Date of This Revision

Quality Assurance Project Plan

Tribe’ s Name 2011 Level 2 Emissions Inventory

Prepared in month, year QAPP title Revision: 0 Date of this revision: Pg. 2 of19 Quality Assurance Project Plan

For the Tribe’ s Name 2011 Level 2 Emissions Inventory

Tribe’ s Name Environmental Protection Department 1.0 Approval and Distribution (A1)

The following signatures attest to these peoples’ personal review and approval of the requirements listed in this QAPP for the 2011 Level 2 Emissions Inventory. This QAPP will be reviewed and approved by all applicable technical and management staff. Copies of this QAPP, including revisions, will be provided to the signatories and others as described in section 3.

Plan Prepared By: ______Date:______Name, Plan Writer/Inventory Development Manager/Title from below

Tribe’ s Official Titles/Names Concurrence:

______Date: ______Name, email, Environmental Protection Department Director

______Date: ______Name, email, Air Program Manager

______Date: ______Name, email, QA Reviewer

______Date: ______Name, email, Title

Grantor’ s Agency/Name Concurrence: ______Date: ______Name, email, EPA Regional Project Officer, or as appropriate after you consult EPA (it may be that the policy is for the EPA regional QA official to sign also)

______Date: ______

2 QAPP title Revision: 0 Date of this revision: Pg. 3 of19 Another EPA name if appropriate, email

3 QAPP title Revision: 0 Date of this revision: Pg. 4 of19 2.0 Table of Contents (A2)

Level 2 QAPPs require at least all the elements from the Project Management category of QAPP elements: 1 (A1), 2 (A2), 3 (A3), 4 (A4), 5 (A5), 6 (A6), 7 (A7), 8 (A8), 9 (A9); from the Measurement Acquisition (data-gathering) section elements 14 (B5, Quality Control),18 (B9, Non-direct measurements), 19 (B10, Data Management), 20 (C1, Assessments) and 21 (C2, Reporting); and all the Data Validation and Usability category elements 22 (D1, Data Review), 23 (D3, Validation Methods), and 24 (Reconciliation with Objectives); as recommended in http://www.epa.gov/ttn/amtic/files/ambient/monitorstrat/gradeapp.pdf and EPA's EIIP Technical Report Series Volume 6 (1996) available at http://www.epa.gov/ttnchie1/eiip/techreport/volume06/. Note that elements 9 (Documentation and Records and 19 (B10, Data Management) are combined, as are the QA/QC Data Usability elements 22 (D1), 23 (D2), and 24 (D3). This EI is a Level II inventory because it will provide supportive data that may be used for strategic decision making, and (in conjunction with information from relevant air quality monitors in our region) may be used to evaluate the need for monitoring on Tribal land, or other programmatic changes.

TABLES Table 1. Data Quality Objectives Table 2: Examples of Information Sources

FIGURES Figure 1. Organization Chart Figure 2. Emissions Inventory Area Map Figure 3. Example TEISS Notes field Screen

References

Attachment A: QA/QC Review Checklist 3.0 Distribution List (A3) The people listed here will receive copies of this QAPP and any revisions. It is the responsibility of the IDM to make copies available to these people, and to keep the most current revision available on the office computer network.  

4 QAPP title Revision: 0 Date of this revision: Pg. 5 of19 4.0 Project Organization (A4) The responsibilities of the key personnel identified on the organization chart are discussed below, and represented in Figure 1.

Figure 1. Tribal Environmental Department Organization Chart

The Name, Environmental Protection Department Director, is responsible for providing the staff resources and time necessary for the inventory development and the Deputy Director for providing communication and updates to the Director. The QA Reviewer will spend approximately two hours every two weeks reviewing documentation (this QAPP, the database logbook, and paper and computer files), data gathered, rough calculations, final estimates, and written reports. The objective of the QA Reviewer’ s involvement is to provide an independent review of the project by someone outside the project. One of the most important functions of the QA Reviewer is to just check the paper and computer files to make sure that they are being updated and documented. The QA Reviewer is technically competent to understand the basics of the emissions inventory, at least on a common sense level, and will use this QAPP as a list of requirements and periodically check that the requirements listed in this QAPP are being met. The QA Reviewer will use the QA/QC Checklist in attachment A as the minimum documentation for the reviews. The inventory development manager (IDM) for the 2011 EI will plan and manage all inventory development activities, including maintaining the up to date QAPP, distributing it to all relevant personnel, and maintaining the current version in the computer files. He/she is responsible for the development and revisions, if warranted, of this QAPP and the final EI report. The IDM is responsible for maintaining a complete data file and documenting all of their activities in a manner that will allow verification of the estimated emissions in accordance with all the requirements of this QAPP. The Environmental Protection Department Director will be consulted if any deviations from this plan or changes in the scope of the work are necessary. No changes in scope or methods will be made without prior approval from the Environmental Protection Department Director or whoever is appropriate.

5.0 Problem Definition/Background (A5)

During the past three decades, complaints about air quality and incidents of hospitalization due to asthma on our land have greatly increased. This project is to identify sources of air pollution that may influence air quality on the Tribe’ s reservation and estimate their emissions in the context of potential affects to the air quality breathed by the people in our communities. The primary purpose of this EI is to inform Tribal leadership of potential environmental and health impacts, and to continue

5 QAPP title Revision: 0 Date of this revision: Pg. 6 of19 to implement plans to protect and monitor air quality. This Emissions Inventory will be used as a baseline to assess future changes in sources or air quality and as a fundamental keystone of our air program. The results may also be used, in conjunction with assessment of the locations and data from nearby state or county air monitors, if relevant, and with discussion with the EPA regional office, to assess air monitoring.

6.0 Summary and Project Description (A6) The purpose of this EI is to develop a thorough, accurate, and up-to-date list of sources and emissions that may affect the air quality breathed by people who live and work in our communities. A buffer zone of 50 miles was chosen because all sources within a 50 mile distance of our exterior boundaries may affect the Tribe’ s air quality, and based on reviewing sources further away, it is unlikely that emissions from sources further than 50 miles from our boundaries would affect air quality on Tribal lands. This inventory will include point and non-point sources, as well as off-road and on-road mobile sources.

The EI will address:

. Volatile organic compounds (VOCs), . carbon monoxide (CO), . oxides of nitrogen (NOx),

. sulfur dioxide (SO2),

. particulate matter ten micrometers in diameter or smaller (PM10),

. particulate matter two and a half micrometers in diameter or smaller (PM2.5), . lead (Pb), and . Hazardous air pollutant (HAPs).

Sources inventoried on Tribal land and within the buffer zone include:  Wood stoves  Burn barrels  Paved and unpaved roads  Agricultural crops (corn)  Gas station  Sawmill  Gravel pit  School using commercial propane for heating  Community center using commercial propane for heating (both the school and community center will be treated as nonpoint sources for purposes of calculations)

This EI is intended as a tool to establish a baseline list of sources and pollutants that may affect our air, in order to track sources and the types and amounts of pollutants they emit as economic development and a changing environment affect air 6 QAPP title Revision: 0 Date of this revision: Pg. 7 of19 quality. In future years, if it is apparent that new sources may be affecting air quality, or there are significant changes to the sources and categories listed above, this EI may be updated, but this inventory will serve as a benchmark for emissions that can affect air quality at this time. The area covered by the EI includes the Tribe’ s reservation external boundaries, plus a buffer zone of approximately 50 miles from the exterior boundaries, so that sources of importance to our air quality can be included. The Tribe’ s reservation and the buffer zone region are shown in Figure 1.

Figure 1. Emissions Inventory Area Map Reservation.

7 QAPP title Revision: 0 Date of this revision: Pg. 8 of19 This EI will be completed using the Tribal Emission Inventory Software Solution version 3.1.0 (TEISS). TEISS is emission inventory development software that is available at no charge to North American Indian Tribes through the Institute for Tribal Environmental Professionals (ITEP) at Northern Arizona University (NAU). TEISS has a simple geographic information system (GIS) interface which allows inventoried sources to be mapped. It includes calculators that are based on EPA’ s AP-42, Fifth Edition, Compilation of Air Pollutant Emission Factors, Volume 1: Stationary Point and Area Sources (AP-42), the EPA’ s "Emission Inventory Improvement Program (EIIP)", and the NEI calculators, as described in the TEISS references at the end of this QAPP. 7.0 Data Quality Objectives (A7) This EI is considered a Level 2 inventory, based on guidance provided by the Emission Inventory Improvement Program (EIIP) (EIIP, 1996). The level of detail recommended for Level 2 emission inventories described in EPA's EIIP Technical Report Series Volume 6 (EIIP, 1996) will be applied to this EI. As shown in Table 1, data quality objectives (DQOs) were established to help ensure the accuracy, completeness, representativeness, and comparability of the inventory, in keeping with the EIIP’ s guidance for Level 2 inventories.

Table 1. Data Quality Objectives Data Quality Process Objective Accuracy For all sources, each numerical value calculated will be checked by the IDM for transcription errors and accuracy, starting from the value obtained about/from the source (throughput, e.g., gallons of propane used by the school boiler: checking that the value written in the logbook/paper is based on the conversation with the school admin is the same value in the excel spreadsheet, then that any conversions are correct (e.g., gallons to thousands-of-gallons that TEISS requires as input), then that this correct value was entered into TEISS, then that the final EI report uses the results from TEISS accurately.) Some source data will go through more steps, and each step will be verified. These verifications will be documented in personal notes and official emails and will be available in case calculations are questioned, and a separate log of corrections made will be kept in a MS Word document, to be stored in the same computer folder for any spreadsheets and electronic notes to assess what percentage of the calculations required correction; At least 20% of the calculations will be reviewed by the QA Reviewer; Upon request, ITEP will review 20% of the calculations as well as the final EI report. Completeness All of the emission sources of concern to the Tribe will be included, or a description of why the emissions are negligible (or not included) will be part of the EI report. All sources included in any previous EIs (if they are available) will be included. 8 QAPP title Revision: 0 Date of this revision: Pg. 9 of19 Representativeness A review of which pollutants are emitted from which sources will be conducted, and compared to similar sources in other regions of the country, just to verify that the pollutants are consistent with similar sources in other jurisdictions and are therefore representative of the pollutants from these source types in other inventories. Comparability To ensure the data are comparable, standard procedures will be followed and results will be presented in the units that are in common use, to allow compatibility with inventories compiled in the future and in other jurisdictions. The most up to date emissions calculators in TEISS 3.1.0 will be used in any calculations, and default values provided by TEISS will be documented in the QC notes, for cases when default values must be used (see figure 2). If default values need to be used, the IDM will use local values (e.g., for silt content for unpaved roads) rather than national defaults. All sources of information will be documented in the IDM logbook and the TEISS QC notes fields.

Figure 2: Example of TEISS Notes Fields Screen:

8.0 Special Training Requirements (A8)

The IDM has received the following training for conducting and emission inventory and the QA\QC procedures necessary to conduct this work:  Name and title; list training and dates  Name and title; list training and dates

9 QAPP title Revision: 0 Date of this revision: Pg. 10 of19  QA Reviewer: John QuestionAuthority; (1) on the job training (2 yrs) as a water quality technician, (2) reading this QAPP and the references in this section, including videos referenced, to understand the steps to producing an Emissions Inventory, and (3) ITEP’ s online Data Management course (dates). Training Requirements References:  ITEP’ s Online EI-Advanced QA QC Module (module 7) ppts and video, accessible at: https://www.youtube.com/playlist? list=PLdtViTRnkGuqwLQr5fja70z6mItEJRVOi  Chapter 7 and Appendix A of EPA’ s Model QA Plan (ch. 5) in Emission Inventory Improvement Program, Volume VI, Quality Assurance Procedures, Accessed from: http://www.epa.gov/ttnchie1/eiip/techreport/volume06/ (these excerpts are also available from the ITEP EI-Advanced course delivery website, in the module 7 folder).

Training will be documented in the email mailbox designated for this EI work by the IDM, and if non-emailed documents are relevant (e.g., completion certificates), these will be pasted in the IDM’ s logbook and/or scanned and saved in the EI folder. Documentation of the QA Reviewer’ s time spent reading the references listed in this section will be documented in an email to the IDM and saved in the designated EI mailbox folder. 9.0 Documentation and Records (A9) and Data Management; Element 19 (B10) The primary requirement for documentation is that it be sufficient so that reconstruction of all inventory development activities is possible— in other words, someone could trace all the data gathering, conversions, calculations, and summaries and arrive at comparable values if they essentially did the estimates a second time using the supporting documentation provided. Note that the following section (14 (B5): Quality Control) includes a list of requirements for recordkeeping and data management, because most of the QC for this EI project consists of activities designed to ensure the adequate quality of records. When developing this EI, there will be two master files: an electronic project folder and a master project logbook in printed form containing handwritten and securely pasted notes. The master project logbook will be kept in the custody of the IDM and secured in the IDM office or on the IDM’ s person for the duration of the project. If certain pages in the logbook are critical, these pages will be scanned (or simply photographed and saved as files) and copied to the external USB drive used as secondary backup. The IDM’ s master project logbook will be used to note all activities that are part of the inventory development, including documenting training in using TEISS and the NEI data, the steps of data transfer, information sources and the complete rationale for decisions made regarding the area of the buffer zone, the choice of excluding any sources or source categories and a summary of the reasons for such choices, and all steps and choices (default or regional values for silt content and similar supporting

10 QAPP title Revision: 0 Date of this revision: Pg. 11 of19 information). This master project notebook will be kept in hard copy. This paper copy will be stored at the Tribe’ s Environmental Programs office in the file labeled “Emission Inventory, year” in the official and accessible project files. Data gathering will be conducted according to U.S. EPA-approved procedures. The approach and supporting documents or references will be thoroughly documented as required by this QAPP and a summary will be included in the emissions inventory report. All information sources will be thoroughly documented in the TEISS Notes fields and the Data Collected From field of the TEISS data entry screens by the IDM, and supplemented by handwritten notes in the logbook if these Notes fields do not capture rationales for decisions made or other information that would be vital to reconstructing the emissions estimates. The IDM will also document when required data needed for specific source categories cannot be obtained or do not apply. The use of default values or regional estimates will be explained in the Notes and/or logbook. Sources of data will include those shown in tTable 2, as well as additional sources that will be thoroughly documented (including URLs and dates accessed noted in the file with that data from that URL). Of particular importance in the supporting documentation are the dates applicable to the activity data (throughput) and ancillary data (e.g., sulfur content, type of fertilizer, etc.), as these EI estimates may be compared against future EI estimates.

Table 2: Examples of Information Sources Source Type Guidance Document Suggested Data Sources Point  AP-42 based calculators Existing inventories, included in TEISS state permit files,  EIIP Volume II facility site visits, county business directories, telephone directory. Nonpoint  AP-42 based calculators Existing inventories and included in TEISS data sources such as  EIIP Volume III surveys or best guesses based on local knowledge. Non-Road  Guidance and emission Site-specific information Mobile factors provided to ITEP by obtained by site visits or EPA’ s OAQPS. contacting the operators, or local knowledge regarding the types of vehicles (e.g., snowmobile types most used). On-Road Mobile  Existing state/county State on-road mobile emissions estimates. source inventory developers, local and Reservation sources, 11 QAPP title Revision: 0 Date of this revision: Pg. 12 of19 State Department of Transportation, Bureau of Indian Affairs Indian Reservation Roads Program

The following information must be included in the documentation for this project: . Units of measurement will be provided with each value, especially those used in unit conversions (units may be headers in spreadsheets); . Complete description of the data file sources as noted in the project logbook (description of the files used and their contents, e.g., county name plus non-point files were originally downloaded from xxx (include full filenames) saved on our office computer (identify by personnel), with filename xxx, and saved in original data file path c:\xxx\xxx, and backed up onto USB drive stored at xxx); . All supporting information, as fully listed in section 14 (Quality Control). Supporting information includes items such as information-gathering telephone conversations (those providing data, contact information, or information used for decision-making on type of source, etc.) Any outstanding questions and/or suggestions for future EIs will also be logged in the master project notebook, and, when relevant, in an email to self and (if appropriate) management for the record, so that a future EI can use the lessons learned during this project. 14.0 Quality Control Requirements (B5) The QA/QC requirements described in this QAPP were developed to help ensure that the emissions estimates generated have the required accuracy, completeness, representativeness, and comparability necessary to meet the project objectives. This section summarizes the quality control requirements for information gathering, recording, back-up, transcription, unit conversion, generation (calculating values), reduction (making tables and graphs with summary and total values), IDM note-taking, and report generation. Quality Assurance requirements, such as for project (TEISS software database saved specifically applicable to this EI) review and overall EI report review, as well as reporting, are covered in the requirements listed in category C: Assessment/Oversight elements of this QAPP. The most critical components of the EI development are those that could be used by an independent party (or a future IDM) to replicate the process and arrive at an identical or very similar set of sources, pollutants, and emission estimates. Therefore, recordkeeping for any decisions made is critical, and such records should include the rationale for any decisions made so that someone else can understand how the decisions were made and why. These notes are perhaps the most important, and are the most easily left undocumented. Such decisions may include the use of default values, decisions on source type category, compromise on full information (e.g., assumptions about filling

12 QAPP title Revision: 0 Date of this revision: Pg. 13 of19 station tank filling method) because site contacts are nonresponsive, etc. Such decisions can occur at many phases of the process. Specific QC requirements corresponding to the different phases of EI development can be summarized as follows:  information gathering: the goal is to include as source-specific information as possible;  recording: full documentation including contact name/email/phone as relevant, dates, method of communication, URL, email identification (re, from, and date, plus saved in designated email mailbox and project notes folder if email is not backed up), file name/path and description in hand-written logbook and MS Word document designated for notes, and generous use of the TEISS QC and Notes fields;  back-up: the TEISS project will be on the IDM’ s desktop computer, which is backed up by the IT person at least weekly; in addition, the TEISS project database will be zipped and backed up onto a USB drive kept with the personal belongings of the IDM. Also, the entire EI folder, containing spreadsheets and supporting documents, will be zipped, renamed as “ backup- date” and copied to the USB drive. These backups will occur at least weekly and more often after significant data entry;  transcription: every value transcribed from one file or document into another will be double checked by the IDM at least weekly, and values cut/pasted from one file into another (e.g., from an email into a spreadsheet, or from a spreadsheet into a TEISS calculator) will all be double checked by the IDM at similar intervals;  choice of estimation method (factors/calculators/source): methods and factors used will be according to EPA recommendations, as reflected in TEISS 3.1.0 and the sources of any other emissions factors or estimates (e.g., if we use county or state emissions estimates for onroad mobile sources we will determine how that office generated the estimates and the models and assumptions they used);  unit conversion: resulting values will be checked for reasonableness and consistency by the IDM and by the QA Reviewer prior to entry into TEISS;  generation (calculating values): EPA-recommended calculators in TEISS 3.1.0 will be used, and values will be checked for reasonableness both by the IDM and the QA Reviewer prior to finalizing the EI report;  reduction (making tables and graphs with summary and total values): TEISS 3.1.0 graphs and tables will be used to generate totals and proportions, and the actual TEISS database project itself will be reviewed by the QA Reviewer prior to EI reporting;  IDM project note-taking: the IDM will make copious notes in both handwritten form and in the computer Notes file (an MS Word file used to copy text, emails, URLs, etc. into a single document that is stored in the EI folder and used for reference), and this Notes file will be reviewed for thoroughness by the IDM at two week intervals or more frequently; 13 QAPP title Revision: 0 Date of this revision: Pg. 14 of19  report generation: the IDM will write the EI report using the output from TEISS 3.1.0 and any supporting information, and all data values and summary values (in tables and charts) will be reviewed first by the IDM for consistency with the values shown in the TEISS report screens and then, in consultation with ITEP, for reasonableness in comparison with other emission inventories from similar jurisdictions (nearby states or county inventories, or comparable jurisdictions); . corrective actions: formal and informal corrective actions will be implemented as soon as quality issues are identified, after any necessary discussion with project management. If QA/QC issues arise that the IDM is unable resolve on their own, the IDM supervisor and others, as appropriate, will be consulted to determine what corrective actions should be undertaken. All corrective actions will be documented both in the EI logbook and in an email to self (and, if appropriate, management, and saved in the designated EI email mailbox) and saved in the EI computer folder. 18.0 Data Acquisition Requirements (Non-Direct Measurements; B9)

There may be some information that is obtained directly by observation (counting cars may be used, for example, which is a direct measurement) but in general most of the information used to generate the emissions estimates is not directly obtained by observations or measurements. Instead, most of the information used will be obtained from other people’ s records, such as purchasing records for propane use by boilers, as provided to the IDM by school administrators, and gasoline purchasing records by gas stations. Because of the extensive use of information obtained from others, it is difficult to place requirements on the quality of the information. However, there are requirements for such information, most of which relate to the thoroughness of the documentation for this project— with the objective that another person, following the same trail of data gathering, could closely replicate the emissions estimates. In addition, the time covered by the information used is critical— the goal will be to use information relevant to the current year, and this will be documented carefully, as some information may be obtained from several winters ago, for example, for wood stoves, while information on gasoline tank filling may be more recent. Again, this calls for scrupulous and extensive note-taking because the only way that someone else could follow the long chain of information and decisions made is with such thorough notes. This entire QAPP is devoted to providing requirements for the quality of this information. The review of data, as described in section 14, includes all data obtained from all sources, and is documented using the QA/QC Checklist in attachment A. 20.0 Assessments and Response (C2)

14 QAPP title Revision: 0 Date of this revision: Pg. 15 of19 Due to severe budget constraints and the small size of this inventory, formal audits will not be conducted during this inventory development process. If the Tribe wishes to submit this EI data to EPA’ s National Emission Inventory (NEI), chooses to use only the information contained in the EI to develop regulations, initiate action against sources on or off the reservation, or take any action that would cost the Tribe funds or manpower, an outside quality assurance authority with experience in emissions inventories will be contracted with to conduct a QA assessment. ITEP at NAU receives funding from EPA’ s Office of Air Quality Planning and Standards (OAQPS) to conduct training and assistance for tribes within the U.S. Typically, this service is provided if the tribe wishes to submit their data to the NEI, but it is not necessary to submit the data to the NEI to get the assistance with reviewing the EI project and resulting emissions estimates. However, formal and informal assessments and corrective actions will occur at regular intervals during the inventory development, as the estimates are produced, and as the EI report is drafted. A QA/QC Checklist (attachment A) will be used to document the reviews that are conducted by the QA Reviewer at approximately two week intervals. Even reviews that are conducted by the IDM on his/her own activities, if formalized and documented using a QC checklist, can be very helpful to assuring the quality of the data gathered and estimates produced, especially because the QC checklists, after completion, are made available to the IDM supervisor and become part of the official record of the project. Whenever possible, the QA Reviewer will complete the QC checklist. Corrective actions, if recommended or required, are noted both in the project logbook and the QC checklist, and in emails sent to the IDM/QA Reviewer and the IDM’ s supervisor, and saved in the email mailbox designated for the EI project. In addition to these ongoing reviews, ITEP will, upon request, review the data gathered, preliminary conversions/calculations made in spreadsheets, review screenshots of TEISS linear data entry screens, the TEISS calculator panels, SCCs used, tables, and graphs. In addition, ITEP can review the TEISS database in its entirety if it is zipped and transmitted to ITEP, and ITEP can also review the EI report that summarizes the emissions estimates. All of ITEP’ s review will be documented in emails saved both by ITEP and the IDM. 21.0 Reporting (C2) Reporting will include internal reports to management on the progress of the EI development, which may be in the form of emails, and, after tribal management approval, submittal of the EI report to the U.S. EPA (the grantor for this project). The procedures, assumptions, and summary tables of emissions will be thoroughly documented in the EI report. An executive summary will be included to facilitate using these emissions estimates in planning and decision making. The report will include summary tables, charts, a narrative description of the results, recommendations for future work and, if appropriate, recommendations for emphasis on particular sources of interest. Any deviations from this QAPP or standard practice in using NEI data or TEISS will be noted in the final report. Also included in the report will be a summary of the QA/QC reviews conducted, the reviews 15 QAPP title Revision: 0 Date of this revision: Pg. 16 of19 conducted by any outside party, a brief summary of any corrective actions implemented, and any concerns or caveats regarding the information or assumptions used when generating the estimates and summarizing the results. For example, if default values were used for a critical factor in the calculations, a recommendation could be that the next EI focus on obtaining source-specific information so that default values for that parameter do not need to be used. If the Tribe chooses to submit their EI data to the NEI, ITEP will be contacted to request assistance with a QA review and for assistance with submitting the data through the EPA’ s Emission Inventory System (EIS). 22.0, 23.0, and 24.0: Data Validation and Usability (D1, D2 and D3) This section describes the requirements for reviewing the project from the larger perspective of questioning whether the project plans and progress really meet the Tribe’ s needs for information about air pollution emissions that could affect the air that is breathed in the communities in the inventory area. This data usability assessment (usability review) will be an ongoing activity, conducted primarily by:  the IDM as data are gathered and calculations are made, and implemented by the IDM’ s vigilance in collecting the data that is really representative of what happens at that source (and documentation of any caveats about the information as described in previous sections);  the IDM supervisor and the QA Reviewer staying on schedule in terms of reviewing nd the data as it is gathered to provide a “ 2 opinion” and sounding board to assist the process so that the IDM o does not waste time gathering unnecessary information; o gathers information that may be useful in assessing the impact of emissions (e.g., if a source contact explains that the boiler is being phased out for a cleaner source, that information is very important in terms of possible decisions to be made based on the EI, but not vital to the calculations of that year’ s emissions from that boiler, which is just useful for “ this ” EI);  Compilation of the information gathered in a way that allows a future IDM to use this EI as a benchmark within the larger context of air pollution on the reservation from year to year and decade to decade. Keeping this paramount will be incentive for the IDM to err on the side of more notes rather than fewer, more backups rather than fewer, and more reviews rather than fewer. So, such observations are critical to note and keep track of for possible inclusion in the EI report, and requires the IDM to continue to think about the larger picture of what affects air quality on their land. It is important to consider the overall mission of reducing air pollution and its resulting adverse health and environmental effects as well as completing the task of an emissions inventory. The biweekly review sessions, using the QC checklist (attachment A) can serve as one opportunity to consider the larger picture, and document and implement any actions taken as a result of such usability reviews.

16 QAPP title Revision: 0 Date of this revision: Pg. 17 of19 References

Emission Inventory Improvement Program (EIIP). 1996. Volumes II-VI. Prepared by the State and Territorial Air Pollution Program Administrators and the Association of Local Air Pollution Control Officials (STAPPA/ALAPCO).

U.S. EPA, 1995. Compilation of Air Pollutant Emission Factors, 5th Edition and Supplements, AP-42, Office of Air Quality Planning and Standards, Research Triangle Park, North Carolina.

TEISS-Specific References: TEISS View Help and supporting documentation for version 3.1.0 available on the IDM computer and at www.weblakes.com EPA Emission Factor and Inventory Group. Appendix A, Instructions and Conventions for Using NEI Input Format Version 2.0, November 2000. Re-issued April 2001. EPA Emission Factor and Inventory Group. The NEI Input Format – Instructions for Entering and Organizing your Data in the Format Records and Source Files. www.epa.gov/ttn/chief. Originally issued November 2000, Re-issued April 2001. EPA Emission Factor and Inventory Group. What is the National Emissions Inventory (NEI)? www.epa.gov/ttn/chief/eidocs/nei.html. Last updated Friday, May 10th, 2002. Accessed February 7th, 2003. EPA Emission Factor and Inventory Group. Organization of SCCs. www.epa.gov/ttn/chief/codes/readscc.txt. Accessed April 21st, 2003. Environmental Protection Agency, 2003. User’ s Guide to MOBILE6.1 and MOBILE6.2 Mobile Source Emission Factor Model (Revised). EPA420-R-03-010, U.S. Environmental Protection Agency, Research Triangle Park, North Carolina 27711. ENVIRON International Corporation, 1998. USER’ S GUIDE FOR THE NATIONAL NONROAD EMISSIONS MODEL DRAFT VERSION. Prepared for U. S. Environmental Protection Agency, National Vehicle and Fuel Emissions Laboratory, Office Building, 2000 Traverwood Drive, Ann Arbor, MI 48105. NATIONAL AIR QUALITY AND EMISSIONS TRENDS REPORT, 1996: http://www.epa.gov/oar/aqtrnd96/chapter5.pdf U.S. EPA, December 10th 2003. National Ambient Air Quality Standards (NAAQS): http://www.epa.gov/air/criteria.html U.S. EPA, November 26th 2003. Air Quality Planning & Standards: http://www.epa.gov/oar/oaqps/peg_caa/pegcaa03.html#topic3a U.S. EPA, January 9th 2004. Technology Transfer Network Air Toxics Website: http://www.epa.gov/ttn/atw/allabout.html 17 QAPP title Revision: 0 Date of this revision: Pg. 18 of19

18 QAPP title Revision: 0 Date of this revision: Pg. 19 of19 Attachment A: QA/QC Checklist, to be completed at least every 2 weeks Date: name: purpose of review:

Material reviewed, stored in what media:

Logbook review (dates, names, URLs, phone numbers, units, description of decisions made, if relevant, file names, path, and computer folder name, list everything checked):

Computer files reviewed (filenames, path, folder names, spreadsheet tab names, source identification and information reviewed):

Other records reviewed (email mailbox, training records, correspondence):

Recommendations for corrective action:

Caveats regarding information usability:

Corrective action taken (name, date, follow-up responsibility to make sure it stays corrected):