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