From: Bo Quick [ mailto:Bo.Quick@southwire.com ]

Sent: Wednesday, July 18, 2012 2:24 PM

To: Rochelle Boyd

Cc: Bahner, Mark A.; Paul Sims Subject: RE: Southwire 2007 Testing



### Rochelle:

Please see our responses in red in the attached. Please contact us if you need additional information.

Thanks...Bo

Bo Quick Southwire Company

One Southwire Drive
Carrollton, GA 30119

770

- 832

- 4657

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

Sent: Wednesday, July 11, 2012 4:25 PM

To: Paul Sims

Cc: Bo Quick; Bahner, Mark A. Subject: Southwire 2007 Testing

In response to some of the comments that we have received from the Secon dary Aluminum RTR proposal, we have listed some questions in regards to the two compliance tests. If you could respond by July 18th, that would be greatly appreciated. If you have any questions, please contact Mark Bahner at (919)

- 541

- 6016. 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

- 320 7
Email: boyd.rochelle@epa.gov

### DATE: J u ly 11 , 2012

SUBJECT: Questions Concerning Performance Tests Conducted at Southwire Corporation in Hawesville, KY, in 2007

FROM: Mark Bahner, RTI International

TO: Rochelle Boyd, U.S. Environmental Protection Agency

The purpose of this memorandum is to document technical questions related to testing that was conducted at Southwire Corporation in Hawesville, KY, in 2007. All tables are located at the end of the

memorandum. All questions are numbered and in italics.

A

. Background

Tests were conducted o n uncontrolled furnace s at Southwire Corporation in Hawesville, KY. Testing

was also conducted on an in

- line fluxer, but the questions in the memorandum concern the testing

conducted on the furnaces.

Testing was performed for PM, HCl and PCDD/PCDF from April 30

– May 02, 2007 at Furnace #5 in Mill 3, and reported on June 26, 2007. Testing was performed for PM, HCl and PCDD/PCDF from July

17

– 19, 2007 at a Group 1 furnace located in Rod Mill 1 and reported on September 5, 2007. Testing

was performed on a furnace stack and also on a temporary canopy hood, which was installed for the test, to capture emissions not directed through the furnace stack.

A summary of the results of the testing is presented in four tables in Appendix A to this mem orandum.

The four tables are:

Table A1 : This table presents data from the June 26, 2007 report. The data included pollutant emissions in pounds per hour and test sampling time. These are converted into total mass measured, so that the

total emissions from the furnace stack can be compared to the total emissions in the canopy hood stack.

Table A2 : This table presents data from the June 26, 2007 report. The data are exclusively in pounds and the table includes a calculation of the percentage of pollutants e mitted through the canopy hood stack versus the total mass of pollutants emitted through both the canopy hood stack and the furnace

stack.

Table A3: This table presents data from the September 5, 2007 report. The data included pollutant emissions in pound s per hour and test sampling time. These are converted into total mass measured, so that the total emissions from the furnace stack can be compared to the total emissions in the canopy

hood stack

.

Table A4: This table presents data from the September 5, 2 007 report. The data are exclusively in pounds and the table includes a calculation of the percentage of pollutants emitted through the canopy

### 2 hood stack versus the total mass of pollutants emitted through both the canopy hood stack and the

furnace stack.

B

. Furnace and Canopy Hood Sampling Times

One aspect of this testing, regarding sampling time at the canopy hoods versus the furnace stacks, potentially affects the results. In the testing reported on June 26, 2007, sampling at the furnace stack was perf ormed from 7.7 to 8 hours per run, whereas sampling at the canopy hood was performed for 3.0 to 3.33 hours per run. This is consistent with the concept that emissions captured by the canopy hood would only occur during furnace charging, whereas emissions t hrough the furnace stack would occur throughout the cycle (charging, melting, and tapping) which presumably lasted 7.7 to 8.0 hours. However, in the testing reported on September 5, 2007, testing at the furnace stack was performed for 3.2 hours per run, wh ereas testing at the canopy hood was performed for 3.0 hours per run. This could mean that the complete furnace cycle was only 0.2 hours longer than the charging period, or it could be a mistake in the testing reported on September 5, 2007, such that the t esting at the furnace stack did not occur throughout the entire furnace cycle. If the testing reported on September 5th did indeed not sample from the furnace stack through ou t the furnace cycle , then the ratio of emissions in the canopy hood stack

to tota l emissions would be biased high. The testing of the furnace stack on September 5, 2007 apparently was conducted for an average of 3.2 hours per run.

Questions:

1 a ) Was the 3.2 hours of sampling at the furnace stack (in the September 5 report) the entire furnace cycle? Y es. Melter 1 batches are typically around 3 hours or so. The canopy was only tested for 3 hours (minimum required by NESHAP).

2 a ) If not, how long was the furnace cycle? NA 1b) Was the 7.8 hours of sampling at the furnace stack (in th e June 26 report) the entire furnace cycle? Yes. Melter/Holder 5 batches are typically around 8 hours. The canopy was only tested for 3 hours (minimum required by NESHAP).

2 b ) If not, how long was the furnace cycle? NA

C

. Potential Dilution Air in th e Stack

Average temperatures and flow rates during the stack testing were as shown in Table 1

. The flow rates

from the furnaces seem so mewhat large (10210 dscfm and 6197 dscfm, for the June 26, 2007 and September 5, 2007 reports, respectively) and the t emperatures seem somewhat low (307 ° F and 379 ° F, for the June 26, 2007 and September 5, 2007 reports, respectively).

Question:

3) Was there any dilution air in the furnace stacks for either the testing reported on June 26, 2007 or the testing reported o n September 5, 2007? (“Dilution air” means air that is not drawn through the furnace, but instead is introduced into a duct downstream of the furnace, to dilute/cool the furnace exhaust gas

. ) No. However, because Melter/Holder #5 is a tilt furnace, the st ack is not directly connected to the furnace. There is a gap between the furnace opening and canopy to allow for the furnace tilt. Melter #1 has a direct exhaust.

### 3 D

. Potential for Emissions from the Furnace to be Drawn into the Canopy Hoods

The cano py hoods were installed for the purposes of testing. The flow rate to the canopy hoods was larger than the flow rate to the furnace stacks. This raises the possibility that emissions that would normally be drawn into the furnace might actually be drawn int o the canopy hood stacks.

Question:

4 ) Does anyone who witnessed the testing have a memory of furnace emissions that would normally be drawn into the furnace instead being drawn into the canopy hoods ? (It is understandable if no

one who witnessed the tes ting in 2007 can remember such a detail five years later.) Every attempt was made with the temporary system design/installation to capture only emissions that escaped from the furnace doors and not draw any emissions from the furnace itself.

E

. Results in the Form of the Emission Standards

The test reports do not have data reported in the form of the emission standards, which are production

based (i.e., the standards for hydrogen chloride and particulate are in pounds per ton of charge, and the

dioxin/f uran standard is in terms of micrograms per megagram of charge).

Question:

5 ) Is there information available that puts the test results reported on June 26, 2007 and September 5, 2007 into the form of the standards, so that it can be determined how the results compare with

the standards? Yes. See the attached excerpt from our November 2007 OM&M Plan

.

F

. Amount of Time Furnace Doors were Open for Furnace Charging

The amount of time furnace doors are open for furnace charging potentially affects the dis tribution of emissions in the canopy hood stacks versus the furnace stacks.

Question:

6

) Is there any information regarding the amount of time the furnace doors were open for charging during the 2007 tests ? (It may be that there typical times are known for present operation s, even if specific times are not available for the 2007 testing.) No specific information is available.
Melter 1

– furnace doors are open for charging scrap and/or cold metal. This time varies depending on the amount of scrap (num ber of loads). Doors are also opened to stir the batch

and skim dross . For the 2007 testing, the door was also opened to add the dry flux (no longer used)

. Best estimate: the doors were/are open approximately 15 minutes /batch

. Melter/Holder

5

– furnac e doors are open for charging scrap and/or cold metal. This time varies depending on the amount of scrap (number of loads). Doors are also opened to stir the batch

, skim dross, add flux, and add/test alloy agents. Best estimate: the doors were/are open approximately 30

minutes /batch.

### 4 

## List of Tables

Table 1. Southwire Temperature and Flow Rate Summary

................................ ................................ .... 5

Table A1. So uthwire Testing Reported June 26, 2007: Complete Test Results

................................ ........ 7 Table A2. Southwire Testing Reported on June 26, 2007: Results in Pounds

................................ .......... 8 Table A3. Southwire Testing Reported September 5, 2007: Complete Test Results

................................ 9 Table A4. Southwire Testing Reported on September 5, 2007: Results in Pounds

................................ . 10

### 5 Table 1

. Southwire Te mperature and Flow Rate Summary

Test Report Date Sampling Location Average Flow Rate (dscfm) Average Temperature ( ° F)

June 26, 2007 September 2007 Rod Mill 1

– Furnace Stack 10,210 307

June 26, 2007 September 2007 R od Mill 1

– Canopy Hood Stack 23,157 130

September 5, 2007

June 2007 Rod Mill 3

– Furnace 5 Stack (Dirty Charge Test) 6,197 379

September 5, 2007

June 2007 Rod Mill 3

– Canopy Hood Stack (Dirty Charge T est) 27,813 113

### 6 Appendix A

Southwire Test Results

### 7 Table A 1. Southwire Testing Reported June 26, 2007: Complete Test Results

Southwire Testing Reported on June 26, 2007

PM PM HCl HCl TOTAL D/F* TOTAL D/F*

Duration(hr) furnace stack

Run 1 7.70 0.56 #/hr 4.31 lb 0.71 #/hr 5.47 lb 8.69E-08 #/hr 6.69E-07 lb

Run 2 8.00 0.75 6.00 lb 0.7 5.60 lb 7.72E-08 #/hr 6.18E-07 lb

Run 3 7.70 0.57 4.39 lb 0.69 5.31 lb 2.18E-08 #/hr 1.68E-07 lb

Duration(hr) canopy hood

Run 1 3.00 0.32 #/hr 0.96 lb 0.51 #/hr 1.53 lb 3.87E-09 #/hr 1.16E-08 lb

Run 2 3.33 0.58 1.93 lb 0.41 1.37 lb 4.92E-09 #/hr 1.64E-08 lb

Run 3 3.00 0.41 1.23 lb 0.28 0.84 lb 2.95E-09 #/hr 8.85E-09 lb

Total

Run 1 5.27 lb 7.00 lb 6.81E-07 lb

Run 2 7.93 lb 6.97 lb 6.34E-07 lb

Run 3 5.62 lb 6.15 lb 1.77E-07 lb

average 6.27 lb 6.71 lb 4.97E-07 lb * reported as 2378

- TCDD equivalent

### 8 Table A2. Southwire Testing Reported on June 26, 2007: Results in Pounds

Southwire Testing Reported on June 26, 2007

Pollutant Location Units Run 1 Run 2 Run 3 Average

PM Furnace stack lb 4.31 6.00 4.39 4.90

PM Canopy hood lb 0.96 1.93 1.23 1.37

PM Total lb 5.27 7.93 5.62 6.27

PM Furnace stack fraction of total 0.82 0.76 0.78 0.78

PM Canopy hood fraction of total 0.18 0.24 0.22 0.22 22% Avg

PM Total fraction of total 1.00 1.00 1.00 1.00

HCl Furnace stack lb 5.47 5.60 5.31 5.46

HCl Canopy hood lb 1.53 1.37 0.84 1.25

HCl Total lb 7.00 6.97 6.15 6.71

HCl Furnace stack fraction of total 0.78 0.80 0.86 0.81

HCl Canopy hood fraction of total 0.22 0.20 0.14 0.19 19% Avg

HCl Total fraction of total 1.00 1.00 1.00 1.00

Total D/F Furnace stack lb 6.69E-07 6.18E-07 1.68E-07 6.35E-07

Total D/F Canopy hood lb 1.16E-08 1.64E-08 8.85E-09 1.48E-08

Total D/F Total lb 6.81E-07 6.34E-07 1.77E-07 4.97E-07

Total D/F Furnace stack fraction of total 0.98 0.97 0.95 0.97

Total D/F Canopy hood fraction of total 0.02 0.03 0.05 0.03 3% Avg

Total D/F Total fraction of total 1.00 1.00 1.00 1.00

### 9 Table A3. Southwire Testing Reported September 5, 2007: Complete Test Results

Southwire Testing Reported on September 5, 2007

PM PM HCl HCl TOTAL D/F* TOTAL D/F*

Duration(hr) furnace stack

Run 1 3.20 0.61 #/hr 1.95 lb 1.38 #/hr 4.42 lb 2.02E-09 #/hr 6.46E-09 lb

Run 2 3.20 0.49 1.57 lb 0.81 2.59 lb 3.97E-09 #/hr 1.27E-08 lb

Run 3 3.20 0.49 1.57 lb 0.68 2.18 lb 8.31E-10 #/hr 2.66E-09 lb

Duration(hr) canopy hood

Run 1 3.00 0.86 #/hr 2.58 lb 0.38 #/hr 1.14 lb 8.31E-09 #/hr 2.49E-08 lb

Run 2 3.00 0.36 1.08 lb 0.25 0.75 lb 2.20E-09 #/hr 6.60E-09 lb

Run 3 3.00 0.53 1.59 lb 0.28 0.84 lb 1.35E-09 #/hr 4.05E-09 lb

Total

Run 1 4.53 lb 5.56 lb 3.14E-08 lb

Run 2 2.65 lb 3.34 lb 1.93E-08 lb

Run 3 3.16 lb 3.02 lb 6.71E-09 lb

average 3.45 lb 3.97 lb 1.91E-08 lb

### 10 Table A4. Southwire Testing Reported on September 5 , 2007: Results in Pounds

Southwire Testing Reported on September 5, 2007

Pollutant Location Units Run 1 Run 2 Run 3 Average

PM Furnace stack lb 1.95 1.57 1.57 1.70

PM Canopy hood lb 2.58 1.08 1.59 1.75

PM Total lb 4.53 2.65 3.16 3.45

PM Furnace stack fraction of total 0.43 0.59 0.50 0.49

PM Canopy hood fraction of total 0.57 0.41 0.50 0.51 51% Avg

PM Total fraction of total 1.00 1.00 1.00 1.00

HCl Furnace stack lb 4.42 2.59 2.18 3.06

HCl Canopy hood lb 1.14 0.75 0.84 0.91

HCl Total lb 5.56 3.34 3.02 3.97

HCl Furnace stack fraction of total 0.79 0.78 0.72 0.77

HCl Canopy hood fraction of total 0.21 0.22 0.28 0.23 23% Avg

HCl Total fraction of total 1.00 1.00 1.00 1.00

Total D/F Furnace stack lb 6.46E-09 1.27E-08 2.66E-09 1.06E-08

Total D/F Canopy hood lb 2.49E-08 6.60E-09 4.05E-09 1.27E-08

Total D/F Total lb 3.14E-08 1.93E-08 6.71E-09 1.91E-08

Total D/F Furnace stack fraction of total 0.21 0.66 0.40 0.42

Total D/F Canopy hood fraction of total 0.79 0.34 0.60 0.58 58% Avg

Total D/F Total fraction of total 1.00 1.00 1.00 1.00From: Bo Quick [ mailto:Bo.Quick@southwire.com ]

Sent: Wednesday, July 18, 2012 2:25 PM

To: Rochelle Boyd; Paul Sims

Cc: Bahner, Mark A. Subject: RE: Southwire 2007 Testing



### Sorry...Forgot the OM&M Plan attachment.

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

Sent: Wednesday, July 11, 2012 4:25 PM

To: Paul Sims

Cc: Bo Quick; Bahner, Mark A. Subject: Southwire 2007 Testing

In response to some of the comments that we have received from the Secondary Aluminum RTR proposal, we have listed some questions in regards to the two compliance tests. If you could respond by July 18th, that would be greatly appreciated. If you have any questions, please contact Mark Bahner at (919)

- 541

- 6016. Thanks

Roch elle 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
Ema il: boyd.rochelle@epa.gov

# Section 3
Emission Standards

### Table 3-1
Sources and Emission Standards

Affected Emission Unit Emission Standard

### Table 3-1 (continued)
Sources and Emission Standards

Affected Emission Unit Emission Standard

NOTES1 These Group 1 furnaces and ACDs have been combined as a SAPU, and will be monitored to calculate the three-day, 24-hour rolling average emission rates for PM and HCl on a daily basis.

2 The SAPU limits listed were calculated as required by 40 CFR 63.1505(k)(1) Equation 1 for PM and (k)( 2) Equation 2 for HCl, using the feed/charge rate to each emission unit du ring the CPTs.



## 3.1 Emission Limits and Compliance Demonstrations

3.1.1 Rod Mill 1 Analytical Results

### Table 3-2 Summary Results: RM1 Charge Conditions

Run Number 1 Duration of Furnace Testing (min) Furnace M1 Charge (tons/batch) ACD1 Charge 2
(tons/hr)

1 All runs were completed on July 18-19, 2007. The M1 furnace runs were number 1 through 3, the ACD1 runs were 1, 3, & 4. 2 The ACD charge rate was calculated based on the c asting speed that was monitored and recorded electr onically during the 3 hour tests (48 fpm) and the density of the aluminum bar cast (0.869 lbs/linear inch).



### Table 3-3 Furnace M1 Summary Results: HCl Emissions

Run Number HCl Furnace Stack

Emissions (lb/hr) HCl Hood Stack Emissions (lbs/hr) Total Mass of HCl Emissions (lbs) 1 NESHAP HCl Emission Rate (lbs/ton charged) 2

1 The total mass of pollutant emitted for each test run is calculated by multiplying the emission rate for each emission unit (in lbs/hr) by the length of each tested period. The l ength of each furnace test run is given in Table 3- 2; the length of the hood stack
test runs is three hours each. 2 The NESHAP emission factor was calculated by divi ding the total mass of pollutant, in pounds, by the charge weight, in tons.



### Table 3-4 Furnace M1 Summary Results: PM Emissions

Run Number PM Furnace Stack

Emissions (lb/hr) PM Hood Stack Emissions (lbs/hr) Total Mass of PM Emissions (lbs) 1 NESHAP PM Emission Rate (lbs/ton charged) 2

1 The total mass of pollutant emitted for each test run is calculated by multiplying the emission rate for each emission unit (in lbs/hr) by the length of each tested period. The l ength of each furnace test run is given in Table 3- 2; the length of the hood stack
test runs is three hours each. 2 The NESHAP emission factor was calculated by divi ding the total mass of pollutant, in pounds, by the charge weight, in tons.

### Table 3-5 Furnace M1 Summary Results: D/F TEQ Emissions

Run Number D/F TEQ Furnace

Stack Emissions (lb/hr) 1 D/F TEQ Hood Stack

Emissions (lbs/hr) 1 Total Mass D/F TEQ Emitted (grains) 2, 3 NESHAP D/F TEQ
Emission Rate (grains/ton charged) 2, 3

1 As reported in the stack testing report. 2 Total D/F emissions are being reported in grains for consistency with the secondary aluminum NESHAP limits. 3 The total mass of pollutant emitted for each tes t run is calculated by multiplying the emission rat e for each emission unit (in lbs/hr) by the length of each tested period. The l ength of each furnace test run is given in Table 3- 2; the length of each hood stack test runs is three hours. For D/F, the pounds of e missions are converted to grains for comparison (1 pound = 7,000 grains)



### Table 3-6 ACD1 Summary Results: HCl Emissions

Run Number 1 ACD1 Charge 2
(tons/hr) HCl ACD1 Stack Emissions (lbs/hr) HCl ACD1 Stack Emissions (lbs/ton)

1 All runs were completed on July 18-19, 2007. The ACD1 runs were 1, 3, & 4. 2 The ACD charge rate was calculated based on the c asting speed that was monitored and recorded electr onically during the 3 hour tests (48 fpm) and the density of the aluminum bar cast (0.869 lbs/linear inch).



### Table 3-7 ACD1 Summary Results: PM Emissions

Run Number 1 ACD1 Charge 2
(tons/hr) PM ACD1 Stack Emissions (lbs/hr) PM ACD1 Stack Emissions (lbs/ton)

1 All runs were completed on July 18-19, 2007. The ACD1 runs were 1, 3, & 4. 2 The ACD charge rate was calculated based on the c asting speed that was monitored and recorded electr onically during the 3 hour tests (48 fpm) and the density of the aluminum bar cast (0.869 lbs/linear inch).

### 3.1.2 Rod Mill 2 Analytical Results

Table 3-8 ACD2 Summary Results: HCl Emissions

Run Number 1 ACD Charge 2
(tons/hr) HCl ACD Stack Emissions (lb/hr) NESHAP HCl Limit (lbs/ton) HCl ACD Stack

Emissions (lb/ton)

1 All runs were completed on July 17, 2007. The AC D2 runs were 1, 2, & 3. 2 The ACD charge rate was calculated based on the c asting speed that was monitored and recorded electr onically during the tests (43-44 fpm) and the density of the aluminum b ar cast (0.986 lbs/linear inch).



### Table 3-9 ACD2 Summary Results: PM Emissions

Run Number 1 ACD Charge 2
(tons/hr) PM ACD Stack Emissions (lb/hr) NESHAP PM Limit (lbs/ton) PM ACD Stack Emissions (lb/ton)

1 All runs were completed on July 17, 2007. The AC D2 runs were 1, 2, & 3. 2 The ACD charge rate was calculated based on the c asting speed that was monitored and recorded electr onically during the tests (43-44 fpm) and the density of the aluminum b ar cast (0.986 lbs/linear inch). 3 Using the significant figures reported in the tes t report, the actual tested average for ACD2 result s in a 0.0095 lbs PM per ton of feed/charge against a limit of 0.01 lbs PM per ton of feed/charge.



### 3.1.3 Rod Mill 3 Analytical Results

### Table 3-10 Summary Results: RM3 Charge Conditions

Run Number 1 Duration of Furnace Testing (min) Furnace H5 Charge (tons/batch) ACD3 Charge 2
(tons/hr)

1 All runs were completed on April 30-May 2, 2007. The runs were number 1 through 3. 2 The ACD charge rate was calculated based on the c asting speed that was monitored and recorded electr onically during the 3 hour tests (42 fpm) and the density of the aluminum bar cast (0.279 lbs/linear inch).



### Table 3-11 RM3 Furnace Summary Results: HCl Emissions

Run Number Mass of Combined

HCl Emissions (Lbs) Mass of ACD HCl Emissions (Lbs) Mass of Furnace HCl Emissions (Lbs) Furnace HCl Emissions (Lbs /ton)

1 See the previously submitted NCSR for calculation of the total pollutant emitted for each test run.

### Table 3-12 RM3 Furnace Summary Results: PM Emissions

Run Number Mass of Combined

PM Emissions (Lbs) Mass of ACD PM Emissions (Lbs) Mass of Furnace PM Emissions (Lbs) Furnace PM Emissions (Lbs/ton)

1 See the previously submitted NCSR for calculation of the total pollutant emitted for each test run.



### Table 3-13 RM3 Furnace Summary Results: D/F TEQ Emissions

Run Number D/F TEQ Furnace

Stack Emissions (lb/hr) 1 D/F TEQ Hood Stack Emissions (lb/hr) 1 Total Mass D/F TEQ Emitted (Grains) 2, 3 Furnace D/F TEQ Emissions (Grains/ton)

1 As reported in the stack testing report. 2 Total D/F emissions are being reported in grains for consistency with the secondary aluminum NESHAP limits. 3 See the previously submitted NCSR for calculatio n of the total pollutant emitted for each test run.



### Table 3-14 ACD3 Summary Results: HCl Emissions

Run Number 1 ACD3 Charge 2
(tons/hr) HCl ACD3 Stack Emissions (lbs/hr) HCl ACD3 Emissions (lbs/ton)

1 All runs were completed on April 30-May 2, 2007. The ACD1 runs were 1, 3, & 4. 2 The ACD charge rate was calculated based on the c asting speed that was monitored and recorded electr onically during the batch tests (42 fpm) and the density of the aluminu m bar cast (0.279 lbs/linear inch).

### Table 3-15 ACD3 Summary Results: PM Emissions

Run Number 1 ACD3 Charge 2
(tons/hr) PM ACD3 Stack Emissions (lbs/hr) PM ACD3 Emissions (lbs/ton)

1 All runs were completed on April 30-May 2, 2007. The ACD1 runs were 1, 3, & 4. 2 The ACD charge rate was calculated based on the c asting speed that was monitored and recorded electr onically during the batch tests (42 fpm) and the density of the aluminu m bar cast (0.279 lbs/linear inch).



## 3.2 SAPU Limits and Results Evaluation

### hr tons hr tons hr tons hr tons hr tons hr tons hr tons hr tons hr tons hr tons hr tons hr tons hr tons hr tons

/

22.4 / 45. 15 / 02. 15 / 4.2 / 4.2 / 8. 12 / 8. 12 / 22.4 PM/ton lb 01.0 /

45. 15 PM/ton lb 01.0 /

02. 15 PM/ton lb 01.0 /

4.2 lbPM/ton 40.0 /

4.2 PM/ton lb 40.0 /

8. 12 lbPM/ton 40.0 /

8. 12 PM/ton lb 40.0

ACD3 ACD2 ACD1 H6 H5 M2 M1 ACD3

ACD2 1 ACD H6 H5 M2 M1

hr tons tons tons hr tons hr tons hr tons hr tons hr tons tonshr hr tons hr tons hr tons hr tons hr tons

/

22.4 45. 15 02. 15 / 4.2 / 4.2 / 8. 12 / 8. 12 / 22.4 HCl/ton lb 04.0 45.

15 HCl/ton lb 04.0 /

02. 15 HCl/ton lb 04.0 /

4.2 lbHCl/ton 40.0 /

4.2 HCl/ton lb 40.0 /

8. 12 lbHCl/ton 40.0 /

8. 12 HCl/ton lb 40.0

ACD3 ACD2 ACD1 H6 H5 M2 M1 ACD3

ACD2 1 ACD H6 H5 M2 M1

### hr tons hr tons hr tons hr tons hr tons hr tons hr tons hr tons hr tons hr tons hr tons hr tons hr tons hr tons

/

22.4 / 45. 15 / 02. 15 / 4.2 / 4.2 / 8. 12 / 8. 12 / 22.4 PM/ton lb 016 .0 /

45. 15 PM/ton lb 0095 .0 /

02. 15 PM/ton lb 073 .0 /

4.2 lbPM/ton 310 .0 /

4.2 PM/ton lb 310 .0 /

8. 12 lbPM/ton 083 .0 /

8. 12 PM/ton lb 083 .0

ACD3 ACD2 ACD1 H6 H5 M2 M1 ACD3

ACD2 1 ACD H6 H5 M2 M1

hr tons hr tons hr tons hr tons hr tons hr tons hr tons hr tons hr tons hr tons hr tons hr tons hr tons hr tons

/

22.4 / 45. 15 / 02. 15 / 4.2 / 4.2 / 8. 12 / 8. 12 / 22.4 HCl/ton lb 092 .0 /

45. 15 HCl/ton lb 016 .0 /

02. 15 HCl/ton lb 027 .0 /

4.2 lbHCl/ton 197 .0 /

4.2 HCl/ton lb 197 .0 /

8. 12 lbHCl/ton 096 .0 /

8. 12 HCl/ton lb 096 .0

ACD3 ACD2 ACD1 H6 H5 M2 M1 ACD3

ACD2 1 ACD H6 H5 M2 M1

### Table 3-16 SCKP SAPU Summary- NESHAP Limits vs. Test Resul 

### t

SAPU Calculations Parameter (EPA Test Method) 1 Calculated SAPU
Emissions Compliant

Notes:
1 EPA Method listed as follows – M26A indicates Met hod 26 A, M5 is Method 5 2 Calculated as required by 40 CFR 63.1505(k)(1) Eq uation 1 for PM, and (k)(2) Equation 2 for HCl 3 Calculated as required by 40 CFR 63.1513(e)(1) Eq uation 9 for PM, and (e)(2) Equation 10 for HCl.From: Bo Quick < Bo.Quick@southwire.com > To: Rochelle Boyd/RTP/USEPA/US@EPA
Cc: Paul Sims < Paul.Sims@southwire.com >, "Bahner, Mark A." < bahner@rti.org > Date: 07/23/2012 04:41 PM Subject: RE: Response from Southwire

Rochelle:

The canopy hood emissio ns represent 3 consecutive hours starting at the beginning of the batch cycle. All of the “door open” time occurred during this 3

- hour period during the batch preparation activities. Once the batch was prepared, the door was no longer opened.

Thank s...Bo

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

Sent: Monday, July 23, 2012 3:55 PM

To: Bo Quick

Cc: Paul Sims; Bahner, Mark A. Subject: Fw: Response from Southwire

Do the emissi ons at the canopy hood for Melter/Holder 5 represent 30 minutes throughout the 8 hour cycle or just during the 3 hours that you sampled at the canopy? Were the 3 hours consecutive? If you sampled only for 3 hours at the canopy, were the doors no longer op ened during the rest of the cycle? Thanks

Furnace Test Report
Date Furnace Stack Sampling Time (hrs) Canopy Hood Sampling Time (hrs) Furnace Cycle Time (hrs) Approximate Door

Open Time (hrs)

Melter 1 September 5, 2007 3.2 3 ~3 0.25

Melter/Holder
5 June 26,
2007 7.8 3 ~8 0.5

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