UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION IX 

Ms. Jasmine Mehta, Chief 

Bureau of Air Quality Planning 

75 Hawthorne Street 

San Francisco" CA 94105·3901 

DEC 1 1 £013 

Nevada Division of Environmental Protection 

90 I South Stewart Street, Suite 400 I 

Carson City, Nevada 8970 I 

Dear Ms. Mehta: 

Thank you for your submission of the Nevada Division of Environmental Protection's (NDEP's) 

2013 Ambient Air Monitoring Network Plan in June, 2013. We have reviewed the submitted 

document based on the requirements set forth under 40 CFR 58. Based on the infonnation 

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 

infonnation in the plan is insufficient to judge whether the requirement has been met, or for 

which the infonnation, as described, does not meet the requirements as specified in 40 CFR 

58.10 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 

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

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

(through corrections within the plan, additional infonnation being included, or discussion) in 

next year's annual monitoring net\vork plan. 

Prinud on Htrydtd Paptr 
If you have any questions regarding this letter or the enclosed comments, please feel free to 

contact me at (415) 947-4534 or Gwen Yoshimura at (415) 947-4134. 

Enclosures: 

Sincerely, 

ull~~~ g __ , 

Meredith Kurpius, Mana:;;O 

Air Quality Analysis Office 

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

B. Additional Items Requiring Attention 

C. Annual Monitoring Network Plan Checklist 

cc: Daren Winkelman, NDEP 

Mike Elges, NDEP 
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 9lacks 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. 

• 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 

Precision/ Accuracy Reports 28 Insufficient to judge 

Annual data certification 29 Insufficient to judge 

Document how agency would 26 Not meeting requirement 

provide for review ofPM2.s 

monitoring network changes 

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 

• [Row 2] On page 20, the Carson City Armory's purpose is described as "to determine 

typical concentration/population exposure." In future plans, please explain how this 

reconciles with a "max concentration" site type for the ozone monitor. 

• [Row 48] The Glen Oaks PMw site type is listed as "typical concentration/population 

oriented"·on page 29. We recommend selecting site types that are included in AQS and 

Appendix D, such as population exposure. 

• [Row 56] The design values provided in the plan are from 2011. Please include more 

current design value information in future plans, or note why more current information is 

not available. 

• [Row 66] As NDEP's PM2.s network is new, please evaluate in your next network 

assessment whether your network includes a site at neighborhood scale in an area of 

expected maximum concentration. 
C. ANNUAL MON1TORING NETWORK PLAN CHECKLIST 

(Updated 11 /26/20 13) 

Year: 2013 

Agency: Nevada Division of Environmental Protection (NDEP) 

40 CFR 58.1 O(a)( I) 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 nonattainrnent areas, PAMS stations, and SPM monitoring stations

40 CFR 58. 1 O(a)( 1) further directs that, "The plan shall include ·a statement of purposes for each monitor and evidence th

each monitor meets the requirements of appendices A, C, 0 , 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 A

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

Administrator are: P AMS, 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 t

comments on its contents and structure. 

Key: 

Whhe = meets the requirement. 

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

=---- 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 meet 

Flag if the req?4 

incorrece? 

58.10 (a)(l) Yes Yes Plan received 6/27/20 13 

ach monitor SS.lO(a){l) Yes Yes On page 20, the Carson City Armory's purpose is 

described as "to determine typical 

concentration/population exposure." In future plans, 

please explain how this reconciles with a "max 

concentration" site type .for the ozone monitor. 

nspection period' 58.10 (a)(!), Yes Yes Cover letter indicates no comments were received. 

58.10 (a)(2) 

network - case when we are 58.10 (a)(2) NA NA 

m modifications (i.e., we 

process6) 

58.10(e) 

network - case when we are 58.1 0 (a)(2) Yes, pg 6-7 Yes Detailed site information for the new PM2.5 SLAMS 

modifications per 58.14(c) 58.10 (b)(5) site (primary and collocated, start date 3/1/2013) in 

58. 1 O(e) Carson City provided on pgs 20-21. EPA approves 

58.14 (c) this new SLAMS sites as part of the network plan 

approval. 

ntation (e.g., attached Yes - Appendix C Yes Approval for Carson City 03 attached as Appendix C. 

 modifications that have Should NDEP move the PM I 0 Manse monitor to the 

ANP approval? Nyc County School District in the future, please 

attach the approval Jetter in the applicable annual 

network plan. 

 1/l/20 11) 58.10 (a)(3) NA NDEP does not have an NCore site 

rces operational (by 58.10 (a)( 4) NA NDEP does not have any required Pb sites 

d RA40 sites submitted by 58.10 (a)(5) NA NDEP does not have any required area-wide or RA40 

N02 sites 

sites operational by 58.10 (a)(5) NA See comment, row 9 

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

ct 

able) - [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 
ANP requirement Citation Was the info Does the Notes 

within 40 submitted?1 lf information 

CFR58 yes, page #s. provided3 meet 

Flag if the req?4 

incorrect2? 

II. N02 plan for near-road sites submitted by 7/1/2013 58.10 (a)(5) NA See comment, 

12. S02 sites operational (by I I I /20 13) 58.10 (a)(6) NA NDEP does no

and 58.13(d) 

13. AQS site identification number for each site 58.1 0(b)(l) Yes, pgs 11-39 Yes 

14. Location of each site: street address and geographic 58.10 (b)(2) Yes, pgs 11-39 Yes 

coordinates 

15. Sampling and analysis method(s) for each measured 58.10 (b )(3) Yes, pgs 11-39 Yes 

parameter 

16. Any proposals to remove or move a monitoring 58. 10 (b )(5) Yes, pgs 6-7 Yes No plans to m

station within a period of 18 months following plan within 18 mon

submittal 

17. Scale of representativeness for each monitor as 58.10(b)(6); Yes, pgs 11-39 Yes 

defined in Appendix D App D 

18. Identification of sites suitable and sites not suitable 58.10 (b)(7) Yes,pgs 11-39 Yes 

for comparison to the annual PM2.5 NAAQS as 

described in Part 58.30 

19. MSA, CBSA, CSA or other area represented by the 58.1 0 (b )(8) Yes, pgs 11-39 Yes 

monitor 

20. Designation of any Pb monitors as either source- 58.JO(b)(9) NA NA No Pb monito

oriented or non-source-oriented 

21. Any source-oriented Pb site for which a waiver has 58. 10 (b)(IO) NA NA No Pb monito

been granted by EPA RA 

22. Any Pb monitor for which a waiver has been 58.10 (b)(! I) NA NA No Pb monito

requested or granted by EPA RA for use ofPb-PM10 

in lieu of Pb-TSP 

23. Identification of required N02 monitors as either near- 58.10 (b)(l 2) NA NA No N02 moni

road or area-wide 

24. Identification of any PM2.s FEMs and/or ARMs not 58.10 (b)(13) NA NA 

eligible to be compared to the NAAQS (Note I: must 58.1l(e) 

include required data assessment.) (Note 2: Required 

SLAMS must monitor PM2.s with NAAQScomparable monitor at the required sample 

frequency.) 

25. For SPMs listed as non-regulatory, note the start Date 58.20(c) NA NA No non-regula

ofFRM/FEMIARM at SPM. If> 24 months, and 

monitor is eligible for comparison to the NAAQS per 

58. 11 (e) and 58.30, the agency must ____ '-------··-

- -

-- -
Citation Was the info Does the Notes 

within 40 submitted? 1 If information 

CFR58 yes, page #s. provided3 meet 

Flag if the req?4 

incorrect2? 

 orE requirements were not 

local agencies provide for 58.IO(c) No Insufficient The plan should include a few sentences stating how 

 PM2.5 monitoring network infonnation to NDEP would provide for the review of changes to the 

f a violating PM2.5 monitor. judge PM2.5 monitoring network that impact the location of 

a violating PM2.5 monitor, should the event arise, per 

40CFR 58.10(c). 

quest for approval for and 58.11 (a) (2) NA NA No request for an alternative to Appendix A. 

requirements for SPMs 

RM which also meets 

s submitted to AQS 58.16(a); Yes, pg 3 Insufficient In addition to describing the general process for 

App A, 1.3 infonnation to certification and submittal of precision/accuracy 

and5.1.1 judge reports, please provide a statement that the reports 

have been submitted and certification completed for 

the year in question. Ideally include the last available 

date ofsubmittaVcertification. If the previous 

calendar year's submittal date is not available, please 

indicate the anticipated submittal date for that year's 

data as well as the submitted date for two years prior. 

(For example, for a plan put out for public comment 

in April 20 14, the plan could include the actual 

submittal date for CY 20 12 data and note an 

anticipated submittal date of May I, 2014 for CY 

2013 data.) 

submitted 58.15 Yes, pg 3 Insufficient In addition to describing the general process for 

App. A 1.3 infonnation to certification and submittal of precision/accuracy 

judge reports, please provide a statement that the reports 

have been submitted and certification completed for 

the year in question. Ideally include the date of 

submittaVcertification. If the previous calendar year's 

submittal date is not available, please indicate the 

anticipated submittal date for that year's data as well 

as the submitted date for two years prior. (For 

example, for a plan put out for public comment in 

April 2014, could include the actual submittal date for 

CY 2012 data and note an anticipated submittal date 

- _()fMay I, 2014 for CY 2013 data.) 

4 
ANP requirement Citation Was the info Docs the Notes 

within 40 submitted?' If information 

CFR58 yes, page #s. provided3 meet 

Flag if the req?4 

incorrect2? 

30. Frequency of flow rate verification for manual PM App A 3.3.2 Yes, pg20-21 Yes Monthly (collo

samplers audit pg21) 

31. Frequency of flow rate verification for automated PM App A 3.2.3 Yes, pgs 11-39 Yes Monthly (all P

analyzers audit PM2.5 at Cars

32. Frequency of one-point flow rate verification for Ph AppA NA NA No Ph monito

samplers audit 3.3.4.1 

33. Frequency of one-point QC check (gaseous) App. A 3.2.1 Yes, pgs 11-39 Yes Perfonned eve

34. Date of last Annual Perfonnance Evaluation (gaseous) App. A 3.2.2 Yes, pgs 11-39 Yes 

35. Dates of last two semi-annual flow rate audits for PM App A, 3.2.4 Yes, pgs 11-39 Yes Not provided 

monitors and 3.3.3 

36. Dates of last two semi-annual flow rate audits for Ph AppA NA NA No Pb monito

monitors 3.3.4.1 

37. PM2.s collocation App A 3.2.5 Yes Yes I SLAMS, I S

SLAMS Carso

38. Designation of a primary monitor if there is more than Need to Yes, pg 20 Yes Carson City A

one monitor for a pollutant at a site. detennine QA Collocated 

collocation than one moni

39. Distance between collocated monitors (Note: waiver App.A Yes, pg 21 Yes 3 meters betw

request or the date of previous waiver approval must 3.2.5.6 and at Carson City 

be included if the distance deviates from 3.2.6.3 

requirement.) 

40. Manual PM10 method collocation met? (note: App A 3.3.1 NA NA None required

continuous PM I 0 does not have this requirement) PMIO instrum

41. Pb collocation AppA NA NA None required

3.3.4.3 monitors 

42. PM10-2.5 collocation (note: only applies to Fresno and App A 3.3.6 NA NA No PM I 0-2.5 

Phoenix NCore sites) 

43. Instrument/monitoring method code for each monitor: App C 2.4.1.2 Yes Yes 

is it reported properly? Is it reported correctly (i.e., 

appropriate method code for regulatory monitors)? 

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

an MSNCSA: does each affected State or local monitoring ag

agency meet full monitoring requirements or is 

an agreement between the affected agencies and the 

EPA Regional Administrator in place? 

45. Start date for each monitor Required to Yes, pgs 11-39 Yes 

detennine if 
Citation Was the info Does the Notes 

within 40 submitted?' lf information 

CFR58 yes, page #s. provided3 meet 

Flag if the req?4 

incorrect2? 

other req. 

(e.g., min# 

and colloc) 

are mel 

or each monitor Required to Yes,pgs 11 -39 Yes 

determine if other req. 

(e.g., min # 

and colloc) are met 

ach instrument App D 1.1 Yes, pgs 11-39 Yes 

58.10(b)(6) 

ent AppD 1.1.1 Yes, pgs 11-39 Yes, but incorrect On pg 29, dte Glen Oaks PMI 0 site type is listed as 

in one instance "typical concentration/popUlation oriented." We 

recommend using population exposure instead, to match &he site types descn"bed in AQS and Appendix 

D. 

-

e for each instrument Required to Yes, pgs 11-39 Yes 

determine if 

other req. 

(e.g., min # 

and colloc) are met 

urrence code for each Required to Yes, pgs 11-39 Yes 

determine if 

other req. 

(e.g., min # 

and colloc) are met 

e (note: date of waiver 58. 10 (b)(4) Yes, pgs 11-39 Yes Waiver attached. 

d if the sampling season App D, 4.1 (i) 

t) 

M2.s - applies to year-round 58.10 (b)(4) Yes Yes Sample year-round for PM2.5. Single FRM is a 

hedules (note: date of waiver 58. 12(d) collocated monitor running on a I :6 day schedule. 

d if the sampling season App D 4.7 

t) EPA 

l:lowchart 

M10 58.10 (b)(4) Yes Yes All continuous monitors operating year round. 

6 
ANP requirement Citation Was the info Does the Notes 

within 40 submitted?1 If information 

CFR58 yes, page #s. provided3 meet 

Flag if the req?4 

incorrece? 

58. 12(e) 

App 04.6 

54. Sampling schedule for Pb 58.10(b)(4) NA NA No Pb monito

58.12(b) 

App 04.5 

55. Sampling schedule for PM10.2.5 58.10 (b)(4) NA NA No PM I 0-2.5 

58.12(t) 

App 04.8 

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

supported by MSA ID, MSA population, DV, # and 2013. Please 

monitors, and # required monitors] (see footnote) 7 TableD-2 future plans. o

not available. 

57. Identification of max. cone. 0 3 monitor(s) App 04.1 (b) Yes, pg 20 Yes Carson City A

concentration 

58. Minimum monitoring requirements met for near-road App04.3.2 Yes Yes None required

N02 (20 14 start date) require N02 m

59. Minimum monitoring requirements met for area-wide App 04.3.3 Yes Yes None required

N02 require N02 m

60. Minimum monitoring requirements met for RA-40 App 0 4.3.4 Yes Yes None required

N02 require N02 m

61. Minimum monitoring requirements met for sol App 0 4.4 Yes Yes None required

[Note: Only monitors considered to be required require S02 m

SLAMs are eligible to be counted towards meeting 

minimum monitoring requirements.l 

62. Minimum monitoring requirements met for Pb [Note: App 04.5 Yes Yes None required

Only monitors considered to be required SLAMs are 58.13(a) require Pb mo

eligible to be counted towards meeting minimum 

monitoring requirements.] 

63. Minimum # of monitors for PM2.5 [Note I: should be AppO, Yes Yes 

supported by MSA ID, MSA population, OV, # 4.7.1(a) and 

monitors, and# required monitors] [Note 2: Only Table 0-5 

monitors considered to be required SLAMs are 

eligible to be counted towards meeting minimum 

mon 

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

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

within 40 submitted? 1 If information 

CFR58 yes, page #s. provided3 meet 

Flag if the req?4 . 

incorrece? 

Clarifications: Provide a list Need to NA NA 

not include all SLAMS. assess several 

 all SLAMS are considered requirements 

sent area-wide air quality AppD Yes Yes 

4.7. l(b) 

ite at neighborhood or AppD Incomplete Iusufficient to As NDEP's PM2.5 network is new, please evaluate in 

xpected maximum 4.7.1(b)(l) judge your next network assessment whether your 

monitoring network includes a site at neigbbothood 

scale in an area of exPected maximum concentration. 

.s required, is there a site in AppD NA NA No additional required PM2.5 sites at this time. 

 4.7.l(b)(2) 

uirements for continuous App D 4.7.2 Yes Yes 

ackground and transport App D 4.7.3 Yes, pg4 Yes State requirement for at least one regional I 

background/transport site satisfied by Jarbidge 

IMPROVE site. 

iation requirements met for App D 4.7.4 Yes Yes None required. NDEP does not have any required 

chemical speciation sites. 

or PM10 App D,4.6 Yes Yes None required per App. D, however, 4 are required 

(a) and Table through a MOU. 

D-4 

uirements met for PM10.2.s App D4.8 Yes Yes None required. 

est road App £6 Yes, pgs 11 -39 Yes 

oad App E Yes, pgs 11-39 Yes 

App E 3(a) Yes,pgs 11-39 Yes App£2 Yes, pgs 11 -39 Yes 

 structure App£2 Yes, pgs 11-39 Yes 

ns on roof App E4(b) Yes,pgs 11 -39 Yes 

ns not on roof App E 4(a) Yes, pgs 11-39 Yes Recommend noting how high the obstacle is above 

the probe in addition to distance. 

App£5 11-39 Yes 

inerator flue App E 3(b) Yes, pgs 11 -39 Yes 

App E, 4(a) Yes, pgs 11-39 Yes 

and 4(b) 

ble) App£9 Yes,pgs 11 -39 Yes 

8 
ANP requirement Citation Was the info Does the Notes 

within 40 submitted?1 If information 

CFR58 yes, page #s. provided3 meet 

Flag if the req?"' 

incorrect2? 

84. Residence time (if applicable) AppE9 Yes, pgs 11-39 Yes 
 Network Plan 

the S/L/T agency during the public comment period? No comments were submitted. · 

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: 

10