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Front Range Ozone Early Action Compact

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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 – PowerPoint PPT presentation

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Date added: 10 September 2019
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Title: Front Range Ozone Early Action Compact


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

2
Overview
  • Denvers 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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