Mr. Gary Barnett

Director, Environmental Compliance & Audit

Aleris International, Incorporated 

25825 Science Park Drive, Suite 400

Beachwood, Ohio 44122-7392

Dear Mr. Barnett:

Thank you for your efforts in assisting with the March 16, 2010, site visit by U.S. 

Environmental Protection Agency (EPA) and RTI personnel to the Aleris International facility in 

Morgantown, Kentucky. We appreciate the time that you and other representatives at Aleris 

International set aside for discussing and showing your manufacturing process.

Enclosed is a draft of the trip report (Enclosure 1) that has been prepared based on the 

information obtained during our site visit. We would appreciate your reviewing the report for 

any errors or omissions. You may return the enclosed copy of the report with your written 

comments. Since this report will eventually become a part of the public record, we want to 

portray your operations as accurately as possible. A copy of the final version of the report 

incorporating your comments will be sent to you for your records. 

The custody receipt for the trip report is also enclosed (Enclosure 2). Please sign and date 

the form to acknowledge receipt of the report and return a copy of the form to: 

Mr. Roberto Morales; U.S. EPA Mailroom (C404-02); U.S. Environmental Protection Agency; 

Office of Air Quality Planning and Standards; 109 T.W. Alexander Drive; Research Triangle 

Park, NC 27711.

If you believe that disclosure of any specific information contained in the trip report 

would reveal trade secrets or other confidential information, you should clearly identify the 

specific information. Please do not label the entire report as “confidential” if only certain 

portions consist of trade secret information. If the EPA determines that there is a need to disclose 

such information, we will need, at that time, the following to support your claim:

1. Measures taken by Aleris International to guard against undesired disclosure of the 

specific information to others;

2. The extent to which the specific information has been disclosed to others and the 

precautions taken in connection therewith;
OAQPS/SPPD/MMG:RBoyd D243-02, 541-1390

(RTI/DGreen/316-3412/7/22/10)

3. Pertinent confidentiality determinations, if any, by other Federal agencies (furnish a 

copy of any such determination, or reference to it, if available); and

4. Whether Aleris International asserts that disclosure of the specific information would 

be likely to result in substantial harmful effects on Aleris International’s competitive position, 

and, if so, what those harmful effects would be, why they should be viewed as substantial, and an 

explanation of the causal relationship between disclosure and such harmful effects.

Any specific information subsequently determined to constitute a trade secret will be 

protected under 18 U.S.C. 1905. If no claim of confidentiality accompanies the information 

when it is received by EPA, it may be made available to the public by EPA without further 

notice (40 CFR Part 2.203, September 1, 1976). Any specific information subsequently

determined to constitute a trade secret will be protected under 18 U.S.C. 1905. However, all 

emissions data will be available to the public. A clarification of the information EPA considers to 

be emissions data is contained in Enclosure 3.

We respectfully request that you submit your review comments on the trip report by

August 26, 2010. If you concur with the information contained in the report, we would 

appreciate a letter to that effect. In addition, please indicate in your letter the specific parts of the 

report, if any, that Aleris International considers to be confidential. If we do not receive a 

response by August 26, 2010, the report will be considered non-confidential and accurate.

Thank you for your cooperation. The information supplied by Aleris International will be 

most helpful in our study. If you have any questions, please call Ms. Rochelle Boyd of my staff 

at (919) 541-1390, or Mr. David Green at RTI at (919) 316-3412.

Sincerely,

Susan Fairchild

Group Leader

Metals and Minerals Group

Office of Air Quality Planning and Standards

3 Enclosures