Case 4:17-cv-00612-RCC Document 3 Filed 12/20/17 Page 1 of 62

1 ELLEN M. MAHAN 2 i Deputy Section Chief Environmental Enforcement Section 3 Environment and Natural Resources Division 4 U.S. Department of Justice

5 JAMES R. MacAYEAL (D.C. Bar # 474664) Senior Counsel 6 Environmental Enforcement Section United States Department of Justice, P.O. Box 7611 Washington, D.C. 20044-7611 a j amie.macayeal@usdoj. gov 9 E io LIZABETH A. STRANGE Acting United States Attorney ~~ JANET K. MARTIN(AZ BAR # 6014) is Civil Chief District Arizona 13 405 W. Congress Street, Suite 4800 14 Tucson, AZ 85701-5040 (520)620-7300 15 j [email protected] 16 ~~ Attorneys for Plaintiff United States of America

is IN THE UNITED STATES DISTRICT COURT 19 FOR THE DISTRICT OF ARIZONA ao al UNITED STATES OF AMERICA, as Plaintiff, 23

24 Civil Action No.

25 CONSENT DECREE (Proposed) 26 APACHE NITROGEN PRODUCTS, ; ~C.~ 27

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2 TABLE OF CONTENTS 3 I. JURISDICTION AND VENiJE ...... 6 4 II. DEFINITIONS ...... 7 5 III. INJUNCTIVE RELIEF ...... 12 6 IV. CIVIL PENALTY ...... 14 V. PERIODIC REPORTING ...... 15 s VI. REVIEW OF SUBMITTALS ...... 16 9 VII. STIPULATED PENALTIES ...... 16 io VIII. RIGHT OF ENTRY ...... 18 ~~ IX. FORCE MAJEURE ...... 18 is X. DISPUTE RESOLUTION ...... 20 13 XI. NOTIFICATION ...... 23 14 XII. EFFECT OF SETTLEMENT/RESERVATION OF RIGHTS .....26 15 XIII. COSTS ...... 27 16 XIV. TERMINATION ...... 27 ~~ XV. MISCELLANEOUS ...... 28 is

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WI~REAS,Plaintiff United States of America on behalf of the United

States Environmental Protection Agency (the "United States") has concurrently

filed a civil action against Defendant Apache Nitrogen Products, Inc.("ANP") for

civil penalties and injunctive relief based on alleged violations of the Clean Air

("CAA"),42 U.S.C. § 7401 et seq., and the Implementation Plan for the State of

Arizona ("SIP") approved by EPA pursuant to the CAA;

WHEREAS,the civil action relates to a nitric acid production unit owned

nd a operated by ANP near Saint David, Arizona (the "ANP facility"), referred to as AOP-4;

WI~REAS, AOP-4 is a dual pressure, Chemico Design nitric acid

production unit commissioned in the 1970s that uses refrigerated extended

absorption and hydrogen peroxide injection during startup for purposes of nitrogen

oxide("NO X")emissions control;

WHEREAS,the United States alleges that the ANP facility has violated the

CAA and the Arizona SIP by commencing construction of a major modification

project at AOP-4 without having undergone a Prevention of Significant

Deterioration ("PSD")review by the Arizona Department of Environmental

Quality ("ADEQ"), the appropriate permitting authority under the Arizona SIP, in order to obtain a permit;

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WHEREAS,the United States also alleges that ANP failed to comply with

ongoing requirements for emissions reporting, in violation of federal regulations

promulgated under Section 111 of the CAA,42 U.S.C. § 7411, dealing with New

Source Performance Standards (the "NSPS program"), specifically 40 CFR Part 60

Subpart G (the "Applicable NSPS");

WHEREAS, ANP performed an evaluation of the installation and operation

of Selective Catalytic Reduction ("SCR") as a NOX abatement("DeNO X")system

for AOP-4 and concluded that the additional back pressure could result in

catastrophic failure of AOP-4's turbine;

WHEREAS,the parties have agreed that ANP will enter into a contract with

Thyssenkrupp Industrial Solutions(USA), Inc. ("TKI") to conduct an Alternative

N OX Reduction Technical Feasibility Study on AOP-4 as described in Appendix A

to this Consent Decree to provide information on the technical feasibility and the

associated risks on process and equipment reliability of NOX abatement

alternatives for AOP-4;

WHEREAS,the parties have agreed that ANP will enter into a contract with TKI within thirty (30) days of the Effective Date, under which TKI will develop a working process simulation model for the AOP-4 process, identifying additional locations for sampling points and instrumentation necessary to refine the simulation;

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1 WHEREAS, the parties have agreed that the contract will require TKI to 2 provide this feedback to ANP such 3 that ANP can install the appropriate monitoring

4 equipment and provide necessary information to complete the study; 5 WHEREAS,the parties have agreed that the contract 6 will rewire TKI to evaluate two SCR control technologies for suitability and utilize the process s simulation model to simulate addition of such potential DeNOx technologies to 9

io determine viability;

~~ WHEREAS, the parties have agreed that the contract will require TKI iz develop a budgetary design and proposal 13 for the appropriate alternative DeN

14 system, including budgetary cost estimate and to evaluate the installation of a 15 and post expander as well as the potential for use of a bypass stack; 16 WHEREAS, ~~ the parties have agreed that the contract will require TKI 18 develop an AOP-4 Study Report on the technical feasibility and the associ 19 risks on process and zo equipment reliability of the NOx abatement alternatives; zi WHEREAS, the parties have agreed that ANP shall include the AOP-4 22 Study Report as part of an AOP-4 Best Available Control 23 Technology("BACT")

24 Analysis, which shall be included as part of an application to ADEQ requesting an 25 AOP-4 BACT Determination; 26 WI~REAS, a~ the parties have agreed that in the event ADEQ's determinati as identifies an appropriate alternative NOx control technology for AOP-4, ANP shall

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submit an application to ADEQ requesting authorization to install and operate such

control technology to continue operation of AOP-4;

WHEREAS, ANP does not admit any liability arising out of the acts or

omissions alleged in the Complaint or in this Consent Decree;

WHEREAS,the Parties agree that the United States' filing of the Complaint

and entry into this Consent Decree constitute diligent prosecution by the United

States, under Section 304(b)(1)(B) of the CAA,42 U.S.C. § 7604(b)(1)(B), of all

matters alleged in the Complaint and addressed by this Consent Decree through

date of lodging of this Consent Decree;

WHEREAS,the Parties have agreed that settlement of the civil claims

alleged in the Complaint is in the public interest and that entry of this Consent

Decree without further litigation is the most appropriate way to resolve the

allegations in the Complaint;

NOW,THEREFORE, IT IS ORDERED, ADJUDGED, AND DECREED as follows:

I. JURISDICTION, VENUE AND PARTIES BOUND

1. This Court has jurisdiction over the subject matter of this action and the

Parties pursuant to 28 U.S.C. §§ 1331, 1345, 1355, and 42 U.S.C. § 7413(b).

2. Venue is proper in the District of Arizona pursuant to

28 U.S.C. §§ 1391(b) and 1395 and 42 U.S.C. § 7413(b).

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3. Notice of the commencement of this action has been given to the State of Arizona.

4. ANP consents to and shall not challenge entry of this Consent Decree nor shall ANP challenge this Court's jurisdiction to enter, enforce, modify, or terming

this Consent Decree.

5. This Consent Decree shall apply to and be binding upon ANP and its successors, and assigns, and upon the United States.

6. If ANP conveys the ANP facility or transfers a lease interest in the ANP facility to athird-party, or if ANP contracts with athird-party to operate all or part of the ANP facility on ANP's behalf, ANP shall give written notice of this Consent Decree to any successor in interest or any contract operator before executing such conveyance or contract. ANP shall send a copy of such written notification to the

United States prior to the closing of such conveyance, transfer or operator a greement, and ANP shall attach a copy of this Consent Decree to any final agreement executed with such third-party. Transfer of ANP's ownership of the ANP facility or its lease interest in the ANP facility, or any contract with a third-party, will not relieve ANP from any obligation in the Consent Decree, or the payment of civil or stipulated penalties required under this Consent Decree.

II. DEFIl~TITIONS

7. Unless otherwise expressly provided herein, terms used in this Consent Case 4:17-cv-00612-RCC Document 3 Filed 12/20/17 Page 8 of 62

Decree that are defined in the CAA and in regulations promulgated thereunder a shall have the meaning assigned 3 to them in the statutes or in such regulations.

4 Whenever terms listed below are used in this Consent Decree or in the Appendices 5 attached hereto and incorporated hereunder, the following definitions shall apply: 6

a. "Alternative NOX Reduction Technical Feasibility Study on AOP- s 4" or "AOP-4 Study" shall mean the study described in Appendix A, which is a 9 proposal io by TKI to ANP detailing the terms and conditions of the study. The ~~ reference in Appendix A, Section 2.2., to EPA's proposed SCR control strategy 12 means the strategy entitled "Proposed Design and Location 13 of SCR" dated April

14 21, 2017 detailed in Appendix B to this Consent Decree.

15 b. "AOP-4 Study Report" shall mean the report generated by the 16

~~ contractor performing the AOP-4 Study that describes the results of the AOP-4 is Study on the technical feasibility and the associated risks on process and 19 equipment reliability zo of the NOx abatement alternatives, including the NOX

zi control strategy described in Appendix B.

22 c. "ANP facility" shall mean the nitric acid plant owned and 23

24 operated by Apache Nitrogen Products, Inc., near Saint David, Arizona.

25 d. "AOP-4" shall mean the dual pressure nitric acid production plant 26 at the ANP '2 facility.

za e. "ADEQ" shall mean the Arizona Department of Environmental

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1 Quality. z f. "AOP-4 BACT 3 Analysis" shall mean an analysis prepared by

4 ANP to identify and assess alternative NOX control technologies for AOP-4. Any 5 such analysis shall consider technical feasibility; energy, environmental, and 6

economic impacts; and other costs consistent with Chapter B of EPA's "New a Source Review Workshop Manual—Prevention of Significant Deterioration and 9 Nonattainment io Area Permitting,"(Draft October 1990)(hereinafter "EPA NSR ~~ Manual"), but shall not include any other elements ofPSD permitting 12 (notwithstanding any reference in Chapter B). 13 The analysis shall, at a minimum,

14 include evaluation of the alternative NOX control technologies considered in the 15 AOP-4 Study as described in Appendix A to this Consent Decree. 16 ~~ g. "AOP-4"BACT Determination" shall mean the conclusion

ie reached by ADEQ after reviewing ANP's AOP-4 BACT Analysis, including the 19 identification of an ao appropriate alternative NOX control technology, if any, for ai installation and operation at AOP-4. Such determination shall be based on z2 consideration of technical feasibility; energy, environmental, and economic 23

24 impacts; and other costs consistent with Chapter B of EPA's NSR Manual, but 25 shall not include any other elements ofPSD permitting (notwithstanding any 26 reference in Chapter B); 2~ and any other information ADEQ believes is appropriate. as Such determination shall become final for purposes of this Consent Decree upon

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ANP's e~austion of any right to administrative or judicial review of the final

decision under Arizona law. For purposes of the BACT Determination and the

determination of any emissions limit for AOP-4,the applicable NSPS shall be 40

CFR Part 60 Subpart G.

h. "CAA" shall mean the Clean Air Act, as amended, 42 U.S.C.

§ 7401 et seq.

i. "Consent Decree" shall mean this Decree and any appendices attached hereto. In the event of conflict between this Decree and the Appendices, t his Decree shall control, except as to the details of the AOP-4 Study.

j. The term "day" shall mean a calendar day unless expressly stated

to be a working day.

k. "Effective Date" shall be the date of entry of this Consent Decree by the Court.

1. "EPA" shall mean the United States Environmental Protection Agency and any successor departments or agencies of the United States.

m. "Force majeure" shall mean any event that arises from causes beyond the control of ANP, of any of ANP's agents, contractors, consultants or any other entity within the control of ANP that delays or prevents the performance of any obligation under this Consent Decree despite ANP's best efforts to fulfill the obligation. "Best efforts" includes anticipating any potential force majeure

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event and addressing the effects of any such event(a) as it is occurring and (b) after it has occurred, to prevent or minimize any resulting delay to the greatest

extent possible. "Force Majeure" does not include ANP's financial inability to

perform any obligation under this Consent Decree.

n. "Interest" shall mean the statutory rate applicable to judgments, 2~ U.S.C. § 1961.

o. "NOX"shall mean all oxides of nitrogen except nitrous oxide

("N2 O").

p. "Paragraph" shall mean a portion of this Consent Decree

identified by an Arabic numeral.

q. "Parties" shall mean the United States and ANP.

r. "Plaintiff' shall mean the United States.

s. "Replacement Contractor" shall mean the contractor selected by

ANP and approved by EPA to complete the AOP-4 Study and AOP-4 Study R eport if the previously approved contractor cannot or will not perform the work for any reason within the required deadline.

t. "Section" shall mean a portion of this Consent Decree identified by a roman numeral.

u. "SCR" shall mean selective catalytic reduction, which is a type of air pollution control technology that reduces emissions of NOX.

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v. "SIP" shall mean the Arizona State Implementation Plan as

approved by EPA under the Clean Air Act.

w. "United States" shall mean the United States of America,

including all of its departments, agencies, and instrumentalities, which includes

without limitation EPA,the Settling Federal Agencies and any federal natural

resources trustee.

x. "Working day" shall mean a day other than a Saturday, Sunday,

Federal holiday. In computing any period of time under this Consent Decree,

where the last day would fall on a Saturday, Sunday, or Federal holiday, the

period shall run until the close of business of the next working day.

III. INJUNCTIVE RELIEF

8. Within thirty (30) days of the Effective Date, ANP shall enter into a

contract with TKI to commence and complete performance of the AOP-4 Study,

and to provide an AOP-4 Study Report to ANP and EPA, within eighteen (18)

months of the Effective Date. ANP shall use best efforts to provide information

described in Appendix A that is necessary for TKI to complete the AOP-4 Study,

and to enforce its contractual rights to ensure the vendor completes the AOP-4

Study as described in Appendix A. In the event ANP determines that TKI cannot or will not perform the AOP-4 Study as described in Appendix A, ANP shall provide notice to EPA of that determination in the progress reports required by

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1 Section V and shall select a Replacement Contractor to perform a comparable 2 study. Upon EPA's approval of the 3 Replacement Contractor, ANP shall enter into

4 a contract with Replacement Contractor to complete the comparable study and 5 associated report within eighteen (18) months of EPA's approval. b 9 . Within ninety (90) days of receipt of the AOP-4 Study Report(or report s for any comparable study approved by EPA), ANP shall submit an application to 9 ADEQ requesting io an AOP-4 BACT Determination. ANP's application shall, at a ~~ minimum include an AOP-4 BACT Analysis; a copy of the AOP-4 Study Report is (or report for any comparable study approved 13 by EPA); a copy of this Consent

14 D ecree, including appendices; and a copy of the Complaint filed in this matter. 15 10. Within 180 days of a final AOP-4 BACT Determination that identifies 16 an appropriate alternative ~~ NOX control technology for AOP-4, ANP shall submit a ~8 permit revision application to ADEQ requesting authorization to install and 19 such control technology zo to continue operation of AOP-4. The permit revision ~~ application shall be in the format specified by ADEQ and shall request a z2 continuously achievable emissions limit consistent with the final AOP-4 23 BACT Determination. 24 ANP shall then install and operate any such alternative NOx 25 control technology for AOP-4 according to the terms of the permit revision issued 26 by ADEQ. 2~

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1 IV. CIVIL PENALTY z 1 1. Within thirty (30) 3 days after the Effective Date of this Consent Decree,

4 or twenty (20) days after receiving payment instructions as described in Paragraph 5 ~ 12, whichever is later, ANP shall pay a civil penalty of six hundred thousand 6 d ollars ($600,000) to the United States. If payment is not made within the due s date, in addition to the civil penalty, ANP shall pay Interest accruing as of the due 9

io date through the date of payment.

~~ 12. Payments under this Consent Decree to the United States shall be made 12 by Electronic Fund Transfer("EFT") to the U.S. Treasury 13 according to current

14 United States EFT procedures. Following the Effective Date of the Consent

15 Decree, current EFT procedures shall be provided to ANP by the Financial 16 ~~ Litigation Unit of the U.S. Attorney's Office for the District of Arizona. is Concurrently with the EFT, ANP shall fax notice of payment to the person 19 designated as "Point of zo Contact" on the EFT transfer instructions, and shall send zi notice of payment to EPA and the United States Department of Justice ("DOJ") at 22 the addresses listed in Section XI (Notification) of this Consent Decree. 23 The notice 24 of payment shall identify:(1) the date and amount of money transferred; 25 (2)the name and address of the transferring bank;(3) this case by name;(4) the 26 civil action number;(5) 27 DOJ # 90-5-2-1-10736;(6) this Consent Decree (including zs the Effective Date); and (7) a description of the reason for the payment(including

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1 the paragraph number of this Consent Decree that is most relevant to the payment). 2 V. PERIODIC 3 REPORTING

4 13. Beginning thirty (30) days after the end of the second full calendar

5 quarter following the entry of this Consent Decree, and continuing on a semi- 6

annual basis until termination of this Consent Decree, and in addition to any other s express reporting requirement in this Consent Decree, ANP shall submit to EPA a 9 progress io report. The progress report shall contain the following information: ~~ a. all requested information necessary to determine compliance 12 with this Consent Decree; and 13

14 b. all information indicating the status of the AOP-4 Study and

15 Study Report, any delay or anticipated delay in completing the AOP-4 Study or the 16 ~~ Study Report, and the steps taken by ANP to mitigate such delay.

is 14. In addition to the progress reports required pursuant to this Section, 19 ANP shall provide a written zo report to Plaintiff of any violation of the requirements

ai of this Consent Decree within fifteen (15) calendar days of when ANP knew or as should have known of any such violation. In this report, ANP shall explain the 23 cause 24 or causes of the violation and all measures taken or to be taken by ANP to

25 prevent such violations in the future. 26 z~ 15. Each ANP report shall be signed by a corporate official with as m anagement responsibility for the subject matter of the notice or report, and shall

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contain the following certification:

This information was prepared either by me or under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my evaluation, or the direction and my inquiry of the persons) who manage the system, or the persons) directly responsible for gathering the information, I hereby certify under penalty of law that, to the best of my knowledge and belief, this information is true, accurate, and complete. I understand that there are significant penalties for submitting false, inaccurate, or incomplete information to the United States. to VI. REVIEW OF SUBMITTALS ~l iz 16. ANP shall submit each air quality-related permit application, plan,

13 report, or other submission required by this Consent Decree to EPA, whenever 14 such a document is is required pursuant to this Consent Decree.

16 VII. STIPULATED PENALTIES

17 17. Subject to the Force Majeure provisions of this Consent Decree, is ANP

19 shall be liable for stipulated penalties for failure to comply with the terms and

20 conditions of this Consent Decree of $1,000 per day per violation for the first thi zi as (30) days and $2,500 per day per violation for the thirty first (31St) day and beyond.

23 18. Penalties shall begin to accrue on the day after performance is due or on 24 the day a violation occurs, whichever is applicable, and shall 25 continue to accrue

26 until performance is satisfactorily completed or until the violation ceases.

27 Stipulated Penalties shall accrue simultaneously for separate violations of this 28 Consent Decree. Any stipulated penalty accruing pursuant to this Consent Decree

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1 shall be payable upon demand and due not later than thirty (30) days after ANP's 2 receipt of EPA's written demand. 3 Such demand shall be sent by certified mail.

4 19. If ANP disputes the claimed violation, ANP may initiate the dispute 5 resolution procedures set forth in this Consent Decree. Otherwise, ANP shall 6 pay the Stipulated Penalties. Subject to the Dispute Resolution procedures set forth in s this Consent Decree, Interest shall accrue on unpaid Stipulated Penalties that are 9 due io and owing thirty (30) days after ANP's receipt of EPA's written demand. ~~ Stipulated penalties shall be paid in the same manner as payment of a civil penalty. 12 20. Payment of stipulated penalties for a violation 13 of this Consent Decree

14 shall be in addition to the right of the United States to seek other judicial or

15 a dministrative relief for the violations that led to stipulated penalties. In assessing 16 penalties ~~ during any proceeding for other judicial or administrative relief, a court is or the United States may consider any payment of stipulated penalties already 19 made by ANP. In addition, zo the United States reserves its right to pursue any or all ai relief for any or all violations outside the purview of this Consent Decree. z2 21. The United States may, in the unreviewable exercise of its discretion, 23 reduce 24 or waive Stipulated Penalties otherwise due under this Consent Decree.

25 22. In the case of Dispute Resolution of Stipulated Penalties, the Stipulated 26 P a~ enalties need not be paid until the following: ze a. If the dispute is resolved by agreement or by a decision of EPA that is

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not appealed to the Court, ANP shall pay accrued penalties determined to be owing, together with Interest, within thirty (30) days of the effective date ofthe

agreement or the receipt of EPA's decision or order.

b. If the dispute is appealed to the Court and the United States prevails i whole or in part, ANP shall pay all accrued penalties determined by the Court to be

owing, together with Interest, within sixty (60) days of receiving the Court's

decision or order, except as provided in Subparagraph c, below.

c. If any Party appeals the District Court's decision, ANP shall pay any and all accrued penalties determined to be owed, together with Interest, within fifteen (15) days of receiving the final appellate court decision requiring payment of stipulated penalties.

VIII. RIGHT OF ENTRY

23. EPA and its respective contractors, consultants, and agents shall have authority to inspect ANP's facility at all reasonable times, upon proper presentation of credentials. This provision does not apply to areas not owned or under the control of ANP. In addition, this provision in no way limits or otherwise affects any right of entry held by EPA pursuant to applicable federal, state, or local laws, regulations, or permits.

IX. FORCE MAJEURE

24. ANP shall satisfy the requirements of any injunctive relief except to the

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extent, and for the period of time, that such performance is prevented or delayed a events which constitute a force 3 majeure, as defined above in Section II

4 (Definitions).

5 25. When a force majeure event occurs, the time for performance of 6 the activity delayed by the force majeure shall be extended for the time period of the s d elay attributable to the force majeure. The time for performance of any activity 9 dependent io on the delayed activity shall be similarly extended, except to the extent ~~ that the dependent activity can be implemented in a shorter time. The United is States, through EPA, shall determine whether dependent 13 activities will be delayed

14 by the force majeure and whether the time period should be extended for 15 performance of such activities. ANP shall adopt all reasonable measures to avoid 16 ~~ or minimize any delay caused by a force majeure. ie 26. When an event occurs or has occurred that may delay or prevent the 19 performance of any zo obligation under this Consent Decree, ANP shall provide

21 written notification to the Chief, Air & TRI Section, Enforcement Division of 22 EPA, Region 9, within twenty (20) days of ANP's knowledge of such 23 event. The written 24 notification shall fully describe: the event that may delay or prevent 25 performance; reasons for the delay; whether ANP claims that the delay resulted 26 from an event ~~ which qualifies as a force majeure; the reasons any such delay is zs beyond the reasonable control of ANP; the anticipated duration of the delay;

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1 actions taken or to be taken to prevent or minimize the delay; a schedule for

implementation of any measures to be taken to mitigate 3 the effect of the delay; and

4 the time needed to implement any dependent activities. For purposes of this

5 Section, ANP will be deemed to have known of any circumstance that any of 6 ANP's agents, contractors, consultants, or any other entity within the control of s ANP,knew or should have known. 9

io 27. ANP's failure to comply with the force majeure notice requirements ~~ provided herein for any delay in performance will be deemed an automatic 12 forfeiture of its right to assert that the delay was caused by a force majeure. 13

14 28. After receiving notice from ANP of a force majeure, the United States,

15 through EPA, shall provide written notification to ANP stating whether it agrees 16 ~~ that there was a force majeure event and whether ANP's request for a delay is

is justified. If the United States does not respond to a request for a delay within 19 (30) days, the failure to respond ao may be treated by ANP as a denial of the request. ai If ANP disagrees with the United States' force majeure determination, ANP may zz initiate dispute resolution as set forth in this Consent Decree. 23

24 X. DISPUTE RESOLUTION

25 29. Unless otherwise expressly provided for in this Consent Decree, the 26 Dispute z~ Resolution procedures of this Section shall be the exclusive mechanism to as resolve disputes arising under or with respect to this Consent Decree. With respect

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1 to any dispute or allegation expressly raised by the United States concerning a ANP's compliance with the Consent Decree, ANP's failure 3 to seek resolution of a

4 dispute under this Section shall preclude ANP from raising any such issue as a

5 defense to an action by the United States to enforce any obligation of ANP arising 6 under this Consent Decree.

a 30. Informal Dispute Resolution. Any dispute subject to Dispute 9 io Resolution under this Consent Decree shall first be the subject of informal ~~ negotiations. The dispute shall be considered to have arisen when a written Notice 12 of Dispute is sent by ANP. Such Notice of Dispute shall state clearly the matter in 13

14 dispute. The period of informal negotiations shall not exceed thirty (30) days from

15 the date the dispute arises, unless that period is modified by written agreement. If 16 ~~ the Parties cannot resolve a dispute by informal negotiations, then the position ie advanced by the United States shall be considered binding unless, within thirty 19 (30) days after the conclusion ao of the informal negotiation period, ANP invokes

21 formal Dispute Resolution procedures as set forth below.

22 31. Formal Dispute Resolution. ANP shall invoke formal Dispute 23

24 Resolution procedures, within the time period provided in the preceding Paragra

25 by serving on the United States a written Statement of Position regarding the 2 6 'I matter a~ in dispute. The Statement of Position shall include, but may not necessarily ae be limited to, any factual data, analysis, or opinion supporting ANP's position and

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1 any supporting documentation relied upon by ANP. z 32. The United States shall serve its Statement 3 of Position within forty-five

4 (45) days of receipt of ANP's Statement of Position. The Statement of Position of 5 the United States shall include, but may not necessarily be limited to, any factual 6 ~ ~ data, analysis, or opinion supporting that position and any supporting s documentation relied upon by the United States. The United States' Statement of 9 Position io shall be binding on ANP, unless ANP files a motion for judicial review of ~~ the dispute in accordance with the following Paragraph. 12 33. ANP may seek judicial review of the dispute by filing with the 13 Court

14 and serving on the United States, in accordance with the Notice provisions of this

15 Consent Decree, a motion requesting judicial resolution of the dispute. The moti 16 ~~ must be filed within thirty (30) days of receipt of the United States' Statement of is Position pursuant to the preceding Paragraph. The motion shall contain a written 19 statement of ANP's position zo on the matter in dispute, including any supporting ~~ factual data, analysis, opinion, or documentation, and shall set forth the relief z2 requested and any schedule within which the dispute must be resolved for orderly 23

24 implementation of the Consent Decree.

25 34. The United States shall respond to ANP's motion within the time period 26 allowed by the Local 2~ Rules of this Court. ANP may file a reply memorandum, to as the extent permitted by the Local Rules.

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1 35. In any dispute ANP shall bear the burden of demonstrating that its

position complies with this Consent Decree 3 and that ANP is entitled to relief under

4 applicable law. The United States reserves the right to argue that its position is 5 reviewable only on the administrative record and must be upheld unless arbitrary 6

and capricious or otherwise not in accordance with law. If the United States a invokes this right, the United States shall compile an administrative record of the 9

to dispute containing all Statements of Position, including supporting documentation ~~ and referenced data or information, and ANP shall have the burden of 1a demonstrating, based on the administrative record, that the position 13 of the United

14 States is arbitrary and capricious or otherwise not in accordance with law.

15 36. The invocation of Dispute Resolution procedures under this Section 16 ~~ shall not, by itself, extend, postpone, or affect in any way any obligation of ANP is under this Consent Decree, unless and until the Court so orders. Stipulated 19 Penalties with respect to 20 the disputed matter shall continue to accrue from the first ai day of noncompliance, but payment shall be stayed pending resolution of the as dispute. If ANP does not prevail on the disputed issue, Stipulated Penalties shall 23

24 be assessed and paid as provided in this Consent Decree.

25 XI. NOTIFICATION 26 37. Except 2~ as otherwise specifically stated herein, all notices and as submissions required by this Consent Decree shall be sent by certified mail,

23 Case 4:17-cv-00612-RCC Document 3 Filed 12/20/17 Page 24 of 62

1 express mail, or similar overnight mail delivery service with return receipt 2 requested. 3

4 38. All notices and reports by ANP shall be signed and affirmed by a 5 corporate official with management responsibility for the subject matter of the 6 notice or report, using the following certification: s I certify that this information was prepared under my direction 9 or supervision in accordance with a system designed to assure io that qualified personnel properly gather and evaluate the information to be submitted. Based on my directions and my ~~ inquiry of those individuals immediately responsible for 12 obtaining the information to be submitted, I certify that the information is true, accurate, and complete to the 13 best of my knowledge, information, and belief. I am aware that there are 14 significant penalties for submitting false information, including the possibility of 15 fines and imprisonment.

16 All notices and reports submitted to EPA or DOJ shall refer to this Consent ~~ D ie ecree and the date of entry of the Consent Decree, and shall cite the case name of

19 United States v. Apache Nitrogen Products, Inc., the case number, and DOJ # 90- ao 5-2-1-10736. ai az 39. Notices and reports to the United States as required by this Consent 23 Decree shall be submitted to: 24

25 if by regular mail or post office express mail:

26 Chief, Environmental Enforcement Section a~ Environment &Natural Resources Division United as States Department of Justice P.O. Box 7611

24 Case 4:17-cv-00612-RCC Document 3 Filed 12/20/17 Page 25 of 62

Washington, D.C. 20044 7611

if by private overnight mail service:

Chief, Environmental Enforcement Section Environment &Natural Resources Division United States Department of Justice 601 D St. NW Washington, D.C. 20005

and to:

Allan Zabel(ORC-2) U.S. Environmental Protection Agency 75 Hawthorne Street San Francisco, CA 94105

Director, Enforcement Division U.S. Environmental Protection Agency 75 Hawthorne Street San Francisco, CA 94105 Attn: Charles Aldred(ENF 2-1)

Director, Air Enforcement Division U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, NW Mail Code: 2242A Washington, DC 20460

Notices to ANP as required by this Consent Decree shall be submitted to: Jeremy Barrett President &General Manager Apache Nitrogen Products, Inc. 1436 S. Apache Powder Rd., St. David, AZ 85630 Mail: P.O. Box 700, Benson, AZ 85602 [email protected]

25 Case 4:17-cv-00612-RCC Document 3 Filed 12/20/17 Page 26 of 62

and to:

Chris Leason Gallagher &Kennedy,PA 2575 East Camelback Road Suite 1100 Phoenix, AZ 85016 [email protected]

XII. EFFECT OF SETTLEMENT/RESERVATION OF RIGHTS

40. Entry of this Consent Decree and compliance with the requirements herein shall resolve and shall be in full settlement and satisfaction of the civil claims of the United States against ANP as alleged in the Finding and Notice of

Violation, dated July 23, 2012, and the Complaint concurrently filed in this action through the lodging of this Consent Decree.

41. Except as specifically provided herein, the United States does not waive any rights or remedies available to it for violation by ANP of federal or state laws or regulations. This Consent Decree shall in no way affect the United States' ability to bring future actions for any claims not alleged in the Complaint or the

Finding and Notice of Violation, dated July 23, 2012, in this case or for claims subject to an express reservation. This Consent Decree does not relieve ANP of any criminal liability.

42. This Consent Decree in no way affects ANP's responsibilities to comply with all federal, state, or local laws and regulations.

26 Case 4:17-cv-00612-RCC Document 3 Filed 12/20/17 Page 27 of 62

43. This Consent Decree does not limit or affect the rights of ANP or of the

United States against any third parties, not party to this Consent Decree, nor does it

limit the rights of third parties, not parties to this Consent Decree, against ANP,

except as otherwise provided by law. This Consent Decree shall not be construed

to create rights in, or grant any cause of action to, any third party not party to this

Consent Decree.

XIII. COSTS

44. The Parties shall bear their own costs of this action, including attorneys' fees.

XIV. TERMINATION

45. This Consent Decree shall terminate after ANP has completed and

satisfied all of the following requirements of this Consent Decree and the

termination procedure set forth below:

a. completion of the injunctive relief specified in this Consent Decree;

and

b. payment of all penalties and other monetary obligations due under the

terms of this Consent Decree.

46. If ANP believes that it has satisfied the requirements for termination set forth above, ANP shall certify such compliance and completion to the United

States in writing. Unless, within sixty (60) days of receipt of ANP's certification,

z~ Case 4:17-cv-00612-RCC Document 3 Filed 12/20/17 Page 28 of 62

the United States objects in writing with specific reasons, the Court may upon

motion by ANP order that this Consent Decree be terminated. If the United States objects to the certification by ANP,then the matter shall be submitted to the Court ~ or f resolution under the dispute resolution provisions of this Consent Decree. In

such case, ANP shall bear the burden of proving that this Consent Decree should

be terminated.

XV. MISCELLANEO

47. The terms of this Consent Decree may be modified only by a

subsequent written agreement signed by the United States and Defendants. Where

the modification constitutes a material change to any term of this Consent Decree,

it shall be effective only upon approval by the Court.

48. The Effective Date of this Consent Decree shall be the date upon which

this Consent Decree is entered by the Court.

49. The Court shall retain jurisdiction over this case until termination of this

Consent Decree, for the purpose of resolving disputes arising under this Consent

Decree or entering orders modifying this Consent Decree or effectuating or

enforcing compliance with the terms of this Consent Decree.

50. The Parties represent that each undersigned signatory signing on their

behalf has full authority to sign the Consent Decree and to bind said party to the terms and conditions of the Consent Decree.

as Case 4:17-cv-00612-RCC Document 3 Filed 12/20/17 Page 29 of 62

51. ANP agrees and acknowledges that final approval of this Consent

Decree by the United States and entry of this Consent Decree is subject to the requirements of 28 C.F.R. § 50.7, which provides for notice of the lodging of this

Consent Decree in the Federal Register, opportunity for public comment for at least thirty (30) days, and consideration of any comments prior to entry of the

Consent Decree by the Court. The United States reserves the right to withdraw consent to this Consent Decree based on comments received during the public notice period. ANP consents to entry of this Consent Decree without further noti to the Court. Upon approval and entry, this Consent Decree shall constitute a final judgment under Rules 54 and 58 of the Federal Rules of Civil Procedure.

29 Case 4:17-cv-00612-RCC Document 3 Filed 12/20/17 Page 30 of 62

IT IS SO ORDERED

DATED this day of , 2017.

LJIVITED STATES DISTRICT JUDGE

30 Case 4:17-cv-00612-RCC Document 3 Filed 12/20/17 Page 31 of 62

Signature page for Consent Decree in United States v. Apache Nitrogen Products, Inc.

'FOR THE PLAINTIFF LJr1ITED STATES OF AMERICA:

DATE: 1~ ~ ~ ~ l , LEN M. MAHAN Deputy Section Chief Environmental Enforcement Section Environment &Natural Resources Division United-~ta~es Department of Justice ~) DATE: Z ~ J S . Mac~YEAL Se for ounsel E i nmental Enforcement Section Environment &Natural Resources Division United States Department of Justice P.O. -Box 7611 Washington, D.C. 20044-7611

31 Case 4:17-cv-00612-RCC Document 3 Filed 12/20/17 Page 32 of 62

1 Signature page for Consent Decree in United States v. Apache Nitrogen Products, Inc. 2

3 FOR THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY: 4

5 Office of Enforcement and Compliance Assurance' 6 United States Environmental Protection Agency

7

s DATE: ~ Z l L~tI ('~- By: 9 SYLV UA

10 Regional Counsel United States Environmental Protection Agency ~~ Region 9 is 75 Hawthorne Street San Francisco, CA 94105 13

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28 Case 4:17-cv-00612-RCC Document 3 Filed 12/20/17 Page 33 of 62

1 Signature page for Consent Decree in United States v. Apache Nitrogen Products, Inc. a

3 4 DATE:,. ~ ~ ~ s 5 ALEXIS STRAUSS Acting Regional Administrator 6 United States Environmental Protection Agency 7 Region 9

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10 Of Counsel: ~~ ALLAN ZABEL iz Office of Regional Counsel(ORC-2) United States Environmental Protection Agency Region 1 9 3 75 Hawthorne Street 14 San Francisco, CA 94105

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33 Case 4:17-cv-00612-RCC Document 3 Filed 12/20/17 Page 34 of 62

1 ~ Signature page for Consent Decree in United States v. Apache Nitrogen Products, Inc. z

3 ~ FOR THE DEFENDANT APACHE r1ITR4GEN PRODUCTS,INC.: 9

5

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7 ', DATE: August 1, 2017 B Name: Jeremy R. Barrett 9 Title: President and General Manager 10

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35 Case 4:17-cv-00612-RCC Document 3 Filed 12/20/17 Page 36 of 62 thyssenivupp Industrial Solutions (USA), Inc. .,^ 6400 S. Fiddler's Green Circle, Suite 700 Greenwood Village, CO 80111 ~~~ •~

• ~

Proposal for Nitric Acid Plant Simulation and DeNOx Budget

Presented to Apache Nitrogen Products Inc.

Prepared by thyssenkrupp Industrial Solutions (USA), Inc. Rev. 4— 30 November 2017 Case 4:17-cv-00612-RCC Document 3 Filed 12/20/17 Page 37 of 62

thyssenlvupp Industrial Solutions (USA), Inc. 6400 S. Fiddler's Green Circle, Suite 700 Greenwood Village, CO 80111 ~~,,•1'~~~ t ~

This Proposal and all pertinent or attached documents remain property of thyssenla-upp

Industrial Solutions (USA), Inc. and shall neither be fully or partly copied or reproduced nor

made accessible or brought to the Imowledge of third parties or competitors, unless express

approval from thyssenkrupp Industrial Solutions (USA), Inc. has first been obtained.

Apache Nitrogen -Nitric Acid Plant Simulation and DeNOx Budget Page 2 of 13 Rev. 4 — 30 November 2017 Case 4:17-cv-00612-RCC Document 3 Filed 12/20/17 Page 38 of 62

thyssenlvupp Industrial Solutions (USA), Inc. 6400 ~. Fiddler's Green Circle, Suite 700 Greenwood Village, CO 80111 i'''''/~~~

~ •

Proposal Contents

1 Background ...... 4 1.1 Project Description ...... 4

2 Scope of Work ...... g

2.1 AOP4 Base Case Simulation ...... 6

2.1.1 Deliverables ...... g

2.2 AOP4 Nitric Acid Plant DeNOx Budgetary Proposal ...... 7

2.2.1 Deliverables ...... 7

2.2.2 Preliminary Red-line PFDs ...... 7 2.2.3 Preliminary Emissions Summary ...... 7 2.2.4 Preliminary Update Points Updated Plot Plan ...... 7

2.3 AOP4 DeNOx Installation Simulation ...... 8 2.3.1 Deliverables ...... 8

2.3.2 Submission of Report ...... 9 2.4 ANPI Obligations ...... 9 2.5 Meetings ...... 10 2.6 Time Schedule ...... 10

2.7 Commercial Terms and Conditions ...... 10 2.7.1 Pricing ...... 10 2.7.2 Payment Schedule ...... 11

2.7.3 Taxes ...... 12

2.7.4 Bid Validiry ...... 12

Apache Nitrogen -Nitric Acid Plant Simulation and DeNOx Budget Page 3 of 13 Rev. 4 — 30 November 2017 Case 4:17-cv-00612-RCC Document 3 Filed 12/20/17 Page 39 of 62

thyssenivupp Industrial Solutions(USA), Inc. 6400 S. Fiddler's Green Circle, Suite 700 Greenwood Village, CO 80111 `'''''1~~~ • ~ 1 Background

Apache Nitrogen Products Inc. (ANPI) operates the dual pressure, Chemico Design AOP4 nitric acid plant in Benson, AZ. This plant was commissioned in the 1970s and includes an extended absorption tower with a chilled water loop. The U.S. Environmental Protection Agency (EPA) and Department of Justice have questioned the feasibility of reducing the nitrogen oxide (NOx) emissions of the AOP4 plant. A voluntary Best Available Control Technology (BACT) evaluation was done to evaluate the installation and operation of a NOx abatement (DeNOx) system and concluded that the additional back pressure may have a detrimental effect on the air compressor set. After deliberations with EPA, it was agreed that a simulation will be conducted to review if a DeNOx system can be installed without the risk of damaging the system. If not possible, the limitations need to be identified; if possible, the location and design need to be identified.

thyssenkrupp Industrial Solutions (USA), Inc. (thyssenkrupp) visited the AOP4 plant August 23- 25. While at the site, the thyssenkrupp team observed the plant operation and talked with operators about how the facility operates. The team collected their results in a Visit Report. In addition, on January 24, 2017, ANPI, thyssenkrupp, and EPA's technical expert met to discuss the study and agree upon a path forward.

1.1 Project Description

During the January 2017 visit, the group agreed that thyssenkrupp would:

1. Develop a working process simulation model for the AOP4 process. As part of the simulation effort identify, additional locations for sampling points and instrumentation necessary to refine the simulation. thyssenkrupp will provide this feedback to ANPI such that ANPI can install the appropriate equipment and provide necessary information.

2. Evaluate two DeNOx technologies for suitability: Uhde DeNOx and Uhde EnviNOxO

3. Utilize the process simulation model to simulate addition of the potential DeNOx technologies to determine viability.

4. Develop a budgetary design and proposal for the appropriate DeNOx system, including budgetary cost estimate. Installation pre and post expander as well as the potential for use of a bypass stack will be evaluated.

5. Develop a summary report for ANPI on the technical feasibility and the associated risks on process and equipment reliability of the NOx abatement alternatives.

Apache Nitrogen -Nitric Acid Plant Simulation and DeNOx Budget Page 4 of 13 Rev. 4 — 30 November 2017 Case 4:17-cv-00612-RCC Document 3 Filed 12/20/17 Page 40 of 62

thyssenlvupp Industrial Solutions(USA), Inc. 6400 S. Fiddler's Green Circle, Suite 700 Greenwood Village, CO 80111 ~~•,•1'~~/ thyssenkrupp Develop a working model and provide support to enable process optimization and continuous improvement initiatives.

This proposal contains a cost estimates for the completion of these two steps executed concurrently.

Apache Nitrogen -Nitric Acid Plant Simulation and DeNOx Budget Page 5 of 13 Rev. 4 — 30 November 2017 Case 4:17-cv-00612-RCC Document 3 Filed 12/20/17 Page 41 of 62

thyssenlvupp Industrial Solutions(USA), Inc. 6400 S. Fiddler's Green Circle, Suite 700 Greenwood Village, CO 80111 /~•••','~~ t ~ 2 Scope of Work 2.1 AOP4 Base Case Simulation

The proposed simulation scope of work for this effort consists of the following activities:

1. Modeling of the AOP4 nitric acid plant utilizing ProSimPlus HNO3 based on operating data from the AOP4 facility.

2. Verification of the simulation model against different observed operating cases at the AOP4 facility (Gauze Start of Life and End of Life, Compressor Start of Life and End of Life and Turndown).

3. Model report.

2.1.1 Deliverables

The model report consists of the following (for each case):

2.1.1.1 Heat and Material Balance

Heat and material balance for the 5 design cases identified in section 2.1 item 2.

2.1.1.2 Simulation flowsheet

Flowsheet from ProSimPlus HNO3 simulation indicating all streams and unit ops.

2.1.1.3 Temperature profile

Temperature profile for the five design cases identified in section 2.1 item 2.

2.1.1.4 Pressure profile

Pressure profile for the five design cases identified in section 2.1 item 2.

2.1.1.5 Tail gas composition

Tail gas composition of NOx components for the five design cases identified in section 2.1 item 2.

Apache Nitrogen -Nitric Acid Plant Simulation and DeNOx Budget Page 6 of 13 Rev. 4 — 30 November 2017 Case 4:17-cv-00612-RCC Document 3 Filed 12/20/17 Page 42 of 62

thyssenlvupp Industrial Solutions(USA), Inc. 6400 S. Fiddler's Green Circle, Suite 700 Greenwood Village, CO 80111 thyssenkrupp 2.2 AOP4 Nitric Acid Plant DeNOx Budgetary Proposal

The DeNOx Budgetary Proposal consists of the following:

1. Preliminary design of an Uhde technology NOx abatement system (Uhde DeNOx or Uhde EnviNOxO) detailed below. (This design will consider potential installation of a NOx abatement system pre and post expander as well as the potential for use of a bypass stack as per EPA request, and described in the document entitled "Proposed Design and Location of SCR," dated April 21, 2017.)

2. Budgetary cost estimate for the engineering and procurement of the NOx abatement system based on the preliminary design.

2.2.1 Deliverables

2.2.1.1 Name-Only Equipment List

The preliminary equipment consists of:

• Equipment name and tag

• Preliminary process sizing dimensions

• Preliminary material selection

• Preliminary design conditions

2.2.2 Preliminary Red-line PFDs

The preliminary red-line PFDs consists of:

• Red-line mark-ups of ANPI's existing PFDs indicating tie-point locations for new equipment and piping

2.2.3 Preliminary Emissions Summary

The preliminary emissions summary indicates the anticipated NOx emissions once the DeNOx system is installed.

2.2.4 Preliminary Update Points Updated Plot Plan

The preliminary updated plot plan indicates the location of all tie points.

Apache Nitrogen -Nitric Acid Plant Simulation and DeNOx Budget Page 7 of 13 Rev. 4 — 30 November 2017 Case 4:17-cv-00612-RCC Document 3 Filed 12/20/17 Page 43 of 62

thyssenlvupp Industrial Solutions(USA), Inc. 6400 S. Fiddler's Green Circle, Suite 700 Greenwood Village, CO 80111 thyssenkrupp 2.3 AOP4 DeNOx Installation Simulation

Once suitable DeNOx alternatives have been identified, the ProSimPlus HNO3 simulation will be updated to incorporate the DeNOx system to determine the impact of the DeNOx system installation on the operations of the AOP4 facility. The output of these simulations will be included in the model report.

The AOP4 simulation will only be verified against operating data provided by ANPI during the course of the study. Data collected during this period will not represent all potential operating conditions possible within the facility. Any operation outside of the range of data collected during this project cannot be guaranteed by the simulation. thyssenkrupp will assure that the design of new equipment and systems will contain safeguards to protect equipment and personnel.

2.3.1 Deliverables

The model report consists of the following (for each case):

2.3.1.1 Heat and Material Balance

Updated heat and material balance for the five design cases (Gauze Start of Life, End of Life, Compressor Start of Life, End of Life, and Turndown) incorporating the DeNOx system.

2.3.1.2 Simulation flowsheet

Flowsheet from ProSimPlus HNO3 simulation indicating all streams and unit ops incorporating the DeNOx system.

2.3.1.3 Temperature profile

Temperature profile for the five design cases identified in section 2.1 item 2 incorporating the DeNOx system.

2.3.1.4 Pressure profile

Pressure profile for the five design cases identified in section 2.1 item 2 incorporating the DeNOx system.

2.3.1.5 Tail gas composition

Tail gas composition of NOx components for the five design cases identified in section 2.1 item 2 incorporating the DeNOx system.

Apache Nitrogen -Nitric Acid Plant Simulation and DeNOx Budget Page 8 of 13 Rev. 4 — 30 November 2017 Case 4:17-cv-00612-RCC Document 3 Filed 12/20/17 Page 44 of 62

thyssenlvupp Industrial Solutions(USA), Inc. 6400 S. Fiddler's Green Circle, Suite 700 Greenwood Village, CO 80111 thyssenkrupp 2.3.2 Submission of Report

The model report will be submitted simultaneously to ANPI and EPA.

2.4 ANPIObligations

thyssenkrupp will provide ANPI with an initial list of operating data points to be collected as the basis of the model. ANPI is responsible to respond to thyssenkrupp with a timeline for collecting this data within five (5) business days of submission. This data will include, but is not limited to:

• Operating temperatures

• Operating pressures

• Operating flowrates

• Nitric Acid yield

• Stream Composition

• PFDs of existing plant

• P&IDs of existing plant

• Layout and arrangement plans of existing plant

Should accurate figure for the data request be unavailable due to limitations within the AOP4 instrumentation system, ANPI is responsible to inform thyssenkrupp within the same time frame so that other provisions may be made. Over the course of the effort, thyssenkrupp may request additional operating data for use in model verification. thyssenkrupp will formally submit a request for additional information, at which point ANPI will have five days to provide the timeline to supply requested operating data.

Upon receipt of data, thyssenkrupp will evaluate data quality for simulation purposes and inform ANPI of status prior to running simulations. If data is not of quality to allow for reasonable simulation, thyssenkrupp will inform ANPI and hold on proceeding with simulation so as not to unnecessarily expend hours trying to verify simulation with poor quality data. It may not to be possible to determine data quality prior to simulation efforts with every data set, but thyssenkrupp will endeavor to do so.

Apache Nitrogen -Nitric Acid Plant Simulation and DeNOx Budget Page 9 of 13 Rev. 4 — 30 November 2017 Case 4:17-cv-00612-RCC Document 3 Filed 12/20/17 Page 45 of 62

thyssenlvupp Industrial Solutions(USA), Inc. 6400 S. Fiddler's Green Circle, Suite 700 Greenwood Village, CO 80111 ~~•,•1'~~~ t ~ 2.5 Meetings

During the execution of this effort, thyssenkrupp has not assumed any expenses for in-person meetings requiring travel. Any travel for meetings will be reimbursed at cost + 10%.

2.6 Time Schedule

See Attachment 1: Preliminary Time Schedule.

2.7 Commercial Terms and Conditions

thyssenkrupp has included a commented, sample "Master Services Agreement" supplied by ANPI that could be utilized as the basis of the agreement if mutually agreed upon. This agreement still requires further internal review by thyssenkrupp. This agreement could also serve as the basis for future work performed by thyssenkrupp for ANPI.

2.7.1 Pricing

The pricing of the project consists of two components:

2.7.1.1 DeNOx budgetary proposal price

Assuming that the DeNOx system design utilizes thyssenkrupp standardized proprietary information, the DeNOx budgetary proposal will be performed on a lump-sum basis with price for this effort of:

USD 15,000.00 (Fifteen Thousand US Dollars)

Apache Nitrogen -Nitric Acid Plant Simulation and DeNOx Budget Page 10 of 13 Rev. 4 — 30 November 2017 Case 4:17-cv-00612-RCC Document 3 Filed 12/20/17 Page 46 of 62

thyssenlvupp Industrial Solutions(USA), Inc. 6400 S. Fiddler's Green Circle, Suite 700 Greenwood Village, CO 80111 thyssenkrupp 2.7.1.2 DeNOx budgetary proposal price

Due to the fact that the simulation work is contingent upon availability and access to information this effort will be performed on a reimbursable basis utilizing the following man-hour rates:

the estimated price for this effort is:

USD 94,000.00 (Ninety Four Thousand US Dollars)

Note:

The price is subject to change based on the actual level of effort required for the completion of the simulation model.)

1Man-hour rates valid through 30 September 2018, rates subject to revision 1 October 2018.

ZThis rate is based on the EURO converted into an USD amount at exchange rate of 1.09 USD/EUR using fixed by European Central Bank (ECB}. Upon the date of invoicing if the exchange rate published by the European Central Bank (ECB) fluctuates by more than 10% (Ten Percent) either way the rate will be adjusted accordingly. ECB's official website is http://sdw.ecb.europa.eu/.

Total budgetary price of lump sum and reimbursable components: USD 109,000.00 (One Hundred NineThousand US Dollars)

2.7.2 Payment Schedule

The Payment Schedule for the Services described in this Proposal is as follows:

Retainer —Upon contract execution 25% of Total Estimated Price in 2.6.1 At the end of each 4 week period Billed actual hours x Rate for previous 4 weeks Delivery of Final Deliverables Final payment (Actual Hours for previous 4 weeks —Retainer) of Total Price in 2.6.1 "All invoices are net

Apache Nitrogen -Nitric Acid Plant Simulation and DeNOx Budget Page 11 of 13 Rev. 4 — 30 November 2017 Case 4:17-cv-00612-RCC Document 3 Filed 12/20/17 Page 47 of 62

thyssenlvupp industrial Solutions(USA), Inc. 6400 S. Fiddler's Green Circle, Suite 700 Greenwood Village, CO 80111 thyssenkrupp 2.7.3 Taxes

All taxes are excluded from this Proposal and will be the responsibility of ANPI.

2.7.4 Bid Validity

This offer will be valid for acceptance until 28 February 2018.

Apache Nitrogen -Nitric Acid Plant Simulation and DeNOx Budget Page 12 of 13 Rev. 4 — 30 November 2017 Case 4:17-cv-00612-RCC Document 3 Filed 12/20/17 Page 48 of 62

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