Massena East Potline Primary Emission Control System Startup, Shutdown, and Malfunction (SSM) Plan
R evision/Reviewed Date: 2

- 14

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Any printed version of this file is UNCONTROLLED, and must be verified against the controlled copy at: http://intranet.mas.alcoa.com/emsolution/areas/East Services & Electrode/Services East.htm before use, unless the words “CONTROLLED HARDCOPY” i s printed on the top of the document. Page: 1 of 15 

# a

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



## Alcoa Massena Operations East Plant

POTLINE PRIMARY EMISSION CONTROL SYSTEM Startup, Shutdown, and Malfunction Plan

Prepared by: Alcoa East Plant Massena, NY 13662

February 14 , 2011

– Added Potline Startup Work Practices December 3, 2008

– Reviewed

- No Changes November 30, 2005

– Reviewed

– No Changes November 25, 2002

– Revision 2

– Addition of Non

NESHAP Title V monitoring

December 31 2001

- Revision 1Massena East Potline Primary Emission Control System Startup, Shutdown, and Malfunction (SSM) Plan Revision/Reviewed Date: 1

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Any printed version of this file is UNCONTROLLED, and must be verified against the controlled copy at: http://intranet.mas.alcoa.com/emsolution/areas/East Services & Electrode/Services East.htm before use, unless the words “CONTROLLED HARDCOPY” is printed on the top of the document. Page: 2 of 15 

### Table of Contents

T ABLE OF CONTENTS

1.0 INTRODUCTION 3

2.0 STARTUP PLAN 3

3 .0 SHUTDOWN PLAN 4

4.0 CORR ECTIVE ACTION PLAN 5 4.1 Primary Aluminum NESHAP 4.1. A LOW AIR FLOW 4.1.B LOW ALUMINA FLOW 4.1.C MAINTENANCE OF CONTINUOUS MONITORING SYSTEM

4.2 Title V Requirements 4.2.A WET SCRUBBER pH OUTSIDE ACCEPTABLE RANGE 4.2.B WET SCRUBBER LIQUOR LEVEL OUTSIDE ACCEPTABLE RANGE 4.2.C MAINTENANCE OF CONTINUOUS MONITORING SYSTEM

5.0 MALFUNCTION PLAN 9 5.1 LOSS OF POTLINE POWER FOR AN EXTENDED PERIOD 5.2 CATASTROPHIC FAI LURE OF FUME CONTROL EQUIPMENT

6.0 VISI BLE EMISSIONS PLAN 10

7.0 PLANNED M AINTENACE SHUTDOWNS 11

APPENDIX A 12Massena East Potline Primary Emission Control System Startup, Shutdown, and Malfunction (SSM) Plan
R evision/Reviewed Date: 2

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Any printed version of this file is UNCONTROLLED, and must be verified against the controlled copy at: http://intranet.mas.alcoa.com/emsolution/areas/East Services & Electrode/Services East.htm before use, unless the words “CONTROLLED HARDCOPY” i s printed on the top of the document. Page: 3 of 15 

### FTC Startup, Shutdown, and Malfunction Plan

1

. 0 Introduction

Primary Aluminum NESHAP The Alcoa East Plant in Massena, New York, operates an alumina injectio n dry scrubbing facility designed for the control of potroom emissions. The overall dry scrubbing facility consists of three similar dry scrubbing systems running in parallel, which respectively treat the emissions from each of the three potlines. Each d ry scrubber contains eight VRI/baghouse modules running in parallel. After treatment in the dry scrubbers, the exhaust air from each control device is subsequently joined together into a common plenum and distributed into two wet scrubbers and associated outlet stacks. This facility is subject to the U.S. Environmental Protection Agency’s Primary Aluminum Maximum Achievable Control Technology (MACT) Standard

– 40 CFR 63, Subpart LL.

This Startup, Shutdown, and Malfunction Plan meets the requirements of P rimary Aluminum NESHAP. This plan contains procedures to be used during startup, shutdown and malfunction as well as procedures for corrective action. This plan will be made available to the permitting authority upon request.

Title V (Non

- NESHAP) Wet Sc rubber This plan will also address the non

- NESHAP Title V requirements for wet scrubber malfunctions and corrective actions. These procedures for proper wet scrubber operations are added to this document for convenience only, and the addition of these pr ocedures does not imply that these actions are necessary to ensure compliance with the Primary Aluminum NESHAP. The wet scrubber procedures have been included in this plan so that all of the requirements for malfunctions and corrective actions of the potroom control devic es are contained in a single document.



### 2

. 0 Startup Plan

A startup or re

- start is defined as the process of re

- energizing an idled section(s) of aluminum reduction cells that is serviced by a common dry scrubber. A section of reduction cells is defined as the group of 21 pots vented through a common wall duct. For example, each dry scrubber treats the emissions from 8 sections of reduction cells. The startup or re

- start 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 pots scheduled for startup or re

- start has had liquid bath added to it.

The following plan is to be followed for the startup or re

- start of any portion of the potline serviced by the emission control device. If the plan is followed, the semi annual report will note the fact. If the plan was not followed, the event is to be reported within 2 days, a notification letter posted within 7 days, and revisions to this plan submitted within 45 days. Revisions to t his plan must be retained for 5 years. If compliance has not been determined, determination willMassena East Potline Primary Emission Control System Startup, Shutdown, and Malfunction (SSM) Plan Revision/Reviewed Date: 1

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Any printed version of this file is UNCONTROLLED, and must be verified against the controlled copy at: http://intranet.mas.alcoa.com/emsolution/areas/East Services & Electrode/Services East.htm before use, unless the words “CONTROLLED HARDCOPY” is printed on the top of the document. Page: 4 of 15 begin within 180 days after the completion of the startup or re

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

- start if appropriate parameters do not already exist

.

1

. It is the responsibility of the “Potline Start

- up Coordinator” to implement the Potline Start

- up Procedure (Appendix A of this plan). It is the responsibility of the “S ervices Lead Supervisor” to implement the start

- up portion of the plan related to the Fume Treatment Center.
2

. The Operator is to assure that prior to adding liquid bath to the first pot that the inlet plenum static pressure meets the parametric limit for c ompliance. In the event of re

- activating an idled baghouse, the Operator is responsible for starting alumina flow and air flow to this compartment. 3

. The Operator is responsible for logging the startup in the SSM log.
4

. Records of the startup are to be retain ed for 5 years.



### 3.0 Shutdown Plan

A shutdown is defined as the process of having the liquid contents of bath and aluminum solidify for all, or any number, of the sections of aluminum reduction cells that are serviced by a common dry scrubber. A section of reduction cells is defined as the group of 21 pots vented through a common wall duct. 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

power. The shutdown concludes 48 hours after the electrical power has been discontinued.

The following plan is to be followed for the shutdown of the portion of a potline served by the emission control device. If this plan is followed, the semiannual report w ill note the fact. If this plan was not followed, the event is to be reported within 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.

In the eve nt of a shutdown of either an entire potline, or a 21 pot section of a potline serviced by a common dry scrubber, the scrubber process will be modified to accommodate the reduced demand and maintain the 24

- hour averaged inlet plenum static pressure (ISP) a bove its parametric limit. System modifications include, but are not limited to, any combination of the following; decrease fan amperage (controlled by the ISP set

- point), decrease the number of fans in operation if necessary, and decrease the number of o perating baghouse modules if necessary.

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 make modifications to the process (outlined above) following the 4 8 hour period and verification that the idled reduction cells have been isolated from the common ventilation duct. For example, reduce fan amperage in order to operate at the desired inlet plenum static pressure. 3

. The Operator is responsible for logging th e shutdown in the SSM log.Massena East Potline Primary Emission Control System Startup, Shutdown, and Malfunction (SSM) Plan Revision/Reviewed Date: 1

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Any printed version of this file is UNCONTROLLED, and must be verified against the controlled copy at: http://intranet.mas.alcoa.com/emsolution/areas/East Services & Electrode/Services East.htm before use, unless the words “CONTROLLED HARDCOPY” is printed on the top of the document. Page: 5 of 15 4

. Records of the shutdown are to be retained for 5 years.



### 4.0 Corrective Action Plan

4.1 Primary Aluminum NESHAP

4.1.A Low Air Flow

The inlet plenum static pressure (ISP) is the surrogate parameter used to control and monitor the air flow rates through each of the three dry scrubbers. Therefore, low air flow is defined as an inlet plenum static pressure lower then the parametric limit . It is determined by comparing the average ISP for each dry scrubber, over a 24

- hour period, to their respective limits for compliance. Failure of the parameter to meet the limit for compliance is termed an exceedance. The following corrective action p lan must be initiated within 1 hour of first becoming aware of the exceedence. The 7 th exceedence on any one dry scrubber during the semi annual reporting period will result in a violation. Both exceedences and violations must be reported on the semi

ann ual report.

Examples of low air flow conditions include, but are not limited to; unplanned fan outages or baghouse module failures that cause the ISP to fall below the limit of compliance.

1

. The Operator is to log the time that he/she first became aware of the exceedence and the time at which he/she initiated the corrective action plan.
2

. The Operator is to confirm the system status, noting which fans or baghouse modules are either offline or impaired. 3

. The Operator is to notify the appropriate maintenance per sonnel or re

- start the off

- line equipment.
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 exceedence in the SSM log. This must include logging the time, date, duration, cause of the exceedence, and any actions taken beyond the scope of this plan, including initials or signature.
6

. Maintenance personnel are responsible for making appropriate entries into main tenance logs.
7

. Records of the exceedence are to be retained for 5 years.

4.1.B Low Alumina Flow

Low alumina flow is defined as an alumina flow rate lower then the parametric limit. It is determined by comparison of the average alumina flow rate for each dry scrubber, over a 24

- hour period, to their respective limits for compliance. Failure of the parameter to meet the limit for compliance is termed an exceedence. The following corrective action plan must be initiated within 1 hour of becoming aware of t he exceedence. Failure to do so will result in a violation. The 7 th exceedence for any one dry scrubber during the semi annual reporting period will result in a violation. Both exceedences and violations must be reported on the semi annual report.Massena East Potline Primary Emission Control System Startup, Shutdown, and Malfunction (SSM) Plan Revision/Reviewed Date: 1

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Any printed version of this file is UNCONTROLLED, and must be verified against the controlled copy at: http://intranet.mas.alcoa.com/emsolution/areas/East Services & Electrode/Services East.htm before use, unless the words “CONTROLLED HARDCOPY” is printed on the top of the document. Page: 6 of 15 Exam ples of low alumina flow conditions include, but are not limited to; loss of electrical power, unexpected failures of air slides or alumina volumetric feeders, plugging of the distribution box, and unexpected failures of equipment associated with the Dense Phase conveying system.

1

. The Operator is to log the time that he/she first became aware of the exceedence and the time at which he/she initiated the corrective action plan.
2

. The Operator is to confirm the system status, noting which process equipment is of fline or otherwise impaired. 3

. The Operator is to notify the appropriate maintenance personnel or re

- start the off

- line equipment.
4

. Personnel responding are to make repair(s), equipment replacement(s), or process change(s) to remedy the situation in a safe, e fficient, and timely manner. 5

. The Operator is responsible for logging the exceedence in the SSM log. This must include logging the time, date, duration, cause of the exceedence, and any actions taken beyond the scope of this plan, including initials or sig nature. 6

. Maintenance personnel are responsible for making appropriate entries into maintenance logs.
7

. Records of the exceedence are to be retained for 5 years

4.1.C Maintenance of Continuous Monitoring System

The following instrumentation or components are required for the continuous parametric monitoring of both air flow and alumina flow through each dry scrubber;

 Alumina Flow

- Alumina Volumetric Feeder (ton/hr)

 Air Flow

- Inlet Plenum Static Pressure Transduce r

- Inlet Plenum Temperature Transmitter

- Inlet Plenum Temperature T/C

Predictable malfunctions would also include, but are not limited to; power interruptions, PLC or PC malfunctions, and PLC/PC communication problems. Malfunctions noted in section 5.2

- Catastrophic Failure of the Fume Control Equipment

– may also result in a loss of the continuous 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 the fact. If this plan was not followed, the event is to be reported within 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.Massena East Potline Primary Emission Control System Startup, Shutdown, and Malfunction (SSM) Plan Revision/Reviewed Date: 1

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Any printed version of this file is UNCONTROLLED, and must be verified against the controlled copy at: http://intranet.mas.alcoa.com/emsolution/areas/East Services & Electrode/Services East.htm before use, unless the words “CONTROLLED HARDCOPY” is printed on the top of the document. Page: 7 of 15 1

. The Operator is to log the time that he/she first became aware of a problem with the continuous monitoring system and the time at which he/she initiated the corrected action plan.
2

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

- li ne or otherwise impaired. 3

. The Operator is to notify appropriate maintenance personnel or re

- start the components.
4

. Personnel responding are to make repair(s), equipment replacement(s), or process change(s) to remedy the situation in a safe, efficient, and t imely manner. 5

. The Operator is responsible logging the repair in the SSM log. This will include logging the time, date, duration, cause of the problem, and actions taken beyond the scope of this plan, including initials or signature.
6

. Records of repair to the continuous monitoring system must be retained for 5 years.

4.2 Title V Requirements

4.2.A Wet Scrubber pH outside acceptable range (Title V only)

If the measured pH is outside its acceptable range over a 24

- hour period, the following corrective actions should be taken.

Examples of conditions that can lead to pH being outside of its acceptable range include, but are not limited to; loss of electrica l power, conductivity probe malfunction, pH probe not reading correctly, loss of reagent flow

1

. The Operator is to log the time that he/she first became aware of the exceedence and the time at which he/she initiated the corrective action plan.
2

. The Operator is to confirm the system status, noting which process equipment is offline or otherwise impaired. 3

. The Operator is to notify the appropriate maintenance personnel or re

- start the off

- line equipment.
4

. Personnel responding are to make repair(s), equipment repl acement(s), or process change(s) to remedy the situation in a safe, efficient, and timely manner. 5

. The Operator is responsible for logging the exceedence in the SSM log. This must include logging the time, date, duration, cause of the exceedence, and any a ctions taken beyond the scope of this plan, including initials or signature.
6

. Maintenance personnel are responsible for making appropriate entries into maintenance logs.
7

. Records of the exceedence are to be retained for 5 years

4.2.B Wet Scrubber Liquor Lev el outside acceptable range (Title V only)

If the measured liquor level is outside its acceptable range over a 24

- hour period, the following corrective actions should be taken.Massena East Potline Primary Emission Control System Startup, Shutdown, and Malfunction (SSM) Plan Revision/Reviewed Date: 1

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Any printed version of this file is UNCONTROLLED, and must be verified against the controlled copy at: http://intranet.mas.alcoa.com/emsolution/areas/East Services & Electrode/Services East.htm before use, unless the words “CONTROLLED HARDCOPY” is printed on the top of the document. Page: 8 of 15 Examples of conditions that can lead to the liquor level being outside of its acceptable range include, but are not limited to; loss of electrical power, loss of make

- up water, loss of recirculation pumps,

1

. The Operator is to log the time that he/she first became aware of the exceedence and the time at which he/she initiated the c orrective action plan.
2

. The Operator is to confirm the system status, noting which process equipment is offline or otherwise impaired. 3

. The Operator is to notify the appropriate maintenance personnel or re

- start the off

- line equipment.
4

. Personnel responding a re 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 exceedence in the SSM log. This must include logging the time, date, duration , cause of the exceedence, and any actions taken beyond the scope of this plan, including initials or signature.
6

. Maintenance personnel are responsible for making appropriate entries into maintenance logs.
7

. Records of the exceedence are to be retained for 5 years

4.2.C Maintenance of Continuous Monitoring System The following instrumentation or components are required for the continuous parametric monitoring of both pH and liquor level through each wet scrubber;

 pH value

- pH probe

 Liquor level

- Level detection

Predictable malfunctions would also include, but are not limited to; power interruptions, PLC or PC malfunctions, and PLC/PC communication problems. Malfunctions noted in section 5.2

- Catastrophic Failure of the Fume Control Equipment

– may a lso result in a loss of the continuous 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 the fact. If this plan was not followed, the event is to be reported within 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 Operator is to log the time that he/she first became aware of a pro blem with the continuous monitoring system and the time at which he/she initiated the corrected action plan.
2

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

line or otherwise impaired.Massena East Potline Primary Emission Control System Startup, Shutdown, and Malfunction (SSM) Plan Revision/Reviewed Date: 1

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Any printed version of this file is UNCONTROLLED, and must be verified against the controlled copy at: http://intranet.mas.alcoa.com/emsolution/areas/East Services & Electrode/Services East.htm before use, unless the words “CONTROLLED HARDCOPY” is printed on the top of the document. Page: 9 of 15 3

. The Operator is to notify approp riate maintenance personnel or re

- start the components.
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 logging the rep air in the SSM log. This will include logging the time, date, duration, cause of the problem, and actions taken beyond the scope of this plan, including initials or signature.
6

. Records of repair to the continuous monitoring system must be retained for 5 ye ars.



### 5.0 Malfunction Plan

5.1 Loss of Potline Power for an Extended Period

A malfunction may cause one or more potline to be de

- energized for an extended period of time. In this situation, the dry scrubber servicing the effected potline may be shut down to conserve heat in the reduction cells. The following plan is to be followed for the idling of a dry scrubber under this condition. If this plan is followed, the semi annual report will note the fact. If this plan is not followed, the event is to be reported within 2 days, and a notification letter posted within 7 days. Should revisions to this plan be 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 dry scrubber to the FTC Supervisor, the Operator will stop the fans and alumina flow to the fume control device.
2

. The Operator is responsible to begin startup of the idled dry scrubber in a safe, efficient, and timely manner following the re

- energizati on of the potline it services. 3

. Normal operation is to be attained as soon as possible following the startup of the dry scrubber.
4

. The Operator is responsible for logging the malfunction in the SSM log. This will include logging the time, date, duration, ca use of the malfunction, and any actions taken beyond the scope of this plan, including initials or signature. 5

. Records of the malfunction are to be retained for 5 years.

5.2 Catastrophic Failure of Fume Control Equipment

A catastrophic failure of the fume control equipment is considered a malfunction. The following plan is to be followed in the event of a catastrophic failure. If this plan is followed, the semi annual report will note the fact. If this plan was not followed, the event is to be reported within 2 days, and a notification letter posted within 7 days. Should revisions to this plan be necessary, they must be submitted within 45 days of the event. Revisions to this plan must be retained for 5

years.

Examples of catastrophic failures to the fume control equipment include, but are not limited to, a collapsed portion of inlet duct, a direct lightning strike, a loss of electrical power, an earthquake, a tornado, or a system fire which results in uncontrolled emissions.Massena East Potline Primary Emission Control System Startup, Shutdown, and Malfunction (SSM) Plan Revision/Reviewed Date: 1

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Any printed version of this file is UNCONTROLLED, and must be verified against the controlled copy at: http://intranet.mas.alcoa.com/emsolution/areas/East Services & Electrode/Services East.htm before use, unless the words “CONTROLLED HARDCOPY” is printed on the top of the document. Page: 10 of 15 1

. As soon as the situation has become stable and hazards cleared, the Operator is to access the system status, noting which dry scrubber is either offline or otherwise impaired.
2

. The Operator is to log the time that he/she first became aware of, or reported, the condition and also log the time he/she began to respond. 3

. The Operator is to notify appropriate maintenance, engineering or other support personnel.
4

. Personnel responding are to make repair(s), equipment replacement(s), or process change(s) to remedy the situation in a safe, e fficient, and timely manner. 5

. The Operator is responsible for logging the malfunction in the SSM log. This will include logging the time, date, duration, cause of the malfunction, and any actions taken beyond the scope of this plan, including initials or s ignature.
6

. Maintenance personnel are responsible for making appropriate entries into any maintenance logs.
7

. Records of the malfunction are to be retained for 5 years.



### 6.0 Visible Emission Plan

The scrubbed gas from each of the three dry scrubbing systems i s combined in a common outlet plenum and exhausted to the atmosphere through two wet scrubber stacks in parallel. The primary role of the wet scrubbers is the removal of sulfur dioxide present in pot fumes, however some residual gaseous fluoride (HF) and particulate will also be removed. As a result, under normal operating conditions of the wet scrubbers, a leaking baghouse module(s) will not result in stack dusting or visible emissions.

Visible emissions, defined as stack dusting, indicate filter bag problems in the upstream baghouse modules in conjunction with the abnormal operation of the wet scrubber. In addition, visible emissions may result in the event of scrubber liquor blowing ou t the stack, resulting in a condition referred to as “white rain”. Wet scrubber operating conditions that may result in visible emissions include, but are not limited to; low or no liquor flow, excessive air flow through the stack, and scaling of the mist reducer blinds. The following visible emission plan must be initiated within 1 hour of noticing visible emissions. Failure to initiate this plan within an hour will result in a violation. Violations must be reported on the semi annual report.

1

. The Oper ator is to report the visible emission condition from any source including, but not limited to, the daily visual inspections made by the Operator.
2

. The Operator is to log the time that he/she first noticed, or was notified of the condition and log the time he/she initiated this plan. 3

. The Operator is to make appropriate process modifications in order to make repairs and remedy the wet scrubber operating conditions, or notify support personnel.
4

. Personnel responding are to make repair(s) and remedy the situatio n in a safe, efficient, and timely manner. 5

. The Operator is responsible for logging the corrective action in the SSM log. This will include logging the time, date, duration, any actions taken beyond the scope of this plan, including initials or signature.Massena East Potline Primary Emission Control System Startup, Shutdown, and Malfunction (SSM) Plan Revision/Reviewed Date: 1

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Any printed version of this file is UNCONTROLLED, and must be verified against the controlled copy at: http://intranet.mas.alcoa.com/emsolution/areas/East Services & Electrode/Services East.htm before use, unless the words “CONTROLLED HARDCOPY” is printed on the top of the document. Page: 11 of 15 6

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

7

. Records of the visible emissions are to be retained for 5 year



### 7.0 Planned Maintenance Shutdowns

The following procedure will be followed in the event that on e or more of the Potroom Fume Control Systems needs to be shutdown completely to safely perform required maintenance. This situation would result in no pot exhaust for the potline(s) allowing uncontrolled emissions out the potroom roof.

1

. All engineering a nd maintenance alternatives will be explored prior to a decision to take a planned shutdown.
2

. Environmental Control will be notified as far in advance (minimum two weeks) to allow communication with regulatory authorities. 3

. The maintenance will be planned in such a manner to allow the work to be safely conducted in a minimum amount of time.

In the event of an emergency unplanned event that requires a shutdown, the Environmental Control Department will be notified immediately.Massena East Potline Primary Emission Control System Startup, Shutdown, and Malfunction (SSM) Plan Revision/Reviewed Date: 1

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Any printed version of this file is UNCONTROLLED, and must be verified against the controlled copy at: http://intranet.mas.alcoa.com/emsolution/areas/East Services & Electrode/Services East.htm before use, unless the words “CONTROLLED HARDCOPY” is printed on the top of the document. Page: 12 of 15 

## APPENDIX A

– POTLINE STARTUP PROCEDURE

A

. General Comments:

a

. Reynolds will assign a pot line start

- up coordinator.

b

. Training on emission control procedures will be completed prior to start

- up for all personnel involved in pot line start

- up.

c

. Primary MACT start

- up, shutdown, malfunction plan will be followed.

d

. The projected schedule for pot line start

- up is attached as Exhibit “A.” Start

- up of pot lines will occur sequentially. Individual pot start

- up rates will be dictated by
available bath. The schedule is subject to change as conditions dictate.

i

. Records will be kept of the total pots started each day.

B

. Fume Treatment Center Operation

a

. Required pot line scrubbing capacity will be started prior to pot line energization.

i

. No more than 21 pots w ill be operated per each baghouse, until at least seven baghouses in a single dry scrubber system are operational. Each dry scrubber system can draw the minimum airflow for an entire potline with seven baghouses operational.

ii

. Minimum airflows per cell for proper ventilation will be maintained using
available data.

1

. Pot line ductwork is equipped with eight fire dampers each controlling a leg of 21 pots. They will initially be closed then opened as each leg has operating pots.

2

. As fire dampers are opened addi tional baghouses and/or fans will
be activated to ensure adequate pot ventilation throughout the startup period.

3

. Wet Scrubbing for SO 2 removal will commence when a sufficient airflow for scrubbing is achieved through a single wet scrubbing
tower. Once the first wet scrubbing tower is online, SO 2 scrubbing will continue throughout the remainder of the potline startup

process.Massena East Potline Primary Emission Control System Startup, Shutdown, and Malfunction (SSM) Plan Revision/Reviewed Date: 1

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Any printed version of this file is UNCONTROLLED, and must be verified against the controlled copy at: http://intranet.mas.alcoa.com/emsolution/areas/East Services & Electrode/Services East.htm before use, unless the words “CONTROLLED HARDCOPY” is printed on the top of the document. Page: 13 of 15 iii

. The parametric limit for alumina flow will be met on a prorated basis based on the number of baghouses in service, for example, 4.5 tons of alumina/hour per 8 baghouses x 2 baghouses = 1.125 tons of alumina/hour for two baghouses.

1

. Alumina feed will be monitored continuously at the fume treatment center for each potline.

iv

. The minimum Inlet static pressure for each potline will be met th roughout

start

- up.

1

. Inlet static pressure will be monitored continuously at the fume treatment center for each potline.

b

. Observations for visible emissions will be made and recorded daily for fume
control stacks.

C

. Pot Operation

a

. Prior to energizing a pot the following activities will be performed.

i

. Inspection of the pot superstructure will be conducted to identify gaps around pot side and end doors, identify any holes or gaps in ductwork, and repairs will be made as required.

ii

. All p ot door mechanisms will be inspected and repaired as needed to assure proper operation.

b

. The general pot line start

- up procedure will be as follows.

i

. Most pots will start up with used cathodes with the metal pad intact. All
solid bath will be removed and th e cell will be preheated with propane
torches for at least 4

- 6 hours. A small amount of molten metal will be added to ensure good electrical contact and then the pot is energized.

ii

. Approximately six days is required to melt the solid aluminum and approach a target temperature of 900 o C.

iii

. The initial pots being started will not have liquid bath available for a pull

up of the anode. Therefore, solid bath will be melted in these pots for approximately 3

- 4 additional days. When available, molten bath is “tapped” from these pots and poured into a pot being started. The anode isMassena East Potline Primary Emission Control System Startup, Shutdown, and Malfunction (SSM) Plan Revision/Reviewed Date: 1

- 27

- 11

Any printed version of this file is UNCONTROLLED, and must be verified against the controlled copy at: http://intranet.mas.alcoa.com/emsolution/areas/East Services & Electrode/Services East.htm before use, unless the words “CONTROLLED HARDCOPY” is printed on the top of the document. Page: 14 of 15 then raised off the metal pad forcing the current through the bath as in a normally operating pot. Solid bath is added and voltage is increased to generate more liquid bath in the recently started pot.

iv

. During start

- up, pots will often become unstable and “hot” >980 o C due to difficulties maintaining critical bath chemistry parameters while melting

a nd tapping bath. Unstable and hot pots will have higher emissions than stable pots due to exposed liquid bath, higher vapor pressures, higher voltages and the need to perform necessary work activities to return it to
normal conditions. Guidelines have be en developed to assist potroom supervisors and operators to methodically address pot instability and return them to normal operation as soon as possible. The guidelines are generally;

1

. Adjusting cell voltage

2

. Adjusting alumina feeding

3

. Monitoring and adjus ting anode current

4

. Monitoring and adjusting liquid level

5

. Reduce temperature by adding solid or liquid bath or metal

c

. Following the energizing of a pot the following activities will be performed.

i

. Pot doors will be closed on all operating pots except when per forming necessary work activities.

ii

. Malfunctioning or damaged pot door mechanisms will be reported to maintenance and repaired promptly.

iii

. Procedures for normal operation will be in place during startup:

1

. Pot door policy

2

. Paste briquette addition

3

. Fume control system operation

4

. Tapping

5

. Pot cut

- outsMassena East Potline Primary Emission Control System Startup, Shutdown, and Malfunction (SSM) Plan Revision/Reviewed Date: 1

- 27

- 11

Any printed version of this file is UNCONTROLLED, and must be verified against the controlled copy at: http://intranet.mas.alcoa.com/emsolution/areas/East Services & Electrode/Services East.htm before use, unless the words “CONTROLLED HARDCOPY” is printed on the top of the document. Page: 15 of 15 iv

. Pot rooms will be swept with a mobile sweeper on a minimum schedule of three times per day.

d

. Compliance demonstrations using approved methods will begin within 180 days
of start

- up for roof monitors.

SSM Plan Revision History

Date of Revision Revision Description Reviewed/Approved by:

2

- 14

- 11 Revised to incorporate Potline Start

- up Procedure Jordan Parent
12

- 3

- 08 Reviewed

– No Changes Jordan Parent
11/30/05 Reviewed

– No Changes Jordan Parent
11/25/02 Addition of Non

- NESHAP Title V monitoring Jordan Parent
12/31/01 Revision Jordan Parent
3/21/01 Original Jordan Parent