July 21, 2011

Golden Aluminum

1405 East 14 th Street
Fort Lupton, Colorado 80621

We are small entity that traces its heritage to the early acceptance of the aluminum can as a viable package. We benefited from the large amount of research and development o f a blossoming industry. The proposal for controls to conform to NESHAPS 1999 came during a time when 400 facilities were counted as Secondary Aluminum Processors. Engineering companies that developed and installed control devises could count on sales to a large field. Today the number has been reduced to 150 , as stated in our information packet. As the field shrinks the opportunity to access engineering expertise and equipment sized to small entity needs becomes difficult and costly

.
The control devices th at are currently in use at our facility were designed and installed by companies that are no longer in business. Broadening of regulations that may result in new control technologies must be shouldered by a shrinking field of players. Proper sized control devices for small entities may have a greater relative cost than that to larger producers.
When preparing for our stack test ICR, we questioned that some of the requested tests were for HAPs that would not be present at ambient temperature because of their volatility. Our scrap feed material consists of mainly of UBC (used beverage containers) and flashing/ webbing produced after a can body or lid is stamped from an aluminum sheet. Our inquiries were answered with these HAPS are indeed identified as of inter est in secondary aluminum emissions. It brings to mind the broad types of scrap materials that are available in this industry. With the universal use of aluminum as containers, pipe, and manufactured equipment, we have no doubt that aluminum and volatiles have come together ; that at some point these items are scrapped . Alloys that such items are made from would not be suitable for our end product mix.
A concern must be that requirements to control HAPs unique to identifiable types of scrap will be
requ ired industry wide, particularly by entities that do not count on scrapped equipment as suitable, determined by end use.
Looking thru the list of SER, it is indeed a diverse group. To exist in 2011 economy a small entity has to work hard to shoulder its way in to viability. Location, access to feed stock, customer relationships, energy availability, transportation all are of extreme importance, as they are to all industry. A small entity is without the benefit of corporate strength, size and bargaining power. Fi lling niche markets , as product makers and scrap receivers , has put pressure on the small entities that still exist. Small entities must retain the ability to change quickly to fill market voids, while maintaining environmental compliance.
Small entity div ersity ensures the primary test objective stated on page 19 “Speciated HAP Data Re presentative of the Industry” will be a considerable challenge.We received SECAL

- ANPR Amendments memo 9

- 30

- 2009 as an attachment to Mr Jutras’s e

- mail 7

- 19

-

2011.

We would l ike to provide the following observations:

SECTION 1
Group 1 furnace definition includes “ or processes clean charge with reactive flux ” which leads to confusion concern ing regulation for Area Sources that are responsible for only D/F under Subpart RRR

.
Aff ected Source definition added to 63.1503 that provides clarity with respect to Subpart RRR.
Capture and Collection Systems All existing capture collection systems have been designed using ACGIH Ventilation Manual 23 rd Edition criteria. We would like to express caution in developing a replacement. The replacement must be a tool that allows for the development of system design to meet real world applications. It should not be a restrictive document that specifies pattern s for hood/system manufacture

.
Resid ence time for afterburners There should be allowance in the residence time calculations for

s ystem des igns that continually loop heated air from the afterburner to the kiln and return to the afterburner

.
SECTION 4
Frequency of testing The clarification of “regardless of levels of emissions”. Is this referring to Major/Area Source distinction?
Additional Data Collected During Performance tests

..... testing and documentation of flow rate for each hood and capture collection system during performance testin g . These are satisfied by meeting design parameters. This adds cost to testing that is unnecessary.

Hood Performance Tests See above.

SECTION 5
Multiple Control Devices

...... calculations for individual furnaces ducted to a common control device.
Clarify c alculations for emissions post control device. Emissions from i ndividual furnaces ducted to a common control device may be calculated in terms of mass charge to the control device

.
Thank

- you for the o pportunity to comment in the SBAR process.

Don Forchette

Golden Aluminum Inc.