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P.1 

I986 

/o/frirfn-s-y 

MEMORANDUM 

TO : 

FROM : 

SUBJECT: 

The Record 

Elizabeth Deutsch 

Phone Log for proposed continuous release reporting regulation 

and proposed regulation on federally permitted releases 

Chen Lezonka - Philadelphia 

(215) 288-5178 

re: PAMS data 

Date: Week of March 25, 1986 

• 99 substances chosen on basis of long-term irrevocable health 

effects at low level exposure (with chronic effects), or insidious 

nature (i.e., no obvious warning properties) 

Carcinogens comprise approximately two-thirds of 99 substances 

30 pesticides 

Phenol added because Philadelphia emits large quantities 

45 of 99 substances chosen are emitted in Philadelphia, according to 

results 

Sources only include stationary (point) sources, not area sources 

such as traffic, service stations, or retail drycleaners 

Howard Wright 

Air Programs Branch 

(Compliance Analysis) 382-2826 

re: SIP sources (State Implementation Plan) 

Date: February 28, 1986 

27,055 Class A (major sources >100 tons per year) (may not be 

permitted) 

Unknown number of CLass B (minor sources <100 tons per year) 

Source of information: CDS - Compliance Data System 

Each SIP source can have multiple permits (for each stack, etc.) 
P.2 

1986 

Brenda Riddle - North Carolina Date: February 27, 1986 

Air Office 

(919) 629-5615 

re: NESHAP and NSPS sources 

• 1012 NESHAP sources as of end of 1st quarter 1986 

• 2804 NSPS sources as of end of 1st quarter 1986 

Gary McCutcheon - North Carolina Date: March 10, 1986 

Control Programs Development Division 

OAQPS, Pollutant Assessment Branch 

(919) 541-5591 

re: PSD and NSR Air Permits (made under SIPs) 

• Attainment area -- PSD (prevention of significant deterioration) 

• Non-attainment area -- NSR (new source review) (more stringent 

requirements) 

• Radian Corp estimates: 

100-400 NRS and PSD permits issued each year for entire facility 

(each facility has an average 1-1/2 units) 

200-250 is average number permits issued yearly 

2/3 of all permits (NSR and PSD) are for major modifications 

rather than for new source 

• Estimated 15-20,000 new sources per year (major modification 

included); many of these avoid NSR because they emit just under the 

cutoff. If these were included, there would probably be 10 times as 

many per year. 

Mike Mundell Date: February 21 & 27, 1986 

Enforcement and Permitting 

475-8324 

I. NPDES: broken down into municipal and non-municipal sources 

Direct Discharges 

a. municipal (POTWs) - includes major and minor: 15,740 with permits 

b. non-municipal - includes major and minor: 48,462 with permits 
P.3 

1986 

-3-

Andy Huddock 

Water Enforcement and Permitting 

382-7745 

Date: February 27, 1986 

II. INDIRECT discharges 

a. covered by pretreatment program: 

(1) categorical industrial sources:* 

(suspected to be low) 

(2) additional significant indirects 

not governed by categories: 

b. not covered by pretreatment program 

14,000 subject to pretreatment standards 

6000-7000 but subject to 

pretreatment 

program 

no data; includes car washes, restaurants, etc. 

could push total number of indirect discharges to 200,000 

Categories arranged by SIC code and process; (approximate) 26 categories,