Denver Metropolitan Area and North Front Range 

8-Hour Ozone 

State Implementation Plan 

Technical Support Document 

For 

Proposed Pneumatic Controller Regulation 

DRAFT 

November 5, 2008 

Colorado Department of Public Health and Environment 

Air Pollution Control Division 

4300 Cherry Creek Drive South 

Denver, Colorado 80246 
Colorado Department of Public Health and Environment / Air Pollution Control Division 

ii

DRAFT - Denver Metro Area/North Front Range 8-hr Ozone SIP 

Technical Support Document for Proposed Pneumatic Controller Regulation 
Colorado Department of Public Health and Environment / Air Pollution Control Division 

 

Table of Contents 

1. PROPOSED REGULATION ...............................................................................................................................1

2. WHAT IS A PNEUMATIC DEVICE?................................................................................................................1

3. WHY WAS THIS PROPOSED REGULATION DEVELOPED? ....................................................................2

4. WHY IS THIS PROPOSED REGULATION REASONABLE?.......................................................................2

4.1. TIMEFRAME ....................................................................................................................................................2

4.2. ASSOCIATED COSTS........................................................................................................................................2

4.3. CONVERSION EFFECTIVENESS.........................................................................................................................3

4.4. EMISSION THRESHOLD....................................................................................................................................3

4.5. APPLYING REGULATION TO ONLY HIGH-BLEED DEVICES ..............................................................................3

5. DATA AND CALCULATIONS...........................................................................................................................4

5.1. EMISSION REDUCTION ....................................................................................................................................4

6. REFERENCES ......................................................................................................................................................6

ATTACHMENT 1 - PNEUMATIC DEVICE PROPOSED REGULATION DATA AND CALCULATIONS.....7

 

iii

DRAFT - Denver Metro Area/North Front Range 8-hr Ozone SIP 

Technical Support Document for Proposed Pneumatic Controller Regulation 
Colorado Department of Public Health and Environment / Air Pollution Control Division 

iv

DRAFT - Denver Metro Area/North Front Range 8-hr Ozone SIP 

Technical Support Document for Proposed Pneumatic Controller Regulation 
Colorado Department of Public Health and Environment / Air Pollution Control Division 

1. Proposed Regulation 

Regulation being proposed to the Air Quality Control Commission in Fall 2008 would require that 

high-bleed natural gas actuated pneumatic controllers in ozone non-attainment areas (NAAs) be 

replaced or retrofit (converted) to low-bleed controllers, unless they are exempt. The proposed 

regulation would also allow for other means to reduce emissions, such as using a solar device or a 

device that is actuated, or powered, using compressed air. Inspections, enhanced maintenance, and 

recordkeeping would be required for remaining exempt high-bleed controllers. Implementation of 

this proposed regulation would lead to a reduction in emissions of volatile organic compounds 

(VOCs), which are precursors to ozone. 

Most background information and data used to develop the proposed regulation were obtained 

from either the Environmental Protection Agency (EPA) Gas STAR program or Independent 

Petroleum Association of Mountain States (IPAMS). Both sources use the term pneumatic 

“device”, while the Colorado Air Pollution Control Division (Division) has chosen to be more 

specific by using the term pneumatic “controller” in the proposed regulation. A pneumatic device 

generally consists of a controller and a valve. The term “device” is used throughout this document 

to be consistent with data provided by EPA Gas STAR program and IPAMS. 

2. What is a pneumatic device? 

Many types of process control devices can be used to operate valves that regulate pressure, flow, 

temperature, and liquid levels. These devices can be operated pneumatically, electrically, or 

mechanically. A pneumatic device is an instrument that is actuated using gas. Most of the devices 

used by the natural gas industry are pneumatically operated. Although instrument air is commonly 

used to power pneumatic devices at gas processing facilities, since electricity is readily available to 

power air compressors at the facilities, the majority of natural gas industry pneumatic devices are 

powered by natural gas since electricity is not readily available at remote locations.1

 

As part of normal operation, most pneumatic devices emit, or “bleed”, gas to the atmosphere, 

either continuously or intermittently. Pneumatic devices generally consist of a controller and a 

valve. Bleed rates are associated with the controller. Gas is vented to atmosphere during 

actuation when valves open and/or close. However, vent rates are not significant and are the same 

whether a high-bleed or low-bleed controller is used. The proposed regulation would address 

bleed rates from controllers that are actuated by natural gas. It will not address valve vent rates or 

controllers actuated by compressed air. 

By definition, high-bleed pneumatic devices emit in excess of 6 standard cubic feet gas per hour 

(scfh) to atmosphere. The highest bleed rate listed in a table published by the EPA is 42 cubic feet 

per hour (cfh).1

 The average bleed rate for high-bleed pneumatic devices in the Denver-Julesburg 

(DJ) Basin is 17cfh.2

 Bleed rates of 6, 17, and 42 cfh natural gas represent emission sources of 

0.3, 0.8, and 2.1 tons per year (tpy) VOC, respectively, assuming a VOC molar fraction of 7.47 

percent, which is representative of the DJ Basin.2

 1

DRAFT - Denver Metro Area/North Front Range 8-hr Ozone SIP 

Technical Support Document for Proposed Pneumatic Controller Regulation 
Colorado Department of Public Health and Environment / Air Pollution Control Division 

3. Why was this proposed regulation developed? 

A 2003 EPA study reported that emissions from pneumatic devices are collectively one of the 

largest sources of methane emissions in the natural gas industry. Natural gas is primarily 

composed of methane, but also contains VOCs and hazardous air pollutants (HAPs). Annual 

nationwide methane emissions are estimated to be approximately 31 billion cubic feet (Bcf) from 

the production sector, 16 Bcf from the processing sector, and 14 Bcf from the transmission sector.1 

VOC emissions from pneumatic devices within the 9-county Denver Metro Area/North Front 

Range (DMA/MFR) NAA were estimated to be 24.8 tons per day (tpd) for the 2006 baseline and 

have been projected to be 31.1 tpd for the 2010 baseline. These emissions represent 13 and 15 

percent of the total VOC emissions from oil and gas sources in the DMA/MFR NAA in 2006 and 

2010, respectively.3 This source category, pneumatic devices, has the second highest VOC 

emissions within the oil and gas industry. Therefore, emission reductions related to this source 

category have the potential to be significant. It is estimated that if this proposed regulated is 

implemented, 2010 VOC emissions will be reduced by approximately 23 tpd. 

4. Why is this proposed regulation reasonable? 

4.1. Timeframe 

Many companies have already converted high-bleed devices to low-bleed devices 

voluntarily, as evidenced from responses to a Section 111 information request letter that the 

Division mailed to industry in June 2008. At a minimum, industry has committed to 

converting approximately 95 percent of high-bleed devices to low-bleed devices by 

November 2008. Therefore, if the proposed regulation is adopted in February 2009, it is 

anticipated that vendors would have enough supply on hand to satisfy orders for low-bleed 

devices and retrofit kits. There has been enough supply during the recent and ongoing 

conversions. 

Under the proposed regulation, companies would be prohibited from installing a high-bleed 

device after February 1, 2009, unless the Division grants an exemption. The Division 

would approve use of a high-bleed device if a company can demonstrate that it is not 

technically feasible (e.g., safety or process concerns) to use a low-bleed device in a specific 

application. High-bleed pneumatic devices that are in place as of the anticipated regulation 

implementation date must be converted to low-bleed devices within three months (by May 

1, 2009), unless the Division grants an exemption. 

4.2. Associated Costs 

Because implementation of this proposed regulation would increase the amount of natural 

gas that industry can sell, companies have the potential to save money. Calculations 

related to proposed regulation are available in Attachment 1 of this document. Costs 

(savings) associated with this proposed regulation include: 

 2

DRAFT - Denver Metro Area/North Front Range 8-hr Ozone SIP 

Technical Support Document for Proposed Pneumatic Controller Regulation 
Colorado Department of Public Health and Environment / Air Pollution Control Division 

• Cost per ton of reduced VOC associated with converting existing pneumatic 

devices and performing enhanced maintenance on remaining high-bleed devices 

would represent an estimated savings of $747 

• Weighted average annualized cost associated with converting existing pneumatic 

devices and performing enhanced maintenance on remaining high-bleed devices 

would represent an estimated savings of $1,505 

• Weighted average annualized cost associated with installing low-bleed pneumatic 

devices for new applications and performing enhanced maintenance on remaining 

high-bleed devices would represent an estimated savings of $1,630 

• Payback time period of implementing this proposed regulation is estimated to be 3 

to 24 months 

4.3. Conversion Effectiveness 

The service life and process control ability of low-bleed pneumatic devices is comparable 

to that of high-bleed devices in most applications. Low-bleed devices are no more likely to 

fail than high-bleed devices.4

 If a device does fail, the process would no longer be 

controlled. For example, if a level controller fails, the dump valve would remain open. 

This would lead to a shortened residence time, which would not allow adequate separation 

between condensate and water. The mixed liquids would flow directly to a tank. This 

failure would be noticed during a regular site visit. It is anticipated that a device that fails 

would be repaired as soon as possible. 

4.4. Emission Threshold 

Typically, the threshold to require a permit for VOC sources in a Colorado NAA is 2 tpy. 

An average high-bleed pneumatic device emission rate in the DMA/MFR NAA is 

approximately 0.8 tpy of VOC. An average low-bleed pneumatic device emission rate in 

the DMA/MFR NAA is approximately 0.1 tpy of VOC.2 The proposed regulation is 

targeting high-bleed devices, which have VOC emissions ranging from 0.3 to 2.1 tpy in the 

DJ Basin. While the low end of the emission range is a lower threshold than required for 

other emission sources, industry is already converting most high-bleed devices. Therefore, 

this proposed regulation represents a reasonably simple means of ensuring further VOC 

reductions. If the proposed regulation only applied to high-bleed devices emitting above 

typical thresholds, emission testing for high-bleed devices may be required to determine 

how many tons per year VOC were being emitted from each device. That could require 

additional resources both for industry and the Division. 

 3

4.5. Applying Regulation to only High-Bleed Devices 

IPAMS estimated that in 2006 there were 41,494 pneumatic devices in the DMA/MFR 

NAA. Of those, 5,524 were high-bleed (13% of total), 34,847 were low-bleed (84% of 

total), and 1,122 were actuated with compressed air and therefore do not emit any natural 

gas or VOCs (3% of total). 

If 5 percent of high-bleed devices receive an exemption from the Division, an estimated 

276 devices would be allowed to remain in place based on 2006 data.2 The percentage of 

exempt high-bleed devices, 5 percent, is based on the projection that 95 percent of devices 

would be converted from high-bleed to low-bleed devices. The regulation would require 

DRAFT - Denver Metro Area/North Front Range 8-hr Ozone SIP 

Technical Support Document for Proposed Pneumatic Controller Regulation 
Colorado Department of Public Health and Environment / Air Pollution Control Division 

that enhanced maintenance be performed on all high-bleed devices. Enhanced maintenance 

potentially reduces emissions. It includes cleaning, tuning, and repairing leaking gaskets, 

tubing fittings, and seals; tuning to operate over a broader range of proportional band; and 

eliminating unnecessary valve positioners. Routine inspection and recordkeeping would 

also be required for remaining high-bleed devices. 

Emissions associated with low-bleed devices are a fraction of the emission threshold level, 

2 tpy, and of high-bleed device emissions. Therefore, it is reasonable to avoid the burdens 

of inspection, enhanced maintenance, and record keeping for low-bleed devices. 

5. Data and Calculations 

Most data used in calculations performed to support proposed regulations regarding pneumatic 

devices are from an IPAMS report.3 Data used to determine the number of devices that would be 

converted or require enhanced maintenance and emission reductions as a result of the proposed 

rule include: 

• Estimated number of devices in 2006 located within the DJ Basin, by device bleed rate 

• 2006 VOC device emissions and fraction of wells in each DJ Basin county 

• Average VOC fraction and molecular weight in DJ Basin natural gas 

Most data used in cost analysis calculations were obtained from vendors. Costs include purchase, 

installation, operation, maintenance, and the benefit earned from sale of natural gas that had 

previously been emitted to the atmosphere. Costs were obtained to replace or retrofit two of the 

most common types of devices, liquid level controllers and pressure controllers. Costs of these 

four scenarios were averaged into one scenario. 

All data and calculations used to support proposed regulations regarding pneumatic devices are 

available in Attachment 1, Pneumatic Device Proposed Regulation Data and Calculations. 

5.1. Emission Reduction 

To calculate the reduction of VOC emissions that would occur in the NAA if the proposed 

regulation is implemented, the following steps were followed. The calculations are 

available in Attachment 1. 

1. Obtain emissions for baseline cases: 24.8 tpd (baseline 2006), 31.1 tpd (baseline 

2010) 

2. Obtain total bleed rate emissions from high bleed devices in the NAA by adding 

bleed rate emissions of each high bleed device in the NAA: 150,885 cfh 

(calculation for each type of high-bleed device based on number and bleed rate of 

each type of device; see Attachment 1 spreadsheet, sheet “device calc”, column S) 

3. Obtain total bleed rate emissions from low-bleed devices in the NAA by adding 

bleed rate emissions of each low-bleed device in the NAA: 30,823 cfh (calculation 

for each type of low-bleed device based on number and bleed rate of each type of 

device; see Attachment 1 spreadsheet, sheet “device calc”, column T): 

 4

4. Obtain 2006 baseline emissions (emissions in terms of bleed rate) by adding the 

total bleed rate emissions of high bleed devices in the NAA to the total bleed rate 

DRAFT - Denver Metro Area/North Front Range 8-hr Ozone SIP 

Technical Support Document for Proposed Pneumatic Controller Regulation 
Colorado Department of Public Health and Environment / Air Pollution Control Division 

emissions of low-bleed devices in the NAA: 150,885 cfh + 30,823 cfh = 181,708 

cfh 

5. Obtain the 2006 total bleed rate emissions of low-bleed devices in the NAA 

(baseline): see step 3 (same parameter; 30,823 cfh) 

6. Obtain the 2006 total bleed rate emissions of low-bleed devices in the NAA 

(converted from high-bleed if proposed regulation had been implemented) by 

adding bleed rate emissions of each converted low-bleed device in the NAA: 

10,148 cfh (calculation for each type of converted low-bleed device based on 

number and bleed rate of each type of device; see Attachment 1 spreadsheet, sheet 

“device calc”, column U) 

7. Obtain the 2006 total bleed rate emissions of high-bleed devices in the NAA 

(remaining 5%, taking into account enhanced maintenance) by adding bleed rate 

emissions of each remaining high bleed device in the NAA taking into account 

bleed rate reductions from enhanced maintenance: 4,782 cfh (calculation for each 

type of high-bleed device based on number and bleed rate of each type of device 

taking into account bleed rate reductions from enhanced maintenance ; see 

Attachment 1 spreadsheet, sheet “device calc”, column W) 

8. Obtain 2006 projected emissions (emissions in terms of bleed rate) by adding the 

total bleed rate emissions of low-bleed devices in the NAA (baseline) to the total 

bleed rate emissions of low-bleed devices in the NAA (converted from high-bleed if 

proposed regulation had been implemented) and total bleed rate emissions of highbleed devices in the NAA (remaining 5%, taking into account enhanced 

maintenance): 30,823 cfh + 10,148 cfh + 4,782 cfh = 45,754 cfh 

9. Obtain reduction percent obtained from implementing proposed regulation based on 

2006 baseline emissions and 2006 projected emissions (as if proposed regulation 

had been in place) (emissions in terms of bleed rate): (181,708 cfh – 45,754 cfh) / 

181,708 cfh = 0.75 or 75% 

10. Obtain 2010 projected emissions based on 2010 baseline emissions and reduction 

percent obtained from implementing proposed regulation: 31.1 * (1-0.75) = 7.8 tpd 

11. Obtain VOC emission reduction that would occur in NAA if proposed regulation is 

implemented by subtracting 2010 projected emissions from 2010 baseline 

emissions: 31.1 tpd – 7.8 tpd = 23.3 tpd 

 5

DRAFT - Denver Metro Area/North Front Range 8-hr Ozone SIP 

Technical Support Document for Proposed Pneumatic Controller Regulation 
Colorado Department of Public Health and Environment / Air Pollution Control Division 

6. References 

1. US EPA, Lessons Learned: Options for Reducing Methane Emissions from Pneumatic Devices 

in the Natural Gas Industry

2. ENVIRON, Buys and Associates, and IPAMS, Development of Baseline 2006 Emissions from 

Oil and Gas Activity in the Denver-Julesburg Basin, February 7, 2008 

3. ENVIRON, Buys and Associates, and IPAMS, Development of Baseline 2006 Emissions from 

Oil and Gas Activity in the Denver-Julesburg Basin, March, 2008 

4. Conversations between the Division and industry/vendors; additionally, document available at 

http://www.fossil.energy.gov/programs/oilgas/publications/environ_benefits/14fsprod.pdf 

DRAFT - Denver Metro Area/North Front Range 8-hr Ozone SIP 

Technical Support Document for Proposed Pneumatic Controller Regulation 

6
Colorado Department of Public Health and Environment / Air Pollution Control Division 

Attachment 1 - Pneumatic Device Proposed Regulation Data 

and Calculations 

DRAFT - Denver Metro Area/North Front Range 8-hr Ozone SIP 

Technical Support Document for Proposed Pneumatic Controller Regulation 

7
Colorado Department of Public Health and Environment / Air Pollution Control Division 

 8

DRAFT - Denver Metro Area/North Front Range 8-hr Ozone SIP 

Technical Support Document for Proposed Pneumatic Controller Regulation 
Colorado Department of Public Health and Environment / Air Pollution Control Division 

DRAFT - Denver Metro Area/North Front Range 8-hr Ozone SIP 

Technical Support Document for Proposed Pneumatic Controller Regulation 

9
Colorado Department of Public Health and Environment / Air Pollution Control Division 

10

DRAFT - Denver Metro Area/North Front Range 8-hr Ozone SIP 

Technical Support Document for Proposed Pneumatic Controller Regulation 
Colorado Department of Public Health and Environment / Air Pollution Control Division 

11

DRAFT - Denver Metro Area/North Front Range 8-hr Ozone SIP 

Technical Support Document for Proposed Pneumatic Controller Regulation 
Colorado Department of Public Health and Environment / Air Pollution Control Division 

12

DRAFT - Denver Metro Area/North Front Range 8-hr Ozone SIP 

Technical Support Document for Proposed Pneumatic Controller Regulation 
Colorado Department of Public Health and Environment / Air Pollution Control Division 

DRAFT - Denver Metro Area/North Front Range 8-hr Ozone SIP 

Technical Support Document for Proposed Pneumatic Controller Regulation 

13
Colorado Department of Public Health and Environment / Air Pollution Control Division 

DRAFT - Denver Metro Area/North Front Range 8-hr Ozone SIP 

Technical Support Document for Proposed Pneumatic Controller Regulation 

14
Colorado Department of Public Health and Environment / Air Pollution Control Division 

DRAFT - Denver Metro Area/North Front Range 8-hr Ozone SIP 

Technical Support Document for Proposed Pneumatic Controller Regulation 

15
Colorado Department of Public Health and Environment / Air Pollution Control Division 

DRAFT - Denver Metro Area/North Front Range 8-hr Ozone SIP 

Technical Support Document for Proposed Pneumatic Controller Regulation 

16
Colorado Department of Public Health and Environment / Air Pollution Control Division 

DRAFT - Denver Metro Area/North Front Range 8-hr Ozone SIP 

Technical Support Document for Proposed Pneumatic Controller Regulation 

17
Colorado Department of Public Health and Environment / Air Pollution Control Division 

18

DRAFT - Denver Metro Area/North Front Range 8-hr Ozone SIP 

Technical Support Document for Proposed Pneumatic Controller Regulation 
Colorado Department of Public Health and Environment / Air Pollution Control Division 

19

DRAFT - Denver Metro Area/North Front Range 8-hr Ozone SIP 

Technical Support Document for Proposed Pneumatic Controller Regulation 
Colorado Department of Public Health and Environment / Air Pollution Control Division 

20

DRAFT - Denver Metro Area/North Front Range 8-hr Ozone SIP 

Technical Support Document for Proposed Pneumatic Controller Regulation 
Colorado Department of Public Health and Environment / Air Pollution Control Division 

21

DRAFT - Denver Metro Area/North Front Range 8-hr Ozone SIP 

Technical Support Document for Proposed Pneumatic Controller Regulation 
Colorado Department of Public Health and Environment / Air Pollution Control Division 

22

DRAFT - Denver Metro Area/North Front Range 8-hr Ozone SIP 

Technical Support Document for Proposed Pneumatic Controller Regulation 
Colorado Department of Public Health and Environment / Air Pollution Control Division 

23

DRAFT - Denver Metro Area/North Front Range 8-hr Ozone SIP 

Technical Support Document for Proposed Pneumatic Controller Regulation 
Colorado Department of Public Health and Environment / Air Pollution Control Division 

24

DRAFT - Denver Metro Area/North Front Range 8-hr Ozone SIP 

Technical Support Document for Proposed Pneumatic Controller Regulation 
Colorado Department of Public Health and Environment / Air Pollution Control Division 

25

DRAFT - Denver Metro Area/North Front Range 8-hr Ozone SIP 

Technical Support Document for Proposed Pneumatic Controller Regulation 
Colorado Department of Public Health and Environment / Air Pollution Control Division 

 2

DRAFT - Denver Metro Area/North Front Range 8-hr Ozone SIP 

Technical Support Document for Proposed Pneumatic Controller Regulation 

6
Colorado Department of Public Health and Environment / Air Pollution Control Division 

 2

DRAFT - Denver Metro Area/North Front Range 8-hr Ozone SIP 

Technical Support Document for Proposed Pneumatic Controller Regulation 

7
Colorado Department of Public Health and Environment / Air Pollution Control Division 

28

DRAFT - Denver Metro Area/North Front Range 8-hr Ozone SIP 

Technical Support Document for Proposed Pneumatic Controller Regulation 
Colorado Department of Public Health and Environment / Air Pollution Control Division 

DRAFT - Denver Metro Area/North Front Range 8-hr Ozone SIP 

Technical Support Document for Proposed Pneumatic Controller Regulation 

29
Colorado Department of Public Health and Environment / Air Pollution Control Division 

DRAFT - Denver Metro Area/North Front Range 8-hr Ozone SIP 

Technical Support Document for Proposed Pneumatic Controller Regulation 

30