INFORMATION RELATIVE TO
THE TITLE V OPERATING PERMIT
June 8, 2020

FOR:
Nucor Steel Jackson Inc.
3630 4th Street
Flowood, MS 39232    

FACILITY DESCRIPTION
Nucor Steel Jackson Inc. (Nucor) is an existing steel “mini” mill, located in Rankin County, which produces steel rebar and merchant shapes. Nucor’s operations fall under SIC code 3312 and NAICS code 33110.  There are three major areas of the facility: the meltshop, where scrap is melted in an electric arc furnace (EAF) and cast into billets; the rolling mill where cast steel is reheated for conversion into specific final shapes; and the General Recycling area, where scrap steel is accepted and processed for reuse/recycling.  Each of these areas are supported by miscellaneous material handling and other ancillary operations.  The manufacturing process is outlined in the attached process flow diagram.

TITLE V SOURCE APPLICABILITY 
The facility’s potential-to-emit exceeds the Title V major source threshold of 100 tons per year (tpy) for each of the following criteria air pollutants: Nitrogen Oxides (NOx), Carbon Monoxide (CO), and Volatile Organic Compounds (VOC).  The facility’s potential-to-emit hazardous air pollutants (HAPs) does not exceed the major source threshold of 25 tpy of total HAPs and 10 tpy for any individual HAP.  

PREVENTION OF SIGNIFICANT DETERIORATION (PSD) APPLICABILITY
The facility is not one of the 28 categorical facilities listed in 40 CFR 52.21(b)(1)(i)(c)(iii); therefore, the PSD threshold for a major source is 250 tpy.  The facility has the potential to emit more than 250 tons per year of Nitrogen Oxides (NOx) and Carbon Monoxide (CO); therefore, the facility is considered a major stationary source.  This permitting action will not change the current PSD status of the facility.

FACILITY MODIFICATIONS AND/OR PERMIT CHANGES
•	In April 2018, Nucor submitted a 502(b)(10) operational flexibility change request to replace the bags in the baghouse at Emission Point AB-001 (the EAF baghouse) with Gore low drag filter bags.  This change does not affect any of the existing permit conditions.

•	In the permit application, Nucor requested that the annual VOC stack testing requirement for Emission Points AB-001 and AB-002 be removed, because of Nucor’s margin of compliance with the 16.22 lb/hr limit, as summarized in the table below.  In lieu of removing the VOC stack testing requirement entirely, MDEQ has reduced the frequency of VOC stack test monitoring from annually to once every five (5) years.  This requirement can be found in Condition 5.B.7.

Test Date	VOC (lb/hr)	Margin of Compliance (%)	
	AB-001	AB-002	Combined		
04/13/2012	0.055	5.95	6.005	65	
04/09/2013	0.59	0.11	0.7	96	
04/09/2014	2.42	2.76	5.18	69	
04/23/2015	0.14	0.07	0.21	99	
04/21/2016	0.8	0.6	1.4	92	
03/22/2017	0.16	2.02	2.18	87	
03/22/2018	2.39	2.06	4.45	74	

•	In the permit application, Nucor requested that the limits for PM included in the permit indicate that the limit is for filterable particulate matter only, on the basis that the limits were established in the PSD Construction Permit issued in 2008, prior to the EPA’s requirement that on or after January 1, 2011, condensable particulate matter be accounted for in applicability determinations and in establishing emissions limitations for PM2.5 and PM10 in PSD permits.  The PM limits in Conditions 3.B.5, 3.B.6, 3.B.7, and 3.B.18 have been edited to clarify the limits are for filterable PM only.

•	Nucor operates a Gas Dispensing Facility (GDF) on-site, which is subject to the requirements of 40 CFR 63, Subpart CCCCCC.  Therefore, the GDF has been added as emission point no. AH-000 in the Section 2 table – Emission Points & Pollution Control Devices.

•	A 0.0052 gr/dscf limit for PM has been added for Emission Points AB-001 and AB-002, from Subparts YYYYY and AAa.  This limit can be found in Condition 3.B.5.

•	The previous permit contained a condition (5.B.2) for emission points AB-001 and AB-002, which required the permittee to utilize operational ranges developed to provide a reasonable assurance of compliance with SO2, CO, and VOC limits.  This permit condition has been removed because adequate demonstrations of compliance are already incorporated into the permit; Nucor has CEMS installed for monitoring SO2 and CO and conducts stack testing for VOC. 

•	The previous permit contained a condition (5.B.21) for emission point AF-001 which required the permittee to utilize operational ranges developed to provide a reasonable assurance of compliance with the process weight PM limit.  This unit is already subject to CAM for PM; therefore, this permit condition is no longer needed and has been removed.

•	The previous permit contained a condition (5.C.11) for emission point AH-000 which required the permittee to submit malfunction reports in accordance with 40 CFR 63.111126(b) – Subpart CCCCCC.  This condition was removed, because 40 CFR 63.111126(b) states: “You are not required to submit notifications or reports as specified in 63.11125, 63.11126, or subpart A of this part, but you must have records available within 24 hours of a request by the Administrator to document your gasoline throughput.”

•	For the CEMS associated with emission points AB-001 and AB-002, semiannual reporting requirements have been added in Condition 5.C.3.

•	Many permit conditions have been moved, condensed, and/or the language edited for clarity.  

COMPLIANCE ASSURANCE MONITORING (CAM) APPLICABILITY
40 CFR Part 64 specifies the requirements for CAM.  The general applicability of this rule can be found in 40 CFR 64.2 and requires a Title V source to comply with the CAM requirements if all three of the following criteria are met for a pollutant-specific emission unit (PSEU):

1.	The unit is subject to an emission limitation or standard for a regulated air pollutant other than exemptions under 40 CFR 64.2(b)(1);
2.	The unit uses a control device to comply with the standard; and
3.	The unit has pre-control emissions exceeding Title V major source threshold.

Control equipment used for emission points with applicable standards are evaluated in the table below.  There is no other control equipment associated with any emission units subject to an emission limit or standard at this facility.

CAM Applicability Table for Sources with Control Devices
Emission Point ID	Control Device 
(not including inherent controls)	Applicable Limit/ Standard	Is standard exempt? (Yes/No)	Pre-Control > 100 tpy (Yes/No)	CAM Applies? (Yes/No)	Type of CAM PSEU
(Large/Other)	
AB-001	Baghouse	0.0018 gr/dscf (BACT)	No	Yes	Yes	Other	
AB-002	Baghouse		No	Yes	Yes	Other	
AF-001	Cyclone	PM process weight	No	Yes	Yes	Other	

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) APPLICABILITY

40 CFR 63, Subpart CCCCCC – National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities
The affected source to which this subpart applies is each gasoline dispensing facility (GDF) that is located at an area source.  The affected source includes each gasoline cargo tank during delivery of product to a GDF and also includes each gasoline storage tank.  Nucor maintains a GDF with a monthly throughput of less than 10,000 gallons and is subject to the requirements of 40 CFR 63.11116.

40 CFR 63, Subpart YYYYY – National Emission Standards for Hazardous Air Pollutants for Area Sources: Electric Arc Furnace Steelmaking Facilities.
Subpart YYYYY is applicable to electric arc furnace (EAF) steelmaking facilities that are an area source.  Nucor is an EAF steelmaking facility and is an area source, therefore, Nucor is subject to Subpart YYYYY.  

NEW SOURCE PERFORMANCE STANDARDS (NSPS) APPLICABILITY

40 CFR 60 Subpart AA – Standards of Performance for Steel Plants: Electric Arc Furnaces Constructed After October 21, 1974, and on or Before August 17, 1983
This subpart applies to facilities in steel plants that produce carbon, alloy, or specialty steels and commence construction, modification, or reconstruction after October 21, 1974, and on or before August 17, 1983.  The affected units were constructed before October 21, 1974 and were modified after August 17, 1983.  Therefore, this subpart does not apply

40 CFR Part 60, Subpart AAa – Standards of Performance for Steel Plants: Electric Arc Furnaces and Argon-Oxygen Decarburization Vessels Constructed After August 17, 1983
Subpart AAa applies to the following affected facilities located at steel plants that produce carbon, alloy, or specialty steels: electric arc furnaces, argon-oxygen decarburization vessels, and dust-handling systems that commence construction, modification, or reconstruction after August 17, 1983.  Nucor meets this applicability criteria; therefore, Subpart AAa applies. 

40 CFR 60 Subpart Kb – Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for which Construction, Reconstruction, or Modification Commenced After July 23, 1984
Subpart Kb applies to each storage vessel containing a volatile organic liquid that is greater than 19,183 gallons in capacity and has been constructed, reconstructed, or modified after July 23, 1984.  All tanks currently in use at the Nucor Mill have capacities below 19,183 gallons and are therefore not subject to Subpart Kb.

SPECIFIC APPLICABLE REQUIREMENTS
The following table summarizes the emissions limitations and monitoring requirements required to demonstrate compliance with each limitation.  Work practice standards are excluded from the table.  For a complete listing of all work practice standards, monitoring, recordkeeping, and reporting requirements, see the Title V permit.

Emission Point No.	Pollutant	Draft Permit Emission Limits	Monitoring Requirements	
AB-000	Opacity	6%	Conduct daily VEEs from the melt shop when the furnace is operating in melting and refining period	
AB-001
AB-002	Opacity	3%	Conduct daily VEEs from the control devices when the furnace is operating in melting and refining period	
AB-001
AB-002	PM
(filterable only)	36.1 tpy (combined limit)
 0.0018 gr/dscf (each)
0.0052 gr/dscf 	Conduct biennial stack testing 

Comply with CAM requirements	
AB-001
AB-002	VOC	0.2323 lb/ton of liquid steel
16.22 lb/hr
63.24 tpy
(combined limits)	Conduct stack testing every 5 years	
AB-001
AB-002	SO2	0.2323 lb/ton of liquid steel
16.22 lb/hr
63.24 tpy
(combined limits)	Continuous Emissions Monitoring System (CEMs)	
AB-001
AB-002	CO	2.141 lb/ton of liquid steel
149.47 lb/hr
582.95 tpy
(combined limits)	Continuous Emissions Monitoring System (CEMs)	
AB-001
AB-002	NOx	0.27 lb/ton of liquid steel (BACT)
16.95 lb/hr
74.24 tpy
(combined limits)	Continuous Emissions Monitoring System (CEMs)	
AB-001
AB-002	Lead	0.12 tpy	These units are subject to CAM for PM.  Lead should be a component of the PM standard – therefore, complying with CAM requirements should also assure compliance with the Lead limit.	
AC-000	Opacity	10%	Maintain and implement the Operation & Maintenance Plan developed to ensure compliance	
AD-001	SO2	0.5 tpy	Utilize maintenance schedules, direct visual observations of the equipment/stack, and various parameter monitoring	
	CO	24.5 tpy		
	VOC	3.42 tpy		
	PM/PM10/PM2.5
(filterable only)	3.1 tpy		
	NOx	162.5 tpy		
AF-000	PM	E = 4.1(p)0.67	Operate cyclone and comply with CAM requirements