## APPENDIX &

Ambient Air Monitoring Network Plan

2012C.2 EPA February 28, 2013 Review Letter

ii 

## CONTENTS

C.1 AMBIENT AIR QUALITY NETWORK PLAN 2012

C. 2 EPA FEBRUARY 28, 2013 REVIEW LETTERC.2 EPA February 28, 2013 Review Letter

iii 

## AMB IENT AIR MONITORING NETWORK PLAN

2012

STATE OF NEVADA

DIVISION OF ENVIRONMENTAL PROTECTION BUREAU OF AIR QUALITY PLANNING

Contact: Daren Winkelman

Ambient Monitoring Program Bureau of Air Quality Planning 901 S. Stewart Street, Suite 4001 Carson City, Nevada 89701 (775) 687-9342 or (775) 687-6396 fax

Email: dwinkelman@ndep.nv.go vii 

### Table of Contents

List of Figures and Tables.................................................................. ii i

Acronyms and Abbreviations............................................................ iv

Over view..................................................................................... 1

G oals................................................................................ ........... 1

B ackground.................................................................................. 2

Ne twork Design....................................................................................................... 3

M inimum Monitoring Requirements................................................... 4

Chan ges in Monitoring Network......................................................... 5

Purpose of Monitors.............................................................. .......... 6

Over view of Monitored Parameters.................................................... 7

S ite Information.................................................................................................... 10

Appe ndix A..................................................................................... 28

App endix B............................................................................................ 29

Appe ndix C.................................................................................. 30iii 

### List of Figures

Figure 1

– Site Map......................................................................... 9

F igure 2

– Elko Grammar School................................................... .... 11

F igure 3

– West End Elementary School.............................................. 13

F igure 4

– Harvey’s Casino and Resort................................................ 15

F igure 5

–

Fernley Intermediate School.................................................... 17

Figure 6

– 3300 E. Fifth Street........................................................... 19

Figure 7

–

Church Site..................................................................... 21

Figure 8

–

Manse Elementary............................................................ 23

F igure 9

– 145 Glen Oaks Street......................................................... 25

Figure 10

– 8825 N. Linda................................................................. 27



### Li st of Tables

Table 1

– NDEP’s Ambient Air Monitoring Network.....................

...... .... 4

Table 2
- NDEP’s Minimum Monitoring Requirements by Pollutant............ 5iv 

### Acronyms and Abbreviations

CAA: Clean Air Act

AQS : Air Quality System

BAQP: Bureau of Air Quality Planning

BAM: Beta Attenuation Monitor

C FR: Code of Federal Regulations

CO: Carbon Monoxide

DCNR: Department of Conservation and Natural Resources

FEM : Federal Equivalent Method

FRM: Federal Reference Method

IMPROVE: Interagency Monitoring of Protected Visual Environments

NAAQS : National Ambient Air Quality Standard

NAC: Nevada Administrative Code

NDEP: Nevada Division of Environmental Protection

O 3 : Ozone

PM: Particulate Matter (2.5 or 10 microns)

SLAMS: State and Local Air Monitoring Station

SPM S: Special Purpose Monitoring Station

USEPA: United States Environmental Protection Agencyv 

### This Page Intentionally Left Blank1 

### Overview

The monitoring program of the Nevada Division of Environmental Protection (NDEP)

operates an ambient air quality monitoring network of gaseous and particulate pollutant

monitors. The monitors are located in small communities throughout rural Nevada. In the

met ropolitan areas of Reno and Las Vegas; the Washoe County District Health Department,

Air Quality Management Division and the Clark County Department of Air Quality and

Environmental Management operate and maintain their respective monitoring networks

separate from NDEP and submit their Network Plan independently to the United States

Environmental P rotection Agency (USEPA).

NDEP regulates air quality to protect public health and the environment. Monitoring data is a

crucial component of regulations used to determine compliance with the USEPA primary and

sec ondary air quality standards. Other important uses of these monitors include: support and

issuance of air quality forecasts, support of long-term health assessments, and tracking longterm air quality both to gauge effectiveness of emission control and abatement strategies and

to quantify accuracy of ambient pollutant monitoring.



### Goals

NDEP created an ambient air quality monitoring program to provide useful and accurate

information on air quality, which is used to evaluate the success of the State’s air quality

programs. The Clean Air Act of 1970, and subsequent amendments, defines air quality

standards f

or various air pollutants necessary to protect the public from injurious pollution

concentrations. Air pollution concentrations that exceed the National Ambient Air Quality

Standa rd (NAAQS) can cause a public health hazard, nuisance, annoyance, or damage to

flora, fauna and personal property.

The NAAQS, published by the USEPA, can be found in 40 Code of Federal Regulations

(CFR) Part 50

, which defines the levels of air quality necessary to protect human health and

welfa re. An area is considered to be in nonattainment for a pollutant if it has violated the

NAAQ S for that pollutant. The CFR includes procedures for evaluating measured air quality2

against the NAAQS. State air quality standards can be found in Nevada Administrative Code

(NAC) 445B.22097.



### Background

The State of Nevada has three jurisdictions which independently manage their own air

pr ograms as designated by statute: Department of Conservation and Natural Resources

(DC NR), Division of Environmental Protection (NDEP), Bureau of Air Quality Planning

(BAQP); Washoe County District Health Department, Air Quality Management Division; and

Clark County Department of Air Quality and Environmental Management.

State agencies that conduct ambient air monitoring using State and Local Air Monitoring

S tations (SLAMS) or Special Purpose Monitoring Stations (SPMS), must use Federal

Re ference Methods (FRM) or Federal Equivalent Methods (FEM) that comply with federal

quali ty assurance requirements listed in 40 CFR 58, Appendix A. In conjunction with the

Network Plan, a BAQP quality assurance plan was developed to form the framework for

planning, implementing, assessing and reporting work performed by the BAQP and for

implementing quality assurance and quality control protocols.

The Ambient Air Monitoring Program Quality Assurance Project Plan (QAPP) was

developed to address quality management as well as quality assurance. The QAPP defines the

policies, procedures, specifications, standards, and documentation necessary to: 1) provide

data of adequate quality to meet monitoring objectives, and 2) minimize loss of air quality

data due to malfunctions or out-of-control conditions. As part of the QAPP, the Quality

Management Plan (QMP) describes the organizational structure, functional responsibilities of

management and staff, lines of authority, and required interfaces between planning,

implementing, assessing and reporting activities involving environmental data operations.

Additionally, the BAQP has developed ambient monitoring guidelines in order to ensure that

ambient air quality data collected, at regulated facilities in the State, are of the highest quality

and c onform to federal requirements for quality assurance listed under 40 CFR 58.3

Ambient air quality monitoring data must be certified on an annual basis as accurate and

compl ete. The certification process begins with the complete submittal of all SLAMS data to

the federal Air Quality System (AQS) for the calendar year. Submittal of data into AQS for

20 10 has been accomplished. BAQP is planning on completing the entry of 2011 data into

AQS by the May 1, 2012, deadline. Precision and accuracy reports and certification of that

da ta should also be submitted within that time frame.



### Net work Design

There are currently nine ambient air quality monitoring stations in Nevada under the

jurisdiction of NDEP. Air quality monitoring is represented entirely by SLAMS. The ozone

moni toring conducted by NDEP is done on a seasonal basis from April 1 to October 31 of

e ach year. The EPA’s approval of a seasonal ozone monitoring schedule for NDEP is

documented in Appendix A. There are two meteorological stations, one in Carson City and

the other in P ahrump. These are used to confirm the local meteorological data from the

monitoring stations.

In addition to these three independent monitoring networks, air quality monitoring is

conducted through the Interagency Monitoring of Protected Visual Environments

(IMPROVE) network by the federal land management agencies. There are two IMPROVE

monitoring sites in Nevada, at the Jarbidge Wilderness area and Great Basin National Park,

Lehman Caves.

The following table shows the locations and types of monitors operated by NDEP.4 

### Table 1: NDEP’S Ambient A ir M onitoring Network

Location Ozone Carbon Monoxide PM10

Elko 1 (SLAMS)

Fallon 1 (SLAMS)

Stateline

- Harvey’s 1 (SLAMS)

Fernley 1 (SLAMS)

Carson City

- 5th Street 1(SLAMS)

Pahrump

- Church Site 1 (SLAMS)

Pahrump

- Manse Elementary 1 (SLAMS)

Pahrump

- Glen Oaks 1 (SLAMS)

Pahrump

- Linda Street 1 (SLAMS)

Total 3 1 5

SLAMS – State and Local Air Monitoring Station



### Minimum Monitoring Requirements

The USEPA provides minimum site requirements for ozone and particulate matter based on

metropoli tan statistical area (MSA) population. The NDEP’s air monitoring network meets

or, in most cases, exceeds the minimum network requirements. The monitors currently

require d in the NDEP monitoring network by the USEPA are located in Stateline (CO),

Carson City (O 3 ), Fallon (O 3 ), Fernley (O 3 ) and Pahrump (PM 10 ). The Stateline monitoring

site is a continuation of a highest concentration site started by the California Air Resources

Board (CARB). Through a Maintenance Plan with USEPA, monitoring and maintenance of

this site was assumed by NDEP in August 2006. The four PM 10 monitoring sites in Pahrump

are required through a Memorandum of Understanding (MOU) between NDEP, USEPA, Nye

County and the Town of Pahrump. Otherwise, according to 40 CFR Part 58 Appendix D:

Tables D -4 and D-5; sections 4.2, 4.3.2, 4.3.3, 4.4.2 and 4.5, additional monitoring for criteria

poll utants is not presently required. The following table outlines the minimum required

monitors with in the NDEP ambient air monitoring network.

.5



### Table 2: Minimum Monitoring Requirements by Pollutant

*Based on 40 CFR Part 58 Appendix D: Tables D-4 and D-5; sections 4.2, 4.3.2, 4.3.3, 4.4.2 and 4.5, additional monitoring for criteria pollutants is not presently required. Additionally, based on the 2008 Lead NAAQS Final Rule, 2010 SO 2 NAAQS Final Rule and the 2010 NO 2 NAAQS Final Rule, NDEP is not required to monitor for these criteria pollutants.



### Changes in Monitoring Network

Over the next 12 months, two significant changes will occur throughout the monitoring

network that will impact data submittal for the 2012 year. NDEP will be relocating the ozone

monitor currently located at the Carson City Maintenance Yard, to a comparable location 2.5

miles west at a vacant lot with access from Carson Street. This move is necessitated by the

city of Carson City re -purposing use of this location. Currently, there are plans and

agr eements for NDEP to begin moving equipment to this new site with objective to gain 9

months of collocated data until March 2013, which is the approximate date that the NDEP

must move from the Carson City Maintenance Yard. The USEPA will be notified when data

coll ection and submittal at the new monitoring site is commenced. The second change will

be t he removal of the Stateline CO monitor. The NDEP plans to discontinue CO monitoring Pollutant Minimum

# of

Monitors Required # of

Monitors

Active # of

Monitors

needed Location MSA/CSA County(ies) County Pop. (2009) Design

Values

Ozone 3 3 0 Carson City Carson City MSA Carson City 55,176 66 ppb (200 9

- 20 11 )

Fallon Fallon MSA Churchill 24,897 59 ppb (200 9

- 20 11 )

Fernley Rural Lyon 52, 641 64 ppb (200 9

- 20 11 )

CO 1 1 0 South Lake

Tahoe Sacramento

- Arden

Truckee

CSA Douglas 45, 464 3. 1 ppm (20 10

- 20 11 )

Lead * 0 0 0 N/A N/A N/A N/A N/A

SO2 * 0 0 0 N/A N/A N/A N/A N/A

NO2 * 0 0 0 N/A N/A N/A N/A N/A

PM10 4 5 0 Elko (1) Elko MSA Elko 47,896 0. 8 (200 9

- 20 11 )

Pahrump (4) Pahrump MSA/Las

Vegas

- Paradise

Pahrump CSA Nye 44,324 Manse =

2.5

Church = 0. 0

Glen Oaks

= N/A

Linda

Street =

0. 0 (200 9

- 2 0 11 )

Total 8 9 06

at Stateline (located at Harvey’s Resort and Hotel on Hwy 50) by June 30, 2012. The NDEP

concludes that 33 years of clean data, all of it under 80 percent of the NAAQS and most

rec ently at 34 percent, with on-going downward trends is sufficient evidence of continued

attainment through 2024 and satisfies 40 CFR 58.14 requirements for discontinuance.

In 2011, NDEP was informed that we had to relocate our PM 10 monitor located at the Manse

School in Pahrump due to the school closing. In February 2011, NDEP submitted a letter to

the EPA requesting approval to relocate the monitor. In March of 2011, NDEP received

approv al to move the existing monitor to the Nye County School District building. However,

the Pahrump School District found a new use for the school allowing NDEP to remain at the

existing site. At this time, NDEP will continue to monitor at the Manse School. If needed,

NDEP has access to the Nye County School District building for our back-up site.

For the next year, NDEP will be evaluating the need to establish a PM 2.5 monitoring network.

Over the next five years, through 2017, NDEP will evaluate our current network to determine

if an y new sites or monitors need to be added to the existing monitoring network.



### Purpose of Monitors

The purpose of the Nevada Air Monitoring Network is to provide useful and accurate

information on air quality, which is used to evaluate the success of the State’s air quality

programs. To accomplish this task, the NAAQS is used to identify the criteria pollutants: CO

(Carbon Monoxide), Pb (Lead), NO 2 (Nitrogen Dioxide), O 3 (Ozone), particulate matter

(PM 10 and PM 2.5 ), and SO 2 (Sulfur Dioxide). Measuring pollutant concentrations in outdoor

air and comparing the measured concentrations to corresponding standards help to classify

ambi ent air quality status of an area as either attainment or nonattainment. The NAAQS is

broke n down into primary and secondary standards. Primary standards are those established

to protect publ ic health. Secondary standards are those established to protect the public

welfare from adverse pollution effects on soils, water, vegetation, man-made materials,

anim als, weather, visibility, climate, property, and the economy. The scientific criteria upon

which the stand ards are based are reviewed periodically by the USEPA, who may reestablish

or change the standards according to its findings.7

A pollutant measurement that is greater than the ambient air quality standard for its specific

averaging time is called an exceedance. This is not necessarily a synonym for a violation; for

each pollutant there are specific rules about how many exceedances are allowed in a given

time pe riod before a pattern of exceedances is considered to be a violation of the NAAQS. A

viola tion may result in regulatory action to clean-up the area’s air. Exceptions are made to

a llow for certain limited exceedances of the standard that may occur, for example, during an

unusual we ather pattern or wildfire (exceptional events). Regulatory action is typically

reserved for cases where the exceedances are too large or too frequent.

Historically, ambient air quality monitoring by BAQP has looked at trends in air quality to

aid in the local planning process. Traffic, wood burning stoves, and growth related activities

have prompted air quality monitoring in specific areas around the State. Data from these sites

has led to public education and outreach to communities identifying the potential health

effects caused by air pollutants in the environment. Ordinances controlling surface area

disturbances and other related activities that produce dust have also been implemented with

the help of the monitoring sites.



### Over view of Monitored Parameters

Carbon Monoxide (CO)

CO is a poisonous gas that, when introduced into the bloodstream, inhibits the delivery of oxygen to body tissue. The health risk is greatest for individuals with cardiovascular disease.

Ozone (O 3 )

Gr ound -level ozone, or photochemical smog, is not emitted into the atmosphere as ozone, but rather is formed by the reactions of other pollutants. The primary pollutants entering into this reaction, VOCs and oxides of nitrogen, create ozone in the presence of sunlight. Ozone is a strong irr itant of the upper respiratory system and also causes damage to crops.

Particulate Matter (PM 10 )

Particulate matter with an aerodynamic diameter of 10 microns or less is emitted from

tra nsportation and industrial sources. Exposure to particle pollution is linked to a variety of significant health problems ranging from aggravated asthma to premature death in people with heart and lung disease.8

Fine Particulate Matter (PM 2.5 )

Fine particulate matter with a diameter of 2.5 microns or less is created primarily from industrial pr ocesses and fuel combustion. These particles are breathed deeply into the lungs. Exposure to particle pollution is linked to a variety of significant health problems ranging from aggravated asthma to premature death in people with heart and lung disease.9 

### Site Map
Figure 1 : A map showing the locations of the monitoring stations maintained in NDEP’s network.

__________________________ 1 Map template from:
http://geology.com/state-map/maps/nevada-county-map.gif Carson City

Stateline

Pahrump Elko

Fernley

Fallon10



### Elko: Detailed Site Information

Prior to 1992 the location for this sampler was the fire station at 723 Railroad Street (ID #32- 007 -003) in a commercial

area. In November of 1992 this continuous PM 10 monitoring site was re located to the roof of the State offices at 850 Elm Street in a predominantly residential area. The monitoring objective was to determine typical concentration/population oriented. The manual sampler was replaced with a continuous (TEOM) PM 10 monitor in December 1998. In September 2008, the TEOM monitor was closed and a new BAM 1020 monitor was sited at the Elko Grammar School #2.

Pollutant PM10 /81102 Monitor Objective Typ. Conc./Population Oriented Spatial Scale Neighborhood Sampling Method Met One BAM

- 1020 Analysis Method EQPM

- 0798

- 122

Start Date 09/25/2008 Operation Schedule Continuous Sampling Season All Year Probe Height 2.6 Meters Dist. fm. supporting structure Vertical Distance =1.2 meters

Dist. fm. obstructions on roof N/A

Distance fm. trees 27 Meters

Distance to furnace or incinerator flue N/A

Unrestricted airflow 360 degrees

Probe material N/A

Residence time N/A Changes in the next 18 months? No Suitable for PM 2.5 comparison? N/A Frequency of flow rate verification Monthly Frequency of one point QC check (gaseous) N/A Last Annual Performance Evaluation (Gaseous) N/A

Last two semi

- annual flow rate audits for PM 12/12/11

05/02/2012 Site Name Elko AQS ID 32

- 007

- 0005

GIS Coordinates Lat +40.838350 Long

- 115.766029

Location Elko Grammar School #2

Address 1055 7 th Street County Elko

Distance to Road 18 Meters

Traffic Count 1400 AADT (2009) Station #0070203

Groundcover Asphalt Representative Area Elko MSA11



### Figure 2 : Elko Grammar School #2, 1055 7th Street

, Elko, NV. PM 10 Monitor12



### Fallon: Detailed Site Information

The ozone monitoring site at 280 South Russell Street is at the West End Elementary School in a residential neighborhood that may be affected by agricultural operations surrounding the City of Fallon. The monitoring objective is to determine typical concentration/population orientation. PM 10 sampling commenced at this site in May 1993 and was discontinued at the end of June 1998. Monitoring for ozone began in October 1999 as an ozone transport site downwind of Reno and Fernley

Pollutant O3 /44201 Monitor Objective Typ. Conc./Population Oriented Spatial Scale Neighborhood Sampling Method Teledyne API Model 400E Analysis Method EQOA

- 0992

- 087

Start Date 10/01/1999 Operation Schedule Seasonal Sampling Season April thru October Probe Height 3.2 Meters

Dist. fm. supporting structure 1 meter from wall

Dist. fm. obstructions on roof N/A

Distance fm. Trees Greater than 10 meters

Distance to furnace or incinerator flue N/A

Unrestricted airflow 180 Degrees

Probe material Teflon

Residence time 10 seconds Changes in the next 18 months? No Suitable for PM 2.5 comparison? N/A Frequency of flow rate verification N/A Frequency of one point QC check (gaseous) Semi

- monthly Last Annual Performance Evaluation (Gaseous) 09/22/2011

Last two semi

- annual flow rate audits for PM N/A Site Name Fallon AQS ID 32

- 001

- 0002

GIS Coordinates Lat +39.472471 Long

- 118.783624

Location West End of Elementary School

Address 280 South Russell Street County Churchill

Distance to Road 65 Meters

Traffic Count 410 AADT (2009) Station #0010135

Groundcover Dirt and Gravel Representative Area Fallon MSA13



### Figure 3 : West End Elementary School, 280 S. Russell Street

, Fallon, NV. Ozone

Monitor14



### Harvey’s Casino and Resort: Detailed Site Information

This is a “micro-scale” monitoring site for carbon monoxide in the core of the Stateline casino hotel area at Lake Tahoe. The site is designed to monitor the highest CO concentrations at Lake Tahoe, and is, taken to be representative of the California and Nevada sides of the south shore casino district. Monitoring at this site began in October 1999 and was previously conducted by the California Air Resources Board by multi-agency cooperative agreement. Starting in July of 2006, NDEP took over the monitoring responsibility for this site under a maintenance agreement with EPA.

Site Name Harvey’s Casino and Resort AQS ID 32

- 005

- 0009

GIS Coordinates Lat +38.960579 Long

- 119.941351

Location 1 st Level of parking garage facing HWY

Address Stateline NV 89449 County Douglas

Distance to Road 9 Meters

Traffic Count 24,000 AADT (2009) Station # 0050044

Groundcover Paved, asphalt and grass Representative Area Sacramento

- Arden Arcade

- Truckee CSA or rural MSA

Pollutant CO/42101 Monitor Objective Highest Concentration Spatial Scale Micro Sampling Method API Teledyne 300M Analysis Method N/A

Start Date 10/01/1999 Operation Schedule Continuous Sampling Season All Year Probe Height 2.5 Meters Dist. fm. supporting structure 1 Meter Horizontally

Dist. fm. obstructions on roof N/A

Distance fm. trees 4 Meters

Distance to furnace or incinerator flue N/A

Unrestricted airflow 180 Degrees

Probe material Teflon

Residence time 5 Seconds Changes in the next 18 months? Yes (Discontinuation)

Suitable for PM 2.5 comparison? N/A Frequency of flow rate verification N/A Frequency of one point QC check (gaseous) Semi

- monthly Last Annual Performance Evaluation (Gaseous) 03/26/2012

Last two semi

- annual flow rate audits for PM N/A15



### Figure 4 : Harvey’s Casino and Resort Lake Tahoe NV. CO Monitor16



### Fernley Intermediate School: Detailed Site Information

Ozone monitoring is done at the Fernley Intermediate School which is located at 320 Hardie Lane. This is an area of mainly residential and agricultural use. There has recently been a large growth of industry both upwind and downwind of this site. Monitoring for PM 10 at this site commenced on May 1995, to determine the agricultural and industrial source impacts and population exposure. PM 10 sampling was discontinued in November 1998. Ozone monitoring began at this site July 2007. However, ozone monitoring (SPMS) was previously conducted at the Fernley Volunteer Fire Department starting in October 1997 and discontinued on October 2003.

Site N ame Fernley AQS ID 32

- 019

- 0006

GIS Coordinates Lat +39.602787 Long

- 119.247741

Location Fernley Intermediate School

Address 320 Hardie Lane County Lyon

Distance to Road 119 Meters

Traffic Count 1300 AADT (2009) Station # 0190119

Groundcover Paved, cement, gravel and dirt Representative Area Rural (Micropolitan Statistical Area)

Pollutant O3/44201 Monitor Objective Typ. Conc./Population Oriented Spatial Scale Urban Sampling Method Teledyne API Model 400E Analysis Method EQOA

- 0992

- 087

Start Date 07/06/2007 Operation Schedule Continuous Sampling Season April to October Probe Height 7 Meters Dist. fm. supporting structure Vertical Distance above 2.1 Meters

Dist. fm. obstructions on roof N/A

Distance fm. trees 15 Meters

Distance to furnace or incinerator flue N/A

Unrestricted airflow 360 Degrees

Probe material Teflon

Residence time 4 Seconds Changes in the next 18 months? No Suitable for PM 2.5 comparison? N/A Frequency of flow rate verification N/A Frequency of one point QC check (gaseous) Semi

- monthly Last Annual Performance Evaluation (Gaseous) 09/22/2011

Last two semi

- annual flow rate audits for PM N/A17



### Figure 5 : Fernley Intermediate School, 320Hardie Lane Fernley NV PM

2.5/Ozone Monitor18



### 3300 E. 5 th 

### Street: Detailed Site Information

This site is located at 3300 East Fifth Street near the Carson City Public Works Department maintenance yard in a transition area, adjacent to wetlands, the City yard, sewage treatment plant, residential neighborhood and the new highway extension of US 395. The pollutants monitored included carbon monoxide and ozone (through 1989) and PM 10 (March 1991- February 1997). The monitoring objective is to determine typical concentration/population oriented. In 2007, an existing meteorological station was restarted, and as previously stated, the ozone monitor from Long Street site was relocated to East Fifth Street. At the end of 2009, the PM 2.5 was relocated to this monitoring site.

Pollutant Ozone/44201 Monitor Objective Typ. Conc./ Population Oriented

Spatial Scale Neighborhood Sampling Method Teledyne API Model 400E Analysis Method EQOA

- 0992

- 087

Start Date 1/1/1989 Operation Schedule April

– October Sampling Season Seasonal Probe Height 10 Meters Dist. fm. supporting structure Vertical distance above 7 meters

Dist. fm. obstructions on roof N/A

Distance fm. trees N/A

Distance to furnace or incinerator flue N/A

Unrestricted airflow 360 Degrees

Probe material Teflon

Residence time 6 Seconds Changes in the next 18 months? Yes Suitable for PM 2.5 comparison? N/A Frequency of flow rate verification N/A Frequency of one point QC check (gaseous) Semi

- monthly

Last Annual Performance Evaluation (Gaseous) 9/28/2011

Last two semi

- annual flow rate audits for PM N/A Site Name East 5 th . Street AQS ID 32

- 510

- 0002

GIS Coordinates Lat +39.167247 Long

- 119.731702

Location Carson City

Address 3300 East 5 th Street County Carson

Distance to Road 10 Meters

Traffic Count 3,500 AADT (2009) Station #0250116

Groundcover Dirt

– Asphalt Parking Lot Representative Area Carson City MSA19



### Figure 6: 3300 E. Fifth Street Carson City, NV Ozone/Met Site20



### Church: Detailed Site Information

The Church Site began operation in 2004 to complement the existing three other sites in the Pahrump monitoring network. Monitoring is accomplished with a continuous beta attenuated monitor located in the southeast corner of the Catholic Church. This site represents the southern-most monitoring in Pahrump Valley. The monitoring objective of this site is a significant source of PM 10 . The surrounding area represents residential with little commercial, some native desert with a mix of dirt and paved roads.

Site Name Church
AQS ID 32

- 023

- 0013

GIS Coordinates Lat + 36.159639 Long

- 115.996263

Location Pahrump

Address 781 E. Gamebird County Nye

Distance to Road 100 Meters

Traffic Count 1,100 AADT (2009) Station #0230010

Groundcover Desert Representative Area Pahrump MSA; Las Vegas

– Paradise

– Pahrump MSA

Pollutant PM10/81102 Monitor Objective Significant Sources

– Dry lake bed 6 miles

to the south

Spatial Scale Urban Sampling Method Met One BAM 1020 Analysis Method EQPM

- 0798

- 122

Start Date 2/14/2004 Operation Schedule Continuous Sampling Season All Year Probe Height 4 Meters Dist. fm. supporting structure Vertical distance above 2 meters

Dist. fm. obstructions on roof N/A

Distance fm. trees 50Meters

Distance to furnace or incinerator flue N/A

Unrestricted airflow 360 Degrees

Probe material Aluminum

Residence time N/A Changes in the next 18 months? No Suitable for PM 2.5 comparison? N/A Frequency of flow rate verification Monthly Frequency of one point QC check (gaseous) N/A

Last Annual Performance Evaluation (Gaseous) N/A

Last two semi

- annual flow rate audits for PM 11/3/2011

5/7/201221



### Figure 7 : Church Site, 781 E. Gamebird Pahrump, NV PM 10 Monitor22



### Manse Elementary: Site Detailed Information

The Manse site represents the monitoring objective for highest concentrations of PM 10 in Pahrump. This site replaces the Community Pool site, which at the time it was operating, represented the highest concentrations of PM 10 in Pahrump. Located at 1020 E. Wilson Road, the Manse Elementary site is located on the roof of the school and monitors for PM 10 using the continuous beta attenuation monitor. The area adjacent to this site represents mostly commercial, some residential, and is adjacent to the busiest activity area of Pahrump. This site is located downwind from residential construction developments that have cleared large parcels of ground for building, as well as agricultural areas that cultivate large areas of farm-ground and raise livestock. Roads surrounding this site are both paved and dirt.

Site Name Manse Elementary AQS ID 32

- 023

- 0014

- 81102

- 1

GIS Coordinates Lat +36.212787 Long

- 115.994802

Location Pahrump

Address 1020 E. Wilson Road County Nye

Distance to Road 50 Meters

Traffic Count 11,000 AADT (2006 ) Station #023000 6

Groundcover Gravel Schoolyard Representative Area Pahrump MSA; Las Vegas

– Paradise

– Pahrump MSA

Pollutant PM10/81102 Monitor Objective Highest Concentrations Spatial Scale Neighborhood Sampling Method Met One BAM 1020 Analysis Method EQPM

- 0798

- 122

Start Date 11/17/2005 Operation Schedule Continuous Sampling Season All Year Probe Height 3.0 Meters Dist. fm. supporting structure Vertical distance above 1 meter

Dist. fm. obstructions on roof N/A

Distance fm. trees 10 Meters

Distance to furnace or incinerator flue N/A

Unrestricted airflow 360 Degrees

Probe material Aluminum

Residence time N/A Changes in the next 18 months? No Suitable for PM 2.5 comparison? N/A Frequency of flow rate verification Monthly Frequency of one point QC check (gaseous) N/A

Last Annual Performance Evaluation (Gaseous) N/A

Last two semi

- annual flow rate audits for PM 11/3/2011

5/7/201223 

### Figure 8 : Manse Elementary, 1020 E. Wilson Road Pahrump, NV PM 10 Monitor24



### Glen Oaks: Site Detailed Information

The Willow Creek site was started in 2003 and was located at 1500 Red Butte on the roof of a building in which irrigation equipment for the golf course is housed. The monitoring objective of this site was to measure typical concentrations/population oriented of PM 10 using the beta attenuated monitor. The surrounding area adjacent to this site is fairway/golf course and residential structures. Due to closure of the golf course, the Willow Creek site was relocated to the Glen Oaks sewer treatment plant in 2009. The Glen Oaks site is a short distance away from the existing golf course site and the monitoring objective did not change.

Site Name Glen Oaks AQS ID 32

- 023

- 0012

GIS Coordinates Lat +36.193469 Long

- 116.007584

Location Pahrump

Address 145 Glen Oaks St. County Nye

Distance to Road 200 Meters

Traffic Count 1,100 AADT (2009) Station #0230010

Groundcover Grass /Gravel Representative Area Pahrump MSA; Las Vegas

– Paradise

– Pahrump MSA

Pollutant PM10/81102 Monitor Objective Typ. Conc./ Population Oriented Spatial Scale Neighborhood Sampling Method Met One BAM 1020 Analysis Method EQPM

- 0798

- 122

Start Date 11/20/2003 Operation Schedule Continuous Sampling Season All Year Probe Height 6.0 Meters Dist. fm. supporting structure Vertical distance above 2 meters

Dist. fm. obstructions on roof N/A

Distance fm. trees 12 Meters

Distance to furnace or incinerator flue N/A

Unrestricted airflow 360 Degrees

Probe material Aluminum

Residence time N/A Changes in the next 18 months? No

Suitable for PM 2.5 comparison? N/A Frequency of flow rate verification Monthly Frequency of one point QC check (gaseous) N/A Last Annual Performance Evaluation (Gaseous) N/A

Last two semi

- annual flow rate audits for PM 11/3/2011

5/7/201225



### Figure 9 : 145 Glen Oaks St.

, Pahrump, NV PM10 Monitor26



### Linda Street: Site Detailed Information

The Linda Street site was started in 2003 and is located at 8825 North Linda Street. The beta attenuated monitor is located on the roof of an old railroad box car and represents not only the northern-most site in the Pahrump monitoring network, but the most rural area. There is some residential surrounding this site, but mainly native desert vegetation with little or no surface disturbances. The monitoring objective for this site is general background levels of PM 10 in Pahrump.

Site Name Linda Street
AQS ID 32

- 023

- 0011

- 81102

- 1

GIS Coordinates Lat +36.349408 Long

- 116.031976

Location Pahrump

Address 8825 N. Linda County Nye

Distance to Road 20 Meters

Traffic Count 2,2 00 AADT (2008) Station #0230008

Groundcover Desert Representative Area Pahrump MSA; Las Vegas

– Paradise

– Pahrump MSA

Pollutant PM10/81102 Monitor Objective General Background Spatial Scale Urban Sampling Method Met One BAM 1020 Analysis Method EQPM

- 0798

- 122

Start Date 5/3/2003 Operation Schedule Continuous Sampling Season All Year Probe Height 6.7 Meters Dist. fm. supporting structure Vertical distance above

roof 3 meters

Dist. fm. obstructions on roof N/A

Distance fm. trees 10 Meters

Distance to furnace or incinerator flue N/A

Unrestricted airflow 360 Degrees

Probe material Aluminum

Residence time N/A Changes in the next 18 months? No Suitable for PM 2.5 comparison? N/A Frequency of flow rate verification Monthly Frequency of one point QC check (gaseous) N/A Last Annual Performance Evaluation (Gaseous) N/A

Last two semi

- annual flow rate audits for PM 11/3/2011

5/7/201227



### Figure 10 : 8825 N. Linda Pahrump, NV PM 10 Monitor28 

### Appendix A. Ozone Seasonality Approval Letter29 

### Appendix B. Manse PM10 Monitor Relocation Approval30 

### Appendix C.

Comment Submittal Information

The proposed 2012 Ambient Air Monitoring Network Plan is posted on the NDEP website for review and comment for thirty (30) days.

Comments may be emailed to Daren Winkelman ( dwinkelman@ndep.nv.gov ) or mailed to,

Daren Winkelman Ambient Monitoring Program Bureau of Air Quality Planning 901 S. Stewart Street, Suite 4001 Carson City, Nevada897013 1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX
75 Hawthorne Street San Francisco, CA 94105

February 28, 2013

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. Bamfo rd:

Thank you for your submission of the State of Nevada, Division of Environmental Protection, Bureau of Air Quality Planning’s 2012 Ambient Air Monitoring Network Plan in July 2012. Based on the information provided in the Plan, EPA approves NDEP's 2012 Plan, except for the five specific items listed in Attachment B where we are not taking action. On December 11, 2012 EPA also approved and provided a separate notification for the relocation of State and Local Air Monitoring Station (SLAMS) ozone monitoring at 3300 E. 5th Street (Site ID: 32-510-0002) to 2601 S. Carson Street in Carson City, NV.

Annual network plans are important documents for regulatory purposes (e.g., State Implementation Plans, designations and redesignations) and public information, in addition to the myriad uses by the air districts. EPA is revising the review process for annual network plans to specifically check and document the comprehensive set of items that are required to be included in the annual network plans per 40 CFR 58.10 in a consistent manner. We have created

a checklist that lists all these items and have included it as Attachment A. While the items in the checklist are required by EPA regulations, we acknowledge that we have not specifically requested some of this information in previous annual network plan reviews. We recognize that your plan may not have all the items that we have currently identified and hope to work with you on the inclusion of these items in future plans. To facilitate these changes, EPA has provided detailed feedback in the checklist where information should be included or revised in next year’s plan.

Please note that we cannot approve portions of the annual network plan for which the information in the plan is insufficient to judge whether the requirement has been met, or for which the information, as described, does not meet the requirements as specified in 40 CFR 58.10 and the associated appendices. Accordingly, we are not acting on the specific portions of your agency’s annual network plan liste d in Attachment B.

In addition to the checklist and list of specific plan elements where EPA Region 9 is not taking

action , enclosed are additional detailed comments on the plan (Attachment C). All of the comments in Attachments A, B, and C should be addressed in next year’s network plan.3 2 EPA also received the comments provided on NDEP’s plan by Mr. John Mosley, Environmental Director of the Pyramid Lake Paiute Tribe. EPA supports Mr. Mosley’s suggestion that in

NDEP’s evaluation of their PM 2.5 network, it would be a good idea to examine concentrations from nearby monitoring that has recently been conducted. Although this suggestion does not require a change to NDEP’s current network plan, we recommend addressing the recommendation as part of NDEP’s ne xt 5

- year network assessment.

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 Offic e

Enclosures: A. Annual Air Monitoring Network Plan Checklist B. Elements where EPA is Not Taking Action

C. Additional Detailed Comments

cc: Daren Winkelman, NDEP Mike Elges, NDEPAttachment B : Annual Air Monitoring Network Plan Items where EPA is Not Taking

Action

We are not ac ting on the portions of annual network plans where either EPA Region 9 lacks the authority to approve spec ific items of the plan, or EPA has determined that a requirement is

either not met or informati on in the plan is insufficient to judge whether the requirement has

been met.

 System modifications (e.g., site closures or moves) are subject to approval per 40 CFR 58.14(c). Information provided in the plan was insufficient for EPA to approve the following system modification listed in the plan per the applicable requirement:

d iscontinuation of the Stateline CO monitor (page 5-6). Therefore, we are not taking

action on this item as part of this year’s annual network plan.

 EPA identified items in you agency’s annual network plan where a requirement was not being met or information in the plan was insufficient to judge whether the requirement was being met based on 40 CFR 58.10 and the associated appendices. Therefore, we are not acting on of the following items:

Item Checklist Row (Attachment A) Issue

Minimum # of monitors for

PM2.5 75 Insufficient information to judge

Requirements for PM2.5 background and transport sites 80 Insufficient information to judge

Monitoring objective for each

instrument 58 Insufficient information to judge

Distance from obstructions not

on roof 91 Insufficient information to judge

Distance from trees 92 Not meeting requirement in one instance

Additional information for each of these items is in included in Attachment A.Attachment C : Additional Detailed Comments

 [Item 24] A numbered street address was not specified for the Harvey’s monitor. EPA suggests providing the address of the building the monitor resides on top of.

 [Item 25] Please correct the typo for the sampling and analysis method reported for the CO monitor at Harvey’s (p.14) in order to clarify that the instrument is of FRM or FEM designation.

 [Item 30] Please clarify when MSA stands for Micropolitan Statistical Area versus Metropolitan Statistical Area. Please also include relevant CSA when appropriate.

 [Item 42] Please adjust next year’s one-point gaseous instrument QC checks to reflect the accurate schedule that should be listed as at least once every two weeks. Currently, the schedule is reported as semi-monthly.

 [Item 59] Although information describing site type is provided in the plan, this is

mis labeled as “Monitor Objective.” Please re-label these rows in next year’s plan to read Site Type. For further guidance on the monitoring objective versus site type, please refer to Attachment D of the Annual Network Plan Memo sent by EPA Region 9 in May 2012.

 [Item 60] In order to clarify that both the pollutant and parameter code are reported in thedetailed site tables (p.10-26), EPA recommends that the rows labeled “Pollutant” get relabeled to read “Pollutant/Parameter code.” A separate row to report only the parameter code may also be an option.

 [Item 61] It is suggested that the parameter occurrence code for each instrument at each monitoring site is specified in next year’s plan.

 [Item 62] The rows labeled as “Operation Schedule” for the ozone monitoring sites should be adjusted from “seasonal” to read “continuous.” The rows labeled “Sampling Season” should specify the days of the sampling season (i.e. April 1 st

– October 31 st ).

 [Item 68] NDEP’s plan reports ozone design values for each of their SLAMS ozone sites in operation (see page 5). Based on the design values reported, the Carson City 5 th Street

site should be labeled as the maximum concentration site in the network. Please ensure future plans specify the maximum concentration site for ozone. This maximum/highest concentration designation should be reported as the Site Type.

 [Items 90 & 91] For future plans, as necessary, report any obstructions (on and off the roof) by providing a distance from the probe/inlet, as well as height of the obstruction.

 [General] EPA recommends that NDEP report detailed information for meteorology tower parameters operated by the agency and incorporate the details into the site tables found on pages 10-26. Examples of helpful detailed site information to provide include:instrument manufacturer and model, start date, siting, and QA/QC information, as

applicable.