UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION IX 

75 Hawthorne Street 

San Francisco, CA 941 05-3901 

OCT 2 1 2015 

Mr. Daniel K. Inouye 

Chief, Monitoring and Planning Branch 

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's 2015 Ambient Air 

Monitoring Network Plan in July 2015. We have reviewed the submitted document based on the 

requirements set forth under 40 CFR 58. Based on the information provided in the plan, the U.S. 

Environmental Protection Agency (EPA) approves all portions ofthe network plan except those 

specifically identified below. 

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 infonnation being included, or discussion) in 

next year's annual monitoring network plan. 

We also want to thank you for your timely submission of the 2015 Ambient Air Monitoring 

Network Assessment for the Washoe County Health District, as required under 40 CFR Part 

Printed on Recycled Paper 
58.10. We recognize that preparing the network assessment was a significant project and we 

appreciate your effort. 

The recently revised ozone NAAQS, finalized on October 1, 2015, includes language that 

revokes all existing seasonal ozone waivers upon the effective date of the final rule. EPA Region 

9 will consider all previously approved ozone season waivers effective until December 31, 2015. 

In advance of the 2016 ozone monitoring season (January- December), EPA Region 9 

recommends that agencies seeking new ozone waivers for the 2015 8-hour Ozone NAAQS of 

0.070 ppm submit waiver requests no later than December 1, 2015. 

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

contact me at (415) 947-4534 or Michael Flagg at (415) 972-3372. 

Enclosures: 

Sincerely, 

lU~~ Meredith Kurpius, M'anagj 

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 (via email): Craig Petersen, Washoe County AQMD 
A. Annual Monitoring Network Plan Items where EPA is Not Taking Action 

We are not acting on the portions of annual network plans where either EPA Region 9 lacks the 

authority to approve specific items of the plan, or EPA has determined that a requirement is 

either not met or information in the plan is insufficient to judge whether the requirement has 

been met. 

• Per 40 CFR 58.11(c), NCore, PAMS, and STN network design and changes are subject to 

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 58.1 0 and the associated 

appendices. Therefore, we are not acting on the following items: 

Item Checklist Row Issue 

For low volume PM 17 Insufficient information to judge 

instruments (flow rate< 200 

liters/minute), all other PM 

instruments are > 1 m from 

the lovol. If no, list distance 

(meters) and instruments. 

Distance from supporting 78 Not meeting requirement 

structure 

Additional infonnation 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). 
B. Additional Items Requiring Attention 

• [Item 21] The minimum monitoring requirements for PM2.s are specified in 40 CFR 58 

Appendix D 4.7.1(a) in terms of number of sites: "State, and where applicable local, 

agencies must operate the minimum number of required PM2.s SLAMS sites listed in 

Table D-5 of this appendix" not number of monitors. Please modify next year's ANP to 

present this requirement in terms of number of sites. 

• [Item 22] There is a requirement for one continuous monitor per 40 CFR 58 Appendix D 

4.7.2. There were three sites in 2014 with continuous PM2.s FEM monitors operating. 

Although there is information in this year's ANP demonstrating the requirement is met, it 

doesn't specifically discuss the requirement in 40 CFR 58 Appendix D 4.7.2. Please 

consider adding this to next year's plan, for example, in a footnote or paragraph 

following Table 4. 
C. ANNUAL MONITORING NETWORK PLAN CHECKLIST 

(Updated October 1, 2015) 

Year: 2015 

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

40 CFR 58.10(a)(l) requires that each Annual Network Plan (ANP) include information regarding the following types of 

monitoring stations including FRM, FEM, and ARM monitors that are part of SLAMS, NCore stations, STN stations, Sta

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

40 CFR 58.1 0( a)( 1) further directs that, "The plan shall include a statement of purposes for each monitor and evidence th

each monitor meets the requirements of appendices A, C, D, and E of this part, where applicable." On this basis, review o

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 A

Regional Administrators, but we will do a check to see if the required information is included and correct. The items requ

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 r

contents provide a binding determination of compliance with those requirements. The checklist is subject to revision in th

comments on its contents and structure. 

Key: 

White I meets the requirement 

Yellow I requirement is not met, or information is insufficient to make a determination. Action requested in next year's p

process (items listed in Enclosure A). 

p reen J item requires attention in order to improve next year's plan (items listed in Enclosure B). 
ANP requirement Citation Was the Does the Notes 

within 40 information information 

CFR58 submitted? 1 If provided3 meet 

yes, page #s. the 

Flag if requirement?4 

incorrect2? 

GENERAL PLAN REQUIREMENTS .......... •.. .• . .~. ;c. >> ·.··· . .. 

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

2. 30-day public comment I inspection period5 58.10 (a)(1), Yes, transmittal Yes No comments re

58.10 (a)(2) email 

3. Modifications to SLAMS network- case when we 58.10 (a)(2) Yes, pages 9-11 Yes None 

are not approving system modifications 58.10 (b)(5) 

58.10(e) 

58.14 

4. Modifications to SLAMS network- case when we 58.10 (a)(2) NA NA None 

are approving system modifications per 58.14 58.10 (b)(5) 

58.10(e) 

58.14 

5. Does plan include documentation (e.g., attached Yes, Appendix Yes Plan includes EP

approval letter) for system modifications that have A&B site closure, the 

been approved since last ANP approval? and expected co

Reno discontinu

6. Any proposals to remove or move a monitoring 58.10 (b)(5) Yes, pages 9-11 Yes Site initiation of 

station within a period of 18 months following plan 5) 

submittal 

7. A plan for establishing a near-road PM2.s monitor (in 58.10(a)(8)(i) NA NA 

CBSAs 2::2.5 million) by 11112015 (plan was due 

July 1, 2014) 

8. A plan for establishing a near-road CO monitor (in 58.10(a)(7) NA NA 

CBSAs 2:: 2.5 million) by 11112015 (plan was due 58.13(e)(1) 

July 1, 2014) 

9. N02 plan for establishment of 2nd near-road monitor 58.10 NA NA 

by 11112015 (plan was due July 1, 2014) (a)(5)(iv) 

1 Response options: NA (Not Applicable), Yes, No, Incomplete, Incorrect. The responses "Incomplete" and "Incorrect" assume that some inform

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 pub

their submitted plan. 
ANP requirement Citation Was the Does the Notes 

within 40 information information 

CFRSS submitted? 1 If provided3 meet 

yes, page #s. the 

Flag if requirement?4 

incorrect2? 

10. Precision/ Accuracy reports submitted to AQS 58.16(a); Yes, page 11 Yes 

App A, 1.3 

and 5.1.1 

11. Atmual data certification submitted 58.15 Yes, page 11 Yes 

App. A 1.3 

12. Statement that SPMs operating an FRM/FEM/ ARM 58.11 (a)(2) NA NA No SPMs curren

that meet Appendix E also meet either Appendix A 

or an approved alternative. Documentation for any 

Appendix A approved alternative should be 

included.6 

13. SPMs operating FRM/FEM/ ARM monitors for over 58.20(c) NA NA No SPMs curren

24 months are listed as comparable to the NAAQS or 

the agency provided documentation that 

requirements from Appendices A, C, or E were not 

met. 7 

14. For agencies that share monitoring responsibilities in App D 2(e) NA NA 

an MSA/CSA: this agency meets full monitoring 

requirements or an agreement between the affected 

agencies and the EPA Regional Administrator is in 

place 

GENERAL PARTICULATE MONITORING REQUIREMENTS (PMtoiPJ\1'z.S:;l~~..;:~~~;s~)£~;t':tii~)z2~~~y ·.·.·.·.·••·• 

7 h:.. ..· .. ···· .. · .· ...•.. . 

15. Designation of a primary monitor if there is more Need to Yes, page 30-31 Yes 

than one monitor for a pollutant at a site. determine 

collocation 

16. Distance between QA collocated monitors (Note: App.A Yes, page 31 Yes 

waiver request or the date of previous waiver 3.2.5.6 and 

approval must be included if the distance deviates 3.2.6.3 

from requirement.) 

6 Alternatives to the requirements of appendix A may be approved for an SPM site as part of the approval of the annual monitoring plan, or separ

7 This requirement only applies to monitors that are eligible for comparison to the NAAQS per 40 CFR §§58.1l(e) and 58.30. 
ANP requirement Citation Was the Does the Notes 

within 40 information information 

CFR58 submitted? 1 1f provided3 meet 

yes, page #s. the 

Flag if requirement? 4 

incorrect2? 

17. For low volume PM instruments (flow rate < 200 AppE Incomplete Insufficient Info Please include d

liters/minute), all other PM instruments are > 1 m ANP 

from the lovol. If no, list distance (meters) and 

instruments. 

18. For high volume PM instruments (flow rate > 200 AppE NA NA None 

liters/minute), all other PM instruments are > 2m 

from the hivol. If no, list distance (meters) and 

instruments. 

I PM2.5 -SPECIFIC MONITORING REQUIREMENTS - 

19. Document how states and local agencies provide for 58.10 (c) Yes, pages 1 0-11 Yes 

the review of changes to a PM2.5 monitoring network 

that impact the location of a violating PM25 monitor. 

20. Identification of any PM2.5 FEMs and/or ARMs not 58.10 (b)(13) NA NA 

eligible to be compared to the NAAQS due to poor 58.11 (e) 

comparability to FRM(s) (Note 1: must include 

required data assessment.) (Note 2: Required 

SLAMS must monitor PM2.5 with NAAQScomparable monitor at the required sample 

frequency.) 

21. Minimum # of monitoring sites for PM2.5 [Note l: AppD, Yes, Pages 4-5 Yes Note the minim

should be supported by MSA ID, MSA population, 4.7.l(a) and PM2.s are specif

DV, # monitoring sites, and # required monitoring Table D-5 4.7.l(a) in terms 

sites] [Note 2: Only monitors considered to be where applicabl

required SLAMs are eligible to be counted towards minimum numb

meeting minimum monitoring requirements.] listed in Table D

monitors. Pleas

this requirement 
ANP requirement Citation Was the Does the Notes 

within 40 information information 

CFR58 submitted? 1 If provided3 meet 

yes, page #s. the 

Flag if requirement? 4 

incorrect2? 

22. Requirements for continuous PMz.s monitoring App04.7.2 Yes, Pages 4-5 Yes There is a requi

(number of monitors and collocation) See Note per 40 CFR 58 A

sites in 2014 wi

operating. Altho

year's ANP dem

doesn't specific

CFR 58 Append

this to next year

paragraph follow

23. FRM/FEM/ ARM PMz.s QA collocation App A3.2.5 Yes, Page 8 Yes 

24. PMz.s Chemical Speciation requirements for official App D 4.7.4 Yes, Page 30 Yes 

STN sites 

25. Identification of sites suitable and sites not suitable 58.10 (b)(7) Yes, Detailed site Yes 

for comparison to the annual PMz.s NAAQS as information 

described in Part 58.30 

26. RequiTed PMz.s sites represent area-wide air quality AppD Yes, Detailed site Yes 

4.7.l(b) information 

27. For PMz.s, within each MSA, at least one site at AppD Yes, Detailed site Yes Galetti is listed 

neighborhood or larger scale in an area of expected 4.7 .l(b)(l) information 

maximum concentration 

28. Minimum monitoring requirement for near-road 58.13(f)(l) NA NA 

PMz.s monitor (in CBSA ~ 2.5 million) by 111/2015 AppD 

4.7.1(b)(2) 

29. If additional SLAMS PMz.s is required, there is a site AppD NA NA 

in an area of poor air quality 4. 7.1(b)(3) 

30. States must have at least one PMz.s regional AppD4.7.3 NA NA This requiremen

background and one PMz.s regional transport site. state. 

31. Sampling schedule for PMz.s - applies to year-round 58.10 (b)(4) Yes, Detailed site Yes 

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

waiver approval must be included if the sampling App D 4.7 

season deviates from requirement) EPA 

flowchart 

32. Frequency of flow rate verification for manual PMz.s AppA3.3.2 Yes, Detailed site Yes 

monitors audit information 

33. Frequency of flow rate verification for automated App A 3.2.3 Yes, Detailed site Yes 

PMz.s monitors audit information 
ANP requirement Citation Wasth~ Does the Notes 

within 40 information information 

CFR58 submitted? 1 If provided3 meet 

yes, page #s. the 

Flag if requirement?4 

incorrect2? 

34. Dates of two semi-annual flow rate audits conducted App A, 3.2.4 Yes, Detailed site Yes 

in CY2014for PMz.s monitors and 3.3.3 information 

I PM to -SPECIFIC MONITORING REQUIREMENTS . 

35. Minimum # of monitoring sites for PM10 AppD, 4.6 Yes, Page 5 Yes 

(a) and Table 

D-4 

36. Manual PM10 method collocation (note: continuous App A3.3.1 NA NA 

PM10 does not have this requirement) 

37. Sampling schedule for PM10 58.10 (b)(4) Yes, Detailed site Yes 

58.12(e) information 

AppD4.6 

38. Frequency of flow rate verification for manual PM10 App A3.3.2 NA NA The only manua

monitors audit QA-collocated P

39. Frequency of flow rate verification for automated AppA3.2.3 Yes, Detailed site Yes 

PM10 monitors audit information 

40. Dates of two semi-ammal flow rate audits conducted App A, 3.2.4 Yes, Detailed site Yes 

in CY2014 for PM10 monitors and 3.3.3 information 

I Pb -SPECIFIC MONITORING REQUIREMENTS ,';, ::: {'~'~1:/:c'f:"' '"y:r:::;(,)N1;·,,/' ,;::::,>:;:~:::~~~{,~'{',,, 

41. Minimum # of monitors for non-NCore Pb [Note: App D4.5 Yes, Page 7 Yes None 

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

eligible to be counted towards meeting minimum 

monitoring requirements.] 

42. Pb collocation: for non-NCore sites App A 3.3.4.3 NA NA 

43. Any source-oriented Pb site for which a waiver has 58.10 (b)(10) NA NA 

been granted by EPA Regional Administrator 

44. Any Pb monitor for which a waiver has been 58.10 (b )(11) NA NA 

requested or granted by EPA Regional Administrator 

for use ofPb-PM10 in lieu ofPb-TSP 

45. Designation of any Pb monitors as either source- 58.10 (b)(9) NA NA 

oriented or non-source-oriented 

46. Sampling schedule for Pb 58.10 (b)(4) NA NA 

58.12(b) 

AppD4.5 
ANP requirement Citation Was the Does the Notes 

within 40 information information 

CFR58 submitted? 1 If provided3 meet 

yes, page #s. the 

Flag if requirement?4 

incorrect2? 

47. Frequency of flow rate verification for Pb monitors App A 3.3.4.1 NA NA 

audit 

48. Dates of two semi-annual flow rate audits conducted App A 3.3.4.1 NA NA 

in CY2015 for Pb monitors 

I GENERAL GASEOUS MONITORING REQUIREMENTS 

49. Frequency of one-point QC check (gaseous) App. A3.2.1 Yes, Detailed site Yes 

information 

50. Date of Annual Performance Evaluation (gaseous) App. A3.2.2 Yes, Detailed site Yes 

conducted in CY2014 information 

I 03. -SPECIFIC MONITORING REQUIREMENTS 

51. Minimum # of monitoring sites for 03 [Note: should App D, 4.1(a) Yes, page4 Yes 

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

monitoring sites, and# required monitoring sites] Table D-2 8 

52. Identification of maximum concentration 03 site( s) App D 4.1 (b) Yes, Detailed site Yes Sparks is listed 

information for 03. 

53. Sampling season for 0 3 (Note: Waivers must be 58.10 (b)(4) Yes, Detailed site Yes 

renewed ammally. EPA expects agencies to submit App D, 4.1 (i) information 

re-evaluations of the relevant data each year with the 

ANP. EPA will then respond as part of the ANP 

response.) 

NOz -SPECIFIC MONITORING REQUIREMENTS ' · .. · .• •· .•• >· :•'. ~·~1i'·2\ :.:·:;. \ ·. '<: . 

. .. 

54. Minimum monitoring requirement for single near- 58.13(c)(3) Yes, Detailed site Yes None required 

road NOz monitor (in CBSA > 1 million) by 1/1/2014 App D4.3.2 information 

55. Minimum monitoring requirement for second near- 58.13(c)(4) Yes, Detailed site Yes None required 

road NOz monitor (in CBSA ::0:: 2.5 million) by AppD information 

1/112015 4.3.2 

8 Only monitors considered to be required SLAMs are eligible to be counted towards meeting minimum monitoring requirements. In addition, oz

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

56.1 Minimum monitoring requirements for area-wide 

N02 monitor in location of expected highest N02 

· concentrations representing neighborhood or larger 

scale (operation required by January 1, 2013) 

57.1 Minimum monitoring requirements for susceptible 

and vulnerable populations monitoring (aka RA40) 

N02 (operation required by January 1, 2013) 

58.1 Identification of required N02 monitors as either 

near-road, area-wide, or vulnerable and susceptible 

population (aka RA40) 

NITORING REQU1REMENTS 

59. I Minimum monitoring requirement for near-road CO 

monitor (in CBSA 2: 2.5 million) by 11112015 

!!!!!!!!!!!!!!! 

SOz -SPECIFIC MONITORING REQUIREMENTS 

60. Minimum monitoring requirements for S02 [Note: 

Only monitors considered to be required SLAMs are 

eligible to be counted towards meeting minimum 

monitoring requirements.] 

61.1 NCore site and all required parameters operational: 

year-round 03, trace S02, trace CO, NOy, NO, PM2.s 

mass, PM2.s continuous, PM2.s speciation, PM10-2.s mass, resultant wind speed at 10m, resultant wind 

direction at 1Om, ambient temperature, relative 

humidity, and Pb at CBSAs 2: 500,000. 

I Citation 

within 40 

CFR58 

I App D4.3.3 

I AppD4.3.4 

I 58.10 (b)(12) 

App D 4.4 

58.10 (a)(3); 

Pb 

collocation 

App.A 

3.3.4.3; PM10. 

2.5 minimum 

monitoring 

App. D4.8; 

PM10-2.s 

sampling schedule 

58.10 (b)(4) 

Was the 

information 

submitted? 1 If 

yes, page #s. 

Flag if 

incorrect2? 

INA 

INA INA 

Yes, Detailed site 

information 

Yes, Detailed site 

information 

Does the 

information 

provided3 meet 

the 

requirement?4 

INA 

INA 

INA 

Yes 

Yes 

I Notes 

None required 

Washoe does no

No Pb is require

population is< 
ANP requirement Citation Was the Does the Notes 

within 40 information information 

CFR58 submitted? 1 If provided3 meet 

yes, page #s. the 

Flag if requirement?4 

incorrect2? 

58.12(£) 

AppD4.8; 

PM10.2.s 

collocation 

App. A3.3.6 

I siTE oR MONITOR- sPECIFic REQUIREMENTs (OFTEN INcLUDED IN tABLEs) 

.62. AQS site identification number for each site 58.10 (b)(l) Yes, Detailed site Yes 

information 

63. Location of each site: street address and geographic 58.10 (b)(2) Yes, Detailed site Yes 

coordinates information 

64. MSA, CBSA, CSA or other area represented by the 58.10 (b)(8) Yes, Detailed site Yes 

monitor information 

65. Parameter occurrence code for each monitor Needed to Yes, Detailed site Yes 

determine if information 

other 

requirements 

(e.g., min# 

and 

collocation) 

are met 

66. Statement of purpose for each monitor 58.10 (a)(l) Yes, Detailed site Yes 

information 

67. Basic monitoring objective for each monitor App D 1.1 Yes, Detailed site Yes 

58.10 (b)(6) information 

68. Site type for each monitor App D 1.1.1 Yes, Detailed site Yes 

information 

69. Monitor type for each monitor, and Network Needed to Yes, Detailed site Yes 

Affiliation(s) as appropriate determine if information 

other 

requirements 

(e.g., min# 

and 

collocation) 

are met 
ANP requirement Citation Was the Does the Notes 

within 40 information information 

CFRSS submitted? 1 1f provided3 meet 

yes, page #s. the 

Flag if requirement?4 

incorrect2? 

70. Scale of representativeness for each monitor as 58.10(b)(6); Yes, Detailed site Yes 

defined in Appendix D AppD information 

71. Parameter code for each monitor Needed to Yes, Detailed site Yes 

determine if information 

other 

requirements 

(e.g., min# 

and 

collocation) 

are met 

72. Method code and description (e.g., manufacturer & 58.10 (b)(3); Yes, Detailed site Yes 

model) for each monitor App C 2.4.1 .2 information 

73. Sampling start date for each monitor Needed to Yes, Detailed site Yes 

determine if information 

other 

requirements 

(e.g., min# 

and 

collocation) 

are met 

74. Distance of monitor from nearest road AppE6 Yes, Detailed site Yes 

information 

75. Traffic count of nearest road AppE Yes, Detailed site Yes 

information 

76. Groundcover App E 3(a) Yes, Detailed site Yes 

- information 

77. Probe height AppE2 Yes, Detailed site Yes 

information 

78. Distance from supporting structure AppE2 Yes, Detailed site No PM instruments 

information meters from any 

79. Distance from obstructions on roof (horizontal App E 4(b) Yes, Detailed site Yes 

distance to the obstruction and vertical height of the information 

obstruction above the probe should be provided) 

80. Distance from obstructions not on roof (horizontal App E 4(a) Yes, Detailed site Yes 

distance to the obstruction and vertical height of the information 

obstruction above the probe should be provided) 
ANP requirement Citation Was the 

within 40 information 

CFR58 submitted? 1 If 

yes, page #s. 

Flag if 

incorrect2? 

81. Distance from the drip line of closest tree(s) AppE5 Yes, Detailed site 

information 

82. Distance to furnace or incinerator flue App E 3(b) Yes, Detailed site 

information 

83. Unrestricted airflow (expressed as degrees around App E, 4(a) Yes, Detailed site 

probe/inlet or percentage of monitoring path) and4(b) information 

84. Probe material (NO/NOz/NOy, SOz, 03; For P AMS: AppE9 Yes, Detailed site 

VOCs, Carbonyls) information 

85. Residence time (NO/NOz/NOy, SOz, 03; For P AMS: AppE9 Yes, Detailed site 

VOCs, Carbonyls) information 

Public Comments on Annual Network Plan 

Were comments submitted to the S/LIT 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? 

Does the 

information 

provided3 meet 

the 

requirement?4 

Yes Yes Yes Yes 

Yes 

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? 

Notes 

For monitors <1

ANP explains "

leaf canopy den

unrestricted airf

the monitoring p

monitoring path 

line of the trees

• 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 

o If yes, provide rationale: