1 TSRIA Document 3: Upwind Sources Other Than PPL Do Not Significantly Influence High Coburn Road Ambient Concentrations (Supplements Charts 4a and 4b from Fe bruary 27, 2014, TSRIA Presentation)

Chart 4c: Emissions from all upwind sources: Coburn 2010 produces an exceptional number of high outlier readings.

This chart is similar to Chart 4a from the TSRIA presentation of February 27, 2014,
except:

 Results are limited to a southwest (SW) wind direction (wind di rection of 210 to 250 degrees)

 Emission rate = PPL + Western Sugar + Phillips 66 + CHS, when PPL is operating

 The green line represents an updated visual outlier boundary for ambient readings. The updated outlier line pr ovides a better fit for the data distribution of all upwind sources th an the yellow line from Chart 4a, separating those ambient readings th at have no nearby readings without QA problems (the blue diamonds).2 Chart 4d: Emissions from all upwi nd sources with 2010 removed. Removing Coburn 2010 greatly reduces outlier readings.

This chart is similar to Chart 4b from the TSRIA presentation of February 27, 2014,
except:

 Results are limited to a SW wind direct ion (wind direction of 210 to 250 degrees)

 Emission rate = PPL + Western Sugar + Phillips 66 + CHS, when PPL is operating

 The same green line as Chart 4c represents an updated visual outlier
boundary for ambient readings. The upda ted outlier line provides a better

fit for the data distribution than the yellow line from Chart 4b.

Updated Chart 4c and 4d Comments:

It has been previously noted that all elevated readings at Coburn Road, relative to the standard, are associated with winds from the southwest, and that all such readings are also associated with periods of PPL-Cor ette operation (see TSD at 13-14). This3 granular analysis, therefor e, focuses on those conditions. The measured hourly emissions rates from major facilities genera lly upwind from the Co burn Road monitor were summed and compared to the recorded SO 2 concentrations at the Coburn Road monitor during periods when the wind was from this southwest direction. The prevailing

wind direction at the Coburn Ro ad monitor is also from the west-southwest; therefore, thousands of points were evaluat ed. Facilities located in th is upwind direction include the PPL–Corette, Western Sugar, Phillips 66, and the much more distant Cenex Harvest States (CHS) facilities. The purpose of this evaluation was to determine if emissions from any major sources in addition to the PPL-Corette facility could rationally explain higher readings re corded at Coburn Road.

The analysis found no significant differenc e between Coburn Road readings as a function of total upwind source s’ emissions by hour, versus as a function of emissions from PPL alone. (See Chart 4a from t he February 27, 2014 TSRIA Presentation for PPL- alone analysis.) The present analysis al so found no cases where summed upwind hourly emissions explained high readings observed during periods of lower PPL emissions, nor did we find cases where su mmed hourly emissions explained suspect / outlier readings that were al most always associated with QA failures in 2010 or other years (see Chart 5 from t he February 27, 2014 TSRIA Presentation). The data
associated with QA-failures are identifie d by date on the charts. This analysis

demonstrates that the non-PPL upwind emission sources did not have a significant influence on, and do not explain, the high r eadings recorded at Coburn Road during the 2009 – 2013 observation period.

As discussed elsewhere, plume-rise variations also do not correlate with or explain the elevated readings. The weight of evidence suggests that the el evated readings are suspect, and that the readings ar e best explained as inaccurate due to their QA-failures.