### 1 **Attachment A: Annual Air Monitoring Network Plan Checklist**  Year: 2012 Agency : Clark County

DAQ 40 CFR 58.10(a) (1) requires that each Annual Network Plan (ANP ) include information regarding the following types of monitors : SLAMS monitoring stations including FRM, FEM, and ARM monitors that are part of SLAMS, NCore stations, STN stations, State speciati on stations, SPM stations, and/or, in serious, severe and extreme ozone nonattainment areas, PAMS stations, and SPM monitoring stations. 40 CFR 58.10(a)(1) further directs that, “ The plan shall include a statement of purposes for each monitor and evidence that siting and operation of each monitor meets the requirements of appendices A, C, D, and E of this part, where applicable. ” On this basis, review of the ANPs is based on the requirements listed in 58.10 along with those in Appendices A, C, D, and E. EPA Region 9 will not take action to approve or disapprove any item for which Part 58 grants approval authority to the Administrator rather than the Regional Administrators, but we will do a check to see if the required information is included and correct. The items requiring approval by the Administrator are: PAMS, NC ore, Speciation (STN/CSN), and NO2 requirements including near road, area
- wide, and RA40
. Please note that this checklist summarizes many of the requirements of 40 CFR Part 58, but does not substitute for those requ irements, nor do its contents provide a binding determination of compliance with those requirements. The checklist is subject to revision in the future and we welc ome comments on its contents and structure. Key : White = meets the req

uirement Grey = Requirement not applicable for this year’s p lan Yellow = does not meet or cannot judge the requirement

– action requested in next year’s plan or outside the ANP process Green = meets the requirement but action requested to improve next year’s plan

### 2

**ANP requirement Citation**  **within 40 CFR 58**  **Was the info**

**submitted? 1**  

### If **yes, page #s .**  **Flag if incorrect**  **2** 

### ? **Does the** 

**information provided** **3** 

### meet **the req ?**  **4** 

### Notes

1. Submit plan by July 1 st 58.10 (a)(1) Yes Yes 2. Statement of purpose for each monitor 58.10 (a)(1) Yes , p. 12, 15
- 16 Yes
3. 30
- day public comment / inspection period 58.10 (a)(1), 58.10 (a)(2) Yes, p.1 of cover

letter. Yes 4. Modifications to SLAMS network

– case when we are not approving actual system modifications (i.e., we will do it outside the ANP process 5 ) 58.10 (a)(2) 58.10(e) Yes , p. 13 & 54
- 56
. Yes Options 3 & 4 listed on page 13 to correct siting deficiencies cannot be approved by EPA at this time without further information. Not enough information provided to approve site terminations proposed on page 54
. Please work with EPA to ensure submittal of evidence showing 40 CFR 58.14 criteria are met prior to terminations/relocations. Region 9 cannot at this time approve the near
-road NO2 monitoring at City Center proposed on page 55 since approval authority currently lies with the Administrator. 5. M odifications to SLAMS network

– case when we are approving actual system modifications per 58.14(c) 58.10 (a)(2) 58.10 (b)(5) 58.10(e) 58.14 (c) Yes, p.13 & p.5 4
-

56 Yes Options 1 & 2 on page 13 are acceptable to correct siting deficiencies.
6. Does plan include documentation (e.g., attached approval letter) for system modifications that have been approved since last ANP approval? Yes, p.12 Yes Page 12 references EPA approval of ozone season shortening (April
- September) at Apex and Mesquite. EPA recommends including a copy of relevant approval letters in next year’s plan
. 7. NCore plan submitted to Admin. by 7/1/2009 58.10 (a)(3) N/A N/A

– HQ app. Clark NCore plan may still need OAQPS official approval. DAQ should work with EPA to ensure approval if not yet in place. 8. NCore site operational (by January 2011 ) 58.10 (a)(3) Yes , p.28
- 29 , 53 , & 55 N/A

– HQ app. Please include PM2.5 continuous , PM10
- 2.5 continuous , and Pb detailed site information in next

1 Response options: N/A (Not Applicable), Yes, No, Incomplete, Incorrect. The responses “Incomplete” and “Incorrect” assume that some information has been provided. 2 To the best of our knowledge. 3 Assuming the information is correct 4 Response options: N/A (Not Applicable)

– [reason], Yes, No, Insufficient to Judge. 5 See 58.14(c)

### 3

**ANP requirement Citation**  **within 40 CFR 58**  **Was the info**

**submitted? 1**  

### If **yes, page #s .**  **Flag if incorrect**  **2** 

### ? **Does the** 

**information provided** **3** 

### meet **the req ?**  **4** 

### Notes

year’s plan
. Detailed meteoro logy instrument information should also be provided. Please i mp lement all required monitoring at NCore if not yet in place and report site details in next year’s plan. The proposed transition of Pb monitoring at Jerome Mack to a high
- volume sampler noted on page 55 is acceptable. 9. Pb plan for ≥1.0 tpy sources submitted by 7/1/2009 58.10 (a)(4) N/A 10. Pb site for ≥1.0 tpy sources operational by 1/1/2010 58.10 (a)(4) N/A 11. Pb plan for 0.5
- 1.0 tpy submitted by 7/1/2011 58.10 (a)(4) N/A 12. Pb site for 0.5
- 1.0 tpy sources operational (by 12/27/2011 ) 58.10 (a)(4) N/A 13. NO2 plan for area
- wide and RA40 sites submitted by 7/1/2012 58.10 (a)(5) No. N/A
- HQ approval Please i dentify area
- wide and RA40 NO2 monitors in next year’s network plan. 14. NO2 area
- wide and RA40 sites operational by 1/1/2013 58.10 (a)(5) N/A 15. NO2 plan for near
-road sites submitted by 7/1/2012 58.10 (a)(5) Incomplete , p.46
- 47. N/A
- HQ approval 16. NO2 near
-road sites operational by ? (N/A until 2013 or 2014 plans) 58.10 (a)(5) N/A 17. SO2 plan for PWEI sites submitted by 2011 58.10 (a)(6) N/A 18. SO2 sites operational by 1/1/2013 58.10 (a)(6) and 58.13(d) N/A 19. CO plan for 2015 near-road sites submitted by 7/1/2014 58.10 (a)(7) and 58.13(e)(1) N/A
20. CO sites for first phase of CO monitors operational by 1/1/2015 58.10 (a)(7) and 58.13(e)(1) N/A
21. CO plan for 2017 near
-road sites by 7/1/2016 58.10 (a)(7) and 58.13(e)(2) N/A
22. CO sites for first phase of CO monitors operational by 1/1/2017 58.10 (a)(7) and N/A

### 4

**ANP requirement Citation**  **within 40 CFR 58**  **Was the info**

**submitted? 1**  

### If **yes, page #s .**  **Flag if incorrect**  **2** 

### ? **Does the** 

**information provided** **3** 

### meet **the req ?**  **4** 

### Notes

58.13(e)(2) 23. AQS site identification number for each site 58.10 (b)(1) Yes , p.15
- 16 & 22
- 37. Yes Please correct AQS code for Paul Meyer on p.33 & Walter Johnson on p.36
. The AQS code format should be fixed for Winterwood on p.37. Include AQS codes for all monitors reporting to AQS including SPMs
. 24. Location of each site: street address and geographic coordinates 58.10 (b)(2) Yes , p.22
- 37. Yes Recomme nd reporting SLAMS coordinates in WGS84 format
. 25. Sam

pling and analysis method(s) for each measured parameter 58.10 (b)(3) Yes , p. 9
- 12, 18 Yes Please specify a method code (if available) for each individual instrument at each existing and proposed site. Although pages 9
- 12 & 18 discuss sampling and analysis method in a general fashion , it does not list individually for each instrument at each site. Recommend including as part of detailed site tables on p.22
- 37. Please include this information for individual SPM s . Details of sampling and analysis methods for Pb and NOy were not found, please include in next year’s plan. EPA R9 recommends adapting the Attachment C format suggested in the 2012 ANP memo. 26. Operating schedule for each monitor (see items 6 2
- 6 6 ) 58.10 (b)(4) Incomplete , p.9
- 10, 12, 29, & 47. Insufficient to

judge
. Operation schedules should specify sampling

frequency (e.g. continous, 1:3, etc.) and season (e.g. year-round, April 1
- Sept 30, etc.). Pb does not specify the frequency nor season, and PM2.5 do es not specify a season
. See items 62, 63 , and 65 for mo re notes on individual parameters
. For guidance on reporting sampling frequency and season, see the suggested format provided in Attachment C of the 2012 Annual Monitoring Network Plan memo sent by Region 9. 27. Any proposals to remove or move a monitoring station within a period of 18 months following plan submittal 58.10 (b)(5) Yes , p.13 & p.54
- 56 Yes See item #4 above.

### 5

**ANP requirement Citation**  **within 40 CFR 58**  **Was the info**

**submitted? 1**  

### If **yes, page #s .**  **Flag if incorrect**  **2** 

### ? **Does the** 

**information provided** **3** 

### meet **the req ?**  **4** 

### Notes

28. Scale of representativeness for each monitor as defined in Appendix D 58.10(b)(6); App D Yes , p.9
- 12 &

p.22
- 37
. Yes. Please also include information for SPM sites in next year’s plan. 29. Identification of sites suitable and sites not suitable for comparison to the annual PM2.5 NAAQS as described in Part 58.30 58.10 (b)(7) Yes, p.11 Yes.
30. MSA, CBSA, CSA or other area represented by the mo nitor 58.10 (b)(8) Yes, p.5 Yes 31. D esignation of any Pb monitors as either source
oriented or non
- source - oriented 58.10 (b)(9) Yes, p.46 Yes 32. Any source
- oriented Pb site for w hich a waiver has been granted by EPA RA 58.10 (b)(10) N/A N/A
- not currently required for DAQ. 33. Any Pb monitor for which a waiver has been requested or granted by EPA RA for use of Pb
- PM10 in lieu of Pb
- TSP 58.10 (b)(11) N/A N/A
- not currently required for DAQ. 34. Identification of required NO2 monitors as either near-road or area
- wide 58.10 (b)(12) Incomplete, p.46 N/A
- HQ approval Area
- wide monitors not identified. Please identify all NO2 required mo nitors in next year’s plan. 35. Document how

states and local agencies provide for the review of changes to a PM2.5 monitoring network that impact the location of a violating PM2.5 mo nitor. 6 58.10 (c) Yes, p.10
- 11 Yes EPA recommends public review in all cases, including for a lost lease and/or notice to vacate.
36. Plan to modify the network that compl ies with findings of the 5
- year netwo rk assessment. [Note: recommended to be submitted on year of network assessment or year after.] 58.10 (e) 58.14 (a) N/A
- Only applies

to year of or after 5
- year netwo rk assessment 37. Precision/Accuracy reports submitted to AQS 58.16(a); App A, 1.3 and 5.1.1 Yes, p.50 Yes.
38. Annual data certification submitted 58.15 App. A 1.3 Yes, p.50. Yes. Recommend including date data certification package was sent to EPA, this would be the certification date. 39. Frequency of flow

rate verification for manual PM samplers audit App A 3.3.2 Yes, p.10 Yes. 40. Frequency of flow

rate verification for automated PM App A 3.2.3 Yes , p.9 Yes Please also include frequency of flow rate

6 The affected state or local agency must document the process for obtaining public comment and include any comments received through the public notification process within their submitted plan.

### 6

**ANP requirement Citation**  **within 40 CFR 58**  **Was the info**

**submitted? 1**  

### If **yes, page #s .**  **Flag if incorrect**  **2** 

### ? **Does the** 

**information provided** **3** 

### meet **the req ?**  **4** 

### Notes

analyzers audit verification for PM10
- 2.5 in next year’s plan. 41. Frequency of one
-point flow rate verification for Pb samplers audit App A 3.3.4.1 No. Insufficient to judge. Include in next year’s plan. 42. Frequency of one
-point QC check (gaseous) App. A 3.2.1 Yes, p.11
- 12. Yes. 43. Date of last Annual Performance Evaluation (gaseous) App. A 3.2.2 Yes , p.51 Yes All evaluations found except for o zone evaluation at Jerome Mack and NO2 at Joel Neal. Please ensure all Annual Performance Evaluations for gases are reported and/or provide a statement clarifying if some evaluations did not occur. 44. Dates of last two semi
- annual flow rate audits for PM mo nitors App A, 3.2.4 and 3.3.3 Yes , p.50
- 51. Yes Palo Verde, Boulder City, and Jerome Mack each reported only one audit for PM10. Only one audit wa s found reported for continuous PM2.5 at Jerome Mack . Please include previous two flow rate dates for all PM monitors and/or provide a statement clarifying if some audits did not occur. 45. Dates of last two semi
- annual flow rate audits for Pb mo nitors App A 3.3.4.1 No. Insufficient to judge. Include in next year’s plan. 46. PM2.5 co
- location App A 3.2.5 Yes, p.18, 34, & 49. Yes. 47. Distance between co - located monitors App. A 3.2.5.6 Yes, p.34 Yes. 48. Manual PM10 method co
- location met? (note: continuous PM10 does not have this requirement) App A 3.3.1 N/A N/A
- not currently required for DAQ. DAQ uses continuous instruments to meet PM10

mo nitoring requirements. 49. Pb co
- location App A 3.3.4.3 N/A N/A
- not currently required for DAQ. 50. PM10
- 2.5 co
- location (note: only applies to Fresno and Phoenix NCore sites) App A 3.3.6 N/A N/A
- not currently required for DAQ. 51. Required # of PM2.5 PEP audits App A 3.2.7 N/A Yes
- EPA requirement 7 52. Required # of Pb PEP audits App A 3.3.4.4 N/A Yes
- EPA requirement 8 53. Required # of NPAP audits (or approved equivalent) App A 2.4 N/A Yes
- EPA requirement 9

7 EPA has reviewed EPA documentation to confirm that these requirements have been met for the area in question. 8 EPA has reviewed EPA documentation to confirm that these requirements have been met for the area in question.

### 7

**ANP requirement Citation**  **within 40 CFR 58**  **Was the info**

**submitted? 1**  

### If **yes, page #s .**  **Flag if incorrect**  **2** 

### ? **Does the** 

**information provided** **3** 

### meet **the req ?**  **4** 

### Notes

54. Instrument/monitoring method code for each monitor: is it reported properly? Is it reported correctly (i.e., appropriate method code for regulatory monitors)? App C 2.4.1.2 Yes , p.18. Yes See related item #25.
55. Placeholder for: Optional request to have PM2.5 continuous instruments treated as non
- FEMs and therefore not comparable to NAAQS? Proposed rule and memo 56. Start date for each monitor Required to determine if other req. (e.g., min # and co
- lo) are met Yes , p.19 Yes Start dates not found for Apex and Mesquite ozone mo nitors . Please list start dates for all required mo nitors.

57. Instrument monitor type for each monitor Required to determine if other req. (e.g., min # and co
- lo) are met Yes , p.18, 22
- 37. Yes
- Please list the monitor type individually for each parameter, rather than for each site.

- A discrepancy occurs between PM2.5 beta attenuation monitors that are listed as SPM on p.18 and SLAMS or NCORE on p.24
- 35. Please correct this discrepancy since a SLAMS/NCORE cannot also be an SPM. See Attachment D of the 2012 Network Plan memo from R9 for guidance on monitor types. Monitor ty pes examples include: SLAMS, Special Purpose, NCore. More than one monitor type may apply to a mo nitor. 58. Monitoring objective for each instrument App D 1.1 58.10 (b)(6) Incomplete, p. 9
- 12 Insufficient to judge. The mo nitoring objective for each instrument refers

to one of three basic objectives: NAAQS compliance, Research, and Public information
. Each instrument in the DAQ network should specify one ( or a combination) of these three objectives. We recommend including this in the detailed site information tables on p.22
- 37. Although DAQ currently specifies a monitoring

9 EPA has revie wed EPA documentation to confirm that these requirements have been met for the area in question.

### 8

**ANP requirement Citation**  **within 40 CFR 58**  **Was the info**

**submitted? 1**  

### If **yes, page #s .**  **Flag if incorrect**  **2** 

### ? **Does the** 

**information provided** **3** 

### meet **the req ?**  **4** 

### Notes

objective for instruments (p.9
- 12), these should be re - labeled to “Site T ype.” See Attachment D of the 2012 Network Plan memo from R9 for guidance on basic monitoring objectives. 59. Site type for each instrument App D 1.1.1 Yes p. 9
- 12 & 58
- 59. Yes Site Types currently appear on p. 9
- 12 & 58
- 59 as “Objective” and “Monitor Objective Type ” respectively. Please change label s to Site Type in next year ’s plan. See Attachment D of the 2012 Network Plan memo from R9 for guidance on Site Types. 60. Instrument parameter code for each instrument Required to determine if other req. (e.g., min # and co
- lo) are met Yes , p.19 Yes Parameter codes not found for Pb (Jerome Mack), seasonal ozone sites (Apex & Mesquite) , and PM10
- 2.5 ( Jerome Mack)
. Please include information for all monitors in next year’s plan.

- Incorrect parameter code appears to be listed for PM2.5 speciation at Jerome Mack on page 19 , please correct.

- Recommend including Parameter Codes in detailed site tables on p.22
- 37 for each parameter. See May 2012 R9 memo, Attachment D for a suggested reporting format. 61. Instrument parameter occurrence code for each instrument Required to determine if other req. (e.g., min # and co
- lo) are met Yes , p.19 Yes Parameter occurrence codes not found for Pb (Jerome Mack), seasonal ozone sites (Apex & Mesquite) , and PM10
- 2.5 (Jerome Mack)
. Please include information for all monitors in next year’s plan.

- Recommend including in detailed site tables on p.22
- 37 for each parameter. See May 2012 R9 memo, Attachment D for a suggested reporting format. 62. Sam

pling seas on for ozone (note: date of waiver App D, 4.1(i) Yes, p.11
- 12, 47 Yes Recommend specifying the sampling schedule and

### 9

**ANP requirement Citation**  **within 40 CFR 58**  **Was the info**

**submitted? 1**  

### If **yes, page #s .**  **Flag if incorrect**  **2** 

### ? **Does the** 

**information provided** **3** 

### meet **the req ?**  **4** 

### Notes

approval must be included if the sampling season deviates from requirement) season in the detailed site information tables for each monitor on p.22
- 37. Recommend including copies of any EPA season waivers granted (i.e. Apex & Mesquite)
. 63. Sam

pling schedule for PM2.5
- applies to year
-round and seasonal sampling schedules (note: date of waiver approval must be included if the sampling season deviates from requirement) 58.12(d) App D 4.7 Yes , p.9
- 10 , 47 Yes Thank you for providing the sampling frequency. Please also clarify the PM2.5monitoring season (e.g. year
-round, April 1

– October 31, etc.) in next year’s plan. Recommend including for each monitor in detailed site info on p.22
- 37. 64. Sam

pling schedule for PM10 58.12(e) App D 4.6 Yes, p.9 , 47 Yes. 65. Sam

pling schedule for Pb 58.12(b) App D 4.5 No. Insufficient to judge. Add Pb sampling schedule and monitoring season

to next year’s plan. Schedule must be 1:6 unless waiver is granted from EPA. Recommend DAQ include sampling schedule in detailed Jerome Mack site table on p.29. 66. Sam

pling schedule for PM10
- 2.5 58.12(f) App D 4.8 Yes, p.29 , 47 Yes. 67. Minimum # of monitors for O3[Note: should be supported by MSA ID, MSA population, DV, # mo nitors, and # required monitors] App D, 4.1(a) and Table D
- 2 Yes , p.49 Yes Please specify MSA population count . Include in next year’s plan. Recommend adapting format suggested by Attachment A of 2012 Annual Monitoring Network Plan memo sent by R9. 68. Identification of max. conc. O3 monitor(s) App D 4.1 (b) Yes, p.30 Insufficient to judge. DAQ special study monitoring at the SMYC site

has shown higher concentration estimates for ozone than the currently listed high SLAMS site at Joel Neal. Appropriate action should be taken by DAQ if the case is that higher ambient concentrations are found in other areas of Clark county. DAQ should work closely with EPA to explore potential solutions. Progress on this situation should be included in next year’s plan. 69. Minimum monitoring requirements met for near
-road NO2 App D 4.3.2 N/A 70. Minimum monitoring requirements met for area
- wide NO2 App D 4.3.3 N/A 71. Minimum monitoring requirements met for RA
- 40 App D 4.3.4 N/A

### 10

**ANP requirement Citation**  **within 40 CFR 58**  **Was the info**

**submitted? 1**  

### If **yes, page #s .**  **Flag if incorrect**  **2** 

### ? **Does the** 

**information provided** **3** 

### meet **the req ?**  **4** 

### Notes

NO2 72. Minimum monitoring requirements met for SO2 App D 4.4 Yes , p.46 & p.49 Yes Please clarify that PWEI requirements are met by the NCore monitor. Recommend including in minimum monitoring requirements table similar to p.49. Recommend adapting format suggested by Attachment A of 2012 Annual Monitoring Network Plan memo sent by R9. 73. Minimum monitoring requirements met for CO App D N/A 74. Minimum monitoring requirements met for Pb App D 4.5 58.13(a) Yes , p. 46
. Yes Please specify CBSA population in order clarify that Clark is meeting requirement . Recommend adapting format suggested by Attachment A of 2012 Annual Monitoring Network Plan memo sent by R9. 75. Minimum # of monitors for PM2.5 [Note: should be supported by MSA ID, MSA population, DV, # mo nitors, and # required monitors] App D, 4.7.1(a) and Table D
- 5 Yes , p.5, 14, 4 9 Yes Please specify MSA population count in order to clarify DAQ is meeting this requirement
. Recommend adapting format suggested by Attachment A of 2012 Annual Monitoring Network Plan memo sent by R9. 76. Required PM2.5 sites represent community
- wide air quality at neighborhood or urban scale App D 4.7.1(b) Yes, p.10 Yes 77. For PM2.5, is at least one site in a population
- oriented area of expected maximum concentration App D 4.7.1(b)(1) Yes, p.10 Yes 78. If >1 SLAMS PM2.5 required, is there a site in an area of poor air quality App D 4.7.1(b)(2) Yes, p.14 Yes Please clarify in next year’s plan that this requirement is being met. 79. Minimum monitoring requirements for continuous PM2.5 App D 4.7.2 Yes , p.9 & 49. Yes Please include MSA population in order to clarify DAQ is meeting this requirement. Please correct this in next year’s plan. Recommend adapting format suggested by Attachment A of 2012 Annual Monitoring Network Plan memo sent by R9. 80. Requirements for PM2.5 background and transport sites App D 4.7.3 Yes, p.15 & 49 N/A since this is a state requirement. Although this is a state requirement and not specific

to Clark, the plan presents contradicting information. Page 15 says Jean is not able to serve as a background site, however other areas of the plan (p.49) label the site as a background. Please correct the objective consistently across the plan. Recommend that state requirements such as this are

### 11

**ANP requirement Citation**  **within 40 CFR 58**  **Was the info**

**submitted? 1**  

### If **yes, page #s .**  **Flag if incorrect**  **2** 

### ? **Does the** 

**information provided** **3** 

### meet **the req ?**  **4** 

### Notes

coordinated through lead state monitoring agency. 81. Are PM2.5 Chemical Speciation requirements met for official STN sites? App D 4.7.4 Yes, p.11 Yes 82. Spatial Averaging for comparison to Annual NAAQS: are intended CMZs defined and met criteria in 40 CFR 50 App N? App D 4.7.5 N/A
83. Minimum # of monitors for PM10 App D, 4.6 (a) and Table D
- 4 Yes, p.49 Yes Specify MSA population and PM10 high NAAQS concentration in order to clarify that DAQ is meeting this requirement . Recommend adapting format suggested by Attachment A of 2012 Annual Monitoring Network Plan memo sent by R9. 84. Minimum monitoring requirements met for PM10
- 2.5 mass App D 4.8 Yes, p.55. Yes 85. Distance of site from nearest road App E 6 Yes , p.20 & 22
- 37 Yes Please also report distance fro m Apex and Mesquite in next year’s plan. 86. Traffic count of nearest road App E Yes , p.20 Yes Mesquite & Apex: please provide traffic counts in next year’s plan for seasonal sites as well
. Recommend including available traffic counts from credible source for nearest road at: Winterwood, Sunrise Acres, Paul Meyer, Palo Verde, Joel Neal, Mesquite, Apex. 87. Groundcover App E 3(a) Yes, p.22
- 37 Yes 88. Probe height App E 2 Yes, p.22
- 73 Yes 89. Distance from supporting structure App E 2 Incomplete, p.22
- 37 Insufficient to

judge for non
gaseous. No for CO at Winterwood. Please include distances from supporting structures

for all parameters including non
- gaseous. CO at Winterwood should be > 1m away from supporting structure. 90. Obstructions on roof App E 4(b) Incomplete, p.22
- 37 Insufficient to

judge. In all c ases specify whether there is an obstruction

on roof . D istance & height should be included to determine if clearly if something is an obstruction
. Please clarify what a cell with a “

—“ signifies. 91. Obstructions not on roof. App E 4(a) No Insufficient to Specify in next year’s plan, distance and height of

### 12

**ANP requirement Citation**  **within 40 CFR 58**  **Was the info**

**submitted? 1**  

### If **yes, page #s .**  **Flag if incorrect**  **2** 

### ? **Does the** 

**information provided** **3** 

### meet **the req ?**  **4** 

### Notes

judge. obstructions not on roof or list if none exist.

Specifically, please ensure height and distance of building next to J.D. Smith site is reported. It is currently difficult to judge whether this is an obstruction. 92. Distance from trees App E 5 Incomplete, p.22
- 37 Insufficient to

judge , No in some instances Information not included for all monitors
. Please

specify what a cell with a “

—“ signifies. Trees at Joel Neal & Green Valley are <10m, please correct siting deficiency. 93. Distance to furnace or incinerator flue App E 3(b) Yes, p.16 Yes 94. Unrestricted airflow App E, 4(a) and 4(b) Yes, p.22
- 37 Yes 95. Probe material (if applicable) App E 9 Yes, p.22
- 37 Yes 96. Residence time (if applicable) App E 9 Yes, p.22
- 37 Yes 

### Public Comments on Annual Network Plan Were comments submitted to the S/L/T agency during the public comment period? **No comments received. See cover letter submitted with plan.**