Document 4JOmv9XgYGNVJbgGNyqx17vqQ
EPA Inspection Report - Page 1 of 25
Region 6 - Enforcement & Compliance Assurance Division
INSPECTION REPORT
Inspection Date(s): Media Program: Regulatory Program(s)
03/22/2022 - 3/23/2022 Clean Air Act (CAA) Louisiana SIP, Title V, NESHAP (40 CFR Part 63), NSPS (40 CFR Part 60)
Company Name: Facility Name: Facility Physical Location:
(city, state, zip code) Mailing address:
(city, state, zip code) County/Parish: Facility Phone Number Facility Contact:
Nucor Steel Louisiana LLC Nucor Steel Louisiana 9101 LA Hwy 3125 Convent, LA 70723 9101 LA Hwy 3125 Convent, LA 70723 St James Parish (225) 331-4000 Marshall Crawford Marshall.Crawford@nucor.com
Environmental Manager
FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC:
110046325400 LDEQ AI 157847, Permit 3086-V9 CEDRI10079752; ICIS 3601404200
331110 Iron and Steel Mills and Ferroalloy Manufacturing
See NAICS
Personnel participating in inspection:
Prince Nfodzo
EPA Region 6 ECDAP
Aimee Boss
EPA Region 6 ECDAP
Cory Lormand
LDEQ, Baton Rouge
Sean Kelley
LDEQ, Baton Rouge
Adam Broussard
LDEQ, Baton Rouge
Marshall Crawford
Nucor Steel Louisiana
Erica Caruso
Nucor Steel Louisiana
Lane Grant
Nucor Steel Louisiana
Beth Brown
Nucor Steel Louisiana
Calvin Hart
Nucor Steel Louisiana
Kelly Phillips
Nucor Steel Louisiana
Environmental Engineer, Lead Inspector Physical Scientist, Inspector-in-Training Environmental Scientist Environmental Scientist Environmental Scientist Environmental Manager Environmental Engineer Technical Manager Environmental Coordinator General Manager Environmental Engineer
EPA Lead Inspector Signature/Date
PRINCE NFODZO
Digitally signed by PRINCE NFODZO DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=PRINCE NFODZO, 0.9.2342.19200300.100.1.1=68001003655862 Date: 2022.05.09 09:54:16 -05'00'
Prince Nfodzo
Date 04/25/2022
Branch Chief Signature/Date
STEVEN THOMPSON Date: 2022.05.09 09:46:51 -05'00' Digitally signed by STEVEN THOMPSON Steve Thompson
Date
6ENFORM-019-R8.2 (02/12/2020)
1
EPA Inspection Report - Page 2 of 25
Section I - INTRODUCTION
Nucor Steel Louisiana, LLC/DRI Facility Inspection dates: 03/22-23/2022
PURPOSE OF THE INSPECTION EPA Region 6 inspectors Prince Nfodzo and Aimee Boss, and LDEQ inspectors Corry Lormand and Sean Kelley arrived at the Nucor Steel Louisiana LLC (Nucor) Direct Reduced Iron (DRI) Facility at 8:40 am on March 22, 2022, for an announced inspection. We met with Nucor representatives Marshall Crawford (Environmental Manager), Kelly Phillips (Environmental Engineer), Calvin Hart (General Manager), Lane Grant (Manager), Beth Brown (Environmental Coordinator), and Erica Caruso (Environmental Engineer). I (Prince Nfodzo) presented my credentials to Marshall Crawford and informed them that this was an EPA follow up inspection to an ongoing investigation regarding Nucor's compliance with the facility's Title V Air Permit and the Clean Air Act. The facility is the subject of an October 27, 2021, petition by Inclusive Louisiana, the Louisiana Bucket Brigade and three individual residents of St. James Parish to EPA to overfile the Louisiana Department of Environmental Quality's (LDEQ) proposed settlement with Nucor for several CAA violations. EPA Region 6 previously issued a Notice of Violation and Opportunity to Confer letter to address unauthorized emissions of hydrogen sulfide and sulfuric acid (H2SO4) mist, and exceedance of permitted annual limits for sulfur dioxide emissions. The scope of the inspection is a full compliance evaluation (FCE) under applicable provisions of the CAA, and includes evaluation of the compliance of the facility with its Title V operating permit, and complaints from the community regarding noxious odors.
FACILITY DESCRIPTION Nucor's DRI facility is located at 9101 LA Hwy 3125, in Convent, St. James Parish, Louisiana. The DRI process reduces the iron oxide content of iron ore pellets into iron metal through direct contact with a reducing gas. The effectiveness of this reduction process is called metallization. The process equipment is designed to achieve a metallization rate of at least 92% of the oxides within the ore. The reduction takes place in a countercurrent vertical shaft furnace, where reducing gas passes up through iron oxide pellets which feed downward through the furnace by gravity. The major elements of the DRI process include iron oxide preparation, reducing gas preparation, operation of the DRI reactor shaft furnace, spent reducing gas preparation for reuse, DRI product handling, and, ancillary operations, including two package boilers, two cooling towers, and a flare for controlling vent gas during emergency situations. The detailed facility and process description is included as Appendix 3.
Section II - OBSERVATIONS
A. Generators Nucor operates seven (7) emergency generators at the DRI facility which are subject to NSPS Part 60 Subpart IIII. We inspected the generators and I reviewed operating and maintenance records. I observed that Nucor is maintaining the generators per the manufacturers' requirement and keeps records as required. I observed that the generators are equipped with non-resettable hour meters as required under 60.4209(a). Photographs of a representative generator's boilerplate information and hour meter are included as Photo Nos. 2 and 3 in Appendix 1. I verified that the generator boilerplate information matches Nucor's records. I reviewed Nucor's permit 3086-V9 and noticed that one
2
EPA Inspection Report - Page 3 of 25
Nucor Steel Louisiana, LLC/DRI Facility Inspection dates: 03/22-23/2022
generator listed in the permit has not been installed and is not operating on site (see Area of Concern (AOC) #4). Additionally, some of the generators are not properly represented in the permit (see AOC #5).
B. Baghouse/Dust Filters We inspected the baghouse and dust filters and did not observe any visible emissions from the exhaust outlets or housings. I reviewed Daily Visible Emissions and Differential Pressure Monitoring records, and observed that Nucor maintained records as required by permit 3086-V9. Nucor previously kept records electronically, but since May 17, 2021, has maintained hard copies of monitoring records. I noted that Nucor's electronic recording system did not have sufficient detail for some entries, and had inconsistencies in other data entered (see AOC #1). Additionally, a number of paper records did not provide information in sufficient detail (see AOC #2). Excerpts from the records reviewed are included as Appendix 4.
C. Particulate Matter Control Specific Requirement (SR) 33 of Nucor's permit requires Nucor to provide partial enclosures and/or water sprays for loading, drop points, and material stockpiles; to water unpaved roadways; and, to periodically sweep paved roads. We did not observe any visible airborne dust emissions from stockpiled materials or roadways. We noticed that unpaved roadways were being watered while we were on site. I reviewed roadway watering and sweeping records, and noticed that Nucor kept the required records. However, I also noticed that recordkeeping inconsistencies revealed that some roadways were not watered during some periods (see AOC #6). Excerpts of the roadway watering log and roadway status information are included as Appendix 5.
D. Process Heater and Boilers SR 63 of Nucor's permit requires Nucor to operate the process heater with good air pollution control equipment and practices and comply with best available control technology (BACT) emission limits for carbon monoxide (CO) , nitrogen oxides (NOx), sulfur dioxide (SO2), and particulate matter (PM), and good combustion practices for volatile organic compounds (VOCs). Additionally, SR 60 requires Nucor to monitor NOx emissions with a continuous emissions monitoring system (CEMS). We verified that Nucor has installed a selective catalytic reduction (SCR) unit to control NOx emissions and is operating a NOx CEMS. A photograph of the CEMS analyzer is included as Photo No. 1 in Appendix 1. I verified that certification and concentration of calibration gases were accurate and current. We observed that a calibration gas bottle was not properly secured, and Nucor properly secured the bottle the next day. I reviewed audit records and noticed that Nucor did not operate and maintain the CEMS at all times in accordance with the requirements of NSPS Part 60 Appendix F (see AOC #7). I reviewed CEMS emissions records and noticed that Nucor exceeded the NOx limit on several occasions (see AOC #8). Per SR 59, Nucor is required to conduct a performance test (PT) every five (5) years. I reviewed reports for PTs conducted in 2015, 2020, and 2021, and noticed that Nucor exceeded emission limits during tests performed in 2020 and 2021 (see AOC #9). Nucor operates two (2) natural gas-fired package boilers at the DRI facility. I reviewed and verified that Nucor kept fuel records, and maintained boilers as required.
3
EPA Inspection Report - Page 4 of 25
Nucor Steel Louisiana, LLC/DRI Facility Inspection dates: 03/22-23/2022
I reviewed reports for performance tests conducted for both boilers in 2020, and noted that emission limits were not exceeded.
E. Flares Nucor operates an emergency flare. During the inspection, we did not observe any visible emissions from the flare. I viewed the flare tip exit with a Forward Looking Infrared (FLIR) optical gas imaging camera and did not observe any hydrocarbon emissions. I reviewed flare records and noted that Nucor maintained records as required by NSPS and the facility's air permit.
F. DRI Unit 2 Nucor's Title V Permit includes provisions for a second DRI unit. Since Nucor no longer wishes to construct and operate the second DRI unit, Nucor should remove all equipment and emission representations associated with the second unconstructed unit from their permit (see AOC #3)
Section III - AREAS OF CONCERN
1. The electronic system used for recording visible emissions monitoring does not provide sufficient detail on the observations made. The data system only notes whether visible emissions were observed or not, and does not provide any additional information or comments. Additionally, inconsistencies were noted in the records, for example, the records show that on 5/14/2021, VE DC11 and VE DC-12 were both not in service (indicated with a `0"), yet visible emissions were observed (indicated with a "1").
2. Paper records of visible emissions monitoring show incomplete information, insufficient detail, and wrong entries. For example, records from 11/7/2021 show time entries for EQT 0176 and EQT 0177 as 6.0 and 3.0 respectively, instead of recognizable time designations. Additionally, the form is prepopulated with an opacity of 20. Based on the content of the records reviewed, it appears that the records from the technicians are not checked for accuracy or completeness before filing.
3. Nucor's Title V permit includes provisions for the construction of DRI Unit 2, including emissions representation for a Furnace Dust Collection system and a Package Boiler which are aggregated in the facility's total emissions. Since Nucor has no intention to construct the additional unit, the DRI Unit 2 with its associated equipment and emission representations should be removed from the Title V and PSD permits.
4. Nucor's Title V permit includes provisions for the construction/installation of six (6) emergency generators. However, only five (5) generators were installed and operating. Since Nucor has no intention to construct/install the additional generator (represented as EQT 0171), this unit with its associated emission representations should be removed from the Title V permit.
5. Information Nucor provided regarding the generators show that some of the generators are incorrectly represented in the Title V permit. For example, all five of the operating emergency generators are grouped and permitted as being subject to 40 CFR 60.4205(b): "Owners and operators of 2007 model year and later emergency stationary CI ICE with a displacement of less than 30 liters per cylinder that are not fire pump engines must comply with the emission standards for new nonroad CI engines in 60.4202, for all pollutants, for the same model year and maximum
4
EPA Inspection Report - Page 5 of 25
Nucor Steel Louisiana, LLC/DRI Facility Inspection dates: 03/22-23/2022
engine power for their 2007 model year and later emergency stationary CI ICE." However, generator information Nucor provided shows that EQT 0122 has a displacement of 65.3 liters per cylinder, and should comply instead with 40 CFR 60.4205(d): "Owners and operators of emergency stationary CI engines with a displacement of greater than or equal to 30 liters per cylinder must meet the requirements in this section." Nucor should review and modify its permit as appropriate to ensure that each generator is properly represented with regard to applicable rules and requirements. 6. Based on records reviewed, there have been several occasions when some roadways were not watered for a long period of time. For example, there is no record of watering roadways 9, 10, 11, 12, 13, 14, 15, 16, 17, A, and B for the period of November 1 - 17, 2021. Nucor's explanation that the roadways were not in use at such times is inconsistent with the records provided. Separate additional information provided by Nucor on roadway status showed that only roadways 9, 10, 11, 12, and A were not in use during the period. 7. NSPS Part 60 Appendix F requires CEMS to be audited quarterly and successive audit conducted not closer than two months. Nucor conducted a Cylinder Gas Audit (CGA) for the Process Heater NOx CEMS 3/13/2019 and a Relative Accuracy Test Audit (RATA) 5/7/2019. Additionally, Nucor did not conduct a CGA during the 4th quarter of 2021. NSPS Part 60 Appendix F also requires that RATA be conducted after every three quarters of conducting a CGA. Nucor did not conduct a RATA during the 2nd quarter of 2020 after conducting CGAs for the 3rd and 4th quarters of 2019 and 1st quarter of 2020. 8. CEMS data reviewed shows that Nucor exceeded the Process Heater NOx emission limit on several occasions. Additionally, there were several occasions that the NOx CEMS was out of service or out of control, and the data acquisition system (DAS) was out of service. 9. Performance Test reports reviewed show that Nucor exceeded PM, CO, SO2, H2SO4 emission limits during the test conducted 1/14/2021 and PM, VOC, CO, SO2 emission limits during the test conducted 11/17-18/2020
EPA Region 6 inspectors Prince Nfodzo and Aimee Boss conducted an inspection closing conference at Nucor Steel Louisiana LLC DRI Facility at 12:15 pm on March 23, 2022. During the closing conference, I presented preliminary findings of the inspection and reviewed AOC #s 1 - 3, which were noted during the inspection. I informed the company representatives present at the closing conference of the procedures that EPA will follow the field inspection, and that the inspection report will be made public on EPA's website. AOC #s 4-9 were determined after the conclusion of the inspection and were not identified or discussed during the closing conference. The sign-in sheets for the opening and closing conferences are included as Appendix 2.
Section IV - FOLLOW UP
After the EPA inspection team exited the Facility on March 23, 2022, Nucor uploaded all the information requested during the inspection to an EPA shared OneDrive folder by March 25, 2022. On April 5, 2022, I requested information regarding Process Heater NOx emissions and CEMS downtime, and had a followup call with Nucor representatives to discuss the data provided. The additional information regarding NOx emissions and CEMS downtime was uploaded to the shared folder on April 8, 2022.
5
EPA Inspection Report - Page 6 of 25
Nucor Steel Louisiana, LLC/DRI Facility Inspection dates: 03/22-23/2022
Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 3 photos taken 3/22/2022 Appendix 2 - Opening and closing conference sign-in sheets Appendix 3 - Facility and Process Description Appendix 4 - Daily Visible Emissions and Differential Pressure Monitoring Appendix 5 - Roadway watering log and roadway status information There was no video recorded during the inspection.
6
EPA Inspection Report - Page 7 of 25
Nucor Steel Louisiana LLC / DRI Facility Inspection Dates: 03/22-23/2022
Appendix 1 Photograph Log
EPA Inspection Report - Page 8 of 25
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 1
Location: Nucor Steel Louisiana - DRI Facility
City: Convent
County/Parish: St James
State: Louisiana
Photo File Name: Date of Photo: Time of Photo: Photographer: Description:
DSCN0770.JPG March 22, 2022 12:42 pm Aimee Boss Process Heater NOx CEMS
EPA Inspection Report - Page 9 of 25
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 2
Location: Nucor Steel Louisiana - DRI Facility
City: Convent
County/Parish: St James
State: Louisiana
Photo File Name: Date of Photo: Time of Photo: Photographer: Description:
DSCN0771.JPG March 22, 2022 12:55 pm Aimee Boss Emergency Generator EQT 0122 Engine Information
EPA Inspection Report - Page 10 of 25
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 3
Location: Nucor Steel Louisiana - DRI Facility
City: Convent
County/Parish: St James
State: Louisiana
Photo File Name: Date of Photo: Time of Photo: Photographer: Description:
DSCN0773.JPG March 22, 2022 12:57 pm Aimee Boss Emergency Generator EQT 0122 Non-resettable hour meter
EPA Inspection Report - Page 11 of 25
Appendix 2 Opening and closing conference sign-in sheets
,;.
EPA Inspection Report - Page 12 of 25 FRS:110046325400 Nucor Steel Louisiana, LLC - ORI Facility
Page 3 of 27
Opening/Pre-Inspection Meeting
Commence opening/pre-inspection meeting________3__/_~_?::_/___'_~_?:-:_____________Time: q 0 0 q"-1,
Name Prince Nfodzo Aimee Boss
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If EPA Inspection Report - Page 13 of 25 FR S:110046325400 Nuco r
uisiana, LLC - ORI Facility Page 25 of 27
Exit interview I Out-briefing Meeting
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EPA Inspection Report - Page 14 of 25
Appendix 3 Facility and Process Description
LDEQ-EDMSEPDAoIncsupmecetniotn1R2e2p5o2r3t 4- 2P,aPgeag15e
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o2f559
AIR PERMIT BRIE FI NG SHEET AIR PERMITS DIVISIO N
LO UISIANA DEPARTMENT OF ENVIRONMENTAL QUA LITY
Direct Reduced Iron Facility Agency Interest No.: 157847 Nuco r Steel Louisiana, LLC Convent, St. J ames Parish, Louisiana
I. Background
Nucor Steel Louisiana, LLC (Nucor) owns and operates the Direct Reduced Iron (DRf) Facility in Convent, Louisiana, under permits 3086-VS (dated January 30. 2020) and PSDLA-75l (M3) (dated June 13, 2019).
II. Origin
A permit application dated April 27, 2020, was submitted requesting a permit modificati on.
Ill. Description
The ORT process reduces the iron oxide content of iron ore pellets into iron metal through direct contact with a reducing gas. The effectiveness of this reduction process is called metallizati on. and the process equipment is designed to achieve a metall ization rate ofat least 92% of the oxides within the ore. The reduction takes place in a countercun-ent ve11ical shalt furn ace, where reducing gas passes up through iron oxide pellets which feed through the furnace by gravity. The major elements of the ORT process include the fol lowing: ( I) iron oxide preparation; (2) reducing gas preparation; (3) DRI reactor shaft furnace; (4) spent reducing gas preparation fo r reuse; (5) ORI product handling; and (6) ancil lary operations, including two package boi lers, two cooling towers, and a fl are for emergency situations.
Tron Oxide Preparation
Iron oxide pellets are brought to the site by ship. The iron oxide pellets are unloaded onto a conveying system and transferred to storage piles. From the storage piles, the iron oxide pellets are screened and coated with a cement mixture in preparation for charging to the ORI reactor furnace. Emissions include particulate matter from the iron oxide screening. conveying, and coating operations. Any excess iron ox ide fines are transferred to storage and sold to customers.
Reducing Gas Preparation
Reducing gas requires preparation prior to introduction into the DRI reactor shaft furnace, and much of the reactor furnace off-gas is reused in the process. Reducing gas is generated initially from natural gas, which is heated by the process heater to an elevated temperature. At this elevated temperature, and in the presence of iron as a catalyst, the natura l gas dissociates into a reducing gas rich in carbon monoxide and hydrogen, which are the primary reductants for the process:
CH4 + C0 2 -. 2CO + 2H2
CH4 + H~O ~ CO + 3H2
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AIR PERMIT BRIEFING SHEET AIR PERMITS DIVISION
LOUISIANA DEPARTMENT OF ENVIRONMENTAL QUALITY
Direct Reduced Iron Facility Agency Interest No.: 157847 Nucor Steel Louisiana, LLC Convent, St. James Parish, Louisiana
DRJ Reactor Shaft Furnace
The DRI reactor shaft furnace is a countercurrent vertical shaft furnace, where reducing gas is passed up through the iron oxide pellets which are charged into the shaft furnace. The carbon monoxide and hydrogen of the reducing gas scavenge oxygen from the iron oxides from the iron oxide pellet charge in the shaft furnace, reducing the oxygenation state of the ores. The resulting products of the reduction process are pure iron, carbon diox ide, and water:
Fe203 + 3H2 ~ 2Fe + 3H20
Fe203 + 3CO ~ 2Fe + 3C02
The rate at which these reactions occur determines the residence time needed to metal lize the iron oxide pellets into DRI product, which typically takes several hours. Once the metallization process is complete, the metalized DRI pellets are cooled and discharged to the cold product pressurized discharge bins.
Spent reducing gas preparation for reuse
Once the process has initiated, spent reducing gas exits the top of the ORI reactor shaft furnace and is cooled and passed through a scrubber to remove entrained dust and excess moisture. A po11ion of thi s gas is then prepared for reuse as reducing gas by removing acid gases such as C02, H:~S, and other reduced sulfur compounds. The reducing gas is passed through an amine absorber which strips it of the acid gas components. The cleaned reducing gas may then be adjusted with sulfur (refonner-less process) and/or natural gas prior to preheating and reforming in preparation for reintroduction into the DRI reactor shaft furnace. Oxygen injection may occur just prior to the shaft furnace to further enhance the reaction.
The acid gases removed by the amine absorption system are passed through an iron-based catalyst bed to capnLre sulfur compounds. After passing through the catalyst, the resulting off-gas is nearly pure carbon dioxide. The captured carbon dioxide may be pipelined and sold to offsite customers. Sulfur is captured by a proprietary sulfur recovery system and is sold as a product or disposed, depending on quality and market conditions.
The remaining top gas leaving the furnace, after the removal ofacid gases, contains unreacted carbon monoxide and hydrogen. This gas is routed to the process gas heater for use as fuel.
ORI Product Handling
Any excess ORI fines are sent to the briquetting plant and then conveyed to the DRI product silos where they are blended with ORI pellets and sold to customers. Product DRl is conveyed from the storage silos back to the docks, where it is loaded onto barges fo r shipment to Nucor's electric arc furnace mi lls and/or outside customers.
Anci llary Operations
Add itional sources serving the DRI facility include two package boilers, two cooling towers, plant roads, and several dust collection points controlled by baghouse filters.
2
EPA Inspection Report - Page 17 of 25
Appendix 4 Daily Visible Emissions and Differential Pressure Monitoring
EPA Inspection Report - Page 18 of 25
TEST_DATE
'VE DC-11 - lnService'
'VE DC-11- VE'
04/17/2021 00:00:00
1
0
04/18/2021 00:00:00
1
0
04/19/2021 00:00:00
1
0
04/20/2021 00:00:00
1
0
04/21/2021 00:00:00
1
0
04/22/2021 00:00:00
1
0
04/23/2021 00 :00:00
1
0
04/24/2021 00 :00 :00
1
0
04/25/2021 00 :00:00
1
0
04/26/2021 00 :00 :00
1
0
04/27/202100 :00:00
1
0
04/28/2021 00 :00:00
1
0
04/29/2021 00:00:00
1
0
04/30/2021 00 :00:00
1
0
05/01/2021 00:00:00
1
0
05/02/2021 00:00:00
1
0
05/03/2021 00 :00:00
1
0
05/04/2021 00 :00:00
1
0
05/05/2021 00 :00:00
1
0
05/06/2021 00 :00:00
1
0
05/07/2021 00 :00:00
1
0
05/08/2021 00 :00:00
1
0
05/09/2021 00:00:00
1
0
05/10/2021 00:00 :00
' 1
0
05/11/2021 00:00 :00
1
0
05/12/2021 00:00 :00
1
0
05/13/2021 00 :00 :00
1
0
05/14/2021 00:00:00
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05/15/2021 00 :00 :00
1
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05/16/2021 00 :00:00
1
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'VE DC-12 - DP'
1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1
'VE DC-12 - lnService'
'VE DC-12 - VE '
1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1
' 1 1
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
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'VE DC-13 - DP'
1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1
'VE DC-13 - lnService'
1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1
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EPA Inspection Report - Page 19 of 25
~
Daily Visible Emissions Monitoring Record - Nucor Steel Louisiana Reference FOP 3086-V9
Observer(s) :
[1] If applicable, attach a completed Method 9 form and schematic. If there are no VE's present, leave Method 9 result's column blank.
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Date: l 1 I 7 I J.oJ'
Emission Point No.
Source Name
Time
Equipment In Service?
Y/N
Visible Emissions?
Y/N.
Method 9 111 completed?
Y/N
Soecific Renuirement No. 20 (Ooacify) Soecific Reauirement No. 27 IVEO) - Baahouses/Dust Filters - Visible Emissions of Filter Vents Monitored Oailv
Soecific Reauirement No. 25 - Differential Pressure Monitored Oailv
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DC-2 Transfer Tower 2 South
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DC-4 Iron Ore Screen Tower East
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DC-5 Iron Ore Screen Tower RJject Bin
EQT0102 DC-6 Iron Ore Feed Bin Tower
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OC-12 Cold DR! Screening Stat(on
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OC-13 Cold DRI Fines/Dust Silo'.
OC-14 DR! Product Silos
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DC-15B ORI Product Screen House South
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YIN'
Check the status which applies:
Normal Operations V
Outage I Shutdown D
All DC's are oos
o
* If all DC's are OOS is checked then sign, date, & submit form.
-- l
I
Method 9 111 Result
DP Reading
I
I
1
Opacity
_J.;.1
s20%
), '-(o
s20%
.2, O'-f
S20%
3.11
s20%
l .) s
s20%
'-1- 1y
s20%
3. <;>!
s20%
3. '1 l
S20%
l-, 'i
s20%
i'~- , ~
s20%
3. s20%
5..). ~
s20%
J:. "'\ I
s20%
~-1 L-(
S20%
~ ~ ')~
s20%
Comments:
NSLA Env Dept, VEO Log
Revision Dl Revised Date: 8/17/21
EPA Inspection Report - Page 20 of 25
..........._. .
Emission Point No.
. .. . --- ..
I
I
Source Name
Time
Equipment In Se rvi c e?
Y/N
Vis i ble Emissions?
Y/N
Method 9 111 com pleted?
Y/N
Method 9 111 attached?
YIN
Method 9 111 Result
I
Specific Requirement No. 20 (Opa city) Soecific Reauirement No. 27 (VEO) Baahouses!Dust Specific Reauirement No. 25 . Differential Pressure Monitored Daily (continued)
EQT0112
DC-17 DR! Metering Bin
()111
EQ T 0 1 13
DC-18 DR! Product Loadou t
o/SO
Filters
Visible Emissions
-r
-r
of Filter
Vents
Monitored
Daily
(co ntinued)
EQT0078
DC-19 Briquetting Mill
61'1 i.-{
-f
--
EQT0121 EQT0123 EQT0148
DC-20 Furnace Emergency Bu nker Baghouse
MDC-0 1 Mobile Du st Collector "*Note the ru n hours
DC-21 South Side of R7 Dry Screen Building
' 01 l 0
0"'101') ti
0 81 '8 -r
EQT0149
DC-22 West Side of RB Wet!Dry Screen Building
0 250
-/
EQT0150
DC-23 Top Cone of Day Bin 1
Cd?) I
'{
Soecific Reauirement No. 87 (Ooacitv) and No. 92 (VEO) New Baghouses Visible Emissions of Filter Ven ts Mon itored Daily
EQT0172 EQT0 173 EQT0174
DC-24 Top Cone of Day Bin 2 DC-25 Top Cone of Day Bin 3 DC-26 Top Cone of Day Bin 4
' 68JS
6RJ'i
-r
6i)l.
I
EQT0175 EQT0176
DC-27 Head Chute of R7-C06 DC-28 Weig h Belt Feeder Pair 1
6 a>J a
I
b D -r
EQT0177
DC-29 Weigh Belt Feeder Pair 2
3.0
'1
Specific Requirement No. 75 (Opacitv) and No. 78 and 81 (VEOJ Hot Flares Visible Emissions Monitored Daily [Once Everv Two Hours Durina a Process Upset Vent]
EQT0071
HF- 1 Hot Fla re No. 1
** ,;20% except fo r a combined total of 6 hours in any 1O consecu tive day period for bu ring in connection with pressure valve re leases fo r control over process upsets
fl lA
1
DP Reading
Opacity
-J
~~'\C\
s 20 %
~ \. 11
s20%
~ J.%
S20 %
l.+ )~
s20%
~o s20%
~)... -1 s20%
1. '1
S20%
1-l
S20 %
\-I
s20%
>.' s20%
>-~
s20%
,.1-}.
s20%
()
s20%
1.0
s20%
$;20%
Comme nt s:
NSLA Env Dept, VEO Log
2
Revision 01 Revised Dat e: 8/17/21
EPA Inspection Report - Page 21 of 25
Appendix 5 Roadway watering log and roadway status information
EPA Inspection Report - Page 22 of 25
Nucor Steel Louisiana, LLC 9101 LA HWY 3125 Convent, LA 70723
Road Watering Log for Permit Number - Title V Permit ARE 003 FUG-102-Paved Fugitivie Dust LAC33:III.509 - Roadway watering and periodic sweeping
Watered Road #'s
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
A
B
C
D
E
F
G
Time: 7:25 AM
6:50 AM 6:55 AM
7:00 AM
7:05 AM
6:40 AM
6:45 AM
Time: 2000 GAL
8:15 AM 8:20 AM
8:25 AM
8:30 AM
8:05 AM
8:10 AM
1-Nov
Time: Time:
11:25 AM 11:30 AM 1:20 AM 1:25 AM
11:35 AM 1:30 AM
11:40 AM 1:35 AM
11:15 AM 1:10 AM
11:20 AM 1:15 AM
Time:
2:15 AM 2:20 AM
2:25 AM
2:30 AM
2:05 AM
2:10 AM
Time:
3:45 AM 3:50 AM
3:55 AM
4:00 AM
3:30 AM
3:35 AM
2-Nov
Time: Time: Time: Time: Time: Time:
8:25 AM 2000 GAL
6:45 AM 9:15 AM 11:10 AM 1:00 AM 2:15 AM 3:45 AM
6:50 AM 9:20 AM 11:15 AM 1:05 AM 2:20 AM 3:50 AM
6:55 AM 9:25 AM 11:20 AM 1:10 AM 2:25 AM 3:55 AM
7:00 AM 9:30 AM 11:25 AM 1:15 AM 2:30 AM 4:00 AM
6:35 AM 9:05 AM 11:00 AM 12:50 PM 2:05 AM 3:35 AM
6:40 AM 9:10 AM 11:05 AM 12:55 PM 2:10 AM 3:40 AM
3-Nov
Time: Time: Time: Time: Time: Time:
7:20 AM 2000 GAL
6:55 AM 8:15 AM 10:15 AM 11:50 AM 1:40 AM 3:50 AM
7:00 AM 8:20 AM 10:20 AM 11:55 AM 1:45 AM 3:55 AM
7:05 AM 8:25 AM 10:25 AM 12:00 PM 1:50 AM 4:00 AM
7:10 AM 8:30 AM 10:30 AM 12:05 PM 1:55 AM 4:05 AM
6:45 AM 9:05 AM 10:05 AM 11:40 AM 1:30 AM 3:40 AM
6:50 AM 9:10 AM 10:15 AM 11:45 AM 1:35 AM 3:45 AM
4-Nov
Time: Time: Time: Time: Time: Time:
8:50 AM 2000 GAL
6:55 AM 9:15 AM 11:20 AM 1:25 AM 2:15 AM 3:50 AM
7:00 AM 9:20 AM 11:25 AM 1:30 AM 2:20 AM 3:55 AM
7:05 AM 9:25 AM 11:30 AM 1:35 AM 2:25 AM 4:00 AM
1:10 AM 9:30 AM 11:35 AM 1:40 AM 2:30 AM 4:05 AM
6:45 AM 9:05 AM 11:10 AM 1:15 AM 2:05 AM 3:40 AM
6:50 AM 9:10 AM 11:15 AM 1:20 AM 2:10 AM 3:45 AM
5-Nov
Time: Time: Time: Time: Time: Time:
8:50 AM 2000 GAL
6:50 AM 7:20 AM 10:25 AM 1:05 AM 2:15 AM 3:55 AM
6:55 AM 7:25 AM 10:30 AM 1:10 AM 2:20 AM 4:00 AM
7:00 AM 7:30 AM 10:35 AM 1:15 AM 2:25 AM 4:00 AM
7:05 AM 7:35 AM 10:40 AM 1:20 AM 2:30 AM 4:05 AM
6:40 AM 7:10 AM 10:15 AM 12:55 PM 2:05 AM 3:45 AM
6:45 AM 7:15 AM 10:20 AM 1:00 AM 2:10 AM 3:50 AM
Time:
Time:
6-Nov
Time: Time:
Time:
Time:
7-Nov
Time: Time: Time: Time:
7:15 AM 2000 GAL
6:45 AM 8:25 AM 9:40 AM 11:40 AM
6:50 AM 8:30 AM 9:45 AM 11:45 AM
6:55 AM 8:35 AM 9:50 AM 11:50 AM
7:00 AM 8:40 AM 9:55 AM 11:55 AM
6:35 AM 8:15 AM 9:30 AM 11:30 AM
6:40 AM 8:20 AM 9:35 AM 11:35 AM
Time:
Time:
8-Nov
Time: Time: Time: Time: Time: Time:
7:40 AM 2000 GAL
6:50 AM 8:10 AM 10:25 AM 1:50 AM 2:20 AM 3:55 AM
6:55 AM 8:15 AM 10:30 AM 1:55 AM 2:25 AM 4:00 AM
7:00 AM 8:20 AM 10:35 AM 2:00 AM 2:30 AM 4:05 AM
7:05 AM 8:25 AM 10:40 AM 2:05 AM 2:35 AM 4:10 AM
6:40 AM 8:00 AM 10:45 AM 1:40 AM 2:10 AM 3:45 AM
6:45 AM 8:05 AM 10:50 AM 1:45 AM 2:15 AM 3:50 AM
9-Nov
Time: Time: Time: Time: Time: Time:
7:30 AM 2000 GAL
6:50 AM 8:30 AM 11:00 AM 1:25 AM 2:30 AM 4:00 AM
6:55 AM 8:35 AM 11:05 AM 1:30 AM 2:35 AM 4:05 AM
7:00 AM 8:40 AM 11:10 AM 1:35 AM 2:40 AM 4:10 AM
7:05 AM 8:45 AM 11:15 AM 1:40 AM 2:45 AM 4:15 AM
6:40 AM 8:20 AM 10:50 AM 1:15 AM 2:20 AM 3:50 AM
6:45 AM 8:25 AM 10:55 AM 1:20 AM 2:25 AM 3:55 AM
10-Nov
Time: Time: Time: Time: Time: Time:
8:25 AM 2000 GAL
7:00 AM 9:25 AM 11:35 AM 1:20 AM 3:00 AM 3:45 AM
7:05 AM 9:30 AM 11:40 AM 1:25 AM 3:05 AM 3:50 AM
7:10 AM 9:35 AM 11:45 AM 1:30 AM 3:10 AM 3:55 AM
7:15 AM 9:40 AM 11:50 AM 1:35 AM 3:15 AM 4:00 AM
6:50 AM 9:15 AM 11:25 AM 1:10 AM 2:50 AM 3:35 AM
6:55 AM 9:20 AM 11:30 AM 1:15 AM 2:55 AM 3:40 AM
11-Nov
Time: Time: Time:
8:00 AM 2000 GAL
6:55 AM 8:50 AM 12:00 PM
7:00 AM 8:55 AM 12:05 PM
7:05 AM 9:00 AM 12:10 PM
7:10 AM 9:05 AM 12:15 PM
6:45 AM 8:40 AM 11:50 AM
6:50 AM 8:45 AM 11:55 AM
EPA Inspection Report - Page 23 of 25
11 Nov 12-Nov 13-Nov 14-Nov 15-Nov 16-Nov 17-Nov 18-Nov 19-Nov 20-Nov 21-Nov 22-Nov
Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time:
7:40 AM 2000 GAL
1:25 AM 2:30 AM 3:50 AM 6:50 AM 9:10 AM 11:50 AM 1:20 AM 2:30 AM 4:05 AM
1:30 AM 2:35 AM 3:55 AM 6:55 AM 9:15 AM 11:55 AM 1:25 AM 2:35 AM 4:10 AM
7:30 AM 2000 GAL
6:50 AM 8:30 AM 9:30 AM
6:55 AM 2:35 AM 9:35 AM
8:15 AM 2000 GAL
9:15 AM 2000 GAL
10:25 AM 2000 GAL
6:50 AM 9:25 AM 11:30 AM 2:00 AM 3:50 AM
6:55 AM 9:30 AM 11:35 AM 2:05 AM 3:55 AM
6:55 AM 8:10 AM 11:50 AM 1:55 AM 4:00 AM
7:00 AM 8:15 AM 11:55 AM 2:00 AM 4:05 AM
7:00 AM 7:50 AM 9:20 AM 12:05 PM 3:55 AM
7:05 AM 7:55 AM 9:25 AM 12:10 PM 4:00 AM
RAIN OUT
8:05 AM 2000 GAL
7:00 AM 2000 GAL
6:55 AM 9:55 AM 11:50 AM 2:20 AM 3:50 AM
7:00 AM 10:00 AM 11:55 AM 2:25 AM 3:55 AM
8:30 AM 9:00 AM
6:00 AM 2000 GAL
7:00 AM 9:15 AM
8:00 AM 9:30 AM
9:00 AM 2000 GAL
10:00 AM
7:00 AM 11:15 AM 12:30 PM
6:30 AM 10:30 AM 12:15 PM
1:35 AM 2:40 AM 4:00 AM 7:00 AM 9:20 AM 12:00 PM 1:30 AM 2:40 AM 4:15 AM
7:00 AM 2:40 AM 9:40 AM
7:00 AM 9:35 AM 11:40 AM 2:10 AM 4:00 AM 7:05 AM 8:20 AM 12:00 PM 2:05 AM 4:10 AM 7:10 AM 8:00 AM 9:30 AM 12:15 PM 4:05 AM
7:05 AM 10:00 AM 12:00 PM 2:30 AM 4:00 AM 9:15 AM
8:15 AM 9:45 AM
6:30 AM 11:00 AM
1:40 AM 2:45 AM 4:05 AM 7:05 AM 9:25 AM 12:05 PM 1:35 AM 2:45 AM 4:20 AM
7:06 AM 2:45 AM 9:45 AM
7:05 AM 9:40 AM 11:45 AM 2:15 AM 4:05 AM
7:10 AM 8:25 AM 12:05 PM 2:10 AM 4:15 AM
7:15 AM 8:05 AM 9:35 AM 12:20 PM 4:10 AM
7:10 AM 10:05 AM 12:05 PM 2:35 AM 4:05 AM
9:20 AM
8:30 AM
RAIN OUT
6:00 AM 1:00 PM
1:15 AM 2:20 AM 3:40 AM 6:40 AM 9:00 AM 11:20 AM 1:10 AM 2:20 AM 3:35 AM
1:20 AM 2:25 AM 3:45 AM 6:45 AM 9:05 AM 11:25 AM 1:15 AM 2:25 AM 3:40 AM
6:40 AM 8:20 AM 9:20 AM
6:40 AM 9:15 AM 11:20 AM 1:50 AM 3:40 AM
6:45 AM 8:00 AM 11:40 AM 1:45 AM 3:50 AM
6:50 AM 7:40 AM 9:10 AM 11:55 AM 3:45 AM
6:45 AM 9:45 AM 11:40 AM 2:10 AM 3:40 AM
6:45 AM 8:25 AM 9:25 AM
6:45 AM 9:20 AM 11:25 AM 1:55 AM 3:45 AM
6:50 AM 8:05 AM 11:45 AM 1:50 AM 3:55 AM
6:55 AM 7:45 AM 9:15 AM 12:00 PM 3:50 AM
RAIN OUT
6:50 AM 9:50 AM 11:45 AM 2:15 AM 3:45 AM
8:45 AM
9:00 AM
8:45 AM 11:30 AM
7:30 AM
8:30 AM 11:45 AM
8:00 AM 12:00 PM
EPA Inspection Report - Page 24 of 25
23-Nov 24-Nov 25-Nov 26-Nov 27-Nov 28-Nov 29-Nov 30-Nov 1-Dec
Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time: Time:
2000 GAL 8:30 AM 2000 GAL
10:00 AM 2000 GAL 6:15 AM 2000 GAL
2:30 PM 2000 GAL
7:00 AM 1:00 PM 3:30 PM
7:15 AM 1:30 PM 3:15 PM
8:30 AM 11:00 AM 11:45 AM
9:00 AM 11:30 AM 4:00 PM
7:30 AM 2000 GAL
6:30 AM 6:45 AM
6:30 AM 2000 GAL
8:00 AM 8:15 AM 10:30 AM 11:15 AM
RAIN EVENT
6:30 AM 2000 GAL
8:00 AM 2000 GAL 7:30 AM 2000 GAL
9:00 AM 2000 GAL
9:30 AM 11:30 AM 1:00 PM 3:45 PM
9:45 AM 12:00 PM 1:30 PM 4:00 PM
6:30 AM 10:30 AM 2:00 PM 3:30 PM
6:47 AM 10:45 AM 2:15 PM 4:15 PM
8:00 AM 1:15 PM 4:00 PM
9:15 AM 11:15 AM 1:00 PM
7:00 AM
9:00 AM 11:00 AM
10:00 AM 1:15 PM 2:00 PM 4:15 PM 7:00 AM 11:00 AM 2:30 PM 4:00 PM
RAIN EVENT
6:00 AM 5:00 PM
6:00 AM 4:30 PM
11:30 AM 2:00 PM
11:45 AM 2:15 PM
12:00 PM 2:30 PM
10:00 AM
9:45 AM 10:45 AM
10:30 AM 4:15 PM
10:15 AM
6:00 AM 2:00 PM
6:00 AM 12:30 PM
9:00 AM 10:30 AM 12:45 PM
9:30 AM 12:00 PM
9:30 AM 12:00 PM
9:15 AM 10:00 AM
9:30 AM 11:30 AM
9:15 AM 11:45 AM
6:00 AM 5:00 PM
3:00 PM
6:00 AM 6:00 PM
RAIN EVENT
10:30 AM 2:15 PM 4:30 PM
10:45 AM 2:30 PM
11:15 AM 2:45 PM 4:45 PM
11:30 AM 1:30 PM 4:30 PM 5:15 PM
11:45 AM 1:15 PM
12:00 PM 3:15 PM 4:45 PM 5:30 PM
1:00 PM 3:00 PM 12:00 PM
EPA Inspection Report - Page 25 of 25
Nucor Steel Louisiana LLC Road Watering
RD # Roads/Areas 1 Plant Road / Ground Area 2 Plant Road / Ground Area 3 Plant Road 4 Plant Road 5 Plant Road 6 Plant Road 7 Plant Road 8 Plant Road 9 Non Road 10 Non Road 11 Non Road/ Non Accessible 12 Plant Road 13 Plant Road -Low traffic 14 Plant Road -Low traffic 15 Plant Road -Low traffic 16 Contractor Parking 17 Plant Road / Ground Area A Public Road B Plant Road C Plant Road D Plant Road E Plant Road F Plant Road G Plant Road H Plant Road
Decommissioned N/A N/A N/A N/A N/A N/A N/A N/A 5/7/2021 3/10/2021 7/29/2020 10/1/2020 N/A N/A N/A N/A N/A 8/6/2021 N/A N/A N/A N/A N/A N/A N/A
Notes
paused road watering due to contruction public/shared road