Ll N DA Ll NGLE 

GOVERNOR 

EXECUTIVE CHAMBERS 

HONOLULU 

November 15,20 10 

Mr. Jared Blumenfeld 

Regional Administrator 

U.S. EPA, Region iX 

75 Hawthorne Street 

SUBJECT: ~ecom~ded Designation for the Newly Promulgated 1-Hour Federal Nitrogen 

Dioxide (NO?) National Ambient Air Quality Standard (NAAQS) 

Pursuant to Section 107(d)(l) of the Clean Air Act, I am recommending that tlie City and County of 

Ho~iolulu (island of Oahu) be designated in attainment of thel-hour NO2 NAAQS, and all other counties in 

tlie state be designated as unclassifiable. The Department of Health (DOH), which manages the ambient air 

monitoring network, has determined that the quality-assured NO2 data for the calendar years 2007 through 

2009 is in attainment with the new federal NO2 standard. 

The state has two air monitoring stations located in the City and County of Honolulu using Federal 

Reference Method saliiplers for the collection of NO2 data. Attachment I contains data summaries from these 

stations for the 3-year 1-hour standard design value. The Kapolei station was shut down in April 2008 for 

needed station repairs and therefore has an incomplete 1 -hour NO2 design value for the year 2008. However, 

Kapolei was determined to be in attainment of the 1 -hour NO2 NAAQS when the 3-year design value was 

calculated using the data substitution method in accordance with 40 CFR Part 50, Appendix S. 

Additionally, tlie DOH will comply with the requirements of 40 CFR Part 58, Appendix D, and 

establish one near-road NO2 monitoring station by January 1, 20 13. 

Based on contilluous compliance with all criteria pollutant NAAQS and ongoing monitoring of air 

pollution sources, the DOH has determined that there are no anticipated changes or activities that would cause 

a significant variation from the currently measured NO2 values. We therefore ask for EPA's consideration of 

our recommendation for attainment of the NO2 standards for the City and County of Honolulu. 

We look forward to working with EPA Region IX on the final NO2 designation. If you have any 

questions, please contact Mr. Wilfred Nagamine at tlie DOH, Clean Air Branch, at (808) 586-4200. 

Attachment 

U 

Sincerely, 

&- 

LINDA LING LJ E 

c: Deborah Jordan, Director, Air Division (AIR-I), U.S. EPA, Region IX 

Gwen M. Yoshimura, Air Quality Analysis Office (AIR-7), U.S. EPA, Region IX 
State of Hawaii 

Appendix I: Attainment of the NO2 NAAQS 

ATTACHMENT I 

State of Hawaii 

Attainment Recommendation of the I-Hour Nitrogen Dioxide (NO2) National 

Ambient Air Quality Standard (NAAQS) 

I. Introduction 

The EPA s~~pplemented the existing primary health-based annual standard with a 

new ?-hour NO2 standard effective January 22, 2010. 

Pursuant to the Clean Air Act 107jd) (I j,states are required to make attainment, 

nonattainment or unclassifiable recommendations one year after promulgation of a 

new standard. 

The state's two NO2 mor~itors are located in the City and County of Honolulu, which 

encorrlpasses the island of Oahu. Currently, there is no NO2 monitoring in the 

counties of Kauai (islands of Kauai and Niihau), Maui (islands of Maui, Molokai, and 

Lanai), Kalawao (Kalaupapa settlement) or Hawaii (island of Hawaii). 

This document provides NO2 data collected at the Kapolei and West Beach air 

monitoring stations supporting attainment of the new I-hour NO2 standard for the 

City and County of Honolulu. 

II. Attainment of the I-Hour NO:, NAAQS 

A. NO2 Air Monitoring Sta,tions and Sarrlpling Method 

B. Data Computation 

Table 1. Summary of NO2 Sampling in the State of Hawaii 

All data handling conventions and corrlputations were according to 40 CFR 50 

Appendix S: Interpretation of the Primary National Ambient Air Quality Standards 

for Oxides of Nitrogen (Nitrogen Dioxide). 

Station 

Kapolei 

West Beach 

Quality assured and certified NO2 data collected in the most recent three years 

(2007 to 2009) were used to determine attainment of the NO2 standards. 

In April 2008, the Kapolei station was shut-down for necessary repairs and 

maintenance. As a result, the second quarter of 2008 did not meet the 75% 

completeness requirement. However, after using the data substitution test for 

incomplete data year (Appendix S 3.2(c)(ii)(B)), the I-hour primary standard 

design value for 2008 was determined to be valid. 

AIRS ID 

15003001 0 

15003001 1 

Page 1 of 2 

Location 

Kapolei, Oahu 

KO Olina, Oahu 

MSA 

Honolulu 

Honolulu. 

NO2 Method 

FRM Chemiluminescent Analyzer 

FRM Chemiluminescent Analyzer 
State of Hawaii 

Appendix I: Attainment of the NO2 NAAQS 

1. I -Hour NO2 Design Values and Completeness 

Attainment of the I-hour NO2 NAAQS is calculated per 40 CFR part 50 Appendix S, 

as follows: 

The I-hour primary standard design value is the 3-year average of the 

annual 9ath percentile daily maximum I -hour values for a monitoring site; 

The I-hour primary NO2 NAAQS is met at a site when the valid I-hour 

primary standard design value is less than or equal to 100 ppb (Table 1); 

and, 

An NO2 I-hour primary standard design value is valid if it encompasses 

three consecutive calendar years sf compiete data (Table 2); 

A year is complete when all 4 quarters have at least 75% data 

capture; 

If any of the years do not meet completeness requirements, the 

standard design value will be considered valid if the "test design 

value" as calculated in 3.2(c)(ii)(B) is below the level of the NAAQS 

(Table 3). 

The data substitution test was applied to the second quarter of 2008 for the 

Kapolei station. Since the I-hour primary standard design value was below the 

level of the NAAQS, it was validated using method 3.2(c)(ii)(B) and resulted in a 

test design value below the level of the NAAQS. Therefore, the actual design 

value is valid. Table 3 summarizes the results of the data substitution test. 

Table 1. I-Hour Design Value: 2007 to 2009 

Table 3. Calculation of Test Design Value for Second Quarter 2008 at the 

Kapolei Air ~onit&in~ Station (1 50030010) I Max I-hour value: 1 Max I-hour value: I Value used in I Recalculated 981n 1 Test desian value 1 

Kapolei 

West Beach 

2007 

26 PPb 

24 PPb 

The City and County of Honolulu (island of Oahu) is in attainment of the I-hour 

NO2 NAAQS. Kauai, Maui, Kalawao, and Hawaii counties are unclassifiable. 

3-year average 

26 ppb 

23 ppb 

2008 

26 PP~ 

18 PPb 

Q2 2008 

17 PPb 

Page 2 of 2 

2009 

26 PP~ 

26 PPb 

Q2 2007-2009 

30 PPb 

substitution 

30 PPb 

percentile value 

30 PPb 

400 ipb? 

Yes, therefore 

actual design 

value is valid