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PM10 SIP Withdrawal and Clean Data Request

The following is the content of a letter sent to the Regional Administrator at the USEPA, Region 2, Judith A. Enck. The letter was signed on January 14, 2013 by Joseph J. Martens, Commissioner.

New York County was designated as a moderate nonattainment area under the 1987 PM10 National Ambient Air Quality Standards (NAAQS) on January 20, 19941. Pursuant to Clean Air Act Section 110, the New York State Department of Environmental Conservation (DEC) submitted a State Implementation Plan (SIP) revision in September 1995 that provided EPA with a demonstration that New York County would attain the PM10 NAAQS by January 20, 2000, as required by the Clean Air Act. This SIP was deemed complete by EPA on January 21, 1996, and subsequently updated by DEC in September 1996.

DEC is hereby withdrawing its SIP for the New York County nonattainment area for the 1987 PM10 NAAQS. We are also withdrawing the associated request for redesignation of the nonattainment area, as originally presented to EPA in a letter dated July 20, 19952.

Data from DEC's air quality monitoring network have demonstrated that New York County was in attainment of the PM10 NAAQS when EPA designated it as nonattainment, and has never had an exceedance of the NAAQS since being so designated. On May 9, 2006, DEC presented to EPA a draft report titled "A Review of Inhalable Particulate (PM10) Air Quality in New York County (Manhattan Island); 1988 to mid-2005."3 DEC noted at the time that the draft report supports a clean data finding for New York County.

In conjunction with withdrawing the PM10 SIP and redesignation request, DEC is again requesting that EPA makes a clean data finding for New York County for the 1987 PM10 NAAQS. Such action is supported by the previously submitted draft study, as well as updated monitored air quality data.

The 24-hour PM10 NAAQS is met when the level of 150 µg/m3 is not exceeded more than once per year on average over a three-year period. The following data represent the 24-hour PM10 values recorded at the PS 19 and Division Street monitors from 2009 - 2011:

Maximum 24-hour PM10 Concentrations in New York County (µg/m3)
Monitor Name Monitor ID 2009 Max
(# Obs.)
2010 Max
(# Obs.)
2011 Max
(# Obs.)
PS 19 36-061-0128 61 (75) 55 (113) 57 (118)
Division Street 36-061-0134 62 (119) 56 (121) 57 (112)

The chart below shows that ambient PM10 concentrations over the last 10 years in New York County have been well below the level of the NAAQS. This chart relies on data from the PS 19 and Division Street monitors, as seen above, as well as from previously operating PM10 monitors at PS 59 and Canal Street.

Comparison of NAAQS level and NY county maximum for 24-hour PM10 concentrations

Although the annual PM10 NAAQS was revoked by EPA, DEC can assure that this standard continues to be met based on the annual arithmetic mean remaining below 50 µg/m3 when averaged over three years. Provided below are a table displaying the 2011 design values for the PS 19 and Division Street monitors (based on 2009 - 2011 data), and a chart displaying New York County's maximum annual PM10 values over the last 10 years as compared to the NAAQS.

Annual Average PM10 Concentrations in New York County (µg/m3)
Monitor Name Monitor ID 2009 Max
(# Obs.)
2010 Max
(# Obs.)
2011 Max
(# Obs.)
2009-2011
Design Value
PS 19 36-061-0128 19.9 (75) 20.3 (113) 20.0 (118) 20.1
Division Street 36-061-0134 21.7 (119) 21.0 (121) 21.5 (112) 21.4

Comparison of NAAQS level and maximum annual average PM10 concentrations in NY county from all monitors for 2002 through 2011

Please call me at (518) 402-8540 if you have any questions.

__________

1 58 FR 67334; published December 21, 1993
2 Letter from Arthur J. Fossa, Director, Division of Air Resources, NYSDEC, to Conrad Simon, Director, Air and Waste Management Division, U.S. EPA
3 Enclosed with letter from James Ralston, Director, Bureau of Air Quality Planning, NYSDEC, to Richard Ruvo, Chief, State Implementation Plan Section, U.S. EPA