DAQ-2025-002820

.i f"r'*\
April2l,2025
l
Viq Electronic & Overnight Mail
Utah Division of Air Quality (
Minor Source Compliance Section
Attn: Chad Gilgen I
195 North 1950 West
Salt Lake City, UT
Subject: Compliance Advisory - Hydro Extrusion USA, LLC - Unrecycled Aluminum Scrap
Production - Condition ILB.l.b of the Approval Order DAQE-AN 108470016-22 - Utah
County
Dear Mr. Gilgen:
On behalf of Hydro Extrusion USA, LLC's Spanish Fork, Utah facility (Hydro), please allow this
letter to serve as Hydro's written response to the above-referenced Compliance Advisory issued by
the Utah Division of Air Quality (UDAQ). Hydro received the Compliance Advisory on
April 8, 2025. Hydro's response is timely submitted.
The Compliance Advisory alleges a potential violation of Condition II.B.l.b of ApprovalOrder
DAQE-AN 108470016-22 (AO) based on a stack test report submitted to UDAQ in March 2025 for a
stack test conducted in October 2024.
Hydro conducted the October 2024 stack test to evaluate whether it could increase the amount of
recycled post-consumer scrap, specifically painted scrap, in a furnace charge and maintain the
emission standards under 40 CFR Part 63 Subpart RRR. The AO establishes a site-specific operating
limit of 10% painted scrap of total charge weight per charge. The October 2024 stack test was not a
performance test for the purpose of demonstrating compliance with the emission limits under the AO.
Results of the October 2024 test demonstrated that increasing painted scrap above the AO restriction
of l0o/o painted scrap of total charge weight per charge was in compliance with 40 CFR Part 63
Subpart RRR.
Prior to conducting the October 2024 stack test, Hydro submitted to UDAQ in April 2024 aSite-
Specific Test Plan (test plan) and a letter requesting temporary compliance discretion for the two AO
conditions:(1) Section Il.B.1.b which limits opacity to 10o/o; and (2) Section Il.B.l.e which limits
painted scrap to l0% of total charge weight per charge. Hydro subsequently met with UDAQ staff on
April 16, 2024, to discuss the test plan and request for temporary compliance discretion. Hydro
received verbal approval from UDAQ to proceed during the meeting. Hydro subsequently received
written approval in an email from Mr. Gilgen UDAQ on April 16,2024, and via a letter from UDAQ
dated April 19,2024, from Kyle Greenberg.
As described in Hydro's April I ,2024 letter requesting temporary compliance discretion and the test
plan, the purpose of stack test was to determine emissions while the facility was not operating in
accordance with conditions of the AO. Hydro specifically requested and understood that it had
received compliance discretion from UDAQ for the two AO conditions noted above, allowing the site
to monitor emissions and opacity during a stack test while processing painted scrap levels above the
o-rpRttrtdeut
l0% limit. Because Hydro received UDAQ approval, Hydro did not violate the AO and respectfully
requests the Compliance Advisory to be withdrawn.
Hydro takes compliance very seriously and is fully committed to compliance with all air permitting
requirements and all applicable environmental laws.
If you have any questions, please feel free to contact me directly at385-277-0331.
Respectfully,
Cecil Jacobson
Environmental Engineer
Hydro Extrusion USA, LLC
1550 Hydro Way
Spanish Fork, UT 84660
4129125, 1:12 PM Stale of Utah Mail - DAQE - AN108470016-22; Compliance Advisory - Hydro Extrusion USA, LLC Response Letter
Chad Gilgen <[e-mail]>
DAQE -AN108470016-22; ComplianceAdvisory - Hydro Extrusion USA, LLC
Response Letter
17 messages
Cecil Jacobson <[e-mail]>
To: Chad Gilgen <[e-mail]>
Cc: Kyle Greenberg <[e-mail]>
Dear Mr. Gilgen,
Mon, Apr 21, 2025 at 1:07 PM
Please find attached Hydro Extrusion USA, LLC response letter to the Compliance Advisory (CA) received April 8th,
2025. A copy of the letter has been mailed to your attention for overnight delivery to the UDAQ. Hydro appreciates the
opportunity to respond to the CA and is available for any questions regarding the letter.
Thank you for your consideration,
Cecil Jacobson
Environmenta I Engineer
Hydro Extrusion USA LLC
M: +1 385 277 O33L
O: [phone]L6
e: Cecil.Jacobson@!yd ro.com
ThcVetucofZcro:
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please immediately notify the sender and delete the e-mail and attached documents. Thank you.
A iiif Response Letter to DAQ 4a-25 Compliance Advisory.pdf
Chad Gilgen <[e-mail]>
To: Cecil Jacobson <[e-mail]>
Cc: Kyle Greenberg <[e-mail]>
Wed, Apr 23,2025 at 10:03 AM
https://mail.google.com/mail/u/0/?ik=36f4379000*r;urp=pt&search=all&permthid=thread-f:1830040347351069944&simpl=msg-f:18300403473510699 1t10
4129125, 1:12 PM
Hello Cecil,
State of Utah Mail - DAQE - AN108470016-22; Compliance Advisory - Hydro Extrusion USA, LLC Response Letter
I have reviewed your response to the Compliance Advisory. Per my email of Aprn | , 2024, and my follow-up email of
April 16, 2024, the compliance discretion by the DAQ was specific to only AO condition ll.B.1 .e allowing the amount of
painted scrap to exceed 10o/o pet charge and did not extend to established opacity limits. Please see attached for that
correspondence.
Thanks,
Chad
Emails to and from this email address may be considered public records and thus subT'ect to Utah GRAMA requirements.
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Gecil J acobson <[e-mail]>
To: Chad Gilgen <[e-mail]>
Cc: Kyle Greenberg <[e-mail]>
Thank you, Chad for the email.
We are reviewing your emailand would like to have fufther discussion.
Thanks again,
Cecil Jacobson
Wed, Apr 23,2025 at 2:50 PM
From: Chad Gilgen <[e-mail]>
Sent: Wednesday, April 23, 2025 10:03 AM
To: Cecil Jacobson <Ceci [e-mail]>
Cc: Kyle Greenberg <kgreenberg@ utah. gov>
Subject: Re: DAQE - AN108470076-22; Compliance Advisory - Hydro Extrusion USA, LLC Response Letter
[This email originated from outside of Hydro. Be carefulwith links and attachments.]
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https://mail.google.com/maiUu/0/?ik=36f4379b00611s\ ,=pt&search=all&permthid=thread-f:1830040347351069944&simpl=msg-f:'18300403473510699. .. 211O
4129125, 1:12 PM State of Utah Mail - DAQE - AN108470016-22; Compliance Advisory - Hydro Extrusion USA, LLC Response Letter
Cecil Jacobson <[e-mail]>
To: Chad Gilgen <[e-mail]>
Fri, Apr 25,2025 al 12:23 PM
Cc: Kyle Greenberg <[e-mail]>, Michele Wood <[e-mail]>, Nicholas Butel
<Nicholas. [e-mail]>, Frank Dougherty <[e-mail]>
Chad,
We at hydro would like to schedule a Teams meeting with Kyle and yourself. ls there a time on Monday that
would work for a short meeting to discuss the Compliance Advisory Letter dated April 3rd, 2025.
Thank you,
CecilJacobson
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Kyle Greenberg <[e-mail]> Fri, Apr 25,2025 at 12:39 PM
To: Chad Gilgen <[e-mail]>
Hi Chad,
I just wanted to let you know l'm using a lot of leave here in the next month. I won't be available 4128 -514;5115 -5125; and
on 5/30.
Kyle
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Of € H vr Kyle Greenberg
Environmental Scientist I Minor Source Compliance
P: (s8s) go6-6sss
airquality.utah.gov
AIR OUALITY
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Chad Gilgen <[e-mail]> Fri, Apr 25,2025 at '12:58 PM
To: Kyle Greenberg <[e-mail]>
HiKyle,
Thanks for the notice. Are you available Monday, May 5 between 9am and 2pm? lf so, let me know a time and I'll
respond back to Cecil proposing that time/date.
Chad
Chad Gilgen I Manager I Minor Source Compliance
385-306-6500 (cell)
AIR
OUALITY
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
https://mail.google.mm/maiUu l0l?ik=3614379010*u;"vv=pt&search=all&permthid=thread-f:1830040347351069944&simpl=msg-f:18300403473510699. . . 3/10
4129125, 1i12PM
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State of Utah Mail - DAQE - AN108470016-22; Compliance Advisory - Hydro Extrusion USA, LLC Response Letter
Chad Gilgen <[e-mail]>
To: Cecil Jacobson <Ceci [e-mail]>
Cc: Kyle Greenberg <[e-mail]>, Michele Wood <[e-mail]>, Nicholas Butel
<Nicholas. [e-mail]>, Frank Doug herty <fdou g [e-mail]>
Hello Cecil,
I am available between 9am - l pm on Monday but I am not sure of Kyle's availability.
Thanks,
Chad
Chad Gilgen I Manager I Minor Source Gompliance
385-306-6500 (cell)
AIR
O UAL ITY
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
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Q
Fri, Apr 25,2025 at 3:20 PM
Kyle Greenberg <[e-mail]>
To: Chad Gilgen <[e-mail]>
Fri, Apr 25,2025 at 3:24 PM
Shoot sorry Chad, I had this email all lined up and ready to send, but didn't send it. I was helping Rik do interviews today
and I have been all over the place. gam to 1 works with my schedule too. I'll reply to the email to let the rest know too.
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Chad Gilgen <[e-mail]>
To: Kyle Greenberg <[e-mail]>
Fri, Apr 25,2025 at 3:26 PM
Hey Kyle,
Thanks, that sounds great. I was just wrapping up for the day and didn't want to leave that request hanging until Monday
with Cecil.
Have a good weekend.
Chad
Chad Gilgen I Manager I Minor Source Compliance
385-306-6500 (cell)
AIR
OUALITY
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
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Q
Kyle Greenberg <[e-mail]>
To: Chad Gilgen <[e-mail]>
Fri, Apr 25,2025 at 3:28 PM
httpsJ/mail.google.com/maiUu l0l?ik=3614379000*u;"*=pt&search=all&permthid=thread-f:1830040347351069944&simpl=msg-f:18300403473510699. .. 4l1O
4129125, 1:12 PM State of Utah Mail - DAQE -AN108470016-22; ComplianceAdvisory - Hydro Extrusion USA, LLC Response Letter
Cc: Cecil Jacobson <[e-mail]>, Michele Wood <[e-mail]>, Nicholas Butel
<[e-mail]>, Frank Dougherty <[e-mail]>
HiCecil,
I will be out of the office all next week, but I am available Monday, May Sth from 9am to 1pm as well.
Thanks,
Kyle
[Quoted text hidden]
Kyle Greenberg
Environmental Scientist I Minor Source Compliance
P: (e8S) 3o6-6533
airquality.utah.gov
AIR OUALITY
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a
il
Cecll Jacobson <[e-mail]>
To: Chad Gilgen <[e-mail]>
Fri, Apr 25,2025 at 3:48 PM
Cc: Kyle Greenberg <[e-mail]>, Michele Wood <[e-mail]>, Nicholas Butel
<[e-mail]>, Frank Dougherty <[e-mail]>
Thanks Chad,
I understand that Kyle will not be able to meet Monday the 28th but if it is ok with you, we would like to meet Monday at
9:00. Please let me know if that is acceptable and we will send out a Teams meeting invite.
Thanks
CecilJacobson
From: Chad Gilgen <[e-mail]>
Sent: Friday, April 25, 2025 3:20:07 PM
To: Cecil Jacobson <[e-mail]>
Cc: Kyle Greenberg <[e-mail]>; Michele Wood <[e-mail]>; Nicholas Butel
<N icholas. Butel@hyd ro.com >; Fra nk Do u gherty <fdou g herty@a l14 i n c.com >
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Nicholas Butel <[e-mail]>Fri, Apr 25,2025 at 4:39 PM
To: CecilJacobson <[e-mail]>, Chad Gilgen <[e-mail]>
Cc: Kyle Greenberg <[e-mail]>, Michele Wood <[e-mail]>, Frank Dougherty
<fdoug [e-mail] >
HiAII,
My apologies for having scheduling conflicts, if we would like to go ahead with Monday, would 10 or noon
mountain work?
Thanks,
-Nick
https://mail.google.com/mail/u l0l?ik=36t4379010*u;"w=pt&search=all&permthid=thread-f:1830040347351069944&simpl=msg-f:'18300403473510699. .. 5/10
4129125,1:12 PM
Nick Butel
State of Utah Mail - DAQE - AN108470016-22; Compliance Advisory - Hydro Extrusion USA, LLC Response Letter
Sr. Environmental Engineer
Envi ronmental Engineeri ng
M: [phone]
nicholas. butel@hyd ro.com
Hydro
Hydro Extrusion USA, LLC
www.hydro.com
G
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Ghad Gilgen <[e-mail]>Sun, Apr 27,2025 at 1:18 PM
To: Nicholas Butel <[e-mail]>
Cc: Cecil Jacobson <[e-mail]>, Kyle Greenberg <[e-mail]>, Michele Wood
<[e-mail]>, Frank Dougherty <[e-mail]>
Hello,
Let's do 12:00 PM on Monday April 28.
Thanks,
Chad
On Apr 25,2025, at 4:39 PM, Nicholas Butel <[e-mail]> wrote:
HiAII,
My apologies for having scheduling conflicts, if we would like to go ahead with Monday, would
10 or noon mountain work?
Thanks,
-Nick
Nlck Butel
Sr. Environmental Engineer
Envi ronmental Engineeri ng
M: [phone]
https://mail.google.com/mail/u l0l?ik=36t4379OOOUu;"w=pt&search=all&permthid=thread-f:1830040347351069944&simpl=msg-f:18300403473510699... 6i 10
4129125, 1:12PM State of Utah Mail - DAQE -AN108470016-22; ComplianceAdvisory- Hydro Extrusion USA, LLC Response Letter
n [e-mail]
Hydro
Hydro Extrusion USA, LLC
www.hydro.com
<imageOO1.png>
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Cecil Jacobson <[e-mail]>
To: Chad Gilgen <[e-mail]>, Nicholas Butel<[e-mail]>
Cc: Kyle Greenberg <[e-mail]>, Michele Wood <[e-mail]>
<fdoug [e-mail]>
Thanks Chad
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Mon, Apr 28,2025 at 7:48 AM
, Frank Dougherty
Ghad Gilgen <[e-mail]>
To: Kyle Greenberg <[e-mail]>
Mon, Apr 28,2025 at 12:31 PM
Hey Kyle,
Disregard my text messages. ljust went through the email correspondence here and realized I misread your response
from last week. I thought you were available today.
Anyway, I met with the Hydro gfoup and they are wanting to see what they can do to clear up the Compliance Advisory. I
told them I'd check in with you and get back to them so I guess let's talk when you're back next week.
Thanks,
Chad
Chad Gilgen ! Manager I Minor Source Compliance
385-306-6500 (cell)
Emails to and from this emailaddress may be considered public records and thus subject to Utah GMMA requirements.
https://mail.google.com/maiUu l0l?ik=3614379*OUr;"vv=pt&search=all&permthid=thread-f:'1830040347351069944&simpl=msg-f:18300403473510699... 7110
4129125, 1:12PM
lQuoted text hiddenl
State of Utah Mail - DAQE -AN108470016-22; ComplianceAdvisory - Hydro Extrusion USA, LLC Response Letter
Chad Gilgen <[e-mail]>Mon, Apr 28,2025 at '12:33 PM
To: Cecil Jacobson <[e-mail]>
Cc: Nicholas Butel <[e-mail]>, Kyle Greenberg <[e-mail]>, Michele Wood
<[e-mail]>, Frank Dougherty <[e-mail]>
Hello Everyone,
Thanks for the call today. Per our discussion, I will check in with Kyle when he's back to work on Monday, May 5 and we
will get back to you after that regarding the Compliance Advisory.
Chad
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
Cecil Jacobson <Ceci [e-mail]>Mon, Apr 28,2025 at 3:23 PM
To: Chad Gilgen <[e-mail]>
Cc: Nicholas Butel <[e-mail]>, Kyle Greenberg <[e-mail]>, Michele Wood
<[e-mail]>, Frank Dougherty <fdougherty@a l14i nc.com>
Thank you, Chad, for the calltoday. After you have a chance to check up with Kyle, we would like to offer
another meeting with you and Kyle to answer questions regarding the compliance advisory. Please let us
know when you would like to meet.
Thanks again,
Cecil Jacobson
From: Chad Gilgen <[e-mail]>
Sent: Monday, April 28,202512:33 PM
To: Ceci I J acobson <Ceci l. J acobson@ hyd ro. com>
Cc: Nicholas Butel <[e-mail]>; Kyle Greenberg <[e-mail]>; Michele Wood
< M ichele.Wood@ hyd ro.com>; Fra n k Dough erty <fdougherty@a ll4inc.com>
Subject: Re: DAQE - AN1084700t6-22; Compliance Advisory - Hydro Extrusion USA, LLC Response Letter
[This email originated from outside of Hydro. Be careful with links and attachments.]
Hello Everyone,
Thanks for the call today. Per our discussion, I will check in with Kyle when he's back to work on Monday, May 5 and we
will get back to you after that regarding the Compliance Advisory.
https://mail.google.com/mail/u/0/?ik=36f4379b466r;eyy=pt&search=all&permthid=thread-f:1830040347351069944&simpl=msg-f:18300403473510699. . .
4129125,1i12PM
Chad
State of Utah Mail - DAQE -AN108470016-22; ComplianceAdvisory - Hydro Extrusion USA, LLC Response Letter
Chad Gllgen I Manager I Mlnor Source Compllance
385-3066500 (cell)
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Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requircments.
[Quoted text hidden]
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