SERA United States Environmental Protection Agency Air and Energy Engineering Research Laboratory Research Triangle Park NC 27711 Research and Development EPA/600/S7-85/022 Aug. 1985 Project Summary A Model for Evaluation of Refinery and Synfuels VOC Emission Data R. G. Wetherold, G. E. Harris, F. D. Skinner, and L P. Provost Estimates of the emissions of volatile organic compounds (VOCs) from petroleum refineries and synfuel plants are of considerable interest to EPA, in- dustry, and the public. Such estimates are needed in the preparation and re- view of Environmental Impact State- ments (EIS) and permits required by the Clean Air Act. In response to this need, several studies have been made of VOC emissions, particularly from refineries. Methods for estimating VOC emissions and the results of VOC emissions tests have been published in various journals and at numerous forums. A need has developed to define a consistent and comprehensive approach for estimat- ing VOC emissions from refineries and synfuel plants. This study has resulted in the devel- opment of a model for performing such estimates. A modular technique was developed in which the entire spectrum of potential VOC emissions sources was defined in a number of process and utility modules. Each module repre- sents a process or auxiliary unit. The user of the model provides emission source counts and other process infor- mation, or uses default values pro- vided. Emissions are calculated, using emission factors for each source type. Detailed examples of the application of the model to both refineries and syn- fuels plants are presented. This Project Summary was devel- oped by EPA's Air and Energy Engineer- ing Research Laboratory, Research Tri- angle Park, NC, to announce key findings of the research project that is fully documented in two separate volumes (see Project Report ordering information at back). Introduction Over the past several years, volatile organic compound (VOC) emissions from petroleum refineries and synfuel plants have been of considerable inter- est to the EPA, industry, and the general public. The preparation and review of Environmental Impact Statements (EIS) and permitting requirements of the Clean Air Act depend on emission esti- mates. In response to this need, several studies have been made of VOC emis- sions, particularly from refineries. Methods for estimating VOC emissions and the results of VOC emissions tests have been published in various journals and at numerous forums. A need has developed to define a consistent and comprehensive approach for estimating VOC emissions from refineries and syn- fuel plants. This study was performed to fulfill this objective. A literature search was conducted to obtain all available information on VOC emissions from petroleum refineries and synfuel plants. The types of synfuel plants included in the search were coal gasification (excluding in-situ gasifica- tion), coal liquefaction (direct and indi- rect), and oil shale processing. Four major sources of emissions were included in the search: process emissions, product storage, baggable fugitive emissions, and nonbaggable fugitive emissions. Both controlled and uncontrolled sources were considered; if the source was controlled, any avail- able information on the degree and type of control and the rationale for control application was included. Process operating parameters and physical data were included if they per- ------- tained to a process stream for which emission data were expected to be available or if they pertained to any ex- isting emission model. Emission data could include measurements of emis- sion rates, measurements of parame- ters that could correlate with or predict emission rates, or composition data. Because of Radian's involvement with EPA in VOC emissions activities over the past 7 years, it was expected that very little information of signifi- cance would be found of which EPA and Radian were not already aware. A search of the DOE ENERGY data base using the DIALOG Information Retrieval Service bore this out. The search in- cluded the last 5 years. Therefore, the bulk of the information was gathered through the Radian library. Particularly in the refinery area, a great deal of the available information on emissions is the result of EPA/Radian testing efforts. Refinery emission data were obtained from a few major sources which had been identified from past studies. These sources are tabulated in the full report. Some of these references also provided additional data (e.g., emission source distributions and process and operating parameters) needed to develop a model for estimating refinery VOC emissions. Much less information on VOC emis- sions from synfuels plants is available than for refineries. The full report sum- marizes the literature surveyed. Source types and frequencies for a number of synfuel processes, together with a lim- ited amount of emission factor data (pri- marily for Lurgi gasification plants), were located. There are thousands of potential VOC emission sources in a refinery or syn- fuel plant, but this variety of sources falls into one of the following general categories: • Process fugitive emissions. These are the result of leakage of VOC from the piping and fittings with which a process unit is constructed. Sources of process fugitive emis- sions and their uncontrolled emis- sion factors are given in Tables 1 and 2. Note that the emission fac- tors are presented by industry, and that there are significant differences between industries. The full report describes how VOCs may be emit- ted from each source type, how such emissions may be controlled, and the effectiveness of these con- trol measures. Table 1. Process Fugitive Emission Factors Emission Factors, Ib/day/source Source Type Pump Seals Pump Seals Compressor Seals Compressor Seals Valves Valves Valves Valves Connections Relief Valves Relief Valves Open End Lines Process Drains Service Category Light Liquidb Heavy Liquid' Hydrocarbon Gas Hydrogend Hydrocarbon Gas Hydrogen Light Liquid Heavy Liquid All Gas Liquid All All Refineries 6.0 7.7 34.0 2.6 1.4 0.43 0.58 0.012 0.013 8.6 0.37 0.12 1.7 SOCMI' 2.6 1.1 12.0 - 0.30 - 0.38 0.01 2e 0.044 5.5 0.37e 0.09 - 'The Synthetic Organic Chemical Manufacturing Industry. These emission factors may be more appropria for petrochemical units associated with refineries or synfuel plants. bAny organic material more volatile than kerosene. cAny organic material with a volatility equal to or less than kerosene. dA stream with greater than 50 percent (by volume) of hydrogen. eFrom refinery data since there were not enough heavy liquid sources found in the SOCMI testing to warrai the development of separate emission factors. • Process combustion emissions. Many refinery or synfuel processes require a great deal of heat input, which may be provided directly by a fixed process heater, or indirectly by steam, generated in a boiler. In- complete fuel combustion and/or reactions between the products of combustion may result in VOC emissions. Emission factors from combustion sources are given in Table 3. • Process point source emissions. Point sources of VOC emissions are present in some process units, and emissions must of necessity be esti- mated for each individual process unit. Data obtained in this study were used to identify the point sources occurring in various pro- cess units and to develop emission factors for each. • Slowdown and flare system emis- sions. Flares are used to handle large emergency releases from re- finery and synfuel plant process units and for combusting continu- ous, low flows of VOC that are trans ported in closed vent systems. Flar destruction efficiencies may rang from 91 to 100 percent; a mean eff ciency of 98 percent is normally as sumed. Wastewater treatment system emit sions. Primary sources of VOi emissions from wastewater treat ment systems are evaporative emis sions from oil/water separators am dissolved air flotation units. Con trolled and uncontrolled emissioi factors are given in Table 4. Sludge/solid waste treating emis sions. Atmospheric VOC emission can result from the land disposal o refinery and synfuel plant oil' wastes. No well-established emis sion factors exist for any of the im portant disposal methods (land farming, landfilling, and surfaci impoundment), but the full repor presents several predictive emis sion models which have been pro posed in the literature. ------- Table 2. Process Fugitive Emission Factors Used in the Gasification, Acid Gas Removal, and Wastewater Extraction Modules Source Type Pump Seals - Aqueous Pump Seals - Hydrocarbon Liquid Compressor Seals - Hydrocarbon Gas Compressor Seals - Hydrogen Gas Valves - Hydrocarbon Gas Valves - Hydrogen Gas Valves - Hydrocarbon Liquids Valves - Aqueous Connections - Hydrocarbon Gas Connections - Hydrocarbon Liquid Connections - Aqueous Relief Valves - Gas • Relief Valves - Liquid Open End Lines Process Drains Sample System Purging VOC Emission Factor, lb/day/sourcea 0.0026 0.011 34.0 2.6 0.0042 0.43 0.0057 0.0026 0.0005 0.0011 < 0.00007 0.34 0.0037 0.12 1.7 0.79 "There is some concern over the accuracy of these numbers, since they represent only the gaseous portion of the leak (i. e., they do not include the potential contribution of liquid leaks). A number of liquid leaks were noted, although most were in aqueous stream service. These factors were included because they are the only source of gasification specific data, but the use of refinery factors may be more accurate if liquid leaks are suspected to be significant. • Emissions from storage tanks. Emission models have been devel- oped for the most commonly used types of tanks used to store crude oil and liquid products or byprod- ucts. These models are quite com- plex; details are given in the full re- port. • Emissions for cooling towers. VOC emissions from cooling towers typi- cally occur as a result of leaks in shell-and-tube heat exchangers through which cooling water circu- lates. An emission factor of 6 Ib VOC/106 gal. of cooling water circu- lated is used. Emissions from product loading op- erations. VOC emissions result from evaporation of products dur- ing loading operations. Emission factors for several different stocks, means of transport, and style of loading are given in Table 5. For other products, emissions may be Table 3. Emission Factors Fuel Type Natural Gas Fuel Oil Coal (Bituminous or Lignite) Coal (Anthracite) for Heaters and Boilers Emission Factors, Industrial Heaters and Boilers (< 100 x 106 Btu/hr) ' 0.0029 0.0667 1.0 Ib/ton negligible lb/106 Btu Utility Boilers (> 100 x 10s Btu/hr) 0.001 0.0667 0.3 Ib/ton negligible estimated by using the factors for the product listed whose volatility is closest to the product of interest. Refineries and synfuel plants may be thought of as consisting of a number of process units and auxiliary operations. To provide a VOC emission model, a number of such process and auxiliary units were selected. Process and auxil- iary modules were developed to repre- sent the process units and auxiliary op- erations in their generic form. Modules were assigned to those processes which may potentially make a signifi- cant contribution to VOC emissions. The refinery and synfuel modules con- sidered in the VOC emission model de- veloped as a result of this study are listed in Tables 6 and 7. Note that there is some overlap; a number of the refin- ery modules will be found in most syn- fuel plants. The full report describes each module so that the user may select those which are applicable to his refin- ery or synfuel plant. Information on the numbers and types of VOC emission sources occur- ring in each module was used to de- velop various levels of default values. These defaults provide useful informa- tion to users of the model who may have different amounts of detailed data regarding a specific refinery or synfuels plant for which an estimate of VOC emissions is desired. Results The VOC emission model is pre- sented in a workbook format in appen- dices to the full report. The model con- sists of calculation sheets and module default sheets. The basic emission cal- culations for all emission sources are done on the calculation sheets. If the person using the model has complete descriptive information about the plant in question, then the calculation sheets will provide everything else necessary to estimate the VOC emissions. In most cases, however, the calculation sheets will require some input data that the user does not have, and the default sheets were designed to provide rea- sonable estimates for .such missing data. The logic flow of the emission model is illustrated in Figure 1. The user first characterizes the plant to be modeled by selecting .appropriate process and auxiliary modules. Process modules are the model's representation of process units (such as a Fluid Catalytic Cracker, a Naphtha Hydrotreater, or a Lurgi Gasi- fier). Auxiliary modules are the repre- ------- sentation of non-process operations (such as wastewater treating, cooling towers, and product storage). If the user does not know which modules should be included, several typical refineries and synfuel plants are fully defined. These "generic plants" may be used as is or simply as a guide in selecting the modules for a particular plant. The emissions are calculated on a module-by-module basis, using emis- sion calculation sheets and default sheets (as necessary). When all the pro- cess modules have been calculated, a similar procedure is followed for the auxiliary modules. The results may be displayed in at least two useful ways. First, the emission estimates on a module-by-module basis will show which modules are producing the most emissions; control efforts can be con- centrated where they will accomplish the greatest emissions reductions. Sec- ond, adding together the emissions from like sources (e.g., light liquid pump seals) can facilitate comparisons of po- tential reductions which may be achieved by control programs aimed at all sources of a given type, such as leak detection and repair programs or im- proved equipment specifications. Several examples of the use of the VOC emission model are detailed in the full report. One of the example plants was a small refinery. Table 8 lists the modules used to represent the small re- finery, and Figure 2 is a block diagram. The results of the model VOC estimate are summarized in Table 9. As de- scribed previously, the VOC model has multiple levels of defaults to allow the user to take advantage of whatever data is available. Table 10 compares the model results, using three levels of de- faults. Conclusions and Recommendations This report presents a mathematical model for estimating VOC emissions from refineries and several types of syn- fuel plants. All significant VOC emission sources have been included in the emis-. sions model. A modular technique was developed in which the entire spectrum of potential VOC emissions sources was defined in a distinct number of process and utility modules. This model is con- venient, flexible, and functional for de- veloping VOC emissions estimates for very diverse petroleum refineries and synfuel plants. The model developed in this study Table 4. Emission Factors for Wastewater Treating Slowdown Systems, Flares, and Cooling Towers Source Type Emission Control Emission Factor Wastewater Treating Oil/Water Separator Oil/Water Separator Oil/Water Separator Dissolved Air Flotation Slowdown and Flares Cooling Towers Uncovered Covered Covered and vented to flare NA NA NA 1.88 lb/103 gal. WV\ 0.38 Ib/W3 gal. WV\ 0.06 lb/103 gal. WU 0.09 lb/103 gal. WV\ 0.8 lb/103 bbl crudt 6 lb/106 gal. CW Table 5. Emission Factors for Product Loading Emission Factor, lb/103 gal. Vehicle Tank Trucks/ Tank Cars Barges Ocean Barges Marine Tankers Loading Style Submerged- normal Splash- normal Submerged- balanced Splash- balanced Clean-vapor free Uncleaned- dedicated Average condition Clean-vapor free Uncleaned- dedicated Ballasted Clean-Vapor free Ballasted Uncleaned- dedicated Average condition Gasoline 5.0 12.0 8.0 8.0 1.2 4.0 4.0 1.3 3.3 2.1 1.0 1.6 2.4 1.4 Jet No. 2 No. 6 Naphtha Kerosene Fuel Oil Fuel Oi 1.5 0.02 0.01 0.0001 4.0 0.04 0.03 0.0003 2.5 NA NA NA 2.5 NA NA NA 1.2 0.13 0.012 0.0000& 0.5 0.005 0.005 0.00004 ------- has several unique and valuable fea- tures. The modules lend themselves readily to individual updating, improve- ment, and expansion, without disturb- ing the integrity of the remaining mod- ules. The model is capable of developing emissions estimates from various levels of information. In the ex- treme, VOC emission estimates for re- fineries and synfuel plants can be devel- oped when only the plant type and capacity are known. The results of these "maximum default" cases are pre- sented as Table 10. Several areas for further work could enhance the model developed in this study. The most obvious is computeri- zation of the model. The modular form of this model is ideal for computeriza- tion. A computerized version of the model would allow rapid estimation of VOC emissions and optimization of pro- cessing and control techniques for min- imizing VOC emissions. Different levels of control could be quickly evaluated under different scenarios. Summaries of emissions from particular sources across modules could be prepared with minimal effort. VOC emissions from fugitive process sources (valves, pumps, flanges, etc.) represent a significant percentage of total VOC emissions. Emissions from these sources are best controlled by a leak detection and repair program. This VOC emissions model could ultimately incorporate EPA's leak detection (LDAR) model to allow additional evaluation and emission minimization studies to be performed rapidly. The LDAR model is currently in computer form. The accuracy of the VOC emission es- timate is not evaluated by the current model. An assessment of accuracy would require information on the accu- racy of the emission source data as well as the equipment counts and loading levels. This information is available (in the form of confidence intervals, stand- ard errors, and other types of error bounds) for some of the data used in developing the model. For other sources, new data are currently being developed which should include an ac- curacy assessment. The level of accu- racy in using the model will also depend on the level of information that the user has available (e.g., equipment counts versus unit capacity levels). The current model could be updated to include lev- els of accuracy for all default values. These values could then be summarized by appropriate error propagation meth- Table 6. Refinery Modules Module Name Comments 1. Atmospheric Crude Distillation 2, Vacuum Crude Distillation 3. Naphtha Hydrotreating 4. Middle Distillate Hydrotreating 5. Gas Oil Hydrotreating 6. Vacuum Resid Hydrodesulfurization 7. Catalytic Reforming 8. Aromatics Extraction 9. Catalytic Cracking 10, Hydrocracking 7 1. Thermal Cracking & Visbreaking 12. Delayed Coking 13. Fluid Coking 14. Light Ends Recovery and Fractiona- tion 15. Other Miscellaneous Fractionation Units 16. Alkylation 17. Polymerization 18. Isomerization 19. Lubes Processing - Volatile Organic Solvents 20. Other Lube Oil Processing Includes desalting, heat exchange network, at- mospheric column, and side stream strippers. Does not include facilities for processing LPG in non-condensible OH gases (see # 14). For sulfur reduction in straight-run or cracked naphthas. For sulfur reduction in jet fuels and kerosene. For low sulfur fuel oils, cracking feed pretreat- ment, and lube oil hydroprocessing. Includes Platforming, Rheniforming, and Powerforming. Does not include naphtha hy- drotreating (see #3). Includes Udex, Sulfolane, and Tetra. Includes fluid and moving bed crackers such as the FCC, HCC, and TCC. Includes reactor, regenerator, main fractionater, and heat ex- change. Light ends recovery and fractionation are not included (see # 14). 27. Asphalt Production 22. Hydrogen Production Includes fluid coking and flexicoking. Includes circulating oil absorption/stripping and fractionation of recovered light ends. Independent naphtha splitters, rerun stills, stabilizers, etc. Includes both HF and H^SO4 alkylation. Production of polymer gasoline from propy- lene and LPG mixtures. Includes both C4 and Cs/C6 isomerization. Includes propane deasphalting, propane de- resining, propane dewaxing, solvent dewax- ing, Duo Sol, solvent deasphalting, MEK de- waxing, and MEK-toluene dewaxing. Includes phenol extraction, furfural extraction, acid treating, SO2 extraction, white oil manu- facture, centrifuge and chilling, naphthenic lube oils, clay contacting, wax deoiling, wax sweating, wax neutral separation, and com- pounding. Includes asphalt oxidizing, asphalt emulsify- ing, Dubbs pitch, and 200°F softening point unfluxed asphalt. Includes steam reforming and partial oxida- tion. ------- Table 6. Refinery Modules (Cont) Module Name Comments 23. Gasoline Treating 24. Other Product Treating 25. Olefins Production 26. Other Volatile Petrochemicals 27. Other Low Volatility Petrochemicals 28. Boilers 29. Slowdown System and Flares 30. Wastewater Treating 31. Sludge/Solids Handling 32. Crude and Product Storage 33. Cooling Towers 34. Product Loading Operations Includes Merox, inhibitor sweetening, mercap- fining, Petreco Locap, Linde, caustic treating, and Doctor treating. Includes clay treating, Linde, salt treating, and blending for middle distillates and fuel oils. Production of mixed olefins from gas, naph- tha, and/or oil feedstocks. Includes butadiene, alpha olefins, aromatics, cumene, cyclohexane, aliphatics, linear paraf- fins, heptene, MEK, MIBK, ethyl amyl ketone, tertiary amylenes, acetone, isobutylene, hydrodealkylation of aromatics. Includes naphthalene, xylenes, mineral spirits, octyl formal alkylate, styrene, phthalic anhy- dride, nonene, diallylamine, poly isobutylene chloride, oxalcohol, phenol, cresylic acid, naphthenic acid, butyl alcohols, pentoxone, sodium sulfonates, tertiary butyl toluene, polymers, carbon black, furfural, catalysts, mesityl oxide, isophorone, gasoline additives, lubricant additives, and oxidates. Independent combustion units for production of steam and/or electricity. Includes oil/water separators (OWS) and dis- solved air flotation (DAF) units. Includes any on-site treatment such as land- farming, landfilling, and ponding. Includes fixed roof and floating roof tanks. Includes loading facilities for tank trucks, tank cars, barges, ocean barges, and marine tankers. ods to estimate the accuracy of emis- sion estimates generated by the model. Obviously, it would be desirable to update the modules periodically as ad- ditional emission data become avail- able. Additional emission data from synfuel facilities should be available during the next 5 years. As the model is employed, users will undoubtedly find additional needs which have not been addressed by or included in the current model. These needs should be cata- logued for future model improvement efforts. This VOC emissions model has been evaluated in a preliminary fashion by applying the model to some specific fa- cilities and comparing the emissions es- timates to results obtained indepen- dently (e.g., through permit proce- dures). Field tests would be more thor- ough and objective. Emissions could be estimated using the model and then measured using transect techniques. The results from this effort could be used to refine, calibrate, and validate the model. ------- Table 7. Synfuel Modules Module Name Comments Coal Preparation (Thermal Drying) Slurry Drying Coal Gasification Methanol Synthesis Fischer-Tropsch Synthesis Mobil M-Gasoline Synthesis Direct Liquefaction Above-Ground Oil-Shale Retorting Acid Gas Removal Oil-Soluble Arsenic Removal Wastewater Solvent Extraction Used in EDS process. Includes gas cooling. Fugitive emissions from some gasifiers negligible because they do not provide significant hydrocarbons. Includes product separation. No default values developed due to lack of pro- cess information. Example: Phenosolvan process Menu of Process and Auxiliary Modules Repeat for Next Module Repeat for Next Module User Input Process Module Defaults Process Module Emission Calculations Facility Definition By Module Selection No — te, u Ini i ser ->ut "i Auxiliary Module Defaults T ' Auxiliary Module Yes Emission Calculations Store Results No Complete ? /Yes Store Results Baseline Emmisions Summary Control Efficiency Defaults User Input Controlled Emissions Summary Fjpurt 1. Logic flow diagram. ------- Table 8. Modules of Example Small Existing Refinery3 Process Modules: Atmospheric Crude Distillation Vacuum Crude Distillation Naphtha Hydrotreating Catalytic Reforming Aromatics Extraction Fluid Catalytic Cracking Light Ends Recovery and Fractionation Other Miscellaneous Fractionation Alkylation Auxiliary Modules: Boiler Slowdown System and Flares Wastewater Collection and Treating Storage—Fixed Roof Tanks Storage-Floating Roof Tanks Cooling Towers Loading Racks-Trucks or Rail Cars "Crude capacity = 50,000 bbl/day. I Slowdown I J System and . I Flares \ Figun 2. Block flow diagram for the example small refinery. 8 ------- Table 9. Summary of Baseline Emissions Source Type/Service Pumps/Light Liquid Pumps/Heavy Liquid Compressors/Hydrocarbon Gas Compressors/Hydrogen Gas Valves/Hydrocarbon Gas Valves/Hydrogen Gas Valves/Light Liquids Valves/Heavy Liquids Connections/All Relief Valves/Gas Relief Valves/Liquid Open-End Lines/All Process Drains/All Combustion Sources Other Point Sources Wastewater Collection and Treating Cooling Towers Slowdown System and Flares Loading Racks Fixed Roof Storage Floating Roof Storage Totals Emissions, Ib/day 522 53 238 6 4938 142 4950 60 748 1446 33 42 539 91 450 1056 1314 110 308 1485 2306 20,837 Percent of Total 2.5 0.3 1.1 neg. 23.7 0.7 23.8 0.3 3.6 6.9 0.1 0.2 2.6 0.4 2.2 5.1 6.3 0.5 1.5 7.1 11.1 100.0 Table 10. Summary of "Maximum Default" Emission Estimates The Type A (or topping) refinery can be es- timated by: Emissions (Ib/day) = 4,024 + (82.3) (Crude Rate in TO3 BPDa) The average Type A refinery has a crude capacity of 14,000 BPSDb. The Type B (or cracking) refinery can be es- timated by: Emissions (Ib/day) = 13,649 + (82.4) (Crude Rate in W3 BPD) The average Type B refinery has a crude capacity of 66,000 BPSD. The Type C (or petrochemicals) refinery can be estimated by: Emissions (Ib/day) = 25,339 + (83.1) (Crude Rate in W3 BPD) The average Type C refinery has a crude capacity of 150,000 BPSD. The Type D (or lubes) refinery can be esti- mated by: Emissions (Ib/day) = 24,455 + (86.0) (Crude Rate in W3 BPD) The average Type D refinery has a crude capacity of 187,000 BPSD. The Type E (or integrated) refinery emis- sions can be estimated by: Emissions (Ib/day) = 30,774 + #6.5; (Crude Rate in 103 BPD) The average Type E refinery has a crude capacity of 312,000 BPSD. aBarrels per day. bBarrels per stream day.. R. G. Wetherold. G. E. Harris. F. D. Skinner, and L. P. Provost are with Radian Corporation. Austin, TX 78766. Robert C. Lagemann is the EPA Project Officer (see below). . The complete report consists of two volumes, entitled "A Model for Evaluation of Refinery and Synfuels VOC Emissions Data:" "Volume!. Technical Report and Appendix A," (Order No. PB85-215 713/AS; Cost: $23.50) "Volume II. Appendices B and C," (Order No. PB 85-215 721/AS; Cost: $16.00) The above reports will be available only from: (cost subject to change} National Technical Information Service 5285 Port Royal Road Springfield, VA 22161 Telephone: 703-487-4650 The EPA Project Officer can be contacted at: Air and Energy Engineering Research Laboratory U.S. Environmental Protection Agency Research Triangle Park, NC27711 , U.S. aCVERNUENT PRINTING OFFICE I«S 559-111/20640 ------- (A xj 00 01 s o 5' 0) O I tn K> o> oo TJ m 30 2 nm Z2 o > u 01 ------- |