Appendix 1

Florida Sulfur Dioxide (SO2) Monitoring Data

There are currently 19 SO2 monitoring sites in the Florida network. Of these, three are currently (based 

on 2008-2010 data) in violation of the 1-hour ambient air quality standard of 75 parts per billion (ppb). 

Compliance with this standard is based on the three-year average of the 99th percentile maximum daily 

1-hour average SO2 concentration. This metric is referred to as the design value. The following map 

shows the current design value for all the SO2 monitoring sites in the state.

The three monitors with design values greater than 75 ppb are located in Hillsborough, Nassau, and 

Escambia counties. Each of these monitors is located in close proximity to a large SO2 source. The 

Hillsborough County violating monitor (Gibsonton) is next to the Mosaic Riverview phosphate processing 

plant, the Nassau County monitor (Fernandina Beach) is next to the Rayonier Performance Fibers mill, 

and the Escambia County monitor (Ellyson) is located near the Gulf Power Crist power plant. The table 

below also provides the statewide data with the site name and county location.
Site Name County

2008-2010 1-hr SO2

Design Value (ppb)

Fay Park Brevard 14

Lincoln Park Elem. Broward 41

Kooker Park Duval 15

Minerva Street Duval 17

Cedar Bay STP Duval 26

Fort Caroline Road Duval 18

Ellyson Escambia 79

White Springs Hamilton 23

Simmons Park Hillsborough 23

Gibsonton Hillsborough 110

Davis Island Hillsborough 47

Sydney Hillsborough 17

DOT Miami Miami-Dade 2

Fernandina Beach Nassau 129

Winter Park Orange 8

Riviera Beach Palm Beach 6

Derby Lane Pinellas 45

Oakwood Pinellas 34

Palatka Barge Port Putnam 39

More detailed information on each monitor can be obtained from the department.
Appendix 2

Sulfur Dioxide (SO2) Nonattainment Boundary Five-Factor Analysis for the Gibsonton Monitoring Site 

(Hillsborough County)

Recommendation

The recommended area of SO2 nonattainment near the Gibsonton monitoring site in Hillsborough 

County is described by a polygon encompassing the predicted area having a design value greater than 

the 1-hour ambient SO2 standard of 75 parts per billion (ppb). This area includes the location of the

violating monitor (AQS monitor ID 0570109). The vertices of the polygon are as follows, using Universal 

Transverse Mercator (UTM) coordinates in UTM zone 17 with datum NAD83:

Vertices UTM Easting (m) UTM Northing (m)

1 358581 3076066

2 355673 3079275

3 360300 3086380

4 366850 3086692

5 368364 3083760

6 365708 3079121

The determination of this area was based on the five factors outlined in the EPA guidance 

memorandum, “Area Designations for the 2010 Revised Primary Sulfur Dioxide National Ambient Air 

Quality Standards (March 24, 2010),” and on air dispersion modeling that was completed following the 

general guidance in the same document. Analysis of the five factors to be considered, as outlined in the 

guidance, and the modeling follows.

Five-Factor Analysis

1. Air Quality Data

There are six SO2 monitors in the Tampa Bay area. The monitor located near Gibsonton, Florida, is 

currently in violation of the new 1-hour SO2 standard. A violation occurs when the three-year average 

of the 99th percentile maximum daily 1-hour average concentration is greater than 75 ppb. All other 

monitors in the area are well below the standard. A summary of the monitoring data is below.
Site:L0570081 - E.G. Simmons Park - #113 County:Hillsborough AQS Monitor ID:12-057-0081-42401-1

Year

Ranked 1-Hour Averages Ranked 3-Hour Averages Ranked 24-Hour Averages

Annual

Average

99th Percentile Values

Design

1 Value st 2nd 1st 2nd 1st 2nd Complete Days Valid

2008 35 (03/01) 29 (09/15) 26 (09/15:09) 17 (02/09:09) 7 (02/09) 6 (09/15) 1.7 25 25

2009 24 (12/29) 23 (09/15) 16 (12/29:00) 15 (09/15:09) 6 (12/27) 6 (01/21) 1.5 18 18

2010 32 (01/11) 32 (01/07) 26 (01/11:18) 23 (01/11:15) 9 (01/11) 6 (01/10) 1.6 25 25 23

Site:L0570109 - South of Tampa, Replaced 0108 County:Hillsborough AQS Monitor ID:12-057-0109-42401-1

Year

Ranked 1-Hour Averages Ranked 3-Hour Averages Ranked 24-Hour Averages

Annual

Average

99th Percentile Values

Design

1 Value st 2nd 1st 2nd 1st 2nd Complete Days Valid

2008 189 (01/01) 169 (09/05) 137 (01/01:18) 135 (01/01:15) 48 (01/01) 30 (03/24) 3.2 123 123

2009 136 (03/02) 134 (02/20) 117 (03/02:00) 109 (03/02:03) 40 (03/02) 27 (04/07) 3.2 104 104

2010 119 (12/27) 117 (12/26) 102 (12/27:00) 96 (12/27:03) 34 (12/27) 28 (12/01) 3.0 104 104 110†

Site:L0571035 - Coast Guard Station - Davis Island County:Hillsborough AQS Monitor ID:12-057-1035-42401-1

Year

Ranked 1-Hour Averages Ranked 3-Hour Averages Ranked 24-Hour Averages

Annual

Average

99th Percentile Values

Design

1 Value st 2nd 1st 2nd 1st 2nd Complete Days Valid

2008 71 (08/27) 70 (07/12) 38 (07/12:00) 38 (10/30:06) 11 (08/24) 10 (10/30) 2.7 49 49

2009 39 (03/22) 38 (02/25) 27 (07/29:03) 24 (02/25:21) 8 (07/29) 7 (12/22) 2.0 35 35

2010 67 (09/19) 66 (11/20) 40 (11/20:00) 39 (09/19:06) 10 (11/19) 8 (09/19) 1.9 57 57 47

Site:L0573002 - Sydney County:Hillsborough AQS Monitor ID:12-057-3002-42401-1

Year

Ranked 1-Hour Averages Ranked 3-Hour Averages Ranked 24-Hour Averages

Annual

Average

99th Percentile Values

Design

1 Value st 2nd 1st 2nd 1st 2nd Complete Days Valid

2008 55 (02/21) 28 (01/31) 20 (02/21:03) 15 (01/31:09) 4 (02/21) 3 (11/22) 1.4 19 19

2009 18 (09/25) 17 (04/19) 10 (01/24:09) 10 (04/09:18) 4 (01/23) 2 (01/24) 1.2 16 16

2010 27 (03/01) 17 (10/31) 19 (03/01:18) 12 (06/15:18) 3 (03/01) 3 (01/05) 1.2 15 15 17
Site:L1030023 - Derby Lane County:Pinellas AQS Monitor ID:12-103-0023-42401-1

Year

Ranked 1-Hour Averages Ranked 3-Hour Averages Ranked 24-Hour Averages

Annual

Average

99th Percentile Values

Design

1 Value st 2nd 1st 2nd 1st 2nd Complete Days Valid

2008 119 (06/07) 94 (07/04) 63 (07/04:09) 57 (06/07:09) 22 (10/23) 18 (06/07) 2.4 62 62

2009 101 (02/13) 100 (02/06) 46 (03/13:12) 46 (02/06:12) 10 (03/24) 9 (02/06) 1.5 58 58

2010 40 (01/11) 19 (01/09) 32 (01/11:12) 27 (01/11:15) 9 (01/11) 6 (01/09) 1.2 15 15 45

Site:L1035003 - Oakwood County:Pinellas AQS Monitor ID:12-103-5003-42401-1

Year

Ranked 1-Hour Averages Ranked 3-Hour Averages Ranked 24-Hour Averages

Annual

Average

99th Percentile Values

Design

1 Value st 2nd 1st 2nd 1st 2nd Complete Days Valid

2008 85 (08/06) 50 (02/25) 36 (08/06:12) 19 (08/06:15) 7 (08/06) 6 (03/05) 1.2 37 37

2009 55 (05/10) 38 (08/24) 38 (05/10:15) 21 (01/23:15) 5 (05/10) 5 (12/29) 1.2 32 32

2010 72 (01/06) 55 (07/14) 39 (01/06:15) 29 (02/26:15) 6 (07/14) 5 (01/06) 1.1 34 34 34

The violating monitor (L0570109) near Gibsonton is located approximately 1 kilometer (km) to the 

southeast of the Mosaic Riverview phosphate fertilizer plant, a major source of SO2 emissions. The 

primary emissions units at this facility are three sulfuric acid plants. 

2. Emissions-Related Data

The following map provides the location of large (100 TPY or greater) SO2 emitting sources in the greater 

Tampa Bay area in relation to the monitors. A few other smaller sources are also included. 
The emissions represented are actual values in 2009. The facility with the greatest SO2 emissions is the 

Tampa Electric Company (TECO) Big Bend power plant. Emissions in 2009 were 8,988 tons. The Mosaic 

Riverview phosphate processing plant, located next to the violating monitor, emitted 2,992 tons.
Map 

ID Site Name SO2 2009 (tpy)

1 HARDEE POWER STATION 6

2 MIDULLA GENERATING STATION 38

3 CF INDUSTRIES-PLANT CITY PHOSP COMPLEX 3,086

4 MOSAIC FERTILIZER-RIVERVIEW FACILITY 2,992

5 BIG BEND STATION 8,988

6 H. L. CULBREATH BAYSIDE POWER STATION 18

7 ENVIROFOCUS TECHNOLOGIES, LLC 782

8 MCKAY BAY REFUSE-TO-ENERGY FACILITY 11

9 MANATEE POWER PLANT 5,997

10 BARTOW PLANT 1,831

11 HIGGINS PLANT 5

12 BAYBORO POWER PLANT 140

13

PINELLAS CO. RESOURCE RECOVERY 

FACILITY 145

14 CHARLES LARSEN MEMORIAL POWER PLANT 294

15 MOSAIC FERTILIZER - BARTOW FACILITY 3,711

16 MOSAIC FERTILIZER - GREEN BAY FACILITY 1,021

17 MOSAIC FERTILIZER - SOUTH PIERCE FACILIT 315

18 MOSAIC FERTILIZER - NEW WALES FACILITY 7,726

19 POLK POWER STATION 1,208

3. Meteorology

A review of the monitoring data in relation to the wind direction at the time of maximum concentrations

revealed that all occurrences of SO2 above the level of the standard (75 ppb) were associated with winds 

coming from the Mosaic Riverview facility. The following aerial photo shows the direction of the Mosaic 

Riverview facility from the SO2 monitor. The distance from the primary SO2 sources (three sulfuric acid 

plants) to the monitor is 1 kilometer, with the direction of the entire facility ranging from 295o to 350o

. 

The following tables list each of the hours in which a concentration was greater than the ambient SO2

standard (75 ppb) along with its associated wind direction. The wind direction data come from the wind 

instrument located at the monitoring site (wind data from the nearby Simmons Park monitoring site are

substituted when data at the Gibsonton site are missing). The tables show that for some hours of high 

SO2 concentration the wind appears to be coming from a direction of about 56o

. There are no SO2

sources from that direction, so the department reviewed the wind direction data for regional 

consistency. A review of these data shows that winds measured at other wind instruments in the area 

during these hours are consistent with a wind flow from the Mosaic Riverview facility. The wind 

direction data from the nearby Simmons Park site, located to the south of the Gibsonton monitor, are

shown as a truer representation of the winds during these hours. We have not identified the reason 

why the Gibsonton wind instrument displays this behavior; however, it appears to be confined to the 
period from November 19, 2009, through February 17, 2010. Both before and after this period, SO2

concentrations remain near zero when the winds are out of this direction.

SO2 Concentration and Associated Wind Direction (2008)

(for hours greater than 75 ppb)

Date Time SO2 (ppb) WD

Simmons 

WD*

20080101 14:00 96 - 347

20080101 15:00 189 - 345

20080101 16:00 122 - 344

20080101 17:00 94 - 342

20080101 18:00 100 - 342

20080101 19:00 142 - 340

20080101 20:00 170 - 344

20080101 21:00 115 - 351

20080102 12:00 76 - 350

20080102 14:00 80 - 345

20080120 0:00 76 310

20080227 15:00 86 297

20080308 22:00 103 303

20080324 15:00 75 302

20080324 16:00 85 304

20080324 17:00 90 306

20080324 19:00 123 307

20080324 20:00 129 300

20080413 5:00 123 297

20080414 18:00 104 294

20080414 19:00 84 295

20080414 20:00 102 295

20080429 19:00 77 293

20080812 18:00 99 317

20080905 7:00 169 306

20080905 8:00 128 306

20080905 10:00 113 294

20080914 16:00 76 308

20081027 21:00 82 308

*Substitute wind direction data from the Simmons Park (0570081) site.
SO2 Concentration and Associated Wind Direction (2009)

(for hours greater than 75 ppb) 

Date Time SO2 (ppb) WD

Simmons 

WD*

20090220 2:00 134 306

20090301 23:00 92 295

20090302 0:00 99 299

20090302 1:00 127 302

20090302 2:00 126 303

20090302 3:00 136 299

20090302 4:00 112 302

20090302 5:00 80 311

20090302 20:00 89 298

20090407 2:00 107 301

20090407 7:00 87 298

20090408 0:00 83 294

20090408 1:00 104 297

20090408 2:00 85 298

20090511 20:00 80 291

20091017 13:00 81 305

20091017 16:00 76 308

20091017 17:00 83 307

20091024 21:00 97 305

20091126 15:00 87 56 339

20091126 16:00 83 55 337

20091126 19:00 96 55 335

20091205 14:00 86 57 345

20091219 3:00 84 56 328

20091219 5:00 79 56 329

20091219 6:00 98 57 336

20091219 7:00 85 56 331

20091219 8:00 87 57 329

20091220 1:00 85 56 333

20091220 2:00 98 56 334

20091220 3:00 94 59 343

20091228 21:00 75 59 346

*Substitute wind direction data from the Simmons Park (0570081) site.
SO2 Concentration and Associated Wind Direction (2010)

(for hours greater than 75 ppb) 

Date Time SO2(ppb) WD

Simmons 

WD

20100105 11:00 85 57 350

20100106 11:00 76 57 347

20100131 1:00 87 55 343

20100212 20:00 78 54 342

20100212 21:00 104 53 343

20100216 4:00 104 54 346

20101015 14:00 76 313

20101105 15:00 79 307

20101201 4:00 89 309

20101201 9:00 111 309

20101201 10:00 76 315

20101201 11:00 93 308

20101201 12:00 86 306

20101226 20:00 117 302

20101226 21:00 107 307

20101227 0:00 95 312

20101227 1:00 113 305

20101227 2:00 100 308

20101227 3:00 119 306

20101227 4:00 95 303

20101227 5:00 75 308

*Substitute wind direction data from the Simmons Park (0570081) site.
4. Geography/Topography

There are no significant topographical features in the Gibsonton area. Elevation changes are minimal. 

The primary geographic feature is Tampa Bay, aside which the Mosaic Riverview facility is located. Wind 

variations can occur along the bay due to land/water temperature differences resulting in a 

juxtaposition of bay and gulf breezes in the afternoon. The wind data from both the monitoring site and 

the Tampa airport reflect this mesoscale wind flow. 

5. Jurisdictional Boundaries

The violating monitor is located within Hillsborough County, roughly in the center of the county. The 

violating area associated with the primary source of SO2 at this monitor is well within the county 

boundary. The recommended nonattainment boundary encompasses this violating area as informed by 

air dispersion modeling.

Air Dispersion Modeling

The department used air dispersion modeling to help delineate the boundary of the recommended 

nonattainment area. In completing this modeling, the department generally followed the guidance 
provided in the March 24, 2011, EPA memorandum, “Area Designations for the 2010 Revised Primary 

Sulfur Dioxide National Ambient Air Quality Standards.” 

a) Model Selection – The department used the AERMOD modeling system.

a. AERMOD ver11103

b. AERMAP ver11103

c. AERMET ver06341

d. AERSURFACE ver08009

b) Modeling Domain – The focus of the nonattainment designation is on the monitor having the 

violation. As noted above, wind data at the monitoring site indicate that all of the high 

concentrations (greater than the standard of 75 ppb) occur within a small wind direction sector 

that implicates the nearby Mosaic Riverview phosphate processing facility. Modeling of this 

source alone indicates that the predicated concentrations at the location of the monitor are 

almost completely explained by this single source. As a result, the modeling domain is centered 

on the Mosaic Riverview facility, which is located only 1000 meters from the monitoring 

location, and the domain extends to a 15 by 15 kilometer area around this facility. 

c) Determining the Sources to Model – Because the Mosaic Riverside facility is the overwhelming 

source of the violation, it is the only source that is modeled for the purpose of informing the 

extent of the nonattainment area. The department recognizes that other SO2 sources in the 

multi-county area could interact with the Mosaic facility for certain wind directions. However, 

for the purpose of simply determining the area of nonattainment encompassing the violating 

monitor, we believe it is sufficient to focus on the Mosaic Riverside facility. Other sources in the 

area will be evaluated individually and collectively through the infrastructure SIP modeling that 

will be completed in the next two years. 

d) Receptor Grid – The receptor grid follows the EPA guidance: a nested grid with 50 meter spacing 

within one kilometer of the source, 100 meter spacing from one to two kilometers, 250 meters 

from two to ten kilometers, and 500 kilometers outside of ten kilometers.

e) Source Inputs – Maximum allowable short-term limits on SO2 emissions or potential-to-emit 

levels were used for all sources. Stack and emission information were obtained from the 

department’s Air Resource Management System, Title V operating permits, and previous air 

construction permit applications. These data were reviewed by Mosaic, resulting in changes in 

refinement of the inputs related to geographic location of buildings and stacks. Where stack 

heights are less than GEP, building downwash effects are included. No stacks at this facility 

exceed GEP limits. The ground surface characteristic of the area is rural as determined through 

land-use data consistent with the guidance.

f) Meteorological Data – Five years (2005-2009) of meteorological data from the National Weather 

Service site at Tampa International Airport were used in this analysis. These data were 

processed through AERMET version 06341. The Tampa airport is located approximately 20 km 

from the Mosaic facility, also along Tampa Bay. These data are deemed representative of the 

area in which Mosaic Riverview is located.

g) Background Concentration – The background concentration at the Gibsonton monitor was 

determined based on the 99th percentile maximum daily 1-hour value on hours that were not 
impacted by the Mosaic Riverview facility. A 90-degree sector of wind directions centered on 

the Mosaic facility was excluded from the calculation to avoid double counting. The 99th

percentile of the remaining concentrations associated with winds not from the direction of the 

Mosaic facility was calculated for each year and averaged. Based on this calculation, the 

background concentration is 25.8 ppb.

Modeling Results

The AERMOD model results were used to determine the areal extent with which this facility would be 

potentially violating the standard. The recommended nonattainment area encompasses the receptors

having modeled violations of the ambient standard associated with the Mosaic Riverview facility. A 

review of the modeled impact at the location of the monitor provides an indication of the general 

performance of the model in describing the SO2 concentrations. The table below compares the model 

results with those at the monitor.

Year Modeled 

Maximum at 

Monitor Location 

(ppb)

Actual 1st High 

Maximum 1 hour 

value at Monitor 

(ppb)

Modeled 4th High 

at Monitor 

Location (ppb)

Actual 4th High 

(99th Percentile) 

at Monitor (ppb)

2005 163.0 151 133.5 135

2006 166.7 130 130.5 96

2007 163.3 143 137.6 126

2008 187.3 189 140.1 123

2009 153.7 136 130.1 104

These results indicate that the model is performing very well in replicating the SO2 concentration at the 

monitoring location, and that the Mosaic Riverview facility explains virtually all of the elevated 

concentrations that occur at this monitor. The design value concentrations in the area due to the 

Mosaic Riverview facility show that there are potentially higher concentrations in other locations. The 

maximum modeled design values associated with the Mosaic facility for 2005-2009 are as follows.

Year Date (MMDDHH) 4th High Concentration (ppb)

2005 010411 506.7

2006 031211 494.8

2007 120811 486.7

2008 090110 462.6

2009 022617 442.1

5-Year Average 478.5

It should be noted that the location of the design value concentration is on the Mosaic plant property.
Because the model performance is very good, the department has used the model results in an exacting 

manner to describe the recommended nonattainment boundaries. The nonattainment area is defined 

as the area where the model predicts that the SO2 concentration (using the five-year average of the 4th

high value as the metric) is greater than the ambient SO2 standard. A polygon with six vertices is used to 

define the areal extent of the nonattainment area. The following aerial photo below shows the bounds 

of the area having modeled concentrations greater than the ambient air quality standard. The 

annotated polygon (white line) outlines the area recommended for nonattainment classification. The 

red shaded area outlines the modeled area greater than the ambient standard. The whited-out area 

describes the property boundary of the Mosaic Riverview facility, with buildings and structures in blue.

Modeling input and output files will be provided on CD/DVD.

Hillsborough County Environmental Protection Commission Letter

Below is a letter received from the Hillsborough County Environmental Protection Commission (HCEPC) 

concurring with the department’s recommendation to limit the size of the SO2 nonattainment area to 

the immediate area of the Gibsonton monitoring site.
COMMISSION Roger P. Stewart Center 

Kevin Beckner - Chairman 3629 Queen Palm Dr. Tampa, FL 33619 

Lesley "Les" Miller - Vice Chairman Ph: (813) 627-2600 

Victor Crist 

Ken Hagan Fax Numbers (813); 

Admin 627·2620 Waste 627-2640 AI Higginbotham legal 627·2602 Wetlands 627-2630 Sandy Murman Water 627·2670 Air 627-2660 Mark Sharpe lab 635-8061 

Executive Director 

Richard D. Garrity, Ph.D. 

May 17,2011 

Mr. Mike Halpin, Director 

Division of Air Resource Management 

Florida Department of Environmental Protection 

2600 Blair Stone Road, MS#551 0 

Tallahassee, Florida 32399-2400 

Re: Recommendation for the S02 Designation and Nonattainment Area in Hillsborough 

County 

Dear Mr. Halpin, 

It is our understanding that the implementation of the recently revised primary national 

ambient air quality standard (NAAQS) for sulfur dioxide (S02) requires states to submit 

designation recommendations to the US EPA Administrator by June 3, 2011. Since one S02 

monitor in Hillsborough County is currently exceeding the revised air quality standard for S02, I 

offer the following comments and enclosed information in support of Secretary Vinyard's 

recommendation to the EPA. 

The Environmental Protection Commission of Hillsborough County (EPC) maintains and 

operates four (4) continuous air monitors to measure S02 and determine compliance with the 

S(h NAAQS. These four monitors were individually located to measure areas of maximum 

popUlation exposure, large sources of S02 emissions, or background concentrations on an urban 

scale. The violating monitor is East Bay (12-057-0109) located about 0.6 miles southeast of 

Mosaic's Riverview facility and its three (3) sulfuric acid manufacturing plants. The facility is a 

Title V source and is major for S02. For your convenience, I have enclosed an aerial photograph 

of the East Bay monitor and surrounding communities. The monitor was placed there in 1997 as 

a source-oriented special purpose monitor (SPM). Under previous ownership, the facility had 

been the subject of citizen complaints and EPC responded by setting up a morutor. 

For the past six years, East Bay has been the only S02 monitor with a design value above 

the new I-hr standard. Currently the design value for all other S02 monitors in the County are 

less than 65% of the standard, thus we believe that the population exposed to the unacceptable 

levels of S02 is limited to the area surrounding the East Bay site. Enclosed is a table showing all 

the southern Hillsborough County site design values for the new I-hour S02 standard applied 

retroactively. 

An agency with values of environmental stewardship, integrity, honesty, and a culture of fairness and cooperation. 

www.epchc.org 

E-Mail: epcinfo@epchc.org 
In addition, the historical record of the meteorological measurements and observed S02 

concentrations clearly indicate that fertilizer manufacturing facility is the single source 

contributing to the S02 violations at the monitoring site. S02 pollution roses were generated for 

the days in 2010 when the maximum 1-hr average concentration was above 75 ppb. They 

indicate the predominant wind direction was from the northwest ordinal quadrant at 5 to 10 mph. 

During these periods, the acid plants were operating in compliance, but were directly upwind of 

East Bay. As the wind speed and direction gradually shifted from these values, the levels 

returned to typical background. A pollution rose and meteorological data chart representative of 

a typical high value day are attached. 

As stated in the US EPA Memorandum, "Area Designations for the 2010 Revised 

Primary Sulfur Dioxide National Ambient Air Quality Standards", dated March 24, 2011, direct 

emissions of sulfur dioxide will result in the highest concentrations close to the source. When 

combined with a short I-hour averaging time for comparison to the standard, it is expected that 

concentrations will diminish significantly with time and distance. In light of the fact that none of 

our other S02 monitors are recording ambient levels near the NAAQS, and the current East Bay 

monitor is only impacted during certain localized metrological conditions, we recommend a 

limited non-attainment boundary of 1.5 km. 

Be advised as time and resources warrant, EPC will look into doing some additional S02 

monitoring in the Riverview area with our mobile monitoring equipment. Any data collected 

prior to the EPA having to make a final determination in June of 2012, will be shared with the 

State. We feel this will be helpful in setting any non-attainment boundary whether it be 1.5 km 

or otherwise. 

Limiting the non-attainment area will allow the State to minimize any unnecessary or 

unintended economic impact to other facilities and at the same time to work expediently to assist 

the surrounding community. We will continue to work closely with Mosaic and the State to 

address this issue. The facility has been cooperative and appears committed to remedying the 

situation. 

Thank you for your consideration. If you need any additional information, please let me 

know. 

J:Jerry Campbell, c~ P.E. 

Air Management Division Director 

cc: Stephen R. David, Mosaic Fertilizer, LLC 

Larry George, Administrator, FDEP OPAPM 

Encs. 
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HIl..I.SIIOROUGH OOLWTY ~ DIOXlDE (PPB) 

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1 .... High Design 1 .......... Design 1Hr .... DI!sip 1 ......... ~ 1 ... "" IlesiiIPI 1 JlrHigh DesigII 

1!JI& Z3I - 291 - 370 - ~ 171 - 240 - 650 - 1Wi 190 DD 30D 2IDi 320 2M 

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1!111 37 1M 216 

- 258 Di 

HM 224 JJII 252 'Ill .325 81 

l!8D 2.1.2 I7l 375 JII5 n5 m 

1!111 ~95 155 282 

- 1& 157 

H!:Z 224 l!II 345 - 327 21& 109 

- 211 - H93 119 155 199 - 2IiG 2B 132 15 Z2& - uti 320 UIi 255 21M ll2 2U 203 UJ 236 IR 

1!B5 310 

- 2.10 ue 327 

- 286 -II 7Z1 DI 

~ 171 

- 11& J55 81 

- 323 

19J1 209 UZ 151 1M 167 - 203 J:. 219 

~ 2U5 IB 120 m J.a& - 2M 

-

- 278 US 

ut!I 153 DD 195 lB 277 l45 210 Ja 176 UZ 

2IDI 11& 111 21J .. 144 UI 3Q5 JI5 

2IDl 130 ., 313 UI 203 IB 250 115 

2m2 192 

- 172 ., 164 B1 1-" JB 

21m 101 

- 135 • 167 ... 131 .. 

211M 79 !3 76 at IB7 SI 31 • 

2IID5 91 14 92 68 151 IB 98 70 

2IJII5 161 n 143 e 130 IU 40 44 

"., 124 11 13 47 143 IU 39 44 

~ 71 62 35 :17 1119 US 

21M 39 !!iO 24 29 136 ua 

2IDJI 67 ~ 32 23 119 U8 

5/5/2011 
Site: C7 EAST BAY SITE 2 

Paramei8r: 02 S02 

Unite: PPB 

02502 

• <35 

• <55 

• <75 

< 100 

< 150 

• <200 

. <500 

,. 500 

Period: 121112010-121112010 

N 

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East Bay Monitor 

December 1, 2010 

400 12 

350 

10 

300 

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,

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100 \ . L A Jl 

J"?\ \ V\ 2 50 

o I ••• r;= --;--'-'. i •.• , •.• ,. l o 

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 

Hours 
Appendix 3

Sulfur Dioxide (SO2) Unclassifiable Area Justification for the Ellyson Monitoring Site (Escambia County)

Recommendation

For the reasons outlined in this appendix, the department’s recommendation that most of the state, as 

a whole, be designated “unclassifiable” or “unclassifiable/attainment” for the 75 parts per billion (ppb) 

1-hour SO2 standard is intended to include the area surrounding the Ellyson monitoring site in Escambia 

County. While the most recent data for 2008-2010 show a violation, the SO2 emissions source (Gulf 

Power Crist power plant) having the overwhelming influence at the monitor added a flue gas 

desulfurization (FGD) system in December 2009. The result, as seen in the charts below, indicate that 

this monitor will show compliance with the standard at the end of the 2009-2011 three-year period. 

The design value should continue to decrease the following year when the higher concentration data 

(pre-scrubber) in 2009 are dropped from the average.

Air Quality Data

The table below shows the recent history of SO2 concentrations at the Ellyson monitor. The strip charts, 

also below, pictorially show the change in SO2 measurements before and after the scrubber at Crist.

Site:A0330004 - Ellyson Industrial Park County:Escambia AQS Monitor ID:12-033-0004-42401-1

Year

Ranked 1-Hour Averages Ranked 3-Hour Averages Ranked 24-Hour Averages

Annual

Average

99th Percentile Values

Design

1 Value st 2nd 1st 2nd 1st 2nd Complete Days Valid

2000 159 (11/11) 147 (08/04) 93 (12/31:12) 76 (06/23:09) 23 (01/24) 21 (06/23) 3.6 140 140

2001 172 (05/12) 152 (09/20) 76 (01/08:06) 76 (05/12:06) 24 (01/08) 21 (03/07) 3.1 100 100

2002 200 (06/02) 91 (02/08) 82 (06/02:06) 80 (02/08:12) 20 (02/08) 19 (11/12) 3.0 84 84 108†

2003 113 (01/07) 102 (12/11) 106 (01/07:12) 76 (01/23:00) 20 (01/23) 18 (01/07) 2.6 76 76 87†

2004 128 (08/15) 95 (05/06) 65 (12/26:12) 62 (09/06:15) 27 (12/26) 17 (08/15) 2.3 85 85 82†

2005 92 (10/08) 83 (08/09) 71 (01/01:09) 68 (10/08:09) 40 (01/01) 18 (10/08) 2.5 69 69 77†

2006 103 (03/24) 85 (11/22) 76 (03/24:00) 68 (11/22:09) 26 (03/24) 24 (11/22) 2.4 79 79 78†

2007 129 (05/12) 85 (11/03) 78 (05/12:09) 63 (06/20:12) 25 (06/20) 16 (11/03) 2.7 81 81 76†

2008 148 (11/17) 133 (12/12) 92 (12/12:09) 77 (11/17:09) 24 (12/12) 22 (10/01) 2.8 119 119 93†

2009 137 (08/31) 85 (08/12) 72 (08/31:12) 68 (08/12:09) 18 (03/02) 14 (04/15) 2.5 74 74 91†

2010 106 (12/14) 56 (04/09) 62 (12/14:12) 45 (01/10:12) 13 (01/10) 12 (12/13) 1.9 45 45 79†

2011 68 (05/06) 22 (05/07) 30 (05/06:06) 25 (05/06:09) 9 (05/06) 3 (01/15) 1.5* 22* 22* 47*
0

25

50

75

100

125

150

175

1

10192837465564738291

100109118127136145154163172181190199208217226235244253262271280289298307316325334343352361

2008

0

25

50

75

100

125

150

175

1

10192837465564738291

100109118127136145154163172181190199208217226235244253262271280289298307316325334343352361

2009

0

25

50

75

100

125

150

175

1

1019283746

5564738291

100109118127136145154163172181190199208217226235244253262271280289298307316325334343352361

2010

0

25

50

75

100

125

150

175

1

112131415161718191

101111121

2011

Maximum Daily 1-hour Average SO2 Concentrations in ppb (2008-2011)
As seen in the table, the 99th percentile maximum daily value for 2010, the first full year of scrubber 

operation, is 45 ppb. There is every expectation that this metric will be well below the level of the 

standard for future years. Indeed, the partial year 2011 shows a greatly reduced value. 

Gulf Power Crist is the Overwhelming Contributor to the Ellyson Monitor

Wind data collected at the Ellyson monitoring site indicate that all hours with high SO2 concentration 

(i.e., greater than 75 ppb) occur with the winds coming from the Gulf Power Crist power plant. The 

following picture shows the location of the Ellyson monitor in relation to the Crist power plant.
The following tables show the wind direction during times of high SO2 for the years 2008 to 2010.

Date Time SO2(ppb) WD

20080114 12:00 76 344

20080223 11:00 85 342

20080223 12:00 127 350

20080305 10:00 92 320

20080429 8:00 113 347

20080429 9:00 118 335

20080624 10:00 119 334

20080806 7:00 94 328

20080823 8:00 102 335

20080823 9:00 85 336

20080823 10:00 103 324

20080917 9:00 89 329

20081001 6:00 83 330

20081026 10:00 105 330

20081117 9:00 148 346

20081212 10:00 122 332

20081212 11:00 133 344

Date Time SO2(ppb) WD

Substiute 

Data

20090812 9:00 85 350 ASOS

20090812 11:00 84 286 ASOS

20090831 12:00 137 322 ASOS

Date Time SO2(ppb) WD

20101214 12:00 106 345

The implication of these data is that the Gulf Power Crist power plant is clearly the overwhelming 

contributor to the historic high SO2 concentrations at the Ellyson monitor. It is also clear from the data 

that the initiation of scrubber operation in December 2009 at the Crist facility has had a marked effect 

on the SO2 concentration data at the Ellyson monitor. It is expected that this monitor will begin having 

compliant data with the three-year period ending in 2011.