APPENDIX B 

Ambient Air Monitoring Network Plan

2012 
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C.2 EPA February 28, 2013 Review Letter 

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CONTENTS

B.1 AMBIENT AIR QUALITY NETWORK PLAN 2012

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

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AMBIENT 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.gov
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ii

Table of Contents 

List of Figures and Tables.................................................................. iii

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

Overview..................................................................................... 1 

Goals........................................................................................... 1 

Background.................................................................................. 2 

Network Design....................................................................................................... 3 

Minimum Monitoring Requirements................................................... 4 

Changes in Monitoring Network......................................................... 5

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

Overview of Monitored Parameters.................................................... 7 

Site Information.................................................................................................... 10 

Appendix A..................................................................................... 28 

Appendix B............................................................................................ 29 

Appendix C.................................................................................. 30 
iii

List of Figures 

Figure 1 – Site Map......................................................................... 9 

Figure 2 – Elko Grammar School....................................................... 11 

Figure 3 – West End Elementary School.............................................. 13 

Figure 4 – Harvey’s Casino and Resort................................................ 15 

Figure 5 – Fernley Intermediate School.................................................... 17

Figure 6 – 3300 E. Fifth Street........................................................... 19

Figure 7 – Church Site..................................................................... 21

Figure 8 – Manse Elementary............................................................ 23 

Figure 9 – 145 Glen Oaks Street......................................................... 25

Figure 10 – 8825 N. Linda................................................................. 27

List of Tables 

Table 1 – NDEP’s Ambient Air Monitoring Network............................... 4

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

Acronyms and Abbreviations 

CAA: Clean Air Act 

AQS: Air Quality System 

BAQP: Bureau of Air Quality Planning 

BAM: Beta Attenuation Monitor 

CFR: 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 

O3: Ozone 

PM: Particulate Matter (2.5 or 10 microns) 

SLAMS: State and Local Air Monitoring Station 

SPMS: Special Purpose Monitoring Station 

USEPA: United States Environmental Protection Agency
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1

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 

metropolitan 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 Protection 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 

secondary 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 for various air pollutants necessary to protect the public from injurious pollution 

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

Standard (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 

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

NAAQS for that pollutant. The CFR includes procedures for evaluating measured air quality 
2

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 

programs as designated by statute: Department of Conservation and Natural Resources 

(DCNR), 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 

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

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

quality 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 conform 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 

complete. 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 

2010 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 

data should also be submitted within that time frame.

Network 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 

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

each 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 Pahrump. 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 Air Monitoring 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 

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

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

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

Carson City (O3), Fallon (O3), Fernley (O3) and Pahrump (PM10). 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 PM10 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 

pollutants is not presently required. The following table outlines the minimum required 

monitors within 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 SO2

NAAQS Final Rule and the 2010 NO2 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 

agreements 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 

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

be the 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 30

Carson City Carson City MSA Carson City 55,176

66 ppb

(2009-

2011)

Fallon Fallon MSA Churchill 24,897

59 ppb

(2009-

2011)

Fernley Rural Lyon 52, 641

64 ppb

(2009-

2011)

CO 1 1 0

South Lake 

Tahoe

Sacramento-ArdenTruckee

CSA

Douglas 45, 464

3.1 ppm

(2010-

2011)

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

(2009-

2011)

Pahrump (4)

Pahrump MSA/Las 

Vegas-ParadisePahrump CSANye 44,324

Manse = 

2.5

Church = 

0.0

Glen Oaks

= N/A

Linda

Street = 

0.0

(2009-

2011)

Total 8 9 0
6

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 

recently 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 PM10 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 

approval 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 PM2.5 monitoring network. 

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

if any 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), NO2 (Nitrogen Dioxide), O3 (Ozone), particulate matter 

(PM10 and PM2.5), and SO2 (Sulfur Dioxide). Measuring pollutant concentrations in outdoor 

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

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

broken down into primary and secondary standards. Primary standards are those established 

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

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

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

which the standards 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 period before a pattern of exceedances is considered to be a violation of the NAAQS. A 

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

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

unusual weather 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.

Overview 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 (O3) 

Ground-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 irritant of the upper respiratory system and also causes damage to crops. 

Particulate Matter (PM10) 

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

transportation 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 (PM2.5) 

Fine particulate matter with a diameter of 2.5 microns or less is created primarily from 

industrial processes 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

Fallon
10

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 PM10 monitoring site was relocated 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) PM10 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 7th Street 

County Elko

Distance to Road 18 Meters

Traffic Count 1400 AADT (2009) Station #0070203

Groundcover Asphalt

Representative Area Elko MSA
11

Figure 2: Elko Grammar School #2, 1055 7th Street, Elko, NV. PM 10 Monitor 
12

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. PM10 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 MSA
13

Figure 3: West End Elementary School, 280 S. Russell Street, Fallon, NV. Ozone 

Monitor 
14

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/A
15

Figure 4: Harvey’s Casino and Resort Lake Tahoe NV. CO Monitor 
16

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 PM10 at this site commenced on May 1995, to determine the agricultural and industrial source 

impacts and population exposure. PM10 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 Name 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/A
17

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

2.5/Ozone Monitor 
18

3300 E. 5th 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 PM10

(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 PM2.5was 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 5th. Street

AQS ID 32-510-0002

GIS Coordinates Lat +39.167247

Long -119.731702

Location Carson City

Address 3300 East 5th 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 MSA
19

Figure 6: 3300 E. Fifth Street Carson City, NV Ozone/Met Site 
20

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 PM10. 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

5/7/2012
21

Figure 7: Church Site, 781 E. Gamebird Pahrump, NV PM 10 Monitor 
22

Manse Elementary: Site Detailed Information 

The Manse site represents the monitoring objective for highest concentrations of PM10 in Pahrump. This site replaces the 

Community Pool site, which at the time it was operating, represented the highest concentrations of PM10 in Pahrump. 

Located at 1020 E. Wilson Road, the Manse Elementary site is located on the roof of the school and monitors for PM10

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 #0230006

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

5/7/2012
23

Figure 8: Manse Elementary, 1020 E. Wilson Road Pahrump, NV PM 10 Monitor 
24

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 PM10 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

5/7/2012
25

Figure 9: 145 Glen Oaks St., Pahrump, NV PM10 Monitor 
26

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 PM10 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 2,200 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

5/7/2012
27

Figure 10: 8825 N. Linda Pahrump, NV PM 10 Monitor 
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Appendix A. 

Ozone Seasonality Approval Letter
29

Appendix B. 

Manse PM10 Monitor Relocation Approval 
30

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, Nevada89701
31

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. Bamford:

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 listed 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. 
32

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 PM2.5 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 next 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 Office 

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, NDEP
33
34
35
36
37
38
39
40
41
42
 

Attachment B: Annual Air Monitoring Network Plan Items where EPA is Not Taking 

Action

We are not acting on the portions of annual network plans where either EPA Region 9 lacks the 

authority to approve specific items of the plan, or EPA has determined that a requirement is 

either not met or information 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: 

discontinuation 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. 

43
 

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 

mislabeled 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 the 

detailed 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 1st– October 31st).

 [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 5th 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: 

44
 

instrument manufacturer and model, start date, siting, and QA/QC information, as 

applicable. 

45