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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@Southwire.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 aluminum 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 

outcome 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 blower/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 experience 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 likely 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 be 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 furnace 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. These 
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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 factors, 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

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

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http://www.southwire.com/legal/email_disclaimer.html

>>> 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 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@Southwire.com>

To: 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 when 
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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 this correct? 

Thanks, 

Paul 

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

>>> 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

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

----- 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 impacts 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