  SEQ CHAPTER \h \r 1 

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;

	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

OAQPS/SPPD/MMG:RBoyd D243-02, 541-1390

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

