UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION IX 

75 Hawthorne Street 

San Francisco, CA 94105·3901 

DEC 1 1 2013 

Mr. Phil Wiker, Engineering Manager 

Clark County Department of Air Quality 

4 70 I West Russell Road, Suite 200 

Las Vegas, Nevada 89118 

Dear Mr. Wiker: 

Thank you for your submission of the Clark County Department of Air Quality (DAQ's) 2013 

Annual Network Plan Report in June 2013. We have reviewed the submitted document based on 

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

approves all portions of the 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 

58.1 0 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 

Allention) 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 fourth enclosure (D. Region 9 Near-road N02 Plan Review Checklist) is the 

checklist EPA used to review those elements of your annual monitoring network plan that deal 

specifically with near-road N02 monitoring. 

The first two enclosures highlight a subset of the more extensive list of items reviewed in the 

third and fourth enclosures. All comments conveyed via this letter (and enclosures) should be 

addressed (through corrections within the plan, additional information being included, or 

discussion) in next year's annual monitoring network plan. 

Prinu d on Htr:ycltd Papa 
If you have any questions regarding this letter or the enclosed comments, please feel free to 

contact me at (415) 947-4534 or Elfego Felix at (415) 947-4141. 

Enclosures: 

Sincerely, 

111_~~ - Meredith 

Air Quality 

Kurpius, 

Analysis 

Man:ge Office ~ 

A. Annual Monitoring Network Plan Items where EPA is Not Taking Action 

B. Additional Items Requiring Attention 

C. Annual Monitoring Network Plan Checklist 

D. Region 9 Near-road N02 Plan Review Checklist 

cc: YousafHameed, DAQ 

Lewis Wallenmeyer, DAQ 
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 is subject to approval of the EPA Administrator. Therefore, 

we are not acting on these items. 

• System modifications (e.g., site closures or moves) are subject to approval per 40 CFR 

58.14(c). Information provided in the plan was insufficient for EPA to approve the follow 

system modifications listed in the plan per the applicable requirement: 

- Green Valley site (page 44) 

- Additional site closures (page 44) 

Therefore, we are not taking action on these items as part of this year's annual network 

plan review. 

• Plans for establishing near-road N02 monitoring are required for submittal as part of the 

Annual Monitoring Network Plan per 40 CFR 58.10(a)(5). Information provided was 

insufficient for EPA to approve the proposed plan for establishing a near-road N02 

monitor in the Las Vegas-Paradise, NV CBSA per the applicable requirements. 

Therefore, we are not acting on this portion of the Annual Monitoring Network Plan. See 

Enclosure D (D. Region 9 Near-road N02 Plan Review Checklist) for more information. 

• 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 58.10 and the associated 

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

Item Checklist Row Issue 

Modifications to SLAMS 4 Insufficient to judge 

network 

N02 plan for near-road sites 11 Insufficient to judge 

submitted by 7/1/2013 

Distance from trees 80 Not meeting requirement in multiple 

instances. 

Dates of last two semi-annual 36 Not meeting requirement 

flow rate audits for Pb 

monitors 

Start dates for SPMs 25,45 Insufficient to judge in multiple instances 

Precision/ Accuracy reports 28 Insufficient to judge 

submitted to AQS 

Annual data certification 29 Insufficient to judge 
submitted 

Date of last Annual 34 Insufficient to judge 

Performance Evaluation 

(gaseous) 

Distance of site from nearest 73 Insufficient to judge in one instance 

road 

Distance from obstructions not 79 Insufficient to judge in one instance 

on roof 

Unrestricted airflow 82 Insufficient to judge in one instance 

Site type 48 Incorrect in one instance 

Additional information 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 6] In future network plans, please include copies of EPA approval letters for system 

modifications that were approved subsequent to approval of the previous year's network 

plan. 

• [Items 15, 43] On page 13, J.D. Smith lists for PM2.s: instrument model Thermo 5014i, 

method code EQPM-0609-183 and lists "Other" instead ofFRM!FEM. On page 5, since 

this monitor is being treated as FEM for PM2.5 collocation purposes, characterization as 

"other" (rather than "FEM") implies that this is a typo. This should be corrected in future 

network plans. 

• [Items 17, 48] On page 8, the 03 monitor at Boulder City has site type as population 

exposure and regional transport, with spatial scale of neighborhood. Please provide 

clarification for the appropriateness of neighborhood spatial scale for re~onal transport. 

• [Item 25] Information was provided that clarified why data from the Spring Mountain 

Youth Camp (SMYC) SPM was not eligible for comparison to the NAAQS. EPA is 

aware that DAQ has applied to participate in EPA's Ozone Advance program. In view 

that the high elevation SMYC SPM site has recorded elevated 0 3 readings, EPA 

recommends that DAQ evaluate in the 2015 Network Assessment, the appropriateness of 

03 monitoring at high elevations. In the assessment, it is recommended that DAQ 

evaluate the potential effects of ozone transport and stratospheric intrusion on high 

elevation areas of Clark County. 

• [Item 37] The ANP (pg. 5) proposes: a) replacing monitors using method code RFPS0598-120 with monitors using method code R.FPS-0498-118; b) movement of the current 

primary FRM monitor at Sunrise Acres to Jerome Mack for collocation with an FRM of 

the same method code; and c) naming of the remaining FRM at Sunrise Acres as the audit 

monitor collocated with the primary PM2.5 FEM. EPA notes that these proposed changes 

would enable the network configuration to meet collocation requirements. 

C. ANNUAL MONITORING NETWORK PLAN CHECKLIST 

(Updated 11 /26/20 13) 

Year: 2013 

Agency: Clark County Department of Air Quality (DAQ) 

40 CFR 58.1 O(a)( 1) requires that each Annual Network Plan {ANP) include information regarding the following types o

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

stations, and/or, in serious, severe and extreme ozone nonattainment areas, PAMS stations, and SPM monitoring station

40 CFR 58.1 O(a)( I) further directs that, "The plan shall include a statement of purposes for each monitor and evidence t

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

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 

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

Administrator are: PAMS, 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 

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

comments on its contents and structure. 

Key: 

White= meets the requirement. 

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

process. (items listed in Enclosure A) -·--.. , =item requires attention in order to improve next year's plan (items listed in Enclosure B) 
Citation Was the info Does the Notes 

within 40 submitted?1 If information 

CFR58 yes, page #s. provided3 

Flag if meet the req?4 

incorrect2? 

58.10 (a)( I) Yes Yes Plan received 20130610 

ach monitor 58. 10 (a)(1) Yes, pgs 6, 8, 10, Yes 

12, 15, 17, 21, 23, 

25, 27, 29, 32,34, 

nspection period' 58. 1.0 (a)(l), Yes, cover letter Yes No comments received 

58.10 (a)(2) 

network - case when we are 58.10 (a)(2) Incomplete, pg 44- Insufficient to Insufficient information provided to 

m modifications (i.e., we can 58.10(e) 45 Judge review/approve system modifications identified in 

ess6) Tables 13 & 14, pg. 44 and near-road site proposal 

on pg.45. EPA appreciates being informed of the 

change to Jerome Mack's site type from high 

concentration to population exposure, and the 

deployment of the Apex Sonic Detection and 

Ranging instruments. 

network - case when we are 58.10 (a)(2) Incomplete, pg. 44 Insufficient to See Row 4 comment. 

odifications per 58.14(c) 58.1 0 (b )(5) judge 

58.10(e) 

58.14 (c) 

ntation (e.g., attached Incomplete, pg. 44 Insufficient to Copies of EPA approval letters shouiEt be induded 

 modifications that have judge in future ANPs. 

ANP approval? - --

 I I I 120 II) 58. 10 (a)(3) Yes, pg 18 Yes 

ces operational (by 58.10 (a)(4) NA NA 

d RA40 sites submitted by 58. 10 (a)(5) Yes Yes Area-wide and RA 40 sites in place and operating. 

operational by 1.11/20 13 58. 10 (a)(5) Yes Yes 

-- -

cable), Yes, No, Incomplete, incorrect. The responses "Incomplete" and " Incorrect" assume that some information has been provided. 

ct 

cable)- [reason], Yes, No, Insufficient to Judge. 

must document the process for obtaining public comment and include any comments received through the public notification process within 

2 

I 

! 
ANP requirement Citation Was the info Does the Notes 

within 40 submitted? 1 If information 

CFR58 yes, page #s. provided3 

Flag if meet the req?4 

incorrecr? 

Pg. 13,22, 30 

II. N02 plan for near-road sites submitted by 7 I I /20 13 58.10 (a){5) Incomplete, pg. 45 Insufficient to See attached n

judge D). 

12. so2 sites operational (by 1/1/2013) 58.10 (a)(6) NA NA 

and 58.13(d) 

13. AQS site identification number for each site 58.10 (b)(l) Yes Yes 

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

coordinates 

IS. Sampling and analysis method(s) for each measUred 58.10 (b)(3) Yes - -- Yes On page 13, J.D

parameter model Thermo 

183 and lists "O

page 5, since th

I for PM:z.s colloc

"other" (rather 

typo. This shou

plans. 

On page 18, Jer

designation EQ

One BAM1020. 

EQPM-0798-12

This should be 

16. Any proposals to remove or move a monitoring station 58. 10 (b)(5) Yes, pgs. 11, 16, Yes Page 11-Ant

within a period of 18 months following plan submittal and 44 (PM2•5 FEM) at 

information sh

after replacem

Page 16 - Ant

(PM2•5 FEM) at 

information sh

after replacem

Page 44-insu

proposed syst

' discontinuatio

L__ 17. Scale of representativeness for each monitor as defmed 58.10(b)(6); Yes Yes 0 3 monitor at 
Citation Was the info Does the Notes 

within 40 submitted? 1 If information 

CFR58 yes, page #s. provided3 I 

Flag if meet the req?4 

incorrecf? 

AppD population exposure and regional transport, with 

spatial scale of neighborhood. Clarification Is 

needed for the appropriateness of neighborhood 

spatial scale for regional transport. 

PMu (FRM), QA monitor at Sunrise Acres Is listed 

1 

as quality assurance for site type and i 

neighborhood for spatial scale. QA Is not an 

appropriate site type. This should be corrected In 

-

future ANPs. 

--

ble and sites not suitable for 58.10 (b)(7) Yes Yes 

PM2.s NAAQS as described 

er area represented by the 58.10(b)(8) Yes Yes 

nitors as either source- 58.10 (b)(9) Yes Yes 

ented 

e for which a waiver has 58.10 (b)(IO) NA NA 

 a waiver has been requested 58.LO(b)(11 ) NA NA 

 use ofPb-PM10 in lieu of 

N02 monitors as either near- 58.10 (b)(l2) Yes, pg. 3 Yes 

 FEMs and/or ARMs not 58.1 0 (b)(l3) NA NA All PM2.5 FEM instruments list a monitoring 

the NAAQS (Note 1: must 58.ll(e) objective ofNAAQS comparison. 

ssment.) (Note 2: Required 

2.s with NAAQS-comparable 

mple frequency.) 

gulatory, note the start Date 58.20(c) Yes, p. 45- 48 Insufficient to Start dates for 03 SPMs Arden Peak, Frenchman 

M. If> 24 months, and judge for Arden Mountain, and Laughlin were not provided. 

mparison to the NAAQS per Peak, Frenchman In your next year's network plan, please clarify 

gency must supply Mountain, and whether the SPMs at the Arden Peak, Frenchman 

 or E requirements were not Laughlin Mountain, and Laughlin sites are FRM, FEM or 

ARM, along with start dates. Note that if it is an 

FRM, FEM or ARM, and it operates greater than 24 , 

4 
ANP requirement Citation Was the info Does the Notes 

within 40 submitted?1 If information 

CFR58 yes, page #s. provided3 

Flag if meet the req?4 

incorrect2? 

months, the da

Information wa

from the Spring 

SPM was not el

NAAQS. EPA is 

participate in E

view that the h

recorded eleva

that DAQ evalu

Assessment, th

at high elevatio

recommended 

effects of ozon

intrusion on hi

26. Document how states and local agencies provide for 58.10 (c) Yes Yes 

the review of changes to a PM2_5 monitoring network 

that imoact the location of a violating PM2_5 monitor. 

27. Does the plan include a request for approval for and 58.11 (a) (2) Yes Yes No 

alternative to appendix A requirements for SPMs 

operating a FRMIFEMI ARM which also meets 

appendix E? 

28. Precision/Accuracy reports submitted to AQS 58.16(a); Incomplete Insufficient to EPA is aware o

App A, 1.3 judge requirement in

and 5.1.1 statement in fu

reports have b

reference the d

submittal. 

29. Annual data certification submitted 58.15 Incomplete Insufficient to EPA is aware o

App. A 1.3 judge requirement in

statement in fu

the annual dat

Please referen

submittal. 

30. Frequency of flow rate verification for manual PM App A 3.3.2 Yes Yes 

samplers audit Pgs 16, 19, 30 
Citation Was the info Does the Notes 

within 40 submitted? 1 If information 

CFR58 yes, page #s. provided3 

Flag if meet the req?4 

incorrect2? 

fication for automated PM App A 3.2.3 Yes Yes 

Pgs 8, 11, 13, 16, 

19, 22, 26, 28, 30, 

w rate verification for Pb App A 3.3.4.1 Yes Yes 

C check (gaseous) App. A 3.2.1 Yes Yes 

mance Evaluation (gaseous) App. A 3.2.2 Yes Insufficient to Sunrise Acres - missing eva I for NOx 

judge 

ual flow rate audits for PM App A, 3.2.4 Yes Yes 

and 3.3.3 

ual flow rate audits for Pb App A 3.3.4. 1 Yes No Semi-annual flow audit for Pb monitor at Jerome 

Mack were three months apart rather than six 

months. Semi-annual flow audits should be 

conducted 5-7 months apart. 

AppA3.2.5 Yes Yes The ANP (pg. 5) pro.poses: a) replacing monitors 

using method code RFP5-0598-120 with monitors using method code RFP5-0498-118; b) movement 

of the current primary FRM monitor at Sunrise 

Acres to Jerome Mack for collocation with an 

FRM of the same method code: and c) naming of 

the remaining FRM at Sunrise Acres as the audit 

monitor collocated with the primary PM2.5 FEM. 

EPA notes that these proposed changes would 

enable the network configuration to meet 

collocation requirements. 

monitor ifthere is more than Need to Yes, pg. 5 Yes 

t at a site. determine 

collocation 

ed monitors (Note: waiver App. A Yes Yes J.D. Smith only has one PM2.s monitor (FEM}, yet a 

ous waiver approval must 3.2.5.6 and distance of 2.6 is listed for the distance between 

deviates from requirement.) 3.2.6.3 collocated monitors. This should be corrected in 

next year's ANP. 

ocation met? (note: App A 3.3.1 NA NA 

have this requirement) 

App A 3.3.4.3 NA NA 

only applies to Fresno and App A 3.3.6 NA NA 

6 
ANP requirement Citation Was the info Does the Notes 

within 40 submitted?1 If information 

CFR58 yes, page #s. provided3 

Flag if meet the req?4 

incorrect2? 

Phoenix NCore sites) 

43. Instrument/monitoring method code for each monitor: App C 2.4.1.2 Yes Insufficient to J.D. Smith lists 

is it reported properly? Is it reported correctly (i.e., judge for J.D. 0609-183 and l

appropriate method code for regulatory monitors)? Smith PM2.5 of FRM/FEM. U

Thermo 5014i. FEM (same ins

page 5, it is bei

collocation pur

future ANPs. 

Jerome Mack-

shows method 

The designatio

Met One BAM

future ANPs. 

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

an MSA/CSA: does each affected State or local agency 

meet full monitoring requirements or is 

an agreement between the affected agencies and the 

EPA Regional Administmtor in place? 

45. Start date for each monitor Required to Yes Insufficient to Start dates for 

determine if judge for Arden Mountain, and 

other req. Peak, Frenchman 

(e.g., min # Mountain, and 

and colloc) 

are met 

Laughlin 

46. Instrument monitor type for each monitor Required to Yes Yes 

determine if 

other req. 

(e.g., min# 

and colloc) 

are met 

47. Monitoring objective for each instrument App D 1.1 Yes Yes 

58.10 (b )(6) 

48. Site type for each instrument App D 1.1. 1 Yes Incorrect in one 0 3 monitor at 

instance population ex

spatial scale o

needed for th
Citation Was the info Does the Notes 

within 40 submitted? 1 If information 

CFR58 yes, page #s. provided3 

Flag if meet the req? 4 

incorrect2? 

spatial scale for regional transport. 

PM2.5 (FRM), QA monitor at Sunrise Acres is listed 

as quality assurance for site type and 

neighborhood for spatial scale. QA is not an 

appropriate site type. This should be corrected in 

future ANPs. 

 for each instrument Required to Yes Yes 

detennine if 

other req. 

(e.g., min # 

and colloc) 

are met 

rrence code for each Required to Yes Yes 

detennine if 

other req. 

(e.g., min # 

and colloc) 

are met 

 (note: date of waiver 58.10(b)(4) Yes Yes Apex and Mesquite 0 3 sites are listed as EPA

if the sampling season App D, 4.1 (i) approved seasonal 0 3 monitoring sites. In next 

) year's ANP, the date of EPA's approval for seasonal 

monitoring should be listed and the approval letter 

attached. 

2.5 - applies to year-round 58.10 (b)(4) Yes Yes 

edules (note: date of waiver 58.12(d) 

 if the sampling season App D 4.7 

) EPA 

flowchart 

10 58.JO(b)(4) Yes Yes 

58.12(e) 

App D 4.6 

58. 10 (b)(4) Yes Yes 

58. 12(b) 

App 04.5 

 10-2.s 58. 10(b)(4) Yes Yes 

58.12(f) 

8 
ANP requirement Citation Was the info Does the Notes 

within 40 submitted? 1 If information 

CFR58 yes, page #s. provided3 

Flag if meet the req?"' 

incorrect2? 

App D 4.8 

56. Minimum# of monitors for 0 3 [Note: should be App D, 4.l{a) Yes Yes 

supported by MSA ID, MSA population, DV, # and Pg.2 

monitors, and # required monitors] (seefootnote/ Table D-2 

57. Identification of max. cone. 0 3 monitor(s) AppD4.I(b) Yes, pg. 2 Yes 

. 58. Minimum monitoring requirements met for near-road App D 4.3.2 

N02 (2014 start date) 

59. Minimum monitoring requirements met for area-wide App D 4.3.3 Yes, pg. 3 Yes 

N02 

60. Minimum monitoring requirements met for RA-40 App D 4.3.4 Yes, pg. 3 Yes 

N02 

61. Minimum monitoring requirements met for S0 2 [Note: App D 4.4 Yes, pg. 3 Yes 

Only monitors considered to be required SLAMs are 

eligible to be counted towards meeting minimum 

monitoring requirements.] · 

62. Minimum monitoring requirements met for Pb [Note: App 0 4.5 Yes Yes 

Only monitors considered to be required SLAMs are 58. 13(a) 

eligible to be counted towards meeting minimum 

monitoring requirements.] 

63. Minimum # of monitors for PM2.5 [Note 1: should be App D, Yes, pg. 2 Yes 

supported by MSA ID, MSA population, DV, # 4.7.l(a) and 

monitors, and# required monitors] [Note 2: Only Table D-5 

monitors considered to be required SLAMs are eligible 

to be counted towards meeting minimum monitoring 

requirements.] 

64. Optional PM2.s Network Clarifications: Provide a list Need to assess NA NA 

of required sites if it does not include all SLAMS. several 

[Note: default will assume all SLAMS are considered requirements 

required sites.l 

65. Required PM25 sites represent area-wide air quality AppD Yes Yes 

4.7.l(b) 

66. For PM2.5, is at least one site at neighborhood or larger App D Yes Yes 

scale in an area of expected maximum concentration 4.7.I(b)(l) 

67. If additional SLAMS PM2.5 required, is there a site in AppD Yes Yes 

7 Only monitors considered to be required SLAMs are eligible to be counted towards meeting minimum monitoring requirements. Ln addition, o

traffic count/distance requirements to be neighborhood scale (40 CFR 58 Appendix E, Table E-1) cannot be counted towards minimum monitor
Citation Was the info Does the Notes 

within 40 submitted?1 If information 

CFR58 yes, page #s. provided3 

Flag if meet the req?"' 

incorrect2? 

4.7.1(b)(3) 

irements for continuous App D 4.7.2 Yes Yes 

ckground and transport sites App D 4.7.3 NA NA State-wide requirement. 

ation requirements met for App 04.7.4 Yes,pg. 18 Yes 

r PM10 App D, 4.6 (a) Yes, pg. 3 Yes Boulder City shows max concentration of 314. Per 

and Table D-4 App. D, table D-4, #of required monitors is 6-10 

(high concentration). Page 3 of ANP shows# of 

required monitors is 4-8. There are 8 SLAMS PM10 

monitors, and 1 NCore PM10 monitor. Thus the 

requirement is satisfied. This should be corrected 

in future ANPs. 

uirements met for PM10•2.s App D 4.8 Yes, pg.18 Yes 

est road App E6 Yes Insufficient to The Mesquite site is listed as 7.7 m from roadway 

judge for Ozone at with AAD.T <1000. This does not meet the 

Mesquite minimum requirement of 10m for ozone 

monitoring at the neighborhood scale. Please 

clarify this situation in next year's plan. Options for 

clarifying the situation may include revisiting the 

spatial scale or seeking of a waiver per 40 CFR 58, 

Appendix E, Section 10. 

ad AppE Yes Yes 

App E 3(a) Yes Yes 

App E2 Yes Yes 

structure App E2 Yes Yes 

s on roof App E 4(b) Yes Yes Apex and Boulder City list "none". Other monitors 

list NA. In future ANPs, if there are no roof 

obstructions, NA should be listed. 

s not on roof App E 4(a) Yes Insufficient to Winterwood lists a distance of 2.5m for 0 3 and 

judge for CO, no obstruction height given. Insufficient 

Winterwood. information to determine if distance is at least 

twice the height that the obstacle protrudes 

above the probe, inlet or monitoring path. 

10 
ANP requirement Citation Was the info Does the Notes 

within 40 submitted? 1 If information 

CFR58 yes, page #s. provided3 

Flag if meet the req?" 

incorrect2? 

Apex and Bou

list NA. In futu

obstructions, 

In future ANP

obstruction is 

should be give

80. Distance from trees App E5 Yes No Joe Neal shows 

and 8.2m (PM

Green Valley s

4.0m (PM2sl· 

Joe Neal and G

2012 ANP revi

with a request 

Neal site is the 

Since trees can 

particularly im

made of the im

data from thes

the deficiencie

81. Distance to furnace or incinerator flue App E 3(b) Yes Yes 

82. Unrestricted airflow App E, 4(a) Incomplete Insufficient to Jerome Mack d

and 4(b) Judge at Jerome pollutants mo

Mack next year's AN

83. Probe material (if applicable) AppE9 Yes Yes 

84. Residence time (if applicable) App E9 Yes Yes 
 Network Plan 

he S/LIT agency during the public comment period? No 

ions. 

ents substantive? 

nes? 

or determination if any comments were considered not substantive: 

d to the substantive comments? 

response adequate? 

mments require separate EPA response (i.e., agency response wasn't adequate)? 

annual network plan that received substantive comments approvable after consideration of comments? 

rationale: 

12 
D. Region 9 Near-road N02 Plan review checklistChecklist Version date: November 26,2013 

Agency: Clark County Department of Air Quality (DAQ) 

CBSA: Las Vegas-Paradise 

This checklist is intended to clarify those elements that EPA will be looking for during the review of proposed near

sites. Please note that this checklist summarizes near-road N02 site requirements of 40 CFR Part 58, but does not su

requirements, nor do its contents provide a binding determination of compliance with those requirements. The check

in the future and we welcome comments on its contents and structure. 

Key: 

White = meets the requirement. 

Yellow= Requirement is not met, or information is insufficient to make a determination. Action requested in next y

ANP process. 

reenl =item requires attention in order to improve next year's plan. 
ECK: 

- Based on 40 CFR 58 

uirements (40 CFR 58.10)-

lan requirement Citation Info Requirement Notes 

submitted?1 met?2 

If yes, page 

#s. 

by July 1, 2013) for 40CFR Incomplete, Insufficient to Plan submitted to EPA on June 4, 2013. 

oad N02 monitoring 58.1 O(a)(5) p.3 & 45 judge 

EPA cannot approve the City Center proposed 

interim location given that the information 

provided does not demonstrate that the site 

meets the minimum siting requirements. DAQ 

will need to resubmit a plan that proposes a 

final candidate site location and includes 

missing information highlighted in this 

checklist. Final proposal should go through a 

minimum 30 day public inspection period 

prior to submittal to EPA. 

c comment on proposed 40CFR Incomplete, Insufficient to See item 1. 

 subsequent to proposal, 58.1 O(a)(2) cover letter judge 

ny received comments 

ion start date 40CFR Incomplete, Insufficient to DAQ acknowledges that near-road N02 

58.1 O(a)(5) p.3 judge monitoring must commence in 2014. Please 

clarify a more precise anticipated operation 

start date. 

ation number 40CFR No Insufficient to Please include this information in the final 

58.IO(b)(l) judge submittal if available. 

ddress & geographical 40CFR Incomplete, Insufficient to Please present a street address and 

58.10(b)(2) p.45 judge geographical coordinates for final site 

selection. 

Applicable), Yes, No, Incomplete, Incorrect. The responses "Incomplete" and "Incorrect" assume that some information has been 

Applicable)- [reason), Yes, No, Insufficient to Judge. Assumes information submitted is correct. 

2 
6 Sampling and analysis method (method 40CFR No Insufficient to Please include th

code) 58.1 O(b)(3) judge submittal. 

7 Operation Schedule (Season & sampling 40CFR No Insufficient to Please include th

frequency) 58.10(b)(4) judge submittal. 

8 Any proposal to remove or move the 40CFR No Insufficient to Please include th

monitor within a period of 18 months 58.1 O(b)(5) judge submittal. 

following plan submittal 

9 Monitoring objective & spatial scale of 40CFR No Insufficient to Please include th

representativeness 58.1 O(b )(6) judge submittal. 

IO CBSA represented by the monitor 40CFR Yes, p.3 Yes 

58.1 O(b )(8) 

Network Design requirements (40 CFR 58, Appendix D, Section 4.3.2 

11 CBSA population & year 40 CFR 58, Yes, p.3 Yes 

App.D 

4.3.2(a) 

12 Maximum AADT counts & year for the 40 CFR 58, Incorrect, Insufficient to Max AADT cou

CBSA(s) App.D p.3 judge this estimate is s

4 .3.2(a) obtained estimat

201 I closer to 2

provide most up 

top segment in C

source. 

13 Correct# of required near-road N02 40 CFR 58, Yes, p.3 Yes EPA estimates t

monitors for the CBSA(s) App.D road N02 monit

4.3.2(a) installation by Ja

date population 

make the final d

14 Were all road segments within the CBSA 40 CFR 58, No Insufficient to Please include th

ranked by AADT? App.D judge submittaL 

4.3.2(a)(l) 

15 Discussion of how fleet mix is considered 40 CFR 58, No Insufficient to Please include th

App.D judge submittal. 

4.3.2(a)(1) 

16 Discussion of how roadway design is 40 CFR 58, No Insufficient to Please include th
App.D judge submittal. 

4.3.2(a)(l ) 

 congestion is 40 CFR 58, No Insufficient to Please include this information in the final 

App.D judge submittal. 

4.3.2(a)(l) 

 terrain is considered 40 CFR 58, No Insufficient to Please include this information in the final 

App.D j udge submittal. 

4.3.2(a)(l) 

 meteorology is 40 CFR 58, No Insufficient to Please include this information in the final 

App.D judge submittal. 

4.3.2(a)( l) 

s considered, ifmultiple 40 CFR 58, No Insufficient to Please include this information in the final 

ere max concentrations App.D judge submittal. 

on of how population 4.3.2(a)(l) 

ered? 

posed is the r in the 40CFRS8, N/A N/A- Will need to include infonnation for this 

 of differing factors App.D approval for factor for anticipated :tid proposed site plan. 

site (i.e. fleet mix; 4.3.2(a)(l) 1st site is still 

n; geographic area within pending. 

t route, interstate, or 

on). 

quirements ( 40 CFR ·ss, Appendix E)-

get road segment as near 40 CFR 58, No Insufficient to Please include this information in the final 

D recommendation is App.E judge submittal. 

& no more than 50 6.4(a) 

ement between 2-7 40 CFR 58, . No Insufficient to Please include this information in the final 

App.E 2 judge submittal. 

m supporting structures 40 CFR 58, No Insufficient to Please include this information in the final 

away vertically or App.E 2 judge submittal. 

ucted between the probe 40 CFR 58, No Insufficient to Please include this information in the final 

arest edge of the targeted App.E 4(d) judge submittal. 

4 
SUPPORTING/ADDITIONAL INFORMATION: Based on N dNO .!. ····~·· .. o TAD and 

Check (Yes, No, Comments 

Insufficient) 

If yesJ page #s. 

If top FE-AADT segment not selected, is adequate justification Insufficient to Information about ranking

provided for higher ranks not selected? j udge process was not provided. 

If similar top FE-AADT candidate sites available, was most Insufficient to Information about ranking

congested segment selected? judge process was not provided. 

17 above. 

Is candidate site selected downwind of target road segment? Insufficient to No information provided. 

judge 19 above. 

Are wind roses included to show predominant wind patterns? No None provided 

Are physical attributes (roadway design, roadside structures, or Insufficient to No information provided. 

terrain) desirable according to Table 4-2 of the Near-road N02 TAD judge 16-19 above. 

(see below)? 

If physical attributes (roadway design, roadside structures, or terrain) Insufficient to No information provided. 

NOT desirable according to Table 4-2 of the Near-road N02 TAD, judge 16-19 above. 

are they TYPICAL for the area? 

Was population exposure correctly considered as an additional factor Insufficient to No information provided. 

AFTER consideration of primary factors (FE-AADT, congestion, judge 20 above. 

roadway design, terrain, meteorology) and IF multiple max 

concentration candidate sites identified? 

Will this be a multi-pollutant site? If so, list additional parameters Yes, p.45 DAQ states their plan to i

planned in Comments. CO monitor at the site by 

1, 2017 as well as a requi

monitor by the same time 

Please indicate whether a

parameters are planned fo

installation at the near-roa

the near future. EPA enco

practice of multi-pollutan

road site installations. 

Does agency ensure candidate selection is NOT in a "unique" Insufficient to No information provided. 

location? (See Near-road N02 TAD section 13.2 included below) judge 
y of At-grade or Deep cut- Field reconnaissance; 

nearly at-grade sections/significant satellite 

ts; with immediate ly below grade; imagery 

llutant surrounding significantly above 

 and terrain. grade (fill or 

n. bridge); above 

brid 

- -

. 

y of present other Presence of sound Field reconnaissance; 

than low (<2 m walls, mature (high satellite 

t; in and thick) imagery 

ollutant height) vegetation, 

 and vegetation or obstructive 

n. safety features buildings. 

such as 

guardrails. 

ollutant Flat or gentle Along mount

ain Field reconnaissance; 

n, local terrain, within a ridges or peaks, digital 

eric valley, or along a 

hillsides, or other elevation models and 

road grade. naturally vegetation 

windswept areas. files; satellite ima_ 

ollutant Relative Strongly Local data; National 

 and downwind predominant Oceanic and 

n. locations; winds upwind positions. Atmospheric 

from road to Administration's 

monitor. (NOAA's) National 

Weather 

Service (NWS}; EPA's Air 

Quality 

n (AQS). I 

6 
13.2 Unique Locations and Background Source Influences 

ln the evaluation process, state and local air agencies may encounter situations where certain 

road segments of interest have characteristics that make the location a unique near-road location 

that has elevated pollutant concentrations. In such cases, the pollutant concentrations are not 

representative of other near-road locations across the CBSA. The unique characteristics of these 

locations could be due to the close proximity of a substantial stationary source, non-road mobile 

sources, or roadway design features (such as tunnel entrances and exits or toll plazas). In 

situations where a state or local air agency has a choice between road segments that otherwise 

have similar potential for peak N02 concentrations, the air agencies should place a higher weight 

on sites that are most influenced by typical roadway activity rather than those that are heavily 

influenced by unique sources or features. This approach increases the probability that the chosen 

site can represent a larger population exposure within and across CBSAs. 

The EPA recognizes that state and local air agencies will likely have a good understanding of 

whether candidate near-road N02 monitoring sites have unique characteristics that do or do not 

represent the CBSA that those sites are within. The EPA encourages state and local air agencies 

to use their local knowledge in site selection and to engage the EPA Regional staff for assistance 

in evaluating such a situation as necessary.