Air Program Air Program Components: an Components: an
Overview & Tribal Overview & Tribal Case StudyCase Study
James PayneJames Payne
Morongo Band of Mission Morongo Band of Mission Indians Environmental Indians Environmental Protection DepartmentProtection Department
ComponentsComponents Dependent upon issues, needs, and goals for Dependent upon issues, needs, and goals for theirtheir air air
quality management objectivesquality management objectives
Some or all components will be utilized, some go hand in Some or all components will be utilized, some go hand in handhand Source EvaluationSource Evaluation Quality Assurance Project Plan (QAPP)Quality Assurance Project Plan (QAPP) Emission Inventory (EI)Emission Inventory (EI) MonitoringMonitoring Data ManagementData Management Data AnalysisData Analysis Air Quality PlanAir Quality Plan Tribal Implementation Plan (TIP)Tribal Implementation Plan (TIP) PermittingPermitting Tribal OrdinancesTribal Ordinances Public Education programPublic Education program
Morongo LocationMorongo Location
Basin TopographyBasin Topography
Source EvaluationSource Evaluation
Take a look at greatest issues of concern Take a look at greatest issues of concern and how they affect:and how they affect: Health of populationHealth of population AestheticsAesthetics Future growthFuture growth
Morongo is currently designated as non-Morongo is currently designated as non-attainment for 8-hour ozone, PM-10, PM-2.5attainment for 8-hour ozone, PM-10, PM-2.5
Riverside County is one of the worst air Riverside County is one of the worst air quality areas in the nation, occasionally the quality areas in the nation, occasionally the worstworst
Quality Assurance Quality Assurance Project PlanProject Plan
Detailed description of Detailed description of whatwhat, , wherewhere, , whenwhen, , whowho, , howhow and and whywhy of project of project activitiesactivities
Sets a course of action to accomplish Sets a course of action to accomplish desired goalsdesired goals
Standardizes the proceduresStandardizes the procedures When approved and followed, creates When approved and followed, creates
legally defensible datalegally defensible data
Morongo Quality Morongo Quality Assurance Project PlanAssurance Project Plan
Created February 2005, sent to EPA shortly Created February 2005, sent to EPA shortly thereafterthereafter
Two times EPA requested changes-QAPP revised, Two times EPA requested changes-QAPP revised, resubmitted to EPAresubmitted to EPA
EPA sent letter commenting on changes with EPA sent letter commenting on changes with approvalsapprovals Not a bad thingNot a bad thing
Currently:Currently: O3 Monitoring: revised 02/13/13: Under Review by O3 Monitoring: revised 02/13/13: Under Review by
EPAEPA PM2.5 Monitoring: revised 09/09/13: Under Review PM2.5 Monitoring: revised 09/09/13: Under Review
by EPAby EPA NOx Monitoring: monitoring for informational NOx Monitoring: monitoring for informational
purposespurposes
Emissions InventoryEmissions Inventory
Two-part process involving Two-part process involving identificationidentification of of
potential emission potential emission sourcessources and then and then
calculating calculating estimatedestimated quantities of quantities of
pollutants pollutants emittedemitted by those sources by those sources
Morongo Emissions Morongo Emissions InventoryInventory
1999/2000 inventory conducted1999/2000 inventory conducted SO2, NO, NO2, CO, ROG, PM-10, PM2-5SO2, NO, NO2, CO, ROG, PM-10, PM2-5
2008 used TEISS for2008 used TEISS for NOx, SOx, VOC’s, CO, PM-10, NOx, SOx, VOC’s, CO, PM-10,
Used a consultant for quantification of identified Used a consultant for quantification of identified
stationary sources located on reservationstationary sources located on reservation
Inventory within major relative boundaries, any Inventory within major relative boundaries, any
smaller land holdings independently classifiedsmaller land holdings independently classified
Mapped major sources using GPS/GIS technologies Mapped major sources using GPS/GIS technologies
as well as available databases and previous studiesas well as available databases and previous studies
Possibility of recruiting ITEP intern for 2015 Possibility of recruiting ITEP intern for 2015
update…update…
Sample Emission SitesSample Emission Sites
MonitoringMonitoring
Develops baseline dataDevelops baseline data Includes meteorological (rain, temp, Includes meteorological (rain, temp,
humidity, etc)humidity, etc) Includes ambient air (ozone, particulate Includes ambient air (ozone, particulate
matter, carbon monoxide, etc)matter, carbon monoxide, etc) Includes Hazardous Air Pollutants (HAP’s) Includes Hazardous Air Pollutants (HAP’s)
also known as Air Toxicsalso known as Air Toxics
Morongo MonitoringMorongo Monitoring Air monitoring station currently monitors O3, Air monitoring station currently monitors O3,
PM2.5, NOxPM2.5, NOx Collocated PM2.5 monitorsCollocated PM2.5 monitors
One federal reference method (FRM) - PartisolOne federal reference method (FRM) - Partisol One federal equivalency method (FEM) - BAMOne federal equivalency method (FEM) - BAM
Wind speed/direction, barometric pressure, temperatureWind speed/direction, barometric pressure, temperature
3 meteorological-only stations with 3 meteorological-only stations with rain gauge, wind speed/direction, temperature, humidity, rain gauge, wind speed/direction, temperature, humidity,
solar radiation, fuel moisture/temp, solar radiation, fuel moisture/temp, derived data such as evapotranspiration, dew point, sun-derived data such as evapotranspiration, dew point, sun-
days, etcdays, etc
Portable PM-2.5 analyzer (mobile air station)Portable PM-2.5 analyzer (mobile air station) Mini-VolMini-Vol School Air Toxics - received report February 2015School Air Toxics - received report February 2015
59 VOC’s, 15 carbonyl compounds and 11 metals.
Morongo Monitoring Morongo Monitoring
Data ManagementData Management
Key component!Key component! Without proper data Without proper data management, management, “valid”“valid” becomes invalid for becomes invalid for certain purposescertain purposes
Tribal Data ToolboxTribal Data Toolbox Air Quality SystemAir Quality System
Morongo Data Morongo Data ManagementManagement
Data stored in datalogger and internal memory of Data stored in datalogger and internal memory of particulate matter monitorparticulate matter monitor
Data retrieved weekly by Environmental SpecialistData retrieved weekly by Environmental Specialist Data cataloged and checked monthly for Data cataloged and checked monthly for
flags/errorsflags/errors In case of noticed problems, data is still susceptible In case of noticed problems, data is still susceptible
to greater review/revisionto greater review/revision
One person doesn’t ensure greatest Quality One person doesn’t ensure greatest Quality AssuranceAssurance
Proceeding with determination of joining a PQAOProceeding with determination of joining a PQAO Data is loaded quarterly into AQSData is loaded quarterly into AQS
Formatted first using Tribal Data ToolboxFormatted first using Tribal Data Toolbox
Data AnalysisData Analysis What are the data telling you?What are the data telling you? Provides insight, forecasting (trends)Provides insight, forecasting (trends) Used for decision making and setting Used for decision making and setting
future goalsfuture goals
Morongo Data AnalysisMorongo Data Analysis During monthly checkDuring monthly check
Use outside source to check AMS data Use outside source to check AMS data consistency, outliersconsistency, outliers
Cross check weather station data against each Cross check weather station data against each other for consistencyother for consistency Bad CowBad Cow
Create graphs & reports for internal needs Create graphs & reports for internal needs and EPA requirementsand EPA requirements Sorry about
that…
Air Quality PlanAir Quality Plan
Long-term tribal program needs and Long-term tribal program needs and optionsoptions
Goals and objectivesGoals and objectives Strategies for program developmentStrategies for program development
Morongo Air Quality PlanMorongo Air Quality Plan
Protect the health and viewshed of Tribal Protect the health and viewshed of Tribal
communitycommunity
Establish actual levels of PM 2.5, O3, and NOx Establish actual levels of PM 2.5, O3, and NOx
on Tribal landson Tribal lands
Utilize PM & O3 data for regulatory purposesUtilize PM & O3 data for regulatory purposes
Monitor long-term ambient air quality changesMonitor long-term ambient air quality changes
Apply for Treatment as State for NotificationApply for Treatment as State for Notification
Tribal Implementation Plan Tribal Implementation Plan (TIP)(TIP)
EPA provides for tribes “Treatment as EPA provides for tribes “Treatment as State (TAS), under the Tribal Authority State (TAS), under the Tribal Authority Rule (TAR) as such:Rule (TAR) as such:
A Tribal Implementation Plan (TIP) is a A Tribal Implementation Plan (TIP) is a Tribes Tribes individually createdindividually created plan for plan for complying with the federal Clean Air Act, complying with the federal Clean Air Act, authorized by the Environmental authorized by the Environmental Protection Agency.Protection Agency.
The TIP consists of narrative, rules, The TIP consists of narrative, rules, technical documentation, and agreements technical documentation, and agreements that an individual state will use to clean up that an individual state will use to clean up polluted areas. polluted areas.
PermittingPermitting Tribes can utilize their plans and authority Tribes can utilize their plans and authority
to issue permits, conduct inspections, and to issue permits, conduct inspections, and place regulations congruent with the place regulations congruent with the permitspermits
Title V stack testing at cogeneration Title V stack testing at cogeneration facility which provides power via natural facility which provides power via natural gas to hotel/casinogas to hotel/casino
Tribal OrdinancesTribal Ordinances
Under the discretion of Tribal Council, General Under the discretion of Tribal Council, General Membership, or other Tribal government bodyMembership, or other Tribal government body
Utilize the Tribal Air Program data and expertise Utilize the Tribal Air Program data and expertise to create and decide on beneficial practicesto create and decide on beneficial practices
““The Tribe finds that it necessary to adopt The Tribe finds that it necessary to adopt standards and procedures by which the Tribe standards and procedures by which the Tribe can take action to prevent such threats, can take action to prevent such threats, pollution, and deterioration.”pollution, and deterioration.”
Created and passed by Council, Air Quality Created and passed by Council, Air Quality Protection Code and Solid and Hazardous Waste Protection Code and Solid and Hazardous Waste CodeCode
Morongo Public Morongo Public Education ProgramEducation Program
Quarterly newsletters, monthly PSA’sQuarterly newsletters, monthly PSA’s Daily Air Quality Index Reports & Daily Air Quality Index Reports &
School Flag ProgramSchool Flag Program Outreach eventsOutreach events Indoor Air Quality-Tools Indoor Air Quality-Tools
for Schools, CO, Moldfor Schools, CO, Mold Part of grant requirementsPart of grant requirements "Tell me, and I'll forget. Show me, and I may "Tell me, and I'll forget. Show me, and I may
not remember. Involve me, and I'll not remember. Involve me, and I'll understand." understand." (unknown) (unknown)
Hurdles and SuccessesHurdles and Successes
Need to recognize capabilities and Need to recognize capabilities and resources including timeresources including time
Only 1- couldn’t do it at the highest levelOnly 1- couldn’t do it at the highest level
Secured fundingSecured funding Using data for redesignation/realignment Using data for redesignation/realignment
of attainment boundaryof attainment boundary Dedicated air specialistDedicated air specialist
What You Should What You Should RememberRemember
Air program can be as simple or complicated as Air program can be as simple or complicated as
your needs dictate; not necessarily based on your needs dictate; not necessarily based on
tribe/reservation sizetribe/reservation size
Evaluate your needs, implement portions of Evaluate your needs, implement portions of
program that make senseprogram that make sense
Make sure you thoroughly assess your time and Make sure you thoroughly assess your time and
program needs before implementationprogram needs before implementation
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