Permit No.: 10281 Expiration Date: April 12, 2011 Page: 1 of 54

AIR OPERATING PERMIT

Puget Sound Clean Air Agency 1904 Third Ave, Suite 105 Seattle, Washington 98101
Issued in accordance with the provisions of Puget Sound Clean Air Agency Regulation I, Article 7; and Chapter 173-401 WAC. Pursuant to Puget Sound Clean Air Agency Regulation I, Article 7, and Chapter 173-401 WAC, Nucor Steel Seattle, Inc. is authorized to operate subject to the terms and conditions in this permit.

PERMIT NO.:10281

DATE OF ISSUANCE: April 12, 2006 Modification: March 4, 2008

ISSUED TO:

Nucor Steel Seattle, Inc.
PERMIT EXPIRATION DATE: April 12, 2011
SIC Code, Primary: NAICS Code: Nature of Business: Mailing Address: Facility Address: Responsible Official: Telephone No.: Site Contact: Telephone No.: FAX No.: Iron and Steel Mills 2424 SW Andover Street, Seattle, WA SW Andover Street, Seattle, WA 98106 Matt Lyons, General Manager (206) 933-2201 Bart Kale, Safety and Environment Manager (206) 933-2238 (206) 933-2207
Puget Sound Clean Air Agency Approval:
_______________________________
Agata Z. McIntyre, P.E. Permit Engineer
Steven M. Van Slyke, P.E. Supervisory Engineer
Nucor Steel, Seattle, Inc. Operating Permit, Modification: March 4, 2008
Permit No. 10281 Expiration Date: April 12, 2011 Page 2 of 54

TABLE OF CONTENTS

I. II. III. IV. V. VI. III. IV. V. EMISSION LIMITS AND PERFORMANCE STANDARDS.. 3 MONITORING, MAINTENANCE AND RECORDKEEPING PROCEDURES. 16 PROHIBITED ACTIVITIES... 23 ACTIVITIES REQUIRING ADDITIONAL APPROVAL.. 25 STANDARD TERMS AND CONDITIONS... 28 PERMIT ACTIONS.... 43 PERMIT SHIELD.... 50 INAPPLICABLE REQUIREMENTS.... 51 APPENDIXES..... 54

TABLES

Table 1 Facility-Wide Applicable Requirements... 5 Table 2 Emission Unit #1 (EU-1): Electric Arc Furnace... 12 Table 3 Emission Unit #2 (EU-2): Meltshop Combustion Sources... 15 Table 4 Emission Unit #3 (EU-3): Reheat Furnace... 15
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NOTE REGARDING CHANGE IN OWNERSHIP OF THE PERMITTED FACILITY
Nucor Steel Seattle Inc. (Nucor) acquired the Seattle plant from Birmingham Steel Corporation on December 9, 2002. Certain underlying documents referred to in this air operating permit, such as Orders of Approval, have not been reopened to change the name of the company, but any terms and conditions in those documents that applied to Birmingham Steel Corporation now apply in exactly the same manner to Nucor Steel Seattle, Inc.
I. EMISSION LIMITS AND PERFORMANCE STANDARDS
The following tables list the citation for each applicable requirement in the second column. This can be a Puget Sound Clean Air Agency requirement, a Washington State Department of Ecology requirement, or a federal requirement. All requirements are federally enforceable unless they are identified in column two by the words STATE ONLY. The third column (Date) contains the adoption or effective date of the requirement. In some cases, the effective dates of the Federally Enforceable Requirement and the State Only Requirement are different because only rules approved by EPA through Sections 110, 111, and 112 of the federal Clean Air Act are federally enforceable and either the state has not yet submitted the regulation to the EPA or the EPA has not yet approved it. STATE ONLY adoption dates are in italicized font. When the EPA does approve the new requirement by adopting it into the State Implementation Plan (SIP), the old requirement will be replaced and superseded by the new requirement. This replacement will take place automatically, with no changes being made to this permit until the permit is renewed. The new requirement will be enforceable by the EPA as well as the Puget Sound Clean Air Agency from the date that it is adopted into the SIP, and the old requirement will no longer be an applicable requirement. The first column is used as an identifier for the requirement, and the fourth (Requirement Paraphrase) column paraphrases the requirement. The first and fourth columns are for information only and are not enforceable conditions of this permit. The actual enforceable requirement is embodied in the requirement cited in the second and third columns. The fifth column (Monitoring, Maintenance & Recordkeeping Method) identifies the methods described in Section II of the permit. Following these methods is required to reasonably assure continuous compliance with, and is an enforceable requirement of, this air operating permit. Note that all inspections, tests, and other actions must be documented (see paragraph 4 of Subsection V.O for specific requirements). The sixth (Emission Standard Period) column identifies the averaging time for the reference test method. The last column (Reference Test Method) identifies the reference method associated with an applicable emission limit that is to be used if and when a source test is required. In some cases where the applicable requirement does not cite a test method, one has been added.

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In the event of conflict or omission between the information contained in the fourth and sixth columns and the actual statute or regulation cited in the second column, the requirements and language of the actual statute or regulation cited shall govern. For more information regarding any of the requirements cited in the second and third columns, refer to the actual requirements cited.
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A. FACILITY-WIDE APPLICABLE REQUIREMENTS The requirements in this section apply facility-wide to all the emission units regulated by this permit except that monitoring methods specified elsewhere in the permit for specific applicable requirements at specific emission units supersede the general monitoring requirements listed in Section I.A.
Table 1 Facility-Wide Applicable Requirements Reqmt No. General I.A.1 WAC 173-400-040 WAC 173-400-040 (STATE ONLY) Opacity Standards I.A.2 Puget Sound Clean Air Agency Reg I: 9.03 (except for 9.03(e)) Puget Sound Clean Air Agency Reg. I: 9.03 (STATE ONLY) WAC 173-400-040(1) WAC 173-400-040(1) (STATE ONLY) 3/11/99 Nucor shall not emit any air pollutants which exhibit greater than 20% opacity for a period or periods aggregating more than 3 minutes in any hour II.A.1(a) Opacity Monitoring More than 3 min. in any 1 hr Ecology Reference Method 9A, 7/12/1990 (See Section X) 9/23/93 2/10/05 All emission units are required to use RACT. No monitoring required N/A N/A Enforceable Requirement Adoption or Effective Date Requirement Paraphrase (Information Only) Monitoring, Maintenance & Recordkeeping Method Emission Standard Period Reference Test Method

3/25/04

9/23/93 2/10/05
Permit No. 10281 Expiration Date: April 12, 2011 Page 6 of 54 Reqmt No. Enforceable Requirement Adoption or Effective Date Requirement Paraphrase (Information Only) Monitoring, Maintenance & Recordkeeping Method Emission Standard Period Reference Test Method
Particulate Matter Standards I.A.3 Puget Sound Clean Air Agency Reg I: 9.09 4/9/98 Nucor shall not emit particulate matter in excess of 0.05 gr/dscf from equipment used in a manufacturing process. II.A.1(a) Opacity Monitoring II.C Compliance Assurance Monitoring (CAM) II.A.1(a) Opacity Monitoring II.C Compliance Assurance Monitoring (CAM) II.A.1(c) Facility-Wide Inspections (3) 1-hour runs (3) 1-hour runs (3) 1-hour runs Puget Sound Clean Air Agency Method 5 (See Section X)

WAC 173-400-060 WAC 173-400-060 (STATE ONLY).

3/22/91 2/10/05

Nucor shall not emit particulate matter in excess of 0.1 gr/dscf uncorrected for excess air from general process units
EPA Method 5 (40 CFR Part 60, Appendix A, July 1, 2005)
WAC 173-400-050(1) WAC 173-400-050(1) (STATE ONLY)
Nucor shall not emit particulate matter in excess of 0.1 gr/dscf corrected to 7% O2 from combustion and incineration units.
SO2 Standards I.A.6 Puget Sound Clean Air Agency Reg I: 9.07 WAC 173-400-040(6) first paragraph only. WAC 173-400-040(6) (STATE ONLY) 4/14/94 9/23/93 2/10/05 Nucor shall not emit SO2 in excess of 1,000 ppmv (dry) corrected to 7% O2 for fuel burning equipment No monitoring required (3) 1-hour runs EPA Method 6C (40 CFR Part 60, Appendix A, July 1, 2005)
Permit No. 10281 Expiration Date: April 12, 2011 Page 7 of 54 Reqmt No. HCl Standards I.A.7 Puget Sound Clean Air Agency Reg. I: 9.10(a) (STATE ONLY) 6/9/88 Nucor shall not emit HCl in excess of 100 ppm (dry) corrected to 7% O2 for combustion sources No monitoring required (3) 1-hour runs EPA Method 26 or 26A (40 CFR Part 60, Appendix A; July 1, 2005) Enforceable Requirement Adoption or Effective Date Requirement Paraphrase (Information Only) Monitoring, Maintenance & Recordkeeping Method Emission Standard Period Reference Test Method
Nuisance Standards I.A.8 WAC 173-400-040(5) Puget Sound Clean Air Agency Reg. I: 9.11 (STATE ONLY) WAC 173-400-040(5) (STATE ONLY) WAC 173-400-040(2) (STATE ONLY) RCW 70.94.040 (STATE ONLY) I.A.9 WAC 173-400-040(4) (STATE ONLY) 8/20/93 3/11/99 Nucor shall not emit air contaminants in sufficient quantities and of such characteristics and duration as is, or is likely to be, injurious to human health, plant or animal life, or property, or which unreasonably interferes with enjoyment of life and property II.A.1(b) Complaint Response II.A.1(c) Facility-Wide Inspections NA NA

2/10/05 2/10/2/10/05

Nucor shall use recognized good practice and procedures to reduce to a minimum odors which may unreasonably interfere with any other property owners use and enjoyment of their property
II.A.1(b) Complaint Response II.A.1(c) Facility-Wide Inspections
Permit No. 10281 Expiration Date: April 12, 2011 Page 8 of 54 Reqmt No. Enforceable Requirement Adoption or Effective Date Requirement Paraphrase (Information Only) Monitoring, Maintenance & Recordkeeping Method Emission Standard Period Reference Test Method

Fugitive Emissions Standards I.A.10 WAC 173-400-040(3) WAC 173-400-040(3) (STATE ONLY) WAC 173-400-040(8) WAC 173-400-040(8) (STATE ONLY 9/23/93 2/10/05 9/23/93 2/10/05 Nucor shall take reasonable precautions to prevent release of fugitive dust. II.A.1(b) Complaint Response II.A.2(c) Meltshop Opacity Monitoring II.A.1(d) Fugitive Dust II.A.1(e) Road Dust II.A.1(f) Scrap Yard Fugitive Dust NA NA
Permit No. 10281 Expiration Date: April 12, 2011 Page 9 of 54 Reqmt No. I.A.11 Enforceable Requirement Puget Sound Clean Air Agency Reg. I: 9.15 Adoption or Effective Date 3/11/99 Requirement Paraphrase (Information Only) (a) Nucor shall not cause or allow visible emissions of fugitive dust unless reasonable precautions are employed to minimize the emissions. Reasonable precautions include, but are not limited to, the following: (1) The use of control equipment, enclosures, and wet (or chemical) suppression techniques, as practical, and curtailment during high winds; (2) Surfacing roadways and parking areas with asphalt, concrete, or gravel; (3) Treating temporary, low-traffic areas (e.g., construction sites) with water or chemical stabilizers, reducing vehicle speeds, constructing pavement or rip rap exit aprons, and cleaning vehicle undercarriages before they exit to prevent the track-out of mud or dirt onto paved public roadways; or (4) Covering or wetting truck loads or allowing adequate freeboard to prevent the escape of dust-bearing materials (b) Compliance with the provisions of this section shall not relieve Nucor of the responsibility of complying with Reg. I:9.11. Monitoring, Maintenance & Recordkeeping Method II.A.1(b) Complaint Response II.A.1(d) Fugitive Dust II.A.1(e) Road Dust II.A.1(f) Scrap Yard Fugitive Dust Emission Standard Period NA Reference Test Method NA
Permit No. 10281 Expiration Date: April 12, 2011 Page 10 of 54 Reqmt No. I.A.12 Enforceable Requirement Order of Approval No. 9669 condition 10 Adoption or Effective Date 2/14/08 Requirement Paraphrase (Information Only) Monitoring, Maintenance & Recordkeeping Method Emission Standard Period NA NA Reference Test Method
Nucor shall minimize fugitive emissions II.A.1(e) Road Dust from paved roads by dispatching a vacuum truck to clean paved roads on a weekly basis when dry conditions persist and by dispatching a water truck to wet down paved roads when dry conditions persist. Nucor shall minimize fugitive emissions from scrap handling by maintaining and operating a sprinkler system in the scrap yard. The sprinklers shall be controlled by an automatic timer that will be adjusted to operate more frequently when dry conditions persist. II.A.1(f) Scrap Yard Fugitive Dust

II.A.2(b) Baghouse Opacity More than 3 Ecology Method 9A Monitoring min in any 1 (See Section IX) hr II.A.2(c) Meltshop Opacity Monitoring II.A.2(b) Baghouse Opacity Average of 6 EPA Method 9 as Monitoring consecutive described in 40 CFR min 60.275a(e)(3)
Shall not emit air contaminants in excess of 3% opacity from an EAF control device, except during startup, shutdown and malfunction (SSM) periods 1
40 CFR 60.2 Definitions. Startup means the setting in operation of an affected facility for any purpose. Shutdown means the cessation of operation of an affected facility for any purpose. Malfunction means any sudden, infrequent, and not reasonably preventable failure of air pollution control equipment, process equipment, or a process to operate in a normal or usual manner. Failures that are caused in part by poor maintenance or careless operation are not malfunctions.
Permit No. 10281 Expiration Date: April 12, 2011 Page 13 of 54 Reqmt No. EU-1.3 Enforceable Requirement 40 CFR 60.272a(a)(3) 40 CFR 60.11(c) EU-1.CFR 60.272a(b) 40 CFR 60.11(c) EU-1.CFR 60.272a(a)(1) 40 CFR 60.8(c) Adoption or Effective Date 10/31/84 10/17/00 10/31/84 10/17/00 10/31/84 10/17/00 Requirement Paraphrase (Information Only) Shall not emit air contaminants in excess of 6% opacity from a shop due solely to emissions from an EAF, except during SSM periods Monitoring, Maintenance & Recordkeeping Method II.A.2(c) Meltshop Opacity Monitoring Emission Standard Period Reference Test Method
Average of 6 EPA Method 9 as consecutive described in 40 CFR min 60.275a(e)(3)
Shall not emit air contaminants equal to or II.A.2(b) Baghouse Opacity Average of 6 EPA Method 9 as greater than 10% opacity from the dust Monitoring consecutive described in 40 CFR loadout system of the EAF baghouses, except min 60.275a(e)(3) during SSM periods Shall not emit particulate matter in excess of 0.0052 gr/dscf, except during SSM periods II.A.2(d) Baghouse Operation Monitoring II.C Compliance Assurance Monitoring (CAM) At least 4 hrs EPA Method 5D, as per run described in 40 CFR 60.275a(e)(1)

EU-1.6

40 CFR 60.11(d)

10/17/00

Shall maintain and operate the EAF and dust No monitoring required handling equipment in a manner consistent with good air pollution control practice for minimizing emissions Nucor Steel shall not produce more than 1.1 million tons of billets during each consecutive 12-month rolling period. Emissions of PM10 from the low temperature (Wheelabrator) baghouse shall not exceed any of the following limits: a) 0.00165 grain per dry standard cubic foot of exhaust gas. II.A.2(a) Compliance with Production Limit Requirement II.A.2(d) Baghouse Operation Monitoring II.A.2(e) PM10 Source Testing II.C Compliance Assurance Monitoring (CAM)

EU-1.7

PSD Permit No. 07-02, approval condition 1

2/15/08

Any consecutive 12-month period 4 hr and 160 dscf and an integral number of heats per sample run

EU-1.8

Order of Approval No. 9669 Condition 4
EPA Methods 5D, 201 or 201A

b) 7.93 pounds per hour.

Permit No. 10281 Expiration Date: April 12, 2011 Page 14 of 54 Reqmt No. EU-1.9 Enforceable Requirement Order of Approval No. 9669 Condition 3 Adoption or Effective Date 2/14/08 Requirement Paraphrase (Information Only) Emissions of PM10 from the high temperature (Baumco) baghouse shall not exceed any of the following limits: a) 0.0018 grain per dry standard cubic foot of exhaust gas. Monitoring, Maintenance & Recordkeeping Method II.A.2(d) Baghouse Operation Monitoring II.A.2(e) PM10 Source Testing II.C Compliance Assurance Monitoring (CAM) Emission Standard Period 4 hr and 160 dscf and an integral number of heats per sample run Any consecutive 30 day period Reference Test Method EPA Methods 5D, 201 or 201A
b) 7.14 pounds per hour. EU-1.10 Order of Approval No. 9669 Condition 6 2/14/08
Emissions of oxides of nitrogen (NOX) from II.A.2(f) NOX and CO the EAF (high and low-temperature Source Testing baghouses combined) shall not exceed 0.480 pound per ton of steel produced for any consecutive 30 day period. Compliance is determined by the average of all tests conducted within a consecutive 30 day period. Emissions of carbon monoxide (CO) from the EAF (high and low-temperature baghouses combined) shall not exceed 1.98 pounds per ton of steel produced for any consecutive 30 day period. Compliance is determined by the average of all tests conducted within a consecutive 30 day period. II.A.2(f) NOX and CO Source Testing

EPA Method 7E

EU-1.11
Order of Approval No. 9669 Condition 7
Any consecutive 30 day period

EPA Method 10

EU-1.12
Order of Approval No. 9669 Condition 8 and 9
If emissions of PM10, NOx, SO2, VOC, or V.R.5(b) Order of lead exceed baseline emissions by more than Approval No. 9669 a significant amount, Nucor shall include in emission report the annual emission report required by V.R.5(b), an explanation as to why emissions of that pollutant differ from preconstruction projections.

WAC 173-401-200(16) states: Insignificant activity or insignificant emissions unit means any activity or emissions unit located at a chapter 401 source which qualifies as insignificant under the criteria listed in WAC 173-401-530. These units and activities are exempt from permit program requirements except as provided in WAC 173-401-530. WAC 173-401-530 contains criteria for identifying insignificant activities and emissions units. It also states that Designation of an emission unit or activity as insignificant for purposes of this chapter does not exempt the unit or activity from any applicable requirement. 3 Puget Sound Clean Air Agency Regulation I, Section 1.07(s) states, EQUIPMENT means any stationary or portable device or any part thereof that emits or may emit any air contaminant into the atmosphere.
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this case, EPA Method 9 observations must be made for the site of highest opacity that directly relates to the cause (or location) of visible emissions observed during a single incident. Records shall be maintained of any 6-minute average that is in excess of the emission limit specified in 40 CFR 60.272a(a). Report exceedances as provided in V.R.1 and 3. [40 CFR 60.273a(c); 2/22/05] (c) Meltshop Opacity Monitoring Observations of the opacity of the visible emissions from the meltshop shall be performed by a certified visible emission observer as follows: shop opacity observations shall be conducted at least once per day 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 EPA Method 9. Shop opacity shall be recorded for any point(s) where visible emissions are observed. Where no visible emissions are observed from the meltshop or baghouses the reader may observe the emissions from the meltshop during one of the 6-minute periods in which baghouse opacity is monitored under condition II.A.2(b). Where it is possible to determine that a number of visible emission sites relate to only one incident of the visible emissions, only one observation of shop opacity will be required. In this case, EPA Method 9 observations must be made for the site of highest opacity that directly relates to the cause (or location) of visible emissions observed during a single incident. Maintain records of all exceedances of the opacity limit in condition EU-1.3. Report exceedances as provided in V.R.1 and 3. [40 CFR 60.273a(d); 3/2/99, 40 CFR 60.276a(g), 10/17/00] (d) Baghouse Operation Monitoring Nucor Steel shall check and record the control system fan motor amperes and damper position on a once-per-shift basis according to 40 CFR 60.274a(b). Nucor Steel shall report fan motor amperage readings that are outside the ranges established according to 40 CFR 60.274a(c), as provided in Section V.R.3. [40 CFR 60.274a(b); 3/2/99;] Nucor Steel shall 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). This inspection shall include observations of the physical appearance of the equipment (e.g., presence of holes in ductwork or hoods, flow constrictions caused by dents or accumulated dust in ductwork, and fan erosion). Any deficiencies shall be noted and proper maintenance performed. [40 CFR 60.274a(d); 3/2/99]

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(e) PM10 Source Testing Source testing for compliance with the PM10 emission limits in Order of Approval No. 9669 Conditions 3 and 4 (Requirements contained in EU-1.8 and EU-1.9) shall utilize EPA Reference Test Methods 5D, 201, or 201A, and shall comply with requirements in Puget Sound Clean Air Agency Regulation I, Section 3.07. Source testing for PM10 shall be conducted at a frequency no less than once per calendar year, with not less than 6 or more than 18 months between any two annual tests. Nucor shall report the results of each test as provided in Section V.N.1. [Order of Approval No. 9669, condition 5 (2/14/08)] (f) NOX and CO Source Testing Source testing for CO and NOX shall be conducted on the inlets of the high temperature and low temperature baghouses no less often than once every calendar year. Source testing shall utilize EPA Reference Methods 10 and 7E respectively, and shall comply with requirements in Puget Sound Clean Air Agency Regulation I, Section 3.07. [Order of Approval No. 9669, conditions 6 and 7 (2/14/08)] Compliance with the NOx and CO emission limits shall be determined by the average of all tests conducted within a consecutive 30 day period. Nucor shall report the results of each test as provided in Section V.N.1. [Order of Approval No. 9669, conditions 6 and 7 (2/14/08)]
B. Operation and Maintenance (O & M) Plan Requirements Nucor Steels O & M Plan shall include procedures specifying how Nucor Steel will assure continuous compliance with emission limits and operational requirements within this permit, as well as Puget Sound Clean Air Agency Regulations I, II and III, and how Nucor Steel will carry out the Minimum Monitoring and Maintenance provisions specified in Sections II.A.1(a) through (f) of this permit. For insignificant emission units, the O & M Plan shall refer to the requirements stated in Section II.A.1(g). The plan shall reflect good industrial practice. In most instances, following the manufacturers operations manual or equipment operational schedule, minimizing emissions until the repairs can be completed and taking measures to prevent recurrence of the problem may be considered good industrial practice. Determination of whether good industrial practice is being used will be based on available information such as monitoring results, opacity observations, review of operations and maintenance procedures, and inspections of the emission unit or equipment. The specific provisions of the O & M Plan, other than those required by Condition Section II.A, shall not be deemed part of this permit. [Puget Sound Clean Air Agency Reg. I: 7.09(b) (9/10/98)]
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C. Compliance Assurance Monitoring (CAM) 1. Applicability The compliance assurance monitoring (CAM) requirements in 40 CFR Part 64 apply to Emission Unit No. 1 (EU-1), the electric arc furnace, with respect to the particulate emission limitations identified in requirements I.A.3, I.A.4, EU-1.5, EU-1.8 and EU-1.9. [40 CFR 64.2 (10/22/97)] 2. Monitoring Approach Nucor shall monitor baghouse opacity and baghouse operation, using the methods specified in permit Sections II.A.2(b) and (d). [40 CFR 64.3 and 64.6(c)(1) (10/22/97)] 3. Quality Assurance and control procedures Visible emissions observers shall be trained and certified as provided in EPA Method 9. Nucor shall conduct annual PM10 source tests, as provided in Section II.A.2(e), to confirm compliance with requirements EU-1.8 and EU-1.9. [40 CFR 64.3(b)(3) and 64.6(c)(1) (10/22/97)] 4. Obligation to monitor and data availability requirement Nucor shall perform the monitoring specified in this Sections II.A.2(b) and (d) whenever the EAF is in operation. [40 CFR 64.7 and 64.6(c)(3)-(4) (10/22/97)] 5. Definition of an excursion An excursion is defined as each baghouse opacity reading taken in accordance with Section II.A.2(b) that shows opacity above zero percent, and every baghouse fan motor amperage reading taken in accordance with Section II.A.2(d) that is outside of the range established under 40 CFR 60.274a(c). An excursion does not necessarily indicate an exceedance of the applicable particulate emission standards referenced in II.C.1 above, nor does evidence of an excursion preclude Nucor from certifying continuous compliance as provided in Section V.M of this permit, if Nucor has other data on which to base a determination of compliance during the reporting period in which the excursion occurred. [40 CFR 64.6(c)(2) (10/22/97); 40 CFR 70.6(c)(5)(iii)(C) (6/27/03)] 6. Response to an excursion Upon detecting an excursion, Nucor shall restore operation of the EAF and the affected baghouse to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practice for minimizing emissions. [40 CR 64.7(d) and 64.6(c)(3) (10/22/97)] 7. Quality Improvement Plan (QIP) Nucor will develop a QIP if there are more than six reportable excursions during any semiNucor Steel, Seattle, Inc. Operating Permit, Modification: March 4, 2008

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annual reporting period referenced in Section V.R.3 of this permit. [40 CFR 64.8 and 64.6(c)(3) (10/22/97)] 8. Reporting
The monthly deviation report required by Section V.R.1 shall include: 1) Summary information on the number, duration and cause (including unknown cause, if applicable) of each excursion and the corrective action taken; 2) Summary information on every failure to meet the data availability requirement in II.C.4; and 3) A description of the actions taken to implement a QIP during the reporting period, if required. Upon completion of a QIP, Nucor shall include documentation that the implementation of the plan has been completed and describe how that plan has reduced the likelihood of occurrence of similar excursions in the next monthly deviation report required by Section V.R.1. [40 CFR 64.9(a) and 64.6(c)(3) (10/22/97)] 9. Recordkeeping The recordkeeping required by Section V.P shall include records of the monitoring data described in this section, corrective actions taken pursuant to II.C.6, any QIP prepared under II.C.7, and any activities taken to implement a QIP. Instead of paper records, Nucor may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks or microfiche, provided that the use of such alternative media allows for expeditious inspection and review. [40 CFR 64.9(b) and 64.6(c)(3) (10/22/97)]
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III. PROHIBITED ACTIVITIES
Nucor Steel is prohibited from conducting, causing, or allowing the following activities: A. Adjustment for Atmospheric Conditions Varying the rate of emissions of a pollutant according to atmospheric conditions or ambient concentrations of that pollutant is prohibited, except as directed according to air pollution episode regulations. [WAC 173-400-205, 9/20/93] B. Open Burning Nucor Steel shall not conduct open burning during any stage of an air pollution episode or period of impaired air quality and shall not conduct any open burning other than the following types: (1) Fires consisting solely of charcoal, propane, natural gas, or wood used solely for the preparation of food, and
4) Fires for instruction in the methods of fighting fires, provided that the person conducting the training fire complies with Puget Sound Clean Air Agency Regulation I, Section 8.07. [Puget Sound Clean Air Agency Regulation I, Sections 8.02(a) and 8.06, 5/13/93], [WAC 173425-020(1), 1/1/93; WAC 173-425-050(1) 1/1/93; RCW 70.94.743, 1998 c68 p1; and RCW 70.94.775(2) 1995 c 362p2 State/Puget Sound Clean Air Agency only] C. Refuse Burning Nucor Steel shall not cause or allow the burning of combustible refuse except in a multiple chamber incinerator provided with control equipment. Nucor Steel shall not operate refuse burning equipment any time other than daylight hours. [Puget Sound Clean Air Agency Regulation I, Section 9.05, 12/9/93] D. Concealment Nucor Steel shall not cause or allow the installation or use of any device or use of any means which, without resulting in a reduction in the total amount of air contaminant emitted, conceals an emission of an air contaminant that would otherwise violate Puget Sound Clean Air Agency Regulation I, Article 9 or Chapter 173-400 WAC. [Puget Sound Clean Air Agency Regulation I, Section 9.13(a), 6/9/88 and WAC 173-400-040(7) 9/20/93] E. Masking Nucor Steel shall not cause or allow the installation or use of any device or use of any means designed to mask the emission of an air contaminant that causes detriment to health, safety or welfare of any person or conceals or masks an emission of an air contaminant that would

(8) (9)

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II.C.8 of the permit, including any required information on implementation of a QIP. Nucor Steel shall maintain a contemporaneous record of all deviations. Nucor Steel shall report any deviations to the Puget Sound Clean Air Agency that represent a potential threat to human health or safety by FAX (206-343-7522) as soon as possible but no later than 12 hours after such a deviation is discovered. Nucor Steel shall report other deviations in writing to Puget Sound Clean Air Agency Operating Permit Certification no later than 30 days after the end of the month during which the deviation is discovered. No deviation report is required for a month in which no deviation is discovered. A Deviation Report may be certified by a responsible official as provided in V.R.4 at the time of submittal; however it is not required to be certified at the time of submittal. Any Deviation Report not certified at the time of submittal must be certified in the semiannual Certification of Reports as per V.R.2 [WAC 173-401-615(3)(b), 10/17/02; 40 CFR 64.9(a) and 64.6(c)(3), 10/22/97] 2. Certification of Reports (semiannual) Nucor Steel shall submit in writing to Puget Sound Clean Air Agency Operating Permit Certification a semi-annual report which shall summarize each permit report filed during the sixmonth period. Each Certification of Reports shall cover a six month interval ending June 30 and December 31, and shall be submitted within 31 days after the end of the period covered by the report. Each Certification of Reports shall be certified by a responsible official as provided in V.R.4. The Certification of Reports need not duplicate information contained in another report. Deviation reports that are submitted pursuant to V.R.1 within a given six-month reporting period may be summarized and certified by the responsible official in this semiannual Certification of Reports. If there were no instances of deviations from permit requirements during the six month period, the semi-annual report shall state that there were no instances of deviations from permit requirements. [WAC 173-401-615(3)(a), 10/17/02] 3. NSPS Subpart AAa Reports (semiannual) Nucor shall submit a written report of the following NSPS Subpart AAa exceedances semiannually to Puget Sound Clean Air Agency Operating Permit Certification: (1) All 6-minute periods, other than during SSM, during which the average opacity from air pollution control equipment used to remove particulate matter from the effluent gas stream generated by the electric arc furnace is 3 percent or greater. [40 CFR 60.276a(b), 3/2/99; 40 CFR 60.11(c), 10/17/00] All shop opacity observations made in accordance with 40 CFR 60.273a(d) in excess of 6%, other than SSM periods. [40 CFR 60.276a(g), 2/12/99; 40 CFR 60.11(c), 10/17/00]
In addition, the report shall describe each period of operation of the control system fan motor amperes at values exceeding 15 percent of the value established under 40 CFR 60.274a(c) other than during SSM. [40 CFR 60.276a(c), 2/12/99; 40 CFR 60.8(c), 3/2/99] These reports may be certified by the responsible official, or they may be listed and certified in the Certification of Reports pursuant to V.R.2. Each NSPS Subpart AAa report shall cover a six

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month interval ending June 30 and December 31, and shall be submitted within 31 days after the end of the period covered by the report. 4. Certification by Responsible Official Any application form, report, or compliance certification submitted pursuant to this permit shall contain certification by a responsible official of truth, accuracy, and completeness. This certification and any other certification required under this permit shall state that, based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate, and complete. [WAC 173-401-520, 11/4/93] 5. Emission reporting (a) Annual facility-wide emission report Nucor Steel shall report annually to the Puget Sound Clean Air Agency listing those air contaminants emitted during the previous calendar year that equal or exceed the following in tons per year: Carbon monoxide (CO) emissions..25 Facility combined total of all toxic air contaminants (TAC) emissions...6 Any single toxic air contaminant (TAC) emissions..2 Nitrogen oxide (NOX) emissions...25 Particulate matter (PM10) emissions...25 Particulate matter (PM2.5) emissions...25 Sulfur oxide (SO2) emissions..25 Volatile organic compounds (VOC) emissions..25 Annual emissions rates shall be reported to the nearest whole ton per year for only those contaminants that equal or exceed the thresholds above. Nucor Steel shall maintain records of information necessary to document any reported emissions or demonstrate that the emissions were less than the above amounts. [Puget Sound Clean Air Agency Regulation I, Section 7.09(a), 9/10/98] Nucor Steel shall submit to the Puget Sound Clean Air Agency any additional information required by WAC 173-400-105(1) or Puget Sound Clean Air Agency Regulation III, Section 1.11. [Puget Sound Clean Air Agency Regulation III, Section 1.11, 12/12/96; WAC 173-400105, 9/20/93, WAC 173-400-105, 2/10/05 State/Puget Sound Clean Air Agency only]
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(b) Order of Approval No. 9669 emission report Nucor Steel shall calculate and maintain a record of annual emissions, in tons per year, on a calendar year basis for a period of ten years following resumption of regular operations after installation of the new crane, as follows: Nucor Steel shall calculate the emissions of PM10, NOX, SO2, VOC and lead from the electric arc furnace and reheat furnace, plus fugitive emissions of PM10 from vehicle travel on paved and unpaved surfaces, slag handling, and scrap handling using the average of the emission factors from all Nucor Steel stack tests conducted during the calendar year or using emission factors from AP-42 or other literature sources if Nucor Steel stack test information is not available; Nucor Steel shall submit an annual report to the Puget Sound Clean Air Agency stating the emissions of PM10, NOX, SO2, VOC and lead during the preceding calendar year. The report shall be submitted to the Puget Sound Clean Air Agency at the same time as Nucor Steels annual emissions report submitted in compliance with Agency Regulation I Section 7.09(a), discussed above in Section V.R.5(a). If the reported annual emissions of PM10, NOX, SO2, VOC or lead exceed the baseline actual emissions established in Condition 9 of this Order by a significant amount, as listed below, the report shall also include an explanation as to why the emissions of that pollutant differ from the preconstruction projection. Baseline actual emissions and significant emission increases are as follows: Baseline actual emissions Pollutant a. PM10 b. SO2 c. NOX d. VOC e. Lead tons per year 32.6 39.6 171.4 24.7 0.11 Significant emission increases tons per year 0.6

[Order of Approval No. 9669, conditions 8 and 9 (2/14/08)] 6. Scrapyard Crane PSD Reports (a) Initial start-up report Nucor shall notify the Washington Department of Ecology and Puget Sound Clean Air Agency in writing at least three days prior to startup of the scrapyard crane permitted under PSD 07-02. [PSD 07-02 approval condition 7 (2/15/08)]
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(b) Semi-annual production report Nucor shall submit semi-annual reports to the Puget Sound Clean Air Agency of the tons of billets produced during each of the 12 rolling month periods that terminate during the reporting period. The first report shall be filed within 30 days of completion of the first 12 month operating period following startup of the rebuilt scrapyard crane. Following reports shall be filed on July 30th for the period of January 1 through June 30th and January 30th for the period of July 1 through December 30th. [PSD 07-02 approval condition 5.1 (2/15/08)] 7. Summary of Routine required reports
Name of Report Monthly Deviation Report Certification of Reports (semiannual) Annual Compliance Certification Order of Approval No. 9669 emission reports Reqmt V.R.1 Due date(s) 30 days after the end of the month deviation occurs January 31, July 31 Annually, January 31 Annually, for 10 years following installation of new crane Annually Semi-annually Certification requirement May certify each report, but normal practice is to summarize and certify Deviation Reports in semiannual Certification of Reports as per V.R.2 Yes, in accordance with V.R.4 Yes, in accordance with V.R.4 Certify in semiannual Certification of Reports as per V.R.2

V.R.2 V.M V.R.5

Emission inventory statement PSD 07-02 semi-annual production report

V.R.5 I.A.1 (a)

Certify in semiannual Certification of Reports as per V.R.2 May certify each report or certify in semiannual Certification of Reports as per V.R.2
S. Emergencies An emergency, as defined in WAC 173-401-645(l), constitutes an affirmative defense to an action brought for noncompliance with a technology-based emission limitation if the conditions of WAC 173-401-645(3) are met. The affirmative defense of emergency shall be demonstrated through properly signed, contemporaneous operating logs, or other relevant evidence that: (1) (2) (3) An emergency occurred and that Nucor Steel can identify the cause(s) of the emergency; Nucor Steel was at the time being properly operated; During the period of the emergency Nucor Steel took all reasonable steps to minimize levels of emissions that exceeded the emission standards or other requirements in the permit; and Nucor Steel submitted notice of the emergency to the Puget Sound Clean Air Agency within two (2) working days of the time when the emissions limitations were exceeded due

Insignificant emission units and activities at Nucor Steel are subject to all applicable requirements set forth in Sections I.A, III and IV. This permit does not require testing, monitoring, reporting or recordkeeping for insignificant emission units or activities except as required by Sections II.A.1(a) through (f) of this permit. Compliance with Sections II.A.1(a) through (f) of this permit shall be deemed to satisfy the requirements of WAC 173-401-615 and 173-401-630(1). [WAC 173-401-530(2)(c), 10/17/02] Where this permit does not require testing, monitoring, recordkeeping and reporting for insignificant emissions units or activities, Nucor may certify continuous compliance if there were no observed, documented, or known instances of noncompliance during the reporting period. Where this permit requires testing, monitoring, recordkeeping and reporting for insignificant emission units or activities, Nucor may certify continuous compliance when the testing, monitoring, and recordkeeping required by the permit revealed no violations during the period, and there were no observed, documented, or known instances of noncompliance during the reporting period. [WAC 173-401-530(2)(d), 10/17/02] An emission unit or activity that qualifies as insignificant solely on the basis of WAC 173-401530(1)(a) shall not exceed the emission thresholds specified in WAC 173-401-530(4) until this permit is modified pursuant to Section VI.E of this permit and WAC 173-401-725. [WAC 173401-530(6), 10/17/02]
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VI. PERMIT ACTIONS

A. Permit Renewal, Revocation and Expiration (1) Renewal application. Nucor Steel shall submit a complete permit renewal application to the Puget Sound Clean Air Agency no later than 12 months prior to the expiration of this permit. The Puget Sound Clean Air Agency will send Nucor Steel a renewal application no later than 18 months prior to the expiration of this permit. Failure of the Puget Sound Clean Air Agency to send Nucor Steel a renewal application shall not relieve Nucor Steel from the obligation to file a timely and complete renewal application. [WAC 173-401710(1), 10/17/02; WAC 173-401-500(2), 10/17/02] Expired permits. Permit expiration terminates Nucor Steels right to operate unless a timely and complete renewal application has been submitted consistent with WAC 173401-710(1) and WAC 173-401-500. All terms and conditions of the permit shall remain in effect after this permit expires if a timely and complete permit application has been submitted. [WAC 173-401-710(3). 10/17/02] Revocation of permits. The Puget Sound Clean Air Agency may revoke a permit only upon the request of Nucor Steel or for cause. The Puget Sound Clean Air Agency shall provide at least thirty days written notice to Nucor Steel prior to revocation of the permit or denial of a permit renewal application. Such notice shall include an explanation of the basis for the proposed action and afford Nucor Steel an opportunity to meet with the Puget Sound Clean Air Agency prior to Puget Sound Clean Air Agencys final decision. A revocation issued under this condition may be issued conditionally with a future effective date and may specify that the revocation will not take effect if Nucor Steel satisfies the specified conditions before the effective date. Nothing in this subsection shall limit Puget Sound Clean Air Agency's authority to issue emergency orders. [WAC 173-401-710(4), 10/17/02] B. Administrative Permit Amendments (1) Definition. An "administrative permit amendment" is a permit revision that: (a) (b) Corrects typographical errors; Identifies a change in the name, address, or phone number of any person identified in the permit, or provides a similar minor administrative change at Nucor Steel; Requires more frequent monitoring or reporting by Nucor Steel; Allows for a change in ownership or operational control of a source where the Puget Sound Clean Air Agency determines that no other change in the permit is necessary, provided that a written agreement containing a specific date for transfer of permit responsibility, coverage, and liability between the current and

Cities are the switching centres of the new economy. We hear a good nowadays about the importance in change of ICTs. Computer and communications technologies do appear to be changing everything, so much so that they are readily perceived as if they are all that the new economy amounts to. In this way what I referred to earlier as education and acumen (the people-assets or human capital of the knowledge economy ) easily get relegated by those who think of the world today as being shaped by its being digital (Negroponte 1995). This is unfortunate because the consequences of the spread of ICTs is promotion of the significance of specific sorts of people. Their heightened significance and location is another of the themes of the new urbanism. It is clear that one of the results of trends in ICTs is that networks are being constructed around the world which impinge on past aspects of time and place. Because we may now conduct affairs in real time through ICT networks previous constraints such as time spent in travelling and moving objects around are reduced. By extension, geographical concerns are minimised by the development of ICT networks since with instantaneous communication across space it is feasible to organise effectively in a wide variety of locations. On the surface this presents the possibility of de-urbanisation since communications networks mean that it is no longer essential to have a physical presence in particular places to remain economically effective. A good deal of futuristic writing describes precisely this: Alvin Toffler s (1990) vision of the electronic cottage , for instance, posits the growth of telecommuting via ICTs so that we may combine high level wealth creation with day-to-day life in a rural idyll. However, it is in fact the case that the growth of information and communications networks can actually stimulate urbanization because dispersed activities must be co-ordinated. In effect, certain cities come to be the brains of the network society , the place where managers and professionals of all kinds congregate to mediate the constant flows of information which allow economic (and other) affairs to operate across time and space. That is, cities are the switching centres of the network society , the places where we find concentrated numbers of systems analysts, designers, accountants, lawyers, bankers, R&D professionals, actuaries, business managers, consultants, financiers, and the like. These are the centralized forces which organise and arrange the world-wide activities of the global economy. At the uppermost level, we may now conceive of world cities such as Los Angeles, New York, Tokyo and London which are at the heart of constant flows of business, financial, political and cultural information flows, and where are gathered a disproportionate number of managers and professionals. However, if these are the leading

switching centres of the new economy there are a host of followers who vie for privileged positions as important nodes of the information age. If one may draw an analogy with the great Victorian cities into and out of which the railways led, so today may we think of the great contemporary urban centres into and out of which flow today s information networks. Necessarily then we find that these attract a disproportionately large percentage of knowledge workers , those mentioned earlier who do not produce tangible things, but remain essential for economic vitality since they generate new schemes, invent new products, plan more productive ways of arranging affairs (which frequently involves transferring production from metropolitan locations to offshore places such as in the Far East), and communicate within and between positions. The new economy is deindustrialized, global, operates round-the-clock and is inherently unstable. It is deindustrialized for a raft of reasons: the ongoing automation of manufacture means there is a less obvious industrial presence, the export of production facilities to regions where labour is cheaper transfers industrial jobs from the metropolitan areas, the increase in value-added - and knowledge-based - activities such as design and marketing (the swoosh in Nike, the emblem on the tee-shirt, the persuasiveness of the promotional campaign) means that occupations here have become more important relative to the costs of raw material production, manufacture continues to decline in favour of the service sector. The new economy is global courtesy of sophisticated communications, especially those enabled by electronic technologies. It is round-the-clock (as it is known in business circles, 7/24) as is evident in the unceasing trade in foreign currencies and the continuous activities of financial institutions dealing in bonds and stocks, as also in the growing tendency for shops to be open all the time. And the new economy is unstable as is seen in the routine runs on shares, the susceptibility of nations and regions to investment and disinvestment in currencies (recently there have been the problems of the Euro, in 1997 the Tiger Economies, in the early and late 1990s Russia.). The new economy is, in the words of Manuel Castells, systemically volatile because the combination of ICTs (providing instantaneous and continuous communications, plus preprogrammed analyses), and the capabilities of finance speculators and investors, mean that companies and even countries can never be settled. There is unrelenting trade and business activity in the world today, and their conduct has accelerated remarkably. A consequence is that everything must become flexible , capable of adaptability and adjustment as a matter of routine. Everyone reading this will be familiar with the end of a job for life rhetoric, of the dramatic decline in occupations such as coal-mining and steel-making, of the uncertainty of tenure impinging on just about everyone today.

It follows that, these being features of the new economy in general, then they are more emphatically markers of the contemporary city today since this is the fulcrum of the new world we inhabit. We may witness this in the fact that cities are especially heavily biased towards service employment rather than manufacture. Where industry remains, it tends to be in the regions, whereas the city shifts increasingly towards white-collar service occupations such as banking, education and retailing. Cities are also markedly more international in orientation and outlook, in their personnel which are often disproportionately composed of overseas employees as well as in the characteristically cosmopolitan character of much of their workforce and, of course, in the plethora of communications technologies that are available. Cities also never close , services being available on demand in a place which never stops. Connectedly, cities are highly dynamic, the frenetic lifestyles of their inhabitants frequently being commented upon. It is not surprising in view of the foregoing that governments and city authorities feel the need to promote education if they are going to survive and prosper in this new economy which places such a high premium on knowledge. One may highlight several reasons for this emphasis. First, there is the need to produce a workforce with appropriate skills to find employment in the new economy , something which apparently necessitates high levels of knowledge attainment (Webster 2000a). Second, education, especially at university level, is needed to nurture the new ideas and innovative practices that are essential to maintaining competitive edge. This is a major reason for forging close business and higher education links in areas such as bio-technology, management training and computer science. Third, a first rate education system is a requisite of success in the new economy because it ought to engender the flexibility and adaptability that will equip people and institutions to survive uncertainty. The goal here is to ensure that the individual is equipped through education to adopt a lifelong learning approach to their employment, something which refuses the assumption that once one had been trained for a job then one performed that role throughout life. Against this, the idea is that education may enable people to learn how to learn , thereby to take responsibility for their own careers, something which will require regular re-skilling and re-education to match the volatility that is endemic in the new economy. The ambition to transform institutions into learning organisations is consonant with this ambition to make the individual responsible for his or her own lifelong learning. Just as people must be empowered to adapt to constant change through education, so too must organizations become capable through constant self-analysis to routinely re-invent themselves.
Education can legitimately be regarded as the foundation upon which is erected the weightless economy. It is largely from education that we get the new technologies, processes and innovations which advance wealth by increasing productivity and generating business. At least as important, it is from education that knowledge workers gain their most indispensable skills. Rarely narrowly vocational (particular skills outdate remarkably quickly in the world today), central capabilities are qualities such as analytical skills, communicative effectiveness, strategic thinking, team working and leadership, combined with a capacity to take responsibility for one s own career pattern (Reich 1991). It is from this conviction that comes Prime Minister Tony Blair s repeated litany: education, education, education. And it is this conviction that motivates policy makers in cities to take measures to reform education in their domains, actions which range from attempts to increase attainment in schools to ensuring the presence of at least one university within their boundaries. A concern of the new urbanism is for those who fail educationally and who in consequence can find no place in the knowledge economy , yet who remain living in close proximity to the affluent. The argument is made that positions in the economy for the unqualified and unskilled are diminishing as industrial occupations decline. There are therefore few routes into employment for the uneducated, who yet are frequently stuck in inner city locations because they lack the qualifications and capital to move. Accordingly, what such people may find by way of work is low status, poorly remunerated, and without security - the burger flipper positions, street cleaners, and restaurant employees. The new urbanism is especially concerned that this indicates the emergence of what Castells (1989) has called the dual city , one which is sharply divided between prosperous knowledge workers and those incapable of finding a place in the new economy (other than, ironically, in servicing the needs for baby-sitting, house cleaning, and similar such as servants of the knowledge workers who require assistance to find time to pursue their frenetically busy lives). The dual city is simultaneously globally connected and locally disconnected (Castells 1996, p.404), a place where a growing divide is observable between the highly educated and well paid who pursue their careers in globally-oriented businesses and those who are excluded from all such and who must suffer multiple deprivations. This is an important dimension of what some have called the digital divide and it is also in evidence in the close proximity, in London, of the City (where the average per head income is in excess of 45,000 per annum) and three boroughs (Tower Hamlets, Newham, and Hackney) which constitute England s most deprived districts as measured against income,

health, education, housing and access to survives and transport (Guardian, April 3, 2000, p.8). Accordingly, questions of social exclusion and inclusion loom large in considerations of the new economy , and nowhere does this happen more vividly than in major cities where associated issues of crime and malaise - manifest in virulent drug problems, high levels of lawlessness, and even in riots - arise. If it is the case that cities are crucial to the new economy , and if it is in cities where information professionals and institutions congregate, then it follows that those cities which can best prepare themselves for such a role and for such agencies will prosper the most. After all, if a city can situate itself to become an information hub then it will be in a position to attract large amounts of investment, and if it has first rate and innovative universities, farsighted and affluent banks and the like, then it will encourage the presence of large numbers of well-rewarded professionals who will at once increase living standards in the city and at the same time stimulate further growth of the new economy. Such is the virtuous circle sought by all major city policy-makers today. Accordingly, ambitious cities endeavour to sell themselves to knowledge professionals and corporate and government investors. And what these cities offer is no longer proximity to natural resources, a fine port or a tradition of engineering (though an international airport is a must), but rather their symbolic capital (Zukin 1995, p.24). That is, their culture , their style , their safety , their amenities , their schools and colleges, their quality of life. In the new economy educated labour and capital are much more mobile than hitherto, so the thrusting city must respond to this agility by offering a range of attractions. These might be its air quality, its theatres, certainly its education system, its transport services, as well as its skyline. What is evident here is that the city s image, rather than straight-forwardly reflecting local activities (think here, for instance, of traditional city images which so often took their imagery from their industrial associations - Sunderland with shipyards and coal-mining, Sheffield with steelmaking, Tampere with its textile factories), is open to packaging and presentation and even recreation. With the symbols associated with the city being nowadays a part of its appeal to investors, there is opportunity to work on this imagery with prospects of achieving substantive results. It seems that place image is now a crucial part of the selling of the city, and that this is necessarily
something which concentrates the minds of those who would have their own cities prosper. An index of this is the emergence of quality of life measures of cities like that conducted in 1999 by one of the world s largest human resources consultancies, William M.Mercer (cf. European Union 2000). This survey judged cities according to ten criteria, ranging across the political, economic and social environment, health care and education provision, to recreation and transport infrastructure. New York was used a the base city with a score of 100, which put it 50th in the overall rankings. The top world s cities on this scale were Vancouver, Zurich, Vienna and Bern, followed by Sydney, Geneva, Auckland, Copenhagen, Helsinki and Amsterdam, with Toronto coming 20th and London 34th. Birmingham, the subject of this essay, was 60th, a position which pleased Birmingham City Council leader Albert Bore who delighted in being compared so well with modern vibrant cities like Chicago, New York, Barcelona and Madrid (Guardian, January 13, 2000). I shall turn directly to Birmingham in a moment, but my point here is simply to observe the rise of such ratings of cities, and how they underline the need for cities today to present themselves as exciting, dynamic, creative, go-getting, aesthetically appealing and convivial places in which to live and invest. Once upon a time a city rose because of its defensive position, or its location at the head of a river, or because it was a centre for the marketing of agricultural products, and imagery stemmed from the rooted functions. Nowadays, however, with labour and capital enjoying a mobility of unprecedented degree, the city must display itself for human and corporate investment across the globe. In this, the city s cultures play a vital part.

Part Two: Birmingham Birmingham, the UK s second city with a population of about 1 million for most of the 20th century (but now in slow decline), has experienced major difficulties in making the transition to the new economy. These problems have not prevented officials as well as civic and business leaders from trying hard, and with some success, to find accord with the coming knowledge society. This is, however, a daunting task. Advocates of change in Birmingham face at the outset the formidable obstacle of the city having a image of its being ugly, dull and lacking in culture. Suggestive of this is the reply of the teacher when asked to exemplify contradiction: he replied, Beautiful Birmingham. This impoverished vision of Birmingham has a long history. For instance, J.B.Priestley, in his well-known travelogue English Journey (1934) visited Birmingham and complained of the extraordinary ugliness of most of the people there (who were) really unpleasing to look at closely (p.105). It was not only the people who so disturbed Priestley: the place itself made much the same impression upon him. He saw nothing, not one single tiny thing, that could possibly raise a man s spirits. It was so many miles of ugliness, squalor, and the wrong kind of vulgarity, the decayed anaemic kind (p.86). He went on to observe how he loathed the whole long array of shops, with their nasty bits of meat., their shoddy cheap furniture, their shoddy clothes, their fly-blown pastry, their coupons and sales and lies and dreariness and ugliness (p.86). The socio-linguist Howard Giles reinforced this point in his studies of the status position of regional accents. He found that, of all the British accents, the lowest ranked of all - beneath Irish, Northerners and even Cockneys - was the Brummie. It was regarded as boring, flat, common and inarticulate just as were those who spoke it. Giles also demonstrated that these judgements had nothing to do with any intrinsic qualities of the Birmingham accent. Tests on the reception of the accent from French Canadians or Americans (i.e. those ignorant of its low status) revealed a very different ranking (Giles and Powesland 1975). In truth the reason for the Birmingham accent being of low standing is because it evokes images of industry , factories and the working class , characteristics for which the city has long been well known. It is a social judgement that determines the ugliness or attractiveness of an accent, just as it is social judgements which deem an accent to be intelligent or friendly. Anyone doubting this might wish to ponder why the Northern Irish accent is currently so evocative of belligerence and bullying. Nonetheless, this does not take away the fact that, when trying to sell Birmingham to potential investors, an image of dullness and lack of culture is created as soon as anyone from the city opens his or her mouth.

One may better understand Birmingham s difficulties in meeting the challenges of the new economy by learning more of its central role in the Industrial Revolution and of its long involvement in manufacture, especially in engineering. From the early decades of the 18th century Birmingham was renowned both for the variety of its industrial enterprises (it has long been described as the city of 1000 trades ) and for its metal-finishing activities (ranging from guns, button-making, to light engineering). Alexis de Tocqueville, for instance, visited the city in the mid-19th century and referred to Birmingham as an immense workshop, a huge forge, a vast shop (quoted in Briggs 1963, p.63). This long-term industrial presence grew throughout the 19th century and, combined with a strong tradition of non-conformism, dissent and suspicion of London s political dominance, led to the late 19th century era of civic gospel. Under the leadership of Joseph Chamberlain, the city underwent a period of radical reconstruction, resulting in much slum clearance and the building of fine Victorian streets, an impressive Council House, and municipal control over key utilities such as water and gas. Birmingham s own university was opened close to the city centre at Edgbaston in 1900, built on a grand scale with a towering clock tower at its centre modelled on the architecture of Sienna, and dedicated to combining scholarship with practical concerns. Birmingham s engineering industries grew to make the city the centre for British motor manufacture. For instance, the origins of today s Rover Group lie in Herbert Austin s Longbridge factory which was established in 1905 and produced 150 Austin Seven cars per week from a workforce of 2000 by 1914 (Briggs 1952, p.45). Relatedly, Dunlop tyres opened a factory in Birmingham in 1910. All such contributed to the perception that Birmingham was little but industry and perforce grim , an image reinforced by the spread of conurbations from Birmingham to the west, to form what became known as the Black Country because of the continuous belching smoke from its manufacturies, blast furnaces and collieries. Birmingham s diversity of manufacture helped it through the 1930s Slump (Briggs 1952, p.286f), but it is clear, with hindsight, that having almost two-thirds of its workforce employed in manufacture at the start of the 1960s (and this was twice the national average even then) was soon to become a weakness. The booming car economy , of which Birmingham was the British centre, meant that unemployment was negligible throughout the 1960s. Indeed, the vigour of the employment situation in Birmingham had long stimulated migration to the city. Most of this was from the neighbouring counties such as Oxfordshire where declining agricultural opportunities were more than matched by higher wages in the city s factories. From further afield the vast majority of migrants were - and had been so for generations - from Ireland, and the Irish continued to account for over half of all migrants

into the 1960s. However, by the mid-1960s there were large migrations from the Commonwealth, such that by 1966 over 40% of a total of almost 120,000 migrants came from the West Indies, Pakistan and India (Sutcliffe and Smith 1974, p.207). This pattern of migration into central areas of Birmingham from without, combined with a developing trend towards established employees - notably the better off and better qualified - moving to the suburbs and commuting into Birmingham for work, was to make an important mark on the character of the city from the 1970s onwards. When the crises of the 1970s arrived, triggered by dramatic oil price rises late in 1973, Birmingham was especially vulnerable because of its relative over-dependence on manufacture. Employment in manufacture in Birmingham went from 64% of the workforce in 1951, to 44% in 1978, 23% in 1997, to 19% in 2000. Behind these statistics lies a huge loss of jobs, in engineering especially. During the 1980s unemployment in the city leapt to more than 20% as Birmingham was hit by the familiar problems of Fordism. Global competition, increased productivity, new technologies, job transfer and the rest set a trend towards de-industrialisation. It continues to this day. The Longbridge Rover works currently employ 8500 (with estimates that up to 50,000 more jobs being dependent on the motor manufacturing sector[Independent, 29 April 2000]), yet the crises of March and April 2000 signal that these are far from assured. In those months the then owner BMW moved to close or sell the Rover plant. A last minute deal with the Phoenix Consortium (local managers and American venture capital) saved the plant. However, as Graeme Maxton, an automobile consultant said of the deal, this just prolongs the agony , since there is global overproduction, more competitive corporations, cheaper manufacturing locations, and the ongoing automation of vehicle manufacture (quoted in Guardian, May 10, 2000). The demise of Birmingham s motor manufacturing industry is but the most visible side of a continuing and now long-term decline in industrial jobs. Confronted with this bleak prognosis, and saddled with an image that made Birmingham exceedingly unappealing to outsiders, just what could be done? Re-Invention During the 1980s, amidst an industrial depression and consequent unemployment rate not seen since the worst of the 1930s, there was a deep sense of foreboding in Birmingham. What emerged was a series of interventions and policies of what Professor Willie Paterson has termed top-down vitality (quoted in Economist, August 8, 1998, p.23). That is, local business leaders, councillors and city council officials designed and developed programmes to revitalise Birmingham. For those who approve, these are seen as imaginative and foresighted. More critical commentators refer to these as a civic boosterism which has used public funds (from the locality as well as from European Regional

Development sources) to shore up private capital (Loftman and Nevin 1996). However they are described, these endeavours bear a remarkably close relation to the analysis and advocacy of the new urbanism. For this reason if no other they merit exemplification. Perhaps most obviously, from the mid-1980s but more radically so since the 1990s, Birmingham has undertaken a sustained programme of urban re-invention and re-presentation of itself which has foregrounded the city s appeal to investors and professional workers by emphasizing its (post)modernity (its dynamism, its fast-footedness, its appetite for change), its cosmopolitanism and connectedness (Birmingham routinely proclaims itself a European City and much else besides, of which more below [McGuiness 1996/7]), its creativity and vision, its rich and varied cultures. This reinvention involves considerable elements of place presentation and PR packaging, of course, but it is much more than the merely symbolic , entailing marked material changes, most obviously in the built environment. It has been an initiative which takes some of its ideas from the regeneration of North American cities, though one needs to be suspicious of suggestions that it is a straight-forward emulation (the car city , dominated by roads, which was Birmigham in the 1960s seems more USderived than anything presently being developed). The skyline of Birmingham, currently dotted with enormous cranes which testify to an intense level of reconstruction and already with an extensive range of high rise towers, may be mistaken for an American cityscape. Indeed, the Brindleyplace development just off Birmingham s city centre, where there is a mixed use site including offices, expensive private apartments and leisure facilities close to all central amenities, alongside fully landscaped and renovated canals, takes much of its inspiration from Baltimore s Harborplace scheme. Aspects of Birmingham s reconstruction include: The cleaning up and redevelopment of the old canal system. In the early 18th century it was the canal network which had given Birmingham a head start in the Industrial Revolution, but this had fallen into disrepair and disuse over the years, and - while it intersected the city - was characteristically polluted, bordered by disused and vandalised factories and warehouses. The modernisiation of the canals, done with an eye for protecting wildlife, and resulting in good pathways, and with cafes and pubs along the way, means that now one may walk into the heart of the city from the outskirts without encountering road traffic. It has also meant that the canal boat leisure trade has been able to blossom. Such a development led the Frankfurter Allgemeine Zeitung to write that Birmingham has more canals than Venice, and more trees than Paris. Furthermore, as just mentioned, the canal redevelopment is an integral component of the 300

back in time. As these groups have settled, and as second and third generations have grown up and begun to disperse through the city, so have developed marked cultural presences alongside hybrid cultural forms. Inevitably these have an influence as the non-white ethnic groups have come to figure more significantly in Birmingham. For instance, by the 1991 census 22% of all Birmingham s residents were non-white, and fully 35% of the under tens came from non-white minorities. The prospect is that, over the next decade or two, demographic trends will lead to Birmingham being the first majorityminority city in the UK (Slater 1996). It is important to note that Birmingham remains a predominantly white city, with 78% being so designated (though this disguises important cultural differences between minorities such as Poles, Irish and Slavs in the city). Nevertheless, non-white minorities are increasing markedly, overwhelmingly because of demographic factors, so that for instance amongst those aged 18-24 over one in four are people of colour. It is this diverse non-white population that has begun to be projected as evidence in Birmingham of an especially appealing and interesting cosmopolitanism. Ethnic minorities were not always so well perceived. It may be remembered that it was in Birmingham that Enoch Powell delivered his famous rivers of blood speech in 1968, where - as Member of Parliament for nearby Wolverhampton - he foresaw inter-ethnic conflict spilling over into civil unrest if levels of migration were maintained. Against this, it seems now that, largely through what one might call the bottom up vitality of migrants and their cultures, leaders in Birmingham have felt able to seize upon cultural diversity as a bonus, for its exotic appeal, for its cuisine, for its multiplicities of ways of life in one location. It is noteworthy, for instance, that Chinatown is to be the cornerstone of Birmingham s Entertainment Zone. Again, there is the recently opened Star City leisure site, built on a the site of a redundant power station near the Spaghetti Junction (that mass of motorway cross-overs that captures vividly the outdated 1970s for many people). Star City is the UK s biggest cinema complex, with 30 screens, seating for 6000 people, and car parking for 2750. Soon this will also have a gym, a bowling complex and many restaurants. However, what is also striking about it is the dedicated 6 screens for Bollywood movies, evidence of the growing significance of the non-white presence in the city (Young 2000). Another instance of Birmingham s cosmopolitanism is the success in the 1990s of Bangra music, a fusion of Asian (especially Punjabi), western and other music such as reggae. While this music reaches far beyond the city, researchers have observed that Birmingham is the cultural capital for Bhangra (Henry et al, n.d.). The same scholars have identified the transnational communities that exist in Birmingham as a result of migration have a significant effect on business success, for example in the establishment of Chinese supermarket suppliers, Islamic banks, and export/import food suppliers dealing in Indian foods. Such instances at once suggest the importance of ethnic minority cultures in

communications technologies, its style, its cosmopolitanism, its cultures, seems to be, well, our story. We are indisputably part of the knowledge lite, and we tell our own favoured tale as regards the city of the future. But even the uppermost estimates of the city s workforce do not exceed one-third being knowledge workers, so how is it that this minority s position comes to be so hegemonic in visions of the future city and in the design of policies for urban change? Ian Taylor (1996) and his colleagues, in what I believe is a remarkable book, remind us that the city is an extraordinarily differentiated place as they document the mental maps of the city expressed by the old, the workless, the young, the migrant, the female, the ethnic minority and so on. My question here is bluntly, whose city are commentators talking about (cf. Parker and Long 2000)? With regard to Birmingham this is especially acute since so many of the most desirable positions sought by the planners, developers and decision-makers have been going, not to people who live in the city, but to those who commute to the city to work and then leave for the suburbs at close of day, though they leave their mark in the splendid new offices, wine bars and elegant designer shops. In 1961 less than one in five jobs in Birmingham was taken by a commuter, yet by 1991 it was more than one in three, and the trend continues (BEIC 2000, p.10). A close study of one of the inner city districts, Nechells (one of England s most deprived areas, and currently suffering from unemployment of around 20%), highlights consequences of this trend. Nechells is the location of some large knowledge business employers (e.g. Aston University, National Westminster Mortgage service, and the Birmingham Post and Mail, each with in excess of 800 employees). However, four out of ten positions in and around Nechells are filled by someone from outside who possesses the necessary qualifications and commutes in and out of the ward. Conversely, Nechells residents for the most part work where they live. The upshot is that, while there are many vacancies in the area for positions in such as banking and finance, locals are not equipped to take these on, being condemned to local jobs at the bottom end of the labour market (BEIC 2000b), while the prize positions go to outsiders. Whose city are we talking about here? I would like to end by recalling some observations of the late Christopher Lasch. In his posthumously published book, The Revolt of the Elites (1995), Lasch makes his main target of opprobrium the highlevel professionals whom Robert Reich (1991) - shortly before he became President Clinton s Secretary for Labour in 1992 - had approvingly described as symbolic analysts. These are people who produce little substantive, but they ease the wheels of the global economy, monopolise ideas and media outlets, and set the styles for the current era. They are highly individualistic, and impressively able to adapt to face new challenges, self-starters armed with networking skills of a high order. They are, of course, those knowledge workers whom the new urbanists so much admire.

Christopher Lasch does not share this admiration. He observes the cosmopolitanism of symbolic analysts as a lack of rootedness in place, their tolerant attitudes and enthusiasm for diversity as an absence of any moral values whatsoever, their openness to change evidence of a lack of substance. They are also affluent and privileged, able, should they decide to move into the city centre itself, to occupy the refurbished or newly constructed penthouse apartments and gated communities which ensure they are not disturbed by their neighbours. It has become voguish to write of the city today in admiring tones as a prime site of change, challenge and the experience of difference. This is something which taps, of course, the tradition of Baudelaire, Simmel and Benjamin. In this genre coping with the disruptions of the city is taken as a measure of one s maturity, doubts about it dismissed as a childlike desire to find solace in a mythic order which has never existed (Sennett 1996). A great many intellectuals, as a group overwhelmingly metropolitan, embrace this heroic vision of the city. It is entirely appropriate that such people, in the words of David Harvey (1989), were to the fore in instituting the turn to postmodernist styles (p.272). It is especially useful here to recall something from Taylor et al Tale of Two Cities (1996). In this s study of the English northern cities Manchester and Sheffield the researchers are at pains to ascertain the experiences and perceptions of the full range of their inhabitants. They neither restrict themselves to the professionals and semi-professional information workers, nor to the regeneration strategies of these deindustrialising cities that are desperately trying to rejuvenate themselves by promoting their image (Manchester has its football team and its music scene, Sheffield its sports stadium and Meadowhall shopping mall). One sizeable group of the population Taylor and his colleagues find in these cities is the elderly. And they testify that one of the most powerful refrains throughout our discussions with the elderly was a kind of class and regional nostalgia for the lost world of mass manufacturing and its associated set of social institutions and political and civic assumptions. Most particularly lamented was the sense of community that was universally asserted to have been characteristic of that particular historical experience (p.247). I would say more about this sense of community that these elderly felt was lost in the contemporary city. One response is to dismiss this as the nostalgia of the passing generation, one which mythologises the past (wasn t life grim up North in the old days?), and which will disappear along with the old in due course. Another retort is that community is a deeply exclusive, even authoritarian, notion, people forced to fit in with cramping and limited beliefs and ways of life. It is easy to conjure here the counterpart of working class community which was warm and caring, just so long as you were

homophobic, white, patriarchal and accepting of the mores of the group. Against this may be set the liberatory style of the modern city, where encounters between differences abound, and where we may establish freely chosen relationships on a basis of choice. One appreciates these replies, and one may concede the value of encountering the new. And yet I still feel that the intense social interaction which is the accompaniment of city life is not enough. A yearning for belonging, for being part of a group whose values one shares and whose habits are one s own, where one may feel comfortable and cared for, where one may achieve a full sense of identity, seems to me still to have resonance. Ironically enough, some urban scholars even see communal bonds as helpful to economic regeneration in Birmingham, citing the transnational networks maintained amongst Chinese, Muslim and even Cypriot groups on the basis of familial, religious and cultural ties, as crucial to the development of business relationships (Henry et al, nd). A good deal of recent enthusiasm for the view that social capital is vital for economic regeneration draws on much the same sort of reasoning (Fukuyama 1995; Putnam 2000). lrich Beck observes that nowadays we are condemned to individualization. It is this condition which is most evident in the contemporary city and, so long as one has the material wherewithal, it can lead to an apparently pleasurable existence. But, when counterposed to the loss of community to which Taylor s respondents testify, it raises the profound question: can the good life be achieved so long as one lives as an isolate? Some might say that, so long as we have the social organisation to meet our material needs, then the individualistic actor is fine. With Emile Durkheim and a long line of fellow communitarians (Etzioni 1993), I at least cannot accept that this is so, though such a position does not mean one is insensitive to the dangers of community - when it transmutes into tribalism - as stifling for some and exclusive of still more. What is does mean, however, is that I feel we need to establish though not set in stone - some balance between self and society which recognises that society means more than sociality, that it implies also some sense of belonging. Another reason this needs to be addressed is the very diversity of cultures in the contemporary city. There is undeniably a much richer mix of cultures in our cities today, and they can stimulate desirable changes, but these cultures are not infinite. Indeed, it is remarkable to me that many who would urge us to embrace the newness of the city, and with it the diversity of cultures, seem blind to the fact that cultures are inherently limiting. There are many cultures, but each is, in some (and doubtless is blurred) ways bounded. That is, after all, what makes them identifiable cultures, and that is precisely where those who belong find their value.

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