NEW GUIDANCE DOCUMENT
ON
TRIBAL AMBIENT MONITORING
Updates to previous draft reviewed by NTAA;
Includes revisions for Sections IV, VII and XII
November 2005
U. S. Environmental Protection Agency
Research Triangle Park, NC
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Table of Contents
New Guidance Document on Tribal Ambient Monitoring
(Note: See Appendix B for proposed alternative structure for Table of Contents)
Section I. Purpose and Audience
Lead: Julie McClintock - EPA/OAQPS 919-541-5339 mcclintock.julie@epa.gov
Bill Grantham - NTEC 505-242-2175 x116 bgrantham@ntec.org
Section II. Guidelines for EPA Support for Tribal Air Monitoring
Lead: Phil Lorang - EPA/O AQPS 919-541-5463 lorang.phil@epa.gov
Bill Grantham - NTEC 505-242-2175 x116 bgrantham@ntec.org
Section III. Background for Planning Tribal Air Monitoring
Lead: Joe Tikvart - EPA/OAQPS/SEE 919-541-7793 tikvart.joe@epa.gov
Section IV. Tribal Air Quality Issues, Relevant Ambient Air Monitoring, and Current
and Recent Tribal Air Monitoring Activities Directed Towards These Issues
Lead: Norm Beloin - EPA/R1 617-918-8387 beloin.norm@epa.gov
Bill Thompson - Penobscot 207-827-7776cleanair@penobscotnation.org
Mike Copeland - EPA/R8 303-312-6010 copeland.michael@epa.gov
Keith Rose - EPA/RIO 206-553-1949 rose.keith@epa.gov
Section V. Implementation of Monitoring (identify all things that need to be done, e.g.,
Q/A, siting requirements, report to AQS, etc.)
Lead: Joy Wiecks - Fond du Lac 218-878-8008 iovwiecks@fdlrez.com
Leland Grooms-EPA/R7 913-551-7124 grooms.leland@epa.gov
Section VI. The Role of Tribal Monitoring in the National Monitoring Strategy
Lead: Phil Lorang - EPA/O AQPS 919-541-5463 lorang.phil@epa.gov
Stephen Hartsfield - NTAA 505-242-2175 x106 shartsfield@ntec.org
Bill Nally - EPA/R6 214-665-8351 nally.bill@epa.gov
Section VII. Understanding Monitoring Data and Its Implications
Lead: Motria Caudill - EPA/R5 312-886-0267 caudill.motria@epa.gov
Glenn Gehring - TAMS 702-784-8269 gehring. glenn@epa. gov
James Hemby - EPA/O AQPS 919-541-5459 hemby.james@epa.gov
Section VIII. Storage and Access to Monitoring Data
Lead: Farshid Farsi - TAMS 702-784-8263 farsi.farshid@epa.gov
Tami Laplante - EPA/O AQPS 919-541-1915 laplante.tami@epa. gov
George Dilbeck - EPA/ORIA 702-784-8278 dilbeck.george@epa.gov
Section IX. Assessment of Ambient Air Quality in Indian Country in the Absence of Air
Monitoring
Lead: Keith Rose - EPA/RIO 206-553-1949 rose.keith@epa.gov
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Ryan Callison - ITEC 800-259-5376x1006 rcallison@cherokee.org
Glenn Gehring - TAMS 702-784-8269 gehring. glenn@epa. gov
Stephen Hartsfield - NTAA 505-242-2175 x106 shartsfield@ntec.org
Bill Thompson - Penobscot 207-827-7776cleanair@penobscotnation.org
Annabelle Allison - ITEP 919-541-0708 allison.annabelle@epa.gov
Section X. How to Request EPA Funding and Other Support
Lead: Stephen Hartsfield - NTAA 505-242-2175 x106 shartsfi el d@ntec. org
Ken Cronin - NTEC 505-242-2175 x115 kcronin@ntec.org
Section XI. Other Air Quality Management Program Elements
Lead: ?????
Leroy Williams (Gila River)
Section XII. The Tribal Perspective
Coordinator: Lisa Riener - Quinault 360-276-8215 x484 lriener@quinault.org
Joy Wiecks - Fond du Lac 218-878-8008 iovwiecks@fdlrez.com
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I. Purpose and Audience
A. Background on EPA's Tribal Air Monitoring Program
EPA's tribal air policy emphasizes that as sovereign governments, tribes set their
own air program goals. Therefore, EPA's goal for the tribal air program is appropriately
to help the tribes understand their air quality problems and to establish and meet their air
quality goals, rather than to set goals or timetables for the tribes.
Tribes are diverse in their air quality problems, challenges, and capabilities. In
addition, tribes often also face non-air risks to the health of their members — as well as
other challenges and disadvantages — that are different from those facing non-tribal
communities. Because of the diversity in situations and goals from tribe to tribe, EPA
has taken the approach of delegating to the Regional Office level the tasks of assisting
tribes in identifying their goals and the task of managing the available resources to help
meet those goals. Because Regions understand individual tribal situations, effective
decisions about funding and in-kind assistance are best made at the Regional Office level.
Regional Offices have taken the initiative on helping tribes set air quality goals and
design ambient monitoring to support them. Regions have prioritized requests from
tribes when they collectively exceed the tribal air management grant funds available to
the Regional Office. Regional Offices also negotiate, award, and manage grants to
individual tribes. Regional Offices provide in-person, telephone, and written guidance
and assistance to the tribal governments at all these stages. Technical training on the
actual operation of monitors is available to tribes through the Tribal Air Monitoring
Support (TAMS) Center, which is supported by a grant from EPA Headquarters. To
date, Regional Offices and individual tribes have entered into grants that have dedicated a
portion of the available tribal air management resources to plan, establish, and operate
approximately [insert #] ambient air monitoring stations in Indian country.
In the course of this deliberately highly decentralized process, Headquarters and
Regional Offices have prepared a limited body of strategic guidance on tribal air
monitoring, i.e., guidance on deciding whether to monitor, what type of monitoring to do,
and how EPA will prioritize requests for funding assistance. This guidance is rather
general in nature, reflecting the need to accommodate the diversity of tribal situations.1
1 The available strategic guidance (excluding technical guidance on monitor operations and maintenance)
includes the following documents, and perhaps others at the individual Regional Office level:
1. 4-page section titled "Tribal Air Quality Management" in the Final National Program and Grant
Guidance for Fiscal Years 2006-2008, April 27, 2005.
2. Memo from Jeffrey R. Holmstead, "Criteria for Providing Funds to Tribes from the State and
Tribal Grant Assistance Appropriation for 103 and 105 Grants," January 27, 2005.
3. "Menu Item: Air Quality Monitoring Activities," in The Tribal Air Grant Framework - A Menu
of Options For Developing Tribal Air Grant Work Plans and Managing Grants for Environmental
Results, September 2004.
http://yosemite.epa.gov/R10/AIRPAGE.NSF/283d45bd5bb068e68825650f0064cdc2/e34950b285
534aa988256dfe0063be55/$FILE/The%20TRIBAL%20AIR%20GRANTS%20FRAMEWORK%
20final.pdf
4. Guidance for Conducting: TRIBAL AIR QUALITY ASSESSMENTS, U.S. EPA Region 10, April
15 2005.
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In addition to this limited body of strategic guidance, tribes have access to the large body
of EPA guidance on monitoring technologies, quality assurance, and data management.
While originally prepared for use by state and local government agencies, this technical
guidance is equally applicable to monitors in tribal settings.
B. Purpose of this Guidance Document
This guidance document is not intended to modify any existing EPA policies on
tribal air quality management. The intended purpose of this guidance document is to
improve the ability of tribes and regional offices to prioritize monitoring resources and to
accomplish the following:
• (1) ensure that tribal goals for tribal air monitoring projects are clearly stated and
documented in grant agreements (or other suitable forms) before resources under EPA
management are applied, that progress in meeting those goals is tracked, and that tracking
results are used to make adjustments when appropriate.
Do we want to imply that regions are not applying standards consistently?
• (2) serve as a useful information resource for tribes as they determine their need for
monitoring, work plans and grant applications, as well as a one stop resource for
locating technical information.
• (3) assist tribes to understand monitoring data.
How do we do this?
• (4) help integrate and coordinate tribal and state/local/national monitoring strategies
and activities.
How? What does this mean? Section 4?
• (5) Recognize the need for flexibility to address the unique needs of individual tribes.
Is this a separate point? Put in intro?
C. Audience
The intended audiences for this document are tribal environmental professionals
and EPA Regional Office and Headquarters staff who are involved in resource
allocations, tribal air grant award and management, program evaluation, strategic
planning of monitoring networks, or technical support to monitoring programs. State
monitoring officials may also benefit from reading this document, as it may improve their
understanding of tribal goals and how EPA strives to help tribes meet their goals. This
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should allow them to collaborate more efficiently with tribes whenever collaboration
serves state and tribal objectives.
This section is OK. If we adopt Bill's proposed new organization then we need to make
sure the new organization addresses different audiences.
D. Relationship to EPA's Strategic Plan, Budget, and Program Assessment
Process
EPA's Strategic Plan for 2003-2008 contains this statement regarding EPA's
commitment to work with tribes:
EPA is committed to working with tribes on a government-to-government
basis to develop the infrastructure and skills tribes need to assess,
understand, and control air quality on their lands. We will increase air
monitoring in Indian country, and, in consultation with tribes, we will
establish needed federal regulatory authorities and help tribes develop and
manage their own air programs in a manner consistent with EPA Indian
Policy and tribal traditions and culture. We plan to complete a policy
determining when Federal Implementation Plans are appropriate for
bringing Clean Air Act programs to Indian country. We will support tribal
air programs by providing technical support, assistance with data
development, and training and outreach, and we will help tribes participate
in discussions of national policy and operations and in regional planning
and coordination activities. Where tribes choose not to develop their own
programs, we will implement air quality programs directly.
In developing its annual budget plans, EPA considers whether sufficient resources are
available to support tribal air monitoring that is necessary and appropriate to protect air
quality in Indian country or to provide important data that helps meets state, local, or
national monitoring data needs. Each year, EPA's budget request to Congress requests a
certain amount of funding for use in giving to grants to tribes to support air quality
management. For the last several years, Congress has appropriated about $11 million for
this purpose.2 It has become apparent that increasing numbers of tribes are interested in
establishing monitoring stations, and that not all interested tribes will be able to obtain
EPA financial support for ambient air monitoring if resources for tribal air quality
management remain steady. Many if not all Regional Offices report that already they are
not able to meet all requests to provide grant funds for tribal air monitoring. Other than
reporting this situation, this guidance document is not intended to examine or make
2 In FY2005, EPA proposed to Congress that there be separate amounts of air grant funding for states and
tribes. EPA observes these two separate ceilings in its operating plan under the enacted FY2005 budget.
EPA has proposed the same separation for FY2006, and EPA has issued grant and technical guidance for
FY2006 based on this separation. InFY2005, $ 11.1 million is available for tribal air management, see
http://www.epa.gov/ocfo/budget/2005/2005bib.pdf. The proposed FY2006 budget provides $ 11 million,
see http://www.epa.gov/ocfo/budget/2006/2006bib.pdf.
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recommendations regarding the overall level of EPA funding and in-kind support to tribal
air quality management. EPA considers this and other budget issues through other
processes. The experience of working across Headquarters and Regional Office and with
tribal professionals in the course of preparing this guidance document [will/has] better
informed EPA staff about the tension between resources and needs, and will inform EPA
budget decision-makers in future years.
The Office of Management and Budget (OMB) on a regular basis assesses EPA's
Air Program to determine how well each part of the Air Program is managed in terms of
having appropriate, and well defined goals; applying resources towards those goals;
providing guidance to partners who help meet the goals; having systems in place to
observe how well the goals are met; and making adjustments in the program when
necessary to reach those goals. In addition to meeting OMB expectations, this "goals and
feedback" model is just good common sense because it helps make sure that limited
resources are used in ways that best meet the right goals. Programs that are found by
OMB to have serious weaknesses in management are asked to make corrections and face
the possibility of funding reduction in future year budget proposals to Congress.
The most recent round of review of the NAAQS air quality program by OMB has
made EPA managers and staff more conscious about the importance of being able to
document that the tribal assistance portion of the Air Program meets OMB measures and
goals, guides participants to meet those goals, tracks progress, and make adjustments
when needed. This guidance document on tribal air monitoring is a new part of such
documentation.
It should be noted that unlike most EPA programs, the goals of the tribal air
monitoring program have been set by the Regional offices and tribes with general
guidance from Headquarters and OAQPS. A result is that people inside and outside of
EPA who are not personally involved in working with tribes on monitoring projects need
the benefit of reporting systems to be able to be aware of and assess what is being
accomplished with available resources. The preparation of this document represents one
cycle of such assessment and reporting, in that current and recent tribal air monitoring
programs are reviewed in Section IV.
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E. The Tribal Perspective
EPA received comment from NTAA and tribal professionals in October on the
11/05 draft. As a result of the comments received, we divided the Guidance effort into
two documents: (1) EPA Guidance to identify and prioritize resources related to tribal air
quality, and (2) Monitoring Guidance for tribes. The Tribal perspective section will
appear in both documents.
Both documents convey EPA guidance and reflect EPA policies and both will be
developed by a workgroup that include tribal environmental professionals. EPA has
opened the development of this document to all interested tribal environmental
professionals to assist us to make a document that takes into account tribal input and is
meaningful to tribes, as well as to EPA. To ensure that tribal views are represented,
particularly if they are not the same views as those represented in this document, we are
at various points in the document delineating text blocks which will offer comment or
reaction from the tribal perspective. These passages are provided by tribal environmental
professionals and NTAA and do not represent EPA policy or guidance, but may be useful
to some or all readers of this document.
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II. Guidelines for EPA Support for Tribal Air Monitoring
This section states the guidelines that EPA applies in its air monitoring work with tribes.
The purpose of listing them here is to promote understanding and observance of the
principles by EPA staff, and to help tribes anticipate and understand the basis for future
EPA actions. Most of these principles flow from the Clean Air Act, the EPA Indian
Policy, the Tribal Air Rule, and other existing law and EPA rules and policies on budget,
quality assurance, ambient monitoring, etc. The wording of these principles was the
subject of the first few conference calls among the project participants. Individual EPA
Regional Offices may have their own guidelines or grant criteria. In the course of
developing this guidance document, Regional Offices reviewed their guidelines to ensure
they did not conflict with those stated here. The guidelines include the following:
a. EPA has a responsibility to relate to each tribe on a government-to-
government basis, and should act in the tribe's best interest. To the extent
possible, EPA should also take into account the tribe's preferences. EPA is
obligated to consult with tribes at an appropriate level. Input from tribal
environmental professionals was obtained starting at an early point in the
development of this guidance/strategy. However, EPA's consultation
responsibilities may require continued discussions between tribal leaders
and appropriate EPA staff or management
b. Tribes set their own air quality goals. EPA strives to assist them in doing
so and in determining how monitoring can help clarify and/or accomplish
those goals.
c. Monitoring supported by EPA grant funds should always be for the
identified purpose of characterizing and/or managing specific known or
suspected short term and/or long term risks to environmental values that
depend on maintaining or restoring good air quality, including:
i.Human health risks (including informing exposed persons about the
level of their exposure)
ii.Ecological risks
iii.Cultural resources and values, including those related to visibility.
d. EPA and each tribe receiving funding to conduct monitoring should reach
a clear understanding, before operations commence, of the duration of the
funding or the timing and process for future decisions regarding
continuation of the funding. There needs to be periodic re-evaluation of
the need for and value of ongoing monitoring, for example on a three- to
five-year cycle.
e. EPA should support tribal capacity building, for example, by helping to
develop the capabilities of tribal staff. Contractor support may be
necessary and appropriate in some situations, but generally is not the
preferred approach to carrying out monitoring. In the area of ambient
monitoring, capability includes development of monitoring objectives,
development of quality assurance plans, installation and operation of the
monitors, execution of quality assurance plans, data handling, and
understanding the implications of the observed ambient concentrations.
EPA should seek to allow a tribe sufficient support and opportunity to
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progress through these stages.
f. EPA has limited resources in its enacted budget to help pay for tribal air
quality management in general. EPA is therefore unable to support all
monitoring in Indian country that may have value to the affected tribes.
g. There needs to be consistency/fairness across tribes, but also flexibility to
hear and if appropriate to address unusual or unexpected tribe-specific
situations.
h. Decisions affecting specific tribes should be made at a level where
individual situations can be appreciated.
i. EPA should encourage all parties to take advantage of all available data on
ambient air quality where technically relevant. Operating monitors may
provide useful information on air quality some distance from their location
and information on transport into and out of state and tribal lands.
j. Tribes should have equal opportunity to participate in programs that are
not inherently tied to state/tribe distinctions, and to benefit from resources
used to support those programs, where such access is consistent with
program goals.3
k. Grant procedures and grant performance must comply with applicable
laws and regulations.
1. EPA will work with tribes to ensure that there is timely EPA and public
access to data collected with federal funds. EPA will need to explain the
significance and need for this access to tribes generally and to each grant
recipient. EPA should help tribes understand the significance of their data
quickly so tribes are never less aware than others of the data and the data's
implications.
m. This EPA guidance does not limit any tribe's right to monitor for whatever
air pollutants it chooses in its own portion of Indian country.
3 For example, EPA's CASTNet monitoring program is intended to monitor acid deposition across broad
areas for the purposes of broad national objectives. Operation of CASTNet is funded separately from the
state and tribal air grant (STAG) funds. Some CASTNet sites are currently located in Indian country. As
new sites are contemplated, tribal lands in the right areas of the country to support the monitoring goals
should be considered equally with state and federal lands.
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III. Background for Planning Tribal Air Monitoring
Introduction
This section contains background on the Clean Air Act, other relevant laws, regulations,
and policies, and other information that is not specifically about tribal air monitoring. It
is intended to assist tribal professionals who are not already familiar with this material, so
that they can participate more easily and effectively with EPA staff. To save space and
time, this section consists of thumbnail sketches and pointers to other documents for
fuller descriptions. In order to be brief and understandable to tribal professionals
unfamiliar with the history and complexity of air pollution law, policy, history, and
technology, the thumbnail sketches are simplified and do not convey all provision or
nuances. They assist tribal staff in understanding the more detailed references, and in
discussing these topics with EPA specialists and more experienced tribal professionals.
Additional substantial amounts of information concerning (1) the Clean Air Act and
associated EPA rules, (2) government policies, program planning, budgets and grants, (3)
technical issues related to monitoring, emissions inventories and air data, and (4) health-
related topics can be found by working through the following Internet addresses:
Clean Air Act — http://www.epa.gov/air/caa/
Chief Financial Officer (EPA) — http://www.epa.gov/ocfo/index.htm
Tribal Air (EPA/OAR) — http://www.epa.gov/air/tribal/
American Indian Environmental Office (EPA)—
http://www.epa.gov/indian/index.htm
Northern Arizona University — http ://www4.nau. edu/
Technology Transfer Network (EPA/OAR) — http://www.epa.gov/ttn/
A. EPA's Planning and Budgeting
EPA's Strategic Plan serves as the Agency's road map for 5 year periods. The plan is
intended to lay out long-term goals, as well as annual goals that will need to be met along
the way. It helps EPA to measure how far it has come towards achieving goals and to
recognize where approaches or directions need adjustment to achieve better results.
Finally, it provides a basis from which EPA's managers can focus on the highest priority
environmental issues and ensure the best use of resources. Strategic Plans were released
in 1997, 2000 and 2003. A plan for the period 2006 - 2011 is in preparation. A
significant goal of the new plan is to build on recent advances in strengthening joint
regional/state/tribal planning.
The Strategic Plan is supplemented by National Program Manager Guidance and
Regional Plans to accomplish goals associated with individual media, e.g., air, including
guidance on grants. The grant guidance specifically addresses funding for tribes and their
monitoring programs. For each fiscal year (which runs from October through
September), EPA also develops a budget which defines the goals and objectives towards
which the Agency intends to work within the fiscal year and the funding necessary to
accomplish these goals and objectives. The budgeting process includes a summary of
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EPA's budget, an annual performance plan, a Congressional justification, and appropriate
links to congressional funding bills.
Also, under the Government Performance and Results Act (GPRA), an Annual Report
which serves as the Agency's program performance report highlights the Agency's
environmental, programmatic, and financial performance for each fiscal year. Progress in
meeting annual performance goals for which data are available is documented, including
that contributed by tribal partners. Useful Internet links to all of this information
includes:
— http://www.epa.gov/ocfopage/plan/plan.htm
— http://www.epa.gov/ocfo/npmguidance/index.htm
— http://www.epa.gov/cfo/npmguidance/oar/20Q5/oar finalnpmguide.pdf
http://vosemite.epa.gov/R10/AIRPAGE.NSF/283d45bd5bb068e68825650
f0064cdc2/e34950b285534aa988256dfe0063be55/$FILE/The%20TRIBA
L%20AIR%20GRANTS%20FRAMEWQRK%20final.pdf
— http://www.epa.gov/ocfopage/budget/index.htm
— http://www.epa.gov/ocfo/finstatement/apr.htm
B. Relevant CAA provisions
Section 301(d) of the Clean Air Act specifically authorizes EPA to treat Indian tribes as
States under the Act. In turn, the EPA Administrator must promulgate regulations
specifying those provisions of this Act for which it is appropriate to treat Indian tribes as
States. These regulations establish requirements that Indian tribes must meet if they
choose to seek such treatment, and provides for awards of federal financial assistance to
tribes to address air quality problems. A range of related policies and initiatives have
also evolved over time with regard to Indian tribes. In particular, the following
documents are relevant: the EPA Indian Policy, the Tribal Air Rule, and the draft
document "Implementing the Clean Air Act in Indian Country". Associated legislative,
regulatory and policy documentation is provided at the following Internet addresses:
Clean Air Act and Tribes
— http://www.epa.gov/air/tribal/tar.html
— http ://www. epa. gov/air/caa/ caa3 01 .txt
— http://www.epa.gov/fedrgstr/EPA-AIR/1998/Februarv/Dav-
12Za3451.htm
EPA Indian Policy
— http://www.epa.gov/indian/policvintitvs.htm
— http://www.epa.gov/indian/pdfs/indian-policv-leavitt-pr.pdf
Tribal Air Rule
http://vosemite.epa.gov/rlQ/airpage.nsf/16388b0c5db97d0088256b58005f
8de5/94f65e27af63d505882569530077ae73!QpenDocument
Implementing the Clean Air Act in Indian Country
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— http://www.epa.gov/air/tribal/1997Caaimp.pdf
C. The January 27, 2005 Holmstead memo on criteria for award of tribal air
grants
This document set forth criteria for the air program to use when reviewing and assessing
tribal requests for grants under the State and Tribal Assistance Grants (STAG)
appropriation. Two overriding factors and four additional criteria for reviewing and
assessing tribal requests for FY05 STAG grants are identified, including significant air
quality related health concerns and environmental/cultural resource concerns as
overriding factors, plus programmatic commitment and leadership, prior grant
performance, location relative to essential data, and commitment to air quality issues.
The complete document is available at the following Internet address:
— HolmsteadTAG_012705.doc
D. Tribal Environmental Agreements
A template for EPA/Tribal Agreements was prepared to establish "workplans" between
the Regions and Tribes to develop environmental protection in Indian country. The
Agreements should reflect the need for development by partnership, flexibility, and re-
visitation through a common set of principles and consistent factors. The Agreements
should respect the sovereignty and legal status of tribes. These Agreements are a critical
next step to further developing environmental protection in Indian country. To
effectively evaluate the need for Tribal program development in a consistent manner as
well as provide a benchmark against which to measure progress over time, the following
outline has been suggested: Preamble/Introduction, Draft EPA/Tribal Agreement
Template, Purpose for Establishing EPA/Tribal Agreements, Guiding Principles, General
Agreement on Region-wide Tribal Issues, Planning and Budget Cycles, and (Name of
Tribe)/EPA Specific Action Plan. Specifics of tribal agreements can be found at the
following Internet address:
— http://www.epa.gov/indian/agree.htm
E. The existing state/local/other monitoring networks: types, purposes, history,
funding
To preserve and improve the quality of the nation's air, it is necessary to evaluate the
status of the atmosphere as compared to clean air standards and historical information.
Ambient air monitoring programs make such assessments possible. A review of the
various air monitoring networks (e.g., SLAMS, NAMS, PAMS, SPMS, including tribal
monitoring) is provided as part of the National Ambient Air Monitoring Strategy. That
strategy and other relevant information on monitoring networks, including tribal
programs, are provided at the following Internet addresses:
— http://www.epa.gov/ttn/amtic/files/ambient/monitorstrat/allstrat.pdf
— http://www.epa.g0v/0ar/0aqps/qa/m0npr0g.html#Ambient
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— http://www.epa.gov/oar/oaqps/montring.html
— http://www.epa.gov/ttn/amtic/amlinks.html
— http://vista.cira.colostate.edu/improve/Default.htm
— http://www.epa.gov/air/tribal/tribetotribe.html
F. The AMTIC Internet website
The Ambient Monitoring Technology Information Center (AMTIC) Internet website is
operated by EPA's Ambient Air Monitoring Group (AAMG). AMTIC contains
information and files on ambient air quality monitoring programs, details on monitoring
methods, relevant documents and articles, information on air quality trends and
nonattainment areas, federal regulations related to ambient air quality monitoring, as well
as information on monitoring training, contacts and related Internet sites. The AMTIC
Internet address is:
— http://www.epa.gov/ttn/amtic/
G. The draft National Ambient Air Monitoring Strategy and related rulemaking
The overarching goal of the draft National Ambient Air Monitoring Strategy is to
improve the scientific and technical competency of the nation's air monitoring networks
while increasing our ability to protect public and environmental welfare; and to
accomplish this in flexible ways that accommodate future needs in an optimized resource
constrained environment. Objectives in achieving this broad based goal include: manage
the Nation's air monitoring networks, establish a new air monitoring approach, provide a
greater degree of timely public air quality information, improve network efficiencies,
foster the utilization of new measurement method technologies, encourage multi-
pollutant measurements, provide a base air monitoring structure, develop and implement
a major public information and outreach program, seek input from the scientific
community, provide air monitoring platforms and data bases, and assess funding levels
needed to maintain support for this monitoring strategy. The impact of this strategy on
tribal monitoring is also addressed, including operation of monitoring sites by Tribes.
The draft monitoring strategy document (4/24/04) and supporting documents that both
provide a description of the strategy and reflect ongoing components of the strategic plan
development are available at the following Internet addresses:
— http://www.epa.gov/ttn/amtic/monstratdoc.html
— http://www.epa.gov/ttn/amtic/monitor.html
H. QA requirements, example QAPPs, resources for developing QAPPs
EPA uses its Quality System to manage the quality of environmental data collection,
generation, and use; the primary goal is to ensure that data are of sufficient quantity and
quality to support decisions for protecting the public and the environment. The Ambient
Air Monitoring Quality Assurance program applies these principles to air quality data.
This is accomplished through effective communication and cooperation with monitoring
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organizations, which include EPA, State, Local, Tribal agencies, the academic
community and industry. The following QA tools are routinely provided: Guidance
Documents. The National Performance Evaluation Program. Data Quality Assessments
and Reports. Ambient Air Quality Assurance Training, and example QAPP's.
Information on QA requirements and examples of applications are available at the
following Internet addresses:
— http://www.epa.gov/qualitv/index.html
— http://www.epa.gov/airprogm/oar/oaqps/qa/index.html
— http://www.epa. gov/ttn/amtic/qualitv. html
— http://www.epa.gov/ttnamtil/files/ambient/airtox/nattsqapp.pdf
I. Data systems for ambient air measurements (AQS, other)
The Air Quality System (AQS) is EPA's widely used repository of ambient air quality
data. AQS stores data from over 10,000 monitors, 5000 of which are currently active.
State, Local and Tribal agencies collect the data and submit it to AQS on a periodic basis.
A detailed description of AQS, supporting manuals and guides, web-based access,
information on training, and links to other sources of air quality information, including
S/L/T agencies in provided at the following Internet address:
— http://www.epa.gov/ttn/airs/airsaqs/
J. Availability of ITEP and TAMS support
The Internet home page for the Institute for Tribal Environmental Professionals (ITEP)
states that "ITEP was established in 1992 to assist Indian Tribes in the management of
their environmental resources through effective training and educational programs."
The Internet home page for the Tribal Air Monitoring Support Center states that "The
Tribal Air Monitoring (TAMS) Center was created through a partnership between Tribes,
the Institute for Tribal Environmental Professionals and the United States Environmental
Protection Agency. It is the first technical training center designed specifically to meet
the needs of tribes involved in air quality management and offers an array of training and
support services to Tribal air professionals. The TAMS Center mission is to strive to
develop tribal capacity to assess, understand and prevent environmental impacts that
adversely affect health, cultural, and natural resources."
Listings of training programs and services are provided respectively at the following
Internet addresses:
— http ://www4. nau. edu/itep/
— http ://www4. nau. edu/tam s/
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K. Availability and role of "benchmarks" for health and ecosystem effects
Air Quality indicators, concentrations of criteria pollutants relative to the NAAQS,
effects on health due to toxic air pollutants, and other ambient measures such as visibility
and acid deposition, all provide benchmarks of the nation's air quality. The 2003 Report
on the Environment makes extensive use of indicators in assessing the status of health
and ecosystem effects; preparation of a report that reflects 2006 has begun. The Report
on the Environment, and associated information on criteria and toxic air pollutants, is
available at the following Internet addresses:
— http://www.epa.gov/indicators/index.htm
— http://www.epa.gov/indicators/roe/html/roeTOC.htm
— http://www.epa.gov/ttn/naaqs/
— http://www.epa.gov/iris/index.html
— http://www.epa.gov/ttnatw01/hlthef/hapindex.html
— http://www.epa.gov/air/toxicair/index.html
— http://www.epa.gov/air/visibilitv/index.html
— http ://www. epa. gov/airmarkets/cmprpt/arp03/summary. html
L. National Emissions Inventory
The National Emissions Inventory (NEI) is a national data base of air emissions
information with input from numerous State and local air agencies, from tribes, and from
industry. This data base contains information on stationary and mobile sources that emit
criteria air pollutants and their precursors, as well as hazardous air pollutants (HAPS).
The data base includes estimates of annual emissions, by source, of air pollutants in each
area of the country, on an annual basis. Emissions estimates for individual point or major
sources (facilities), as well as county level estimates for area, mobile and other sources,
are available currently for 1990 and 1996 through 1999 for criteria pollutants, and for
1999 for HAPs. A final version of the 2002 NEI will be ready in December 2005.
Four of the six criteria pollutants are included in the NEI data base: CO, NOx, S02, and
PM10 and PM2.5. The NEI also includes emissions of VOC, which are ozone
precursors, emitted from motor vehicle fuel distribution and chemical manufacturing, as
well as other solvent uses. VOCs react with NOx in the atmosphere to form ozone.
Ammonia (NH3) is an additional pollutant included in the NEI. The NEI data base
defines three classes of criteria air pollutant sources, e.g., point, area, and mobile.
Hazardous air pollutants, also known as toxic air pollutants, are those pollutants that are
known or suspected to cause serious health problems. Section 112 of the Clean Air Act
(CAA) currently identifies a list of 188 pollutants as HAPs. The list of HAPs includes
relatively common pollutants such as formaldehyde, chlorine, methanol, and asbestos, as
well as numerous less common substances. The NEI data base includes emission
estimates for the 188 HAPs from stationary major and area sources and mobile sources,
as defined in the Clean Air Act (CAA). The NEI includes three classes of HAP emission
sources: Major, Area and Other, and Mobile.
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More information about the NEI data base and the compilation of criteria pollutant and
HAP emissions inventories, and links to the data base, are available at the following
Internet addresses:
— http://www.epa.gov/ttn/chief/net/index.html
— http://www.epa.gov/ttn/chief/eiinformation.html
M. National Air Toxics Assessment
The National Air Toxics Assessment (NATA) is a national-scale assessment of 33 air
pollutants (a subset of 32 air toxics on the Clean Air Act's list of 188 air toxics plus diesel
particulate matter (diesel PM)). The assessment includes four steps that look at the year
1996:
1. Compiling a national emissions inventory of air toxics emissions from outdoor
sources.
2. Estimating ambient concentrations of air toxics across the contiguous United
States.
3. Estimating population exposures across the contiguous United States.
4. Characterizing potential public health risk due to inhalation of air toxics including
both cancer and non-cancer effects.
The goal of the national-scale assessment is to identify those air toxics which are of
greatest potential concern, in terms of contribution to population risk. The results will be
used to set priorities for the collection of additional air toxics data (e.g., emissions data
and ambient monitoring data). Note: As of May 2002, the results posted for all four steps
include revisions based on input from scientific peer review. Results are available at the
following Internet address:
— http://www.epa. gov/ttn/atw/nata/
N. Air quality modeling methods and tools, in particular how they may be able
to give insight into air quality in Indian country when ambient monitoring is not
available
There are three types of air quality models: dispersion, photochemical, and receptor
models used in assessing control strategies and source impacts. Source code and
associated user's guides and documentation are routinely provided for
preferred/recommended models, screening models, and alternative models. In addition,
guidance if provided for applying air quality models for regulatory applications for both
State Implementation Plans (SIP) demonstrations and revisions, as well as permit
applications for new source reviews, including Prevention of Significant Deterioration
(PSD) regulations. These latter applications are particularly relevant for estimating air
quality impacts in Indian country. Also available is the Model Clearinghouse which is
designed to help record the interpretation of modeling guidance for specific regulatory
applications. Modeling contacts within the EPA Regional Offices and State
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environmental agencies are available. Detailed information on models, codes and
guidance in their use is available at the following Internet addresses:
— http://www.epa. gov/ttn/ scram/
— http://www.epa.gov/scram001/tt22.htm
— http://www.epa.gov/scram001/tt25.htm
O. Indoor air issues including radon and mold
Radon and mold can both be problems in indoor environments. Radon is odorless and
tasteless, but may exist at ambient air levels that exceed safe limits in homes. Air
containing radon that is breathed indoors is the second leading cause of lung cancer in the
United States today. Likewise, molds are part of the natural environment and are
produced by means of tiny spores. Mold may begin growing indoors when mold spores
land on surfaces that are wet. Molds can gradually destroy the things they grow on, but
damage to homes and furnishings can be prevented and potential health problems avoided
by controlling moisture and eliminating mold growth. Internet addresses with additional
information on radon and mold, associated effects, and mitigation strategies are available
at the following Internet addresses:
— http://www.epa.gov/iaq/index.html
— http://www.epa.gov/mold/index.html
— http://www.epa.gov/radon/index.html
— http://www.epa.gov/iaq/atozindex.html
P. The New Source Review and PSD programs and their relationship to
monitoring needs
The New Source Review (NSR) permitting program applies to new major stationary
sources and major modifications locating in areas designated as nonattainment for the
NAAQS. The Prevention of Significant Deterioration (PSD) permitting program applies
to new major stationary sources and major modifications locating in areas designated as
attainment or unclassifiable for the NAAQS. These programs generally require the
permit applicant to conduct a source impact analysis, using monitored data and air quality
models. For the NSR program, the impact analysis must demonstrate that the new or
modified source will not cause or contribute to a violation of state or national air quality
standards or cause an adverse impact to visibility in any federal Class I area. The PSD
program is generally designed to provide a more comprehensive source impact analysis
than the NSR program, including effect on air quality related values, e.g., visibility, that
have been identified for Class I areas. NSR/PSD and the use of air monitoring data in
source impact analyses to identify existing (representative) conditions and potential
future impacts are addressed at the following Internet addresses:
— http://www.epa.gov/nsr/
— http://www.epa.gov/ttn/amtic/files/ambient/criteria/reldocs/4-87-0Q7.pdf
— http://www.epa.gov/ttnamtil/files/ambient/visible/r-99-0Q3.pdf
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Q. Clean Air Act section 110(a)(2)(D) - the interstate transport provision that
also addresses transport between states and tribes.
Section 110(a)(2)(D) is the provision of the Clean Air Act that requires EPA to ensure
that each state's SIP prevents emissions from that state contributing significantly to
nonattainment in another state. So far, EPA has used this section twice to require states
to control their emissions because of effects on nonattainment in other states, in the NOx
SIP Call rule and the Clean Air Interstate Rule. A section of the Clean Air Interstate Rule
preamble discussed the tribal issues of that particular action.
Tribes can be treated as if they were states under this provision, both as upwind
contributors and as downwind receptors of air pollution, but as of the date of this
document no such tribe has actually been officially treated in this way. In concept, this
section can apply between a tribe and the state within which it is located, not just other
states. A downwind tribe would need to be experiencing nonattainment with a NAAQS
for this provision to be used to seek emission reductions from the upwind state or states;
to date, only monitoring data has been used as evidence of such nonattainment in the two
cases in which EPA has applied this section to states. The details of Section 110 and
applications in national rules are available at the following Internet address:
— http://www.epa.gov/oar/caa/caallO.txt
— http: //www, epa. gov/ttn/naaq s/ozone/rto/rto. html
— http: //www, epa. gov/C AIR/index. html
R. The GAP program
Under its Indian Policy, Presidential Memorandum and Executive Orders, EPA works
with Tribal governments on a government-to-government basis and recognizes Tribes as
the primary parties for making environmental policy decisions and carrying out program
responsibilities affecting Indian reservations, their environments, and the health and
welfare of the reservation populace. One tool that EPA has to assist Tribes in developing
Tribal environmental protection programs is the General Assistance Program (GAP).
"Guidelines on the Award and Management of General Assistance Agreements for Indian
Tribes" provide the national policy guidelines and criteria for the award and
administration of GAP grants. They reflect statutory and regulatory requirements and, in
some instances, establish new binding requirements that have not been announced
previously. The EPA Regions may provide supplemental guidelines and establish
Regional priorities and criteria that are consistent with relevant statutes, regulations and
this document. The complete document is available at the following Internet address:
— http://www.epa.gov/indian/pdfs/gap200Q.pdf
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S. Visibility provisions of the Clean Air Act, mandatory and non-mandatory
Class I areas
Section 162 of the Clean Air Act designates international parks, national wilderness
areas, national memorial parks, and national parks greater than a certain size to be Class I
areas. Sections 169A and 169B declare as a national goal the prevention of any future,
and the remedying of any existing, impairment of visibility in such areas where
impairment results from manmade air pollution. A study and report to Congress on
available methods for implementing this national goal is authorized and is to be
accompanied by recommendations for monitoring, modeling and preventing/remedying
manmade pollution and resulting visibility impairment. Regulations are to be
promulgated to assure reasonable progress toward meeting the national goal and
compliance with the requirements of these sections. An assessment and evaluation that
identifies, to the extent possible, sources and source regions of visibility impairment
including natural sources as well as source regions of clear air for class I areas is to be
made within 3 years after enactment of the Clean Air Act Amendments of 1990.
Establishment of Visibility Transport Regions and Commissions is authorized for
assessing the scientific and technical data, pertaining to adverse impacts on visibility
from potential or projected growth in emissions from sources located in the Visibility
Transport Region and recommend measures that should be taken under the Clean Air Act
to remedy such adverse impacts. Relevant sections of the CAA, reports on visibility, and
information on the regional haze program and on Regional Planning Organizations can be
found at the following Internet addresses:
— http://www.epa.gov/air/caa/caal62.txt
— http://www.epa.gov/air/caa/caal69A.txt
— http://www.epa.gov/air/caa/caal69B.txt
— http://www.epa.gov/air/visibilitv/index.html
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IV. Tribal Air Quality Issues, Relevant Air Monitoring Air Monitoring and
Tribal Air Monitoring Activities
This section will examine the reasons for tribal air quality monitoring and provide
examples of current tribal air monitoring.
Section 301 (d) of the 1990 Clean Air Act Amendments provides federally recognized
tribal governments the authority to implement Clean Air Act programs for their
reservations and other land that they can demonstrate jurisdiction. The Tribal Authority
Rule (TAR) promulgated on February 12, 1998, further delineates the authority of tribes
to implement air quality programs under the Act.
Tribes may need to conduct ambient air monitoring for a variety of reasons which include
the following: (1) attainment with health and welfare based National Ambient Air
Quality Standards (NAAQS); (2) impairment of visibility and biological diversity for
vistas within or near reservations; (3) measurement of toxic air pollutants for health and
ecological effects; (4) collection of near-real time data for reporting Air Quality Index
(AQI) to the tribal community and to EPA's AIRNOW real-time mapping program, (5)
monitoring air quality related to tribal environmental and cultural resource concerns, (6)
being part of a Regional/State monitoring network (7) for determining air quality
background levels and establishing air quality baselines and (8) to increase awareness
that indoor environments play a large, if not the largest, role in causing the increase in
asthma and respiratory disease.
Tribes have a need to understand the short and long term effects of long distance
transport on tribal lands and the effects of atmospheric deposition on the ecology of their
lands. Tribes also need air monitoring data to identify the role of off-reservation sources
and /or to build a case or partnership for controlling those sources. Examples of these
programs include long term IMPROVE, NADP, MDN, ozone, PM2.5, precursor gas and
toxic air quality monitoring.
The following is a review with examples of how the tribes have conducted air quality
monitoring to provide data: (see appendix?? for more detailed examples of specific air
monitoring)
1. Air monitoring for compliance with health based NAAQSs
Tribes are currently monitoring to demonstrate compliance with national
standards, primarily for ozone and particulate matter, in areas of the country that
are not in compliance with the NAAQSs for these pollutants. The data from these
sites may be used to demonstrate the need to develop a tribal implementation
plan, to show the inadequacies of state or federal implementation plans (or
monitoring networks) or to warn tribal members of unhealthy air quality. Tribes
may also be well located to perform air monitoring that broadens the coverage of
state SIP monitoring networks. For example, several tribes in Regions 1 operate
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ozone and PM2.5 air monitoring sites in areas that the states are unable to
monitor, such as the island of Martha's Vineyard, MA or far eastern ME.
An example of this type of air monitoring is the ozone air quality monitoring
being performed is the Wampanoag Tribe of Gay Head at Aquinnah, MA
(Martha's Vineyard). The tribe is currently operating an air monitoring program
consisting of an ozone monitor, an IMPROVE sampler, and a meteorological
station. The station is located in the Massachusetts non-attainment area in an
area where there is no state air monitoring. In 2005 the station recorded four days
above the 8-hr. ozone NAAQS and provided the tribe with health related air
quality data to inform tribal members. Data from this station will also provide the
tribe with the ability to ensure that ozone air quality standards will be met in the
future.
PM10 monitoring has been on-going in non-attainment areas on Tribal lands in
Montana for many years. The Confederated Salish and Kootenai Tribes and the
Northern Cheyenne Tribes were designated non-attainment for PM10 in 1989.
Ongoing monitoring for PM10 will be required to satisfy compliance with their
respective Tribal Implementation Plans. PM2.5 monitoring was also initiated in
these two areas as a screening tool to ensure compliance with the PM2.5 standard.
2. Impairment of visibility for vistas within or near reservations
Visibility measurements are another important measurement objective for tribal
reservations designated as Federal mandatory Class 1 areas. The CAA
amendments of 1990 set a target of improving visibility in mandatory Class 1
Areas to natural visibility conditions by 2064. Data from these sites will provide
tribes important information to determine the impacts from regional haze on
visual impairment on tribal lands. Examples of visibility measurements on tribal
lands include the operation of IMPROVE monitors by a number of tribes and the
operation of haze-cameras on tribal lands. The Aroostook Band of Micmac
Indians operate both an IMPROVE monitor and a haze camera at their air
monitoring site in Presque Isle Maine. Data from this site is included in the
National IMPROVE web page and the haze camera is included as part of the
NESCAUM haze-cam network. The Assiniboine and Sioux Tribes of the Fort
Peck Indian Reservation in northern Montana also operate an IMPROVE monitor
which they use to monitor the status of their voluntary Class 1 air shed. They, the
Confederated Salish and Kootenai Tribes, and the Northern Cheyenne Tribes
operate IMPROVE samplers that supplement the core IMPROVE network and
provide valuable information on areas that would otherwise lack monitoring
resolution.
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3. Toxic air pollutants for health and ecological effects
Tribes are also monitoring for hazardous air pollutants and/or air toxics. Air
monitoring for these pollutants can either be for short term exposures when there
is a chemical release or for long term community and ecological impacts. Sources
of these pollutants include nearby stationary sources, area sources, mobile
sources, and long distance transport from urban areas. Data from these sites
provide the tribes critical information on hazardous pollutant exposures and
impacts of air toxics on communities and tribal lands through risk analyses
conducted using this monitoring data. Examples of this type of monitoring
include mercury deposition monitoring or the impact of a nearby power plant or
pulp mill. The Nez Perce Tribe of Idaho is currently conducting air toxics
monitoring in the town of Lewiston and on their reservation for toxic emissions
from the Potlatch pulp mill in Lewiston.
4. Monitoring to Support AQI and AIRNow
Some Tribes are operating continuous monitoring for ozone and PM2.5 and
convert these data to the appropriate AQI, based on EPA's AQI concept. This
AQI relates concentration of pollutants to their potential health effects and can be
used to alert a community to unhealthy air quality conditions. Another critical role
for tribal monitoring is being part of the national AIRNOW mapping program.
These sites provide near real-time data quality information and valuable
information to better understand the fate and transport of air pollution.
5. Significant air quality related environmental and cultural resource concerns
One of the most important reasons that tribes are conducting air quality
monitoring is to gather information on the long term air quality effects on the
tribal community and on tribal lands. In many cases tribes use their ancestral
lands for subsistence hunting and fishing, traditional rites, and harvesting native
plants. Tribes are concerned that long term exposures to air pollutants, acid rain,
and heavy metal deposition will adversely affect these resources. It should be
noted that this type of air monitoring requires a long term commitment both in
term of funding and in resources (for operation of equipment and
analyses/assessments of the data). Examples of this type of monitoring include
operating trace level S02, CO and NOy monitors, sulfate, nitrate, metals, and
NADP & MDN samplers and IMPROVE sampler
6. Regional Monitoring
Another critical role for tribal monitoring is being part of a Regional/State
monitoring network. Tribes may be well located to perform air monitoring that
broadens the coverage of state SIP monitoring networks and supports the national
AIRNOW mapping program. Several tribes in Regions 1 operate ozone and
PM2.5 air monitoring sites in areas that the states are unable to monitor, such as
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the island of Martha's Vineyard, MA or far eastern ME. Not only do these sites
provide extended coverage for the regional air monitoring program, but also they
provide improved coverage for EPA's AIRNOW real-time air quality mapping
program. These sites provide valuable information to better understand the fate
and transport of air pollution.
7. Determining Air Quality Background Levels and Establishing Air Quality
Baselines for PSD
In some cases tribes will need to conduct air quality monitoring to determine air
quality background levels or to establish a baseline. This information is important
for the protection of areas with pristine air quality and to provide quantitative data
before new stationary sources are located in or near Indian Country.
8. Indoor Air Quality
The increase in asthma and respiratory disease, and the attempt to discover their
causes has led to an increased awareness that indoor environments play a large, if
not the largest, role in causing this issue. Molds, tobacco smoke, Radon,
improper ventilation, insect infestations, and cooking/heating fires all play a role
in increasing the effects of respiratory distress on effected populations and to a
disproportionate extent, Tribal members. Funding for monitoring projects such as
the Radon monitoring program, Tools for Schools, and others, can be used to
assist in identifying problems and suggest solutions. This information can be
used to act or can influence other mechanisms to assist in remediation of Indoor
Air Quality issues.
9. Source Monitoring
Tribes may need to conduct emission monitoring on their major point sources for
compliance purposes. This may be in the form of stack tests or by conducting
continuous emission monitoring. Normally tribes monitors for particulate, sulfur
dioxide, nitrogen oxides, volatile organic compounds and/or carbon monoxide.
Generally this monitoring is required by a PSD or operating permit.
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V. Implementation of Monitoring
There is a growing movement in the United States of Tribal organizations taking an
increased interest in ambient air quality issues on Tribal lands.
Tribes wishing to examine ambient air quality issues on their reservations or tribal lands
should have a good working strategy in place as they decide what their interests and
concerns are in the development of their work plan and program strategy. Tribal entities
often decide that the best way to assess the current air quality situation is through the use
of ambient air quality monitors. A strategic approach to monitoring should incorporate
specific planning stages.
Initially, a tribe will need to work with their EPA regional contacts to begin development
of a work plan which will be required for EPA operational grant funds and used to
organize the direction of the program. This is especially important in the planning phase
as many of the air monitoring development steps can be incorporated into the work plan
objectives and thus funded by EPA. This also obligates EPA to provide guidance and
technical assistance throughout the whole process.
The tribe should then research a complete list of sources on local, regional and even
national levels depending on the pollutant of interest and type of monitoring
incorporated. A tribe can identify which pollutants are of the greatest concern through
existing methods and tools such as:
• EPA Air Quality System (AQS): A national database that tracks air monitoring
data from state, local, and other entities
• Data from existing programs such as IMPROVE, CASTNET, etc.
• State Emission inventories
• Private industry monitoring data
• Climatology data
In correlation with the data, the type and need of monitoring should also focus on the
category of source. The category of source will determine a great deal of what method of
monitoring should be utilized and if it is worth pursuing. Categories can be broken down
as follows:
• Stationary
o Fixed facilities such as:
o Factories
o Power Plants
o Chemical Process Industries
o Petroleum Refineries
• Area
o Dry Cleaners
o Bakeries
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o Surface Coating Operations
o Home Furnaces
o Crop Burning
• Mobile
o On-Road
¦ Trucks
¦ Buses
¦ Cars
o Off-Road
¦ Farm vehicles
¦ Construction Equipment
¦ Trains
A tribe should take all of this information in to account before deciding to start sampling.
Many tribes often perform their own emission inventory prior to designing a sampling
program which can be incorporated into the EPA grant work plan. Two important
questions should be asked and answered by the tribe about air monitoring before it
begins:
1) Why are we sampling?
2) What is our response or plan if our sampling data indicates unhealthy
conditions?
Once the pollutant parameter has been identified the sampling methodology should be
decided on. The final decision on what type of monitors to used will also focus on many
factors such as cost, accuracy, level of quality assurance, weather conditions, and
conditions at monitoring site (electricity and phone line availability). Ambient air
monitors can be broken down in following two general groups, manual and continuous:
• Manual Samplers
o Time averaged data
o Sampling Media
¦ Filter samples
¦ Cartridges
¦ Canisters
o Analyzed in separate step
• Continuous Samplers
o Instrumental methods
o On-line data
The type of air monitoring sampler to be used should weigh heavily on the monitoring
objectives the tribe has developed concentrating on what they want the data to provide.
Such reasons might be:
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• To determine highest concentrations expected to occur in the area covered by a
monitoring network
• To determine representative concentrations in areas of high population density
• To determine impact on ambient pollution levels of significant source categories
• To determine background concentration levels
This step is a difficult and important one. For example, many tribes are involved in
particulate sampling. They may choose to deploy a couple manual PM2.5 samplers to an
area of their tribal land. This will require a daily operator (or whenver the sampler runs)
to collect the filters to process. This monitor will require electricity. The tribe may
choose a continuous PM2.5 monitor, this will involve using a data logger to record
readings and can be downloaded from a modem to a remote site if phone connections are
available. The tribe may want to become vested in existing national programs for
particulate, such as the IMPROVE and CASTNET, which offer assistance in all areas of
operation, or the tribe may choose to use mini-volume samplers which are more portable
and can be used in a mobile status.
An air monitoring site should be chosen based on what information the tribe wishes to
capture. Monitoring can be performed to capture emissions from a specific source, for
background information, or to gather information on concentrations found near schools
and neighborhoods. Some Reservations are large enough that monitors are needed in
multiple locations.
Once a tribe has identified pollutants of concern and a potential site(s), grant money must
be obtained. A work plan is drafted explaining the need for a monitor and submitted to
the Regional EPA office. Cost information must be collected, both for the monitor and
for ancillary costs. Ancillary costs vary widely with the type of monitor needed and
where it is to be located. These may cover: construction of a monitoring shed or
purchase of a monitoring trailer; installation of electricity and phone service; purchase of
a data logger and chart recorder; lab costs; purchase of calibration devices; spare parts for
monitor; tools for working on the monitor; and shipping costs to the lab. Some monitors
are very complex and must be shipped back to the vendor for servicing, these costs
should be considered. For a complex monitor, vendors often offer to come out and place
the monitor themselves and give a training session, these costs must also be considered.
A dedicated computer or laptop may be purchased for gathering data, analyzing it, and
uploading it to national databases.
A tribe must also consider how audits are to be performed. These services must be
performed by an outside party using separate equipment and may be contracted out.
Costs for these services may be large. A tribe may even consider contracting out the
entire operation of a monitor, although these costs may be prohibitive.
Once a work plan has been approved and grant money is in hand, the tribe must order the
monitor and ancillary equipment and arrange for its placement. All this activity must be
coordinated, along with laboratory analysis. Tribes must also learn how to use the
monitor and write a quality assurance project plan (QAPP) and Standard Operating
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Procedures for its operation. This can be a months-long process. Once the tribe has
finished the QAPP, it is submitted to the Regional Office for approval. Although QAPPs
are supposed to be written and approved before a tribe actually starts collecting data, this
may be unrealistic. It is hard to write a QAPP for a monitor one has never seen, let alone
operated. Although QAPPs may be copied from another tribal or state agency's QAPP,
the operation of the monitor still needs to be understood by the tribal operators. ITEP
courses are available for some types of monitors but not for all, and courses are offered
infrequently. Tribes are also strongly encouraged to collect meteorological data at the
monitoring site. This involves pricing, ordering, installing and operating additional
pieces of equipment.
After data is collected, tribes need to be able to understand what to do with it. ITEP
offers Data Analysis courses where tribes can learn basic statistical techniques used for
demonstrating compliance with National Ambient Air Quality Standards. Data also
needs to be uploaded to the EPA's AQS database. Some tribes put their data on a website
so tribal members can access it on a day-to-day basis.
All of the above considerations need to be addressed if a tribe is to have a successful
monitoring program.
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VI. The Role of Tribal Monitoring In the National Monitoring Strategy
[This section will explain the history, status, and content of the National Ambient Air
Monitoring Strategy and the relationship between it and tribal monitoring programs.]
(to be completed)
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VII. Understanding Monitoring Data and Its Implications
1. Background
There are many approaches to data interpretation ranging from a simple data summary to
complex statistical procedures. The range of possibilities can be overwhelming, but is easily
narrowed by asking a simple question: "Why was monitoring conducted in the first place?" The
appropriate use of monitoring data is intimately linked with the monitoring objective. Assuming
that the monitoring agency has followed the procedures outlined in Section ??, the existing or
proposed monitoring plan has a purpose in mind and steps have been taken to ensure that the final
data product is adequate for its intended purpose.
For example, an agency located in a potential high ozone area may set up an ozone monitor to
gauge attainment of the National Ambient Air Quality Standard (NAAQS). Quality assurance
measures must be put in place to collect reliable data for a 3-year period. If the dataset is found to
meet data quality objectives then it may be used as the basis for NAAQS attainment designation
for the county. If the data are incomplete or otherwise compromised, then an attainment
determination will not be possible.
Similarly, there are data quality requirements for hazardous air pollutant (HAP) monitoring which
is intended for use in exposure assessment and health risk interpretation. It is not uncommon for
an agency to collect ambient HAP data only to discover later that the wrong target compounds
were reported or that detection limits were too high to allow comparing the data against cancer
risk benchmarks. These problems can be minimized by effective planning which identifies the
intended use of monitoring data and delineates specific monitoring quality objectives.
2. Purpose
The main goal of this section is to help Tribal staff achieve their monitoring program objectives
through an effective use of monitoring data. We will give an overview of potential data uses and
provide links to relevant guidance documents and examples. Possible data uses include:
determining attainment of NAAQS for criteria pollutants; characterizing population exposure to
HAPs, also known as "air toxics"; assessing air pollutant trends over time; and attributing source
contribution to air pollution.
Basic data summary and statistical techniques allow the monitoring agency to effectively
communicate project results. These methods are important for a variety of purposes: to inform
Tribal members and others about local air quality; to summarize monitoring results in grant
documentation and the final project report; and to describe prior air quality findings as
justification for new or renewed funding in a grant application.
This section will be useful to an agency that has already collected a dataset and needs help
understanding it. However it may be even more valuable to a program manager who is in the
stages of planning an air quality study as it will provide a clear understanding of what an ambient
monitoring program can do for them and what questions it can answer.
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3.
Recommendations for specific data uses
3.1 Criteria pollutants
Tribal agencies that conduct ambient air quality monitoring most frequently collect data for the
six common pollutants (also referred to as "criteria" pollutants): carbon monoxide (CO), lead
(Pb), nitrogen dioxide (NOx), ozone (03), particulate matter (PM), and sulfur dioxide (S02). PM
falls into two categories: particles smaller than 10 microns in diameter (PMi0) and particles
smaller than 2.5 microns (PM2 5). This section will describe how criteria pollutant monitoring data
may be interpreted and used as part of an air quality management program.
For more information on sources of criteria pollutants, health and environmental effects, efforts
underway to help reduce the pollutant, and other helpful resources, visit:
www. epa. go v/ai r/u rban ai r/6 po 11. h tm 1
3.1.1 NAAQS attainment
EPA has set NAAQS standards for the six criteria pollutants. The NAAQS include both primary
and secondary standards. Primary standards set limits to protect public health, including the
health of "sensitive" populations such as asthmatics, children, and the elderly. Secondary
standards set limits to protect public welfare, including protection against decreased visibility,
damage to animals, crops, vegetation, and buildings. The table below lists the current NAAQS
for criteria pollutants. Units of measure for the standards are parts per million (ppm) by volume,
milligrams per cubic meter of air (mg/m3), and micrograms per cubic meter of air (fig/m3).
Table 1. National Ambient Air Quality Standards
Pollutant Primary
(Standards
Averaging Times Secondary
(Standards
Carbon Monoxide
9 ppm (10
mg/m3)
8-hour1
None
35 ppm
(40 mg/m3)
1-hour1
None
Lead
1.5 (ig/m3 Quarterly Average Same as Primary
Nitrogen Dioxide
0.053 ppm Annual (Arithmetic
(100 (ig/m3) Mean)
Same as Primary
Particulate Matter
(PM )
50 (ig/m3
Annual2 (Arith.
Mean)
Same as Primary
150 ug/m3
24-hour1
Particulate Matter
(PM )
15.0 |_ig/m3
Annual3 (Arith.
Mean)
Same as Primary
65 ug/m3
24-hour4
Ozone
0.08 ppm
8-hour5
Same as Primary
Sulfur Oxides
0.03 ppm
Annual (Arith.
Mean)
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0.14 ppm
24-houi'
3-hour1
0.5 ppm
(1300 ug/m3)
1 Not to be exceeded more than once per year.
2 To attain this standard, the 3-year average of the weighted annual mean PM10 concentration at each monitor within an
area must not exceed 50 ug/m3.
3 To attain this standard, the 3-year average of the weighted annual mean PM2 5 concentrations from single or multiple
community-oriented monitors must not exceed 15.0 ug/m3.
4 To attain this standard, the 3-year average of the 98th percentile of 24-hour concentrations at each population-oriented
monitor within an area must not exceed 65 ug/m3.
5 To attain this standard, the 3-year average of the fourth-highest daily maximum 8-hour average ozone concentrations
measured at each monitor within an area over each year must not exceed 0.08 ppm.
"Designation" is the term EPA use to describe the air quality in a given area for any of the criteria
pollutants. Geographic areas are designated as "attainment" or "nonattainment" based on
ambient air monitoring data collected in that area and reported to the Air Quality System (AQS)
national database. Tribes and States submit recommendations to the EPA as to whether or not an
area is attaining the NAAQS for a criteria pollutant. After working with the Tribal or State
agencies and considering the air quality data, EPA officially designates an area as attainment or
nonattainment. If an area is designated as nonattainment EPA informs the public that the air in the
area is unhealthy to breathe, and states, local and tribal governments must develop and implement
control plans to reduce pollution. A Tribal Implementation Plan (TIP) is a set of regulatory
programs that a tribe can develop and adopt to help attain or maintain national air quality
standards. Once a nonattainment area meets the standards and additional redesignation
requirements in the CAA [Section 107(d)(3)(E)], EPA will designate the areata attainment as a
"maintenance area."
The website listed below provides an unofficial list of Tribes in 8-hour ozone nonattainment areas
as of April 15, 2004. Official nonattainment boundaries are specified in 40 CFR Part 81.
www.epa.gov/ozonedesignations/tribaldesig.htm
Detailed instructions on how to determine attainment status based on ambient monitoring data
may be found in the Code of Federal Regulations (CFR) Title 40 Part 50. The relevant passages
for each criteria pollutant is included as Attachment 1 and may also be accessed on the web at:
http ://ecfr. gpoaccess. sov/c gi/t/text/text-
idx?c=ecfr&sid=el8bc4907fc6d399c035b0bdl25e238b&tpl=/ecfrbrowse/Title40/40cfr50 main 02.tpl
3.1.2 Understanding the Air Quality Index (AQI) and AIRNow
The AQI is an index for reporting daily air quality. It tells how clean or polluted the air is, and
what associated health effects might be a concern for the public. The AQI focuses on health
effects that may be experienced within a few hours or days after breathing polluted air. EPA
calculates the AQI for five of the criteria pollutants: 03, PM, CO, S02, and NOx. The AQI scale
runs from 0 to 500. The higher the AQI value, the greater the level of air pollution and the greater
the health concern. For example, an AQI value of 50 represents good air quality with little
potential to affect public health, while an AQI value over 300 represents hazardous air quality.
An AQI value of 100 generally corresponds to the national air quality standard for the pollutant,
which is the level EPA has set to protect public health. AQI values below 100 are generally
thought of as satisfactory. When AQI values are above 100, air quality is considered to be
unhealthy-at first for certain sensitive groups of people, then for everyone as AQI values get
higher.
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Raw ambient air monitoring data is converted into AQI values using standard formulas developed
by EPA. An AQI value is calculated for each pollutant in an area. The highest AQI value for the
individual pollutants is the AQI value for that day. For example, if a certain date had AQI values
of 90 for ozone and 88 for sulfur dioxide, the AQI value would be 90 for the pollutant ozone on
that day.
The purpose of the AQI is to help the public understand what local air quality means to their
health. To make it easier to understand, the AQI is divided into six categories, each of which
corresponds to a different level of health concern. The six levels of health concern and what they
mean are:
¦ "Good" The AQI value for your community is between 0 and 50. Air quality is
considered satisfactory, and air pollution poses little or no risk.
¦ "Moderate" The AQI for your community is between 51 and 100. Air quality is
acceptable; however, for some pollutants there may be a moderate health concern for a
very small number of people. For example, people who are unusually sensitive to ozone
may experience respiratory symptoms.
¦ "Unhealthy for Sensitive Groups" When AQI values are between 101 and 150,
members of sensitive groups may experience health effects. This means they are likely to
be affected at lower levels than the general public. For example, people with lung disease
are at greater risk from exposure to ozone, while people with either lung disease or heart
disease are at greater risk from exposure to particle pollution. The general public is not
likely to be affected when the AQI is in this range.
¦ "Unhealthy" Everyone may begin to experience health effects when AQI values are
between 151 and 200. Members of sensitive groups may experience more serious health
effects.
¦ "Very Unhealthy" AQI values between 201 and 300 trigger a health alert, meaning
everyone may experience more serious health effects.
¦ "Hazardous" AQI values over 300 trigger health warnings of emergency conditions.
The entire population is more likely to be affected.
The AIRNow Web site delivers daily AQI forecasts as well as real-time AQI conditions for over
300 cities across the United States. The EPA developed the AIRNow program together with the
National Oceanic and Atmospheric Administration (NOAA), National Park Service (NPS),
Tribal, State, and Local agencies to provide the public with easy access to national air quality
information. AQI data are presented in maps which were generated based on "real-time"
ambient monitoring data using either federal reference or equivalent monitoring techniques or
techniques approved by the state, local or tribal monitoring agencies. Although some preliminary
data quality assessments are performed, the data as such are not fully verified and validated
through the quality assurance procedures monitoring organizations use to officially submit and
certify data in AQS. Therefore, data are used on the AIRNow Web site only for the purpose of
reporting the AQI. Information on the AIRNow web site is not used to formulate or support
regulation, guidance or any other Agency decision or position.
In 2005 there were 13 Tribal monitoring agencies that participated in AIRNow. Tribes interested
in joining the AIRNow network should contact Richard Wayland (OAQPS) at 919-541-4603 or
email: wavland.richard@,epa.gov.
Air quality forecasts and more information about AQI and AIRNow is available at:
www. airnow. gov
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3.1.3 Putting data into context
In addition to determining NAAQS attainment and AQI values, Tribal monitoring agencies may
benefit from putting their monitoring data into a broader context. There are a few ways to do this.
The Tribe may look up data for the same pollutant at other monitoring sites located in the same
State or region to see how the values compare. It may also be helpful to look at a nation-wide
summary of data or a list of nonattainment areas. A broader context may also be obtained by
learning about national trends in air quality data.
EPA's AirData website provides access to air pollution data for the entire US. AirData produces
reports and maps of air pollution data based on user-specified queries. For example a Tribal
agency located in Arizona may wish to look up last year's ozone data for all monitoring sites in
the State. The link below is the interface where the user selects the geographic area for the data
search. Subsequent web pages narrow the search to the desired pollutant, year, and report format.
http: //www .epa. go v/ai r/data/ geosel .html
EPA's "Green Book" lists all nonattainment areas in the US. The user can access a variety of
maps and reports for each criteria pollutant at this web site:
http://www.epa.gov/air/oaqps/greenbk/
EPA tracks air pollution trends using two main indicators: ambient air monitoring data and
pollutant emissions. EPA estimates nationwide emissions of criteria pollutants and air toxics
based on many factors, including actual measurements, levels of industrial activity, fuel
consumption, vehicles miles traveled, and other estimates of activities that cause pollution.
For EPA's most recent evaluation of air pollution trends, click on the following:
http: //www .epa. gov/airtrends/
3.2 Air quality characterization for ambient, deposition, and visibility data
The previous section was focused specifically on criteria pollutants and interpreting data in terms
of the NAAQS rules. Beyond the six criteria pollutants, however, there are hundreds of other
pollutants and indices that a monitoring agency may wish to address. These non-criteria
pollutants and measures include ambient air toxics, wet/dry deposition, visibility data, and even
biomonitoring of ozone injury to sensitive plants. These types of data do not have corresponding
national air quality standards that help to guide data summary and interpretation. Instead,
monitoring results should be described using basic summary statistics. The data may also be
visualized using simple graphic techniques.
3.2.1 Basic summary statistics
The first step in summarizing air quality data is to take inventory of the number of samples
collected, the range of measurements, and to provide related information about the monitoring
schedule. It is important to specify the measurement units of the pollutant. If any of the samples
are below detection limits then it becomes necessary to state the minimum detection limit (MDL)
and the number of samples below the MDL. An example in table form is shown below.
34
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Table 2. Example of monitoring data summary
Pollutant
Sampling
Sampling
Total
Unit
MDL
Min.
Max.
Number
schedule
period
samples
value
value
samples
-------
Formulas for measuring central tendency:
Let X1r X,,X,, represent the n data points.
Sample Mea- The sample mean x is the sum of al the data points divided by the total number of data
ooints tm
— 1 8
x= I
n 1
Sample Median: The sample median (X> is the center of the data when the measurements are ranked in
order from smallest to largest. To compute the sample median, list the data from smallest: to largest and
label these points X,, „ X,;2:„ . . ., X(„, (so that X,,, is the smallest, X:2) is the second smallest, and X,„, is
the largest).
If the number of data points is odd, then X = j,,}
X „ +2',
If the number of data points is even, then X = —SS —
2
Relative Standing (Percentiles)
It may be useful to know the relative position of one or several observations in relation to all of
the observations. Percentiles are one such measure of relative standing that may also be useful for
summarizing data. A percentile is the data value that is greater than or equal to a given percentage
of the data values. For example the data point which is the 25 th percentile is greater than or equal
to 25% of the data values and is less than or equal to 75%. Important percentiles usually
reviewed are the quartiles of the data: the 25th, 50th, and 75th percentiles. The 50th percentile is
also called the sample median (previously described), and the 25th and 75th percentiles are used to
estimate the dispersion of a data set (next section).
Formula for calculating percentiles with example:
Let X X. , X. represent the n data sera. To commits the p* perce.ttLe. y;p t f rst list tne eata frcir
snalest tc largest and laoel these ooints X,, . X . .. . Xr. iso that X is the smallest. X . s the
second sn?]lei3t a-d X . is the largest). Let t = d,'". DC. a no nultoly the sample size n fcy t Diviee the
resJt rto She -nteger part aid re fractional oart i e , let nt = j + g where; is fe rteger part and g is the
fraction pal Then the p* perce~tle. yipi, s calculated by.
If 3 = 0, yCpl- = (Xl]:i + X,,*, :,)»'2
otherwise, y(p) =
E-a'nsj'le The 'SO1, and Ij:'" cercenti e will he computed for the following 10 data points (ordered frcn
snalesf 'o Ltigesh 4 4 4 5,5 e 7 7, 8 and 13 ppli
For the 95tr pereent'le, t = p/1 DO = 95/100= .95 and nt = (1Q)(.95) = 9.5 = 9* - Therefore j = 9 and
£ = .5. Because g = 5-0 ycif; = XtJ,„ = X,.,, = X,Wl = 10 ppm. Therefore 10 fpn s the 95*
percenti e o* the above data
Measures of Dispersion
Measures of central tendency are more meaningful if accompanied by information on how the
data spread out from the center. Measures of dispersion in a data set include the range, variance,
sample standard deviation, coefficient of variation, and the interquartile range. These measures
are all described below and formulas provided.
The easiest measure of dispersion to compute is the sample range. For small samples, the range
is easy to interpret and may adequately represent the dispersion of the data. For large samples,
36
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the range is not very informative because it only considers (and therefore is greatly influenced)
by extreme values.
The sample variance measures the dispersion from the mean of a data set. A large sample
variance implies that there is a large spread among the data so that the data are not clustered
around the mean. A small sample variance implies that there is little spread among the data so
that most of the data are near the mean. The sample variance is affected by extreme values and by
a large number of nondetects. The sample standard deviation is the square root of the sample
variance and has the same unit of measure as the data.
The coefficient of variation (CV) is a unitless measure that allows the comparison of
dispersion across several sets of data. The CV is often used in environmental applications
because variability (expressed as a standard deviation) is often proportional to the mean.
When extreme values are present, the interquartile range may be more representative of the
dispersion of the data than the standard deviation. This statistical quantity does not depend on
extreme values and is therefore useful when the data include a large number of nondetects.
Formulas for calculating measures of dispersion:
Let X,, X-,,X,„ represent fie n data, points..
Sample Rarce Tie sample range (R| is tie difference between the largest value and the smallest value
of the sampie. e , R. = maximum - minimum.
San.pie ' 'a larce: To compute the sample variance (s2), compute:
Vv; - VA-r
s* = ^
11-1
Sample Standard Deviation: The sample standard deviation {s} is the square root of the sample
variance, i.e.,
5 = JP
Coefficient of Variation: The coefficient of variation (CV) is Hie standard deviation divided, by the sample
mean (Section 2.2.2), i.e., CV = a.' S... The CV is often expressed as a percentage.
Interquartile Range: Use the directions in Section 2.2.1 to compute the 25* and 75* percentiles of the
data (¥(25) and y(75) respectively). 'The interquartile range (ICR) is 9m difference between these values,
IQR = y{75} - yp5).
3.2.2 Trends analysis
To be written
3.2.3 Data visualization
Simple graphing techniques are useful to describe the dataset and communicate monitoring
results. Graphs can be used to identify patterns and trends in the data. Graphical representations
include displays of individual data points, statistical quantities, temporal data, spatial data, and
two or more variables.
37
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Detailed instructions on how to produce these graphics are provided in Section 2 of the
previously mentioned "Guidance for Data Quality Assessment - Practical Methods for Data
Analysis", available at: http://www.epa.gov/qualitv/qs-docs/g9-final.pdf
Histogram/Frequency Plots
Two of the oldest methods for summarizing data distributions are the frequency plot and the
histogram. Both the histogram and the frequency plot use the same basic principles to display the
data: dividing the data range into units, counting the number of points within the units, and
displaying the data as the height or area within a bar graph.
Figure 1. Example of a frequency plot
Box and Whisker Plot
A box and whisker plot or box plot is a schematic diagram useful for visualizing important
statistical quantities of the data. A box and whiskers plot is composed of a central box divided by
a line and two lines extending out from the box called whiskers. The length of the central box
indicates the spread of the bulk of the data (the central 50%) while the length of the whiskers
show how stretched the tails of the distribution are. The sample median is displayed as a line
through the box and the sample mean is displayed using a '+' sign. Any unusually small or large
data points are displayed by a ' *' on the plot.
Figure 2. Example of a box and whisker plot
+
Scatter Plot
For data sets consisting of paired observations where two or more variables are measured for each
sampling point, a scatter plot is one of the most powerful tools for analyzing the relationship
between two or more variables. A scatter plot clearly shows the relationship between two
variables. Both potential outliers from a single variable and potential outliers from the paired
variables may be identified on this plot. A scatter plot also displays the correlation between the
38
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two variables. Scatter plots of highly linearly correlated variables cluster compactly around a
straight line.
Figure 3. Example of a scatter plot
Time Plot
One of the simplest plots to generate that provides a large amount of information is a time plot. A
time plot is a plot of the data over time. This plot makes it easy to identify large-scale and small-
scale trends overtime. Small-scale trends show up on a time plot as fluctuations in smaller time
periods. For example, ozone levels over the course of one day typically rise until the afternoon,
then decrease, and this process is repeated every day. An example of a large-scale trend is a
multi-year decrease in air pollution resulting from effective air quality control programs. For
example, the annual average concentration of NOx at a particular monitoring site may decline
over the course of several years as a result of emissions controls at local industries and the
introduction of cleaner cars.
Figure 4. Example of a time plot
20
15
> 10
1
* * 9k
r * m
-* * * i** m 3K m *
* * ** ** * * JS
~ *
* *
* *
* * *** *
10
15
20
25
Time
30
35
40
45
50
39
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3.2.4 References, tools, and resources
There are additional resources for air monitoring staff and data analysts
who would like to learn more about statistical techniques and data analysis.
EPA courses
EPA's Air Pollution Training Institute (APTI) primarily provides technical air pollution training
to state, tribal, and local air pollution professionals, although others may benefit from this
training. The curriculum is available in classroom, telecourse, self-instruction, and web-based
formats. A few potentially useful courses are described below.
Introduction to Environmental Statistics
This series of online lectures was developed for USEPA by the University of Illinois at Chicago
School of Public Health, Environmental and Occupational Health Sciences Division. No
registration is required to access the archived lectures. The lectures are available at this website:
http://www.epa.gov/air/oaqps/eog/envirostats/index.html
Module 1: Interpreting Your Monitoring Data
Mudule 2: Sampling and Analytical Limitations & Sample Detection Limits
Module 3: Quality Assurance Quality Control
Module 4: Analysis of Trends
Module 5: Language of Data Graphing
Module 6: Censored Values and Extreme Values
Module 7: Fundamentals of Trajectory Analysis
Introduction to Environmental Statistics - SI:473B
This course introduces the student to the basic concepts of statistical analysis. The course was
designed for students with little formal education in statistics who must apply statistical
techniques to analyze environmental data. The package has seven modules, a workbook, and a
VHS format video tape. The workbook and video tape are mailed to the student by EPA, but it is
necessary to acquire one of the recommended companion texts.
Course information is available at:
http://www.epa.sov/air/oaqps/eos/catalos/si473b.html
Major Topics
• Descriptive statistics
• Hypothesis testing
• One- and two-sample t-tests of significant differences
• Analysis of variance
• Chi-square techniques for tests of homogeneity of data sets
• Decision flow chart
• Quality control charts
• Guide to statistical problem solving
40
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Training Courses on Quality Assurance and Quality Control Activities
EPA Quality Staff develops a variety of traditional training courses on quality assurance (QA)
and quality control (QC) activities and the EPA quality system. For each course, there is a
facilitator guide with slides and speaker notes, suggested activities, and supplementary materials
for student handouts. Instructors should have an applied knowledge in quality system
management, as well as quality assurance and quality control activities.
One subject area of particular interest is "Interpreting monitoring data". This half day course
teaches participants how to deal with monitoring data using statistics. Participants learn about the
need to incorporate systematic planning into monitoring activities, realize the importance of
representativeness, be able to graphically view the data, and gain an insight into the complexities
of statistical analyses of monitoring data. "Introduction to Data Quality Assessment" is another
useful subject area. This one-day course demonstrates how to perform a data quality assessment
(DQA) to evaluate data and provides detailed information on graphical and statistical tools. This
course will familiarize participants with the process for performing a data quality assessment. It
does not involve detailed instructions on the statistics involved in the process. The course is
intended for managers or analysts that either use (analyze) data themselves or review the use of
data by others. Materials are available at: http://www.epa.gov/qualitv/trcourse .html
Other tools and resources
EPA has a website for Quality-Related Resources which contains links to other sources of
information on quality systems available on the web:
http: //www .epa. gov/qualitv/qa links .html
Examples of tools and resources available through the EPA quality resources page:
DataPlot - National Institutes of Science and Technology
DataPlot is a free, public-domain, multi-platform software system for scientific
visualization, statistical analysis, and non-linear modeling.
www.itl.nist.gov/div898/software/dataplot.html/
StatPages.Net - John C. Pezzullo
Contains links to online calculators, free statistical software, online statistics books,
tutorials, and related resources.
members.aol.com/iohnp71/iavastat.html
Statistics Calculators - UCLA Department of Statistics
Calculators include statistical graphs, power calculations, sample size calculations,
etc.
calculators.stat.ucla.edu/
George Mason University - Guide to Statistical Software
A comparison of commercially available statistical software.
www.galaxv.gmu.edu/papers/astrl.html
3.3 Source apportionment: using tools such as emissions inventories, wind direction
data, and receptor models to determine pollution sources
To be written
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3.4 Exposure assessment for hazardous air pollutants
To be written
3.5 Multi-media exposure assessment using deposition monitoring
To be written
4 Conclusions
To be written
5 Attachment 1. Excerpts from CFR on NAAQS monitoring
03 (8-Hour)
§50.10 National 8-hour primary and secondary ambient air quality standards for ozone.
(a) The level of the national 8-hour primary and secondary ambient air quality standards for
ozone, measured by a reference method based on appendix D to this part and designated in
accordance with part 53 of this chapter, is 0.08 parts per million (ppm), daily maximum 8-hour
average.
(b) The 8-hour primary and secondary ozone ambient air quality standards are met at an ambient
air quality monitoring site when the average of the annual fourth-highest daily maximum 8-hour
average ozone concentration is less than or equal to 0.08 ppm, as determined in accordance with
appendix I to this part.
PM10
§ 50.6 National primary and secondary ambient air quality standards for PMi0.
(a) The level of the national primary and secondary 24-hour ambient air quality standards for
particulate matter is 150 micrograms per cubic meter ((.ig/m 3 ), 24-hour average concentration.
The standards are attained when the expected number of days per calendar year with a 24-hour
average concentration above 150 (ig/m 3 , as determined in accordance with appendix K to this
part, is equal to or less than one.
(b) The level of the national primary and secondary annual standards for particulate matter is 50
micrograms per cubic meter ((.ig/m 3 ), annual arithmetic mean. The standards are attained when
the expected annual arithmetic mean concentration, as determined in accordance with appendix K
to this part, is less than or equal to 50 (ig/m 3 .
(c) For the purpose of determining attainment of the primary and secondary standards, particulate
matter shall be measured in the ambient air as PM10 (particles with an aerodynamic diameter less
than or equal to a nominal 10 micrometers) by:
(1) A reference method based on appendix J and designated in accordance with part 53 of this
chapter, or
(2) An equivalent method designated in accordance with part 53 of this chapter.
pm25
§ 50.7 National primary and secondary ambient air quality standards for PM2.5.
42
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(a) The national primary and secondary ambient air quality standards for particulate matter are
15.0 micrograms per cubic meter (|_ig/m3) annual arithmetic mean concentration, and 65 j^ig/m3
24-hour average concentration measured in the ambient air as PM2.5 (particles with an
aerodynamic diameter less than or equal to a nominal 2.5 micrometers) by either:
(1) A reference method based on appendix L of this part and designated in accordance with part
53 of this chapter; or
(2) An equivalent method designated in accordance with part 53 of this chapter.
(b) The annual primary and secondary PM2.5 standards are met when the annual arithmetic mean
concentration, as determined in accordance with appendix N of this part, is less than or equal to
15.0 micrograms per cubic meter.
(c) The 24-hour primary and secondary PM2.5 standards are met when the 98th
percentile 24-hour concentration, as determined in accordance with appendix N of
this part, is less than or equal to 65 micrograms per cubic meter.
Pb
§ 50.12 National primary and secondary ambient air quality standards for lead.
National primary and secondary ambient air quality standards for lead and its
compounds, measured as elemental lead by a reference method based on appendix G
to this part, or by an equivalent method, are: 1.5 micrograms per cubic meter,
maximum arithmetic mean averaged over a calendar quarter.
no2
40 CFR §50.11 National primary and secondary ambient air quality standards for nitrogen
dioxide.
(a) The level of the national primary ambient air quality standard for nitrogen dioxide is 0.053
parts per million (100 micrograms per cubic meter), annual arithmetic mean concentration.
(b) The level of national secondary ambient air quality standard for nitrogen dioxide is 0.053
parts per million (100 micrograms per cubic meter), annual arithmetic mean concentration.
(c) The levels of the standards shall be measured by:
(1) A reference method based on appendix F and designated in accordance with part 53 of this
chapter, or
(2) An equivalent method designated in accordance with part 53 of this chapter.
(d) The standards are attained when the annual arithmetic mean concentration in a
calendar year is less than or equal to 0.053 ppm, rounded to three decimal places
(fractional parts equal to or greater than 0.0005 ppm must be rounded up). To
demonstrate attainment, an annual mean must be based upon hourly data that are at
least 75 percent complete or upon data derived from manual methods that are at least
75 percent complete for the scheduled sampling days in each calendar quarter.
so2
40 CFR § 50.4 National primary ambient air quality standards for sulfur oxides (sulfur dioxide).
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(a) The level of the annual standard is 0.030 parts per million (ppm), not to be exceeded in a
calendar year. The annual arithmetic mean shall be rounded to three decimal places (fractional
parts equal to or greater than 0.0005 ppm shall be rounded up).
(b) The level of the 24-hour standard is 0.14 parts per million (ppm), not to be exceeded more
than once per calendar year. The 24-hour averages shall be determined from successive
nonoverlapping 24-hour blocks starting at midnight each calendar day and shall be rounded to
two decimal places (fractional parts equal to or greater than 0.005 ppm shall be rounded up).
(c) Sulfur oxides shall be measured in the ambient air as sulfur dioxide by the reference method
described in appendix A to this part or by an equivalent method designated in accordance with
part 53 of this chapter.
(d) To demonstrate attainment, the annual arithmetic mean and the second-highest 24-hour
averages must be based upon hourly data that are at least 75 percent complete in each calendar
quarter. A 24-hour block average shall be considered valid if at least 75 percent of the hourly
averages for the 24-hour period are available. In the event that only 18, 19, 20, 21, 22, or 23
hourly averages are available, the 24-hour block average shall be computed as the sum of the
available hourly averages using 18, 19, etc. as the divisor. If fewer than 18 hourly averages are
available, but the 24-hour average would exceed the level of the standard when zeros are
substituted for the missing values, subject to the rounding rule of paragraph (b) of this section,
then this shall be considered a valid 24-hour average. In this case, the 24-hour block average shall
be computed as the sum of the available hourly averages divided by 24.
CO
40 CFR § 50.8 National primary ambient air quality standards for carbon monoxide.
(a) The national primary ambient air quality standards for carbon monoxide are:
(1) 9 parts per million (10 milligrams per cubic meter) for an 8-hour average concentration not to
be exceeded more than once per year and
(2) 35 parts per million (40 milligrams per cubic meter) for a 1-hour average concentration not to
be exceeded more than once per year.
(b) The levels of carbon monoxide in the ambient air shall be measured by:
(1) A reference method based on appendix C and designated in accordance with part 53 of this
chapter, or
(2) An equivalent method designated in accordance with part 53 of this chapter.
(c) An 8-hour average shall be considered valid if at least 75 percent of the hourly average for the
8-hour period are available. In the event that only six (or seven) hourly averages are available, the
8-hour average shall be computed on the basis of the hours available using six (or seven) as the
divisor.
(d) When summarizing data for comparision with the standards, averages shall be stated to one
decimal place. Comparison of the data with the levels of the standards in parts per million shall be
made in terms of integers with fractional parts of 0.5 or greater rounding up.
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VIII. Storage and Access to Monitoring Data
Problem Statement
Tribes collect environmental data principally for internal use so tribal leaders can make
informed decisions to accomplish their environmental policy objectives. Historically,
EPA has required tribes in some Regions to submit data to the Air Quality System (AQS)
as a deliverable for their Clean Air Act related grants. Not all EPA Regions have
required tribal data to be submittal to AQS. Recently, there has been a push by EPA for
all tribes to submit their data to AQS in all EPA Regions.
Many tribes have argued that forcing them to submit data to AQS is an infringement on
their inherent tribal sovereignty. Others have argued that it isn't stated in the Tribal
Authority Rule that tribal data must be submitted to a national database, and the new
requirement is policy, not law. There is a link between tribal sovereignty and data
collected on tribal lands, and some tribal governments are expressing significant
reluctance to being forced to submit data to national databases, such as AQS. Policy
relating to tribal AQS data submittal should carefully consider tribal concerns and include
dialog with tribal leaders at the highest levels of government.
There is also a "right to know" aspect in U.S. public environmental policy. Both tribal
and non-tribal U.S. citizens live within the tribal environmental jurisdictions as defined
by the Tribal Authority Rule of the Clean Air Act, and policies developed and
implemented within Indian country can also impact neighboring jurisdictions. This
complicates the issue of tribal sovereignty as it relates to public access to environmental
information. This is especially true for environmental data gathered through federal
funding. These are also things that need to be considered.
As previously stated, several tribes currently submit their data to AQS. There are other
tribes that are very open to submitting data to AQS in principal, yet the resources to
accomplish the task are limited. Technical staff within tribal nations are frequently
tasked with multiple duties. This sometimes requires one person to develop and utilize
technical expertise in virtually every aspect of implementing the Clean Air Act within
their jurisdictions. The time they can spend submitting data to AQS is limited. Since this
is an infrequent task, usually only required on a quarterly basis, it can also be a difficult
task to master. New resources to assist with AQS data submittal may be necessary.
Presently there isn't a single person anywhere in the U.S. whose sole job is to assist tribes
with AQS entry.
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A. Description of AQS for Tribal Needs
(to be completed)
B. Getting data into EPA's AQS System
(to be completed)
C. What Data and When Should It Be Entered into AQS
(to be completed)
D. Who Has Access to Data Once Submitted to AQS
(to be completed)
E. How AQS Can Be Used to Retrieve Tribal Monitoring Data in Useful Forms
(to be completed)
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IX. Assessment of Ambient Air Quality in Indian country in the Absence of Air
Monitoring
Prior to conducting air monitoring, Tribes may want to assess air quality in Indian
Country to determine if monitoring is warranted. This section will identify and briefly
discuss web-based and computer models that are available to Tribes to assess air quality
in Indian Country. The methods addressed in this section include:
1. Web-Based Air Quality Data Resources
2. Data Interpolation Methods
3. Local-Scale Plume Models
4. Large-Scale Grid Models
5. Smoke Models
6. High-split Model to identify sources on worst days
X.. How to Request EPA Funding and Other Support
[This section is intended to give the first steps in applying for funding and tips for things
to be careful about. In the early conference calls on this document-writing project, the
point was made that this section may emphasize that it is appropriate for each tribe to
request the resources actually needed to accomplish its monitoring goals, to create a more
complete record regarding the sufficiency of resources made available.]
(to be completed)
XI. Other Air Quality Management Program Elements
[This section is intended to give first steps and other information regarding development
of emissions inventories and source reporting, adoption of source emissions standards,
adoption and operation of permitting programs, etc. for the benefit of tribes that are
considering or are in the early stages of involvement in such programs.]
(to be completed)
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XII. The Tribal Perspective
In 2004, the Environmental Protection Agency produced a final draft document on their
National Ambient Air Monitoring Strategy (NAAMS). (This document should be
reviewed and commented upon by this group). The EPA says interesting and positive
things about the integration of tribes in the national air monitoring strategy document.
EPA had decided originally to do a separate air monitoring strategy for tribes so that
tribes would not get "lost" in the national strategy. This is an important issue.
One of the motivations for tribes to want to monitor the air quality are human health
issues; it is not a scientific interest in this subject. This motivation is not addressed in the
NAAMS. But the NAAMS document must be examined for it has many useful details
that address tribal air monitoring.
It is useful to refer to this document: the National Ambient Air Monitoring Strategy.
Some important points in it are:
EPA's entire air monitoring structure has clearly moved to the Ncore strategy. This
document states that there is a role for tribal participation in several Levels of this
strategy. These Levels are clearly framed in this NAAMS document. And the role of
tribes is clearly stated.
Ambient monitoring systems are a critical part of America's air program infrastructure.
Air data from these monitoring systems are used to do several things, such as:
characterize "air quality" and associated health and ecosystem impacts, to develop
emission strategies to reduce adverse impacts, and to account for air quality progress over
time.
The United States spends well over $200 million annually on routine
ambient air monitoring programs, a figure dwarfed by the billions associated with
emission reduction strategies. The ambient air data provide a basis for an accounting of
an air programs progress. Therefore you can determine the value of those investments.
The Ncore strategy , mentioned in the NAAMS, talks about:
Comprehensive monitors, (55 in rural areas) and Level 3 monitors (1,000 monitors
specifically for local concerns, hotspots, etc). The 2004 EPA Draft Monitoring
Strategy also states that tribes have the right to participate in this Ncore strategy.
Clearly the tribes have a purpose and a right to be involved with this strategy.
In this NAAMS there is fairly clear statement of tribal needs:
"The prevailing air monitoring issues for Tribes include a severe shortage of
resources for equipment, maintenance, operations, personnel and training".
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This Tribal Perspective supports the NAAMS statement of need. The tribes care about
monitoring for human health reasons, not necessarily scientific reasons. And the tribes
need resources for air monitoring on tribal lands.
The NAAMS highlights the fact that the Ncore strategy could benefit from including
tribes because the tribes can provide additional monitoring sites, fill data gaps, and
identify background conditions. These are the reasons how tribal air monitoring could
help the entire strategy. Tribal monitoring can help this air quality infrastructure.
Many tribes are in isolated areas, but are subject to poor downwind air quality. The tribes
want to know the air quality data, and the effects on human health. This is the reason that
many tribes want their own air monitors. Human health issues are of the utmost
importance to tribes (you cannot take care of "Mother Earth" without your own health
being good).
The NAAMS document also acknowledges that the priority for tribes is not just trying to
be useful for the national strategy, but that:
"Monitoring priorities must be based on Tribal decisions, which in many cases
involve developing a better characterization of local exposure to air pollutants."
The NAAMS mentions the benefits of the TAMS center in Las Vegas, NV. This center
for tribal air work is an important tool for the tribes. It helps the tribes in many ways to
deal with their ambient air monitoring.
The NAAMS mentions the RPO's in integrating tribes into larger air monitoring
strategies. The RPO's help tribes and states work on air issues, it brings them together
for work on air monitoring. There must be team work on all levels to preserve air
quality.
The NAAMS document recognizes that tribes will benefit by being able to identify
threats to health. Tribes must be able to deal with air monitoring on tribal lands. Tribes
do not trust the states or the Federal government to do this for them because of past
historical experience. But the basic fact is that the Federal government and the
Environmental Protection Agency have written into its basis, the protection of the tribes.
The original Tribal Monitoring Strategy paper spoke of the Ncore strategy. As outlined
in the Ncore strategy, finding a meaningful way to participate in that strategy is
important. A tribal affiliated group, such as the Institute for Tribal Environmental
Professionals (ITEP), should be identified to do the "representativeness" analysis for all
tribes, in certain regions of the US. Identifying those tribes that is not currently
represented by the Ncore network should be made. These tribes should have access to the
regional air monitoring data to see the status of their air quality. This project should also
be aimed at locating tribes that would serve to fill data gaps, and those that have air
pristine enough to provide background conditions. A perfect example of how this could
be performed is when ITEP worked with the Western Regional Air Partnership (WRAP).
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Below is a template for this process. It discusses how ITEP worked with tribes in the
West to uncover these tribal issues. Perhaps this template could be used over the entire
US:
In 1996, the Grand Canyon Visibility Transport Commission (GCVTC, the
predecessor to WRAP) identified a need for emissions inventories and air
monitoring on and near tribal lands in the Western USA. We need to do this
Nation wide for all tribes. This western US project, funded by the Western
Regional Air Partnership's (WRAP) Tribal Data Development Working Group
(TDDWG), served as a first step in gathering existing information on tribal air
quality in the WRAP region. This is an important template for all of the US. The
purpose of this project was to assess the current state of tribal air quality data and
programs in the WRAP region and to clarify future needs in tribal air quality data
development. The information collected and summarized is meant to inform the
committees on the magnitude of the gap in air quality data over tribal lands, in the
West. It is also meant to provide a starting point for planning future data
development efforts in Indian Country, all over the USA.
Several critical issues were identified through this project, they include:
• A serious limitation on environmental program resources among the
WRAP tribes.
• A high demand for new and continuing tribal air quality programs in the
WRAP region.
• A shortage of tribal staff to deal with air quality issues.
The following will describe how these issues were identified and could be a template for
how this could be accomplished all over the USA.
ITEP was contracted to gather information on tribal air programs in the WRAP region for
this project. ITEP compiled a list of the 237 federally recognized tribes in the WRAP
region, along with environmental and/or air program contacts for each of the tribes. ITEP
attempted to contact 220 of these tribes and 156 tribes completed the assessment
instrument. ITEP staff persons were assigned to make all of the contacts.
One of the critical findings of ITEP's inquiries was a serious limitation on environmental
program resources among the WRAP tribes. This is true all over the US. Information
gathered in 2001, for the western states indicated that only 22% of the 156 tribes it
contacted are currently involved in the WRAP. Of those not currently involved in the
WRAP, 41% indicated that they were not involved due to lack of staff and/or resources.
Twenty-five percent (25%) said that they were not aware of the WRAP prior to the ITEP
phone call. This data suggests a need for a more active outreach program for tribes. This
is true all over the US.
The shortage of tribal staff to deal with air quality issues was apparent in every phase of
the WRAP project. It was difficult to schedule meetings due to tribal staffs full
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schedules. Additional staff in tribal air programs would increase the quality and quantity
of tribal air programs, as well as provide tribal staff with time for informed and
meaningful participation in air monitoring work.
Research also revealed a high demand for new and continuing tribal air quality programs
in the WRAP region, and across the USA. When asked if the tribe had an air program,
38% (60 tribes) said that they did. The other 96 tribes indicated that they did not have an
air program. Planning to meet the demands for tribal air programs should be underway,
not only for these new tribes but for the tribes that have been found to be seriously
understaffed. As more tribes endeavor to assess, monitor and protect their air quality,
additional resources must be identified to support quality tribal air programs.
Many tribes in the WRAP region effect air quality through prescribed burning programs.
One hundred fifty-six (156) tribes were asked if prescribed burning occurred on their
reservation. Approximately half (76) of the tribes responding said that prescribed
burning did occur on their reservation. An additional 14 tribes, who do not currently use
prescribed burns, indicated that they plan to use them in the future. This information
indicates that tribes should play an integral part in regional planning of fire emissions.
Air monitoring is important where use of fire occurs often. This happens on tribal lands,
and monitoring of the air is an important issue for tribes concerned with human health.
This project identified several challenges and opportunities for tribal air quality programs
in the Western USA, and could be used as a template all over the USA.
[The coordinator/authors for this section may choose to convey the tribal perspective by
the use of delineated text blocks within other individual sections as well as including this
section.]
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Appendix A
Examples of Tribal Air Monitoring
Name of Monitoring Project
Tribe
Project Objectives
Pollutants Monitored
Description of the Project (include budget information)
Quality Assurance
Data Analysis/Assessment
Results/Conclusions/Outcomes
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Appendix B
Tribal Air Monitoring Guidance Document
Proposed Revision to Table of Contents
Old § No
I. Background
A.. Purpose and Audience
B. Guidelines Principles for EPA Support for Tribal Air Monitoring
C. Background for Planning Tribal Air Monitoring
II EPA Policy and Strategies regarding tribal air monitoring
A. Tribal Air Quality Issues, Relevant Ambient Air Monitoring, and Current and
Recent Tribal Air Monitoring Activities Directed Towards These Issues
B. The Role of Tribal Monitoring in the National Monitoring Strategy
III Guidance for Tribes on air monitoring issues
A. Implementation of Monitoring (identify all things that need to be done, e.g., Q/A,
siting requirements, report to AQS, etc.)
B. How to Request EPA Funding and Other Support
C. Storage and Access to Monitoring Data
D. Understanding Monitoring Data and Its Implications
E. Assessment of Ambient Air Quality in Indian Country
in the Absence of Air Monitoring
F. Other Air Quality Management Program Elements
IV Tribal Perspective
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Appendix C
Examples of Tribal Air Monitoring
Examples of Tribal Air Monitoring Projects
Name of
Project
Tribe
Project
Objectives
Pollutants
Monitored
Description of
Project/Budget
QA
Plan?
(yes/no)
Location
of Data
Data
Analysis/Assessment
Results/Conclusions/Outcomes
Sioux
Manufacturing
Air Toxics
Monitoring
Project
Spirit Lake
Tribe, Fort
Totten, ND
Measure
ambient air
toxics in
proximity of
manufacturing
plant and
community
VOCs and
Carbonyls
using
UATMP
canisters and
Puf sampler,
met monitor
Yes
EPA reviewed data
that was supplied by
monitoring
completed by Tribe
and analyzed by EPA
contractor, compared
values to IRIS RfC
Monitored HAPs were far
below RfCs for inhalation.
Tribe wishes to conduct follow-
up short-term project after
installation of controls at source.
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