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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

Front Range OzoneEarly Action Compact

Presentation to WESTAR

Regional Ozone Conference

Steven Arnold

Air Pollution Control Division

March 9th, 2004

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

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


early action compact
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
early action compact1
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
overview of the eac schedule
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

the concept of nonattainment
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
potential ozone nonattainment boundary
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
new boundary may include north front range counties
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

Oil/Gas Activities

(from Colorado Oil and Gas Conservation Commission)

Purple: Permits

Green/Red: All Oil/Gas Wells

development of the ozone plan
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
development of the ozone plan1
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
development of the ozone plan2
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
what next
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