### New York State Department of Environmental Conservation Division of Air Resources, Bureau of Abatement Planning 50 Wolf Road , Albany, New York 12233-3251 Telephone: 518-467-6379 Fax: 518-457-0794

To:

From: Date: Re: 

### MEMORANDUM Bill Hirsch, NYC DOT Denny Escarpeta, NYS DEC 

### Geny Kelpin, NYC DEP Harold Nudelman, NYC DEP 

### Antonia Bryson, NYC DEP Salvatore, lorfida, NYC DOT KenNewkirk, NYS DEC Doug Surpitski, NYS DEC Jim Ralston, NYS DEC Mike Kormanik, NYS DEC Dave Park 1125/95 PM-10 SIP PlanningMeeting Langdon Marsh Commissioner

Thank you, all, for attending the PM-10 SIP planning meeting atNYC DOT onJanuary 13, 1995. Please find attached a record ofwhattranspired atthis meetingandissues to be brought upwith EPA 

### at the February 1

### meeting. Also attached is therevised agenda for 

### February 1. 

### This agenda may be subject to change
.

cc : Dave Shaw Gerard Soffian, NYC DOT Kristeen Gaffney, US EPA Region II Tom Carney, NYS DOT

### PM-10 

### SIP Omanization MccUne 

### Nota January 

### 13, 1995 NewYork City DOT, 40Worth Street
I. Redesignation Request and a Maintenance Plan vs. an AttainmentDemonstration: A redesignation request 

### was defined as a commitment not to increase the emissions ofa particular pollutant (in

### this case 

### PM-I

### 0), whereas an attainment demonstration commitsto drive the level of emissions down. In the case of an attainment demonstration for 

### PM-10, the 

### CAAA specifies, in§ 

### 188 (c) 

### (1), that the 

### area ofmoderate nonattainment

### for PM-10 

### has up to 

### six calendar years from the date ofthe area's nonattainment designation to demonstrate attainment. Inthe case ofManhattan. 

### this would be 

### January 20, 2000
. Initially DEC had proposed to write a redesignation request and a maintenance plan for submittal to EPA July 20, 1995
. DEP has questioned the wisdom ofthis strategy. Their thoughts on the matter boils down to a matter of political perception of this problem
. If Manhattan is redesignated 

### as attaining the PM-10 standard, 

### then politicians and the organizations affected by the 

### PM-I0 abatement strategies may fight any control measures imposedby the maintenance plan. using the 

### argument thatManhattan already 

### attains the 

### PM-10 standard 

### thus negating any need for PM-10 controls. Additionally, an attainment demonstration may have more leverage against organizations 

### like New York Transitto introduce a cleanerburning municipal bus fleet or, for that matter, it may have more leverage against budget restraints to implement the control measures necessary to reduce the emission ofPM-10 

### inNYC. DEC will discuss thismatter internally
. It was suggested that ajointmeeting be scheduled with MTA and NY Transit once the PM-10 SIP development is more organized. This issue should be brought up atthe February 

### 1meeting with 

### EPA. Ultimately, the redesignation request and maintenance plan tack is contingent upon Manhattan's attaining the 

### NAAQS for 

### PM-10 in 1994. Monitoring 

### data through October 

### II, 1994 states thatthe annual average 

### was inviolation. There 

### has been no update ofthis data so far
. Regardless, 

### if DEC follows 

### through with a redesignationrequest and maintenance

### plan, EPA may be opposed to this in several ways. The ambient monitoring data at the Madison Avenue site for 1994 may not meetthe 75% capture rate, the third quarter ambient data may exceed the annual average and the monitoring network is incomplete (one monitoring site at 

### 3 7 Street between 

### 7 and 8 Avenue and another at Canal and Lafayette). EPA may argue that there are no other traffic level 

### sampling sites in Manhattan, and thus this calls for the monitors at 

### Canal and Lafayette and at 37 Street between 

### 7 and 

### 8 A venues, 

### be online and part ofthe 

### NAMS network before designating the area incompliance. The Six Phase Saturation Study indicated that the Madison Avenue site was

**th~** most likely to have a violation ofthe NAAQS for PM-10, thus the installation ofthe continuous monitor at that site. 

### The Canal Street site and the Garment 

### District site (37 Street) also had high readings during

### the Saturation Study, which is why they have been chosen as additional locations to install real time monitors. It cannot be determined when these additional sites will be available for data collection as plans for, at least, the Canal Street site have been stalled by the NY City Landmarks Bureau, which would like an aesthetically pleasing enclosurebuilt around themonitor. This issue should not, butmay delay DEC's efforts to submit a 

### PM-10 SIP. Also, the question arises whetherthis problem shouldbe considered on a microscale level or on a regional one. EPA should be asked to clarify this point atthe February 

### 1meeting
. When the Ambient Data becomes available, 

### DEC will make its decisions accordingly as to what type ofplan it can submit and what type ofplan it 

### will submit
. In 

### the actual plan, 

### DEC should indicate to EPA that the Satmation Study was 

### used to determine where a violation ofthe 

### PM-10 standard would actually occur. This resulted in the monitor installation at Madison Ave. DEC continues to view this site as the worst PM-10 site in Manhattanfrom an airquality perspective. Asthe othertwo continuous monitors come online, DEC will study the data and implement the necessary contingency measures should either ofthe two monitors reeord a violation ofthe standard. These contingency measures 

### will be included 

### in the plan, as confirmed commitments; not adopted programs. Contingency measures {or Canal Street and 3 7 Street should include trucks.

II. Inventory: A. Stationary Sources: The Gertler/Hershey study was discussed, as was its relevance 

### in requesting a waiver ofthe 

### PM-10 stationary source inventory. Several argwnents 

### were foreseen from 

### EPA in regard to the use . of

### this study for 

### a S
.S. inventory waiver
. 

### This study was per.formed during 

### a 48 hourperiod 

### in April 

### of 1993 at

### the Madison Avenue and 

### 47 Street sampling site. 

### Problems 

### people have with 

### this study is the duration ofsampling ( 48 hours), the time ofyear that this study occurred (April which is not the beating season) and the nwnber oflocations where this study tookplace (one). B. 

### Part 5 Model: According to 

### DEP, the 

### Part 5 Model has reported values of 80% to 90% fugitive dust at MadisonAvenue, using the default data. When using local 

### DEP data.. estimates of70% fugitive dust were modeled. This represents a severe overestimation ofthe actual ambient conditions at Madison Avenue. Also DEP faults the model in that it does not account for rainfall and the mobile source exhaust fraction is not generated as a function ofspeed. As a side note, 

### DEP indicated that the model attributes more PM-10 emission from buses than trucks. Also, DEP questions whether the model has been approved or not.