1 From: Rochelle Boyd [Boyd.Rochelle@epamail.epa.gov]

Sent: Wednesday, July 13, 2011 11:02 AM

To: Paul Sims

Cc: Bo Quick

Subject: Re: Fw: Subpart RRR Testing Enclosures

Thanks, this is very helpful. I appreciate your time and effort in explaining your experience with this testing process. l will

contact Bo as well. Thanks

Rochelle Boyd, Environmental Engineer

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards

Sector Policies and Programs Division

109 T.W. Alexander Drive, RTP, NC 27711

Mail Drop D243

- 02

Ph: (919) 541

- 1390 Fax: (919) 541

- 3207

Email: boyd.rochelle@epa.gov

From: "Paul Sims" <paul_sims@South wire.com>

To: Rochelle Boyd/RTP/USEPA/US@EPA

Cc: "Bo Quick" <bo_quick@Southwire.com>

Date: 07/13/2011 10:53 AM

Subject: Re: Fw: Subpart RRR Testing Enclosures

Rochelle,

As you probably are aware, we have constructed temporary testing capture systems at Southwire's al uminum rod mill in

Hawesville, KY. All nine of our existing furnaces at that location are uncontrolled. When we were performing Subpart

RRR emissions testing in the 2006/2007 time frame, KY DEP and US EPA raised concerns about fugitive emissions. An

out come of our discussions with the agencies to resolve their concerns was that we agreed to include fugitive emissions

in our testing protocol for those furnaces designated as Group 1.

For one typical furnace, our efforts to capture the fugitive emissions consisted of the following activities at the

approximate costs as noted:

1. Design of the temporary hood capture system by a consultant

- $11,000

2. Fabrication and installation of the hood and duct work by a contractor

- $50,000

3. Purchase of the bl ower/fan

- $15,000

The sum of the above is $76,000 for one furnace, and this doesn't include (i) any internal expenses for activities for which

we used our own resources and (ii) the actual emissions testing expense.

Considerations from our experie nce that we believe to be noteworthy for existing furnaces are:

- Temporary Installations

- Add

- on capture devices for testing purposes generally are temporary installations that must

be removed after completion of testing. Permanent installations li kely would be considerably more expensive than noted

above because the design and installation would be much more complicated.

- Safety Concerns

- The temporary capture devices can create safety concerns because work practices and material

flow must b e modified to perform routine job functions in and around the hood and its supporting structure.

- Unique Systems

- Typically each furnace requires a unique capture system design because furnace access, door

dimensions, and other factors vary from fur nace to furnace. In other words, we were generally unable to directly use the

blowers, hooding, duct work, etc. at other furnaces.

- Our Experience

– While our Kentucky Plant has 9 furnaces, we only conducted stack tests on 2 units in 2007. These2 2 units were representative of 2 other units, giving us a total of 4 Group 1 furnaces. Operationally, we would have liked

to have some or all of our remaining furnaces classified as Group 1 units as well. However, we elected not to do so for a

number of fa ctors, namely the safety concerns around testing for fugitive emissions and the additional cost burden.

If you have any additional inquiries, please contact Bo Quick at Southwire. Bo is familiar with the operations and

emissions testing protocol at our Kentucky plant and he is very familiar with Subpart RRR. I copied Bo on this response;

his direct contact information is bo_quick@southwire.com and his direct tel. no. is 770

- 832

- 4657.

I hope you find this information helpful.

Sincerely

Paul

Paul N. Sims, P.E.

Director, Environmental Affairs

Southwire Company

1 Southwire Drive

Carrollton, GA 30119

tel. no. 770

- 832

- 4679

fax no. 770

- 832

- 5630

paul_sims@southwire.com



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>>> Rochelle Boyd <Boyd.Rochelle@epamail.epa.gov> 7/11/2011 12:09 PM >>>

Exactly.

Rochelle Boyd, Environmental Engineer

U.S. Environmental Protection Agency

Office of Ai r Quality Planning and Standards

Sector Policies and Programs Division

109 T.W. Alexander Drive, RTP, NC 27711

Mail Drop D243

- 02

Ph: (919) 541

- 1390 Fax: (919) 541

- 3207

Email: boyd.rochelle@epa.gov

From: "Paul Sims" <paul_sims@Southwire.com>

T o: Rochelle Boyd/RTP/USEPA/US@EPA

Date: 07/11/2011 12:07 PM

Subject: Re: Fw: Subpart RRR Testing Enclosures



### Rochelle,

I am working on it now and plan to have the info to you in the next day or so. Just to be sure we get the correct

info, let me clarify what I think you are seeking. With an uncontrolled furnace, one can sample and test the

emissions from the furnace stack, but there is no way to capture fugitive emissions that exit the furnace when3 

### the furnace doors are temporarily opened to add metal and/or flux and generally work the melt (i.e., remove

dross, etc.). In order to include these fugitive emissions, one must construct a capture hood with ductwork, etc.

What I understand you to be seeking is the cost to design, construct, and install a capture device (for example, a

hood) to include these fugitive emissions. Is th is correct?

Thanks,

Paul

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

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- mail security disclaimer:

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>>> Rochelle Boyd <Boyd.Rochelle@epamail.epa.gov> 7/11/2011 11:38 AM >>>

Have you had a chance to look up those costs? Thanks

Rochelle Boyd, Environmental Engineer

U.S. Environmental Protection Agency

Of fice of Air Quality Planning and Standards

Sector Policies and Programs Division

109 T.W. Alexander Drive, RTP, NC 27711

Mail Drop D243

- 02

Ph: (919) 541

- 1390 Fax: (919) 541

- 3207

Email: boyd.rochelle@epa.gov

----- Forwarded by Rochelle Boyd/RTP/USEPA/US on 07/11/2011 11:37 AM

-----

From: Rochelle Boyd/RTP/USEPA/US

To: paul_sims@southwire.com

Date: 07/01/2011 01:49 PM

Subject: Subpart RRR Testing Enclosures

Hi, Mr. Sims, I am looking to get cost of construction and testing of uncontrolled furnaces. Do you have any cost

estimates? We are looking to see what the possible impact s would be if we require this as part of our rule amendment

proposal in November. Thanks

Rochelle Boyd, Environmental Engineer

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards

Sector Policies and Programs Division

109 T .W. Alexander Drive, RTP, NC 27711

Mail Drop D243

- 02

Ph: (919) 541

- 1390 Fax: (919) 541

- 3207

Email: boyd.rochelle@epa.gov