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July 28, 1989 Request for PSD
Applicability Determination Golden Aluminum Company, San Antonio,
Texas 3.34
Golden Aluminum facility is properly considered a
"secondary metal production plant". Although
little guidance towards defining "secondary metal
production plant" exists, either in the Clean Air
Act, the federal PSD regulations, or even in the
legislative history, Golden Aluminum's plant is
the type of source Congress that intended to be
covered by the PSD provisions of the Act, because
the proposed plant would emit several thousand
tons of particulates without control equipment.
Also, EPA interprets the congressional intent as
based upon the source's pollutant emitting
activity (e.g., smelting) rather than the source's
finished product.
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