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
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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 &
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School Flag Program
Outreach events
Indoor Air Quality-Tools
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