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 speciation 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 future 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 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?1If 

yes, page #s. 

Flag if 

incorrect2?

Does the 

information 

provided3 meet 

the req?

4

Notes 

1. Submit plan by July 1st 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. Modifications to SLAMS network – case when we are 

not approving actual system modifications (i.e., we 

will do it outside the ANP process5)

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 Stateline 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 relocation

from 3300 East 5th Street to 2601 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. Modifications 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 

modifications were 

found in EPA’s 

review.

6. Does plan include documentation (e.g., attached 

approval letter) for system modifications 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 “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?1If 

yes, page #s. 

Flag if 

incorrect2?

Does the 

information 

provided3 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 

monitoring 

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 number 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. Sampling and analysis method(s) for each measured 

parameter

58.10 (b)(3) Yes, p.10-26 Yes The CO SLAMS monitor at Harvey’s Casino 

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?1If 

yes, page #s. 

Flag if 

incorrect2?

Does the 

information 

provided3 meet 

the req?

4

Notes 

clarification with the agency, EPA has verified that

a typo 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 62-66) 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. Scale 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 PM2.5 

monitors identified.

30. MSA, CBSA, CSA or other area represented by the 

monitor

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-Pahrump is a CSA (p.20-26)

31. Designation of any Pb monitors as either sourceoriented or non-source-oriented58.10 (b)(9) N/A N/A- no current 

requirement

32. Any source-oriented Pb site for which 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 PM2.5 
5

ANP requirement Citation 

within 40 

CFR 58

Was the info 

submitted?1If 

yes, page #s. 

Flag if 

incorrect2?

Does the 

information 

provided3 meet 

the req?

4

Notes 

the review of changes to a PM2.5 monitoring network 

that impact the location of a violating PM2.5 

monitor.6

monitors 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 network 

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 PM2.5 

monitors 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 once every two weeks unless 

agencies have been approved for an alternative 

schedule. Upon further follow-up with NDEP, the 

agency has clarified 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 

monitors

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 public notification process within 

their submitted plan.
6

ANP requirement Citation 

within 40 

CFR 58

Was the info 

submitted?1If 

yes, page #s. 

Flag if 

incorrect2?

Does the 

information 

provided3 meet 

the req?

4

Notes 

monitors 3.3.4.1 requirement

46. PM2.5 co-location App A 3.2.5 N/A N/A- No PM2.5 

monitors identified.

47. Distance between co-located monitors App. A 

3.2.5.6

N/A N/A- No collocated 

monitors 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 

requirement7

52. Required # of Pb PEP audits App A 

3.3.4.4

N/A Yes - EPA 

requirement8

53. Required # of NPAP audits (or approved equivalent) App A 2.4 Yes - EPA 

requirement9

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 codes 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 question.
7

ANP requirement Citation 

within 40 

CFR 58

Was the info 

submitted?1If 

yes, page #s. 

Flag if 

incorrect2?

Does the 

information 

provided3 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 Insufficient 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 monitor 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 

Type.”

-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?1If 

yes, page #s. 

Flag if 

incorrect2?

Does the 

information 

provided3 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. Sampling 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. Sampling 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 PM2.5 

monitors identified.

64. Sampling schedule for PM10 58.12(e)

App D 4.6

Yes, p.10, 20, 22, 

24, 26

Yes

65. Sampling schedule for Pb 58.12(b)

App D 4.5

N/A N/A- no current 

requirement

66. Sampling 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, # 

monitors, 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 5th 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?1If 

yes, page #s. 

Flag if 

incorrect2?

Does the 

information 

provided3 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, # 

monitors, and # required monitors]

App D,

4.7.1(a) and 

Table D-5

No Insufficient to 

judge

-PM2.5 minimum 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 PM2.5 

monitors 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 PM2.5 

monitors 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 PM2.5 

monitors identified.

79. Minimum monitoring requirements for continuous 

PM2.5

App D 4.7.2 N/A N/A- No PM2.5 

monitors 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?1If 

yes, page #s. 

Flag if 

incorrect2?

Does the 

information 

provided3 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 

potential 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.