UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX
75 Hawthorne Street San Francisco, CA 94105



### February 13, 2013

Mr. Nolan Hirai, Acting Manager

Clean Air Branch Department of Health

State of Hawaii

P.O. Box 3378 Honolulu, Hawaii 96801

- 3378

Dear Mr. Hirai :

Thank you for your submission of the State of Hawaii’s Air Monitoring Network Plan submitted

in 2012

. Based on the information provided in the plan, EPA approves all portions of the network plan except those specifically identified below.

Annual network plans are important documents for regulatory purposes (e.g., State Implementation Plans, designations and redesignations ) and public information, in addition to the myriad uses by the air districts. EPA is revising the review process for ann ual network plans to specifically check and document the comprehensive set of items that are required to be included in the annual network plans per 40 CFR 58.10 in a consistent manner. We have created

a checklist that lists all these items and have includ ed it as Attachment A. W hile the items in the checklist are required by EPA regulations , we acknowledge that we have not specifically requested some of this information in previous annual network plan reviews . We recognize that your plan may not have all t he items that we have currently identified and hope to work with you on the inclusion of these items in future plans. To facilitate these changes, EPA has provided

detailed feedback in the checklist where information should be included or revised in next y ear’s plan.

Please note that we cannot approve portions of th e annual network plan for which the information in the plan is insufficient to judge whether the requirement has been met, or for

which the information , as described, does not meet the requirements as specified in 40 CFR 58.10 and the associated appendices. EPA Region 9 also cannot approve portions of the plan for which the EPA Administrator has approval authority. Accordingly, we are not acting on the specific portion s of your agency ’s annual network plan listed in Attachment B.

In addition to the checklist and list of specific plan elements where EPA Region 9 is not taking

action , enclosed are additional detailed comments on the plan (Attachment C ). All of the

comments in Attachments A, B, and C should be addressed in next year’s network plan. If you

### have any questions regarding this letter or the enclosed comments, please feel free to contact me

at (415) 972

- 3851 or Dena Vallano at (415) 972

- 3134

.

Since rely,

/s/

Matthew Lakin, Manager Air Quality Analysis Office

Enclosure s : A. Annual Air Monitoring Network Plan Checklist

B. Elements where EPA is Not Taking Action

C. Additional Detailed Comments

cc: Wanda Chang, HDOH, State Laboratories Division, Environmental Health Analytical

Services Branch Henry Yee, HDOH, State Laboratories Division, Air Surveillance and Analysis Section Lisa Young, HDOH, Clean Air Branch Susan Kihara, HDOH, Clean Air Branch

### 1 Attachment A : Annual Air Monitoring Network P lan C hecklist

Year: 2012 Agency: State of Hawaii, Department of Health

40 CFR 58.10(a) (1) requires that each A nnual N etwork P lan (ANP) include information regarding the following types of monitors : SLAMS monitoring stations including FRM, FEM, and ARM monitors that are part of SLAMS, NCore stations, STN stations, State speciati on stations, SPM stations, and/or, in serious, severe and ext reme ozone nonattainment areas, PAMS stations, and SPM monitoring stations.

40 CFR 58.10(a)(1) further directs that, “ The plan shall include a statement of purposes for each monitor and evidence that siting and operation of each monitor meets the requirem ents of appendices A, C, D, and E of this part, where applicable. ” On this basis, review of the ANPs is based on the requirements listed in 58.10 along with those in Appendices A, C, D, and E.

EPA R egion 9 will not take action to approve or disapprove any item for which Part 58 grants approval authority to the Administrator rather than the Regional Administrators, but we will do a check to see if the required information is included and correct. The items requiri ng approval by the Administrator are: PAMS, NCore, Speciation (STN/CSN), and NO2 requirements including near road, area

- wide, and RA40.

Please note that this checklist summarizes many of the requirements of 40 CFR Part 58, but does not substitute for those requ irements, nor do its contents provide a binding determination of compliance with those requirements. The checklist is subject to revision in the future and we welc ome comments on its contents and structure.

Key: White = meets the requirement and no action requested

Yellow = does not meet or cannot judge the requirement

– action requested in next year’s plan or outside the ANP process

Green = meets the requirement but action requested to improve next year’s plan

### 2

ANP requirement Citation

within 40

CFR 58 Was the info

submitted 1 

### ? If yes, page #s

. Flag

if in correct 2 

### ? Does the

information provided 3



### meet the

req ? 4 

### Notes

1. Submit plan by July 1 st 58.10 (a)(1) Yes , p. 1; 6/29/2012 Yes Received on June 29 th , 2012

2. Statement of purpose for each monitor 58.10 (a)(1) Yes , p. 5

- 7 , 27 Yes

3. 30

- day public comment / inspection period 5 58.10 (a)(1), 58.10 (a)(2) Yes , p. 4 Yes Public comment period was from May 21

– June 21,

2012 on Clean Air Branch Website (App A)

4. M odifications to SLAMS network

– case when we are not approving actual system modifications (i.e., we will do it outside the ANP process 6 ) 58.10 (a)(2) 58.10(e) Yes , p. 19 Yes Plan includes proposed NO 2 SLAMS addition and one

additional PM 2.5 FEM collocated monitor at Kona

station

.

5. Modifications to SLAMS network

– case when we are approving actual system modifications per 58.14(c) 58.10 (a)(2) 58.10 (b)(5) 58.10(e) 58.14 (c) N / A N / A The plan does not include any new requests.

6. Does plan include documentation (e.g., attached approval letter) for system modifications that have been approved since last ANP approval? No, p. 10 No The plan did not include any information or approval letter on planned collocated PM 2.5 FEM (BAM 1020)

monitor at Kona.

7. NCore site operational ( by 1/1/2011 ) 58.10 (a)(3) Yes, p.19 Yes The NCore station became fully operational on January 1, 2011.

8. Pb site for 0.5

- 1.0 tpy sources operational ( by

12/27/2011 ) 58.10 (a)(4) N/A, p. 14 N/A No Pb source

- oriented monitoring is required. There are no sources in the state emitting 0.5 or more TPY of

Pb.

9. NO2 plan for area

- wide and RA40 sites

submitted by 7/1/2012 58.10 (a)(5) N/A N/A

- HQ approval Not required; Honolulu population < 1 million

10. NO2 plan for near

- road sites submitted by

7/1/2012 58.10 (a)(5) Incomplete, p 16, 21

- 26 N/A

- HQ approval Insufficient to judge. The site will be operational by

Jan. 1, 2013, but proposed sites have not been

confirmed.

11. AQS site identification number for each site 58.10 (b)(1) Yes, p. 27 Yes

12. Location of each site: street address and geographic coordinates 58.10 (b)(2) Yes, Sec 3.0 (p. 28

- 52 for all sites) Yes

1 Response options: NA (Not Applicable), Yes, No, Incomplete, Incorrect. The responses “Incomplete” and “Incorrect” assume that some information has been provided

2 To the best of our knowledge.

3 Assuming the information is correct

4 Response options: NA (Not Applicable)

– [reason], Yes, No, Insufficient to Judge.

5 The affected state or local agency must document the process for obtaining public comment and include any comments received t hrough the public notification process within their submitted plan.

6 See 58.14(c)

### 3

ANP requirement Citation

within 40

CFR 58 Was the info

submitted 1 

### ? If yes, page #s

. Flag

if in correct 2 

### ? Does the

information provided 3



### meet the

req ? 4 

### Notes

13. Sampling and analysis method(s) for each measured parameter 58.10 (b)(3) Yes, Sec. 3.0 Yes Method code is “missing/TBD” for TSP

- Pb at KA

NCore station.

14. Operating schedule for each monitor (see items

6 2

- 6 6 ) 58.10 (b)(4) Yes, Sec 3.0 Yes 12 months, continuous; TSP

- Pb is 1:6

15. Any proposals to remove or move a monitoring station within a period of 18 months following plan submittal 58.10 (b)(5) Yes, p. 26, 45 Yes The noted changes in the next 18 months include:

1. To meet minimum collocated requirements, PM2.5

FEM BAM 1020 Monitor to be established at

Kona

2. Addition of new SPMS station for volcanic emissions monitoring on NW side of island by end

of 2012

16. Scale of representativeness for each monitor as defined in Appendix D 58.10(b)(6); App D Yes, Sec 3.0 Insufficient

information to judge in some

instances According to Appendix E, section 6.3 (b), MV may

need to be reclassified as a middle/micro scale site for PM2.5 based on distance to traffic lane (6.5m) and ADT (5207).

According to Appendix E, section 6.3 (b), OV may need to be changed to a middle/micro scale site for PM2.5 based on distance to traffic lane (13.6m) and ADT (no data).

17. Identification of sites suitable and sites not suitable for comparison to the annual PM2.5 NAAQS as described in Part 58.30 58.10 (b)(7) Yes, Sec 3.0, p. 10 Yes

18. MSA, CBSA, CSA or other area represented by

the monitor 58.10 (b)(8) Yes, Sec 3.0 Yes Hawaii’s only CBSA/MSA/CSA is Honolulu.

19. D esignation of any Pb monitors as either source

oriented or non

- source

- oriented 58.10 (b)(9) Yes, p.14 Yes Monitors are designated as non

- source oriented.

20. Any source

- oriented Pb site for which a waiver has been granted by EPA RA 58.10 (b)(10) N/A, p. 14 N/A

21. Any Pb monitor for which a waiver has been requested or granted by EPA RA for us of Pb

PM10 in lieu of Pb

- TSP 58.10 (b)(11) N/A, p. 14 N/A

22. Document how states and local agencies provide for the review of changes to a PM2.5 monitoring network that impact the l ocation of a violating 58.10 (c) Yes, P. 7 Yes

### 4

ANP requirement Citation

within 40

CFR 58 Was the info

submitted 1 

### ? If yes, page #s

. Flag

if in correct 2 

### ? Does the

information provided 3



### meet the

req ? 4 

### Notes

PM2.5 monitor.

23. Precision/Accuracy reports submitted to AQS 58.16(a); App A , 1.3 and

5.1.1 Yes, Sec 3.0 Yes Quarterly

24. Annual data certification submitted 58.15 App. A 1.3 Yes, but incomplete

for one site, p.45 Yes in most cases, but

insufficient to judge in one

instance. All submitted by 5/1/12 except Kona (left blank)

25. Frequency of flow rate verification for manual PM samplers audit App A 3.3.2 Yes, Sec 3.0 Yes Monthly

26. Frequency of flow rate verification for automated PM analyzers audit App A 3.2.3 Yes, Sec 3.0 Yes Monthly

27. Frequency of one

- point flow rate verification for Pb samplers audit App A 3.3.4.1 No No No information was provided for Kapolei NCore site.

28. Frequency of one

- point QC check (gaseous) App. A 3.2.1 Yes, Sec 3.0 Yes Weekly

29. Date of last Annual Performance Evaluation (gaseous) App. A 3.2.2 Yes, Sec 3.0 Yes in most cases, No for the specific

situations listed

in the notes KA NCORE site conducted only a partial gaseous audit

– O 3 , CO, PM 2.5spec , PM 10 passed. The plan notes that they did not conduct other gas audits. Please clarify in future plans.

30. Dates of last two semi

- annual flow rate audits

for PM monitors App A, 3.2.4 and

3.3.3 No, Sec 3.0 Yes for cases

where

information was complete.

Insufficient to judge for incomplete

information. Need to include specific dates (specified as

“monthly”).

31. Dates of last two semi

- annual flow rate audits

for Pb monitors App A 3.3.4.1 No, Sec 3.0, p. 33 Yes for cases

where

information was complete.

Insufficient to judge for incomplete Need to include specific dates (specified as

“monthly”).

### 5

ANP requirement Citation

within 40

CFR 58 Was the info

submitted 1 

### ? If yes, page #s

. Flag

if in correct 2 

### ? Does the

information provided 3



### meet the

req ? 4 

### Notes

information.

32. PM2.5 co

- location App A 3.2.5 Yes, p. 10 Yes See Attachment B of the 2012 ANP memo. Details for PM2.5 FEM (BAM 1020) monitor at Kona in late 2012 are not addressed in plan.

33. Distance between co

- l ocated monitors App. A 3.2.5.6 Yes, p. 30 Yes Addressed for KA station.

34. Manual PM10 method co

- location met? (note:

continuous PM10 does not have this requirement) App A 3.3.1 N/A N/A All continuous monitors

35. Pb co

- location App A 3.3.4.3 N/A N/A Only non

- source site is NCORE

36. PM10

- 2.5 co

- location (note: only applies to Fresno and Phoenix NCore sites) App A 3.3.6 N/A N/A

37. Instrument/monitoring method code for each monitor: is it reported properly? Is it reported correctly (i.e., appropriate method code for regulatory monitors)? App C 2.4.1.2 Incomplete. Sec 3.0, p.32 Yes in most cases, No for the specific

situations listed

in the notes Method code is “missing/TBD” for TSP

- Pb at KA

NCore station.

38. Start date for each monitor Required to

determine if other req. (e.g., min #

and co

- lo) are met Yes, Sec 3.0 Yes

39. Instrument monitor type for each monitor Required to

determine if other req. (e.g., min #

and co

- lo) are met Yes, but incomplete,

p. 19 and Sec 3.0 Insufficient to Judge The plan identifies full stations as SLAMS or SPM, but

not specific monitors. Monito r types should be listed by monitor, although Table 3.1, p. 27 lists parameters

for each site.

40. Monitoring objective for each instrument App D 1.1 58.10 (b)(6) Yes, Sec 3.0, p. 27 Yes

41. Site type for each instrument App D 1.1.1 Yes, Sec 3.0 Yes

42. Instrument parameter code for each instrument Required to

determine if other req. (e.g., min #

and co

- lo) are met Yes, Sec 3.0 Yes

43. Instrument parameter occurrence code for each

instrument Required to

determine if other req. (e.g., min #

and co

- lo) are met Yes, Sec 3.0 Yes

44. Sampling season for ozone (note: date of waiver App D, 4.1(i) Yes, Sec 3.0 Yes

### 6

ANP requirement Citation

within 40

CFR 58 Was the info

submitted 1 

### ? If yes, page #s

. Flag

if in correct 2 

### ? Does the

information provided 3



### meet the

req ? 4 

### Notes

approval must be included if the sampling season deviates from requirement)

45. Sampling schedule for PM2.5

- applies to year

round and seasonal sampling schedules (note: date of waiver approval must be included if the sampling season deviates from requirement) 58.12(d) App D 4.7 Yes, Sec 3.0 Yes All continuous or 1:3

46. Sampling schedule for PM10 58.12(e) App D 4.6 Yes, Sec 3.0 Yes Continuous

47. Sampling schedule for Pb 58.12(b) App D 4.5 Yes, p. 32 Yes 1:6

48. Sampling schedule for PM10

- 2.5 58.12(f) App D 4.8 Yes, p. 32 Yes Continuous

49. Minimum # of monitors for O3 [Note: should be supported by MSA ID, MSA population, DV, # monitors, and # required monitors] App D, 4.1 (a)

and

Table D

- 2 Yes, p. 12 Yes

50. Identification of max. conc. O3 monitor(s) App D 4.1 (b) Yes, p. 12 Yes Lists DV site (highest DV of monitors in the MSA) for

each MSA.

51. Minimum monitoring requirements met for SO2 App D 4.4 Yes, p. 17 Yes

52. Minimum monitoring requirements met for Pb App D 4.5 58.13(a) Yes, p. 14 Yes

53. Minimum # of SLAMS sites for PM2.5 [Note: should be supported by MSA ID, MSA population, DV, # monitors, and # required monitors] App D

, 4.7.1(a) and Table

D

- 5 Yes, p.10 Yes

54. Required PM2.5 sites represent community

wide air App D 4.7.1(b) Yes. Sec 3.0 Yes

55. For PM2.5, is at least one site in a population

oriented area of expected maximum

concentration App D 4.7.1(b)(1) Yes, p. 10 Yes

56. If >1 SLAMS PM2.5 required, is there a site in an area of poor air quality App D 4.7.1(b)(2) N/A N/A Only 1 SLAMS PM2.5 is required.

57. Minimum monitoring requirements for

continuous PM2.5 App D 4.7.2 Yes, p.10 Yes

58. Requirements for PM2.5 background and transport sites App D 4.7.3 Yes, p. 37 N/A

– state level Sand Island is identified as a transport site, but no site is identified as a background site.

59. Are PM2.5 Chemical Speciation requirements App D 4.7.4 Yes Yes Kapolei

### 7

ANP requirement Citation

within 40

CFR 58 Was the info

submitted 1 

### ? If yes, page #s

. Flag

if in correct 2 

### ? Does the

information provided 3



### meet the

req ? 4 

### Notes

met for official STN sites?

60. Minimum # of monitors for PM10 App D , 4.6 (a)

and Table D

- 4 Yes, p.. 8 Yes

61. Minimum monitoring requirements met for

PM10

- 2.5 mass and speciation App D 4.8 Yes, p. 32 Yes

62. Distance of site from nearest road App E 6 Yes, Sec 3.0 Yes in most cases, No for the specific

situations listed

in the notes The Plan notes that the MV station is <10m from

nearest traffic lane for PM2.5 and SO2.

63. Traffic count of nearest road App E Yes, Sec 3.0 Yes in most cases, No for the specific

situations listed

in the notes N/A or “no data” for several roadways at the following

sites: KH, KA, PC, KH, HL, KN, OV, PA, PE . Please clarify estimated road usage in future plans.

64. Groundcover App E 3(a) Yes, Sec 3.0 Yes Vegetated for KA, SI, KH, NI, HL, KN, MN, OV, PA,

PE

65. Probe height App E 2 Yes, Sec 3.0 Yes

66. Distance from supporting structure App E 2 Yes, Sec 3.0 Yes Horizontal distance NA for KA, SI, KH, NI, HL, KN,
MV, OV, PA

67. Distance from obstructions on roof App E 4(b) Yes, Sec 3.0 Yes N/A for KH, KA, SI, NI, HL, KN, MV, OV, PA (height not provided for any sites)

68. Distance from obstructions not on roof App E 4(a) Yes, Sec 3.0 Insufficient to Judge Need height above obstacle, in addition to distance to

obstacle, to judge whether this requirement is met (e.g. KH, KA, SI, NI, HL, KN, MV, OV, PA

. 69. Distance from trees App E 5 Yes, Sec 3.0 Yes The Plan notes that NI is 5.2m ESE, HL is 4.6m S, and OV is 7m ENE from trees (includes PM2.5, but not ozone monitors).

70. Distance to furnace or incinerator flue App E 3(b) Yes, Sec 3.0 Yes N/A for KA, PC, SI, KH, NI, KN, MV, OV, PA, PE

71. Unrestricted airflow App E , 4(a) and 4(b) Yes, Sec 3.0 Yes

72. Probe material (if applicable) App E 9 Yes, Sec 3.0 Yes

73. Residence time (if applicable) App E 9 Yes, Sec 3.0 Yes

74.

75. Not required as part of plan but good to

check

### 8

ANP requirement Citation

within 40

CFR 58 Was the info

submitted 1 

### ? If yes, page #s

. Flag

if in correct 2 

### ? Does the

information provided 3



### meet the

req ? 4 

### Notes

76. For SPMs listed as non

- regulatory, note the start

Date of FRM/FEM/ARM at SPM. If > 24 months, agency must supply information that App A, C or E requirements were not met. 58.20(c)

– (e) Yes, Sec 3.0 Insufficient to judge PE began operating in 2005

77.



### Public Comments on Annual Network Plan Were comments submitted to the S/L/T agency during the public comment period? Yes If no, skip the remaining questions. If yes:

 Were any of the comments substantive?

o If yes, which ones?

o Explain basis for determination if any comments were considered not substantive:

 Request for PUNA

- E station to change sensitivity for hydrogen sulfide.

 State/EPA should being air monitoring activity at Pohakuloa Training Area.

 Analysis for depleted uranium in aerosols should be added monitored components at a standard station.

 Did the agency respond to the substantive comments?

o If yes, was the response adequate?

o Yes

 Do the substantive comments require separate EPA response (i.e., agency response wasn’t adequate)?

o No

 Are the sections of the annual network plan that received substantive comments approvable after consideration of comments? NA. We are not acting on these portions of the plans at this time.

o If yes, provide ratio nale:

### Attachment B : Annual Air Monitoring Network P la n Items where EPA is N ot Taking

A ction

We are not acting on the portions of annual network plans where either EPA Region 9 lacks the authority to approve specific items of the plan, or EPA has determined that a requirement is

either not met or information in the plan is insufficient to judge whether the requirement has

been met.

 NCore and the plan for NO 2 

### monitoring require EPA Administrator approv al. Per 40 CFR 58.11(c), NCore network design and changes are subject to approval of the EPA Administrator and per 40 CFR 58.10(a)(5) plans for establishing NO 2 

### monitoring sites are submitted to the EPA Administrator for action. Therefore, we are not acting on these

items.

 System modifications (e.g., site closures or moves ) are subject to approval per 40 CFR 58.14(c). Information provided in the plan was insufficient for EPA to approve the following system modification listed in the plan per the applicable requirement: addition

of collocated PM 2.5 

### FEM (BAM 1020) monitor at Kona (page 10). Therefore, we are not acting on these items as part of this year’s annual network plan.

 EPA identified items in you agency’s annual network plan where a requirement was not being met or information in the plan was insufficient to judge whether the require ment was being met based on 40 CFR 58.10 and the associated appendices. Therefore, we are not acting on of the following items:

Item Checklist Row (Attachment A) Issue

Annual data certification 24 Insufficient information to judge in

some instances

Dates of last two semi

- annual flow

rate audits for PM monitors 30 Insufficient information to judge

Dates of last two semi

- annual flow

rate audits for Pb monitors 31 Insufficient information to judge

Frequency of one

- point flow rate

verification for Pb samplers audit 27 Insufficient information to judge in

some instances

Traffic count of nearest road 63 Insufficient information to judge in

some instances Instrument monitor type for each

instrument 39 Insufficient information to judge in

some instances

Distance of site from nearest road 62 Insufficient information to judge in

some instances

Distance from obstructions not on

roof 68 Insufficient information to judge

Additional information for each of these items is in included in Attachment A.

### Attachment C : Additional Detailed Comments

 [Item 16 , 62 ] The distance to the nearest traffic lane (6.5m) and A ADT (5207) may indicate that M ountain V iew should be reclassified as a middle/micro scale site for PM 2.5



### . Please clarify in future plans why a larger scale classification is appropriate for this site.

 [Item 16 , 63 ] The distance to the nearest traffic lane (13.6m) and A ADT (no data) may indicate that O cean View should be reclassified to a middle/micro scale site for PM 2.5



### . Please clarify in future plans why a larger scale classification is appropriate for this site.

 [Item 37] The method code is “missing/TBD” for TSP

- Pb at the K apolei NCore station. Please correct in future plans.

 [ Item 58] Sand Island is identified as a PM 2.5 

### transport site, but no site is identified as a

PM 2.5 

### background site. Please clarify in future plans.