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 t he information provided in the P lan, 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. W hile the items in the checklist are required by EPA regulations , we acknowledge that we have not specifically requested some of this informa tion 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 th e annual network plan for which the information in the plan is insufficient to judge whether the requ irement 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 co mments on the plan (Attachment C ). All of thecomments 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 PM 2.5 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

- 41 41

.

Sincerely,

/s/

Matthew Lakin, Ma nager Air Quality Analysis Office

Enclosure s : 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, NDEPAttachment B : Annual Air Monitoring Network P lan I tems where EPA is N ot Taking

Action

We are not acting on the portions of annual network plan s 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 p er 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:

d iscontinuation of the Stateline CO monitor (page 5

- 6)

. Therefore, w e are not taki ng 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 ba sed 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 pr ovided in the plan, this is

mis labeled 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 clari fy 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 re

labeled 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 1 st

– October 31 st ).

 [Item 68] NDEP’s plan reports ozon e design values for each of their SLAMS ozone sites in operation (se e page 5). Based on the design values reported, the Carson City 5 th 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

concentrat ion 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 recommend s 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.