UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX 

75 Hawthorne Street 

San Francisco, CA 94105 

November 1, 2011

Mr. Rob Bamford, Chief

Bureau of 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 also 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) 947-4141.

Sincerely,

/s/

Matthew Lakin, Manager

Air Quality Analysis Office

Air Division

Enclosures

Comments on 2011 Network Plan for NDEP

Attachment A- Sample Site Specific Reporting Format

cc: Daren Winkelman, Monitoring Supervisor, BAQP
Comments 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 information was not 

included. Please ensure 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, Appendix E) is checked 

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 measured 

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 sites:

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 analysis 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 PM2.5 SPM sites in next year’s network 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. EPA 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 monitor 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 specific reporting requirements. If a reporting 

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

o See Attachment A for a suggested 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 for 

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 objective

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