The two GM facilities which are
programmed together, have dedicated
railway service between them, but are
located a mile apart, should be
considered one source for the purpose of
PSD review. Since the switch will not
cause any creditable increases, it is
not subject to PSD. The definition of
source under PSD has 3 criteria:
- Common Industrial Grouping
- Common ownership or control
- Contiguous or adjacent sites
The facilities in question, without argument,
meet the first two criteria. And, based on
the unique set up of these facilities EPA
considers them adjacent and therefore can be
considered one source for PSD.
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