 3 ,a `. 000 6 9 N O > �a O C b0 T 4 N O 4 0 a, 04 F^.F. � 3 .a on ao o w c c Z ca •a' o o E .d c > c T .ti b 0 im N .w eC+ . C O .. a ; C a D y 1/4Rw s 3 e aoo. 0 co E o 0 ce 4 Z 0 ° _ ; i ; .. `a a .. en en co M �v o c '� c c cciu 00 4> -I 144 W a a a o .0 "o `o ti �` 0 a m 44a `� N Q > a> > °.+ �, a' u Q E 0 P c 25 E W " Q w v o E '� U D E 0 v E h c u Q E 0 3 8 - > I1 C.141 U U () O > O >. A O 4M ao > N v eD 0.' �' y U 0 a 9 ? O , N .,-.D \ 4 ,0 t, d N S N °a ai C ur .6 4� W N E, F N t\ 'd - rd ^ C4 N W .°3 E & '� 0 C c 2cn > ≥ y 'v m 7C1 U W o E 3 — -a ^w�{� W y. La) as Z Z a 00 .`" �. m C o a ° a) _ �, O y U Q .0 > C 0 . O O U O x a. N O O > 7 )",Emi it f� o O Li. N F C v, o ° ` o U .8 U O U �• N in U R 7"' O 4-, r 0 o a• cC z r E o w ka ti E w w° c U '- Q a' c 0 - Za, .-1 L C 0 C O O c G N F E y U it' ra W O v c a w a E M a E L Ujd tie .a cmY0 0 _ ado °Lm o la' Ce M 9 c E .0 co cb cn -g .2�'Re - u o, co 0 e5 0 5e.y a > �, _ _ N w W A C a b O O C ww, 0 0 U 00 00 v w .. E m a m 000 r r7 o a .� C4 N 6.a o K a y z4,Z o'o y o j c .E .o .o 'x _ 'c p m E � Ili A E E._N_�- " - C C o c a`d —„Th., o v o c v d "� U 3 N �_ h o p a s .c a .E c a o= - -0 s ≥ o > ^l. LI E c 'y tc„ 3 " O .0 w 00 c 0 m o m •o .p vvv `-a i¢ o ro d L a' ,o L. w - w 7 C d y°J„ ''a V1 U x E 9 O C O ta'> a7 C •D.o s 'E E U x z F O w, 'E as c x a/�� L m a0 n c a 9 a �a U t R 13 00 L >, k6)., O 0 v ^ C o at a' O c ! — w0 Y y `c U u_ co Q cC O.l cNi Vl a > m c C ._ a `� oN ° ° 0"ao m a m a C E 0 6; ° i0 O QI ,- =.1.11-. e C\ u d L ,r N a C N G 'a a E �, E i.. O vi o0 .. 00 N F w N a 10 GC: o A '� i oa ,cui w c 9 c0 ° 0 °= = b m y 9 m a' '3 v a' a ~ •• a .. N " 0 O o 0 .0 0 E O '= .`. s 9 9 OD MI .0 , o .0 - v C.� E c...) aJ C O O °G )ti 'vi O ` N p ,00 0 a L •.O u 0. O 0 E .- .a N• y .- '"a) o A ¢, d ce m v u C7 a N o i c o cy: << <..l -0 ; Z O o L Z .. > ≥ " ^Q]� .E I 2 2 u 9 0 a I a c T a, c °' h j. ?vv>°'., I a "" o W E .°e 4 '`� ads o w o �/. uj c 8 c Q o c .a � � � 0 = �, `° U ,a 0 d > 0 ca• d c cmy = L. g ro E e E o A Y o < m c o 2 .c �a m > a s c.-a w0 Qi tam, -. U (n a u w Z C7 ♦ ♦ ♦ ♦ z c. F 'Z ♦ ¢ cn E-. ♦ a a r -. sa e a o E z s w o o v w w fr e v y.. R p7 1 T 0 ., E $ 6 a C V a yo U mo _v al W W `� W W L v 00 04.V 00 w o 1112E: c c o u t7 � ,.off $'2'a ° ti :'d.ps C oy301 12 -8 E u c x° L at I^ m d 5 y.+, E 5u `oub O y CEL E N '2 E o 1 O. N a 0 R fto' 9; A JF-.. 7 eyRn a,.W o " a e� N u J+ d 6" ' Z m o . c .c g 8 o N 0 c00 ce, .�. o = c A M E o 3 3 ?� o xi ca - pp 0. 0 `6. � y� d O. o m �.I O O U ❑ vi ik O O •• y U. d .R 0 h p °' F ., r o: c m a� yc V1 L mN N 3 I^ y W o o a a • = E w e o E 0 nq h U v R �M <cp , u y o a 5: c v° .o O. E a. s fAi I d G • to U 7 6 z - 0 O N Tr N l-- O, •F,. '..-I c CID 0 c v o ❑ c U c '' 'e el en m i 7 ' V 9 C O 0 0 a O U 5 m U. C0 N O O r % 0-Fa...0 E to CN U E W 'I m � a x ❑ -0 o > as = ° •x <k i. � qz� . GO ❑ y W m ❑ y p w0 CV W ° O ▪ '11111 A U d c a C .au Ez 0. C Qj N O •� O U 0 r4.jil 6 cp,j 'U" .S E T O E CO C d y Ye .R `L a o I^ U F > U E t>. ``� a C .. g m a W w ..R, 0 0 .c O E C 0 N `o .� c W m o Jc a 'm o °° d € g '" 03 es vu ' °'5 c o F y y• c m.. cg al U °� v q .N e e 0 0 U E F. I—I4 x w M y m1. E p 0 '' .3 Z =▪ r 0 '711 Z ,'�1 0 o¢ix, iii 1 E a i 6- v₹� uaF "x ---,1,* 01 .5 ` o y W w .�'. v wY Q w v .„.tr a r *�a PCyy .*A s N. V] a _l '� U O .. tl Chi WY" a4 4 u C CI A F w ia� It m a V .�. F' O U .n .1 t v r a 'a q Z o t, c. _r- a " •-• —ems 0 v 0 __ w m m< Jyr n '° ¢ x W �E_I'," �1 O ,`d o > E wSL7 .yO--�i.. a 'C c " d'* m'� O N 7 -,',Id .7_-. V O F O en •n L r y y .,te ₹ °$k l a+ z o q.c c a v a .7^ c c, �E .o., ° V.,ter "h .' W CO '$ 0 1.°°o. a rl a, O >. °� p v �" ,�-,. a Yi `' a • W o 4: £ ¢9 a- s E 'S o` d fn u •7. U h a e a>i �. '• i t g., ' x r, � H 6 .T. O Pr ,. a3 .. C a o r y G q ? r m < s" co U m v o �2 r x 3 m op ay Q u ca . ! 4. o. A `7 aS > = .t+ G .Lo+ C 55 2 > �t' v- ' 1 w U W > v b 0 v'Fi aL+ ; O .C U O "'i e. U P. - f`r�f� ',.-37,,,,,, I • 5 — in Y w 0 c d v E ¢.c c m 0 .C a s a w a d Boa w N O 0 r o > > u J GO = O N N 0 C ,.= -' O* O. o ! o m 6 l ! 0 o 0 N o o .c v o W ... Ox UO O N ? °_' u ba a u O `°�... c ` e,z .0 m g > cn c4 > E. CI e o Z > U m o . , >( Z '3 - e c c ti e .o. 5 i. tr. 0.. w F s c g q r F o 5 co E 0 ❑ o ® W o y o0 m ti U >• ¢ in • Z. m ° � < Q G O m e 1 '^ a c et w � E 2 d f N� n Sn n c s ° 2 ^ m O d p o. o W U m e o 0 0 ° a U U '� m H > .� .e o. '> w d o .o. en M `� 3 u x q p. G r e 4 E a {G ≥ F o a o o V W tr.. N• L a >, v c = 'G W A L' G q e `o vaa -m L a FW 'a —' e c '- "-' .. d y G 'Oh +- ▪ y '��" pap N W 2 y r°j E G, �• cR y y g E. O W yE .. W ._ °a W eiLP N • e v ,a. d .00' d O m x a 43 re 8 CO c O �o w = ° G G WO tr, _ d q d a .. U F, c a 9 A • o o n a e c o ^' J T T O A v m m 00 g c ^ _° . o C v d. a. W 2 u, p o a a ? 0 0 S d re re ea 6• � o s y d 1 >. 3 ° LWG O c9 >' c e E -r 4e o o y P V L N .. _ d 0 w u 'j N .1 al Q 0.) .8 W E L N C o < i Ea; 0 0 .V. C' a W ,� o Q w E c.. U 3 U N = A x x O O 9 L� ?. W z 9 W O L d y L, y •• v. O O q V] ° O 2 0• a O W ea •c4" O m A L O d o .9 G c W"' c o ' .E C d E 3: u W o o G ° ° g m .o m s U .p ° a .o x ° I O T a L H y O O O A W U L MI A n n a •c d c. C n °" •Wo o v a a U y m .d, - $ Q o > m a ' 2 'E U U 1 3 w O L• .JG O �" d •U L d G 4° O (y. M V p -, t^ w dp y W Ti a Z G E W 9 oil) o E-i a))v !. U II R Fl W 4 an 4 Q. • C p L O an go n 'n 8 T.. :4-) z e4,4 O d U U d T Y '^ I t t cu W 0 O 'f 3 0 3 G O m V p �. N C C Cr C -, 3- • 3 `0 ° 0 o co W e re) iq. ti c a N. N. ❑ ❑ N. R' ❑ ❑ e c Q _Q Q Q 1 x c M P4 a o � � � o x3 0 d d ® ❑ ❑ ❑ 'aaz w d ❑ ❑ El U• at °1 w o _' T O N 0I. C 3 r. 0 0 0 a r+ � L. W G °^ 0 Y 2 Z Z Z C a O N 'J' O 0 W L 6 O N id .� O d 5 X 3 0 .. o.)tag or 2 Q .. ao r.: C at O VI W N H d N .N. d a E Q .M. 3 e a e W S CO m L ^N N 1V N c Nl N Y y ray r'L Z G.\ t NM M v '� a _ O VNi o ..y LA ' ° O CO O M M 3 H ® ❑ ❑ >r 3 O• O o 0.Z U �_.' a U U d 0. N N M 9 R w W d 9 2 n W N a a o E X LL H ° E E re e` a H O G o a .. z e m o m 0) Y > a A :: O ti W o o w T ^ o i1 c :a U y` S N o H PH 0 04 W N 'O Cy,.o `, F0.. fi JJ� O A.13 — 0 N A ry W a N CO^ O E y e e Z or G W ^ U C -I- VNi 0 ,. N ° U] O c up y d ; O O W rl _1 ° A — G M v o v d 40 0 y V' e Y C/] _ w A P- x T p N g M O C„J p' Y. y L. @ (Yi VA m V e rd. 'a `0 2 N o '3 Q ,c a w ^ WoW c o N A c p: U y o O 44 o� Q Z A-44m E a V. .H. '3 - v .. c °3 2 E w U yat. v Y =- a p O e f/J L a. . A T.- W p. W •o cd 4 1 T w a e i° z O �', 2 ° A .a - LO O. `JC 2 ~� es by rTi m L L .. tr.. ., v -- G ti r6 r0 a .''+ a rI-4 co Po sl ?r v m p a GO L ° W p a P .E ', en O Q y .00. G A r a a '�' o w v z' V .a C ^ N v E G L co .- e 08 W d d o G a a /� Py is c a ... oo �o p S co *1 2 u z v rl=1 a '1E) N d C U m C ` C0 O C d h El; 0. L U W m p' U A . d A E .a. «� .a. C.) o O O E L la g 'm 2 VJ O L �L a m a O .� at 'J Si m O.� 7 h o L .. 7 I 2 2 O a .o I y I E G I 3 Z1.4 o v < o ¢ o GI &' 'a $ 3 c '5 .E o 54 p a G. .n is o o rd o r N G W .- • _ _ s 0) ¢ u ... O Vii m v U m 0' W d `o `o .; = ._ — — y d a �, ,� 3. ® W Pr w vn p. rn w 2 Pa 3 s cn a .. :i v) z • o a q 4) C) a C0 ] ' W o Q ¢ Q 6 6 Q a ' o o a a a a a a g a h us 5 a o o .qy W W W W W W y y u m Ts o a- u 0- o E 'F'..' = e c co C m _ O n W 9 u W .. �' '72) •� a T. - o c C V] i m .0 e a w m ° a q b as o cd 4,_ o > P z x a d 'z v o W a o 0 5 CS e A _ S O o E c r y o ❑ > > .m Q u W c n. a .. o .e v e u y O es y emi a ^] a p� a 0.i U.[q N O o 0 0 OA i 0 .d a d q C od0 e 0 C ,0 c V M a gm N_ a e o o a 3 0 ^L, ,0 2 rm/ V] ^� G z « 8 ,a et W L) E.-. E y �p./ t a 0 L. Q u 0 7 Pr'. G N m 0. h a g e o Wi U — >' v. y a 'a a' u ',� Ta, e W 9 •o o t a d 7 o a ,.a O a c 'o t u9 N 0 ,g e n v y e n, vx y o 0 q �. i+ .2 o ❑ ❑ Q d c •>et a u 7 0. ` - o 0 o e o g a a a c' yq � U ti ❑❑ Ewu O• q NNO � O L02 ¢ eYf t• gi ::� g c..) e = V.E 1• 4 y2 0 a 0 L (48 m o � 0t AM 4,7'n,' 'O a o O ^ y b w O 0 ' ?:] w '• ? d'in4 � 7.-. m a .a '� ,'� N 01 +' E ti : 11 y a o `e �`hh �k f Sri o s a I �� o E � y _ e ! ffit7t11 ho O x O W < € Y _ d m e o W p 9 v u 31:1 W G 410 7 5 7y f 4)) Y U S N .0.. 4 u 3 x O C 04 x%T ii.E t t t}j � y u G O Q �l m V rial I. Sore ,= a o o ] t t�tett�rTc U ti M .`C' '° ,z y iii, m = 2 i ,4-4 Y^I.'z# Z w m m 0,r C3 gE u; a ' W g u v r t ns� °{ u r 3 3 12> :5 u 0 N O o o E -„ icy ^ fy ;i'�₹9 r E �•. p y. p ly y N Vl �' y y a 0 V >kd ;;. AT: °' o —4:x'03 m A j C7 w a op.. o T�` "H. t'�f,kj ,`�y} S5�yt V [WI G in p u O C 0 a 4U c x .6 G • _ '+ FC f`S` ' rtn m e O O u W � h2 j u 1,041%;7 �i x. E y 2 G V, A a raj IC y xt : 9 0 V I; - i. o v e g d "C o S I u 9 a -▪ H m > > rx w,, + *ci,¢yo-" ,+x 1 E ii i;. ra q S u.-. a a W g y m v o >0 ° E .C. ? o ',2 In I 5q a o U I a d ►� °cO c z o 'o Ey a .0 o, a Ap • J4 41,T - 0u O a C .7 N o T V 6.-. O Ci L ,LF''fxkk3 LAti,ei Po'E W a: �i a .E e �' •E W : U W` '.�'a�j ' E q _y. a Ems w y a F ,4 w . r «, 2 u a Er c a Zoo o0 m u a u Z' Pi• - I ••' o m aq o o r) T - o, O eNES' Cu'J G �a _a.. y u W, � i C W O § ? E a g 5 o G L. W O a p`3 e`U .O 0 q yo 5 > U. O - o > W H L 'k x' 6 �" O d Tar ay O' 0 0 C. 0 '2 ,$ a c 9® w U w o a > o ® I I i • O v « z N L' Q� v a `o E e y E 0 Q 44 Crl 0 a —>' E z v F .2 ti F a 0 0 0.0.¢6W op t., w o e \, el el ,.`.' V I.� o 0 o a caa b � a e ' 'en o¢ E 3 ^^ v W U p " vi �+ a„ '^ v.`^.. m o 'J N e a 0 'a O > O .1-) N C d 2'2 U � O L N L'+.; v = L O 4+ v a) e x c y w ^ c -.. "C m 0 w 0 a e Lp c o a .p c. 0.1 a c., a c V = .o E q _ o .. c5'v "in m "- W Z 0 N .4i \ . v u E o a R .� .. > 0 N a tc, 0 L pW., O b ev p M d " o o E E a = `w" 0 L MI > c CJ a) L .".. L N o C W c a o T O _o, t « u co o .e F'0 i `� m ^ R▪ .E U H a a s = 0 0 0 0 o 0 E 0 `° 3 © pc, E - a.F; 0 o 3 Ni Cn a c c ❑ ❑ as a 0 w Z z Z Z E 0 w ,L0-. 3 'a a o � n ≥ 3 3 cc v g g L. .e- c � a. 0 0 " ®® ® ❑ wL o w >. c c w W v ICI .�.� 3 . - �7 0 0 E y c.4 y >, 3 .c. E a./0�1. 0. . > w E a « °' v o L .' V aJ L 4J Y ld �. L a = > U F L N CO d `. 'J' S..1 P" `a U a « c. U .", c «'. o t o d ^ w b 4.E s". Z « 0.r 0,m c rg m Cr O o c o z Er, L" >' m 2 ,"o. CC 0 o 0, H a 0, o G N 0 Q 0 0 .E 0 0 I Cl) o a v .. a c o w 0 v v m v 9 = o v d '- om 0 0 0 d o ≥ p Y m o v 7 Y J~ J' o o E « E -- w• 46s. U 0 5 o w 'a� 0 Q e d F. o 7. m 0 2 .La o - o U N E S W " co o (J o c 00 w E• W Ti d' a t U c a m °' .- E a°' ❑❑ ❑ ® :2 a E ° 04 > at; P. ° a " E Q 6� o m o ° >:1 a u H v :. W 4- i U d a = w Q1 a W v u Z ar sa in JIiI ' ' tP ' ! c v�o. 3 �. CO p v, E 0 CG FG ❑ ❑ ai F ❑ ❑ - v c cM 0 _O--. r. O f� a O • o Lo +�- - 2 0 Z W v y,i . 0 ® ❑ d�1 o '^ a U c w .a T v a y a c a' °' N 13 op o o as• 9 [I+ N LR) 0 N U 0 0 0 > ttl 0 00 .ti gb 54 1 v co N N .°). %� ❑❑® a y .00 0. a o .. a e co Nel 9 c 3 U a T E ., a 0 Ti a Q v b es a - " c tn o y>. 0 0 E o v C ti 000 M N .0 U ;3 .0 J C .� O 'ol o i 'd es es 0 W A W v1 o c o U .. .. M 0 0" m a U g - >^ J' en 0 m .. w _I ` 0. �"1 U U v 0.ti• 9 O A O O Q - o C C u .14— .-n i Q - O N O " ; ,..., r„ re. Z 1711 W N E o r 9 c o..o F0+ ®®❑ .E a " E 00 z z . c " N -- " • c� U X 0 N - C - L C U ~ .a a a.. k' N N L O Y L) Y L' O 'O U v�-\{))O L Q. D Q4 T�r F� C U m A 9 0 Vg d rl Z i° 0 0 .o ._ E - ,°_ CO a m e 4m c ..t" tiSde o f y se U m CP v 0. C .. H O O " E 0. o- W C - b C .. a' 'L O m o 7 cr CC .-. N V] EO 5 F 4. N Cp a Z• 2 0 0 G �° > E o v e - NN = `o W 3 ra E ▪ M E" o -O 0 o E - o -'o E da .4 0• �' 7 WL M 0 el O o N ce O G " \° es U C r l y 0 w U 0 0 0 A "43.0 ` Z 1 ftN c a C Ln C O .r 0 O_°�-•Np. __w 0 3- O• 9 4 Lll "o E a N —in ____ m c E y m °o,.ea �; a o E.. W c - " W` c 3 a o o. v :0 c E " ' 0. c 0 o w ,VJ.al = U ? N VI — 7.. .. C O H C O y C, Q Q¢ g 5 -o a0 C 0. N O F W m'«• y O g O N Vl O a C 0 .� 1 Y N c Y •EC. _� C V" u 0 VI _ � G Y Y O Y. C .. n ^- C_ .G O (Po !C W cs V 40 O 3 E O u u Vl .-Y L .. c'Li, es 0 C O c 0 a.4 ^ Q 2 A 3 3 R 0. O ° 5 0 0 O " FQ 00 O c t 'O N - a• N ¢ N C ,- 0^ 0 0 " 0 U opy t0i N O E °A N pp o '3 C O ❑ Y N E di ei C vi iri 4 UI tOU '0 9 Q ^O G vi Y qv ,8 O E o E = a A 0. d 0 ^� ° .. " L O 0 N o, o oL ED. 0 o F L^ v a v > o f _ pr ,y 3 I Z Z 0 0 0 'o I oy .L.0n ."n v " o o I y t0 0 g g a °a.,' m �, = w v Z a' T Q U 6 M or o " y s r el' w i y y 3 a :i2 Eit .1:2E �+ 0 4 0 a a F" 0 a z — « v v a te.. o "^ d '-' - o0 .70-. o = w ao o E v� E E o 'x o `° o y N p c 6y .. r ti a '.� rn c � w o o '4. " € 3Qaa . 0 - . — C i. ci o U N ' `'A 0 0 Cr,0 ' O p., w v) a � w Z O ♦ ♦ A rn Z a zn. c O s o ui ` v v o o s 3 .'.:w-g o 0 o a [r oU m '� bQ O 6 6 6 0 F U• Oad, Z E g m • W 3 0 C oH. O O o do d N O W h tOi o moo. (�. N r o N 0 O v' 4o+ O 0 oo C7 .n c, g �? Rr o ... H_ i !; ! d a O O b 7m .. E C .C O O O W C: Uv y 0 0 y 1-'i 'A E o c U `b-� aax Td E-4 5u � o ff ao °'y v dF 3 r A o v el 2 O .e l 8 = "' € Ti 1 Y PO x tC O o u et: v p7 _ m 0 r Vo � J Q .5.-1 g et 0 a ▪ t N .N- O ; a C \ 0.) FH .u'. C.) .0.1 „ e o `�. U • q a ISI » e o L. N N v00 d. 0 C U N p 't o 9 N y VI .a-, O 00 N �rb a O' f 4 ••-• ..,\ L W CG. N II G N E p .G. C O O w 0,2 7' \ 4r�p o ,-07 Ca .n ti W U.4 o a I L- lm q O ..-P. II o Faa .ii $ v 0 ^p, ++ [.� O o; 'O.� G o I4 8 El 0 ~flu1 tt o'O O N o V. U lit .P N el -. ca ,' o +G w t+'1, E ¢0 .E o Uoa. UCo ." O ,r J�r/� E q� 'o `o.' o m w E v .� v o al it W 4m Z h uk ❑ N L. Q RI . 'e' i. 0 9 O' a O Cp0y C N(.7. U a n° o aEi i -- COI V 2 2 O . U,. N CI c > > .� .'a o d : g N y a w SD t ,x a a aU o a � s d' a 'a a op c 0 c A 3 z N OS 6 o U 8 6 0 .74 O c ¢ ] a a a `a o3 w « o y aJ _ v . m G a' 0 E d 'c c e o . ''' a' Cs - 1 o o O c o o u u .0 i° t' b0 U F...d-' > U U Q M c 2 c adi v " v o oki y� IgII o0 o y a �wc .a E 'e € �,, o5 0 t'y a F , 2.e,,_, :ocn 1".a. N y 5 N H 0. N e::: O t! eD O !: (• 3 o o v 3 v 'o 0 o 0 0 C N e at ,� ax. F l^ 6.ID . ' L. Q M p z o ^ z U Q .. >. o : S:flhid n; 1i tit._, e a c u H E v e s" `r1 v°c a.. w4 "_p .+ t'd E_ . '� .0 m O •oC a_I' ' it F { :.€ 5 G" r.t p'> E II W W b r.`+ ❑ at xv{a a C ' C I. U y.a at .. u ys,,, y > m y $. .'�'u.�y{bp "3 v?. i„ u'S- wY' i° Otr. p L. Zi o A. o"� o u c G G 0 6 C a Q cc IIIA:. R }r'z a 3Y}.e�. in' m .: a , W � 0 m N ,C a U 'E U ; 0 m t4 e A a!b el',... u 0 a OE E ._".. cn .; e0i o O °» o a >, 4-7,,,,,-/e.,.„34,,r—.,.....k, e o as y74 Pr 0. C H e o p w qj c a� G co, b t T v a C O ,�y/ Imo, m o^ N_ o a o o q. s 32:s---,:414:.444 x . s t vw=** CO mo b '' sy N v U U y 0, O0, URJ ro O o O 'c 52 v U +cE W it o In �I� 0 r 9 y 6 00 .md . G\ c o C o E 0- o N qq c W ? O O O °� _ v v 1 o 82 �. g v.G .... 2 z " � C U F F a � in a Q 0 O ;L > U aci O � . O = '.0�. b m ¢o,�'I Ca 00 ❑ 0 0 w y � Z d yo - 00 a' . O a O o a o _ < o o co ro "c o c W op., ge N N cacoet y o > e o E. W e A. y c >_, o.o o O. ^� 0 0—y 0 .W. c >, W U' c —0 0 .q( ni v en a 0 ^., x ,Ed °' li, a d. ' w 3 = E "^oi°n s n o. Q.. x o u a T 0 c 2 .co. m = ro .S N W 'o .o - .O - q a 3 'o' a 'y m y 'F �,o o0co Z . s v al r C y q a w 'E m y 'E o iti v > ≥ a ro vi r W 'oa a n a o .o cD N 7 C u d w N 6 N% Ian Ira y O .. w N y CID >O .0 al x .p 07 ur get) ' d e w al Q 'O o ro 3 °i Ti w 0 0 0 0 Y �' °' .E F `� c m a o 0. 0 .0�. E as N 0 b o > >. m °' U f- o v *' o o a o m g o ro o 0 0 71 Cl v .E x y .� c y ° F ON 7 m C E o a• , 0 3 u O, ,��, r/] ^� c y = L 7 �, °' '' °' 3 w o ? o coi f " co . d m ❑ ❑ Y lag Y z O E o i'" � c 3 e i.: ti Q 3 a acre 1 C lC L H N b0 N_ i C o 0J CD y Q Z O , >, i O .x ≥, •3 • a W a > o o f d e o -6 � 0 0 a �+ ;" s. � u e o aci o c 0 o rz .- > W a E E. c..) c m o 0 o u s s s E C o c `o Z a. �, s. �' Td Z y '',. wi m '� o ° W q WO v e c ca V� ' o " O a, 'c .; 0 0'refWi, = v ! " _ o y , f 11):'( 9 w .E 0 .c es e >, u 0 < d a., .v., 7 6 o c i o E U c m 5 i G U i 7 0 _ z 2 U U G -; $• a u 6 F d a a y . v 5. F, a o .W o W re m : rit R pW� a .�_, � W °� °> c "�,' �i d • , v H m :� 4 U d� v A p0-, d m 6 Q 0 0 O 7s. W ''� O c o0 E 0. m = o o a -5 C o 0 o o y 3 • ,m s, 'd:'o ' sU. ° Pi F a 5 ❑ ❑ C C ❑ ❑ 3 o 0 c b. c x'8 y. E c a a1 .. c ro .�..N. U G ,_, C3 a0i G o 'ai aci 1/45 >'o t..• Le a s 3 o z o a > ��-i't_ IK' 0 0 a 0 eP = _ C N ro ❑,O O U a 0 'G cA on a V N h 0.0"'0 O.r: W pA A O 9 aD N a0 c.' m N EJ N.2 0 y '� A ,M b O M N 0 't"..' 0 r7 V L-g a c en en 3 wcn -o en QI ; E. .. C 0 c. en O [� ifi O. W O co ace L Q O q C O .o d U ® .. O o ///Vrrr ! c Q W ac O O N O .. —J W Sk N o rf o ,� Y o W U U o Uo. a w ;1 $ 53 0 F z c,E g.� 00 c w z cn W N z 0 ry 3 S 3 m F o E. o o $rLJ 0 o'Z o 4 o. .. '� O utN"a 0K T v ' O . 0 42 O s w .. .. > is P]E a 0 - a X E 0 0 < W o c 0 > rt-‘17 c„ v Z rCC% -2 � 3 o E m °D faC e N b o ea .. In 6 .. Ri _ L� -,qwp, 4' ai O ycy G 6 Fes-, o ' '� ; a) d ? ¢ ^ • i-7 Lb A � E O F o 0 .. °o a 2i, c aCi m m id.; v E y. 1_ >z .W a W o U v' y m oi°a c m `c° E a:a° 3o E U) v t- g°2 o JCn ccr F Tv gni ti cn —. > L 's, i x' a L c ya O a 6 m c y c .tt mg m c H C m NI p. .r 0 _I 4 o c _c, a 'o ''� x .- 'o .>v O g H '- C P7 o C i 3 d 0.° ovi d v a .y o."0 m rd a -0 v C4 v v,o = /N� 3. G' N _ O 0 L 'O U a 6 0 O CI s-, ate, 0 ` ti, y p ce a) • E d Y 0 m U vi N co N O o a O O U 6 o. �i ro C G U , 00 ER, d' m E °� -• .0. C7 E o ra E o F. w :E `-' y 3 > ea m ° a y I z Zli. o a " a o I o v o L Pk a u m o w i7, cr "' C .� Q U d n o `0' a. 3 Q o — o d 3 `v . C7. .E a g d W o E •E O 0b O - 0 c _, 0 N 0 ' —0 0 E 0 t s o_ c .�' p c, c _ F a q .� G n 3 U o.. U W O v rnY O K �' O E vl E C E O •x a a O o O 0 0 0 F 0 a0 ro 0 v m `0 0 0 _ z it L L P. w v v, a w m �. z c� 3 � ra ❑ ❑ ❑ ❑ ❑ ® La ® W o I z L . }'� W W j u 7 Y p q 0 O �{ l< �i C..OE O cC, LL'' E '�Jr 0 0 nN W N N tC p4 1 J, et 5 L O.� m. W tCc+G Q QI 2L I W 2 W W ° 0. PI 9 e e L ° V -• r� c Oo(J. O b N U U O] 9 0 0. 0 y N O. _ 0 m 'J m M C., N N O c 9 W u pV C O .. � `id J H4 Cf W cep a 1 r c C7 c m w o 0 7 O C) .3 c 0. w el pe ., e a o, p L •a) v e ai °3. 02 Q 2 ,.9,o 2) c, .y c a z s v g -I. a Q F 5 _ `d se •U 3 C� D A zp m ° mo i0 d N os 2 u W v o !�aW.i. tO .,f ry M �• x, Ct. el t9 O as 0 a it a 8 ' en 'g th, 47 N a c 9y O37 _ — "1 r ib p d h re 0. ^^I E a = a ; n . 03 11 T 'p ',PA 5 p N r- c . ^ O Ni si,o o QCSI �ct, m .O( I Oa "2 O ,a v .. Q d z EE !0E2 !0 er mO eN d O OO= ttr e u. e 61 V� u .e� o a g d W b.�.� CS O "^ T N `� ti .0o L 1 C _ p o N N '� m o a �^ m4-t• ) S 0 ep O O e O in -, C c F O L U c > a.F: iM m 2 E ° T U y O U W O U '1' w 0 L O tOi ®: L L. 2 .W co I En""' -02 o �' m a. x ❑ d E d n != !o� gyp} p �>�� 9 ia 0 7 ^°o' O G 40 A a OA co) ❑ . U p N �`• o os 0 a X X O'F+ {a-• 9 — 0 et o a 0 3 0 0 0 8 .o o O Is 2 �'re 0 --2. � s � .poi �.' a it y °' m Oe E y x C C d _ 3 O. W a e W °' a O 7 0 E m u'< ea o eto 023 W E 0 U .e c 2 W 'a .- Ln .o :.9 ,4 � d 00 um co O W v... •aWn W ha . II O C V VD O o O O C O Q p L C W C g w z e -' u E 'a o W � •S ew ., > ii . co04 o W N Ti sd � ° laa !a L E x > p d Ii w a 0 6 d. J y \Jl) C1 slitt L. `o vi m Q d 'x a ra U IE c4 �J ¢.I '�.—'`� U L. _ o La. ZEn > U U q e W e n or �n t e .5 ` Z r3 v . e p a a O,...) 'L •o v�W s42 x 0 co O L l' ( r• O F, >• ❑ t O >, 0 -•0 0 '0s --:, q 8 2 y 7 C 'y co E c c ' W W a N �' e V E O Po g W W .a o d o s > > e 0 IG o o a E 8 o E p a P � o °': p a g ¢..v o Lbw A � ,u 0 O Ga �� c• u G 0 y ate.. t u a 2 {9 +�: ILL, Z W a X C7 a• N d U .0 C a°i 0 e v 4C x _ 1rr d.. F4 Y �..'o,�.. b o ,,�L, v U 0 0 n c Lo, U P. . EE 0 p Y b, az N G 6 L."..- b .. m C o > v d T m CU U u w_ U s. cn �w .S U o o .0 E N a.g 3 a W o y U_, .7 u 'W pp n o qp o a I c v m a L I 8 o O U c W Tc¢ O oo 0 O N .w�, y �' a>i u O 0 E U x 0 x u c a> o d- ua h 9 o w u > iii W' I� Ll u �7 Pp. O z U O W F s k G « O A W ® ❑ m Q 0 w 0 W @e 3 ) ca { ) / / . 0 O 7 OS 3 E \ ) - o — - . -S 4 ; ) ) \ & / o ) ° a 16- . 9 - 0 \ en a k / \ \ 0 ~ - < co \ 2 co c, 8 2D- 2 a - { b o . cy _ / \ _o z 8 E E _ E \ 3 ) Q � \ � Z Za) x co 0X w2 IL E § ZE ) % I \ \ Li- Dc al E 72\ —I -g $ 7- O � ) � O7, - � \ d L.L. CC | e z a w2 ! / » 2 @ -J c% - S uJ 3co C• |EL) \ — co a / : + E \\ = iri_ \ o a 2 J -O. / w 0 � PCe / N \ a) 0 co) j V _ 2 S $ 2 ) a = w 64E; (D \ f < \ 2 \ 3 $ } \ c 4 ) CD f } ® . i ) < I Z ; \ ] ) ! : k O 2 E I '- Cl) I a a Z E § ) O \ ) }/ \ = I 2 > 2 J ) ! E ( \ % ) k ( \ k ) { } � \ ) c a) 03 a a. O z ± u 0 \ 0 -co } co 2 Hello