Green Mill Startup, Shutdown and Malfunction Plan Page 1 of 9

Alcoa – Mt. Holly

TV-0420-0015

Condition: Start-Up of Green Mill

To prevent excess or uncontrolled emissions from the Green Mill, this startup plan must be 

followed for all startups. In the event that a start-up of green anode processing equipment served 

by this emission control system creates or leads to a situation that causes operation outside of 

appropriate parametric ranges for process gas flow or coke flow, the following Start-Up plan 

must be re-initiated within one hour of first becoming aware of the situation.

A start-up is defined as the process of heating green anode mixing, green mix transfer and green 

anode forming equipment to a temperature above the softening point of the pitch binder to 

produce green anodes. The start-up begins when the emission control system is started. The 

start-up concludes when green anode production begins. Appropriate limits for parametric 

ranges during a start-up are those typical ranges that have previously been established for this 

emission control device. 

1. The Operator(s) is to assure that prior to Green Mill start-up that the emission control system 

is on line and operating within normal parametric limits.

2. In the event of operation outside of acceptable parametric limits, the Operator is to assure 

that the emission control system is still on line. If this is not the case, a shut down of green 

anode mixing, green mix transfer and green anode forming equipment is to be initiated.

3. The Start-Up concludes when production of green anodes begins.

4. The Start-Up is to be logged. Include the time, date, duration of event, extraordinary actions 

taken beyond the scope of this plan, and initials or clock number. Records of the start-up are 

to be retained for five (5) years.

Note: All revisions to this plan are to be retained for five (5) years from their date of issue.
Green Mill Startup, Shutdown and Malfunction Plan Page 2 of 9

Alcoa – Mt. Holly

TV-0420-0015

Condition: Shut-Down of Green Mill

To prevent excess or uncontrolled emissions from the Green Mill, this shutdown plan must be 

followed for all shutdowns. In the event that a shut-down of green anode processing equipment 

served by this emission control system creates or leads to a situation that causes operation 

outside of appropriate parametric ranges for process gas flow or coke flow, the following ShutDown plan must be re-initiated within one hour of first becoming aware of the situation.

A shut-down is defined as the process of intentional shut down of green anode mixing, mix 

transfer and green anode forming equipment and emission control equipment. The shut-down 

process include reductions in temperature below the softening point of the pitch binder. The 

shut-down begins when pitch flow to the mixer stops, ending the production of green anode 

paste. The shut-down concludes when the components of the system have cooled below the 

softening point temperature of the pitch binder, and the emission control device is shut down. 

Appropriate limits for parametric ranges during a shut-down are those typical ranges that have 

previously been established for this emission control device. 

1. In the event of operation outside of approved parametric limits the Operator is to assure that 

the emission control system is still on line. If this is not the case, the shut down of green 

anode; mixing, mix transfer, and forming equipment is to proceed immediately and efforts to 

re-start the emission control system are to be initiated.

2. The Shut-Down concludes when the components of the system have cooled below the 

softening point temperature of the pitch binder. The emission control system may be shut 

down after this has occurred.

3. The Shut-Down is to be logged. Include the time, date, duration of event, extraordinary 

actions taken beyond the scope of this plan, and initials or clock number signature. Records 

of the shut-down are to be retained for five (5) years.

Note: All revisions to this plan are to be retained for five (5) years from their date of issue.
Green Mill Startup, Shutdown and Malfunction Plan Page 3 of 9

Alcoa – Mt. Holly

TV-0420-0015

Condition: Low Flow of Process Gas (Loss of Fan Draft)

In the event of low flow of process gas (a.k.a.- low air flow) through this emission control 

system the following malfunction and corrective action plan must be initiated within one hour

of first becoming aware of a malfunction.

Examples of low flow conditions include, but are not limited to; unexpected loss of electrical 

power and reductions in flow due to unplanned outages that generates a fan draft-hours per day 

parametric that is below the established limit of 2.5" wg.

1. The operator is to confirm the system status, noting which system components are either off 

line or otherwise 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 to check the system 

status.

2. Following this initial response, the operator or proxy is to notify appropriate Maintenance 

and Environmental personnel and/or initiate a maintenance work order, or restart the unit(s).

3. Personnel responding to the malfunction 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 system operator or proxy will be responsible for logging the time, date, duration and 

cause of the malfunction, extraordinary actions taken beyond the scope of this plan, and 

initials or a signature. Maintenance personnel will be responsible for making appropriate 

entries into any maintenance logs.

5. Records of the malfunction and maintenance activity are to be retained for five (5) years. 

Should non-conformance with an applicable requirement occur, it is to be entered into the 

semi-annual reporting period log kept by the Environmental Department.

Note: All revisions to this plan are to be retained for five (5) years from their date of issue.
Green Mill Startup, Shutdown and Malfunction Plan Page 4 of 9

Alcoa – Mt. Holly

TV-0420-0015

Condition: Low Flow of Coke

In the event of low flow of coke through this emission control system the following malfunction 

and corrective action plan must be initiated within one hour of first becoming aware of a 

malfunction.

Examples of low flow conditions include, but are not limited to; unexpected failure of the 

primary feeder or one of its components or the primary blower that generates a rotary vane 

feeder-hours per day (RVF-Hr/Day) parametric that is below the established limit of 1.8 tons per 

hour.

1. The operator is to confirm the system status, verifying the no feed or reduced feed condition. 

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 to check the system status.

2. Following this initial response, the operator or proxy is to notify appropriate Maintenance 

and Environmental personnel and/or initiate a maintenance work order, or restart the unit(s). 

3. Personnel responding to the malfunction 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 system operator or proxy will be responsible for logging the time, date, duration and 

cause of the malfunction, extraordinary actions taken beyond the scope of this plan, and 

initials or a signature. Maintenance personnel will be responsible for making appropriate 

entries into any maintenance logs.

5. Records of the malfunction and maintenance activity are to be retained for five (5) years. 

Should non-conformance with an applicable requirement occur, it is to be entered into the 

semi-annual reporting period log kept by the Environmental Department.

Note: All revisions to this plan are to be retained for five (5) years from their date of issue.
Green Mill Startup, Shutdown and Malfunction Plan Page 5 of 9

Alcoa – Mt. Holly

TV-0420-0015

Condition: Loss of Parametric Monitoring - Fan Draft 

In the event of loss of fan draft signal for this emission control system the following malfunction 

and corrective action plan must be initiated within one hour of first becoming aware of a 

malfunction.

Examples of loss of signal include, but are not limited to; unexpected failure of the 

programmable logic controller, PLC, or remote monitoring system for more than six (6) hours in 

any twenty-four (24) hour period or loss of a measurement device component that results in a fan 

draft-hours per day parametric that is below the established limit of 2.5"wg.

1. The operator or technician is to confirm the system status, noting which PLC is off line or 

which compartments have suffered signal loss. 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 to check the system status.

2. Following this initial response, the operator or proxy is to notify appropriate Maintenance 

and Environmental personnel and/or initiate a maintenance work order, or restart the PLC.

3. Personnel responding to the malfunction 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 system operator or proxy will be responsible for logging the time, date, duration and 

cause of the malfunction, extraordinary actions taken beyond the scope of this plan, and 

initials or a signature. Maintenance personnel will be responsible for making appropriate 

entries into any maintenance logs.

5. Records of the malfunction and maintenance activity are to be retained for five (5) years. 

Should non-conformance with an applicable requirement occur, it is to be entered into the 

semi-annual reporting period log kept by the Environmental Department.

Note: All revisions to this plan are to be retained for five (5) years from their date of issue.
Green Mill Startup, Shutdown and Malfunction Plan Page 6 of 9

Alcoa – Mt. Holly

TV-0420-0015

Condition: Loss of Parametric Monitoring - Green Mill On/Off Status

In the event of loss of on/off signal(s) for the Green Mill the following malfunction and 

corrective action plan must be initiated within one hour of first becoming aware of a 

malfunction.

Examples of loss of signal include, but are not limited to; unexpected failure of the 

programmable logic controller, PLC or remote monitoring system for more than six (6) hours in 

any twenty-four (24) hour period or loss of a measurement device component that results in a 

loss of Green Mill start and stop times that is below the established limits.

1. The operator or technician is to confirm the system status, noting which PLC is off line or 

which compartments have suffered signal loss. 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 to check the system status.

2. Following this initial response, the operator or proxy is to notify appropriate Maintenance 

and Environmental personnel and/or initiate a maintenance work order, or restart the PLC.

3. Personnel responding to the malfunction 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 system operator or proxy will be responsible for logging the time, date, duration and 

cause of the malfunction, extraordinary actions taken beyond the scope of this plan, and 

initials or a signature. Maintenance personnel will be responsible for making appropriate 

entries into any maintenance logs.

5. Records of the malfunction and maintenance activity are to be retained for five (5) years. 

Should non-conformance with an applicable requirement occur, it is to be entered into the 

semi-annual reporting period log kept by the Environmental Department.

Note: All revisions to this plan are to be retained for five (5) years from their date of issue.
Green Mill Startup, Shutdown and Malfunction Plan Page 7 of 9

Alcoa – Mt. Holly

TV-0420-0015

Condition: Loss of Parametric Monitoring - Rotary Vane Feeder 

In the event of loss of rotary vane feeder, RVF, signal for this emission control system the 

following malfunction and corrective action plan must be initiated within one hour of first 

becoming aware of a malfunction.

Examples of loss of signal include, but are not limited to; unexpected failure of the 

programmable logic controller, PLC or remote monitoring station for more than six (6) hours in 

any twenty-four (24) hour period or loss of a measurement device component that results in a 

RVF-hours per day parametric that is below the established limit of 1.8 tons per hour.

1. The operator or technician is to confirm the system status, noting which PLC is off line or 

which compartments have suffered signal loss. 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 to check the system status.

2. Following this initial response, the operator or proxy is to notify appropriate Maintenance 

and Environmental personnel and/or initiate a maintenance work order, or restart the PLC.

3. Personnel responding to the malfunction 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 system operator or proxy will be responsible for logging the time, date, duration and 

cause of the malfunction, extraordinary actions taken beyond the scope of this plan, and 

initials or a signature. Maintenance personnel will be responsible for making appropriate 

entries into any maintenance logs.

5. Records of the malfunction and maintenance activity are to be retained for five (5) years. 

Should non-conformance with an applicable requirement occur, it is to be entered into the 

semi-annual reporting period log kept by the Environmental Department.

Note: All revisions to this plan are to be retained for five (5) years from their date of issue.
Green Mill Startup, Shutdown and Malfunction Plan Page 8 of 9

Alcoa – Mt. Holly

TV-0420-0015

Condition: Catastrophic Failure of Fume Control Equipment

In the event of catastrophic failure of emission control equipment or components in this emission 

control system the following malfunction and corrective action plan must be initiated within one 

hour of first becoming aware of a malfunction.

Examples of catastrophic failure include, but are not limited to; collapse of a unit or duct, a direct 

lightning strike, loss of electrical power, an earthquake, 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 or 

proxy is to confirm the system status, noting which components are either off line or 

otherwise 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 to check the system 

status.

2. Following this initial response, the operator or proxy is to notify appropriate Maintenance, 

Engineering, Environmental and support personnel.

3. Personnel responding to the malfunction 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 system operator or proxy will be responsible for logging the time, date, duration and 

cause of the malfunction, extraordinary actions taken beyond the scope of this plan, and 

initials or a signature. Maintenance personnel will be responsible for making appropriate 

entries into any maintenance logs.

5. Records of the malfunction and maintenance activity are to be retained for five (5) years. 

Should non-conformance with an applicable requirement occur, it is to be entered into the 

semi-annual reporting period log kept by the Environmental Department.

Note: All revisions to this plan are to be retained for five (5) years from their date of issue.
Green Mill Startup, Shutdown and Malfunction Plan Page 9 of 9

Alcoa – Mt. Holly

TV-0420-0015

Condition: Visible Emissions - Dusting Stack(s) 

In the event that emissions outside the normal operating range are visibly being emitted from the 

exhaust(s) of this emission control system the following malfunction and corrective action plan 

must be initiated within one hour of first becoming aware of a malfunction.

Examples of visible emissions or dusting stack(s) include, but are not limited to; continuous 

visible emissions noted by the Operator from the stack of the emission control device.

1. The operator is to report the dusting stack from any source including, but not limited to the 

daily visual checks made by the Emission Control Shift Technician. The operator is to log 

the time that the condition was first noticed or reported and also log the time at which he/she 

reported emissions or initiated this plan.

2. Following this initial response, the operator or proxy is to make arrangements to have the 

baghouse shut down to make repairs.

3. Personnel responding to the malfunction are to make repair(s) to remedy the situation in a 

safe, efficient, and timely manner.

4. The system operator or proxy will be responsible for logging the time, date, duration and 

cause of the malfunction, extraordinary actions taken beyond the scope of this plan, and 

initials or a signature in the visible emission log. Maintenance or Environmental personnel 

will be responsible for making appropriate entries into any maintenance logs.

5. Records of the event and maintenance activity are to be retained for five (5) years. Should 

non-conformance with an applicable requirement occur, it is to be entered into the semiannual reporting period log kept by the Environmental Department.

Note: All revisions to this plan are to be retained for five (5) years from their date of issue.