UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX

75 Hawthorne Street

San Francisco, CA 94105

November 1, 2011

Mr. Rob Bamford, Chief

Bureau o f Air Quality Planning

Nevada Division of Environmental Protection

901 S. Stewart, Suite 4001

Carson City , NV 89701

Dear Mr. Bamford :

Thank you for your timely submittal of the 2011 Annual Monitoring Network Plan for the Nevada

Division of Environmental Protection (NDEP). EPA has reviewed the submitted document and found

that it meets the requirements set forth under 40 CFR Part 58.10. We al so appreciate your addressing

our comments to last year’s 2010 Network Plan.

If you have any questions regarding this letter or the enclosed comments , please feel free to contact me

at (415) 972

- 3851 or Elfego Felix at (415) 947

- 4 141

.

Sincerely,

/s/

Matthew Lakin, Manager

Air Quality Analysis Office

Air Division

Enclosure s

Comments on 2011 Network Plan for NDEP

Attachment A

- Sample Site Specific Reporting Format

cc: Daren Winkelman , Monitoring Supervisor, BAQPComments on 2011 Network Plan for NDEP

Please update next year’s network plan to reflect the following comments :

1. 40 CFR 58.10(b) identifies information that agencies must include for existing and proposed sites.

EPA is aware of the Manse school replacement site in Pahrump for which this info rmation was not

included. Please ensur e that an AQS account is established and all appropriate information for this

replacement site is documented in your 2012 network plan submission.

2. 40 CFR 58.10(b)(2) requires geographical coordinates be reported for each monitoring site. EPA

found that in some instances the coordinates reported for NDEP ’s sites are misreported by

approximately 800 meters (i.e. Manse site) . Please correct this for next year’s network plan and

ensure that this and all other siting information (as specified in 40 CFR 58, A ppendix E) is check ed

and updated for each of NDEP’s sites on an annual basis. The most up to date information should be

reflected in the annual network plan.

3. 40 CFR 58.10(b)(3) requires that the sampling and analysis method(s) for each parameter measur ed

be reported. EPA found that NDEP’s current method for reporting this requirement is either lacking

or unclear for multiple sites. In order to clarify and facilitate the reporting of this requirement,

please implement the following for each of your sit es:

o To report appropriate FRM/FEM sampling and analysis method(s), please refer to the tables

listed towards the end of the List of Designated Reference and Equivalent Methods . A link to

the latest List of Designated Reference and Equivalent Methods can be found at

http://www.epa.gov/ttn/amtic/criteria.html . For the sampling method, please report the

appropriate instrument name and model found under the table column labeled method . For

the an alysis method, please report the designation number found under the column heading

Designation No.

o For non

- FRM/non

- FEM instruments, please report the full instrument name and model as the

sampling method, and either describe or provide a reference to the analysis method used.

4. 40 CFR 58.16(e) requires the state to submit any portion or all of the SLAMS and SPM data to EPA

upon request. Please report at minimum the three most recent design values obtained from the

NDEP PM 2.5 SPM sites in next year’s netwo rk plan. Although this data may not be used for direct

comparison to the NAAQS nor for designations decisions, it may help to inform the decision of

whether or not NAAQS monitoring may be necessary , and its submission to EPA is required by

regulation

.

5. EP A found that NDEP’s format for reporting site specific information is somewhat unclear and may

benefit from a change in format. EPA recommends the following format changes be implemented

for each of the NDEP sites:

o Separate the site specific from the moni tor specific information.

o Use a gridded table to clearly differentiate from parameter to parameter.

o For each of the monitors at a given site, use a single column to report all information for that

monitor.

o Use a unique row for each of the monitor specifi c reporting requirements. If a reporting

requirement is not applicable t o a monitor, fill the cell in with N/A.

o See Attachment A for a s uggested Sample Site Specific Reporting Format that NDEP can

choose to follow.Attachment A

- Sample Site Specific Reporting Format

Site Name

[Give a broad overview of the site and rationale for its location. Include a description of site and purpose of monitoring f or

each pollutant. Photographs and a map of the site are encouraged.]

Site Specific Information

Site Name ABC Elementary

AQS ID XX

- XXX

- XXXX

GIS coordinates Lat & Long

Location In shed, on school, etc.

Address 123 Market Street, San Francisco, CA

County San Francisco

Dist. to road X meters

Traffic count Report AADT

Groundcover Paved, vegetated, etc.

Representative Area List MSA or CSA (indicate which)

Monitor Specific Information

Pollutant O3 PM2.5 (FEM)

Monitor obj ective

Spatial scale

Sampling method

Analysis method

Start date

Operation schedule

Sampling season

Probe height

Distance from supporting structure

Distance from obstructions on roof

Distance from obstructions not on roof

Distance from trees

Distance to furnace or incinerator flue

Distance between collocated monitors

Unrestricted airflow

Probe material

Residence time

Will there be changes within the next

18 months?

Is it suitable for comparison against

the annual PM2.5?

Frequency of flow rate verification for

manual PM samplers audit

Frequency of flow rate verification for

automated PM analyzers audit

Frequency of one

- point QC check

(gaseous)

Last Annual Performance Evaluation

(gaseous)

Last two semi

- annual flow rate audits

for PM monitors