DAQ-2024-008646

1

DAQC-627-24
Site ID 10008 (B5)
MEMORANDUM

TO: CEM FILE – NUCOR STEEL – Plymouth Division

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Rob Leishman, Environmental Scientist

DATE: June 25, 2024

SUBJECT: Source: Electric Arc Furnace (EAF) #1 and #2
Contact: Kyndal Bair – 435-458-2496
Doug Jones – 435-458-2415
Location: West Cemetery Road, Plymouth, Box Elder County, UT
Test Contractor: Alliance Technical Group
FRS ID#: UT0000004900300002
Permit/AO#: Title V operating permit 300002004 dated May 23, 2022,
Last revised May 23, 2022
Subject: Review of RA/PST Protocol dated June 21, 2024

On June 21, 2024, DAQ received a protocol by email for a RA/PST (relative accuracy/performance
specification test) of the Nucor Steel Plymouth Division EAF #1 and #2 located in Plymouth, UT.
Testing will be performed on August 6, 2024, to determine the relative accuracy of the CO2, NOX, SO2,
O2, and CO primary and secondary monitoring systems.

PROTOCOL CONDITIONS:

1. RM 1 used to determine sample velocity traverses: OK
2. RM 2 used to determine stack gas velocity and volumetric flow rate: OK
3. RM 3A used to determine dry molecular weight of the gas stream: OK
4. RM 4 used to determine moisture content: OK
5. RM 6C used to determine SO2 emissions: OK
6. RM 7E used to determine NOX concentrations of emissions: OK
7. RM 10 used to determine CO concentrations of emissions: OK
DEVIATIONS: No deviations were noted.

CONCLUSION: The protocol appears to be acceptable.

RECOMMENDATION: Send attached protocol review and test date confirmation notice.

1 8 2

Site Specific Test Plan
Baghouse CEMS RATA

Nucor Steel-Utah
West Cemetery Rd.
Plymouth, UT 84330

Sources to be Tested: EAF #1 & #2
Proposed Test Date: August 6, 2024

Project No. AST-2024-3136-002

Prepared By
Alliance Technical Group, LLC
3683 W 2270 S, Suite E
West Valley City, UT 84120

Site Specific Test Plan
Test Program Summary

AST-2024-3136-002 Nucor – Plymouth, UT Page i

Regulatory Information

Permit Nos. Utah Department of Environmental Quality, Division of Air Quality
Approval Order DAQE-AN100080048-21-20 Issued on October 28, 2021,
Title V Permit No. 300002004 revised May 23, 2022 and Utah State
Implementation Plan (Sections IX.H.11&12).
Regulatory Citations 40 CFR Part 60, Appendix B – Performance Specifications 2, 3, 4A and 6

Source Information

Source Name Source ID RATA Parameters
Electric Arc Furnaces Unit# EAF 1 & 2 VFR, O2, CO2, SO2, NOx, CO

Contact Information

Test Location Test Company
Nucor Steel-Utah
West Cemetery Rd.
Plymouth, Utah

Doug Jones
P.O. Box 100
Plymouth, UT 84330-0100
[e-mail]
[phone]

Kyndal Bair
P.O. Box 100
Plymouth, UT 84330
[e-mail]
[phone]
Alliance Technical Group, LLC
3683 W 2270 S, Suite E
West Valley City, UT 84120

Project Manager
Charles Horton
[e-mail]
[phone]

Field Team Leader
Ryan Lyons
[e-mail]
[phone]
(subject to change)

QA/QC Manager
Kathleen Shonk
[e-mail]
[phone]

Test Plan/Report Coordinator
Delaine Spangler
[e-mail]

Site Specific Test Plan
Table of Contents

AST-2024-3136-002 Nucor – Plymouth, UT Page ii

TABLE OF CONTENTS

1.0 Introduction ................................................................................................................................................. 1-1
1.1 Process/Control System Descriptions .......................................................................................................... 1-1
1.2 CEMS Descriptions ..................................................................................................................................... 1-1
1.3 Project Team ............................................................................................................................................... 1-2
1.4 Safety Requirements ................................................................................................................................... 1-2
2.0 Summary of Test Program .......................................................................................................................... 2-1
2.1 General Description ..................................................................................................................................... 2-1
2.2 Process/Control System Parameters to be Monitored and Recorded .......................................................... 2-1
2.3 Proposed Test Schedule............................................................................................................................... 2-1
2.4 Emission Limits........................................................................................................................................... 2-2
2.5 Test Report .................................................................................................................................................. 2-3
3.0 Testing Methodology .................................................................................................................................. 3-1
3.1 U.S. EPA Reference Test Methods 1 and 2 – Sampling/Traverse Points and Volumetric Flow Rate ........ 3-1
3.2 U.S. EPA Reference Test Method 3A – Oxygen/Carbon Dioxide .............................................................. 3-1
3.3 U.S. EPA Reference Test Method 3/3A – Oxygen/Carbon Dioxide ........................................................... 3-2
3.4 U.S. EPA Reference Test Method 4 – Moisture Content ............................................................................ 3-2
3.5 U.S. EPA Reference Test Method 6C – Sulfur Dioxide .............................................................................. 3-2
3.6 U.S. EPA Reference Test Method 7E – Nitrogen Oxides ........................................................................... 3-2
3.7 U.S. EPA Reference Test Method 10 – Carbon Monoxide ......................................................................... 3-3
3.8 U.S. EPA Reference Test Method 205 – Gas Dilution System Certification .............................................. 3-3
3.9 Quality Assurance/Quality Control – U.S. EPA Reference Test Methods 3A, 6C, 7E and 10 ................... 3-3
3.10 Quality Assurance/Quality Control – U.S. EPA Reference Test Method 3/3A ...................................... 3-4
4.0 Quality Assurance Program ......................................................................................................................... 4-1
4.1 Equipment ................................................................................................................................................... 4-1
4.2 Field Sampling ............................................................................................................................................ 4-2
LIST OF TABLES

Table 1-1: Project Team ........................................................................................................................................... 1-2
Table 2-1: Program Outline and Tentative Test Schedule ........................................................................................ 2-2
Table 2-2: Relative Accuracy Requirements and Limits .......................................................................................... 2-2
Table 3-1: Source Testing Methodology .................................................................................................................. 3-1

Site Specific Test Plan
Introduction

AST-2024-3136-002 Nucor – Plymouth, UT Page 1-1

1.0 Introduction
Alliance Technical Group, LLC (Alliance) was retained by Nucor Steel-Utah (Nucor) to conduct performance
specification (PS) testing at the Plymouth, Utah facility. Portions of the facility are subject to provisions of 40 CFR
60, Appendix B, PS 2, 3, 4A and 6 and the Utah Department of Environmental quality, Division of Air Quality
(UDAQ) Approval Order DAQE-AN100080048-21-20, Title V Permit No. 300002004 and the Utah State
Implementation Plan (SIP) Sections IX.H.11 and 12. Testing will include conducting a relative accuracy test audits
(RATA) to determine the relative accuracy (RA) of the oxygen (O2), carbon dioxide (CO2), sulfur dioxide (SO2),
nitrogen oxides (NOx), and carbon monoxide (CO) continuous emission monitoring system (CEMS) serving the
combined Electric Arc Furnaces (EAF) #1 and #2 Baghouse exhaust. Testing will also include conducting a RATA
on the volumetric flow rate (VFR) continuous emissions rate monitoring system (CERMS) serving both inlet (upper
and lower) ducts to the EAF exhaust simultaneously.

This site-specific test plan (SSTP) has been prepared to address the notification and testing requirements of the
UDAQ Approval Order DAQE-AN100080048-21-20, Tile V Permit No. 300002004 and the Utah SIP Sections
IX.H.11 and 12.
1.1 Process/Control System Descriptions
Nucor operates two (2) Electric Arc Furnaces (EAFs) for recycling mild steel at their facility located in Plymouth,
Utah. Air emissions from the EAFs are collected with negative pressure ducts located at the top of each furnace. In
addition, a large overhead canopy with a negative pressure duct collects the fugitive air emissions during operation.
The emissions from the duct system are routed to a spark arresting and mixing chamber. Six fans draw the
emissions from the spark arrestor and mixing chamber and force the emissions into a positive pressure baghouse to
be filtered. The EAF Baghouse emissions are vented to atmosphere through a single air emissions stack located
above the baghouse.
1.2 CEMS Descriptions
Primary CEMS
Pollutant Pollutant Pollutant Diluent
Parameter: NOx CO SO2 O2/CO2
Make: Thermo Scientific Thermo Scientific Thermo Scientific Thermo Scientific
Model: 42iQLS-ACBNA 48iQ-ACN 43iQ-ACN 410iQ-ACN
Serial No.: 1181830033 1181830035 1181830034 1181830036
Span: 250 ppmv 1,000 ppmv 0-50 ppmv 20,000 ppmv

Secondary CEMS
Pollutant Pollutant Pollutant Diluent
Parameter: NOx CO SO2 O2/CO2
Make: ECOCHEM ECOCHEM ECOCHEM ECOCHEM
Model: MC3 MC3 MC3 MC3
Serial No.: 512 512 512 512
Span: 250 ppmv 1,000 ppmv 0-50 ppmv 20,000 ppmv

Site Specific Test Plan
Introduction

AST-2024-3136-002 Nucor – Plymouth, UT Page 1-2

1.3 Project Team
Personnel planned to be involved in this project are identified in the following table.

Table 1-1: Project Team

Nucor Personnel Kyndal Bair
Regulatory Agency UDAQ
Alliance Personnel Ryan Lyons
other field personnel assigned at time of testing event
1.4 Safety Requirements
Testing personnel will undergo site-specific safety training for all applicable areas upon arrival at the site. Alliance
personnel will have current OSHA or MSHA safety training and be equipped with hard hats, safety glasses with side
shields, steel-toed safety shoes, hearing protection, fire resistant clothing, and fall protection (including shock
corded lanyards and full-body harnesses). Alliance personnel will conduct themselves in a manner consistent with
Client and Alliance’s safety policies.

A Job Safety Analysis (JSA) will be completed daily by the Alliance Field Team Leader.

Site Specific Test Plan
Summary of Test Programs

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2.0 Summary of Test Program
To satisfy the requirements of the UDAQ Approval Order DAQE-AN100080048-21-20, Title V Permit No.
300002004 and 40 CFR 60, Appendix B, PS 2, 3, 4A and 6 the facility will conduct a performance test program to
determine the compliance status of the EAF #1 and #2.
2.1 General Description
All testing will be performed in accordance with specifications stipulated in U.S. EPA Reference Test Methods 1, 2,
3A, 3/3A, 4, 6C, 7E and 10. Table 2-1 presents an outline and tentative schedule for the emissions testing program.
The following is a summary of the test objectives.

• Testing will be performed to demonstrate compliance with the UDAQ Approval Order DAQE-
AN100080048-21-20, Title V Permit No. 300002004 and 40 CFR 60, Appendix B, PS 2, 3, 4A and 6.
• Emissions testing will be conducted on the combined exhaust of EAF #1 and #2.
• Each of the 9-12 RATA runs will be approximately 21 minutes in duration.
• The dual inlet stack flow RATA will include a minimum of nine (9) and a maximum of twelve (12)
velocity profiles conducted per U.S. EPA Reference Test Method 2 simultaneously on each inlet stack.
Concurrent dry gas molecular weight and stack gas moisture measurements will be made per U.S. EPA
Reference Test Methods 3/3A and 4, respectively. Each flow profile will include 3 - 4 test runs for sixty
(60) minutes.
2.2 Process/Control System Parameters to be Monitored and Recorded
Plant personnel will collect operational and parametric data at least once every 15 minutes during the testing. The
following list identifies the measurements, observations and records that will be collected during the testing
program:

• Production rate – ton/hr
• CEMS Data
• CERMS Data
2.3 Proposed Test Schedule
Table 2-1 presents an outline and tentative schedule for the emissions testing program. If production is temporarily
interrupted or reduced below 90% of the max, the test run will be temporarily paused until production resumes
satisfactory levels. Likewise, a run may be paused due to long work hours in the day and resume during daylight
hours the following day.

Site Specific Test Plan
Summary of Test Programs

AST-2024-3136-002 Nucor – Plymouth, UT Page 2-2

Table 2-1: Program Outline and Tentative Test Schedule

Testing Location Parameter US EPA Method No. of Runs Run Duration Est. Onsite
Time
DAY 1 – August 6, 2024
EAF Baghouse Dual
Inlets
VFR 1-2 9-12 21 min
10 hr
BWS 3 / 3A, 4 3-4 60 min
EAF Baghouse
Exhaust
O2 / CO2 3A
9-12 21 min SO2 6C
NOx 7E
CO 10
2.4 Emission Limits
Emission limits for each pollutant are below.

Table 2-2: Relative Accuracy Requirements and Limits

Source CEMS Required Relative
Accuracy
Applicable Standard /
Limit Citation
EAF
Baghouse
VFR ≤20 % -- 60, Appendix B, PS 6
O2 ≤20 % or ± 1 % O2 60, Appendix B, PS 3
CO2 ≤20 % or ± 1 % CO2 -- 60, Appendix B, PS 3
SO2 ≤20 % (RM) or ≤10 % (AS) 89 lb/hr
(based on 24-hr average) 60, Appendix B, PS 2
NOx ≤20 % (RM) or ≤10 % (AS)
59.5 lb/hr
(based on calendar day
average)
60, Appendix B, PS 2
CO ±10 % (RM) or ± 5% (AS) 1,200 lb/hr (1 hr average) 60, Appendix B, PS 4

Site Specific Test Plan
Summary of Test Programs

AST-2024-3136-002 Nucor – Plymouth, UT Page 2-3

2.5 Test Report
The final test report must be submitted within 60 days of the completion of the performance test and will include the
following information.
• Introduction – Brief discussion of project scope of work and activities.
• Results and Discussion – A summary of test results and process/control system operational data with
comparison to regulatory requirements or vendor guarantees along with a description of process conditions
and/or testing deviations that may have affected the testing results.
• Methodology – A description of the sampling and analytical methodologies.
• Sample Calculations – Example calculations for each target parameter.
• Field Data – Copies of actual handwritten or electronic field data sheets.
• Laboratory Data – Copies of laboratory report(s) and chain of custody(s).
• Quality Control Data – Copies of all instrument calibration data and/or calibration gas certificates.
• Process Operating/Control System Data – Process operating and control system data (as provided by
Nucor) to support the test results.

Site Specific Test Plan
Testing Methodology

AST-2024-3136-002 Nucor – Plymouth, UT Page 3-1

3.0 Testing Methodology
This section provides a description of the sampling and analytical procedures for each test method that will be
employed during the test program. All equipment, procedures and quality assurance measures necessary for the
completion of the test program meet or exceed the specifications of each relevant test method. The emission testing
program will be conducted in accordance with the test methods listed in Table 3-1.

Table 3-1: Source Testing Methodology

Parameter U.S. EPA Reference
Test Methods Notes/Remarks
Volumetric Flow Rate 1 & 2 Full Velocity Traverses
Oxygen / Carbon Dioxide 3A Instrumental Analysis
Oxygen/Carbon Dioxide 3/3A Integrated Bag / Instrumental Analysis
Moisture Content 4 Gravimetric Analysis
Sulfur Dioxide 6C Instrumental Analysis
Nitrogen Oxides 7E Instrumental Analysis
Carbon Monoxide 10 Instrumental Analysis
Gas Dilution System Certification 205 --

All stack diameters, depths, widths, upstream and downstream disturbance distances and nipple lengths will be
measured on site with a verification measurement provided by the Field Team Leader.
3.1 U.S. EPA Reference Test Methods 1 and 2 – Sampling/Traverse Points and Volumetric Flow Rate
The sampling location and number of traverse (sampling) points will be selected in accordance with U.S. EPA
Reference Test Method 1. To determine the minimum number of traverse points, the upstream and downstream
distances will be equated into equivalent diameters and compared to Figure 1-2 in U.S. EPA Reference Test Method
1.

Full velocity traverses will be conducted in accordance with U.S. EPA Reference Test Method 2 to determine the
average stack gas velocity pressure, static pressure and temperature. The velocity and static pressure measurement
system will consist of a pitot tube and inclined manometer. The stack gas temperature will be measured with a K-
type thermocouple and pyrometer.

Stack gas velocity pressure and temperature readings will be recorded during each test run. The data collected will
be utilized to calculate the volumetric flow rate for comparison to the continuous emission rate monitoring system
(CERMS). The relative accuracy of the CERMS will be determined based on procedures found in 40 CFR 60,
Performance Specification 6.
3.2 U.S. EPA Reference Test Method 3A – Oxygen/Carbon Dioxide
The oxygen (O2) and carbon dioxide (CO2) testing will be conducted in accordance with U.S. EPA Reference Test
Method 3A. Data will be collected online and reported in one-minute averages. The sampling system will consist
of a stainless steel probe, Teflon sample line(s), gas conditioning system and the identified gas analyzer. The gas
conditioning system will be a non-contact condenser used to remove moisture from the stack gas. If an unheated

Site Specific Test Plan
Testing Methodology

AST-2024-3136-002 Nucor – Plymouth, UT Page 3-2

Teflon sample line is used, then a portable non-contact condenser will be placed in the system directly after the
probe. Otherwise, a heated Teflon sample line will be used. The quality control measures are described in Section
3.9.

The relative accuracy of the O2 and CO2 CEMS will be determined based on procedures found in 40 CFR 60,
Performance Specification 3.
3.3 U.S. EPA Reference Test Method 3/3A – Oxygen/Carbon Dioxide
The oxygen (O2) and carbon dioxide (CO2) testing will be conducted in accordance with U.S. EPA Reference Test
Method 3/3A. One (1) integrated Tedlar bag sample will be collected during each test run. The bags will be
collected from the positive pressure side of the sample pump and conditioner. They will be collected through a
manifold with a restriction (either rotameter or critical orifice) to ensure even filling throughout the course of the
run. Samples will be concurrent with the test runs. The bag samples will be analyzed on site with a gas analyzer.
The remaining stack gas constituent will be assumed to be nitrogen for the stack gas molecular weight
determination. The quality control measures are described in Section 3.10.
3.4 U.S. EPA Reference Test Method 4 – Moisture Content
The stack gas moisture content will be determined in accordance with U.S. EPA Reference Test Method 4. The gas
conditioning train will consist of a series of chilled impingers. Prior to testing, each impinger will be filled with a
known quantity of water or silica gel. Each impinger will be analyzed gravimetrically before and after each test run
on the same analytical balance to determine the amount of moisture condensed.
3.5 U.S. EPA Reference Test Method 6C – Sulfur Dioxide
The sulfur dioxide (SO2) testing will be conducted in accordance with U.S. EPA Reference Test Method 6C. Data
will be collected online and reported in one-minute averages. The sampling system will consist of a heated stainless
steel probe, Teflon sample line(s), gas conditioning system and the identified analyzer. The gas conditioning system
will be a non-contact condenser used to remove moisture from the source gas. If an unheated Teflon sample line is
used, then a portable non-contact condenser will be placed in the system directly after the probe. Otherwise, a
heated Teflon sample line will be used. The quality control measures are described in Section 3.9.

The relative accuracy of the SO2 CEMS will be determined based on procedures found in 40 CFR 60, Performance
Specification 2.
3.6 U.S. EPA Reference Test Method 7E – Nitrogen Oxides
The nitrogen oxides (NOx) testing will be conducted in accordance with U.S. EPA Reference Test Method 7E. Data
will be collected online and reported in one-minute averages. The sampling system will consist of a stainless steel
probe, Teflon sample line(s), gas conditioning system and the identified gas analyzer. The gas conditioning system
will be a non-contact condenser used to remove moisture from the stack gas. If an unheated Teflon sample line is
used, then a portable non-contact condenser will be placed in the system directly after the probe. Otherwise, a
heated Teflon sample line will be used. The quality control measures are described in Section 3.9.

The relative accuracy of the NOx CEMS will be determined based on procedures found in 40 CFR 60, Performance
Specification 2.

Site Specific Test Plan
Testing Methodology

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3.7 U.S. EPA Reference Test Method 10 – Carbon Monoxide
The carbon monoxide (CO) testing will be conducted in accordance with U.S. EPA Reference Test Method 10.
Data will be collected online and reported in one-minute averages. The sampling system will consist of a stainless
steel probe, Teflon sample line(s), gas conditioning system, and the identified gas analyzer. The gas conditioning
system will be a non-contact condenser used to remove moisture from the gas. If an unheated Teflon sample line is
used, then a portable non-contact condenser will be placed in the system directly after the probe. Otherwise, a
heated Teflon sample line will be used. The quality control measures are described in Section 3.9.

The relative accuracy of the CO CEMS will be determined based on procedures found in 40 CFR 60, Performance
Specification 4A.
3.8 U.S. EPA Reference Test Method 205 – Gas Dilution System Certification
A calibration gas dilution system field check will be conducted in accordance with U.S. EPA Reference Method
205. An initial three (3) point calibration will be conducted, using individual Protocol 1 gases, on the analyzer used
to complete the dilution system field check. Multiple dilution rates and total gas flow rates will be utilized to force
the dilution system to perform two dilutions on each mass flow controller. The diluted calibration gases will be sent
directly to the analyzer, and the analyzer response will be recorded in an electronic field data sheet. A mid-level
supply gas, with a cylinder concentration within 10% of one of the gas divider settings described above, will be
introduced directly to the analyzer, and the analyzer response recorded in an electronic field data sheet. The
cylinder concentration and the analyzer response must agree within 2%. These steps will be repeated three (3)
times. The average analyzer response must agree within 2% of the predicted gas concentration. No single injection
shall differ more than 2% from the average instrument response for that dilution.
3.9 Quality Assurance/Quality Control – U.S. EPA Reference Test Methods 3A, 6C, 7E and 10
Cylinder calibration gases will meet EPA Protocol 1 (+/- 2%) standards. Copies of all calibration gas certificates
will be included in the Quality Assurance/Quality Control Appendix of the report.

Low Level gas will be introduced directly to the analyzer. After adjusting the analyzer to the Low Level gas
concentration and once the analyzer reading is stable, the analyzer value will be recorded. This process will be
repeated for the High Level gas. For the Calibration Error Test, Low, Mid, and High Level calibration gases will be
sequentially introduced directly to the analyzer. The Calibration Error for each gas must be within 2.0 percent of the
Calibration Span or 0.5 ppmv/% absolute difference.

High or Mid Level gas (whichever is closer to the stack gas concentration) will be introduced at the probe and the
time required for the analyzer reading to reach 95 percent or 0.5 ppm/% (whichever was less restrictive) of the gas
concentration will be recorded. The analyzer reading will be observed until it reaches a stable value, and this value
will be recorded. Next, Low Level gas will be introduced at the probe and the time required for the analyzer reading
to decrease to a value within 5.0 percent or 0.5 ppm/% (whichever was less restrictive) will be recorded. If the Low
Level gas is zero gas, the acceptable response must be 5.0 percent of the upscale gas concentration or 0.5 ppm/%
(whichever was less restrictive). The analyzer reading will be observed until it reaches a stable value and this value
will be recorded. The measurement system response time and initial system bias will be determined from these data.
The System Bias for each gas must be within 5.0 percent of the Calibration Span or 0.5 ppmv/% absolute difference.

High or Mid Level gas (whichever is closer to the stack gas concentration) will be introduced at the probe. After the
analyzer response is stable, the value will be recorded. Next, Low Level gas will be introduced at the probe, and the

Site Specific Test Plan
Testing Methodology

AST-2024-3136-002 Nucor – Plymouth, UT Page 3-4

analyzer value will be recorded once it reaches a stable response. The System Bias for each gas must be within 5.0
percent of the Calibration Span or 0.5 ppmv/% absolute difference or the data is invalidated and the Calibration
Error Test and System Bias must be repeated.

The Drift between pre- and post-run System Bias must be within 3 percent of the Calibration Span or 0.5 ppmv/%
absolute difference or the Calibration Error Test and System Bias must be repeated.

To determine the number of sampling points, a gas stratification check will be conducted prior to initiating testing.
The pollutant concentrations will be measured at twelve traverse points (as described in Method 1) or three points
(16.7, 50.0 and 83.3 percent of the measurement line). Each traverse point will be sampled for a minimum of twice
the system response time.

If the pollutant concentration at each traverse point do not differ more than 5% or 0.5 ppm/0.3% (whichever is less
restrictive) of the average pollutant concentration, then single point sampling will be conducted during the test runs.
If the pollutant concentration does not meet these specifications but differs less than 10% or 1.0 ppm/0.5% from the
average concentration, then three (3) point sampling will be conducted (stacks less than 7.8 feet in diameter - 16.7,
50.0 and 83.3 percent of the measurement line; stacks greater than 7.8 feet in diameter – 0.4, 1.0, and 2.0 meters
from the stack wall). If the pollutant concentration differs by more than 10% or 1.0 ppm/0.5% from the average
concentration, then sampling will be conducted at a minimum of twelve (12) traverse points. Copies of stratification
check data will be included in the Quality Assurance/Quality Control Appendix of the report.

An NO2 – NO converter check will be performed on the analyzer prior to initiating testing or at the completion of
testing. An approximately 50 ppm nitrogen dioxide cylinder gas will be introduced directly to the NOx analyzer and
the instrument response will be recorded in an electronic data sheet. The instrument response must be within +/- 10
percent of the cylinder concentration.

A Data Acquisition System with battery backup will be used to record the instrument response in one (1) minute
averages. The data will be continuously stored as a *.CSV file in Excel format on the hard drive of a computer. At
the completion of testing, the data will also be saved to the Alliance server. All data will be reviewed by the Field
Team Leader before leaving the facility. Once arriving at Alliance’s office, all written and electronic data will be
relinquished to the report coordinator and then a final review will be performed by the Project Manager.
3.10 Quality Assurance/Quality Control – U.S. EPA Reference Test Method 3/3A
Cylinder calibration gases will meet EPA Protocol 1 (+/- 2%) standards. Copies of all calibration gas certificates
will be included in the Quality Assurance/Quality Control Appendix of the report.

Low Level gas will be introduced directly to the analyzer. After adjusting the analyzer to the Low-Level gas
concentration and once the analyzer reading is stable, the analyzer value will be recorded. This process will be
repeated for the High-Level gas. For the Calibration Error Test, Low, Mid, and High-Level calibration gases will be
sequentially introduced directly to the analyzer. The Calibration Error for each gas must be within 2.0 percent of the
Calibration Span or 0.5% absolute difference.

A Data Acquisition System with battery backup will be used to record the instrument response in one (1) minute
averages. The data will be continuously stored as a *.CSV file in Excel format on the hard drive of a computer. At
the completion of testing, the data will also be saved to the Alliance server. All data will be reviewed by the Field

Site Specific Test Plan
Testing Methodology

AST-2024-3136-002 Nucor – Plymouth, UT Page 3-5

Team Leader before leaving the facility. Once arriving at Alliance’s office, all written and electronic data will be
relinquished to the report coordinator and then a final review will be performed by the Project Manager.

Site Specific Test Plan
Quality Assurance Program

AST-2024-3136-002 Nucor – Plymouth, UT Page 4-1

4.0 Quality Assurance Program
Alliance follows the procedures outlined in the Quality Assurance/Quality Control Management Plan to ensure the
continuous production of useful and valid data throughout the course of this test program. The QC checks and
procedures described in this section represent an integral part of the overall sampling and analytical scheme.
Adherence to prescribed procedures is quite often the most applicable QC check.
4.1 Equipment
Field test equipment is assigned a unique, permanent identification number. Prior to mobilizing for the test
program, equipment is inspected before being packed to detect equipment problems prior to arriving on site. This
minimizes lost time on the job site due to equipment failure. Occasional equipment failure in the field is
unavoidable despite the most rigorous inspection and maintenance procedures. Therefore, replacements for critical
equipment or components are brought to the job site. Equipment returning from the field is inspected before it is
returned to storage. During the course of these inspections, items are cleaned, repaired, reconditioned and
recalibrated where necessary.

Calibrations are conducted in a manner, and at a frequency, which meets or exceeds U.S. EPA specifications. The
calibration procedures outlined in the U.S. EPA Methods, and those recommended within the Quality Assurance
Handbook for Air Pollution Measurement Systems: Volume III (EPA-600/R-94/038c, September 1994) are utilized.
When these methods are inapplicable, methods such as those prescribed by the American Society for Testing and
Materials (ASTM) or other nationally recognized agency may be used. Data obtained during calibrations is checked
for completeness and accuracy. Copies of calibration forms are included in the report.

The following sections elaborate on the calibration procedures followed by Alliance for these items of equipment.

• Dry Gas Meter and Orifice. A full meter calibration using critical orifices as the calibration standard is
conducted at least semi-annually, more frequently if required. The meter calibration procedure determines
the meter correction factor (Y) and the meter’s orifice pressure differential (ΔH@). Alliance uses approved
Alternative Method 009 as a post-test calibration check to ensure that the correction factor has not changed
more than 5% since the last full meter calibration. This check is performed after each test series.
• Pitot Tubes and Manometers. Type-S pitot tubes that meet the geometric criteria required by U.S. EPA
Reference Test Method 2 are assigned a coefficient of 0.84 unless a specific coefficient has been
determined from a wind tunnel calibration. If a specific coefficient from a wind tunnel calibration has been
obtained that coefficient will be used in lieu of 0.84. Standard pitot tubes that meet the geometric criteria
required by U.S. EPA Reference Test Method 2 are assigned a coefficient of 0.99. Any pitot tubes not
meeting the appropriate geometric criteria are discarded and replaced. Manometers are verified to be level
and zeroed prior to each test run and do not require further calibration.
• Temperature Measuring Devices. All thermocouple sensors mounted in Dry Gas Meter Consoles are
calibrated semi-annually with a NIST-traceable thermocouple calibrator (temperature simulator) and
verified during field use using a second NIST-traceable meter. NIST-traceable thermocouple calibrators
are calibrated annually by an outside laboratory.
• Digital Calipers. Calipers are calibrated annually by Alliance by using gage blocks that are calibrated
annually by an outside laboratory.
• Barometer. The barometric pressure is obtained from a nationally recognized agency or a calibrated
barometer. Calibrated barometers are checked prior to each field trip against a mercury barometer. The

Site Specific Test Plan
Quality Assurance Program

AST-2024-3136-002 Nucor – Plymouth, UT Page 4-2

barometer is acceptable if the values agree within ± 2 percent absolute. Barometers not meeting this
requirement are adjusted or taken out of service.
• Balances and Weights. Balances are calibrated annually by an outside laboratory. A functional check is
conducted on the balance each day it is use in the field using a calibration weight. Weights are re-certified
every two (2) years by an outside laboratory or internally. If conducted internally, they are weighed on a
NIST traceable balance. If the weight does not meet the expected criteria, they are replaced.
• Other Equipment. A mass flow controller calibration is conducted on each Environics system annually
following the procedures in the Manufacturer’s Operation manual. Other equipment such as probes,
umbilical lines, cold boxes, etc. are routinely maintained and inspected to ensure that they are in good
working order. They are repaired or replaced as needed.
4.2 Field Sampling
Field sampling will be done in accordance with the Standard Operating Procedures (SOP) for the applicable test
method(s). General QC measures for the test program include:
• Cleaned glassware and sample train components will be sealed until assembly.
• Sample trains will be leak checked before and after each test run.
• Appropriate probe, filter and impinger temperatures will be maintained.
• The sampling port will be sealed to prevent air from leaking from the port.
• Dry gas meter, ΔP, ΔH, temperature and pump vacuum data will be recorded during each sample point.
• All raw data will be maintained in organized manner.
• All raw data will be reviewed on a daily basis for completeness and acceptability.