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Front Range Ozone Early Action Compact

Front Range Ozone Early Action Compact. Presentation to WESTAR Regional Ozone Conference Steven Arnold Air Pollution Control Division March 9th, 2004. Overview. Denver’s Ozone Problem Sources The Early Action Compact Non-Attainment Boundary Control Actions. Ozone Summary.

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Front Range Ozone Early Action Compact

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  1. Front Range OzoneEarly Action Compact Presentation to WESTAR Regional Ozone Conference Steven Arnold Air Pollution Control Division March 9th, 2004

  2. Overview • Denver’s Ozone Problem • Sources • The Early Action Compact • Non-Attainment Boundary • Control Actions

  3. Ozone Summary

  4. Ozone Status

  5. Upslope Meteorology

  6. Ozone averaging more than 80 ppb between 10,000 and 18,000 feet represents carry- over from the previous day and/or transport. This ozone would have been available for mixing throughout the mixed layer during the late afternoon, contributing to the ozone burden at the surface.

  7. Back Trajectory Analysis- AQI 177- NOAA Air Resources Laboratory

  8. Back Trajectory Analysis-AQI 129- NOAA Air Resources Laboratory

  9. Back Trajectory Analysis-AQI 101- NOAA Air Resources Laboratory

  10. Topography (Denver Boulder Greeley CMSA Highlighted)

  11. Denver Metro + Weld County VOC Emission Inventory

  12. Denver Metro + Weld County NOx Emission Inventory

  13. Early Action Compact To avoid nonattainment, the Denver area entered into the Early Action Compact • A multi-agency agreement • RAQC, CDOT, AQCC, EPA, DRCOG, CDPHE, and Elbert, Larimer, Morgan and Weld Counties • Controls implemented faster than traditional process • Requires complex modeling • Requires implementing controls by 12/31/05 • Success must be shown by 12/31/07 – attainment

  14. Early Action Compact • Joining the EAC ensures a nonattainment designation will be deferred for all counties • Control over control measures • No transportation or general conformity • No nonattainment NSR permitting requirements • No RACT for all stationary sources • No “nonattainment” stigma • Basically, an “insurance policy” from nonattainment • Failure to meet any of the EAC deadlines triggers automatic activation of nonattainment

  15. Overview of the EAC Schedule 3/11 - AQCC public hearing 3-5/04 - Legislative review of AQCC adopted SIP 4/15/04 - EPA finalizes designation (deferred) and boundaries 12/31/04 - Plan due to EPA

  16. The Concept of Nonattainment • If an area violates the standard, then EPA designates “nonattainment” • A State Implementation Plan (SIP) is required • SIP = control strategy plan with technical information • Emission controls must be enforceable • Conformity and more stringent source controls

  17. Potential Ozone Nonattainment Boundary • EPA guidance recommends a minimum nonattainment boundary as the Denver/Boulder/Greeley CMSA • Also, the CAA requires the area to include “…the area that can be shown to cause or contribute to nonattainment…” • Review of sources, modeling, topography, and meteorology are considered in determining the boundaries

  18. New Boundary May IncludeNorth Front Range Counties • Sources in many counties may “cause or contribute” to violations • Weld County and RMNP monitors are perilously close to recording violations • EPA recommends 11 counties as the 8-hour ozone nonattainment area • Adams, Arapahoe, Boulder, Broomfield, Denver, Douglas, Elbert, Jefferson, Larimer, Morgan and Weld • CDPHE responded to EPA proposal • Shave off northern Larimer and Weld Counties, all of Elbert County, and eastern Morgan, Weld, Adams, and Arapahoe Counties from boundary

  19. Proposed 8-hour Ozone Nonattainment Area

  20. Eastern Colorado VOC Sources (Denver Boulder Greeley CMSA Highlighted)

  21. Eastern Colorado NOx Sources (Denver Boulder Greeley CMSA Highlighted)

  22. Oil/Gas Activities (from Colorado Oil and Gas Conservation Commission) Purple: Permits Green/Red: All Oil/Gas Wells

  23. Eastern Colorado Oil and Gas (Denver Boulder Greeley CMSA Highlighted)

  24. Ozone Modeling Area for EAC

  25. Development of theOzone Plan • A plan has been drafted and proposed to the Air Quality Control Commission • Description of the problem • Accounting of all emission sources (“inventories”) • Photochemical modeling to predict success by 2008

  26. Development of theOzone Plan • Controls on certain sources proposed • Flash emissions from oil/gas sources • 8.1 psi RVP gasoline • EPA may set RVP at 7.8 psi • Uncontrolled industrial engines • Natural gas processing plants • Dehydrators at oil/gas operations • Current controls remain in place • Enhanced I/M, federal measures, existing stationary sources rules

  27. Development of theOzone Plan • Modeling these reductions shows improvement, but not enough • All monitoring sites below 85 ppb in 2007 except the Rocky Flats site – 85.6 ppb • “Weight of the evidence” used to show attainment • Used if modeled concentrations less than 90 ppb • Corroborative analysis of modeling results/uncertainties, emissions trends, anomalous meteorology, levels of control • Attainment presumed based on the proposed plan • AQCC hearing March 11th; Legislature then reviews

  28. What Next? • Monitoring this summer will provide new perspectives • Modeling will continue to be refined • Legislative session and AQCC Actions are only Round 1 • EPA actions and actions of 22 parties and other interests are all unknowns

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