### 1 **Attachment A: Annual Air**  **M onitoring**  **N etwork**  **P lan**  **C hecklist**  Year: 2012 Agency : Washoe County AQMD 40 CFR 58.10(a) (1) requires that each Annual Network Plan (ANP ) include information regarding the following types of monitors : SLAMS monitoring stations including FRM, FEM, and ARM monitors that are part of SLAMS, NCore stations, STN stations, State speciati on stations, SPM stations, and/or, in serious, severe and extreme ozone nonattainment areas, PAMS stations, and SPM monitoring stations. 40 CFR 58.10(a)(1) further directs that, “ The plan shall include a statement of purposes for each monitor and evidence that s iting and operation of each monitor meets the requirements of appendices A, C, D, and E of this part, where applicab le. ” On this basis, review of the ANPs is based on the 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 Administrator rather than the Regional Administrators, but we will do a check to see if the required information is included and correct. The items requiring approval by the Administrator are: PAMS, NC ore, Speciation (STN/CSN), and NO2 requirements including ne ar road, area
-wide, and RA40
. Please note that this checklist summarizes many of the requirements of 40 CFR Part 58, but does not substitute for those requirements, nor do its contents provide a binding determination of compliance with those requirements. The checklist is subject to revision in the future and we welcome comments on its contents and structure. Key : White = meets the requirement Grey = Requirement not applicable for this year’s plan Yellow = does not meet or cannot judge the requirement

– action requested in next year’s plan or outside the ANP process Green = meets the requirement but action requested to improve next year’s plan

### 2

**ANP requirement Citation**  **within 40 CFR 58**  **Was the info**

**submitted? 1**  

### If **yes, page #s .**  **Flag if incorrect**  **2** 

### ? **Does the** 

**information provided** **3** 

### meet **the req ?**  **4** 

### Notes

1. Submit plan by July 1 st 58.10 (a)(1) Yes Yes Plan submitted July 2, 2012 , please aim to submit by or prior to July 1. 2. Statement of purpose for each mo nitor 58.10 (a)(1) Yes , p. 11, 14, 17, 20, 23, 29, 32, 36 Yes
3. 30
- day public comment / inspection period 58.10 (a)(1), 58.10 (a)(2) Yes , p.1 Yes 4. M odifications to SLAMS network

– case when we are not approving actual system modifications (i.e., we will do it outside the ANP process 5 ) 58.10 (a)(2) 58.10(e) N/A N/A
- no such mo difications proposed. 5. M odifications to SLAMS network

– case when we are approving actual system modifications per 58.14(c) 58.10 (a)(2) 58.10 (b)(5) 58.10(e) 58.14 (c) Yes , p. 9 Yes The network modifications proposed do not require EPA approval and we find these acceptable. 6. Does plan include documentation (e.g., attached approval letter) for system modifications that have been approved since last ANP approval? N/A N/A Suggest including any past or future copies of EPA approval letters received for system mo difications. 7. NCore plan submitted to Admin. by 7/1/2009 58.10 (a)(3) N/A 8. NCore site operational (by Decem ber 2010) 58.10 (a)(3) Yes , p.3 NA
- HQ approval Please report details of meteorology parameters taken at the NCore site. See [General] comment from Attachment C. 9. Pb plan for ≥1.0 tpy sources submitted by 7/1/2009 58.10 (a)(4) N/A 10. Pb site for ≥1.0 tpy sources operational by 1/1/2010 58.10 (a)(4) N/A 11. Pb plan for 0.5
- 1.0 tpy submitted by 7/1/2011 58.10 (a)(4) N/A 12. Pb site for 0.5
- 1.0 tpy sources operational by 12/27/2011 58.10 (a)(4) N/A N/A
- no Pb mo nitoring requirement Please provide clarity and justification as to why

AQMD does not currently have a Pb monitoring requirement under this criteira
. 13. NO2 plan for area
- wide and RA40 sites submitted by 7/1/2012 58.10 (a)(5) N/A N/A
- no requirement for AQMD 14. NO2 area
- wide and RA40 sites operational by 58.10 (a)(5) N/A

1 Response options: N/A (Not Applicable), Yes, No, Incomplete, Incorrect. The responses “Incomplete” and “Incorrect” assume that some information has been provided. 2 To the best of our knowledge. 3 Assuming the information is correct 4 Response options: N/A (Not Applicable)

– [reason], Yes, No, Insufficient to Judge. 5 See 58.14(c)

### 3

**ANP requirement Citation**  **within 40 CFR 58**  **Was the info**

**submitted? 1**  

### If **yes, page #s .**  **Flag if incorrect**  **2** 

### ? **Does the** 

**information provided** **3** 

### meet **the req ?**  **4** 

### Notes

1/1/2013 15. NO2 plan for near
-road sites submitted by 7/1/2012 58.10 (a)(5) N/A N/A
- no requirement for AQMD 16. NO2 near-road sites operational by (N/A until 2013 or 2014 plans) 58.10 (a)(5) N/A 17. SO2 plan for PWEI sites submitted by 2011 58.10 (a)(6) N/A 18. SO2 sites operational by 1/1/2013 58.10 (a)(6) and 58.13(d) N/A 19. CO plan for 2015 near
-road sites submitted by 7/1/2014 58.10 (a)(7) and 58.13(e)(1) N/A
20. CO sites for first phase of CO monitors operational by 1/1/2015 58.10 (a)(7) and 58.13(e)(1) N/A
21. CO plan for 2017 near
-road sites by 7/1/2016 58.10 (a)(7) and 58.13(e)(2) N/A
22. CO sites for first phase of CO monitors operational by 1/1/2017 58.10 (a)(7) and 58.13(e)(2) N/A
23. AQS site identification number for each site 58.10 (b)(1) Yes , p.11, 14, 17, 20, 23, 29, 32, 36 Yes 24. Location of each site: street address and geographic coordinates 58.10 (b)(2) Yes , p.11, 14, 17, 20, 23, 29, 32, 36 Yes 25. Sam

pling and analysis method(s) for each measured parameter 58.10 (b)(3) Yes , p.13, 16, 19, 22, 25
- 28, 31, 34
- 35, 38 Yes
26. Operating schedule for each monitor (see items 6 2
- 6 6 ) 58.10 (b)(4) Yes , p.13, 16, 19, 22, 25
- 28, 31, 34
- 35, 38 Yes
27. Any proposals to remove or move a monitoring station within a period of 18 months following plan submittal 58.10 (b)(5) Yes , p.9 Yes See #5 above
. 28. S cale of representativeness for each monitor as defined in Appendix D 58.10(b)(6); App D Yes , p.13, 16, 19,

22, 25
- 28, 31, 34
- 35, 38 Yes

### 4

**ANP requirement Citation**  **within 40 CFR 58**  **Was the info**

**submitted? 1**  

### If **yes, page #s .**  **Flag if incorrect**  **2** 

### ? **Does the** 

**information provided** **3** 

### meet **the req ?**  **4** 

### Notes

29. Identification of sites suitable and sites not suitable for comparison to the annual PM2.5 NAAQS as described in Part 58.30 58.10 (b)(7) Yes , p.27
- 28, 35 Yes
30. MSA, CBSA, CSA or other area represented by the mo nitor 58.10 (b)(8) Yes , p.11, 14, 17, 20, 23, 29, 32, 36 Yes 31. Designation of any Pb monitors as either source
oriented or non
- source - oriented 58.10 (b)(9) N/A N/A
- no requirement for AQMD 32. Any source
- oriented Pb site for w hich a waiver has been granted by EPA RA 58.10 (b)(10) N/A N/A
- no requirement for AQMD 33. Any Pb monitor for which a waiver has been requested or granted by EPA RA for us of Pb
- PM10 in lieu of Pb
- TSP 58.10 (b)(11) N/A N/A
- no requirement for AQMD 34. Identification of required NO2 monitors as either near-road or area
- wide 58.10 (b)(12) N/A 35. Document how

states and local agencies provide for the review of changes to a PM2.5 monitoring network that impact the location of a violating PM2.5 mo nitor. 6 58.10 (c) Yes, p10 Yes

36. Plan to modify the network that complies with findings of the 5
- year network assessment. [Note: recommended to be submitted on year of network assessment or year after.] 58.10 (e) 58.14 (a) Only applies to

year of or af

ter 5
- year network assessment [Yes if plan was

submitted, either with ANP or separately] 37. Precision/Accuracy reports submitted to AQS 58.16(a); App A , 1.3 and 5.1.1 Yes, p.10 Yes
38. Annual data certification submitted 58.15 App. A 1.3 Yes, p.10 Yes 39. Frequency of flow

rate verification for manual PM samplers audit App A 3.3.2 Yes, p.13, 22, 27
- 28, 31, 35, 38 Yes 40. Frequency of flow

rate verification for automated PM analyzers audit App A 3.2.3 Yes, p.22, 28, 31, 35, 38 Yes 41. Frequency of one
-point flow rate verification for Pb App A N/A N/A
- no

6 The affected state or local agency must document the process for obtaining public comment and include any comments received through the public notification process within their submitted plan.

### 5

**ANP requirement Citation**  **within 40 CFR 58**  **Was the info**

**submitted? 1**  

### If **yes, page #s .**  **Flag if incorrect**  **2** 

### ? **Does the** 

**information provided** **3** 

### meet **the req ?**  **4** 

### Notes

samplers audit 3.3.4.1 requirement for AQMD 42. Frequency of one
-point QC check (gaseous) App. A 3.2.1 Yes, p.13, 16, 19, 25
- 26, 31, 34, 38 Yes 43. Date of last Annual Performance Evaluation (gaseous) App. A 3.2.2 Yes, p.13, 16, 19, 25
- 26, 31, 34, 38 Yes 44. Dates of last two semi
- annual flow rate audits for PM mo nitors App A , 3.2.4 and 3.3.3 Yes, p.13, 22, 27
-

28, 31, 35, 38 Yes 45. Dates of last two semi
- annual flow rate audits for Pb mo nitors App A 3.3.4.1 N/A N/A
- no requirement for AQMD 46. PM2.5 co
- location App A 3.2.5 Yes,p.27 Yes 47. Distance between co - l ocated monitors App. A 3.2.5.6 Yes, p.27, 35 Insufficient to judge Reno3 PM2.5 collocated monitors are reported as

1.1m apart and Sparks PM10 collocated monitors are reported as 1.5m apart. These distances are acceptable as long as the flow rate is less than 200 liters/min. In follow
-up conversation with AQMD, they have clarified that the flow rate is indeed less than 200 liters/min and therefore these collocation distances are acceptable. Furthermore, the need for a PM10 collocation has been eliminated given that all instruments in AQMD’s fleet have been switched to continuous FEMs. Please include the flow rates for remained collocated instruments in next year’s plan in order to clarify that collocation distances are acceptable
. 48. Manual PM10 method co - location met? (note: continuous PM10 does not have this requirement) App A 3.3.1 Yes , p. 5 Yes In follow
-up communication with the agency, Washoe has clarified that they no longer operate filter based PM10 instruments and therefore collocation requirements would not apply. Please make this clarification in next year’s plan.

### 6

**ANP requirement Citation**  **within 40 CFR 58**  **Was the info**

**submitted? 1**  

### If **yes, page #s .**  **Flag if incorrect**  **2** 

### ? **Does the** 

**information provided** **3** 

### meet **the req ?**  **4** 

### Notes

49. Pb co
- location App A 3.3.4.3 N/A N/A
- no requirement for AQMD 50. PM10
- 2.5 co
- location (note: only applies to Fresno and Phoenix NCore sites) App A 3.3.6 N/A N/A
- no requirement for AQMD 51. Required # of PM2.5 PEP audits App A 3.2.7 N/A Yes
- EPA requirement 7 52. Required # of Pb PEP audits App A 3.3.4.4 N/A Yes
- EPA requirement 8 53. Required # of NPAP audits (or approved equivalent) App A 2.4 N/A Yes
- EPA requirement 9 54. Instrument/monitoring method code for each monitor: is it reported properly? Is it reported correctly (i.e., appropriate method code for regulatory monitors)? App C 2.4.1.2 No Insufficient to judge Method codes were not found in EPA’s review,

please include this information in next year’s plan. See the “List of Designated Reference and Equivalent Methods” found on EPA’s AMTIC website for latest list of method codes for each instrument. Suggest reporting method codes for each parameter at eac h site in the detailed site information tables of the network plan. See suggested format provided in Attachment C of the Annual Monitoring Network Plan memo sent by EPA Region in May 2012. 55. Placeholder for: Optional request to have PM2.5 continuous instruments treated as non
- FEMs and therefore not comparable to NAAQS? N/A
56. Start date for each monitor Required to determine if other req. (e.g., min # and co
- lo) are Yes, p.13, 16, 19,

22, 25
- 28, 31, 34
- 35, 38 Yes

7 EPA has reviewed EPA documentation to confirm that these requirements have been met for the area in question. 8 EPA has reviewed EPA documentation to confirm that these requirements have been met for the area in question. 9 EPA has revie wed EPA documentation to confirm that these requirements have been met for the area in question.

### 7

**ANP requirement Citation**  **within 40 CFR 58**  **Was the info**

**submitted? 1**  

### If **yes, page #s .**  **Flag if incorrect**  **2** 

### ? **Does the** 

**information provided** **3** 

### meet **the req ?**  **4** 

### Notes

met 57. Instrument monitor type for each mo nitor Required to determine if other req. (e.g., min # and co
- lo) are met Yes, p.13, 16, 19,

22, 25
- 28, 31, 34
- 35, 38 Yes This field was called “Monitor Classification” in 2012 Plan. Please rename to “Monitor Type” in next year’s plan.

58. Monitoring objec tive for each instrument App D 1.1 58.10 (b)(6) Incorrect insufficient to judge The “monitoring objective” listed should be

changed to “site type” in each of the detailed Site Information tables. “Monitoring objective” could include the following types: public info, NAAQS comparison, or research. For a suggested reporting format, pl ease see Attachment C of the May 2012 memo sent by EPA Region 9. 59. Site type for each instrument App D 1.1.1 Yes, p.13, 16, 19, 22, 25
- 28, 31. 34
- 35, 38 Yes Please rename “Monitoring Objective” to read “Site Type” in the detailed site information tables. See#58 related above. 60. Instrument parameter code for each instrument Required to determine if other req. (e.g., min # and co
- lo) are met No insufficient to judge Please include in next year’s plan. Suggest

including for each parameter in detailed site inf ormation tables. For a suggested reporting format, please see Attachment C of the May 2012 memo sent by EPA Region 9. 61. Instrument parameter occurrence code for each instrument Required to determine if other req. (e.g., min # and co
- lo) are met No insufficient to judge Please include in next year’s plan. Suggest

including for each parameter in detailed site information tables. For a suggested reporting format, please see Attachment C of the May 2012 memo sent by EPA Region 9. 62. Sam

pling season for ozone (note: date of waiver approval must be included if the sampling season deviates from requirement) App D, 4.1(i) Yes, p.16, 19, 26, 31, 34, 38 Yes
63. Sam

pling schedule for PM2.5
- applies to year
-round and seasonal sampling schedules (note: date of waiver 58.12(d) App D 4.7 Yes, p. 27
- 28, 35 Yes

### 8

**ANP requirement Citation**  **within 40 CFR 58**  **Was the info**

**submitted? 1**  

### If **yes, page #s .**  **Flag if incorrect**  **2** 

### ? **Does the** 

**information provided** **3** 

### meet **the req ?**  **4** 

### Notes

approval must be included if the sampling season deviates from requirement) 64. Sam

pling schedule for PM10 58.12(e) App D 4.6 Yes , p. 5, 13, 22,

27, 31, 35, 38 Yes In follow
-up communication with the agency, Washoe has clarified that they no longer operate filter based PM10 instruments and that all SLAMS PM10 measurements come from continuous monitors. Please make this clarification in next year’s plan. 65. Sam

pling schedule for Pb 58.12(b) App D 4.5 N/A N/A
- no requirement for AQMD 66. Sam

pling schedule for PM10
- 2.5 58.12(f) App D 4.8 Yes, p. 27
- 28 Yes 67. Minimum # of sites for O3 [Note: should be supported by MSA ID, MSA population, DV, # sites, and # required sites] App D, 4.1 (a) and Table D
- 2 Yes, p. 4 Yes Please report monitoring requirements in terms of minimum required number of sites rather than mo nitors. For example, a single monitoring station that hosts multiple ozone monitors counts as a single site to meet minimum monitoring requirements for ozone. 68. Identification of max. conc. O3 monitor(s) App D 4.1 (b) Yes, p. 38 Yes 69. Minimum monitoring requirements met for near
-road NO2 App D 4.3.2 N/A 70. Minimum monitoring requirements met for area
- wide NO2 App D 4.3.3 N/A 71. Minimum monitoring requirements met for RA
- 40 NO2 App D 4.3.4 N/A 72. Minimum monitoring requirements met for SO2 App D 4.4 Yes, p. 6 Yes 73. Minimum monitoring requirements met for CO App D Yes, p.5 Yes Please specify NCore CO monitoring required. 74. Minimum monitoring requirements met for Pb App D 4.5 58.13(a) N/A N/A
- no requirement for AQMD See #12.
75. Minimum # of monitors for PM2.5 [Note: should be supported by MSA ID, MSA population, DV, # sites, and # required sites] App D , 4.7.1(a) and Table D
- 5 Yes, p. 4 Yes Monitoring requirements should be calculated in terms of # of sites, not monitors, as outlined in 40 CFR Part 58 Appendix D. A site with a primary and collocated monitor should be counted as one of the required sites. SPM sites should not be

### 9

**ANP requirement Citation**  **within 40 CFR 58**  **Was the info**

**submitted? 1**  

### If **yes, page #s .**  **Flag if incorrect**  **2** 

### ? **Does the** 

**information provided** **3** 

### meet **the req ?**  **4** 

### Notes

counted for the purposes of meeting SLAMS minimum monitoring requirements. Please correct these calculations in next year’s plan. 76. Required PM2.5 sites represent community
- wide air quality at neighborhood or urban scale App D 4.7.1(b) Yes, p.27
- 28, 35 Yes 77. For PM2.5, is at least one site in a population
- oriented area of expected maximum concentration App D 4.7.1(b)(1) Incomplete, p. 27
-

28, 35 Insufficient to

judge PM2.5 site is listed as “population oriented.”

Please specify the site that is located in area of expected maximum concentration. 78. If >1 SLAMS PM2.5 required, is there a site in an area of poor air quality App D 4.7.1(b)(2) N/A N/A
- no requirement for AQMD 79. Minimum monitoring requirements for continuous PM2.5 App D 4.7.2 Yes, p.28 & 35 Yes 80. Requirements for PM2.5 background and transport sites App D 4.7.3 N/A N/A
- State level Recommend referencing location of sites in next year’s plan 81. Are PM2.5 Chemical Speciation requirements met for official STN sites? App D 4.7.4 Yes, p.28 Yes 82. Spatial Averaging for comparison to Annual NAAQS: are intended CMZs defined and met criteria in 40 CFR 50 App N? App D 4.7.5
83. Minimum # of monitors for PM10 App D , 4.6 (a) and Table D
- 4 Yes, p. 5 Yes Please report Max Concentration values to support number of required sites. See 2012 Annual Monitoring Network Plan memo
Attachment A for guidance on reporting minimum monitoring requirements for PM10. 84. Minimum monitoring requirements met for PM10
- 2.5 mass App D 4.8 Yes, p.35 Yes 85. Distance of site from nearest road App E 6 Yes, p.11, 14, 17, 20, 23, 29. 32, 36 Yes Incline Site

– Ozone monitor. Traffic counts should be given for nearest downwind road, which appears to be Tahoe Blvd, in next year’s plan. Plumb
- Kit Site

– It is unclear which distance segment applies to the traffic count provi ded. In next year’s plan please clearly tie road segment distance to that segment’s count for all sites.

### 10

**ANP requirement Citation**  **within 40 CFR 58**  **Was the info**

**submitted? 1**  

### If **yes, page #s .**  **Flag if incorrect**  **2** 

### ? **Does the** 

**information provided** **3** 

### meet **the req ?**  **4** 

### Notes

Toll Site

– According to 40 CFR Part 58 Appendix E, Figure E
- 1, the distances and counts provided suggest PM monitors may be at “neighborhood scale,” please revisit and verify appropriate scale in next year’s plan. Note: P arameters at a site can have a different spatial scale s and should be calculated individually by parameter rather than for an entire site. 86. Traffic count of nearest road App E Yes p.11, 14, 17, 20, 23, 29, 32, 36 Yes See notes in #85 87. Groundcover App E 3(a) Yes p.13, 16, 19, 22, 25
- 28, 31, 34
- 35, 38 Yes
88. Probe height App E 2 Yes p.13, 16, 19, 22, 25
- 28, 31, 34
- 35, 38 Yes
89. Distance from supporting structure App E 2 Yes p.13, 16, 19, 22, 25
- 28, 31, 34
- 35, 38 Yes
90. Distance from obstructions on roof App E 4(b) Yes p.13, 16, 19, 22, 25
- 28, 31, 34
- 35, 38 Yes For future obstructions that may exist, please include distance and height of obstruction. 91. Distance from obstructions not on roof App E 4(a) Incomplete p.13, 16, 19, 22, 25
- 28, 31. 34
- 35, 38 Insufficient to

judge 40 CFR 58, Appendix E specifies that “the

distance from the obstacle to the probe, inlet, or mo nitoring path must be at least twice the height that the obstacle pro trudes above the probe, inlet, or monitoring path. ” Please provide obstruction height in next year’s plan. 92. Distance from trees App E 5 Yes p.13, 16, 19, 22, 25
- 28, 31. 34
- 35, 38 Yes
93. Distance to furnace or incinerator flue App E 3(b) Yes p.13, 16, 19, 22, 25
- 28, 31, 34
- 35, 38 Yes
94. Unrestricted airflow App E , 4(a) Yes p.13, 16, 19, Yes

### 11

**ANP requirement Citation**  **within 40 CFR 58**  **Was the info**

**submitted? 1**  

### If **yes, page #s .**  **Flag if incorrect**  **2** 

### ? **Does the** 

**information provided** **3** 

### meet **the req ?**  **4** 

### Notes

and 4(b) 22, 25
- 28, 31, 34
-

35, 38 95. Probe material (if applicable) App E 9 Yes p.13, 16, 19, 22, 25
- 28, 31, 34
- 35, 38 Yes
96. Residence time (if applicable) App E 9 Yes p.13, 16, 19, 22, 25
- 28, 31, 34
- 35, 38 Yes



### Public Comments on Annual Network Plan Were comments submitted to the S/L/T agency during the public comment period? **Yes** Were any of the comments substantive? **No.** Explain basis for determination if any comments were considered not substantive: **No specific ties to not meeting requirements of the annual network plans specified in 40 CFR 58.10.**  Did the agency

respond to the substantive comments? **Although comments were not substantive, the agency did provid e a**  **n adequate response.**