. I 

New York State Department of En9"1rl1~~~b Conservation 

50 Wolf Road, Albany, New York 12233 , T. AGY. RO r· 

Mr. Conrad Simon 

Director 

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AIR PPOGn, , ·nANs BR '· 

February 14, 1994 

Air and Waste Management Division 

United States Environmental Protection 

Agency, Region II 

Jacob K. Javits Federal Building 

New York, New York 10278-0012 

Dear Mr. Simon:~~~~ 

Thomas C. Jorllng 

Commissioner 

Thank you for notifying us of the designation of Manhattan 

as moderate non attainment for particular matter (PM10 ) in the 

December 21, 1993 Federal Register. Your offer of assistance in 

developing the PM10 State Implementation Plan (S.IP) is welcomed 

and ~ppreciated. To address your immediate concern, we have come 

to the conclusion that PM10 problems and the control strategies to 

solve them cannot be limited to an area smaller than the borough 

of Manhattan. The steps you outlined in the January 20, 1994 

correspondence are helpful, and I will relate to you where we 

stand in those matters and how your office can be of help. 

In regards to air quality information, the six-phase PM10 

Saturation Air Quality Monitoring study is in final analysis, and 

completion is expected by the end of March. All of the data, 

past and present, indicate that the Madison Avenue site contains 

the highest levels of PM10 , and there is nothing which would lead 

us to any other conclusion. Therefore, we expect to report the 

Madison Avenue site as the most probable location for an 

exceedance of the PM10 standard. 

A recent NYS DEC study has characterized the PM10 sample at 

the Madison Avenue site, on average, as 52.8% diesel exhaust 

particulate, 22.9% due to long range transport (principally 

ammonium sulfate, and ammonium nitrate) 8.5% Road Dust, 5.9% 

marine aerosol (sea salt) transported from the Atlantic Ocean, 

5.9% gasoline exhaust particulate, and 5.0% residual carbon from 

fossil fuel combustion and iron particulate, all of which are 

based upon the total weight of PM10 • These percentages change 

significantly with the time of day, although those associated 

with diesel emissions did not drop below a four hour average of 

() printed on leey(;led pepe< 

l 
2. 

30% during the 48 hour test period. This constitutes our impetus 

in designating heavy duty diesel vehicles as the primary 

contributors to the PM10 problem in Midtown Manhattan. 

At this juncture, we must advise against limiting the 

nonattainment status to only a certain portion of Manhattan, as 

the main controllable source of PM10 has been identified as the 

heavy duty diesel traffic in midtown Manhattan (tentative numbers 

suggest that motor vehicle emissions constitute on the order of 

70% of the total annual PM10 sample weight). Since these emitters 

of PM10 are mobile, they would have the ability to move freely in 

and out of the nonattainment area. This could decrease the 

effectiveness of any implemented PM10 control strategies and shift 

the site of highest PM10 to another area within the Borough. 

We expect, that upon completion of analysis the 1993 

particulate matter monitoring results for 1993 will yield an 

annual mean that is below the PM10 standard. If this be the case, 

and the three year average upon which compliance is determined 

results in a value below the PM10 standard, NYS will seek to 

petition EPA to redesignate New York County back to attainment 

status. On the same note, one correction, the Madison Avenue 

monitor failed to meet the 75% data acquisition criteria in 1990, 

not 1992. 

Since we have identified diesel vehicles as the largest 

controllable population of the PM10 emitters, the diesel vehicle 

emissions model has become the center point of our PM10 SIP 

development. We must thank you for expediting its development 

and availability. The need for accurate traffic data was 

stressed in your January 20, 1994 correspondence, a consideration 

with which we agree wholeheartedly. Since your letter John Walsh 

of your staff has helped us acquire the parameters which need to 

be collected. We are now coordinating with the New York City 

Departments of Transportation (NYCDOT) and Environmental 

Protection to obtain that data while the diesel vehicle emissions 

model undergoes final development. 

The July 20, 1995 submittal date for the PM10 SIP is 

acknowledged and confirmed. Currently we are establishing a 

protocol and consultation process among the various relevant 

government agencies. James Ralston has been designated as our 

lead contact person and will work with Ray Werner in the 

development of the PM10 SIP . 

Thank you for understanding the other pressing clean-air 

demands placed upon our state. I am certain that through a 

cooperative effort between the Environmental Protection Agency , 

New York state Department of Environmental Conservation, and all 

other agencies involved, the PM10 SIP will be developed in a 

timely fashion. 
cc: R. Werner 

R. Kapichak wfencl. 

G. Cioffi wfencl. 

~ Nudelman, NYCDEP wfencl. 

G. Soffian, NYCDOT wjencl. 

D. Park 

Sincerely, 

Thomas 

~ M. Allen, P.E. 

Director 

Division of Air Resources 

3.