Air Program Components: an Overview & Tribal Case Study James Payne Morongo Band of Mission Indians Environmental Protection Department

Components  Dependent upon issues, needs, and goals for their air quality management objectives  Some or all components will be utilized, some go hand in hand  Source Evaluation  Quality Assurance Project Plan (QAPP)  Emission Inventory (EI)  Monitoring  Data Management  Data Analysis  Air Quality Plan  Tribal Implementation Plan (TIP)  Permitting  Tribal Ordinances  Public Education program

Morongo Location

Basin Topography

Source Evaluation  Take a look at greatest issues of concern and how they affect:  Health of population  Aesthetics  Future growth  Morongo is currently designated as non- attainment for 8-hour ozone, PM-10, PM-2.5  Riverside County is one of the worst air quality areas in the nation, occasionally the worst

Quality Assurance Project Plan  Detailed description of what, where, when, who, how and why of project activities  Sets a course of action to accomplish desired goals  Standardizes the procedures  When approved and followed, creates legally defensible data

Morongo Quality Assurance Project Plan  Created February 2005, sent to EPA shortly thereafter  Two times EPA requested changes-QAPP revised, resubmitted to EPA  EPA sent letter commenting on changes with approvals  Not a bad thing Currently:  O3 Monitoring: revised 02/13/13: Under Review by EPA  PM2.5 Monitoring: revised 09/09/13: Under Review by EPA  NOx Monitoring: monitoring for informational purposes

Emissions Inventory  Two-part process involving identification of potential emission sources and then calculating estimated quantities of pollutants emitted by those sources

Morongo Emissions Inventory  1999/2000 inventory conducted  SO2, NO, NO2, CO, ROG, PM-10, PM2-5  2008 used TEISS for  NOx, SOx, VOC’s, CO, PM-10,  Used a consultant for quantification of identified stationary sources located on reservation  Inventory within major relative boundaries, any smaller land holdings independently classified  Mapped major sources using GPS/GIS technologies as well as available databases and previous studies  Possibility of recruiting ITEP intern for 2015 update…

Sample Emission Sites

Monitoring  Develops baseline data  Includes meteorological (rain, temp, humidity, etc)  Includes ambient air (ozone, particulate matter, carbon monoxide, etc)  Includes Hazardous Air Pollutants (HAP’s) also known as Air Toxics

Morongo Monitoring  Air monitoring station currently monitors O3, PM2.5, NOx  Collocated PM2.5 monitors  One federal reference method (FRM) - Partisol  One federal equivalency method (FEM) - BAM  Wind speed/direction, barometric pressure, temperature  3 meteorological-only stations with  rain gauge, wind speed/direction, temperature, humidity, solar radiation, fuel moisture/temp,  derived data such as evapotranspiration, dew point, sun-days, etc  Portable PM-2.5 analyzer (mobile air station)  Mini-Vol  School Air Toxics - received report February 2015   59 VOC’s, 15 carbonyl compounds and 11 metals.

Morongo Monitoring

Data Management  Key component! Without proper data management, “valid” becomes invalid for certain purposes  Tribal Data Toolbox  Air Quality System

Morongo Data Management  Data stored in datalogger and internal memory of particulate matter monitor  Data retrieved weekly by Environmental Specialist  Data cataloged and checked monthly for flags/errors  In case of noticed problems, data is still susceptible to greater review/revision  One person doesn’t ensure greatest Quality Assurance  Proceeding with determination of joining a PQAO  Data is loaded quarterly into AQS  Formatted first using Tribal Data Toolbox

Data Analysis  What are the data telling you?  Provides insight, forecasting (trends)  Used for decision making and setting future goals

Morongo Data Analysis  During monthly check  Use outside source to check AMS data consistency, outliers  Cross check weather station data against each other for consistency  Bad Cow  Create graphs & reports for internal needs and EPA requirements Sorry about that…

Air Quality Plan  Long-term tribal program needs and options  Goals and objectives  Strategies for program development

Morongo Air Quality Plan  Protect the health and viewshed of Tribal community  Establish actual levels of PM 2.5, O3, and NOx on Tribal lands  Utilize PM & O3 data for regulatory purposes  Monitor long-term ambient air quality changes  Apply for Treatment as State for Notification

Tribal Implementation Plan (TIP)  EPA provides for tribes “Treatment as State (TAS), under the Tribal Authority Rule (TAR) as such:  A Tribal Implementation Plan (TIP) is a Tribes individually created plan for complying with the federal Clean Air Act, authorized by the Environmental Protection Agency.  The TIP consists of narrative, rules, technical documentation, and agreements that an individual state will use to clean up polluted areas.

Permitting  Tribes can utilize their plans and authority to issue permits, conduct inspections, and place regulations congruent with the permits  Title V stack testing at cogeneration facility which provides power via natural gas to hotel/casino

Tribal Ordinances  Under the discretion of Tribal Council, General Membership, or other Tribal government body  Utilize the Tribal Air Program data and expertise to create and decide on beneficial practices  “The Tribe finds that it necessary to adopt standards and procedures by which the Tribe can take action to prevent such threats, pollution, and deterioration.”  Created and passed by Council, Air Quality Protection Code and Solid and Hazardous Waste Code

Morongo Public Education Program  Quarterly newsletters, monthly PSA’s  Daily Air Quality Index Reports & School Flag Program School Flag Program  Outreach events  Indoor Air Quality-Tools for Schools, CO, Mold for Schools, CO, Mold  Part of grant requirements  "Tell me, and I'll forget. Show me, and I may not remember. Involve me, and I'll understand." (unknown)

Hurdles and Successes  Need to recognize capabilities and resources including time  Only 1- couldn’t do it at the highest level  Secured funding  Using data for redesignation/realignment of attainment boundary  Dedicated air specialist

What You Should Remember  Air program can be as simple or complicated as your needs dictate; not necessarily based on tribe/reservation size  Evaluate your needs, implement portions of program that make sense  Make sure you thoroughly assess your time and program needs before implementation