AIR QUALITY MANAGEMENT

1001 East Ninth Street I P.O. Box 11130 I Reno, Nevada 89520

AQM Office: 775-784-7200 I Fax: 775-784-7225 I washoecounty.us/health

Serving Reno, Sparks and all of Washoe County, Nevada. Washoe County is an Equal Opportunity Employer.

March 5, 2015

Meredith Kurpius

Manager, Air Quality Analysis Office

U.S. Environmental Protection Agency, Region IX

75 Hawthorne Street, AIR-7

San Francisco, CA 94105

Subject: Proposed Modification to the Washoe County Health District, Air Quality Management 

Division Ambient Air Monitoring Network

Dear Ms. Kurpius:

Pursuant to 40 CFR 58.14, the Washoe County Health District, Air Quality Management Division 

(AQMD) requests review and approval for a modification to the existing ambient air monitoring 

network. The AQMD is proposing to:

1. Closure of the Galletti SLAMS (AQS ID 32-031-0022) including discontinuation of all 

monitors (CO, PM10, PM2.5, PM10-2.5, and meteorology); and 

2. Initiate a Special Purpose Monitor (SPM) for 18 months and establishing a State and 

Local Air Monitoring Stations (SLAMS) in the Spanish Springs area of southern Washoe 

County to monitor Ozone, PM10, PM2.5, PM10-2.5, and meteorology.

In November 2014, the Nevada Department of Transportation (NDOT) informed the AQMD of an 

emergency paving project requiring the Galletti SLAMS to be removed its current location. Final 

quality assurance verifications were conducted during the week of November 17, 2014. CO and PM 

data through the final verifications will be submitted to AQS. Data capture will not meet 75 percent 

for the October-December 2014 reporting period. As of March 1, 2015, the emergency paving project 

has not been completed. NDOT’s paving project and reconfiguration will make it extremely difficult 

to return to Galletti’s original location.

The proposed modifications are consistent with the AQMD 2010 Network Assessment and 2014 

Annual Network Plan. Attached are data demonstrations (Appendices A, B, C) and an Excel 

spreadsheet (Network Modification Request (2015-03-05).xlsx) to support AQMD’s proposal to close

Galletti. Additional case-by-case justifications for the closure of Galletti include proximity to trees

and NDOT’s “dirt pile” operation. PM10 and PM2.5 concentrations were impacted by the 

American/Rim (2013) and King (2014) Fires. These data are flagged in AQS with either 

Informational or Request to Exclude flags. An Exceptional Events Demonstration for the 

American/Rim Fires was submitted to EPA Region IX in 2014. A demonstration for the King Fire is 

expected to be submitted in Fall 2015. 
Subject: Network Modification Request 

Date: March 5, 201 5 

Page 2 of 14 

If you require additional information, feel free to contact me or Mr. Craig Petersen at (775) 784-7200. 

Sincerely, 

·-v~~ 

Daniel Inouye 

Monitoring and Planning Branch Chief 

cc: Katherine Hoag, EPA Region IX 

Craig Petersen, AQMD 

Jennifer Budge, Washoe County Regional Parks and Open Space 
Subject: Network Modification Request

Date: March 5, 2015

Page 3 of 14

Attachment A

40 CFR 58.14(c)(1) Criteria Test for the Galletti SLAMS with and without 

2013 American/Rim Fires Exceptional Events 
Subject: Network Modification Request

Date: March 5, 2015

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Year 1 Year 2 Year 3 Year 4 Year 5 Ave Max

5 Year Maximums with EE (2009-13)

Parameter

Averaging 

Times 2009 2010 2011 2012 2013 2009-13 Std. Dev. s

Student's t value 

(90% 

confidence)

Number of Data 

Values (n )

90% Upper CINAAQS80% NAAQSTest

CO (ppm) 1-hr 3.1 2.7 2.8 2.9 2.6 2.82 0.19 2.13 5 3.0 35 28.0 PASS

CO (ppm) 8-hr 2.6 2.3 1.9 2.1 2.2 2.22 0.26 2.13 5 2.5 9 7.2 PASS

PM10 (ug/m3) 24-hr 91 87 113 77 131 99.80 21.84 2.13 5 120.6 150 120.0 FAIL

PM2.5 (ug/m3) 24-hr 100.2 100.20 #DIV/0! 2.13 5 #DIV/0! 35 28.0 #DIV/0!

PM2.5 (ug/m3) Annual 11.5 11.50 #DIV/0! 2.13 5 #DIV/0! 12 9.6 #DIV/0!

Year 1 Year 2 Year 3 Year 4 Year 5 Ave Max

5 Year Maximums without EE (2009-13)

Parameter

Averaging 

Times 2009 2010 2011 2012 2013 2009-13 Std. Dev. s

Student's t value 

(90% 

confidence)

Number of Data 

Values (n )

90% Upper CINAAQS80% NAAQSTest

CO (ppm) 1-hr 3.1 2.7 2.8 2.9 2.6 2.82 0.19 2.13 5 3.0 35 28.0 PASS

CO (ppm) 8-hr 2.6 2.3 1.9 2.1 2.2 2.22 0.26 2.13 5 2.5 9 7.2 PASS

PM10 (ug/m3) 24-hr 91 87 113 77 117 97.00 17.26 2.13 5 113.4 150 120.0 PASS

PM2.5 (ug/m3) 24-hr 33.8 33.80 #DIV/0! 2.13 5 #DIV/0! 35 28.0 #DIV/0!

PM2.5 (ug/m3) Annual 9.5 9.50 #DIV/0! 2.13 5 #DIV/0! 12 9.6 #DIV/0!
Subject: Network Modification Request

Date: March 5, 2015

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Attachment B

Closure of the Galletti SLAMS including discontinuing CO, PM10, PM2.5, and PM10-2.5 monitoring
Subject: Network Modification Request

Date: March 5, 2015

Page 6 of 14

Carbon Monoxide

Discontinuation of CO monitoring is based on criteria in 40 CFR 58.14(c)(1), including the points 

below. 

1. The monitor has shown attainment during the previous five years (2009-2013), 

specifically:

a. The monitor has never exceeded the 1-hour NAAQS of 35 ppm, and

b. The monitor last exceeded the 8-hour NAAQS in 1991.

2. The monitor has a probability of less than 10 percent of exceeding 80 percent of the 

current 1-hour and 8-hour NAAQS.

Table 1

40 CFR 58.14(c)(1) Criteria Test

(2009-13)

Averaging 

Time

90% Upper CI

(ppm)

80% of NAAQS

(ppm) Criteria Met?

1-hour 3.0 28.0 Yes

8-hour 2.5 7.2 Yes

3. The monitor is not required in the:

a. EPA approved CO maintenance plan, nor 

b. Second-ten year maintenance plan submitted to EPA on November 7, 2014.

4. The monitor is not the only CO monitor in the Truckee Meadows CO maintenance area. 

CO monitoring will continue at four stations, including the Reno3 (32-031-0016) and 

Sparks (32-031-1005) stations which are approximately 1.5 miles west and 2.1 miles east 

respectively, of the Galletti SLAMS.

5. The requirements of Appendix D will continue to be met.

6. In addition, EPA identified trees that affect the monitor’s spatial scale (See Technical 

System Audit Report (September 4-6, 2013) August 2014, Finding 5). 

PM10

Discontinuation of PM10 monitoring is based on criteria in 40 CFR 58.14(c), specifically the case-bycase criteria and including the points below.

1. The monitor has shown attainment during the previous five years (2009-2013), 

specifically the monitor last exceeded the 24-hour NAAQS in 2005. (Note: One PM10

exceedance occurred in 2014 from the King Fire. An Exceptional Events Demonstration 

is expected to be submitted to EPA Region IX in Fall 2015.) 

2. The monitor does not have a probability of less than 10 percent of exceeding 80 percent 

of the current 24-hour NAAQS of 150 μg/m3. However, the monitor will pass this test if 

154 μg/m3 is used as the NAAQS. The monitor will also pass if Informationally flagged 

data from the 2013 American/Rim Fires are excluded from this test. 
Subject: Network Modification Request

Date: March 5, 2015

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Table 2

40 CFR 58.14(c)(1) Criteria Test

(2009-13)

90% Upper CI

(μg/m3)

80% of NAAQS

(μg/m3) Criteria Met?

24-hour 120.6 120.0 No

3. The monitor is not required in the:

a. “Serious” PM10 Attainment Plan submitted to EPA on August 5, 2002, , nor 

b. Redesignation Request and Maintenance Plan submitted to EPA on November 7, 

2014.

4. The monitor is not the only PM10 monitor in the Truckee Meadows PM10 non-attainment 

area. PM10 monitoring will continue at five stations, including the Reno3 (32-031-0016) 

and Sparks (32-031-1005) stations which are approximately 1.5 miles west and 2.1 miles 

east respectively, of the Galletti SLAMS.

5. Closure of the Galletti SLAMS is a recommendation in the 2010 Network Assessment.

6. The requirements of Appendix D will continue to be met.

7. In addition, EPA identified trees and a minor PM source that affect the monitor’s spatial 

scale (See Technical System Audit Report (September 4-6, 2013) August 2014, Findings 

5 and 6). 

8. In conjunction with the proposed Spanish Springs SPM/SLAMS, the overall balance of 

the PM network Area Served and Population Served distributions will be improved.

PM2.5

Discontinuation of PM2.5 monitoring is based on criteria in 40 CFR 58.14(c), specifically the case-bycase criteria and including the points below.

1. The monitor began sampling in 2013 and does not have a valid design value to compare 

against the 24-hour and annual PM2.5 NAAQS. (Note: PM2.5 concentrations were impacted 

by the American/Rim (2013) and King (2014) Fires. These data are flagged in AQS with 

either Informational or Request to Exclude flags. An Exceptional Events Demonstration for 

the American/Rim Fires was submitted to EPA Region IX in 2014. A Demonstration for the 

King Fire is expected to be submitted in Fall 2015.)

2. All geographic areas of Washoe County are currently designated as 

“Unclassifiable/Attainment” for the 24-hour and annual PM2.5 NAAQS, therefore the 

monitor is not required in any attainment nor maintenance plan.

3. The monitor is not the only PM2.5 monitor in the Truckee Meadows. PM2.5 monitoring 

will continue at two stations, including the Reno3 (32-031-0016) and Sparks (32-031-

1005) stations which are approximately 1.5 miles west and 2.1 miles east respectively, of 

the Galletti SLAMS. 

4. Closure of the Galletti SLAMS is a recommendation in the 2010 Network Assessment.

5. The requirements of Appendix D will continue to be met.

6. EPA identified trees and a minor PM source that affects the monitor’s spatial scale (See 

Technical System Audit Report (September 4-6, 2013) August 2014, Findings 5 and 6). 

7. In conjunction with the proposed Spanish Springs SPM/SLAMS, the overall balance of 

the PM network Area Served and Population Served distributions will be improved.
Subject: Network Modification Request

Date: March 5, 2015

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Attachment C

Initiation of an SPM/SLAMS in Spanish Springs to monitor Ozone, PM10, PM2.5, PM10-2.5, and 

Meteorology
Subject: Network Modification Request

Date: March 5, 2015

Page 9 of 14

Initiation of an SPM/SLAMS in the Spanish Springs area (Lazy 5 Regional Park)

Initiating a SPM/SLAMS station to monitor Ozone, PM10, PM2.5, PM10-2.5, and Meteorology is based 

on 40 CFR 58.14(b). The AQMD is requesting approval of the Spanish Springs SPM/SLAMS to be 

in conjunction with closure of the Galletti SLAMS. The points below support the AQMD request. 

1. An SPM/SLAMS station in the Spanish Springs area is a recommendation in the 2010 

Network Assessment.

2. In conjunction with the proposed Galletti SLAMS closure, the overall balance of the PM 

network Area Served and Population Served distributions will be improved.

3. In conjunction with the proposed Galletti SLAMS closure, the AQMD will maintain 

staffing and budgetary capacity. This is consistent with the “Zero-Sum Game” -

“Monitoring Network Assessments: Best Practices and Lessons Learned” presented at the 

2014 National Ambient Air Monitoring Conference.

4. AQMD has received preliminary approval from the Washoe County Regional Parks and 

Open Space Department to establish an SPM/SLAMS at the Lazy 5 Regional Park in 

Spanish Springs. AQMD is researching other requirements (i.e., Parks Commission 

approval, availability of power, right of entry, etc.).

5. The proposed location will not prohibit any planned future development included in the 

Lazy 5 Park Master Plan.
Subject: Network Modification Request

Date: March 5, 2015

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Figure 1
Subject: Network Modification Request

Date: March 5, 2015

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Proposed Spanish Springs SPM/SLAMS

Detailed Site Information

Site Name: Spanish Springs

AQS ID: 31-031-xxxx

Geographical coordinates: 39° 37.287’ N, 119° 43.124’ W

Location: North side of Lazy 5 Regional Park

Street address: 7200 Pyramid Way

Sparks, NV 89436

County: Washoe

Distance to road: 460 meters to Pyramid Hwy

Traffic count: 10,033 AADT (2011-2013)

(NDOT ATR 0311032 - SR445, 0.375 miles north of Sunset Spring Road)

Groundcover: Paved / Vegetated

Representative area: Reno-Sparks MSA

Figure 2

Proposed Spanish Springs Monitoring Station (looking north)
Subject: Network Modification Request

Date: March 5, 2015

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Proposed Spanish Springs SPM/SLAMS

PM10 PM2.5 PM10-2.5 Ozone

Site type Population 

Exposure

Population 

Exposure

Population 

Exposure

Population 

Exposure

Monitor type SLAMS SLAMS SLAMS SLAMS

Spatial scale Neighborhood Neighborhood Neighborhood Neighborhood

Sampling method Met One BAM 

1020

Met One BAM 

1020

Met One BAM 

1020 TAPI T400

Analysis method Beta Attenuation Beta Attenuation Beta Attenuation UV Photometry

Method code 122 170 185 087

Parameter code 81102 & 85101 88101 86101 44201

Parameter occurrence code 1 1 1 1

Start date 07/01/15 (est) 07/01/15 (est) 07/01/15 (est) 07/01/15 (est)

Operation schedule Continuous Continuous Continuous Continuous

Sampling season All year All year All year All year

Monitoring objective(s) NAAQS 

comparison

NAAQS 

comparison Research Support NAAQS comparison

Probe height 4.8 meters 4.8 meters 4.8 meters 4.0 meters

Height of obstruction not on roof 14.5 meters 14.5 meters 14.5 meters 14.5 meters

Distance:

from obstructions not on roof 30.5 meters 30.5 meters 30.5 meters 30.5 meters

from obstructions on roof n/a n/a n/a n/a

from trees

to furnace or incinerator flue n/a n/a n/a n/a

between collocated monitors n/a n/a n/a n/a

from supporting structure 2.0 meters 2.0 meters 2.0 meters 1.2 meters

Flow rate 16.7 l/min 16.7 l/min 16.7 l/min 720-880 cc/min

Unrestricted airflow 360 degrees 360 degrees 360 degrees 360 degrees

Probe material n/a n/a n/a Teflon

Residence time n/a n/a n/a 13 seconds

Proposed modifications within the 

next 18 months?

Is the monitor suitable for 

comparison against the annual 

PM2.5 NAAQS?

n/a Yes n/a n/a

Frequency of:

flow rate verification for manual 

samplers audit (PM) n/a n/a n/a n/a

flow rate verification for 

automated analyzers audit (PM)

Bi-weekly 

verifications and 

quarterly audits

Bi-weekly 

verifications and 

quarterly audits

Bi-weekly 

verifications and 

quarterly audits

n/a

one-point QC check (gaseous) n/a n/a n/a Bi-weekly (3 point)
Subject: Network Modification Request

Date: March 5, 2015

Page 13 of 14

Figure 3

Proposed Spanish Springs Monitoring Station

Fence and Shelter Footprint

Figure 4

Proposed Spanish Springs Monitoring Station

Distance to Roadway

Approx 100 feet

Building Height Approx 47.5 feet

Approx 460 meters
Subject: Network Modification Request

Date: March 5, 2015

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Figure 5

Proposed Spanish Springs Monitoring Station

Air Monitoring Shelter Description

Monitoring Station

1. Sani-Hut built shelter, 8’ x 12’, skid mounted.

2. 10 meter, T-135 telescoping Aluma Tower with building brackets (no guy wiring).

3. 100A, single-phase 120V/240V overhead power service.

4. Black iron security fence, 16’ x 24’ perimeter, 8’ in height, 3⁄4” square pressed point picket top.

Instrumentation (inside shelter)

1. Teledyne-API T400 ozone analyzer.

2. Met One BAM 1020 continuous PM10 monitor.

3. Met One BAM 1020 continuous PM2.5 monitor.

4. ESC 8832 data logger.

Instrumentation (on tower)

1. Met One 50.5H sonic anemometer.

2. YSI 700 ambient temperature sensor.

Instrumentation (on roof)

1. Met One BAM 1020 PM10 inlet.

2. Met One BAM 1020 PM2.5 inlet.

3. Avant Wireless broadband antenna.

Interior Heating/Cooling

1. Baseboard heater.

2. Window mounted A/C unit.