# A PPENDIX 

# D

### Appendix D
Campbell County, Kentucky SO2 Monitor 21-037-3002
2010-2014 Exceedance Analysis
January 20, 2014

I. Background
Between January 1, 2010 and A ugust 31, 2014, 44 exceedances of the 2010 1-hour SO2 National Ambient Air Quality Standard (NAAQS) of 75 ppb were recorded at the John’s Hill Road Monitoring Site in Camp bell County, Kentucky, Monitor ID 21-037-
3002. This monitor, shown in Table 1, is located in t he northern part of Campbell County, Kentucky, south of Cincinnati, Ohio (Figure 1).

In this report, data is analyzed to identify potential SO2 sources contributing to the 1-
hour NAAQS exceedances at Monitor 21-0 37-3002. Two major SO2 emission sources were considered for the investigation, give n their proximity to the monitors and the predominant wind directions potentially impacti ng the monitor in Campbell County. The sources, Duke Energy’s W.C. Beckjord (Be ckjord) and W. H. Zimm er (Zimmer) facilities in Clermont County, OH, are located east and south-east, respectfully, of Kentucky monitor 21-037-3002 (Figure 2).

II. Methodology
A back trajectory analysis was performed fo r the exceedances at monitor 21-037-3002 using the National Oceanic and Atmospheric Administration’s (NOAA) Hybrid Single Particle Lagrangian Integrated Trajectory Model (HYSPLIT) 1 

### . HYSPLIT is a complete system for modeling simple air parcel trajectories, both in forward and backward modes. The model calculation method is a hybr id between the Lagrangian approach, which uses a moving frame of reference as the air par cels move from their initial location, and the Eulerian approach, which uses a fixed 3-dimensional grid as a fr ame of reference.

For this report HYSPLIT back-trajectories were created using NOAA’s archived North American Mesoscale Modeling System, 12 kilometer grid resolution meteorological dataset (NAM 12 kilometers). The back trajec tories originated at the violating monitor location on each hour that corresponds to a measured exceedance of the 1-hr SO2

NAAQS and were initialized at 500 meters above ground level with the “Model Vertical Velocity” model option. The main purpose of these analyses was to determine a probable cause of recorded exceedances by simula ting the flow of 24-hour air trajectory patterns in the backward mode. Meteorolog ical data used to create the HYSPLIT back trajectories was taken from the National Weather Service Station located at the

Cincinnati Northern Kentu cky Airport (KCVG).

Back-trajectories alone were not used for th is analysis since they may not always be indicative of flow patterns during very sh ort periods of time when exceedances occur

1 Draxler, R.R. and Rolph, G.D., 2012. HYSPLIT (HYbrid Single

‐ Particle Lagrangian Integrated Trajectory) Model access via NOAA

ARL READY Website (http://ready.arl.noaa.gov/HYSPLIT.php). NOAA Air Resources Laboratory, Silver Spring, MD.

### (e.g, single or few hours). In those cases, an analysis of hourly wind patterns aids in determining the flow of emissions fr om these sources for the hours around the

exceedance.

Table 1. Summary of the 2010 1-hour SO2 NAAQS exceedances at Monitor ID 21-037-

3002.

Year Month Day Hour (EST) Monitored Value (ppb)

2010 April 14 9:00 106
2010 April 14 13:00 142
2010 April 14 14:00 140
2010 April 14 15:00 86
2010 April 14 16:00 86
2010 July 31 14:00 82
2010 August 27 9:00 118
2010 September 14 11:00 99

2010 November 24 11:00 105
2011 February 23 9:00 137

2011 March 3 10:00 86

2011 March 3 13:00 92

2011 March 7 12:00 82

2011 March 7 13:00 76

2011 March 7 15:00 87

2011 March 8 17:00 84

2011 March 20 7:00 89
2011 April 22 3:00 109

2011 June 3 10:00 102

2011 June 3 11:00 142
2011 July 5 10:00 91
2011 July 5 11:00 180
2011 July 15 17:00 76
2011 July 15 18:00 92
2011 August 30 10:00 86
2011 August 30 11:00 76
2011 August 30 12:00 84
2011 August 30 13:00 84
2011 August 30 14:00 80
2012 January 11 12:00 76
2012 January 25 12:00 85
2012 February 3 17:00 82
2012 February 20 12:00 117
2012 February 20 13:00 156
2012 February 28 12:00 77
2012 April 7 11:00 99

### Year Month Day Hour (EST) Monitored Value (ppb)

2012 April 7 15:00 81
2012 May 6 18:00 93
2013 February 9 13:00 96
2013 February 9 14:00 124
2013 February 25 9:00 100
2013 February 25 10:00 125

2013 March 5 6:00 125

2014 March 6 12:00 93Figure 1. Topographic map of the Monitor ID21-037-3002 and nearby AirportsCincinnatiNorthernKentuckyAirportCincinnatiMunicipalAirport21‐037‐3002NorthFigure 2. Locations of Duke Energy’s W.C. Beckjord and WilliamH. Zimmer facilitiesNorth

### The results of the exceedance day HYPSLIT back trajectory modeling were divided into the following categories:

Section III: Beckjord Trajectories - HYSPL IT trajectories passed over or near Beckjord (29 exceedances);

Section IV: Zimmer Trajectories - HYSPLIT trajectories passed over or near Zimmer (1 exceedance);

Section V: Intermediate Trajectories (4 exceedances);

Section VI: Other Trajectories – HYSPLI T trajectories do not clearly indicate either Beckjord or Zi mmer (10 exceedances).

This report is organized in acco rdance with the above categories.

For all exceedance days, a further exami nation of the surface meteorology was conducted. There are two surface meteorology stations located near the Kentucky

Monitor 21-037-3002. To determine the best stat ion to use for this analysis, a windrose of all days in which an exceedance was re corded at monitor 21-037-3002 during the 2010 to 2014 period is shown for both Cinc innati Northern Kentucky Airport (KCVG Station #93814) and Cinci nnati Municipal Airport (KLUK Station # 93812) in Figure 3 and Figure 4, respectively. It is readily appa rent from the windrose data in Figure 4 that the river valley close to Cincinnati Municipal Ai rport influences the local wind direction.

Meteorological data from t he Cincinnati Northern Kentucky Airport was selected based on the similar topography of the airport loca tion and the monitor station location (Figure 1). Although the weather station located at Cincinnat i Municipal Airport is closer in proximity to the monitoring station location, the closeness of this airport to the river valley channels local winds in a northeast to southwest or southeast to northeast direction. This channeling is not expect ed to be present at the monitoring station

location.

### Figure 3: Cincinnati Northern Kentucky Airport (KCVG) wind rose for all exceedance days, 2010 to 2014

### Figure 4: Cincinnati Municipal Airport (KLUK) wind rose for all exceedance days, 2010

to 2014

### In some instances, the hourly emissions data were also reviewed in addition to the meteorological and HYSPLITY back trajectories. Hourly emissions data were

downloaded from the U.S. EPA’s Clean Air Ma rkets Database (CAMD) and analyzed in comparison with the monitor exceedances.

The annual 2010-2014 emissions, shown in

Table 2

Table 2. Annual emissions summary for Beckjord and Zimmer, indicate that the Beckjord facility emitted significantly more SO 2 than the Zimmer facility during the time period 2010-2014. It should be noted that t he Zimmer facility was fitted with flue gas

de-sulfurization controls in December of 1990, which operat e continuously by permit. The Beckjord facility does not have similar, advanced pollution controls for SO2.

Table 2. Annual emissions su mmary for Beckjord and Zimmer

Annual SO2 Emission (tons)
Facility 2010 2011 2012 2013 2014 W H Zimmer Generating Station 19,388 18,044 11,975 18,457 9,780 W C Beckjord Generating Station 69,156 90,835 67,069 51,900 32,627 Note: Emissions for Jan. 1, 2010-Aug. 31, 2014

The following sections of this report descri be the results of the findings of the above described analyses.

### III. Beckjord Trajectories

This section includes exceedance days in which the HYSPLIT back trajectories pass directly over or in close proximity to the Be ckjord facility indicati ng a high probability of Beckjord contributing to the exceedances repor ted at the monitor. In this Section

surface level wind data is also discussed in relation to the exceedance time and dates.

April 14, 2010

On April 14, 2010, five exceedances were reported at Monitor ID 21-037-3002 between

9:00 and 16:00. The exceedance values r anged from 86 to 142 ppb. Three HYSPLIT back trajectories were modeled as show n in Figure 5a to represent the five

exceedances in the table below. The surfac e level meteorological windrose data was also plotted to determine w here the wind was blowing from on the exceedance date. Figure 5b shows the windrose data for a 24 h our period on the exceedance day (0:00 to 23:00), Figure 5c and 5d show the windrose data around the time of the 9:00 hour and 13:00 to 16:00 hour exceedance periods, respectively.

All three back trajectories pass di rectly over or in close prox imity to the Beckjord facility. This indicates a high probability of Beckjord contributing to the exceedances reported at the monitor. In addition, t he windrose data at the time of the exceedances shows the wind was blowing predominantly fr om the eastern direction, where the Beckjord facility is located. The April 14, 2010 exceedances are attributable to the Beckjord facility.

Trajectory

ID Year Month Day Hour Monitored Value
(ppb)

1a 2010 4 14 9:00 106

1a 2010 4 14 13:00 142

1b 2010 4 14 14:00 140

1c 2010 4 14 15:00 86

1c 2010 4 14 16:00 86a)b) c) d)Figure 5. a) HYSPLIT back trajectory modeling for April 14, 2010; b) 24-hour windrose data at KCVG Station onApril 14, 2010; c) 3-hour windrose data from 8:00 to 10:00at KCVG Station on April 14, 2010; d)6-hour windrose data from 12:00-17:00.North

### November 24, 2010

On November 24, 2010, one exc eedance was reported at Monitor ID 21-037-3002 at 11:00. The exceedance value reported was 105 ppb as shown in the table below. The exceedance was modeled by one HYSPLIT back trajectory in Figure 6a. The meteorological wi ndrose data was also plotted to determine where the wind was blowing from on t he exceedance date. Figure 6b shows the windrose data for a 24 hour period on the ex ceedance day (0:00 to 23:00), Figur e 6c shows the windrose data

around the time of t he exceedance hour.

The HYSPLIT back trajectory passes in close proximit y to the Beckjord facility. This indicates a high probability of Beckjord cont ributing to the exceedances reported at the monitor. In addition, the

windrose data at the time of the exceedances shows the wind was blowing predominantly from the eastern direction, where the Beckjord facility is located. The November 24, 2010 exceedances are

attributable to the Beckjord facility.

Trajectory ID Year Month Day Hour Reading

5 2010 November 24 11:00 105a)b) c)Figure 6. a) HYSPLIT back trajectory modeling for April 14, 2010; b) 24-hour windrose data at KCVG Station onNovember 24, 2010; c)3-hour windrose data from 10:00 to 12:00 at KCVG Station on November 24, 2010.North

### March 3, 2011

On March 3, 2011, two exceedances were r eported at Monitor ID 21-037-3002 at 10:00 and 13:00. The exceedance values report ed were 86 and 92, respectively. The exceedances were modeled by one HYSPLIT ba ck trajectory in Figure 7a. The surface level meteorological windrose data was also plotted to determine where the wind was blowing from on the exceedance date. Figure 7b shows the windrose data for a 24 hour period on the exceedance day (0:00 to 23: 00), Figure 7c and 7d show the windrose

data around the time of t he exceedance hours.

The HYSPLIT back trajectory passes in close proximity to the Beckjord facility. This indicates a high probability of Beckjord cont ributing to the exceedanc es reported at the monitor. In addition, the wi ndrose data at the time of th e exceedances shows the wind was blowing exclusively from the eastern direction, where the Beckjord facility is
located. The March 3, 2011 exceedances are t herefore expected to be attributable to the Beckjord facility.

Trajectory ID Year Month Day Hour Reading

7 2011 March 3 10:00 86

7 2011 March 3 13:00 92a)b) c) d)Figure 7. a) Beckjord and Zimmer CEMS dataand monitored values at Kentucky Monitor ID21-037-3002 on March 3, 2011; b) 24-hourwindrose data at KCVG Station on March 3,2011; c) 3-hour windrose data from 9:00 to 11:00 at KCVGStation on March 3, 2011; d)3-hour windrose data from 12:00 to 14:00at KCVG Stationon March 3, 2011.North

### March 7, 2011

On March 7, 2011, three exceedances were reported at Monitor ID 21-037-3002

between 12:00 and 15:00. The exceedance val ues reported ranged from 76 to 87 ppb.

The exceedances were modeled by one HYSPLIT back trajec tory in Figure 8a. The surface level meteorological windrose data was also plotted to determine where the wind was blowing from on the exceedance date. Figure 8b shows the windrose data for a 24 hour period on the exceedance day (0: 00 to 23:00), Figure 8c and 8d show the

windrose data around the time of the exceedance hours.

The HYSPLIT back trajectory passes in close proximity to the Beckjord facility indicating a high probability of Beckjord c ontributing to the exceedances reported at the monitor. In addition, the windrose data at the time of the exc eedances shows the wind was blowing predominately from the eas tern direction, where the Beckjord facility is located. The March 7, 2011 exceedances are theref ore predicted to be attributable to the Beckjord facility.

Trajectory ID Year Month Day Hour Reading

8 2011 March 7 12:00 82

8 2011 March 7 13:00 76

8 2011 March 7 15:00 87a)b) c) d)Figure 8. a) Beckjord and Zimmer CEMS dataand monitored values at Kentucky Monitor ID21-037-3002 on March 7, 2011; b) 24-hourwindrose data at KCVG Station on March 7, 2011; c) 4-hour windrose data from 11:00 to 14:00 at KCVG Stationon March 7, 2011; d)3-hour windrose data from14:00 to 16:00 at KCVGStation on March 7, 2011.North

### June 3, 2011

On June 3, 2011, two exceedances were repor ted at Monitor ID 21-037-3002 between 10:00 and

11:00. The exceedance values reported ranged from 102 to 142 ppb. The exceedances were modeled by one HYSPLIT back trajectory in Figure 9a. The meteorological windrose data was also plotted to determine where the wind was blowing from on the exceedance date. Figure 9b shows the windrose data for a 24 hour period on the exceedanc e day (0:00 to 23:00), Figure 9c shows the

windrose data around the time of the exceedance.

The HYSPLIT back trajectory passes in close proximit y to the Beckjord facility. This indicates a high probability of Beckjord cont ributing to the exceedances reported at the monitor. In addition, the

windrose data around the time of the exceedances shows the wind was blo wing predominately from the eastern direction, where the Beckjord facility is located. The June 3, 2011 exceedances are therefore predicted to be attributable to the Beckjord facility.

Trajectory ID Year Month Day Hour Reading

11 2011 June 3 10:00 102

11 2011 June 3 11:00 142a)b) c)Figure 9. a) Beckjord and Zimmer CEMS dataand monitored values at Kentucky Monitor ID21-037-3002 on June 3, 2011; b) 24-hourwindrose data at KCVG Station on June 3,2011; c) 4-hour windrose data from 9:00 to12:00 at KCVG Station on June 3, 2011.North

### July 15, 2011

On July 15, 2011, two exceedances were repor ted at Monitor ID 21-037-3002 between 17:00 and

18:00. The exceedance values r eported ranged from 76 to 92 ppb. The exceedances were modeled by one HYSPLIT back trajectory in Figure 10a. The meteorological win drose data was also plotted to

determine where the wind was blow ing from on the exceedance date. Figure 10b shows the windrose data for a 24 hour period on the exceedance day (0:00 to 23:00) , Figure 10c shows the windrose data

around the time of the exceedance.

The HYSPLIT back trajectory passes in close proximit y to the Beckjord facility. This indicates a high probability of Beckjord contri buting to the exceedances reported at the monitor. The windrose data at

the time of the exceedances sh ows the wind was blowing predom inately from the northeast and northwest direction. However, giv en the lack of other significant sour ces of SO2 located north of the monitor and the close proxim ity of the HYPSLIT back tr ajectory, it is likely that the emissions from Beckjord contributed to the exceedances.

Trajectory ID Year Month Day Hour Reading
13 2011 July 15 17:00 76
13 2011 July 15 18:00 92a)b) c)Figure 10. a) Beckjord and Zimmer CEMS data andmonitored values at Kentucky Monitor ID21-037-3002 on June 3, 2011; b) 24-hourwindrose data at KCVG Station on June 3,2011; c) 4-hour windrose data from 16:00 to19:00 at KCVG Station on June 3, 2011.North

### August 30, 2011

On August 30, 2011, five exceedances were repor ted at Monitor ID 21- 037-3002 between 10:00 and

14:00. The exceedance values r eported ranged from 76 to 86 ppb. The exceedances were modeled by four HYSPLIT back trajectory in Figure 11a. The meteorological windrose data was also plotted to

determine where the wind was blow ing from on the exceedance date. Figure 11b shows the windrose data for a 24 hour period on the ex ceedance day (0:00 to 23:00), Figur e 8c shows the windrose data

around the time of the exceedance.

The HYSPLIT back trajectories pass in close proximit y to the Beckjord facility . This indicates a high probability of Beckjord cont ributing to the exceedances reported at the monitor. The windrose data on the day of the exceedance and at the time of the exceedances shows the wind was blowing predominately from the east. The August 30, 2011 exceedances ar e therefore predicted to be attributable to the Beckjord facility.

Trajectory ID Year Month Day Hour Reading
14a 2011 August 30 10:00 86
14b 2011 August 30 11:00 76
14b 2011 August 30 12:00 84
14c 2011 August 30 13:00 84
14d 2011 August 30 14:00 80a)b) c)Figure 11. a) Beckjord and Zimmer CEMS data andmonitored values at Kentucky Monitor ID21-037-3002 on August 30, 2011; b) 24-hour windrose data at KCVG Station on August30, 2011; c) 6-hour windrose data from 9:00 to 15:00 at KCVG Station on August30,2011.North

### February 20, 2012

On February 20, 2012, two exceedances were r eported at Monitor ID 21-037-3002 between 12:00

and 13:00. The exceedance values reported ranged from 117 to 156 ppb. The exceedances were modeled by one HYSPLIT back trajecto ry in Figure 12a. The meteorol ogical windrose data was also plotted to determine where the wind was blowing fr om on the exceedance date. Figure 12b shows the windrose data for a 24 hour period on the exceedanc e day (0:00 to 23:00), Figure 12c shows the

windrose data around the time of the exceedance.

The HYSPLIT back trajectory passes in close proximit y to the Beckjord facility. This indicates a high probability of Beckjord cont ributing to the exceedances reported at the monitor. The windrose data on the day of the exceedance and at the time of the exceedances shows the wind was blowing predominately from the east/southeast. The August 30 , 2011 exceedances are t herefore predicted to be attributable to the Beckjord facility.

Trajectory ID Year Month Day Hour Reading
18 2012 February 20 12:00 117
18 2012 February 20 13:00 156a)b) c)Figure 12. a) Beckjord and Zimmer CEMS data andmonitored values at Kentucky Monitor ID21-037-3002 on February 20, 2012; b)24-hour windrose data at KCVG Station on February 20,2012; c) 4-hour windrose data from 11:00 to 14:00at KCVG Station onFebruary 20, 2012.North

### April 7, 2012

On April 7, 2012, one exceedance was reported at Monitor ID 21-037-3002 at 11:00. The exceedance value reported was 99 ppb. The exceedance was model ed by one HYSPLIT back trajectory in Figure 13a. The meteorological windrose data was also plotted to determine where the wind was blowing from on the exceedance date. Figure 13b shows the windrose data for a 24 hour period on the exceedance day (0:00 to 23:00), Figure 13c show s the windrose data around the time of the

exceedance.

The HYSPLIT back trajectory passes in close proximit y to the Beckjord facility. This indicates a high probability of Beckjord cont ributing to the exceedances reported at the monitor. The windrose data on the day of the exceedance and at the time of the exceedances shows the wind was blowing predominately from the east/southeast. Zimmer was no t operating on this day; the April 7, 2012 exceedance is therefore predicted to be at tributable to the Beckjord facility.

Trajectory ID Year Month Day Hour Reading
20a 2012 April 7 11:00 99a)b) c)Figure 13. a) Beckjord and Zimmer CEMS data andmonitored values at Kentucky Monitor ID21-037-3002 on April 7, 2012; b) 24-hourwindrose data at KCVG Station on April 7,2012; c) 3-hour windrose data from 10:00 to12:00 at KCVG Station on April 7, 2012.North

### May 6, 2012

On May 6, 2012, one exce edance was reported at Monitor ID 21- 037-3002 at 18:00. The exceedance value reported ranged was 93 ppb. The exceedance was modeled by o ne back trajectory in Figure 14a. The meteorological windrose data was also plotted to determine where the wind was blowing from on the exceedance date. Figure 14b shows the windrose data for a 24 hour period on the exceedance day (0:00 to 23:00), Figure 14c show s the windrose data around the time of the

exceedance.

The HYSPLIT back trajectories pass in close proximit y to the Beckjord facility . This indicates a high probability of Beckjord cont ributing to the exceedances reported at the monitor. The windrose data

from around time of the exceedance shows the wind was blowing from the east and southeast. Also, Zimmer did not operate on this day. The May 6, 2012 exceedances are therefore predicted to be attributable to the Beckjord facility.

Trajectory ID Year Month Day Hour Reading
21 2012 May 6 18:00 93a)b) c)Figure 14. a) Beckjord and Zimmer CEMS data andmonitored values at Kentucky Monitor ID 21-037-3002 on May 6, 2012; b) 24-hourwindrose data at KCVG Station on May 6,2012; c) 3-hour windrose data from 17:00 to 19:00 at KCVG Station on May 6, 2012.North

### February 9, 2013

On February 9, 2013, two exceedances were repor ted at Monitor ID 21-037- 3002 between 13:00 and

14:00. The exceedance values r eported ranged from 96 to 124 (Table 6). The exceedances were each modeled by an individual trajectory in Figure 15a. The me teorological windrose data was also plotted to determine where the wind was blowing fr om on the exceedance date. Figure 15b shows the windrose data for a 24 hour period on the exceedanc e day (0:00 to 23:00), Figure 15c shows the

windrose data around the time of the exceedance.

The HYSPLIT back trajectories pass in close proximit y to the Beckjord facility . This indicates a high probability of Beckjord cont ributing to the exceedan ces reported at the monitor. The surface

windrose data from around time of the exceedance shows the wind wa s blowing from the east and southeast. Zimmer did not operate on this day; t he February 9, 2013 exceed ances are therefore predicted to be attributable to the Beckjord facility.

Trajectory ID Year Month Day Hour Reading
22a 2013 February 9 13:00 96
22b 2013 February 9 14:00 124a)b) c)Figure 15. a) Beckjord and Zimmer CEMS data andmonitored values at Kentucky Monitor ID 21-037-3002 on February 9, 2013; b) 24-hour windrose data at KCVG Stationon February 9, 2013; c) 2-hour windrose data from 13:00 to 14:00at KCVG Station on February9, 2013.North

### February 25, 2013

On February 25, 2013, two exceedances were reported at Monitor ID 21-037-3002 at 9:00 and 10:00. The exceedance values reported ranged from 100 to 125 ppb. The ex ceedances were each modeled by an individual trajectory in Figure 16a. The meteorological wind rose data was also plotted to

determine where the wind was blow ing from on the exceedance date. Figure 16b shows the windrose data for a 24 hour period on the exceedance day (0:00 to 23:00) , Figure 16c shows the windrose data

around the time of the exceedance.

The HYSPLIT back trajectories pass directly over and in close proximity to t he Beckjord facility. This indicates a high probability of Be ckjord contributing to the exceedances reported at the monitor. The

surface windrose data from around time of the exceedance shows the wind was blowing from the east/southeast. Zimmer did not operate on this day, therefore, the Februar y 25, 2013 exceedances are predicted to be attributable to the Beckjord facility.

Trajectory ID Year Month Day Hour Reading
23a 2013 February 25 9:00 100
23b 2013 February 25 10:00 125a)b) c)Figure 16. a) Beckjord and Zimmer CEMS data andmonitored values at Kentucky Monitor ID21-037-3002 on February 25, 2013; b)24-hour windrose data at KCVG Station on February 25,2013; c) 4-hour windrosedata from 8:00 to 11:00at KCVG Station onFebruary 25, 2013.North

### March 5, 2013

On March 5, 2013, one exceedanc e was reported at Monitor ID 21-037-3002 at 6:00. The exceedance value reported was 125 ppb. The exceedance was modeled by an indivi dual trajectory in Figure 17a. The meteorological windrose data was also plotted to determine where the wind was blowing from on the exceedance date. Figure 17b shows the windros e data for a 24 hour period on the exceedance day (0:00 to 23:00), Figure 17c sh ows the windrose data around the time of the

exceedance.

The HYSPLIT back trajectories pass in close proximit y to the Beckjord facility . This indicates a high probability of Beckjord cont ributing to the exceedan ces reported at the monitor. The surface windrose data on the exceedance day and around ti me of the exceedance show the wind was blowing predominately fr om the east. The March 5, 2013 exceedanc e is therefore predicted to be attributable to the Beckjord facility.

Trajectory ID Year Month Day Hour Reading

24 2013 March 5 6:00 125a)b)Figure 17. a) Beckjord and Zimmer CEMS data andmonitored values at Kentucky Monitor ID21-037-3002 on March 5, 2014; b) 24-hour windrose data at KCVG Station on March 5,2014; c) 2-hour windrose data from 5:00 to7:00 at KCVG Station on March 5, 2014.North

### IV. Zimmer Trajectories

This Section includes exceedance da ys in which the HYSPLIT back trajectories pass directly over or in close proximity to the Zimmer facility indicati ng a high probability of Zimmer contributing to the exceedances reported at the monitor. Also in th is Section, data including surface wind data and CEMS data were analyzed to draw conclusions about the likely contribution of Zimmer emissions in

relation to the exceedance at the monitor.

February 3, 2012

On February 3, 2012, one exceedance was report ed at Monitor ID 21-037-3002 at 17:00. The exceedance value reported was 82 ppb. The exceedance was modeled by one HYSPLIT back trajectory in Figure 18a. The me teorological windrose dat a was also plotted to determine where the wind was blowing from on the exce edance date. Figure 18b shows the windrose data for a 24 hour period on the exceedance day (0: 00 to 23:00), Figure 18c shows the windrose data around the time of the exceedance hour. Figur e 18d shows the CEMS data for both the Beckjord and Zimmer

facilities in relation to the recorded monitored valu es on an hourly basis for the exceedance day. The HYSPLIT back trajectory passes in close proximity to the Zimmer facility. This indicates a high probability of Zimmer contri buting to the exceedances reported at the monitor. The windrose data at the time of the exceedances shows the wind was blowing predominantly from the northeastern direction with a slight contribution form the s outheastern direction between 16:00 and 18:00. Examining the windrose data for t he entire day shows surface winds blowing predominately from the

east/ southeast direction. Based on the results of the HYSPLIT data it would appear Zimmer was the most likely contributor. However, based on the windrose data it would ap pear Beckjord was more likely the contributor to the ex ceedance on February 3, 2012. It should be noted emissions from Beckjord were over five times the emissions of Zimmer prior to and during the exceedance period.

Trajectory ID Year Month Day Hour Reading
17 2012 February 3 17:00 82

### a) 

## Northb) c)d)Figure 18. a) Beckjord and Zimmer CEMS data andmonitored values at Kentucky Monitor ID 21-037-3002 on February 3, 2012; b) 24-hour windrose data at KCVG Stationon February 3, 2012; c) 3-hour windrose data from 16:00 to 18:00at KCVG Station on February3, 2012.0102030405060708090050001000015000200002500030000 0:00 1:00 2:00 3:00 4:00 5:00 6:00 7:00 8:00 9:00 10:00 11:00 12:00 13:00 14:00 15:00 16:00 17:00 18:00 19:00 20:00 21:00 22:00 23:00

SO2 (lbs/hr)HourFebruary3,2012CEMSData(Beckjord)CEMSData(Zimmer)MonitorValue(ppb)

### V. Intermediate Trajectories

This Section includes exceedance days in which the HYSPLIT back trajectories pass between the Beckjord and Zimmer facilities and are not directly a ttributable to either facility. Additional data including surface wind data and CEMS were anal yzed to draw conclusions about the likely contributions of Beckjord and Zimmer emissions in relation to the exceedanc e at the monitor.

March 8, 2011 - Beckjord

On March 8, 2011, one exceedance was reported at Monitor ID 21-037-3002 at 17:00. The exceedance value reported was 84 ppb. The exceedance was modeled by one HYSPLIT back trajectory in Figure 19a. The me teorological windrose dat a was also plotted to determine where the wind was blowing from on the exce edance date. Figure 19b shows the windrose data for a 24 hour period on the exceedance day (0: 00 to 23:00), Figure 19c shows the windrose data around the time of the exceedance hour. Figure 19d shows t he CEMS data for both the Beckjord and Zimmer

facilities in relation to the recorded monitored valu es on an hourly basis for the exceedance day. The HYSPLIT back trajectory passes in between the Be ckjord facility and the Zimme r facility. Examination

of the wind rose around the time of the exceedance demonstrates that the pr evailing surface winds

were from the East. The surfac e wind direction data w ould suggest that emissions from Beckjord were most likely impacting the monitor and contribut ing to the exceedance. In addition, emissions data shown in Figure 6e, demonstrat e that on this date emissions from the Beckjord facility were approximately four times greater t han those of Zimmer. Based on the analysis of the data for March 8, 2011 Beckjord has a hi gh probability of contributing to the exceedance at the monitor.

Trajectory ID Year Month Day Hour Reading

9 2011 March 8 17:00 84

a) 

## Northb)c)d)Figure 19. a) Beckjord and Zimmer CEMS data andmonitored values at Kentucky Monitor ID21-037-3002 on March 8, 2011; b) 24-hour windrose data at KCVG Station on March8, 2011; c) 3-hour windrose data from 16:00 to 18:00 atKCVG Station on March 8,2011; d) CEMS data for both the Beckjord and Zimmer facilities in relation to the recorded monitored values on an hourly basisfor theexceedance day.010203040506070809005000100001500020000250003000035000 0:00 1:00 2:00 3:00 4:00 5:00 6:00 7:00 8:00 9:00 10:00 11:00 12:00 13:00 14:00 15:00 16:00 17:00 18:00 19:00 20:00 21:00 22:00 23:00

SO2 (lbs/hr)HourMarch8,2011CEMSData(Beckjord)CEMSData(Zimmer)MonitorValue(ppb)

### March 20, 2011 - Beckjord

On March 20, 2011, one exceedance was reported at Monitor ID 21-037-3002 at 7:00. The exceedance value reported was 89 ppb. The exceedance was modeled by one HYSPLIT back trajectory in Figure 20. The meteorological wi ndrose data was also plott ed to determine where the wind was blowing from on the exce edance date. Figure 20b shows the windrose data for a 24 hour period on the exceedance day (0: 00 to 23:00), Figure 20c shows the windrose data around the time of the exceedance hour. Figure 20d shows t he CEMS data for both the Beckjord and Zimmer

facilities in relation to the recorded monitored valu es on an hourly basis for the exceedance day. The HYSPLIT back trajectory passes in between the Beckjord facility and the Zimmer facility.

Examination of the wind rose ar ound the time of the exceedance dem onstrates that the prevailing

surface winds were from the East. The surface wind direction data would suggest that emissions from Beckjord were most likely impacting the monitor and contributi ng to the exceedance. It should be noted that the winds did not begi n blowing from the south and sout heast until approximately 13:00,

well after the exceedance was re corded. Additionally, prior to the exceedance emissions from Beckjord increased markedly in a relatively short period of time, while emissions from Zimmer remained relatively constant. Taking these further data into account, it is highly probable that emissions from Beckjord are the likely contributor to the exce edance recorded on March 20, 2011.

Trajectory ID Year Month Day Hour Reading

10 2011 March 20 7:00 89

a) 

## Northb)c)d)Figure 20. a) Beckjord and Zimmer CEMS data and monitored values at Kentucky MonitorID 21-037-3002 on March 20, 2011; b) 24-hour windrose data at KCVG Station on March20, 2011; c) 3-hour windrose data from 6:00to 8:00 at KCVG Station on March 20,2011; d) CEMS data for both the Beckjord and Zimmer facilities in relation to the recorded monitored values on an hourly basisfor theexceedance day.0102030405060708090100050001000015000200002500030000 0:00 1:00 2:00 3:00 4:00 5:00 6:00 7:00 8:00 9:00 10:00 11:00 12:00 13:00 14:00 15:00 16:00 17:00 18:00 19:00 20:00 21:00 22:00 23:00

SO2 (lbs/hr)HourMarch20,2011CEMSData(Beckjord)CEMSData(Zimmer)MonitorValue(ppb)

### February 28, 2012 - Beckjord

On February 28, 2012, one exc eedance was reported at Monitor ID 21-037-3002 at 12:00. The exceedance value reported was 77 ppb. The exceedance was modeled by one HYSPLIT back trajectory in Figure 21a. The trajectory analysis on this date is at ypical, as the upper level winds take a circuitous route around both Beckjord and Zimmer pr ior to reaching the monitor location. This impedes a straightforward determination of t he cause of the exceedance based on the HYSPLIT data. The meteorological windr ose data was also plotted to det ermine where the wind was blowing from on the exceedance date. Figure 21b shows the windrose data for a 24 hour period on the exceedance day (0:00 to 23:00), Figure 21c show s the windrose data around the time of the exceedance hour. Figure 21d shows the CEMS data fo r both the Beckjord and Zimmer facilities in

relation to the recorded monitor ed values on an hourly basis for the exceedance day. The surface

wind data around the time of the vi olation shows predominant winds from the eastern direction.

Further examination of the emissi ons data shows only that emi ssions data from Beckjord were approximately five times greater than that of Zimmer. Taking these fu rther data into account, it is highly probable that emissions from Beckjord are the likely contribu tor to the exceedance on February
28, 2012.

Trajectory ID Year Month Day Hour Reading
19 2012 February 28 12:00 77

a) 

## Northb) c)d)Figure 21. a) Beckjord and Zimmer CEMS data andmonitored values at Kentucky Monitor ID21-037-3002 on February 28, 2012; b)24-hour windrose data at KCVG Station on February 28,2012; c) 3-hour windrosedata from 11:00 to 13:00at KCVG Station onFebruary 28, 2012; d) CEMS data for both the Beckjord and Zimmer facilities in relation to the recorded monitored values on anhourlybasis for the exceedance day.0102030405060708090050001000015000200002500030000 0:00 1:00 2:00 3:00 4:00 5:00 6:00 7:00 8:00 9:00 10:00 11:00 12:00 13:00 14:00 15:00 16:00 17:00 18:00 19:00 20:00 21:00 22:00 23:00

SO2 (lbs/hr)HourFebruary28,2012CEMSData(Beckjord)CEMSData(Zimmer)MonitorValue(ppb)

### April 7, 2012 – Beckjord

On April 7, 2012, two exceedances were repor ted at Monitor ID 21-037-3002. Beckjord was determined to be the most probably contributor the exceedance at the 11:00 hour as discussed in Section I of this report. The exceedance of 81 ppb at 15:00 is discussed bel ow. The exceedance was modeled by one HYSPLIT back trajecto ry in Figure 22a. The meteorol ogical windrose data was also plotted to determine where the wind was blowing fr om on the exceedance date. Figure 22b shows the windrose data for a 24 hour period on the exce edance day (0:00 to 23:00), Figure 22c shows the windrose data around the time of the exceedance hour. Figure 22d shows the CEMS data for both the Beckjord and Zimmer facilities in relation to the recorded monitored values on an hourly basis for the exceedance day.

The HYSPLIT back trajectory passes in close proximit y to the Zimmer facility. This indicates a high probability of Zimmer contri buting to the exceedance r eported at the monitor. The windrose data at

the time of the exceedances wi nds were blowing from the east/s outheast direction between 14:00 and 16:00. This would indicate Beckjord and Zi mmer may have contributed to the exceedance; however, as shown in Figure 22d Zimmer did not have SO 2 

### emissions on this day. Therefore, it is most likely that the exceedance was c aused by the Beckjord facility.

Trajectory ID Year Month Day Hour Reading
20c 2012 April 7 15:00 81

a)



## Northb)c)d)Figure 22. a) Beckjord and Zimmer CEMS data andmonitored values at Kentucky Monitor ID21-037-3002 on April 7, 2012; b) 24-hourwindrose data at KCVG Station on April 7,2012; c) 3-hour windrose data from 14:00 to 16:00 at KCVG Station on April 7, 2012; d)CEMS data for both the Beckjord and Zimmer facilities in relation to the recorded monitored values on an hourly basis for theexceedance day.020406080100120050001000015000200002500030000 0:00 1:00 2:00 3:00 4:00 5:00 6:00 7:00 8:00 9:00 10:00 11:00 12:00 13:00 14:00 15:00 16:00 17:00 18:00 19:00 20:00 21:00 22:00 23:00

SO2 (lbs/hr)HourApril7,2012CEMSData(Beckjord)CEMSData(Zimmer)MonitorValue(ppb)

### VI. Other Trajectories

This Section includes exceedance days in which the HYSPLIT back trajectories do not pass near proximity to Beckjord or Zimmer. For these exce edance days, the analysis relied heavily upon the

surface wind data and CEMS data to determine the likely contri bution of Beckjord and Zimmer

emissions in relation to the exceedance at the monitor.

July 31, 2010 - Beckjord

On July 31, 2010, one exceedance was reported at Monitor ID 21- 037-3002 at 14:00. The reported exceedance value was 82 ppb. One HYSP LIT back trajectories was modeled as shown in Figure 23a to represent the exceedanc e in the table below. The meteorologica l windrose data was also plotted to

determine where the wind was blow ing from on the exceedance date. Figure 23b shows the windrose data for a 24 hour period on the exceedance day (0:00 to 23:00) , Figure 23c shows the windrose data

around the time of the 14:00 hour exceedance.

The HYSPLIT back trajectories pass north the Beckjord fac ility. The windrose data at the time of the exceedances shows the wind was blowing exclusively fr om the direction where the Beckjord facility is located. The SO2 emissions at the Beckjord fac ility markedly increased in the hours priors to the exceedance. Based on the combined interpretation of the data presented for this exceedance day, Beckjord is the most likely contributor to the exceedances reported at the monitor.

Trajectory ID Year Month Day Hour Reading

2 2010 7 31 14:00 82

a) 

## Northb)c)d)Figure 23. a) Beckjord and Zimmer CEMS data andmonitored values at Kentucky Monitor ID21-037-3002 on July 31, 2010; b) 24-hourwindrose data at KCVG Station on July 31, 2010; c) 3-hour windrose datafrom 13:00 to 15:00 at KCVGStation on July 31, 2010; d)CEMS data for both the Beckjord and Zimmer facilities in relation to the recorded monitored values on an hourly basis for theexceedance day.0102030405060708090050001000015000200002500030000 0:00 1:00 2:00 3:00 4:00 5:00 6:00 7:00 8:00 9:00 10:00 11:00 12:00 13:00 14:00 15:00 16:00 17:00 18:00 19:00 20:00 21:00 22:00 23:00

SO2 (lbs/hr)HourJuly31,2010CEMSData(Beckjord)CEMSData(Zimmer)MonitorValue(ppb)

### August 27, 2010 - Beckjord

On August 27, 2010, one exceedance was reported at Monitor ID 21-037-3002 at 9:00. The exceedance value reported was 118 ppb. The exceedance was mo deled by one HYSPLIT back trajectory in Figure 24a. The me teorological windrose dat a was also plotted to determine where the wind was blowing from on the exce edance date. Figure 24b shows the windrose data for a 24 hour period on the exceedance day (0: 00 to 23:00), Figure 24c shows the windrose data around the time of the exceedance hour. Figure 24d shows t he CEMS data for both the Beckjord and Zimmer

facilities in relation to the recorded monitored val ues on an hourly basis for the exceedance day.

The HYSPLIT back trajectory is show n north of the Beckjord facility. The windrose data at the time of

the exceedances shows the wind was blowing from the east/nort heast. The SO2 emissions at the Beckjord facility markedly increased in the hours priors to the exceedance. Based on the data presented for this exceedance day, Beckjord is th e most likely contributor to the exceedances reported at the monitor.

Trajectory ID Year Month Day Hour Reading

3 2010 August 27 9:00 118

a) 

## Northb)c)Figure 24. a) Beckjord and Zimmer CEMS data andmonitored values at Kentucky Monitor ID21-037-3002 on August 27, 2010; b) 24-hour windrose data at KCVG Station on August27, 2010; c) 3-hour windrose data from 8:00 to10:00 at KCVG Station on August 27,2010; d) CEMS data for both the Beckjord and Zimmer facilities in relation to the recorded monitored values on an hourly basisfor theexceedance day.0204060801001201400500010000150002000025000 0:00 1:00 2:00 3:00 4:00 5:00 6:00 7:00 8:00 9:00 10:00 11:00 12:00 13:00 14:00 15:00 16:00 17:00 18:00 19:00 20:00 21:00 22:00 23:00

SO2 (lbs/hr)HourAugust27,2010CEMSData(Beckjord)CEMSData(Zimmer)MonitorValue(ppb)

### September 14, 2010 – Beckjord

On September 14, 2010, one exceedance was repor ted at Monitor ID 21-037-3002 at 11:00. The exceedance value reported was 118 ppb. The exceedance was mo deled by one HYSPLIT back trajectory in Figure 25a. The me teorological windrose dat a was also plotted to determine where the wind was blowing from on the exce edance date. Figure 25b shows the windrose data for a 24 hour period on the exceedance day (0: 00 to 23:00), Figure 25c shows the windrose data around the time of the exceedance hour. Figure 25d shows t he CEMS data for both the Beckjord and Zimmer

facilities in relation to the recorded monitored val ues on an hourly basis for the exceedance day.

The HYSPLIT trajectory does not pass over or in close proximity to Beckjord or Zimmer. Examination

of the wind direction data reveals that surface leve l winds on this date were primarily from the east which suggests that emissions fr om Beckjord are the likely cause of the exceedance on this date. Furthermore, examination of the emissions data s hown in Figure 25d shows that emissions from Beckjord markedly increased in the hours leading up to the exceedance. Base d on the data, and the lack of other significant sources of SO2 along the trajectory shown, Beckjord was determined to be the most likely contribu tor to the exceedance.

a) Trajectory ID Year Month Day Hour Reading

4 2010 September 14 11:00 99



## Northb)c)d)Figure 25. a) HYSPLIT back trajectory from Monitor ID 21-037-3002on September 14, 2010 at 11:00; c) 24-hour windrose data atKCVG Station on September14, 2010; d) 3-hour windrose data from8:00 to 11:00 at KCVG Stationon September 14, 2010; d) CEMSdata for both the Beckjord and Zimmer facilities in relation to the recorded monitored values onan hourly basis for the exceedance day.0204060801001200500010000150002000025000 0:00 1:00 2:00 3:00 4:00 5:00 6:00 7:00 8:00 9:00 10:00 11:00 12:00 13:00 14:00 15:00 16:00 17:00 18:00 19:00 20:00 21:00 22:00 23:00

SO2 (lbs/hr)HourSeptember14,2010CEMSData(Beckjord)CEMSData(Zimmer)MonitorValue(ppb)

### February 23, 2011 - Beckjord

On February 23, 2011, one e xceedance was reported at Monito r ID 21-037-3002 at 9:00. The exceedance value reported was 137 ppb. The exceedance was mo deled by one HYSPLIT back trajectory in Figure 26a. The me teorological windrose dat a was also plotted to determine where the wind was blowing from on the exce edance date. Figure 26b shows the windrose data for a 24 hour period on the exceedance day (0: 00 to 23:00), Figure 26c shows the windrose data around the time of the exceedance hour. Figur e 26d shows the CEMS data for both the Beckjord and Zimmer

facilities in relation to the recorded monitored val ues on an hourly basis for the exceedance day.

The HYSPLIT trajectory does not pa ss over or in close proximity to Beckjord or Zimmer. Emissions

from both facilities were relative ly stable throughout the day and reco rded values remained low at the monitor with the exception of the sharp spike observed at the exc eedance hour. Examination of the

wind direction data reveals that surface level wi nds on this date were predominantly from the

southeast direction where Zimmer is located. Winds data around the time of the exceedance reveals that surface level winds during this period were predominantly fr om the eastern direction where Beckjord is located. Based on the data, Beckjord was determined to be the most likely contributor to

the exceedance.

Trajectory ID Year Month Day Hour Reading
6 2011 February 23 9:00 137

a) 

## Northb)c)d)Figure 26. a) Beckjord and Zimmer CEMS data andmonitored values at Kentucky Monitor ID21-037-3002 on February 23, 2011; b)24-hour windrose data at KCVG Station on February 23,2011; c) 3-hour windrosedata from 8:00 to 11:00at KCVG Station onFebruary 23, 2011; d) CEMS data for both the Beckjord and Zimmer facilities in relation to the recorded monitored values on anhourlybasis for the exceedance day.0204060801001201401600100002000030000400005000060000 0:00 1:00 2:00 3:00 4:00 5:00 6:00 7:00 8:00 9:00 10:00 11:00 12:00 13:00 14:00 15:00 16:00 17:00 18:00 19:00 20:00 21:00 22:00 23:00

SO2 (lbs/hr)HourFebruary23,2011CEMSData(Beckjord)CEMSData(Zimmer)MonitorValue(ppb)

### April 22, 2011 – Beckjord

On April 22, 2011, one exceedance wa s reported at Monitor ID 21- 037-3002 at 3:00. The exceedance value reported was 109 ppb. T he exceedance was modeled by one HYSPLIT back trajectory in Figure 27a. The meteorological windrose data was also plotted to determine where the wind was blowing from on the exceedance date. Figure 27b shows the windros e data for a 24 hour period on the exceedance day (0:00 to 23:00), Figure 27c sh ows the windrose data around the time of the exceedance hour. Figure 27d shows the CEMS data fo r both the Beckjord and Zimmer facilities in

relation to the recorded monitored values on an hourly basis for th e exceedance day.

The HYSPLIT trajectory does not pass over or in close proximity to Beckjord or Zimmer. Examination

of the surface wind direction data reveals that su rface level winds on this date were predominantly

from the east. Winds data around t he time of the exceedance shows t hat surface level winds during this period were also predominant ly from the east where Beckjord is located. Based on the data, Beckjord was determined to be the most likely contributor to the exceedance.

Trajectory ID Year Month Day Hour Reading
35 2011 April 22 3:00 109

a) 35



## Northb)c)d)Figure 27. a) Beckjord and Zimmer CEMS data andmonitored values at Kentucky Monitor ID21-037-3002 on April 22, 2011; b) 24-hour windrose data at KCVG Station on April22, 2011; c) 3-hour windrose data from 2:00to 4:00 at KCVG Station on April 22, 2011; d)CEMS data for both the Beckjord and Zimmer facilities in relation to the recorded monitored values on an hourly basis for theexceedance day.0204060801001200500010000150002000025000 0:00 1:00 2:00 3:00 4:00 5:00 6:00 7:00 8:00 9:00 10:00 11:00 12:00 13:00 14:00 15:00 16:00 17:00 18:00 19:00 20:00 21:00 22:00 23:00

SO2 (lbs/hr)HourApril22,2011CEMSData(Beckjord)CEMSData(Zimmer)MonitorValue(ppb)

### July 5, 2011 - Beckjord

On July 5, 2011, two exceedances were repor ted at Monitor ID 21- 037-3002 between 10:00 and 11:00. The exceedance values reported were 91 and 180, respectively. The exceedances were modeled by one HYSPLIT back trajecto ry in Figure 28a. The meteorol ogical windrose data was also plotted to determine where the wind was blowing fr om on the exceedance date. Figure 28b shows the windrose data for a 24 hour period on the exce edance day (0:00 to 23:00), Figure 28c shows the

windrose data around the time of the exceedance hours. Figure 28d shows the CEMS data for both the Beckjord and Zimmer facilities in relation to t he recorded monitored val ues on an hourly basis for the exceedance day.

The HYSPLIT trajectory does not pass over or in close proximity to Beckjord or Zimmer. Examination

of the surface wind direction data reveals that su rface level winds on this date were predominantly

northwest. Wind data around the time of the exceedance shows that su rface level winds during this period were from the northeast/east/southeast indicating that Beckjord or Zimmer may have

contributed to the exceedance. T he CEMS data shows the Beckjord em issions markedly increased in the hours prior to the exceedance and the emissions at Zimmer we re zero at the time of the exceedance and for several hours pr ior. Based on this information , Beckjord was determined to be the most likely contribu tor to the exceedance.

Trajectory ID Year Month Day Hour Reading
12 2011 July 5 10:00 91
12 2011 July 5 11:00 180

a) 

## Northb) c)d)Figure 28. a) Beckjord and Zimmer CEMS data and monitored values at Kentucky Monitor ID 21-037-3002 on July 5, 2011; b) 24-hourwindrose data at KCVG Station on July 5, 2011; c) 3-hour windrose data from 9:00 to 12:00at KCVG Station on July 5, 2011; d) CEMSdata for both the Beckjord and Zimmer facilities in relation to the recorded monitored values onan hourly basis for the exceedance day.0204060801001201401601802000500010000150002000025000300003500040000 0:00 1:00 2:00 3:00 4:00 5:00 6:00 7:00 8:00 9:00 10:00 11:00 12:00 13:00 14:00 15:00 16:00 17:00 18:00 19:00 20:00 21:00 22:00 23:00

SO2 (lbs/hr)HourJuly5,2011CEMSData(Beckjord)CEMSData(Zimmer)MonitorValue(ppb)

### January 11, 2012 - Beckjord

On January 11, 2012, one exceedance was reported at Monitor ID 21-037-3002 between at 12:00. The exceedance value reported was 76 ppb. The exceedance was modeled by one HYSPLIT back trajectory in Figure 29a. The me teorological windrose dat a was also plotted to determine where the wind was blowing from on the exce edance date. Figure 29b shows the windrose data for a 24 hour period on the exceedance day (0: 00 to 23:00), Figure 29c shows the windrose data around the time of the exceedance hour. Figur e 29d shows the CEMS data for both the Beckjord and Zimmer

facilities in relation to the recorded monitored val ues on an hourly basis for the exceedance day.

The HYSPLIT trajectory does not pass over or in cl ose proximity to Beckjord or Zimmer. The CEMS data shows a slight increase in SO2 emissions in the hours prior to the exceedance; the Zimmer SO2 emissions remained steadily elevat ed throughout the day until dropping off at 15:00. Examination of

the surface wind direction data reveals that surface level winds on this date were predominantly from

the east. Surface level wind data ar ound the time of the exceedance sh ows that surface level winds during this period were exclusively from the east indicating a high probability that Beckjord

contributed to the exceedance. Ba sed on this information, Beckjord was determined to be the most likely contributor to the exceedance.

Trajectory ID Year Month Day Hour Reading
15 2012 January 11 12:00 76

a) 

## Northb) c)d)Figure 29. a) Beckjord and Zimmer CEMS data andmonitored values at Kentucky Monitor ID 21-037-3002 on January 11, 2012; b) 24-hour windrose data at KCVG Station on January 11,2012; c) 3-hour windrose data from 11:00 to 13:00 at KCVG Station on January11,2012; d) CEMS data for both theBeckjord and Zimmer facilities in relation to the recorded monitored values on an hourly basis forthe exceedance day.0102030405060708005000100001500020000250003000035000 0:00 1:00 2:00 3:00 4:00 5:00 6:00 7:00 8:00 9:00 10:00 11:00 12:00 13:00 14:00 15:00 16:00 17:00 18:00 19:00 20:00 21:00 22:00 23:00

SO2 (lbs/hr)HourJanuary11,2012CEMSData(Beckjord)CEMSData(Zimmer)MonitorValue(ppb)

### January 25, 2012 – Beckjord/Combined

On January 25, 2012, one exceedance was reported at Monitor ID 21-037-3002 at 12:00. The exceedance value reported was 85 ppb. The exceedance was modeled by one HYSPLIT back trajectory in Figure 30a. The me teorological windrose dat a was also plotted to determine where the wind was blowing from on the exce edance date. Figure 30b shows the windrose data for a 24 hour period on the exceedance day (0: 00 to 23:00), Figure 30c shows the windrose data around the time of the exceedance hour. Figur e 30d shows the CEMS data for both the Beckjord and Zimmer

facilities in relation to the recorded monitored val ues on an hourly basis for the exceedance day.

The HYSPLIT trajectory does not pass over or in cl ose proximity to Beckjord or Zimmer. The CEMS

data shows both facilities emissions remained rela tively constant throughout the day. Examination of

the surface wind direction data around the time of the exceedance shows wind s were blowing from

the northeast/east/southeast directi on. It should be noted that Beckjor d’s emissions were over four times that of Zimmer during the day. This would indicate that Beckj ord was the main contributor to the exceedance although wind data may i ndicate Zimmer had a contribution.

Trajectory ID Year Month Day Hour Reading
16 2012 January 25 12:00 85

a) 

## Northb) c)d)Figure 30. a) Beckjord and Zimmer CEMS data andmonitored values at Kentucky Monitor ID 21-037-3002 on January 25, 2012; b) 24-hour windrose data at KCVG Station on January 25,2012; c) 3-hour windrose data from 11:00 to 13:00 at KCVG Station on January25,2012; d) CEMS data for both theBeckjord and Zimmer facilities in relation tothe recorded monitored values on an hourly basis forthe exceedance day.010203040506070809002000400060008000100001200014000160001800020000 0:00 1:00 2:00 3:00 4:00 5:00 6:00 7:00 8:00 9:00 10:00 11:00 12:00 13:00 14:00 15:00 16:00 17:00 18:00 19:00 20:00 21:00 22:00 23:00

SO2 (lbs/hr)HourJanuary25,2012CEMSData(Beckjord)CEMSData(Zimmer)MonitorValue(ppb)

### March 6, 2014 – neither

On March 6, 2013, one exceedance was reported at Monitor ID 21-037-3002 at 12:00. The exceedance value reported was 93 ppb. The exceedance was modeled by an individual trajectory in Figure 31a. The meteorological windrose data was also plotted to determine where the wind was blowing from on the exceedance date. Figure 31b shows the windros e data for a 24 hour period on the exceedance day (0:00 to 23:00), Figure 31c sh ows the windrose data around the time of the

exceedance.

The HYSPLIT back trajectories pass north of the Be ckjord facility. The surface windrose data on the exceedance day and around time of t he exceedance show the wind was blowing predominately from
the northeast. The March 6, 2014 exc eedance is therefore not attribut able to Beckjord or Zimmer.

Ohio EPA is not aware of other major sources of SO2 emissions in the area encompassed by the trajectory.

Trajectory ID Year Month Day Hour Reading

25 2014 March 6 12:00 93

a) 

## Northb) c)Figure 31. a) Beckjord and Zimmer CEMS data andmonitored values at Kentucky Monitor ID21-037-3002 on March 6, 2014; b) 24-hour windrose data at KCVG Station on March6, 2014; c) 2-hour windrose data from 11:00 to 13:00 atKCVG Station on March 6,2014; d) CEMS data for both the Beckjord and Zimmer facilities in relation to the recorded monitored values on an hourly basisfor theexceedance day.010203040506070809010005000100001500020000250003000035000 0:00 1:00 2:00 3:00 4:00 5:00 6:00 7:00 8:00 9:00 10:00 11:00 12:00 13:00 14:00 15:00 16:00 17:00 18:00 19:00 20:00 21:00 22:00 23:00

SO2 (lbs/hr)HourMarch6,2014CEMSData(Beckjord)CEMSData(Zimmer)MonitorValue(ppb)

### VII. Summary

Between January 1, 2010 and August 31, 2014, 44 ex ceedances of the 2010 1-hour SO2 NAAQS were reported at Monitor ID 21-037- 3002. Review of the dat a presented in this report indicates 42 of the exceedances were most likely attributable to SO 2 emissions at the W.C. Beckjord Facility; and 1 exceedance was likely attributable to the W.C. Be ckjord Facility but may have been influenced by SO2 emissions from both facilities; and 1 exceedanc e was not attributable to either facility.

As presented in Table 2 of this report, the W.C. Beckjord Facility consistently emitted substantially higher SO2 emission for the per iod analyzed. Although emissions themselves are not directly indicative of a particular source causing or c ontributing to an exceedance or exceedances, together with the majority of exceedances being attributable to Beckjord demonstrates t he Beckjord facility is the primary SO2 source causing exceedances of the 1-hour SO2 NAAQS at monitor 21-037-3002.