## 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 Bo yd, 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 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 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 canop y 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 canop y 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, 2 007 report. The data are exclusively in pounds and the table includes a calculation of the percentage of pollutants emitted through the canopy

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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 canop y 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 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 canop y 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: 1 a ) Was the 3.2 hours of sampling at the furnace stack (in the September 5 report) the entire furnace cycle? 2 a ) 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? 2 b ) 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 Septemb er 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
. )

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**D .**  **Potential for Emissions from the Furnace to be Drawn into**  **the Can opy Hoods**  The canop y hoods were installed for the purposes of testing. The flow rate to the canop y 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 ye ars 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 production
based (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 .**  **Am ount 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 ty

pical times are known for present operation s, even if specific times are not available for the 2007 testing.)

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# 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

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**Table 1**  **. Southwire Te**  **mperature 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**

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**Table A**  **1. Southwire Testing Reported June 26, 2007: Complete Test Results**  **Southw ir** **e Te**  **stin g R** 

**ep or** **ted on J**  **une 2**  **6, 2**  **007 PM**  **PM HCl**  **HCl TOTA** **L D /F**  ***** **TOTA L D**  **/F** ***** Durat ion(hr) fu rn ace 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

Durat ion(hr) canopy h ood 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

To ta l 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 av erage 6. 27 lb 6. 71 lb 4. 97E-07 lb * reported as 2378 -TCDD equivalent

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**Table A2. Southwire Testing Reported on June 26, 2007: Results in Pounds**  **Southw ir** **e Te**  **sti ng Re**  **por ted** **on J une**  **2 6,** **2 007**  **Pollut an**  **t Loc**  **at ion**  **Un it** **s Run 1**  **Ru n 2**  **Ru n 3**  **Ave rag**  **e** PM Fu rnace stack lb 4. 31 6. 00 4. 39 4. 90 PM Canopy h ood lb 0. 96 1. 93 1. 23 1. 37

PM To ta l lb 5. 27 7. 93 5. 62 6. 27 PM Fu rnace stack fra cti on of to ta l 0. 82 0. 76 0. 78 0. 78 PM Canopy h ood fra cti on of to ta l 0. 18 0. 24 0. 22 0. 22 22% Avg PM To ta l fra cti on of to ta l 1. 00 1. 00 1. 00 1. 00 HCl Fu rnace stack lb 5. 47 5. 60 5. 31 5. 46 HCl Canopy h ood lb 1. 53 1. 37 0. 84 1. 25 HCl To ta l lb 7. 00 6. 97 6. 15 6. 71 HCl Fu rnace stack fra cti on of to ta l 0. 78 0. 80 0. 86 0. 81 HCl Canopy h ood fra cti on of to ta l 0. 22 0. 20 0. 14 0. 19 19% Avg

HCl To ta l fra cti on of to ta l 1. 00 1. 00 1. 00 1. 00 To ta l D/ F Fu rnace stack lb 6. 69E- 07 6. 18E -07 1. 68E -07 6. 35E -07 To ta l D/ F Canopy h ood lb 1. 16E- 08 1. 64E -08 8. 85E -09 1. 48E -08 To ta l D/ F To ta l lb 6. 81E- 07 6. 34E -07 1. 77E -07 4. 97E -07 To ta l D/ F Fu rnace stack fra cti on of to ta l 0. 98 0. 97 0. 95 0. 97 To ta l D/ F Canopy h ood fra cti on of to ta l 0. 02 0. 03 0. 05 0. 03 3% Avg To ta l D/ F To ta l fra cti on of to ta l 1. 00 1. 00 1. 00 1. 00

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**Table A3. Southwire Testing Reported September 5, 2007: Complete Test Results So**  **uthw ir** **e Te**  **st ing Re**  **por ted** **on Se pt**  **emb er**  **5, 2**  **007 PM**  **PM HCl**  **HCl TOTA** **L D/F** ***** **TOTAL D /F**  ***** Durat ion(hr) fu rnace stack Run 1 3. 20 0. 61 #/hr 1. 95 lb 1. 38 #/hr 4. 42 lb 2. 02E -09 #/hr 6. 46E -0 9 lb Run 2 3. 20 0. 49 1. 57 lb 0. 81 2. 59 lb 3. 97E -09 #/hr 1. 27E -0 8 lb Run 3 3. 20 0. 49 1. 57 lb 0. 68 2. 18 lb 8. 31E -10 #/hr 2. 66E -0 9 lb

Durat ion(hr) ca nopy h ood Run 1 3. 00 0. 86 #/hr 2. 58 lb 0. 38 #/hr 1. 14 lb 8. 31E -09 #/hr 2. 49E -0 8 lb Run 2 3. 00 0. 36 1. 08 lb 0. 25 0. 75 lb 2. 20E -09 #/hr 6. 60E -0 9 lb Run 3 3. 00 0. 53 1. 59 lb 0. 28 0. 84 lb 1. 35E -09 #/hr 4. 05E -0 9 lb

To ta l Run 1 4. 53 lb 5. 56 lb 3. 14E -0 8 lb Run 2 2. 65 lb 3. 34 lb 1. 93E -0 8 lb Run 3 3. 16 lb 3. 02 lb 6. 71E -0 9 lb av erage 3. 45 lb 3. 97 lb 1. 91E -0 8 lb

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**Table A4.**  **Southwire Testing Reported on September 5**  **, 2007: Results in Pounds** Southw ire Testing Reporte d on Septem ber 5 , 2007 **Po llutant**  **Lo ca** **tio n**  **Units Run**  **1 Run**  **2 Ru** **n 3 Av**  **er ag**  **e** PM Fur na ce stack lb 1. 95 1. 57 1. 57 1. 70 PM Canopy hood lb 2. 58 1. 08 1. 59 1. 75

PM Tota l lb 4. 53 2. 65 3. 16 3. 45 PM Fur na ce stack fracti on of tota l 0. 43 0. 59 0. 50 0. 49 PM Canopy hood fracti on of tota l 0. 57 0. 41 0. 50 0. 51 51% Avg PM Tota l fracti on of tota l 1. 00 1. 00 1. 00 1. 00 HCl Fur na ce stack lb 4. 42 2. 59 2. 18 3. 06 HCl Canopy hood lb 1. 14 0. 75 0. 84 0. 91 HCl Tota l lb 5. 56 3. 34 3. 02 3. 97 HCl Fur na ce stack fracti on of tota l 0. 79 0. 78 0. 72 0. 77 HCl Canopy hood fracti on of tota l 0. 21 0. 22 0. 28 0. 23 23% Avg
HCl Tota l fracti on of tota l 1. 00 1. 00 1. 00 1. 00 Tota l D/F Fur na ce stack lb 6. 46E -09 1. 27E-08 2. 66E-09 1. 06E -0 8 Tota l D/F Canopy hood lb 2. 49E -0 8 6. 60E-09 4. 05E-09 1. 27E -0 8 Tota l D/F Tota l lb 3. 14E -0 8 1. 93E-08 6. 71E-09 1. 91E -0 8 Tota l D/F Fur na ce stack fracti on of tota l 0. 21 0. 66 0. 40 0. 42 Tota l D/F Canopy hood fracti on of tota l 0. 79 0. 34 0. 60 0. 58 58% Avg Tota l D/F Tota l fracti on of tota l 1. 00 1. 00 1. 00 1. 00