NUCOR STEEL TUSCALOOSA INC · 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

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


................................................................................................................................................ 12

FEDERAL REGULATIONS ............................................................................................................. 14


EQUALIZING FURNACE EMISSIONS ............................................................................................... 14

SKULL LANCING OPERATION W/ BAGHOUSE ....................................................................... 15


ADEM Admin. Code r. 335-3-4-.01(1)(a) and (b), “Visible Emissions” for Control of Particulate

Emissions ................................................................................................................................ 15


................................................................................................................................................ 16

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SKULL LANCING OPERATION EMISSIONS ...................................................................................... 17

HOT ROLLING MILL ................................................................................................................ 18



Emissions ................................................................................................................................ 18



HOT ROLLING MILL EMISSIONS ................................................................................................... 19

EXISTING EMERGENCY GENERATORS .................................................................................. 20



Emissions ................................................................................................................................ 20


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)


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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.


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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


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


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


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


Filterable and condensable PM2.5 emissions from the meltshop baghouses shall not


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


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


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


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%.


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.


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


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)].


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:



10


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.


The Permittee shall use the test methods in §63.10686(d) to demonstrate compliance with the

emission standards in §63.10686(b).


The Permittee shall comply with the monitoring requirements in §63.10686(d)-(e).


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:


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


12

EQUALIZING FURNACE (400 MMBTU/HR)


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


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.


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.


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.


14






FEDERAL REGULATIONS


Applicability:





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


15

SKULL LANCING OPERATION W/ BAGHOUSE


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.


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


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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.






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.


Method 5 of 40 CFR part 60, appendix A shall be used in the determination of PM emissions.


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.




A record of each weekly inspection and the results of each annual inspection.


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FEDERAL REGULATIONS


Applicability:





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.


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HOT ROLLING MILL


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



Applicability:

The opacity of the particulate off of stack associated with the hot rolling mill would be subject

to the standards in this subpart.






source discharge into the atmosphere particulate that results in an opacity greater than 40%, as

determined by a six minute average.



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.


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FEDERAL REGULATIONS


Applicability:





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.


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EXISTING EMERGENCY GENERATORS


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



Applicability:

The opacity of the particulate from the engine stacks would be subject to the standards in this

subpart.






source discharge into the atmosphere particulate that results in an opacity greater than 40%,

as determined by a six minute average.



Emissions Monitoring/Recordkeeping and Reporting Requirements:

There are no monitoring or recordkeeping and reporting requirements.


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FEDERAL REGULATIONS

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP)

40 CFR Part 63 Subpart A, “General Provisions”

Applicability:



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.


These units do not require testing.


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


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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.


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.


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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

Documents

NUCOR STEEL TUSCALOOSA INC · 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