DAQ-2024-008647

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
DAQC-628-24
Site ID 10008 (B5)

Doug Jones
Nucor Steel – Plymouth Division
P.O. Box 100
Plymouth, UT 84330

Dear Mr. Jones:

Re: Nucor Steel – Plymouth Division (Nucor) – Pretest Protocol for Carbon Monoxide (CO),
Carbon Dioxide (CO2), Flow, Nitrogen Oxides (NOx), Sulfur Dioxide (SO2), Relative
Accuracy Test – Box Elder County

The Utah Division of Air Quality (DAQ) reviewed Nucor’s pretest protocol emailed on
June 21, 2024. The proposed test shall be performed under the following conditions:

Nucor’s monitoring system to be certified:

Point Source Channel Manufacturer Model # Monitor SN
Primary CEM
Baghouse Stack
NOX Thermo Scientific 42iQLS-ACBNA 1181830033
CO Thermo Scientific 48iQ-ACN 1181830035
SO2 Thermo Scientific 43iQ-ACN 1181830034
O2/CO2 Thermo Scientific 410iQ-ACN 1181830036
Secondary CEM
Baghouse Stack
NOX Echochem MC3 512
CO Echochem MC3 512
SO2 Echochem MC3 512
O2/CO2 Echochem MC3 512

Alliance Technical Group will conduct a relative accuracy/performance specification test on Nucor’s
continuous monitoring systems.

Relative accuracy must be determined in the units of the emission standard or equivalent units of the
emission standard, i.e., tons/year shall be tested in pounds/hour or lb Hg/MM ton clinker 30-DRA
shall be tested as lb Hg/MM ton clinker.

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DAQC-628-24
Page 2

The DAQ understands that testing will be conducted as follows:

Test Date Point Source Parameter EPA Reference Method
August 6, 2024
Baghouse Stack
CO2 and Flow Method 1, 2, 3A, and 4
CO Method 10
NOx Method 7E
SO2 Method 6C

• Reference Method 1 - Sample and Velocity Traverses for Stationary Point Sources as
outlined in 40 CFR 60 Appendix A shall be used to determine the location and number
of sampling points as applicable.

• Reference Method 2 - Determination of Stack Gas Velocity and Volumetric Flow Rate
– (Type S Pitot Tube) as outlined in 40 CFR 60 Appendix A.

• Reference Method 3A - Determination of Oxygen and Carbon Dioxide Concentrations
in Emissions from Stationary Point Sources – (Instrumental Analyzer Procedure) as
outlined in 40 CFR 60 Appendix A.

• Reference Method 4 - Determination of Moisture Content in Stack Gases as outlined in
40 CFR 60 Appendix A shall be used to determine the stack gas moisture content.

• Reference Method 6C - Determination of Sulfur Dioxide Emissions from Stationary
Point Sources - (Instrumental Analyzer Procedure) as outlined in 40 CFR 60 Appendix A.

• Reference Method 7E - Determination of Nitrogen Oxide Emissions from Stationary
Point Sources - (Instrumental Analyzer Procedure) as outlined in 40 CFR 60 Appendix A.

• Reference Method 10 - Determination of Carbon Monoxide Emissions from Stationary
Point Sources - (Instrumental Analyzer Procedure) as outlined in 40 CFR 60 Appendix A.

• Deviations - The Director or the representative of the Director must be notified of and
approve deviations of the Reference Method test. Any deviation from these conditions
without approval from the DAQ may constitute rejection of these tests.

Acceptance of a protocol does not relieve the owner/operator and the testing contractor
from strict adherence to all applicable EPA methods, DAQ policies, Utah Air Quality
Rules (UAQR), and methods approved by the Director. Any deviation from EPA
methods, DAQ policies, UAQR, and methods approved by the Director must be
addressed separately and express written consent given prior to commencement of
testing.

• Field data (Point Source emission data and test data) shall be turned over to the DAQ
in a timely manner for review.

DAQC-628-24
Page 3

• The Director will determine the relative accuracy of each monitoring system based on
Point Source continuous emission monitoring data and test data acquired by the staff
member of the DAQ during the test.

• All test reports must be submitted to the Director no later than 60 days after
completion of the test.

• The test report shall include all raw calibration data and raw emission data with date
and time stamps.

Relative accuracy test reports must contain:

1. Point source continuous monitor, channel, manufacturer, and serial number.

2. Raw stack test data and continuous monitor data with date and time stamps.

3. Emission data reported in concentration (ppm or %) and units in the applicable
emission limit.

The DAQ requires that all test reports include a statement signed by a responsible official
certifying that:

1. Testing was conducted while the Point Source was operating at the rate and/or
conditions specified in the applicable approval order, operating permit, or federal
regulation.

2. During testing, the Point Source combusted fuels, used raw materials, and maintained
process conditions representative of normal operations, and operated under such other
relevant conditions specified by the Director.

3. Based on information and belief formed after reasonable inquiry, the statements and
information contained in the report are true, accurate, and complete.

Should you have any questions concerning this matter, contact me at [phone] or by
email at [e-mail].

Sincerely,

Rob Leishman, Environmental Scientist
Major Source Compliance Section

RL: jl

cc: Bear River Health Department
Alliance Technical Group
* $ . # ( ) - — 0 ) A D v A ? A C @ D w A D ˜
Rob Leishman Jr