1 Attachment 

Hi Greg,

Thank you for catching the discrepancy in the nonpoint source category. We went back and rechecked our numbers and we found an error in the residual fuel oil 

combustion calculations. We corrected it and revised the AirSHED Summary 2005, 2008, 2018 table below as well as the numbers in the attached document. 

However, there is still a large difference between the 2005 AirSHED numbers and the 2005 NEI for this category. 

2005 Nonpoint SO2 (without wind dust and wildfire)

NEI AirSHED (revised) AirSHED (original) 

468 TPY 3,716 TPY 3,449 TPY

2008 Nonpoint SO2 (without wind dust and wildfire)

NEI AirSHED (revised) AirSHED (original)

3,512 TPY 1,576 TPY 3,498 TPY

NEI Data:

The 2005 NEI nonpoint SO2 number of 468 TPY was carried over from the 2002 NEI. That is, the 2005 NEI nonpoint SO2 was set equal to the 2002 number of 

468 TPY (not calculated based on 2005 data). The 2008 NEI numbers were based on Hawaii (AirSHED) data and supplemented with EPA data for any missing 

categories (so this 2008 NEI data would need to be updated with Hawaii’s revised data).

AirSHED Data:

The reason for the fluctuation in the AirSHED nonpoint SO2 data from 2005 to 2008 is due to the change in residual fuel oil consumption for Hawaii (obtained 

from the U.S. Energy Information Administration (EIA)). At the time the emissions were determined, the 2005 and 2008 data were not available and thus the 

emissions were projected based on the 2004 data and growth factors. With this revision, we also revised the 2005 and 2008 calculations for the nonpoint residual 

oil combustion, using actual 2005 and 2008 data (both EIA data and point source data which was subtracted to prevent double counting). The 2005 EIA residual 

oil consumption for Hawaii dropped significantly from the year 2005 to 2008 (781 E3BBL vs. 448 E3BBL), thus resulting in lower emissions in 2008. The 

decrease in SO2 emissions are the most pronounced as it has a much higher residual oil combustion emission factor than the other pollutants.

Nonpoint Residual fuel oil combustion 

2005 SO2 emissions: 2,839 TPY 2005 EIA Residual oil consumption minus point consumption: 431 E3BBL

2008 SO2 emissions: 657 TPY 2005 EIA Residual oil consumption minus point consumption: 100 E3BBL

Should you need any further information on this, feel free to contact me via email or phone (808) 586-4200.

Thank you, 

Marianne Rossio

RE: follow-up on EI analysis 

Rossio, Marianne Fuji 

to: 

Ligh, Priscilla W K, Gregory Nudd 

11/18/2011 04:18 PM 

Cc: 

Carol Bohnenkamp, "McFall, Keith", "Takamoto, Scott", Thomas Webb 

Hide Details 

From: "Rossio, Marianne Fuji" <marianne.rossio@doh.hawaii.gov>

To: "Ligh, Priscilla W K" <priscilla.ligh@doh.hawaii.gov>, Gregory Nudd/R9/USEPA/US@EPA 

Cc: Carol Bohnenkamp/R9/USEPA/US@EPA, "McFall, Keith" <Keith.McFall@doh.hawaii.gov>, "Takamoto, Scott" 

<scott.takamoto@doh.hawaii.gov>, Thomas Webb/R9/USEPA/US@EPA 

History: This message has been replied to and forwarded. 

RevA Emissions inventory response to EPA 11-17-11 for EPA.doc

AirSHED Summary (Old) AirSHED Summary

2005, 2008, 2018 2005, 2008, 2018

As of September 23,2011

As of November 

17,2011

Carbon Monoxide Carbon Monoxide

Non-Point Biogenic Non-road On-road Point

NonPoint Biogenic Non-road On-road Point

2005 108,482 22,118 101,750 176,450 7,831 2005 108,487 22,118 101,750 176,450 7,831

2008 108,520 22,118 88,505 109,721 8,579 2008 108,490 22,118 88,505 109,721 8,579

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Note for above tables: 

From: Ligh, Priscilla W K 

Sent: Monday, November 14, 2011 5:00 PM 

To: Nudd.Gregory@epamail.epa.gov

Cc: Bohnenkamp.Carol@epamail.epa.gov; McFall, Keith; Rossio, Marianne Fuji; Takamoto, Scott; Webb.Thomas@epamail.epa.gov

Subject: RE: follow-up on EI analysis

 

Hi Greg,

I got back with Marianne and Scott today and it seems you identified a discrepancy where we need to adjust the AirSHED inventory. The NonPoint numbers in AirSHED are 

higher than the NEI due to some double counting. Marianne and Scott will go ahead and make the adjustments and send you the updated numbers, hopefully tomorrow or 

Wednesday. The NEI 2008 numbers ultimately matched the 2008 numbers because the NEI used Hawaii’s numbers.

A very good catch on your part. In addressing the emission inventory, both Marianne and Scott are good resources depending on the source category or specific subject matter. 

Maybe if you start with Marianne, she can patch in Scott if required, since the discussions may affect both their area of coverage.

Thanks so much, Priscilla

Priscilla Ligh

Clean Air Branch

Hawaii Department of Health

(808) 586-4200

priscilla.ligh@doh.hawaii.gov

From: Nudd.Gregory@epamail.epa.gov [mailto:Nudd.Gregory@epamail.epa.gov] 

Sent: Thursday, November 10, 2011 9:19 AM 

To: Ligh, Priscilla W K 

Cc: Bohnenkamp.Carol@epamail.epa.gov; McFall, Keith; Rossio, Marianne Fuji; Takamoto, Scott; Webb.Thomas@epamail.epa.gov

Subject: follow-up on EI analysis

 

Priscilla: 

Do to other priorities, I'm just now taking a deeper look at this information. I've got one (hopefully) easy question and one request for follow-up: 

(1) In the AirSHED to NEI comparison for 2005, the AirSHED number for NonPoint SO2 (3,449 tpy) is MUCH higher than the NEI number (468 tpy). 

This discrepancy mostly disappears in the 2008 comparison. Is this just a typo? 

(2) The numbers for SO2 that you are quoting for ships underway (commercial shipping) in 2005 are very high. But, there's a lot about that section that I don't understand. 

Who is the best person at Hawaii DOH for me to discuss this issue with? 

Thanks in advance, 

Greg 

From: "Ligh, Priscilla W K" <priscilla.ligh@doh.hawaii.gov> 

To: Gregory Nudd/R9/USEPA/US@EPA 

Cc: Carol Bohnenkamp/R9/USEPA/US@EPA, Thomas Webb/R9/USEPA/US@EPA, "McFall, Keith" <Keith.McFall@doh.hawaii.gov>, "Rossio, Marianne Fuji" <marianne.rossio@doh.hawaii.gov>, "Scott Takamoto" 

<scott.takamoto@doh.hawaii.gov> 

Date: 09/23/2011 06:32 PM 

Subject: RE: Regional Haze questions 

2018 108,628 22,118 98,908 112,085 18,257 2018 108,633 22,118 98,908 112,085 18,257

Nitrogen Oxides Nitrogen Oxides

Non-Point Biogenic Non-road On-road Point

NonPoint Biogenic Non-road On-road Point

2005 3,619 4,617 11,921 15,907 22,745 2005 3,665 4,617 11,921 15,907 22,745

2008 3,658 4,617 11,744 12,192 20,246 2008 3,322 4,617 11,744 12,192 20,246

2018 3,829 4,617 13,218 6,800 28,594 2018 3,879 4,617 13,218 6,800 28,594

PM10 PM10

Non-Point Biogenic Non-road On-road Point

NonPoint Biogenic Non-road On-road Point

2005 89,970 382,637 1,047 412 3,536 2005 89,987 382,637 1,047 412 3,536

2008 91,621 382,637 985 364 3,389 2008 91,497 382,637 985 364 3,389

2018 100,067 421,222 1,097 397 5,052 2018 100,085 421,222 1,097 397 5,052

Sulfur Dioxide Sulfur Dioxide

Non-Point Biogenic Non-road On-road Point

NonPoint Biogenic Non-road On-road Point

2005 4,040 961,366 4,291 349 27,072 2005 4,307 961,366 4,291 349 27,072

2008 4,089 1,195,314 3,835 106 25,849 2008 2,167 1,195,314 3,835 106 25,849

2018 3,831 683,746 6,283 129 36,212 2018 4,115 683,746 6,283 129 36,212

Volatile Organic Compound Volatile Organic Compound

Non-Point Biogenic Non-road On-road Point

NonPoint Biogenic Non-road On-road Point

2005 21,649 130,153 6,593 17,486 2,695 2005 21,649 130,153 6,593 17,486 2,695

2008 22,756 130,153 5,384 12,326 2,544 2008 22,754 130,153 5,384 12,326 2,544

2018 24,783 130,153 5,347 8,827 4,157 2018 24,783 130,153 5,347 8,827 4,157

Changes are shown in pink.

Non-Point Sources: area source emissions, including fire (wildfire, ag burn, structural) and 

 dust (ag tilling, road dust, and construction) emissions 

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Hi Greg, 

 

Following up with an update on Hawaii’s Emissions Inventory. Marianne Rossio and Scott Takamoto provided an assessment of the AirSHED database as well as the NEI 

database concerning Hawaii’s emissions (see attached for details: Hawaii EI AirSHED vs NEI.doc). The comparison shows: 

1) If no changes are made to the databases, which database numbers (AirSHED or NEI) may be better to use. 

2) If updates are being planned, suggested changes to consider. 

 

Overall, if no changes are made, AirSHED numbers are expected to be better since the estimates take into account Hawaii’s local information. Calendar year 2018 will require 

rework in any case to include updates. 

 

The NEI revised their definition of source categories between calendar years 2005 to 2008 (e.g, fire/dust from nonpoint to event; aircraft from non-road to point; and commercial 

marine/locomotives from non-road to nonpoint), as well as the models used for estimating emissions (e.g, nonroad 2005 to nonroad 2008, and introduction of MOVES). 

Therefore, between years, the NEI numbers may not be ideal for comparison. 

 

For your information, the numbers on AirSHED for 2005, 2008, and 2018 are shown below (performed consistently between years). Economic impacts were not considered for 

2008, unless actual activity data was used in the calculations. Updates for ECA, and the use of MOVES are not accounted for in AirSHED. 

 

AirSHED Summary

 

 

We would be very interested if a contract is taken out to update the emissions inventory. We can further discuss, but in the meantime, if you have questions on AirSHED please 

2005, 2008, 2018 

 As of September 23,2011 

Carbon Monoxide 

 Non-Point Biogenic Non-road On-road Point 

2005 108,482 22,118 101,750 176,450 7,831 

2008 108,520 22,118 88,505 109,721 8,579 For 2008 CMV and Aircraft used 2005 #s 

2018 108,628 22,118 98,908 112,085 18,257 

Nitrogen Oxides 

 Non-Point Biogenic Non-road On-road Point 

2005 3,619 4,617 11,921 15,907 22,745 

2008 3,658 4,617 11,744 12,192 20,246 

2018 3,829 4,617 13,218 6,800 28,594 

PM10 

 Non-Point Biogenic Non-road On-road Point 

2005 89,970 382,637 1,047 412 3,536 

2008 91,621 382,637 985 364 3,389 

2018 100,067 421,222 1,097 397 5,052 

Sulfur Dioxide 

 Non-Point Biogenic Non-road On-road Point 

2005 4,040 961,366 4,291 349 27,072 

2008 4,089 1,195,314 3,835 106 25,849 

2018 3,831 683,746 6,283 129 36,212 

Volatile Organic Compound 

 Non-Point Biogenic Non-road On-road Point 

2005 21,649 130,153 6,593 17,486 2,695 

2008 22,756 130,153 5,384 12,326 2,544 

2018 24,783 130,153 5,347 8,827 4,157 

 

Non-Point Sources: area source emissions, including fire (wildfire, ag burn, structural) and 

 dust (ag tilling, road dust, and construction) emissions 

Non-Road Sources: nonroad model results plus airport, commercial marine (£ 30 nm), and locomotive emissions 

 2005: used Nonroad 2005 NEI used NMIN (includes Nonroad 2005) 

 2008: used Nonroad 2005 NEI used NMIN (includes Nonroad 2008) 

 consider: rerunning with Nonroad 2008 w/ Hawaii's data 

 moving aircraft emissions to Point 

 moving commercial marine & locomotive emissions to Non-Point 

On-road Sources: 2005: used Mobile 6.2 NEI used NMIN (includes MOBILE6.2) 

 2008: used Mobile 6.2 NEI used NMIN (includes MOBILE6.2) 

 consider: rerunning with MOVES w/ Hawaii's data 

Point Sources: only includes large stationary sources 

 

2018 revisit inventory for updates 

Biogenic consider rerunning GLOBEIS if better met data available, volcano estimate good, except for 2018 

 

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feel free to contact Marianne or Scott at the same number below, or email. 

 

Thanks, and hope all is well....Priscilla 

 

FYI. Also attached AirSHED emissions breakdown by county for 2005 and 2008. 

 

Priscilla Ligh 

Clean Air Branch 

Hawaii Department of Health 

(808) 586-4200 

 

priscilla.ligh@doh.hawaii.gov 

 

From: Nudd.Gregory@epamail.epa.gov [mailto:Nudd.Gregory@epamail.epa.gov] 

Sent: Wednesday, August 24, 2011 5:43 AM

To: McFall, Keith

Cc: Bohnenkamp.Carol@epamail.epa.gov; Ligh, Priscilla W K; Webb.Thomas@epamail.epa.gov

Subject: RE: Regional Haze questions 

 

Hi Keith, 

 

Thanks for the quick response. Some clarifying note: 

 

Analysis of fire data: Wasn't Maui where we say significant fire signature in the monitoring data? If you've got that analysis complete, I'd like to see it. 

 

EI updates: I was planning to have a contractor do that. I just wanted to get your feedback on the idea. We may also need some info on how to get it into 

your EI data management system. 

 

If you can only get one thing done for me this week, that write-up on how the reasonable progress sources were identified would be the most helpful. 

 

Thanks! 

 

Greg 

-----"McFall, Keith" <Keith.McFall@doh.hawaii.gov> wrote: ----- 

To: Gregory Nudd/R9/USEPA/US@EPA 

From: "McFall, Keith" <Keith.McFall@doh.hawaii.gov>

Date: 08/23/2011 07:44PM 

Cc: Thomas Webb/R9/USEPA/US@EPA, Carol Bohnenkamp/R9/USEPA/US@EPA, "Ligh, Priscilla W K" <priscilla.ligh@doh.hawaii.gov>

Subject: RE: Regional Haze questions 

Hi Greg, 

 

Thank you for your email. I will get you a better update by the end of the week, but I wanted to get back to you today to let you know I passed this along to Priscilla and that we are working on 

it. 

 

1) * Did you complete your analysis of the contributions of anthropogenic fires to visibility impairment? If so, could you send me a copy of that. I haven't seen it yet. Are there any 

practices in place in Hawaii to limit fires in order to protect visibility at Class I areas?

 

So far, I have only examined the Maui fire data. I still need to acquire and examine the Hawaii data and review the states fire protection plans. I expect 

that will take a few weeks. 

2) * Tom said that you had researched BART sources in other states that are similar to the one in Hawaii (oil-fired, base load, EGUs). To your knowledge have any BART 

determinations been proposed for those sources?

 

There are a handful of oil fired units that I thought were comparable. I will compile my list and try to get that out by the end of this week (I am on vacation next week). 

 

3) * I'm trying to figure out how the reasonable progress sources were identified. Do you have a document that walks through and explains that process?

 

We expect to have this for you by the end of this week. 

 

4) * What's your opinion on how the 2018 visibility goals should be set? 

 

I need to review the glidepath calculations and will coordinate a response. This may take a few weeks. 

5) * It seems to me that it would be helpful to update the emissions inventory that Environ prepared in a few areas, please let me know what you think:

 1. Update 2008 and 2018 projections since they do not reflect the impact of the economic recession and subsequent slow growth 2008-2011.

 2. Update the 2018 shipping emissions projections to account for the Emissions Control Area (ECA) requirements.

 3. Update the 2005, 2008 and 2018 mobile source inventories to use the MOVES emissions model rather than Mobile (not required for this FIP, but a good idea as NOx will 

be going up and you'll want an apples-to-apples comparison)

 

I will have to get back to you with a time estimate. 

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6) * What other outstanding issues do you think are out there? (Aside from what was addressed in our recent letter to HECO.)

 

I will think on this and get back to you by the end of the week. 

 

I think a phone discussion is a good idea. Since I need to spin back up on some of these items, I think it would probably be most productive to have it after I get 

back from vacation. 

 

Thank you, 

 

Keith 

 

From: Nudd.Gregory@epamail.epa.gov [mailto:Nudd.Gregory@epamail.epa.gov] 

Sent: Tuesday, August 23, 2011 12:04 PM

To: McFall, Keith

Cc: Webb.Thomas@epamail.epa.gov; Bohnenkamp.Carol@epamail.epa.gov

Subject: Regional Haze questions 

 

Keith, 

I've been assigned to be the technical lead for the Hawaii Regional Haze FIP. I'll be working with Tom Webb and Carol Bohnenkamp on this effort. I've reviewed quite a bit of 

material that you and others have produced on this effort. I've got a few questions for you, in no particular order: 

* Did you complete your analysis of the contributions of anthropogenic fires to visibility impairment? If so, could you send me a copy of that. I haven't seen it yet. Are there any 

practices in place in Hawaii to limit fires in order to protect visibility at Class I areas? 

* Tom said that you had researched BART sources in other states that are similar to the one in Hawaii (oil-fired, base load, EGUs). To your knowledge have any BART 

determinations been proposed for those sources? 

* I'm trying to figure out how the reasonable progress sources were identified. Do you have a document that walks through and explains that process? 

* What's your opinion on how the 2018 visibility goals should be set? 

* It seems to me that it would be helpful to update the emissions inventory that Environ prepared in a few areas, please let me know what you think:

 1. Update 2008 and 2018 projections since they do not reflect the impact of the economic recession and subsequent slow growth 2008-2011.

 2. Update the 2018 shipping emissions projections to account for the Emissions Control Area (ECA) requirements.

 3. Update the 2005, 2008 and 2018 mobile source inventories to use the MOVES emissions model rather than Mobile (not required for this FIP, but a good idea as NOx will 

be going up and you'll want an apples-to-apples comparison) 

* What other outstanding issues do you think are out there? (Aside from what was addressed in our recent letter to HECO.) 

I've been impressed with the work you've done so far on this and I look forward to working with you on developing the proposed FIP. Feel free to call if you think that would be 

more efficient than exchanging emails. 

Greg Nudd

USEPA Region 9 

Air Planning Office

415-947-4107

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