Air Quality Management Division 

Washoe County Health District 

P.O. Box 11130 

Reno, Nevada 89520-0027 

Dear Mr. Inouye: 

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

Division (AQMD's) 2013 Ambient Air Monitoring Network Plan in July 2013. We have 

reviewed the submitted document based on the requirements set forth under 40 CFR 58. Based 

on the information provided in the plan, EPA approves all portions of the network plan except 

those specifically identified below. With this plan approval, we also formally approve the 

following system modification(s): relocation of the Galletti site to address adequate spacing from 

trees, and initiation of SLAMS PM2.s monitoring at the Sparks site. 

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. EPA Region 9 also cannot approve portions of the plan for 

which the EPA Administrator has not delegated approval authority to the regional offices. 

Accordingly, the first enclosure (A. Annual Monitoring Network Plan Items where EPA is Not 

Taking Action) provides a listing of specific items of your agency's annual monitoring network 

plan where EPA is not taking action. The second enclosure (B. Additional Items Requiring 

Attention) is a listing of additional items in the plan that EPA wishes to bring to your agency's 

attention. 

The third enclosure (C. Annual Monitoring Network Plan Checklist) is the checklist EPA used to 

review your plan for overall items that are required to be included in the annual network plan 

along with our assessment of whether the plan submitted by your agency addresses those 

requirements. 

The first two enclosures highlight a subset of the more extensive list of items reviewed in the 

third enclosure. All comments conveyed via this letter (and enclosures) should be addressed 

(through corrections within the plan, additional information being included, or discussion) in 

next year's annual monitoring network plan. 

Print~d on Rtcycltd Paptr 
Enclosures: 

Meredith Kurpius, Manager 

Air Quality Analysis Office 

A. Annual Monitoring Network Plan Items where EPA is Not Taking Action 

B. Additional Items Requiring Attention 

C. Annual Monitoring Network Plan Checklist 

cc: Craig Petersen, AQMD 

Kevin Dick, AQMD 
(

), 

g

g

j

approval of the EPA Administrator. Therefore, we are not acting on these items. 

• EPA identified items in your agency's annual monitoring 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 the following items: 

Item Checklist Row Issue 

Modifications to SLAMS 4 Insufficient to judge 

network 

Document how states and 26 Insufficient to judge 

local agencies provide for the 

review of changes to a PM2.s 

monitoring network that 

impact the location of a 

violating PM2.s monitor. 

Scale of representativeness for 17,73 Insufficient to judge in some instances 

each monitor & distance of 

site from nearest road 

Monitoring objective for each 47 Insufficient to judge 

instrument 

Site type for each instrument 48 Insufficient tojudge in some instances 

Additional information for each of these items may be found for the row listed in column 2, in 

the third enclosure (C. Annual Monitoring Network Plan Checklist). 
• [Item 38] AQMD uses the term ''Designated" (rather than ''Primary'') to differentiate 

between a "Collocated" monitor. It is recommended that the term ''Primary'' be adopted 

in place of"Designated." · 

• [Item 46] NCore required parameters reported (p.26-31) are considered a subset of the 

SLAMS network. Please also add SLAMS as a monitor type to the NCore parameters. 
C. ANNUAL MONITORING NETWORK PLAN CHECKLIST 

(Updated 11/26/2013) 

Year: 2013 

Agency: Washoe County Health District Air Quality Management Division (AQMD) 

40 CFR 58.1 O(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 speciation stations, SPM 

stations, and/or, in serious, severe and extreme ozone nonattainment areas, P AMS stations, and SPM monitoring stations. 

40 CFR 58.10(a)(l) 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: P AMS, NCore, and Speciation (STN/CSN). 

Please note that this checklist summarizes many of the requirements of 40 CFR Part 58, but does not substitute for those requirements, nor do its 

contents provide a binding determination of compliance with those requirements. The checklist is subject to revision in the future and we welcome 

comments on its contents and structure. 

Key: 

White = meets the requirement. 

Yellow= requirement is not met, or information is insufficient to make a determination. Action requested in next year's plan or outside the ANP 

process. 

= item requires attention in order to improve next year's plan. 

1 
ANP requirement Citation Was the info Does the Notes 

within 40 submitted?1 If information 

CFR58 yes, page #s. provided3 meet 

Flag if the req?4 · 

incorrecr? 

1. Submit plan by July 1st 58.10 (a)(l) Yes Yes 

2. Statement of purpose for each monitor 58.10 (a)(1) Yes, p.l2-39 Yes 

3. 30-day public comment I inspection period~ 58.10 (a)(1), Yes, coverletter Yes No comments received. 

58.10 (a)(2) 

4. Modifications to SLAMS network - case when we are 58.10 (a)(2) Yes, p.7-8 Insufficient to judge -Please include a rationale for the proposal to 

not approving actual system modifications (i.e., we 58.10(e) initiate SLAMS PM2.

5 monitoring at Galletti 

will do it outside the ANP process6

) (p.8). 

-While EPA Region 9 does not have authority to 

approve the Reno3 NCore site meteorology 

modifications proposed on p.7, we fmd these 

acceptable and would recommend approval to the 

Administrator. 

5. Modifications to SLAMS network- case when we are 58.10 (a)(2) Yes, p.7-8 Yes -EPA approves the relocation of entire Galletti 

approving actual system modifications per 58.14(c) 58.10 (b)(5) site approximately 45 meters north to correct the 

58.10(e) spacing from trees siting issues. 

58.14 (c) 

- EPA is aware of AQMD efforts to better 

understand the spatial distribution ofPM2•

5 across 

the region and the potential for higher PM2.s 

concentrations at Sparks in particular. EPA 

therefore approves the initiation ofPM2•

5 SLAMS 

monitoring (and collocation as needed) at the 

Sparks site. 

- -EPA appreciates AQMD's effort to inform EPA 

1 Response options: NA (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: NA (Not Applicable)- [reason], Yes, No, Insufficient to Judge. 

5 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 See 58.14(c) 

2 
ANP requirement Citation Was the info Does the Notes 

within 40 submitted?1 If information 

CFR58 yes, page #s. provided3 meet 

Flag if the req?4 

incorrecf? 

of the PM10 instrument modifications occurring 

within their SLAMS network at the Galletti & 

Sparks site (p. 7). SLAMS FRM/FEM instrument 

modifications, provided they are replacing other 

SLAMS FRMIFEM designated instruments, do 

not require EPA approval. Therefore, AQMD's 

proposed PM10 SLAMS instrument replacements 

from manual methods to continuous methods is 

acceptable, provided that the replacement 

instruments continue to be SLAMS and of 

FRMIFEM designation. 

-Meteorology instrument adjustments at the Toll, 

So.Reno, Plumb-kit, Galletti, and Sparks sites are 

acceptable and do not require EPA approval. 

6. Does plan include documentation (e.g., attached N/A N/A No system modifications approved outside the 

approval letter) for system modifications that have ANP since last ANP approval. 

been approved since last ANP approval? 

7. NCore site operational (by 1/1/2011) 58.10 (a)(3) Yes, p.24-31 N/A- HQ approval All required parameters operational. EPA does 

not currently expect agencies to operate speciated 

PMu1-2.s. 

8. Ph site for 0.5-1.0 tpy sources operational (by 58.10 (a)(4) N/A N/A- no current No sources over 0.5 tons per year and a CBSA 

12/27/2011) requirement. population less than 500,000 listed as rationale_ on 

p.4. 

9. N~ plan for area-wide and RA40 sites submitted by 58.10 (a)(5) N/A N/A- no current EPA recommends for AQMD to clarify the 

7/1/2012 requirement. applicability of this requirement in future ANP 

submittals (currently not applicable). 

10. N~ area-wide and RA40 sites operational by 58.10 (a)(S) N/A N/A- no current EPA recommends for AQMD to clarify the 

1/1/2013 requirement. applicability of this requirement in future ANP 

submittals (currently not applicable). 

11. N02 plan for near-road sites submitted by 7/1/2013 58.10 (a)(5) N/A N/A- no current AQMD lists CBSA population size as rationale 

requirement. on p.4. 

12. so2 sites ope~tional (by 1/1/2013) 58.10 (a)(6) Yes, p.27 Yes -AQMD operates one required monitor at NCore. 

and 58.13(d) PWEI monitoring not currently required. 

- EPA recommends for AQMD to clarify the 

applicability of PWEI monitoring requirements in 

- - - - -- future N"lP submittals { currentl}' not ap~licable ). 

3 
ANP requirement Citation Was the info Does the Notes 

within 40 submitted?1 H information 

CFR58 yes, page #s. provided3 meet 

Flag if the req?4 

incorrecr? 

13. AQS site identification number for each site 58.10 (b)(l) Yes, p.12-39 Yes 

14. Location of each site: street address and geographic 58.10 (b)(2) "X"es, p.l2-39 Yes 

coordinates 

15. Sampling and analysis method(s) for each measured 58.10 (b )(3) Yes, p.14-41 Yes 

parameter 

16. Any proposals to remove or move a monitoring station 58.10 (b)(5) Yes,p.7 Yes See Galletti site relocation from item 5 above. 

within a period of 18 months following plan submittal 

17. Scale of representativeness for each monitor as 58.1 O(b )(6); Yes, p.l4-41 Insufficient to judge See item 73 for discussion on Reno3. 

defmed in Appendix D AppD some parameters at 

Reno3 

Yes- all others 

18. Identification of sites suitable and sites not suitable for 58.10 (b)(7) Yes, p.14-41 Yes 

comparison to the annual PM2.s NAAQS as described 

in Part 58.30 -

19. MSA, CBSA, CSA or other area represented by the 58.10 (b)(8) Yes, p.12-39 Yes 

monitor 

20. Designation of any Pb monitors as either source- 58.10 {b)(9) N/A N/A- no current 

oriented or non-source-oriented requirement 

21. Any source-oriented Pb site for which a waiver has 58.10 (b)(lO) N/A N/A- no current 

been granted by EPA RA requirement 

22. Any Pb monitor for which a waiver has been 58.10 (b)(ll) N/A N/A- no current 

requested or granted by EPA RA for use ofPb-PM10 requirement 

in lieu ofPb-TSP 

23. Identification of required N02 monitors as either 58.10 {b)(l2) N/A N/A- no current 

near-road or area-wide requirement 

24. Identification of any PM2.s FEMs and/or ARMs not 58.10 (b)(13) N/A N/A-no such 

eligible to be compared to the NAAQS (Note 1: must 58.11 (e) monitors identified 

include required data assessmenq (Note 2: Required 

SLAMS must monitor PM2.s with NAAOScomparable monitor at the required sample 

frequency.) 

25. For SPMs listed as non-regulatory, note the start Date 58.20(c) Yes,p.3 &38 Yes The PM2.s and PM10 SPM BAMs listed on p.38 if 

ofFRMIFEM/ARM at SPM. If> 24 ytonths, and continuing to operate past July 2013 should be 

monitor is eligible for COiilparison to the NAAQS per listed as NAAQS comparable unless information 

58.11 (e) and 58.30, the agency must supply is provided showing App.A, C, or E are not being 

information that App A, C orE requirements were not met. 

4 
ANP requirement Citation Was the info Does the Notes 

within 40 submitted?1 If information 

CFR58 yes, page #s. provided3 meet 

Flag if the req?4 

incorrecr? 

met. - 26. Document how states and local agencies provide for 58.10 (c) Incomplete, p.l & 8 Insufficient to judge AQMD provides a section in the ANP describing 

the review of changes to a PM2.

5 monitoring network the public inspection process and modifications to 

that impact the location of a violating PM2..s monitor. the PM2.

5 monitoring network. Please clarify 

specifically how AQMD provides for the review 

of changes to a PM2.5 monitoring network that 

impact the location of a violating PM2.

5 monitor. 

27. Does the plan include a request for approval for and 58.11 (a) (2) N/A N/A-no such 

alternative to appendix A requirements for SPMs request included 

operating a FRMIFEM/ ARM which also meets 

appendixE? 

28. Precision/Accuracy reports submitted to AQS 58.16(a); Yes, p.8 Yes 

AppA, 1.3 

and 5.1.1 

29. Annual data certification submitted 58.15 Yes, p.8 Yes I 

App.A 1.3 I 30. Frequency of flow rate verification for manual PM AppA3.3.2 Yes, p.14-41 Yes 

samplers audit 

31. Frequency of flow rate verification for automated PM · AppA3.2.3 Yes, p.14-41 Yes 

analyzers audit 

32. Frequency of one-point flow rate verification for Ph App A 3.3.4.1 N/A N/ A- no current 

samplers audit requirement 

33. Frequency of one-point QC check (gaseous) App. A 3.2.1 Yes, p.14-41 Yes 

34. Date oflast Annual Performance Evaluation (gaseous) App.A3.2.2 Yes, p.14-41 Yes 

35. Dates of last two semi-annual flow rate audits for PM AppA,3:2.4 Yes, p.14-41 Yes 

monitors and3.3.3 

36. Dates of last two semi-annual flow rate audits for Ph App A 3.3.4.1 N/A N/A- no current 

monitors requirement 

37. PM2.s collocation AppA3.2.5 Yes, p.28 Yes It is recommended that AQMD develop a section 

in future ANP submittals that describes how 

collocation requirements are being met. 

38. Designation of a primary monitor if there is more than Need to Yes, p.28 & 38 Yes AQMD uses the term "Designated" (rather than 

one monitor for a pollutant at a site. determine "Primary") to differentiate between a 

collocation "Collocated" monitor. It is recommended that the 

term "Primary'' be adopted in place of 

"Designated." 

39. Distance between collocated monitors (Note: waiver App.A Yes, p.28 & 38 Yes 

5 
ANP requirement Citation Was the ilifo Does the Notes 

within I 40 submitted?1 H information 

. CFR58 yes, page #s. provided3 meet 

Flag if the req?4 

incorrecf? i 

request or the date of previous waiver approval must 3.2.5.6 and 

be included if the distance deviates from requirement.) 3.2.6.3 

40. Manual PM10 method collocation met? (note: AppA 3.3.1 Yes, p.38 Yes It is recommended that AQMD develop a section 1 

continuous PM10 does not have this requirement) in future ANP submittals that describes how 

collocation requirements are being met. I 

41. Ph collocation App A 3.3.4.3 N/A N/A- no current I 

requirement 

42. PM10•2•

5 collocation (note: only applies to Fresno and AppA3.3.6 N/A N/A- no current 

Phoenix NCore sites) requirement 

43. Instrument/monitoring method code for each monitor: AppC2.4J.2 Yes, p.l4-41 Yes 

is it reported properly? Is it reported correctly (i.e., 

appropriate method code for regulatory_ monitors~? 

44. For agencies that share monitoring responsibilities in AppD2(e) Yes, p.4-5& 9 Yes AQMD currently meets all minimum monitoring 

an MSA/CSA: does each affected State or local requirements for the Reno-Sparks, NV CBSA. 

agency meet full monitoring requirements or is 

an agreement between the affected agencies and the 

EPA Regional Administrator in place? 

45. Start date for each monitor Required to Yes, p.l4-41 Yes 

determine if 

otherreq. 

(e.g., min# 

and colloc) 

are met -

46. Instrument monitor ty.pe for each monitor Required to Yes. p.l4-4l Yes NCore required parameters reported (p.26-31) are 

determine if considered a subset of the SLAMS network. 

otherreq. Please also add SLAMS as a monitor type to the 

(e.g., min# NCore parameters. 

and colloc) 

are met 

47. Monitoring objective for each instrument App D 1.1 No Insufficient to judge Recommend adding a row called "Monitoring 

58.10 (b)(6) objective(s)" to the detailed site tables on p.l4-4l. 

The monitoring objective should list one or a 

combination of the following: NAAQS 

comparison, Public Information, and/or Research. 

48. Site type for each instrument App D 1.1.1 Incorrect, p.14-4l Insufficient to judge These should match one of the acceptable AQS 

in multiple codes for Site Types. See Attachment D of the 

instances Region 9 2012 ANP memo for guidance or feel 

free to contact Region 9 directly. 

6 
ANP requirement Citation Was the info Does the Notes 

within 40 submitted?1 If information 

CFR58 yes, page #s. provided3 meet 

Flag if the req?4 

incorrecf? 

49. Instrument parameter code for each instrument Required to Yes, p.14-41 Yes 

determine if 

otherreq. 

(e.g., min# 

and colloc) 

are met 

50. Instrument parameter occurrence code for each Required to Yes, p.14-41 Yes 

instrument determine if 

other req. 

(e.g., min# 

and colloc) 

are met 

51. Sampling season for ozone (note: date of waiver 58.10 (bX4) Yes, p.14-41 Yes Currently all year for all ozone sites. 

approval must be included if the sampling season App D, 4.l(i) 

deviates from requirement) 

52. Sampling schedule for PM2.s - applies to year-round 58.10 (b)(4) Yes, p.28-29 & 38 Yes 

and seasonal sampling schedules (note: date of waiver 58.12(d) 

approval must be included if the sampling season AppD4.7 

deviates from requirement) EPA 

flowchart 

53. Sampling schedule for PM10 58.10 (bX4) Yes. P.14-41 Yes 

58.12(e) 

AppD4.6 

54. Sampling schedule for Pb. 58.10 (bX4) N/A N/A- no current 

58.12(b) requirement 

AppD4.5 

55. Sampling schedule for PM1o.2.s 58.10 (b)(4) Yes, p.28-29 Yes 

58.12(t) 

App_D4.8 

56. Minimum# of monitors for 0 3 [Note: should be App D, 4.1(a) Yes, p.4 Yes 

supported by MSA ID, MSA population, DV, # and 

monitors, and# required monitors] (see footnote)' TableD-2 

57. Identification of max. cone. 0 3 monitor(& AppD4.1 (b) Yes, p.20, 34, &37 Yes 

58. Minimum monitoring requirements met for near-road AppD4.3.2 N/A NIA- no current 

7 Only monitors considered to be required SLAMs are eligible to be counted towards meeting minimum monitoring requirements. In addition, ozone monitors that do not meet 

traffic count/distance requirements to be neighborhood scale ( 40 CFR 58 Appendix E, Table E-1) cannot be counted towards minimum monitoring requirements. 

7 
ANP requirement Citation Was the info Does the Notes 

within 40 submitted?1 If information 

CFR58 yes, page #s. provided3 meet 

I Flag if the req?4 

incorrect I 

2

? 

N02 (2014 start date) requirement 

59. Minimum monitoring requirements met for area-wide AppD4.3.3 N/A N/A- no current i 

N02 requirement 

60. Minimum monitoring requirements met for RA-40 AppD4.3.4 N/A N/A- no current 

N02 requirement I 

61. Minimum monitoring requirements met for so2 AppD4.4 Yes,p.5 Yes Yes for NCore, no current PWEI requirement. I 

[Note: Only monitors considered to be required 

SLAMs are eligible to be counted towards meeting 

minimum monitoring requirements.] 

62. Minimum monitoring requirements met for Pb [Note: AppD4.5 N/A N/A- no current 

Only monitors considered to be required SLAMs are 58.13(a) requirement 

eligible to be counted towards meeting minimum 

monitoring requirements.] 

63. Minimum # of monitors for PM2.5 [Note 1: should be AppD, Yes, p.4 Yes 

supported by MSA ID, MSA population, DV, # 4.7.l(a) and 

monitors, and# required monitors] [Note 2~ Only Table D-5 

monitors considered to be required SLAMs are 

eligible to be counted towards meeting minimum 

monitoring requirements.] 

64. Optional PM2.s Network Clarifications: Provide a list Need to N/A N/A 

of required sites if it does not include all SLAMS. assess several 

[Note: default will assume all SLAMS are considered requirements 

required sites.] 

65. Required PM2.s sites represent area-wide air quality AppD . Yes Yes 

4.7.!{1>) 

66. For PM25, is at least one site at neighborhood or larger AppD Yes,p.28 Yes 

scale in an area of expected maximum concentration 4.7.l(b)(l) 

67. If additional SLAMS PM2.

5 required, is there a si~ in .A.ppD N/A N/A- no additional 

an area of poor air quality 4.7.1(b)(2) sites required 

68. Minimum monitoring requirements for continuous AppD4.7.2 Yes, p.4 Yes 

PM2.s 

69. Requirements for PM2.

5 background and transport App D 4.7.3 N/A N/A- state 

sites requirement 

70. Are PM2.

5 Chemical Speciation requirements met for AppD4.7.4 Yes,p.29 Yes 

official STN sites? 

71. Minimum# of monitors for PM10 App D, 4.6 (a) Yes,p.5 Yes 

and Table D-4 

8 
ANP requirement Citation Was the info Does the Notes I within 40 submitted?1 If information 

CFR58 yes, page #s. provided3 meet I 

Flag if the req?4 

incorrecf? 

72. Minimum monitoring requirements met for PM10 .. 2.s AppD4.8 Yes, p.28-29 Yes 

mass 

73. Distance of site from nearest road AppE6 Yes, p.12-39 Insufficient to judge -The Reno3 site is listed as 6.7 m from River 

atReno3 Rock Road and does not provide traffic estimates 

for this road. This does not meet the minimum 

Yes- all others requirement of 1Om for ozone, oxides of nitrogen 

(NO, N02, NOy), and CO monitoring at the 

neighborhood scale. Please clarify this situation in 

next year's plan. Options for clarifying the 

situation may include revisiting the spatial scale 

or seeking of a waiver per 40 CFR 58, Appendix 

E, Section 10. 

-All parameters (Ozone, CO, & PM10) at the Toll 

site are listed as middle scale due to the distance 

from the probe to the nearest roadway. Ozone and 

PM10 are of sufficient distance from the road to be 

considered neighborhood scale. AQMD may 

choose to reexamine the scale for two parameters 

as deemed appropriate. 

74. Traffic count of nearest road AppE Yes, p.12-39 Yes 

75. Groundcover AppE 3(a) Yes, p.12-39 Yes 

76. Probe height AppE2 Yes, p.14-41 Yes 

77. Distance from-supporting structure AppE2 Yes, p.14-41 Yes 

78. Distance from obstructions on roof App E4(b) Yes, p.14-41 Yes 

79. Distance from obsP"uctions not on roof AppE4(a) Yes, p.14-41 Yes 

80. Distance from trees AppES Yes, p.14-41 Yes 

81. Distance to furnace or incinerator flue A_pp E 3(b)_ Yes,p.14-41 Yes 

82. Unrestricted airflow AppE, 4(a) Yes, p.14-41 Yes 

and4(b) 

83. Probe material (if applicable) AppE9 Yes, _1).14-41 Yes 

84. Residence time (if applicable) AppE9 Yes, p.14-41 Yes 

9 
Public Comments on Annual Network Plan 

Were comments submitted to the S/L/T agency during the public comment period? No 

If no, skip the remaining questions. 

If yes: 

• Were any of the comments substantive? 

o If yes, which ones? 

o Explain basis for determination if any comments were considered not substantive: 

• Did the agency respond to the substantive comments? 

o If yes, was the response adequate? 

• Do the substantive comments require separate EPA response (i.e., agency response wasn't adequate)? 

• Are the sections of the annual network plan that received substantive comments approvable after consideration of comments? 

o If yes, provide rationale: 

10