UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX
75 Hawthorne Street San Francisco, CA 94105

February 28, 2013

Mr. Daniel Inouye, Branch Chief Monitoring and Planning Air Quality Management Division Washoe County Health District

P.O. Box 11130 Reno, NV 89520

- 0027

Dear Mr. Inouye :

Thank you for your submission of the Washoe County Health District, Air Quality Management

Division’s 2012 Ambient Air Monitoring Network Plan in July 2012

. Based on the information provided in the plan, EPA approves all portions of the network plan except those specifically

identified below

.

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 tha t lists all these items and have included it as Attachment A. W hile 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 reco gnize 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 th e 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. EPA Region 9 also cannot approve portions of the plan for which the EPA Administrator has approval authority. Accordingly, we are not acting on the

spe cific 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 co mments on the plan (Attachment C ). All of the

comments in Attachments A , B

, and C should be addressed in next year’s network plan. If youhave 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

- 41 41

.

Sincerely,

/s/

Matthew Lakin, Manager Air Quality Analysis Office

Enclosure s : A. Annual Air Monitoring Network Plan Checklist

B. Elements where EPA is Not Taking Action

C. Additional Detailed Comments

cc: Julie Hunter, AQMD Craig Petersen , AQMD Kevin Dick, AQMDAttachment B : Annual Air Monitoring Network P lan I tems where EPA is N ot Taking

Action

We are not acting on the portions of annual network plan s 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.

 Pe r 40 CFR 58.11(c), NCore and STN network design and changes are subject to approval of the EPA Administrator. Therefore, we are not acting on these items.

 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

For PM2.5, is at least one site in a population

- oriented area of expected maximum

concentration 77 Insufficient to judge

Instrument/monitoring method

code for each monitor 54 Insufficient to judge

Monitoring objective for each

instrument 58 Insufficient to judge

Instrument parameter code for

each instrument 60 Insufficient to judge

Instrument parameter

occurrence code for each

instrument 61 Insufficient to judge

Distance from obstructions not

on roof 91 Insufficient to judge

Additional information for each of these items is in included in Attachment A

.Attachment C : Additional Detailed Comments

 [Item 12] Please provide clarity and justification as to why no minimum Pb monitoring requirements currently exist for Washoe County (i.e. no current sources over 0.5 tons per year).

 [Item 47] Please clarify that distances between collo cated monitors at Reno3 are acceptable given that flow rates are less than 200 liters/minute. Furthermore, the need for

a PM 10 collocation at Reno3 has been eliminated given that all instruments in AQMD’s

fleet have been switched to continuous FEMs. Please clarify the flow rates for remaining

collocated instruments.

 [Item 48] Please clarify in next year’s plan that AQMD no longer operates filter based

PM 10 SLAMS instruments and therefore no collocation requirement exists.

 [Item 57] Please rename the “Moni tor Classification” rows in next year’s plan to read “Monitor Type.”

 [Item 59] Please rename the “Monitor Objective” rows in next year’s plan to read “Site type.”

 [Item 64] Please clarify in next year’s plan that AQMD now only operates continuous

PM 10 SLAMS instruments and therefore sampling frequency is continuous.

 [Items 67, 72, 73, 75, 79, 83] Please report minimum monitoring requirements in terms of active and required number of sites, rather than monitors. For example, a single site hosting multi ple active monitors counts as a single site to meet minimum monitoring requirements.

 [Item 73] Recommend specifying on page 5 the CO monitor required at the NCore site.

 [Item 83] Although AQMD exceeds the minimum number of required sites for PM10, it

wou ld be helpful for next year’s plan to report the maximum concentrations in the network in order to support the minimum number of sites necessary.

 [Items 85 & 86] Please provide traffic counts for the nearest road to a monitoring site. In the case of the Incline site, the nearest road with available traffic counts appeared to be

Tahoe Blvd. The Plumb

- kit site road distan ce and coun t information was a bit unclear.

Please more clearly pair a distance to the road with the traffic counts for that road. Traffic information reported for the Toll site suggests that PM monitors may be at a neighborhood scale, however these are currently labeled as middle scale. Please revisit

and verify the spatial scale reported for PM monitoring at the Toll site.

 [Items 90 ] For future plans, as necessary, report any obs tructions on the roof by providing a distance from the probe/inlet, as well as height of the obstruction. [General] EPA recommends that AQMD report detailed information for meteorology

parameters on a per site basis and incorporate the details into the site tables found on pages 13

- 38

. Examples of helpful detailed site information to provide include: instrumen t manufacturer and model, start date, siting, and QA/QC information , as applicable

.