CONTROLLED HARDCOPY Massena West Potline Primary Emission Control System Startup, Shutdown, and Malfunction (SSM) Plan

Revision/Reviewed Date: 9/2/09

Any printed version of this file is UNCONTROLLED, and must be verified against the controlled copy at: http://intranet.mas.alcoa.com/emsol ution/areas/West

- Services & Electrode/Services West.htm before use, unless the words “CONTROLLED HARDCOPY” is printed on the top of the document. Page: 1 of 8 

# National Emission Standards for Hazardous Air Pollutants for Primary Aluminum Reduction Plants



# ALCOA

Massena Operations

POTLINE PRIMARY EMISSION CONTROL SYSTEM

Start U p, Shut Down, and Malfunction Plan

Prepared by:

Alcoa

Park Avenue East

Mas sena NY 13662

2009 Sep 02

– Appendix A editing

1999 Oct 06

- revised CMS maintenance 1999 Sep 23

– added CMS maintenance 1999 April 22

- originalCONTROLLED HARDCOPY Massena West Potline Primary Emission Control System Startup, Shutdown, and Malfunction (SSM) Plan

Revision/Reviewed Date: 9/2/09

Any printed version of this file is UNCONTROLLED, and must be verified against the controlled copy at: http://intranet.mas.alcoa.com/emsol ution/areas/West

- Services & Electrode/Services West.htm before use, unless the words “CONTROLLED HARDCOPY” is printed on the top of the document. Page: 2 of 8 

## T ABLE OF 

## C ONTENTS

PAGE

TABLE OF CONTENTS i

1.0 INTRODUCTION 1

2.0 START UP PLAN 1

3.0 SHUT DOWN PLAN 1

4.0 CORRECTIVE ACTI ON PLAN 2

LOW AIR FLOW

LOW ALUMINA FLOW

MAINTENANCE OF CONTI NUOUS MONTORING SYST EM

5.0 MALFUNCTION PLA N 3

LOSS OF POTLINE POWE R FOR AN EXTENDED PE RIOD

CATASTROPHIC FAILURE OF F UME CONTROL EQUIPMEN T

6

. 0 VISIBLE EMISSION PLA N 4

FLOW CHART APPENDIX A



### 1.0 INTRODUCTION

This Start up, Shut down, Malfunction Plan meets the requirements of the Primary Aluminum NESHAP. This plan contains procedures to be used during pe riods of start up, shut down, and malfunction as well as procedures for corrective action. This plan will be made available to the permitting authority upon request.



### 2.0 START UP PLAN

A start

- up or re

- start is defined as the process of re

- energ izing an idled section(s) of aluminum reduction cells and that is serviced by an idled A

- 398 fume control device(s). The start up or restart begins when the first idled reduction cell has liquid bath added to it. The start

- up or re

- start

concludes when the last of the number of pots scheduled for start

- up or re

- start has been energized.

The following plan is to be followed for the start

- up or re

- start of the portion of the potline served by the emission control device. If this plan is followed, the semi annual report will note that it was followed. If this plan was not followed, the event is to be reported with 2 days, a notification letter posted within 7 days, and revisions to this plan submitted within 45 days. Revisions to this plan

must be retained f or 5 years.CONTROLLED HARDCOPY Massena West Potline Primary Emission Control System Startup, Shutdown, and Malfunction (SSM) Plan

Revision/Reviewed Date: 9/2/09

Any printed version of this file is UNCONTROLLED, and must be verified against the controlled copy at: http://intranet.mas.alcoa.com/emsol ution/areas/West

- Services & Electrode/Services West.htm before use, unless the words “CONTROLLED HARDCOPY” is printed on the top of the document. Page: 3 of 8 If compliance has not been determined, determination will begin following 180 days after the completion of the start

- up or re

- start. The appropriate limits for the parameters will be determined following 180 days after the completion of the startup or restart.

1

. The Operator is to assure that prior to adding liquid bath to the first pot, a fluidized bed of

alumina has to be established in an A

- 398 compartment. The Operator is responsible for starting alumina flow and air flow to this first com partment.

2

. The Operator is to target the ratio of pots operating to A

- 398 compartments on line to below 12. If the ratio exceeds 12, then an additional A

- 398 compartment is to be put on line. (This ratio of a maximum of 12 pots for each A

- 398 compartment applies only during start

- up and

re

- start conditions to assure a consistently high minimum process air flow rate from all pots

that have been started or re

- started.)

3

. The Operator is responsible for logging the Start

- Up on the SSMlog.

4

. Records of the start

- up are to retained for five (5) years.



### 3.0 SHUT DOWN PLAN

A shut

- down is defined as the process of having the liquid contents of bath and aluminum solidify for all of the aluminum reduction cells that are serviced by a common A

- 398 Fume Cont rol Device. The shutdown begins when electrical power has been intentionally discontinued for the purpose of a shutdown or 24 hours after a sustained unintentional loss of electric power. The shut

- down concludes 48 hours after service of electrical power h as been discontinued.

The following plan is to be followed for the shut

- down of the portion of the potline served by the emission control device. If this plan is followed, the semi annual report will note that it was followed. If this plan was not followe d, the event is to be reported with 2 days, a notification letter posted within 7 days, and revisions to this plan submitted within 45 days. Revisions to this plan must be retained for 5 years.

1

. The liquid contents of the reduction cells will be frozen and gaseous emissions will cease after 48 hours without electrical power.

2

. The Operator may shut down A

- 398 compartments any time after the 48 hour period.

3

. The Operator is responsible for logging the Shut Down on the SSMlog.

4

. Records of the shut down are to b e retained for five (5) years.



### 4.0 CORRECTIVE ACTION PLAN

4.1 Low Air Flow

Low air flow is defined as air flow lower than the parametric limit. It is determined by comparison of the average ACFM for each A

- 398 Fume Control Device over the potroo m cycle to the limit for compliance. Failure of the parameter to meet the limit for compliance is an exceedance. The following Corrective Action Plan must be initiated within one hour of first becoming aware of the

exceedance. The failure to initiate this Corrective Action plan within an hour will result in a

violation. The 7 th exceedance on an A

- 398 Fume Control Device in the semi annual reporting period will result in a violation. Both exceedances and violations must be reported on the semi annual report

.

Examples of low air flow conditions include, but are not limited to, unplanned A

- 398 compartment outages that result in simultaneous multiple compartment downtime within the control device.CONTROLLED HARDCOPY Massena West Potline Primary Emission Control System Startup, Shutdown, and Malfunction (SSM) Plan

Revision/Reviewed Date: 9/2/09

Any printed version of this file is UNCONTROLLED, and must be verified against the controlled copy at: http://intranet.mas.alcoa.com/emsol ution/areas/West

- Services & Electrode/Services West.htm before use, unless the words “CONTROLLED HARDCOPY” is printed on the top of the document. Page: 4 of 8 1

. The Operator is to log the time that he/she first became awa re of the exceedance and the time at which he/she initiated the corrective action plan.

2

. The Operator is to confirm the system status, noting which A

- 398 component(s) are either off line or otherwise impaired.

3

. The Operator is to notify appropriate mainten ance personnel or restart the component(s).

4

. Personnel responding are to make repair(s), equipment replacement(s), or process change(s) to remedy the situation in a safe, efficient, and timely manner.

5

. The Operator is responsible for logging the exceedance on the SSMlog. This will include logging the time, date, duration, and cause of the exceedance, any actions taken beyond the scope of this plan, and initials or signature.

6

. Maintenance personnel are responsible for making appropriate entries into maintenanc e logs.

7

. Records of the exceedance are to be retained for five (5) years.

4.2 Low Alumina Flow

Low alumina flow is defined as an alumina flow rate lower than the parametric limit. It is determined by comparison of the average alumina flow per hour for ea ch A

- 398 Fume Control Device over the potroom cycle to the limit for compliance. Failure of the parameter to meet the limit for compliance is an exceedance. The following Corrective Action Plan must be initiated within one hour of first becoming aware of t he exceedance. The failure to initiate this Corrective Action plan within an hour will result in a violation. The 7 th exceedance on an A

- 398 Fume Control Device in the semi annual reporting period will result in a violation. Both exceedances and

violation s must be reported on the semi annual report.

Examples of low alumina flow conditions include, but are not limited to; loss of electrical power, unexpected failure of the feed air slide or rotary vane feeder(s), and unplanned A

- 398 compartment outages tha t result in simultaneous multiple compartment downtime within the

control device.

1

. The Operator is to log the time that he/she first became aware of the exceedance and the time at which he/she initiated the corrective action plan.

2

. The Operator is to conf irm the system status, noting which A

- 398 component(s) are either off line or otherwise impaired.

3

. The Operator is to notify appropriate maintenance personnel or restart the component(s).

4

. Personnel responding are to make repair(s), equipment replacement(s ), or process change(s) to remedy the situation in a safe, efficient, and timely manner.

5

. The Operator is responsible for logging the exceedance on the SSMlog. This will include logging the time, date, duration, and cause of the exceedance, any actions take n beyond the scope of this plan, and initials or signature.

6

. Maintenance personnel are responsible for making appropriate entries into any maintenance logs.

7

. Records of the exceedance are to be retained for five (5) years.

4.3 Maintenance of Continuous Mo nitoring System

The following parts of the Continuous Monitoring System are identified as necessary to correct routine or predictable malfunctions. A398 Rotary Vane Feeder Zero Speed Switch A398 Fan Amp Meter A398 Duct Temp Transmitter A398 Duct Temp RTDCONTROLLED HARDCOPY Massena West Potline Primary Emission Control System Startup, Shutdown, and Malfunction (SSM) Plan

Revision/Reviewed Date: 9/2/09

Any printed version of this file is UNCONTROLLED, and must be verified against the controlled copy at: http://intranet.mas.alcoa.com/emsol ution/areas/West

- Services & Electrode/Services West.htm before use, unless the words “CONTROLLED HARDCOPY” is printed on the top of the document. Page: 5 of 8 Predictable malfunctions would also include power interruptions, PLC/PC malfunctions, and PLC

PC communication problems. Malfunctions as noted in catastrophic failure of the fume control equipment (see section 5.2) may also result in loss of the continu ous monitoring system.

The following plan is to be followed for repair of the Continuous Monitoring System. If this plan is followed, the semi annual report will note that it was followed. If this plan was not followed, the event is to be reported with 2 days, a notification letter posted within 7 days, and revisions to this plan submitted within 45 days. Revisions to this plan must be retained for 5 years. The Operator is to log the time that he/she first became aware of the problem with the continuous mo nitoring system and the time at which he/she initiated the corrective action plan.

1

. The Operator is to confirm the system status, noting which component(s) are either off line or otherwise impaired.

2

. The Operator is to notify appropriate maintenance pers onnel or restart the component(s).

3

. Personnel responding are to make repair(s), equipment replacement(s), or process change(s) to remedy the situation in a safe, efficient, and timely manner. Malfunctions with other components than what are listed above o r other events which affect the CMS and are not addressed by this plan must be communicated to the New York State Department of Environmental Conservation (NYSDEC) within 24 hours after commencing actions inconsistent with the plan.

4

. The Operator is respo nsible for logging the repair on the SSMlog. This will include logging the time, date, duration, and cause of the problem any actions taken beyond the scope of this plan, and initials or signature.

5

. Maintenance personnel are responsible for making appropri ate entries into any maintenance logs. Records of the repa ir of the continuous monitoring system are to be retained for five (5) years.



### 5.0 MALFUNCTION PLAN

5.1 Loss of Potline Power for an extended period

A malfunction may cause the entire potline t o be de energized for an extended period of time. In
this situation, the A

- 398 Fume Control Devices may be shut down to conserve heat in the smelting cells. The following plan is to be followed for the idling of the A398 Fume Control Devices in this

situat ion. If this plan is followed, the semi annual report will note that it was followed. If this plan was not followed, the event is to be reported with 2 days, a notification letter posted within 7 days. If revisions to this plan are necessary, they must be submitted within 45 days of the event. Revisions to this plan must be retained for 5 years.

1

. Following the request to idle the A398 Fume control devices, the Operator will stop the fans

and alumina flow for the A

- 398 compartments.

2

. The Operator is respon sible to begin start up of A

- 398 compartments in a safe, efficient, and timely manner following the re

- energization of the potline.



### 3

. Normal operation is to be attained as soon as possible following the start up of the A

- 398

compartments



### . 4

. The Operator is re sponsible for logging the malfunction on the SSMlog. This will include logging the time, date, duration, and cause of the malfunction, any actions taken beyond the scope of this plan, and initials or signature.



### 5

. Records of the malfunction are to be retaine d for five (5) years.

5.2 Catastrophic Failure of Fume Control EquipmentCONTROLLED HARDCOPY Massena West Potline Primary Emission Control System Startup, Shutdown, and Malfunction (SSM) Plan

Revision/Reviewed Date: 9/2/09

Any printed version of this file is UNCONTROLLED, and must be verified against the controlled copy at: http://intranet.mas.alcoa.com/emsol ution/areas/West

- Services & Electrode/Services West.htm before use, unless the words “CONTROLLED HARDCOPY” is printed on the top of the document. Page: 6 of 8 A catastrophic failure of the fume control equipment is considered a malfunction. The following plan is to be followed for a catastrophic failure of the fume control device. If this plan is followed, the semi annual report will note that it was followed. If this plan was not followed, the event is to be reported with 2 days, a notification letter posted within 7 days. If revisions to this plan are necessary, they must be submitte d within 45 days of the event. Revisions to this plan must be retained for 5 years.

Examples of catastrophic failure include, but are not limited to; collapse of an A

- 398 unit of inlet duct, a direct lightning strike, a loss of electrical power, an earthq uake, a tornado, or a system fire

that results in uncontrolled emissions.

1

. As soon as the situation has become stable and hazards have been cleared, the Operator is to confirm the system status, noting which A

- 398 compartments are either off line or

other wise impaired. The operator is to log the time that the condition was first noticed or reported and also log the time at which he/she first began to respond.

2

. The Operator is to notify appropriate maintenance, engineering and support personnel.

3

. Personnel r esponding are to make repair(s), equipment replacement(s), or process change(s) to remedy the situation in a safe, efficient, and timely manner.

4

. The Operator is responsible for logging the malfunction on the SSMlog. This will include logging the time, date , duration, and cause of the malfunction, any actions taken beyond the scope of this plan, and initials or signature.

5

. Maintenance personnel are responsible for making appropriate entries into any maintenance logs.

6

. Records of the malfunction are to be reta ined for five (5) years.



### 6.0 VISIBLE EMISSION PLAN

Visible emissions are defined as stack dusting which indicates filter bag problems. The following Visible Emission Plan must begin within one hour of noticing visible emissions. The failure to

initi ate this plan within an hour will result in a violation. Violations must be reported on the semi annual report.

1

. The Operator is to report the dusting stack(s) from any source including, but not limited to the daily visual checks made by the Operator.

2

. The Operator is to log the time that he/she first noticed or was notified of the condition and also log the time which he/she initiated this plan.

3

. The Operator is to shut down the appropriate compartment to make repairs.

4

. Personnel responding are to make rep air(s), to remedy the situation in a safe, efficient, and timely manner.

5

. The Operator is responsible for logging the corrective action on the SSMlog. This will include logging the time, date, duration, any actions taken beyond the scope of this plan, and i nitials or signature.

6

. Maintenance personnel are responsible for making appropriate entries into any maintenance logs.

7

. Records of the visible emissions are to be retained for five (5) yea rsCONTROLLED HARDCOPY Massena West Potline Primary Emission Control System Startup, Shutdown, and Malfunction (SSM) Plan

Revision/Reviewed Date: 9/2/09

Any printed version of this file is UNCONTROLLED, and must be verified against the controlled copy at: http://intranet.mas.alcoa.com/emsol ution/areas/West

- Services & Electrode/Services West.htm before use, unless the words “CONTROLLED HARDCOPY” is printed on the top of the document. Page: 7 of 8 

### APPENDIX A

Flowchart

ξ 63.850 Notification, reporting, and record keeping requirements. NO Violation

Parametrics Over

Limit?
(Exceedance) SOP’s Corrective

Action within

One Hour YES Y Violation NO

6 Month Report YES

7 th within

six Months? Violation

YES

Test

Results Over

Limit? Violation YES

Startup, Shutdown,

Malfunction and

Corrective Action

Plans Followed

Plan? Re port Plan

Followed YES

Report within
two days.

Letter within
7 days

Revise & submit plan in 45 days NO Recordkeeping Visible

Emissions Start corrective

Action within

one hour YES DocumentCONTROLLED HARDCOPY Massena West Potline Primary Emission Control System Startup, Shutdown, and Malfunction (SSM) Plan

Revision/Reviewed Date: 9/2/09

Any printed version of this file is UNCONTROLLED, and must be verified against the controlled copy at: http://intranet.mas.alcoa.com/emsol ution/areas/West

- Services & Electrode/Services West.htm before use, unless the words “CONTROLLED HARDCOPY” is printed on the top of the document. Page: 8 of 8 Revision /Review History

Date of Revision /Review Revision Description Reviewed/Approved by:

9/2/2009 Revised

– Appendix A editing Na than Rufa

12/3/2008 Reviewed

– No change Jordan Parent

10/27/2005 Reviewed

– No change Jordan Parent

10/6/1999 Revised CMS maintenance Jordan Parent

9/23/1999 Revision

– Added CMS maintenance Jordan Parent

4/22/1999 Original Jordan Parent

Con trolled Hardcopy Listing

Control Number Controlled Hard copy Owner/Location

1 B Courtyard