### 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, Ro chelle [ 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 Engi neer
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 valu es 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 3.27E

05 gr/hr 9.63E

07 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 d ata for M1 and ACD1 is contained in Table s 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

emissio ns 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 ACD 1 Process Conditions

Run Duration

(min) Average

Casting Rate (fpm) Average

Casting

Rate 1
( ton /hr ) Total

Charge 1
(tons/test) ACD Cl 2

Injection

Rate (ml/min) ACD Cl 2

Injection

Rate ( lb/hr ) ACD Cl 2

Injection

Rate ( lb/ton Al )

1 1 80 50.0 15.64 46.94 1908 0.767 0.049

2 1 80 47.6 14.89 44.67 2047 0.823 0.055

3 1 80 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 charge d 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 operate d 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 est imate s 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. 68 E

- 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: TBD FLUX 

### = 0 lb M1 Scrap: TBD SCRAP 

### = 17,449 lb

Difference between 2011 CPT and 2007 CPT
M1 Additional Flux: (TBD FLUX 

### – 75 lb) = (0 lb

– 75 lb) =

- 75 lb* M1 Additional Scrap: (TBD SCRAP 

### – 10,100 l b) = (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 PM 2011 = [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 HCl 2011 = [ 1.15 lb HCl + ( 1.68 E

- 02 lb HCl /lb flux x 0 lb flux) + ( 1.14 E

- 04 lb HCl

/lb scrap x 7,349 lb scrap)] = 1. 9 9 lb HCl

M1 Fugitive D/F 2011 = [ 1.75E

- 04 gr D/F TEQ + ( 2.33 E

- 0 6 gr D/F TEQ /lb flux x 0 lb flux) + ( 1.73 E

- 0 8 gr D/F TEQ

/lb scrap x 7,349 lb scrap)] = 3.01E

- 04 gr D/F TEQTable 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 C alculated by multiplying the stack emission rate ( lb/hr) by the length of each tested period (hours) as given in Table 4

- 1.

2 C alculated by summing the average mass of stack emissions and average mass of fugitive emissions

. 3 C alculated by dividing the average total mass of emissions (lb) by th e 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 1.7 2 8

2 0.515 1.738

3 0.725 2.266

Average 0. 598 1.9 1 4.45 6.3 6 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 5.91 E

- 11 1 .29E

- 6

2 5.52 E

- 1 1 1

. 3 0E

- 6

3 1.24 E

- 10 2.71 E

- 6

Average 7.94 E

- 1 1 1.77 E

- 6 3.01E

- 04 3. 03 E

- 04 6.93 E

- 06 2.10E

- 04

1 Total D/F emissions are being reported in grains for consistency with the sec ondary 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 0.97 4 0.0 62

3 0.591 0.040 0.504 0.0 34

4 0.582 0.039 0.599 0.0 4 0

Average 0.581 0.038 0.04 0.69 2 0.0 45 0.01



## 4.2 Rod Mill 2 Analytical Results

Process data for M 3 and ACD 2 is provid ed in Table s 4

- 7 and 4

- 8 . The analytical results from the testing

event conducted Dec ember 6

- 7 , 2011 on RM 2 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: M 3 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, 7 55 16,218 2,705 0 0 40.34 20.1

Average

-- -- -- -- -- -- 40.28 20. 7



### Table 4

- 8
Summary Results: RM 2 and ACD 2 Process Conditions

Run Duration

(min) Average

Casting Rate (fpm) Average

Casting

Rate 1
( ton /hr ) Total

Charge 1
(tons/test) ACD Cl 2

Injection

Rate (ml/min) ACD Cl 2

Injection

Rate ( lb/hr ) ACD Cl 2

Injection

Rate ( lb/ton Al )

1 1 80 44.0 15.6 2 46. 86 2051 0.825 0.053

2 1 80 44.0 15.62 46.86 2049 0.824 0.053

3 1 80 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 hou r tests and the density of the aluminum bar cast (0. 9 86 lbs/linear inch).

### E missions from M 3 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 M 3
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 condition s 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 fro m 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 conservativ ely 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 fr om

Melter 1.

In summary, Southwire is c alculat ing 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 M 3 Additional Flux) + (M1 R1 Scrap Emission Factor x M 3 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: TBD FLUX 

### = 0 lb M3 Scrap: TBD SCRAP 

### = 16,637 lb

Difference between 2011 CPT and 2007 CPT
M3 Additional Flux: (TBD FLUX 

### – 75 lb) = (0 lb

– 75 lb) =

- 75 lb* M3 Additional Scrap: (TBD SCRAP 

### – 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 PM 2011 = [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 HCl 2011 = [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/F 2011 = [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. 60 E

- 04 gr D/F TEQ

Table 4

- 9

Furnace M 3 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 0.0 04 0.0 13

2 0.009 0.029

3 0.013 0.041

Average 0.009 0.0 3 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 M 3 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 0.40Table 4

- 11

Furnace M 3 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 6.65 E

- 1 1 1.48 E

- 6

2 2.7 3 E

- 10 6.2 6 E

- 6

3 7.35 E

- 1 1 1.60 E

- 6

Average 1. 38E

- 10 3.1 1E

- 6 3. 60 E

- 04 3. 6 3 E

- 04 9.0 1 E

- 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
ACD 2 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 0.0 80

3 0. 373 0.024 0. 85 4 0.0 55

4 0. 444 0.029 0. 882 0.0 57

Average 0. 396 0.025 0.04 0. 996 0.0 64 0.01



## 4.3 Rod Mill 3 Analytical Results

Process d ata for H5 and ACD3 is contained in Table s 4

- 13 and 4

- 14 . The analytical results from the
testing event conducted November 8

- 10, 2011 on RM3 are summarized in Tables 4

- 1 5 through 4

- 1 8

. 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 1 0,425 0 1001 25 20.62 25.2

3 413 29,525 1 0,317 0 1024 25 20.45 25.2

Average

-- -- -- -- -- -- 20.09 2 5.8

Table 4

- 14 Summary Results: RM3 and ACD3 Process Conditions

Run Duration

(min) Average

Casting Rate (fpm) Average

Casting

Rate 1
(ton /hr) Total

Charge 1
(tons/test) ACD Cl 2

Injection

Rate (ml/min) ACD Cl 2

Injection

Rate (lb/hr) ACD Cl 2

Injection

Rate (lb/ton Al)

1 442 4 0.0 4.18 30.79 2781 0.767 0.27

2 465 37.9 3.96 30.69 2 860 0.823 0. 29

3 420 4 4 .0 4.60 32.20 3276 0.835 0. 29

Average

-- 40.6 4.25

-- 2 972

-- 0. 2 8

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 com ponent of the combined H5 stack sample.

Therefore, SCKP also col lected samples in the ACD duct in order to evaluate compliance as an
independent emission source. To calculate HCl and PM emission factor s for the furnace alone for use in

the SAPU calculati on 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 estim ating 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 201 1 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 add ition 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: TBD FLUX 

### = 33 lb

H5 Scrap: TBD SCRAP 

### = 10,360 lb

Difference between 2011 CPT and 2007 CPT
H5 Additional Flux: (TBD FLUX 

### – 50 lb) = (33 lb

– 50 lb) =

- 17 lb* H5 Additional Scrap: (TBD SCRAP 

### – 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 PM 2011 = [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 HCl 2011 = [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/F 2011 = [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 TEQTable 4

- 15 Furnace H5 Summary Results: HCl Emissions

Run Combined

Furnace &
ACD
Emissions (lb/hr) Mass of

Combin ed

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 0.5 3 4.13

3 0.47 3.2 4

Average 0.61 4.4 3 1. 36 1.53 2. 89 0.1 4 0.40

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

- 13

. 2 C alculated 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

Furna ce 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 6.6 0 E

- 0 9 3.3 0 E

- 04

2 6.6 5 E

- 0 9 3.62 E

- 04

3 7. 66 E

- 10 3.69 E

- 05

Average 3. 72 E

- 0 9 2.43 E

- 04 1.15 E

- 04 3. 5 8 E

- 04 1. 7 8 E

- 0 5 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 emi ssions 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 0.14 0

3 0.348 2.7 0 0.088 0.284 2.2 0 0.072

4 0.39 9 2.7 9 0.08 7 0.9 8 4 6. 89 0.21 4

Average 0.4 2 3.0 7 0.098 0.04 0.6 2 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 2 011 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 request ing 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 comb ined 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

- 1 9 . 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

calcul ated 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 fr om 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 (0.4 0 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)

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

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)

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

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 rate s (lb/ton of feed/charge) multiplied by the charge rate s

from the ACDs during the CP Ts [(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 fac ility’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/t on 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)

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

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 (0.0 38 lb/ton x 15.19 ton/hr) +

ACD2 (0.0 25 lb/ton x 15.59 ton/hr) +

ACD3 (0.0 98 lb/ton x 4.25 ton/hr)

= 0. 05 lb HCl/ton M1 (13.64 ton/hr) + M2 (13.64 ton/hr) + M3 (12.63 ton/hr) + H5 (2.77 ton/hr) +

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

- 1 9 SCKP SAPU Summary

- NESHAP Limits vs. Test Resul 

### t

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

PM (M ethod 5) 0. 23 lb/ton 0. 13 lb/ton YES

HCl (M ethod 26A) 0.2 4 lb/ton 0.0 5 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 seco ndary aluminum NESHAP requirements
for all parameters tested.