NFII 4BFRCROMB IE

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### Mr
. Jared Blumen f eld Regional Admin istrator U
. S
. EPA, Region IX 75 Hawthorne Street EXECUTIVE CH A MBERS

**HO ~OLULU**  

### May 19,2011



# jii;;;J;~~t SUBJECT: Recommended Designation for the New ly Promulgated 1-Hour Federal Su lfur Dioxide (S02) 

### Nat iona l Ambient Air Quality Standard ( NAAQS) Purs u ant to Section 107(d)(1) of the Clean Air Act, I am recommending that a ll count i es i n the State of Hawaii be des i gnated as unclass ifiable. The U.S. Envi ronmental P r otect ion Agency (EPA) requires that attainment determinations be made using both mon itored and mode l ed data. Although t he Department of Health ( DOH) has monitored S02 data from seven ambient air monitoring stations, modeling was not conduct ed bu t 

### will be performed in accordance w ith the recently Issued mode li ng guidance. A summary of the 2008 to 201 

# o S02 data collected at all monitoring stations is prese n ted in Attachmen t I
. Exceedances of the 1-hour S02 standard on the island of H awaii are due to emissions from the ongoi n g K i lauea volcano eruption and have been flagged accordingly in EPA's Air Quality Syst em (AQS). Documentations have been submitted to EPA for concurrence with exclud i ng the f lagged data as exceptional events
. There have been no exceedances of the 1-hour S02 standard on the island of Oahu , where t he majority of anthropogenic sources are located
. We look forward to worki ng with EPA , Region IX, on t he fi nal S02 des i gnation
. If you h ave any questions, p l ease contact Mr. Wi lfred Nagamine of the DOH , Clean A i r Branch, at (808) 586·4200
.

Attachmen t c : Deborah Jo rdan. Director, Air Division (AIR-1 )
. U
.S. Env ironmental Protection Agency , Ai r D ivi sion Gwen Yoshimura, Air Quality Analysis Office (AIR -7) , U
. S. Environmental Protect ion Ag en cy

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**~d. ;~** State of Hawaii Attachment 1 : Designatio n Recom mendation of t he 1 - Ho ur S0 2 NMOS 

### ATTACHMENT I 

### State of Hawaii Designation Recommendation of 

### the 1-Hour Sulfur Dioxide 

### (502 ) 

### National Ambient Air Qua l ity 

### Standard (NAAQS)
I. Recommendation As detailed in this document. 

### it is recommend ed that all counties i n the State of Hawa i i be initially designated as unclassifiable for the 1-hour S02 NAAQ8. Withou t the modeled 802 

### component, the state cannot make a defi nitive determination of attainment or non-attainment. During the most recent complete data years of 2008 to 2010 , there were seven S02 mon itoring stati ons in the state
. Three S02 mon i to rs were located in the City and County of Honolulu , which encompasses the island of Oahu and is the only Metropo l itan Statistical A rea (M8A) in the state. Four S02 mon itors were located in Hawaii County for the monitoring of volcanic emiss ions. No 802 monitoring was conducted in the rest of the state which includes the Counties of Kauai {i slands of Kauai and Ni i h au), Ka lawao (Ka laupapa), and Maui {is lands of Mau i, Molokai, lanai and Kahoo lawe). II. Basis f or the Recommendation T he U .S. Environmenta l Protection Agency (EPA) rev i sed the p rimary health-based S02 

### NAAQS by establish in g a new 1-hour S02 standard effective June 2 , 201 0. Pursuant to the Federal Clean Ai r Act 107(d) (1) , states are requ i red to make attainment, nonattainment, or unclassifiable recommendations one year after promulgation of a new standard
. To determ i ne compliance with the new 1-hour 80 2 

### NMOS , EPA is requiring a hybrid approach using both monitored and modeled data. However , timely guidance in conduct i ng large-scaled refined modeling for 802 was not provided and in absence of modeled data the state can on ly recommend an unclassifiable designation
. Using monitoring data , the 1-hour 80 2 

### standard is attained when the three year average of the gg lh 

### percentile of the dai ly maximum 1-hour average at each moni1or do es not exceed 75 parts per bi l lion (p pb)
. In 2008 to 2010 , all three monitors i n the Honol u lu MSA showed no violations of the standard. The amb i ent air stations on the island of Hawaii were established to monitor the impact of 80 2 

### emissions from the Ki lauea volcano
. Althoug h the f our monitors s howed exceedances of the 1-ho ur standard , the data from these stations were f lagged as being due to a natural event. The state has submitted the requ i red exceptional events documentation s to EPAS tate of Hawaii Attach ment 1: Desi g n ation Recomm e nd at ion o f th e 1 -Ho ur S0 2 N AAO S Region 9 providing the causal relationship be tween the act ive volcano and the 

### S02 e xceedances. With the data excluded , all st ations on t h e island of Hawai i would be i n complianc e with the standard. Therefore , although none of t he Honolulu M8A 802 monitors v i o lated the standard , the area is unc lassifiab l e because of t h e absence of large-scaled refined mode li ng . 

### There were exceedances of the standard 

### in Hawaii 

### Coun ty but the 

### area is unclassitiabl e because the data is due to a natural event awaiting exclusion concurrence by EPA and there is a lack of modeling data
. The rest of the state (Kauai , Maui , and Kalawao Counties) is unclass ifiable because th ere was no 802 monitoring or modeling conducted. Ill
. Dat a Exclusion Due to a Natu r a l Even t The 

### S02 ambient air monitori n g st ations on t he island of Hawa ii were est ablished to monitor i mpacts f rom volcanic emissio n s . T h e Kilauea volcano has be e n erupt i ng cont i nuous l y since 1983 emitting on average 2 , 000 ton s per day o f 80 2. In Marc h 2
.

008 , a second vent opened at t h e summit causing an increase of 

### S02 up to 9 ,000 tons per day at one poin t. Th e Hilo and Mountain View stations were established to monitor 

### 802 during southerly winds ; the Pahala a n d Kana stations were established to moni t or 

### 802 during t he prevalent north easte rty winds. All hour1y data of 75 ppb and greater fro m thes e stations have b ee n flagged with the AQ8 code " AS " for vo l canic erupti on. Quarterly exceptional events documentations have been submitted to EPA Region 9 for concurrence wit h the flags for data exclusion
. In the 2008 n at ional emissions Inventory , S0 2 em issions f rom a n thropog enic sou rces in Hawaii County wer e 73 percent less t han in the C ity and County of Hono l ulu
. This equated to 

### 5 ,257 annual t ons of 802 emitted i n Hawa ii County compared to 19 , 678 tons em itted i n the City and County of Honolulu f rom point , area, on - road, and off- road sources. However, 802 emiss i ons f r om biogenic sources were attributed entire ly to t he volcano at 961 , 366 annual tons i n Hawai i Cou n ty com pa red to ze ro tons i n all oth e r co u nt ies. The vo l c an o is cl e a r l y t he si ngl e largest 802 emitte r in the state
. IV. 2008 to 201 0 1-Hour

**SO ~**  NAAQS Comp l iance Data The following tab l e presen t s the 99 1h perce nti l e va l ues and the 3- year average from 2008 to 2010 at the three stati ons in t he City and County of Honolul u and the fou r stati ons on the isl a nd of Hawa i i. T he three year averag e gg ltl percentile of t he daily maximum 1 - hou r 802 values is the metric that detenni n es atta
. inm e nt of the stand a rd
. All daily max i mum values 

### 75 ppb and above collected from the sta t ions on the island of Hawaii wer e excluded from consideration
. There was no S02 monitoring in Kauai a n d Ma u i co u nti es.Stat e of Hawa i i Att a chment 1: Des ignation Recomme n dat i on of t h e 1-Hour 80 2 NAAOS
Station 2008 2009 2010

**3- ~e**  **ar** average 99th percent ile 99 th percentile 99111 percentile 99 pe rcentiles City & County of Honolulu H onolu l u (15003 1 001) 11 15 1 3 13.0 Kapo l ei (1500300 10 ) 1 6 9 18 14.3 VV estBeach (150030011) 13 

### 15 1 2 13
. 3 

### Hawaii County Hllo (15001 1 006) 5 1 53 56 54.0 Kona ( 1 5001 1 012) 67 49 60 58
.7 Paha la ( 15001 2016) 72 74 70 72
.0 Mt. V 1 ew ( 1500120 1 7) 58 64 57 59
.7 The Mt V1 ew stat 1 o n was closed m Octob-er20 1 0 and moved to a n ew location
. The 20 1 0 data yaa r represent s 3 quarters of compl ete data
.