UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX 

75 Hawthorne Street 

San Francisco, CA 94105 

February 28, 2013

Mr. Rob Bamford, Chief

Bureau of Air Quality Planning

Nevada Division of Environmental Protection

901 S. Stewart, Suite 4001

Carson City, NV 89701

Dear Mr. Bamford:

Thank you for your submission of the State of Nevada, Division of Environmental Protection,

Bureau of Air Quality Planning’s 2012 Ambient Air Monitoring Network Plan in July 2012. 

Based on the information provided in the Plan, EPA approves NDEP's 2012 Plan, except for the 

five specific items listed in Attachment B where we are not taking action. On December 11, 2012 

EPA also approved and provided a separate notification for the relocation of State and Local Air 

Monitoring Station (SLAMS) ozone monitoring at 3300 E. 5th Street (Site ID: 32-510-0002) to 

2601 S. Carson Street in Carson City, NV.

Annual network plans are important documents for regulatory purposes (e.g., State 

Implementation Plans, designations and redesignations) and public information, in addition to 

the myriad uses by the air districts. EPA is revising the review process for annual network plans 

to specifically check and document the comprehensive set of items that are required to be 

included in the annual network plans per 40 CFR 58.10 in a consistent manner. We have created 

a checklist that lists all these items and have included it as Attachment A. While the items in the 

checklist are required by EPA regulations, we acknowledge that we have not specifically 

requested some of this information in previous annual network plan reviews. We recognize that 

your plan may not have all the items that we have currently identified and hope to work with you 

on the inclusion of these items in future plans. To facilitate these changes, EPA has provided 

detailed feedback in the checklist where information should be included or revised in next year’s 

plan.

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. Accordingly, we are not acting on the specific portions of 

your agency’s annual network plan listed in Attachment B.

In addition to the checklist and list of specific plan elements where EPA Region 9 is not taking 

action, enclosed are additional detailed comments on the plan (Attachment C). All of the 
comments in Attachments A, B, and C should be addressed in next year’s network plan. 

EPA also received the comments provided on NDEP’s plan by Mr. John Mosley, Environmental 

Director of the Pyramid Lake Paiute Tribe. EPA supports Mr. Mosley’s suggestion that in 

NDEP’s evaluation of their PM2.5 network, it would be a good idea to examine concentrations 

from nearby monitoring that has recently been conducted. Although this suggestion does not 

require a change to NDEP’s current network plan, we recommend addressing the 

recommendation as part of NDEP’s next 5-year network assessment.

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

Enclosures:

A. Annual Air Monitoring Network Plan Checklist

B. Elements where EPA is Not Taking Action

C. Additional Detailed Comments

cc: Daren Winkelman, NDEP

Mike Elges, NDEP
Attachment B: Annual Air 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.

 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 

following system modification listed in the plan per the applicable requirement:

discontinuation of the Stateline CO monitor (page 5-6). Therefore, we are not taking 

action on this item as part of this year’s annual network plan.

 EPA identified items in you agency’s annual 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 of the following items:

Item Checklist Row

(Attachment A)

Issue

Minimum # of monitors for 

PM2.5

75 Insufficient information to judge

Requirements for PM2.5 

background and transport sites

80 Insufficient information to judge

Monitoring objective for each 

instrument

58 Insufficient information to judge

Distance from obstructions not 

on roof

91 Insufficient information to judge

Distance from trees 92 Not meeting requirement in one instance

Additional information for each of these items is in included in Attachment A.
Attachment C: Additional Detailed Comments

 [Item 24] A numbered street address was not specified for the Harvey’s monitor. EPA 

suggests providing the address of the building the monitor resides on top of.

 [Item 25] Please correct the typo for the sampling and analysis method reported for the 

CO monitor at Harvey’s (p.14) in order to clarify that the instrument is of FRM or FEM 

designation.

 [Item 30] Please clarify when MSA stands for Micropolitan Statistical Area versus 

Metropolitan Statistical Area. Please also include relevant CSA when appropriate.

 [Item 42] Please adjust next year’s one-point gaseous instrument QC checks to reflect the 

accurate schedule that should be listed as at least once every two weeks. Currently, the 

schedule is reported as semi-monthly.

 [Item 59] Although information describing site type is provided in the plan, this is 

mislabeled as “Monitor Objective.” Please re-label these rows in next year’s plan to read 

Site Type. For further guidance on the monitoring objective versus site type, please refer 

to Attachment D of the Annual Network Plan Memo sent by EPA Region 9 in May 2012.

 [Item 60] In order to clarify that both the pollutant and parameter code are reported in the 

detailed site tables (p.10-26), EPA recommends that the rows labeled “Pollutant” get relabeled to read “Pollutant/Parameter code.” A separate row to report only the parameter 

code may also be an option.

 [Item 61] It is suggested that the parameter occurrence code for each instrument at each 

monitoring site is specified in next year’s plan.

 [Item 62] The rows labeled as “Operation Schedule” for the ozone monitoring sites 

should be adjusted from “seasonal” to read “continuous.” The rows labeled “Sampling 

Season” should specify the days of the sampling season (i.e. April 1st– October 31st).

 [Item 68] NDEP’s plan reports ozone design values for each of their SLAMS ozone sites 

in operation (see page 5). Based on the design values reported, the Carson City 5th Street 

site should be labeled as the maximum concentration site in the network. Please ensure 

future plans specify the maximum concentration site for ozone. This maximum/highest 

concentration designation should be reported as the Site Type.

 [Items 90 & 91] For future plans, as necessary, report any obstructions (on and off the 

roof) by providing a distance from the probe/inlet, as well as height of the obstruction.

 [General] EPA recommends that NDEP report detailed information for meteorology 

tower parameters operated by the agency and incorporate the details into the site tables 

found on pages 10-26. Examples of helpful detailed site information to provide include: 
instrument manufacturer and model, start date, siting, and QA/QC information, as 

applicable.