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 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.) 



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 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.	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.)   



List of Tables

  TOC \h \z \t "Table Title,1"    HYPERLINK \l "_Toc315445237"  Table 1.
    Southwire Temperature and Flow Rate Summary	  PAGEREF _Toc315445237
\h  5  

  HYPERLINK \l "_Toc315445240"  Table A1.  Southwire Testing Reported
June 26, 2007: Complete Test Results	  PAGEREF _Toc315445240 \h  7  

  HYPERLINK \l "_Toc315445241"  Table A2.  Southwire Testing Reported on
June 26, 2007: Results in Pounds	  PAGEREF _Toc315445241 \h  8  

  HYPERLINK \l "_Toc315445242"  Table A3.  Southwire Testing Reported
September 5, 2007: Complete Test Results	  PAGEREF _Toc315445242 \h  9  

  HYPERLINK \l "_Toc315445243"  Table A4.  Southwire Testing Reported on
September 5, 2007: Results in Pounds	  PAGEREF _Toc315445243 \h  10  

 



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





Appendix A

Southwire Test Results

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

* reported as 2378-TCDD equivalent

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

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

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

  PAGE   \* MERGEFORMAT  3 

	

  PAGE   \* MERGEFORMAT  6 

