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 

Ken Newkirk, NYS DEC 

Doug Surpitski, NYS DEC 

Jim Ralston, NYS DEC 

Mike Kormanik, NYS DEC 

Dave Park 

1125/95 

PM-1 0 SIP Planning Meeting 

Langdon Marsh 

Commissioner 

Thank you, all, for attending the PM-10 SIP planning meeting at NYC DOT on January 13, 1995. 

Please find attached a record of what transpired at this meeting and issues to be brought up with EPA 

at the February 1 meeting. Also attached is the revised 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 

New York City DOT, 40 Worth Street 

I. Redesignation Request and a Maintenance Plan vs. an Attainment Demonstration: 

A redesignation request was defined as a commitment not to increase the emissions of a 

particular pollutant (in this case PM-I 0), whereas an attainment demonstration commits to drive the 

level of emissions down. In the case of an attainment demonstration for PM-1 0, the CAAA 

specifies, in§ 188 (c) (1), that the area of moderate nonattainment for PM-10 has up to six calendar 

years from the date of the area's nonattainment designation to demonstrate attainment. In the case 

of Manhattan. 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 of this 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-1 0 standard, then politicians and the organizations affected by the 

PM-I 0 abatement strategies may fight any control measures imposed by the maintenance plan. using 

the argument that Manhattan already attains the PM-1 0 standard thus negating any need for PM-1 0 

controls. Additionally, an attainment demonstration may have more leverage against organizations 

like New York Transit to introduce a cleaner burning 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 in NYC. 

DEC will discuss this matter internally. It was suggested that a joint meeting be scheduled 

with MTA and NY Transit once the PM-10 SIP development is more organized. This issue should 

be brought up at the February 1 meeting 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 that the annual average was in violation. There has been no update of this data so far. 

Regardless, if DEC follows through with a redesignation request and maintenance plan, EPA 

may be opposed to this in several ways. The ambient monitoring data at the Madison A venue site 

for 1994 may not meet the 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 A venue 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 of the NAMS network before designating the 

area in compliance. 

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 enclosure built around the monitor. This issue should not, 

but may delay DEC's efforts to submit a PM-1 0 SIP. Also, the question arises whether this problem 

should be considered on a microscale level or on a regional one. EPA should be asked to clarify this 

point at the February 1 meeting. 

When the Ambient Data becomes available, DEC will make its decisions accordingly as to 

what type of plan it can submit and what type of plan it will submit. 

In the actual plan, DEC should indicate to EPA that the Satmation Study was used to 

determine where a violation of the PM-1 0 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 

Manhattan from an air quality perspective. As the other two continuous monitors come on line, DEC 

will study the data and implement the necessary contingency measures should either of the two 

monitors reeord a violation of the 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 of the 

PM-1 0 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 hour period in April 

of 1993 at the Madison Avenue and 47 Street sampling site. Problems people have with this study 

is the duration of sampling ( 48 hours), the time of year that this study occurred (April which is not 

the beating season) and the nwnber of locations where this study took place (one). 

B. Part 5 Model: 

According to DEP, the Part 5 Model has reported values of 80% to 90% fugitive dust at 

Madison Avenue, using the default data. When using local DEP data.. estimates of 70% fugitive dust 

were modeled. This represents a severe overestimation of the actual ambient conditions at Madison 

A venue. 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 of speed. As a side note, DEP indicated that the 

model attributes more PM-1 0 emission from buses than trucks. Also, DEP questions whether the 

model has been approved or not.