## New York State Department of Environmental Conservation

Division of Air Resources

Bureau of Air Quality Planning,**zn<~** Floor

625 Broadway, Albany, New York 12233-3251

Phone: (518) 402-8396 • FAX: (518) 402-9035

Website: www.dec.state.ny.us



### Mr. Richard Ruvo, Chief

State Implementation Plan Section

Air Programs Branch May9, 2006

United State environmental Protection Agency

Region 2

290 Broadway

New York, New York 10007-1866

Dear 

### Mr. Ruvo: Denise M. Sheehan

Commissioner



### We have reviewed your March 8, 2006 letter regarding the Madison A venue air quality

monitoring data. As you had characterized correctly, the data collection does not meet the

requirements of 40 CFR Part 58; and as such, would not be considered as valid for use in

regulatory programs. Mr. John Seitz's memorandum of March 22, 1997 entitled "Agency Policy

on the Use of Special Purpose Monitoring Data" further affirms this position since the ambient

monitoring was conducted under special purpose monitoring conditions and does not meet EPA's

requirements related to siting or method.

We have enclosed a draft report which includes an analysis and review ofPM

10 

### monitoring results from the last 18 years. We believe this report is suitable for the purposes of

showing that the PM

10 

### data from the last several years are below the PM

10 

### standard.

We respectfully suggest that the enclosed draft report supports a clean data finding which

will moot further PM

10 

### SIP work and the associated nonattainment designation. We note that

EPA has recently approved a clean data finding for two areas in Arizona, the Ajo nonattainment

area finding was proposed at 71FR6437, February 8, 2006 and announced as a direct final at

71FR6352; The Yuma nonattairunent area finding was proposed at 71FR13063, Marchl4, 2006

and announced as a direct final at 71FR13021. We request your review of this report and look

forward to your comments.



## 61 :8**~~** 

## S I A'IW 90DZ

### Please contact Matthew Reis, P.E., at (518) 402-8396 if you have any questions.

Enclosure

cc: M. Reis

D. Shaw

J. Higgins

C. McCarthy

G. Sistla

P. Lavin



### H. Felton

M. Sheehan

W. Pienta 

# , s;cererJbc>t.v--\P'

James Ralston, P.E.

Director

Bureau of Air Quality Planning

### New York State 

# A Review of

Inhalable Particulate

(PM10)

Air Quality



# . In



# New York County

(Manhattan Island)

1988 

# to mid-2005

Department of Environmental Conservation



### Division of Air Resources

Air Quality Planning

Draft

May 9, 2006This report was authored by W.J.Pienta, with the aid and assistance of K.Civerolo, R Twaddell, H. Dirk

Felton, S.H. Mo, J.Kent, and G.Sistla. 

# .Introduction

Ambient measurements of inhalable particulate matter (PM 10 ), have been

carried out routinely across the state of New York since 1988. Based on these

measurements, the USEPA noted that only one of the areas, New York County,

NY was in nonattainment or was exceeding the annual form of the NAAQS of 50

ug/m3. Although measurement of ambient PM 10 levels in New York County were

made at 8 monitoring sites since 1998, it should be noted that the data at any site

were often limited to less than 3 years due to logistic and other reasons, thereby

requiring a careful**asses~ment** of the entire data base. In this study, we

attempted such an assessment utilizing descriptive statistical tools and time

series analysis in examining if the measurements exhibit exceedance of the

annual and daily PM, NAAQS, which are 50 and 150 ug/m3, respectively. Our

analysis indicates that overall PM 10 levels exhibit a downward trend in the county,

and that the area is below the annual NMOS. Examination of the measured

PM 1 o levels, including special purpose monitors (SPM), indicates that all the sites

are below the NMOS level, even though these measurements may not meet all

the criteria set forth under SLAMS/NAMS operational protocols.

This review looks at all available data, whether or not specific regulatory

requirements are met. In some cases, data may not have met sufficiency criteria

spelled out in federal regulations. In other cases, data may not have been

gathered using reference or equivalent methods.

Monitoring Sites

Figure 1 (the figure number corresponds to the page number of the

accompanying "graphics PDF" file) provides two panels; Fig. 1 (a) shows the

location of all historical monitors in NY County, while Fig.1(b) shows only the

current PM 1 o monitoring sites.

Data Review

Descriptive Statistical Summary: Figure 2 displays a summary of all

data available from PM 10 sites in NY County since 1988. In the columns to the

left of the graphic are the named site and, then, a numeric designator for the

specific site. Each of these sites has a designation of 36-061-xxxx. This

identifies the state (36), and county (061) within the state, and then the specific

monitoring site (four digits)

The graphic consists of a series of 

### ubox and whisker" plots (also

simply called a box plot) that summarizes the data from each of the sites. The

data are divided into four areas of equal frequency, called quartiles. The

interquartile range (IQR), which determines the length of the box, is the

difference between the third and first quartiles. The length of the box bounds the

middle 50% of the data, and is a visual measure of the dispersion. For those of

us unaccustomed to interquartile ranges as a measure of variability, standard

deviations are also listed in Table 1 for each site. The median is drawn as a

vertical line, while the average is plotted as a plus(+). To establish the bounds

on potential extreme values and outliers, a lower (left) whisker is drawn from the

lower quartile to the smallest point that is still within1.5 interquartile ranges fromthat lower quartile. In a similar manner, the upper (right) whisker extends out to

the largest point within 1.5 IQRs. Values between 1.5 & 3.0 IQRs are plotted as

individual points, and data beyond 

### ± 3.0 IQRs are plotted as points with a plus

through them. A legend in the lower right of Figure 2 summarizes these features

of the box plots presented here.

Also listed in Figure 2, to the right of each individual box plot and in line

with each site, are (1) the number of samples, (2) the time span of the monitoring

effort, and, (3) sample frequency. The standard for the annual form of the

NAAQS is highlighted along the horizontal axis and a vertical line is established

at the level of 50 1Jg/m 3

• This level is shown as an indicator, and some caveats

on interpreting the one and only average that is above this standard are

discussed below. Table 1 provides numerical values for the average, median,

and standard deviation.

TABLE 1: Summary Statistics

Site 10 Count Average Median Standard

Deviation

0002-CCNY 35 29.9 26.0 12.9

0010-Mabel Dean 4,976 22.9 19.8 13.4

0056-P.S. 59 478 34.7 31.8 16.3

0062-Canal St. P.O. 427 25.4 23.2 11.8

0069-Bowery Savings 211 42.2 39.0 17.9

0077-Mad. Ave Research Site 590 51.9 47.6 21.8

0093-37 St. 53 41.3 37.0 21.2

0095-Canal@. Broadway 133 46.9 44.6 17.4

0123-Albanv St. 10,625 27.0 23.4 16.4

0125-Pace Plaza/Park Row 24,982 24.5 21.3 14.1

0130-23 Wall St.@ Broad 5,335 27.4 24.9 13.8

From the array of box plots in Figure 2, two distinct features are important

to note. First, and most germane to the point of this exercise, is that Madison

Avenue has a long-term average that exceeds the NAAQS in its annual form. A

number of points with regard to that simple statement must quickly be made.

First, from its inception, this site has been subject to some controversy over its

location insofar as its use beyond a research site (a.k.a. a special purpose

monitor). Recent agreements between NYS DEC and USEPA acknowledge its

continued value as a research site, but admit that, as a special purpose monitor,

the site does not meet requirements for use in non-attainment

designations/attainment demonstrations. Second, there is a penchant for making

comparisons to the NAAQS where data exists, despite the inapplicability of the

Madison Ave. site for purposes of judging attainment. So it is with the

Department's technical staff as well. As subsequent figures will show. more

recent data, even for the Madison Ave. site, remain below the NAAQS. Other

sites are lower still. Furthermore, the long term average for the Madison Ave.

research site cannot be considered the expected value for future measurements

at this site, in light of a downward trend in the recent data. The significance ofthe trend should be investigated further, but that is beyond the scope of this

effort.

Another feature of the box plots is the ease with which stations that report

hourly values can be distinguished from those stations collecting 24-houraveraged samples. The**~extra-long~** tail of the**~extretnen** right side of the

distribution of values is the tell-tale sign of hourly data, and should remind us that

PM 10 measurements tend towards a lognonnal rather than a normal distribution.

More large values are expected in a lognormal distribution, so that statistical

tests based upon a presumption of normality will judge far more of the values in

the right-hand tail to be "outliers" when they are not necessarily outliers in a

lognormal distribution. For these and other practical reasons, this review does

not dwell on statistical tests for the significance of the trend lines.

Times Series Analysis: Figure 3 is a time series of all the available daily

data (Figure 4 presents the hourly data). Figure 3 contains the data from 8

different sites in 5 so-called "small multiples", meaning that the five graphs share

a common X-axis covering a time span from late 1987 to the recent past. In this

particular case, the range or span of theY-axis is the same in all five plots as

well. The five graphs are labeled (a) thru (e) along the right margin. Having a

common X-axis allows for easy comparisons across several sites for the same

time period by scanning up and down the vertical axis. None of the daily

averages exceed the daily form of the NAAQS (150**~g/m ).**  For each of the eight

site-specific time series, a trend line that represents the best straight line fit thru

the data is also drawn. The averages are given in Table 1. Two points need to

be made with regard to the trend lines. First, if the trend is real (i.e. significant),

then the average is not the best measure of the expected value of a future

measurement or series of measurements. The second is that one of the

properties of a least-squares regression line is that the mean value is a point on

the trend line. So, if a trend line is entirely below the NAAQS, it provides

incontrovertible evidence that the site is in attainment over the span of time

covered (independent of whether such a trend line is statistically significant).

Thus, it should be clear from Figure 3 that all sites, except Madison Ave, were in

attainment. Furthermore, the more recent Madison Ave. data, for which a

separate trend line is drawn (see Fig. 3(d)). is below the NAAQS for the most

recent years (the last four years, to be specific). A closer look at only the most

recent Madison Ave. data appears as Figure 6.

Figure 4 presents hourly data from four differing sites. Only Pace

Plaza/Park Row site continues to sample at present, although it, too, is a special

purpose monitor. The salient feature of Figure 4 is that all four sites were well

below the annual NAAQS, since each of the trend lines is well below the 

### NMOS.

Hourly data contain more short-term but elevated concentrations (which gives

rise to a lognormal distribution mentioned earlier), and creates the long tails

discussed in relation to the box plots of Figure 2. This is reinforced 

### by the

magnitude of theY-axis range or span that is necessary to fully display all the

measurement values. To assist in making numerical and visual comparisons

with the daily (24 hour average) data shown in Figure 3 for the other sites, thehourly data was reduced to daily averages. No minimum threshold for the

number of hourly samples was established for this exercise. Some days have

averages comprised of as few as 8 or 9 hours of data. All daily averages are

plotted in Figure 5. None of these daily values exceeds 150**~g/m .**  Trendlines

are also presented.

Figure 6(a) redraws from Figure 3 only the most recent data for Madison

Avenue, and superimposes a second-order trend line through these daily values.

In Figure 6(b), the daily values are reduced to annual averages. Annual

averages from Canal St. P.O. (calculated from the daily values in F'ig. 3(c)) are

plotted as well. These annual averages can be compared to the annual NAAQS

that is drawn in as a long red bar across the plot.

Conclusion**~** New York County has measured attainment at the Canal St. P.O. for the

past three years. Two other special purpose monitors, one measuring street

level, traffic-related particulate, and the other measuring particulate ,upwind of the

World Trade Center remediation and reconstruction efforts, also are measuring

PM 10 that is below the NAAQS. New York County should be officially declared to

have attained the standard by US EPA.(a)ApproximateLocationsofPM10MonitorsinManhattanfrom1988tothepresent<-§r.J<:."'-'--0se-f---CCNYv37thSt.Wof7thAve.CanalSt.P.O.PacePlaza/ParkRowAlbanySt.()I,v----P.S.59MadtsonAve.BowerySavingsBank._\---._MabelDeanH.S.CanalStatBroadwayWallSt.atBroadSt.(b)ApproximateLocationsofPM10MonitorsinManhattanasofFebruary2006_z\rv.:;;..Q,MadisonAve.CanalSt.P.0......_____PacePlaza/ParkRow()Box-and-whlakerplote;forPM10datafromallalteaInNYCountySiteloCJJtlon&AQS10"---.-------.,-------r,-------,----..--,----r---CCNY0002jOn=35from4.22.89to11.12.89tin6day.sMabelDean0010..•n=4976fromtt6.89to6.14.01tin6daye'tilt1.26.00,thenhourlyP.S.590056f+--lJDIJ<DJn=478from1.1.93to12.31.981in6dayeCanalSt.P.0.0002••n=A27from12.6.01to6.30.051in3dayeBawerySsvlnge0069Io•n"'211from3.4.88to3.20.931In6dsyeMad.Ave.Reeearch0077Ie+n,590from1.1.93to12.31.98(116dl!l.)&4.15.00to12.29.04(113dl!l.)37thSt.009300•n""53from4.22.97to5.5.98tin6dayeCanal@6'way0095n=133from12.11.95to12.31.981i_n6day!lAlbanySt.0123e--[EH-·-·••••n""10,625from10.30.01to5.14.03hourlyP8cePlaz.l'I/P8rkRowOt25IIn"'24,982from9.13.02to9.30.05hourly23Wl!lllSt."Broad0130......n=5,335from11.17.2001to7.1.02hour(yI-------'------__l___L_0.A100200300400AnnualNAAQSSampi•Valuonotes:1.notallofthe:datasummarizedhereisIntheAQSsystem2.samplingmethodsmayvarywithinandbetwensitesoverthetimespanW,J.f'i<m\:6..12706LEGEND'Q•boxllncompaeeeemiddle50'7.ofthlld8t.l'l;verticallinethruboxIathemlldian;plueelgnletheaverage;whlekllrerepreeent±1.5tlmllethelnU:rqusrtllllrange(IQR);pointebeyond±1.5IQRareplottedIndividually;beyond3lnterquartlli':rangllethepointehavea+elgn

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The Annual form of the NAAQS of 50 f.lg/m3 is highlighted in red in each plot



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