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. T his letter serves as an official approval of the annual network plan and all of the proposed modifica tions 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 co m ments , please feel free to contact me
at (41 5) 972

- 3851 or Elfego Felix at (415) 947

- 4 141

.

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, AQMDComments 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 instr uments 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 a pproval 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 comm ents received during the public inspection period were submitted along with this plan to EPA Region IX.” These two statements disagree. EPA r equests 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.