773 San Marin Drive, Suite 2115, Novato, CA 94998 415.899.0700 Draft Final Report

2010 OZONE PROJECTIONS FOR THE 2010 BASE CASE

AND 2010 SENSITIVITY TESTS AND 2010 OZONE SOURCE

APPORTIONMENT MODELI NG FOR THE DENVER

8-HOUR OZONE STATE IM PLEMENTATION PLAN

Prepared for:

Regional Air Quality Council 1445 Market Street, Suite 260 Denver, Colorado 80202

Prepared by:

Dennis McNally

Cyndi Loomis Alpine Geophysics, LLC 7341 Poppy Way Arvada, Colorado 80007

Ralph Morris Tanarit Sakulyanontvittaya

Edward Tai ENVIRON International Corporation

773 San Marin Dr. Suite 2115 Novato, CA 94998

September 8, 2008September 2008

i TABLE OF CONTENTS

Page

EXECUTIVE SUMMARY .................................................................................................... ES-1

Overview of Approach.........................................................................................................ES -1 2010 Base Case Ozone Projections......................................................................................ES-1 2010 Sensitivity Test Results...............................................................................................ES -4 2010 Ozone Source Apportionment Modeling....................................................................ES-7 Conclusions of 2010 Ozone Projections And Emissions Sensitivity Tests..........................................................................................ES-11

1.0 INTRODUCTION............................................................................................................... . 1-1

1.1 Background................................................................................................................. ..... 1-1 1.2 Purpose.................................................................................................................... ......... 1-1 1.3 Overview of Modeling Approach .................................................................................... 1-2 1.4 2010 Emissions Modeling Approach............................................................................... 1-3

2.0 2010 OZONE PROJECTIONS........................................................................................... 2-1

2.1 Introduction.............................................................................................................. ........ 2-1 2.2 Ozone Projection Procedures........................................................................................... 2-1 2.3 Ozone Projections for the 2010 Base Case...................................................................... 2-3 2.4 2010 Sensitivity Tests.................................................................................................... 2-10

3.0 2010 APCA SOURCE APPORTIONMENT..................................................................... 3-1

3-1 Introduction............................................................................................................... ....... 3-1 3-2 Technical Description ...................................................................................................... 3-1 3-3 Application Methodology ................................................................................................ 3-6 3-4 Analysis Methodology and Results ................................................................................. 3-8

4. REFERENCES.................................................................................................................. ... 4-1

APPENDICES

Appendix A: Projected 2010 8-Hour Ozone Design Values (DVF) at DMA Monitoring Sites for the 2010 Base Case and 2010 Emission Sensitivity ScenariosSeptember 2008

ii Appendix B: Differences in pr ojected 2010 8-hour ozone Design Values between the 2010 Sensitivity tests and the 2010 Base Case using the MATS Unmonitored Area Test Projection Procedure Appendix C: Ozone Source Apportionment Modeling Results for each Monitor in the Denver Nonattainment Area with Daily Maximum 8-Hour ozone > 70 ppb and the 2010 Base Case Emissions Scenario using the Anthropogenic Precursor Culpability Assessment (APCA) Source Apportionment Approach

TABLES

Table ES-1. Current-year (DVC) and projected future-year (DVF) 8-hour ozone Design Values using the CAMx 2006 and 2010 base case modeling results........................................................................ES-3

Table ES-2. Results of the Denver 20 10 emission sensitivity tests.......................................ES-6 Table 2-1. Fourth highest daily maximum 8-hour ozone concentrations ppm) at monitoring sites in the Denver area during 2005, 2006 and 2007 and 2005-2007 8-hour ozone Design Values that is used as the current-year Design Value (DVC) starting point for the 201 0 8-hour ozone projections........................................... 2-3 Table 2-2. Summary of 2006 and 2010 base case VOC, NOx and CO emissions in Colorado for July 21-23, 2006 ................................................. 2-4 Table 2-3. Current-year (DVC) a nd projected future-year (DVF) 8-hour ozone Design Values using the CAMx 2006 and 2010 base case modeling results.......................................................................... 2-5 Table 2-4. Description of 2010 sens itivity tests performed using the Denver CAMx 12/4 km modeling system ......................................................... 2-11 Table 2-5. Results of 2010 sensitivity tests......................................................................... 2-13 Table 3-1. Source apportionment sour ce groups for Denver SIP 2010 modeling ................ 3-7 Table 3-2. Source apportionment sour ce regions for Denver SIP 2010 modeling................ 3-7

FIGURES

Figure ES-1. Current-year inter polated 8-hour ozone Design Values (DVC; left) and projected future-year 8-hour ozone Design Values (DVF; right) for the 2010 base case simulation..............ES-3 Figure ES-2a. Rocky Flats North s ource apportionment for 29 July including boundary conditions...........................................................................ES-9 Figure ES-2b. Rocky Flats North sour ce apportionment for 29 July excluding boundary conditions..........................................................................ES-9 Figure ES-2c. Rocky Flats North s ource apportionment for 29 July attributable to anthropogenic NOx emissions..................................................ES-10 Figure ES-2d. Rocky Flats North sour ce apportionment for 29 July attributable to anthropogen ic and biogenic VOC emissions............................ES-10September 2008

iii Figure 1-1a. Nested 36/12/4 km mode ling domains for the Denver 8-hour ozone modeling study. Blue line domains are for CAMx/SMOKE

domains that are nested in the MM5 red line domains ........................................ 1-2 Figure 1-1b. Nested 12/4 km modeling domains for the Denver CAMx air quality and SMOKE emissions modeling............................................................ 1-3 Figure 2-1. Difference plots in daily maximum 8-hour ozone

concentrations between the 2010 and 2006 base case CAMx simulations for July 29 (top left), June 27 (top right), June 28 (bottom left) and June 12 (bottom right), 2006 ...................................... 2-6 Figure 2-2. 2010 minus 2006 base ca se emissions difference plots for NOx (left) and VOC....................................................................................... 2-7 Figure 2-3a. Current-year 8-hour ozone Design Values (DVC) interpolated by the MATS tool ................................................................................................ 2-8 Figure 2-3b. Projected 2010 8-hour ozone Design Values (DVF) generated by the MATS tool for the 2010 base

case emissions scenario........................................................................................ 2-9 Figure 3-1. Source apportionment sour ce regions in 12km CAMx domain........................... 3-7 Figure 3-2. Source apportionment sour ce regions in 4km CAMx domain............................. 3-8 Figure 3-3a. Rocky Flats No rth source apportionment for 29 July including boundary conditions........................................................................................... 3-10 Figure 3-3b. Rocky Flats North sour ce apportionment for 29 July excluding boundary conditions.......................................................................... 3-10 Figure 3-3c. Rocky Flats North sour ce apportionment for 29 July attributable to anthropogenic NOx sources........................................................ 3-11 Figure 3-3d. Rocky Flats North sour ce apportionment for 29 July attributable to anthropogenic VOC sources....................................................... 3-11 Figure 3-3a. Fort Collins West source apportionment for 29 July including boundary conditions........................................................................................... 3-12 Figure 3-3b. Fort Collins West source apportionment for 29 July excluding boundary conditions........................................................................................... 3-12 Figure 3-3c. Fort Collins West source apportionment for 29 July attributable to anthropogenic NOx sources........................................................................... 3-13 Figure 3-3d. Fort Collins West source apportionment for 29 July attributable to anthropogenic VOC sources .......................................................................... 3-13F:\Denver_O3_2008\Reports\2010_Sens_OSAT \draft#1\Exec_Sum1.doc August 2008 ES-1 EXECUTIVE SUMMARY

Due to violations of the 0.08 parts per million (ppm) 8-hour ozone National Ambient Air Quality Standard (NAAQS) based on 2005-2007 air quali ty data, in November 2007 the Denver Metropolitan Area (DMA) reverted to an 8-hour ozone nonattainment area. This requires the DMA to develop an 8-hour ozone State Implemen tation Plan (SIP) that demonstrates the area will achieve the 0.08 ppm 8-hour ozone NAAQS by 2010. The Denver Regional Air Quality Council (RAQC), in consultation with the Colo rado Department of Health and Environment (CDPHE) Air Pollution Control Division (APCD), contracted with ENVIRON International Corporation and their subcontra ctor Alpine Geophysics, LLC to develop the photochemical modeling databases necessary to demonstrate that the DMA will achieve the 0.08 ppm 8-hour ozone NAAQS by 2010.

OVERVIEW OF APPROACH

The Comprehensive Air-quality Mo del with extensions (CAMx; www.camx.com ) was set up for a June-July 2006 episode on a 36/12/4 km grid with the 4 km domain focused on Colorado. Meteorological inputs were prepared using th e MM5 meteorological model whose results and evaluation are discussed by McNally and co-workers (2008). An initial emissions inventory was prepared using the SMOKE emissions modeling system and a preliminary 2006 base case was performed. A preliminary model performa nce evaluation was conducted and diagnostic sensitivity tests performed to identify an optimal model conf iguration for simulating ozone formation in the DMA (Morris et al., 2008b). A revised final CAMx 2006 base case (Run 17) simulation was performed and a comprehensiv e model performance evaluation was conducted (Morris et al., 2008c). Although there were some model performance issues on some of the modeling days during the June-Jul y 2006 episode, usually due to an ozone underestimation bias, on a vast majority of the modeling days the ozone model performance achieved EPA’s model performance goals that along with the other mode l performance metrics indicated that the model was simulating the observed ozone sufficiently well for use in making ozone projections. Furthermore, on most days the model reproduced the observed VOC/NOx ratios in Denver quite well suggesting that the model is simulating the same chemical regimes as observed as well.

2010 BASE CASE OZONE PROJECTIONS

The procedures given in EPA’s 8-hour ozone modeling guidance were used to project current year 8-hour ozone Design Values (DVC) to obt ain projected future year 2010 8-hour ozone Design Values (DVF) at each of the DMA monito ring sites (EPA, 2007). These procedures use the 2006 and 2010 base case modeling results in a relative fashion whereby modeled relative response factors (RRFs) are used to scale the current year 8-h our ozone Design Value (DVC) to obtain the projected future year 8-hour ozone Design Value (DVF):

DVF = DVC x RRF

For the Denver 2010 ozone projections, with on e exception, the DVCs were based on the 8-hour ozone Design Values from the 2005-2007 period (i .e., the three year av erage of the fourthF:\Denver_O3_2008\Reports\2010_Sens_OSAT \draft#1\Exec_Sum1.doc August 2008 ES-2 highest daily maximum 8-hour ozone concentration at each monitor). The exception to this was for the Fort Collins West (FTCW) monitor that started monitoring in 2006 so that the two year average of the fourth highest daily maximum 8-hour ozone concentrations was used from 2006-

2007 for FTCW.

Table ES-1 summarizes the projected 8-hour ozone Design Values (DVF) at the DMA monitoring sites for the 2010 base case simulation using the CAMx 2006 and 2010 base case modeling results and EPA recommended default oz one projection procedures described above. The maximum projected 8-hour ozone Design Valu e is 84 ppb and occurs at both the Rocky Flats North (RFNO) and Fort Coll ins West (FCTW) monitoring site s (see column 5 in Table ES1). As this value is 84 ppb or lower, then the 2010 base case modeling results pass the modeled attainment demonstration test. However, be cause the maximum projected 8-hour ozone Design Values lie between 82 and 87 ppb, then a WOE an alysis is required. Although the EPA 8-hour ozone projection procedure is to truncate the final projected DVF for comparisons with the NAAQS, in column 6 of Table ES-1 we present the DVFs to the nearest tenth of a ppb before

truncation. In this case we s ee that the projected 2010 base ca se DVFs at RFNO and FTCW are both 84.9 ppb.

Also shown in Table ES-1 are the RRFs and the cu t-off thresholds used in selecting days and number of days used in calcula ting the RRF. The EPA desire to use at least 10 modeled days is satisfied using the Denver June-July 2006 modeli ng period. In order to achieve that many modeled days, the cut-off threshold had to be reduced from 74 ppb to 78 ppb depending on the monitor, with the RFNO and FTCW monitors using a 78 and 76 ppb thresholds, respectively.

The level of ozone reductions in the projected Design Values app ears to be greater the further away from central Denver the monitor resides. In fact, ozone is estimated to increase very slightly at the monitors in or immediately dow nwind of the urban core. This is due to the

reductions in on-road mobile sources NOx emissions that increase ozone in the urban core. The ozone increases are due to less ozone titration due to reduction in the primary emitted NOx

emissions and/or less inhibition effect that hi gh NOx concentrations have on ozone formation. As one moves away from the Denver urban core, the ozone increases between 2006 and 2010 turn into no change and then to ozone decreases. The distance from the Denver urban core when the ozone increases change to ozone decreases varies by day due to changes in emissions (e.g., weekday versus weekend day) and changes in meteorology. The RFNO monitor lies near the

modeled ozone increase-to-decrease cross ove r distance, which explains why the model projected 2010 Design Value is re lative insensitive to the change s in emissions from 2006 to 2010 at this site (85.0 to 84.9 ppb, a 0.1 ppb reduction); of the 10 days used to construct the RRF for RFNO there are some days of ozone increases and some with ozone decreases. At the FTCW monitoring site, on the other hand, th e model is more responsive (1.1 ppb ozone reduction) as it is an area where the modeled ozone changes eith er stay the same or are reduced between 2006

and 2010.

Figure ES-1 display the results of EPA’s unmoni tored area analysis fo r the 2010 base case. DVCs in excess of 80 ppb are estimated to the sout h, west and northwest of Denver stretching to Fort Collins and then west of Fort Collins (Fig ure ES-1, left). In fact, the unmonitored area procedure estimates that there are current-year DVCs in ex cess of the 85 ppb NAAQS occurring in 12 grid cells to the west of the Fort Collins monitoring sites. The projected DVFs for the 2010 base case (Figure ES-1, right) have greatly reduced the spatial exte nt of the DVFs in excess of 80 ppb occurring to the south, west and northwest of Denver and the 12 cells with DVCs exceedingF:\Denver_O3_2008\Reports\2010_Sens_OSAT \draft#1\Exec_Sum1.doc August 2008 ES-3 the 85 ppb NAAQS have been reduced by half to 6 grid cells in the 201 0 base case emissions

scenario. EPA stresses that the unmonitored area analysis is much more uncertain than the

modeled attainment test at the monitors. And whereas additional emission s controls would likely

be needed to eliminate continued violations at the monitor, such actions may not be appropriate for the unmonitored area analysis.

Table ES-1. Current-year (DVC) and projected future-year (DVF) 8-hour ozone Design Values using the CAMx 2006 and 2010 base case modeling results.

2005-07 2010 Base Case

Site ID Monitor Name County DVC DVF DVF RRF Cutoff #days 80013001 Welby Adams 70.0 70 70.2 1.0042 77.0 11 80050002 Highland Arapahoe 78.0 77 77.3 0.9916 78.0 14

80130011 S. Boulder Creek Boul der 81.0 80 80.8 0.9976 78.0 10

80310002 Denver - CAMP Denv er 56.0 56 56.0 1.0017 78.0 10 80310014 Carriage Denver 74.0 74 74.1 1.0022 78.0 10 80350004 Chatfield State Park Douglas 84.0 83 83.4 0.9934 78.0 11 80410013 USAF Academy El Paso 73.0 72 72.0 0.9873 75.0 10 80410016 Manitou Springs El Paso 74.0 73 73.7 0.9966 74.0 10

80590002 Arvada Jefferson 79.0 79 79.2 1.0026 78.0 10

80590005 Welch Jefferson 75.0 75 75.0 1.0004 78.0 10 80590006 Rocky Flats North Jefferson 85.0 84 84.9 0.9994 78.0 10

80590011 NREL Jefferson 82.0 82 82.3 1.0039 78.0 11

80690011 Fort Collins - West Larimer 86.0 84 84.9 0.9874 76.0 10

80691004 Fort Collins Larimer 74.0 73 73.0 0.9878 76.0 12 81230009 Greeley - Weld Tower Weld 78.0 77 77.7 0.9964 75.0 10

GTH161 Gunnison Gunnison 68.0 67 67.8 0.9984 74.0 10

ROM206 Larimer Larimer 76.0 75 75.2 0.9903 77.0 10

ROM406 Larimer Larimer 76.0 75 75.2 0.9903 77.0 10

Figure ES-1. Current-year interpolated 8-hour ozone Design Values (DVC; left) and projected future-year 8-hour ozone Design Values (DVF; right) for the 2010 base case simulation.F:\Denver_O3_2008\Reports\2010_Sens_OSAT \draft#1\Exec_Sum1.doc August 2008 ES-4 2010 SENSITIVITY TEST RESULTS

Sixteen (16) 2010 emissions reductions sensi tivity tests were conduc ted with the CAMx modeling system. Most of these emission reduc tion sensitivity tests reduced VOC and/or NOx emissions from a specific source category either just within the Denver nonattainment area (NAA) or within the entire state of Colorado. Ozone projections were made at each of the monitoring sites for each of the 2010 sensitivity tests. We also performed the unmonitored area analysis for each sensitivity test to better understa nd the spatial extent of any ozone benefits or adverse effects. All sensitivity tests modified emissions from the 2010 base case emissions

scenario.

Table ES-2 displays the result s of the 2010 sensitivity tests in terms of VOC, NOx and CO emission reductions from the 2010 base case, ch anges in projected 8-hour ozone Design Values at the key RFNO and FTCW monitoring sites, maximum difference in 2010 8-hour ozone Design Values anywhere in the DMA and maxi mum difference in daily maximum 8-hour ozone concentrations anywhere in the DMA and on any of the modeling days.

Mobile Source Emissions : The first three sensitivity tests examined the sensitivity of 2010 ozone projections to on-road mobile source em issions. Reducing on-road mobile sources VOC emissions 20% in the DMA reduces the projected DVFs at RFNO and FTCW by 0.2 and 0.1 ppb, respectively. The 7 psi RVP gasoline in on-ro ad mobile source gasoline vehicles reduces the DVFs by 0.1 ppb at both monitors. And the zero percent ethanol penetr ation scenario in the on-road and non-road mobile source gasoline engines increases the DVF at RFNO by 0.1 ppb,

and has no effect at FTCW.

Oil and Gas VOC Emissions : VOC emissions from O&G sources in the NAA were reduced by 20% (b1-sens04) and 40% (b1-sens04d) in two of the 2010 emissions sensitivity tests. The O&G

VOC emission reductions had little effect at th e RFNO monitor, but redu ced the projected DVF at the FTCW monitor by 0.1 and 0.2 ppb, respectively. The spatial maps of differences in the DVFs show a large area of ozone benefits due to the O&G VOC re ductions centered on the O&G production area in Weld County. The RFNO monitor is right at the edge of this benefits area. Note that the Denver EAC SIP modeling of the June-July 2002 episode saw more transport from the Weld County O&G production area down to the RFNO monitor, so these results are partly an artifact of the meteorological condi tions of the June-July 2006 modeling period. The O&G VOC emissions clearly have an effect on ozone formation in the Fort Collins area. In fact, the 6 grid cells west of Fort Collins that are projected to still violat e the 0.08 ppm 8-hour ozone NAAQS in the 2010 base case (Figure ES-1, right) are reduced to 4 and 3 grid cells in the 20% and 40% O&G VOC emission reduction sensitivity scenarios. Clearly VOC emission reductions from O&G sources in Weld County would benefit ozone attainment in th e Fort Collins area and likely elsewhere in the Denver NAA unde r other meteorological conditions.

Combined VOC & NOx Sensitivity Simulations : Sensitivity simulations b1-sens04b and b1-

sens04c looked at combined VOC and NOx emi ssions reductions from area, non-road point and O&G emissions in the NAA. Although both si mulations reduced VOC emissions by 20%, NOx emissions were reduced by 20% in sens04b and by 30% in sens04c allowing us to isolate the

effects of the NOx controls. Several of the othe r sensitivity tests also allow us to isolate the

effects of the VOC and NOx controls in these two sensitivity tests for each source category. The

b1-sens04b 20% VOC/NOx emissions reduction scenario reduces the DVF at RFNO by 0.5 ppb.

This is due to reductions in the RFNO ozone DVF of approximately 0.1 ppb from area sourceF:\Denver_O3_2008\Reports\2010_Sens_OSAT \draft#1\Exec_Sum1.doc August 2008 ES-5 VOC (b1-sens07), 0.1 ppb from O&G VOC ( b1-sens04), 0.2 ppb from non-road VOC (b1- sens06) and 0.2 ppb from point a nd O&G source NOx (b1-sens05). An additional 0.2 ppb ozone

reduction in the RFNO DVF is obtained when the NOx reduction is increased from 20% to 30%. At the FTCW monitor, the effects of the NOx em ission reductions alone are even greater. The 20% VOC/NOx reduction gives a 1.1 ppb reduction in the ozone DVF at the FTCW monitor; increasing the NOx reduction by another 10% increases the oz one reduction at the FTCW monitor by another 0.5 ppb (total 1.6 ppb reduction). This suggests that a majority of the ozone

benefits at FTCW are due to the NOx emi ssion reductions. Although as noted above, VOC

emission reductions from O&G sources in the NAA are also beneficial for reducing ozone in the

Forth Collins area. With the ex ception of a couple grid cells of isolated ozone increases, the

effects of the combined VOC/NOx controls ar e wide-spread reductions in ozone throughout the

DMA.

State-Wide Sensitivity : The state-wide sensitivity tests pr oduce nearly the same ozone benefits

at DMA monitors as the controls in the NAA alone. This is seen most clearly by comparing b1-

sens05 with b1-sens08 that examine a 20% reduc tion in NOx emissions from point and O&G sources in, respectively, the NAA and Colorado. They produce the same ozone reduction at RFNO (0.2 ppb) and the state-wide reduction produces slightly more ozone reduction at FTCW (0.6 ppb) than the NAA controls alone (0.5 ppb). At this time we have only evaluated the effects of the state-wide emission reduction sensitivity tests within the DMA. There are likely more

ozone benefits due to the Colorado state-wide emission reductions outside of the DMA that may be important given the new lower (March 2008) ozone NAAQS.

Bark Beetle Sensitivity : The effects of accounting for the Bark Beetle infestation on biogenic

emissions have small effects on the DVFs in the DMA (0.1 ppb reduction). Thus, the 2010 Denver ozone projections are not affect ed by the Bark Beetle infestation.

The 2010 emissions sensitivity tests show higher ozone sensitivity to reducing NOx emissions than reducing VOC emissions. Although there are sma ll areas of ozone increases due to NOx emissions reductions in the Denver urban core, a nd at the locations (gri d cells) of some point sources, the overall ozone reduction benefits of the NOx controls outweigh the ozone increases. Furthermore, the locations of the highest ozone increases due to NOx reductions are monitoring sites with low ozone concentrations. Although the ozone benefits of VOC reductions do not seem as great as those from NOx reducti ons, VOC emissions reductions do reduce ozone somewhat and do not exhibit any ozone increases as seen with the NOx emissions reductions. In particular, the VOC emissions reductions from O&G sources have ozone benefits in the Fort Collins area and particular th e key FTCW ozone monitor.F:\Denver_O3_2008\Reports\2010_Sens_OSAT\draft#1\Exec_Sum1.doc August 2008ES-6Table ES-2.Results of the Denver 2010 emission sensitivity tests.Emissions (TPD)% Anthro (%)DV Ozone(PPB)Grid DVOzone(ppb)*Grid Diff.Ozone(ppb)**TestDescriptionCOVOCNOxCOVOCNOxRFNOFTCWMax.Min.Max.Min.2006.a3Current Year 8-HourOzone Design Value8586b12010 Base Case-386.0 -42.2 -50.1 -10.2% -5.3% -5.6%84.984.9b1-sns0120% VOC On-Road NAA0.0 -22.8 0.0 0.0% -3.0% 0.0%-0.2-0.1 0.1 -0.2 0.1 -0.6b1-sns02Evap VOC On-Road inNAA (7 psi RVP)-46.9 -9.8 -0.3 -1.4% -1.3% 0.0%-0.1-0.1 0.1 -0.1 -0.2 -0.3b1-sns030% Ethanol in NAA323.3 -3.8 -2.0 9.5% -0.5% -0.2%0.10.0 0.4 0.0 1.3 -0.2b1-sns0420% VOC O&G in NAA0.0 -48.2 0.0 0.0% -6.4% 0.0%0.0-0.1 0.0 -0.4 0.0 -0.8b1-sns04b20% VOC & NOx Ar, Pnt,Non-Rd and O&G in NAA0.0 -72.5 -41.3 0.0% -9.6% -4.9%-0.5-1.1 1.8 -1.4 3.2 -3.3b1-sns04c20% VOC & 30% NOx Ar,Pnt, Non-Rd, O&G in NAA0.0 -72.5 -62.0 0.0% -9.6% -7.4%-0.7-1.6 2.8 -2.0 5.1 -4.7b1-sns04d40% VOC O&G in NAA0.0 -96.3 0.0 0.0%-12.7% 0.0%-0.1-0.2 0.1 -0.7 0.1 -1.7b1-sns0520% NOx Pnt & O&G NAA0.0 0.0 -20.6 0.0% 0.0% -2.5%-0.2-0.5 0.3 -0.8 1.7 -2.0b1-sns0620% VOC Non-Rd in NAA0.0 -12.7 0.0 0.0% -1.7% 0.0%-0.2-0.1 0.0 -0.2 0.0 -0.8b1-sns0720% VOC Area in NAA0.0 -7.5 0.0 0.0% -1.0% 0.0%-0.1-0.1 0.0 -0.1 0.0 -0.2b1-sns0820% NOx Pnt & O&G CO0.0 0.0 -78.0 0.0% 0.0% -9.3%-0.2-0.6 1.1 -1.0 2.2 -2.2b1-sns0920% VOC O&G in CO0.0 -67.2 0.0 0.0% -8.9% 0.0%0.0-0.1 0.1 -0.3 0.1 -0.8b1-sns1020% VOC & NOx Point &O&G in CO 0.0 -77.5 -78.0 0.0% -10.2% -9.3%-0.3-0.6 0.9 -1.2 2.1 -2.7b1-sns1120% NOx Point & O&G inNAA + 20% NOx Pawnee0.0 0.0 -23.0 0.0% 0.0% -2.7%-0.2-0.5 0.3 -0.8 1.7 -2.0b1-sns12aEffects of increase in BarkBeetle 2006 to 2010-8.4 -87.8 -0.3 -0.2% -11.6% 0.0%0.0-0.1 0.1 -0.1 0.1 -0.1b1-sns12bEffects of 2010 BarkBeetle infestation-21.1 -233.5 -0.8 -0.6% -30.8% -0.1%-0.1-0.1 0.1 -0.1 0.3 -0.3F:\Denver_O3_2008\Reports\2010_Sens_OSAT\d raft#1\Exec_Sum1.doc August 2008 ES-7 2010 OZONE SOURCE APPO RTIONMENT MODELING

The Anthropogenic Precursor Culpability Asse ssment (APCA) version of the CAMx ozone source apportionment was applied using the 201 0 base case inventory with the emissions segregated into 8 source categories and 11 source regions. The source categories are presented in Table ES-3 and the geographic source regi ons are given in Table ES-4. Ozone source apportionment is obtained for each source group, which consist of a source region and source category (e.g., on-road mobile sources from the 7-County Denver Metro area). As the

contributions of ozone from initial concentratio ns (IC) and boundary conditions (BC) are always obtained, this results in ozone source apportionment to 90 separa te source groups in the Denver ozone source apportionment m odeling (90 = 8 x 11 + 2).

The CAMx ozone source apportionment uses reactiv e tracers that operate in parallel to the host model. For each source group, ther e are four tracers correspondi ng to the source group’s VOC and NOx concentrations (V i and N i ) and ozone formed that is attributable to the source groups VOC concentrations (O3V i ) or NOx concentrations (O3N i ). In the original Ozone Source Apportionment Technology (OSAT) ozone source apportionment approach implemented in CAMx, when ozone is formed in a grid cell it is attributable to a source group based on the relative contributions of the source groups VOC or NOx concentration to the total VOC or NOx concentration in that grid cell based on a dete rmination of whether the ozone formed was under VOC-limited or NOx-limited conditions. Thus, in OSAT the O3V and O3N reactive tracers

indicate how much of the ozone is formed under VOC-limited versus NOx-limited conditions. This results in OSAT assigning ozone to bioge nic VOCs, which is not necessarily control strategy relevant information as they are unc ontrollable. The APCA version of source apportionment only assigns ozone formed to biogeni c (uncontrollable) sources when it is due to the interaction of biogenic VOC with biogenic NOx. When ozone is formed under VOC-limited conditions due to the interaction of biogenic VOC with anthropogenic NOx, a case where OSAT would assign it to the biogenic VOC (O3V) sour ce group, APCA redirects the assignment to the anthropogenic NOx (O3N) source group. Thus, with APCA the O3V and O3N tracers no longer represent ozone formed under VOC-limited and NOx-limited conditions.

The source apportionment results were analyzed at each of the ozone monitor sites in the DMA. At each monitor location, for each day, the 8-hou r average ozone results for each period over 70 ppb were averaged to develop a composite contribution.

Example displays for a high ozone day (July 29 th ) at the Rocky Flats Nort h monitor are presented in Figure ES-2. APCA ozone s ource apportionment modeling resu lts for other days and other monitors are presented in Appendix C. The resu lts show significant day-to-day and monitor-tomonitor variations. Figure ES-2a presents the ozone results including the boundary conditions, that is, the contribution from sources outside the 12 km domain. Of the 76.1 ppb of ozone estimated at the monitor, ~48 ppb (two-thirds) was transported into the 12 km domain and ~18 ppb (one-third) was attributed to sources in the seven-county Denver Metro area. Figure ES-2b presents the same results as ES-2a, but without the boundary conditions pl otted and the vertical scale expanded to better resolve the source region contributions. This figure shows that of the ~18 ppb from Metropolitan Denver sources, ~10 ppb was from motor vehicles, ~5 ppb was from

non-road mobile sources with the balance from other sources. Figure ES-2c presents the ozone

formed that is attributable to anthropogenic NOx concentrations, whereas Figure ES-2d presents the ozone formed attributable to anthropogeni c and biogenic VOC concen trations. These twoF:\Denver_O3_2008\Reports\2010_Sens_OSAT\d raft#1\Exec_Sum1.doc August 2008 ES-8 figures suggest that emission reductions from an thropogenic NOx sources will be more effective at reducing ozone in the mode l than reductions from anthropo genic VOC sources, although both

VOC and NOx controls will reduce ozone. The Fort Collins West monitor shows similar contributions as the Rocky Flats North monitor ex cept the highest contributions are from sources in the Larimer/Weld County source region and o il and gas sources from Larimer/Weld county have a large contribution.

The source apportionment results vary by day and by location. However, several overall trends emerge, namely:

• Regional ozone transport into the 12 km do main is the largest contributor, often accounting for more than two-thirds of the total ozone;

• At the Denver Metropolitan monitors the la rgest contributors ar e Denver Metropolitan metro area motor vehicle and non-road sources;

• At the Fort Collins and Greeley monitors, the largest contributors tend to be Larimer and Weld County motor vehicles, non-road sour ces and oil and gas sources, and Denver Metropolitan sources;

• The majority of the ozone formed is attr ibutable to anthropogenic NOx emissions.

In interpreting these results it is important to keep in mind that these source apportionment results are based on the Denver SIP 2006 modeling episode and are meteorologically dependent. For instance, the source apportionment modeling in support of the Denver Early Action Compact using a 2002 ozone episode showed more impact of sources in Northern Colorado into the Denver Metropolitan area.F:\Denver_O3_2008\Reports\2010_Sens_OSAT\d raft#1\Exec_Sum1.doc August 2008 ES-9 Figure ES-2a. Rocky Flats North source apporti onment for 29 July including boundary
conditions.

Figure ES-2b. Rocky Flats North source apporti onment for 29 July excluding boundary
conditions.F:\Denver_O3_2008\Reports\2010_Sens_OSAT\d raft#1\Exec_Sum1.doc August 2008 ES-10 Figure ES-2c. Rocky Flats North source apporti onment for 29 July attributable to anthropogenic NOx emissions.

Figure ES-2d. Rocky Flats North source apporti onment for 29 July attributable to anthropogenic and biogenic VOC emissions.F:\Denver_O3_2008\Reports\2010_Sens_OSAT\d raft#1\Exec_Sum1.doc August 2008 ES-11 CONCLUSIONS OF 2010 OZ ONE PROJECTIONS AND

EMISSIONS SENSITIVITY TESTS

The 2010 emissions reduction sensitivity tests and 2010 ozone source apportionment modeling provide consistent results. The source appor tionment modeling estimates that when daily maximum 8-hour ozone concentrations are greater than 70 ppb then approximately two-thirds of the ozone in the DMA is coming from outside of the Denver 12 km modeling domain (roughly outside of Colorado and adjacent states). Most of the remainder one-third of the ozone comes from sources within the Denver 9-county NAA. For the Rocky Flats North monitoring site on July 29, 2006, the 2010 ozone source apportionment results suggest that half of the locally generated ozone comes from on-road mobile sour ces, with ~1/4 from non-road mobile source, 1/8 from EGU point sources and the remainder 1/8 from area, non-EGU and oil and gas (O&G) sources from the 7-County Denver area. For the Forth Collins West monitoring sites a similar breakdown in source categories is seen only sour ces from Larimer/Weld Counties contribute more than sources from the 7-County DMA a nd O&G emissions from Larimer/Weld Counties are major contributors as well.

The APCA ozone source apportion ment attributes most of the ozone formed to anthropogenic NOx emissions rather than anthropogenic and biogenic VOC emissions. This suggests that anthropogenic NOx control may be a viable path toward reducing ozone concentrations. The 2010 sensitivity modeling also suggests that NOx emissions reductions are effective at reducing ozone concentrations. However, the 2010 emissions sensitivity tests also saw areas where the

NOx emission reductions resulted in ozone increases. These areas include isolated grid cells at the locations of some point sources and within the Denver urban core. The extent of the ozone

increases due to the NOx controls in the Denver urban core varied day-to-day due to changes in emissions (e.g., weekday versus weekend day) a nd meteorology. However, the overall benefits for reducing ozone from the NOx controls out we igh the adverse effects of the ozone increases, although care should be taken in the level and types of NOx emi ssions controlled to limit the adverse effects. Although the VOC emission reductions do not produce as large ozone reduction as the NOx controls at some key sites (e.g., Fo rt Collins West), they always reduce ozone or

have no effect and no adverse effects of VOC emissions redu ctions are seen.

Thus, an ozone reduction path using either NOx and/or VOC emission reductions appear to be a viable paths in the Denver area. The VOC emi ssion reductions always reduce ozone or have no or very little effect. Although the ozone reductions due to the NOx controls are larger and more widespread, there are also local ozone increases due to the NOx controls that need to be

considered.F:\Denver_O3_2008\Reports\2010_Sens_OSAT\draft#1\Sec1_2010_Intro1.doc August 2008 1-1 1.0 INTRODUCTION

1.1 BACKGROUND

Ozone air quality in the Denve r Metropolitan Area (D MA) has been near the 8-hour ozone National Ambient Air Quality Standard (NAAQS) of 0.08 ppm (exceedance defined by values of 85 ppb or higher) for several years. In December 2002, the Denver Regional Air Quality Council (RAQC) and Colorado Department of Health and Environment (CDPHE) Air Pollution Control Division (APCD) and others entered in to an 8-hour ozone Early Action Compact (EAC) with the U.S. Environmental Protection Agency (E PA). EPA’s EAC allows an area to submit an enforceable 8-hour ozone State Implementation Plan (SIP) by March 2004 that demonstrates attainment of the 8-hour ozone NAAQS by 2007. In return, EPA will defer the classification of

an area as nonattainment until 2007. Base d on 2005-2007 measured air quality, the DMA violated the 0.08 ppm 8-hour ozone NAAQS, so in November 2007 the DMA reverted to an 8- hour ozone nonattainment area and is required to prepare an 8-hour ozone State Implementation Plan (SIP) that demonstrates attainment by 2010. The contracting team of ENVIRON International Corporation, and their subcontract or Alpine Geophysics, LLC, were selected by the RAQC and CDPHE to perform the 2010 8-hour oz one attainment demonstration modeling for

the new SIP.

On March 12, 2008, EPA promulgated a new primary ozone NAAQS that has the same form as the 0.08 ppm 8-hour ozone NAAQS, but lowers the threshold from 0.08 ppm (85 ppb) to 0.075 ppm (75 ppb). Of the ~14 ozone monitors in the greater DMA, ha lf have 2005-2007 8-hour ozone DVs that are 75 ppb or higher. The cu rrent Denver 8-hour ozone SIP modeling effort addresses the 0.08 ppm 8-hour ozone NAAQS, the new 0.075 ppm 8-hour ozone NAAQS will be

addressed in the future.

1.2 PURPOSE

The fifth generation Mesocale Model (MM5) me teorological model (Anthes and Warner, 1978; Dudhia, 1993), the Sparse Matrix Operating Kernel Emissions (SMOKE) modeling system (Coats, 1996) and the Comprehensive Air- quality Model with extensions (CAMx) photochemical grid model (ENVIRON, 2008) are be ing used to model ozone in the Denver area for a June-July 2006 modeling period for the purposes of demonstrating attainment of the 8-hour ozone standard by 2010. The 8-hour ozone m odeling activities being performed by the ENVIRON/Alpine Modeling Team consis ts of the following activities:

• Development of a Denver 8-hour ozone SIP a ttainment demonstration Modeling Protocol (Morris et al., 2007; http://www.ozoneaware.org/documents /DraftFinalProtocolDenver8- HourOzoneNov282007.pdf );

• MM5 meteorological modeling and model pe rformance evaluation (McNally et al., 2008a);

• Development of a preliminary 36/12/4 km photochemical modeling database for the June-July 2006 episode, the DMA, and initia l model performance evaluation, sensitivity test modeling and identification of optimal model configuration for simulating ozone in the DMA (Morris et al., 2008b);F:\Denver_O3_2008\Reports\2010_Sens_OSAT\draft#1\Sec1_2010_Intro1.doc August 2008 1-2 • Final base case modeling and model perfor mance evaluation for the June-July 2006 DMA episode (Morris et al., 2008c);

• 2010 base case modeling, emission sensitivity tests and ozone source apportionment modeling (this document); and

• 2010 control strategy modeling (in progress).

1.3 OVERVIEW OF MODELING APPROACH

Figure 1-1a displays the MM5 (r ed) and CAMx (blue) 36/12/4 km modeling domains used in the Denver 8-hour ozone modeling study. The CAMx model was first applied to the 36 km continental U.S. domain using boundary condi tions (BCs) from a globa l climate air quality model (Figure 1-1a). The CAMx 2006 and 2010 base case modeling results from the 36 km continental U.S. domain simulation are then pr ocessed to generate BCs for the CAMx 12/4 km domain (Figure 1-1b) and the, respectively, 2006 12/4 km base case and 2010 12/4 km base case and sensitivity simulations. The CAMx simula tions for the 12/4 km domains were run using two-way interactive grid nesting (i.e., pollutant s can flow back and forth between the 12 km and 4 km domains to account for recirculation).

-2880-2520-2160-1800-1440-1080 -720 -360 0 360 720 1080 1440 1800 2160 2520 2880 -2160 -1800 -1440 -1080

-720 -360 0 360 720 1080 1440 1800 2160

MM5 36 km CAMx 36 km MM5 12km CAMx 12km MM5 4km CAMx 4

Figure 1-1a. Nested 36/12/4 km modeling domains for the Denver 8-hour ozone modeling study. Blue line domains are for CAMx/SMOKE domains that are nested in the MM5 red line

domains.F:\Denver_O3_2008\Reports\2010_Sens_OSAT\draft#1\Sec1_2010_Intro1.doc August 2008 1-3 -1680-1560-1440-1320-1200-1080 -960 -840 -720 -600 -480 -360 -240 -120 0 120 240 -600 -480 -360 -240 -120 0 120 240 360 480

CAMx 12km CAMx 4km



### Denver CAMx 12 and 4 km Domain
Figure 1-1b. Nested 12/4 km modeling domains for t he Denver CAMx air quality and SMOKE emissions modeling.

1.4 2010 EMISSIONS MODELING APPROACH

The 2010 base case emissions were prepared using the same proce dures as used to prepare the

final 2006 base case emissions scenario (Morris et al., 2008 b). The CDPHE/APCD provided 2010 emissions for all anthropogenic emission sources except oil and gas (O&G) emissions in the Denver-Julesburg Basin for which 2010 emissi ons from the WRAP Phase III O&G emissions development project were utilized (Bar-Ilan et al., 2008b). Outside of Colorado the 2010 anthropogenic emissions were based on the WR AP 2002 and 2018 emissions inventories. CAMx-ready emissions were generated using the Sparse Matrix Operat or Kernel Emissions (SMOKE) emissions modeling system (Coats, 1996) for all anthropogenic emissions categories except on-road mobile sources in the DMA, whic h used the Consolidated Community Emissions Processing Tool (ConCEPT) modeling system (Loomis et al., 2005). The same biogenic emissions were used for the 2010 base case as were used for the final 2006 base case biogenic

emissions were based on the Model of Emissions of Gases and Aerosols from Nature (MEGAN) biogenic emissions model (Guenther and Wiedinmy er, 2004). Emissions from fires were also kept constant between the 2006 base case and 2010 base case emission scenarios.F:\Denver_O3_2008\Reports\2010_Sens_OSAT \draft#1\Sec2_2010-DV1.doc August 2008 2-1 2.0 2010 OZONE PROJECTIONS

2.1 INTRODUCTION

This section presents the 2010 ozone Design Valu e projections for the 2010 base case and the 2010 emission sensitivity scenarios. These pr ojections are made using the CAMx modeling results for the 2006 base case (Morris et al ., 2008b,c) and the 2010 base case and emission sensitivity scenarios. The EPA Modeled Attainme nt Test Software (MATS) tool was used to make the 2010 8-hour ozone Design Value projections.

2.2 OZONE PROJECTION PROCEDURES

The EPA modeling guidance for 8-hour ozone attainment de monstration modeling contain specific procedures that use current-year and futu re-year modeling results in a relative fashion to scale current-year observed 8- hour ozone Design Values to pr oject future-year 8-hour ozone Design Values for comparisons with the NAAQS (EPA, 2007). The EPA guidance projection procedures were used to estimate 2010 8-hour ozone Design Values for the 2010 base case and 2010 sensitivity simulations. If the future-year De sign Value for a monitor is less than or equal to 84 ppb, the modeled attainment test is passed. If the future-year Design Value is greater than or equal to 85 ppb, the modeled attainment test is not passed. If the future-year Design Value lies between 82 and 87 ppb, a weight of evidence (WOE) determination is required that provides

corroborative information that attainment will be achieved in the future-year.

The EPA guidance procedure for projecting futu re-year 8-hour ozone Design Values has been

codified in EPA’s Modeled Atta inment Test Software (MATS; http://www.epa.gov/ttn/scram/modelingapps_mats.htm ). This procedure st arts with a currentyear observed 8-hour ozone Design Value (DVC) for each monitor. The modeling results are

then used to scale the observed 8-hour ozone DVC to obtain a future-year 8-hour ozone Design Value projection (DVF). This is done thr ough the calculation of model-estimated relative response factors (RRFs) that are the ratio of th e model-estimated 8-hour ozone concentrations for the future-year to current-year emission scenarios. The RRF is monitor-specific and is used to scale the current year observed design value ( DVC) to estimate the projected future-year 8-hour ozone design value (DVF):

DVF = DVC x RRF

The RRF is defined as the ratio of the averag e of the maximum 8-hour ozone concentrations “near a monitor” for the future-year emissions scen ario to the average for the current year base

case emissions scenario. The EPA default defini tion of “near a monitor” is to select the maximum model-estimated daily maximum 8-hour oz one concentrations from an array of grid

cells centered on the monitor. The size of the arra y of grid cells centered on the monitor is grid cell size dependent and for the 4 km grid cell resolutions used in the Denver modeling, EPA recommends use of an array of 7 x 7 grid cells centered on the monitor (EPA, 2007).F:\Denver_O3_2008\Reports\2010_Sens_OSAT \draft#1\Sec2_2010-DV1.doc August 2008 2-2 EPA’s 8-hour ozone modeling guidance includes the following language for selecting the current-year observed 8-hour ozone design values that are used in the modeled attainment

demonstration test:

“For the modeled attainment tests we reco mmend using the average of the three design value periods which include the baseline inven tory year...The average of the three design value periods best represents the baseline concentration, while ta king into account the variability of meteorology and emi ssions (over a five year period).” (EPA, 2007, pg. 22).

For the Denver modeling that used the 2006 base line inventory and modeling year, that would mean the current year 8-hour ozone Design Value (DVC) would be based on the average of three years of Design Values from 2004-2006, 2005-2007 and 2006-2008. As the 2008 ozone season is not yet complete, the 2006-2008 8-hour ozone Desi gn Values can not yet be calculated. We considered using the average of two year s of Design Values from 2004-2006 and 2005-2007, but

in that case none of the DVCs would be violatin g the 8-hour ozone NAAQS. Thus, we used the 2005-2007 Design Value as the starting current-y ear Design Value (DVC) in the 2010 ozone projections for all monitors but one. This is appropriate as the 2005- 2007 8-hour ozone Design Values are the very ones that resulted in De nver being declared an 8-hour ozone nonattainment area in November 2007. The one exception to this is for the Fort Collins West monitor that started operating in 2006 so a “2-year” 8-hour ozone Design Value will be used (i.e., average of fourth highest daily maximum 8-hour ozone concentrations from 2006 and 2007). Table 2-1 displays the fourth highest da ily maximum 8-hour ozone concentr ations at monitors in the Denver area and the 2005-2007 Design Values that were used as the DVC starting point for the future-year ozone projections. The use of these DVCs was agreed to by RAQC, CDPHE and EPA early on in the process and was stated in the Modeling Protocol (Morris et al., 2007).

EPA recommends that at least of 10 modeling da ys be included in the calculation of the RRFs and future-year design values with an absolute 5 day minimum. The criterion for using an episode day in calculating the episode average Desi gn Value for that monitor is that the modeled daily maximum 8-hour ozone near the monito r exceeds a minimum threshold value. EPA recommends use of an 85 ppb threshold in the future-year 8-hour ozone Design Value calculations, but if insufficient number of days are available to calculate the RRFs then this threshold can be reduced by 1 ppb until sufficien t modeling days are obtained, or until a 70 ppb floor is obtained. When the 70 ppb threshold floo r is reached and there are less than 5 days available for calculating a RRF, then no RRF is calculated. For the Denver June-July 2006 modeling, we were able to calculate RRFs for all monitors in the DMA using 10 days or more of modeling results and never achieved the 70 ppb threshold floor.

In the final step of the modeled attainment te st, the projected future -year 8-hour ozone Design Value is truncated to the nearest ppb and then compared with the NAAQ S; if it is 84 ppb or

lower at all monitors in the area then the modele d attainment test is passed. As noted above, even if the modeled attainment test is passe d, if there are any proj ected 8-hour ozone Design Values above 82 ppb, then a weight of evidence (WOE) analysis is required that presents

corroborative evidence that attainment would be achieved. Even if the modeled attainment test is not passed, if the projected future-year 8-hou r ozone Design Values at all monitors are 87 ppb or lower, a WOE attainment demo nstration may still be conducted.F:\Denver_O3_2008\Reports\2010_Sens_OSAT \draft#1\Sec2_2010-DV1.doc August 2008 2-3 Table 2-1. Fourth highest daily maximum 8-hour ozone concentrations (ppm) at monitoring sites in the Denver area during 2005, 2006 and 2007 and 2005-2007 8-hour ozone Design Values that is used as the current-year Design Value (DVC) starting point for the 2010 8-hour ozone projections.

Site Name 2005

4 th Maximum 8-Hour Average

Value (ppm) 2006

4 th Maximum 8-Hour Average

Value (ppm) 2007

4 th Maximum 8-Hour Average

Value (ppm) 2005 - 2007 3-Year Average

4 th Maximum Value (ppm) Welby 0.073 0.069 0.070 0.070 Highland 0.080 0.081 0.075 0.078
S. Boulder Creek 0.076 0.082 0.085 0.081
Denver – CAMP 0.051 0.062 0.057 0.056 Carriage 0.074 0.072 0.076 0.074
Chatfield State Park 0.084 0.086 0.082 0.084 USAF Academy 0.077 0.072 0.071 0.073 Manitou Springs 0.075 0.076 0.072 0.074

Arvada 0.078 0.082 0.078 0.079

Welch 0.064 0.081 0.080 0.075 Rocky Flats North 0.077 0.090 0.090 0.085

NREL 0.079 0.083 0.085 0.082
Fort Collins – West --- 0.087 0.085 0.086*
Fort Collins 0.076 0.078 0.069 0.074 Greeley – Weld Tower 0.078 0.082 0.074 0.078 Rocky Mountains NP 0.075 0.076 0.078* 0.076 * Fort Collins West monitor started in 2006 so a 2-year average 4 th maximum 8-hour ozone concentrations is used

EPA’s 8-hour ozone projection procedure also in cludes an unmonitored area analysis that has

also been codified in MATS. The unmonitored area analysis uses the future-year 8-hour ozone Design Value projection procedure described above applied to e ach grid cell in the modeling domain. In this procedure, the current-year Design Values (DVC) are first interpolated to each grid cell in the modeling domain. This interp olation scheme uses the modeled concentration gradients in its interpolation procedures. RRF s are then obtained for each grid cell in the modeling domain using the procedures describe d above except using the actual modeled daily maximum 8-hour ozone concentrations in each grid cell (co-located) rather than values near the grid cell. The same rules are used to assure th ere are sufficient days to calculate a robust and reliable RRF. Namely, pick the highest days ab ove a threshold value so that at least 10 modeling days are used in the RRFs by reducing the threshold from 85 ppb until the 70 ppb floor is reached. If with the 70 ppb floor there are 5 or more days the RRF is still used. However, for grid cells in which there ar e less than 5 modeling days w ith daily maximum 8-hour ozone concentrations greater than 70 ppb no RRF is calculated and consequently no 2010 projected DVF is obtained for that grid cell.

2.3 OZONE PROJECTIONS FOR THE 2010 BASE CASE

The EPA recommended procedures for projecting future year 8-hour ozone Design Values and the MATS tool were used with the CAMx 2006 and 2010 base case modeling results to project 2010 8-hour ozone Design Values at monitors in the Denver area. Table 2-2 shows the total VOC, NOx and CO emissions in Colorado for the 2006 and 2010 base case and three representative days from the June-July 2006 mo deling period (including a weekday and weekendF:\Denver_O3_2008\Reports\2010_Sens_OSAT \draft#1\Sec2_2010-DV1.doc August 2008 2-4 days). The anthropogenic emissions are for the state of Colorado, whereas the biogenic emissions are for the 4 km grid domain, which matches the state of Colorado reasonably well (see Figure 1-1). The anthropogenic VOC, NOx a nd CO emissions are projected to be reduced by 5.3%, 3.3% and 10.1% between 2006 and 2010 on th e weekday selected (July 21). When accounting for the presence of biogenic emissi ons, the percent reduc tion of NOx and CO

emissions between 2006 and 2010 are reduced a l ittle, but for the VOC emissions the 5.3% reduction in anthropogenic VOC emissions is re duced to 0.6% reduction when accounting for

total emissions state-wide in Colorado.

Table 2-2. Summary of 2006 and 2010 base case VOC, NOx and CO emissions in Colorado for July 21-23, 2006. Anthropogenic Biogenic

2006
Base 2010
Base Difference (TPD) Difference (%) (TPD) VOC (TPD) July 21 (Friday) 807.0 764.0 -43.0 -5.3% 3795.1 July 22 (Saturday) 807.2 775.0 -32.2 -4.0% 4596.3 July 23 (Sunday) 799.0 771.1 -27.8 -3.5% 4960.3 NOx (TPD) July 21 (Friday) 862.6 833.8 -28.8 -3.3% 39.4 July 22 (Saturday) 715.3 713.0 -2.3 -0.3% 42.4 July 23 (Sunday) 704.4 699.1 -5.3 -0.7% 51.2 CO (TPD) July 21 (Friday) 3840.2 3452.3 -388.0 -10.1% 575.1 July 22 (Saturday) 4281.9 3979.4 -302.5 -7.1% 647.7 July 23 (Sunday) 4284.6 4016.9 -267.7 -6.2% 722.6

Table 2-3 summarizes the projec ted 8-hour ozone Design Values (DVF) at the DMA monitoring

sites for the 2010 base case simulation usi ng the CAMx 2006 and 2010 base case modeling

results and EPA recommended de fault ozone projection procedur es described above. The maximum projected 8-hour ozone Design Value is 84 ppb and occurs at both the Rocky Flats North (RFNO) and Fort Collins West (FCTW) monito ring sites (see column 5). As this value is 84 ppb or lower, then the 2010 base case mode ling results pass the modeled attainment demonstration test. However, because the ma ximum projected 8-hour oz one Design Values lie between 82 and 87 ppb, then a WOE analysis is required. Although the EPA 8-hour ozone projection procedure is to trunc ate the final projected DVF for comparisons with the NAAQS, in column 6 we present the DVFs to the nearest tent h of a ppb before truncation. In this case we see that the projected 2010 base cas e DVFs at RFNO and FTCW are both 84.9 ppb.

Also shown in Table 2-3 is the RRF and the cut- off threshold used in selecting days and number of days used in calculating the RRF. The EPA desi re to use at least 10 modeled days is satisfied using the Denver June-July 2006 modeling period. In order to achieve that many modeled days,

the cut-off threshold had to be reduced to 74 ppb to 78 ppb depending on the monitor, with the RFNO and FTCW monitors using a 78 and 76 ppb threshold, respectively.

The level of ozone reductions in the projected Design Values app ears to be greater the further away from central Denver the monitor resides. In fact, ozone is estimated to increase very slightly at the monitors in or immediately dow nwind of the urban core. This is due to the

reductions in on-road mobile sources NOx emissions that increase ozone in the urban core. This

ozone increase due to NOx emission reductions is due to less ozone titration from a reduction ofF:\Denver_O3_2008\Reports\2010_Sens_OSAT \draft#1\Sec2_2010-DV1.doc August 2008 2-5 the primary emitted NO emissions (NO + O 3 Æ NO 2 +O 2 ) and/or less NOx inhibition effect on ozone formation that high NOx concentrations ha ve as a termination step to the radical cycle (NO 2 + OH Æ HNO 3 ). This effect is seen in differen ce plots in daily maximum 8-hour ozone

concentrations between the 2010 and 2006 base case simulations shown in Figure 2-1 for four days. These four days were selected because th ey were four common days out of the ~10 that were used in the 2010 Design Value projections for both the RFNO and FTCW monitoring sites.

Most of the NOx emission reductions between the 2006 and 2010 base cases occur in the DMA, as shown in Figure 2-2. This is the area th at experiences ozone increases from 2006 to 2010 (Figure 2-1). As one moves away from the Denver urban core, the ozone increases between 2006 and 2010 turn into no change and then to oz one decreases. The distance from the Denver urban core when the ozone increases change to oz one decreases varies by day due to changes in emissions (e.g., weekday versus weekend day) a nd changes in meteorology. The RFNO monitor

lies near the modeled ozone incr ease-to-decrease cross over dist ance, which explains why the model projected 2010 Design Value is relative inse nsitive to the changes in emissions from 2006 to 2010 at this site (85.0 to 84.9 ppb, a 0.1 ppb reduction); of the 10 days used to construct the RRF for RFNO there are some days of ozone incr eases and some with oz one decreases. This effect is seen in the ozone difference plots for f our of the ten days used in developing the RRF for the RFNO monitoring site. At the FTCW monitoring site, on the other hand, the model is more responsive (1.1 ppb ozone reduction) as it is an area far enough away from the Denver urban core where the modeled ozone changes eith er stay the same or are reduced between 2006

and 2010.

Table 2-3. Current-year (DVC) and projected future-year (DVF) 8-hour ozone Design Values using the CAMx 2006 and 2010 base case modeling results.

2010 Base Case
Site ID Monitor Name County 2005-07
DVC DVF DVF RRF Cutoff #days 80013001 Welby Adams 70.0 70 70.2 1.0042 77.0 11 80050002 Highland Arapahoe 78.0 77 77.3 0.9916 78.0 14
80130011 S. Boulder Creek Boul der 81.0 80 80.8 0.9976 78.0 10
80310002 Denver - CAMP Denv er 56.0 56 56.0 1.0017 78.0 10 80310014 Carriage Denver 74.0 74 74.1 1.0022 78.0 10 80350004 Chatfield State Park Douglas 84.0 83 83.4 0.9934 78.0 11 80410013 USAF Academy El Paso 73.0 72 72.0 0.9873 75.0 10 80410016 Manitou Springs El Paso 74.0 73 73.7 0.9966 74.0 10

80590002 Arvada Jefferson 79.0 79 79.2 1.0026 78.0 10

80590005 Welch Jefferson 75.0 75 75.0 1.0004 78.0 10 80590006 Rocky Flats North Jefferson 85.0 84 84.9 0.9994 78.0 10

80590011 NREL Jefferson 82.0 82 82.3 1.0039 78.0 11
80690011 Fort Collins - West Larimer 86.0 84 84.9 0.9874 76.0 10
80691004 Fort Collins Larimer 74.0 73 73.0 0.9878 76.0 12 81230009 Greeley - Weld Tower Weld 78.0 77 77.7 0.9964 75.0 10
GTH161 Gunnison Gunnison 68.0 67 67.8 0.9984 74.0 10
ROM206 Larimer Larimer 76.0 75 75.2 0.9903 77.0 10
ROM406 Larimer Larimer 76.0 75 75.2 0.9903 77.0 10F:\Denver_O3_2008\Reports\2010_Sens_OSAT \draft#1\Sec2_2010-DV1.doc August 2008 2-6 Figure 2-1. Difference plots in daily maximum 8-hour ozone concentrations between the 2010 and 2006 base case CAMx simulations for July 29 (top left), June 27 (top right), June 28 (bottom left) and June 12 (bottom right), 2006.F:\Denver_O3_2008\Reports\2010_Sens_OSAT \draft#1\Sec2_2010-DV1.doc August 2008 2-7 Figure 2-2. 2010 minus 2006 base case emissions difference plots for NOx (left) and VOC (right).

Figure 2-3 displays the results of the 8-hour ozone DVF projecti ons using the unmonitored area analysis from MATS. Figure 2-3a displays the interpolated fields of the current year Design Values (DVCs). DVCs in excess of 80 ppb are es timated to the south, west and northwest of Denver stretching to Fort Collins and then west of Fort Collins. In fact, the MATS interpolation procedures estimates that current-year DVCs in excess of the 85 ppb NAAQS occur in 12 grid

cells to the west of the Fort Collins sites (Figure 2-3a). Th e projected DVFs for the 2010 base case (Figure 2-3b) have greatly reduced the sp atial extent of the DVFs in excess of 80 ppb occurring to the south, west and northwest of Denver and the 12 cells with DVCs exceeding the 85 ppb NAAQS have been reduced by half to 6 grid cells in the 2010 base case emissions

scenario.

EPA guidance stresses that the unmonitored area te st has more uncertainties than the projections at the monitors and it should be treated separate ly from the monitor based attainment test (EPA, 2007). EPA further notes that while it is expected that additional emission controls are needed to eliminate predicted violations of the monitor based test, the same requirements may not be appropriate in unmonitored area s. In any event, EPA recommends that areas of predicted

violations in the unmonitored ar ea test be scrutinized and understood to determine whether they are likely to exist in the ambient air or whether they may be caused by an error or uncertainties in the modeling system. At a minimum, it may be appropriate to deploy additional ozone monitors

to such areas. In the case of the Denver ozone modeling, higher ozone concentrations are

estimated west of Fort Collins than at the locatio ns of the two monitors in Fort Collins on some days and this does not appear to be due to an error in the modeling system. Whether it may be

due to uncertainties in the modeli ng system can not be determined. However, the placement of the Fort Collins West monitor west of the orig inal Fort Collins monito r in 2006 has found much higher observed ozone in the ambient air, it does not seems implausible that even higher values

could exist even further west from Fort Collins.F:\Denver_O3_2008\Reports\2010_Sens_OSAT \draft#1\Sec2_2010-DV1.doc August 2008 2-8 Figure 2-3a. Current-year 8-hour ozone Design Values (DVC) interpolated by the MATS tool.F:\Denver_O3_2008\Reports\2010_Sens_OSAT \draft#1\Sec2_2010-DV1.doc August 2008 2-9 Figure 2-3b. Projected 2010 8-hour ozone Design Values (DVF) generated by the MATS tool
for the 2010 base case emissions scenario.F:\Denver_O3_2008\Reports\2010_Sens_OSAT \draft#1\Sec2_2010-DV1.doc August 2008 2-10 2.4 2010 SENSITIVITY TESTS

Sixteen (16) 2010 emissions reductions sensi tivity tests were conduc ted with the CAMx modeling system. Most of these emission reduc tion sensitivity tests reduced VOC and/or NOx emissions from a specific source category either just within the Denver nonattainment area (NAA) or within the entire state of Colorado. Ozone projections were made at each of the monitoring sites for each of the 2010 sensitivity tests. We also performed the unmonitored area analysis for each sensitivity test to better understa nd the spatial extent of any ozone benefits or

adverse effects. Table 2-4 describes each of the se nsitivity tests. All se nsitivity tests modified

emissions from the 2010 base case emissions scenario.

The first three sensitivity tests examined the sensitivity of 2010 ozone formation to on-road

mobile sources emissions within the Denver NAA. The first 2010 sensitivity test (b1-sens01)

examined a 20% across-the-board reduction in VOC emissions from on-road mobile sources in the NAA. The second sensitivity test examined the effects of reducing evaporative VOC emissions from on-road mobile sources by specif ying a baseline gasoline Reid Vapor Pressure (RVP) of 7 psi. Thus, with the assumed 85% ethanol market penetration in 2010 with a 1 psi waiver and a 7.8 psi RVP for the base case gasoline, this results in a re duction in the average RVP of gasoline in the Denver NAA from 8.65 psi in the 2010 base case to 7.85 psi in the b1- sen02 2010 sensitivity case. The third mobile source sensitivity test assumed zero ethanol market penetration in the NAA and accompanyi ng changes in on-road and non-road mobile gasoline engines’ VOC, NOx and CO emissions.

The next 11 sensitivity tests list ed in Table 2-4 (b1-sens04 to b1-sens11) are self explanatory with reductions in VOC and/or NOx from specifi cally identified source categories either just within the Denver NAA or throughout Colorado.

The final two sensitivity tests were designed to assess the sensitivity that the Bark Beetle infestation would have on bioge nic VOC emissions and projected 2010 ozone concentrations. The MEGAN biogenic emissions model was used to estimate the effects the Bark Beetle infestation would have on biogenic emissi ons. The 2006 and 2010 base case MEGAN biogenic

emissions simulations assumed no Bark Beetle infest ation. Estimates of the spatial extent of the

Bark Beetle infestation from 2006 and 2010 were obt ained from Dr. Christine Wiedinmyer of the National Center for Atmospheric Research (NCAR) and MEGAN was rerun assuming that biogenic emissions were reduced over the infestation areas to obt ain two new sets of biogenic emission inputs accounting for the extent of Bark Beetle infestation in 2006 and 2010. The first Bark Beetle infestation sensitivity test was de signed to determine whet her the reductions in biogenic emissions due to the changes in Bark Beetle infestation between 2006 and 2010 would affect the 2010 ozone projecti ons (b1-sens12a). This was accomplished by reducing biogenic

emissions from the MEGAN no Bark Beetle si mulation used in the 2006 and 2010 base case simulations by the reductions in the bioge nic emissions estimates between the MEGAN 2006

and 2010 Bark Beetle infestation emissions estimat es. The second Bark Beetle sensitivity test was designed to determine whether the differences of with or without Bark Beetle effects on biogenic emission would affect ozone formation so used the MEGAN 2010 Bark Beetle infestation biogenic emission estimates with all other emissions identical to the 2010 base case

simulation.F:\Denver_O3_2008\Reports\2010_Sens_OSAT \draft#1\Sec2_2010-DV1.doc August 2008 2-11 Table 2-4. Description of 2010 sensitivity tests performed using the Denver CAMx 12/4 km modeling system.

Sens Test Description

2006.a3 2006 base case and current year 8-hour Ozone Design Value (DVC)

b1 2010 Base Case

b1-sns01 20% reduction in VOC on-road mobile sources in NAA

b1-sns02 Evaporative VOC on-road mobile sens itivity in NAA using 7 psi RVP gasoline

b1-sns03 0% Ethanol penetration in NAA

b1-sns04 20% reduction in VOC from O&G sources in NAA

b1-sns04b 20% reduction in VOC & NOx from ar ea, point, non-road and O&G sources in NAA b1-sns04c 20% VOC & 30% NOx reduction in area, point, non-road and O&G sources in NAA

b1-sns04d 40% reduction in VOC from O&G sources in NAA

b1-sns05 20% reduction in NOx from point & O&G sources in NAA

b1-sns06 20% reduction in VOC from non-road mobile sources in NAA

b1-sns07 20% reduction in VOC from area sources in NAA

b1-sns08 20% reduction in NOx from point & O&G sources in Colorado

b1-sns09 20% reduction in VOC from O&G sources in Colorado

b1-sns10 20% reduction in VOC & NOx from point & O&G sources in Colorado b1-sns11 20% reduction in NOx from point & O&G in NAA + 20% reduction in NOx from Pawnee

b1-sns12a Effects of increase in Bark Beetle infestation 2006 to 2010

b1-sns12b Effects of 2010 Bark Beetle infestation

Table 2-6 displays the results of the 2010 sensitivity tests in terms of VOC, NOx and CO emission reductions from the 2010 base case, ch anges in projected 8-hour ozone Design Values at the key RFNO and FTCW monitoring sites, maximum difference in 2010 8-hour ozone Design Values anywhere in the DMA and maxi mum difference in daily maximum 8-hour ozone concentrations anywhere in the DMA and on any of the modeling days. Projected 8-hour ozone Design Values for the 2010 sensitivity tests and a ll of the monitoring sites are given in Appendix A. Spatial maps of differences in the proj ected DVFs between the 2010 sensitivity simulations

and the 2010 base case ar e shown in Appendix B.

Mobile Source Emissions : Reducing on-road mobile sources VOC emissions 20% in the DMA reduces the projected DVFs at RFNO and FTCW by 0.2 and 0.1 ppb, respectively. The 7 psi RVP gasoline in on-road mobile source gasoli ne vehicles reduces the DVFs by 0.1 ppb at both monitors. And the zero percent ethanol penetration scenario in the on-road and non-road mobile source gasoline engines increases the DVF at RFNO by 0.1 ppb, and has no effect at FTCW. The spatial maps (Appendix B) show that the reductions in the DVF due to the 20% mobile sources VOC control are small, in the 0.05 to 0. 5 ppb range across the DMA. The reductions for the 7 psi scenario are even smaller. And the ozone increases in the no ethanol scenario are comparable to the reductions in the 20% VOC mobile scenario.

Oil and Gas VOC Emissions : VOC emissions from O&G sources in the NAA were reduced by 20% (b1-sens04) and 40% (b1-sens04d) in two of the 2010 emissions sensitivity tests. The O&G

VOC emission reductions had little effect at th e RFNO monitor, but redu ced the projected DVF at the FTCW monitor by 0.1 and 0.2 ppb, respectively. The spatial maps of differences in the DVFs show a large area of ozone benefits due to the O&G VOC re ductions centered on the O&G production area in Weld County. The RFNO monitor is right at the edge of this benefits area. Note that the Denver EAC SIP modeling of the June-July 2002 episode saw more transport from the Weld County O&G production area down to the RFNO monitor, so these results areF:\Denver_O3_2008\Reports\2010_Sens_OSAT \draft#1\Sec2_2010-DV1.doc August 2008 2-12 partly an artifact of the meteorological condi tions of the June-July 2006 modeling period. The O&G VOC emissions clearly have an effect on ozone formation in the Fort Collins area. In fact, the 6 grid cells west of Fort Collins that are projected to still violat e the 0.08 ppm 8-hour ozone NAAQS in the 2010 base case (Figur e 2-3b) are reduced to 4 and 3 grid cells in the 20% and 40% O&G VOC emission reduction sensitivity s cenarios. Clearly VOC emission reductions from O&G sources in Weld County would benefit oz one attainment in the Fort Collins area and likely elsewhere in the Denver NAA unde r other meteorological conditions.

Combined VOC & NOx Sensitivity Simulations : Sensitivity simulations b1-sens04b and b1-

sens04c looked at combined VOC and NOx emi ssions reductions from area, non-road point and O&G emissions in the NAA. Although both si mulations reduced VOC emissions by 20%, NOx emissions were reduced by 20% in sens04b and by 30% in sens04c allowing us to isolate the

effects of the NOx controls. Several of the othe r sensitivity tests also allow us to isolate the

effects of the VOC and NOx controls in these two sensitivity tests for each source category. The

b1-sens04b 20% VOC/NOx emissions reduction scenario reduces the DVF at RFNO by 0.5 ppb.

This is due to reductions in the RFNO ozone DVF of approximately 0.1 ppb from area source VOC (b1-sens07), 0.1 ppb from O&G VOC ( b1-sens04), 0.2 ppb from non-road VOC (b1- sens06) and 0.2 ppb from point a nd O&G source NOx (b1-sens05). An additional 0.2 ppb ozone

reduction in the RFNO DVF is obtained when the NOx reduction is increased from 20% to 30%. At the FTCW monitor, the effects of the NOx em ission reductions alone is even greater. The 20% VOC/NOx reduction gives a 1.1 ppb reduction in the ozone DVF at the FTCW monitor, increasing the NOx reduction by another 10% increases the oz one reduction at the FTCW monitor by another 0.5 ppb (total 1.6 ppb reduction). This suggests that a majority of the ozone

benefits at FTCW are due to the NOx emi ssion reductions. Although as noted above, VOC

emission reductions from O&G sources in the NAA are also beneficial for reducing ozone in the

Forth Collins area. With the ex ception of a couple grid cells of isolated ozone increases, the

effects of the combined VOC/NOx controls ar e wide-spread reductions in ozone throughout the DMA (Appendix B).

State-Wide Sensitivity : The state-wide sensitivity tests pr oduce nearly the same ozone benefits

at DMA monitors as the controls in the NAA alone. This is seen most clearly by comparing b1-

sens05 with b1-sens08 that examine a 20% reduc tion in NOx emissions from point and O&G sources in, respectively, the NAA and Colorado. They produce the same ozone reduction at RFNO (0.2 ppb) and the state-wide reduction produces slightly more ozone reduction at FTCW (0.6 ppb) than the NAA controls alone (0.5 ppb). At this time we have only evaluated the effects of the state-wide emission reduction sensitivity tests within the DMA. There are likely more

ozone benefits due to the Colorado state-wide emission reductions outside of the DMA that may be important given the new lower (March 2008) ozone NAAQS.

Bark Beetle Sensitivity : The effects of accounting for the Bark Beetle infestation on biogenic

emissions have small effects on the DVFs in th e DMA (0.1 ppb reduction). An examination of the difference plots in Appendix B shows small ar eas of ozone decreases in the DMA and small areas of ozone increases on the western slopes of the Rocky Mountains. This is because ozone

formation in the DMA occurs under a mixtur e of VOC-limited and NOx-limited conditions, whereas ozone formation in the western slope is primarily NOx-limited. The Bark Beetle

infestation reduces VOC emissions that in turn reduce ozone in the DMA under VOC-limited ozone formation conditions. However, over th e western slope small ozone increases occur because of the reduction in biogenic VOC emissions which in turn reduce the reaction of olefin VOC species (e.g., isoprene) with ozone there by increasing ozone con centrations slightly.F:\Denver_O3_2008\Reports\2010_Sens_OSAT\draft#1\Sec2_2010-DV1.doc August 20082-13Table 2-5.Results of 2010 sensitivity tests.Emissions (TPD)% Anthro (%)DV Ozone(PPB)Grid DVOzone(ppb)*Grid Diff.Ozone(ppb)**TestDescriptionCOVOCNOxCOVOCNOxRFNOFTCWMax.Min.Max.Min.2006.a3Current Year 8-HourOzone Design Value8586b12010 Base Case-386.0 -42.2 -50.1 -10.2% -5.3% -5.6%84.984.9b1-sns0120% VOC On-Road NAA0.0 -22.8 0.0 0.0% -3.0% 0.0%-0.2-0.1 0.1 -0.2 0.1 -0.6b1-sns02Evap VOC On-Road inNAA (7 psi RVP)-46.9 -9.8 -0.3 -1.4% -1.3% 0.0%-0.1-0.1 0.1 -0.1 -0.2 -0.3b1-sns030% Ethanol in NAA323.3 -3.8 -2.0 9.5% -0.5% -0.2%0.10.0 0.4 0.0 1.3 -0.2b1-sns0420% VOC O&G in NAA0.0 -48.2 0.0 0.0% -6.4% 0.0%0.0-0.1 0.0 -0.4 0.0 -0.8b1-sns04b20% VOC & NOx Ar, Pnt,Non-Rd and O&G in NAA0.0 -72.5 -41.3 0.0% -9.6% -4.9%-0.5-1.1 1.8 -1.4 3.2 -3.3b1-sns04c20% VOC & 30% NOx Ar,Pnt, Non-Rd, O&G in NAA0.0 -72.5 -62.0 0.0% -9.6% -7.4%-0.7-1.6 2.8 -2.0 5.1 -4.7b1-sns04d40% VOC O&G in NAA0.0 -96.3 0.0 0.0%-12.7% 0.0%-0.1-0.2 0.1 -0.7 0.1 -1.7b1-sns0520% NOx Pnt & O&G NAA0.0 0.0 -20.6 0.0% 0.0% -2.5%-0.2-0.5 0.3 -0.8 1.7 -2.0b1-sns0620% VOC Non-Rd in NAA0.0 -12.7 0.0 0.0% -1.7% 0.0%-0.2-0.1 0.0 -0.2 0.0 -0.8b1-sns0720% VOC Area in NAA0.0 -7.5 0.0 0.0% -1.0% 0.0%-0.1-0.1 0.0 -0.1 0.0 -0.2b1-sns0820% NOx Pnt & O&G CO0.0 0.0 -78.0 0.0% 0.0% -9.3%-0.2-0.6 1.1 -1.0 2.2 -2.2b1-sns0920% VOC O&G in CO0.0 -67.2 0.0 0.0% -8.9% 0.0%0.0-0.1 0.1 -0.3 0.1 -0.8b1-sns1020% VOC & NOx Point &O&G in CO 0.0 -77.5 -78.0 0.0% -10.2% -9.3%-0.3-0.6 0.9 -1.2 2.1 -2.7b1-sns1120% NOx Point & O&G inNAA + 20% NOx Pawnee0.0 0.0 -23.0 0.0% 0.0% -2.7%-0.2-0.5 0.3 -0.8 1.7 -2.0b1-sns12aEffects of increase in BarkBeetle 2006 to 2010-8.4 -87.8 -0.3 -0.2% -11.6% 0.0%0.0-0.1 0.1 -0.1 0.1 -0.1b1-sns12bEffects of 2010 BarkBeetle infestation-21.1 -233.5 -0.8 -0.6% -30.8% -0.1%-0.1-0.1 0.1 -0.1 0.3 -0.32010 Base Case emission reductions from 2006 levels, all other emission reductions from 2010Base Cases* Maximum difference in 2010 design value anywhere on the 4km grid.**Maximum difference in daily maximum 8-hourozone concentration anywhere on the 4km grid.F:\Denver_O3_2008\Reports\2010_Sens_OSAT\d raft#1\Sec3_2010-apca1.doc August 2008 3-1 3.0 2010 APCA SOURCE APPORTIONMENT

3.1 INTRODUCTION

This section presents the 2010 ozone source appo rtionment modeling. This analysis is made using the CAMx modeling results for the 2010 base case emissions using the June-July 2006 episode (Morris et al., 2008b,c). This secti on begins with a techni cal description of the technique, followed by the application me thodology and concluding with the analysis methodology and results.

3.2 TECHNICAL DESCRIPTION

Photochemical grid models are used to develop NO

x and/or VOC emission reduction strategies to attain ozone air quality objectives. Traditi onally, the development of an ozone attainment strategy involves iteration through many photochemi cal grid model scenarios to identify which pollutants, source categories and s ource regions should be controlled. It is impractical to analyze every potential control strategy and so there is potential for implementing controls on sources

that contribute little to the high ozone levels or, conversely, not controlling sources that do

contribute.

3.2.1 Introduction to OSAT

ENVIRON developed an ozone source attributio n approach that has become known as the “Ozone Source Apportionment Technology”, or OSAT (Yarwood et al., 1996). This method was implemented in the CAMx photochemical grid model. OSAT provides a method for estimating the contributions of multiple source areas, categories, and pollutant types to ozone formation in a single model run.

The main challenges in developing and impl ementing a methodology to track the spatial and temporal relationships between separate groups of emission sources and ozone formation are:

• Accounting not only for the pres ence of ozone precursors from a given source region at a given receptor location, but also accurately estimating the cumula tive contribution to ozone production of those pr ecursors while they were en-route to the receptor.

• Insuring compatibility with th e underlying air quality model formulation so that derived source-receptor relationships will be consiste nt with model response to emission changes.

• Providing sufficient spatial and temporal re solution while managi ng, within practical constraints, the computer resources re quired to run the software tool.

The methodology is designed so that all ozone an d precursor concentratio ns are attributed among the selected source groupings at all times. T hus, for all receptor locations and times, the ozone (or ozone precursor concentra tions) predicted by CAMx is at tributed among the source groupings selected for OSAT. The methodology also estimates the fractions of ozone arriving atF:\Denver_O3_2008\Reports\2010_Sens_OSAT\d raft#1\Sec3_2010-apca1.doc August 2008 3-2 the receptor that were formed en-route under VOC- or NO X -limited conditions. This information

indicates how ozone concentrations at the r eceptor will respond to reductions in VOC and NO X precursor emissions.

The biggest limitation of this, or any other, ozon e source apportionment approach likely results

from the non-linear nature of the chemical intera ctions between emissions from different source groupings and their effect on ozone formation. This means that as soon as the emission inventory is perturbed, the source receptor relationships begin to change. Thus, OSAT can only estimate the contribution to ozone from a speci fic source grouping under the current emissions scenario. It cannot directly quantify the ozone reductions that will result from an emission control strategy because the CAMx response may well be non-linear with the magnitude of the control applied (e.g. 20 percent or 60 percent control) and th e presence/absence of other simultaneous controls on other source groupings.

However, this fundamental truth of photoche mical modeling does not limit the usefulness of OSAT: arguably it increases its usefulness. At any rate, it suggests th e following approach to control strategy development with OSAT. For the base CAMx scenario, OSAT could be used to identify specific source groupings for which ozone reductions from emissions controls would be maximized. Just as important, OSAT will identify source groupings for which emissions

controls are not effective at reducing ozone concentrations. Th e most effective and feasible control measures identified in this way can be applied to the emission inventory, leading to a

revised CAMx scenario with di fferent (lower) emissions. If additional controls are needed, OSAT could be applied again to identify the most effective control measures under the new conditions. Development of the control plan will still proceed by an itera tive process, but OSAT can be used to guide the proce ss to develop (and justify) more refined, better-targeted and more

cost-effective ozone control strategies.

3.2.2 OSAT/APCA Technical Formulation

CAMx has been extended to accommodate extra tr acer species needed to perform ozone source apportionment. For each user-specified source grouping (geographical area/emissions category) there are two distinct types of tracer species, “timing tracers” 1 and “ozone reaction tracers.” The timing tracers are used to track the temporal relationships between precursor emissions and

ozone formation. The ozone reaction tracer s track the fate of ozone precursors (NO X and VOC) emissions from each source grouping plus the ozone formation attributed to those emissions. The methodology requires that all ozone precursors be tracked so th at all contributions to ozone can be accounted for, thus ozone and precursors originating from the model boundary and initial concentrations are also tracked as separate source groupings (however, no timing tracers are

allocated to the initial or boundary conditions). The following sub-sections describe the methodologies employed for the timing and ozone reaction tracers.

OSAT tracks ozone formation from user define d source groups using reactive “ozone-tracers” that run in parallel to the CAMx host model. OSAT does not affect the host CAMX model calculations; rather it extracts information on ozone formation source-relationships from the

model in a mass consistent fashion. There are four ozone-reaction tra cers per source area to account for the contributions of emissions of sepa rate source areas to the complex process of the

1 Note that “timing tracers” were not used in the Denver ozone source apporti onment modeling so are not discussed further.F:\Denver_O3_2008\Reports\2010_Sens_OSAT\d raft#1\Sec3_2010-apca1.doc August 2008 3-3 ozone formation activity. It is impor tant to recall that the mass of NO X or VOC from a given source area that may be present at a given receptor at a selected hour is often not particularly relevant to the amount of ozone present there at th at time. Rather, it is the contribution to ozone formation activity of source areas’ NO X and VOC emissions en-route to a receptor that must be determined. The ozone-reaction tracers are designed to integrate these en-route contributions to ozone production/de struction activity.

Ozone formation involves both NO X and VOCs, and the NO X and VOCs participating in ozone formation in any particular grid cell/time st ep may have originated from different source groupings. The ozone formation process can be c ontrolled more by the avai lability of VOCs or

NO X , depending upon the relative abundance of bot h precursors, and ozone formation is

described either as VOC-limited or NO X -limited, respectively. Wh en ozone production at a given location and time is NO X -limited it makes sense to attri bute ozone production to source groupings based on their cont ributions to the local NO X and similarly to allocate based on VOC

contributions when ozone formation is VOC-limited. Consequently, separate tracers are used to track ozone formation occurring under NO X -and VOC-limited conditions.

The four types of ozone-reaction tracers that are tracked for each source grouping (i.e., geographic area/source category, boundary conditions or initial conditions) are explained below. The name of each tracer uniquely identif ies the source grouping it represents:

N i = NO X tracer for source grouping i . Emitted with the same spatial and temporal

distribution as NO X emissions for source grouping i . Decays with local

d

NO X /

d t

for each grid cell/time step.

V i = VOC tracer for source grouping i . Emitted with the same spatial and temporal

distribution as VOC emi ssions for source grouping i . Decays with local

d VOC/ d t

for each grid cell/time step. Note that VOC tracers are defined as single carbon species, so their concentra tions are numerically equal in ppb and ppbC units.

O3V i = Tracer of ozone formation under VOC li mited conditions attributed to source grouping i . If ozone formation is determin ed to be VOC-limited for a given grid cell/time step, O3V i is formed in proportion to local d O 3 /

d t

in proportion weighted by the distribut ion of VOC precursors (V i ).

O3N i = Tracer of ozone formation under NO X limited conditions attributed to source grouping i . If ozone formation is determined to be NO X -limited for a given grid cell/time step, O3N i is formed in proportion to local d O 3 /

d t

in proportion weighted by the distribution of NO X precursors (N i ).

The ozone reaction tracer methodology was designed to be inherently mass consistent with CAMx. In other words, the sums of the NO X , VOC and ozone tracers should remain consistent with their standard CAMx counterparts as follows:F:\Denver_O3_2008\Reports\2010_Sens_OSAT\d raft#1\Sec3_2010-apca1.doc August 2008 3-4 

## ∑ ∑ ∑ ∑ ∑

+ = = + =

i i i i

N O V O O VOCs CB V NO NO N

3 3 3 4 2

The tracer families, N i and V i , track NO X and VOC emissions from each source grouping to

allow attribution of ozone forma tion as it occurs throughout CAMx. The rates of emission of the

N i and V i tracers are set equa l to the total NO X and VOC emissions in th e inventory for a source grouping, respectively. For the V i tracers, the emissions are set equal on a ppmC basis. For the initial condition (IC) source grouping, the N IC and V IC tracers are initialized from the CAMx

initial concentration fields and receive no more mass input after the start of the simulation. For the boundary condition (BC) s ource grouping, the fluxes of NO X and VOC entering CAMx from the boundaries are effectively inte rpreted as emissions of the N BC and V BC tracers at the model

boundaries. Unlike emission sour ce groupings, boundary and init ial conditions also introduce ozone directly into CAMx. Since there is no way of determining whether the ozone in the boundary and initial conditions was formed under VOC or NO X limited conditions, this ozone is divided equally between O3N and O3V tracers. However, subsequent ozone formation within CAMx from boundary and initial condition VOCs and NO X is allocated to O3V and O3N tracers

on the basis of whether ozone fo rmation occurred under VOC or NO X limited conditions.

The N i , V i , O3N i and O3V i tracers are deposited at rates de termined by the standard CAMx deposition calculation on a surface gr id cell by grid cell basis. For NO X , the deposition velocity

for each tracer N i [ V d ( N i ) ] is set equal to the concentrati on weighted average of the deposition

velocities for NO and NO 2 :

Similarly, the deposition ve locity for each tracer V i is set equal to the concentration weighted average of the deposition velocities for the VOC species (the concentration weighting is performed on a ppmC basis). The deposition veloc ity for the O3N and O3V tracers is set equal to the ozone deposition velocity.

The N i , V i , O3N i and O3V i tracers are transported and diffused in the horizontal and vertical using the same transport and diffusion fluxes us ed in the host model for NOx, VOC and ozone, respectively.

The N i tracer mass in each grid cell at each time step decays according to the chemical change in the CAMx predicted NO X ( Δ NO X ) weighted by the tracer cont ribution to the total of NO X tracers from all source groupings:

The V i tracer mass in each grid cell at each time step decays according to the chemical change in the CAMx predicted VOC ( Δ VOC ) weighted by the tracer cont ribution to the total of VOC 

## ( ) ( ) ( )

2 2 2 

### NO NO NO V NO NO V NO N V D D

i d 

### + × + ×

=



# ∑ × Δ + =

i i

x i i 

### N N NO N NF:\Denver_O3_2008\Reports\2010_Sens_OSAT\d raft#1\Sec3_2010-apca1.doc August 2008 3-5 tracers from all source groupings. However, be cause the reactivity of VOCs from different source groupings can be different, a weighting factor based on the OH-reactivity of each V tracer ( kOH i ) is also introduced. The kOH i for each source grouping is calculated at the start of each simulation period (typically one day) by averagin g the OH rate constants of the speciated VOC emissions for each source grouping. The V tracer mass in each grid cell at each time step decays at a rate determined by the following equation:

The O3N and O3V tracers for each source grouping accumulate a weighted fraction of the ozone production activity ( PO 3 ) and ozone destruction activity ( DO 3 ) that occurs in each grid cell at each time step. The process of apportioning PO 3 and DO 3 across O3N and O3V tracers occurs

as follows:

1. Determine whether the local (grid cell/time step) ozone production process is NO X or VOC limited. As described in detail below, the determination is based on the ratio of

the local HNO 3 and H 2 O 2 production rates. If the H 2 O 2 /HNO 3 production ratio is greater than 1/3 during a time st ep, then ozone formation is NO X limited. If this ratio is less than or equal to 1/3, then ozone formation is VOC limited.

2. For allocating ozone production und er conditions determined to be:

(a) NO X limited: allocate PO 3 across O3N tracers

(b) VOC limited: allocate PO 3 across O3v tracers based on maximum incremental reactivity (MIR) factors

3. For ozone destruction, alloca te across all ozone tracers.

where X = N and V.

This is the algorithm used for OSAT ozone s ource apportionment. Th e Anthropogenic Precursor Culpability Assessment (APCA) method of ozone source apportionment in CAMx was used in the Denver 2010 modeling uses a different al gorithm for allocati ng ozone production, as

described below.

The MIRs used in equation (5) are the weighted average MIRs for the emissions in each source group. The MIR approach was developed by Cart er (1994) to approxima te the ozone forming potential of VOCs accounting for both kinetic an d mechanistic reactivity effects. The MIR 

## ( ) 

# ∑ × ×
× Δ + =

i i i i

i i 

### kOH V kOH V VOC V V



# ∑ × + =

i i

i i 

### N N PO N O N O 3 

### 3 3



# ∑ × ×
× + =

i i i i

i i 

### MIR V MIR V PO V O V O 3 

### 3 3



## ∑ × + =

i i

i i X X DO X O X O 3 3 3F:\Denver_O3_2008\Reports\2010_Sens_OSAT\d raft#1\Sec3_2010-apca1.doc August 2008 3-6 represents the ozone formation potential of th e VOC mixture accounting for the VOC reactions

with OH as well as the effects of all of the VOC products that produce ozone formation. The

VOC + OH reaction is the main VOC destruction mechanism so it is appropriate to weight the

VOC destruction across the VOC reactive tracer s by their composite r eaction rate with OH (kOH).

The determination of whether the ozone produc ed is under more VOC-limited or NOx-limited

conditions is based on the main radical termina tion reactions in the atmosphere. Under VOClimited conditions the instantaneous production of HNO3 is higher, whereas under NOx-limited conditions the instantaneous production of H2O2 is higher. Thus a ratio of the production of these two species is used to determine whethe r ozone formation was more VOC-limited or NOxlimited, which was extensively tested in the development of OSAT (ENVIRON, 2008).

Anthropogenic Precursor Culpability Assessment (APCA). APCA differs from OSAT in recognizing that certain emission groups are not controllable (e.g., biogenic emissions) and that apportioning ozone production to th ese groups does not provide info rmation that is relevant to control strategies. To address this, in situations where OSAT would attribute ozone production to non-controllable (i.e., biogeni c) emissions, APCA re-allocates that ozone production to the controllable portion of precursors th at participated in ozone formation with the non-controllable precursor. In the case where biogenic emissi ons are the uncontrollabl e source category, APCA would only attribute ozone production to biogenic emissions when ozone formation is due to the interaction of biogenic VOC with biogenic NO X . When ozone formation is due to biogenic VOC and anthropogenic NO X under VOC-limited conditions (a situation in which OSAT would attribute ozone production to biogenic VOC), APCA re-directs that attribution to the anthropogenic NO X precursors present. The use of APCA instead of OSAT results in more

ozone formation attribut ed to anthropogenic NO X sources and less ozone fo rmation attributed to biogenic sources. APCA is not really a “source apportionment” technique because it expresses biases as to which sources should be implicated (i.e., those that are c ontrollable), hence it is referred to as a “culpability assessment.” .

3.3 APPLICATION METHODOLOGY

The APCA version of the CAMx ozone source apportionment was applied using the 2010 base case inventory with the emissions segregated in to 8 source categories a nd 11 source regions. The source categories are presented in Table 3-1. A list of the source regions is presented in a tabular form in Table 3-2 and in graphical form in Figures 3-1 and 3-2 for the 12 km and 4 km CAMx domains, respectively. No te that in some cases only sm all portions of states on the periphery of the 12 km grid are included in the analysis. Further note that source regions are defined on a grid cell basis, with each grid cell a ssigned to the region with the largest area. Thus, it is possible for sources on the border of a regi on to get assigned to an adjacent region.F:\Denver_O3_2008\Reports\2010_Sens_OSAT\d raft#1\Sec3_2010-apca1.doc August 2008 3-7 Table 3-1. Source apportionment source groups for Denver SIP 2010 modeling. Source Apportionment Source Groups Biogenic/Fires
On-road Motor Vehicles

Non-road
Oil and Gas
Area Sources
Industrial Point Sources
Electric Generation Units Boundary and Initial Conditions

Table 3-2. Source apportionment source regions for Denver SIP 2010 modeling. Source Apportionment Source Regions 7-County Denver Metro
Larimer/Weld Counties
Northeastern Colorado
Southeastern Colorado
Southwestern Colorado
Northwestern Colorado Wyoming, Idaho, Oregon Utah, Nevada, California Arizona, New Mexico Kansas, Texas, Oklahoma, Missouri, Arkansas Nebraska, South Dakota, Minnesota, Iowa

Figure 3-1. Source apportionment source regions in 12km CAMx domain.F:\Denver_O3_2008\Reports\2010_Sens_OSAT\d raft#1\Sec3_2010-apca1.doc August 2008 3-8 Figure 3-2. Source apportionment source regions in 4km CAMx domain.

3.4 ANALYSIS METHODOLOGY AND RESULTS

The source apportionment results were analyzed at the ozone monitor site s used in the ozone attainment test presented in Sect ion 2 of this report. At each monitor location, for each day, the 8-hour average ozone results for each period ove r 70 ppb were averaged to develop a composite

contribution.

Example displays for a high ozone day (July 29 th ) at the Rocky Flats North and Fort Collins West monitors, the two monitors with the highest future year design values are presented in this section. APCA ozone source apportionment modeli ng results for other days and other monitors are presented in Appendix C. The results show significant day-to-day and monitor-to-monitor variation. The Rocky Flats North results are presen ted in Figure 3-3. Figure 3-3a presents the ozone results including the boundary conditions, that is, the cont ribution from sources outside the 12 km domain. Of the 76.1 ppb of ozone estima ted at the monitor, ~48 ppb was transported into the 12 km domain and ~18 ppb was attributed to sources in the seven-county Denver Metro area. Figure 3-3b presents the same results as 3-3a, but without the boundary conditions plotted and the vertical scale expanded to better reso lve the source region cont ributions. This figure shows that of the ~18 ppb from Metro Denver so urces ~10 ppb was from motor vehicles, ~5 ppbF:\Denver_O3_2008\Reports\2010_Sens_OSAT\d raft#1\Sec3_2010-apca1.doc August 2008 3-9 was from non-road mobile sources with the balan ce from other sources. Figure 3-3c presents the ozone formed under anthropogenic NOx-limited conditions, that is, ozone formed under conditions where the model is responsive to NOx controls or since the APCA version of source apportionment was used, ozone formed under VOC- limited conditions due to the interaction of biogenic VOC with anthropogenic NOx. Figur e 3-3d presents the ozone formed under anthropogenic VOC-limited conditions, that is, oz one formed under conditions where the model is responsive to VOC controls. These two fi gures suggest that emi ssion reductions from NOx sources will be more effective at reducing oz one in the model than reductions from VOC sources, although both VOC and NOx controls will reduce ozone. Analogous plots for the Fort Collins West monitor are presented in Figure 3-4 that show similar contributions as the Rocky Flats North monitor, except the highest contri butions are from sources in the Larimer/Weld County source region and oil and gas sources from Larimer/Weld County have a large contribution which they di dn’t at Rocky Flats North.

The source apportionment results vary by day and by location. However, several overall trends emerge, namely:

• Regional ozone transport into the 12 km do main is the largest contributor, often accounting for more than two-thirds of the total ozone;

• At the Denver Metropolitan monitors, the la rgest contributors ar e Denver Metropolitan area motor vehicle and non-road sources;

• At the Fort Collins and Greeley monitors the largest contributors tend to be Larimer and Weld County motor vehicles, non-road sour ces and oil and gas sources, and Denver Metropolitan sources;

• The majority of the ozone is attri butable to anthropogenic NOx emissions.

In interpreting these results it is important to keep in mind that these source apportionment results are based on the Denver SIP 2006 modeling episode and are meteorologically dependent. For instance, the source apportionment modeling in support of the Denver Early Action Compact (Morris et. Al., 2004f,g) using th e 2002 ozone episode showed more impact of sources in Larimer/Weld Counties into the Denver Metropolitan area.F:\Denver_O3_2008\Reports\2010_Sens_OSAT\d raft#1\Sec3_2010-apca1.doc August 2008 3-10 Figure 3-3a. Rocky Flats North source apportionment for 29 July including boundary
conditions.

Figure 3-3b. Rocky Flats North source apportionment for 29 July excluding boundary
conditions.F:\Denver_O3_2008\Reports\2010_Sens_OSAT\d raft#1\Sec3_2010-apca1.doc August 2008 3-11 Figure 3-3c. Rocky Flats North source apportionment for 29 July attributable to anthropogenic
NOx sources.

Figure 3-3d. Rocky Flats North source apportionment for 29 July attributable to anthropogenic
VOC sources.F:\Denver_O3_2008\Reports\2010_Sens_OSAT\d raft#1\Sec3_2010-apca1.doc August 2008 3-12 Figure 3-3a. Fort Collins West source apportionment for 29 July including boundary conditions.

Figure 3-3b. Fort Collins West source apportionment for 29 July excluding boundary

conditions.F:\Denver_O3_2008\Reports\2010_Sens_OSAT\d raft#1\Sec3_2010-apca1.doc August 2008 3-13 Figure 3-3c. Fort Collins West source apportionment for 29 July attributable to anthropogenic
NOx sources.

Figure 3-3d. Fort Collins West source apportionment for 29 July attributable to anthropogenic
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