AIR POLLUTION CONTROL
IN THE STATE OF HAWAII
AN EVALUATION REPORT
WITH RECOMMENDATIONS
FOR PROGRAM IMPROVEMENTS
U. S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air Programs
-------
THE STATE OF HAWAII
AIR POLLUTION CONTROL PROGRAM
i 0 0
AN EVALUATION REPORT i " "
WITH RECOMMENDATIONS FOR PROGRAM IMPROVEMENTS
.Dan J. deRoeck
.ENVIRONMENTAL PROTECTION AGENCY
Air Pollution Control Office
February 1971
-------
^1
* v*«
£
3-1
a'V".J$
TABLE OF CONTENTS
. . PAGE
';,. INTRODUCTION 1
BACKGROUND 3
1. ADMINISTRATION . 5..
Organization 5
Regional Air Pollution Control Activities 6
County Advisory Air Pollution Control Associations. ... 8
Program Objectives and Planning 9
,,. Information and Education 10
Training 11
Manpower Needs 12
2. LEGAL ASPECSS . . 16
Legal Authority 16
'Regulations 20
3. TECHNICAL SERVICES. .... . .-.-.-.-.--.-.-.-. ... 27-
" Air Quality Monitoring 27
Laboratory Operations and Facilities 31
Instrument Calibration and Maintenance 32
Data Processing and Analysis 33
Meteorological Data ". 35
4. ENFORCEMENT 37
Compliance Schedules. .................. 38
Violation Identification. .j___...^-_a_- .".... -.39 _
Complaint Handling 41
Scheduled Inspections 42
5. ENGINEERING ....... 44
Emission Inventory 44
Permit System '........... 46
Source Testing . _47
Emergency Plan "l~T~7~7~~". '". 49
-------
5
,'.-'*
.' 1
'i
" INTRODUCTION ' ' "' .
. . * i . .y"
'-.''.' *
The State of Hawaii was designated as an Air Quality Control
Region on August 13, 1970. The Hawaii Air Quality Control Region
consists of the territorial area encompassed by the outermost boundaries
of the State including the territorial areas of all municipalities
located therein; " In accordance with the Clean Air Amendments of 1970,
the State must submit "a plan which provides for implementation,
maintenance and enforcement" of national ambient air quality
standards. The implementation plan must be submitted to the
Federal Government for review and approval within nine months after
the standards are promulgated..
-The purpose of this report is to present a preliminary review of .
. -'y . , .... . _ _ __
activities being performed by the State of Hawaii to fulfill their
responsibilities as described above, and to review proposals and make
recommendations affecting future progress of the State's efforts.
This report is based on information and material supplied by the
Air Sanitation Branch, Hawaii State Department of Health. Their
cooperation and assistance is gratefully acknowledged at this time.
In addition, information contained in the grant files of the Air
Pollution Control Office in Raleigh, North Carolina, has been utilized.
This evaluation procedure does not provide sufficient information to
support a comprehensive functional program audit. An in-depth study
of the State's air pollution control program should be made within a
year to evaluate the State's progress in the development and implementation
of a comprehensive program, that will adequately preserve air quality.
-------
- : ;»/ : i
' j *.'j,> » ' _
N1IHAU
LIHUE
cr/VA«y
so
Mile*
75
100
Slolt of Htwoii
-------
- BACKGROUND
' . . » R, -**' ' .»
' . -
The State of Hawaii is relatively free of'serious large scale air
pollution problems. The prevalence of the trade winds, and local
winds of mountainous °r oceanic nature, preclude the occurrence of
.atmospheric stagnation conditions as experienced inrmostjsections of
the mainland. ^However, meteorological conditions and point source
emissions are factors causing local air pollution problems of immediate
concern.
Hawaii consists of four counties, which include eight major
islands. Th^island of Oahu (Honolulu County) is perhaps of greatest
concern because of its high population density and its relatively high
concentration of pollutant emission sources. Oahu's land area of 604
.square miles represents less than 10 percent of the State's total size,
yet 82 percent of the State's 748,575 persons live there. The great
unbalance of population to land area is further increased by the fact
that half of the State's residents are concentrated in the City of
Honolulu.
The major source of pollutants is the automobile. This source
contributes almost 43 percent (by weight) of the State's total
pollutant emissions. Honolulu County, where 79 percent of all motor
vehicle travel occurs, frequently experiences a photochemical problem
from this source.
The State is notably devoid of heavy industrial complexes with
the exception of a petroleum refinery and a steel rolling mill. From
-------
an air pollution standpoint, the refinery and the mineral products
industry are the most significant industrial process sources of air
: pollutants. ,
^ . The southwest corner of Oahu has been zoned as a heavy industrial
area. Fortunately, the tradewinds carry most of the pollutants from
the sources in this area out to sea. ..-.''<
The most important fuel consumed for heat and power is residual
fuel oil. There are seven uncontrolled major steam-electric generating
plants in the State (three are located on the island of Oahu).
Emission inventory data (1968) indicates that the bulk of domestic
refuse is disposed of by means of on-site backyard burning. Even in
Honolulu County, where the only two municipal incinerators are located,
- backyard burning prevails over any other disposal method. The central
disposal facility in each county practices open burning as a means to
teduce bulk.
- Agriculture, mainly the sugar cane and pineapple industries, are
an important aspect of Hawaii's economy. The sugar industry is a
significant source of particulate emissions particularly during land
clearing operations. While the pineapple and coffee industries have
odor-related problems, they are generally considered local in nature.
-------
3
:.'i
' ' ADMINISTRATION
The Air Pollution Control Law, Chapter 322,' Part V, Hawaii
*
Revised Statutes provides the legal authority with which the State
of Hawaii presently acts to control air pollution in the State.
Utilizing the provisions of this authority in two counties Public
Health Regulations, Chapter 31, Air Pollution (Honolulu City-County)
and Public Health Regulations, Chapter 35, Air Pollution (Maui County)
have been adopted by the State Department of Health. The State air
pollution control program, as administered by the Department, is
responsible for the enforcement of all air pollution regulations.
Financial support from the Federal Government to stimulate the
development of an effective control agency was received by the
State of Hawaii for a three-year period commencing in April, 1965,
and ending in March, 1968. The budget for fiscal year 1969-70 totaled
$72,857 (no Federal assistance) as compared to $30,943 during the
previous fiscal period. Based on manpower projections (see page 15)
and assuming a full-strength operation of 26 man years of effort,
APCO estimates a total budget requirement of approximately $442,000
for the Hawaii State air pollution control program.
Organization
The responsibility for air pollution control in the State of
Hawaii has been delegated to the State Department of Health.
-------
..VI
'!
6 ,
Control activities are presently being conducted by the Department
through the Air Sanitation Branch of the Environmental Health Division.
The Air Sanitation Branch has recently experienced a significant
growth in manpower which has provided the program with additional
strength and competency. With the expansion, the Branch has proposed
an organizational structure designed to establish a more clearly
\
defined functional division of manpower than had been possible
previously with the smaller organization. When approved, the Air
>
Sanitation Branch would be divided into three functional sections -
Technical Services, Investigational and Enforcement, and Engineering
-:±H»
and Support. (Refer to the proposed organizational chart, page 7.)
Administrative responsibility would be retained by the full-time
Branch Chief (EHS VII), with each section supervised by an individual
responsible for coordinating the activities of subordinate personnel.
Recommendation 1.1 . Update the position descriptions
for all personnel in accordance with the proposed
organizational structure of the Air Sanitation Branch.
Regional Air Pollution Control Activities
r
."..The unique island geography of the State of Hawaii
vhas resulted in the air pollution control agency's development of
some program operations on a decentralized basis. The State agency
has, in fact, commenced with the construction of permanent facilities
on the islands of Maui, Kauai and Hawaii so that at least one member
of the agency could be permanently located at each of these major
locations.
-------
%
T^fyV^jSi^^^ .. . r- _'.. .-... ;,fyv<
;:;/'^-'>''-'--^£^- i ^; &5s'i. :. .'j
COUNTY ADVISORY AIR POLLUTION
CONTROL ASSOCIATIONS -
1. Honolulu Co.
2. Maul Co.
3. Kauai Co.
4. Hawaii Co.
TECHNICAL SERVICES
SECTION
Cheir.if-t IV
(Pos// 3107)
CHEMIST III
(Pos# 21933)
CHEMIST III
2193/.)
ORGANIZATIONAL CHART
AIR SANITATION BRANCH
BRANCH CHIEF
EHS VII
(Pos# 3219)^
INVESTIGATIONAL AND
ENFORCEMENT
SECTION
EHSJTV
TPo^ 21930)
4
SHS III
r.ff' 3110)"
EH3 III
E# 21270)
Kia III
(Po-^ 211*20$
Oahu-75^ '
EHS III
(Pot-.// 21932)
CLERICAL
Steno III
(Pos# 120A2)
Steno II
(Pos^ 21931)
ENGINEERING AND
SUPPORT
SECTION
Enrinccr III
(Per;.? 1239TT
EHS III. KCOLOGIST
(r-o'^ 22209) v
MECHANICAL ENGR.
State Assignee
from EPA
-------
8
*
^_ _j^ " _ _ " j_ a, ' " ' "
These facilities will include laboratory space for the analysis of
all samples collected on these islands. Present plans include the
assignment of one Environmental Health Specialist (EHS III) to each
of the three islands by the summer of 1972. " " > -
-';« Certain activities such as routine enforcement and air sampling
! .:.!;j . . operations are best performed from a decentralized point of operation.
',. Sii This is especially true considering the island setting of Hawaii. In
':"M
_:~v> order to ensure a successful decentralization of air pollution control
- '^" . 4 *** ' .<.'' '' '"
.V-j activities, the State agency must develop an operational plan that
' "?..:<
. ~. .~=jt
/t{ j . provides for adequate coordination of program activities and optimizes
A the use of all facilities now being constructed. The area of greatest
, .;«!t ' 'Concern with regard to the regional activities is the possible
....^ . duplication of laboratory operations for the analysis of air quality
:'| samples. A discussion of this potential problem is incorporated
" j '
',- ' within the discussion of laboratory operations and facilities in
.- '=M the technical services section of this report.
.'JU; County Advisory Air Pollution Control Associations
v,'Vi;i ~ " A special feature of the air pollution control effort in the State
. - of Hawaii has been the establishment of four county advisory air
~ - :, pollution control associations. The primary function of the advisory
.1; : : associations is to study air pollution problems in their respective
. . -: counties and present recommendations to the State Department of Health.
', In addition, all local rules and regulations are forwarded to the
-------
"J'~{l . affected county association for comment before being adopted by the
;| State Health Department. As required by law, the secretarial position,
°;| for each association has been filled by a member of the Air Sanitation
: -| -Branch. (See Enforcement Section, page 36.)
: The last county to establish this activity is .Hawaii County. The
'.; Director of the State Health Department designated members for this
. .3 ' . -;;'
- vj advisory association and scheduled the first meeting for January 27, 1971,
Program Objectives and Planning
' - ?_iti3» .<
The foundation for an effective and timely development of program
.
activities is a comprehensive system of program planning. Such
'-
planning requires a realization of the objectives which must ultimately
be achieved. A successful program for air pollution control would
include the defining of long-range objectives (5 or more years), but
must be supported by intermediate and short-term objectives as well.
In awareness of the ultimate goal "to prevent, abate and control
air pollution" the State agency has developed, within its area of
_..._. - -
jurisdiction, specific short-term objectives. Immediate plans include
developing and implementing a permit system, updating the emission
inventory, and expanding the air" monitoring network. The recent
expansion of the agency's staff and the proposed restructuring of the
organization represent significant steps in fulfilling these plans.
Further success will be dependent upon making necessary changes in
-------
.
m
10
legislation, periodically evaluating manpower and resource needs,
and continuously monitoring and modifying program activities to remain
consistent with environmental needs. In addition, agency plans should
include a timetable of interim ambient air quality objectives and a
date for final achievement of ambient air quality standards. All program
plans should guide the agency toward a more aggressive enforcemerit policy
in complete support of ambient air quality goals, and consistent with
the Air Quality Control Region Implementation Plan requirements. The 1970
Clean Air Amendments, Section 110, requires the State Implementation Plan
to provide for attainment of primary air quality standards within 3 years
after its approval.
Recommendation 1.2 . Develop a system to
monitor and evaluate progress being made toward
achieving all long- and short-term objectives.
Complete immediate plans to update the emission
inventory, expand the air sampling network and
develop a permit system of operation.
- ' -' Information and Education
fi The agency has employed the services of an Information Specialist
'<( (Ecologist) to develop a public information program. A successful
1 communication system should be developed to transmit status reports
.3 . "~
| and control activities in a manner that effectively obtains or
\
1 sustains public interest and support. Those needing such information
-------
;;$
11
include public officials, the employees and management officials of
emission sources, the news media, and the concerned public.
Recommendation 1.3 . Develop a public information
system to compile and distribute pertinent information
to all concerned groups and/or individuals. The
. system could also be designed to include provisions
for film presentation, lectures, and- distribution of
air. pollution literature.
;; Training
,: A program of in-service training has been planned to provide
Vj
; new personnel with an understanding of the agency's administrative
j ......_'
'i and operating procedures. In-service training should be coordinated
.. j
.; with a program of formal training courses to further develop
) individual skills and competency. It is important that new personnel
rl . .receive training in the areas in which they are expected to perform;
,--, however, an ongoing training program should not exclude what may be
-3 considered to be the "experienced" segment of the staff. All personnel
>."'j -- - - -
-"; - must be provided the opportunity to update and expand technical,
:\ managerial and other special skills.
i
.J In the past, State funds were not available for out-of-State
'i
travel. It is important, especially with the isolation of this
State, that the appropriation of funds for out-of-State travel be
made immediately so as not to jeopardize essential training activities.
-------
::1 ''."-, ' '
":^;3 . Recommendation 1.4. Develop a training program
-.''.."--- / f°r flH staff members. The program should be designed
. - . " to take advantage of formal training courses provided
-: .>VJ _ by APCO, universities, etc. in order to increase and
.".V-3 ' improve staff effectiveness. Formal training should
::?:-;. :-' . .be supplemented by in-house training activities
~'.':'-4 " designed to meet special needs.
' <~ * ^ ' .' . *
X'iȣ^ Manpower Needs
1 The State air pollution control agency must evaluate existing
-;-v'.vj resources and perform estimates of all resource needs required to
0 operate an effective control program. In estimating resource needs,
:.; \ _ the component of greatest concern is that of manpower. Manpower is
;-''':^"\ " of primary concern because it is so often the most difficult resource
i to acquire, the most expensive to maintain, and the hardest to justify.
'. '1
.'>: .i The recent expansion to fourteen persons has allowed the agency
:'":&'"' \ to focus attention on the development stage of various projects that
.:";:.') will play an important role in the control program's effectiveness.
<: .--j
,-.-'- However, the successful implementation and routine performance of
'.! essential activities such as an ongoing emission inventory, the permit
'"" 'i
. I system, and an active air surveillance program will require an increase
' ' 1
| of staff over that now employed. Manpower estimates based on the
v
:1 APCO manpower model are presented on page 15. The estimates indicate
-- - .'= the total manpower strength (and the specific functional areas to
, \:' . which the man years of effort_are to be applied) considered to be
-------
13
adequate in order to operate an effective and comprehensive air
| pollution control program in the State'of Hawaii.
'V
'j It is recommended for the present time that the agency continue
: .
4 ' with its plans to permanently locate one Environmental Health Specialist
3 .
i .
.j (EHS III) on each of the islands of Maui, Kauai, and Hawaii. The
*i
; three individuals thereby assigned would handle routine enforcement
ii
?* activities, necessary air sampling, and generally any basic operations
-'
:j as needed on the respective islands. It is anticipated that assistance
: will become necessary on occasions to perform special studies, handle
j complex engineering problems, etc. This assistance should be supplied
:j by the main office in Honolulu. The agency should not assign additional
] personnel to the islands until the need is clearly justified.
j The major portion of the manpower will remain in the central
: Air Sanitation Branch Office in Honolulu. This is to be expected not
; only because of the more comprehensive air pollution control effort
_ j
.3 required for this city-county area, but also because many operations
. i
j for the entire State can be most efficiently and effectively handled
%
' from the central operating point. All management services should be
; - performed centrally. Perhaps the area of most immediate concern is
i
; the recruitment of personnel to replace the vacated positions in the
/ Investigational and Enforcement Section when assignments are made
."^
'; to the islands. These replacements should be obtained as soon as
'1 possible so that the individuals may have sufficient time to gain
>
required knowledge of agency policies and operations, as well as
-------
:>.'::!
- ^:
4;"-"
14
specific job techniques. Proceed with efforts to bring all other
areas of the program to full strength so that a well-balanced air
pollution control effort can be implemented.
Recommendation 1.5. Evaluate overall manpower needs.
Place priority on those functional areas of immediate
importance to the control program (see estimate of
manpower, page 15). As EHS III positions are transferred
to the outer islands, replace these positions with
inspector (enforcement) personnel for control program
activities in Honolulu metropolitan area.
;H
A
-------
-m
15
ESTIMATED MANPOWER NEEDS FOR THE
HAWAII (HONOLULU) AIR QUALITY CONTROL REGION
.-, -. «**
a
Function .
Management Services
Policy, Recruitment, etc.
Staff Training,^ Education/Information
Administrative and Clerical
Field Enforcement Services
Scheduled Inspections - Fuel & Refuse
,._ Indus try
Complaints and Field Patrol
-z*
Engineering Services
Permit System . -
Source Testing .,
Emission Estimates
Engr'ing. Repts., New Regs-., etc.
/"
Technical Services
i
Air Quality Monitoring
Special Studies
Data Processing
Instrument Calibration
Lab. Operations
TOTAL
Total
1.4
1.3
5.0
7.7
2.0
1.5
5.7
9.2
2.6
0.8
0.6
1.0
5.0
1.1
0.7
1.0
0.5
0.8
4.1
26.0
Honolulu Co.
1.0
1.0
3.0
5.0
1.4
1.1
4.7
7.2
2.0
0.6
0.4
0.7
3.7
' 0.4
' 0.4
0.7
0.3
0.5
2.3
18.2
Remainder
of Statp
0.4
0.3
2.0
2.7
0.6
0.4
1.0
2.0
0.6
0.2
0.2
013
1-3
a
0.7
0.3
0.3
0.2
0.3
1.8
7.8
-------
r=p?*1
''"
16
' ''.'-' LEGAL ASPECTS
The State of Hawaii's legal authority and regulations pertaining
to air pollution control have been reviewed in order to assess their
consistency with state-of-the-art control efficiency. This in no way
implies adequacy in meeting air quality standards for any particular
burden area in the State. Areas have been identified where legislation
is completely lacking or modifications need to be made. Additions
and modifications as required by the Clean Air Amendment of 1970
must be accomplished within a reasonable period as they will effect the
acceptability of the State Implementation Plan for the Air Quality
Control Region.
LEGAL AUTHORITY
Section 322-64 Powers; Specific
Part (4) provides the authority to requirfe the submittal of
plans and the filing of reports to the agency. The provision for
requiring reports, however, "shall be conditional upon either the consent
of the person engaged or desiring to engage in operations which may
result in air pollution or the direction of the department, which
direction may issue only after a hearing upon notice to the person
engaged in such operations." This section of legislation is interpreted
to make each "direction" of the health department (Air Sanitation
Branch) a separate order. This policy is felt to be inadequate for
-------
. :.]] i?
obtaining essential source and emission information. Hearing procedures
would overwhelm the agency if this action is required for every
'emission source. "" ""_'..'
Recommendation 2.1; Obtain adequate legal
V.r«j authority which gives the air pollution control
>?-J agency power to require the reporting of emission
'";! and source information without the clause for a
.£w^ ' , hearing prior to each action.
?[v; J . Part (5) contains a confidentiality of records provision. The Clean
- .; Air Amendments of 1970 require that States make all pertinent emission
^ information available for public inspection. This authority must be
'' clearly established in the State's Legislation.
' '~'i^ (
'.' ."-'' ' Recommendation 2..2 . Obtain authority to require
that emission information and data be made available
-^ ., for public inspection.
'.. j
J-₯i
'..,:;', Section 322-69 Enforcement
" ""' ?
-:'-, ' Part (a) requires a hearing to answer all charges of complaints
~ * -*' ^*»
'& -\ ~-\
;.''. made against air pollution violators whether the charges be filed with
or by the Department of Health. Essentially, this means that the purpose
.;'. of the hearing is to determine the initial guilt of any suspected
'/ ' violator. The determination of initial guilt should be a responsibility
of the air pollution control agency - more specifically, the enforcement
-------
/ "~ -'--^-' ~<"-- ^^-
1
18
personnel who will be trained to recognize and document violations
(e.g., open burning and visible emission violations) of applicable
State regulations. '
The State law must provide the agency with adequate authority to
expediently enforce and abate emission violations. The hearing procedure
must not be mandatory but should be provided as a means of reconciling
compliance schedules and for public recourse in grievance cases.
-\.-'"-;jj . Recommendation 2.3 . Establish clear authority for
£j;-_--j the Air Sanitation Branch (or the Health Department)
.V-rij
/.;'* - -^.~*o issue a notice of violation which includes an
.'- !?;< , abatement order and without the mandatory requirement
V j . \.- '-..of hearing procedures. Changes in part (a) of
'r-fi : ' this section will require a change in part (b)
' . M . ' - ' " " '
\"| as well. ...
;-<< Section 322-70 Orders; Progress Reports
. Ifi -As a result of recommendations made for Section 322-69, Enforcement,
tj
:] part (a), orders to require corrective measures by a violator need not
. ;j be made "consequent to the hearing" if such hearing is not utilized.
* ' * * *
.! Recommendation 2.4 . Remove the phrase "consequent
'.']' t6 the hearing" from Section 322-70, Orders, Progress
; Reports to be consistent with Recommendation 2.3.
-------
19
. .
' ' .
Section 322-72 Penalty for Violation of Rules and Regulations
' The present penalty for violations of any air pollution control
rules or regulations stipulates a $500 fine, with each day of violation
' '
: constituting a separate offense. Violations must carry penalties
.J . severe enough to discourage violators from incurring the penalty as a
:"j cost of doing business which involves less expense than incorporating
' ! ' **
-'! control measures. For this reason, it is generally felt that the
1
^j maximum penalty provision be at least $1000 per day with each day of
^ violation a separate offense. (Some States now provide for civil
*j
t
:,.] penalties up to $10,000 per day.)
.1
j - «* '
:j Recommendation 2.5. Modify Section 322-72, Penalty
;1 '-. for Violation of Rules and Regulations, as amended, to
r '( .''".
'-i '''' establish a larger monetary penalty sufficient to
'
% discourage unjustifiable and frequent violations of any
'.»
"..' air pollution control rule or regulation.
. q Emergency Episodes
]
}i
|. The State agency does not have adequate authority to implement an
-; ^ emergency episode plan necessary for the protection of health and
'.-.] welfare. An acceptable Implementation Plan requires the authority for
,.-': the State agency to seek immediate abatement of those conditions which
create an air pollution episode in any or all parts of the State. The
, ' authority should eliminate any conflicts or unnecessary administrative
' '*
.'. "i
procedures which cause undue delay where immediate action is essential.
"i Further discussion of the emergency episode plan is found in the
.,."/
Engineering Section, page 48.
-------
20
' . " Recommendation 2.6. Obtain authority through
State legislation to implement emergency episode
procedures. This authority should be comparable to
Section 303 of the Clean Air Act, as amended (1970).
The Clean Air Amendments of 1970 have necessitated specific
inclusions to the State of Hawaii's enabling legislation of the
State is to carry out its responsibilities. This required legal
authority must be adopted so that the State can provide an approvable
Implementation Plan.
Recommendation 2.7. Obtain the folLowing provisions
as required by the Clean Air Amendments of 1970:
(1) Authority to require installation of equipment,
by owner or operator of stationary sources, to
monitor emissions and to conduct source tests.
«
(2) Authority (to the extent necessary to achieve and
maintain National Air Quality Standards) to adopt
land use and transportation control.
(3) Authority (to the extent necessary and practicable)
for periodic inspection and testing of motor vehicles
to enforce compliance with applicable emission standards.
REGULATIONS
The air pollution control regulations for Honolulu County (Public
Health Regulations, Chapter 3D and Maul County (PHR, Chapter 35) are
-------
21
seriously outdated and very limited in scope. The State must proceed
immediately to update existing regulations and develop additional
regulations as necessary to satisfy Implementation Plan requirements
and to protect and preserve air quality.
The State has not developed regulations for the counties of Kaui
and Hawaii. These counties contain sources of air pollution that' must
be controlled and abated. Furthermore, the regulations should be
designed .to prevent future air pollution problems. In view of the
inadequacy or non-existence of present regulations, the State must
enact a set of regulations applicable to the entire Air Quality Control
Region consistent with Implementation Plan requirements. The State will
also be required to possess and demonstrate the legal ability to
regulate, through control, prevention and abatement, all potential
sources of air pollution.
Recommendation 2.8. Develop and promulgate a set
of Statewide air pollution control regulations.
These regulations should reflect the latest control
technology .and must satisfy air quality needs in
accordance with Implementation Plan requirements.
The development and promulgation of air pollution regulations
should include, but not necessarily be limited to the following
categories:
-------
22
(A) Particulate Matter
(1) Visible Emissions
The present trend of new regulations is to require all
'j ..'-..
".'J . new sources to meet No. 1 Ringelmann or its equivalent
] opacity. As a part of this regulation existing sources
V ,.,.'
i . -. should be scheduled to meet the same standard within a 'time
"t * . y
..', - . period as specified by the agency, but no longer than three
'! '"'"
'i - . years.
^5 * .
": - Recommendation 2.9. Promulgate a regulation to
';] - . ..^^iimit visible emissions to a No. 1 Ringelmann and
,-i *
20 percent equivalent opacity for all new sources.
'". . '* ;. The regulation should include the provision that all
ij ,. existing sources comply within 3 years or a time to be
:i specified in the State implementation plan - whichever
[.'I is more stringent.
(2) Open Burning ' _...'..' v'v '-:» ' «- '
The State agency must have control over all open
burning operations. Exempted sources such as fire training
schools, disposal of hazardous materials, etc. should be
permitted only through direct agency approval. Agricultural
burning should not be exempted. (The problem of agricultural
burning as related to the process of sugar cane production is
unique to four areas of the United States- Puerto Rico,
Florida, Louisiana and Hawaii). Open burning of this nature
-------
';! 23
rv^ contributes significantly to Hawaii's total emissions of
;fcf|- particulates, carbon monoxide, hydrocarbons, and nitrogen
>-j oxides. Sulfur oxides emissions are considered to be
| negligible. Admittedly, alternative methods for the harvesting
-I
:'\ process are few in number; however, they do exist. Agricultural
-J . burning should be phased put through a timetable developed by
*$% the agency and submitted in the Implementation Plan.
7!
. !
iVi
3J& Recommendation 2.10. Promulgate a regulation to ban
"if i
r-| all open burning activities except as specifically
. ,-j approved by the agency. Agricultural burning should
£3g be phased out and not exempt from the regulation.
^-'r*
I (3) Incinerators
^
i
. ~J Incinerators have been shown to be significant contributors
J . to the air pollution problem in many cities. EPA-APCO has
!-'.;
-------
24
*i
"~&M
'W
existing municipal incinerators and future incineration
facilities to be constructed in the State. This requires a
well-designed multi-chamber or multi-stage combustion
incinerator. In many instances a scrubber or other control
device will be required to adequately control particulate
(primarily fly ash) emissions.
Recommendation 2.11. Promulgate an incinerator
regulation.
j~
(4) Fuel Burning Equipment
A particulate emission regulation must be developed to
control fuel burning equipment. The regulation should
emphasize control of the steam-electric generating plants
which presently have no control systems. The problem of black
smoke can be adequately corrected by improving combustion
techniques; however, oil-fired fuel burning equipment will
continue to emit a visible mist when sulfur content exceeds
0.5 percent by weight. EPA-APCO has proposed a regulation that
would limit the emission of particulate matter, from oil-fired
fuel burning equipment rated greater than or equal to 250
million BTU per hour heat input, to 0.025 pounds per million
BTU per hour. This regulation should provide the State of
Hawaii with adequate air quality protection and be.compatible
with the States image of a clean and healthy environment.
-------
.'"; 25
1
- - . ! . '
o.;;.j Recommendation 2.12. Promulgate an adequate
« !
'.:." -t^j ' regulation to control particulate emissions from
V & .<
- .~^G
:*; fuel burning equipment, with emphasis on oil-fired
"'^5 '
:" jj power plants.
":.:.";;":^ , C5) Process Equipment
'"'^
:f-^ - The process-weight or potential emission rate concept
:;S:-v'-'i has been proven to be an effective means of controlling
S^
," . $ most types of process emission sources. This restricts
:.';.;^
;: total particulate emission rates from industrial processes
' ;...t as a function of the process-weight rate. Process weight
' ?-'5 - ms*
is, generally, the total weight of all materials, except
> ; : gases, introduced into a process. This approach removes
., '; dilution as a means of circumventing emission standards and
""'_ _i
' -. ] ' it assures increasingly strict control of larger source
'V\
- . J .
operations.
./. ; Recommendation )A"\- Promulgate a process-weight
.i«v-'.-3
i-'-C'J
..':vl regulation to control industrial processes. The
' j
';..-;"; _ _, regulation should be modeled along the lines of the
~r~: V'3
'.:'-^: Los Angeles process-weight table. An alternate
";.-'": approach would be to develop specific process
'.-:
regulations, exhibiting comparable stringency to
:...'. the Los Angeles regulation, for major industries.
-------
26
(B) Gaseous Pollutants
The State of Hawaii does not presently have regulations
related to the control of gaseous pollutants, except for an outdated
sulfur dioxide regulation (Chapter 35, Section 7) applicable
to the county of Maui. National air quality standards will be
promulgated and each State must provide for "implementation,
maintenance and enforcement" of any and all such standards as
directed by the Clean Air Amendments of 1970. Hawaii, therefore,
j . must adopt regulations to control gaseous pollutants from
i
".; stationary and mobile sources to comply with National standards
'4
.) and to prevent deterioration of existing air quality.
1 . The combustion of residual fuel oil represents a principal
j
2 source of sulfur oxides which can be controlled through use of
low-sulfur fuel and/or flue-gas desulfurization. Furthermore,
j
j other gaseous pollutants including nitrogen oxides emissions from
..j the steam-electric utilities will require regulations to ensure
j
,:| adequate pollutant control.
]
*3 Motor vehicles are largely responsible for hydrocarbon,
j carbon monoxide, nitrogen oxides and lead pollution problems.
"1
.1
Such regulations as may be necessary should be established to
^ maintain Federal standards by inspection programs, annual tune-ups,
.!
! - retro-fitting of used vehicles, etc. The State must expand its
-J present legal authority concerning motor vehicles in order to
.1 successfully implement adequate regulatory action.
-------
.; 27
?4
;j TECHNICAL SERVICES
'";:1 ; '
I ' Functions commonly assigned to the technical service unit of an
-...] air pollution control agency include air quality monitoring, instrument
j calibration, laboratory operations, data processing and special studies.
The Technical Services Section of the Air Sanitation Branch should be
structured to perform these functions. In some cases, this will require
-
.' a transfer of the existing assignment of functions from the other
;?
1 sections to the Technical Service Section. The discussion which
:Vji follows includes recommendations to this effect.
*"-!
« The Technical Services Section presently has one supervisor
; Chemist IV and two Chemist Ill's to perform the required duties.
..-I Assistance will be provided by the Investigational and Enforcement Section
".!
;K' (EHS III) as needed to support air sampling activities on assigned
outer islands.
.4
! Air Quality Monitoring
'» '
;1 The air quality surveillance network should furnish measurements
"';'!
"-'.--! . . ....of the primary pollutants in order to provide: (1) long-term averages,
'V' (2) real time data for emergency episode periods, and (3) data as
needed for program planning and public information.
The Hawaii State Agency presently operates one permanent sampling
site which is located at the health department building in the City
of Honolulu. The station was designed to collect particulate matter
(hi-vol sampler); carbon monoxide, hydrocarbons and oxidants (continuous
-------
:-.,-m
,::< '-^ 3
28
instruments); sulfur dioxide and nitrogen oxides (bubblers). Mechanical
'difficulty experienced with continuous equipment has temporarily halted
monitoring for carbon monoxide and hydrocarbons, while the instrument
used for measuring oxidant levels has recently been discarded.
Oxidant levels, therefore, are presently being measured along with
-sulfur dioxide and nitrogen oxides using sequential samplers for a
K-i
single 30-minute period each morning. (During "adverse conditions",
sampling is extended throughout the morning into part of the
s
afternoon.) The present sampling frequency is inadequate for the
achievement of the basic objectives of an air quality surveillance
network.
''... Recommendation 3*1. Establish a continuous air
' '',
monitoring station in the City of Honolulu. This
would require repair of existing continuous
instruments (carbon monoxide and hydrocarbon) and
acquiring continuous instruments for the gaseous
pollutants - sulfur dioxide, nitrogen oxides, and oxidants,
Permanent sampling stations have been planned for the islands of
Maui, Kauai, and Hawaii. Sampling activities on these islands have
not been adequately planned with regard to sampling frequency or
duration, and the result has been the lack of any well-defined pollutant
problem areas. The agency needs to develop a sampling network plan
which is indicative of specific pollutant problems and establishes
-------
29
frequencies at which each pollutant needs to be monitored for meaningful
air quality data. It is thereby recommended that the State agency
focus initial attention on these emission sources suspected of having
a measurable impact on air quality. Suspected sources should be
quantified under a special sampling program to provide information
indicating areas where routine air monitoring activities may be
. .
necessary to satisfy implementation plan requirements for all primary
pollutants.
)'" t . . . ---.-<.
The summary table on page 30 recommends, initials sampling
activities that will assist the State agency in documenting air
quality sampling needs. Hi-vol samplers should be distributed in
areas of high population density. (Each hi-vol should be accompanied
with a sulfation plate.) Basic manual bubbler sampling equipment
should be made available to each of the three outer islands. Initial
oxidant studies should be conducted by obtaining one Mast ozone
instrument. This instrument has been chosen on the basis of its
relative simplicity and cost. It should be put into operation as
soon as possible so that the agency may search for strategic locations
of peak oxidant formations on each of the islands (Mauai, Kauai, and
Hawaii).
The establishment of a comprehensive air sampling network will
require both time and resources. However, the agency needs to obtain
valid air quality data from suspected areas of major pollutants as
soon as possible in order to satisfy requirements for an approvable
-------
AIR QUALITY SURVEILLANCE NETWORK
RECOMMENDED FOR THE STATE OF HAWAII
COUNTY
HONOLULU
KAUAI
MAUI
HAWAII
PARTICIPATES
Hi-Vols. S.I. Buckets
5 1
2
2
2 i
Gases ..'. ..:
CONTINUOUS
S02 CO NO OX HC
1 1 2a 11
lb
lb
b
BUBBLERS
(S02, NO, & N02)
2
lc
; ;':
:':' 2° ;'
PLATES
S04
5
2 '
2
0
2
Separate instruments for NO and N02- (one each)
'One instrument is to be utilized for special studies
%
'Special sampling projects
-------
-,. 1
. x.
31
Implementation Plan. The special studies should indicate those areas
of highest sampling priority. Eventually, information should be
available to represent all portions of the State to evaluate progress
being made in maintaining air quality standards.
Recommendation 3.2. Develop and implement a
*. plan for special air sampling projects. (Oil-fired
power plants should receive initial attention.) Use
the recommended sampling network provided by APCO in
the development of sampling activity plans.
^
Recommendation 3.3. Utilize the data obtained
..', from all special studies to set a priority in
" .;;., establishing air monitoring stations. The State
should plan to monitor compliance with air "
quality standards. Sampling frequencies (for mechanical
devices) and averaging times -(for continuous instruments)
must be dictated by the national ambient air quality
standards.
Laboratory Operations and Facilities
The central facility for laboratory operations is located at
the health department building in the City of Honolulu. The existing
staff of three chemists should be adequate to handle all necessary
analytical procedures in support of sampling activities. However,
-------
";-..: J£*-.i
'if.
.1- -~o
;* \ -_ -.1
"j
32
the burden of accumulating transportation expenses may make it desirable
to allow some analyses to be performed at facilities on the outer
islands. The major equipment necessary to establish only basic
analytical capabilities would include a colorimeter, reagents, a
balance, minimal glassware, a source of distilled water and a sink.
Analytical capabilities for oxidants should be provided only by the
central laboratory until studies made with the Mast ozone instrument
are able to justify the need for routine sampling of this pollutant
j
category.
All hi-vol particulate samples should be mailed to Honolulu for
analysis. A breakdown of total suspended particulate matter may
eventually be required and this procedure should not be duplicated
unnecessarily. . .-
Recommendation 3.A . Establish basic analytical
capabilities which could be handled by the EHS III
at facilities on the outer islands. Particulate samples
should be mailed to the central laboratory. Analytical
capabilities for oxidants should not be developed on
the islands until justified.
Instrument Calibration and Maintenance
The generation of valid data requires that all instruments be
properly maintained. This maintenance includes calibration at the
time of installation and on a routine basis therafter. The daily
-------
.. ;-^-J
?;j
.-'. 'A
-J
.. ^
33
*
operation of the continuous analyzers located at the health department
building can be performed by the chemists, and necessary calibrations
could be made by these individuals as well. Hi-vols, bubblers,
etc, distributed throughout the State, could be calibrated by periodically
sending the equipment back to the laboratory.
The existing functional statement for the Air Sanitation Branch
assigns the responsibility of instrument calibration to the Engineering
and Support Section. Changes should be initiated to transfer this
activity to the Technical Services Section.
Recommendation 3.5. Transfer the function of
instrument calibration from the Engineering and
Support Section to the Technical Support Section.
All calibrations should be performed by the
Honolulu laboratory group.
Data Processing and Analysis
The ultimate success of a sampling and information acquisition
program depends upon the utility of the data it produces. Utility
implies that data be summarized in an appropriate format and be
retrievable on a short-time, basis. The design of a sampling
network, a permit system and other record keeping operations must
be accompanied by the design of a system of data acquisition and
analysis that considers the flow of data and its uses.
-------
34
The agency needs to develop a data control format and have
immediate access to a data processing system. Mechanisms for data
reduction, storage, retrieval, and analysis must be an integral part
of any such system. The data processing system should be organized
to provide current summaries of air quality, emission, complaint
and meteorological data, as well as control actions. The correlation
and analyses of these data would provide information that can be used
for program planning, preparation of reports, development of further
control strategies and the release of information to other governmental
agencies and the interested public.
State funds have already been approved so that the agency may
purchase a programmable calculator. The agency also has access,
through the health department, to State computer facilities;
however, these facilities have not yet been used for air pollution
control. Basic data handling procedures could be handled by the
Technical Services Section, but the use of a computer would require
special programming assistance.
Recommendation 3.6. Purchase a calculator which
will supply the Air Sanitation Branch with adequate
data computation capability. Evaluate by uses of
available computer facilities to assist in a data
handling system. Centralize data processing activities
for'"the Branch in Technical Services Section.
-------
-;? 4
35
Recommendation 3.7. Develop the data processing
system to provide information comparable to the
periods required for any and all air quality standards.
The data analysis should provide the maximum concen-
trations for pollutants sampled and compute means and
standard deviations for all averaging times required.
All data should be expressed in metric units, preferably
in the SAROAD format.
.*
Meteorological Data
It is not expected that a significant degree of planning related
to urban modeling will be required for the State of Hawaii. Therefore,
meteorological data needs are expected to be relatively small. In a
few instances some special observations may be required in the vicinity
of major industrial or agricultural sources.
The Technical Services Section is responsible for providing
meteorological information, but the agency does not employ a meteorologist.
Local assistance with respect to air pollution climatology can be
obtained from meteorologists from the National Oceanic and
Atmospheric Administration (NOAA, formerly ESSA). Meteorological
observational data are available from various airports. Meteorological
assistance should be available to determine if these observations are
representative for program needs. Such assistance can be provided
by APCO or by contract with a local consulting firm.
-------
ill
1-1
36
Recommendation 3.8. Obtain any necessary meteorological
data from available sources within the State. The
Technical Services Section can then compile pertinent
data for publication. The limited amount of meteorological
assistance required can be provided by APCO or on a
contract basis with a local-consulting firm. '
-------
.; 37
.3 ENFORCEMENT
-1 .
i . - '
,S ...
'' The proposed Investigational and Enforcement Section is designed
to continuously monitor the progress of air pollution sources towards
- ij compliance by (1) investigating complaints, (2) conducting self-
'
.| initiated .inspection, (3) developing satisfactory compliance schedules.,
»--j an<* (^) performing compliance investigations.
'-i ' '
3 . Pending final approval, the Investigational and Enforcement Section
'2J)
^' will consist of five Environmental Health Specialists (EHS) qualified
.: . to perform not only enforcement-type activities but numerous engineering
" .' *
':; and technical service functions as well. The supervisory position will
" :.-^-^ '
be filled by an EHS IV, while subordinate positions will be filled
' "i
; by four EHS Ill-level personnel. Each EHS III is qualified to
':. operate the air sampling stations in cooperation with the Technical
-" .1 -'
' : Services Section, perform stack sampling with the Engineering and
;'(
! Support Section, and provide assistance and support in reviewing
..'
'';. plans and specifications. As a special function, these four positions
sp serve as secretaries for each of the county advisory air pollution
:-/j control associations.
ll - - - - - - - .
. ] To date, the major emphasis of the air pollution control program
.; has not been placed upon enforcement activities. Abatement aspects
.f
. -, of the control program thus far have generally been conducted on a
'."- small scale, informal basis. This lack of enforcement strength may be
^ attributable to the inadequacy of present State legislation. Iraprove-
; ments in the legislation, however, will be only part of a successful
enforcement effort. Adequate enforcement and regulations must be
supported by a carefully planned, well-executed program of abatement,
-------
.:-.J
-- 1
':$
1
.''i
.' ;:*!
".!
38
prevention and control of all potential air pollution sources.
Compliance Schedules
Guidelines for the development of State Implementation Plans
indicate that all sources of air pollution should display "prompt and
orderly progress" in obtaining compliance with ambient air quality
standards. The enforcement section should require, and assist when
necessary, all violators to develop and submit acceptable compliance
schedules indicating how and when sources will be controlled. The
agency has obtained schedules from "two or three major sources," but
schedules from all sources should be obtained to complete a successful
program.
Recommendation 4.1. Develop a compliance
scheduling procedure that can readily be employed
to negotiate source compliance schedules for meeting
the forthcoming emission regulations. Sources should
be made aware of their obligations and requirements.
The compliance schedule should require specific
dates for the completion of engineering evaluation
and design, purchase, installation and final approval
for operation.
-------
39
Formal procedures must be developed for carrying out enforcement
and compliance activities. These procedures should cover all aspects,
from initial detection to the legal recourse of the courts.
j The agency must have the assistance of legal counsel from the
;',^ State Attorney General's Office. A lawyer has been assigned to the
->V?1 .
- ^ State Department of Health; however, the Air Sanitation Branch has
:'.1
found little success in obtaining the assistance of the legal staff
in air pollution enforcement actions whenever the need has arisen.
If adequate legal counsel is not readily available to work directly
with the program, then aggressive enforcement action is not likely
to develop. v
Recommendation 4.2. Establish specific procedures,
with strict penalties, by which the Air Sanitation
Branch can effectively perform enforcement actions
against any violators who fail to provide and/or
adhere to acceptable control schedules and require-
ments. The agency must 'obtain adequate legal counsel
to support enforcement efforts.-
Violation Identification
'-1
' /
Most source compliance activities should be handled without hearings
or lengthy administrative procedures. Such procedures are cumbersome
and can cause undue delay where immediate action is desirable. The
agency has stated that many .small operations have been handled by "bluffing"
-------
40
.,.,. ,- ,>.. the owner or operator into compliance. The agency needs the strength
to handle obvious, and oftentimes, small violations without subjecting
each violation to a hearing as legislation presently requires.
Recommendation 4.3. Eliminate the need for routine
. hearings and administrative procedures by providing
' ' , tff. '
the agency with the authority to determine the initial
guilt of violators of open burning and visible
emission regulations. In such cases, on-site
citations should be issued.
The individuals working in the enforcement section must be qualified
to cite violators. For example, these people should be thoroughly
qualified'to make accurate visible emission readings based upon the Ringelmam
' Number or equivalent opacity. Training courses for enforcement personnel
I . should reflect current enforcement techniques and should include periodic
\ training for smoke reading. Smoke readers should be recertified every
i six months to retain expert qualifications.
----- --Recommendation 4.4. Provide training for all
: enforcement inspection personnel, including engineers.
Such training must include qualification (with
recertification semi-annually) for visible emission
reading. Training programs should also be provided
to support surveillance, inspection and enforcement
activities for gaseous control regulations.
-------
m
41
Important tools for air pollution detection and enforcement
include cameras, binoculars, scentometers, carbon monoxide detector
tubes, basic hydrocarbon detectors, stopwatches and maps. The agency
has some equipment which includes an old Polaroid camera which will
not take color photographs. The concept of equivalent opacity makes
it important and necessary that photographic equipment be capable of
making color photos. Each member of the enforcement staff should be
assigned a complete set of modern enforcement devices and equipment.
Recommendation 4.5. Assign a complete set of enforce-
ment equipment to each member of the enforcement section.
Each man would then be responsible for the maintenance
of equipment assigned to him.
Complaint Handling
;
The agency does not provide official service for handling
complaints after normal working hours or during weekends. In fact,
some complaints received during the course of the normal work day
have not been handled as promptly as desirable. In most cases when
a complaint is received on an island other than Oahu, it is handled
initially by a State District Health Officer on that island. A local
sanitarian handles the preliminary investigative phase and prepares
a report based upon his observations. In the past, the Air Sanitation
Branch's small staff prevented immediate follow-up on such reports.
-------
42
In some instances a period of a week or more would pass before action
..Trf was taken by the agency. Complaints initiated by a concerned public
'$
merit prompt action by the air pollution control agency. Prompt action
may require an on-site investigation or at least telephone contact to
discuss the problem. After-hour and weekend complaints can oftentimes
be handled by working through the local police and fire departments,
:;'M
-$ then key agency personnel could be contacted by these departments if
their services are required.
' ^ Recommendation 4.6. Develop a program that is more
* * *^5
^|| responsive to registered complaints. Coordinate
x-i after-hour and weekend complaint handling activities
^"J
'.-£?* . with local police and fire departments and provide
.'/
"'-'; . . home telephone numbers of key agency personnel.
:&~\ . Inform the public as to how complaints should be made
^ j during these periods.
Scheduled Inspections
Inspection activities are an important phase of an enforcement
program. Routine inspections are necessary for the surveillance of
all potential sources of air pollution in order to ascertain conformance
with regulatory requirements. Major sources should receive frequently
scheduled inspections, perhaps as often as every three months in
some instances, while smaller sources could be visited less frequently
-------
43
except where problem conditions are known to exist. The inspection
program can be integrated into the operation of the permit system as
soon as both activities are implemented. (See Engineering Section)
'£$ Recommendation 4.7. Establish and implement a plan
*?""
; "^ ..', . for scheduled inspections with priority given to
.-\ .-; major and problem sources. Develop, the program so that
:j - all potential pollution sources will be inspected
~M ""
,j " periodically to guarantee adequate compliance.
-------
44
' . . .. - . ENGINEERING
* -.» i i i MI
'
Engineering functions will be performed by the Engineering
and Support Section. The Section consists of an Engineer III, an
.
Ecologist (EHS III), and a Mechanical Engineer assigned to the State
program by the Federal Government. The APCO manpower model indicates
'
a need for the agency to fill additional positions to support engineering
activities. The manpower strength shown should ensure that these
responsibilities will be performed adequately and on a routine basis.
Recommendation 5.1. Evaluate the workload of the
existing engineering staff in order to determine
adequate manpower needs. The APCO manpower model has
'"--....
indicated those areas where needs may exist.-.
"' '" """ '"' "" ' . " '"
(See page 15)
Emission Inventory
'
The State's emission inventory dates back several years to a
' ....,.-- .-- - ...- - -i .. ..-.-
study compiled by the National Air Pollution Control Administration (now
APCO) as part of the Consultation Report for the Hawaii (Honolulu) Air
Quality Control Region. The data obtained using the "Rapid Survey
Technique" is largely representative of 1968, and the emission
estimates available from the technique describe the levels and
conditions during that year.
The emission inventory plays an important role in the overall air
pollution control program. It quantitates the air pollution problem
and, when used in conjunction with air quality data, can be an essential
-------
45
indicator of the degree of control necessary to achieve desired air
quality goals. The inventory helps to determine a priority schedule for
required abatement actions. Furthermore, the emission data, along with
air quality and meteorological data, will serve as a basis for determining
the acceptability of the control regulations portion of the implementation
plan. For these reasons, the development of a system which provides
for continuous updating and expansion of the emission inventory is
mandatory.
The existing inventory includes data from five major pollutants -
sulfur oxides, particulate matter, carbon monoxide, hydrocarbons and
nitrogen oxides. Standards for additional pollutants will require
emission data for those pollutants as a part of the emission inventory.
New sources, process equipment modifications and changes, improved
control equipment, and other important factors that change with time
can be reflected in the emission inventory only when it is maintained
as a continuous activity. The establishment of a permit system would
assist in providing the information necessary for an up-to-date,
comprehensive emission inventory.
Recommendation 5.2. Develop a system which would
provide for continuous updating and expansion of.
a comprehensive emission inventory. The system
must provide information for specific pollutant
emissions, operating conditions, control equipment, etc.
The implementation of a permit system supplies a
good, continuous source for much of the necessary
information.
-------
46
-.1
. ,v ,.:.J
Permit System
The Hawaii Air Pollution Control Law delegates specific power to
require permits prior to installation or operation of any activity
which may result in air pollution. The Air Sanitation Branch, instead,
began implementation of a relatively simple and now outdated registra-
tion system. The system was enacted under the advice of the State
Attorney General and because of the general opinion that the agency
lacked adequate engineering support at that time to maintain a more
sophisticated system. A registration system does not effectively
prevent new ?.i»ces of air pollution. On the other hand, a permit "
system that includes both a permit to construct and a permit to operate
provides an effective enforcement procedure to prevent and control all
*s '
sources of air pollution. The permit system gives the agency the
/-
power to review and approve plans, specifications, and data related
to the equipment or process. Furthermore, it provides the best
mechanism by which the agency can require adequate control equipment
and facilities on new construction and to make the best improvements
on existing installations. . . ...._..
The agency must carefully evaluate manpower needs within the
engineering section. Qualified manpower must be available to maintain
technical files, review and evaluate plans and specifications,
calculate types and quantities of pollutants generated and emitted from
sources and collected by control devices, and to determine control
device operating effectiveness. These are all important activities
-------
47
related to the operation of a permit system, which should be developed
by the agency. Once established, the permit system can be very
beneficial in the operation of other functional areas such as the
emission inventory, compliance schedules, inspections, emergency proce-
dures, etc.
Recommendation 5.3. Establish a permit system
which provides the agency with specific approval
power for the construction and operation of all
potential air pollution sources. Operating permits
should be issued on an annual basis with an initial
emphasis on significant sources.
Recommendation 5.4. Establish standard procedures
for plan review as a function of the permit system.
Recommendation 5.5. Design the permit system to
provide information necessary for the continuous
updating of the emission inventory, reevaluation of
control strategies, development of emergency procedures,
etc. Code all permits on a grid basis according to
geographical location.
Source Testing
Source testing is an essential capability necessary for
documenting certain compliance conditions and providing quantitative
data for emission factors, emission composition, etc. Source testing
-------
'-'!
'.-'3
-'1
~y
i
48
is perhaps the most accurate method of establishing the quantity of
pollutants being emitted from any given source. The agency appears
to have source test capability. The engineer on the staff has had
experience with stack sampling; however, the personnel who will assist
with this testing will require formal training.
Recommendation 5.6. Schedule training, as soon as
possible, for personnel involved in source testing
activities. Additional in-service training will be
necessary to further refine source sampling skills
and techniques.
The agency has only one stack sampling assembly on hand. In
order to collect duplicate samples without intermittent washing of
equipment it is necessary to have extra sets of sample boxes, probes
and glassware.
Recommendation 5.7. Purchase enough source testing
equipment to allow simultaneous duplicate samples to
be obtained.
The agency needs to develop standard procedures for source
sampling. Some industrial processes may require a modification of
the standard procedures to satisfy individual conditions; however,
the agency should have the authority to review and approve any
modifications.
-------
v: 49
"| Recommendation 5.8. Develop standard source testing
''! ' -'*.,-
j ; procedures and stipulate them as a part of emission
! ' -,'1 ' t
.3 regulations. Such testing procedures should be available
'l ._*'.'.
1 . to source management as the means for documenting
-;] . compliance with emission regulations.
.;* Emergency Plan .
The State air pollution control program does not have the authority
to implement emergency episode procedures for sudden and severe air
pollution problems. This authority is required for an approvable
implementatiion* plan.
The emergency episode plan should include episode criteria, a
detection and alert system, a detailed plan of action, a communication
.system, and a description of the utilization of available resources.
The emphasis of emergency episode planning should be on preventing or
at least minimizing the occurrence of high air pollutant concentrations
through ongoing compliance activities. The Engineering and Support
Section should develop these emergency procedures and be made
- responsible for the ultimate implementation of any necessary action.
Recommendation 5.9, Assign the responsibility for
developing and implementing an emergency episode plan
to the Engineering and Support Section.
] . Recommendation 5.10. Develop a plan, including
1 administrative procedures, for implementing air
pollution warning and alert procedures. All
-------
.-§^-3
'";"" ^j
- -i
-. i
50
persons affected by such plans should be notified
in advance of their responsibilities in emergency
situation.
Note: The above recommendations are based upon the premise that
the 'State will be required to establish emergency procedure plans.
This may not necessarily be the case - it is anticipated that requirements
and guidelines pertaining to each State will be documented in the near
future, and these will inform the State of Hawaii of its need for
such plans. In the meantime, it is known, however, that the State is
required to adopt adequate legal authority to implement the plans.
------- |