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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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