UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX 

75 Hawthorne Street 

San Francisco, CA 94105 

November 1, 2011

Mr. Kevin Dick, Director

Air Quality Management Division

Washoe County Health District

1001 East Ninth Street, Suite A115

P.O. Box 11130

Reno, NV 89520-0027

Dear Mr. Dick:

Thank you for your timely submittal of the 2011 Annual Monitoring Network Plan for the Washoe 

County Health District Air Quality Management Division (AQMD). EPA has reviewed the submitted 

document and found that it is complete, informative, very detailed and meets the requirements set forth 

under 40 CFR Part 58.10. We also appreciate your addressing in full our comments to last year’s 2010 

Network Plan. This letter serves as an official approval of the annual network plan and all of the 

proposed modifications except the Sparks site special purpose monitoring proposed for non-submission

into the AQS. This issue, along with special purpose monitoring at the Reno3 is further discussed in our 

enclosed comments. AQMD should continue to work with EPA Region 9 staff to obtain the proper 

documentation and approvals necessary to establish proper special purpose monitoring at the Sparks and 

Reno3 sites.

If you have any questions regarding this letter or the enclosed comments, please feel free to contact me 

at (415) 972-3851 or Elfego Felix at (415) 947-4141.

Sincerely,

/s/

Matthew Lakin, Manager

Air Quality Analysis Office

Air Division

Enclosure

cc: Craig Petersen, Senior Air Quality Specialist, AQMD

Julie Hunter, Air Quality Specialist, AQMD
Comments on 2011 Network Plan for Washoe County AQMD

Please update next year’s network plan to reflect the following comments:

1. 40 CFR 58.20(b) requires any SPM data collected using an FRM, FEM, or ARM must meet the 

requirements of §58.11, §58.12, and appendix A or an approved alternative. Furthermore, SPM data 

collected using an FRM, FEM, or ARM that meets appendix A must also report to AQS. Pertaining 

to this, EPA noted that the following corrections will need to be made for the AQMD network:

o For the new FEM particulate instruments that are planned for installation at the Sparks site 

(pp.8), AQMD will either need to meet the requirements of §58.11, §58.12, appendix A and 

submit data into AQS, or submit an alternative plan for EPA approval that may allow for 

non-submittal into AQS. 

o It was noted that AQMD also operates PM continuous FEM instruments as SPMs at the 

Reno3 site and is not currently submitting this data into AQS (pp.3). These Reno3 monitors 

will also either need to meet the requirements of §58.11, §58.12, appendix A and submit data 

into AQS, or submit an alternative plan for EPA approval that may allow for non-submittal 

into AQS. 

AQMD should continue to work closely with EPA Regional staff to ensure the appropriate 

documentation and approvals are in place that allow for particulate monitoring at the Sparks and 

Reno3 sites using FEM instrumentation that does not report to AQS.

2. The cover letter of AQMD’s network plan says that no comments were received during the public 

inspection period of the plan. Page 1 of the Network Plan however contains the following language: 

“Public comments received during the public inspection period were submitted along with this plan 

to EPA Region IX.” These two statements disagree. EPA requests that this information be clarified 

in next year’s plan and that a consistent message is delivered in the plan as well as the cover letter.