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NUCOR STEEL TUSCALOOSA, INC. TUSCALOOSA, AL
FACILITY NO.: 413-0033
MAJOR SOURCE OPERATING PERMIT
TITLE V RENEWAL DRAFT
(THIS PAGE LEFT BLANK INTENTIONALLY)
i
Table of Contents
PROCESS DESCRIPTION ............................................................................................................ 1
NOTABLE CHANGES ................................................................................................................. 2
ONE (1) ELECTRIC ARC FURNACE, TWO (2) LADLE METALLURGY STATIONS, AND
CONTINUOUS CASTER WITH TWO (2) MELTSHOP BAGHOUSES ............................................ 4
STATE REGULATIONS ................................................................................................................... 5
ADEM Admin. Code r. 335-3-14-.04, “Prevention of Significant Deterioration (PSD) Permitting”
.................................................................................................................................................. 5
FEDERAL REGULATIONS ............................................................................................................... 7
NEW SOURCE PERFORMANCE STANDARDS (NSPS) ....................................................................... 7
40 CFR Part 60, Subpart A, “General Provisions” ..................................................................... 7
40 CFR Part 60 Subpart AAa, “Standards of Performance for Steel Plants: Electric Arc Furnaces and
Argon-Decarburization Vessels Constructed After August 17, 1983” ...................................... 8
NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) ............................ 9
40 CFR Part 63 Subpart A, “General Provisions” ...................................................................... 9
40 CFR Part 63 Subpart YYYYY, “National Emission Standards for Hazardous Air Pollutants for Area
Sources: Electric Arc Furnace Steelmaking Facilities” ............................................................ 10
40 CFR 64, “COMPLIANCE ASSURANCE MONITORING (CAM)” ...................................................... 10
MELTSHOP BAGHOUSE EMISSIONS .............................................................................................. 11
EQUALIZING FURNACE (400 MMBTU/HR) ............................................................................. 12
STATE REGULATIONS ................................................................................................................. 12
ADEM Admin. Code r. 335-3-14-.04, “Prevention of Significant Deterioration (PSD) Permitting”
................................................................................................................................................ 12
FEDERAL REGULATIONS ............................................................................................................. 14
40 CFR 64, “COMPLIANCE ASSURANCE MONITORING (CAM)” ...................................................... 14
EQUALIZING FURNACE EMISSIONS ............................................................................................... 14
SKULL LANCING OPERATION W/ BAGHOUSE ....................................................................... 15
STATE REGULATIONS ................................................................................................................. 15
ADEM Admin. Code r. 335-3-4-.01(1)(a) and (b), “Visible Emissions” for Control of Particulate
Emissions ................................................................................................................................ 15
ADEM Admin. Code r. 335-3-14-.04, “Prevention of Significant Deterioration (PSD) Permitting”
................................................................................................................................................ 16
ii
FEDERAL REGULATIONS ............................................................................................................. 17
40 CFR 64, “COMPLIANCE ASSURANCE MONITORING (CAM)” ...................................................... 17
SKULL LANCING OPERATION EMISSIONS ...................................................................................... 17
HOT ROLLING MILL ................................................................................................................ 18
STATE REGULATIONS ................................................................................................................. 18
ADEM Admin. Code r. 335-3-4-.01(1)(a) and (b), “Visible Emissions” for Control of Particulate
Emissions ................................................................................................................................ 18
FEDERAL REGULATIONS ............................................................................................................. 19
40 CFR 64, “COMPLIANCE ASSURANCE MONITORING (CAM)” ...................................................... 19
HOT ROLLING MILL EMISSIONS ................................................................................................... 19
EXISTING EMERGENCY GENERATORS .................................................................................. 20
STATE REGULATIONS ................................................................................................................. 20
ADEM Admin. Code r. 335-3-4-.01(1)(a) and (b), “Visible Emissions” for Control of Particulate
Emissions ................................................................................................................................ 20
FEDERAL REGULATIONS ............................................................................................................. 21
NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) .......................... 21
40 CFR Part 63 Subpart A, “General Provisions” .................................................................... 21
40 CFR Part 63 Subpart ZZZZ, “National Emission Standards for Hazardous Air Pollutants for
Reciprocating Internal Combustion Engines (RICE)” .............................................................. 21
EXISTING EMERGENCY GENERATORS EMISSIONS......................................................................... 22
RECOMMENDATIONS ............................................................................................................. 23
1
NUCOR STEEL TUSCALOOSA, INC. TUSCALOOSA COUNTY, AL
Facility No.: 413-0033
STATEMENT OF BASIS
This proposed Title V Major Source Operating Permit (MSOP) renewal is issued under
the provisions of ADEM Admin. Code r. 335-3-16. The above named applicant has
requested authorization to perform the work or operate the facility shown on the
application and drawings, plans and other documents attached hereto or on file with the
Air Division of the Alabama Department of Environmental Management, in accordance
with the terms and conditions of this permit.
Nucor Steel Tuscaloosa, Inc. (Nucor) was issued its existing MSOP on September 23,
2013, with an expiration date of September 15, 2018. Per ADEM Rule 335-3-16-.12(2),
an application for permit renewal shall be submitted at least six (6) months, but not more
than eighteen (18) months, before the date of expiration of the permit. The renewal
application was submitted to the Department in a timely manner on January 23, 2018.
PROCESS DESCRIPTION
The following significant sources of air pollution are located at this facility (a list of
insignificant sources can be found in the renewal application):
Electric Arc Furnace
Two (2) Ladle Metallurgy Furnaces
Continuous Caster and other miscellaneous sources in the Meltshop
400 MMBtu/hr Equalizing Furnace
Skull Lancing Operation
Four (4) Diesel Fired Emergency Generators (423 BHP, 800 BHP, 2,168 BHP, &
2,575 BHP)
The electric arc furnace (EAF) operates in a batch mode, whereby the scrap steel and
scrap substitutes are conveyed and/or charged, melted, and tapped. As the scrap metal
melts into molten steel, oxygen lancing and carbon injection are performed. This
operational cycle is repeated for each batch, which can take up to one hour to complete.
The molten steel is then tapped into a ladle and transported from the EAF to the ladle
metallurgy furnaces (LMFs). The LMFs are used primarily to adjust the composition (by
adding alloys, lime, and wire) and temperature of the steel prior to continuous casting.
After the composition and temperature of the molten steel is adjusted at the LMFs, the
ladle of molten steel is transferred to the continuous caster. The molten steel is poured
from the ladle into a tundish, which funnels the molten steel into a mold. The steel
solidifies as it passes through the water-cooled mold, providing immediate cooling of the
NUCOR STEEL TUSCALOOSA, INC. Facility No.: 413-0033 Statement of Basis
2
outer skin. The equalizing furnace heats the steel slabs to a uniform rolling temperature.
The skull lancing operation consists of a building where metal skulls are cut from the
EAF into smaller pieces such that the pieces can be returned to the EAF as a raw material
for melting.
The emissions generated from the EAF are captured by the direct evacuation control
(DEC), which evacuates the exhaust gases directly from the furnace to the Meltshop
Baghouses. Emissions from the LMFs are captured by a side draft hood and also
evacuated to the Meltshop Baghouses. An overhead roof exhaust system evacuates
fugitive emissions from the closed roof plenums to the main duct system directed to the
Meltshop Baghouses.
NOTABLE CHANGES
On July 22, 2014, the Department issued Nucor Air Permit Nos. 413-0033-X014 through
X020. These permits covered the following units:
413-0033-X014 Additional baghouse (BH-02) for the EAF, LMFs, & Caster
413-0033-X015 Austenitizing Furnace (40.6 MMBtu/hr)
413-0033-X016 Tempering Furnace (35 MMBtu/hr)
413-0033-X017 Vacuum Degasser w/ Flare and Cooling Towers
413-0033-X018 800 BHP Diesel Fired Emergency Generator (Heat Treat)
413-0033-X019 400 kW Propane Fired Emergency Generator
413-0033-X020 Two (2) Plasma Torch Cutting Beds (0.32 MMBtu/hr)
AP X014 lowered the steel production requirements from 2,628,000 tons per consecutive
12 month period to 2,000,000 tons. PSD/BACT limits for filterable and condensable
PM10 and PM2.5 were also imposed on the meltshop baghouses. Nucor constructed the
second baghouse for the meltshop units but did not construct the units covered by Air
Permit Nos. X015 through X020.
On September 30, 2016, the Department received an application from Nucor proposing to
modify the existing EAF to create a larger heel, add two 5 MW burners to the EAF, add a
heat treat facility consisting of the following: an austenitizing furnace, tempering furnace,
two car bottom furnaces) and a cooling tower, and add a TK Energizer Ladle Heater. On
March 9, 2017, the Department reissued Air Permit Nos. 413-0033-X014 through X016,
voided X017 through X020, and issued X021 and X022:
413-0033-X014 Additional baghouse (BH-02) for the EAF, LMFs, & Caster
413-0033-X015 Austenitizing Furnace (40.6 MMBtu/hr)
413-0033-X016 Tempering Furnace (35 MMBtu/hr)
413-0033-X021 Car Bottom Furnaces (45 MMBtu/hr, each)
413-0033-X022 TK Energizer Ladle Heater (5 MMBtu/hr)
NUCOR STEEL TUSCALOOSA, INC. Facility No.: 413-0033 Statement of Basis
3
AP X014 lowered the steel production requirements from 2,000,000 tons per consecutive
12 month period to 1,800,000 tons and the SO2 limit for these units from 138.0 lb/hr and
0.46 lb/ton of steel produced to 132.0 lb/hr and 0.44 lb/ton of steel produced. A limit for
greenhouse gas emissions (CO2e) was also included in this permit. The modifications to
the EAF are in process so these changes will be addressed in the Title V. The remaining
units have not been constructed and, therefore, will not be addressed in the Title V.
Included in the September 30, 2016 application were previously unrecognized VOC and
particulate matter emissions from the Hot Rolling Mill. The Department did not issue an
air permit for the hot rolling mill since it did not require any PSD/BACT limits.
However, since these emissions exceed the level which would be considered “trivial or
insignificant” activity (5 tons per year), this unit will be added to the Title V permit.
NUCOR STEEL TUSCALOOSA, INC. Facility No.: 413-0033 Statement of Basis
4
ONE (1) ELECTRIC ARC FURNACE, TWO (2) LADLE METALLURGY
STATIONS, AND CONTINUOUS CASTER WITH TWO (2) MELTSHOP
BAGHOUSES
DESCRIPTION POLLUTANT EMISSION
LIMIT REGULATIONS
One (1) Electric Arc Furnace, Two (2)
Ladle Metallurgy Stations, and
Continuous Caster with Two (2)
Meltshop Baghouses (BH-01 and BH-
02)
PM
(Filterable)
0.0018 gr/dscf* Rule 335-3-14-.4(9)
[PSD/BACT]
PM10
(Filterable &
Condensable)
0.0052 gr/dscf* Rule 335-3-14-.4(9)
[PSD/BACT]
PM2.5
(Filterable &
Condensable)
0.0049 gr/dscf* Rule 335-3-14-.4(9)
[PSD/BACT]
SO2 132.0 lb/hr
and
0.44 lb/ton of steel
produced*
Rule 335-3-14-.04(9)
[PSD/BACT]
NOX 105.0 lb/hr
and
0.35 lb/ton of steel
produced*
Rule 335-3-14-.04(9)
[PSD/BACT]
CO 660.0 lb/hr
and
2.2 lb/ton of steel
produced*
Rule 335-3-14-.04(9)
[PSD/BACT]
VOC 39.0 lb/hr
and
0.13 lb/ton of steel
produced*
Rule 335-3-14-.04(9)
[PSD/BACT]
Pb 0.60 lb/hr Rule 335-3-14-.04(9)
[PSD/BACT]
Opacity Less than 3%* 40 CFR 60.272a(a)(2)
Meltshop Building Opacity Less than 6% 40 CFR 60.272a(a)(3)
Baghouse Dust Handling System Opacity Less than 10% 40 CFR 60.272a(b)
*Combined limit with LMF, CC-ladled steel through EAF shall not exceed 1,800,000 ton/12-month
NUCOR STEEL TUSCALOOSA, INC. Facility No.: 413-0033 Statement of Basis
5
STATE REGULATIONS
ADEM Admin. Code r. 335-3-14-.04, “Prevention of Significant
Deterioration (PSD) Permitting”
Applicability:
The emission points associated with the meltshop are subject to PSD/BACT limits and
requirements. The limits/requirements in this section are being rolled into the Title V from
Air Permit No. 413-0033-X014, issued on March 9, 2017.
Emission Standards:
The facility shall comply with the following limits:
The production of molten (ladled) steel by the electric arc furnace shall not exceed
1,800,000 tons during any consecutive twelve month period.
The opacity of emissions from the stack associated with the electric arc furnace and
ladle metallurgy furnaces meltshop baghouses shall not exceed three percent (3%)
opacity as determined by a six (6) minute average.
Filterable particulate matter (PM) emissions from the meltshop baghouses shall not
exceed an outlet grain loading of 0.0018 gr/dscf.
Filterable and condensable PM10 emissions from the meltshop baghouses shall not
exceed an outlet grain loading of 0.0052 gr/dscf.
Filterable and condensable PM2.5 emissions from the meltshop baghouses shall not
exceed an outlet grain loading of 0.0049 gr/dscf.
Sulfur dioxide (SO2) emissions from the meltshop baghouses shall not exceed 132.0
lb/hr and 0.44 lb/ton of steel produced.
Nitrogen oxide (NOX) emissions from the meltshop baghouses shall not exceed 105.0
lb/hr and 0.35 lb/ton of steel produced.
Carbon monoxide (CO) emissions from the meltshop baghouses shall not exceed
660.0 lb/hr and 2.2 lb/ton of steel produced.
Volatile organic compound (VOC) emissions as propane from the meltshop baghouses
shall not exceed 39.0 lb/hr and 0.13 lb/ton of steel produced.
Lead emissions from the meltshop baghouses shall not exceed 0.60 lb/hr.
CO2e emissions from this unit shall not exceed 378,621 tons per year (TPY) based on
a twelve (12) month rolling total.
The facility shall comply with the following requirements:
All dust handling systems (screw conveyors, silos, dumpsters, etc.) from baghouse
NUCOR STEEL TUSCALOOSA, INC. Facility No.: 413-0033 Statement of Basis
6
hoppers shall be enclosed to prevent fugitive emissions from these handling systems.
All paved roads shall be vacuum swept or flushed of surface material at least once
every third consecutive day. The vacuum sweeper shall have a minimum blower
capacity of 12,000 cfm, and the flushing machine shall dispense water at a rate of 0.32
gal/yd2.
All paved parking areas shall be vacuum swept or flushed of surface material at least
once every calendar quarter. The vacuum sweeper shall have a minimum blower
capacity of 12,000 cfm, and the flushing machine shall dispense water at a rate of 0.32
gal/yd2.
Paved road flushing specified in this permit is not required when the temperature is
below 32°F. Paved road or area cleaning is not required when precipitation during the
previous 24-hour period has exceeded 0.01 inches.
Storage piles, storage silos, and material handling systems for iron and steel scrap, hot
briquetted iron, pig iron, iron carbide, fluxing materials, direct reduced iron (DRI),
and alloying agents shall be maintained in such a way so as to minimize the
generation of dust.
Compliance and Performance Test Methods and Procedures:
The facility shall comply with the following test methods/procedures:
Method 9 of 40 CFR part 60, appendix A shall be used in the determination of
opacity.
Method 5 of 40 CFR part 60, appendix A shall be used in the determination of PM
(filterable) emissions.
Method 202 of 40 CFR part 60, appendix A shall be used in the determination of total
PM (filterable and condensable) emissions.
Method 6C of 40 CFR part 60, appendix A shall be used in the determination of SO2
emissions.
Method 7E of 40 CFR part 60, appendix A shall be used in the determination of NOX
emissions.
Method 10 of 40 CFR part 60, appendix A shall be used in the determination of CO
emissions.
Method 25A of 40 CFR part 60, appendix A, or another method approved by the
Department, shall be used in the determination of VOC emissions.
Method 12 of 40 CFR part 60, appendix A shall be used in the determination of lead
emissions.
Emission Monitoring:
The common baghouse stack is equipped with a continuous opacity monitoring system
NUCOR STEEL TUSCALOOSA, INC. Facility No.: 413-0033 Statement of Basis
7
(COMS). The COMS will be operated and maintained according to the procedures in
Performance Specification 1 of 40 CFR part 60, appendix B.
A visual inspection of the dust handling equipment will be performed at least once per day by
a person familiar with Method 9. If visible emissions are noted at any time, an observation
shall be performed in accordance with Method 9, and appropriate actions shall be taken to
eliminate the emissions immediately.
The sulfur content of each load of injection carbon received shall be monitored. The sulfur
content of the injection carbon utilized in the EAF shall not exceed the sulfur content of the
carbon used in the most recent compliance test that demonstrated compliance. Vendor test
data or shipment certifications may be used to verify the sulfur content in the injection
carbon.
Quarterly inspections of the direct evacuation control system (DEC) shall be conducted.
Recordkeeping and Reporting Requirements:
The facility shall maintain the following records in a for suitable for inspection for a period of
at least five (5) years:
Records documenting each occasion in which paved areas are cleaned in accordance
with the permit and any occasion in which these paved areas are not cleaned according
to required schedule. This record shall include any justification for failure to meet the
required schedule, such as equipment breakdown or inclement weather conditions. A
summary of this record shall be submitted with the semi-annual report required by
§60.276a(b) of 40 CFR part 60, subpart AAa.
Twelve (12) month rolling total CO2e emissions from this source.
Sulfur content in the injection carbon utilized in the EAF.
Monthly and 12-month rolling total steel production.
Each visible inspection, to include Method 9 visible observations. This should also
include problems observed and corrective actions taken.
Quarterly inspections performed on the DEC.
FEDERAL REGULATIONS
NEW SOURCE PERFORMANCE STANDARDS (NSPS)
40 CFR Part 60, Subpart A, “General Provisions”
Applicability:
Provided that the facility is subject to one of the applicable subparts found under this part, the
NUCOR STEEL TUSCALOOSA, INC. Facility No.: 413-0033 Statement of Basis
8
facility shall comply with this regulation as specified in that subpart.
40 CFR Part 60 Subpart AAa, “Standards of Performance for Steel Plants:
Electric Arc Furnaces and Argon-Decarburization Vessels Constructed After
August 17, 1983”
Applicability:
Per §60.270a(a), the electric arc furnace (EAF) is subject to this subpart.
Emission Standards:
Per §60.272a(a)(1), particulate matter (PM) emissions from the control device(s) shall not
exceed 12 mg/dscm (0.0052 gr/dscf).
Per §60.272a(a)(2), the opacity of emissions from the control device(s) shall not exceed 3%.
Per §60.272a(a)(3), the opacity of emissions from the meltshop building shall not exceed 6%.
Per §60.272a(b), the opacity of emissions from the dust handling system shall not exceed
10%.
Compliance and Performance Test Methods and Procedures:
Per §60.275a(e)(1), Method 5 of 40 CFR part 60, appendix A shall be used in the
determination of PM emissions.
Per §60.275a(e)(3), Method 9 of 40 CFR part 60, appendix A shall be used in the
determination of opacity.
Emission Monitoring:
Per §60.273a(a), the baghouses shall be equipped with a continuous opacity monitoring
system (COMS).
Per §60.273a(d), daily observations of the shop opacity shall be performed when the furnace
is operating in the meltdown and refining period. Shop opacity shall be determined as the
arithmetic average of 24 consecutive 15-second opacity observations of emissions from the
shop taken in accordance with Method 9.
The Permittee shall comply with the monitoring requirements in §60.274a, summarized
below:
Check and record furnace static pressure of DEC system once per shift and either
check and record the control system fan motor amperes and damper position on a
once-per-shift basis; install, calibrate, and maintain a monitoring device that
continuously records the volumetric flow rate through each separately ducted hood; or
NUCOR STEEL TUSCALOOSA, INC. Facility No.: 413-0033 Statement of Basis
9
install, calibrate, and maintain a monitoring device that continuously records the
volumetric flow rate at the control device inlet and check and record damper positions
on a once-per-shift basis [§60.274a(b)].
When demonstrating compliance with the shop opacity requirement, the control
system fan motor amperes and all damper positions, the volumetric flow rate through
each separately ducted hood, or the volumetric flow rate at the control device inlet and
all damper positions shall be determined during all periods in which a hood is
operated for the purpose of capturing emissions from the EAF [§60.274a(c)].
Perform monthly operational status inspections of the equipment that is important to
the performance of the total capture system (i.e., pressure sensors, dampers, and
damper switches) [§60.274a(d)].
Except as provided for under §60.273a(d), if emissions during any phase of the heat
time are controlled by the use of a DEC system, the owner or operator shall install,
calibrate, and maintain a monitoring device that allows the pressure in the free space
inside the EAF to be monitored. The pressure shall be recorded as 15-minute
integrated averages [§60.274a(f)].
Except as provided for under §60.273a(d), the pressure in the free space inside the
furnace shall be determined during the meltdown and refining period(s) using the
monitoring device required under §60.274a(f) [§60.274a(g)].
Recordkeeping and Reporting Requirements:
Per §60.276a(a), a record of the data obtained under §60.274a(b) and a record of all monthly
operational status inspection performed under §60.274a(c) shall be maintained for a period of
at least two (2) years.
Per §60.276a(b), the Permittee shall submit a written report of exceedances of the control
device opacity, as indicated by the COMs, to the Department semi-annually. For the purposes
of these reports, exceedances are defined as all 6-minute periods during which the average
opacity is 3 percent or greater.
Per §60.276a(g), the Permittee shall submit a written report of exceedances of the EAF shop
and dust handling equipment opacity limits to the Department semi-annually. For purposes of
these reports, exceedances are defined as opacity observations from the EAF shop and/or the
dust handling equipment in excess of the emission limits specified in the permit. Copies of
Method 9 observations performed shall be included with the report.
NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP)
40 CFR Part 63 Subpart A, “General Provisions”
Applicability:
Provided that the facility is subject to one of the applicable subparts found under this part, the
NUCOR STEEL TUSCALOOSA, INC. Facility No.: 413-0033 Statement of Basis
10
facility shall comply with this regulation as specified in that subpart.
40 CFR Part 63 Subpart YYYYY, “National Emission Standards for
Hazardous Air Pollutants for Area Sources: Electric Arc Furnace
Steelmaking Facilities”
Applicability:
Per §63.10680(a), the facility is subject to this subpart because it is an electric arc furnace
(EAF) steelmaking facility that is an area source of hazardous air pollutant (HAP) emissions.
Emission Standards:
The Permittee shall comply with the requirements for the control of contaminants from scrap
in §63.10685, specifically the development of a pollution prevention plan for chlorinated
plastics, lead, and organic liquids [§63.10685(a)(1)-(2)] and a site specific plan for mercury
switches or another approved mercury programs [§63.10685(b)(1)-(2)].
The Permittee demonstrates compliance with the requirements in §63.10686(b) for the EAF
by complying with the requirements of 40 CFR part 60, subpart AAa.
Compliance and Performance Test Methods and Procedures:
The Permittee shall use the test methods in §63.10686(d) to demonstrate compliance with the
emission standards in §63.10686(b).
Emission Monitoring:
The Permittee shall comply with the monitoring requirements in §63.10686(d)-(e).
Recordkeeping and Reporting Requirements:
The Permittee shall comply with the recordkeeping and reporting requirements in
§63.10685(c) and §63.10690(b).
40 CFR 64, “COMPLIANCE ASSURANCE MONITORING (CAM)”
Applicability:
This subpart is applicable to an emission source provided the source meets the following
criteria: it is subject to an emission limit or standard, it uses a control device to achieve
compliance with the emissions limit or standard, and it has pre-controlled emissions from a
regulated air pollutants that are equal to or greater than 100 percent of the amount, in tons per
year, required for a source to be classified as a major source [40 CFR 64.2(a)]. Therefore, this
source is subject to CAM requirements for PM.
Nucor has developed a CAM plan with five indicators of compliance:
NUCOR STEEL TUSCALOOSA, INC. Facility No.: 413-0033 Statement of Basis
11
1) Pressure drop between the inlet and outlet of the baghouses: an excursion is
defined as a pressure differential below 4.0 inches of water and greater than 16.0
inches of water [for BH-01] and greater than 30.0 inches of water [for BH-02]. The
pressure drop will be measured by a magnehelic once every 15 minutes. The
magnehelic will be calibrated annually.
2) Opacity measured via the COMS: an excursion is defined as an opacity
measurement exceeding 3.0% on a 6-minute average. The opacity will be measured
continuously. The COMS will be operated and maintained according to the procedures
in Performance Specification 1 of 40 CFR part 60, appendix B.
3) Opacity measured via Method 9: an exceedance is defined as the presence of visible
emissions greater than 3.0 % opacity on a 6-minute average. A Method 9 observation
will performed at least once each day.
4) Particulate matter concentration: an exceedance is defined as a PM reading greater
than 0.0018 gr/dscf. The baghouse stacks will be tested annually for PM emissions
using Method 5.
5) Condition of the baghouse bags: an excursion is defined as a failure to perform the
monthly inspection of the bags. The baghouses will be inspected at least once a
month.
MELTSHOP BAGHOUSE EMISSIONS
Expected meltshop baghouse emissions (lb/hr) were calculated using stack test data and
actual steel production for the year 2017.
MELTSHOP BAGHOUSE EMISSIONS
(lb/hr)
PM SO2 NOX CO VOC Lead
BH-01
&
BH-02
8.42 37.6 52.4 215 23.0 0.03
NUCOR STEEL TUSCALOOSA, INC. Facility No.: 413-0033 Statement of Basis
12
EQUALIZING FURNACE (400 MMBTU/HR)
DESCRIPTION POLLUTANT EMISSION
LIMIT REGULATIONS
Equalizing Furnace (EQF-01) PM 0.0167 lb/MMBtu
and
6.68 lb/hr
Rule 335-3-14-.04(9)
[PSD/BACT]
SO2 0.0006 lb/MMBtu
and
0.24 lb/hr
Rule 335-3-14-.04(9)
[PSD/BACT]
NOX 0.075 lb/MMBtu
and
30.0 lb/hr
Rule 335-3-14-.04(9)
[PSD/BACT]
CO 0.084 lb/MMBtu
and
33.6 lb/hr
Rule 335-3-14-.04(9)
[PSD/BACT]
VOC 0.0055 lb/MMBtu
and
2.2 lb/hr
Rule 335-3-14-.04(9)
[PSD/BACT]
Opacity Less than 10% Rule 335-3-14-.04(9)
[PSD/BACT]
STATE REGULATIONS
ADEM Admin. Code r. 335-3-14-.04, “Prevention of Significant Deterioration
(PSD) Permitting”
Applicability:
The stack associated with the equalizing furnace is subject to PSD/BACT limits. The
limits/requirements in this section have remain unchanged since being rolled into the Initial
Title V Permit via significant modification from Air Permit 413-0033-X009, issued June 6,
2006.
Emission Standards:
The facility shall comply with the following limits:
The opacity of emissions from the stack associated with the equalizing furnace shall
NUCOR STEEL TUSCALOOSA, INC. Facility No.: 413-0033 Statement of Basis
13
not exceed three percent (3%) opacity as determined by a six (6) minute average.
Particulate matter (PM) emissions from the stack associated with the equalizing
furnace shall not exceed 6.68 lb/hr and 0.0167 lb/MMBtu.
Sulfur dioxide (SO2) emissions from the stack associated with the equalizing furnace
shall not exceed 0.24 lb/hr and 0.0006 lb/MMBtu.
Nitrogen oxide (NOX) emissions from the stack associated with the equalizing furnace
shall not exceed 30.0 lb/hr and 0.075 lb/MMBtu.
Carbon monoxide (CO) emissions from the stack associated with the equalizing
furnace shall not exceed 33.6 lb/hr and 0.084 lb/MMBtu.
Volatile organic compound (VOC) emissions as propane from the stack associated with
the equalizing furnace shall not exceed 2.2 lb/hr and 0.0055 lb/MMBtu.
Compliance and Performance Test Methods and Procedures:
The facility shall comply with the following test methods/procedures:
Method 9 of 40 CFR part 60, appendix A shall be used in the determination of opacity.
Method 5 of 40 CFR part 60, appendix A shall be used in the determination of PM
(filterable) emissions.
Method 6C of 40 CFR part 60, appendix A shall be used in the determination of SO2
emissions.
Method 7E of 40 CFR part 60, appendix A shall be used in the determination of NOX
emissions.
Method 10 of 40 CFR part 60, appendix A shall be used in the determination of CO
emissions.
Method 25A of 40 CFR part 60, appendix A, or another method approved by the
Department, shall be used in the determination of VOC emissions.
Emission Monitoring:
The Permittee is required to limit the amount of iron oxides and various components of scale
on the slabs prior to processing in order to ensure the best possible surface cleanliness of the
slabs that are processed in the equalizing furnace.
A visual inspection of the stack associated with the equalizing furnace will be performed at
least once per day by a person familiar with Method 9. If visible emissions are noted at any
time, an observation shall be performed in accordance with Method 9, and appropriate actions
shall be taken to eliminate the emissions within four hours of the initial observation.
NUCOR STEEL TUSCALOOSA, INC. Facility No.: 413-0033 Statement of Basis
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Recordkeeping and Reporting Requirements:
The facility shall maintain the following records in a for suitable for inspection for a period of
at least five (5) years:
Each visible inspection, to include Method 9 visible observations. This should also
include problems observed and corrective actions taken.
FEDERAL REGULATIONS
40 CFR 64, “COMPLIANCE ASSURANCE MONITORING (CAM)”
Applicability:
This subpart is applicable to an emission source provided the source meets the following
criteria: it is subject to an emission limit or standard, it uses a control device to achieve
compliance with the emissions limit or standard, and it has pre-controlled emissions from a
regulated air pollutants that are equal to or greater than 100 percent of the amount, in tons per
year, required for a source to be classified as a major source [40 CFR 64.2(a)]. Since the
equalizing furnace is not equipped with a control device, CAM does not apply.
EQUALIZING FURNACE EMISSIONS
Expected equalizing furnace emissions (lb/hr) were calculated using stack test data and actual
fuel usage for the year 2017.
EQUALIZING FURNACE EMISSIONS
(lb/hr)
PM SO2 NOX CO VOC
1.85 0.07 8.30 9.29 0.61
NUCOR STEEL TUSCALOOSA, INC. Facility No.: 413-0033 Statement of Basis
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SKULL LANCING OPERATION W/ BAGHOUSE
DESCRIPTION POLLUTANT EMISSION
LIMIT REGULATIONS
Skull Lancing Operation (SL-01) PM
3.3 lb/hr Rule 335-3-14-.04(9)
[PSD/BACT]
Opacity No more than one 6 min
avg. > 20%
AND
Rule 335-3-4-.01(1)(a)
No 6 min avg. > 40% Rule 335-3-4-.01(1)(b)
STATE REGULATIONS
ADEM Admin. Code r. 335-3-4-.01(1)(a) and (b), “Visible Emissions” for
Control of Particulate Emissions
Applicability:
The opacity of the particulate off of stack associated with the skull lancing operation would be
subject to the standards in this subpart.
Emissions Standards:
ADEM Admin. Code r. 335-3-4-.01(1)(a) states that except for one 6-minute period during
any 60-minute periods, stationary emission sources shall not discharge into the atmosphere
particulate that results in an opacity greater than 20%, as determined by a 6-minute average.
ADEM Admin. Code r. 335-3-4-.01(1)(b) states that at no time shall a stationary emission
source discharge into the atmosphere particulate that results in an opacity greater than 40%, as
determined by a six minute average.
Compliance and Performance Test Methods and Procedures:
Method 9 of 40 CFR part 60, appendix A would be used in the determination of opacity.
Emissions Monitoring:
A visual inspection of the stack associated with the skull lancing operation will be performed
at least once per day by a person familiar with Method 9. If visible emissions are noted in
NUCOR STEEL TUSCALOOSA, INC. Facility No.: 413-0033 Statement of Basis
16
excess of 10% at any time, an observation shall be performed in accordance with Method 9,
and appropriate actions shall be taken to eliminate the emissions within four hours of the initial
observation.
Recordkeeping and Reporting Requirements:
The facility shall maintain the following records in a for suitable for inspection for a period of
at least five (5) years:
Each visible inspection, to include Method 9 visible observations. This should also
include problems observed and corrective actions taken.
ADEM Admin. Code r. 335-3-14-.04, “Prevention of Significant Deterioration
(PSD) Permitting”
Applicability:
The stack associated with the skull lancing operation is subject to a PSD/BACT limit for
particulate matter. The limit/requirements in this section have remain unchanged since being
rolled into the Initial Title V Permit from Air Permit 413-0033-X013, issued May 25, 2000.
Emission Standards:
Particulate matter (PM) emissions from the stack associated with the skull lancing operation
shall not exceed 3.3 lb/hr.
Compliance and Performance Test Methods and Procedures:
Method 5 of 40 CFR part 60, appendix A shall be used in the determination of PM emissions.
Emission Monitoring:
The Permittee shall perform a weekly inspection of the baghouse to verify proper operation,
including checking hopper, fan, and cleaning cycles and checking all hoods and ductwork.
The Permittee shall perform an annual inspection of the baghouse to verify proper operation,
including inspecting the baghouse structure, access doors, door seals, and bags and an internal
inspection of the baghouse hoppers.
Recordkeeping and Reporting Requirements:
The facility shall maintain the following records in a for suitable for inspection for a period of
at least five (5) years:
A record of each weekly inspection and the results of each annual inspection.
NUCOR STEEL TUSCALOOSA, INC. Facility No.: 413-0033 Statement of Basis
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FEDERAL REGULATIONS
40 CFR 64, “COMPLIANCE ASSURANCE MONITORING (CAM)”
Applicability:
This subpart is applicable to an emission source provided the source meets the following
criteria: it is subject to an emission limit or standard, it uses a control device to achieve
compliance with the emissions limit or standard, and it has pre-controlled emissions from a
regulated air pollutants that are equal to or greater than 100 percent of the amount, in tons per
year, required for a source to be classified as a major source [40 CFR 64.2(a)]. Since the skull
lancing operation does not have the pre-controlled potential to emit more than 100 TPY of
PM, CAM does not apply.
SKULL LANCING OPERATION EMISSIONS
The expected skull lancing operation PM emissions are 0.18 lb/hr. This is based on the most
recent stack test data (2011) and the expected hours of operation.
NUCOR STEEL TUSCALOOSA, INC. Facility No.: 413-0033 Statement of Basis
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HOT ROLLING MILL
DESCRIPTION POLLUTANT EMISSION
LIMIT REGULATIONS
Hot Rolling Mill (HRM) Opacity No more than one 6 min
avg. > 20%
AND
Rule 335-3-4-.01(1)(a)
No 6 min avg. > 40% Rule 335-3-4-.01(1)(b)
STATE REGULATIONS
ADEM Admin. Code r. 335-3-4-.01(1)(a) and (b), “Visible Emissions” for
Control of Particulate Emissions
Applicability:
The opacity of the particulate off of stack associated with the hot rolling mill would be subject
to the standards in this subpart.
Emissions Standards:
ADEM Admin. Code r. 335-3-4-.01(1)(a) states that except for one 6-minute period during
any 60-minute periods, stationary emission sources shall not discharge into the atmosphere
particulate that results in an opacity greater than 20%, as determined by a 6-minute average.
ADEM Admin. Code r. 335-3-4-.01(1)(b) states that at no time shall a stationary emission
source discharge into the atmosphere particulate that results in an opacity greater than 40%, as
determined by a six minute average.
Compliance and Performance Test Methods and Procedures:
Method 9 of 40 CFR part 60, appendix A would be used in the determination of opacity.
Emissions Monitoring:
A visual inspection of the stack associated with the hot rolling mill will be performed at least
once per day by a person familiar with Method 9. If visible emissions are noted in excess of
10% at any time, an observation shall be performed in accordance with Method 9, and
appropriate actions shall be taken to eliminate the emissions within four hours of the initial
observation.
NUCOR STEEL TUSCALOOSA, INC. Facility No.: 413-0033 Statement of Basis
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Recordkeeping and Reporting Requirements:
The facility shall maintain the following records in a for suitable for inspection for a period of
at least five (5) years:
Each visible inspection, to include Method 9 visible observations. This should also
include problems observed and corrective actions taken.
FEDERAL REGULATIONS
40 CFR 64, “COMPLIANCE ASSURANCE MONITORING (CAM)”
Applicability:
This subpart is applicable to an emission source provided the source meets the following
criteria: it is subject to an emission limit or standard, it uses a control device to achieve
compliance with the emissions limit or standard, and it has pre-controlled emissions from a
regulated air pollutants that are equal to or greater than 100 percent of the amount, in tons per
year, required for a source to be classified as a major source [40 CFR 64.2(a)]. Since the hot
rolling mill does not have the pre-controlled potential to emit more than 100 TPY of any
regulated pollutant, CAM does not apply.
HOT ROLLING MILL EMISSIONS
The expected hot rolling mill PM emissions are 2.44 lb/hr. This is based on the most recent
stack test (2011) and the expected hours of operation.
NUCOR STEEL TUSCALOOSA, INC. Facility No.: 413-0033 Statement of Basis
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EXISTING EMERGENCY GENERATORS
DESCRIPTION POLLUTANT EMISSION
LIMIT REGULATIONS
Existing Diesel Fired Emergency
Generators
423 BHP (Pond)
800 BHP (Hot Mill)
2,168 BHP (Meltshop)
2,575 BHP (Caster)
HAPs Work or Management
Practices
40 CFR 63.6603(a)
Opacity No more than one 6 min
avg. > 20%
AND
Rule 335-3-4-.01(1)(a)
No 6 min avg. > 40% Rule 335-3-4-.01(1)(b)
STATE REGULATIONS
ADEM Admin. Code r. 335-3-4-.01(1)(a) and (b), “Visible Emissions” for
Control of Particulate Emissions
Applicability:
The opacity of the particulate from the engine stacks would be subject to the standards in this
subpart.
Emissions Standards:
ADEM Admin. Code r. 335-3-4-.01(1)(a) states that except for one 6-minute period during
any 60-minute periods, stationary emission sources shall not discharge into the atmosphere
particulate that results in an opacity greater than 20%, as determined by a 6-minute average.
ADEM Admin. Code r. 335-3-4-.01(1)(b) states that at no time shall a stationary emission
source discharge into the atmosphere particulate that results in an opacity greater than 40%,
as determined by a six minute average.
Compliance and Performance Test Methods and Procedures:
Method 9 of 40 CFR part 60, appendix A would be used in the determination of opacity.
Emissions Monitoring/Recordkeeping and Reporting Requirements:
There are no monitoring or recordkeeping and reporting requirements.
NUCOR STEEL TUSCALOOSA, INC. Facility No.: 413-0033 Statement of Basis
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FEDERAL REGULATIONS
NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP)
40 CFR Part 63 Subpart A, “General Provisions”
Applicability:
Provided that the facility is subject to one of the applicable subparts found under this part, the
facility shall comply with this regulation as specified in that subpart.
40 CFR Part 63 Subpart ZZZZ, “National Emission Standards for
Hazardous Air Pollutants for Reciprocating Internal Combustion Engines
(RICE)”
Applicability:
Per §63.6585(c) and §63.6590(1)(iii), the engines are subject to this subpart.
Emission Standards:
Per §63.6603(a), the Permittee shall comply with the work practice standards found in Table
2d (No.4) of subpart ZZZZ for each engine.
The Permittee shall comply with the fuel requirements in §63.6604(b).
Per §63.6605(b), at all times the engines must be operated and maintained, including
associated air pollution control equipment and monitoring equipment, in a manner consistent
with safety and good air pollution control practices for minimizing emissions.
Compliance and Performance Test Methods and Procedures:
These units do not require testing.
Emission Monitoring:
Per §63.6625(f), a non-resettable hour meter shall be installed on each engine.
Each engine’s time spent at idle during startup shall be minimized and the engine’s startup
time shall be minimized to a period needed for appropriate and safe loading of the engine as
specified in §63.6625(h).
Per §63.6640(a), continuous compliance with the requirements of 40 CFR part 63, subpart
ZZZZ shall be demonstrated by meeting one of the following requirements:
Operating and maintaining the stationary RICE according to the manufacturer’s
NUCOR STEEL TUSCALOOSA, INC. Facility No.: 413-0033 Statement of Basis
22
emission-related operation and maintenance instructions.
Developing and following your own maintenance plan which must provide to the
extent practicable for the maintenance and operation of the engine in a manner
consistent with good air pollution control practice for minimizing emissions.
Per §63.6640(f), these engines may be operated for the purpose of maintenance checks and
readiness testing, provided that the tests are recommended by Federal, State or local
government, the manufacturer, the vendor, or the insurance company associated with the
engine. Maintenance checks and readiness testing of these engines are limited to 100 hours
per year. There is no time limit on the use of these units in emergency situations. The owner
or operator may petition the Administrator for approval of additional hours to be used for
maintenance checks and readiness testing, but a petition is not required if the owner or
operator maintains records indicating that Federal, State, or local standards require
maintenance and testing of emergency ICE beyond 100 hours per year . These units may
operate up to 50 hours per year in non-emergency situations, but those 50 hours are counted
towards the 100 hours per year provided for maintenance and testing. The 50 hours per year
for non-emergency situations cannot be used for peak shaving or to generate income for a
facility to supply power to an electric grid or otherwise supply non-emergency power as part
of a financial arrangement with another entity. Any operation other than emergency
operation, maintenance and testing, and operation in non-emergency situations for 50 hours
per year, as permitted in 40 CFR part 63, subpart ZZZZ, is prohibited.
Recordkeeping and Reporting Requirements:
Per §63.6655(e)(2), the Permittee must keep records of the maintenance conducted on these
engines in order to demonstrate that you operated and maintained these units and after-
treatment control device (if any) according to your own maintenance plan.
Per §63.6655(f)(2), the Permittee must keep records of the hours of operation of each engine
that is recorded through the non-resettable hour meter. The facility must document how many
hours are spent for emergency operation, including what classified the operation as
emergency and how many hours are spent for non-emergency operation. If the engines are
used for demand response operation, the owner or operator must keep records of the
notification of the emergency situation, and the time the engine was operated as part of
demand response.
EXISTING EMERGENCY GENERATORS EMISSIONS
Expected emergency engine emissions (lb/hr) were calculated using manufacturer provided
emission factors and the maximum number of hours allowed for emergency operation.
NUCOR STEEL TUSCALOOSA, INC. Facility No.: 413-0033 Statement of Basis
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ENGINE EMISSIONS
(lb/hr)
PM SO2 NOX CO VOC
0.30 0.10 2.10 0.50 0.20
RECOMMENDATIONS
I recommend that Nucor Steel Tuscaloosa, Inc. be issued a renewal for its facility operating
under MSOP No. 413-0033. My recommendation is based on the fact that the facility should be
able to comply with all federal and state requirements specified in its permit.
__________________________________ DRAFT
Jennifer Youngpeter Date
Air Division
Energy Branch
Industrial Minerals Section
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