### 1 **Attachment A: Annual**  **Air Monitoring Network Plan Checklist**  Year: 2012 Agency : Nevada Division of Environmental Protection: Bureau of Air Quality Planning 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. 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 f uture and we welcome comments on its contents and structure. Key : White = meets the requirement Grey = Requirement not applicable for this year’s plan Yellow = does not meet or cannot judge the requirement

– action requested in next year’s plan or outside the ANP pro cess 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 in**  **correct 2**  

### ? **Does the** 

**information provided** **3** 

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

### Notes

1. Submit plan by July 1 st 58.10 (a)(1) Yes Yes . Electronic plan submitted on July 2, please aim to submit by or prior to July 1. 2. Statement of purpose for each monitor 58.10 (a)(1) Yes, p.10 - 26 Yes 3. 30 - day public comment / inspection period 58.10 (a)(1), 58.10 (a)(2) Yes, cover letter &

p.30 Yes 4. M odifications 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.5 - 6 Yes - At this time, EPA is not acting on the approval of the Harvey’s S tateline CO monitor closure because it is the last monitor in the maintenance area and under 40 CFR 58.14(c)(3), a SIP with a specific reproducible approach to monitoring must first be approved.

- EPA approves the Carson City site reloc ation from 3300 East 5 th Street to 2 601 S. Carson Street . A separate letter documenting this approval was emailed on 12/12/2012 and should be referenced in next year’s plan . 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) N/A N/A- no such mo difications were found in EPA’s review. 6. Does plan include documentation (e.g., attached approval letter) for system mo difications that have been approved since last ANP approval? Yes, p.29 Yes 7. NCore plan submitted to Admin. by 7/1/2009 58.10 (a)(3) N/A 8. NCore site operational by 1/1/2011 58.10 (a)(3) N/A N/A- NDEP does not operate an NCore site. 9. Pb plan for ≥1.0 tpy sources submitted by 7/1/2009 58.10 (a)(4) N/A 1 Response options: N/A (Not Applicable), Yes, No, Incomplete, Incorrect. The responses “Incom plete” 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 in**  **correct 2**  

### ? **Does the** 

**information provided** **3** 

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

### Notes

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 N/A- no Pb mo nitoring requirement. 13. NO2 plan for area - wide and RA40 sites submitted by 7/1/2012 58.10 (a)(5) N/A N/A- no requirement for NO2 monitoring. 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) N/A N/A- no requirement for NO2 monitoring. 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 58.13(e)(2) N/A 23. AQS site identification num ber for each site 58.10 (b)(1) Yes, p.10 - 26 Yes 24. Location of each site: street address and geographic coordinates 58.10 (b)(2) Yes, p.10 - 26 Yes Please include a street address for Harvey’s Casino and Resort site on p.14. 25. Sam

pling and analysis method(s) for each measured parameter 58.10 (b)(3) Yes, p.10 - 26 Yes The CO SLAMS monitor at Harvey’s Ca sino listed on p.14 does not appear to report an accurate FRM or FEM instrument code . Upon follow- up

### 4

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

**submitted? 1**  

### If **yes, page #s .**  **Flag if in**  **correct 2**  

### ? **Does the** 

**information provided** **3** 

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

### Notes

clarification with the agency, EPA has verified that a ty po was reported for the CO monitor and that it is indeed a designated FRM or FEM. Please ensure this typo is corrected in next year’s plan. 26. Operating schedule for each monitor (see items 6 2 - 6 6 ) 58.10 (b)(4) Yes Yes (see items 62 - 66) 27. Any proposals to remove or move a monitoring station within a period of 18 months following plan submittal 58.10 (b)(5) Yes Yes 28. S cale of representativeness for each monitor as defined in Appendix D 58.10(b)(6); App D Yes, p.10 - 26 Yes 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) N/A N/A- No PM 2.5 mo nitors identified. 30. MSA, CBSA, CSA or other area represented by the mo nitor 58.10 (b)(8) Yes , 10 - 26 Yes - For Elko and Fallon, please clarify that MSA stands for Micropolitan Statistical Area (p.10 & 12)

- For Harvey’s Casino and Resort, please modify “rural MSA” to read “Gardnerville Ranchos Micropolitan Statistical Area”(p.14)

- 

### Fernley should be Reno - Sparks - Fernley CSA and Fernley Micropolitan Statistical Area (p.16)

- For the Carson City site, please clarify the MSA stands for Metropolitan Statistical Area (p.18)

- For Pahrump sites, please clarify that Pahrump is a Micropolitan Statistical Area and that Las Vegas - Paradise - Pahrum

p is a CSA (p.20 - 26) 31. D esignation of any Pb monitors as either source oriented or non- source - oriented 58.10 (b)(9) N/A N/A- no current requirement 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- no current requirement 33. Any Pb monitor for which a waiver has been requested or granted by EPA RA for us of Pb - PM10 in lieu of Pb - TSP 58.10 (b)(11) N/A N/A- no current requirement 34. Identification of required NO2 monitors as either near-road or area - wide 58.10 (b)(12) N/A 35. Document how

states and local agencies provide for 58.10 (c) N/A N/A- No PM 2.5

### 5

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

**submitted? 1**  

### If **yes, page #s .**  **Flag if in**  **correct 2**  

### ? **Does the** 

**information provided** **3** 

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

### Notes

the review of changes to a PM2.5 monitoring network that impact the location of a violating PM2.5 mo nitor. 6 mo nitors identified. 36. Plan to modify the network that complies with findings of the 5 - year network 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.3 Yes NDEP states that they intend to submit this information for the 2011 data year by May 1, 2012. 38. Annual data certification submitted 58.15 App. A 1.3 Yes, p.3 Yes 39. Frequency of flow

rate verification for manual PM samplers audit App A 3.3.2 N/A N/A- No PM 2.5 mo nitors identified. All PM10 monitoring done with continuous

instruments. 40. Frequency of flow

rate verification for automated PM analyzers audit App A 3.2.3 Yes, p.10, 20, 22, 24, 26 Yes 41. Frequency of one -point flow rate verification for Pb samplers audit App A 3.3.4.1 N/A 42. Frequency of one -point QC check (gaseous) App. A 3.2.1 Yes, p.12, 14, 16, 18. Yes EPA found all gaseous sites are listed as having semi - monthly one -point QC checks . Checks are required at least onc e every two weeks unless agencies have been approved for an alternative schedule . Upon further follow-up with NDEP, the agency has cl arified that these checks do occur at least once every two weeks. Please adjust next’s year’s plan to report the accurate schedule. 43. Date of last Annual Performance Evaluation (gaseous) App. A 3.2.2 Yes, p.12, 14, 16, 18 Yes 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.10, 20, 22,

24, 26 Yes 45. Dates of last two semi - annual flow rate audits for Pb App A N/A N/A- no current 6 The affected state or local agency must document the process for obtaining public comment and include any comments received through the pu blic 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 in**  **correct 2**  

### ? **Does the** 

**information provided** **3** 

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

### Notes

mo nitors 3.3.4.1 requirement 46. PM2.5 co - location App A 3.2.5 N/A N/A- No PM 2.5 mo nitors identified. 47. Distance between co - l ocated monitors App. A 3.2.5.6 N/A N/A- No collocated mo nitors identified. 48. Manual PM10 method co - location met? (note: continuous PM10 does not have this requirement) App A 3.3.1 N/A N/A- no current requirement NDEP currently operates all continuous

instruments 49. Pb co - location App A 3.3.4.3 N/A N/A- no current requirement 50. PM10 - 2.5 co - location (note: only applies to Fresno and Phoenix NCore sites) App A 3.3.6 N/A N/A- no current requirement 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 Yes - EPA requirement 9 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.10 - 26 Yes Method code s lists for FEM & FRM instruments are published on EPA AMTIC website available at: http://www.epa.gov/ttnamti1/files/ambient/criteria/ reference - equivalent- methods - list.pdf 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.10 - 22 Yes

57. Instrument monitor type for each monitor Required to Yes, p.4 Yes 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. 9 EPA has reviewed EPA documentation to confirm that these requirements have been met for the area in questi on.

### 7

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

**submitted? 1**  

### If **yes, page #s .**  **Flag if in**  **correct 2**  

### ? **Does the** 

**information provided** **3** 

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

### Notes

determine if other req. (e.g., min # and co - lo) are met 58. Monitoring objective for each instrument App D 1.1 58.10 (b)(6) Incorrect , p.10 - 26 In sufficient to judge. The current “Monitor Objective” rows should be

changed to “Site Type.” Monitor Objective refers to one or more of three basic monitoring objectives: (1) provide air pollution data to the general public in a timely manner, (2) support compliance with ambient air quality standards and emissions strategy development, and (3) support air pollution research studies. See attachment D of the 2012 Annual Monitoring Network Plan memo sent by EPA R9 for further guidance. Please add correct monitor objective for each mo nitor in next year’s plan. 59. Site type for each instrument App D 1.1.1 Yes, p.10 - 26 Yes - Information was submitted as “Monitor Objective.” Please change row name to “Site Ty pe.”

- Church site on p.20 should be changed to “Source Oriented” site type if the purpose of the monitor is targeted to capture the dry lake bed source described in the plan.

- See related check#58 above. 60. Instrument parameter code for each instrument Required to determine if other req. (e.g., min # and co - lo) are met Yes, p.10 - 26 Yes Recommend modifying “Pollutant” row name to read “Pollutant/Parameter Code” in order to clarify that the Parameter code is also being reported. 61. Instrument parameter occurrence code for each instrument Required to determine if other req. (e.g., min # and co - lo) are met N/A N/A- NDEP operates one parameter at each site. EPA recommends the reporting of Parameter

Occurrence Code (POC) as separate line in the detailed site information tables . This will be especially useful for any collocations that may be established in the future.

### 8

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

**submitted? 1**  

### If **yes, page #s .**  **Flag if in**  **correct 2**  

### ? **Does the** 

**information provided** **3** 

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

### Notes

See Attachment C of the 2012 Annual Monitoring Network Plan memo sent by EPA R9 for suggested format to report POC. 62. Sam

pling season for ozone (note: date of waiver approval must be included if the sampling season deviates from requirement) App D, 4.1(i) Yes, p.12, 16, 18, 28 Yes “Operation Schedule” row should be adjusted to “continuous” for current ozone monitors. “Sampling Season” row should be adjusted to “April 1

– October 31” for current ozone monitors at Carson City, Fernley, and Fallon. 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 N/A N/A- No PM 2.5 mo nitors identified. 64. Sam

pling schedule for PM10 58.12(e) App D 4.6 Yes, p.10, 20, 22,

24, 26 Yes 65. Sam

pling schedule for Pb 58.12(b) App D 4.5 N/A N/A- no current requirement 66. Sam

pling schedule for PM10 - 2.5 58.12(f) App D 4.8 N/A N/A- no current requirement 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.5 Yes 68. Identification of max. conc. O3 monitor(s) App D 4.1 (b) Yes, p.5 Yes Ozone design values are reported for each of the sites in NDEP’s network, however a site capturing maximum ozone concentration for the Carson City MSA is not currently specified . Please label the site with the highest design value as the maximum concentration in next year’s plan. For this year’s plan for example, that site would be the Carson City 5 th Street site. 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 NO2 App D 4.3.4 N/A 72. Minimum monitoring requirements met for SO2 App D 4.4 N/A N/A- no current

### 9

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

**submitted? 1**  

### If **yes, page #s .**  **Flag if in**  **correct 2**  

### ? **Does the** 

**information provided** **3** 

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

### Notes

requirement 73. Minimum monitoring requirements met for CO App D 4.2 N/A 74. Minimum monitoring requirements met for Pb App D 4.5 58.13(a) N/A N/A- no current requirement 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 No Insufficient to judge - PM2.5 mi nimum monitoring requirements are not

specified . The Carson City Metropolitan Statistical Area is above the 50,000 population threshold and may require a SLAMS site. Please specify PM2.5 minimum monitoring requirements and include supporting information in next year’s plan .

- Please also include detailed site information for any SPM PM2.5 monitoring. 76. Required PM2.5 sites represent community - wide air quality at neighborhood or urban scale App D 4.7.1(b) N/A N/A- No PM 2.5 mo nitors identified. 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) N/A N/A- No PM 2.5 mo nitors identified. 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) N/A N/A- No PM 2.5 mo nitors identified. 79. Minimum monitoring requirements for continuous PM2.5 App D 4.7.2 N/A N/A- No PM 2.5 mo nitors identified. 80. Requirements for PM2.5 background and transport sites App D 4.7.3 No Insufficient to judge - This requirement may be met by sites operated by

other agencies in Nevada or outside of the state if comparable. Please clarify how this requirement is being met in next year’s plan. 81. Are PM2.5 Chemical Speciation requirements met for official STN sites? App D 4.7.4 N/A N/A- no current requirement 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.5 Yes 84. Minimum monitoring requirements met for PM10 - 2.5 mass App D 4.8 N/A N/A- no current requirement 85. Distance of site from nearest road App E 6 Yes, p.10 - 26 Yes 86. Traffic count of nearest road App E Yes, p.10 - 26 Yes

### 10

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

**submitted? 1**  

### If **yes, page #s .**  **Flag if in**  **correct 2**  

### ? **Does the** 

**information provided** **3** 

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

### Notes

87. Groundcover App E 3(a) Yes, p.10 - 26 Yes 88. Probe height App E 2 Yes, p.10 - 26 Yes 89. Distance from supporting structure App E 2 Yes, p.10 - 26 Yes 90. Distance from obstructions on roof App E 4(b) Yes, p.10 - 26 Yes For future obstructions that may exist , please include distance and height of obstruction . 91. Distance from obstructions not on roof App E 4(a) No Insufficient to judge Please include in next year’s network plan

information on any potential obstructions not on roof. Please ensure that distance and height for any po tential obstruction is specified . 92. Distance from trees App E 5 Yes, p.10 - 26 No for CO monitor at Harvey’s. Yes - all others 90% of the monitoring path must be at least 10

meters or further from the drip line of trees. The trees at Harvey’s are only 4 meters away. Per 40 CFR 58, App.E 5(c) please clarify whether any trees or shrubs are located between the probe and the roadway. 93. Distance to furnace or incinerator flue App E 3(b) Yes, p.10 - 26 Yes 94. Unrestricted airflow App E , 4(a) and 4(b) Yes, p.10 - 26 Yes 95. Probe material (if applicable) App E 9 Yes, p.10 - 26 Yes 96. Residence time (if applicable) App E 9 Yes, p.10 - 26 Yes 

### Public Comments on Annual Network Plan Were comments submitted to the S/L/T agency during the public comment period? **Yes . John Mosley, Environmental Director, Pyramid Lake Paiute**  **Tribe** Were any of the comments substantive? **No, with respect to the annual network plan ,**  **however EPA believes Pyramid Lake raises a good suggestion to NDEP with their #3 listed**  **comment . In NDEP’s evaluation of their PM2.5 monitoring network** **, as part of the**  **next 5**  **- year network assessment**  **, it would be a good idea to examine concentrations from**  **nearby monitoring .**