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? 

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

1b) Was the 7.8 hours of sampling at the furnace stack (in the June 26 report) the entire furnace 

cycle? 

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

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.) 
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.)

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?

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.) 
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 Rod Mill 1 – Furnace Stack 10,210 307

June 26, 2007 Rod Mill 1 – Canopy Hood Stack 23,157 130

September 5, 2007

Rod Mill 3 – Furnace 5 Stack 

(Dirty Charge Test) 6,197 379

September 5, 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