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 annual 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 included it as Attachment A. While 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 the 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 year’s 

plan.

Please note that we cannot approve portions of the 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 portions 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.

Sincerely,

/s/

Matthew Lakin, Manager

Air Quality Analysis Office

Enclosures:

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 Plan Checklist

Year: 2012

Agency: State of Hawaii, Department of Health

40 CFR 58.10(a)(1) requires that each Annual Network Plan (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 speciation stations, SPM 

stations, and/or, in serious, severe and extreme 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 requirements 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 Region 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 requiring 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 requirements, nor do its 

contents provide a binding determination of compliance with those requirements. The checklist is subject to revision in the future and we welcome 

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 

submitted1? If 

yes, page #s. Flag 

if incorrect2?

Does the 

information 

provided3

meet the 

req?

4

Notes 

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

2. Statement of purpose for each monitor 58.10 (a)(1) Yes, p. 5-7, 27 Yes

3. 30-day public comment / inspection period558.10 (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. Modifications to SLAMS network – case when 

we are not approving actual system 

modifications (i.e., we will do it outside the 

ANP process6)

58.10 (a)(2)

58.10(e)

Yes, p. 19 Yes Plan includes proposed NO2 SLAMS addition and one 

additional PM2.5 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 PM2.5 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 through the public notification process within 

their submitted plan.

6

See 58.14(c)
3

ANP requirement Citation 

within 40 

CFR 58

Was the info 

submitted1? If 

yes, page #s. Flag 

if incorrect2?

Does the 

information 

provided3

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 

62-66)

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. Designation of any Pb monitors as either sourceoriented or non-source-oriented58.10 (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 PbPM10 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 location of a violating 

58.10 (c) Yes, P. 7 Yes 
4

ANP requirement Citation 

within 40 

CFR 58

Was the info 

submitted1? If 

yes, page #s. Flag 

if incorrect2?

Does the 

information 

provided3

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 

– O3, CO, PM2.5spec, PM10 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 

submitted1? If 

yes, page #s. Flag 

if incorrect2?

Does the 

information 

provided3

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-located 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. Monitor 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 

submitted1? If 

yes, page #s. Flag 

if incorrect2?

Does the 

information 

provided3

meet the 

req?

4

Notes 

approval must be included if the sampling 

season deviates from requirement)

45. Sampling schedule for PM2.5 - applies to yearround 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 communitywide air App D

4.7.1(b)

Yes. Sec 3.0 Yes 

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

submitted1? If 

yes, page #s. Flag 

if incorrect2?

Does the 

information 

provided3

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 

submitted1? If 

yes, page #s. Flag 

if incorrect2?

Does the 

information 

provided3

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 rationale:
Attachment B: Annual Air Monitoring Network Plan Items where EPA is Not Taking 

Action

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 NO2 monitoring require EPA Administrator approval. 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 NO2 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 PM2.5 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 requirement 

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 AADT (5207) may 

indicate that Mountain View should be reclassified as a middle/micro scale site for PM2.5. 

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 AADT (no data) may 

indicate that Ocean View should be reclassified to a middle/micro scale site for PM2.5. 

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 Kapolei NCore station. 

Please correct in future plans.

 [Item 58] Sand Island is identified as a PM2.5 transport site, but no site is identified as a 

PM2.5 background site. Please clarify in future plans.