From: "Bon - CDPHE, Daniel" <daniel.bon@state.co.us>

Subject: Re: Pneumatic Controllers

Date: November 1, 2013 4:52:08 PM EDT

To: David McCabe <dmccabe@catf.us>

David,

I did just speak to Kirsten King, our Stationary Sources Program Director. She unequivocally says we have not received a single request for an

exemption for any pneumatic device under this section of Reg. 7. She is the highest authority we have at CDPHE on this matter. 

Hope that helps.

Daniel

On Fri, Nov 1, 2013 at 2:03 PM, David McCabe <dmccabe@catf.us> wrote:

Thanks!!! 

I would like an official answer (so we can cite it) - maybe not right away if that is not easy. 

David McCabe

dmccabe@catf.us

+1 626 710 6542

On Nov 1, 2013, at 4:01 PM, Bon - CDPHE, Daniel wrote:

Hi David,

Nice to see you too. I did do a little asking around. Top people in our oil and gas permitting team are definitely aware of the wording (referred to in

your email) that would allow such petitions to be filed. None of the people I spoke with had ever seen or heard of any such exemptions being applied

for, let alone granted. I would say that the number is vanishingly small, close to zero. The person who would be able to answer officially and

definitively has been on vacation but should be back next week.

So to answer your question, I do not think there are many, if any such petitions. If you need an official response from the Division, let me know and I

can figure out how to get it to the right people.

Hope you had a great Halloween!

Daniel

On Fri, Nov 1, 2013 at 12:56 PM, David McCabe <dmccabe@catf.us> wrote:

Hi Dan,

It was good to see you at the meeting in Boulder last week.

I have a couple questions about pneumatic controllers.

Section XVIII.C of Reg. 7 - current text - require all NEW pneumatic controllers placed in service in the 8-hr O3 Control Area (or any other O3 nonattainment or maintenance area) since 2/1/09 to be low-bleed, unless "the o/o shall submit justification for high-bleed pneumatic controllers to be

installed due to safety and /or process purposes prior to installation."

Likewise, the section requires all EXISTING hi-bleed pneumatic controllers (installed before 2/1/09) in the O3 area(s) to be replaced with lo-bleed

controllers by 5/1/09, unless the o/o submitted justification as above by 3/1/09.

My questions:

- How many justifications have been submitted for new higher bleed controllers? Of those, is a breakdown available between justification for hibleed continuous bleed controllers, and intermittent bleed controllers? (Intermittent bleeds have a typical emissions HIGHER than low (continuous)

bleed devices - see the UT study for example. And they appear to be the most common type.)

- How many justifications have been submitted to keep hi-bleed controllers in operation?

- Of these justifications, if any have been denied, I would also like to know how many.

Give me a call if you have any questions about these questions. I really appreciate any help you can give us - this would be very useful
information.

David

David McCabe

dmccabe@catf.us

+1 626 710 6542

-- 

Daniel Bon

Air Quality Planner

Planning and Policy, Air Pollution Control Division

Colorado Department of Public Health and Environment

4300 Cherry Creek Drive South

Denver, CO 80246-1530

daniel.bon@state.co.us

303.692.6302

-- 

Daniel Bon

Air Quality Planner

Planning and Policy, Air Pollution Control Division

Colorado Department of Public Health and Environment

4300 Cherry Creek Drive South

Denver, CO 80246-1530

daniel.bon@state.co.us

303.692.6302