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

A QM 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 revi ew and approval for a modification to the existing ambient air monitoring network. The AQMD is proposing to:

1. C losure of the Galletti SLAMS (AQS ID 32

- 031

- 0022) including discontinuation of all monitors (CO, PM 10 

### , PM 2.5 

### , PM 10

- 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, PM 10 

### , PM 2.5 

### , PM 10

- 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 Nove mber 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, t he 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 p roposed modifications are consistent with the AQMD 2010 Network Assessment and 2014

Annual Network Plan. Attached are data demonstratio ns (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

. PM 10 

### and PM 2.5 

### 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 d emonstration 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 SpaceSubject: 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 EventsSubject: Network Modification Request

Date: March 5

, 2015 Page 4 of 14

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 CI NAAQS 80% NAAQS

Test

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 CI NAAQS 80% NAAQS

Test

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 Page 5 of 14



### Attachment B

Closure of the Galletti SLAMS including discontinuing CO, PM 10 

### , PM 2.5 

### , and PM 10

- 2.5 

### monitoringSubject: 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 Gallett i 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).

PM 10



### Discontinuation of PM 10 

### mo nitoring is based on criteria in 40 CFR 58.14(c)

, specifically the case

- by

case criteria and including the points below

. 1. The monitor has shown attainment during the previous five years (2009

- 2013), specifically t he monitor last exceeded the 24

- hour NAAQS in 2005 . (Note : One PM 10 

### 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. T he monitor does not have a probability of less than 10 percent of exceeding 80 perc ent

of the current 24

- hour NAAQS of 150 μ g/m 3



### . However, the monitor will pass this test if

154 μ g/m 3 

### 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 Page 7 of 14



### Table 2 40 CFR 58.14(c)(1) Criteria Test (2009

- 13) 90% Upper CI
( μ g/m 3 

### ) 80% of NAAQS
( μ g/m 3 

### ) Criteria Met ?

24

- hour 120.6 120.0 No

3. The monitor is not required in the:

a. “Serious” PM 10 

### 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 PM 10 

### monitor in the Truckee Meadows PM 10 

### non

- attainment

area. PM 10 

### monitoring will continue at five stations, including the Reno3 (32

- 031

- 0016) and Sparks (32

- 0 31

- 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 ad dition, 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 ba lance of the PM network Area Served and Population Served distributions will be improved.

PM 2.5



### Discontinuation of PM 2.5 

### monitoring is based on criteria in 40 CFR 58.14(c), specifically the case

- by

case 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 PM 2.5 

### NAAQS. (Note : PM 2.5 

### concentrations were impacted by the American/Rim (2013) and King (2014) Fires. These data are flagged in AQS wit h 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 o f Washoe County are currently designated as

“Unclassifiable/Attainment” for the 24

- hour and annual PM 2.5 

### NAAQS, therefore the monitor is not required in any attainment nor maintenance plan.

3. The monitor is not the only PM 2.5 

### monitor in the Truckee Meadows. PM 2.5 

### 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 recomme ndation 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 , Findin gs 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 Page 8 of 14



### Attachment C

Initiation of an SPM/ SLAMS in Spanish Springs to monitor Ozone, PM 10 

### , PM 2.5 

### , PM 10

- 2.5, 

### and MeteorologySubject: Network Modification Request

Date: March 5

, 2015 Page 9 of 14



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

Initiating a SPM/ SLAMS station to monitor Ozone, PM 10 

### , PM 2.5 

### , PM 10

- 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. A n SPM/ SLAMS station in the Spanish Springs area is a recommendation in the 2010

Network Assessmen t.
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 Washo e County Regional Parks and Open Space Department to establish a n 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 Page 10 of 14



### Figure 1Subject: Network Modification Request

Date: March 5

, 2015 Page 11 of 14



### 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 Page 12 of 14



### Proposed Spanish Springs SPM/SLAMS

PM 10 PM 2.5 PM 10

- 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

PM 2.5 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 metersSubject: Network Modification Request

Date: March 5

, 2015 Page 14 of 14



### 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 w iring).

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 PM 10 

### monitor.

3. Met One BAM 1020 continuous PM 2.5 

### 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 PM 10 

### inlet.

2. Met One BAM 1020 PM 2.5 

### inlet.

3. Avant Wireless broadband antenna.

Interior Heating/Cooling

1. Baseboard heater.

2. Window mounted A/C unit.