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 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

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
DATE: July 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 on uncontrolled furnaces 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 memorandum. 

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 emitted 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 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 A4: This table presents data from the September 5, 2007 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 

performed 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 through 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, whereas 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 testing 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 throughout the furnace cycle, then the ratio of emissions in the canopy hood stack

to total 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:

1a) Was the 3.2 hours of sampling at the furnace stack (in the September 5 report) the entire

furnace cycle? Yes. Melter 1 batches are typically around 3 hours or so. The canopy was only 

tested for 3 hours (minimum required by NESHAP). 

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

1b) Was the 7.8 hours of sampling at the furnace stack (in the 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). 

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

C. Potential Dilution Air in the Stack

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

from the furnaces seem somewhat large (10210 dscfm and 6197 dscfm, for the June 26, 2007 and 

September 5, 2007 reports, respectively) and the temperatures 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 on 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 stack 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 canopy 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 into 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 testing 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 productionbased (i.e., the standards for hydrogen chloride and particulate are in pounds per ton of charge, and the 

dioxin/furan 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 distribution 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 operations, 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 (number 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 – furnace 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. Southwire 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 Temperature 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 Rod 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 Test) 27,813 113
6

Appendix A

Southwire Test Results
7

Table A1. 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 1.00











From: 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

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
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 during 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 Charge2 

(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 casting speed that was monitored and recorded electronically 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 length 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 dividing 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 length 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 dividing 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 test run is calculated by multiplying the emission rate for each emission unit (in 

lbs/hr) by the length of each tested period. The length 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 emissions are converted to grains for comparison (1 pound = 7,000 grains) 

Table 3-6 

ACD1 Summary Results: HCl Emissions 

Run Number 1 ACD1 Charge2

 

(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 casting speed that was monitored and recorded electronically 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 Charge2

 

(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 casting speed that was monitored and recorded electronically 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 Charge2

 

(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 ACD2 runs were 1, 2, & 3. 

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

tests (43-44 fpm) and the density of the aluminum bar cast (0.986 lbs/linear inch). 

Table 3-9 

ACD2 Summary Results: PM Emissions 

Run Number 1 ACD Charge2

 

(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 ACD2 runs were 1, 2, & 3. 

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

tests (43-44 fpm) and the density of the aluminum bar cast (0.986 lbs/linear inch). 

3 Using the significant figures reported in the test report, the actual tested average for ACD2 results 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 Charge2 

(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 casting speed that was monitored and recorded electronically 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 calculation of the total pollutant emitted for each test run.

Table 3-14 

ACD3 Summary Results: HCl Emissions 

Run Number 1 ACD3 Charge2

 

(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 casting speed that was monitored and recorded electronically during the 

batch tests (42 fpm) and the density of the aluminum bar cast (0.279 lbs/linear inch). 
Table 3-15 

ACD3 Summary Results: PM Emissions 

Run Number 1 ACD3 Charge2

 

(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 casting speed that was monitored and recorded electronically during the 

batch tests (42 fpm) and the density of the aluminum bar cast (0.279 lbs/linear inch). 

3.2 SAPU Limits and Results Evaluation 
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 hr

15 02. / 15 45. / 22.4 /

12 8. / 12 8. / 4.2 / 4.2 /

01.0 lb PM/ton 22.4 /

01.0 lb PM/ton 15 45. /

01.0 lb PM/ton 15 02. /

40.0 lbPM/ton 4.2 /

40.0 lb PM/ton 4.2 /

40.0 lbPM/ton 12 8. /

40.0 lb PM/ton 12 8. /

ACD1 ACD2 ACD3

M1 M2 H5 H6

ACD3

ACD2

ACD1

H6

H5

M2

M1

tons tons tons hr

tons hr tons hr tons hr tons hr

tons hr

tonshr

tons hr

tons hr

tons hr

tons hr

tons hr

15 02. 15 45. 22.4 /

12 8. / 12 8. / 4.2 / 4.2 /

04.0 lb HCl/ton 22.4 /

04.0 lbHCl/ton 15 45.

04.0 lbHCl/ton 15 02. /

40.0 lbHCl/ton 4.2 /

40.0 lb HCl/ton 4.2 /

40.0 lbHCl/ton 12 8. /

40.0 lbHCl/ton 12 8. /

ACD1 ACD2 ACD3

M1 M2 H5 H6

ACD3

ACD2

ACD1

H6

H5

M2

M1
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 hr

15 02. / 15 45. / 22.4 /

12 8. / 12 8. / 4.2 / 4.2 /

.0 016 lb PM/ton 22.4 /

.0 0095 lb PM/ton 15 45. /

.0 073 lb PM/ton 15 02. /

.0 310 lbPM/ton 4.2 /

.0 310 lb PM/ton 4.2 /

.0 083 lbPM/ton 12 8. /

.0 083 lb PM/ton 12 8. /

ACD1 ACD2 ACD3

M1 M2 H5 H6

ACD3

ACD2

ACD1

H6

H5

M2

M1

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 hr

15 02. / 15 45. / 22.4 /

12 8. / 12 8. / 4.2 / 4.2 /

.0 092 lb HCl/ton 22.4 /

.0 016 lbHCl/ton 15 45. /

.0 027 lbHCl/ton 15 02. /

.0 197 lbHCl/ton 4.2 /

.0 197 lbHCl/ton 4.2 /

.0 096 lbHCl/ton 12 8. /

.0 096 lbHCl/ton 12 8. /

ACD1 ACD2 ACD3

M1 M2 H5 H6

ACD3

ACD2

ACD1

H6

H5

M2

M1
Table 3-16 

SCKP SAPU Summary- NESHAP Limits vs. Test Result

SAPU Calculations Parameter 

(EPA Test Method) 1 

Calculated SAPU 

Emissions Compliant 

Notes: 

1 EPA Method listed as follows – M26A indicates Method 26 A, M5 is Method 5 

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

3 Calculated as required by 40 CFR 63.1513(e)(1) Equation 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 emissions 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. 

Thanks...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 emissions 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 opened 

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 DoorOpen 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