1

Attachment A: Annual Air Monitoring Network Plan Checklist

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 speciation 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 siting and operation of 

each monitor meets the requirements of appendices A, C, D, and E of this part, where applicable.” 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, NCore, Speciation (STN/CSN), and NO2 requirements including near 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?1If 

yes, page #s. 

Flag if 

incorrect2?

Does the 

information 

provided3 meet 

the req?

4

Notes 

1. Submit plan by July 1st 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 monitor 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. Modifications to SLAMS network – case when we are 

not approving actual system modifications (i.e., we 

will do it outside the ANP process5)

58.10 (a)(2)

58.10(e)

N/A N/A- no such 

modifications 

proposed.

5. Modifications 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 

modifications.

7. NCore plan submitted to Admin. by 7/1/2009 58.10 (a)(3) N/A

8. NCore site operational (by December 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 

monitoring 

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. Sampling 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 62-66) 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.Scale 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?1If 

yes, page #s. 

Flag if 

incorrect2?

Does the 

information 

provided3 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 

monitor

58.10 (b)(8) Yes, p.11, 14, 17, 

20, 23, 29, 32, 36

Yes

31. Designation of any Pb monitors as either sourceoriented or non-source-oriented58.10 (b)(9) N/A N/A- no 

requirement for 

AQMD

32. Any source-oriented Pb site for which 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 

monitor.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 after 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?1If 

yes, page #s. 

Flag if 

incorrect2?

Does the 

information 

provided3 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 

monitors

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 

monitors

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-located 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?1If 

yes, page #s. 

Flag if 

incorrect2?

Does the 

information 

provided3 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 

requirement7

52. Required # of Pb PEP audits App A 

3.3.4.4

N/A Yes - EPA 

requirement8

53. Required # of NPAP audits (or approved equivalent) App A 2.4 N/A Yes - EPA 

requirement9

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 each 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 reviewed 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?1If 

yes, page #s. 

Flag if 

incorrect2?

Does the 

information 

provided3 meet 

the req?

4

Notes 

met

57. Instrument monitor type for each monitor 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 objective 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, please 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 

information 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. Sampling 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. Sampling 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?1If 

yes, page #s. 

Flag if 

incorrect2?

Does the 

information 

provided3 meet 

the req?

4

Notes 

approval must be included if the sampling season 

deviates from requirement)

64. Sampling 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. Sampling schedule for Pb 58.12(b)

App D 4.5

N/A N/A- no 

requirement for 

AQMD

66. Sampling 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 

monitors. 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?1If 

yes, page #s. 

Flag if 

incorrect2?

Does the 

information 

provided3 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 memoAttachment 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 provided. 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?1If 

yes, page #s. 

Flag if 

incorrect2?

Does the 

information 

provided3 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: Parameters at a site can have a different 

spatial scales 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 

monitoring path must be at least twice the height 

that the obstacle protrudes 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?1If 

yes, page #s. 

Flag if 

incorrect2?

Does the 

information 

provided3 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 provide an adequate response.