July 21, 2011

Golden Aluminum 

1405 East 14th 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 of 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 that 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 interest 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 

required 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 into 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. Filling 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 diversity ensures the primary test objective stated on page 19 “Speciated HAP Data 

Representative 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 like to provide the following observations:

SECTION 1

Group 1 furnace definition includes “or processes clean charge with reactive flux” which leads to 

confusion concerning regulation for Area Sources that are responsible for only D/F under Subpart RRR.

Affected 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 23rd 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 patterns for hood/system 

manufacture.

Residence time for afterburners There should be allowance in the residence time calculations for 

system designs 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 testing. 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 calculations for emissions post control device. Emissions from individual furnaces ducted to a 

common control device may be calculated in terms of mass charge to the control device.

Thank-you for the opportunity to comment in the SBAR process.

Don Forchette

Golden Aluminum Inc.