# V. Implementation of Monitoring

There is a growing movement in the United States of Tribal agencies
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 strategy in place as they
develop their work plan and program strategy. Tribal agencies 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 so that
monitoring time and money is spent wisely. Consideration of the
following sections will help Tribes plan and carry out an appropriate
strategy.

A.  **Objectives**

The type of air monitoring sampler to be used should depend heavily on
the monitoring objectives the Tribe has developed concentrating on what
they want the data to provide. Such reasons might include, but are not
limited to:

-   To determine the location and levels of the highest concentrations
    expected to occur in the area covered by a monitoring network
    (potentially to establish official status as
    attainment/non-attainment)

-   To determine concentrations that are representative of longer
    averaging periods or a broader geographic area

-   To assess potential toxic hot spots

-   To assess visibility

-   To ensure protection of PSD increments

-   To determine impact on ambient pollution levels of significant local
    source categories

-   To determine baseline concentration levels (to compare to future
    levels to measure changes and try to determine source of changes)

-   To study pollutant transport issues in order to understand how the
    tribal area is being impacted by upwind sources and what those
    sources are

-   To assess mercury and other persistent bioaccumulative toxics (PBT)
    deposition

-   To develop control strategies

-   To perform model validation

-   To aid in public air quality reporting and forecasting

Four important questions should be considered by the Tribe before
monitoring begins:

1)  Why are we monitoring?

2)  What are we monitoring?

3)  Who in the tribal organization will watch the results as they come
    in, and how?

4)  What could our response or plan be if our monitoring data indicates
    unhealthy conditions?

Tribes need to consider what purpose the data collected will be used
for. Validated, defensible data may be needed for applications such as
attainment/non-attainment designation purposes. If a Tribe wishes to
make such a designation, a Federal Reference Method (FRM) or Federal
Equivalent Method (FEM) monitor must be used for the pollutant of
concern. These are monitors that have specifically been approved by the
EPA to use for assessing compliance with the National Ambient Air
Quality Standards (NAAQS) for that pollutant. If a tribe is not
monitoring to demonstrate compliance, other types of monitors could be
used. For example; the type of PM filter samplers used in the IMPROVE
program, a TEOM-based continuous PM monitor, or passive badge-type ozone
monitors. These types of monitors have not been approved by EPA for
compliance purposes but are still considered to be a viable form of
monitoring. A Tribe might choose one of these unofficial monitors over
an FRM or FEM based on ease of operation, cost, simpler access to
laboratory services, or other reasons.

Tribes should be aware that data collected with federal money, such as
EPA grants, is considered to be in the public domain and EPA's
expectation is that eventually the data will be accessible to the
general public. Data collected during a limited start-up period while a
Tribe is still working out problems can be an exception if agreed to
with the EPA Regional Office. If a Tribe wants to keep data
confidential, it cannot be collected using federal funds.

B.  **Pollutant Selection**

The Tribe should research a complete list of technical information
resources 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, tribal, and other entities

-   Toxic Release Inventory (TRI)

-   Other tribes and tribal consortiums who have their own monitoring
    programs

-   Data from existing programs such as Interagency Monitoring of
    Protected Visual Environments (IMPROVE), Clean Air Status and Trends
    Network (CASTNET), National Atmospheric Deposition Program (NADP),
    etc.

-   State and Tribal Emission inventories (many tribes do their own
    inventory prior to making monitoring decisions)

-   Private industry monitoring data

-   Climatology data

-   Observations from other environmental programs within the same tribe
    (i.e. water quality, forestry, wildlife management)

-   Federal Land Managers

-   Regional Planning Organizations - Central Regional Air Planning
    Association (CENRAP), Western Regional Air Partnership (WRAP),
    Visibility Improvement State and Tribal Association of the Southeast
    (VISTAS), Mid-Atlantic/Northeast Visibility Union (MANE-VU), Midwest
    RPO, etc.)

In correlation with the data, the type and need of monitoring should
also focus on the category of source. The category of source will help
determine what method of monitoring should be utilized and if it is
worth pursuing. Categories can be broken down as follows:

-   Stationary or Point (please see SCC codes for full list)

    -   Factories

    -   Power Plants

    -   Chemical Process Industries

    -   Petroleum Refineries

-   Area (please see AP-42, Chapter 13)

    -   Dry Cleaners

    -   Road Dust

    -   Gas Stations, Auto Body Shops

    -   Woodburning Stoves, Burn Barrels

    -   Crop Burning/Prescribed Burning

-   Mobile (please see AP-42, Chapter xx for full listing)

    -   On-Road

        -   Trucks (Semi tractors/trailers)

        -   Buses

        -   Cars

    -   Off-Road

        -   Farm vehicles

        -   Construction Equipment

        -   Trains

        -   Recreational Vehicles (Boats, ATV's, Snowmobiles, etc.)

Tribes can assess the risks that different pollutants pose by studying
unit risks and reference concentrations. This information is available
on EPA's website (National Center for Environmental Assessment (NCEA) ,
Integrated Risk Information System (IRIS), Technology Transfer Network
-- National-Scale Air Toxics Assessment) . The EPA has its own
assessment group called the Risk Assessment Forum, made up of senior EPA
scientists. This forum "was established to promote Agency-wide consensus
on difficult and controversial risk assessment issues and to ensure that
this consensus is incorporated into appropriate Agency risk assessment
guidance". Tribes should be aware that the scientific understanding of
these pollutants may change over time, as more data becomes available.
Also, different organizations and experts can have different assessments
of these substances. Tribes should make sure they are looking at data
from credible sources.

Tribes that are considering monitoring or that are already conducting
monitoring are encouraged to watch for proposed changes in the NAAQS or
scientific data on health risks with regard to the pollutant of
potential concern. For example, if a NAAQS standard were to be lowered
for PM10 (or any other criteria pollutant that was being monitored for)
because new evidence indicated the adverse health impacts suspected were
no longer an issue, then the tribe would want to re-evaluate the purpose
of the monitoring and consider whether it is still necessary. To keep
abreast of changes in the standards, tribes can use a variety of
sources. Information is often available through the National Tribal Air
Association (NTAA), through EPA outreach efforts, through Regional
Tribal Operations Committees (RTOC), or on EPA's Ambient Monitoring
Technology Information Center (AMTIC) website.

C.  **Monitor Selection**

Once the pollutant parameter (or pollutant wished to monitor for) has
been identified, the sampling methodology should be decided upon. The
final decision on what type of monitor to use will focus on many factors
such as (but not limited to): cost; accuracy; level of tribal monitoring
experience; seasonal conditions; expected program continuity; the need
to monitor for one or multiple pollutants; monitor maintenance/service
requirements; and conditions at monitoring site (electricity and phone
line availability). Ambient air monitors can be broken down into two
general groups, manual and continuous:

-   Manual Samplers

    -   Time averaged data

    -   Sampling Media

        -   Filters, Cartridges, Canisters, Precipitation samples

    -   Analyzed in separate step in a qualified laboratory

    -   Most do not need a shed or trailer, may need shade

-   Continuous Samplers

    -   Instrumental methods (clarify)

    -   On-line data (clarify)

    -   Continuous data stream

    -   Most or all need a shed or trailer

This step is a difficult and important one. For example, many Tribes are
involved in particulate sampling. They may choose to deploy a couple of
manual PM~2.5~ samplers in an area of their Tribal land. This will
require an operator to collect the filters to have them analyzed by a
lab. The Tribe may choose a continuous PM~2.5~ monitor, which will
involve a data logger to record readings and can be downloaded from a
modem to a remote site. However, a continuous monitor may be more
complex and may require a shed or trailer and more maintenance. Or the
Tribe may choose to use mini-volume samplers which are more portable and
can be used in a mobile status but do require laboratory analysis.
Tribes can obtain laboratory services to weigh PM filters from TAMS
without charge, or for a fee (payable from EPA grant funds) from the
IMPROVE program or from national contracts administered by EPA. The
Tribe may want to host monitoring sites in existing national programs,
such as the National Atmospheric Deposition Program/Mercury Deposition
Network (NADP/MDN) and CASTNET, which offer assistance in all areas of
operation. In these program a Tribe would typically contribute staff
time for site operation and maintenance but the national program would
pay for laboratory analysis and/or program costs. Before joining a
national program, the Tribe should make sure that the program is a good
match for the Tribe and that the monitoring objectives of the program
are similar to the Tribe's.

Tribes are strongly encouraged to collect meteorological data at the
monitoring site. Usually a minimal station measures wind speed and
direction, relative humidity, temperature, barometric pressure, and
precipitation, and uses a data logger for gathering and storing data.
This involves purchasing and operating additional pieces of equipment.
There are standard procedures for submitting meteorological data to the
AQS and/or AIRNOW data systems so that the Tribe and others can access
it.

D.  **Siting**

A monitoring site should be chosen based on what information the tribe
wishes to capture and the objectives described in Section A. Some
Reservations are so large that monitors are needed in multiple locations
or a Tribe may wish to place multiple monitors in order to study
transport issues. Multiple monitors for different pollutants may be
placed at the same site, which provides a more robust data set for
understanding what is happening to air quality and why. Needless
redundancy in monitors at one site should, of course, be avoided.

A site should be chosen with consideration for the following concerns.
The site should be in a location where data collection objectives can be
addressed (i.e. close to a school, close to a certain source, rural for
background levels, etc). Each monitor has set criterion for siting to
make sure that it monitors real ambient air. This should be investigated
for each monitor before a purchase or site is decided upon. Most
importantly, monitors need to be situated a certain distance away from
trees or other tall obstructions, such as buildings, and the monitor
probe needs to be situated a certain distance above the ground. The site
should be easily and safely accessible by staff, should allow for
electrical and phone hook-up, or solar power if feasible, and should
minimize opportunities for vandalism. The site should be accessible
year-round, through spring rains and winter snowfalls, and should allow
for location of a shed or trailer, if needed. It is useful for the site
to be accessible by a vehicle carrying equipment and gases needed for
quality assurance audits.

Because many Reservations are located in rural areas, impediments may
exist to running electrical or phone service to site locations. Tribes
are encouraged to look at alternative solutions, such as radio,
satellite, or Internet-based communications systems and generator, wind,
or solar-derived power.

Depending on the type of monitor chosen and the local climate, a
monitoring shed or trailer that is weather-tight,
temperature-controlled, and has adequate space may be needed. If a
trailer is not available, shed kits can be purchased locally. The Tribe
should consider future monitoring needs when arranging for a shelter so
that extra space and adequate power sources are available.

Tribes should consider the timing involved in installing a monitor. For
example, a grant received in late summer may result in monitors being
placed the following spring. Time is needed to receive the grant money,
order the monitor, prepare the site, write the QAPP, contract laboratory
analysis, and learn how to operate the monitor. These steps can take
months and can be slowed by weather conditions.

E.  **Funding**

Once a Tribe has identified pollutants of concern, found a site, and has
chosen a specific monitor funds should be sought. Initially, a Tribe may
choose to work with their EPA regional contacts to begin development of
a work plan, which will be required in order to receive EPA funds and
will be used to organize the direction of the air 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 EPA offers ambient air funding under Sections 103 and 105 of the
Clean Air Act. Section 103 grants are for air program planning and
short-term projects while Section 105 grants are for operating an
ongoing air program and for long-term projects. Section 103 grants have
the advantage of not requiring the Tribe to match any of the federal
funds, while Section 105 grants require a Tribal match of between 5% and
40% of the total amount of the grant. Further information on Tribal
match requirements can be found in Section 10 of this document or 40CFR
§ 35.575 or 40CFR § 49.4{q}. A Tribe should start out with a 103 grant
and can then apply for 105 funding after the air program has been
established. Tribes can also perform some air-related activities under
EPA's General Assistance Program (GAP).

Other funding options are also available to tribes and should be
explored. As more Tribes apply for EPA air grants, competition has
become tighter. In addition, EPA's budget is not growing and may shrink
in the future. This means that tribes may have to look at alternate
funding sources. Creative opportunities can be found for Tribes to link
their interests to those of other organizations. For instance, National
Oceanic an Atmospheric Administration (NOAA) grants could be awarded for
Tribes to obtain meteorological data that is of interest both to NOAA
and the Tribe. A United States Department of Agriculture (USDA) --
Concentrated Animal Feeding Operations (CAFO) grant could be obtained to
fund ammonia monitoring (of interest in regional haze considerations).
Indian Health Services (IHS) may fund monitoring if it is believed that
air emissions are directly causing health problems on the Reservation.
These are just a few suggestions for places where Tribes can look for
funds.

As mentioned in Section A, the desire to keep data confidential may also
lead tribes to pursue other alternatives. Some tribes pay for their
monitoring using tribal funds. Other Tribes have obtained monitoring
money through Regional Planning Organizations (RPOs) to collect
monitoring data beneficial to both the Tribe and the RPO. Some Tribes
work with state agencies to share monitoring costs and responsibilities
and then share the data with the state agency. Some air-related
activities can coincide with other federal grants. For example, a
meteorological station could serve to gather air-quality data and could
also gather data for alternative wind energy feasibility studies under a
Federal Energy Resources Commission grant.

Before any kind of funding request can be made, cost information must be
collected for the monitor and for ancillary costs. Ancillary costs vary
widely with the type of monitor needed and where it will be located.
These may cover: construction of a monitoring shed or purchase of a
monitoring trailer; installation of electricity and phone service (these
costs may be considerable in rural areas); purchase of a data management
system; lab costs; purchase of calibration devices; spare parts for
monitor; tools for working on the monitor; shipping costs to the lab;
and lab services themselves [^1]. If the Tribe is becoming part of a
program, such as IMPROVE, many of these costs will be combined into an
annual program fee. Some monitors and/or calibration equipment are very
complex and must be shipped back to the vendor for servicing, so these
costs should be considered. Vendors often offer services to visit the
site and install more complex monitors and provide training sessions to
Tribal staff. Though this may be costly, the Tribe may want to consider
this option. A dedicated computer, palm, or laptop may be purchased for
downloading data, analyzing it, and uploading it to various databases or
websites.

Tribes may attend training courses to prepare for monitoring. The
Institute for Tribal Environmental Professionals (ITEP) and the Tribal
Air Monitoring Support (TAMS) center offer courses including: air toxics
monitoring; meteorological monitoring; writing a QAPP; dataloggers; air
quality computations; data management; PM monitoring; ozone monitoring;
Tribal Emission Inventory Software Solution (TEISS); and EPA's Air
Quality System (AQS). Tribes should consider which of these courses they
may want to attend and plan for travel costs.

F.  **Quality Assurance/Quality Control**

Depending on the Tribe's objectives (see Part A of this section) the
data obtained must be quality assured to an acceptable level. Data is
useless if the Tribe is unable to show that it was collected properly
(i.e. verifiable and defensible). Data collected for designation
purposes is going to be held to a higher standard than data collected
for informational purposes, however in any case a Quality Assurance
Project Plan (QAPP) and Standard Operating Procedures (SOPs) will be
needed, along with regularly scheduled audits, verifications, and
calibrations.

The most important step in a quality assurance/quality control (QA/QC)
program is learning to operate and service the monitor properly. ITEP
courses are available for some types of monitors but not all. Some
vendors offer regular training courses at their facilities or offer
services to set up the monitor and train the staff for a daily fee plus
travel costs. Neighboring tribes, tribal consortiums, or state or local
agencies may also offer assistance. If a Tribe is a member of an RPO,
arrangements might be made for some training. Federal agencies such as
the Forest Service and Park Service sometimes operate monitors and may
be able to offer assistance.

The Tribe must prepare a QAPP and SOP's for all monitoring activities.
This can be a months-long process, depending on the complexity of the
monitor and the purpose the Tribe will be using the data for. Once the
Tribe has finished writing the QAPP, it is submitted to the Regional
Office for approval. Although QAPPs are supposed to be written and
approved before any data is collected, this may be unrealistic for
tribes. It is hard to write a QAPP for a monitor one has never seen or
operated. Although QAPPs may be copied from another tribal or state
agency, the operation of the monitor still needs to be understood by the
Tribal operators because the operators must follow the QAPP on a daily
basis. Ancillary equipment also needs to be understood for proper
operation and maintenance. Weather instruments, data loggers, electric
surge protectors, and associated computers fall under this category.

The EPA's OAQPS is working with ITEP to develop a generic ambient air
monitoring QAPPs software product. This product is planned to be
available in September of 2006. The EPA is also considering the
implementation of a Quality Assurance certification program in its draft
National Monitoring Strategy. This program would establish a national
accreditation process to certify QA personnel. Although participation
would not be mandatory, the program would help foster consistency in
training and QA requirements across the nation.

Calibrations of all equipment at the monitoring site must also be
scheduled regularly. Calibrations test the monitor's response at a
number of data points and at a zero point. Calibrations are performed
for any of the following reasons (not an exhaustive list): initial
instrument installation; instrument Zero/Precision/Span drift tolerances
are exceeded; maintenance or repairs affect calibration; instrument is
physically relocated; instrument has not been calibrated within 3
months. Calibrations can be performed by Tribal staff and are required
regularly enough that this is the most efficient scenario. A Tribe can
also hire a contractor.

Zero/Span/Precision (ZPS) checks are performed on some continuous
monitors. These instruments are subject to drift and variation in
internal patterns over time as part of their normal operation. The
calibration relationship between what the instrument is reading and the
true value of what it is measuring must be checked periodically through
ZPS checks. These checks are done very routinely and it is probably best
for Tribal staff to learn to perform them. Learning these techniques
will help with learning to do calibrations and general maintenance.
Procedures can be found in the instruction manuals that come with the
monitor or can be copied from other state or tribal agencies.

Field blanks are used to assess contamination that might occur as a
result of inadequate sample container preparation, or contamination that
may occur during shipping or handling in the field. Blanks are used only
for physical samples sent for laboratory analysis.

Tribe must schedule regular audits, which are formal detailed studies of
one or more aspects of a project conducted by independent auditors.
Audits study specific criteria previously determined by the site manager
to be critical to the success of the project and test a monitor's
response to a known input. There are system audits and performance
audits. Performance audits check how far "off" a monitor's response is
from its input and checks the slope of a best-fit line. The system audit
tests the gas standards used for calibrations, spans, and precision
checks; shows that the data pass validity tests concerning completeness,
reasonability, span limits, and precision points; verifies siting
criteria; and ensures that recommendations from previous have been
implemented.

EPA audit guidelines and requirements can be found in guidance documents
for each specific pollutant. Auditing equipment needs to be completely
independent of equipment used for routine calibration and QC checks on
the equipment. Audit criteria should be included in a Tribe's QAPP so
the Tribe can assess when a monitor has passed an audit and when it has
not.

In each EPA Region, EPA employees have designed monitoring trailers and
conduct traveling audits each summer for tribes in those regions
(Regions 1 and 2 share a trailer). Audits can also be performed by other
Tribes, TAMS staff, state agencies, or by contractors. A Tribe may even
consider contracting out the entire operation of a monitor, although
these costs may be prohibitive and contractors may not have the same
dedication or interest for the project as the Tribe. In addition,
learning how to plan, implement, operate and maintain a monitoring
network is often believed to be a crucial part of Tribal
capacity-building.

The EPA also requires Tribes to write Quality Management Plans (QMP's),
which cover the operation of an entire office. The EPA looks at a
Tribe's QMP along with its QAPP's when awarding funds.

G.  **Data Management**

During and after the data collection process, Tribes need to handle the
data they produce. Continuous monitors collect large volumes of data
that need to be recorded as it is generated. Data from all types of
monitors needs to be stored until it can be reviewed and quality
assured. Once the data is quality assured, it needs to be corrected,
flagged as necessary, and placed in a repository where other interested
parties can view it. Since this document contains an entire section
(Section VIII) devoted to data storage and access, we will offer only a
short synopsis here.

ITEP offers Data Analysis courses where Tribes can learn basic
statistical techniques used for demonstrating compliance with the NAAQS.
Certain data needs to be uploaded to the EPA's AQS or AIRNOW databases
if funded with EPA grants. Some Tribes place their data on a website so
Tribal members can access it on a day-to-day basis. A number of tribes
work with state agencies or RPO's and offer their data on those
agencies' websites.

**Refer to the independent multi-tribe real time data system that is
similar to Texas's. Tim Hanley can describe it???**

Part of data management involves site and instrument logbooks where
information and results are recorded manually. A site logbook should be
kept to detail maintenance activities, problems at the site and how
these problems were corrected. For example, power outages and equipment
failures need to be noted. In addition to a site logbook, a separate
logbook should be kept for each individual monitor to record the results
of calibrations and other procedures. Logbooks serve as the
"institutional memory" of a site or monitor and can help staff members
remember when a specific problem occurred and how it was addressed.

H.  **Data Access**

One goal of collecting monitoring data is to allow the general
population to see monitoring data as soon as it is processed and
quality-assured. Sensitive individuals can then choose to limit their
physical activity if pollution levels are high. Data can be useful to
other groups who are studying air pollution for scientific or
policy-setting purposes. All data gathered using federal funds should to
be sent to the EPA so it can be included in national databases. Some
tribes also choose to use their own website to make data available to
their constituents. Other tribes work with other agencies or contractors
to disseminate their data.

**Refer to the independent multi-tribe real time data system that is
similar to Texas's. Tim Hanley can describe it???**

[^1]: For example, the cost of lab and shipping services for an IMPROVE
    protocol site is \$33,000 per year.