From: Bo Quick <Bo.Quick@southwire.com>

Sent: Friday, September 13, 2013 2:01 PM

To: Boyd, Rochelle

Subject: RE: Southwire

Rochelle:

The calculations below are correct, except they are only for the furnace stacks themselves. We also attempted to estimate fugitive emissions based on the 2007 testing. Please see the attached 

where we walk through our approach/calculations. If you have any questions, please let me know.

Thanks...Bo

From: Boyd, Rochelle [mailto:Boyd.Rochelle@epa.gov] 

Sent: Thursday, September 12, 2013 7:56 PM

To: Bo Quick

Subject: FW: Southwire

FYI, please review the data below for accuracy. Thanks

Rochelle Boyd, Environmental Engineer

U.S. EPA

109 T.W. Alexander Drive 

Mail Code (D243-02)

Research Triangle Park, NC 27711

PH: 919-541-1390 Fax: 919-541-3207
From: Laney, Michael N. <mnl@rti.org>

Sent: Thursday, September 12, 2013 1:37 PM

To: Boyd, Rochelle

Cc: Bahner, Mark A.

Subject: FW: Southwire stuff for Thursday

Rochelle,

We used data from Southwire’s 2011 test report to calculate D/F emissions rates. Given some of the assumptions we made to derive those and because the values we calculated are much lower 

than those from their ICR, it would be a good idea to send them to Southwire either to confirm the numbers or to correct them. We also included what we currently have in the modeling 

calculation file. If they have questions about any of this, if you want, you can put them in touch with either me or Mark.

Southwire Co. Kentucky Plant, November 2011 Test Report

Furnace #1 Melter/Holder Furnace #5 Melting Furnace #2 Data Source

Net sample time (avg) 192.5 min 3.208333 hr 436 min 7.266667 hr 191.5 min 3.191667 hr Tables 3-1, 3-4, 3-7

D/F TEQ (avg) 5.56E-07 gr/hr

3.27E05 gr/hr9.63E07 gr/hr Tables 3-1, 3-4, 3-7

Total Charge (avg) 87506 lb 43.753 tons 40200 lb 20.1 tons 80560 lb 40.28 tons

App. A, Melting Furnace #1 Process 

Data

Calc. charge/hr 13.6373 tons/hr 2.766055 tons/hr 12.62037 tons/hr Calculated

Calc. TEQ gr/ton 4.08E-08 TEQ gr/ton 1.18E-05

TEQ 

gr/ton 7.63E-08

TEQ 

gr/ton Calculated

CalcTEQ ug/Mg 2.91E-03 TEQ ug/Mg 8.44E-01

TEQ 

ug/Mg 5.45E-03

TEQ 

ug/Mg Calculated
Current Modeling File

C

Mike Laney

RTI International

3040 Cornwallis Rd

PO Box 12194

Research Triangle Park, NC 27709

Phone: 919-316-3413

Fax: 919-316-3420

It's always greener on the other side with Southwire, Reduce, Reuse, Recycle!

Please click on this hyperlink to read our e-mail security disclaimer: 

http://www.southwire.com/legal/email_disclaimer.html
Section 4 - Test Results

4.1 Rod Mill 1 Analytical Results

The process data for M1 and ACD1 is contained in Tables 4-1 and 4-2. The analytical results from the 

testing event conducted November 1-2, 2011 on RM1 are restated in Tables 4-3 through 4-6. A complete 

copy of the Stack Test Results is included in Appendix C, and a summary of the production data and 

emissions calculations are included in Appendix D of this document.

Table 4-1

Summary Results: M1 Process Conditions

Run

Duration 

(min)

Molten 

Primary 

Metal 

(lb)

Outside 

Scrap 

(lb)

Cold 

Primary 

Metal 

(lb)

Alloy 

Addition

(lb)

Flux 

Addition 

(lb)

Total 

Furnace 

Charge 

(tons)

Scrap 

Content 

(%)

1 187.5 76,220 15,411 0 0 0 45.82 16.8

2 202.5 72,435 18,596 0 0 0 45.52 20.4

3 187.5 61,515 18,341 0 0 0 39.93 23.0

Average -- -- -- -- -- -- 43.75 20.0

Table 4-2

Summary Results: RM1 and ACD1 Process Conditions

Run

Duration 

(min)

Average 

Casting 

Rate (fpm)

Average 

Casting 

Rate1

(ton/hr)

Total

Charge1

(tons/test)

ACD Cl2

Injection 

Rate 

(ml/min)

ACD Cl2

Injection 

Rate

(lb/hr)

ACD Cl2

Injection 

Rate

(lb/ton Al)

1 180 50.0 15.64 46.94 1908 0.767 0.049

2 180 47.6 14.89 44.67 2047 0.823 0.055

3 180 48.0 15.02 45.06 2077 0.835 0.055

Average -- 48.5 15.18 -- 2011 -- 0.053

1 The ACD charge rate was calculated based on the casting speed that was monitored and recorded electronically during the 3 hour tests

and the density of the aluminum bar cast (0.869 lbs/linear inch). 

The emissions from M1 were determined by collecting samples from the furnace stack and estimating 

fugitive emissions as discussed in Section 2.3 and demonstrated in Appendix H. Total emissions 

calculations are also calculated below: 
Southwire charged approximately 20% outside scrap or “other than clean charge” in melting furnace M1

during the 2011 CPT. For the 2007 event, the facility charged approximately 12% outside scrap. SCKP

charged 25-50 lb of dry reactive flux per run to the furnace during the 2007 CPT; however, SCKP elected 

to not charge any dry reactive flux during the 2011 CPT as the facility no longer uses this material during 

the production process. Otherwise, SCKP operated the furnace during the 2011 CPT under the same 

conditions as the 2007 test event. Therefore, to estimate emissions associated with the 2011 CPT, the 

2007 emissions were adjusted to account for the difference in scrap charge rate and flux addition rate. 

Conservatively using the test run with the highest fugitive emissions (Run 1 or R1) of the three 2007 test 

runs for each parameter, Southwire estimates M1 fugitive emissions as follows:

2007 CPT – M1 worst case

M1 R1 Flux: 75 lb

M1 R1 Scrap: 10,100 lb

M1 R1 Fugitive Emissions: 2.58 lb PM; 1.15 lb HCl; 1.75E-04 grains D/F

M1 R1 Flux Emission Factor: 3.44E-02 lb PM/lb flux; 1.68E-02 lb HCl/lb flux; 

2.33E-06 grains D/F/lb flux

M1 R1 Scrap Emission Factor: 2.55E-04 lb PM/lb scrap; 1.14E-04 lb HCl/lb scrap; 

1.73E-08 grains D/F/lb scrap

2011 CPT – Average of 3 Runs

M1 Flux: TBDFLUX = 0 lb

M1 Scrap: TBDSCRAP = 17,449 lb

Difference between 2011 CPT and 2007 CPT

M1 Additional Flux: (TBDFLUX – 75 lb) = (0 lb – 75 lb) = -75 lb*

M1 Additional Scrap: (TBDSCRAP – 10,100 lb) = (17,449 lb – 10,100 lb) = 7,349 lb

*Value assumed to be “0” because difference is calculated to be negative.

M1 Fugitive Emissions = [M1 R1 Fugitive Emissions + (M1 R1 Flux Emission Factor x M1 Additional Flux) 

+ (M1 R1 Scrap Emission Factor x M1 Additional Scrap)]

M1 Fugitive PM2011 = [2.58 lb PM + (3.44E-02 lb PM/lb flux x 0 lb flux) 

+ (2.55E-04 lb PM/lb scrap x 7,349 lb scrap)] = 4.45 lb PM

M1 Fugitive HCl2011 = [1.15 lb HCl + (1.68E-02 lb HCl/lb flux x 0 lb flux) 

+ (1.14E-04 lb HCl/lb scrap x 7,349 lb scrap)] = 1.99 lb HCl

M1 Fugitive D/F2011 = [1.75E-04 gr D/F TEQ + (2.33E-06 gr D/F TEQ/lb flux x 0 lb flux) 

+ (1.73E-08 gr D/F TEQ/lb scrap x 7,349 lb scrap)] = 3.01E-04 gr D/F TEQ
Table 4-3

Furnace M1 Summary Results: HCl Emissions

Run

Furnace 

Stack 

Emissions

(lb/hr)

Mass of 

Stack 

Emissions 

(lb) 1

Mass of 

Fugitive 

Emissions

(lb)

Total Mass 

of Emissions 

(lb) 2

Emission 

Rate 

(lb/ton 

charged) 3

NESHAP 

Limit 

(lb/ton 

charged)

1 0.010 0.031

2 0.007 0.024

3 0.020 0.063

Average 0.012 0.04 1.99 2.03 0.05 0.40

1 Calculated by multiplying the stack emission rate (lb/hr) by the length of each tested period (hours) as given in Table 4-1.

2 Calculated by summing the average mass of stack emissions and average mass of fugitive emissions.

3 Calculated by dividing the average total mass of emissions (lb) by the average charge weight (tons). 

Table 4-4

Furnace M1 Summary Results: PM Emissions

Run

Furnace 

Stack 

Emissions

(lb/hr)

Mass of 

Stack 

Emissions 

(lb)

Mass of 

Fugitive 

Emissions

(lb)

Total Mass 

of Emissions 

(lb) 1

Emission 

Rate 

(lb/ton 

charged)

NESHAP 

Limit 

(lb/ton 

charged)

1 0.553 1.728

2 0.515 1.738

3 0.725 2.266

Average 0.598 1.91 4.45 6.36 0.15 0.40

Table 4-5

Furnace M1 Summary Results: D/F TEQ Emissions

Run

Furnace 

Stack 

Emissions 

(lb TEQ/hr)

Mass of Stack 

Emissions 

(grains TEQ)

1

Mass of 

Fugitive

Emissions 

(grains TEQ)

Total Mass 

D/F TEQ 

Emitted 

(grains)

Emission 

Rate 

(grain 

TEQ/ton 

charged)

NESHAP 

Emission 

Rate (grains

TEQ/ton 

charged)

1 5.91E-11 1.29E-6

2 5.52E-11 1.30E-6

3 1.24E-10 2.71E-6

Average 7.94E-11 1.77E-6 3.01E-04 3.03E-04 6.93E-06 2.10E-04

1 Total D/F emissions are being reported in grains for consistency with the secondary aluminum NESHAP limits. 

ACD1, as a continuous process, was sampled for three hours per test run. 
Table 4-6

ACD1 Summary Results: HCl and PM Emissions

Run

HCl

Emissions 

(lb/hr)

HCl 

Emissions 

(lb/ton)

NESHAP 

PM Limit 

(lb/ton)

PM 

Emissions 

(lb/hr)

PM

Emissions 

(lb/ton)

NESHAP 

PM Limit 

(lb/ton)

1 0.569 0.036 0.974 0.062

3 0.591 0.040 0.504 0.034

4 0.582 0.039 0.599 0.040

Average 0.581 0.038 0.04 0.692 0.045 0.01

4.2 Rod Mill 2 Analytical Results

Process data for M3 and ACD2 is provided in Tables 4-7 and 4-8. The analytical results from the testing 

event conducted December 6-7, 2011 on RM2 are restated in Tables 4-9 through 4-12. A complete copy 

of the Source Emission Evaluation Report and a summary of the production data, and emissions 

calculations are included in Appendix C and Appendix D of this document.

Table 4-7

Summary Results: M3 Process Conditions

Run

Duration 

(min)

Molten 

Primary 

Metal 

(lb)

Outside 

Scrap 

(lb)

Cold 

Primary 

Metal 

(lb)

Alloy 

Addition

(lb)

Flux 

Addition 

(lb)

Total 

Furnace 

Charge 

(tons)

Scrap 

Content 

(%)

1 191 67,090 16,188 0 0 0 41.64 19.4

2 196.5 57,625 17,504 2,595 0 0 38.86 22.5

3 187 61,755 16,218 2,705 0 0 40.34 20.1

Average -- -- -- -- -- -- 40.28 20.7

Table 4-8

Summary Results: RM2 and ACD2 Process Conditions

Run

Duration 

(min)

Average 

Casting 

Rate (fpm)

Average 

Casting 

Rate1

(ton/hr)

Total

Charge1

(tons/test)

ACD Cl2

Injection 

Rate 

(ml/min)

ACD Cl2

Injection 

Rate

(lb/hr)

ACD Cl2

Injection 

Rate

(lb/ton Al)

1 180 44.0 15.62 46.86 2051 0.825 0.053

2 180 44.0 15.62 46.86 2049 0.824 0.053

3 180 43.8 15.55 46.65 1962 0.790 0.051

Average -- 43.9 15.59 -- 2021 -- 0.052

1 The ACD charge rate was calculated based on the casting speed that was monitored and recorded electronically during the 3 hour tests

and the density of the aluminum bar cast (0.986 lbs/linear inch). 
Emissions from M3 were determined by collecting samples from the furnace stack and estimating fugitive 

emissions as discussed in Section 2.3 and demonstrated in Appendix H. Total emissions calculations are 

also calculated below: 

Southwire charged approximately 20% outside scrap or “other than clean charge” in melting furnace M3

during the 2011 CPT. Also, SCKP elected to not charge any dry reactive flux during the 2011 CPT. 

Otherwise, SCKP operated furnace M3 during the 2011 CPT under essentially the same conditions as 

furnace M1 the 2007 test event. 

Because of the operational similarities between the secondary aluminum emission units in Rod Mill 1 and 

Rod Mill 2, the measured emissions from Melter 1 are predictive of the emissions expected from Melter 

3. In fact, the total emissions would be expected to be the same from Melter 1 and Melter 3 up to and 

until the charge materials and solid flux amounts charged in Melter 3 exceed the amounts tested in the 

CPT on Melter 1. From that point, the fugitive emissions from Melter 3 could be accurately estimated by 

adding a calculated amount of emissions, based on the pounds of additional divisional scrap (i.e., off-site 

scrap) and solid flux that are added, to the base fugitive emissions established from the CPT on Melter 1. 

Once the charge door is closed, the emissions from Melter 3 would be captured and measured as part of 

the main furnace stack emissions. 

M3 and M1 only differ significantly in the size of the charge door. As discussed in Appendix H, 

Southwire is estimating the increase in fugitive emissions measured and the fugitive emission factors 

calculated from the CPT on Melter 1 by 25% to conservatively approximate the fugitive emissions from 

Melter 3 during compliance testing. This factor (1.25 multiplier) addresses the physical difference in the 

door sizes of the two furnaces and allows the fugitives from Melter 3 to be estimated using test data from 

Melter 1.

In summary, Southwire is calculating Melter 3 fugitive emissions using the same approach as outlined for 

Melter 1 in Section 4.1 above, with the application of a 1.25 multiplier as described by the following 

equation. 

M3 Fugitive Emissions = [M1 R1 Fugitive Emissions + (M1 R1 Flux Emission Factor x M3 Additional Flux) + (M1 

R1 Scrap Emission Factor x M3 Additional Scrap)] x 1.25

2007 CPT – M1 worst case

M1 R1 Flux: 75 lb

M1 R1 Scrap: 10,100 lb

M1 R1 Fugitive Emissions: 2.58 lb PM; 1.15 lb HCl; 1.75E-04 grains D/F

M1 R1 Flux Emission Factor: 3.44E-02 lb PM/lb flux; 1.68E-02 lb HCl/lb flux; 

2.33E-06 grains D/F/lb flux

M1 R1 Scrap Emission Factor: 2.55E-04 lb PM/lb scrap; 1.14E-04 lb HCl/lb scrap; 

1.73E-08 grains D/F/lb scrap
2011 CPT – Average of 3 Runs

M3 Flux: TBDFLUX = 0 lb

M3 Scrap: TBDSCRAP = 16,637 lb

Difference between 2011 CPT and 2007 CPT

M3 Additional Flux: (TBDFLUX – 75 lb) = (0 lb – 75 lb) = -75 lb*

M3 Additional Scrap: (TBDSCRAP – 10,100 lb) = (16,637 lb – 10,100 lb) = 6,537 lb

*Value assumed to be “0” because difference is calculated to be negative.

M3 Fugitive PM2011 = [2.58 lb PM + (3.44E-02 lb PM/lb flux x 0 lb flux) 

+ (2.55E-04 lb PM/lb scrap x 6,537 lb scrap)] x 1.25 = 5.31 lb PM

M3 Fugitive HCl2011 = [1.15 lb HCl + (1.68E-02 lb HCl/lb flux x 0 lb flux) 

+ (1.14E-04 lb HCl/lb scrap x 6,537 lb scrap)] x 1.25 = 2.37 lb HCl

M3 Fugitive D/F2011 = [1.75E-04 gr D/F TEQ + (2.33E-06 gr D/F TEQ/lb flux x 0 lb flux) 

+ (1.73E-08 gr D/F TEQ/lb scrap x 6,537 lb scrap)] x 1.25 = 3.60E-04 gr D/F TEQ

Table 4-9

Furnace M3 Summary Results: HCl Emissions

Run

Furnace 

Stack 

Emissions

(lb/hr)

Mass of 

Stack 

Emissions 

(lb) 1

Mass of 

Fugitive 

Emissions

(lb)

Total Mass 

of Emissions 

(lb) 2

Emission 

Rate 

(lb/ton 

charged) 3

NESHAP 

Limit 

(lb/ton 

charged)

1 0.004 0.013

2 0.009 0.029

3 0.013 0.041

Average 0.009 0.03 2.37 2.40 0.06 0.40

1 Calculated by multiplying the stack emission rate (lb/hr) by the length of each tested period (hours) as given in Table 4-7.

2 Calculated by summing the average mass of stack emissions and average mass of fugitive emissions.

3 Calculated by dividing the average total mass of emissions (lb) by the average charge weight (tons). 

Table 4-10

Furnace M3 Summary Results: PM Emissions

Run

Furnace 

Stack 

Emissions

(lb/hr)

Mass of 

Stack 

Emissions 

(lb)

Mass of 

Fugitive 

Emissions

(lb)

Total Mass 

of Emissions 

(lb) 1

Emission 

Rate 

(lb/ton 

charged)

NESHAP 

Limit 

(lb/ton 

charged)

1 0.15 0.48

2 0.39 1.28

3 0.21 0.65

Average 0.25 0.80 5.31 6.11 0.15 0.40
Table 4-11

Furnace M3 Summary Results: D/F TEQ Emissions

Run

Furnace 

Stack 

Emissions 

(lb TEQ/hr)

Mass of Stack 

Emissions 

(grains TEQ)1

Mass of 

Fugitive 

Emissions 

(grains TEQ)

Total Mass 

D/F TEQ 

Emitted 

(grains)

Emission 

Rate 

(grain 

TEQ/ton 

charged)

NESHAP 

Emission 

Rate (grains 

TEQ/ton 

charged)

1 6.65E-11 1.48E-6

2 2.73E-10 6.26E-6

3 7.35E-11 1.60E-6

Average 1.38E-10 3.11E-6 3.60E-04 3.63E-04 9.01E-06 2.10E-04

1 Total D/F emissions are being reported in grains for consistency with the secondary aluminum NESHAP limits. 

As a continuous process, ACD2 was sampled for three hours per test run. 

Table 4-12

ACD2 Summary Results: HCl and PM Emissions

Run

HCl 

Emissions 

(lb/hr)

HCl 

Emissions 

(lb/ton)

NESHAP 

PM Limit 

(lb/ton)

PM 

Emissions 

(lb/hr)

PM 

Emissions 

(lb/ton)

NESHAP 

PM Limit 

(lb/ton)

1 0.371 0.024 1.252 0.080

3 0.373 0.024 0.854 0.055

4 0.444 0.029 0.882 0.057

Average 0.396 0.025 0.04 0.996 0.064 0.01

4.3 Rod Mill 3 Analytical Results

Process data for H5 and ACD3 is contained in Tables 4-13 and 4-14. The analytical results from the 

testing event conducted November 8-10, 2011 on RM3 are summarized in Tables 4-15 through 4-18. A 

copy of the Source Emission Evaluation Report and a summary of the production data and emissions 

calculations are included in Appendix C and Appendix D.
Table 4-13

Summary Results: H5 Process Conditions

Run

Duration 

(min)

Molten 

Primary 

Metal 

(lb)

Outside 

Scrap 

(lb)

Cold 

Primary 

Metal 

(lb)

Alloy 

Addition

(lb)

Flux 

Addition 

(lb)

Total 

Furnace 

Charge 

(tons)

Scrap 

Content 

(%)

1 428 27,035 10,337 0 961 50 19.19 26.9

2 467 29,875 10,425 0 1001 25 20.62 25.2

3 413 29,525 10,317 0 1024 25 20.45 25.2

Average -- -- -- -- -- -- 20.09 25.8

Table 4-14

Summary Results: RM3 and ACD3 Process Conditions

Run

Duration 

(min)

Average 

Casting 

Rate (fpm)

Average 

Casting 

Rate1

(ton/hr)

Total 

Charge1

(tons/test)

ACD Cl2

Injection 

Rate 

(ml/min)

ACD Cl2

Injection 

Rate 

(lb/hr)

ACD Cl2

Injection 

Rate 

(lb/ton Al)

1 442 40.0 4.18 30.79 2781 0.767 0.27

2 465 37.9 3.96 30.69 2860 0.823 0.29

3 420 44.0 4.60 32.20 3276 0.835 0.29

Average -- 40.6 4.25 -- 2972 -- 0.28

1 The ACD charge rate was calculated based on the casting speed that was monitored and recorded electronically during the tests

and the density of the aluminum bar cast (0.291 lb/linear inch). 

The ACD was tested as a continuous operating unit processing at a sustained, constant molten metal 

throughput rate over the entire test period. The emissions from the ACD are discharged via an exhaust 

duct to the H5 stack and, thus, were measured as a component of the combined H5 stack sample. 

Therefore, SCKP also collected samples in the ACD duct in order to evaluate compliance as an 

independent emission source. To calculate HCl and PM emission factors for the furnace alone for use in 

the SAPU calculation equations, the mass of emissions from the ACD was calculated for the furnace 

compliance performance test period using the independent ACD sampling data. The ACD’s emissions 

were subtracted from the mass of emissions measured at the combined roof stack. This yielded the 

emissions attributed to the furnace operation alone emitted through the combined roof stack. Emissions 

of D/F were measured from the H5 stack only.

Emissions from H5 were determined by collecting samples from the furnace stack and estimating fugitive 

emissions as discussed in Section 2.3 and demonstrated in Appendix H. Total emissions calculations are 

also calculated below: 

Southwire charged approximately 25% outside scrap or “other than clean charge” in furnace H5 during 

the 2011 CPT. For the 2007 event, the facility charged approximately 23% outside scrap. SCKP charged 
25-50 lb of dry reactive flux per run to the furnace during the 2007 CPT, and similar quantities of the 

same flux were charged during the 2011 CPT. Otherwise, SCKP operated the furnace during the 2011 

CPT under the same conditions as the 2007 test event. Therefore, to estimate emissions associated with 

the 2011 CPT, the 2007 emissions were adjusted to account for the difference in scrap charge rate and 

flux addition rate. Conservatively using the test run with the highest fugitive emissions of the three 2007 

test runs for each parameter, Southwire estimates H5 fugitive emissions as follows:

2007 CPT – H5 worst case

M1 Flux: 50 lb (R1)

M1 Scrap: 10,930 lb (R2)

M1 Fugitive Emissions: 1.91 lb PM (R2); 1.53 lb HCl (R1); 1.15E-04 grains D/F (R2)

M1 R1 Flux Emission Factor: 7.63E-02 lb PM/lb flux (R2); 5.46E-02 lb HCl/lb flux (R2); 

4.59E-06 grains D/F/lb flux (R2)

M1 R1 Scrap Emission Factor: 1.75E-04 lb PM/lb scrap (R2); 2.13E-04 lb HCl/lb scrap (R1); 

1.13E-08 grains D/F/lb scrap (R1)

2011 CPT – Average of 3 Runs

H5 Flux: TBDFLUX = 33 lb

H5 Scrap: TBDSCRAP = 10,360 lb

Difference between 2011 CPT and 2007 CPT

H5 Additional Flux: (TBDFLUX – 50 lb) = (33 lb – 50 lb) = -17 lb*

H5 Additional Scrap: (TBDSCRAP – 10,930 lb) = (10,360 lb – 10,930 lb) = -570 lb*

*Value assumed to be “0” because difference is calculated to be negative.

H5 Fugitive Emissions = [H5 Max Fugitive Emissions + (H5 Max Flux Emission Factor x H5 Additional Flux) 

+ (H5 Max Scrap Emission Factor x H5 Additional Scrap)]

H5 Fugitive PM2011 = [1.91 lb PM + (7.63E-02 lb PM/lb flux x 0 lb flux) 

+ (1.75E-04 lb PM/lb scrap x 0 lb scrap)] = 1.91 lb PM

H5 Fugitive HCl2011 = [1.53 lb HCl + (5.46E-02 lb HCl/lb flux x 0 lb flux) 

+ (2.13E-04 lb HCl/lb scrap x 0 lb scrap)] = 1.53 lb HCl

H5 Fugitive D/F2011 = [1.15E-04 gr D/F TEQ + (4.59E-06 gr D/F TEQ/lb flux x 0 lb flux) 

+ (1.13E-08 gr D/F TEQ/lb scrap x 0 lb scrap)] = 1.15E-04 gr D/F TEQ
Table 4-15

Furnace H5 Summary Results: HCl Emissions

Run

Combined 

Furnace & 

ACD

Emissions

(lb/hr)

Mass of 

Combined 

Furnace & 

ACD

Emissions

(lb) 1

Average 

Mass of 

Furnace

Emissions 

(lb) 2

Mass of 

Fugitive 

Emissions

(lb)

Total Mass 

of 

Emissions 

(lb) 3

Emission 

Rate 

(lb/ton 

charged) 4

NESHAP 

Limit 

(lb/ton 

charged)

1 0.83 5.92

2 0.53 4.13

3 0.47 3.24

Average 0.61 4.43 1.36 1.53 2.89 0.14 0.40

1 Calculated by multiplying combined furnace & ACD stack emission rate (lb/hr) by length of each furnace test (hr) as given in Table 4-13.

2 Calculated by subtracting mass of ACD emissions (from Table 4-18) from combined furnace & ACD stack emission.

3 Calculated by summing the average mass of stack emissions and average mass of fugitive emissions.

4 Calculated by dividing the average total mass of emissions (lb) by the average charge weight (tons). 

Table 4-16

Furnace H5 Summary Results: PM Emissions

Run

Combined 

Furnace & 

ACD

Emissions

(lb/hr)

Mass of 

Combined 

Furnace 

& ACD

Emissions

(lb)

Average 

Mass of 

Furnace

Emissions 

(lb)

Mass of 

Fugitive 

Emissions

(lb)

Total Mass 

of 

Emissions 

(lb) 1

Emission 

Rate 

(lb/ton 

charged)

NESHAP 

Limit 

(lb/ton 

charged)

1 2.95 21.04

2 0.90 7.01

3 0.45 3.10

Average 1.43 10.38 5.91 1.91 7.82 0.39 0.40

Table 4-17

Furnace H5 Summary Results: D/F TEQ Emissions

Run

Furnace 

Stack 

Emissions 

(lb TEQ/hr)

Mass of Stack 

Emissions 

(grains TEQ)1

Mass of 

Fugitive 

Emissions 

(grains TEQ)

Total Mass 

D/F TEQ 

Emitted 

(grains)

Emission 

Rate 

(grain 

TEQ/ton 

charged)

NESHAP 

Emission 

Rate (grains 

TEQ/ton 

charged)

1 6.60E-09 3.30E-04

2 6.65E-09 3.62E-04

3 7.66E-10 3.69E-05

Average 3.72E-09 2.43E-04 1.15E-04 3.58E-04 1.78E-05 2.10E-04

1 Total D/F emissions are being reported in grains for consistency with the secondary aluminum NESHAP limits. 
ACD3 was sampled for the length of the furnace batch per test run to allow the measured ACD emissions 

contribution to be subtracted from the combined stack sample. This yields the furnace emissions from the 

combined stack. 

Table 4-18

ACD3 Summary Results: HCl and PM Emissions

Run

HCl 

Emissions 

(lb/hr)

Mass of 

HCl 

Emissions 

(lb)

HCl 

Emissions 

(lb/ton)

NESHAP 

PM 

Limit 

(lb/ton)

PM 

Emissions 

(lb/hr)

Mass of 

PM 

Emissions 

(lb)

PM 

Emissions 

(lb/ton)

NESHAP 

PM 

Limit 

(lb/ton)

1 0.505 3.72 0.121 0.586 4.32 0.140

3 0.348 2.70 0.088 0.284 2.20 0.072

4 0.399 2.79 0.087 0.984 6.89 0.214

Average 0.42 3.07 0.098 0.04 0.62 4.47 0.142 0.01

4.4 SAPU Limits and Results Evaluation 

In 2007, Southwire determined that the most advantageous way for SCKP to demonstrate compliance 

with the NESHAP regulations was for the facility to combine the Group 1 furnaces (M1, M2, H5, and 

H6) and the in-line fluxers (ACD1, ACD2, and ACD3) into a single SAPU, and utilize the equations in 40 

CFR 63.1505(k)(1)and (2) to calculate the limits for PM and HCl emissions. With the 2011 NESHAP 

CPT, SCKP also tested M3 and, under a separate submittal, SCKP is notifying DAQ that the facility 

intends to exercise the alternative operating scenario in the facility’s permit to reclassify M3 from a 

Group 2 furnace to a Group 1 furnace.

Thus, SCKP is requesting approval from the agency to modify the existing SAPU (including Group 1 

furnaces M1, M2, H5, and H6 and in-line fluxers ACD1, ACD2 and ACD3) to also include furnace M3, 

in accordance with 40 CFR 63.1505(k)(6), such that they may be combined into a new SAPU. The 

results obtained during the 2011 CPT are calculated and compared to the SAPU limits for PM and HCl in 

Table 4-19. The facility will maintain records of the 3-day, 24-hour rolling average PM and HCl 

emission calculations versus the PM and HCl limits established during the CPT.

To demonstrate compliance, the calculation of the SAPU limits and the tested emission rate results for 

PM and HCl are described below. From 40 CFR 63.1505(k) Equation 1, the PM limit for the SAPU is 

calculated by adding the allowable particulate emissions contribution from each of the Group 1 furnaces 

[(0.40 lbs PM per ton of feed/charge) x (furnace charge rate during the performance tests in tons/hr)] and 

the allowable particulate emissions contribution from the in-line fluxers [(0.01 lbs PM per ton of 

feed/charge) x (ACD charge rate during the performance tests in tons/hr)]. These allowable particulate 

emissions are then divided by the sum of the average charge rates to the furnaces (tons/hr) and the ACDs

(tons/hr) during the performance tests to establish the PM limit from the CPT in pounds per ton charge. 
From the CPT, the calculated PM limit for the facility’s SAPU is (calculated using the MACT emission 

rate applicable to each emission unit);

M1 (0.40 lb/ton x 13.64 ton/hr) + 

M2 (0.40 lb/ton x 13.64 ton/hr) + 

M3 (0.40 lb/ton x 12.63 ton/hr) + 

H5 (0.40 lb/ton x 2.77 ton/hr) + 

H6 (0.40 lb/ton x 2.77 ton/hr) +

ACD1 (0.01 lb/ton x 15.19 ton/hr) + 

ACD2 (0.01 lb/ton x 15.59 ton/hr) + 

ACD3 (0.01 lb/ton x 4.25 ton/hr) 

M1 (13.64 ton/hr) + M2 (13.64 ton/hr) + M3 (12.63 ton/hr) + H5 (2.77 ton/hr) + = 0.23 lb PM/ton

H6 (2.77 ton/hr) + ACD1 (15.19 ton/hr) + ACD2 (15.59 ton/hr) + ACD3 (4.25 ton/hr)

Using 40 CFR 63.1505(k) Equation 2, the calculated HCl limit for the facility’s SAPU is (calculated using the MACT 

emission rate applicable to each emission unit);

M1 (0.40 lb/ton x 13.64 ton/hr) + 

M2 (0.40 lb/ton x 13.64 ton/hr) + 

M3 (0.40 lb/ton x 12.63 ton/hr) + 

H5 (0.40 lb/ton x 2.77 ton/hr) + 

H6 (0.40 lb/ton x 2.77 ton/hr) +

ACD1 (0.04 lb/ton x 15.19 ton/hr) + 

ACD2 (0.04 lb/ton x 15.59 ton/hr) + 

ACD3 (0.04 lb/ton x 4.25 ton/hr)

M1 (13.64 ton/hr) + M2 (13.64 ton/hr) + M3 (12.63 ton/hr) + H5 (2.77 ton/hr) + = 0.24 lb HCl/ton

H6 (2.77 ton/hr) + ACD1 (15.19 ton/hr) + ACD2 (15.59 ton/hr) + ACD3 (4.25 ton/hr)

Similarly, as per 40CFR 63.1513(e) Equation 9, the mass weighted SAPU PM emissions are calculated 

by adding the CPT measured furnace PM emission rates (lb/ton of feed/charge) multiplied by the charge

rates from the furnaces during the CPT [(lb PM per ton of feed/charge) x (furnace charge rate (tons/hr)] 

and the CPT measured ACD PM emission rates (lb/ton of feed/charge) multiplied by the charge rates

from the ACDs during the CPTs [(lb PM per ton of feed/charge) x (ACD charge rate (tons/hr)]. These 

measured emissions are then divided by the sum of the charge rates to the furnaces and the ACDs during 

the performance test. 

From the CPTs, the measured PM emission rate for the facility’s SAPU is (calculated using the emission rate 

demonstrated during each performance test event);
M1 (0.15 lb/ton x 13.64 ton/hr) + 

M2 (0.15 lb/ton x 13.64 ton/hr) + 

M3 (0.15 lb/ton x 12.63 ton/hr) + 

H5 (0.39 lb/ton x 2.77 ton/hr) + 

H6 (0.39 lb/ton x 2.77 ton/hr) +

ACD1 (0.045 lb/ton x 15.19 ton/hr) + 

ACD2 (0.064 lb/ton x 15.59 ton/hr) + 

ACD3 (0.142 lb/ton x 4.25 ton/hr) 

M1 (13.64 ton/hr) + M2 (13.64 ton/hr) + M3 (12.63 ton/hr) + H5 (2.77 ton/hr) + = 0.13 lb PM/ton

H6 (2.77 ton/hr) + ACD1 (15.19 ton/hr) + ACD2 (15.59 ton/hr) + ACD3 (4.25 ton/hr)

Using 40CFR 63.1513(e) Equation 10, the measured HCl emission rate for the facility’s SAPU is (calculated using the 

emission rate demonstrated during each performance test event);

M1 (0.05 lb/ton x 13.64 ton/hr) + 

M2 (0.05 lb/ton x 13.64 ton/hr) + 

M3 (0.06 lb/ton x 12.63 ton/hr) + 

H5 (0.15 lb/ton x 2.77 ton/hr) + 

H6 (0.15 lb/ton x 2.77 ton/hr) +

ACD1 (0.038 lb/ton x 15.19 ton/hr) + 

ACD2 (0.025 lb/ton x 15.59 ton/hr) + 

ACD3 (0.098 lb/ton x 4.25 ton/hr)

M1 (13.64 ton/hr) + M2 (13.64 ton/hr) + M3 (12.63 ton/hr) + H5 (2.77 ton/hr) + = 0.05 lb HCl/ton

H6 (2.77 ton/hr) + ACD1 (15.19 ton/hr) + ACD2 (15.59 ton/hr) + ACD3 (4.25 ton/hr)

As allowed under 40 CFR 63.1505(k)(4), SCKP demonstrated that the D/F emissions from the Group 1 

furnaces in the facility SAPU comply as individual emission units with the D/F limit established in 40 

CFR 63.1505(i)(3). 

Table 4-19

SCKP SAPU Summary- NESHAP Limits vs. Test Result

Parameter

(EPA Test Method) SAPU Limit 1 CPT Result 2 Compliant?

PM (Method 5) 0.23 lb/ton 0.13 lb/ton YES

HCl (Method 26A) 0.24 lb/ton 0.05 lb/ton YES

1 Calculated as required by 40 CFR 63.1505(k)(1) Equation 1 for PM, and (k)(2) Equation 2 for HCl.

2 Calculated as required by 40 CFR 63.1513(e)(1) Equation 9 for PM, and (e)(2) Equation 10 for HCl.

For the conditions found in the Secondary Aluminum NESHAP, results show that the facility SAPU 

emissions from the Group 1 furnaces using other than clean charge materials (M1, M2, M3, H5, and H6) 

and the in-line fluxers (ACD1, ACD2, and ACD3) meet the secondary aluminum NESHAP requirements 

for all parameters tested.